ML063260007

DG-1170 Redline/Strikeout Version (Enclosure 4)

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DG-1170
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This regulatory guide is being issued in draft form to involve the public in the early stages of the development of a regulatory positionin this area. It has not received staff review or approval and does not represent an official NRC staff position.Public comments are being solicited on this draft guide (including any implementation schedule) and its associated regulatoryanalysis or value/impact statement. Comments should be accompanied by appropriate supporting data. Written comments may be submitted to the Rules and Directives Branch, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. Comments may be submitted electronically through the NRC's interactive rulemaking Web page at http://www.nrc.gov/what-we-do/regulatory/rulemaking.html. Copies of comments received may be examined at the NRC'sPublic Document Room, 11555 Rockville Pike, Rockville, MD. Comments will be most helpful if received by December 24, 2006

.Requests for single copies of draft or active regulatory guides (which may be reproduced) or placement on an automatic distribution listfor single copies of future draft guides in specific divisions should be made to the U.S. Nuclear Regulatory Commission, Washington, DC 20555, Attention: Reproduction and Distribution Services Section, or by fax to (301)415-2289; or by email to Distribution@nrc.gov. Electronic copies of this draft regulatory guide are available through the NRC's interactive rulemakingWeb page (see above); the NRC's public Web site under Draft Regulatory Guides in the Regulatory Guides document collection of the NRC's Electronic Reading Room at http://www.nrc.gov/reading-rm/doc-collections/; and the NRC's Agencywide DocumentsAccess and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under Accession No. ML063100359.

U.S. NUCLEAR REGULATORY COMMISSION April November 200 1 6REGULATORY GUIDE l OFFICE OF NUCLEAR REGULATORY RESEARCH Division 1 ll DRAFT REGULATORY GUIDE lContact: R.F. Radlinski l(301) 415-3174 llDRAFT REGULATORY GUIDE 1.189l(Draft was issued as DG-1097)FIRE PROTECTION FOR OPERATING DG-1170l(Proposed Revision 1 of Regulatory Guide 1.189, dated April 2001) llFIRE PROTECTION lFOR NUCLEAR POWER PLANTS l

AVAILABILITY INFORMATIONSingle copies of regulatory guides, both active and draft, and draftNUREG documents may be obtained free of charge by writing theReproduction and Distribution Services Section, OCIO, USNRC,Washington, DC 20555-0001, or by email to<DISTRIBUTION@NRC.GOV>, or by fax to (301)415-2289. Activeguides may also be purchased from the National Techni cal InformationService on a standing order basis. Details on this service may beobtained by writing NTIS, 5285 Port Royal Road, Springfield, VA 22161. Many NRC documents are available electronically in our ReferenceLibrary on our web site, <WWW.NRC.GOV>, and through ourElectronic Reading Room (ADAMS, or PARS, document system) at thesame site. Copies of active and draft guides and many other NRCdocuments are available for inspection or copying for a fee from the NRC Public Document Room at 11555 Rockville Pike, Rockville, MD;the PDR's mailing address is USNRC PDR, Washington, DC 20555;telephone (301)415-4737 or (800)397-4209; fax (301)415-3548; email is<PDR@NRC.GOV>.Copies of NUREG-series reports are available at current rates from theU.S. Government Prin ting Office, P.O. Bo x 37082, Washington, DC20402-9328 (telephone (202)512-1800); or from the National TechnicalInformation Service by writing NTIS at 5285 Port Royal Road,Springfield, VA 22161; or telephone (703)487-4650; or on the internet at<http://www.ntis.gov/ordernow> . Copies are available for inspectionor copying for a fee from the NRC Public Document Room at 11555Rockville Pike, Rockville, MD; the PDR's mailing address is USNRCPDR, Washington, DC 20555; telephone (301)415-4737 or (800)397-4209; fax (301)415-3548; email is <PDR@NRC.GOV>.TABLE OF CONTENTSA.INTRODUCTION1B.DISCUSSION2BACKGROUND2 REGULATORY REQUIREMENTS6LICENSING AND DESIGN BASIS9 FIRE PROTECTION PROGRAM GOALS/OBJECTIVES11C. REGULATORY POSITION14 1.FIRE PROTECTION PROGRAM14 1.1Organization, Staffi ng, and Responsibilities151.2Fire Hazards Analysis 171.3Safe Shutdown Analysis 20 1.4Fire Test Reports and Fire Data 211.5Compensatory Measures 21 1.6Fire Protection Training and Qualifications221.7Quality Assurance25 1.8Fire Protection Program Changes/Code Deviations32 2.FIRE PREVENTION39 2.1Control of Combustibles39 2.2Control of Ignition Sources42 2.3Housekeeping432.4Fire Protection System Maintenance and Impairments43 3.FIRE DETECTION AND SUPPRESSION44 3.1Fire Detection (Design Objectives and Performance Criteria)443.2Fire Protection Water Supply Systems (Design Objectives and Performance Criteria)463.3Automatic Suppression Systems (Design Objectives and Performance Criteria)493.4Manual Suppression Systems and Equipment523.5Manual Firefighting Capabilities534.BUILDING DESIGN/PASSIVE FEATURES58 4.1General Building and Building System Design584.2Passive Fire Resistive Features68 4.3Testing and Qualifi cation of Electrical Raceway Fire BarrierSystems745.SAFE SHUTDOWN CAPABILITY835.1Safe Shutdown Performance Goals for Redundant Systems845.2Alternative or Dedicated Shutdown Design and Performance Goals 845.3Hot Standby (PWR) Hot Shutdown (BWR) Systems andInstrumentation855.4Cold Shutdown Systems and Instrumentation and Allowable Repairs875.5Fire Protection of Safe Shutdown Capability88 5.6 Alternative, Dedicated, or Backup Shutdown Capability93 5.7Post-Fire Safe Shutdown Procedures956.FIRE PROTECTION FOR AREAS IMPORTANT TO SAFETY966.1Areas Related to Power Operation966.2Other Areas1027.PROTECTION OF SPECIAL FIRE HAZARDS EXPOSING AREAS IMPORTANT TO SAFETY104 7.1Reactor Coolant Pu mp Oil Collection1047.2Turbine/Generator Building105 7.3Station Tr ansformers1057.4Diesel Fuel Oil Storage Areas106 7.5Flammable Gas Storage and Distribution106D. IMPLEMENTATION107GLOSSARY108 REFERENCES113APPENDIX A: EQUIVALENCY122REGULATORY ANALYSIS124BACKFIT ANALYSIS 124A. INTRODUCTION llA. INTRODUCTION l

lThe primary objectives of fire protection programs (FPPs) at U.S. nuclear plants are to minimize both lthe probability of occurrence and the consequences of fire. To meet these objectives, the fire protection programs FPPs for operating nuclear power plants are designed to provide reasonable assurance, through ldefense -in -depth, that a fire will not prevent the performance of necessary safe

-shutdown functions

, andlthat radioactive releases to the environment in the event of a fire will be minimized.

lThe NRC's regulatory framework that the U.S. Nuclear Regulatory Commission (NRC) has lestablished for nuclear plant fire protection programs is FPPs consists of a number of regulations and lsupporting guidelines, including, but not limited to, General Design Criterion 3 (GDC 3), 10 CFR 50.48, Appendix R) 3, "Fire Protection," as set forth in Appendix A, "General Design Criteria for Nuclear Power lPlants," to Title 10, Part 50, "Domestic Licensing of Production and Utilization Facilities," of the Code oflFederal Regulations (10 CFR Part 50); 10 CFR 50.48, "Fire Protection"; Appendix R, "Fire Protection lProgram for Nuclear Power Facilities Operating Prior to January 1, 1979,"

to 10 CFR Part 50

,; regulatory lguides ,; generic communications

([e.g., G g eneric Letters, Bulletins, and Information Notices), NUREG lreports, the Standard letters (GLs), regulatory issue summaries (RISs), bulletins, and information notices l(INs)]; NUREG-series reports, including NUREG-0800, "Standard Review Plan (NUREG-0800) and lassociated Branch Technical Positions,for the Review of Safety Analysis Reports for Nuclear Power lPlants" (NUREG-0800 or SRP);

and industry standards. Since all of the fire protection regulations l

DG-1170, Page 6 promulgated by the NRC are do not applicable apply to all plants, they have this guide does not beenlcharacterized categorize them as regulations in this guide. Licensees should refer to their plant-specific llicensing bases to determine the applicability of a specific regulation to a specific plant.

lThis draft regulatory guide is organized as shown on the following pages.

lPagellA.INTRODUCTION

....................................................................

1l lB.DISCUSSION

.......................................................................

5lBackground

.........................................................................

5lRegulatory Requirements

..............................................................

10lLicensing and Design Basis

............................................................

12lFire Protection Program Goals and Objectives

.............................................

16l lC.REGULATORY POSITION

...........................................................

20l l1.FIRE PROTECTION PROGRAM

...............................................

20l1.1 Organization, Staffing, and Responsibilities

.................................

20l1.2 Fire Hazards Analysis

..................................................

22l1.3 Safe-Shutdown Analysis

................................................

25l1.4 Fire Test Reports and Fire Data

...........................................

25l1.5 Compensatory Measures

................................................

26l1.6 Fire Protection Training and Qualifications

.................................

27l1.7 Quality Assurance

.....................................................

30l1.8 Fire Protection Program Changes/Code Deviations

...........................

37l l2.FIRE PREVENTION

.........................................................

44l2.1 Control of Combustibles

................................................

44l2.2 Control of Ignition Sources

..............................................

47l2.3 Housekeeping

........................................................

48l2.4 Fire Protection System Maintenance and Impairments

.........................

48l l3.FIRE DETECTION AND SUPPRESSION

.........................................

49l3.1 Fire Detection

........................................................

49l3.2 Fire Protection Water Supply Systems

.....................................

50l3.3 Automatic Suppression Systems

..........................................

53l3.4 Manual Suppression Systems and Equipment

................................

55l3.5 Manual Firefighting Capabilities

..........................................

57l l4.BUILDING DESIGN/PASSIVE FEATURES

......................................

61l4.1 General Building and Building System Design

...............................

61l4.2 Passive Fire-Resistive Features

...........................................

71l4.3 Testing and Qualification of Electrical Raceway Fire Barrier Systems

.............

76l l5.SAFE-SHUTDOWN CAPABILITY

..............................................

85l5.1 Post-Fire Safe-Shutdown Performance Goals

................................

86l5.2 Cold Shutdown and Allowable Repairs

.....................................

86l5.3 Fire Protection of Safe-Shutdown Capability

................................

87l5.4 Alternative and Dedicated Shutdown Capability

..............................

90l5.5 Post-Fire Safe-Shutdown Procedures

......................................

93l5.6 Shutdown/Low-Power Operation

.........................................

94l l

DG-1170, Page 7 6.FIRE PROTECTION FOR AREAS IMPORTANT TO SAFETY

.......................

94l6.1 Areas Related to Power Operation

........................................

94l6.2 Other Areas

.........................................................

100ll7.PROTECTION OF SPECIAL FIRE HAZARDS EXPOSING AREAS lIMPORTANT TO SAFETY

...................................................

101l7.1 Reactor Coolant Pump Oil Collection

.....................................

101l7.2 Turbine/Generator Building

............................................

102l7.3 Station Transformers

..................................................

103l7.4 Diesel Fuel Oil Storage Areas

...........................................

103l7.5 Flammable Gas Storage and Distribution

..................................

103l7.6 Nearby Facilities

..........

.............................................

104l l8.FIRE PROTECTION FOR NEW REACTORS

....................................

104l8.1 General............................................................

104l8.2 Enhanced Fire Protection Criteria

........................................

104l8.3 Passive Plant Safe-Shutdown Condition

...................................

105l8.4 Applicable Industry Codes and Standards

..................................

105l8.5 Other New Reactor Designs

............................................

105l8.6 Fire Protection Program Implementation Schedule

...........................

106l8.7 Fire Protection for Nonpower Operation

...................................

106l l9.FIRE PROTECTION FOR LICENSE RENEWAL

.................................

106l lD.IMPLEMENTATION

...............................................................

108l lREGULATORY ANALYSIS

................................................................

108l lBACKFIT ANALYSIS

.....................................................................

108l lGLOSSARY..............................................................................

109l lREFERENCES

............................................................................

115l lAPPENDIX A. EQUIVALENCY

.............................................................

A-1l lAPPENDIX B. FIRE PROBABILISTIC RISK ASSESSMENTS

....................................

B-1llSection B, Discussion "Discussion

, of this guide

" provides a brief history and discussion of the ldevelopment and application of fire protection regulations and guidelines in the U.S. commercial nuclear lpower industry. The discussion includes summaries of the applicable regulations, the primary fire protection objectives, the varied licensing and design bases, and the primary assumptions relative to

postulated fire events for nuclear power reactors.

Section C, Regulatory "Regulatory Position, provides" identifies staff positions and guidance lrelative relevant to providing an acceptable level of fire protection for operating nuclear power plants.

lThe positions and guidance provided are a compilation of the fire protection requirements and guidelines lfrom the existing regulations and staff guidance. In addition, as appropriate, this section offers newlguidance is provided where the existing guidance is weak or non

-existent.lSection D, Implementation "Implementation

," describes how the NRC staff will use this guide.

l DG-1170, Page 8 This The NRC staff developed this regulatory guide has been developed to provide a lcomprehensive fire protection guidance document and to identify the scope and depth of fire protection that the staff would consider acceptable for nuclear plants currently operating as of January power plants.

lThe original issue of this guide addressed only plants operating as of January 1, 2001. This revisionlprovides guidance for new reactor designs. In addition, this revision incorporates the guidance previously lincluded in Branch Technical Position (BTP) SPLB 9.5-1, "Guidelines for Fire Protection for Nuclear lPower Plants (Formerly BTP CMEB 9.5-1)." This regulatory guide may be used for licensee self-lassessments and as the deterministic basis for future rulemaking.

llMany existing nuclear plants are adopting risk-informed, performance-based FPPs in accordance lwith 10 CFR 50.48(c) and National Fire Protection Association (NFPA) Standard 805, "Performance-lBased Standard for Fire Protection for Light-Water Reactor Electric Generating Plants," 2001 Edition.

lWhile much of the guidance provided here has been incorporated in the FPP of these plants and will lcontinue to be appropriate for a risk-informed, performance-based FPP, the guidance provided lin Regulatory Guide 1.205, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water lNuclear Power Plants," will take precedence over the guidance provided in this regulatory guide lfor plants that adopt a risk-informed, performance-based FPP in accordance with 10 CFR 50.48(c).

l lRisk-informed and performance-based alternatives to the guidance presented in this r documentlthat are in accordance with R egulatory g G uide 1.205 may be acceptable to the NRC staff. lThe for plants that do not modify their licenses in accordance with 10 CFR 50.48(c). Licensees lthat do not adopt a program based on NFPA 805 may use risk-informed, performance-based methods to ldetermine the acceptability of a plant change; however, licensees should submit the methodology,lincluding acceptance criteria, for NRC review and approval as a license amendment request in laccordance with 10 CFR 50.90, "Application for Amendment of License or Construction Permit," before limplementing the change.

llRegulatory Guide 1.191, "Fire Protection Program for Nuclear Power Plants During lDecommissioning and Permanent Shutdown," provides specific criteria and guidelines for FPPs lfor shutdown and decommissioning of nuclear power plants.

l lThe NRC issues regulatory guides to describe to the public methods that the staff considers lacceptable for use in implementing specific parts of the agency's regulations, to explain techniques lthat the staff uses in evaluating specific problems or postulated accidents, and to provide guidance lto applicants. Regulatory guides are not substitutes for regulations, and compliance with regulatory guides lis not required. The NRC issues regulatory guides in draft form to solicit public comment and involve lthe public in developing the agency's regulatory positions. Draft regulatory guides have not received lcomplete staff review and, therefore, they do not represent official NRC staff positions.

l lThis regulatory guide contains information collections contained in this regulatory guide that arelcovered by the requirements of 10 CFR Part 50, which were approved by the Office of Management and lBudget , approval (OMB) approved under OMB control number 3150-0011.

If a means used to impose an linformation collection does not display a currently valid OMB control number, t T he NRC may not neitherlconduct or nor sponsor, and a person is not required to respond to, the information an information collection lrequest or requirement unless the requesting document displays a currently valid OMB control number

. lllB. DISCUSSION l

DG-1170, Page 9 BACKGROUND

Background

lDuring the initial implementation of the U.S. nuclear reactor program, regulatory acceptance of fire protection programs of FPPs at nuclear power plants was based on the broad performance objectives of lGeneral Design Criterion 3 (GDC 3) in Appendix A to 10 CFR Part 50. Appendix A establishes the lnecessary design, fabrication, construction, testing, and performance requirements for structures, systems, and components (SSCs) important to safety. GDC 3 addresses fire protection requirements and lspecifies, in part, that (1) structures, systems, and components SSCs important to safety must be designed land located to minimize the probability and effects of fires and explosions, (2) noncombustible and heat-resistant materials must be used wherever practical, and (3) fire detection and suppression systems lmust be provided to minimize the adverse effects of fires on structures, systems, and components SSCslimportant to safety. However , during this early stage of nuclear power regulation , given the lack of detailed implementation guidance for this general design criterion GDC during this early stage of nuclear lpower regulation , the level of fire protection was generally found to be considered acceptable if the lfacility complied with local fire codes and received an acceptable rating from its fire insurance underwriter. Thus, the fire protection features installed in early U.S. nuclear power plants were very

similar to those installed in conventional fossil-fuel power generation stations.

A fire at the Browns Ferry Nuclear Power Plant, Unit 1, on March 22, 1975, was a pivotal event that brought fundamental change to fire protection and its regulation in the U.S. nuclear power industry.

The fire started when plant workers in the cable spreading room used an open flame to test for air leakage

through a non-fire-rated (polyurethane foam) penetration seal that led to the reactor building. The fire

ignited both the seal material and the electrical cables that passed through it, and burned for almost 7

hours before it was being extinguished using by a water hose stream.

The greatest amount of fire damage lactually occurred on the reactor building side of the penetration, in an area roughly 12.2 m meters (m) [40lfeet (ft)] by 6.1 m (20 f ee t). M The fire affected m ore than 1600 1,600 cables, routed in 117 conduits and l26 cable trays , were; of the affected and, of those cables affected , 628 were important to safety. The fire ldamage to electrical power, control systems, and instrumentation cables impeded the functioning of both normal and standby reactor cooling systems and degraded plant monitoring capability for the operators.

Given the loss of multiple safety systems, operators had to initiate emergency repairs in order to restore the systems needed to place the reactor in a safe

-shutdown condition.

lThe investigations that followed the Browns Ferry fire identified significant deficiencies, in bothlin the design of fire protection features and in the licensee's procedures for responding to a fire event.

lThe investigators concluded that the occupant safety and property protection concerns of fire insurance underwriters did not sufficiently encompass nuclear safety issues, especially in terms of the potential for

fire damage to cause the failure of redundant success paths of systems and components important for safe

reactor shutdown. In its report (NUREG-0050, February 1976, "Recommendations Related to Browns Ferry Fire"Fire," February 1976

), the NRC

's Browns Ferry special review team recommended that the lNRC agency (1) develop detailed guidance for implementing the general design criterion for fire lprotection and (2) conduct a detailed review of the fire protection program FPP at each operating nuclear lpower plant, comparing it which would compare the FPP to the guidance developed.

lIn May 1976, the NRC issued Branch Technical Position (BTP) APCSB 9.5-1 , "Guidelines for lFire Protection for Nuclear Power Plants," dated May 1, 1976 , which incorporated the recommendations lfrom the Browns Ferry fire special review team and provided technical guidelines to assist licensees in preparing their fire protection programs FPPs. As part of this action, the staff requested asked eachl DG-1170, Page 10 licensee to provide an analysis that divided dividing the plant into distinct fire areas and ldemonstrated demonstrating that redundant success paths of equipment required to achieve and maintain safe

-lshutdown conditions for the reactor were adequately protected from fire damage. However, the lguidelines of APCSB 9.5-1 applied only to those licensees that filed for a construction permit after July l1, 1976.In September 1976, in an effort to establish defense-in-depth fire protection programs FPPs ,lwithout significantly affecting the design, construction, or operation of existing plants that were either already operating or well past the design stage and into construction, the NRC modified the guidelines in

APCSB 9.5-1 and issued Appendix A to APCSB 9.5-1. This guidance provided acceptable alternatives

in areas where strict compliance with APCSB 9.5-1 would require significant modifications.

Additionally, the NRC informed each plant that the staff would use the guidance in Appendix A wouldlbe used to analyze the consequences of a postulated fire within each area of the plant and requested licensees to provide results of the fire hazards analysis performed for each unit and the technical

specifications for the present fire protection systems.

Early in 1977

, each licensee responded with a fire protection program an FPP evaluation that lincluded a fire hazard s analysis.

These The staff reviewed these analyses were reviewed by the staff lusing the guidelines of Appendix A to APCSB 9.5-1. The staff also conducted inspections of inspectedloperating reactors to examine the relationship of structures, systems, and components SSCs important to lsafety with the fire hazards, potential consequences of fires, and the fire protection features. After reviewing licensee s' responses to the BTP, the staff determined that additional guidance on the lmanagement and administration of fire protection programs FPPs was necessary

, and , in mid-1977, issued lGeneric Letter 77-002, GL 77-02, "Nuclear Plant Fire Protection Functional Responsibilities,lAdministrative Controls and Quality Assurance,"

which provided criteria used by the staff in to review oflspecific elements of a licensee's fire protection program FPP , including organization, training,lcombustible and ignition source controls, firefighting procedures

, and quality assurance (QA). M ThelBTP review process resolved m any fire protection issues were resolved during the BTP review process,land agreements were included , as reflected in the NRC-issued safety evaluation reports (SERs).

lBy the late 1970s to early 1980, the majority of most operating plants had completed their lanalyses and implemented most much of the fire protection program FPP guidance and recommendations lspecified in Appendix A to the BTP. In most cases, the NRC had found the licensees' proposed modifications resulting from these analyses to be acceptable.

In certain instances, however, technical ldisagreements between licensees and the NRC staff led to some licensees

' opposition to oppose t o heladopt some ion of the certain specified fire protection recommendations, such as the requirements for fire lbrigade size and training; water supplies for fire suppression systems; alternative, dedicated, or backup shutdown capability; emergency lighting; qualifications of penetration seals used to enclose places where

cables penetrated fire barriers; and the prevention of reactor coolant pump (RCP) oil system fires.

lFollowing deliberation, the Commission determined that, given the generic nature of some of the disputed issues, a rulemaking was necessary to ensure proper implementation of the NRC's firelprotection requirements.

In November 1980, the NRC published the "Fire"Fire Protection

"" rule, 10 CFR 50.48, which lspecified broad performance requirements, as well as Appendix R , "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979," to 10 CFR Part 50, which specified detailed regulatory requirements for resolving the disputed issues.

As originally proposed (Federal Register , Vol.Volume 45, No. 1&5 Numbers 1 and 5 , May 22,l1980), Appendix R would have applied to all plants licensed prior to before January 1, 1979, including l

DG-1170, Page 11 those for which the staff had previously accepted the fire protection features as meeting the provisions of Appendix A to APCSB 9.5

--1. After analyzing comments on the proposed rule, the Commission ldetermined that only three 3 of the fifteen 15 items in Appendix R were of such safety

-significance that lthey should apply to all plants (licensed prior to before January 1, 1979), including those for which thelstaff had previously approved alternative fire protection actions had been approved previously by the lstaff. These three items are fire protection of safe

-shutdown capability (including alternative, dedicated,lor backup shutdown systems), emergency lighting, and the reactor coolant pump RCP oil system.

lAccordingly, the final rule required all reactors licensed to operate before January 1, 1979, to comply with these three items even if the NRC had previously approved alternative fire protection features in

these areas (Federal Register , Vol.Volume 45, Nov.November 19, 1980).

llIn addition, the rule provided an exemption process that can be requested by a. A licensee canlrequest an exemption, provided that a required fire protection feature to be exempted would not enhance lfire protection safety in the facility

, or that such modifications may be detrimental to overall safety

([10lCFR 50.48(c)(6)

)]. Under this process, if the Director

, of the NRC's Office of Nuclear Reactor lRegulation

, (NRR) determine d s that a licensee has made a prima facie showing of a sound technical basis lfor such an assertion, then the the Commission would delay implementation dates of the rule wereldelayed until it took final Commission action on the exemption request. Appendix R to 10 CFR Part 50 land 10 CFR 50.48 became effective on February 17, 1981.

During the initial backfit of the fire protection regulation, the NRC approved a large number of many plant-specific exemptions (i.e., alternative methods to achieve the underlying purpose of the lregulation) at about 60 nuclear power plants. Since the mid-1980s, as licensees' programs have bec a o melmore compliant with the fire protection regulations, the number of exemptions requested and approved has decreased. Even so, the ongoing review of licensee fire protection programs FPPs , the licensee lefforts to save costs while maintaining an acceptable level of safety, and the emergence of additional technical issues (such as the deliberations over the adequacy of Thermo-Lag as a fire protection barrier)

have resulted in several hundred exemptions to specific elements of the NRC fire protection

requirements.

This progression, the broad provisions of the general design criterion GDC , the detailed limplementing guidance, the plant-by-plant review, and finally the issuance and backfit of the fire protection regulation and the prescriptive requirements of Appendix R resulted in a complex regulatory

framework for fire protection in U.S. nuclear power plants licensed prior to before 1979 and resulted in lthe issuance of a number of additional guidelines, clarifications, and interpretations, primarily as generic letters. Plants licensed after January 1, 1979, were not required to meet the provisions of Appendix R

unless specified directed to do so in specific license conditions. These plants were typically reviewed lto using the guidelines of Section 9.5.1 , "Fire Protection Program,"

of the Standard Review Plan SRPl(NUREG-0800), which subsumed the criteria specified in Appendix R. In July 1981, the NRC issued a major revision to NUREG-0800 for use in the review of new license applications. This revision included lStandard Review Plan SRP Section 9.5.1 with Branch Technical Position BTP CMEB 9.5-1 as an update lto the earlier fire protection BTPs.

Following promulgation of 10 CFR 50.48 and Appendix R, the staff issued Generic Letter GL 81-l12 , "Fire Protection Rule (February 20 45 FR 76602, November 19 , 198 1 0)," and later its associated lclarification letter (March 22, 1982). In these letters, the staff identified the information necessary to perform their its reviews of licensee compliance with the alternative or dedicated shutdown requirements lof Section III.G.3 of Appendix R. Staff guidance provided in these letters defined safe

-shutdownlobjectives, reactor performance goals, necessary safe

-shutdown systems and components, and associated lcircuit identification and analysis methods.

Generic Letter GL 81-12 also requested that licenseesldevelop technical specifications be developed for safe -shutdown equipment that was were not already lincluded in the existing plant technical specifications.

DG-1170, Page 12 Most licensees requested and were granted received additional time to perform their reanalysis,lpropose modifications to improve post

-fire safe -shutdown capability, and identify exemptions for lcertain fire protection configurations. In reviewing some exemption requests, the staff noted that a number of licensees had made significantly different interpretations of certain requirements.

These Thelstaff identified these differences were identified in the staff's draft SERs and were discussed them onlseveral occasions with the cognizant licensees. These discussions culminated in the issuance of Generic Letter 83-33 (October 19, 1983).

GL 83-33, "NRC Positions on Certain Requirements of Appendix R to l10 CFR Part 50."

lCertain licensees disagreed with, or found it difficult to implement, the interpretations provided in Generic Letter GL 83-33. To pursue the matter with senior NRC management, the industry formed the lNuclear Utility Fire Protection Group. Subsequently, the staff formed the Steering Committee on Fire Protection Policy.

Following staff inspections of operating plants, which identified a number of significant items of non-compliance, noncompliance and disagreements in the implementation of interpretations provided in lGeneric Letter GL 83-33, the Nuclear Utility Fire Protection Group requested interpretations of certain lAppendix R requirements and provided prepared a list of questions to be discussed with the industry. The lNRC responded by holding workshops in each R r egion to assist the industry in understanding the NRC's lrequirements and to improve the staff's understanding of the industry's concerns. The Fire Protection lPolicy Steering Committee documented the results of these workshops and the S s teering C c ommittee's lfindings and recommendations for addressing ongoing fire protection issues were documented in Generic Letter 85-01 in the Fire Protection Policy Steering Committee Report. Generic Letter 85-01 The report lincluded a proposed G g eneric L l etter that provided additional interpretations related to compliance with lAppendix R and staff answers to the industry's list of questions from the workshops.

This proposed Generic Letter was The staff revised and later issued as G this proposed g eneric L l etter as GL 86--10,l"Implementation of Fire Protection Requirements," on April 24, 1986.

Also included in Generic Letter GL 86-10 was a "standard license condition" for adoption by llicensees. Through the implementation and adoption of a standard license condition, a licensee was allowed to make changes to its fire protection program FPP without prior notification to first notifying thelNRC in accordance with the provisions of 10 CFR 50.59, "Changes, Tests and Experiments,"

providedlthat the changes did not adversely affect the plant's ability to achieve and maintain post-fire safelshutdown after a fire. The licensee, u U pon modification of the license to adopt the standard condition,lthe licensee could also amend the license to remove the fire protection technical specifications.

GenericlLetter GL 88-12, "Removal of Fire Protection Requirements from Technical Specifications" l(Specifications," dated August 2, 1988

), gave licensees additional guidance for implementation lof implementing the standard license condition and removal of removing the technical specifications lassociated with fire detection and suppression, fire barriers, and fire brigade staffing.

T Licensees were to lretain t he technical specifications associated with safe

-shutdown equipment and the administrative lcontrols related to fire protection audits were to be retained under the guidance of the generic letter.

As illustrated Beginning in the preceding discussion late 1990s , the Commission's Commission lprovided the NRC staff with guidance for identifying and assessing performance-based approaches to lregulation. In SECY-98-0058, "Development of a Risk-Informed, Performance-Based Regulation for lFire Protection at Nuclear Power Plants," dated March 26, 1998, the NRC staff proposed to the lCommission that the staff work with the NFPA and industry to develop a performance-based, risk-linformed consensus standard for fire protection requirements and guidelines consist of a multitude of lrules, generic communications, staff guidance, and other related documents. Current industry and DG-1170, Page 13 regulatory issues have prompted action on the part of the NRC to compile the current fire protection regulations and guidelines for operating reactors into this comprehensive guide.

REGULATORY REQUIREMENTS There are a number of regulatory requirements with applicability to the development and implementation of fire protection programs for nuclear power plants currently operating as of January 1, 2001. The primary requirements are summarized in this section.

Appendix A to 10 CFR Part 50 Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50 establishes for those plants for which its provisions apply, the necessary design, fabrication, construction, testing, and performance requirements for structures, systems, and components important to safety (see Glossary). The following subsections summarize those GDC with specific application to fire protection of nuclear power plants.

GDC 3, Fire Protection GDC 3 requires that structures, systems, and components important to safety be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. Noncombustible and heat resistant materials are required to be used wherever practical, particularly in locations such as the containment and control room. Fire detection and fighting systems of appropriate capacity and capability are required to be provided and designed to minimize the adverse effects of fires on structures, systems, and components important to safety. GDC 3 also requires that firefighting systems be designed to ensure that their failure, rupture, or inadvertent operation does not significantly impair the safety capability of these structures, systems, and components.

GDC 5, Sharing of Structures, Systems, and Components GDC 5 requires that structures, systems, and components important to safety not be shared among nuclear power units unless it can be shown that such sharing will not significantly impair their ability to perform their safety functions, including, in the event of an accident in one unit, an orderly shutdown and cooldown of the remaining units.

GDC 19, Control Room GDC 19 requires that a control room be provided from which actions can be taken to operate the nuclear power unit under normal and accident conditions, while limiting radiation exposure to control room personnel under accident conditions for the duration of the accident. GDC 19 also requires that equipment and locations outside the control room be provided with the design capability to accomplish hot shutdown of the reactor and with a potential capability for subsequent cold shutdown of the reactor.

GDC 23, Protection System Failure Modes GDC 23 requires that the protection system be designed to fail into a safe state or into a state demonstrated to be acceptable on some other defined basis if conditions such as disconnection of the system, loss of energy (e.g., electric power, instrument air), or postulated adverse environments (e.g., extreme heat or cold, fire, pressure, steam, water, radiation) are experienced.

DG-1170, Page 14 10 CFR 50.48 Section 50.48 of 10 CFR Part 50 requires that each operating nuclear power plant have a fire protection plan that satisfies General Design Criterion 3 of Appendix A to 10 CFR Part 50. It specifies what should be contained in such a plan and lists the basic fire protection guidelines for the plan.

Section 50.48 also requires that all plants with operating licenses prior to January 1, 1979, satisfy the requirements of Sections III.G, III.J, and III.O, and other sections of Appendix R to 10 CFR Part 50, where approval of similar features had not been obtained prior to the effective date of Appendix R.

Plants licensed to operate after January 1, 1979, must meet the provisions of 10 CFR 50.48(a).

As discussed later in this guide in the Licensing and Design Basis section, deviations from NRC fire protection requirements are documented and reviewed under different processes depending on the date of the operating license. Appendix R requirements for pre-1979 plants are processed under the exemption process. Deviations from other applicable guidelines are identified and evaluated in the staff's Safety Evaluation Reports. For post-1979 plants, where fire protection features do not meet applicable NRC requirements or commitments, or alternative approaches are proposed, the condition is documented as a deviation.

Appendix R to 10 CFR Part 50 Appendix R to 10 CFR Part 50 applies to licensed nuclear power electric generating stations that were operating prior to January 1, 1979, except as noted in 10 CFR 50.48(b). With respect to certain generic issues for such facilities, Appendix R identifies fire protection features required to satisfy Criterion 3 of Appendix A. There are two categories of Appendix R provisions that are applicable to the fire protection features of these facilities.

The first category consists of those provisions that were required to be backfit in their entirety, regardless of whether alternatives to the specific requirements had been previously approved by the NRC. The requirements are identified in Sections III.G, "Fire Protection of Safe Shutdown Capability";

III.J, "Emergency Lighting"; and III.O, "Oil Collection System for Reactor Coolant Pump." Those plants subject to the requirements of Section III.G.3 must also meet the requirements of Section III.L.

The second category consists of requirements concerning the open items of previous NRC staff fire protection reviews. Open items are defined as fire protection features that had not been previously approved by the NRC staff as satisfying the provisions of Appendix A to APCSB 9.5-1, as reflected in SERs. Except as specified in the license conditions of individual plants, Appendix R was not required to be implemented by plants that were licensed to operate after January 1, 1979. Rather, fire protection programs at these later plants were typically reviewed against the licensing review guidelines of Section 9.5-1 to the Standard Review Plan (NUREG-0800). SRP Section 9.5-1 and the associated CMEB 9.5-1 consolidated the guidance of the previous BTP, Appendix A to APCSB 9.5-1, Appendix R, and other staff guidance.

10 CFR Parts 50.72 and 50.73 These regulations prescribe the notification and reporting requirements for nuclear power plant licensees, including those related to fire protection programs. Section 50.72 provides for immediate DG-1170, Page 15 notification requirements via the emergency notification system (ENS), and Section 50.73 provides for 60-day written that, if the standard was acceptable, would be endorsed by the staff in a rulemaking. The lNFPA Standards Council issued NFPA 805, 2001 Edition, on January 13, 2001. The NRC published l10 CFR 50.48(c) endorsing NFPA 805 on June 16, 2004 (69 FR 33536). Regulatory Guide 1.205 lprovides staff guidance for licensees that elect to adopt a risk-informed, performance-based FPP in laccordance with 10 CFR 50.48(c) and NFPA 805.

llIn 1997, the NRC staff noticed that a series of licensee event reports (LERs)

.lThe information reported under 10 CFR 50.72 and 50.73 is used by the NRC staff in responding to emergencies, monitoring ongoing events, confirming licensing bases, studying potentially generic safety problems, assessing trends and patterns of operational experience, monitoring performance, identifying precursors of more significant events, and providing operational experience to the industry.

The two rules have identical reporting thresholds and similar language whenever possible. They are complementary and of equal importance, with necessary dissimilarities in reporting requirements to meet their different purposes.

The regulation, 10 CFR 50.72, is structured to provide telephone notification of reportable events to the NRC Operations Center within a time frame established by the relative importance of the events.

Events are categorized as either emergencies (immediate notifications, but no later than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) or non-emergencies. Non-emergencies are further categorized into 1-hour and 4-hour notifications; non-emergency events requiring 4-hour notifications generally have slightly less urgency and safety significance than those requiring 1-hour notifications. Immediate telephone notification to the NRC Operations Center of declared emergencies is necessary so the NRC may immediately respond.

Reporting of non-emergency events and conditions is necessary to permit timely NRC follow-up via event monitoring, special inspections, generic communications, or resolution of public or media concerns.

According to 10 CFR 50.73, written LERs must be submitted on reportable events within 60 days of their occurrence, after a thorough analysis of the event, its root causes, safety assessments, and corrective actions are available, to permit NRC engineering analyses and studies.

LICENSING AND DESIGN BASIS The fire protection licensing and design basis is dependent on a number of factors that may differ considerably for individual plants. However, with the issuance of the fire protection rule, 10 CFR 50.48, and Appendix R to 10 CFR 50, the applicability of certain fire protection requirements, including those within the rule, was established on the basis of the licensing date for a given plant being before or after January 1, 1979.

Plants Licensed Prior to January 1, 1979 The primary licensing basis for plants licensed to operate prior to January 1, 1979, is comprised of the plant license conditions, Appendix R and any approved exemptions, and the staff's Safety Evaluation Reports (SERs) on the fire protection program.

Safety Evaluation Reports The SERs document the staff acceptance of the plant fire protection program or elements thereof.

For plants licensed to operate prior to January 1, 1979, the staff's SERs also establish the extent to which the requirements of Appendix R to 10 CFR Part 50 apply. Plants whose fire protection features were DG-1170, Page 16 accepted by the NRC as satisfying the provisions of Appendix A to Branch Technical Position (BTP)

APCSB 9.5-1, or were accepted in comprehensive SERs issued prior to publication of Appendix A to BTP APCSB 9.5-1 in August 1976, were only required to meet the provisions of Sections III.G (III.L), III.J, and III.O of Appendix R.

Exemptions to Appendix R Effective February 17, 1981, the NRC amended its regulations by adding 10 CFR 50.48 and Appendix R to 10 CFR Part 50, requiring certain provisions for fire protection in nuclear power plants licensed to operate before January 1, 1979.

Plants with previously approved fire protection features (see Safety Evaluation Reports above) were exempted from the requirements of Appendix R with the exception of Sections III.G, III.J, and III.O.The required schedules for licensees to comply with the provisions of Appendix R were established in 10 CFR 50.48(c). Provisions were also included in the rule to allow licensees to file exemptions from Appendix R requirements on the basis that the required modifications would not enhance fire protection safety in the facility or would be detrimental to overall facility safety. These exemptions, upon approval by the staff, become a part of the fire protection licensing basis. The provisions of 10 CFR 50.48(c) have since expired and have been deleted from the regulations. Future exemptions should be requested in accordance with 10 CFR 50.12, as discussed below. (See Regulatory Position 1.8.2.)

Exemptions from fire protection requirements may also be requested in accordance with the provisions of 10 CFR 50.12. Under 10 CFR 50.12, the Commission may grant exemptions from the requirements of the regulations in 10 CFR Part 50, which are:

1.Authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security.

2.The Commission will not consider granting an exemption unless special circumstances are present. Special circumstances are present whenever; Application of the regulation in the particular circumstances conflicts with other rules or requirements of the Commission; orApplication of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule; orCompliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated; orThe exemption would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemption; or DG-1170, Page 17The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation; orThere is present any other material circumstance not considered when the regulation was adopted for which it would be in the public interest to grant an exemption. If such condition is relied on exclusively for satisfying criteria (2) above, the exemption may not be granted until the Executive Director for Operations has consulted with the Commission.

Operating License Conditions Most operating plant licenses contain a section on fire protection. License conditions for plants licensed prior to January 1, 1979, typically contain a condition requiring implementation of modifications committed to by the licensee as a result of the fire protection program review with respect to the branch technical position. These license conditions were added by amendments issued between 1977 and February 17, 1981, the effective date of 10 CFR 50.48 and Appendix R.

As a result of numerous compliance, inspection, and enforcement issues associated with the various plant license conditions, the staff developed a standard licensing condition. The standard license condition, and the NRC's recommendation that it be adopted by licensees, was transmitted to licensees in Generic Letter 86-10. Additional guidance regarding removal of the fire protection requirements from the plant technical specifications was provided to licensees in Generic Letter 88-12. The changes were promulgated to provide licensees greater flexibility in the management and implementation of the fire protection program and to clarify the fire protection licensing basis for the specific facility.

Plants Licensed After January 1, 1979 Plants licensed after January 1, 1979, are subject to the requirements of 10 CFR 50.48(a) only, and as such must meet the provisions of GDC 3 as specified in their license conditions and as accepted by the NRC in their SERs. These plants are typically reviewed to the guidance of SRP Section 9.5-1.

For these plants, where commitments to specific guidelines cannot be met, or alternative approaches are proposed, the differences between the licensee's program and the guidelines are documented in deviations (see Regulatory Position 1.4.4).

FIRE PROTECTION PROGRAM GOALS/OBJECTIVES Defense in Depth Fire protection for nuclear power plants uses the concept of defense in depth to achieve the required degree of reactor safety by using echelons of administrative controls, fire protection systems and features, and safe shutdown capability. These defense-in-depth principles are aimed at achieving the following objectives.To prevent fires from starting,To detect rapidly, control, and extinguish promptly those fires that do occur, and DG-1170, Page 18To provide protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by the fire suppression activities will not prevent the safe shutdown of the plant.

Assumptions Postulated Fire Fire damage to safe shutdown equipment is assessed on the basis of a single fire, including an exposure fire. An exposure fire is a fire in a given area that involves either in situ or transient combustibles and has the potential to affect structures, systems, and components important to safety located in or adjacent to that same area. The effects of such fire (e.g., smoke, heat, or ignition) can adversely affect those structures, systems, and components important to safety. Thus, a fire involving one success path of safe shutdown equipment may constitute an exposure fire for the redundant success path located in the same area, and a fire involving combustibles other than either redundant success path may constitute an exposure fire to both redundant success paths located in the same area.

Three levels of fire damage limits are established according to the safety function of the structure, system, or component. Damage limits for hot shutdown and cold shutdown systems and components are described in Regulatory Positions 5.3 and 5.4, respectively. Redundant systems necessary for mitigation of consequences following design basis accidents, but not required for safe shutdown may be damaged by a single exposure fire as discussed below in the Safety-Related Structures, Systems, and Components section.

The most stringent fire damage limit should apply for those systems that fall into more than one category.The fire event for considering the need for alternative or dedicated shutdown is a postulated fire in a specific fire area containing redundant safe shutdown cables/equipment where it has been determined that fire protection means specified in Regulatory Position 5.5 cannot be provided to ensure that safe shutdown capability will be preserved.

Conditions of Fire Occurrence It is assumed that a fire may occur at any time, but is not postulated to occur simultaneously with plant accidents or the most severe natural phenomena.

On multiple reactor sites, unrelated fires in two or more units need not be postulated to occur simultaneously. Fires involving facilities shared between units and fires caused by man-made site-related events that have a reasonable probability of occurring and affecting more than one reactor unit (such as an aircraft crash) should be considered.

Loss of Offsite Power/Station Blackout In evaluating the capability to accomplish post-fire safe shutdown, offsite power may or may not be available and consideration should be given to both cases. However, loss of offsite power need not be considered for a fire in non-alternative or dedicated shutdown areas if it can be shown that offsite power cannot be lost due to a fire in that area.

In accordance with the guidelines in Regulatory Position 5.6 of this guide, the capability to accomplish safe shutdown should be demonstrated for a loss of offsite power with a duration of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

However, in evaluating safe shutdown circuits, including associated circuits, the availability of uninterrupted power (i.e., offsite power available) may impact the ability to control the safe shutdown of DG-1170, Page 19 the plant by increasing the potential for associated circuit interactions resulting from fire damage to energized power and control circuits.

Several licensees have alternative post-fire safe shutdown methodologies that may result in loss of all ac power (i.e., station blackout). Some of these plants voluntarily enter station blackout (SBO) as a means to cope with the potential for spurious operations and to provide positive (manual) control of safe shutdown equipment. Others have procedures that may cause a SBO condition to be created as a result of fire effects (e.g., procedures that direct operators to manually trip the credited safe shutdown emergency diesel generator (EDG) in the event of fire damage to circuits of vital EDG support systems).

The ability to cope with SBO as part of the post-fire safe shutdown methodology is dependent on such issues as timeline logic; assumptions and bases for plant and operator response relative to component realignment; the ability of plant operators to monitor and control plant parameters and align plant components before, during, and after SBO control room evacuation and abandonment; and the practicality and reliability of EDG start and load (and restart, if applicable) under post-fire safe shutdown SBO conditions. The relative risk of self-imposed SBO may greatly exceed the actual risk posed by the fire and should be given appropriate consideration when evaluating the plant safe shutdown design and procedures.

Fragility of Structures, Systems, and Components to Fire Damage Fire damage to structures, systems, and components can result from heat, smoke, or ignition.

Fire is assumed to damage safe shutdown structures, systems, and components within the fire area of concern as discussed in the Postulated Fire section above and subject to the guidelines in Regulatory Positions 5.3 and 5.4 of this guide and as determined by the fire hazards analysis. When using a performance-based or risk-informed alternative approach, the fragility of structures, systems, and components to fire damage, including the ability to repair affected structures, systems, and components, should be considered.

Fire Protection Program Performance Goals Safety-Related Structures, Systems, and Components Because fire may affect safe shutdown systems, and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.

Post-Fire Safe Shutdown The performance objectives of the fire protection program relative to post-fire safe shutdown are to ensure that one success path of structures, systems, and components necessary for hot shutdown is free of fire damage, and to limit fire damage such that one success path of structures, systems, and components necessary to achieve and maintain cold shutdown can be repaired or made operable within a specified time period using onsite capabilities (see Regulatory Position 5.3).

Prevention of Radiological Release The fire protection program, including the fire hazards analysis, should demonstrate that the plant will maintain the ability to minimize the potential for radioactive releases to the environment in the event of a fire. Fires are expected to occur over the life of a nuclear power plant and thus should be treated as anticipated operational occurrences. Requirements for protection against radiation during 1During the 1980s, many licensees used Thermo-Lag 330-1 as a fire barrier material to satisfy the requirements ofAppendix R,Section III.G. In December 1992, the staff issued GL 92-08, "Thermo-Lag 330-1 Fire Barriers,"which discussed issues with the Thermo-Lag 330-1 fire barrier material.

2 The concept of using a potential heat release limit of 8141 kJ/kg (3500 Btu/lb) is similar to the "limited combustible"concept with its like limit, as set forth in NFPA 220, "Standard on Types of Building Construction."Additional analysis lof the EPRI/NEI test results appears in NUREG/CR-6776, "Cable Insulation Resistance Measurements Made During lCable Fire Tests," ML022600200 and ML022600307.

lDG-1170, Page 20 normal operations are in 10 CFR Part 20. Anticipated operational occurrences should not result in radiological consequences, and the exposure criteria of 10 CFR Part 20 apply.

Post-Fire Safe Shutdown Reactor Safety/Performance Goals Power Operations One success path of cables and had identified plant-specific problems related to potential fire-linduced electrical circuit failures that could prevent operation or cause maloperation of equipment lnecessary to achieve and maintain hot shutdown is to be maintained free of fire damage. The reactor safety and performance goals for post-fire safe shutdown should ensure that the specified acceptable fuel design limits are not exceeded. Post-fire reactor safety and performance goals for alternative or dedicated shutdown are. The NRC staff documented these problems in IN 99-17, "Problems Associated lwith Post-Fire Safe-Shutdown Circuit Analysis." Because of the number of similar LERs, the NRC ltreated the issue generically. In 1998, the NRC staff began interacting with interested stakeholders to lunderstand the problem and develop an effective risk-informed solution to the circuit analysis issue.

lBecause of the number of different stakeholder interpretations of the regulations, the NRC issued lEnforcement Guidance Memorandum (EGM)98-002, which provided enforcement discretion for circuit-lrelated findings. Also, the NRC temporarily suspended circuit-related fire protection inspections in l2000.llIn 2000, the NRC implemented the Reactor Oversight Process which included systematic linspections of licensees' safe-shutdown capability. During these inspections, fire protection inspectors lnoticed that many licensees had not upgraded or replaced Thermo-Lag 330-1 fire barrier material (1) orlhad not provided the separation distance between redundant safe-shutdown success paths necessary to lsatisfy the requirements in Section III.G.2 of Appendix R to 10 CFR Part 50. Some licensees lcompensated for the lack of or degraded fire barriers by relying on operator manual actions which had lnot been reviewed and approved by the NRC through the exemption process of 10 CFR 50.12, "Specific lExemptions." Other licensees misinterpreted Section III.G.1 to allow the use of operator manual actions in llieu of the means specified in Section III.

L G.2 although redundant safe-shutdown success paths were in lthe same fire area.

lIn 2001, the Electric Power Research Institute (EPRI) and Nuclear Energy Institute (NEI) lperformed a series of cable functionality fire tests to advance the nuclear industry's knowledge of fire-linduced circuit failures, particularly the potential for spurious equipment actuations initiated by hot lshorts. EPRI coordinated this effort and issued the final report, "Spurious Actuation of Electrical lCircuits Due to Cable Fires: Results of an Expert Elicitation" (Report No. 1006961, May 2002).

(2) NEIlconsidered the results of the testing in preparing an industry guidance document for circuit analysis,lNEI 00-01, "Guidance for Post-Fire Safe-Shutdown Circuit Analysis."

lThe variety of interpretations with respect to circuit analysis issues stemmed partly from the lprevious lack of knowledge of the potential for certain types of circuit failure mechanisms. The cable lfire tests performed by EPRI/NEI significantly increased the knowledge available to the industry and the lNRC with respect to fire-induced circuit failures and their potential to cause multiple spurious actuations l

DG-1170, Page 21 that could affect safe shutdown after a fire. To bring closure to these issues and support the resumption lof circuit analysis inspections, the NRC staff issued RIS 2005-30, "Clarification of Post-Fire Safe-lShutdown Circuit Regulatory Requirements." The staff issued this generic communication to clarify lregulatory requirements related to post-fire safe-shutdown circuit analyses and protection, particularly lthe requirements of Appendix R to 10 CFR 50.lShutdown/Refueling Operations Text Was Moved From Here: 1 C. REGULATORY POSITION1.FIRE PROTECTION PROGRAM In accordance with 10 CFR 50.48, a fire protection program must be established at each nuclear power plant. The program should establish the fire protection policy for the protection of structures, systems, and components important to safety at each plant and the procedures, equipment, and personnel required to implement the program at the plant site.

The fire protection program should extend the concept of defense in depth to fire protection in fire areas important to safety, with the following objectives.To prevent fires from starting;To detect rapidly, control, and extinguish promptly those fires that do occur;To provide protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by the fire suppression activities will not prevent the safe shutdown of the plant.

In accordance with 10 CFR 50.48, the fire protection program must:Identify the various positions within the licensee's organization that are responsible for the program and state the authorities delegated to these positions (see Regulatory Position 1.1);

DG-1170, Page 22Describe specific features such as administrative controls and personnel requirements for fire prevention (see Regulatory Position 2);Outline the plans for fire detection and suppression capability, and limitation of fire damage (see Regulatory Positions 1.2, 3, and 4);Describe personnel requirements for manual fire suppression activities (see Regulatory Position 3.5); andDescribe the means to limit fire damage to structures, systems, and components important to safety so that capability to safely shut down the plant is ensured (see Regulatory Positions 1.3 and 5).

On reactor sites with an operating reactor and with construction, modification, or decommissioning of other units under way, the fire protection program should provide for continuing evaluation of fire hazards associated with these activities. Additional fire barriers, fire protection capability, and administrative controls should be provided as necessary to protect the operating unit from construction or decommissioning fire hazards.

The guidance in Regulatory Position 1 is based on 10 CFR 50.48, Appendix R to 10 CFR Part 50, and CMEB 9.5-1.1.1Organization, Staffing, and Responsibilities The fire protection program should be under the direction of an individual who has been delegated authority commensurate with the responsibilities CFR Part 50, which licensees had interpreted lin a manner inconsistent with regulatory expectations. The bases of the position and who has available lstaff personnel knowledgeable in both positions presented in the generic communication are the current lregulations applicable to these circuits, which are supported by the industry cable fire test results. The lNRC staff resumed inspection of fire-induced safe-shutdown circuits in January 2005.

lThe NRC issued RIS 2006-10, "Regulatory Expectations with Appendix R Section III.G.2 lOperator Manual Actions," to inform the licensees about the staff's expectations, schedule, and lenforcement policy for resolving issues related to crediting operator manual actions and the subsequent ltermination of EGM 98-02, "Enforcement Guidance Memorandum-Disposition of Violations of lAppendix R, Sections III.G and III.L Regarding Circuit Failures."

lAs illustrated in the preceding discussion, the Commission's fire protection and nuclear safety.

lResponsibility for the overall fire protection program should be assigned to a person who has management control over all organizations involved in fire protection activities. Formulation and assurance of program implementation may be delegated to a staff composed of personnel prepared by training and experience in fire protection and personnel prepared by training and experience in nuclear DG-1170, Page 23 plant safety to provide a comprehensive approach in directing the fire protection program for the nuclear power plant.

The following positions or organizations should be designated.a.The upper level management position that has management responsibility for the formulation, implementation, and assessment of the effectiveness of the nuclear plant requirements and guidelines consist of rules, generic communications, staff lguidance, and other related documents. Recent industry and regulatory issues have lprompted the NRC to update this comprehensive guide to provide additional clarification lof regulatory expectations with respect to FPPs. This revision reflects the staff positions ldocumented in the recent generic communications.

llFor new reactor designs, the overall maturity of fire protection program.lb.The management positions directly responsible for formulating, implementing, and periodically assessing the effectiveness of the regulations, the many years of nuclear plant loperating experience, the improvement of analysis methodologies, and the opportunity to lincorporate these benefits in the original plant design provide the bases for enhanced firelprotection program for the licensee's

.ll DG-1170, Page 24 Regulatory Requirements llA number of regulatory requirements apply to the development and implementation of FPPs for lnuclear power plant , including fire drills and training conducted by the fire brigade and plant personnel.

The results of these assessments should be reported to the upper level management position responsible for fire protection with recommendations for improvements or corrective actions as deemed necessary.

Text Was Moved From Here: 2d.The onsite positions that:

Text Was Moved From Here: 3ii.Are responsible for the firefighting training for operating plant personnel and the plant's fire brigade, design and selection of equipment, periodic inspection and testing of fire protection systems and equipment in accordance with established procedures

s. This section summarizes the primary requirements.

llAppendix A to 10 CFR Part 50 llAppendix A to 10 CFR Part 50 establishes

, and evaluation of test results and determination of the lacceptability of the systems under test.iii.Assist in the critique of all fire drills to determine how well the training objectives have been met.iv.Are responsible for the in-plant fire protection review of proposed work activities to identify potential transient fire hazards and specify required additional fire protection in the work activity procedure.v.Implement a program for indoctrination of all those plant contractor personnel in lappropriate administrative procedures that implement s to which its provisions lapply, the fire protection program and the emergency procedures relative to fire lprotection.vi.Implement a program for instruction of personnel on the proper handling of accidental events such as leaks or spills of flammable materials that are related to fire protection.vii.Are responsible for review of hot work.e.The onsite position responsible for fire protection quality assurance. This position is responsible for ensuring the effective implementation of the fire protection program by planned inspections, scheduled audits necessary design, fabrication, construction, testing

,land verification that the results of these inspections and audits are promptly reported to cognizant management personnel.f.The positions that are part of the plant fire brigade (also see Regulatory Position 3.5.1).

DG-1170, Page 25i.The plant fire brigade positions should be responsible for fighting fires. The authority and responsibility of each fire brigade position relative performance lrequirements for SSCs important to safety. The following subsections lsummarize those GDCs with specific application to fire protection should belclearly defined.ii.The responsibilities of each fire brigade position should correspond with the actions required by the firefighting procedures.iii.Collateral responsibilities of the fire brigade members should not conflict with their responsibilities related to the fire brigade during a fire emergency.iv.The minimum number of trained fire brigade members available onsite for each operating shift should be of nuclear power plants.

llGDC 3, Fire Protection llGDC 3 requires that SSCs important to safety be designed and located to minimize, consistent lwith the activities required to combat credible and challenging fires, but no less than 5 members. The size of the fire brigade should be based upon the functions required to fight fires with adequate allowance for injuries. Fire brigade staffing should account for all operational and emergency response demands on shift personnel in the event of a significant fire.

The guidance in Regulatory Position 1.1 is based on CMEB 9.5-1, IN 91-77, IN 95-48, and Stello Letter to Bixel (1978).1.2Fire Hazards Analysis A fire hazards analysis should be performed to demonstrate that the plant will maintain the ability to perform safe shutdown functions and minimize radioactive material releases to the environment in the event of a fire. This analysis should be revised as necessary to reflect plant design and operational changes.The fire hazards analysis accomplishes the following objectives:a.Considers potential in situ and transient fire hazards;b.Determines the consequences of fire in any location in the plant on the ability to safely shut down the reactor or on the ability to minimize and control the release of radioactivity to the environment; and c.Specifies measures for fire prevention, fire detection, fire suppression, and fire otherlsafety requirements, the probability and effect of fires and explosions. Noncombustible land heat-resistant materials must be used wherever practical, particularly in locations lsuch as the containment and alternative shutdown capability for each fire area containing lstructures, systems, and components important to safety in accordance with NRC guidelines and regulations.

Text Was Moved From Here: 4 DG-1170, Page 26 The fire hazards analysis should address the following elements and attributes.The NRC fire protection requirements and guidance that apply.Amounts, types, configurations, and locations of cable insulation and other combustible materials.In situ fire hazards.Automatic fire control room. Fire detection and suppression capability. The effects of llightning strikes should be included in the design of fire detection systems.Layout and configurations of structures, systems, and components firefighting systems of lappropriate capacity and capability must be provided and designed to minimize the ladverse effects of fires on SSCs important to safety.

The protection for safe shutdown lsystems (see Regulatory Positions 5.5 and 5.6) within a fire area should be determined on the basis of the worst case fire that is likely to occur and the resulting damage. The extent of such damage should be justified in the fire hazards analysis. The analysis should consider the degree of spatial separation between redundant shutdown systems, the presence of in situ and transient combustibles, the available fire protection systems and features, sources of ignition, and the susceptibility to fire damage of the safe-shutdown-related cables, equipment, systems, and features in the area.Reliance on and qualifications of fire barriers, including fire test results, the quality of the materials and barrier system, and the quality of the barrier installation.Fire area construction (walls, floor, ceiling, dimensions, volume, ventilation, and congestion). The fire hazard analysis should be the mechanism to determine that fire areas have been properly selected. Guidelines for fire areas and zones are provided in Regulatory Position 4.1.2 of this guide.Location and type of manual firefighting equipment and accessibility for manual fire fighting.Potential disabling effects of fire suppression systems on shutdown capability. The term"damage by fire" in Appendix R also includes damage to equipment from the normal or inadvertent operation of fire suppression systems. The fire hazards analysis should address the effects of firefighting activities. GDC 3 of Appendix A to 10 CFR Part 50 states that "Fire-fighting GDC 3 also requires that firefighting systems shall be designed lto assure ensure that their failure, rupture , or inadvertent operation does not significantly limpair the safety capability of these structures, systems, and components."Availability of oxygen (for example, inerted containment).Alternative, dedicated, or backup shutdown capability.

Fire initiation should be postulated at the location within each fire area/zone that will produce the most severe fire with the potential to adversely impact structures, systems, and components SSCs.ll DG-1170, Page 27 GDC 5, Sharing of Structures, Systems, and Components llGDC 5 requires that nuclear power units do not share SSCs important to safety. Fireldevelopment should consider the potential for involvement of other combustibles, both fixed and transient, in the fire area. Where automatic suppression systems are installed, unless the licensees can lshow that such sharing will not significantly impair the units' ability to perform their safety functions,lincluding, in the event of an accident in one unit, an orderly shutdown and cooldown of the remaining lunits.llGDC 19, Control Room llGDC 19 requires that the licensee provide a control room from which personnel can operate the lnuclear power unit under normal and accident conditions and which limits radiation exposure to control lroom personnel under accident conditions for the duration of the accident. GDC 19 also requires that lequipment and locations outside the control room be designed to accomplish hot shutdown of the reactor land have a potential capability for subsequent cold shutdown of the reactor.

llGDC 23, Protection System Failure Modes llGDC 23 requires that the protection system be designed to fail into a safe state or into a state ldemonstrated to be acceptable on some other defined basis if the plant experiences conditions such as ldisconnection of the system, loss of energy (e.g., electric power, instrument air), or postulated adverse lenvironments (e.g., extreme heat or cold, fire, pressure, steam, water, radiation).

ll10 CFR 50.48, "Fire Protection" llIn accordance with 10 CFR 50.48, each operating nuclear power plant must have an FPP that lsatisfies GDC 3 of Appendix A to 10 CFR Part 50. The regulation specifies what an FPP should contain land lists the basic fire protection guidelines for the plan.

llAs stated in 10 CFR 50.48(b), all plants that had operating licenses before January 1, 1979, must lsatisfy the requirements of Sections III.G, III.J, and III.O, and other sections of Appendix R to l10 CFR Part 50, in cases in which licensees had not obtained approval of similar features before the leffective date of Appendix R. Plants licensed to operate after January 1, 1979, must meet the provisions lof 10 CFR 50.48(a).

l lAll currently licensed plants may voluntarily adopt a risk-informed, performance-based FPP in laccordance with 10 CFR 50.48(c) and NFPA 805. The regulation in 10 CFR 50.48(c), which the lCommission adopted in 2004 (69 FR 33536; June 16, 2004), incorporates NFPA 805 by reference, with lcertain exceptions, and allows licensees to voluntarily adopt and maintain an FPP that meets the lrequirements of NFPA 805 as an alternative to meeting the requirements of 10 CFR 50.48(b) or the plant-lspecific fire protection license conditions.

l lAppendix R to 10 CFR Part 50, "Fire Protection Program for Nuclear Power Facilities Operating lPrior to January 1, 1979 "llAppendix R to 10 CFR Part 50 applies to licensed nuclear power electric generating stations that lwere operating before January 1, 1979, except as noted in 10 CFR 50.48(b). With respect to certain lgeneric issues for such facilities, Appendix R identifies fire protection features required to satisfy l

DG-1170, Page 28 Criterion 3 of Appendix A. Two categories of Appendix R provisions apply to the fire protection lfeatures of these facilities.

llThe first category consists of those provisions that licensees were required to backfit in their lentirety, regardless of whether the NRC had previously approved alternatives to the specific lrequirements. The requirements appear in Sections III.G, "Fire Protection of Safe-Shutdown Capability";

lIII.J, "Emergency Lighting"; and III.O, "Oil Collection System for Reactor Coolant Pump." Those plants lsubject to the requirements of Section III.G.3 must also meet the requirements of Section III.L.

l lThe second category consists of requirements concerning the open items of previous NRC staff lfire protection reviews. Open items are defined as fire protection features that the NRC staff had not lpreviously approved as satisfying the provisions of Appendix A to BTP APCSB 9.5-1, as reflected in lSERs.l lExcept as specified in the license conditions of individual plants, plants that were licensed to loperate after January 1, 1979, were not required to implement Appendix R. Rather, the NRC staff ltypically reviewed the FPPs for these plants against the licensing review guidelines of SRP Section 9.5.1.

lPrevious revisions of SRP Section 9.5.1 and the associated CMEB 9.5-1 consolidated the guidance of the lprevious BTP, Appendix A to APCSB 9.5-1, Appendix R, and other staff guidance. (The staff has lremoved that guidance from Revision 5 of SRP Section 9.5.1 and included it in this regulatory guide.)

l l10 CFR 50.72 and 10 CFR 50.73 llThese regulations prescribe the notification and reporting requirements for nuclear power plant llicensees, including those related to FPPs. The regulation in 10 CFR 50.72, "Immediate Notification lRequirements for Operating Nuclear Power Reactors," provides immediate notification requirements via lthe Emergency Notification System (ENS), and 10 CFR 50.73, "Licensee Event Report System,"

lprovides for 60-day written LERs.

llThe NRC staff uses the information reported under 10 CFR 50.72 and 10 CFR 50.73 in lresponding to emergencies, monitoring ongoing events, confirming licensing bases, studying potentially lgeneric safety problems, assessing trends and patterns of operational experience, monitoring lperformance, identifying precursors of more significant events, and providing operational experience to lthe industry.

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DG-1170, Page 29 Licensing and Design Basis llThe fire protection licensing and design basis depends on several factors that may differ lconsiderably for individual plants. However, the issuance of the Fire Protection rule, 10 CFR 50.48, and lAppendix R to 10 CFR Part 50 established the applicability of certain fire protection requirements,lincluding those within the rule, on the basis of whether the licensing date for a given plant is before or lafter January 1, 1979 [except for plants that have adopted an NFPA 805 licensing basis in accordance lwith 10 CFR 50.48(c)].

l lThe current licensing basis (CLB) is the set of NRC requirements applicable to a specific plant land a licensee's written commitments for ensuring compliance with and operation within applicable NRC lrequirements and the plant-specific design basis (including all modifications and additions to such lcommitments over the life of the license) that are docketed and in effect. The CLB includes the NRC lregulations contained in 10 CFR Parts 2, 19, 20, 21, 26, 30, 40, 50, 51, 54, 55, 70, 72, 73, 100 and lappendices thereto; orders; license conditions; exemptions; and technical specifications. It also includes lthe plant-specific design-basis information defined in 10 CFR 50.2 as documented in the most recent lfinal safety analysis report (FSAR) as required by 10 CFR 50.71 and the licensee's commitments lremaining in effect that were made in docketed licensing correspondence such as licensee responses to lNRC bulletins, generic letters, and enforcement actions, as well as licensee commitments documented in lNRC safety evaluations or licensee event reports.

l lDesign bases means that information which identifies the specific functions to be performed by a lstructure, system, or component of a facility, and the specific values or ranges of values chosen for lcontrolling parameters as reference bounds for design. These values may be (1) restraints derived from lgenerally accepted "state-of-the-art" practices for achieving functional goals, or (2) requirements derived lfrom analysis (based on calculation and/or experiments) of the effects of the postulated fire should be levaluated with and without actuation of the automatic suppression system.

"Worst case" fires need not be postulated to be concurrent with non-fire-related failures in safety systems, other a postulated accident for which a structure, system, or component must meet its functional lgoals.llPlants Licensed before January 1, 1979 llThe primary licensing basis for plants licensed to operate before January 1, 1979, comprises the lplant license conditions, Appendix R, approved exemptions, and the staff's SERs on the FPP.

ll DG-1170, Page 30 Safety Evaluation Reports llThe SERs document the staff acceptance of the plant FPP or its elements. For plants licensed to loperate before January 1, 1979, the staff's SERs also establish the extent to which the requirements of lAppendix R to 10 CFR Part 50 apply. Plants for which the NRC accepted the fire protection features as lsatisfying the provisions of Appendix A to BTP APCSB 9.5-1, or were accepted in comprehensive SERs lissued before the publication of Appendix A to BTP APCSB 9.5-1 in August 1976, were required to meet lonly the provisions of Sections III.G (III.L), III.J, and III.O of Appendix R.

llFor pre-1979 licensees, a staff decision in an SER that approves an aspect of the FPP that does lnot comply with regulatory requirements does not eliminate the need for an exemption. For example,lpre-1979 licensees who have SERs, but not a corresponding exemption that approves operator manual lactions credited with meeting the protection requirements of Appendix R,Section III.G.2, must request lan exemption under 10 CFR 50.12 by (1) highlighting the special circumstances of l10 CFR 50.12(a)(2)(ii), (2) citing the SER as the safety basis, and (3) confirming that the safety basis lestablished in the SER remains valid.

l lExemptions from Appendix R llEffective February 17, 1981, the NRC amended its regulations by adding 10 CFR 50.48 and lAppendix R to 10 CFR Part 50, requiring certain provisions for fire protection in nuclear power plants llicensed to operate before January 1, 1979.

llPlants with previously approved fire protection features (see the above section on SERs) were lexempt from the requirements of Appendix R with the exception of Sections III.G, III.J, and III.O.

l lThe licensee may also request exemptions from fire protection requirements in accordance with lthe provisions of 10 CFR 50.12. Under that regulation, the Commission may grant exemptions from the lrequirements of the regulations in 10 CFR Part 50 in the following cases:

la.The exemption is authorized by law, will not present an undue risk to the public health and lsafety, and is consistent with the common defense and security.

lb.The Commission will not consider granting an exemption unless special circumstances are lpresent. Special circumstances include the following:

li.Application of the regulation in the particular circumstances conflicts with other rules or lrequirements of the Commission.

lii.Application of the regulation in the particular circumstances would not serve the lunderlying purpose of the rule or is not necessary to achieve the underlying purpose of lthe rule.liii.Compliance would result in undue hardship or other costs that significantly exceed those lcontemplated when the regulation was adopted, or that significantly exceed those lincurred by others similarly situated.

liv.The exemption would result in benefit to the public health and safety that compensates lfor any decrease in safety that may result from granting the exemption.

l DG-1170, Page 31 v.The exemption would provide only temporary relief from the applicable regulation, and lthe licensee or applicant has made good faith efforts to comply with the regulation.

lvi.There is present any other material circumstance not considered when the regulation was ladopted for which it would be in the public interest to grant an exemption. If the request lrelies exclusively on such condition to satisfy criterion (2) above, the exemption may not lbe granted until the Executive Director for Operations has consulted with the lCommission.

llOperating License Conditions llFire protection license conditions for plants licensed before January 1, 1979, typically require limplementation of modifications committed to by the licensee as a result of the FPP review with respect lto the BTP. These license conditions appear in amendments issued between 1977 and February 17, 1981,lthe effective date of 10 CFR 50.48 and Appendix R.

llAs a result of numerous compliance, inspection, and enforcement issues associated with the lvarious plant license conditions, the staff developed a standard licensing condition for fire protection.

lThe NRC transmitted this license condition, and the recommendation that licensees adopt it, in GL 86-10.

lThe licensees received additional guidance regarding removal of the fire protection requirements from lthe plant technical specifications in GL 88-12. The NRC promulgated these changes to give licensees lgreater flexibility in the management and implementation of the FPP and to clarify the fire protection llicensing basis for the specific facility.

l lPlants Licensed after January 1, 1979 llExisting plants licensed after January 1, 1979, are subject to the requirements of 10 CFR l50.48(a) [except those plants that have adopted a performance-based FPP in accordance with 10 CFR l50.48(c)] and, thus, must meet the provisions of GDC 3 as specified in their license conditions and as laccepted by the NRC in the SERs. The NRC staff typically reviews these plants according to the lguidance and acceptance criteria of SRP Section 9.5.1. For plants that cannot meet commitments to lspecific guidelines or that have proposed alternative approaches, the differences between the licensee's lprogram and the guidelines are documented in deviations. (See Regulatory Position 1.8 of this guide.)

llLicense Renewal llThe fire protection licensing and design basis under license renewal should not differ lsignificantly from that in effect before renewal, with the exception that licensees must include fire lprotection SSCs in license renewal scoping and aging management programs as appropriate. Licensees lmust submit an application for renewal of a nuclear power plant operating license in accordance with the lprovisions of 10 CFR Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power lPlants." Regulatory Guide 1.188, "Standard Format and Content for Applications To Renew Nuclear lPower Plant Operating Licenses," provides additional information and guidelines on the renewal process.

lThe regulatory guide endorses the methods contained in NEI 95-10, "Industry Guideline for lImplementing the Requirements of 10 CFR Part 54-The License Renewal Rule," Revision 6, issued in lMarch 2005. Regulatory Position 9 of this document provides guidance regarding the fire protection laspects of license renewal.

ll DG-1170, Page 32 Power Uprates llThe fire protection licensing and design basis for plants requesting power uprates should not ldiffer significantly from the basis in effect before the uprate request. The review of changes resulting lfrom the power uprate must ensure that the post-fire safe-shutdown capability is maintained and that lSSCs important to safety are protected from the effects of fire and explosion.

llShutdown and Decommissioned Plant sllFor those plants that are permanently shutdown and/or are undergoing decommissioning, the llicensing basis changes in accordance with the requirements in 10 CFR 50.82. For permanently lshutdown reactors, 10 CFR Part 50, 10 CFR 50.48(f), and Regulatory Guide 1.191 govern fire protection.

lThe fire protection objectives listed in 10 CFR 50.48(f) are to (1) reasonably prevent fires from loccurring, (2) rapidly detect, control, and extinguish those fires that do occur, and (3) minimize the risk lof fire-induced radiological hazards to the public, environment, and plant workers.

llCode of Record llWhen existing plants were originally licensed, the licensee generally committed to complying lwith a specific edition of applicable industry codes and standards such as the NFPA fire codes. The lspecific edition to which the licensee originally committed is still the "code of record." Licensees are not lrequired to comply with later editions of these codes and standards, except when they specifically adopt a llater edition in accordance with regulatory guidelines or when new fire protection systems protecting lSSCs important to safety are installed. The code of record for the new fire protection system should be lthe edition that is in effect when the system is designed or when a commitment to add the system is made lto the staff. The code of record for the unchanged fire protection systems will not change. In general, for lmodifications to an existing fire protection system that are permitted by the code of record, the staff does lnot require that the system be brought into compliance with the current edition of the code.

llNew Reactors llThe FPPs for new reactor plants that submit applications in accordance with 10 CFR Part 52,l"Early Site Permits; Standard Design Certifications; and Combined Licenses for Nuclear Power Plants,"

lare subject to 10 CFR 50.48(a) and the criteria for enhanced fire protection in accordance with SECY l016, "Evolutionary Light-Water Reactor (LWR) Certification Issues and Their Relationship to Current lRegulatory Requirements"; SECY-93-087, "Policy, Technical, and Licensing Issues Pertaining to lEvolutionary and Advanced Light-Water Reactor (ALWR) Designs"; and SECY-94-084, "Policy and lTechnical Issues Associated with the Regulatory Treatment of Non-Safety Systems in Passive Plant lDesigns." SECY-90-016 established enhanced fire protection criteria for evolutionary light-water lreactors. SECY-93-087 recommended that the enhanced criteria be extended to include passive reactor ldesigns. The Commission approved SECY-90-016 and SECY-93-087 in staff requirements memoranda l(SRM). SECY-94-084, in part, establishes criteria defining safe-shutdown conditions for passive light-lwater reactor designs. The NRC staff uses the guidance and acceptance criteria of SRP Section 9.5.1 in lreviewing new reactor FPPs.

ll DG-1170, Page 33 Fire Protection Program Goals and Objectives llDefense-in-Depth llFire protection for nuclear power plants uses the concept of defense-in-depth to achieve the lrequired degree of reactor safety. This concept entails the use of echelons of administrative controls, fire lprotection systems and features, and safe-shutdown capability to achieve the following objectives:

l*to prevent fires from starting l*to detect rapidly, control, and extinguish promptly those fires that do occur l*to protect SSCs important to safety so that a fire that is not promptly extinguished by the fire lsuppression activities will not prevent the safe shutdown of the plant or result in release of lradioactive materials to the environment llAssumptions llPostulated Fire l

lAnalysts assess fire damage to safe-shutdown equipment or fires with the potential to result in lrelease of radioactive materials to the environment on the basis of a single fire, including an exposure lfire. An exposure fire is a fire in a given area that involves either in situ or transient combustibles and lhas the potential to affect SSCs important to safety or release of radioactive materials located in or ladjacent to that same area. The effects of such fire (e.g., smoke, heat, or ignition) can adversely affect lthose SSCs important to safety, or the ability to prevent release of radioactive materials. Thus, a fire linvolving one success path of safe-shutdown equipment may constitute an exposure fire for the redundant lsuccess path located in the same area, and a fire involving combustibles not in either redundant success lpath may constitute an exposure fire for both redundant success paths located in the same area.

llThere is no regulatory requirement to prevent fire-induced failure of redundant systems lnecessary for mitigation of consequences following design-basis accidents if the system is not required to loperate for safe shutdown after a fire. However, the licensee is required to prevent (or mitigate, where lpermitted by regulatory requirements) fire-induced failures of these systems if the failure could prevent lsafe shutdown (e.g., because of spurious actuations). The most stringent fire damage limit should apply lto those systems that fall into more than one category.

l lFor the application of fire protection regulatory requirements, redundant trains of systems may be ltwo or more similar trains of equivalent capacity in the same system powered by separate electrical ldivisions or they may be two or more separate systems designed to perform the same post-fire safe-lshutdown function. In cases where the regulatory requirements for protection (e.g., fire barriers,lseparation, suppression, and/or detection) of at least one of the redundant trains in a single fire area lcannot be met or where the post-fire safe-shutdown function of the train or system is not the design lfunction, the regulatory requirements for alternative/dedicated shutdown systems apply. In the context of lpost-fire safe-shutdown, the redundant train or alternative/dedicated shutdown system credited with lperforming the required functions are also referred to as success paths.

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DG-1170, Page 34 Conditions of Fire Occurrence llThe analysis assumes that a fire may occur at any time but does not postulate a fire occurring lsimultaneously with and independently from plant accidents

, or the most severe natural phenomena. lOn multiple-reactor sites, such as floods or high winds. However, severe natural phenomena,lsuch as earthquakes, may initiate a fire event and should be considered in evaluating the design capability lof fire protection systems and features.

lOn multiple reactor sites, the analysis need not postulate the simultaneous occurrence of lunrelated fires in two or more units need not be postulated to occur simultaneously. F. The licensee lshould consider f ires involving facilities shared between units and fires caused by man-made site-lrelated random natural or manmade events that have a reasonable probability of occurring and affecting lmore than one reactor unit (such as an aircraft crash) should be considered.

The fire hazards analysis should separately identify hazards and provide appropriate protection in locations where losses of structures, systems, and components

.llLoss of Offsite Power/Station Blackout llIn evaluating the capability to accomplish safe shutdown after fires, the licensee should consider lwhether offsite power will be available. However, the licensee need not consider loss of offsite power lfor a fire in nonalternative or dedicated shutdown areas if it can show that offsite power cannot be lost lbecause of a fire in that area.

lAs described in Regulatory Position 5.4.1 of this guide, alternative shutdown capability should laccommodate post-fire conditions when offsite power is available and conditions when offsite power is lnot available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In an evaluation of safe-shutdown circuits, the availability of uninterrupted lpower (i.e., offsite power remains available) may impact the ability to control the safe shutdown of the lplant by increasing the potential for circuit interactions resulting from fire damage to energized power land control circuits that may result in spurious actuations.

lSeveral operating plant licensees have alternative methodologies that rely on intentional ldisconnection of alternating current (ac) power to specific equipment or to the entire plant as a means to lachieve safe shutdown after a fire. The purpose of these self-induced station blackouts (SISBOs) is to leliminate potential spurious actuations that could prevent safe shutdown and allow manual control of lrequired equipment. Some licensees have procedures that cause a SISBO condition to be created as a lresult of fire effects [e.g., procedures that direct operators to manually trip the credited safe-shutdown lemergency diesel generator (EDG) in the event of fire damage to circuits of vital EDG support systems].

lThe acceptability of safe-shutdown procedures that voluntarily enter, or otherwise create, a SISBO lcondition is determined on a case-by-case basis.

lThe ability to cope with SISBO as part of the post-fire safe-shutdown methodology depends on lsuch issues as time-line logic; assumptions and bases for plant and operator response relative to lcomponent realignment; the ability of plant operators to monitor and control plant parameters and align lplant components before, during, and after SISBO control room evacuation and abandonment; and the lpracticality and reliability of EDG start and load (and restart, if applicable) under post-fire safe-shutdown lSISBO conditions.

lThe risk of self-imposed SISBO may greatly exceed the actual risk posed by the fire, and the llicensee should consider the risk carefully when evaluating the plant safe-shutdown design and lprocedures. A plant typically uses this approach to avoid or minimize the need for operator manual l

DG-1170, Page 35 actions after a fire. However, acceptable operator manual actions that are implemented in accordance lwith Regulatory Position 5.3.3 and NUREG-1852, "Demonstrating the Feasibility and Reliability of lOperator Manual Actions in Response to Fire," may present a lower risk than the SISBO approach.

lNew reactor designs should not rely on SISBO to mitigate potential fire damage to safe-lshutdown systems.

llFragility of Structures, Systems, and Components Exposed to Fire Damage llFire damage to SSCs important to safety can occur as a result of the following.

l1.Concentrations of combustible contents, including transient fire hazards of combustibles expected to be used in normal operations such as refueling, maintenance, and modifications,2.Continuity of combustible contents, furnishings, building materials, or combinations thereof in configurations conducive to fire spread, 3.Exposures to fire, result from heat, smoke, or water, including those that may necessitate levacuation from areas that are required to be attended for safe shutdown,4.Fire in control rooms or other locations having critical functions important to safety, 5.Lack of adequate access or smoke removal facilities that impede plant operations or fire extinguishment in plant areas important to safety, 6.Lack of explosion-prevention measures, 7.Loss of electric power or control and instrumentation circuits, 8.Inadvertent operation of fire suppression systems.

The ignition. Fire is assumed to damage safe-shutdown SSCs within the fire area of concern as ldiscussed in the "Postulated Fire" section (above) and as determined by the fire hazards analysis shouldlbe performed by qualified fire protection and reactor systems engineers.

Experienced judgment is necessary to identify fire hazards and

.llFire Protection Program Performance Goals llSafety-Related Structures, Systems, and Components l

lGDC 3 of Appendix A to 10 CFR Part 50 requires that the FPP protect SSCs important to safety lfrom the effects of fire. However, the post-fire loss of function of systems used to mitigate thelconsequences of a postulated fire starting at any location in the plant. Evaluation of design-basis laccidents does not per se impact public safety. The FPP must protect all equipment important to safety; lhowever, the need to limit fire damage to systems required to achieve and maintain post-fire safe-lshutdown conditions is greater than the need to limit fire damage to those systems required to mitigate lthe consequences of the postulated fire on nuclear safety should be performed by persons thoroughly trained and experienced in reactor safety. The person conducting the analysis of fire hazards should be thoroughly trained and experienced in the principles of industrial fire prevention and control and in fire DG-1170, Page 36 phenomena from fire initiation, through its development, to propagation into adjoining spaces. The fire hazard analysis should be conducted by or under the direct supervision of an engineer with the qualifications in design-basis accidents.

llPost-Fire Safe-Shutdown llThe performance objectives of the FPP related to safe shutdown after a fire are to ensure that one lsuccess path of SSCs necessary for hot shutdown is free of fire damage and to limit fire damage such that lone success path of SSCs necessary to achieve and maintain cold shutdown can be repaired or made loperable within a specified time period using onsite capabilities.

lFor reactor designs certified in 10 CFR Part 52, the plant should achieve safe shutdown with the lassumption that fire will render all equipment in any one fire area inoperable, recognizing that post-fire lreentry for repairs or operator actions will not be possible. For passive light-water reactor designs that lrely on natural circulation and heat transfer to remove reactor decay heat, SECY-94-084 and Regulatory lPosition 1.6.1.a.The guidance in Regulatory Position 1.2 is based on GDC 3, 8.3 define "safe shutdown."

llPrevention of Radiological Release llThe FPP, including the fire hazards analysis, should demonstrate that the plant will maintain the lability to minimize the potential for radioactive releases to the environment in the event of a fire. Fires lare expected to occur over the life of a nuclear power plant and, thus, should be treated as anticipated loperational occurrences as defined in Appendix A to 10 CFR Part 50. Requirements for protection lagainst radiation during normal operations appear in 10 CFR Part 20, "Standards for Protection Against lRadiation." Anticipated operational occurrences should not result in unacceptable radiological lconsequences, and the exposure criteria of 10 CFR Part 20 apply. Prevention of a radiological release lthat could result in a radiological hazard to the public, environment, or plant personnel becomes the lprimary objective for the shutdown and decommissioning FPP.

ll DG-1170, Page 37 Post-Fire Safe-Shutdown Reactor Safety/Performance Goals llPower Operations l

lOne success path of cables and equipment necessary to achieve and maintain safe shutdown lshould be maintained free of fire damage. The reactor safety and performance goals for safe shutdown lafter a fire should ensure that the specified acceptable fuel design limits are not exceeded.Section III.L lof Appendix R to 10 CFR Part 50, ASB 9.5-1, CMEB 9.5-1, GL 86-10, IN 83-41, and IN 86-106.

l1.3 Safe Shutdown Analysis Part 50 specifies post-fire reactor safety and performance goals for alternative or dedicated shutdown.

llShutdown/Refueling Operations lllText Moved Here: 1 lDuring shutdown operations, particularly during maintenance or refueling outages, fire conditions can change significantly as a result of work activities. Redundant systems important to safety

may not be available as allowed by described in plant T t echnical S s pecifications and plant procedures.

lFire protection during shutdown or refueling conditions should minimize the potential for fire events to impact safety functions (e.g., reactivity control, reactor decay heat removal, spent fuel pool cooling)

, or result in the release of radioactive materials, under the differing unusual conditions that may be present lduring these operations.

End Of Moved Text llC. REGULATORY POSITION ll1.Fire Protection Program llIn accordance with 10 CFR 50.48, each operating nuclear power plant must provide have an FPP.

lThe plan should establish the fire protection policy for the protection of SSCs important to safety at each lplant and the procedures, equipment, and personnel required to implement the program at the plant site.

llThe FPP should extend the concept of defense-in-depth to fire protection in fire areas important lto safety, with the following three objectives:

la.to prevent fires from starting lb.to detect rapidly, control, and extinguish promptly those fires that do occur lc.to provide protection for SSCs important to safety so that if the fire suppressions activities are lunable to promptly extinguish a fire, safe shutdown of the plant can still be achieved l

lIn accordance with 10 CFR 50.48, the FPP must do the following:

la.Identify the various positions within the licensee's organization that are responsible for the lprogram and state the authorities delegated to these positions. (See Regulatory Position 1.1 of lthis guide.)

lb.Describe specific features such as administrative controls and personnel requirements for fire lprevention. (See Regulatory Position 2 of this guide.)

l DG-1170, Page 38 c.Outline the plans for fire detection and suppression capability and limitation of fire damage.

l(See Regulatory Positions 1.2, 3, and 4 of this guide.)

ld.Describe personnel requirements for manual fire suppression activities.

l(See Regulatory Position 3.5 of this guide.)

le.Describe the means to limit fire damage to structures, systems, and components SSCs important lto safety so that to ensure the capability to safely shut down the reactor is ensured.

lA safe shutdown analysis should be developed that demonstrates the capability of the plant to safely shut down for a fire in any given area. The safe shutdown performance goals and reactor performance criteria applicable to safe shutdown are identified in Regulatory Positions 5.1 and 5.2 of this guide. Recommended systems and instrumentation for accomplishing safe shutdown are identified in Regulatory Positions 5.3 and 5.4 for hot shutdown and cold shutdown, respectively. The selected systems should be demonstrated to accomplish the safe shutdown functions within the fire damage guidelines of Regulatory Positions 5.3 and 5.4.

The analysis should identify the safe shutdown components and associated non-safety circuits for each fire area and demonstrate that the guidelines of Regulatory Position 5.5 are met or that alternative, dedicated, or backup shutdown is provided in accordance with Regulatory Position 5.6 of this guide. For each plant, the combinations of systems that provide the shutdown functions may be unique for each area; however, the shutdown functions provided should ensure that the safe shutdown performance objectives are achieved.

Procedures necessary to implement safe shutdown should also be developed and implemented as appropriate (see Regulatory Position 5.7).1.4 Fire Test Reports and Fire Data Fire reports and data (e.g., fire barrier testing results and cable derating data) that are used to demonstrate compliance with NRC fire protection requirements should be evaluated to ensure that the information is applicable and representative of the conditions for which the information is being applied.

NFPA 251, "Standard Methods of Tests of Fire Endurance of Building Construction and Materials," advises that the test conditions should be evaluated carefully because variations from the construction of the test specimen or from the condition in which it is tested may substantially change the performance characteristics of the tested assembly.

Relative to testing of fire barrier assemblies, not all possible configurations can be tested, and additional guidance is provided in plant. (See Regulatory Positions 1.

8.3 and 4.2 of this guide for levaluation of installed configurations that deviate from tested conditions.

The guidance in Regulatory Position 1.4 is based on GL 92-08.1.5Compensatory Measures Temporary changes to specific 3 and 5 of this guide.)

llFor reactor sites that have both an operating reactor, as well as construction, modification, or ldecommissioning of other units under way, the FPP should provide for continuing evaluation of fire lhazards associated with these activities. The licensee should provide additional fire barriers, firel DG-1170, Page 39 protection features that may be necessary to accomplish maintenance or modifications are acceptable provided interim compensatory measures, such as fire watches, temporary fire barriers, or backup suppression capability, are implemented. For common types of deficiencies, the specific compensatory measures are generally noted in technical specifications or the NRC-approved capability, and ladministrative controls as necessary to protect the operating unit(s) from any fire hazards associated with lconstruction or decommissioning activities.

ll1.1 Organization, Staffing, and Responsibilities llThe FPP should describe the organizational structure and responsibilities for its establishment land implementation. These responsibilities include FPP policy; program management (including lprogram development, maintenance, updating, and compliance verification);

fire protection program.

lFor unique situations, the appropriate compensatory measures are determined by the licensee.

Text Was Moved From Here: 5 The guidance in Regulatory Position 1.5 is based on CMEB 9.5-1, GL 86-10, GL 91-18, and IN 97-48.1.6Fire Protection Training and Qualifications The fire protection program should be under the direction of an individual staffing and lqualifications; engineering and modification; inspection, testing, and maintenance of fire protection lsystems, features, and equipment; fire prevention; emergency response (e.g., fire brigades and offsite lmutual aid); and general employee, operator, and fire brigade training.

llThe licensee should assign direction of the FPP to an individual who has been delegated lauthority commensurate with the responsibilities of the position and who has available staff personnel lknowledgeable in both fire protection and nuclear safety.

Plant personnel should be adequately trained in llThe licensee should assign overall responsibility for the FPP to a person who has management lcontrol over all organizations involved in fire protection activities. Formulation and assurance of lprogram implementation may be delegated to a staff composed of personnel prepared by training and lexperience in fire protection and personnel prepared by training and experience in nuclear plant safety to lprovide a comprehensive approach in directing the FPP for the nuclear power plant.

l lThe following positions or organizations should be designated:

la.The upper-level management position has responsibility for the formulation, implementation, and lassessment of the effectiveness of the nuclear plant FPP.

lb.Other management positions have direct responsible for formulating, implementing, and lperiodically assessing the effectiveness of the FPP for the licensees nuclear power plant,lincluding fire drills and training conducted by the fire brigade and plant personnel. The results lof these assessments should be reported to the upper-level management position responsible for lfire protection with recommendations for improvements or corrective actions as deemed lnecessary.

llText Moved Here: 2 l

DG-1170, Page 40 c.The An onsite management position is responsible for the overall administration of the lplant operations and emergency plans that include the fire protection and prevention program and that provide a single point of control and contact for all contingencies. On

sites with an operating reactor

, a nd with s well as ongoing construction, modification, or ldecommissioning of other units under way , the superintendent of the operating plant should have the lead responsibility for site fire protection.

End Of Moved Text ld.Additional onsite positions have responsibility for the following:

llText Moved Here: 3 li.Implement periodic inspections to minimize the amount of combustibles in plant areas important to safety; determine the effectiveness of housekeeping practices;

ensure the availability and acceptable condition of all fire protection

systems/equipment, emergency breathing apparatu se s, emergency lighting,lcommunication equipment, fire stops, penetration seals, and fire retardant coatings; and ensure that prompt and effective corrective actions are taken to

correct conditions adverse to fire protection and preclude their recurrence.

End Of Moved Text lii.Provide firefighting training for operating plant personnel and the plant's fire brigade; ldesign and select equipment; periodically inspect and test fire protection systems and lequipment in accordance with established procedures; and evaluate test results and ldetermine the acceptability of the systems under test.

liii.Assist in the critique of all fire drills to determine how well the training objectives have lbeen met.liv.Review proposed work activities with regard to in-plant fire protection, identify potential ltransient fire hazards, and specify required additional fire protection in the work activity lprocedure.

lv.Implement a program to indoctrinate all plant contractor personnel in appropriate ladministrative procedures that implement the fire protection program FPP and thelemergency procedures relative to fire protection.

The guidance in Regulatory vi.Implement a program to instruct personnel on the proper lhandling of accidental events such as leaks or spills of lflammable materials that are related to fire protection.

lvii.Review hot work.

l DG-1170, Page 41 e.An onsite position is responsible for fire protection QA. This position ensures the effective limplementation of the FPP by planned inspections, scheduled audits, and verification that the lresults of these inspections and audits are promptly reported to cognizant management personnel.

lf.The plant's fire brigade positions should be identified with the following in mind l(see also Regulatory Position 1.6 is based on Appendix R 3.5.1 of this guide):

li.The plant fire brigade positions should be responsible for fighting fires. The authority land responsibility of each fire brigade position relative to fire protection should be lclearly defined.

lii.The responsibilities of each fire brigade position should correspond with the actions lrequired by the firefighting procedures.

liii.Collateral responsibilities of the fire brigade members should not conflict with their lresponsibilities related to the fire brigade during a fire emergency.

liv.The minimum number of trained fire brigade members available on site for each loperating shift should be consistent with the activities required to combat credible and lchallenging fires, but should be no less than five members. The size of the fire brigade lshould be based upon the functions required to fight fires, with adequate allowance for linjuries. Fire brigade staffing should account for all operational and emergency response ldemands on shift personnel in the event of a significant fire.

ll1.2 Fire Hazards Analysis llA fire hazards analysis should be performed to demonstrate that the plant will maintain the lability to perform safe-shutdown functions and minimize radioactive material releases to the environment lin the event of a fire. This analysis should be revised as necessary to reflect plant design and operational lchanges.llThe fire hazards analysis accomplishes the following objectives:

la.considers potential in situ and transient fire hazards lb.determines the effects of a fire in any location in the plant on the ability to safely shut down lthe reactor or to minimize and control the release of radioactivity to the environment lc.specifies measures for fire prevention, fire detection, fire suppression, and fire containment land alternative shutdown capability for each fire area containing SSCs important to safety lin accordance with NRC guidelines and regulations l

l lText Moved Here: 4 lThe fire hazards analysis verifies that the applicable NRC fire protection program lguidelines regulatory requirements and guidance for the FPP have been met.

The analysis lists lapplicable elements of the program, with explanatory statements as needed to identify location, type of system, and design criteria.

The analysis should identify and justify any deviations from lthe regulatory guidelines.

Justification for deviations from the regulatory guidelines should lshow demonstrate that an equivalent level of protection will be achieved. (s S ee Regulatory lPosition 1.8 of this guide regarding when such deviations are subject to the exemption request lprocess.). Deletion of a protective feature without compensating alternative protection measures lis typically unacceptable, unless it is clearly demonstrated that the protective measure is not needed because of the design and arrangement of the particular plant.

DG-1170, Page 42 End Of Moved Text llThe fire hazards analysis should address the following elements and attributes:

la.The applicability of NRC fire protection requirements and guidance should be evaluated.

lb.In situ and potential transient fire and explosion hazards, including amounts, types,lconfigurations, and locations of flammable and combustible materials (e.g., electric cable linsulation and jacketing material, lube oil, diesel fuel oil, flammable gases, chemicals, building lmaterials and finishes) associated with operations, maintenance, and refueling activities should lbe identified. The continuity of combustible materials (e.g., exposed electrical cables that span lthe distance between redundant trains), the potential for fire spread, and sources of ignition lshould be identified and described in the analysis.

lc.External exposure hazards (e.g., flammable and combustible liquid or gas storage, auxiliary lboiler units, adjacent industrial facilities or transportation systems, natural vegetation, and ladjacent plant support facilities) that could potentially expose SSCs important to safety to ldamage from the effects (e.g., heat, flame, smoke) of fires should be identified. Wildfire hazards lshould be addressed if there is the potential for a wildfire to damage SSCs important to safety.

ld.The design, installation, operation, testing, and maintenance of automatic fire detection and lsuppression capability should be addressed. The fire hazards analysis should describe the level lof automatic protection (e.g., water spray density, gaseous agent concentration) provided relative lto the specific fire hazards that have been identified. The effects of lightning strikes should be lincluded in the design of fire detection systems.

le.The layout and configurations of SSCs important to safety should be depicted. The protection lfor safe-shutdown systems (see Regulatory Positions 5.3 and 5.4 of this guide) within a fire area lshould be determined on the basis of the worst-case fire that is likely to occur and the resulting ldamage. The fire hazards analysis should explain and document the extent of such damage. The lanalysis should consider the degree of spatial separation between redundant shutdown systems,lthe presence of in situ and transient combustibles, the available fire protection systems and lfeatures, sources of ignition, and the susceptibility to fire damage of the safe-shutdown-related lcables, equipment, systems, and features in the area. Where automatic suppression systems are linstalled, the fire hazards analysis should evaluate the effects of the postulated fire with and lwithout actuation of the automatic suppression system.

lf.Reliance on and qualifications of fire barriers, including fire test results, the quality of the lmaterials and barrier system, and the quality of the barrier installation should be described.

lRegulatory Position 4.3 of this guide provides detailed guidelines for testing and qualification of lelectrical raceway fire barrier systems.

lg.Fire area construction (walls, floor, and ceiling materials, including coatings and thicknesses; lfireproofing of structural members; area dimensions and volume; normal ventilation and smoke lremoval capability; and level of congestion as it applies to access for manual firefighting lactivities) should be described. The fire hazards analysis should provide sufficient information lto determine that fire areas have been properly selected based on the fire hazards present and the lneed for separation of SSCs important to safety. Regulatory Position 4.1.2 provides guidelines lfor fire areas and zones.

lh.Manual suppression capability, including systems (e.g., hydrants, standpipes, extinguishers), fire lbrigades, manual firefighting equipment, plans and procedures, training, drills, mutual aid, and laccessibility of plant areas for manual firefighting should be identified. The fire hazards analysis l

DG-1170, Page 43 should list the location and type of manual firefighting equipment and accessibility for manual lfirefighting.

li.Potential fire impacts on operations should be identified, including:

li.fire in control rooms or other locations where operations important to safety are lperformedlii.fire conditions that may necessitate evacuation from areas that are required to be lattended for safe shutdown liii.lack of adequate access or smoke removal facilities that impede plant operations or fire lextinguishment in plant areas important to safety lj.Potential disabling effects of fire suppression systems on safe-shutdown capability should be lidentified. The term "damage by fire" in Appendix R also includes damage to equipment from lthe normal or inadvertent operation of fire suppression systems. The fire hazards analysis should laddress the effects of firefighting activities. GDC 3 of Appendix A to 10 CFR Part 50 andlCMEB 9.5-1.1.6.1Fire Protection Staff states that "Fire-fighting systems shall be designed to assure that ltheir rupture or inadvertent operation does not significantly impair the safety capability of these lstructures, systems, and components."

lk.Explosion-prevention measures in areas subject to potential explosive environments from lflammable gases or other potentially energetic sources (e.g., chemical treatment systems,lion exchange columns, high-voltage electrical equipment) should be listed.

ll.The availability of oxygen (e.g., inerted containment) should be identified.

lm.Alternative or dedicated shutdown capability for those fire areas where adequate separation of lredundant safe-shutdown systems cannot be achieved should be identified.

llFire initiation should be postulated at the location within each fire area/zone that will produce the lmost severe fire with the potential to adversely impact SSCs important to safety. Fire development lshould consider the potential for involvement of other combustibles, both fixed and transient, in the fire larea. Where automatic suppression systems are installed, the effects of the postulated fire should be levaluated with and without actuation of the automatic suppression system.

l l"Worst-case" fires need not be postulated to be concurrent with non-fire-related failures in safety lsystems, other plant accidents, or the most severe natural phenomena.

l lOn multiple-reactor sites, unrelated fires in two or more units need not be postulated to occur lsimultaneously. Fires involving facilities shared between units and fires caused by manmade site-related levents that have a reasonable probability of occurring and affecting more than one reactor unit (such as lan aircraft crash) should be considered.

l lThe fire hazards analysis should separately identify hazards and provide appropriate protection in llocations where losses of SSCs important to safety can occur as a result of the following:

la.concentrations of combustible contents, including transient fire hazards of combustibles expected lto be used in normal operations, such as refueling, maintenance, and modifications l

DG-1170, Page 44 b.continuity of combustible contents, furnishings, building materials, or combinations thereof in lconfigurations conducive to fire spread lc.exposures to fire, heat, smoke, or water, including those that may necessitate evacuation from lareas that are required to be attended for safe shutdown ld.fire in control rooms or other locations having critical functions important to safety le.lack of adequate access or smoke removal facilities that impede plant operations or fire lextinguishment in plant areas important to safety lf.lack of explosion-prevention measures lg.loss of electric power or control and instrumentation circuits lh.inadvertent operation of fire suppression systems lQualified fire protection and reactor systems engineers should perform the fire hazards analysis.

lIdentifying fire hazards and the consequences of a postulated fire starting at any location in the plant lrequires experienced judgment. Persons who are thoroughly trained and experienced in reactor safety are lable to evaluation the consequences of the postulated fire on nuclear safety. The person conducting the lanalysis of fire hazards should be thoroughly trained and experienced in the principles of industrial fire lprevention and control and in fire phenomena from fire initiation, through its development, to lpropagation into adjoining spaces. The fire hazards analysis should be conducted by or under the direct lsupervision of an engineer with the qualifications listed in Regulatory Position 1.6.1.a of this guide.

ll1.3 Safe-Shutdown Analysis llIn accordance with 10 CFR 50.48, each operating nuclear power plant must provide the means to llimit fire damage to SSCs important to safety so that the capability to safely shut down the reactor is lensured.lLicensees should develop a safe-shutdown analysis to demonstrate the capability of the plant to lsafely shut down for a fire in any given area. Regulatory Position 5.1 of this guide identifies the safe-lshutdown performance goals. The licensee should demonstrate the ability of the selected systems to laccomplish these performance goals.

lThe analysis should identify the safe-shutdown components and circuits for each fire area and ldemonstrate that the guidelines of Regulatory Position 5.3 are met or that alternative, dedicated, or lbackup shutdown is provided in accordance with Regulatory Position 5.4 of this guide. For each plant,lthe combinations of systems that provide the shutdown functions may be unique for each area; however,lthe shutdown functions provided should ensure that the safe-shutdown performance objectives are lachieved.lThe licensee should also develop and implement procedures necessary to implement safe lshutdown as appropriate. (See Regulatory Position 5.5 of this guide.)

ll1.4 Fire Test Reports and Fire Data llThe licensee should evaluate fire reports and data (e.g., fire barrier testing results and cable lderating data) that are used to demonstrate compliance with NRC fire protection requirements to ensure lthat the information is applicable and representative of the conditions for which the information is being lapplied.lNFPA 251 advises that test conditions should be evaluated carefully because variations from the lconstruction of the test specimen or from the condition in which it is tested may substantially change the lperformance characteristics of the tested assembly.

l DG-1170, Page 45 Relative to testing of fire barrier assemblies, not all possible configurations can be tested; lRegulatory Positions 1.8.3 and 4.3 of this guide provide additional guidance for evaluating installed lconfigurations that deviate from tested conditions.

ll1.5 Compensatory Measures llTemporary changes to specific fire protection features that may be necessary to accomplish lmaintenance or modifications are acceptable, provided interim compensatory measures, such as fire lwatches, temporary fire barriers, or backup suppression capability, are implemented. For common types lof deficiencies, the technical specifications or the NRC-approved FPP generally note the specific lcompensatory measures. For unique situations or for measures that the approved FPP does not include,lthe licensee may determine appropriate compensatory measures. A licensee may opt to implement an lalternative compensatory measure, or combination of measures, to the one stated in its FPP. A licensee lmay implement such alternative measures without prior approval of the Commission if all of the lfollowing are available:

la.a documented evaluation showing the impact of the new compensatory measure lb.a documented evaluation comparing the new compensatory measure to the compensatory lmeasure required by the licensee's FPP lc.evaluations showing that the new compensatory measure(s) will not adversely affect the ability lof the plant to achieve and maintain safe shutdown in the event of a fire llAny change to the FPP must comply with the GDC and the requirements of 10 CFR 50.48(a) and lmust be retained as a record pursuant to 10 CFR 50.48(a). The licensee's change to the FPP is subject to linspection by the NRC.

l lThe evaluation of the alternate compensatory measure should incorporate risk insights regarding lthe location, quantity, and type of combustible material in the fire area; the presence of ignition sources land their likelihood of occurrence; the automatic fire suppression and fire detection capability in the fire larea; the manual fire suppression capability in the fire area; and the human error probability where lapplicable.

l l

lText Moved Here: 5 lC The licensee may implement c ompensatory measures may also be implemented for degraded land nonconforming conditions. In its evaluation of the impact of a degraded or nonconforming condition on plant and individual SSC operation and on operability of structures, systems, and components , allicensee may decide to implement a compensatory measure as an interim step to restore operability or to otherwise enhance the capability of structures, systems, and components SSCs important to safety untillthe final corrective action is complete. Reliance on a compensatory measure for operability should be an important consideration in establishing the "reasonable time frame""reasonable timeframe" to complete lthe corrective action process.

As stated in Revision 1 of GL 91-18, t T he NRC would normally expect lthat conditions that require interim compensatory measures to demonstrate operability would to belresolved more promptly than conditions that are not dependent on compensatory measures to show operability , because; such reliance suggests a greater degree of degradation. Similarly, if an operability ldetermination is based upon operator action, the NRC staff would expect the nonconforming condition to lbe resolved expeditiously. (See Regulatory Position 1.8.5 for additional guidance on operability lassessments.)

lEnd Of Moved Text ll DG-1170, Page 46 NRC Inspection Manual Part 9900, "Operability Determinations & Functionality Assessments lfor Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety" provides ladditional guidance on operability assessments that the Reactor Oversight Process will apply when lconducting inspections. This guidance supersedes the guidance provided in Revision 1 of GL 91-18,l"Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded land Nonconforming Conditions and on Operability."

ll1.6 Fire Protection Training and Qualifications lllThe FPP should be under the direction of an individual who has available staff personnel lknowledgeable in both fire protection and nuclear safety. Plant personnel should be adequately trained in lthe administrative procedures that implement the FPP and the emergency procedures relative to fire lprotection.

l l1.6.1 Fire Protection Staff Training and Qualifications llFire protection staff should meet the following qualifications

la.The formulation and assurance of the fire protection program FPP and its implementation should lbe the responsibility of personnel prepared by training and experience in fire protection and in nuclear plant safety to provide a comprehensive approach in directing the fire protection program FPP for the nuclear power plant. A fire protection engineer (or a consultant) who is a lgraduate of an engineering curriculum of accepted standing and satisfies the eligibility requirements as a Member in the Society of Fire Protection Engineers (SFPE) should be a lmember of the organization responsible for the formulation and implementation of the firelprotection program FPP.lb.The fire brigade members

qualifications should include satisfactory completion of a physical lexamination for performing strenuous activity and the fire brigade training as described in lRegulatory Position 1.6.4.c.The personnel responsible for the maintenance and testing of the fire protection systems should be qualified by training and experience for such work.d.The personnel responsible for the training of the fire brigade should be qualified by knowledge, suitable training, and experience for such work.

The guidance in Regulatory Position 1.6.1 is based on CMEB 9.5-1.

1.6.2 General Employee Training llEach nuclear plant employee has a responsibility in to the prevention prevent , detection detect , andlsuppression of suppress fires. Site g G eneral site employee training should introduce all personnel to the lelements of the site fire protection program

's FPP , including the responsibilities of the fire protection lstaff. Instruction Training should be provided also include information on the types of fires and related l

DG-1170, Page 47 extinguishing agents, specific fire hazards at the site, and actions in the event of a fire suppression system actuation.

General employee training should provide specific instruction to site and contractor personnel on the following:

a.A a ppropriate actions to take upon discovering a fire, including, for example, notification of the lcontrol room, attempt attempting to extinguish the fire, and actuation of local fire suppression lsystems.lb.A a ctions upon hearing a fire alarm

llc.A a dministrative controls on the use of combustibles and ignition sources

andlld.The actions necessary in the event of a combustible liquid spill or gas release/leaks.

The guidance in Regulatory Position 1.6.2 is based on IP 64704.

1.6.3 release or leaks ll1.6.3 Fire Watch Training llFire watches provide for observation and control of fire hazards associated with hot work, or andlthey may act as compensatory measures for degraded fire protection systems and features. Specific fire watch training should provide instruction on fire watch duties, responsibilities, and required actions for

both 1-hour roving and continuous fire watches. Fire watch qualifications should include hands-on

training on a practice fire with the extinguishing equipment to be used while on fire watch. If fire

watches are to be used as compensatory actions, the fire watch training should include record

-keeping requirements.

The guidance in Regulatory Position 1.6.3 is in GL 93-03 and IP 64704.

DG-1170, Page 48 1.6.4 Fire Brigade Training and Qualifications llThe fire brigade training program should ensure that establish and maintain the capability to fight lcredible and challenging fires is established and maintained. The program should consist of initial classroom instruction followed by periodic classroom instruction, firefighting practice, and fire drills. l(s S ee Regulatory Position 3.5.1.4 for drill guidance

.). lNumerous NFPA standards provide guidelines applicable to the training of fire brigades.

T ThelNRC staff considers t he training recommendations of NFPA 600, ""Standard on Industrial Fire lBrigades,"" including the applicable NFPA publications referenced in NFPA 600, are considered to belappropriate criteria for training of the plant fire brigade.

The licensee may also use NFPA 1410,l"Standard"Standard on Training for Initial Fire Attack," may also be used as applicable Emergency Scene lOperations," and NFPA 1500, "Standard on Fire Department Occupational Safety and Health Program" las appropriate. NFPA booklets and pamphlets listed in NFPA 600 may be used

, as applicable

, forltraining references. In addition, the licensee should use courses in fire prevention and fire suppression lthat are recognized or sponsored by the fire protection industry should be used

.1.6.4.1 Qualifications. llThe brigade leader and at least two brigade members should have sufficient training in or lknowledge of plant systems to understand the effects of fire and fire suppressants on safe

-shutdownlcapability. The brigade leader should be competent to assess the potential safety consequences of a fire and advise control room personnel. Such competence by the brigade leader may be evidenced by

possession of an operator

s license or equivalent knowledge of plant systems. Nuclear power plants lstaffed with a dedicated professional fire department may utilize a fire team advisor to assess the potential safety consequences of a fire and advise the control room and incident commander. The fire

team advisor should possess an operator

s license or equivalent knowledge of plant systems and be ldedicated to supporting the fire incident commander during fire emergency events.

The qualification of fire brigade members should include an annual physical examination to determine their ability to perform strenuous firefighting activities.

DG-1170, Page 49 1.6.4.2 Instruction

. The instruction llInstruction should be provided by qualified individuals who are knowledgeable, experienced, and lsuitably trained in fighting the types of fires that could occur in the plant and in using the types of equipment available in the nuclear power plant.

I The licensee should provide i nstruction should be lprovided to all fire brigade members and fire brigade leaders.

The initial classroom instruction should include the following

la.I i ndoctrination of the plant firefighting plan with specific identification of each individual

slresponsibilities.

b.I i dentification of the type and location of fire hazards and associated types of fires that could loccur in the plant. c.T t he toxic and corrosive characteristics of expected products of combustion ld.ld.Identification identification of the location of firefighting equipment for each fire area and lfamiliarization with the layout of the plant, including access and egress routes to each area. l DG-1170, Page 50 e.T t he proper use of available firefighting equipment and the correct method of fighting each type lof fire , including the following

li.F f ires involving radioactive materials

,llii.F f ires in energized electrical equipment

,lliii.F f ires in cables and cable trays

,lliv.H h ydrogen fires

,llv.F f ires involving flammable and combustible liquids or hazardous process chemicals

,llvi.F f ires resulting from construction or modifications (welding), and llvii.R r ecord file fires. llf.T t he proper use of communication, lighting, ventilation, and emergency breathing equipment

.lg.T t he proper method for fighting fires inside buildings and confined spaces

.lh.T t he direction and coordination of the firefighting activities (fire brigade leaders only)

.li.D d etailed review of firefighting strategies and procedures. lj.R r eview of the latest plant modifications and corresponding changes in firefighting plans

.lTraining The licensee should coordinate training of the plant fire brigade should be coordinated lwith the local fire department so that responsibilities and duties are delineated in advance. This coordination should be part of the training course and should be included in the training of the local fire

department staff.

Instruction should provide the techniques, equipment, and skills for the use of water in fighting electrical cable fires in nuclear plants, particularly in areas containing a high concentration of electric

cables with plastic insulation.

DG-1170, Page 51 Regular The licensee should hold regularly planned meetings should be held at least quarterly for lall brigade members to review changes in the fire protection program FPP and other subjects as necessary.

lP The licensee should offer p eriodic refresher training sessions should be held to repeat the lclassroom instruction program for all brigade members over a two-year 2-year period. These sessions lmay be concurrent with the regular ly planned meetings.

lR The licensee should schedule r etraining or broadened training for fire fighting firefighting lwithin buildings should be scheduled for all those brigade members whose performance records show deficiencies.

1.6.4.3 Fire Brigade Practice

.llThe P licensee should hold p ractice sessions should be held for each shift fire brigade on the lproper method of fighting the various types of fires that could occur in a nuclear power plant.

Theselsessions should provide brigade members with experience in actual fire extinguishment and the use of self-contained breathing apparatus es under the strenuous conditions encountered in firelfighting firefighting. T The licensee should provide t hese practice sessions should be provided at leastlonce per year for each fire brigade member.

1.6.4.4 Fire Brigade Training Records

.llThe I licensee should maintain i ndividual records of training provided to each fire brigade lmember, including drill critiques, should be maintained for at least 3 years to ensure that each member receives training in all parts of the training program.

These records of training should be available for lNRC review.

The guidance in Regulatory Position 1.6.4 is based on Appendix R to 10 CFR Part 50, APCSB 9.5-1, and CMEB 9.5-1.1.7Quality Assurance lThe quality assurance (overall plant QA plan should include the QA) program for fire protection lshould be part of the overall plant QA program. For fire protection systems, the licensee should have and maintain a QA program that provides assurance that the fire protection systems are designed, fabricated, erected, tested, maintained, and operated so that they will function as intended. Fire protection systems

are not "safety-related""safety-related" and are , therefore , are not within the scope of Appendix B

,l"Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants,"

to 10 CFR Part 50,lunless the licensee has committed to include these systems under the plant's Appendix B program for t. lT he plant. NRC staff generally used guidance for an acceptable QA program for fire protection systems,lpreviously given in Section C.4 of Branch Technical Position BTP CMEB 9.5-1, Rev.Revision 2,ldated issued July 1981, was generally used in the review and acceptance of approved fire protection lprograms FPPs for plants licensed after January 1, 1979.

This regulatory guide incorporates that guidance land the NRC staff will continue to use it in the review and acceptance of approved FPPs for new lreactors. For plants licensed prior to January 1, 1979, similar guidance is specified in APCSB 9.5-1 and lAppendix A thereto and in Generic Letter GL 77-02, "Nuclear"Nuclear Plant Fire Protection Functional lResponsibilities, Administrative Controls and Quality Assurance

," specify similar guidance

."l DG-1170, Page 52 The QA program should be under the management control of the plant's QA organization shouldlmanage the fire protection QA program

. This control consists of (1) formulating and/or verifying that the lfire protection QA program incorporates suitable requirements and is acceptable to the management responsible for fire protection

, and (2) verifying the effectiveness of the QA program for fire protection lthrough review, surveillance, and audits.

Performance of Personnel outside the QA organization may lperform other QA program functions for meeting the fire protection program requirements may be lperformed by personnel outside of the QA organization.

to meet the FPP requirements.

lTo implement the F f ire P p rotection QA P p rogram in this Regulatory Position, licensees have the loption of either (1) including the fire protection QA program as part of the plant's overall QA program under Appendix B to 10 CFR Part 50

, or (2) providing for NRC review a description of the fire lprotection QA program and the measures for implementing t its implementation measure.

lT he fire protection QA program.lThe fire protection QA program should satisfy the specific criteria. These criteria that apply tolitems within the scope of the fire protection program FPP , such as fire protection systems and features,lemergency lighting, communication and self-contained breathing apparatus es , as well as and the firelprotection requirements of applicable equipment important to safety.

1.7.1 Design and Procurement Document Control llMeasures The licensee should be established establish measures to include the guidance lof presented in this g Regulatory G uide in its design and procurement documents and that deviations ltherefrom are controlled such that:

a.. The licensee should also control deviations from this guidance such that the following occurs:

la.Design and procurement document changes, including field changes and design deviations, are lsubject to the same level of controls, reviews, and approvals that were applicable to the original document.lb.Quality standards are specified in t T he design documents, such as appropriate fire protection lcodes and standards, specify quality standards, and deviations and changes from these quality lstandards are controlled.

c.N Qualified personnel review n ew designs and plant modifications, including fire protection lsystems, are reviewed by qualified personnel to ensure inclusion of appropriate fire protection requirements. These reviews should include items such as the following

l*D i.d esign reviews to verify adequacy of wiring isolation and cable lseparation criteria. *Dl DG-1170, Page 53 ii.d esign reviews to verify appropriate requirements for room isolation (sealing l penetrations, floors floors , and other fire barriers). ld.AlSee Regulatory Position 1.8 for guidance on FPP changes and code deviations.

ld.Qualified personnel perform and document the review and approval of the adequacy of fire lprotection requirements and quality requirements stated in procurement documents are performed and documented by qualified personnel. This review should determine that fire protection requirements and quality requirements are correctly stated, inspect a i ble, andlcontrollable; there are adequate acceptance and rejection criteria; and the procurement document has been prepared, reviewed, and approved in accordance with applicable QA program

requirements.

1.7.2 Instructions, Procedures, and Drawings llI Documented instructions, procedures, or drawings should prescribe i nspections, tests,ladministrative controls, fire drills, and training that govern the fire protection program should be prescribed by documented instructions, procedures, or drawings and should be accomplished in accordance with these documents such that:

FPP and the licensee should ensure the following:

la.Indoctrination and training programs for fire prevention and fire fighting firefighting arelimplemented in accordance with documented procedures.

b.Activities such as design, installation, inspection, test, maintenance, and modification of fire protection systems are prescribed and accomplished in accordance with documented instructions, procedures, and drawings.

c.Instructions and procedures for design, installation, inspection, test, maintenance, modification, and administrative controls are reviewed to ensure that the proper fire protection requirements

are addressed, such as control of ignition sources and combustibles, provisions for backup fire

protection capability, disabling disablement of a fire protection system, and the restriction on lmaterial substitution unless specifically evaluated.

d.The installation or application of penetration seals, fire barrier systems, and fire retardant coatings is performed by trained personnel using approved procedures.

DG-1170, Page 54 1.7.3 Control of Purchased Material, Equipment, and Services llMeasures The licensee should be established establish the following measures to ensure that lpurchased material, equipment, and services conform to the procurement documents. These measures should include

a.P p rovisions, as appropriate, for source evaluation and selection, objective evidence of quality lfurnished by the contractor, inspections at suppliers, or receipt inspections

.b.S s ource or receipt inspection, a s t a minimum, for those items whose quality cannot be verified lafter installation.

1.7.4 Inspection A that, once installed, cannot have their quality verified ll1.7.4 Inspection llThe licensee should establish and execute a program for independent inspection of activities laffecting fire protection should be established and executed by, or for, that allows the organization lperforming the activity to verify conformance to documented installation drawings and test procedures for accomplishing activities. This program should include the following

la.I i nspection s of:l*Installation installation , maintenance, and modification of fire protection systems or lfeatureslb.l *Emergency inspection of emergency lighting and communication equipment to lensure conformance to design and installation requirements lc. lb.Inspection inspection of penetration seals, fire barriers, and fire retardant coating linstallations to verify the activity is satisfactorily completed. cld.I i nspections of cable routing to verify conformance with design requirements. ld e.I i nspections to verify that appropriate requirements for room isolation (sealing penetrations,lfloors, and other fire barriers) are accomplished during construction lf. l DG-1170, Page 55e.Measures measures to ensure that inspection personnel are independent from the lindividuals performing the activity being inspected and are knowledgeable in the design and installation requirements for fire protection. flg.I i nspection procedures, instructions, and check lists that provide for the following

l*I i.i dentification of characteristics and activities to be inspected

.l *Ilii.i dentification of the individuals or groups responsible for performing the inspection loperation.*Aliii.a cceptance and rejection criteria

.l*Aliv.a description of the method of inspection

.l *Rlv.r ecording of evidence of completing the completion and verifying verification of almanufacturing, inspection, or test operation

.*Rlvi.r ecording of inspector or data recorder and the results of the inspection operation lh. lg.Periodic periodic inspections of fire protection systems, emergency breathing and lauxiliary equipment, emergency lighting, and communication equipment to ensure the acceptable condition of these items. hli.P p eriodic inspection of materials subject to degradation

, such as fire barriers, stops, seals, and lfire retardant coatings to ensure that these items have not deteriorated or been damaged

.l DG-1170, Page 56 1.7.5 Test and Test Control llA test program The licensee should be establish ed and implemented implement a test program tolensure that testing is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements.

The tests should be performed in accordance with written test lprocedures; test results should be properly evaluated and corrective act ed on ions taken as necessary. Theltest program should include the following

la.Installation Testing - Following Testing-Following construction, modification, repair or lreplacement, the licensee should perform sufficient testing should be performed to demonstrate lthat fire protection systems, emergency lighting, and communication equipment will perform satisfactorily in service and that design criteria are met. Written test procedures for installation

tests should incorporate the requirements and acceptance limits contained in applicable design ldocuments.

b.Periodic testing - T Testing-The licensee should develop and document t he schedules and lmethods for periodic testing are developed and documented. F Periodic testing of f ire protection lequipment, emergency lighting, and communication equipment are tested periodically to willlensure that the equipment will function properly and continue to meet the design criteria.c.Programs are established for QA/QC c.Quality Assurance-The licensee should establish lprograms for QA and quality control (QC) to verify ltesting of fire protection systems and features and to verify that determine whether test personnel are leffectively trained.

d.Testld.Documentation-A qualified individual or group should be responsible for ensuring that test lresults are documented, evaluated, and their acceptability determined by a qualified responsible individual or group.

1.7.6 acceptable.

ll1.7.6 Inspection, Test, and Operating Status llMeasures The licensee should be established establish measures to provide for the documentation lor identification of items that have satisfactorily passed required tests and inspections.

These measures lshould include provisions for identification by means of tags, labels, or similar temporary markings to indicate completion of required inspections and tests and operating status.

1.7.7Nonconforming Items llMeasuresThe licensee should be established establish measures to control items that do lnot conform to specified requireme nts to prevent inadvertent use or installation. These measures should include provisions to ensure thatthe following

l DG-1170, Page 57a.Nonconforming, inoperative, or malfunctioning fire protection systems, emergencylighting, and communication equipment are appropriately tagged or labeled.

b.The identification, documentation, segregation, review disposition, and notification to theaffected organization of nonconforming materials, parts, co mponents, or services areprocedurally controlled.

c.Documentation identifies the nonconforming item, describe s the nonconformance and thedisposition of the nonconforming item

, and includes signature a pproval of the disposition.

ld.Provisions are established to identify those individuals or groups delegated theresponsibility and authority for the dis position and approval of nonconforming items.

1.7.8Corrective Action llMeasuresThe licensee should be established establish measures to ensure that conditionsl adverse to fire protection, such as failures, malfunctions, deficiencies , deviations, defective components, uncontrolled combustib le materials, and nonconformances, are promptly identified, reported, and corrected. Thes e measures should ensure thatthe following

la.Procedures are established for evaluation of conditions adverse to fi re protection (such as nonconformance, failures, malf unctions, deficiencies, devia tions, and defective materialand equipment) to determine the necessary corrective action.

b.In the case of significant or repetitive conditi ons adverse to fire protection, including fire incidents, the cause of the conditions is determined and analyzed

, and prompt corrective actions are taken to preclude recurrence.

The cause of the condition and the correctivelaction taken are promptly reported to cognizant levels of management for review and assessment.

DG-1170, Page 58 1.7.9Records llRecordsThe licensee should be prepare d and maintainedmaintain records to furnish levidence that the plant is meeting the criteria enumerated above are being met for activities laffecting the fire protection program suchFPP so that the following is true

la.Records are identifiable and retrievable and should demonstrate conformance to fire protection requirements.

The records should include results of inspections, tests, reviews,land audits; non

-conformance and corrective action reports; construc tion, maintenance, and modification records; and certified manufacturers

data. lb.R Established r ecord retention requirements are established.

l1.7.10 Audits Audits should be c onducted and documentedexist.ll1.7.10 AuditsllThe licensee should conduct and document audits to verify compliance with the firelprotection program such thatFPP and ensure the following

la.Audits are performed to verify compliance with the administrative controls andimplementation of quality assurance QA criteria, including design and procurement ldocuments, instructions, procedures, drawings, and inspection and test activities as they apply to fire protection features and safe

-shutdown capability. These audits are lperformed by QA personnel perform these audits in accordance with preestablished lwritten procedures or check lists and conducted by. The trained personnel who conduct lthe audits should not having have direct responsibilities in the areas being audited.

lb.Audit results are documented and then reviewed with management that has responsibility in responsible for the area audited.

lc.Follow-up action is taken by responsible management to correct the deficien cies revealedby the audit.

d.Audits are performed annually to provide an overall assessment of conformance to fire protection requirements.

DG-1170, Page 59 F A qualified audit team should perform f ire protection audits should be performed by a lqualified audit team. The team should at the least include at least a lead auditor from thellicensees QA organization, a systems engineer, and a fire protection engineer. The lead auditorlshould be qualified, for example, per in accordance with American Society of Mechanical lEngineers (ASME) NQA-1, "Quality Assurance Program Requirements for Nuclear Facilities"l(or an alternative consistent with the general quality assurance QA program requirements). Thelsystems engineer should be knowledgeable in safety systems, operating procedures, andemergency procedures. The fire protection engineer s (or engineering consultant) should meet the qualifications for membership in the Society of Fire Protection Engineers at the grade of m M ember. in the SFPE The fire protection engineer can be a licensee employee who is has notlbeen directly responsible for the site fire protection program's FPP for two 2 out of three 3 years. lHowever , but should beevery third year an outside independent fire pr otection consultant everylthird year should be part of the audit team. This audit team approach will ensure that theltechnical requirements as well as the and QA requirements are adequately assessed.lInsurance company inspections typically do not satisfy any of the fire protection auditrequirements because they do not evaluate plant fire protection programsFPPs against the NRClrequirements, including the requirements for post-fire safe

-shutdown. Insurance companyl inspections do not reassess or re

-evaluate the fire protection programFPP, since the insurancelcompany has already agreed to insure the licensee

s program as it is being implemented. lInsurance company inspections are generally limited to checking systems and materials for

proper condition a nd maintenance

, and inspecting hazardous c onditions related to property protection and life. However, if the insurance company develops an inspection that has the proper scope and the inspection team includes a person knowledgeable in nuclear safety, aninsurance company may perform these audits in conjunction with a lead auditor from the licensees QA organization.l ThreeThe following paragraphs specify three distinct fire protection audits are specified lbelow. Originally, licensees were required to incorporate these audits into their T technicallS s pecifications, consistent with Standardized Technical Specification Section 6.5.2.8, i Items h, i,land j. Some licensees may have elected to relocate technical specification requirements related

to review and audit requirements to the ir QA plan. Incorporation of such requirements into thelQA plan may revise existing technical specifica tion audit frequencies by implementation of aperformance-based schedule. Exceptions to th e allowable use of performance-based audit frequencies include the triennial audit of fire protection plansFPPs, conducted by outsidel qualified fire consultant s, which should be maintained in accordance with technical specification requirements.1.7.10.1Annual Fire Protection Audit

. l lFor those licensees who have relocated audit requirements from their T technicallS specifications to the QA program, " annual" fire protection audits may be changed to al"maximum"maximum interval of 24 months

"" by implementation of a performance-basedlschedule, if justified by performance reviews, provided that the maximum audit interval does notexceed the 2-year interval specified in ANSI N18.7.

DG-1170, Page 60 The elements that should be incorporated in the American National Standards lInstitute/American Nuclear Society (ANSI/ANS) 3.2-1994, "Adminis trative Controls and Quality lAssurance for the Operational Phase of Nuclear Power Plants." The annual audit are shouldlincorporate the following elements

la.Purpose -- The Purpose-The purpose of the annual audit is to assess the plant fire lprotection equipment and program implementation to verify that a level of safetyconsistent with NRC guidelin es continues to be provided.

b.Scope -- Each Scope-Each audit should verify that the commitments of the SAR safetylanalysis report and that the requirements of the T technical S specifications and license lconditions have been met and that modifications to systems and structures or changes inoperating procedures have not decreased the level of safety in the plant. The audit should include inspection of all plant areas for which fire protecti on is provided and, inparticular, examination of fire barriers, fire detection systems, and fire extinguishingsystems provided for equipment important to safety. The audit should verify that thelfollowing: l DG-1170, Page 61i.The installed fire protection system s and barriers are appropriate for the objectsprotected by comparing them to NRC guidelines and SER-a pproved alternativesand noting any deviations. SSCs important to safety based on a comparison with NRC regulatory requirements and the lapproved FPP. Devia tions should be noted.

lii.The fire hazard in each fire area has not increased above that which wasthe safety lanalysis report specified in the SAR

. liii.Regularly scheduled maintenance is performed on plant fire protection systems.

iv.Identified deficiencies have been promptly and adequately corrected.

v.Special permit procedures (hot work, valve positioning) are being followed.

vi.Plant personnel are receiving appropriate training in fire prevention andfirefighting procedures and the training program is consis tent with approved standards. (The audit team should witness a typical training session.)

lvii.Plant response to fire emergencies is adequate by analyzingbased on an analysis of lincident records and witnessing an unplanned fire drill.

viii.Administrative controls are limiting transient combustibles in areas important tosafety. ix.Problem areas identified in prev ious audits have been corrected.The audit should analyze all problem areas identified by the audit and recommend appropriate fire protecti on measures to provide a level of safety consistent with NRC guidelines.

l1.7.10.2 24-Month Fire Protection Audit. llThe purpose of the 24-month audit of the fire protection programFPP and implementingl procedures is to should ensure that the requirements for design, procurement, fabrication,linstallation, testing, ma intenance, and administrative controls for the respective programs continue to be are included in the plant QA program for fire protection and meet the criteria of thelQA/QC program established by the licensee, consistent with this guide.

These audits should beperformed by p P ersonnel from the licensee

s QA organization

, who do not have directl DG-1170, Page 62responsibility for the program being evaluated, should perform these audit ed s. These audits lwould normally encompass an evaluation of existing programmatic documents to verify continued adherence to NRC requirements.

1.7.10.3 Triennial Fire Protection Audit. llThe triennial audit is basically the same as the annual a udit; the difference lies in the lsource of the auditors. The annual audit may be performed by q Qualified utility personnel who lare not directly responsible for the site fire protection programFPP or by an outside independent lfire protection consultant. T may perform t he triennial annual audit should be performed by. lHowever, an outside independent fire protection consultant should perform the triennial audit. lThese audits would normally encompass an evaluation of existing documents (other than those addressed under the 24-month audit) plus and an inspection of fire protection system operability,linspection of the integrity of fire barriers, and witnessing the pe rformance of procedures to verifythat the fire protection programlicensee has been fully implemented the FPP and that the plan isladequate for the objects protected.

Duplicate audits are not required , (i.e., the 3-year audit lreplaces the

" annual audit

" for the year in which it is performed

).lThe guidance in Regulatory Position 1.7 is based on CMEB 9.5-1, AL 95-06. GL 82-21,and GL 86-10.1.8Fire Protection Program Changes/Code Deviations lThis section provides guidance relative to the regulatory mechanisms for addressingchanges, deviations, exemptions, and other issues affecting compliance with fire protectionregulatory requirements.

Risk-informed, performance-based methodologies may be used to levaluate the acceptability of FPP changes; howev er, the licensee should use NRC reviewed and lapproved methodologies and accepta nce criteria for this approach. Regulatory Guide 1.174 lincludes guidance for risk-informed changes to a plant's current licensing basis. This section lprovides guidance with respect to fire modeling and Appendix B provides guidance with respect lto probabilistic risk assessment.

l1.8.1Safety Evaluations llIf thean existing plant licensee has adopted the standard license condition for firelprotection and incorporated the fire protection programFPP in the final safety analysis report l(FSAR), the licensee may make changes to the approved fire protection programFPP without thelCommission's prior approval of the Commission only if those changes would not adversely laffect the ability to achieve and maintain safe shutdown in the event of a fire as documented in a safety evaluation. In addition to planned changes, a safety evaluation may also be required fornonconforming conditions. An FPP change is any change to plant hardware or plant program ldocuments and procedures that impacts the FPP. In addition to changes directly related to fire lprotection, this type of change may include plant changes that are not directly associated with the lfire protection system or procedures but that could, for example, impact the results of the post-lfire, safe-shutdown circuit analysis. Another example of an FPP change is an in situ condition l(physical or programmatic) that is an FPP regulatory noncompliance or a fire protection l

DG-1170, Page 63licensing-basis noncompliance and which the licen see does not intend to correct via a plant or lprogrammatic modification.

lGeneric Letter GL 86-10 recommended that licensees incorporate the fire protection lprogramFPP in the facility Final Safety Analysis Report (FSAR). Incorporation of the firelprotection programFPP and major commitments, including the fire hazards analysis, by referencel in to the FSAR for the facility places the fire protection programFPP, including the systems, theladministrative and technical controls, the organization, and other plan t features associated with fire protection on a consistent status with other plant features described in the FSAR.

GenericLetter GL 86-10 further recommended the adoption of the standard license condition (seelRegulatory Position 1.8.1.2 of this guide), requiring licensees to comply with the provisions ofl the approved fire protection programFPP as described in the FSAR and establishing when NRClapproval for changes to the program is required.

The licensee should maintain, in auditable form, a current record of all such changes,including an analysis of the effects of the change on the standard fire protection program, and lshould make such records available to NRC Inspectors upon request. All changes to theapproved program should be reported, along with the FSAR revisions required by 10 CFR 50.71(e).1.8.1.1 Non-Standardlicense condition recommended by GL 86-10 is not applicable to lthe FPP for new reactors that are licensed in accordance with 10 CFR Part 52. Changes to new lreactor FPPs that do not require exemption requests should be evaluated and processed in laccordance with 10 CFR 50.59. The appendices to 10 CFR Part 52 include additional lrequirements for processing changes and exemptions for new reactors that are based on a lcertified design.

l l1.8.1.1Nonstandard License Condition

. llIf the fire protection programFPP committed to by the licensee is required by a specificllicense condition and is not part of the FSAR for the facility, the licensee s may be required tolsubmit amendment requests even for relatively minor changes to the fire protection programFPP.l DG-1170, Page 64 1.8.1.2 Standard License Condition

.llThe TNRC transmitted t he standard license cond ition for fire protection was transmitted lto licensees in April 1986 as part of Generic Letter GL 86-10 with information on its applicability lto specific plants. The standard license condition reads as follows:Fire Protection l(Name of Licensee) shall implement and maintain in effect all provisions lof the approved fire protection program as described in the Final Safety lAnalysis Report for the facility (or as described in submittals dated -------

l---) and as approved in the SER dated -----------

(and Supplements dated --

l-------) subject to the following provision:The licensee may make changes to the approved fire lprotection program without prior approval of theCommission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

The adoptionGL 88-12 provides additional guidance for implementation of the standard llicense condition in conjunction with the incorporation of the fire protection program in theFSAR for the facility provides a more consistent approach to evaluating changes to the facility,including those and removal of the technical specifications associated with the fire protection lprogram detection and suppression, fire barriers, and fire brigade staffing

.lWithin the context of the standard fire protection license condition, the phrase "notadversely affect the ability to achieve and maintain safe shutdown in the event of a fire," means to maintain sufficient safety margins. SeeRegulatory Guide 1.174, "An Approach for Using lProbabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the lLicensing Basis," defines maintaining sufficient safety margins as either of the following:

la.Codes and standards or thei r alternatives approved for use by the NRC are met.

lb.Safety analysis acceptance criteria in the licensing basis are met or proposed revisions lprovide sufficient margin to account for analysis and data uncertainty.

llIt would be considered sufficient to maintain applicable safety margins by relating item l(a) above specifically to changes to the FPP under the standard license condition; changes that lmaintain compliance with the applicable NF PA codes and standards endorsed by the NRC; lAppendix R to 10 CFR Part 50; this regulatory guide; and the applicable BTPs, NUREG-series lreports, and other NRC-approve d or NRC-issued documents.

llOther documents approved or issued by the NRC that would provide a basis for lcompliance would include topical reports endorsed by the staff or other staff-documented generic lpositions or generic communications. If the licensee has an analysis in a retrievable and l

DG-1170, Page 65auditable format that demonstrates compliance with the applicable N RC-approved document(s),lthe change is acceptable, provided that the change meets current regulations (e.g., 10 CFR 50.48,lAppendix R to 10 CFR Part 50, where applicable , and GDC 3), and is consistent with the ldefense-in-depth philosophy for fire protection. (See Section II.A of Appendix R to 10 CFR Part l50.) The NRC would not require an assessment of the risk impact of the change to demonstrate lcompliance with Regulatory Position 1 of Regulatory Guide 1.174 for additional information.

l1.8.1.3 Exemption/Deviation vs

.llThe NRC would find the substitution of repairs in lieu of installed fire protection systems land features for systems and components requi red to achieve and ma intain cold shutdown lacceptable so long as the time to repair the cold shutdown capability did not exceed the limits lprescribed in Appendix R to 10 CFR Part 50. An assessment of the risk impact may or may not lbe necessary for satisfying the provisions under item (b), above, depending upon the nature of the lchange and the analysis used to justify the change. Regulatory Position 5 of this guide provides ladditional guidance with respect to acceptable operator manual actions.

l lThe licensee is responsible for demonstrating that the change has not resulted in an ladverse effect on safe shutdown or noncompliance with the app licable NRC requirements. An lappropriate analysis is required to demonstrate that the change is acceptable. The licensee's lfailure to conduct the appropriate analysis is a failure to m eet the plant's fire protection license lcondition. The depth and scope of the analysis depends upon the nature of the change and the ltype of analytical tool relied upon to justify the subject change. A change that does not maintain la sufficient margin of safety fails to meet the plant's license condition.

l lFPP changes that adversely affect the ability to achieve and maintain safe shutdown in the levent of a fire and are not in compliance with regulatory requirements need prior approval by the lNRC. Changes submitted to the NRC for re view and approval should include a technical ljustification for the propos ed alternative approach.

ll1.8.1.3Exemptions, License Amendments, and the Standard License Condition llIf a proposed change alters compliance with a rule then an exemption from the rule is lrequired in accordance with 10 CFR 50

.12. If a proposed change involves a change toalters allicense condition or technical specification that was used to satisfy NRC requirements, thellicensee should submit a license amendment request should be submitted. When a change thatlfalls within the scope of the changes allowed unde r the standard fire pr otection license condition is planned, the licensee's evaluation is should be made in conformance with the standard firelprotection license condition to determine whether the change would adversely affect the ability to

achieve and maintain safe shutdown. The assessment shoul d include the effect on the firehazard s analysis and the consideration of should consider whether circuits or components

,lincluding associated circuits, for a success path of equipmen t needed for safe shutdown are beingaffected or a new element introduced in the area. If th is e evaluation concludes that there is noladverse affect, the licensee should document this conclusion and its basis should be documented land bemake it available for future inspection and reference. If the evaluation finds that there islan adverse affect, or that it is outside the basis for an exemption (or deviation) that was granted DG-1170, Page 66 (or approved) for the area involved, the licensee s hould make modifications to achieveconformance, justify and request an exemption, or seek a license amendment from the NRC.

1.8.1.4 Nonconforming Conditions. llIn addition to an evaluation of planned changes, a safety an evaluation may also be lrequired for nonconforming conditions.In the case of a degraded or nonconforming condition, a safety an evaluation isldependent depends on the licensee's compensatory and corrective actions taken by the licensee. lThere are three Three potential conditions exist for determining the need for performance of a lsafety an evaluation. These conditions are (1) the use of interim compensatory actions, or (2)lcorrective actions that result in a change, or (3) corrective actions that restore the nonconforming lor degraded condition to the previous condition.

If the licensee takes an interim compensatory action is taken to address the condition that lfalls within the scope of the standa rd fire protection license condition, it should conduct a reviewlshould be conducted and which may result in a safety evaluation. The intent of the review is toldetermine whether the compensatory action itself (not the degraded condition) impacts otheraspects of the facility described in the FSAR.In its evaluation of the impact of a degraded or nonconforming condition on plantoperation and on operability of structures, systems, and components, a licensee may decide toimplement a compensatory measure as an interim step to restore operability or to otherwiseenhance the capability of structures, systems, and components until the final corrective action iscomplete. Reliance on a compensatory measure for operability should be an importantconsideration in establishing the "reasonable time frame" to complete the corrective actionprocess. In accordance with GL 91-18, NRC would normally expect that conditions that requireinterim compensatory measures to demonstrate operability would be resolved more promptlythan conditions that are not dependent on compensatory measures to show operability, becausesuch reliance suggests a greater degree of degradation. Similarly, if an operability de terminationis based upon operator action, NRC would expect the nonconforming condition to be resolvedexpeditiously.If the condition is accepted "as-is"as-is ,"" resulting in something different from that ldescribed in the FSAR

, or is modified to something differentthat differs from that described in lthe FSAR, the condition should be considered a change and subjected to a safety evaluation.

DG-1170, Page 67 1.8.1.5 Reporting Guidelines

. llThe licensee should maintain records of fire protection program-relatedFPP-related lchanges in the facility, of changes in procedures, and of tests and experiments made in accordance with the standard fire protection li cense condition. These records should include awritten evaluation that provides the bases for the determination that the change does not adversely affect safe

-shutdown capability.l The licensee should maintain, in auditable form, a current record of all such changes and lshould make such records available to NRC inspectors upon request. All changes to the lapproved program should be reported along with the FSAR revisions required by 10 CFR l50.71(e).l lIn accordance with 10 CFR 50.48, the licensee must maintain records of all changes inlthe facility must be maintained until the termination of the license. Records of superseded procedures must be maintained for a period of 3 years from the date the record was superseded.The guidance in Regulatory Position 1.8.1 is based on 10 CFR 50.48, GL 86-10, and GL 91-18.1.8.2Exemptions to Appendix R of to 10 CFR Part 50 llFor plants licensed prior to before January 1, 1979, the NRC requires requests for lexemption requests from the requirements of Appendix R are required for modifications orlconditions that do not comply with the applicable sections of Appendix R. The exclusion of theapplicability of sections of Appendix R other than Sections III.G, III.J, and III.O (and SectionlIII.L as applicable), III.J, and III.O is limited to those features accepted by the NRC staff assatisfying the provisions of Appendix A to Branch Technical PositionBTP APCSB 9.5-1lreflected in staff fire protection safety evaluation reports SERs issued prior to before the effectiveldate of the rule. For these previously approved features, an exemption request is not requiredexcept for proposed modifications that would alter previously approved features used to satisfy NRC requirements.Plant-specific conditions may preclude complia nce with one or more of the provisionsspecified in Appendix R. In such a case, the li censee should demonstrate, by means of a detailedfire hazards analysis, that the existing protection, or that the existing protection in conjunction with proposed modifications, will provide a level of safety equiva lent to the technicalrequirements of Appendix R.When the fire hazards analysis (see Regulatory Position 1.2 of this guide) shows thatadequate fire safety can be provided by an alternative approach can provide adequate fire safety l(i.e., an approach different fro m the specified requirement such as the use of a 1-hour fire

-ratedlbarrier where a 3-hour barrier is specified), licensees that are required to meet Appendix R mayrequest NRC approval of an exemption from the technical requirements of Appendix R. Anyexemption request should incl ude a sound technical basis that clearly demonstratesdemonstrating lthat the fire protection defense-in-depth philosophy is appropriately ma intained and that the DG-1170, Page 68exemption is technically justified. As part of its evaluation, the licensee should provide sound technical justification if it does not propose to install or improve th e automatic suppressionand/or detection capabilities in the area of concern

, and/or if it does not intend to implement lother more restrictive fire preventi on, detection, or suppression measures.Generally, the staff will accept an alternative fire protection configuration on the basis of la detailed fire hazards analysis if the following conditions are met:

la.The alternative configuration ensures that one success path of equipment necessary to lachieve hot shutdown from either the control room or emergency control stations is free lof fire damage.

llText Moved Here: 6 lb.The alternative configuration ensures that fire damage to equipment necessary to achieve lcold shutdown is limited so that it and can be repaired within a reasonable time (minor lrepair using components stored on the site); and.lEnd Of Moved Text lc.Fire-retardant coatings are not used as fire barriers.

ld.Modifications required to meet Appendix R requirements woul d not enhance fire lprotection safety levels above that provided by either existing or proposed alternatives.

llThe staff will also accept an alternative fire protection configuration on the basis of a ldetailed fire hazards analysis if:a.The alternative ensures that one success path of equipment necessary to achieve hot shutdown from either the control room or emergency control stations is free of firedamage; and Text Was Moved From Here: 6c.Fire-retardant coatings are not used as fire barriers; and d.Modification required to meet Appendix R would not enhance fi re protection safety levels above that provided by either existing or proposed alternatives.

The staff will also accept an alternative fire protection configura tion on the basis of adetailed fire hazards analysis when the licensee can demonstrate that modifications required tomeet the requirements of Appendix R would be detrimental to overall facility safety, the lalternative configuration satisfies the four aforementioned above criteria, and the alternative lconfiguration provides an ade quate level of fire safety.

E The licensee should file requests for exemptions to the requirements of 10 CFR 50.48 land Appendix R are to be filed10 CFR Part 50 in accordance with 10 CFR 50.12.

l DG-1170, Page 69The guidance in Regulatory Position 1.8.2 is based on GL 86-10.

1.8.3Appendix R Equivalency Evaluations llThe NRC interpretations of certain Appendix R requirements allow a licensee to choosel not to seek prior NRC review and approval of, for example, a fire area boundary, in which casean evaluation should be performed by a fire protection engineer (assisted by others as needed) and should perform an evaluation which should be retained for a future NRC audit.

E Thellicensee should ensure that such e valuations of this type should be are written and organized tolfacilitate review by a person not involved in the evaluation. All calculations supporting t Thelevaluation should be availableinclude all supporting calculations and clearly state all assumptionslclearly stated at the outset. The licensee should retain these evaluations should be retained forlsubsequent NRC audits. Appendix A to this guide provides examples

.The guidance in Regulatory Position 1.8.3 is based on GL 86-10.1.8.4Deviations of previously accepted equivalency evaluations.

ll1.8.4License Amendments llPlants licensed after January 1, 1979, that have committed to meet the requirements ofSections III.G, III.J, and III.O of Appendix R to 10 CFR Part 50 or other NRC guidance (e.g.,lCMEB 9.5-1), and are required to do so as a license condition, do not need to request exemptionsfor alternative config urations. However, the FSAR or fire hazards analysis should identify and ljustify deviations from the requirements of Sections III.G, III.J, and III.O or other applicablelrequirements or guidance should be identified and justified in the FSAR or FHA

, and th es eldeviation s may require a license amendment to change the license condition.

Deviations lsubmitted to the NRC for review and approvalLicensees should include a technical justificationl for the proposed alternative approach in any license amendment it submits to the NRC for review land approval. The technical justification should addr ess the criteria described in Regulatoryl Positions 1.8.1 , S for safety E evaluations, and 1.8.2 for exemptions.

lThe guidance in Regulatory Position 1.8.4 is based on GL 86-10.

1.8.5ll1.8.5Operability Assessments llStructures, systems, and componentsThe licensee must subject SSCs that are relied uponlin the licensee's fire protection plan requiredFPP under 10 CFR 50.48 are to be subjected toloperability assessments and pr ompt corrective action when inoperable, degraded, ornonconforming conditions are identified. The process of ensuring operability is continuous andconsists of the verification of operability by surveillance activities and formal determinations of operability whenever a verification or other indication calls into question the ability of a structure, system, or component n SSC to perform its specified function.

Prompt action should be ltaken by the licensee any time a structure, system, or component The licensee should take prompt l

DG-1170, Page 70action any time an SSC important to safety is found to be inoperable. If an immediate threat to lpublic health and safety is iden tified, action to place the plant in a safe condition should begin as soon as possible.

A structure, system, or component n SSC is considered operable when it can perform its lintended function (e.g., a fire pump that is rated for 2500 GPMgpm at 120 psi is capable of lmeeting or exceeding that flow and pressure). The definition of operability includes the principlethat a system can perform its specified safety functions only when all its necessary supportsystems are capable of performing their rela ted support functions (e.g., an automatic firesuppression system is operable only if the detection system that is used to actuate the firesuppression system is also operable). If a necessary support system is inoperable, thecorresponding structure, system, or component SSC should also be declared inoperable. The loperability determination may be based on analysis, testing, operating experience, engineering judgment, or a combination of these methods. In the absence of a reasonable expectation that astructure, system, or component n SSC is operable, the structure, system, or component SSClshould be declared inoperable.Full qualification of a required structure, system, or component SSC is defined as lconforming to all aspects of the current licensing basis, including the applicable codes andstandards (e.g., NFPA), design criteria, and commitments (e.g., Branch Technical Positions). The fact that a structure, system, or component n SSC is not fully qualified may render the lstructure, system, or component SSC degraded or nonconforming, but does not in all cases render lthat structure, system, or componente SSC unable to perform its specified function. A degraded lcondition exists when there has been an a loss of quality or functional capability of a structure,lsystem or component n SSC (e.g., a fire test has determined that a fire barrier that was credited lwith a fire

-resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> has been determined by a fire test to only provide s a fire -lresistance rating of only two 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) has occurred. A nonconforming condition exists when lthere is a failure to meet requirements or licensee commitments (e.g., missing the performance of the weekly fire pump test as required by NFPA 20, "Standard for the Installation of Centrifugal lFire Pumps"). If a structure, system, or component n SSC important to safety is degraded or lnonconforming but operable, the licensee should esta blish an acceptable basis for its continuedoperability. The licensee should promptly identify and correct the condition that resulted in thedegraded or nonconforming condition.Automatic actuation of structures, systems, or componentsa system is frequently provided las a design feature for mitigating fire events (e.g., automatic suppression systems). When thelicensee is considering the substitution of a manual action for an automatic actuation, thelicensee's its determination of operability should consider the differences in the performance lbetween the automatic and manual action and the ability of the manual action to accomplish the

specified function. The li censee should have written procedures in place and conduct traininglprior to before the substitution of any manual action for the loss of an automatic feature.

lCThe licensee may use compensatory measures may be used as an interim step to restore loperability or to enhance the capability of structures, systems, or components SSCs that arel DG-1170, Page 71degraded or nonconforming until the fi nal corrective action is complete

d. Reliance oncompensatory measures should be considered in establishing the a reasonable timelframetimeframe to complete the corrective action process. Generally, conditions that requirelcompensatory measures to restore or enhance operability should be resolved more promptly than conditions that are not dependent upon compensatory measures. The compensatory measures selected should be appropriate to the adverse condition identified (e.g., use of mobile fire apparatus es to compensate for a fire pump that is degraded).

(See Regulatory Position 1.5 forladditional guidance regarding compensatory actions.

The guidance in Regulatory Position 1.8.5 is based on GL 91-18 and IM STS-10.

1.8.6)ll1.8.610 CFR 50.72 Notification and 10 CFR 50.73 Reporting lThe requirements of 10 CFR 50.72 and 10 CFR 50.73 have applicability apply tolreporting certain events and cond itions related to fire protec tion at nuclear power plants.

FLicensees should report fire events or fire protection deficiencies that meet the criteria of 10lCFR 50.72 and 10 CFR 50.73 should be reported to the NRC as appropriate

, and in accordancelwith the requirements of these regulations. Guidance for meeting the requirements of 10 CFR 50.72 and 50.73 is provided in NUREG-1022, "Event Reporting Guidelines:

10 CFR 50.72 andl 50.73," which was prepared by the NRC staff to clarifyRevision 1, issued January 1998 provides lguidance for meeting the requirements of these two sections. The NRC staff prepared NUREG-l1022 to clarify the implementation of the 10 CFR 50.72 and 10 CFR 50.73 rules and consolidatelimportant NRC reporting guidelines into one reference document.

The document is structured tolassist licensees in achieving prompt and complete reporting of specifie d events and conditions.

AThe Statements of Consideration for the rules include additional reporting guidance forl10 CFR 50.72 and 50.73 was contained in the Statements of Considerations for the rules. The guidance in Regulatory Position 1.8.6 is based on 10 CFR 50.72, 10 CFR 50.73 , and NUREG-1022

.1.8.7 NFPA Code and Standard Deviation Evaluations llFor those fire protection structures, systems, and components SSCs installed to satisfy thelNRC requirements and designed to NFPA codes and standards, the code of record is the codeledition in force at the time of the design and installation is the code of record to which the design is evaluated. Deviationsor at the time the commitment is made to the NRC for a fire protection lfeature. The FSAR or the fire hazards analysis should identify and justify deviations from thel codes should be identified and justified in the FSAR or FHA. Deviations should not degrade the performance of fire protection systems or features. The code standards of record is determined by lthe licenseerelated to the design and installation of fire protection systems and features required lto satisfy NRC requirements in all new reactor designs are those NFPA codes and standards in leffect 180 days prior to the submittal of the application under 10 CFR Part 50 or 10 CFR Part 52

.l DG-1170, Page 72A licensee may apply the equivalency concept in meeting the provisions of the NFPAcodes and standards. Nothing in the NFPA codes or standards is intended to prevent the use ofmethods, systems, or devices of equivalent or superior quality, strength, fire resistance,effectiveness, durability, and safety as alternatives to those prescribed by the codes or standards, provided technical documentation demonstrates equivalency and the method, system, or device is listed or approved fo r the intended purpose.An exemption is not required for deviation from NFPA codes.

The NRC guidelines lreference certain NFPA codes as providing guidance acceptable to the staff , and; therefore

, suchlcodes may be accorded the same status as regulatory guides. More recent editions of the NFPA lcodes require submittal of technical documentation to the "authority having jurisdiction" (AHJ) lto demonstrate equivalency of an alternative system, method or device for AHJ approval.

lWhether or not the code of record includes th is requirement, the NRC does not require review land approval of equivalency evaluations. However, th e licensee should document these levaluations and make them available for NRC review.

lWhen the applicant/licensee states that its design "meets"meets the NFPA code(s)

"" or l"meets"meets the intent of the NFPA code(s)

"" and does not identify any deviations from such lcodes, the NRC expects that the design conforms to the codes and the design is subject toinspection against the NFPA codes code of record

.lThe "Authority Having Jurisdiction" AHJ (as described in NFPA documents

) refers to the lDirector , of the NRC's Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory lCommission (or Director of the Office of New Reactors, for new reactors), or designee,lconsistent with the authority specified in 10 CFR 1.43. The guidance in Regulatory Position 1.8.7 is based on GL 86-10.2.FIRE PREVENTIONAdministrative, "Office of Nuclear Reactor Regulation."

ll1.8.8 Fire Modeling llWhere the evaluation of an FPP change is based on fire modeling, licensees should ldocument that the fire models and methods us ed meet the NRC requirements. The licensee lshould also document that the models and methods used in the analyses were used within their llimitations and with the rigor required by the nature and scope of the analyses. These analyses lmay use simple hand calculations or more complex computer models, depending on the specific lconditions of the scenario being evaluated. Appendix C to NFPA 805 and Appendix D to NEI l04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection lProgram Under 10 CFR 50.48(c)

," contain discussions that are useful in determining which fire lmodels to use and applying those fire models within their limitations. However, the NRC only lendorses the fire models, methodologies, data, and examples in these appendices to the extent lthat they have been or can be adequately verified and validated or to the extent they are lappropriate for the specific application.

l DG-1170, Page 73The NRC's Office of Nuclear Regulatory Research (RES) and EPRI have documented the lverification and validation (V&V) process for parts of five fire models in draft NUREG-l1824/EPRI 1011999, "Verification and Validation of Selected Fire Models for Nuclear Power lPlant Applications." The specific fire models documented are (1) NUREG-1805, "Fire lDynamics Tools (FDTs)"; (2) Fire-Induced Vulnerability Evaluation (FIVE), Revision 1; (3) the lNational Institute of Standards and Technology (NIST) Consolidated Model of Fire Growth and lSmoke Transport (CFAST); (4) the Electricité de France (EdF) MAGIC code; and (5) the NIST lFire Dynamics Simulator (FDS).

l lLicensees may propose the use of fire models that have not specifically undergone V&V lby the NRC; however, licensees are responsible for providing evidence of acceptable V&V of lthese fire models. The V&V doc uments for licensee-proposed fire models are subject to NRC lreview and approval.

l l2.Fire Prevention llFire prevention is the first line of defense-in-d epth for fire protection. The fire prevention lattributes of the program are directly related to the fire protection objective to minimize the lpotential for fire to occur. These attributes involve design and administrative measures that lprovide a reasonable level of assurance that fire hazards are adequately protected and managed land that fire consequences will be limited for those fires that do occur.

l lThe licensee should establish administrative controls and procedures should be lestablished to minimize fire hazards in areas containing structures, systems, and components SSCs important to safety. Normal and abnormal conditions or other anticipatedloperations such as modifications (e.g., breaching fire barriers or fire stops, impairment of firedetection and suppression systems) and transient fire hazard conditions

, such as those associatedlwith maintenance activities

, should be reviewed by appr opriate levels of management , and. Thellicensee should implement appropriate compensatory measures such as fire watches or temporarylfire barriers should be implemented to ensure adequate fire protection and reactor safety.For plants that have permanently ceased operations and are in the process of ldecommissioning, the fire hazards are constantly changing and fire protection systems and lfeatures are being dismantled. Fire prevention attributes of the program are key to minimizing lthe potential for fire and subsequent release of radioactive materials under these dynamic lconditions.

l lThe following sections provide guidance relative to fire prevention measures, includinglcontrol of combustibles and ignition sources

, and housekeeping inspections.

ORegulatory lPosition 1.1 discusses organizational responsibilities for implementation of fire preventionlmeasures are discussed in Regulatory Position 1.1. Portions of NFPA 1, ""Uniform FirelPrevention Code," including Chapters 3-8, 28, and 34," contain additional guidance that may bel used in the development and implement ation of fire prevention measures.

2.1Control of Combustibles l

DG-1170, Page 74Fire prevention administrative controls should include procedures to control handling anduse of combustibles, prohibit storage of combustibles in plant areas important to safety or ,lestablish designated storage areas with appropria te fire protection, and control use of specificcombustibles (e.g., wood) in plant areas important to safety.

l2.1.1 Transient Fire Hazards llBulk storage of combustible materials should be prohibited inside or adjacent to buildings lor systems important to safety during all modes of plant operation. Procedures should govern thehandling of and limit transient fire hazards such as combustible and flammable liquids, wood andplastic products, high-efficiency particulate air (HEPA) and charcoal filters, dry ion exchange lresins, or other combustible materials in buildings containing sy stems or equipment important tosafety during all phases of operation, and especiallyparticularly during maintenance,lmodification, or refueling operations.Transient fire hazards that cannot be e liminated should be controlled and suitable protection should be provided. Specific c ontrols and protective measures include the following

la.Unused ion exchange resins should not be stored in areas that contain or exposeequipment important to safety.

lb.Hazardous chemicals should not be stored in areas that contain or expose equipmentimportant to safety.

lc.Use of wood inside buildings containing syst ems or equipment important to safety shouldbe permitted only when suitabl e noncombustible substitutes are not available. All wood smaller than 152 mmmillimeters (mm) x 152 mm

([6 inch (in.) x 6 in ch).] used in plant lareas important to safety during maintenance, modification, or refueling operation (suchas lay-down blocks or scaffolding) s hould be treated with a flame retardant. (Forlguidance, see NFPA 703, "Standard"Standard for Fire -Retardant ImpregnatedTreatedlWood and Fire

-Retardant Coatings for Building Materials," for guidance

."). Woodlshould be allowed into plant areas important to safety only when it is to be usedimmediately.

ld.The use of plastic materials should be minimized. Halogenated plastics such as polyvinyl lchloride (PVC) and neoprene should be used only when substitute noncombustiblematerials are not available. All plastic materials, including flame and fire retardant DG-1170, Page 75 materials, will burn with an intensity and BTU production in a range similar to that ofordinary hydrocarbons. When burning, they produce heavy smoke that obscures visibilityand can plug air filters, especially charcoal and HEPA filters.

The h Halogenated plasticslalso release free chlorine and hydrogen chloride when burning, which are toxic to humansand corrosive to equipment. NFPA 701, "Standard"Standard Methods of Fire Tests forlFlame-ResistantFlame Propagation of Textiles and Films,"" provides guidance on fireltesting of flame

-resistant plastic films (e.g., plastic sheeting, tarpaulins).l le.Use of combustible material such as HEPA and charcoal filters, dry ion exchange resins, or other combustible supplies in areas important to safety shoul d be controlled. Such materials should be allowed into areas important to safety only when they are to be usedimmediately.

lf.Equipment or supplies (such as new fuel) shipped in untreated combustible packingcontainers may be unpacked in areas containing equipment or systems important to safetyif required for valid operating reasons.

However, all combustible materials should belremoved from the area immediately following unpacking.

Such transient combustiblel material, unless stored in approved containers, should not be left unattended. Loosecombustible packing material, such as wood or paper excelsior or polyethylene sheeting, should be placed in metal containers with tight-fitting

, self-closing metal covers.llg.Materials that collect and contain radioactivity

, such as spent ion exchange resins,lcharcoal filters, and HEPA filters

, should be stored in closed metal tanks or containerslthat are located in areas free from ignition sources or combustibles. These materialsshould be protected from exposure to fires in adjacent areas as well. Considerationshould be given to requirements for removal of decay heat from entrained radioactivematerials.2.1.2Modifications Thelh.Temporary power cables used during maintenance outages are transient combustibles and lpotential ignition sources. Procedures should adequately address fire protection for ltemporary electrical power supply and distribution.

ll DG-1170, Page 76 2.1.2 Modifications llFire prevention elements of the FPP should be maintained when plant modifications are lmade. The modification procedures should c ontain provisions that evaluate the impacts of lmodifications on the fire prevention design features and progra ms. The licensee should follow lthe guidelines of Regulatory Position 4.1.1 should be followed in the design of plant lmodifications. Modifications of structures, systems, and components should be reviewed by p Personnel in the fire protection organization should review modifications of SSCs to ensure that lfixed fire loadings are not increased beyond those accounted for in the fire hazards analysis, or if increased, suitable protection is provided and the fire hazards analysis is revised accordingly.

2.1.3Flammable and Combustible Liquids and Gases llFlammable and combustible liquids and gases are potentially significant fire hazards and lprocedures should clearly define the use, handling, and storage of these hazards. The handling,luse, and storage of flammable and combustible liquids should, as a minimum, comply with theprovisions of NFPA 30, "Flammable"Flammable and Combustible Liquids Code." "lMiscellaneous storage and piping for flammable or combustible liquids or gases shouldnot create a potential fire exposure hazard to systems important to safety.

Systems important to safety should be isolat ed or separated from co mbustible materials. When this is not possible because of the nature of the safety system or the combustible material, special protection should be provided to prevent a fire from defeating the safety system function. Such protection may involve a combination of automatic fire suppr ession and constructioncapable of withstanding and containing a fire that consumes all combustibles present. Examplesof such combustible materials that may not be separable from the remainder of its system areemergency diesel generator EDG fuel oil day tanks, turbine-generator oil and hydraulic control lfluid systems, and reactor coolant pump RCP lube oil systems.

lDiesel fuel oil tanks should meet the guidelines of Regulatory Positions 6.1.8 and 7.4 ofthis guide.. Turbine-generator lube oil and hydraulic systems should meet the guidelines in lRegulatory Position 7.2. Reactor coolant pumpRegulatory Position 7.1 provides guidelines for lRCP oil collection system guidelines are provided in Regulatory Position 7.1systems.lBulk gas storage and use should meet the guidelines of Regulatory Position 7.5 of thisguide.2.1.4 External/Exposure Fire Hazards llWhen a structure, system or component n SSC important to safety is near installations

,lsuch as flammable liquid or gas storage, the licensee should evaluate the risk of exposure fires l(originating in such installations) to the structures, systems, SSCs and components should be levaluated andtake appropriate protective measures taken. NFPA 80A,l"Recommended"Recommended Practice for Protection of Buildings from Exterior Fire lExposures,"" provides guidance on such exposure protection. NFPA 30 provides guidance l

DG-1170, Page 77relative to minimum separation distances from flammable and combustible liquid storage tanks. NFPA 5 0A 5 , "Standard for Gaseous Hydrogen Systems at Consumer Sites," and NFPA 50B,l"Standard for Liquefied Hydrogen Sy stems at Consumer Sites," providethe Storage, Use, and lHandling of Compressed Gases and Cryogenic Fluids in Portable and Stationary Containers,lCylinders, and Tanks," provides separation distances for gaseous and liquefied hydrogen

,lrespectively. (s See Regulatory Position 7.5 of this guide.

). NFPA 58, "Liquefied Petroleum GaslCode," provides guidance for liquefied petroleum gas.Miscellaneous areas

, such as shops, warehouses, auxiliary boiler rooms, fuel oil tanks,lradwaste buildings, and flammable and combustible liquid storage tanks

, should be located andlprotected such that a fire or the effects of a fire, including smoke, will not adversely affect anylsystems or equipment SSCs important to safety.

(See the previous section for guidelineslrelativerelated to location oflocating diesel fuel oil tanks and compressed gas supplies external tolstructures important to safety.

)lIn geographic areas where there is a potential for damage from wildfires (i.e., forest,brush, vegetation), the licensee should evaluate the risk potential from wildfire should belevaluated for structures that contain systems or components SSCs important to safety

, and takelappropriate measures should be taken. NFPA 299 1144, "Standard for Protection of Life andlProperty from Wildfire," provides guidance on assessing wildfire severity and appropriate protection measures.

The guidance in Regulatory Position 2.1 is based on Appendix R to 10 CFR Part 50 andCMEB 9.5-1.2.2Control of Ignition Sources lFire protection administrative controls shou ld establish procedures to govern use of llElectrical equipment (permanent and temporary), hot work activities (e.g., open flame,lwelding, cutting and grinding), high-temperature equipment and surfaces, heating equipment l(permanent and temporary installation), reactive chemicals, static electricity, and smoking are all lpotential ignition sources. Design, installation, modificati on, maintenance, and operational lprocedures and practices should control potential ignition sources.

llEngineering design practices should provide assurance that el ectrical equipment is lproperly designed and installed in accordance with industry standards, heat generating equipment lor equipment with hot surfaces is properly cooled or separated from combustible materials, and lsystems containing flammable and combustible liquids or gases are properly designed and llocated to minimize the exposure of these materials to ignition sources.

l lRegulatory Position 3.5 of Regulatory Guide 1.191 contains similar guidelines for those lplants that have permanently ceased operation.

l l2.2.1Open Flame, Welding, Cutting

, and Grinding (Hot Work) l DG-1170, Page 78 lWork involving ignition sources such as welding and flame cutting should be done under lclosely controlled conditions. Persons performing and directly assisting in such work should be trained and equipped to prevent and combat fires. If this is not possible, a person qualified in fireprotection should directly monitor the work and function as a fire watch.The use of ignition sources should be governed by use of a hot work permit system tocontrol open flame, welding, cutting, brazing, or soldering operations.

A separate permit should be issued for each area where work is to be done. If work continues over more than one shift, the permit should be valid for not more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the plant is operating or for the durationof a particular job during plant shutdown. NFPA-51BNFPA 51B , "Standard"Standard for FirelPrevention in Use ofDuring Welding, Cutting and Welding ProcessesOther Hot Work

,"" includeslguidance for safeguarding the hazards associated with welding and cutting operations.

2.2.2Temporary Electrical Installations llThe use of temporary services at power reactor facilities is routine, especially in to supportlof maintenance and other activities during outages. In view of the magnitude and complexity ofsome temporary services, proper engineering and, once installed, maintenance of the design basisbecome significant. Plant administrative controls should provide for engineering review oftemporary installations. Thes e reviews should ensure that appropriate precau tions, limitations,and maintenance practices are established for the term of such installations. The Institute of Electrical and Electronic s Engineers (IEEE) Standard 835, "Standard"Standard Power Cable lAmpacity Tables,"" ANSI/IEEE C.2, "National Electrical Safety Code," " and NFPA 70,l"National"National Electrical Code,"" provide guidance on temporary electrical installations,lincluding derating of closely spaced cables.

2.2.3Other Sources llLeak testing and similar procedures su ch as airflow determination should not use one oflthe commercially available techniques. Open open flames or combustion-generated smoke shouldlnot be permitted.

.l lProcedures and practices should provide for control of temporary heating devices. Use of lspace heaters and maintenance equipment (e.g., tar kettles for roofing opera tions) in plant areas lshould be strictly controlled and reviewed by the plant's fire protection staff. Engineering lprocedures and practices should provide assurance that temporary heating devices are properly linstalled according to the listing, including required separations from combustible materials and lsurfaces. Temporary heating devices should be placed so as to avoid overturning and installed in laccordance with their listing, including clearance to combustible material, equipment, or

construction. Asphalt and ta r kettles should be located in a safe place or on a fire-resistive roof ata point where they avoid ignition of combustible material below. Continuous supervision should be maintained while kettle s are in operation and me tal kettle covers and fire extinguishers should be provided.

DG-1170, Page 79The guidance in Regulatory Position 2.2 is based on ASB 9.5-1, CMEB 9.5-1, IN 91-17,and IP 64704.2.3Housekeeping lA The licensee should establish administrative controls should be established to minimizelfire hazards in areas containing structures, systems, and components SSCs important to safety. l These controls should establish procedures to govern removal of waste, debris, scrap, oil spills, and other combustibles after completion of a work activity or at the end of the shift. lAdministrative controls should also include procedures for performing and to maintain lhousekeeping inspections. Periodic maintaining periodic housekeeping inspections should be lperformed to ensure continued comp liance with fire protection administrative controls controls.

lHousekeeping practices should ensure that drainage systems, especially drain hub grills, in areas lcontaining fixed water-based suppression systems remain free of debris to minimize flooding if lthe systems discharge. Regulatory Guide 1.39, "Housekeeping Requirements for Water-Cooled lNuclear Power Plants," Revi sion 2, issued September 1977, provides guidance on housekeeping,lincluding the disposal of combustible materials.

The guidance in Regulatory Position 2.3 is based on Appendix R to 10 CFR Part 50,CMEB 9.5-1, and Regulatory Guide 1.39.2.4Fire Protection System Maintenance and Impairments lF The licensee should establish fire protection administrative controls should belestablished to address the following:a.Fire protection features should be main tained and tested by qualified personnel. (seelRegulatory PositionSee Regulatory Position 1.6.1.c of this guide.

).lb.Impairments to fire barrier s, fire detection, and fire suppression systems should becontrolled by a permit system. Compensatory measures (see Regulatory Position 1.5 oflthis guide) should be established in areas where systems are so disarmed.l DG-1170, Page 80c.Successful fire protection requires inspection, testing, and main tenance of the fire protection equipment. A test plan that lis ts the individuals and their responsibilities in connection with routine tests and inspections of the fire protection systems should be developed.

The test plan should contain the types, frequency, and deta iled procedures for ltesting. Frequency of testing should be based on the code of record for the applicable fireprotection system. Procedures should also contain instructions on maintaining fireprotection during those periods when the fire protection system is impaired or during periods of plant maintenance , (e.g., fire watches

).ld.Fire barriers, including dampers, doors, and penetration seals, should be routinely inspected. Penetration seals may be inspected on a frequency and relative sample basisthat provides assurance that the seals are functional. Sample size and inspectionfrequency should be determined by the total number of pene trations and observed failurerates. Inspection frequency should ensure that all seals will be inspected every 10 years.The guidance in Regulatory Position 2.4 is based on Appendix R to 10 CFR Part 50 andCMEB 9.5-1.3.FIRE DETECTION AND SUPPRESSION 3.1 3.Fire Detection (Design Objectives and Performance Criteria) lFireand Suppression ll3.1Fire Detection llIn general, the fire hazards analysis and regulatory requirements determine the scope of lfire detection and suppression in the plant, wher eas the applicable industry codes and standards l(generally NFPA codes, st andards, and recommended practices) determine the design,linstallation, and testing requirements of the systems and components. The design of fire ldetection systems should be designed to minimize the adverse effects of fires on structures,systems, and components SSCs important to safety. Automatic fire detection systems should be linstalled in all areas of the plant that contain or present an exposure fire hazard to structures,systems, and components SSCs important to safety. These fire detection systems should be lcapable of operating with or without offsite power.With regard to protection of safe

-shutdown systems, Regulatory Positions 5.5.b and 5.5.c lof this guide state that "In, "In addition, fire detectors and an automatic fire suppression system lshould be installed in the fire area.

"" See Regulatory Position 1.8.3 and the information in lAppendix A for guidance relative toWhere automatic fire detecti on is installed, it should provide lcomplete protection throughout the fire area. For those areas where less than full-area coverage lis provided.

DG-1170, Page 81 3.1.1only partial coverage is installed, the fire hazards analysis should demonstrate the ladequacy of the design to provide the necessary protection.

ll3.1.1Fire Detection and Alarm Design Objectives and Performance Criteria llThe fire detection and alarm system should be designed with the following objectives

.l:la.Detection systems are to be provided for all areas that contain or present a fire exposureto equipment important to safety.b.Fire detection and alarm systems should comply with the requirements of Class Alsystems as defined in NFPA 72, "National"National Fire Alarm Code,"" and Class Ilcircuits as defined in NFPA 70.c.Fire detectors are selected and installed in accordance with NFPA 72. Pre

-operationaland periodic testing of pulsed

-line-type heat detectors demonstrate that the frequencieslused will not affect the actuation of protective relays in other plant systems.d.Fire detection and alarm systems give audible and visibl e alarm and annunciation in thecontrol room. Where zoned detection systems are used in a given fire area, local meansare provided to identify which detector zone has actuated.e.Fire alarms are distinctive and unique so they will not be confused to avoid confusion withlany other plant system alarms.f.Primary and secondary power supplies are provided for the fire detection system and forelectrically operated control valves for automatic suppression systems. Such primary andsecondary power supplies are to should satisfy the provisions of NFPA 72. This can belaccomplished by using normal offsite power as the primary supply with a 4-hour batterysupply as a secondary supply and by providing the capability for manual connection to thelClass 1E emergency power bus within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of loss of offsite pow er. Such connectionshould follow the applicable guidance in Regulatory Guides 1.6, 1.32, and 1.75."Independence Between Redundant Standby (Onsite) Power Sources and Between Their lDistribution Systems," issued March 1971; 1.32, "Criteria for Power Systems for Nuclear Power lPlants," Revision 3, issued March 2004; and 1.75, "Physical Independence of Electric Systems,"

lRevision 3, issued February 2005.

lg.In areas of high seismic activity, the need to design the fire detection and alarm systemsto be functional following the a safe -shutdown earthquake should be considered.l DG-1170, Page 82h.The fire detection and alarm systems should retain their original design capability for (1) natural phenomena of less severity and greater frequency than the most severe naturalphenomena (approximately once in 10 years) su ch as tornadoes, hurricanes, floods, icestorms, or small-intensity ear thquakes that are characteristic of the geographic region

, andl(2) potential man

-made site-related events such as oil barge collisions or aircraft crashesthat have a reasonable probability of occurring at a specific plant site.i.Redundant cable systems important to safety located in cable trays should be provided with fire detection. (Also see Regulatory Positions 4.1.3.3 and 6.1.3.)

j i.Containment fire detection sy stems should be provided for non

-inerted containments in laccordance with the guidance in Regulatory Position 6.1.1.3 of this guide

.lk j.Control room fire detection and alarms should be provided in accordance with the lguidance in Regulatory Position 6.1.2 of this guide

.ll k.The following areas that contain equipment important to safety should be provided with lautomatic fire detectors that alar m and annunciate in the control room

-plant computer lrooms, switchgear rooms, remote shutdown panels, battery rooms, diesel generator areas, pump rooms, new and spent fuel areas, and radwaste and decontamination areas. (ASeela lso see Regulatory Positions 6.1 and 6.2

.)lThe guidance in Regulatory Position 3.1 is based on GDC 3, Appendix R to 10 CFR Part50, and CMEB 9.5-1.

3.2 of this guide.)

ll3.2Fire Protection Water Supply Systems (Design Objectives and Performance lCriteria)l3.2.1 Fire Protection Water Supply llNFPA 22, "Standard"Standard for Water Tanks for Private Fire Protection,"" and NFPAl24, "Standard"Standard for the Installation of Private Fire Service Mains and Their lAppurtenances,"" provide guidance for fire protection wate r supplies. The fire protection water lsupply system should meet the following criteria.a.Two separate, reliable fre shwater supplies should be providedavailable. Saltwater or lbrackish water should not be used unless a ll freshwater supplies have been exhausted.

DG-1170, Page 83b.The fire water supply should be calculated on the basis of the largest expected flow rate for a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, but not less than 1,136,000 liters (L) (300,000 gallons).

This flowl rate should be based (conservatively) on 1900 liters per meter (L/m) (500 gpm) forlmanual hose streams plus the largest design demand of any sprinkler or deluge system asdetermined in accordance with NFPA 13, "Standard"Standard for the Installation oflSprinkler Systems,"" or NFPA 15, "Standard"Standard for Water Spray Fixed Systemslfor Fire Protection." The fire water supply should be capable of delivering this designdemand over the longest piping route of the water supply system.

"lc.If tanks are used for water supply, two 100%100-percent system capacity tanks [minimum ofl1,136,000 L (300,000 gallons) each] should be installed. They should be sointerconnected thatto allow pumps can to take suction from either or both. However, alfailure in one tank or its piping should not cause both tanks to drain. Water supplycapacity should be capable of refilling either tank in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or less.ld.Common water supply tanks are acceptable for fire and sanitary or service water storage.

lWhen this is done, however, minimum fire water storage requirements should bededicated by passive means, for example, use of a verti cal standpipe for other waterservices.

Administrative controls, including locks for tank outlet valves, are unacceptablelas the only means to ensure minimum water volume.e.Freshwater lakes or ponds of sufficient size may qualify as the sole source of water for fire protection but require sepa rate redundant suctions in one or more intake structures.

These supplies should be separated so that a failure of one supply will not result in afailure of the other supply.f.When a common water supply is permitted for fire protection and the ultimate heat sink, the following conditions should also be satisfied:li.The additional fire protection water requirements are designed into the totalstorage capacity , and.lii.Failure of the fire protection system should not degrade the function of theultimate heat sink.g.Other water systems that may be used as one of the two fire water supplies should bepermanently connected to the fire main system and should be capable of automaticalignment to the fire main system. Pumps, controls, and power supplies in these systemsshould satisfy the requirements for the main fire pumps. The use of other water systems DG-1170, Page 84 for fire protection should not be incompatible with their functions required for safe plantshutdown. Failure of the other system should not degrade the fire main system.h.For multi-unit nuclear power plant sites with a common yard fire main loop, commonwater supplies may be utilized.i.Fire water supplies should be filtered and treated as necessary to prevent or controlbiofouling or microbiologically induced corrosion of fire water systems. If the supply israw service water, fire water piping runs should be periodically flus hed and flow tested.j.Provisions should be made to supply wa ter to at least two standpipes and hoseconnections for manual firefighting in areas containing equipment re quired for safe plant shutdown in the event of a safe

-shutdown earthquake. The piping system serving such lhose stations should be analyzed for safe

-shutdown earthquake loading and should be lprovided with supports to ensure system pressure integrity. The piping and valves for theportion of hose standpipe system affected by this functional requirement should, a s t alminimum, satisfy ASME/ANSIASME B31.1 , "Power Piping

." The water supply for this lcondition may be obtained by ma nual operator actuation of valv es in a connection to the hose standpipe header from a normal seismic Category I water system such as theessential service water system. The cross

-connection should be (a 1) capable of providing lflow to at least two hose stations [approximately 284 L/m (75 gpm) per hose station], and (b 2) designed to the same standards as the seismic Category I water system

(i.e., itlshould not degrade the performance of the seismic Category I water system

).l3.2.2Fire Pumps llFire pump installations should conform to NFPA 20, "Standard for the Installation of lCentrifugal Fire Pumps," and should meet the following criteria

.:la.If fire pumps are required to meet system pressure or fl ow requirements, a sufficient number of pumps is provided to ensure that 100%100-percent capacity will be available lassuming failure of the largest pump or loss of offsite power (e.g., three 50%50-percent lpumps or two 100%100-percent pumps). This can be accomplished, for example, by lproviding either electric moto r-driven fire pumps and diesel-driven fire pumps or two ormore seismic Category I Class 1E elect ric motor-driven fire pumps connected toredundant Class 1E emergency power buses. (s See Regulatory Guides 1.6, 1.32, andl1.75.)"Independence Between Redundant Standby (Onsite) Power Sources and Between Their lDistribution Systems," issued March 1971; 1.32, "Criteria for Power Systems for Nuclear Power lPlants," Revision 3, issued March 2004; and 1.75, "Physical Independence of Electric Systems,"

lRevision 3, issued February 2005.)

l DG-1170, Page 85b.Individual fire pump connections to the yard fire main l oop are separated withsectionalizing valves between connections. Each pump and its driver and controls arelocated in a room separated from the remaining fire pumps by a fire wall with a minimum rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

c.The fuel for the diesel fire pumps is separated so that it does not provide a fire sourceexposing equipment important to safety.

ld.Alarms or annunciators to indicate pump running, driver availability, failure to start, andl low fire-mainfire main pressure are provided in the control room.l l3.2.3 Fire Mains llAn underground yard fire main loop should be installed to furnish anticipated waterlrequirements. NFPA 24 provides appropriate guidance for such installation. NFPA 24references other design codes and standards developed by such organizations as the AmericanNational Standards Institute (ANSI) and the American Water Works Association (AWWA). Thefollowing specific criteria should be addressed:

a.TypeThe type of pipe and water treatment are design considerations with tuberculation asl one of the parameters.

b.M The means for inspecting and flushing the fire main are provided.lc.Sectional control valves should be visually indicating , (e.g., post

--indicator valves

).ld.Control and sectionalizing valves in fire mains and water-based fire suppression systemsare electrically supervised or administratively controlled (e.g., locked valves with key control, tamper-proof seals).

The electrical supervision signal indicates in the controllroom. All valves in the fire protection system are periodically checked to verify position. l(For guidance, see NFPA 25, "Standard"Standard for the Inspection, Testing, andlMaintenance of Water-Based Fire Protection Systems," for guidance

.").le.The fire main system piping is separate from service or sanitary water system piping,except as described in Regulatory Position 3.2.1 of this guide with regard to providinglseismically designed water supply for standpipes and hose connections.

DG-1170, Page 86f.A common yard fire main loop may serve multi

-unit nuclear power plant sites if cross-connected between units.

Sectional control valves permit maintaining independence of the individual loop around each unit. For multiple-reactor sites withwidely separated plants [approaching 1.6 kmkilometer (km) (1 mile (mi)) or more],lseparate yard fire main loops are used.g.Sectional control valves are provided to isolate portions of the fire main for maintenanceor repair without shutting off the supply to primary and backup fire suppression systemsserving areas that contain or expose equipment important to safety.h.Valves are installed to permit isolation of outside hydrants from the fire main for maintenance or repair without interrupting the water supply to automatic or manual firesuppression systems in any area containing or presenting a fire hazard to equipmentimportant to safety.i.Sprinkler systems and manual hose station st andpipes have connections to the yard mainsystem so that a single active failure or a line break cannot impair both the primary andbackup fire suppression systems. Alternatively, headers fed from each end are permittedinside buildings to supply both sprinkler and standpipe systems, provided steel piping andfittings meeting the requirements of ASME/ANSIASME B31.1 are used for the headers lup to and including the first valve supplying the sprinkler systems whe re n such headers lare part of the seismically analyzed hose standpipe system. When provided, such headersare considered an extension of the yard main system.

Each sprinkler and standpipe lsystem should be equipped with OS&Y (an outside screw and yoke

) gate valve or other lapproved shutoff valve and water flow alarm.The guidance in Regulatory Position 3.2 is based on Appendix R to 10 CFR Part 50,CMEB 9.5-1, Supplement 1 to GL 89-13, and IE Bulletin BL 81-03.3.3Automatic Suppression Systems (Design Objectives and Performance Criteria) lAutomatic suppression should be installed as determined by the fire hazards analysis andas necessary to protect redundant systems or components necessary for safe shutdown and SSCslimportant to safety.

(s See Regulatory Positions 5.5.b, 5.5.c, and 16 of this guide

.3.1).lIn areas of high seismic activity, the need to design the fire suppression systems to befunctional following the safe

-shutdown earthquake should be considered.

lThe fire suppression systems should retain their original design capability for (1) natural phenomena of less severity and greater frequency than th e most severe natural phenomena(approximately once in 10 years) such as tornadoes, hurricanes, floods, ice storms, orsmall-intensity earthquakes that are characteristic of the geographic region

, and (2) potential l

DG-1170, Page 87man-made site-related events such as oil barge collisions or aircraft crashes that have areasonable probability of occurring at a specific plant site.

lFor water suppression systems and fire detection systems that use metal plates for heat lcollection above individual sprinkler heads or detectors that are located well below the ceiling of la fire area (e.g., at some intermediate height in the room, below ceiling-mounted pipe and cable ltray), it should be demonstrated that this design will ensure acceptable actuation times. IN 2002-l24, "Potential Problems with Heat Collectors on Fire Protection Sprinklers," provides a ldiscussion of this issue. In general, the use of such plates has not been demonstrated to provide ladequate heat collection to effectively activate the sprinkler head or detector and may impair lsystem response.

l l3.3.1 Water-b Based Systems llEquipment important to safety that does not itself require protection by water-basedlsuppression systems

, but is subject to unacceptable damage if wetted by suppression systemldischarge , should be appropriately protected (e.g., water shields or baffles).

Drains should be lprovided as required to protect equipment important to safety from flooding damage.

ll3.3.1.1 Sprinkler and Spray Systems

. llWater sprinkler and spray suppression systems are the most widely used means oflimplementing automatic water-bas ed fire suppression. Sprinkler and spray systems should, a s t alminimum, conform to requireme nts of appropriate standards such as NFPA 13 andNFPA15NFPA 15.l3.3.1.2 Water Mist Systems

. llWater mist suppression systems may be useful in specialized situ ations, particularly inlthose areas where the application of water needs to be restricted. Water mist systems shouldl conform to appropriate standards such as NFPA 750, "Standard"Standard on Water Mist FirelProtection Systems.

""l3.3.1.3 Foam-Water Sprinkler and Spray Systems

. llCertain fires, such as those involving flammable liquids, respond well to foaml suppression. Consideration should be given to the use of foam sprinkler and spray systems. Foam sprinkler and spray systems should confor m to appropriate standards such as NFPA 16,"Standard"Standard for the Installation of Deluge Foam-Water Sprinkler and Foam-Water SpraylSystems," NFPA 16A, "Standard for the Installation of Closed-Head Foam-Water SprinklerSystems," NFPA 11, "Standard" and NFPA 11, "Standard for Low-Expansion Foam," and NFPA l11A, "Standard for Medium- and High-Expansion Foam Systems." 3.3.2Low-, Medium-, and High-Expansion Foam."

l DG-1170, Page 88 3.3.2 Gaseous Fire Suppression llGaseous systems should be evaluated for potential impacts on the habitability of areas lcontaining equipment important to safety where operations personnel perform safe-shutdown lactions or where fire-fighting activities may become necessary. Where gas suppression systems lare installed, openings in the area should be adequately sealed or the suppression system shouldbe sized to compensate for the loss of the suppression agent through floor drains and otheropenings. (ASee a lso see Regulatory Position 4.1.5

.) of this guide.)

llThe design of gaseous suppression systems should consider the following, as applicable:

la.the minimum required gas concentration, dist ribution, soak time, and ventilation control lb.the anoxia and toxicity hazards associated with the gas lc.the possibility of secondary thermal shock (cooling) damage ld.conflicting requirements for venting during system discharge to prevent loverpressurization versus sealing to prevent loss of agent le.location and selection of the activating detectors lf.the toxicity and corrosive characteristics of the thermal decomposition products of the lagentlWhere total flooding gas extinguishing systems are used, area intake and exhaust ventilation dampers should be c ontrolled in accordance with appr opriate standard s to maintainthe necessary gas concentration. (See NFPA 12, "Standard"Standard on Carbon Dioxide lExtinguishing Systems,"" NFPA 12A, "Standard"Standard on Halon 1301 Fire Extinguishing lSystems," " and NFPA 2001, "Standard"Standard on Clean Agent Fire Extinguishing Systems."

) l(Also , see Regulatory Position 4.1.4.4 of this guide

.)lThe adequacy of gas suppression systems and protected area boundary seals to contain thegas suppressant should be tested as specified in the applicable NFPA S s tandards.lManually actuated gaseous suppression systems should not be used as the primarysuppression system for protecting structures, systems, and components SSCs important to safety.

lManually actuated gaseous systems are acceptable as a backup to automatic water-based firesuppression systems.

3.3.2.1 Carbon Dioxide (CO

2) Systems. llCarbon dioxide extinguishing systems should comply with the requirements of NFPA 12

,l"Carbon Dioxide Extinguishing Systems

." Where automatic carbon dioxide systems are used,they should be equipped with a pre

-discharge alarm system and a discharge delay to permitpersonnel egress. Provisions for locally disarming automatic carbon dioxide systems should bekey locked and under strict administrative control. Automatic carbon dioxide extinguishingsystems should not be disarmed unless controls as described in Regulatory Position 2.4 of thislguide are provided.

l DG-1170, Page 89In addition to the guidelines of NFPA 12, preventive maintenance and testing of thesystems, including verifying agent quantity of high-pressure CO 2 cylinders, should be done.

Particular consideration should also be given to:a.The minimum required CO 2 concentration, distributi on, soak time, and ventilation control;b.The anoxia and toxicity hazards associated with CO 2;c.The possibility of secondary thermal shock (cooling) damage;d.Conflicting requirements for venting during CO 2 injection to prevent over pressurizationversus sealing to prevent loss of agent; ande.Location and selection of the activating detectors.

3.3.2.2 Halon. llHalon fire extinguishing systems should comply with the requirements of NFPA 12A. lWhere automatic Halon systems are used, they should be equipped with a pre

-discharge alarmand a discharge delay to permit personnel egress. Provisions for locally disarming automaticHalon systems should be key locked and under stri ct administrative contro

l. Automatic Halonextinguishing systems should not be disarmed unle ss controls as described in Regulatory Position 2.4 of this guide are provided.

lIn addition to the guidelines of NFPA 12A, preventive maintenance and testing of thesystems, including verifying agent quantity of the Halon cylinders, should be done.

Particular consideration should also be given to:a.The minimum required Halon concentrati on, distribution, soak time, and ventilation control,b.The toxicity of Halon,c.The toxicity and corrosive characteristic s of the thermal decomposition products of Halon, andd.The location and selection of the activating detectors.

3.3.2.3 Clean Agents

. llHalon alternative (or "clean"clean agent"") fire extinguishing systems should complylwith applicable standards such as NFPA 2001. Only listed or approved agents should be used. lProvisions for locally disarming automatic systems should be key locked and under strictl DG-1170, Page 90administrative control. Automatic extinguishing systems should not be disarmed unless controlsas described in Regulatory Position 2.4 of this guide are provided.

lIn addition to the guidelines of NFPA 2001, preventive maintenance and testing of thesystems, including verifying agent quantity of the clean agent cylinde rs/containers, should be done.Particular consideration should also be given to:a.The minimum required clean agent concentra tion, distribution, soak time, and ventilation control,b.The toxicity of the clean agent, c.The toxicity and corrosive characteristics of the thermal decomposition products of theclean agent,d.Conflicting requirements for venting during clean agent injection to prevent overpressurization versus sealing to prevent the loss of agent, ande.The effectiveness of the particular clean agent at its design concentration for the protectedhazard.f.The location and selection of the activating detectors.The guidance in Regulatory Position 3.3 is based on Appendix R to 10 CFR Part 50,CMEB 9.5-1, and IN 92-28.3.4Manual Suppression Systems and Equipment lA The licensee should provide a manual firefighting capability should be provided lthroughout the plant to limit the extent of fire damage. Standpipes, hydrants, and portableequipment consisting of hoses, nozzles, and extinguishers should be provided for use by properlytrained firefighting personnel.

3.4.1 Standpipes and Hose Stations llInterior manual hose installation s should be able to reach any location that contains, or lcould present a fire exposure hazard to, equipment important to safety with at least one effective hose stream. To accomplish this, standpipes with hose connections equipped with a maximum of 30.5 m (100 f ee t) of 38 -mm (1-1/2-inches 1.5-in.) woven-jacket, lined fire hose and suitable lnozzles should be provided in all buildings on all floors. These systems should conform toNFPA 14, "Standard"Standard for the Installation of Standpipe and Hose Systems,"" for sizing,lspacing, and pipe support requirements for Class III sta ndpipes. Water supply calculations s hould demonstrate that the water supply system can meet the lstandpipe pressure and flow requirements of NFPA 14.

l DG-1170, Page 91 Hose stations should be located as dictated by the fire hazard s analysis to facilitate accessland use for firefighting operations. Alternative hose stations should be provide d for an area if thefire hazard could block access to a single hose station serving that area.The proper type of hose nozzle to be supp lied to each area should be based on the firehazard s analysis. The usual combination spray/straight-stream nozzle should not be used in areaslwhere the straight stream can cause unacceptable mechanical damage. Fixed fog nozzles shouldbe provided at locations where high-voltage shock hazards exist. All hose nozzles should haveshutoff capability.

GVolume II, Section 10, Chapter 1, of the 19 th Edition of the " NFPA Fire lProtection Handbook," provides guidance on safe distances for water application to live electricall equipment may be found in the "NFPA Fire Protection Handbook," Chapter 6, Eighteenth Edition.Fire hose should meet the recommendations of NFPA 1961, "Standard"Standard on FirelHose," " and should be hydrostatically tested in accordance with the recommendations of NFPAl 1962, "Standard"Standard for the Inspection, Care, and Use , of Fire Hose Couplings and Nozzlesland the Service Testing of Fire Hose Including Couplings and Nozzles

." "l3.4.2 Hydrants and Hose Houses llOutside manual hose installation s should be sufficient to provide an effective hose streamlto any onsite location where fixed or transient combustibles could jeopardize equipmentimportant to safety. Hydrants should be installed approximately every 76 m (250 ft) on the yardmain system. A hose house equipped with hose and combination nozzle and other auxiliaryequipment recommended in NFPA 24 should be provided as needed, but at least every 305 m(1,000 ft). Alternatively, a mobile means of providing hose and associated equipment, such aslhose carts or trucks, may be used. When provi ded, such mobile equipm ent should be equivalentto the equipment supplied by three hose houses. Mobile equipment should be maintained in good working order and should be readily available lfor fire-fighting activities.

lThreads compatible with those used by local fire departments s hould be provided on allhydrants, hose couplings, and standpipe risers. Alternatively, a sufficient number of hose threadadapters may be provided.Fire hose should be hydrostatically tested in accordance with the recommendations ofNFPA 1962. Fire hose stored in outside hose houses should be tested annually.

l DG-1170, Page 92 3.4.3 Manual Foam llFor flammable and combustible liquid fire hazards, consideration should be given to theuse of foam systems for manual fire suppression protection. These systems should comply withthe requirements of NFPA 11, NFPA 11A, and NFPA 11C, "Standard for Mobile FoamApparatus," as applicable

.l l3.4.4Fire Extinguishers llFire extinguishers should be provided in ar eas that contain or could present a fire lexposure hazard to equipment important to safety. Dry chemical e Extinguishers should be linstalled with due consideration given to possible adverse e ffects on equipment important tosafety installed in the area. NFPA 10, "Standard"Standard for Portable Fire Extinguishers,""lprovides guidance on the installation (including location and spacing) and the use and application lof fire extinguishers.The guidance in Regulatory Position 3.4 is based on 3.4.5 Fixed Manual Suppression llSome fixed fire suppression systems may be manually actuated (e.g., fixed suppression lsystems provided in accordance with Section III.G.3 of Appendix R to 10 CFR Part 50 andlCMEB 9.5-1.

3.5). Manual actuation is generally limited to water spray sy stems and should not be used lfor gaseous suppression systems except when the system provides backup to an automatic water lsuppression system. Fixed manual suppression systems should be designed in accordance with lapplicable guidance of the appropriate NFPA standards. A change from an automatic system to a lmanually actuated system should be supported by an appr opriate evaluation.

ll3.5Manual Firefighting Capabilities l3.5.1 Fire Brigade llA site fire brigade tr ained and equipped for fire fightingfirefighting should be established land should be on site at all times to ensure adequate manual firefighting capability for all areas ofthe plant containing structures, systems, and components SSCs important to safety. The fire lbrigade leader should have ready access to keys for any locked doors.

GRegulatory Position 1.6.4 of this guide provides guidance on fire brigade training and lqualification is provided in Regulatory Position 1.6.4qualifications

.lThe guidelines of NFPA 600 are considered appropriate criteria for organizing, training,and operating a plant fire brigade.

3.5.1.1 Fire Brigade Staffing

. ll DG-1170, Page 93The fire brigade should be include at least five members on each shift. The shiftl supervisor should not be a member of the fire brigade.

3.5.1.2 Equipment. llThe equipment provided for the brigade shoul d consist of personal protective equipmentl such as turnout coats, bunker pants, boots, gloves, hard hats, emergency communicationsequipment, portable lights, portable ventilation equipment, and portable extinguishers.

Self-contained breathing apparatus es using full-face positive-pressure masks approved bylNIOSH (the National Institute for Occupational Safety and Health

- (approval formerly givenlby the U.S. Bureau of Mines) should be provided for fire brigade, damage control, and control room personnel. At least 10 masks should be available for fire brigade personnel. Control roompersonnel may be furnished breathing air by a manifold system piped from a storage reservoir if practical. Service or rated operating life should be at least one-half hour 30 minutes for thelself-contained units. Additional guidance is provided in NFPA 1404, "Standard for a FireDepartment Self-Contained Breathing Apparatus Program."Service Respiratory Protection Program," provides additional guidance.

llFire brigade equipment should be stor ed in accordance with manufacturers' lrecommendations (e.g., firefighter clothing should not to be stor ed where it will be subjected to lultraviolet light from the sun, welding, or fluorescent lights).

l lAt least a 1-hour supply of breathing air in extra bottles should be located on the plantlsite for each unit of self-contained breathing apparatus. In addition, an onsite 6-hour supply of reserve air should be provided for the fire brigade personnel and arranged to permit quick andcomplete replenishment of exhausted air supply bottles as they are returned. If compressors are used serve as a source of breathing air, only units approved for breathing air should be used andl the compressors should be operable assumingin the event of a loss of offsite power. Special carel should be taken to locate the compressor in areas free of dust and contaminants.During refueling and maintenance periods, ad equate self-contained breathing apparatus eslshould be provided near the containment entrances for firefighting and damage control personnel.

These units should be independent of any breathing apparatu ses or air supply systems providedlfor general plant activities and should be clearly marked as emergency equipment.

DG-1170, Page 94 3.5.1.3 Procedures and Pre

-fire Plans

. llProcedures should be established to control actions by the fire brigade on uponlnotification by the control room of a fire

, and to define firefighting strategies. These procedures should include the following

la. A actions to be taken by control room personnel to notify the fire brigade upon report of a lfire or receipt of an alarm on the control room fire alarm panel, for example (e.g.,lannouncing the location of the fire over the PA public address system, sounding fire lalarms, and notifying the shift supervisor and the fire brigade leader of the type, size, and location of the fire

.)lb. A actions to be taken by the fire brigade after notification by the control room of a fire l(e.g., for example, assembling assembling in a designated location, receiving directions lfrom the fire brigade leader, and discharging specific firefighting responsibilities,lincluding selection and transportation of firefighting equipment to the fire location,lselection of protective equipment, operating instructions for use of fire suppression systems, and use of preplanned strategies for fighting fires in specific areas

.l)lc. Define the strategies for fighting fires in all plant areas. These strategies shoulddesignate, including the following

li.F fire hazards in each area covered by the specific pre

-fire plans

.lii.F SSCs credited for fire safe shutdown.

liii.fire suppression agents best suited for extinguishing the fires associated with the lfire hazards in that area and the nearest location of these suppression agents

.li ii v.M most favorable direction from which to attack a fire in each area in view of the lventilation 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. A , as well as a lllaccess and egress routes that involve involving locked doors should be specifically lidentified in the procedure with and the appropriate precau tions and methods for laccess specified

.iv v.P plant systems that should be managed to reduce the damage potential during a llocal fire and the location of local and remote controls for such management (e.g.,

DG-1170, Page 95any hydraulic or electrical systems in the zone covered by the specific firefightingprocedure that could increase the hazards in the area because of overpressurizationoverpressurization or electrical hazards)

.lv i.V vital heat-sensitive system components that need to be kept cool while fighting allocal fire. I , in particular, hazardous com bustibles that need cooling should be ldesignated.

vi i.O organization of firefighting brigades and the assignment of special dutieslaccording to job title so that all firefighting functions are covered by any complete shift personnel complement. These duties include (including command control oflthe brigade, transporting fire suppre ssion and support equipment to the firescenes, applying the extinguishing agent to the fire, communication with the control room, and coordination w ith outside fire departments

.vii.Potential, according to job title so that all firefighting functions are covered by any lcomplete shift pe rsonnel complement lviii.potential radiological and toxic hazards in fire zones

.lviii ix.V ventilation system operation that ensures desired plant air distribution when thelventilation flow is modified for fire containment or smoke clearing operation

.ix x.O operations requiring control room and shift engineer coordination orlauthorization

.x i.I i nstructions for plant operators and general plant personnel during fire

.lxi i.C communications between the fire brigade leader, fire brigade, offsite mutual aidl responders, control room, and licensee's emergency response organization

.Appropriate firefighting procedures should identify the tec hniques and equipment for theuse of water in fighting electrical cable fires in nuc lear plants, particularly in areas containing ahigh concentration of electric cables with plastic insulation. Additional guidance on pre-fireplanning is provided in NFPA 1620NFPA 1620 , "Recommended "Recommended Practice forlPre-Incident Planning," provides additional gu idance on prefire planning

."ll3.5.1.4 Performance Assessment/Drill Criteria

. ll DG-1170, Page 96Fire brigade drills should be performed in the plant so that the fire brigade can practice as la team. Drills should be performed quarterly for each shift fire brigade. Each fire brigade member should participate in at least two drills per year annually.lA sufficient number of these drills, but not less than one for each shift

's fire brigade per lyear, should be unannounced to determine the firefighting readiness of the plant

's fire brigade,lbrigade leader, and fire protection systems and equipment. Persons planning and authorizing an unannounced drill should ensure that the responding shift fire brigade members are not awarethat a drill is being planned until it has begun. At least one drill per year should be performed on a "back"back shift"" for each shift

's fire brigade.

lThe drillslicensee should be preplannedpreplan the drills to establish the traininglobjectives of the drill and should be critiqued critique them to determine how well the training lobjectives have been met.

Unannounced drills should be planned and critiqued by m M embers oflthe management staff responsible for plant safety and fire protection should plan and critique lunannounced drills

. Performance deficiencies of a fire brigade or of individual fire brigade lmembers should be remedied by scheduling additional training for the brigade or members.Unsatisfactory drill performance should be followed by a repeat drill within 30 days.

The local fire department shoul d be invited to participate in drills at least annually.

lAt 3-year intervals, a randomly selected unannounced drill should be critiqued by qualified individuals inde pendent of the licensee

s staff should critique a randomly selected lunannounced drill. A copy of the written report from such individuals should be available for lNRC review.Drills should include the following:

a.Assessment of fire alarm The effectiveness of the fire alarms, time required to notify and lassemble the fire brigade, a nd selection, placement, and use of equipment and firefightingstrategies

. should b.Assessment of each e assessed.

lb.Each brigade member

s knowledge of his or her role in the firefighting strategy for the larea assumed to contain the fire. Assessment of , and the brigade members'member'slconformance with established plant firefighting procedures and use of firefightingequipment, including self-contained emergency breathing apparatus es , communication,llighting, and ventilation should be assessed

. lc.The simulated use of firefighting equipment required to cope with the situation and typeof fire selected for the drill should be evaluated. The area and type of fire chosen for the ldrill should differ from those used in the previous drills so that brigade members aretrained in fighting fires in various plant areas. The situation selected should simulate the DG-1170, Page 97size and arrangement of a fire that could reasonably occur in the area selected, allowingfor fire development during the time required to respond, obtain equipment, and organizefor the fire, assuming loss of automatic suppression capability.

d.Assessment of t The brigade leader

s direction of the firefighting effort as should belassessed with regard to thoroughness, accuracy, and effectiveness.l Drill records should be retained for a period of 3 years and made available for NRCinspection. (See Regulatory Position 1.6.4 of this guide for additional guidancedirection on drilll records.)3.5.2Offsite Manual Fire-F fighting Resources llOnsite fire brigades typically fulfill the role of first responder, but may not have sufficientlpersonnel, equipment, and capability to handle all possible fire events. Arrangements withoffsite fire services may be necessary to augment onsite firefighting capabilities, consistent with the fire hazards analysis and pre

-fire planning documents. The FPP should describe the lcapabilities (e.g., equipment compatibility, training, drills, and command control) of offsite lresponders.

l3.5.2.1 Capabilities

. llThe local offsite fire departments providing that provide back up manual firefightinglresources should have the following capabilities:

a.P p ersonnel and equipment with capacities consistent with t hose assumed in the plant

slfire hazards analysis and pre

-fire plans

.b.H h ose threads or adapters to connect with onsite hydrants, hose couplings, and standpipelrisers. (Regulatory Position 3.4.2 states that onsite fire suppression water systems shouldhave threads compatible with those used by local fire departments or a sufficient numberof thread adapters available

.)3.5.2.2 Training. llLocal offsite fire department personnel providing who provide back up manuallfirefighting resources should be trained in the following

la.O operational precautions when fighting fires on nuclear power plant sites and the needlfor radiological protection of personnel and the special haza rds associated with a nuclear power plant site. l DG-1170, Page 98 b.T t he procedures for notification and ex pected roles of the offsite responders

.lc.S site access procedures and the identity (by position and title) of the individual in the lonsite organization who w ill control the responders

support activities. O (offsitelresponse support personnel should be provide d with appropriate identification cardswhere required. )ld.F f ire protection authorities, responsibilities, and accountabilities with regard to lresponding to a plant fire, including the fi re event command structure between the plantfire brigade and offsite responders

.le.P plant layout, plant fire protection systems and equipment, plant fire hazards, and pre

-firelresponse plans and procedures. 3.5.2.3 Agreement/Plant Exercise

.llThe W licensee should establish written mutual aid agreements should be established lbetween the utility and the offsite fire departments that are assumedlisted in the fire hazards lanalysis and pre

-fire plans toas providing a support response to a plant fire. These agreements lshould delineate fire protection authorities, re sponsibilities, and accountabilities with regard toresponding to plant fire or emergency events, including the fire event command structurebetween the plant fire brigade and offsite responders.The plant fire brigade drill schedule should provide for periodic local fire department participation (at least annually). These drills should effectively exercise the fire event commandstructure between the plant fire brigade and offsite responders. (See Regulatory Position 3.5.1.4for guidance on conduct and evaluation of fire brig ade drills.) Offsite fi re department responseshould be tested periodically in conjunction with the required exercises of the radiologicalemergency response plan required by 10 CFR 50.47

.The guidance in Regulatory Position 3.5 is based on Appendix R to 10 CFR Part 50,NUREG-0654, and CMEB 9.5-1.4.BUILDING DESIGN/PASSIVE FEATURES 4.1, "Emergency Plans."

ll4.Building Design/Passive Features ll4.1General Building and Building System Design l

DG-1170, Page 99This section provides guidance on building layout (e.g., fire areas and zones), materials ofconstruction, and building system design (e.g., electrical, HVAC, lighting, and communicationsystems) important to effective fire prevention and protection.

GRegulatory Position 4.2 lprovides g uidance for passive fire barriers is provided in Regulatory Position 4.2

.l4.1.1Combustibility of Building Components and Features llAccording to GDC 3, noncombustible and heat

-resistant materials must be usedlwherever practical throughout the unit. Inte rior wall and structural components, thermal insulation materials, radiation shielding materials, and soundproofing should be noncombustible.

lThe fire hazards analysis should identify in situ combustible materials used in plant SSCs and lspecify suitable fire protection.

lMetal deck roof cons truction should be noncom bustible and listed as"acceptable"acceptable for fire"" in the UL BuildingUnderwriters Laboratories, Inc. (UL),l"Building Materials Directory," or listed as Class I in the Factory Mutual Research Approvall Guide.

DG-1170, Page 100 4.1.1.1 Interior Finish

. llInterior finishes should be noncombustible. The following materials are acceptable for luse as interior finish without evidence of test and listing by a recognized testing laboratory:

a.P p laster, acoustic plaster, and gypsum plasterboard (gypsu m wallboard), either plain,lwallpapered, or painted with oil- or water-base paint

,lb.C ceramic tile

, and ceramic panels

,llc.G glass , and glass blocks

,lld.B b rick, stone, and concrete blocks, plain or painted

,lle.S s teel and aluminum panels, plain, painted, or enameled , andllf.V vinyl tile, vinyl-asbestos tile, linoleum, or asphalt tile on concrete floors

.llSuspended ceilings and their supports s hould be of noncombus tible construction.

lConcealed spaces should be devoid of combustibles except as noted in Regulatory Position 6.1.2

,lControl Room Complex of this guide

.lIn situ fire hazards should be iden tified and suitable protection provided.

3 Trays exceeding 610 mm (24 inches) should be counted as two trays; trays exceeding 1220 mm (48 inches) should becounted as three trays, regardless of tray fill.The concept of using a potential heat release limit of 8141 kJ/kg (3,500 lBtu/lb) is similar to the "limited combustible" concept with its like limit, as set forth in NFPA 220, "Standard on Types lof Building Construction."

lDG-1170, Page 101 4.1.1.2 Testing and Qualification. llInterior finishes should be noncombustible (see Definitionsthe "Glossary" section of thislguide) or listed by an approving laboratory for the following

la.S surface flame spread rating of 25 or less

, and a smoke development rating of 450 or less,l when tested under American Society for Testing and Materials (ASTM) E-84,l"Standard"Standard Test Method for Surface Burning Characteristics of BuildinglMaterials," and Materials" lb.P p otential heat release of 8141 kilojoules per kilogram (kJ/kg) (3500 Btu/lb3,500 Btu per lpound/) or less when tested under ASTM D3286 or NFPA 259, "Standard ASTM D-3286,l"Standard Test Method for Gross Calorific value of Coal and Coke by the Isoperibol lBomb Calorimeter," or NFPA 259, "Standard Test Method for Potential Heat of Buildingl Materials.""(3)lc.F floor covering critical radiant flux should be as determined by testing in accordance withlNFPA 253, "Test"Standard Method of Test for Critical Radiant Flux of Floor CoveringlSystems Using a Radiant Heat Energy Source."The guidance in Regulatory Position 4.1.1 is based on GDC 3, Appendix R to 10 CFRPart 50, ASB 9.5-1, and CMEB 9.5-1.4.1.2Compartmentation Source"ll4.1.2Compartmentalization, Fire Areas

, and Zones llIn accordance with GDC 3, structures, systems, and components SSCs important to safetylmust be designed and located to minimize the probability and effect of fires and explosions. The

concept of compartmentationcompartmentalization meets GDC 3, in part, by utilizing passivel fire barriers to subdivide the plant into separate areas or zones. These fire areas or zones servethe primary purpose of confining the effects of fires to a single compartment or area, therebyminimizing the potential for advers e effects from fires on redundant structures, systems, and components SSCs important to safety.l DG-1170, Page 102 4.1.2.1 Fire Areas

. llA fire area is defined as that portion of a building or plant that is separated from other lareas by fire barriers, including components of construction such as beams, joists, columns, penetration seals or closures, fi re doors, and fire dampers. Fire barriers that define the boundaries of a fire area should have a fire

-resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> or more and should belprovidedachieve the following

la.To separate structures, systems, and components separation of SSCs important to safety lfrom any potential fires in non

-safety-related areas that could affect their ability toperform their safety function

b.To separate separation of redundant success pathstrains of systems and components limportant to safety from each other so that both are not subject to damage from a single fire;c.To separate separation of individual units on a multiple-unit multiunit site unless the lrequirements of General Design Criterion 5GDC 5, "Sharing of Structures, Systems, and lComponents," are met with respect to fires

.lFire areas should be esta blished on the basis of t The fire hazards analysis should be used lto establish fire areas. Particular design attention to the use of separate

, isolated fire areas for lredundant cables will help to avoi d loss of redundant cables important to safety. Separate fireareas should also be employed to limit the spread of fires between components, including high concentrations of cables important to safety that are major fire hazards within a safety division.Where fire area boundaries are not 3-hour rate d, or not wall-to-wa ll or floor-to-ceiling boundaries with all penetrations sealed to the fire rating of the boundaries, the licensee should lperform an evaluation should be performed to assess the adequacy of the fire area boundaries l(i.e., barriers) to determine whet her the boundaries will withstand th e hazards associated with thearea and, as necessary, protect im portant equipment within the ar ea from a fire outside the area. Unsealed openings should be iden tified and considered when evaluating the overall effectiveness of the barrier (See Regulatory Position 1.4.3 for positi ons related to barrier evaluations. (SeelRegulatory Position 4.2.1 of this guide for positions related to fire barrier testing and lacceptance.)If a wall or floor/ceiling assembly contains major unprotected openings

, such aslhatchways and stairways, plant lo cations on either side of such a barrier should be considered a spart of a single fire area. If success path A is separated by a cumulative horizontal distance of 6.1 m (20 f eet) from success path B, with no intervening combustible materials or fire hazards, and both elevations are provided with fire detection and suppressi on, the area would be consideredacceptable.

DG-1170, Page 103Exterior walls, including penetr ations, should be qualified as rated fire barriers if they are required to separate safe

-shutdown equipment on the interior of the plant from the redundantlequipment located in the immediate vicinity of the exterior wall, if they separate plant areas important to safety from non

-safety-related areas that present a significant fire exposure to theareas important to safety, or if otherwise designated by the FSAR or fire hazards analysis.

An exterior yard area without fire barriers should be cons idered as one fire area.

The arealmay consist of several fire zones. (s See Regulatory Position 4.1.2.2 of this guide.

).l4.1.2.2 Fire Zones

. llFire zones are subdivisions of a fire area and are typically based on fire hazards analyseslthat demonstrate that the fire protection systems and features within the fire zone provide an appropriate level of protection for the associated hazards. Fire zone concepts may be used toestablish zones within fire areas where furthe r subdivision into additional fire areas is notpractical on the basis of existing plant design and layout (e.lg., inside containment).

lEvaluations by some licensees made prior to before Appendix R to 10 CFR Part 50 was lpublished were based on fire zones that do not meet the strict definition of fire areas. In somel cases, the separation of redunda nt success paths within the fire zone boundaries and theseparation between fire zones do not comply with the separation requirements of Appendix R. Such configurations may be acceptable under the exemption process.An exterior yard area considered as one fire area may consist of several fire zones. Thefire hazards analysis should be used to determine the boundaries of the fire zones should be ldetermined by a fire hazards analysis. The protection for redundant , alternative, dedicated, orbackup shutdown systems within a yard area should be determined on the basis of the largestpostulated fire that is likely to occur and the resulting damage. The boundaries of such damageshould be justified with a fire hazards analysis.

The analysis should consider the degree oflspatial separation between divisions; the presence of in situ and transient combustibles, includingvehicular traffic; grading; availa ble fire protection; sources of ignition; and the vulnerability andcriticality of the shutdown

-related systems.l DG-1170, Page 104 4.1.2.3 Access and Egress Design. Provisions should be made for personnel laccess to and escape routes from each fire area. Under emergency conditions, promptingress into certain areas important to safety should be ensured to enable llThe plant layout should provide adequate means of access to all plant areas for manuallfire suppression and safe shutdown of a nuclear power plant. . The plant layout should also allow for safe access and egress to areas for personnel performing lsafe-shutdown operations. Consider ations should include fire and post-fire habitability in safe-lshutdown areas, protection or separation from fire conditions of access and egress pathways to lsafe-shutdown SSCs, and potential restrictions or delays to safe-shutdown area access potentially lcaused by security locking systems.

lStairwells outside primary containment serving as escape routes, access routes forfirefighting, or access routes to areas containing equipment necessary for safe shutdown shouldbe enclosed in masonry or conc rete towers with a minimum fire rating of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and self-closingClass B fire doors. Fire exit routes should be clearly marked.

Prompt emergency ingress into electrically locked areas by essential personnel should beensured through the combined use and provision of the following features.

a.R reliable and uninterruptible auxiliary power to the entire electrical locking system,lincluding its controls

.lb.E electrical locking devices that are required to fail in the secure mode for security lpurposes, with secure mechanical means a nd associated procedures to override thedevices upon loss of both primary and auxiliary power (e.g., key locks with keys held by appropriate personnel who know when and how to use them)

.c.P periodic tests of all locking systems and mechanical overrides to confirm their loperability and their capability to switch to auxiliary power. Also see Regulatory Positions 4.1.6 and 4.1.7 for guidanceof this guide provide direction lrelated to emergency lighting and communication capabilities during fires.

lThe guidance in Regulatory Position 4.1.2 is based on GDC 3, Appendix R to 10 CFRPart 50, CMEB 9.5-1, GL 83-33, GL 86-10, BL 81-03, and IN 84-09.

DG-1170, Page 105 4.1.3 Electrical Cable System Fire Protection Design l4.1.3.1 Cable Design

. llElectric cable construction should pass the flame test in IEEE Standard 383, ""IEEElStandard for Type Test of Class IE Electric Cables, Field Splices, and Connections for NuclearlPower Generating Stations,"" or IEEE Standard 1202, ""IEEE Standard for Flame Testing oflCables for Use in Cable Trays in Industrial and Comme rcial Occupancies.

"" (This does not limply that cables passing either test w ill not require additi onal fire protection.) For cablelinstallations in operating plants and plants under construction prior to before July 1, 1976, that dolnot meet the IEEE Standard 383 fl ame test requirements, all cab les should be covered with anapproved flame retardant coating and properly derated

, or be protected by automatic suppression.

4.1.3.2 Although cable coatings have been s hown to reduce flame spread, coated cables lare considered intervening combustibles when determining the protection requirements of lSection III.G.2 of Appendix R to 10 CFR Part 50. Coated cables do not have higher damage lthresholds and, therefore, are not equivalent to IEEE 383 cables. In addition, coated cables can land do ignite in fires.

l lNew reactor fiber optic cable insulation and jacketing should al so meet the fire and flame ltest requirements of IEEE 383 or IEEE 1202.

l l4.1.3.2Raceway/Cable Tray Construction. llOnly metal should be used for cable trays. Only metallic tubing should be used forl conduit. Thin-wall metallic tubing should not be used. Flexible metallic tubing should only beused in short lengths to connect components to equipment. Other raceways should be made of noncombustible material. Cable raceways should be used only for cables.

4.1.3.3 Electrical Cable System Fire Detection and Suppression

. llRedundant cable systems important to safety outside the cable spreading room should belseparated from each other and from potential fire exposure hazards in non

-safety-related areas by fire barriers with a minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to the extent feasible. Th e ose fire areas thatlcontain cable trays important to safety should be provided with fire detection. Cable trays shouldbe accessible for manual fire fightingfirefighting and cables should be designed to allow wettingl down with fire suppression water without electrical faulting. Ma nual hose stations and portablehand extinguishers should be provided.Manual hose standpipe systems may be relied upon to provide the primary fire suppression (in lieu of automatic water suppression systems) for cable trays of a single divisionimportant to safety that are se parated from redundant safety divisions by a fire barrier with aminimum rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and are normally accessible for manual fire fightingfirefighting if alllof the following conditions are met

.:l 4 The 181°C [325°F] temperature condition was established by allowing the temperature of the unexposed side of the firebarrier to rise 139°C [250°F] above the assumed 24°C [75°F] ambient air temperature, as measured by thethermocouples within the test specimen at the onset of the fire exposure during the fire test.orays exceeding 610 mml(24 in.) should be counted as two trays; trays exceeding 1,220 mm (48 in.) should be counted as three trays, regardless lof tray fill.

lDG-1170, Page 106a.The number of equivalent (4) standard 610-mm- (24-inch-24-in.-) wide cable trays (both limportant to safety and non

-safety-related) in a given fire area is 6 six or less;l.lb.The cabling does not provide instrumentation, control, or power to systems required to achieve and maintain hot shutdown; and.lc.Smoke detectors are provided in the area of these cable routings, and continuous line-typeheat detectors are provided in the cable trays.In other areas where it may not be possible because of other overriding design featuresnecessary for reasons of nuclear safety to separate redundant cable systems important to safety by3-hour-rated fire barriers, or if cable trays are not accessible for manual firefighting, cable trays should be protected by an automatic fire suppression system.

4.1.3.4 Electrical Cable Separation

. llRedundant systems used to mitigate the consequences of design

-basis accidents but not lnecessary for safe shutdown may be lost to a single exposure fire. However, protection should beprovided so that a fire within only one such system will not damage the redundant system. Therefore, the separation criteriaguidelines of Regulatory Position 5.

53 of this guide apply only lto the electrical cabling needed to support the systems that are used for post-fire safe -shutdown.

lAll other redundant Class 1E and associated electrical cables shoul d meet the separationcriteriaguidelines of Regulatory Guide 1.75.

lWhen the electrical cabling is covered by separation criteria required for both post-firelsafe -shutdown and accident mitigation, the more stringent criteria of Regulatory Position 5.

5 3lapply. [Note that compliance with post-fire safe -shutdown requirements may be achieved lwithout separation of redundant Class 1E cabling by providing alternative, dedi cated, or backupshutdown capability (see Regulatory Position 5.

6 4); however, this does not preclude the lseparation criteria of Regulatory Guide 1.75 for redundant Class 1E and associated cables used inaccident mitigation.]For plants with a C c onstruction P permit issued prior to before July 1, 1976, where cables limportant to safety do not satisfy the provisions of Regulatory Guide 1.75, all exposed cables should be covered with an approved fire retardant coating or a fixed automatic water firesuppression system should be provided

.4.1.3.5 Transformers

. ll DG-1170, Page 107Transformers that present a fire hazard to equipment important to safety should belprotected as described in Regulatory Position 7.3 of this guide.

4.1.3.6 Electrical Cabinets

. llElectrical cabinets present an ignition source for fires and a potential for explosivelelectrical faults that can result in damage not only to the cabinet of origin, but also to equipment,cables, and other electrical cabinets in the vicinity of the cabinet of origin. Fire protectionsystems and features provided for the general area containing the cabinet may not be adequate toprevent damage to adjacent equipment, cables, and cabinets following an energetic electrical fault. Energetic electrical faults are more of a concern with high-voltage electrical cabinets

([i.e.,l480 volts (V) and above)]. High- voltageHigh-voltage cabinets should be provided withladequate spatial separation or substantial physical barriers to minimize the potential for an energetic electrical fault to damage adjacent equipment, cables, or cabinets important to safety.Rooms containing elect rical cabinets important to safety should be provided with area

-wide automatic fire detection, automatic fire suppression, and manual fire suppression capability.Electrical cabinets containing a quantity of combustible materials (e.g., cabling) sufficientto propagate a fire outside the cabinet of fire origin should be provided with in-cabinet automatic fire detection.The guidance in Regulatory Position 4.1.3 is based on APCSB 9.5-1, CMEB 9.5-1, and Mattson Memo 1983.

4.1.4HVAC Design llSuitable design of the ventilation systems can limit the consequences of a fire bylpreventing the spread of the products of combustion to other fire areas. It is important thatmeans be provided to ventilate, exhaust, or isolate the fire area as required and that consideration be given to the consequences of failure of ventilation systemssystem failure caused by the fire,lcausingresulting in a loss of control for ventilating, exhausting, or isolating a given fire area.

lSpecial protection for ventilation power and control cables may be necessary. The powersupply and controls for mechanical ventilation sy stems should be run outsi de the fire area servedby the system where practical.Release of smoke and gases containing radioactive material s to the environment shouldbe monitored in accordance with emergency plans as described in the guidelines of Regulatory

Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors

." Anylventilation system designed to exhaust potentially radioactive smoke or gases should beevaluated to ensure that inadvertent operation or single failures will not violate the radiologically controlled areas of the plant design. This should include containment functions for protecting thepublic and maintaining habitability for operations personnel.

DG-1170, Page 108Fresh air supply intakes to areas containing equipment or system s important to safety should be located remote away from the exhaust air outlets and sm oke vents of other fire areas to lminimize the possibility of contaminating the in take air with the products of combustion.Where total

-flooding gas

-extinguishing systems are used, area intake and exhaust lventilation dampers should be controlled in accordance with NFPA 12 and , NFPA 12A, or NFPAl2001 to maintain the necessary gas concentration. (ASee a lso see Regulatory Position 3.3.2 oflthis guide

.)ll4.1.4.1 Combustibility of Filter Media

. llFilters for particulate and gaseous effluents may be fabricated of combustible media (e.g.,lHEPA and charcoal filters). The ignition and burning of these filters may result in a direct release of radioactive material to the environment

, or may provide an unfiltered pathway uponfailure of the filter. Filter combustion may spread fire to other areas.Engineered safety feature filters should be protected in accordance with the guidelines ofRegulatory Guide 1.52, "Design, Inspection, and Testing Criteria for Air Filtration and lAdsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup System lLight-Water-Cooled Nuclear Power Plants

." Any filter that includes combustible materials and lis a potential exposure fire hazard that may affect components important to safety should beprotected as determined by the fire hazards analysis.

l l4.1.4.2 Smoke Control/Removal

. llSmoke from fires can be toxic, corrosive, and may obscure visibility for emergency legress and access to plant areas. Smoke control and removal may be necessary to support manual suppression activities and safe

-shutdown operations.

lConsideration should be given to the inst allation of automatic suppression systems as ameans of limiting to limit smoke and heat generation. Smoke and corrosive gases should lgenerally be discharged directly outside to an area that will not affect plant areas important to safety. The normal plant ventilation system may be used for this purpose

, if capable and lavailable. To facilitate manual firefighting, separate sm oke and heat vents should be providedconsidered in specific areas such as cable spreading rooms, diesel fuel oil storage areas,lswitchgear rooms, and other areas where the potential exists for heavy smoke conditions. (s S eelNFPA 204, "Guide"Standard for Smoke and Heat Venting," for additional guidance on smoke lcontrol.").l4.1.4.3 Habitability

. llProtection of plant operations staff from the effects of fire and fire suppression (e.g.,lgaseous suppression agents) may be necessary to en sure safe shutdown of the plant. For controlroom evacuation, egress pathways and remote control stations should also be habitable.

DG-1170, Page 109Consideration should be gi ven to protection of safe

-shutdown areas from infiltration of gaseouslsuppression agents. The capability to ventilate, exha ust, or isolate is particularly important toensure the habitability of rooms or spaces that should be attended in an emergency. In thedesign, provision should be made for personnel access to and escape routes from each fire area. Habitability of the following areas should be considered

.:lC a.control rooml lb.P post-fire safe

-shutdown areasl lc.P personnel access and egress pathwaysl lStairwells should be designed to minimize smoke infiltration during a fire. Staircasesmay serve as escape routes and access routes for fire fightingfirefighting. Fire exit routes shouldlbe clearly marked. Stairwells, el evators, and chutes should be en closed in fire-rated construction with automatic fire doors at least equal to the enclosure construction

, at each opening into thebuilding. Elevators should not be used during fire emergencies.

4.1.4.4 Fire Dampers

. llRedundant safe

-shutdown components may be separated by fire-resistant walls, floors,lenclosures, or other types of barriers. For the fire barriers to be effective in limiting the propagation of fire, ventila tion duct penetrations of fire barriers should be protected by means offire dampers that are arranged to automatically close in the event of fire. Additional guidance is provided in NFPA 90A, "Standard"Standard for the Installation of Air Conditioning andlVentilating Systems," provides additional guidance

." (ASee a lso see Regulatory Positionl 4.2.1.3.)The guidance in Regulatory Position 4.1.4 is based on CMEB 9.5-1 and IN 83-69.

4.1.5 Drainage of this guide.)

ll4.1.5 DrainagellFloor drains sized to remove expected firefighting water without flooding equipmentimportant to safety should be provided in areas where fixed water fire suppression systems areinstalled. Floor drains should al so be provided in other areas where hand hose lines may be usedif such firefighting water could cause unacceptable damage to equipment important to safety in the area. Facility design should ensure that fire water discharge in one area does not impactequipment important to safety in adjacent areas. Housekeeping procedures should ensure that ldrains are not blocked by accumulated dirt or other debris.

lWhere gasgaseous suppression systems are installed, the drains should be provided withladequate seals or the gas suppression system should be sized to compensate for the loss of thesuppression agent through the drains. (s See Regulatory Position 3.3.2 of this guide.

).l DG-1170, Page 110 DrainsDrainage in areas containing combustible liquids should have provisions for lpreventing the backflow ofequipment important to safety should be designed to minimize the lpotential to propagate fire from areas containing flammable or combustible liquids to plant areas limportant to safety through via the interconnected drain drainage system s.lWater drainage from areas that may contain radioactivity should be collected, sampled,and analyzed before discharge to the environment.The guidance in Regulatory Position 4.1.5 is based on CMEB 9.5-1.

4.1.6 Emergency Lighting llEmergency lighting should be provided throughout the plant as necessary to support fire lsuppression actions

, and safe -shutdown operations, including access and emergency egresslpathways to safe-shutdown areas during a fire event.

l4.1.6.1 Egress Safety

. llEmergency lighting should be provided in support of the emergency egress design lguidelines in outlined in Regulatory Position 4.1.2.3 of this guide

. l DG-1170, Page 111 4.1.6.2 Post-Fire Safe

-Shutdown. llLighting is vital to post-fire safe

-shutdown and emergency response in the event of fire. l S The licensee should provide suitable fixed and portable emergency lighting should be provided

,las follows

.:la.Fixed , self-contained lighting consisting of fluorescent or sealed-beam units withl individual 8-hour minimum battery power supplies should be provided in areas needed for operation of safe

-shutdown equipment and for access and egress routes thereto.

lThe level of illumination provided by emergency lighting in access routes to and in areas where shutdown functions are performed is a level that is sufficient to enable an operatorto reach that area and perform the shutdown functions. At the remote shutdown panels, the illumination levels should be suffi cient for control panel operators.

The bases forestimating these levels of lighting are the gu idelines contained in Section 9.5.3 of the Standard Review Plan, NUREG-0800. If a licensee has provided emergency lighting perin accordance with Section III.J of Appendix R to 10 CFR Part 50, the licensee shouldlverify by field testing that this lighting is adequate to perform the intended tasks.Routine maintenance and initial and periodic field testing of emergency lighting systemsshould ensure their ability to support access, egress, and operations activities for the full8-hour period accounting for anticipated envi ronmental conditions, battery conditions, and bulb life.b.Suitable sealed-beam battery-powered portable hand lights should be provided foremergency use by the fire brigade and othe r operations personnel re quired to achieve safe plant shutdown.If emergency lights are powered from a central battery or batteries power the emergency llights, the distribution system should contain such protective devices thatnecessary to preclude alfire in one area will not causefrom causing a loss of emergency lighting in any unaffected areal neededrequired for safe -shutdown operations.lThe guidance in Regulatory Position 4.1.6 is based on Appendix R to 10 CFR Part 50,CMEB 9.5-1, GL 86-10, IN 95-36, IP 64100, TI 2515/62, and Vollmer Memo 1983b.

4.1.7Communications llThe communication system design should provide effective communication betweenl plant personnel in all vital areas during fire conditions under maximum potential noise levels.

DG-1170, Page 112Two-way voice communications are vital to safe shutdown and emergency response in the event of fire. Suitable comm unication devices should be provided

, as follows

.:la.Fixed emergency communications indepe ndent of the normal plant communicationsystem should be installed at preselected stations.b.A portable radio communications system should be provided for use by the fire brigade and other operations pers onnel required to achieve safe plant shutdown.

This system lshould not interfere with the communications capabilities of the plant security force. Fixed repeaters installed to permit use of portable radio communication units should beprotected from exposure fire damage.

Pre-operational and periodic testing should ldemonstrate that the frequencies used for portable radio communication will not affect the actuation of protective relays.The guidance in Regulatory Position 4.1.7 is based on NUREG-0800 and CMEB 9.5-1.

4.1.8Explosion Prevention llIn situ and transient explosion hazards should be identified a nd suitable protection lprovided. Transient explosion hazards that cannot be eliminated s hould be controlled and suitable protection provided. (See Regulatory Position 2.1 of this guide regarding control of lcombustibles.)Miscellaneous storage and piping for flammable or combustible liquids or gases shouldnot create a potential exposure hazard to systems important to safety or the fire protectionsystems that serve those areas. (ASee a lso see Regulatory Positions 2.1.3 and 7.5 of this guide

.)lSystems or processes that involve hydrogen supplies (e.g., generator cooling systems andreactor coolant hydrogen addition systems) and those that may evolve hydrogen or explosivegases (e.g., waste gas and solid radioactive waste processing systems) should be designed toprevent development of explosive mixtures by limiting the concentration of explosive gases and

vapors within enclosures to less than 50%50 percent of the lower explosive limit, or by limiting loxygen within systems containing hydrogen. Hydrogen distribution and supply systems shouldinclude design features that mitigate the consequences of system damage, such as excess flow

valves or flow restrictors, double-walled pipe with annulus leak detection, and rupturediaphragms.

(ASee a lso see Regulatory Position 7.5 of this guide

.)lThe construction, installati on, operation, and maintenance of bulk gas (includingliquefied gas) storage and the related loading and dispensing systems should comply with goodindustry practice and the relevant NFPA S standards, as applicable (e.g., NFPA 50A, "Standard lfor Gaseous Hydrogen Systems at Consumer Sites," NFPA 50B, "Standard for LiquefiedHydrogen Systems at Consumer Sites," 54 and NFPA 54, "National Fuel Gas Code" 55).lIf the potential for an explosive mixture of hydrogen and oxygen exists in off gasoffgaslsystems, the systems should either be designed to withstand the effects of a hydrogen explosion DG-1170, Page 113or be provided with dual gas analyzers with automatic cont rol functions to preclude theformation or buildup of explosive mixtures. The guidance in Regulatory Position 4.18 is in NUREG-0800 and CMEB 9.5-1.4.2Passive Fire ResistiveNFPA 69 is the applicable standard for explosion prevention lsystems.l lRevision 1of Regulatory Guide 1.91, "Evaluations of Explosions Postulated to Occur on lTransportation Routes Near Nuclear Power Plants," provides guidance for the assessment of lexplosion hazards related to transportation near the plant site.

ll4.2Passive Fire-Resistive Featuresll4.2.1 Structural Fire Barriers llFire barriers are those components of construction (walls, floors, and their supports),lincluding beams, joists, columns, penetration seal s or closures, fire doors, and fire dampers thatare rated by approving laboratorie s in hours of resistance to fire and are used to prevent thespread of fire.Where exact replication of a tested configur ation cannot be achieved, the field installationshould meet all of the following criteria

.:la.The continuity of the fire barrier material is maintained

.lb.The thickness of the barrier is maintained

.lc.The nature of the support assembly is unchanged from the tested configuration

.ld.The application or "end"end use"" of the fire barrier is unchanged from the testedlconfiguration

.le.The configuration has been reviewed by a qualified fire protection engineer and found to provide an equiva lent level of protection.

lNew reactor designs should be based on providing structur al barriers between redundant lsafe-shutdown success paths wherever feasible and should minimize the reliance on localized lelectrical raceway fire barrier systems, as described in Regulatory Position 4.2.3 of this guide.

lThis approach is in accordance with the enhanced fire protection criteria for new reactors ldescribed in Regulatory Position 8.2 of this guide.

l DG-1170, Page 114 lSee Regulatory Position 4.1.2 of this guide for additional guidance on the design of fire lbarriers relative to compartmentationcompartmentalization and separation of equipment.

l4.2.1.1 Wall, Floor, and Ceiling Assemblies

. llWall, floor, and ceiling constr uction should be noncombustible. (s See Regulatory lPosition 4.1.1 of this guide.

). NFPA 221, "Standard"Standard for High-Challenge Fire Walls and lFire Barrier Walls,"" can be used as guidance for constructi on of fire barrier walls. Materials of lconstruction for walls, floors, and ceilings serving as fire barriers should be rated by approving laboratories in hours of resistance to fire.Building design should ensure that openings through fire barriers are properly protected. Openings through fire barriers that separate fire areas should be s ealed or closed to provide a fire

-resistance rating at least equal to that required of the barrier itself.

The construction and linstallation techniques for penetrations through fi re barriers should be qualified by fire endurancetests. (see RegulatorySee Regulatory Position 4.2.1.5, Testing and Qualification of this guide.

).l4.2.1.2 Fire Doors. llBuilding design should ensure that door openings are properly protected.

These openings lshould be protected with fire doors that have been qualified by a fire test. The construction and installation techniques for doors and door openings throug h fire barriers should be in accordance consistent with the door manufacturer's recommendations and the tested lconfiguration.

Modifications to fire doors should be evaluated. Where a door is part of a fire areaboundary, and a modification does not affect the fire rating (for examplee.g., installation of lsecurity "contacts""contacts"), no further analysis need be performed. If the modifications could lreduce the fire rating (for examplee.g., installation of a vision panel), the fire rating of the door lshould be reassessed to ensure that it continues to provide an equivalent a level of protection lequivalent to a rated fire door.

lFire doors should be self-closing or provided with closing mechanisms and should beinspected semiannually to verify that automatic hold-open, release, and closing mechanisms and latches are operable. One of the following measures should be provided to ensure theythat thelfire doors will protect the opening as required in case of fire

.:la.Fire doors should be kept closed and electrically supervised at a continuously mannedlocation;.lb.Fire doors should be locked closed and inspected weekly to verify that the doors are in theclosed position

DG-1170, Page 115

.lc.Fire doors should be provided with automatic hold-open and release mechanisms andlinspected daily to verify that doorways are free of obstructions

or.ld.Fire doors should be kept closed and inspected daily to verify that they are in the closed position. Areas protected by automatic total flooding gas suppression systems should haveelectrically supervised self-closing fire doors or should satisfy option (a) above.

Additional guidance for fire doors is provided in NFPA 80, "Standard"Standard for FirelDoors and Fire Windows.

""l4.2.1.3 Fire Dampers

. llBuilding design should ensure that ventilation openings are properly protected. Theselopenings should be protected with fire dampers that have been fire tested. In addition, the construction and installa tion techniques for ventilation openings through fire barriers should bequalified by fire endurance tests. For ventilation ducts that penetr ate or terminate at a fire wall,guidance in NFPA 90A indicates that ventilation fi re dampers should be in stalled within the fire wall penetration for barriers with a fire rating greater than or equal to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. NFPA 90Arequires that fire dampers be installed in all air transfer openings within a rated wall.

Until recently, the only industry standard governing the design, fabrication, and testing offire dampers was Underwriters Laboratories, Inc. (UL)

UL Standard 555, "Fire"Fire Dampers andlCeiling Dampers

."" The standard does not evaluate whether or not fire dampers will close underlair flowairflow conditions. Therefore, the UL fire damper rating only indicates whether a firel damper in the closed position will maintain its integrity under fire conditions for a specific time period.Fire damper testing methods that do not simula te the actual total di fferential pressure atthe damper (i.e., visual inspection or drop testing with duct access panels open) may not showoperability under air flowairflow conditions. Fire damper surveillance testing should model airlflowairflow to ensure that the dampers will close fully when called upon to do so. This can beladdressed by (1) type testing "worst-case" air flow"worst-case" airflow conditions ofl plant-specific fire damper configurations, (2) testing under air flowairflow conditions all damperslinstalled in required fire barriers, or (3) administratively shutting down the ventilation systems to

an area upon confirmation of a fire. The last approach should be incorporated into plantemergency procedures should incorporate the latter approach

.l DG-1170, Page 116 4.2.1.4 Penetration Seals. llOpenings through fire barriers for pipe, conduit, and cable trays that separate fire areas lshould be sealed or cl osed to provide a fire

-resistance rating at least equa l to that required of the lbarrier itself. Openings inside conduit larger than 102 mm (4 inches in.) in diameter should be lsealed at the fire barri er penetration. Openings inside conduit 102 mm (4 inches 4 in.) or less in ldiameter should be seal ed at the fire barrier unless the conduit extends at least 1.5 m (5 f ee t) oneach side of the fire barrier and is sealed either at both ends or at the fire barrier with material toprevent the passage of smoke and hot gases. Fire barrier penetrations that maintain environmental isolation or pressure differentials should be qualified by test to maintain thebarrier integrity under such conditions.

Penetration seals should be installed by qualif ied individuals

, who are trained andlacertified by the manufacturer. A ppropriate quality assurance/quality control QA/QC methodslshould be in force during installation. As part of the installation process, penetration seals should be specifically labeled and documented then inspected to ensure that the seal does not contain lvoids, gaps, and splitshas been installed in accordance with its design

.l4.2.1.5 Testing and Qualification lla.Structural F fire BarrierslThebarriers-The design adequacy of fire barrier walls, floors, ceilings, and enclosures lshould be verified by fire endurance testing.

The NRC fire protection guidance refers to lthe guidance of NFPA 251 and ASTM E-119, "Standard"Standard Test Methods for Fire lTests of Building Cons truction and Materials,"" as acceptable test methods for ldemonstrating fire endurance performance. The guidance of NFPA 251 and ASTME-119 should be consulted with regard to construction, materials, workmanship, and details such as dimensions of parts and the size of the specimens to be tested. In addition,NFPA 251 and ASTM E-119 should be consulted with regard to the placement of thermocouples on the specimen.

The following represent the fire endurance test acceptance criteria for wall, floor, ceiling,land enclosure fire barriers are:i.The fire barrier design has withstood the fire endurance test without the lpassage of flame or the ignition of cotton waste on the unexposed side fora period of time equivalent to the fire

-resistance rating required of the lbarrier;.lii.The temperature levels recorded on the unexposed side of the fire barrier lare analyzed and demonstra bl te that the maximum temperature does not lexceed 139

° C [250°F](250 F) above the ambient; and l DG-1170, Page 117 atmosphere.

liii.The fire barrier remains intact a nd does not allow projection of waterlbeyond the unexposed surface during the hose stream test.If the above criteria are met for fire barrier walls, floors, ceilings, and free

-lstanding equipment enclosures separating safe

-shutdown functions within thelsame fire area, the barrier is acceptable.

b.Penetration F fire BarrierslPenetrationbarriers-Penetration fire barriers should be qualified by tests conducted by anlindependent testing authority in accordance with the provisions of NFPA 251 and ASTME-119, "Standard Test Methods for Fire Tests of Building Construction and Materials." orlASTM E-119. In addition, ASTM E-814, "Standard"Standard Test Method for Fire Testslof Through-Penetration Fire Stops,"" or IEEE Standard 634, ""IEEE Standard CablelPenetration Fire Stop Qualification Test,"" could be used in the development of alstandard fire test.

DG-1170, Page 118The acceptance criteria for the test are as follows

li.The fire barrier design has with stood the fire endurance test without lpassage of flame or the ignition of cables on the unexposed side for aperiod of time equivalent to the fire resistance

-rating required of the lbarrier.ii.The temperature levels recorded for the unexposed side of the fire barrier lare analyzed and demonstrate that the maximum temperature does not exceed 181

° C (325° F) or 139° C (250° F) above the ambientltemperature. Higher temperatures at through

-penetrations may be lpermitted when justified in terms of cable insulation ignitability.iii.The fire barrier remains intact a nd does not allow pr ojection of water lbeyond the unexposed surface during the hose stream test.

The stream lshould be delivered through(1) through a 38 -mm (1-1/2-inch 1.5-in.)lnozzle set at a discharge angle of 30%30 percent with a nozzle pressure of l517 kPa (75 psi) and a minimum discharge of 284 L/m (75 gpm) with thetip of the nozzle a maximum of 1.5 m (5 ft) from the exposed face

, or thelstream should be delivered (2) through a 38

-mm (1-1/2-inch 1.5-in.) nozzlelset at a discharge angle of 15%15 percent with a nozzle pressure of 517 lkPa (75 psi) and a minimum discharge of 284 L/m (75 gpm) with the tip ofthe nozzle a maximum of 3 m (10 ft) from the exposed face

, or the stream lshould be delivered (3) through a 64

-mm (2-1/2-inch 2.5-in.) national lstandard playpipe equipped with 29

-mm (1-1/8-inch 1 c-in.) tip, nozzle lpressure of 207 kPa (30 psi), located 6.1 m (20 ft) from the exposed face.

lThe construction and in stallation techniques fo r door and ventilation lopenings and other penetrations through fire ba rriers should be qualifiedby fire endurance tests. The test specimen should be truly representative of the construction for which classifi cation is desired as to materials, workmanship, and details such as dime nsions of parts, and should be built under conditions representative of those obtaining as practically applied inbuilding construction and operation. The physical properties of thematerials and ingredients used in th e test specimen s hould be determined and recorded.

In view of the large number of possible penetration seal configurations, it may notbe practical to test every penetration configuration. The following section providesguidance on evaluation ofevaluating penetration seal designs against the results of limited lfire test programs.

l l4.2.1.6 Evaluation of Penetration Seal Designs with Limited Testing. l DG-1170, Page 119The results of fire test programs that include a limited selection of test specimens thatlhave been specifically designed to enco mpass or bound the entire population of in-plantpenetration seal configurations may be acceptable. In such cases, the engineering evaluationperformed to justify the seal designs should consider the following

.:la.Size of sealed opening - Inopening-In some cases, a successful fire endurance test of al particular fire barrier penetration seal configuration for a particular size opening may beused to justify the same configuration for smaller openings.b.Penetrating items - Aitems-A satisfactory test of a seal configuration that contains al particular pattern of penetrating items can be used to qualify variations on the tested pattern. Variations that are acceptable include eliminating or repositioning one or moreof the penetrating items, reducing the size (cross-sectional ar ea) of a particularpenetrating item, or increasing the spacing between penetrating items. However, since penetrating items provide structural support to the seal, the free area of the seal materialand the dimensions of the largest free span may also be factors that affect the fire-resistive performance of the seal assembly. The thickness of the seal material needed to obtain a particular fire rating may also be a function of the free area or the distancebetween the penetrating items and the outside edge of the seal assembly. In other cases, consideration of the penetrating items takes on special performance importance because oflthe heat sink they provide.c.Cable type and fill - Afill-A satisfactory test of a seal configuration with certainlelectrical penetrations containing a specified fill ratio and cable type can be used to qualify similar configurations containing the same or a smaller cable fill ratio and the same cable jacket material or a less combustible jacket material. The thermal conductivity of the penetrating cables is also important.d.Damming materials - Thematerials-The fire -resistive performance of a given seallconfiguration can be improved if a fire-resistant damming material covers one or both surfaces of the seal. A satisfactory test of a seal configuration w ithout a permanent fire-resistant dam can be used to qualify the same configuration with a permanent fire-resistant dam, all other seal attributes being equal.

The converse is not true.e.Configuration orientation - A orientation-A satisfactory test of a particular seallconfiguration in the horizontal orientation (with the test fire below the seal) can be usedto qualify the same configuration in a vertical orientation if the symmetry of the design configurations are comparable. For example, if a non

-symmetric penetration sealconfiguration (e.g., a seal with a damming board on the bottom

, but not on the top) isqualified for a floor-ceiling orientation with the damming board on the fire side of the test DG-1170, Page 120specimen, the configuration could only be qualified for a wall orientation if a dammingboard was installed on both sides of the seal or if the potential fire hazard is limited to the side with the damming board.f.Material type and thickness - Satisfactorythickness-Satisfactory testing of a particular lseal configuration with a specific seal mate rial thickness can be used to qualify the sameconfiguration with a greater seal material thickness of the same type of seal material. The converse is not true.g.Type testing - Intesting-In cases in which a single test of a particular seal configuration lis to serve as a qualification test for the same or similar design configurations with different design parameters, the tested configuration should be the worst-case designconfiguration with the worst-case combination of design parameters.

This would test andqualify a condition that would fail first, if failure occurs at all. Successful testing of the lworst-case condition can then serve to qualify the same or similar design configurations lfor design parameters within the test range. It would be appropriate to conduct multipletests to assess a range of design parameters.The guidance in Regulatory Position 4.2.1 is based on Appendix R to 10 CFR Part 50,CMEB 9.5-1, NUREG-1552, Supplement 1 to NUREG 1552, GL 86-10, Supplement 1 to GL86-10, IN 83-69, IN 88-04, IN 88-56, and IN 89-52.

4.2.2 4.2.2Structural Steel Protection. llStructural steel forming a part of or supporting fire barriers should be protected to provide lfire resistance equivalent to that required of the barrier. Where the structural steel is notprotected and has a lower fire rating than the required rating of the fire barrier, the configurationshould be justified by a fire hazards analysis that showsshould justify the configuration by ldemonstrating the temperature that the steel will reach during fire and the ability of the steel to lcarry the required loads at that temperature. The need to protect structural steel that forms a part

of or supports fire barriers is consistent with sound fire protection engineering principles asdelineated in NFPA codes and standards and the NFPA Fire"Fire Protection Handbook.

"lStructural steel whose sole purpose is to carry dynamic loads from a seismic event need not be protected solely to meet fire barrier requirements, unless the failure of any structural steelmember owing to a fire could result in significant degradation of the fire barrier.

The guidance in Regulatory Position 4.2.2 is based on CMEB 9.5-1, GL 88-33, and GL 86-10.4.2.3 Fire Resistive ll DG-1170, Page 121 4.2.3Fire-Resistive Protection for Electrical Circuits ll4.2.3.1 Electrical Raceway Fire Barrier Systems. llRedundant cable systems important to safety should be separated from each other andlfrom potential fire exposure hazards in non-safety-related areas in accordance with the separationmeans of Regulatory Position 5.5.

a-ca-c of this guide. For In areas where the separation oflelectrical circuits important to post-fire safe -shutdown cannot be accomplished viaby means of lrated structural fire barrier s, cable protection assemblies have should be en applied to conduit andlcable trays to meet 1-hour a nd 3-hour separati on requirements, as required. Where 1-hour fire-lresistive barriers are applied, au tomatic fire detecti on and suppression should also be installed

.lThe design of fire barriers for horizontal and vertical cable trays should meet the requirements of ASTM E119, E-119 including a hose stream test.

TRegulatory Position 4.3.2 of lthis guide discusses the acceptance criteria for raceway fire barriers is discussed in Regulatory lPosition 4.3.2 to this guide

.4.2.3.2 Fire -Rated Cables. llLicensees should request an exemption or de viation, as appropriate, when relying on fire

-lrated cables to meet NRC requi rements for protection of safe

-shutdown systems or componentslfrom the affectseffects of fire. (See Regulatory Position 1.8 of this guide.)l4.2.3.3 Fire Stops for Cable Routing. llFire stops should be installed every 6.1 m (20 f eet) along horizontal cable routings inlareas important to safety that are not protected by automatic water systems. Vertical cableroutings should have fire stops installed at each floor

/-ceiling level. Between levels or in verticall cable chases, fire stops should be installed at the mid-height if the vertical run is 6.1 m (20 f ee t)or more , but less than 9.1 m (30 f ee t) or at 4.6

-m (15-f oot) intervals in vertical runs of 9.1 m (30l f ee t) or more unless such vertical cable routings are protected by automatic water systemsdirected on the cable trays. Individual fire stop designs should prevent the propagation of a fire for a minimum period of 30 minutes when tested for the largest number of cable routings andmaximum cable density.4.3Testing and Qualification of Electrical Raceway Fire Barrier Systems l4.3.1 Electrical Raceway Fire Barrier Systems:

General Guidelines llFire barriers relied upon to protect post-fire shutdown-related systems and to meet thel separation means of discussed in Regulatory Position 5.

5 3 should have a fire rating of either 1 orl3 hours. Fire rating is defined as the endur ance period of a fire barrier or structure; it defines

,lwhich relates to the period of resistance to a standard fire exposure before the first critical pointl in behavior is observed.

5WhenThe 181 C (325 F) temperature condition was established by allowing the temperature criteria are exceeded or ldamage occurs, component operability at the temperatures experiencedof the unexposed side of the fire barrier to rise l139 C (250 F) above the assumed 24 C (75 F) ambient air temperature, as measured by the thermocouples within lthe test specimen at the onset of the fire exposure during the fire test should be assessed. Fire endurance tests that are ljudged acceptable on the basis of a visual inspection of specific components or cables included in the test specimenmay not be applied to other components or cables without a specific evaluation

.DG-1170, Page 122Fire endurance ratings of building construction and materials are demonstrated by testingfire barrier assemblies in accordance with the provisions of the applicable sections of NFPA 251and ASTM E-119. Assemblies that pass specified acceptance criteria (e.g., standardtime-temperature fire endurance exposure, unexposed side temperature rise, and hose streamimpingement) are considered to have a specific fire

-resistance rating.

lThe basic premise of the fire

-resistance criteria is that those fire barriers that do not lexceed 181

° C [325°F](325 F) cold -side temperature (5) and pass the hose stream test provide lreasonable assurance that the shutdown capability is protected without further analyses. If thetemperature criterion is exceeded, sufficient add itional information is needed to perform anengineering evaluation to demonstrate that the shutdown capability is protected.

4.3.2Fire Endurance Test Acceptance Criteria for Electrical Raceway and lComponent Fire Barrier Systems for Separating Safe

-Shutdown Functions lW within the Same Fire Area llThe fire endurance qualification test for fire barrier materials applied directly to a lraceway or component is considered to be successful if all three of the following conditions aremet.:l1.a.The average unexposed side temperature of the fire barrier system, as measured lon the exterior surface of the raceway or component, did not exceed 139

° Cl[250°F](250 F) above its initia l temperature; andl.l(NFPA 251 and ASTM E-119 allow this temperature to be determined by averagingthermocouple temperature readings. For the purposes of this criterion, the licensee may luse thermocouple averaging can be used provided if similar series of thermocouples (e.g.,lcable tray side rail) are averaged together to determine temperature performance of the raceway fire barrier system. In additi on, conditions of acceptance are placed on thetemperatures measured by a single thermocouple. If any single thermocouple exceeds 30percent of the maximum allowable temperature rise (i.e., 139

° C + 42° C = 181° Cl[(250° F + 75° F = 325°F]325 F), the test exceeded the temperature criteria limit.) l2.b.Irrespective of the unexposed side temperature rise during the fire test, if cables or lcomponents are included in the fire barri er test specimen, a visual inspection is 6Examples of thermal cable degradation are jacket swelling, splitting, cracking, blistering, melting, or discoloration;shield exposed; conductor insulation exposed, degraded, or discolored; bare copper conductor exposed. When theltemperature criteria are exceeded or damage occurs, component operability at the temperatures experienced during the lfire test should be assessed. Fire endurance tests that are judged acceptable on the basis of a visual inspection of lspecific components or cables included in the test specimen may not be applied to other components or cables without la specific evaluation.

l7For the thermocouples installed on conduits, cable tray side rails,Examples of thermal cable degradation are jacket lswelling, splitting, cracking, blistering, melting, or discoloration; shield exposed; conductor insulation exposed,ldegraded, or discolored; and bare copper conductors, a +13 mm [+ 1/2 inch] installation tolerance is lacceptable.conductor exposed.

lDG-1170, Page 123performed.

(6) Cables should not show signs of degraded conditions (7) resultingfrom the thermal effects of the fire exposure; and.l(When signs of thermal degradation are pres ent, the fire barrier did not perform its intended fire-resistive function. For barriers that are not capable of performing theirintended function, an engineering analysis that demonstrates that the functionality ofthermally degraded cables or components was maintained and that the cables or components would have adequately performed their intended function s during and after alpostulated fire exposure should be performed. A methodology for demonstrating thefunctionality of cables during and after a fire test exposure is provided below. The purpose of the functionality tests is to justify observed deviations in fire barrier performance. For fire barrier test specimens that are tested without cables, an engineeringanalysis justifying internal fire barrier temperature conditions greater than allowed can be

based on a comparison of the fire barrier internal temperature profile measured during thefire endurance test to existing cable specifi c performance data, such as environmentalqualification (EQ) tests.

)3.c.The cable tray, raceway, or component fire barrier system remained intact duringlthe fire exposure and water hose stream test without developing any openingsthrough which the cable tray, raceway, or component (e.g., cables) is visible.

(SeelRegulatory Position 4.3.3 of this guide regarding acceptable hose stream testl methods.)lThe test specimen should be representative of represent the construction for which the firelrating is desired as to mate rials, workmanship, and details

, such as dimensions of parts, andl should be built under representative conditions. Raceway fire barrier systems being subjected to qualification fire e ndurance tests should be representative of represent the ir end use. Forlexample, if it isthe licensee intend ed s to install a cable tray fire barrier system in the plantlwithout protecting the cable tray supports, the test program should duplicate these fieldconditions. In addition, the fire test program should encompass or bound raceway sizes and thevarious configurations for those fire barrier systems installed in the plant. It should be noted that s Several test specimens will be required in order to qualify various sizes of horizontal andl DG-1170, Page 124vertical runs of cable trays and conduits, junction boxes and pull boxes, etcand similar lconfigurations. The cable tray or raceway design used for the tests should be constructed with lmaterials and config urations representative of in-plant conditions (e.g., the mass associated withtypical steel conduits and cable trays, representative internal and extern al penetration seals).

Iflcables are included in the raceway fire barrier test specimen, these cables should berepresentative of represent the installed plant-specific cables.

lMeasuring cable temperatures is not a reliable means for determining excessivetemperature conditions that may occur at any point along the length of the cable during the firetest. In lieu of measuring the unexposed surface temperature of the fire barrier test specimen, methods that will measure the surface temperature of the raceway (e.g., exterior of the conduit,side rails of cable trays, bottom and top of cable tray surfaces, junction box external surfaces) can

be considered as equivalent if the raceway components used to construct the fire test specimen represent plant-specific components and configurations.

The metal surfaces of the raceway,lunder fire test conditions, exhibit good thermal conductivity properties. Temperatures measuredon these surfaces provide an indication of the actual temperature rise within the fire barrier system.In 1979, American Nuclear Insurers (ANI) issued a fire endurance test method forraceway fire barrier systems for insurance purposes. This method, "Fire Endurance ProtectiveEnvelope Systems for Class 1E Electrical Circuits" (ANI Test), specified that cable temperaturesbe monitored by thermocouples. Since cable j ackets have a low thermal conductivity, the actuallocal temperatures of the cable jackets' indicati ons of barrier failure and internal fire barriertemperature rise conditions during the fire exposure are masked. Monitoring cable temperaturescan give indications of low inte rnal fire barrier temperature conditions during the fire endurancetest. Using this temperature monitoring approach, cable damage can occur without indication ofexcessive temperatures on the cables. This, linked with no loss of circuit integrity, would give indications ofindicates a successful test. The staff considers monitoring the cable temperature as lthe primary means of determining cable tray or raceway fire barrier performance to be

nonconservative. Therefore, the staff ha s incorporated the provision for a post

--fire visual linspection of cables that are installed in fire barrier test specimens. As discussed above,temperatures monitored on the exterior surface of the raceway provide a more representative

indication of fire barrier performance.

Fire endurance tests of raceway fire barrier systems shouldmay be performed with or lwithout cables in the raceway. This method is preferred because by e Excluding cables from the ltest specimen it eliminates bias in the test results created by the thermal mass of the cables and islthe NRC-preferred method. Without th is e thermal mass of the cables, the internal temperature lconditions measured by the test specimen thermocouples during the fire exposure will provide amore accurate determination of fire barrier thermal performance. The following sections provide lguidance for both approaches.

ll 8 The review guidance for Megger and Hi-Pot test voltages was derived from IEEE 383-1974 and IEEE 690-1984.

Forlthe thermocouples installed on conduits, cable tray side rails, and bare copper conductors, a +13 mm [+ 0.5 in.]

linstallation tolerance is acceptable.

lDG-1170, Page 125 4.3.2.1 Thermocouple Placement - TestPlacement-Test Specimens Containing lCables. llThe following are acceptable pl acements of thermocouples for determining the thermallperformance of raceway or cable tray fire barrier systems that contain cables during the fireexposure.:la.Conduits - The Conduits-The temperature rise on the unexposed surface of a firelbarrier system installed on a conduit should be measured by placing the thermocouplesevery 152 mm

[(6 inches]in.)(8) on the exterior conduit surface underneath the fire barrierlmaterial. The thermocouples should be attached to the exterior conduit surface locatedl opposite the test deck and clos est to the furnace fire source.

Thermocouples should also lbe placed immediately adjacent to all st ructural members, supports, and barrier lpenetrations.

lb.Cable trays-The temperature rise on the unexposed surface of a fire barrier system linstalled on a cable tray should be measured by placing the thermocouples on the exterior lsurface of the tray side rails between the cable tray side rail and the fire barrier material.

lIn addition to placing thermocouples on the side rails, thermocoupl es should be attached lto two AWG 8-stranded bare copper conductors. The fi rst copper conductor should be linstalled on the bottom of the cable tray rungs along the entire length and down the llongitudinal center of the cable tray run.

The second conductor should be installed along lthe outer top surface of the cables closest to the top and toward the center of the fire lbarrier. Thermocouples should be placed every 152 mm (6 in.) down the longitudinal lcenter along the outside surface of the cable tray side rails and along the bare copper lconductors.

Thermocouples should also be placed immediately adjacent to all structurall members, supports, and barrier penetrations.b.Cable Trays

- c.Junction boxes-The temperature rise on the unexposed surface of la fire barrier system installed on junction boxes should be lmeasured by placing thermocouples on either the inside or the loutside of each junction box surface. Each junction box surface or lface should have a minimum of one thermocouple, located at its lgeometric center. In add ition, one thermocouple should be linstalled for every 0.9 m 2 (1 ft 2) of junction box surface area.

lThese thermocouples should be located at the geometric centers of lthe 0.9-m 2 (1-ft 2) areas. At least one th ermocouple should also be lplaced within 25 mm (1 in.) of each penetration lconnector/interface.

l DG-1170, Page 126 d.Airdrops-The internal airdrop temperatures should be measured by thermocouples lplaced every 305 mm (12 in.) on the cables routed within the airdrop and by a stranded lAWG 8 bare copper conductor routed inside and along the entire length of the airdrop lsystem with thermocouples installed every 152 mm (6 in.) along the length of the copper lconductor. The copper conductor should be in close proximity to the unexposed surface lof the fire barrier material. Thermocouples should also be placed immediately adjacent to lall supports and barri er penetrations.

ll DG-1170, Page 127 4.3.2.2Thermocouple Placement-Test Specimens without Cables llThe following are acceptable thermocouple placements for determining the thermal lperformance of raceway or cable tray fire barrier systems that do not contain cables.

llText Moved Here: 7 la.Conduits - The Conduits-The temperature rise of the unexposed surface of a firelbarrier system installed on a conduit should be measured byplacing thermocouples every 152 mm

[(6 inches]in.) on thelexterior conduit surface between the conduit and the unexposed surface of the fire barrier materi al. These thermocouples should beattached to the exterior conduit surface opposite the test deck and closest to the furnace fire source. The internal raceway

temperatures should be measured by a stranded AWG 8 barecopper conductor routed through the entire length of the conduitsystem with thermocouples installed every 152 mm

[(6 inches]in.)lalong the length of the copper conductor. Thermocouples should also be placed immediately adjacent to all structural members, supports, and barrier penetrations.

b.Cable trays-TheEnd Of Moved Text lThe temperature rise on the unexposed surface of a fire barrier system installed on a cable trayshould be measured by placing the thermocouples every 152 mm (6 in.) on the exterior surface ofl the each tray's side rails between the cable tray side rail and the fire barrier material. In addition lto placing thermocouples on the side rails, thermocouples should be attached to two AWG 8 strandedInternal raceway temperatures should be measured by a stranded AWG 8 bare copperl conductor s. The first copper conduc tor should be installed routed on the bottom top of the cableltray rungs along the entire length and down the longitudinal center of the cable tray run. Thesecond conductor should be installed along the outer top surface of the cables closest to the topand toward the center of the fire barrier with thermocouples installed every 152 mm (6 in.) along lthe length of the copper conductor. Thermocouples should be placed every 152 mm (6 inches) ldown the longitudinal center along the outside surface of the cable tray side rails and along the bare copper conductors.

Thermocouples should also be placed immediately adjacent to all structural members, supports , and barrier penetrations.c.Junction Boxes (JBs) - Theboxes-The temperature rise on the unexposed surface of alfire barrier system installed on junction boxes should be measured by placing thermocouples on either the insi de or the outside of each JB junction box surface. Eachl JB junction box surface or face should have a minimum of one thermocouple, located atlits geometric center. In addition, one thermocouple should be installed for every one square foot 0.9 m 2 (1 ft 2) of JB junction box surface area. These thermocouples should bellocated at the geometric centers of the one square foot 0.9-m 2 (1-ft 2) areas. At least onel thermocouple should also be placed within 25 mm (1 in ch.) of each penetrationlconnector/interface.

DG-1170, Page 128 d.Airdrops - The Airdrops-The internal airdrop temperat ures should be measured bylthermocouples placed every 305 mm (12 inches) on the cables routed within the air drop and by a stranded AWG 8 bare copper conductor routed inside and along the entire lengthof the airdrop system with thermocouples installed every 152 mm (6 inches in.) along the llength of the copper conductor. The copper conductor should be in close proximity with to the unexposed surface of the fire barrier material. Thermocouples should also be lplaced immediately adjacent to all supports and barrier penetrations.4.3.2.2 Thermocouple Placement -- Test Specimens Without Cables. The following are acceptable thermocouple placements for determining the thermal performance of raceway orcable tray fire barrier syst ems that do not contain cables.Text Was Moved From Here: 7b.Cable Trays - The temperature rise on the unexposed surface of a fire barrier systeminstalled on a cable tray should be measured by placing thermocouples every 152 mm [6 inches]on the exterior surface of each tray side rails between the side rail and the fire barrier material. Internal raceway temperatures should be measured by a stranded AWG 8 bare copper conductorrouted on the top of the cable tray rungs along the entire length and down the longitudinal centerof the cable tray run with thermocouples installed every 152 mm [6 inches] along the length of the copper conductor. Thermocouples should be placed immediately adj acent to all structural members, supports, and ba rrier penetrations. c.Junction Boxes - The temperature rise on the unexposed surface of a fire barrier systeminstalled on junction boxes (JBs) should be measured by placing thermocouples on either theinside or the outside of each JB surface. Each JB surface or face should have a minimum of onethermocouple, located at its geometric center. In addition, one thermocouple should be installedfor every one square foot of JB surface area.

These thermocouples should be located at thegeometric centers of the one squa re foot areas. At least one thermocouple should also be placedwithin 25 mm [1 inch] of each penetration conn ector/interface.

d.Airdrops

- The internal airdrop temperatures should be measured by a stranded AWG 8 bare copper conductor routed inside and along the entire length of the airdrop system withthermocouples installed every 152 mm [6 inches] along the length of the copper conductor. Thecopper conductor should be in close proximity with the unexposed surface of the fire barrier material. Thermocouples should also be placed immediately adjacent to all supports and penetrations.

4.3.2.3 Criteria for Averaging Temperatures. llTemperature conditions on the unexposed surfaces of the fire barrier material during the lfire test will be determined by averaging the temperatures measured by the thermocouplesinstalled in or on the raceway. In determining To determine these temperature conditions, the lthermocouples measuring similar areas of the fire barrier should be averaged together.

DG-1170, Page 129 Acceptance will be based on the individual averages. The following methods of averaging should be followed.

a.Conduits - The Conduits-The thermocouples applied to the outside metal surfacelof the conduit should be averaged together.

b.Cable Trays - Thetrays-The thermocouples on each cable tray side rail shouldlbe averaged separately. For example, thermocouples placed on one side rail willbe averaged separately from the other side rail.

In addition, the temperaturelconditions measured by thermocouples on the bare copper conductor should beaveraged separately from the side rails.

c.Junction Boxes - For JBsboxes-For junction boxes that have only onel thermocouple on each JB junction box surface, the individual JB junction box lsurface thermocouples should be averaged together. For JBsjunction boxes thatlhave more than one thermocouple on each JB junction box surface, thel thermocouples on the individual JB junction box surfaces should be averagedltogether.d.Airdrops - The Airdrops-The thermocouples placed on the copper conductorl within the airdrop fire barrier should be averaged together.The average of any thermocouple group should not exceed 139

° C [250°F](250 F)labove the unexposed side temperature within the fi re barrier test specimen at the onset of the fireendurance test. In addition, the temperature of each individual thermoc ouple will be evaluated. Individual thermocouple conditions should not exceed the 139

° C [250°F](250 F) temperaturelrise by more than 30 percent

([i.e., 181° C [375°F (325 F)]).lIf a fire barrier test specimen without cables does not meet the average or maximumsingle point temperature criteria, the internal raceway temperature profile as measured by the

instrumented bare copper conductors during the fire exposure can be used to assess cablefunctionality through air oven tests of plant

-specific cable types and construction, as discussedl below.4.3.3 Hose Stream Tests llNFPA 251 and ASTM E-119 allow flexibility in hose stream testing. The standardsl allow the hose stream test to be performed on a duplicate test specimen subjected to a fire endurance test for a period equal to one-half of that indicated as the fire

-resistance rating, but notlfor more than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (e.g., 30-minute 30-minute fire exposure to qualify a 1-hour fire

-ratedlbarrier).

DG-1170, Page 130 For safe -shutdown-related fire barrier systems and duplicate electrical cable tray or lraceway and component fire barrier test specimens that have been exposed to the 1/2-duration one-lhalf-duration test fire exposure, the staff finds the hose stream application specified by NFPA l251 to be acceptable. NFPA 251 requires the stream of water to be delivered through a 64-mm l[21/2-inch](2.5-in.) hose discharging through a standard 29-mm [11/2-inch](1.5-in.) playpipelnozzle onto the test specimen after the fire exposure test. The stream is applied with the nozzle orifice positioned 6.1 meters

[(20 feet]ft) away from the center of the test specimen at a pressure lof 207 kPa [(30 psi]). The application of the stream is to all exposed parts of the specimen for a lduration of at least 1 minut e for a 1-hour barrier and 2 1/2.5 minutes for a 3-hour barrier.

lAs an alternative for to electrical raceway fire barrier test specimens, the application of the lhose stream test can be performed immediately after the completion of the full fire endurance testperiod. If this method is used to satisfy the hose stream test criteria, any one of the following lhose stream applications is acceptable

.:l a.The stream applied at random to all exposed surfaces of the test specimen through a 64-mm [21/2-inch](2.5-in.) national standard playpipe with a 29-mm

[(11/2- inch].5-in.) orificelat a pressure of 207 kPa

[(30 psi]) at a distance of 6.1 meters

[(20 feet]ft) from thelspecimen. (Durations of the hose stream applications

-= 1 minute for a 1-hour barrier land 21/2.5 minutes for a 3-hour barrier.)

or lb.The stream applied at random to all exposed surfaces of the test specimen through a 38-mm [11/2-inch](1.5-in.) fog nozzle set at a discharge angle of 30 degrees with a nozzle lpressure of 517 kPa

[(75 psi]) and a minimum discharge of 284 lpm [L/m (75 gpm]) withlthe tip of the nozzle at a maximum of 1.5 meters

[(5 feet]ft) from the test specimen.

l(Duration of the hose stream application

-= 5 minutes for both 1-hour and 3-hour lbarriers.)

orc.The stream applied at random to all exposed surfaces of the test specimen through a 38-mm [11/2-inch](1.5-in.) fog nozzle set at a discharge angle of 15 degrees with a nozzle lpressure of 517 kPa

[(75 psi]) and a minimum discharge of 284 lpm [L/m (75 gpm]) withlthe tip of the nozzle at a maximum of 3 meters [m (10 feet]ft) from the test specimen.

l(Duration of the hose stream application

-= 5 minutes for both 1-hour and 3-hour lbarriers.)

l4.3.4 Demonstrating Functionality of Cables Protected by Raceway Fire Barrier lSystems D d uring and A a fter Fire Endura nce Test Exposure llDuring fire tests of raceway fire barrier systems, thermal damage to the cables has led tocable jacket and insulation degradation without the loss of circuit integrity as monitored usingANI criteria

([applied voltage of 8 to 10 volts 8-10V direct current (dc)]. Since cable voltages lused for ANI circuit integrity tests do not replicate cable operating voltages, loss of cable linsulation conditions can exist during the fire test without a dead short occurring. It is expected DG-1170, Page 131that if the cables were at rated power and current, a fault would propagate. The use of circuitintegrity monitoring during the fire endurance test is not a valid method for demonstrating that the protected shutdown circuits are capable of performing their required function during and afterthe test fire exposure. Therefore, the NRC does not require circuit integrity monitoring using thelANI criteria is not required to satisfy NRC its acceptance criteria for fire barrier qualification. l The following approaches are acceptable for evaluation ofevaluating cable functionality.l l4.3.4.1 Use of Environmental Qualification Data

. llComparison of the fire barrier internal time-temperature profile measured during the firelendurance test to existing cable pe rformance data, such as data from environmental qualification (EQ) tests, could be proposed to the staff as a method for demonstrating cable functionality. EQtesting is typically performed to rigorous conditions, including rated voltage and current. Bycorrelating the EQ test time-temperature profile to the fire test time-temperature profile, the EQl test data would provide a viab le mechanism to ensure cable functionality. A large body of EQtest data for many cable types exists today. The use of EQ data represents a cost-effectiveapproach for addressing cable functionality for fire tests for those cases wherein which thel181° C [325°F](325 F) limit is exceeded. A comparison of fi re test temperature profiles tolexisting EQ and loss-of-coolant accident (LOCA) test results or air oven test results is an acceptable approach to demonstratedemonstrating cable functionality provided that the subjectlanalysis incorporates the anticipated temperature rise that is due tocaused by the self heatingleffects of installed power cables with the fire test results.

4.3.4.2 Cable Insulation Tests

. llThe nuclear industry uses two principal materials used as cable insulation and cableljackets by the nuclear industry are

, thermoplastics and thermosetting polymeric materials. Althermoplastic material can be softened and re

-softened by heating and reheating. Conversely,thermosetting cable insulation materials cure by chemical r eaction and do not soften whenheated. Under excessive heating

, thermosetting insulation becomes stiff and brittle. Electricallfaults may be caused by softening and flowing of thermoplastic insulating materials at temperatures as low as 149

° C [300°F](300 F). Thermosetting electrical conductor insulationlmaterials usually retain their el ectrical properties under short-term exposures to temperatures ashigh as 260

° C [500°F](500 F). Insulation resistance (Megger) tests provide indications of thelcondition of the cable insulation resistance, whereas the high

-potential (Hi-Pot) test provideslassurance that the cable has sufficient dielectric strength to withstand the applied rated voltage.

A cable insulation failure usually results from two breakdown modes

. One failure mode islexcessive dielectric loss that is due toresulting from low insulation resistance, and the otherlfailure mode is overpotential stress that is due to caused by loss of dielectric strength of thelinsulation material.

9 A Megger test voltage of 1000 V dc is acceptable provided a Hi-Pot test is performed after the Megger test for powercables rated at less than 1000 V ac.The review guidance for Megger and Hi-Pot test voltages was derived from IEEE l383 and IEEE 690, "IEEE Standard for the Design and Installation of Cable Systems for Class 1E Circuits in Nuclear lPower Generating Stations."

lDG-1170, Page 132 To provide reasonable assurance that the cab les would have functioned during and afterthe fire exposure, Megger tests need to be performed before the fire test, at multiple time intervals during the fire exposure (i.e., every 20 minutes during the 1-hour fire test and everyhour during the 3-hour fire test) for instrumentation cables only

, and immediately after the fire endurance test to assess the cable insulation resistance levels.

This testing will assure ensure thatlthe cables will maintain the insulation resistance levels necessary for proper operation ofinstruments.The Megger tests

([pre-fire, during the fire

[(if performed

]), and immediately after the fire ltest conditions

)] should be done conducto r-to-conductor for multi

-conductor and conductor-lto-ground for all cables.

The minimum acceptable insulation resistance (IR) value, using the test lvoltage values as shown in the table below, is determined by using the following expression:IR (Mega-ohms) = {[K+1 Mega-ohm ]

• 1000 (ft)

} / Length/Length (ft)lWhere K = 1 Mega-ohm/KV

• Operating Voltage (expressed in KV)In addition, to determine the insulation resistance IR levels required for nuclear linstrumentation cables, an assessment of the minimum insulation resistance IR value (e.g., one lmega-ohm) and its potential impact on the functionality of these cables should be evaluated.

Anlac or dc high potential (Hi-Pot) test for power cables greater than 1000 volts (V) should also beperformed after the post

--fire Megger tests to assess the dielectric strength. This test provides lassurance that the cable will withstand the applied voltage during and after a fire. The high potentialHi-Pot test should be performed for a 5

-minute duration at 60 percent of either 80 V/mil lac or 240 V/mil dc (e.g., 125 mil conductor insulation thickness x 240 V/mil dc x 0.6 = 18,000 V dc). The table below Table 1 summarizes the Megger and Hi-Pot test voltages (9) that, when lapplied to power, control, a nd instrumentation cables, woul d constitute an acceptable cablefunctionality test.Table 1. Functiona lity Test Voltages l

10A Megger test voltage of 1,000 V dc is acceptable provided a Hi-Pot test is performed after the Megger test for powercables rated at less than 1,000 V ac.DG-1170, Page 133TYPEOPERATING VOLTAGEMEGGER TEST VOLTAGEHIGH

-POTENTIALlTEST VOLTAGE Power>1000 V ac2500 V dc60% x 80 V/mil (ac) 60% x 240 V/mil (dc)Power<1000<1,000 V ac 1500 1,500 V dc (10)NonelInstrument and Control<250 V dc

<120 V ac 500 V dcNoneThe electrical cable functionality tests r ecommended above are one acceptable method. Alternative methods to assess degradation of cable functionality. The NRC staff will belevaluated evaluate alternative methods on a case-by-case basis. The above tablelsummarizingsummarizes the "typical" Megger and Hi-Pot test voltages are "typical" , and thelapplicant can follow the applicable industry standards and manufacturer

s recommendations forlthe specific cable application in the performance of the insulation resistance IR and Hi-Pot tests.l 4.3.4.3 Air Oven Tests

. llAir oven tests can be used to evaluate the functionality of cables for those cable tray orlraceway fire barrier test spec imens tested without cables. This testing method consists ofexposing insulated wires and cables at rated voltage to elevated temperatures in a circulating air oven. The temperature profile for regulating the temperature in the air oven during this test is the temperature measured by the AWG 8 bare copper conductor during the fire exposure of thosecable tray or raceway test specimens that were tested without cables.The test method described by UL Subject 1724, "Outline"Outline of Investigation for FirelTests for Electrical Circuit Protective Systems,"" Issue Number 2, August 1991, Appendix B,l"Qualification"Qualification Test for Circuit Integrity of Insulated Electrical Wires and Cables inlElectrical Circuit Protection Systems,"" is acceptable, with the following modifications

.:la.a.During the air oven test the cables are to be energized at rated voltage. The cablesl are to be monitored for conduc tor-to-conductor faults in multi

-conductor cablesand conductor-to-ground fau lts in all conductors.

b.lb.The cables being evaluated should be subjected to the Megger and high potentialHi-Potltests, previously recommended above in Regulatory Position 4.3.4.2, "Cable Insulation lTests." c.l DG-1170, Page 134 c.The impact force test, which simulates the force of impact imposed on the raceway by the lsolid stream test, described in UL 1724, Appendix B, paragraph B3.16, is does notlrequired need to be performed.

l4.3.4.4 Cable Thermal Exposure Threshold

. llThe following analysis, which is based on determining whether a specific insulation lmaterial will maintain electrical integrity and operability within a raceway fire barrier systemduring and after an external fire exposure, is an acceptable method for evaluating cablefunctionality. In order t T o determine cable functionality, it is necessary to consider the operating lcable temperatures within the fire barrier system at the onset of the fire exposure and the thermal exposure threshold (TET) temperature of the cable. For example, if the TET of a specificthermoplastic cable insulation (Brand X) is 149

° C [300°F](300 F) and the normal operating ltemperature within the fire barrier system is 66

° C [150°F](150 F), the maximum temperature lrise within the fire barrier system should not exceed 83

° C [150°F](150 F) during exposure to lan external fire of a dura tion equal to the required fire

-resistance rating of the barrier. For this lexample, the TET limit for Brand X cable is 83

° C [150°F](150 F) above the cable operating ltemperatures within the fire barrier system at the onset of the external fire exposure. The cable

TET limits in conjunction with a post

-test visual cable inspection a nd the Hi-Pot test describedabove should readily demonstrate the functionality of the cable circuit during and after a fire.The normal cable operating temperature can be determined by loading cable specimensinstalled within a thermal barrier system in the test configuration with rated voltage and current.

The TET temperature limits for most cable insulation may be obtained from the manufacturer

slpublished data, which is are given as the short-circuit rating limit. With the known TET and lnormal operating temperature for each thermal barrier system configuration, the maximumtemperature rise limit within a fire barrier system may then be determined.

The guidance in Regulatory Position 4.3.4 is based on Appendix R to 10 CFR Part 50,APCSB 9.5-1, ASB 9.5-1, CMEB 9.5-1, GL 86-10, and Supplement 1 to GL 86-10.4.3.5 Cable Qualification Electric cable construction should, as a minimum, pass the flame test in IEEEStandard 383 or IEEE Standard 1202. (This does not imply that cables passing either test will not require additional fire protection.) For cable installations in operating plants and plants underconstruction prior to July 1, 1976, that do not meet the IEEE 383 flame test requirements, the cables should be covered with an approved flame retardant coating and properly derated.

Non-qualified cable that is not covered with an approved flame retardant coating should be protected with an automatic fire suppression system.5.SAFE SHUTDOWN CAPABILITY ll DG-1170, Page 135 5.Safe-Shutdown Capability lWhen considering the consequences of a fire in a given fire area during the evaluation of safe -shutdown capabilities of the plant, it should be demonstrated that one success path ofl equipment and electrical circuits that can be used to bring the reactor to hot shutdown conditions lin the case of BWRs, or hot standby in the case of PWRs, remains unaffected by thefireshutdown/standby conditions, remains free of fire damage. It should also be demonstratedlthat fire damage to one success path of equipment needed for achieving cold shutdown will be

limited so that equipment will be returned to an operating condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or for areasrequiring alternate, dedi cated, or backup shutdown, the licensee should demonstrate that coldlshutdown capability can be restored and cold shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.One of the objectives of the fire protection program is to demonstrate that one successpath of systems necessary to achieve and maintain hot shutdown (e.g., hot standby for a PWR,hot shutdown for a BWR) are maintained free of fire damage. The For reactor designs that lcannot safely remain in hot standby/shutdown for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, it should be demonstrated that a cold lshutdown condition can be achieved and maintained within the required period of time.

l lFor existing reactor plants, the success path of safe

-shutdown systems should be capablelof meeting Regulatory Positions 5.1 and or 5.2 of this guide and performing the necessarylshutdown functions. The capability of the requi red shutdown functions should be based on aprevious analysis, if possible (e.g., those analyses in the FSAR

). The equipment required for alternative or dedicated shutdown should have the same or equivalent capability as that relied on in the above-referenced analysis.5.1Safe Shutdownanalyses.llThe FPP should include an analysis to demonstrate that the SSCs important to safety can laccomplish their respective post-fire safe-shutdown functions. The safe-shutdown analysis lshould demonstrate that redundant safe-shutdown systems and components, including electrical lcircuits for which fire-induced failure could directly or indirectly pr event safe shutdown, are ladequately protected such that one success path remains free of fire damage in the event of lpostulated fires. This protection should be provided by fire barriers, physical separation with no lintervening combustibles, and/or automatic detection and suppression, as required by applicable lregulations. Where one redundant success path cannot be adequately protecte d, an alternative or ldedicated shutdown success path should be identified and protected to the extent necessary to lensure post-fire safe-shutdown.

l lThe safe-shutdown analysis for new reactor designs must demonstrate that safe shutdown lcan be achieved assuming that all equipment in any one fire area (except for the control room and lcontainment) will be rendered inoperable by fire and that reentry into the fire area for repairs and loperator actions is not possible. (See Regulatory Position 8.2 of this guide.) Consequently, new lreactors should not credit physical separation or local fire barriers (e.g., electrical raceway fire lbarrier systems) within these fire areas as providing adequate protection. The control room is lexcluded from this approach, provided the design includes an independent alternative shutdown lcapability that is physically and electrically inde pendent of the control room. New reactors must l

DG-1170, Page 136 provide fire protection for redundant shutdown systems in the reactor containment building that lwill ensure, to the extent practicable, that at l east one post-fire shutdown success path will be free lof fire damage.

l lThe safe-shutdown analysis shoul d evaluate a fire in each fire area containing SSCs limportant to safety and identify a post-fire safe-shutdown success path (i.e., all trains or systems lthat are required to remain free of fire damage to perform the necessary safe-shutdown lfunctions). The analysis also identifies all fire-induced circuit failures that could directly or lindirectly (e.g., by causing a spuri ous actuation) prevent safe shutdown.

ll DG-1170, Page 137 5.1Post-Fire Safe-Shutdown Performance Goals for Redundant Systems lEnsure that fuel integrity is maintained and that there are no adverse consequenceson the reactor pressure vessel inte grity or the attached piping. Fuel integrity is maintainedprovided the fuel design limits are not exceeded.

The guidance in Regulatory Position 5.1 is based on the Richards Letter (2000).

5.2Alternative or Dedicated Shutdown Design and Performance Goals 5.2.1Alternative or Dedicated Safe Shutdown System Design GoalsDuring the llDuring post-fire shutdown, the reactor coolant system process variables should must belmaintained within those predicted for a loss of normal ac power, and the fission productboundary integrity should shall not be affected

, i.e., there should shall be no fuel clad damage,lrupture of any primary coolant boundary, or rupture of the containment boundary.The systems used for alternative or dedicated Licensees should ensure that fire protection lfeatures are provided for structures, systems, and components importa nt to safe shutdown that are lcapable of limiting fire damage so that one success path of systems necessary to achieve and lmaintain hot shutdown conditions from either the control room or emergency control station(s) is lfree of fire damage.

l lAs noted in IN 84-09, "Lessons Learned from NRC Inspections of Fi re Protection Safe-lShutdown Systems (10 CFR Part 50, Appendix R)

," the post-fire sa fe-shutdown performance lgoals are the same for both redundant success paths and a lternative/dedicated shutdown need notlbe designed to (1) seismic Category I criteria, (2) single failure criteria, or (3) other design basisaccident criteria, except the portions of these systems that interface with or impact existing safetysystems.5.2.2Safe Shutdown Performance Goals for Alternative or Dedicated Systems The systems.Section III.L of Appendix R provides the following specific performancelgoals forto achieve the shutdown functions should bepost-fire safe-shutdown goals

la.The reactivity control function should be capable of achieving and maintaining coldshutdown reactivity conditions.

lb.The reactor coolant makeup f unction should be capable of maintaining the reactor coolant level above the top of the core for boiling-water reactors (BWRs) and within the levellindication of the pressurizer for pressurized-water reactors (PWRs).l DG-1170, Page 138 lc.The reactor heat removal function should be capable of achieving and maintaining decay heat removal.

ld.The process monitoring function should be capable of providing direct readings of theprocess variables necessary to perfo rm and control the above functions.

le.The supporting functions should be capable of providing the process cooling, lubrication,etc.,and other activities necessary to permit the operation of the equipment used for safe

-lshutdown functions.

lThe guidance for Regulatory Position 5.2 is in Appendix R to 10 CFR Part 50 andCMEB 9.5-1.5.3Hot Standby (PWR) Hot Shutdown (BWR) Systems and InstrumentationOne success path of equipment necessary to achieve hot standby (PWR) or hot shutdown(BWR) from either the control room or emergency control stations should be maintained free offire damage by a single fire, including an ex posure fire. Manual opera tion of valves, switches,and circuit breakers is allowed to operate equipment and isolate sy stems and is not considered arepair. Damage consid erations should also include damage to equipment from the normal or inadvertent operation of fire suppression systems.Recovery actions are allowed to systems and components not used for hot shutdown, but whose fire or fire suppressant-induced maloperations may adversely affect hot shutdowncapability. These recovery actions should be achievable prior to the maloperations causing an unrecoverable plant condition.5.3.1 PWR Systems and Instrumentation In accordance with GL 81-12,llGL 81-12 describes the systems and instrumentation with the following capabilitiesthatlare generally necessary for achieving hot standby of PWRs.

5.3.1.1 Reactivity Control. Reactor trip capability (scram) and boration capability(e.g., charging pump, makeup pump or high-pressure injection pump taking suction fromconcentrated borated water supplies, as well as letdown system if required).

DG-1170, Page 139 5.3.1.2 Reactor Coolant Makeup. Reactor coolant makeup capability, e.g., chargingpumps or the high-pressure injection pumps. Power-operated relief valves may be required to reduce pressure to allow use of the high-pressure injection pumps.5.3.1.3 Reactor Coolant System Pressure Control. Reactor pressure controlcapability, e.g., charging pumps or pressurizer heaters and use of the letdown systems if required.5.3.1.4 Decay Heat Removal. Decay heat removal capability, e.g., power-operatedrelief valves (steam generator) or safety relief valves for heat removal with a water supply andemergency or auxiliary feedwater pumps for makeup to the steam generator. Service water orother pumps may be required to provide water for auxiliary feed pump suction if the condensatestorage tank capacity is not adequate for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.5.3.1.5 Process Monitoring Instrumentation. The following instrumentation isconsidered necessary to achieve hot standby for PWRs.Pressurizer pressure and levelReactor coolant cold leg temperature and core exit thermocouples or hot legtemperatureSteam generator pressure and wide-range levelSource-range flux monitorDiagnostic instrumentation for shutdown systemsLevel indication for all tanks used (e.g., CST).5.3.1.6 Support. The equipment required to suppor t operation of the above describedshutdown equipment, e.g., instrument air, component cooling water, se rvice water, and onsitepower sources (ac, dc), and associated electrical distribution systems.5.3.2BWR Systems and InstrumentationIn accordance with GL 81-12,post-fire safe-shutdown for existing PWRs and BWRs. The lsystems and instrumentation with the following capabilities are generally necessary for achievinghot shutdown of BWRs.

5.3.2.1 Reactivity Control.. Reactor trip capability (scram).

5.3.2.2 Reactor Coolant Makeup. Reactor coolant inventory makeup capability, e.g.,reactor core isolation cooling system (RCIC), the high-pressure coolant injection system (HPCI),low pressure coolant injection (LPCI), and core spray.5.3.2.3 Reactor Pressure Control and Decay Heat Removal. Depressurizationsystem valves or safety relief valves for venting to the suppression pool. The residual heatremoval system in steam condensing mode and the service water system may also be used forheat removal to the ultimate heat sink.5.3.2.4 Suppression Pool Cooling.

Residual heat removal system (in suppression poolcooling mode) service water syst em to maintain hot shutdown.

DG-1170, Page 1405.3.2.5 Process Monitoring. The following instrumentation is considered necessary toachieve hot shutdown for BWRs.Reactor water level and pressure,Suppression pool leve l and temperature,Emergency or isola tion condenser level,Diagnostic instrumentation for shutdown systems,Level indication for all tanks used.5.3.2.6 Support.

The equipment required to suppor t operation of the above describedshutdown equipment, e.g., instrument air, closed loop cooling water, service water, and onsitepower sources (ac and dc), and associated electrical distribution systems.The guidance in Regulatory Position 5.3 is based on Appendix R to 10 CFR Part 50, GL81-12, GL 86-10, and Richards Letter (2000).5.4 Cold Shutdown Systems and Instrumentation required for specific plants is included lin the plant licensing basis and the operating parameters that determin e post-fire safe-shutdown lare included in the plant Technical Specifications.

l l5.2Cold Shutdown and Allowable Repairs lFor normal safe shutdown, redundant systems necessary to achieve cold shutdown may bedamaged by a single fire, but damage should be limited so that at least one success path 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 capability or within the time period lrequired to achieve a safe-shutdow n condition, if less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

.lFor alternative or dedicated shutdown, equipment or systems that are the means to achieve and maintain cold shutdown conditions should not be damaged by fire

, or the firedamage to such equipment and systems should be limited so that the systems can be made operable and cold shutdow n achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (or less, if required) using only onsite lpower. Systems and components used for safe shutdown after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (or less, if required) maylbe powered from offsite power only.Cold shutdown capability repairs (e.g., the replacement of fuses and the replacement ofcabling) are permitted. Selected equipment replacem ent is also allowed if practical. Proceduresshould be prepared for repairing damaged equipment (see Regulatory Position 5.

7 5.3 of thislguide), and dedicated replacement e quipment should be stored on s ite and contro lled. Repairs lshould be of sufficient quality to ensure safe operation until the normal e quipment is restored toan operating condition.

Repairs not permitted include the use of clip leads in control panels (i.e., hard-wired lterminal lugs should be used) and the use of jumper cables other than those fastened withterminal lugs.

DG-1170, Page 141When repairs are necessary in the fire area, the licensee should demons trate that sufficienttime is available to allow the area to be re

-entered, that expected fire and fire suppressant damagewill not prevent the repairs from taking place, and that the repair proce dures will not adverselyimpact operating systems.5.4.1 PWR Systems and Instrumentation for Cold Shutdown Regulatory Position 5.4.1 provides guidance on equipment and capability that is generallynecessary to achieve cold shutdown, in addition to that already described in Regulatory Positions5.3.1 and 5.3.2, to maintain hot standby (PWR) or hot shutdown (BWR).5.4.1.1 Reactor Coolant System Pressure Reduction to Residual Heat RemovalSystem (RHR) Capability. Reactor coolant system pressure reduction by cooldown using steamgenerator power operate d relief valves or a tmospheric dump valves.5.4.1.2 Decay Heat Removal. Decay heat removal capability, e.g., residual heatremoval system, component cooling water system, and service water system to remove heat andmaintain cold shutdown.5.4.1.3 Support. Support capability, e.g., offsite pow er and the associ ated electricaldistribution system to supply the above equipment.5.4.2 BWR Systems and InstrumentationAt this point the equipment necessary for hot shutdown has reduced the primary systempressure and temperature to the point that the RHR system may be placed in service in RHRcooling mode. Decay heat removal and associated support systems are generally needed Thelcombination of an automatic depressurization sy stem and low-pressure safety injection system lcan provide cold shutdown capability. The application of regulatory allowance for repairs or lmanual actions for cold shutdown

.l5.4.2.1 Decay Heat Removal. Residual heat removal system in the RHR coolingmode, service water system.5.4.2.2 Support. Support capability, e.g., offsite pow er and the associated distributionsystems, to provide for shutdown equipment.The guidance in Regulatory Position 5.4 is based on Appendix R to 10 CFR Part 50,CMEB 9.5-1, GL 81-12, GL 86-10, IN 84-09, and Mattson Memo (1982).

5.5 systems does not extend to these systems when they are credited for achieving and lmaintaining hot shutdown.

l l5.3Fire Protection of Safe

-Shutdown Capability lFire barriers or automatic suppr ession, or both, should be installed as necessary to protectredundant systems or components necessary for safe shutdown. Except where in thosel DG-1170, Page 142circumstances in which alternative or dedicated shutdown systems are required, or where cableslor equipment , or cables (including associated non-safetyelectrical circuits that could prevent loperation or cause maloperation due to hot shorts, open circuits, or shorts to ground

) oflredundant success paths of systems necessary to achieve and ma intain hot shutdown conditionsare located within the same fire area outside of primary containment, the licensee should provide lfor currently operating reactor plants one of the following means of ensuring that one of the lsuccess paths (of equipment for hot shutdown) is free of fire damage should be provided.(Regulatory Position 8.2 of this guide provide s the protection require ments for redundant post-lfire safe-shutdown success paths in new reactor plants):

la.Separation of cab les and equipment and associated non-safety circuits of redundant lsuccess paths by a fire barrier having a 3-hour rating should be achieved. Structural steel lforming part of or supporting the fire barrier should be protected to provide fire resistance equivalent to that of the barrier.b.Separation of cab les and equipment and associated non-safety circuits of redundantsuccess paths by a horizontal distance of more than 6.1 m (20 f eet) with no interveningcombustible or fire hazards should be achieved. In addition, fire detectors and an automatic lfire suppression system should be installed in the fire area.Insulation of electrical cables, including those with fire

-resistive coatings, should be lconsidered as intervening combustibles in other than negligible quantities (i.e., isolated

cable runs) as determined by engineering and fire hazard s analysis. Cables in conduit are lnot considered intervening combustibles.c.Enclosure of cable and equipment and associated circuits of one redundant success path inla fire barrier having a 1-hour rating should be achieved. In addition, fire detectors and an lautomatic fire suppression system should be installed in the area where the fire area islpostulated

.lIn meeting the provisions of I i tems b and c above, the insta llation of fire suppression and ldetection in a fire area should be sufficient to protect against the hazards of the area. In thisregard, detection and suppression providing less than full area coverage may be evaluated asadequate to comply with the regulation. (s S ee Regulatory Position 1.8.3

.).lInside non-inerted containments, the licensee should provide fire protection should be lprovided that is in accordance with the criteria above

, or as specified in Regulatory Position 6.1.1.1 of this guide. The guidance in Regulatory Position 5.5 is in Appendix R to 10 CFR Part 50, CMEB 9.5-1, GL 83-33, GL 86-10, and IN 84-09.

DG-1170, Page 1435.5.1 Associated Circuits of ConcernAny (associated) non-safety or safety circuits in a fire area that could adversely affect theidentified shutdown equipment by feeding back potentially disabling conditions (e.g., hot shortsor shorts to ground) to power s upplies or control circuits of th at equipment should be evaluated. Such disabling conditions should be prevented to provide assurance that the identified safeshutdown equipment will function as designed.Circuits within a fire area may be subject to fire damage that can affect or prevent post-fire safe shutdown capability. Associated circuits of concern are defined as those cables (safety-related, non-safety-re lated Class 1E and non-Cl ass 1E) that have a phy sical separation less thanthat specified in a through c of Regulatory Position 5.5 and have one of the following.a.A common power source with the shutdown e quipment (redundant or a lternative) and the power source is not electrically protected from the circuit of concern by coordinatedbreakers, fuses, or similar devices.b.A connection to circuits of equipment w hose spurious operation would adversely affectthe shutdown capability (e.g., RHR/RCS isolation valves, ADS valves, PORVs, steamgenerator atmospheric dump valves, instrumentation, steam bypass).Text Was Moved From Here: 8Hot short conditions are assumed to exist until action has been taken to isolate the circuit from the fire area, or other actions as appropria te have been taken to negate the effects of the spurious actuation.c.A common enclosure (e.g., raceway, panel, junction) with the shutdown cables (redundant or alternative) (1) that is not electrically protected by circuit breakers, fuses,or similar devices or (2) will allow propagation of the fire into the common enclosure.The guidance in Regulatory Position 5.5.1 is based on GL 81-12, GL 86-10, and Holahan Memo (1990).

5.5.2 of this guide.

ll DG-1170, Page 144 5.3.1Identification and Evaluation of Associated Circuits of Concern lIt is recognized that there are different approaches that may be used to reach the sameobjective of determining the interaction of associated circuits with shutdown systems. One approach is to start with the fire area, identify what is in the fire area, and determine theinteraction between what is in the fire area and the shutdown systems th at are outside the fire area. This approach has been designated th e "Fire Area Approach." A second approach,designated the "Systems Approac h," would be to identify the shutdown systems outside a firearea and then determine those circuits that are located in the fire area and that are Post-FirelSafe-Shutdown Circuits l

lThe post-fire safe-shutdown analysis must ensure that one success path of shutdown lSSCs remains free of fire damage for a single fire in any single plant fire area. The NRC lacknowledges Chapter 3 of industry guidance document, NEI-00-01, Revision 1, in RIS 2005-30,las providing an acceptable deterministic methodology for analys is of post-fire safe-shutdown lcircuits, when applied in conjunction with the RIS. (The guidance provided in RIS 2005-30 is lalso included in this regulatory guide.) All ci rcuits for which fire-induced failure could prevent lsafe shutdown must be addressed in the analysis and appr opriate protection must be provided.

ll5.3.2Hi/Low Pressure Interface llThe licensee should ev aluate the circuits associated with the shutdown system.

lHigh impedance faults should be considered for all associated circuits located in the firearea of concern. Thus, simultaneous high impedan ce faults (below the trip point for the breaker on each individual circuit) for all associated circuits located in the fire area should be consideredin the evaluation of the safe shutdown capability. Clearing such faults on associated circuits thatmayHi/Low pressure interfaces for the potential to adversely affect safe shutdown may belaccomplished by manual breaker trips governed by written procedures.

Circuit coordinationstudies need not be performed if it is assumed that shutdown capability will be disabled by suchhigh impedance faults and appropriate written procedures for clearing them are provided.5.5.2.1 Fire Area Approach. a.For each fire area, identify (1) the power cables that connect to the same power supply of the alternative, dedicated, or backup shutdown system and the function of each powercable, (2) the cables that are considered for possible spurious operation that couldadversely affect safe shutdown and the function of each cable, and (3) the cables thatshare a common enclosure with circuits of the alternative or dedicated shutdown systemsand the function of each cable.b.Demonstrate that fire-induced failures (e.g., hot shorts, open circuits, or shorts to ground) of each of the cables identifie d above will not prevent opera tion or cause maloperation of the alternative or dedicated shutdown method.

DG-1170, Page 145c.For each cable where electrical isolation has been provided, drawings should bedeveloped that illustrate how electrical isolation is accomplished.5.5.2.2 Systems Approach

.a.Develop a methodology to assess the potential of associated circuits that adversely affectthe alternative or dedicated shutdown systems. The methodology should provide for identification of circuits that share a common power supply or common enclosure withthe alternative or dedicated shutdown system and the circuits whose spurious operationwould affect shutdown. Additionally, the method for determining whether these circuits are associated circuits of concern for the fire area should be included.b.Identify the associated circuits of concern in the fire area and demonstrate that fire-induced failures (e.g., hot shorts, open circuits, or shorts to ground) of each of the cableswill not prevent operation or cause maloperation of the alternative or dedicated shutdown method.c.For each cable where electrical isolation has been provided, drawings should bedeveloped that illustrate how electrical isolation is accomplished.The guidance in Regulatory Position 5.5.2 is based on GL 81-12 and GL 86-10.5.5.3 Hi/Low Pressure InterfaceFor either approach described in Regulatory Position 5.5.2.1 or 5.5.2.2, an evaluation ofHi/Low pressure interfaces shoul d be performed. Circuits associated with Hi/Low pressure interfaces should be evaluated for the potential to adversely a ffect safe shutdown. For example, the residual heat removal (RHR) system is generally a low-pressure system that interfaces withlthe high-pressure primary coolant system. Thus, the interface most likely consists of two redundant and independent motor-operated valves.

TBoth of these two motor-operated valvesl and their associated power and control cables may be subject to damage from a single fire. Thislsingle fire could cause the two valves to spuriously open, resulting in an interfacing system LOCA through the subject Hi/Low

-pressure system interface. To ensure that this interface andlother Hi/Low pressure interfaces are adequately protected from the effects of a single fire, thefollowinglicensee should be performed.

lperform an evaluation, as follows:

la.Identify each Hi/Low

-pressure interface that uses redundant electrically controlledl devices (such as two series motor

-operated valves) to isolate or preclude rupture of anylprimary coolant boundary.

DG-1170, Page 146b.For each set of redundant valves identified in this Regulatory Position 5.5.3, verify thatthe redundant cabling (power and control) ha ve s adequate physical separation as stated by lRegulatory Position 5.

5 3 of this guide.

lc.For each case w W here adequate separati on is not provided, demonstrate that fire-induced lfailures (multiple hot shorts, open circuits, and shorts to ground) of the cables will not lcause maloperation and result in an interfacing systems LOCA.The guidance in Regulatory Position 5.5.3 is based on GL 81-12.5.5.4 Protection of Associated Circuits of ConcernThe shutdown capability may be protected from the adverse effect of damage toassociated circuits of concern by the separation and protection guidelines of Regulatory Position5.5 of this guide, or alternatively by the following methods as applied to each type of associatedcircuit.Text Was Moved From Here: 9 5.3.3 Operator Manual Actions llThe associated circuit of concern interrupting devices (breakers or fuses) time-overcurrent ltrip characteristic for all circuit faultspost-fire safe-shutdown analysis should cause describe thelinterrupting device to interrupt the fault current prior to initiation of a trip of any upstreaminterrupting device that will cause a loss of the common power source.The power source should supply themethodology necessary fault current for sufficient ltime to ensure the proper coordination w ithout loss of function of theaccomplish safe lshutdown loads.The acceptability of a particular interrupting device is c onsidered demonstrated if

,lincluding any operator actions required. Manual actions may not be credited in lieu of providing lthe following criteria are met:The interrupting device design should be factory tested to verify overcurrentrequiredlprotection as designedof redundant systems located in the same fire area required by lSection III.G.2 of Appendix R to 10 CFR Part 50, unless the NRC has reviewed and lapproved a specific operator manual action for a specific plant through the exemption lprocess of 10 CFR 50.12. If permitted by the plan t license, plants that were licensed after lJanuary 1979 may credit operator manual actions for these areas if it can be shown that lthe use of the operator manual action does not adversely affect safe shutdown.

llIf one of the redundant success paths in the same fire area is maintained free of fire ldamage by one of the specified means in Appendix R,Section III.G

.2, then the use of operator lmanual actions, or other means necessary, to mitigate fire-induced operation or maloperation to lthe second success path may be considered in accordance with the applicable UL, ANSI, or lNEMA standards.

DG-1170, Page 147For low and medium voltage switchgear (480V and above), circuit breaker/protectiverelay periodic testing should demonstrate th at the overall coordina tion scheme remainswithin the limits specified in the design criteria. This testing may be performed as aseries of overlapping tests.Text Was Moved From Here: 10Fuses, when used as interrupting devices, do not require periodic testing because of theirstability, lack of drift, and high reliability. Administrativ e controls should ensure thatreplacement fuses with ratings other than those selected for proper coordinating are notaccidentally used.5.5.4.2 Spurious Operation Circuits. Provide a means to isolate the equipment and components from the fire area prior to the fire (i.e., remove power, open circuit breakers).

Provide electrical isolation th at prevents spurious operati on. Potential isolation devices include breakers, fuses, amplifie rs, control switches, current tr ansformers, fiber optic couplers,relays, and transducers.

Provide a means to detect spurious operations and develop procedureslicensee's FPP and llicense condition because Section III.G.2 has been satisfied (e.g., to stop a pump that spuriously lstarts and could prevent or adversely impact safe shutdown if allowed to continuously operate).

lOperator manual actions may also be credited when alternate or dedicated shutdown capability is lprovided.l lFor pre-1979 licensees, a staff decision in an SER that approves the use of operator lmanual actions, in lieu of one of the means specified in Section III.G.2 of Appendix R, does not leliminate the need for an exemption. Pre-1979 li censees that have SERs, but not a corresponding lexemption, and that approve ope rator manual actions must request an exemption under 10 CFR l50.12, highlighting the special circumstances of 10 CFR 50.12(a)(2)(ii), citing the SER as the lsafety basis, and confirming that the safety basis established in the SER remains valid.

l lRIS 2006-10 provides additional guidance on regulatory expectations for operator manual lactions. All fire-relate d operator manual actions must be feasible and reliable. NUREG-1852 lprovides technical bases in the form of criteria and technical guidance for justifying that operator lmanual actions are feasible and can reliably be performed under a wide range of plant conditions lthat an operator might encounter during a fire. NUREG-1852 only addr esses operator manual lactions and does not address the additional regulatory requireme nts associated with operator lmanual actions, e.g., requirement s for detection and suppression.

Use of operator manual actions ldoes not obviate the detection and automatic s uppression capabilities that are required by the lregulations. In addition, the omission or elimin ation of these capabilities in an area containing lSSCs (including circuits) important to safety would generally be considered an adverse effect on lsafe shutdown since it would reduce, at a minimum, fire protection defense-in-depth.

ll DG-1170, Page 148Because the fire protection requirements, including the protection of safe-shutdown lcapability and the prevention of radiological release, can be integrated in the planning and design lphase, a new reactor plant should have min imal reliance on operato r manual actions and lalternative/dedicated shutdown systems (protection for fires in the main control room will require lalternative shutdown capability).

l l5.3.4Spurious Actuations llThe post-fire safe-shutdown circuit analysis must address all possible fire-induced lfailures, including multiple spurious actuations. Although some licensees have based this lanalysis on the assumption that multiple spurious actuations will not occur simultaneously or in lrapid succession, cable fire testing performed by the industry had demonstrated that multiple lspurious actuations occurring in rapid succession (without sufficient time to mitigate the lmaloperation of equipment (e.g., closure of the block valve if a PORV spuriously operates,opening of the breakers to removeconsequences) have a relatively high probability of occurring.

lThe success path SSCs, including circuits, must be protected from fire damage that could prevent lsafe shutdown.

l lNote that the crediting of operator manual actions is not an acceptable approach for lmitigating spurious operation of safety injection).

l5.5.4.3 Common Enclosures. Provide appropriate measures to prevent propagation ofthe fire.Provide electrical protection (e.g., breakers, fuses, or similar devices).The guidance operations of components in redundant safe-shutdown trains or systems l(i.e., the primary, not the alte rnative/dedicated, safe-shutdown trains or systems), except as lpreviously discussed in Regulatory Position 5.5.4 is based on GL 81-12 and IN 88-45.

l5.6 Alternative, Dedicated, or Backup3.3. (Also, refer to RIS 2005-30 for further ldiscussion of this issue.) See the "Glossary" section of this regulatory guide for a definition of lredundant trains/systems.

l l

DG-1170, Page 149 5.4Alternative and Dedicated Shutdown Capability l5.6 4.1 General Guidelines lAlternative, dedicated, or backup shutdow n capability and its associated circuits,independent of cables, systems, or components in the area, room, or zone under consideration, should be provided:a.In areas where the fire protection featur es cannot ensure safe shutdown capability inthe event of a fire in that area (i.e., where the protection of systems whose functions are required for hot shutdown does not satisfy th e criteria of Regulatory Position 5.5) or b.Where redundant success paths of systems required for hot shutdown located in thesame fire area may be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems.Fire detection and a manua lly actuated fixed water suppression system or anautomatically actuated gaseous suppression system should be installed in the area, room, orzone under consideration.While independence is clearly achieved where alternative shutdown equipment isoutside the fire area under consideration, alternative shutdown equipment in the same firearea but independent of the room or the zone under consideration may be acceptable. Where alternative, dedicated, or backup shutdown is provided for a room or zone, the capabilityshould be physically and electrically independent of that room or zone. The vulnerability ofthe equipment and personnel required at the location of the alte rnative, dedicated, or backupshutdown capability to the environmen ts produced at that location as a result of the fire or fire suppressants should be evaluated. These environments may be due to the hot layer, smoke,drifting suppressants, common ventilation systems, common drain systems, or flooding. Inaddition, other interactions between the locations may be possible in unique configurations. Therefore, the "room" concept sh ould be justified by a detailed fire hazards analysis thatdemonstrates a single fire will not disable both normal shutdown equipment and the llAppendix R to 10 CFR Part 50 defines alternative shutdown capability as being provided lby rerouting, relocating, or modifying existing systems, whereas dedicat ed shutdown is defined las being provided by installing new structures and systems for th e function of post-fire shutdown.

lSince post-fire repairs cannot be credited for achieving and maintaining hot shutdown, the llicensee should implement the required rerouting, relocating, or modifying of the existing system lfor alternative shutdown capability in existing plants when the need for additional alternative lshutdown capability is identified.

l lFor those fire areas where alternative or dedicated shutdown capability is required, the llicensee should provide fixed fire suppression and detection for the fire area containing the lredundant success paths (detecti on and suppression are not necessarily required for the area lcontaining the alternative/dedicated shutdown system except where required by the fire hazards lanalysis).

l lThe safe-shutdown analysis must demonstrate that alternate or dedicated shutdown l

DG-1170, Page 150systems, components, including electrical circuits, necessary to achie ve and maintain hot lshutdown are free of fire damage and capable of performing the necessary safe-shutdown lfunctions or prevented from causing actions that prevent safe shutdown

.lThe alternative , /dedicated , or backup shutdown capability for specific fire areas may be lunique for each such area, or it may be one unique combination of systems for all such areas. Ineither case, the alternative shutdown capability shoul d be independent of th e specific fire areas and should accommodate post-fire conditions whe re n offsite power is available and whe re nloffsite power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

P The licensee should provide procedures to limplement the alternative or dedicatedalternative/dedicated shutdown capability should be lprovided , as described in Regulatory Position 5.

7 5 of this guide.

l5.4.2The performance goals and criteria for Associated Circuits of Concern llWhen alternative or dedicated shutdown are described in systems are credited for lachieving post-fire safe-shutdown, a specific category of circuits has been defined (referred to as l"associated circuits of concern") and acceptable approaches to mitigating the consequences of lfire-induced failure of these circ uits have been identified. These circuits are nonsafety or safety lcircuits that could adversely affect the identified shutdown equipment by feeding back potentially ldisabling conditions (e.g., hot shorts or shorts to ground) to power supplies or control circuits of lthat equipment and should be evaluated. Such disabling conditions should be prevented to lprovide assurance that the identified safe-shutdown equipment will function as designed.

l lAssociated circuits of con cern are defined as those cables (safety-related, nonsafety-lrelated Class 1E and non-Class 1E) that have a physical sepa ration less than that specified in lRegulatory Positions 5.3.a through 5.3.c of this guide, and have one of the following:

la.a common power source with the shutdown equi pment (redundant or a lternative) that is lnot electrically protected from the circuit of concern by coordinate d breakers, fuses, or lsimilar devices lb.a connection to circuits of equipment that would adversely affect the shutdown capability lif spuriously operated (e.g., RHR/reactor coolant system isolation valves, automatic ldepressurization system valves, power-operated relief valves, steam generator latmospheric dump valves, instrumentation, steam bypass) l DG-1170, Page 151 lText Moved Here: 8 lFor consideration of spurious actuations, the licensee should evaluate all possiblelfunctional failure states should be evaluated, that is, the component could be energized or de-energized by one or more circuit failure modes (i.e., hot shorts, open circuits, andshorts to ground). Therefore, valves could fail open or closed

, pumps could fail runningl or not running

, or electrical distribution breakers could fail open or closed. For three-lphase ac circuits, the probability of getting a hot short on all three phases in the proper

sequence to cause spurious operation of a motor is considered sufficiently low as to notrequire evaluation except for any cases involving Hi/Lo pressure interfaces. Forungrounded dc circuits, if itthe licensee can be show n that onlyat least two hot shorts oflthe proper polarity without grounding could are required to cause spurious operation, nol further evaluation is necessary except for any cases involving Hi/Lo pressure interfaces. However, two proper polarity faults in ung rounded multi-conductor dc circuits should beconsidered.End Of Moved Text lHot short conditions are assumed to exist until action has been taken to isolate the circuit lfrom the fire area or other actions as appropria te have been taken to negate the effects of lthe spurious actuation.

lc.a common enclosure (e.g., raceway, panel, junction) with the shutdown cables (redundant lor alternative) that (1) is not electrically protected by circuit breakers, fuses, or similar ldevices, or (2) will allow propagation of the fire into the common enclosure l

l5.4.3 Protection of Associated Circuits of Concern llThe shutdown capability may be protected from the adverse effect of damage to lassociated circuits of concern by th e separation and protection guidelines of Regulatory Positionl 5.2 of this guide.The guidance in Regulatory Position 5.6.1 is based on Appendix R to 10 CFR Part 50,CMEB 9.5-1, GL 81-12, GL 86-10, and IN 84-09.

5.6.2 3 of this guide or, alternatively, by the following methods as applied to each type lof associated circuit of concern.

l l5.4.3.1Common Power Source llText Moved Here: 9 l5.5.4.1 Common Power Source. Provide A load fuse/breaker (i.e., interrupting devices)l to feeder fuse/breaker coordination to preven t loss of the redundant or alternative shutdown power source may be necessary. IEEE Standard 242, "IEEE"IEEE Recommended Practices forlProtection and Coordination of Indus trial and Commercial Power Systems,"" provides detailedlguidance on achieving proper coordination.

DG-1170, Page 152 To ensure that the coordination criteria are met, the following should apply:End Of Moved Text la.The associated circuit of concern interrupting devices (breakers or fuses) time-overcurrent ltrip characteristic for all circuit faults should cause the interrupting device to interrupt the lfault current before initiation of a trip of any upstream interrupting device that will cause la loss of the common power source.

lb.The power source should supply the necessary fault current for sufficient time to ensure lthe proper coordination without loss of function of the shutdown loads.

llThe acceptability of a particular interrupting device is consid ered demonstrated if the lfollowing criteria are met:

la.The interrupting device design should be factory tested to verify overcurrent protection as ldesigned in accordance with the applicable UL, ANSI, or National Electrical lManufacturers Association standards.

lb.For low- and medium-voltage switchgear (480V and above), circuit breaker/protective lrelay periodic testing should demonstrate that the overall coordination scheme remains within lthe limits specified in the design criteria. This testing may be performed as a series of loverlapping tests.

lc.lText Moved Here: 10 lMolded case circuit breakers should periodically be manually exercised and inspected to ensureease of operation. On a rotating refueling outag e basis, a sample of these breakers should betested to determine that breaker drift is within that allowed by the design criteria. Breakers

should be tested in accordance with an accepted quality control QC testing methodology.

llEnd Of Moved Text ld.Fuses, when used as interrupting devices, do not require periodic testing because of their lstability, lack of drift, and high reliability. Administrativ e controls should ensure that lreplacement fuses with ratings other than those selected for proper coordinating are not laccidentally used.

l l5.4.3.2Spurious Operation Circuits llSpurious operation is considered mitigated if one of the following criteria are met:

la.A means to isolate the equipment and com ponents from the fire area before the fire l(i.e., remove power, open circ uit breakers) is provided.

lb.Electrical isolation that prev ents spurious operation is pr ovided. Potential isolation ldevices include breakers, fuses, amplifiers, control switches, current transformers, fiber loptic couplers, relays, and transducers.

l DG-1170, Page 153 c.A means to detect spurious operations and develop procedures to mitigate the lmaloperation of equipment (e.g

., closure of the block valv e if a power-operated relief lvalve spuriously operates, opening of the breakers to remove spurious operation of safety linjection) is provided.

l l5.4.3.3Common Enclosures llAppropriate measures to prevent propagation of the fire should be provided.

llElectrical protection (e.g., break ers, fuses, or similar devi ces) should also be provided.

ll5.4.4Control Room Fires llThe control room fire area c ontains the controls and inst ruments for redundant shutdownsystems in close proximity. (usually s Separation is usually a few inches

.). Remote shutdownlcapability and its associated circuits for the control room and its required circuits should belindependent of the cables, systems, and components in the control room fire area.The damage to systems in the control room for a fire that causes evacuation of the control room cannot be predicted.

A The licensee should conduct a bounding analysis should be made tolassure ensure that safe conditions can be maintained from outside the control room. This analysislis dependent on the specific design.

The usual assumption areThe following assumptions usually lapply:la.The reactor is tripped in the control room.l lb.Offsite power is lost as well as automatic starting of the onsite ac generators and theautomatic function of valves and pumps whose with control circuits that could be affectedlby a control room fire.

lThe analysis should demonstrate that the capability exists to manually achieve safe

-lshutdown conditions from outside the control room by restoring ac power to designated pumps,lassuring that valve lineups are correct, and assuming that any malfunctions of valves that permitthe loss of reactor coolant can be corrected before un

-restorable conditions occur.

DG-1170, Page 154The only manual action in the control room prior to before evacuation for which credit is lusually given credit for is reactor trip. For any additional control room actions deemed necessaryprior to before evacuation, a demonstration of the capability of performing such actions should be lprovided for staff review. Additionally, the licensee should provide assurance would have to be lprovided that such actions could not be negated by subsequent spurious actuation signalsresulting from the postulated fire.Post-fire return to the control room should be governed by those procedures and lconditions as described in Regulatory Position 5.

7 5.2 of this guide

.lAfter returning to the control room, the operators can take any actions compatible with the condition of the control room. Controls in any area (cabinet where the fire occurred) may not be available. Smoke and fire suppressant damage in other areas (cabinets) should also beassessed and corrective action take n before controls in such cabinets are deemed functional. Controls in undamaged areas (cabinets) may be ope rated as required. Repa irs inside the controlroom may be performed to reach cold shutdown.The guidance in Regulatory Position 5.6.2 is based on GL 86-10.

5.7 5Post-Fire Safe

-Shutdown Procedures lProcedures for effecting safe shutdown should reflect the re sults and conclusions of the safe -shutdown analysis. Implementation of the pr ocedures should not further degrade plant lsafety functions. Time-critical operations for effecting sa fe shutdown identified in the safe

-lshutdown analysis and incorporated in pos t-fire procedures should be validated.

l5.7 5.1 Safe -Shutdown Procedures llThe only requirement for p Post-fire safe

-shutdown operating procedures is should beldeveloped for those areas where alternative or dedicated shutdown is required. For other areas of lthe plant, shutdown would normally be achieved using the normal operating procedures or plantemergency operating procedures.

5.7 5.2 Remote Shutdown Procedures llProcedures should be in eff ect that describe the tasks to implement remote shutdown lcapability whe re n offsite power is available and whe re n offsite power is not available for 72 lhours. These procedures should also address necessary actions to compensate for spuriousoperations and high

-impedance faults if such actions are necessary to effect safe shutdown.

lProcedures governing return to the c ontrol room should consider the following conditions:a.The fire has been extinguished and so verified by appropriate fi re protection personnel

DG-1170, Page 155

.lb.The control room has been deemed habitable by appropriate fire protection personnel andthe shift supervisor

.lc.Damage has been assessed and, if necessary, corrective acti on has been taken to ensurethat necessary safety, control, and information systems are functional (some operatorsmay assist with these tasks), and the shift supervisor has authorized return of plant control to the control room

.ld.Turnover procedures that ensure an orderly transfer of control fro m the remote shutdown panel to the control room have been completed.

l5.7 5.3 Repair Procedures llP The licensee should develop p rocedures should be developed for performance of repairslnecessary to achieve and maintain cold shutdown conditions. For alternative shutdown, procedures should be in effect to accomplish repairs necessary to achie ve and maintain cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

For plants that must proceed to cold shutdown prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the lprocedures should support the required time for initiation of cold shutdown.

lThe performance of repair procedures should not adversely impact operating systems needed to maintain hot shutdown.The guidance in Regulatory Position 5.7 is based on Appendix R to 10 CFR Part 50,CMEB 9.5-1, GL 81-12, GL 86-10, IN 84-09, and IP 64100.6.FIRE PROTECTION FOR AREAS IMPORTANT TO SAFETY 5.6lShutdown/Low-Power Operations llSafe-shutdown requirements and objectives are focused on achieving shutdown lconditions for fires occurring during normal at-power operations. During shutdown operations l(i.e., maintenance or refueling outages), fire risk may increase significantly as a result of work lactivities. In addition, redundant systems important to safety may not be available as allowed by lplant technical specifications and plant procedures. The FPP should be reviewed to verify that lfire protection systems, features, and procedures will minimize the potential for fire events to limpact safety functions (e.g., reactivity control, reactor decay heat removal, spent fuel pool lcooling) or result in the unacceptable release of radioactive materials, under the differing lconditions that may be present during shutdown operations.

ll DG-1170, Page 156 6.Fire Protection for Areas Important to Safety lSeveral areas within a nuclear power plant present unique hazards or design issuesrelative to fire protec tion and safe shutdown.

G This section provides g uidance applicable to lspecific plant areas is provided in this section

.6.1Areas Related to Power Operation l6.1.1 Containment llFire protection for the primary and secondary containment areas should be provided forthe hazards identified in the fire hazard s analysis. Under normal conditions, containment fire lhazards may include lubricating oils, hydraulic fluids, cables, electrical penetrations, electricalcabinets, and charcoal filters. During refueling and maintenance operations, additional hazards may be introduced, including cont amination control and decontamination materials and supplies,scaffolding, plastic sheathing, wood planking, chemicals, and hot work. The fire hazards lanalysis should evaluate the effects of postulated fires within the primary containment should be levaluated in the Fire Hazard Analysis to ensure that the integrity of the primary coolant systemand containment is not jeopardized and the safe

-shutdown performance objectives described in lRegulatory Position 5.1 of this guide are met, assuming no action is taken to fight the fire.Guidance for reactor coolant pump oil collection is provided in Regulatory Position 7.1 ofthis guideprovides guidance for RCP oil collection

.l6.1.1.1 Containment Electrical Separation

. llFor secondary containment areas, cable fire hazards that could affect safety should be lprotected against as described in Regulatory Position 4.1.3.3 of this guide

.l DG-1170, Page 157Inside non-inerted containments, one of the fire protection means specified in Regulatory Position 5.

5 3, or one of the following

, should be provided

.:lSeparation a.separation of cables and equipment and associated non

-safety circuits ofl redundant success pathstrains by a horizontal distance of more than 6.1 ml(20 ft) with no intervening combustibles or fire hazards

lb.I i nstallation of fire detectors and an automatic fire suppression system in the fire area

orllc.S separation of cables and e quipment and associated non

-safety circuits of redundantl success pathstrains by a noncombustible radiant energy shield having a minimum firelrating of one-half hour. The fire protection capability of the radiant energy shield may be demonstrated 30 minutes, as demonstrated by testing or analysis

.l DG-1170, Page 158 6.1.1.2 Containment Fire Suppression

.llThe licensee F should provide fire suppression systems should be provided on the basis of la fire hazards analysis. During normal operations, containment is generally inaccessible and

,ltherefore , fire protection should be provided by automatic fixed systems.

lAutomatic fire suppression capability need not be provided in primary containment atmospheres that are inerted during normal operations. However, inerted containments shouldhave manual firefighting capability, including standpipes, hose st ations, and portableextinguishers, to provide protection during refueling and main tenance operations.

Standpipe and hose stations should also be installed inside PWR containments and BWR containments that are not inerted. Standpipe and hose stations inside containment may beconnected to a high-quality water supply of sufficient quantity and pressure other than the fire main loop if plant-specific features prevent extending the fire main supply inside containment. For BWR drywells, standpipe and hose stations should be placed outside the drywell withadequate lengths of hose, no longer than 30.5 m (100 ft), to reach any location inside the drywell lwith an effective hose stream.

The containment penetration of the standpipe system should meet the isolation requirements of GDC 56, "Primary Containment Isolation," of Appendix A to 10 CFR Part 50 land should be S seismic Category 1 and Quality Group B.

lOperation of the fire protection systems should not compromise the integrity of thecontainment or other systems important to safety. Fire protection activities in the containment

areas should function in conjuncti on with total containment require ments such as ventilation and control of contaminated liquid and gaseous release.

A The licensee should place a dequate self-contained breathing apparatus should be lprovided es near the containment entrances for firefighting and damage control personnel. These lunits should be independent of any breathing apparatus es or air supply systems provided for lgeneral plant activities and should be clearly marked as emergency equipment.

6.1.1.3 Containment Fire Detection

. llFire detection systems should alarm and a nnunciate in the control room. In primary lcontainment, fire detection sy stems should be provided for each fire hazard. For primary andsecondary containment, the type of detection used and the locati on of the detectors should be themost suitable for the particular type of fire hazard identified by the fire hazard s analysis.

lA general area fire detection capability should be provided in the primary containment as backup for to the above described hazard detection. To accomplish this, suitable smoke or heat ldetectors compatible with the ra diation environment should be inst alled in the air recirculationsystem ahead of any filters.

DG-1170, Page 159The guidance in Regulatory Position 6.1.1 is based on Appendix R to 10 CFR Part 50,CMEB 9.5-1, and GL 86-10.

6.1.2 Control Room Complex llThe control room complex (including galleys

, and office spaces, etc.) should be protectedlagainst disabling fire damage and should be separated from other areas of the plant by floors,walls, and roof having minimum fire

-resistance ratings of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Peripheral rooms in thelcontrol room complex should ha ve automatic water suppression and should be separated fromthe control room by noncombustib le construction with a fire

-resistance rating of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. lVentilation system openings between the cont rol room and periphe ral rooms should haveautomatic smoke dampers that close on upon operation of the fire detection or suppressionlsystem. If a gas extinguishing system is us ed for fire suppression, these dampers should bestrong enough to support the pressure rise accompanying the agent discharge and seal tightlyagainst infiltration of the agent into the control room. Carbon dioxide total flooding systems arenot acceptable for these areas.Breathing apparatu se s for control room operators should be readily available.l All cables that enter the control room should terminate in the control room. That is, nocabling should be routed through the control room from one area to another. Cables in under-floor and ceiling spaces should meet the separation criteria necessary for fire protection.

Equipment that is important to safety should be mounted on pedestals or the control rooml should have curbs and drains to direct water away from such equipment. Such drains should be provided with a means for closing to maintain integrity of the control room in the event of otherlaccidents requiring control room isolation.There should be no carpeting in the The control room should not be carpeted. Wherelcarpeting has been installed (e.g., for s ound abatement or other human factors), the carpeting itlshould be tested to standards such as ASTM D2859, "Standard"Standard Test Method forlFlammability of Finished Textile Floor Covering Materials,"" to establish the flammabilitylcharacteristics of the material.

These characteristics shoul d be addressed in the The fire hazardslanalysis should address these characteristics

.l6.1.2.1 Control Room Fire Suppression

. llManual firefighting capability should be provided for both of the following

la.F fire originating within a cabinet, console, or connecting cables

and lb.E exposure fires involving combustibles in the general room area

.l DG-1170, Page 160 Portable Class A and Class C fire extinguishers should be located in the control room. A hose station should be installed inside or immediately outside the control room.Nozzles that are compatible with the hazard s and equipment in the control room should be provided for the manual hose station. The nozzles chosen should satisfymeet actuallfirefighting needs, satisfy electrical safety, and minimize physical damage to electrical equipment from hose stream impingement.Fully enclosed electrical raceways located in under-floor and ceiling spaces, if over 0.09 m 2 (1 sq ft 1 ft 2) in cross-sectional area, should have automatic fire suppr ession inside. Area lautomatic fire suppression should be provided for under-floor and ceiling spaces if these spaces lare used for cable runs

, unless all cable is run in 10 cm-centimeter (4-in ch.) or smaller steel lconduit or the cables are in fully enclosed raceways internally protected by automatic fire suppression.

6.1.2.2 Control Room Fire Detection

. llSmoke detectors should be provided in the control room, cabinets, and consoles. If lredundant safe

-shutdown equipment is located in the sa me control room cabinet or console,ladditional fire protection meas ures should be provided. Alar m and local indication should be provided in the control room.

The outside air intake(s) for the control room ventilation system should be provided withsmoke detection capability to alarm in the control room to enable manual isolation of the control room ventilation system and

, thus , prevent smoke from entering the control room.

ll6.1.2.3 Control Room Ventilation

. llVenting of smoke produced by fire in the control room by means of the normal lventilation system is acceptable; however, provisi on should be made to pe rmit isolation of therecirculating portion of the normal ventilation system. Manually operated venting of the control

room should be available to the operators.Air-handling functions should be ducted separately from cable runs in ceiling and floorspaces. If cables are routed in under-floor or ceiling spaces, these spaces should not be used as lair plenums for ventilation of the control room.The guidance in Regulatory Position 6.1.2 is based on APCSB 9.5-1 and CMEB 9.5-1.

6.1.3 6.1.3 Cable Spreading Room ll DG-1170, Page 161A separate cable spreading room should be provided for each redundant division. Cablespreading rooms should not be shared between reactors. Each cable spreading room should be separated from the others and from other areas of the plant by barriers with a minimum fire ratingof 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. If this is not possible, an a lternative, dedicated, or backup shutdown capability should be provided.Cable spreading rooms should have the following

la.A a t least two remote and separate entrances for access by fire brigade personnel

lb.A an aisle separation between tray stack s at least 0.9 m (3 ft) wide and 2 1.4 5 m (8 5 ft)lhigh;c.H hose stations and portable extinguishers installed immediately outside the room; andld.A area fire detection. lIf division cables are not separated by 3-hour barriers, separa tion should meet theguidelines of Regulatory Guide 1.75 and the cable s should have a suitable fire retardant coating.

l(New reactor cables should meet the fire and flame test requirements of IEEE 383 or IEEE 1202.)

lThe primary fire suppression in the cable spreading room should be an automatic watersystem , such as closed-head sprinklers, open-head deluge system, or open directional water spraylsystem. Deluge and open spray systems should have provisions for manua l operation at a remote station; however, there should be provisions to preclude inadvertent opera tion. Determination ofthe location of sprinkler heads or spray nozzles should consider cable tray arrangements andpossible transient combustibles to ensure adequate water coverage for areas that could presentexposure hazards to the cable system. Cables should be designed to allow wetting down withwater supplied by the fire suppression system without electrical faulting.Open-head deluge and open directional spray systems should be zoned so that a single failure will not deprive the entire area of automatic fire suppression capability.The use of foam is acceptable providedso long as it is of a type capable of beingthat canlbe delivered by a sprinkler or deluge system.lAlternative gas systems (Halon, clean agent, or CO

2) may be used for primary firesuppression if they are backed up by an installed water spray system and hose stations andportable extinguishers immediately outside the room and if t. The access requirements statedl above are should also be met.lDFloor drains should be provided to remove firefighting water should be provided. lWhen gas systems are installed, drains should have adequate seals or the gas extinguishingsystems should be sized to compensate for losses through the drains.

DG-1170, Page 162The ventilation system to each cable spreading room should be designed to isolate thearea upon actuation of any gas extinguishing system in the area. Separate manually actuatedsmoke venting that is operable from outside the room should be providedconsidered for the cable lspreading room.The guidance in Regulatory Position 6.1.3 is based on APCSB 9.5-1 and CMEB 9.5-1.

6.1.4 6.1.4Plant Computer Rooms llComputer rooms for computers performing functions important to safety that are not part lof the control room complex shoul d be separated from other areas of the plant by barriers havinga minimum fire

-resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and should be protected by automatic detection and lfixed automatic suppression. Computers that are part of the control room complex but are notllocated in the control room should be separated and protected as described in Regulatory Position l6.1.2 for peripheral rooms. Computer cabinets locat ed in the control room should be protected as other control room equipment and cable runs therein. Non

-safety-related com puters outside thecontrol room complex should be se parated from plant area s important to safety by fire barrierswith a minimum rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and should be pr otected as needed to prevent fire and smokedamage to equipment important to safety. Manual hose stations and portable extinguishersshould be located in areas containing equipment important to safety. NFPA 75,"Standard"Standard for the Protection of Electronic Computer/Data ProcessingInformation lTechnology Equipment,"" provides additional guidance.

lThe guidance in Regulatory Position 6.1.4 is based on CMEB 9.5-1.

6.1.5 ll6.1.5Switchgear Rooms llSwitchgear rooms containing equipment important to safety should be separated from the lremainder of the plant by barriers with a minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Redundant switchgearsafety divisions should be separated from each other by barriers with a 3-hour fire rating.

Automatic fire detectors should alarm and annunciate in the control room and alarm locally. Cables entering the switchgear room that do not terminate or perform a function there should bekept at a minimum to minimize the fire hazard. These rooms should not be used for any other purpose. Automatic fire suppression should be provided consistent with other safetyconsiderations. Fire hose stations and portable fire extinguishers should be readily availableoutside the area.Some high-voltage electrical equipment (e.g., switchgear and tran sformers) have the lpotential for an energetic electrical fault that can damage SSCs important to safety. The fire lhazards analysis should consider the potential for this type of fault.

lEquipment should be located to facilitate access for manual firefighting. Drains (seeRegulatory Position 4.1.5 of this guide) should be provided to prev ent water accumulation from ldamaging equipment important to safety. Remote

, manually actuated ventilation should be l

DG-1170, Page 163 providedconsidered for venting smoke when manual fi re suppression effort is needed. (s SeelRegulatory Position 4.1.4

).The guidance in Regulatory Position 6.1.5 is based on CMEB 9.5-1.

6.1.6 of this guide.)

ll6.1.6Remote Shutdown Panels llPanels providing remote shutdown capability should be separated from the control roomcomplex by b Barriers having a minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> should separate panels providing lremote shutdown capability from the control room complex. Panels providing remote shutdownlcapability should be electrically isolated from the control room complex so that a fire in eitherarea will not affect shutdown capability from the other area. The general area housing remote panels important to safety should be provided with automatic fire detectors that alarm locally and alarm and annunciate in the c ontrol room. Combustible mate rials should be controlled and limited to those required for operation. Portable extinguishers and manual hose stations shouldbe readily available in the general area.

The guidance in Regulatory Position 6.1.6 is based on CMEB 9.5-1.

6.1.7 llLocations containing remote shutdown panels must be hab itable under fire and post-fire lconditions that require their use. Habitability should also be addre ssed for remote shutdown lpanels protected by or adjacent to areas with gaseous fire suppression systems.

ll6.1.7Station Battery Rooms llBattery rooms important to safety should be protected against fires and explosions.

lBattery rooms should be separate d from each other and other areas of the plant by barriers havinga minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> inclusive of all penetrations and openings.

DCThese battery lrooms should not house dc switchgear and inverters should not be located in these battery rooms. lAutomatic fire detection should be provided to alarm and annunciate in the control room andalarm locally.

VBattery room ventilation systems in the battery rooms should be capable oflmaintaining the hydrogen concentration well below 2%2 percent. Loss of ventilation should bel alarmed in the control room. Standpipes, hose stations, and portable extinguishers should bereadily available outside the room.

The guidance in Regulatory Position 6.1.7 is based on CMEB 9.5-1.

6.1.8 ll6.1.8Diesel Generator Rooms ll DG-1170, Page 164Diesel generators important to safety should be separated from each other and from other lareas of the plant by fire barriers that have a fire resistancefire-resistance rating of at least 3 lhours. Diesel generators that are not important to safety should be separated from plant areas lcontaining equipment and circuits important to safety by fire barriers that have a fire-resistance lrating of at least 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

Automatic fire suppression should be installed to suppress or control any diesel generatoror lubricating oil fires. Such systems should be designed for operation when the diesel is running to operate without affecting the diesel when it is running. Automatic fire detection lshould be provided to alarm and annunciate in th e control room and alarm locally. Hose stationsand portable extinguishers should be readily available outside the area. Drainage for firefighting water should be provided and a means for local manual venting of smoke should be lprovidedconsidered

.lDay tanks with a total capacity of up to 4164 4,164 L (1100 1,100 gallons) may be located lin the rooms with diesel generator areas important to safety under the following conditions:

la.The day tank is located in a separate enclosure with a fire

-resistance rating of at least l3 hours, including doors or pe netrations. These enclos ures should be capable ofcontaining the entire contents of the day tanks and should be protected by an automaticfire suppression system

or.lb.The day tank is located inside the diesel ge nerator room in a diked enclosure that hassufficient capacity to hold 110%110 percent of the contents of the day tank or is drained lto a safe location.The guidance in Regulatory Position 6.1.8 is based on CMEB 9.5-1.

DG-1170, Page 165 6.1.9 Pump Rooms llPump houses and rooms housing redundant pump trains important to safety should bel separated from each other and from other areas of the plant by fire barriers having at least 3-hourratings. These rooms should be protected by au tomatic fire detection and suppression unless afire hazards analysis can demonstrate that a fire will not endanger other equipment required for safe plant shutdown. Fire detection should alar m and annunciate in the control room and alarmlocally. Hose stations and portable extinguishers should be readily accessible.

Equipment pedestals, curbs, and floor dr ains should be provided to prevent wateraccumulation from damaging equipment important to safety. (s See Regulatory Position 4.1.5 oflthis guide.

).lProvisions should be made fo r manual control of the ventilation system to facilitate smoke removal if required for manual firefighting operation. (s See Regulatory Position 4.1.4

).lThe guidance in Regulatory Position 6.1.9 is based on CMEB 9.5-1.6.2Other Areas of this guide.)

ll6.2Other Areas lOther areas within the plant may contain hazards or equipment that warrant special consideration relative to fire protection, including areas containing significant quantities ofradioactive materials, yard areas containing water supplies or systems important to safety, and theplant cooling tower.

6.2.1 New Fuel Areas llPortable hand extinguishers should be located near this area. Also, hose stations shouldl be located outside but within hose reach of this area. Automatic fire de tection should alarm and annunciate in the control room and alarm locally. Combustib les should be limited to a minimum in the new fuel area. The storage area should be provided with a drainage system to precludeaccumulation of water.The storage configuration of new fuel should always be maintained to preclude criticalityfor any water density that might occur during fire water application.

The guidance in Regulatory Position 6.2.1 is based on CMEB 9.5-1.

6.2.2 ll6.2.2Spent Fuel Areas ll DG-1170, Page 166Protection for the spent fuel pool area should be provided by localLocal hose stations land portable extinguishers should provide protection for the spent fuel pool

. Automatic fire ldetection should be provided to alarm and annunciate in the control room and to alarm locally.The guidance in Regulatory Position 6.6.2 is based on CMEB 9.5-1.

6.2.3 Regulatory Guide 1.191 provides additional guidelines re lative to fire protection lof spent fuel areas for permanently shut down reactors that have not completed removal of the lspent fuel to an independently licensed storage facility.

l l6.2.3 Radwaste Building/Storage Areas and Decontamination Areas llRadioactive waste buildings, storage ar eas, and decontamination areas should be lseparated from other areas of the plant by fire barriers having at least 3-hour ratings. Automatic sprinklers should be used in all areas where co mbustible materials are located. Alternatively, manual hose stations and portable extinguishers (hand

-held and large

-wheeled units sized laccording to the hazards) are acceptable.

Automatic fire detection should be provided to annunciate and alarm in the control room and alarm locally. Ventilation systems in these areasshould be capable of being isolated to prevent th e release of radioactive materials to other areasor the environment. Water from firefighting ac tivities should drain to li quid radwaste collectionsystems.Materials that collect and contain radioactivity, such as spent ion exchange resins, charcoal filters, and HEPA filters, should be stored in closed meta l tanks or containers that arelocated in areas free from ignition sources or co mbustibles. These mate rials should be protectedfrom exposure to fires in adjacent areas as well.

Consideration should be given to requirementsfor removal of decay heat from entrained radioactive materials.

The guidance in Regulatory Position 6.2.3 is based on CMEB 9.5-1.

6.2.4 Dry Cask Independent Spent Fuel Storage Areas llF The requirements of 10 CFR 72.122(c) address fire protection of dry cask storage isladdressed byand other independent spent fuel storage facilities. The fire protection provided for lthese facilities should be commensurate with the potential fire hazards and with the potential for lan unacceptable release of radiation during and following a fire. In addition to the requirements lof 10 CFR Part 7210 CFR Part 72, "Licensing Requirements for the Independent Storage of lSpent Nuclear Fuel and , High-Level Radioactive Waste." In addition to the requirements of 10 lCFR Part 72, and Reactor-Related Greater Than Class C Waste

," fire protection for independent lspent fuel storage installations should ensure that fires involving such installations will not impact plant operations and plant areas important to safety.

6.2.5 Water Tanks llStorage tanks that supply water for safe s hutdown should be protected from the effects of lan exposure fire. Combustible materials should not be stored next to outdoor tanks.

DG-1170, Page 167The guidance in Regulatory Position 6.2.5 is based on CMEB 9.5-1.

6.2.6 Cooling Towers llCooling towers should be constructed of noncombustible construction or so be located andlprotected in such a way that a fire will not adversely affect any systems or equipment importantlto safety. Cooling towers shoul d be of noncombustible construction when the basins are used for the ultimate heat sink or for the fire protection water supply. The guidance in Regulatory Position 6.2.6 is based on CMEB 9.5-1.7.PROTECTION OF SPECIAL FIRE HAZARDS EXPOSING AREASIMPORTANT TO SAFETY 7.1For the latter, provisions should be made to ensure a continuous supply of fire protection lwater whenever the cooling tower basin is drained for cleaning or other maintenance.

ll7.Protection of Special Fire Hazards Exposing Areas Important to Safety ll7.1Reactor Coolant Pump Oil Collection lThe reactor coolant pump (RCP)External RCPs with oil lubrication systems should belequipped with an oil collection system if the containment is not inerted during normal operation. The oil collection system should be so designed, engineer ed, and installed to ensure that failurelwill not lead to fire during normal or design

-basis accident conditions and that there is lreasonable assurance that the system will withstand the safe

-shutdown earthquake.lSuch collection systems should be capable of collecting lube oil from all potentialpressurized and unpressurized leakage sites in the RCP lube oil systems. Leakage should be collected and drained to a vented closed container that can hold the entire lube oil systeminventory. A flame arrester is required in the vent if the fl ashpoint characteristics of the oilpresent the hazard of fire flashback. Leakage points to be protected should include, but are notlimited to, 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 whe re n such features exist on the RCPs. lThe drain line should be large enough to accommodate the largest potential oil leak.

DG-1170, Page 168 One or more tanks need to be provided with sufficient capacity to collect the total lube oilinventory from all RCPs draining to the container.

Alternatives that may be acceptable areinclude the following

la.One or more tanks are provided with sufficient capacity to hold the total lube oilinventory of one RCP with margin if the tank is located such that any overflow from thetank will be drained to a safe location where the lube oil will not present an exposure fire hazard to or otherwise endanger equipment important to safety

or .lb.Where the RCP lube oil system is shown, by analysis, to be capable of withstanding the lsafe -shutdown earthquake (SSE) (eliminating the consideration of simultaneous lube oil lsystem ruptures from a seismic event), protection is provided for random leaks atmechanical joints in the lube oil system (e.g., flanges, RTDresistance temperature ldetectors connections, sightglasses). Alternative methods of protection may be deemed lacceptable for such designs. In RCP lube oil collection systems of such designs, one or

more tanks need to be provided with sufficient capacity to hold the total lube oilinventory of one RCP with margin. Because protection is required only against possibleleakage resulting from random leaks from the one pump at a time, any overflow from the tanks need not be considered

or .lc.For pumps with the lube oil contained entirely within the pump casing, an oil collectionsystem may not be required provided it can be shown that there are no potentiallysignificant leakage points.The guidance in Regulatory Position 7.1 is based on Appendix R to 10 CFR Part 50,CMEB 9.5-1, GL 86-10, IN 84-09, and Vollmer Memo (1983a).7.2Turbine/Generator Building lThe turbine building should be separated from adjacent structures containing equipmentimportant to safety by a fire barrier with a rating of at least 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The fire barriers should bedesigned to maintain structural integrity even in the event of a complete collapse of the turbine structure. Openings and penetrations in the fire barrier should be minimized and should not belocated where the turbine oil system or generator hydrogen cooling system creates a direct fire exposure hazard to the barrier. Considering the severity of the fire hazards, defense

-in -depthlmay dictate additional protection to ensure barrier integrity. The guidance in Regulatory Position 7.2 is based on CMEB 9.5-1.7.2.1 Oil Systems and the potential effect of a major turbine building fire on the ability lto maintain operator control of the plant and safely shut down should be evaluated.

l DG-1170, Page 169 7.2.1Oil Systems llTurbine buildings contain large sources of combustible liquids, including reservoirs andpiping for lube oil, seal oil, and electro

-hydraulic systems. These systems should be separatedfrom systems important to safety by 3-hour ra ted barriers. Additi onal protection should beprovided on the basis of the hazard

, or where fire barriers are not provided. (See Regulatory Position 2.1.3

.) The guidance in Regulatory Position is based on ASB 9.5-1.

7.2.2 Hydrogen SystemTurbine-generators of this guide.)

ll7.2.2 Hydrogen System llTurbine generators may use hydrogen for cooling. Hydrogen storage and distributionlsystems should meet the guidelines provided in Regulatory Position 7.5 of this guide.

7.2.3 Smoke Control llSmoke control should be provided in the turbine building to mitigate potential heavyl smoke conditions associated with co mbustible liquid and cable fires. Specific guidance is provided in Regulatory Position 4.1.4 of this guideprovides specific guidance

.l7.3Station Transformers lTransformers installed inside fire areas containing systems important to safety should beof the dry type or insulated and cooled with noncombustible li quid. Transformers filled with combustible fluid that are located indoors shoul d be enclosed in a transformer vault.

ANFPA 70loffers additional guidance is provided in NFPA 70

.lOutdoor oil-filled transformers should have oil spill confinement features or drainageaway from the buildings. Such transformers shoul d be located at least 15.2 m (50 ft) distant fromthe building, or building walls within 15.2 m (50 ft) of oil-filled transf ormers should be withoutopenings and have a fire

-resistance rating of at least 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

lThe guidance in Regulatory Position 7.3 is based on CMEB 9.5-1.7.4Diesel Fuel Oil Storage Areas lDiesel fuel oil tanks with a capacity greater than 4164 4,164 L (1,100 gallons) should notlbe located inside buildings containing equipment important to safety. If above

-ground tanks areused, they should be located at least 15.2 m (50 ft) from any building containing equipmentimportant to safety, or if located within 15.2 m (50 ft), they should be housed in a separatebuilding with constructionconstructed with materials having a minimum fire

-resistance rating ofl 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Potential oil spills s hould be confined or directed away from buildings containing DG-1170, Page 170equipment important to safety.

Totally buried tanks are acceptable outside or under buildings. l(s See NFPA 30 for additional guidance

.).lAbove-ground An automatic fire suppression system should protect aboveground oillstorage, including those tanks located in a separate building, should be protected by an automaticfire suppression system. The guidance in Regulatory Position 7.4 is based on CMEB 9.5-1

.7.5Flammable Gas Storage and Distribution lBulk gas storage (either compressed or cryogenic) should not be permitted insidestructures housing equipment important to safety. Storage of flammable gas such as hydrogen should be located outdoors or in separate

, detached buildings so that a fire or explosion will not ladversely affect any systems or equipment important to safety. NFPA 50A and 50B provideadditional guidance.

Care should be taken to locate high-pressure gas storage containers with the long axisparallel to building walls. This will minimize the possibility of wall penetration in the event of a container failure. Acetylene-O oxygen gas cylinder storage locati ons should not be in areas that lcontain or expose equipment important to safety or the fire protection systems that serve thoseequipment areas. A permit system should be required for use ofAcetylene-Oxygenacetylene-oxygen gas storage cylinders in areas of the plant important to lsafety. NFPA 55, "Standard for the Storage, Use, and Handling of Compressed and LiquefiedGases in Portable Cylinders," provides additional guidance.

Risks to equipment important to safety from hydrogen supply systems can be minimizedby designing hydrogen lines in plant areas important to safety to S seismic Class I requirements,lsleeving the piping such that the pipe is directly vented to the outside , or. Risks can also be lminimized through the use of restricting orifices or excess flow valves to limit the maximum lflow rate from the storage facility to the areas of concern so that in case of a line break, the hydrogen concentration in the affected areas will not exceed 2%2 percent. This approach lincludes pre

-operational testing and subsequent retesting of excess fl ow valves and measures to prevent buildup of unacceptable amounts of trapped hydrogen and inadvert ent operation with thesafety features bypassed. A so mewhat less cost-effective altern ative involves use of a normallyisolated supply with in termittent ma nual makeup.

AEPRI NP-5283-SR-A, "Guidelines for lPermanent BWR Hydrogen Water Chemistry Installati ons," provides additional guidelines and lcriteria for the design, insta llation, and operation of flammable cryogenic and compressed gassystems are provided in EPRI NP-5283-SR-A. The guidance

.ll DG-1170, Page 171 7.6Nearby Facilities llThe FPP should address plant support facilities (e.g., offices, maintenance shops,lwarehouses, temporary structures, equipment storage yards), collocated power generating units l(e.g., nuclear, coal, natural gas), and nearby industrial facilities (e.g., chemical plants, refineries,lmanufacturing facilities) to the extent that fires and or explosions in these facilities may affect lequipment important to safety. Fire protection systems and f eatures should be adequate to lprotect against potential exposure fires and explosions from nearby facilities.

l l8.Fire Protection for New Reactors ll8.1GeneralllMany of the current fire protection requirements and guidelines for operating reactors lwere issued after Commission approval of construction permits and/or operating licenses. The lbackfit of these requirements and guidelines to existing plant designs created the need for lconsiderable flexibility in the application of the regulations on a plant-by-plant basis. New lreactor designs should integrate fire protection requirements, including the protection of safe-lshutdown capability and the prevention of radiological release, into the planning and design lphase for the plant. In addition, new reactor designs should minimize or eliminate the use of lalternative/dedicated shutdown systems and should only rely on such systems when it is not lfeasible to provide the require d protection for redundant safe-shutdown systems, such as in the lmain control room. Similarly, when practical, reliance on ope rator manual actions should be lavoided and reliance on localized electrical raceway fire barrier systems should be minimized.

llUnless specifically noted otherwise, the guidance in this regulatory guide is applicable to lthe FPP for new reactor plants. DG-1145, "Combined License Applications for Nuclear Power lPlants (LWR Edition)," provides guidance regarding the scope and content of the COL lapplication for new reactors.

l l8.2Enhanced Fire Protection Criteria llNew reactor designs should ensure that safe-shutdown can be achieved assuming that all lequipment in any one fire area will be rendered inoperable by fire and that reentry into the fire larea for repairs and operator actions is not possible. Because of its physical configuration, the lcontrol room is excluded from this approach, provided the design includes an independent lalternative shutdown capability that is physically and electrically independent of the control lroom. The control room should be evaluated to en sure that the effects of fire do not adversely laffect the ability to achieve and maintain safe shutdown.

New reactors should provide fire lprotection for redundant shutdown systems in the reactor containment building that will ensure,lto the extent practicable, that one shutdown division will be free of fire damage. Additionally,lnew reactor designs should ensure that smoke, hot gases, or the fire suppressant will not migrate linto other fire areas to the extent that they could adversely affect safe-shutdown capabilities,lincluding operator actions.

l l

DG-1170, Page 172 8.3Passive Plant Safe-Shutdown Condition llAs discussed in SECY-94-084, the definiti ons of safe shutdown contained in the lCommission's regulations and guidelines do not address the inherent limitations of passive RHR lsystems.l lIn GDC 34, "Residual Heat Removal," of Appendix A to 10 CFR Part 50, the NRC lregulations require that the design include an RHR system to remove residual heat from the lreactor core so that specified acceptable fuel design limits are not exceeded. GDC 34 further lrequires suitable redundancy of the components and features of the RHR system to ensure that lthe system safety functions can be accomplished, assuming a loss of offsite power or onsite lpower, coincident with a single failure.

l lPassive reactor designs are limited by the inherent ability of the pa ssive heat removal lprocesses and cannot reduce the temperature of the reactor coolant system below the boiling lpoint of water for heat transfer to occur between the reactor coolant and the heat sink. The plant ldesigns include cooling systems to bring the reactor to cold shutdown or refueling condition; lhowever, these systems are not safety grade. These nonsafety-grade systems (i.e., makeup water lto the heat sink and cool-down capability) are necessary to maintain long-term cooling (i.e.,lbeyond 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) and must be capable of accomplishing their respective functions without ldamage to the fuel as demonstrated by design and analysis.

llBased on the discussion and recommendations of SECY-94-084, the passive decay heat lremoval systems must be capable of achieving and maintaining 215.6 C (420 F) or below for lnon-LOCA events. This safe-shutdown condition is predicated on demonstration of acceptable lpassive safety system performance.

l l8.4Applicable Industry Codes and Standards llIn general, the FPP for new light-water reactor designs should comply with the provisions lspecified in NFPA 804, "Standard for Fire Protection for Advanced Light-Water Reactor Electric lGenerating Plants," as they relate to the protection of post-fire safe-shutdown capability and the lmitigation of a radiological release resulting from a fire. However, the NRC has not formally lendorsed NFPA 804 and some of the guidance in the NFPA standard conflicts with regulatory lrequirements. When conflicts occur, the applicable regulatory requirements and guidance,lincluding the guidance in this regulatory guide, will govern. The standards of record related to lthe design and installation of fire protection systems and features required to satisfy NRC lrequirements in all new reactor designs are those NFPA codes and standards in effect 180 days lbefore the submittal of the application under 10 CFR Part 50 or 10 CFR Part 52.

ll8.5Other New Reactor Designs llFire protection programs for proposed new non-light-water reactor designs should meet lthe overall fire protection objectives and guidance provided in the applicable regulations and this lregulatory guide as they relate to safe shutdown and radiological release, as well as the specific lfire protection requirements, as applicable. Fire hazards shoul d be identified, evaluated, and an l

DG-1170, Page 173 appropriate leve l of protection provided to meet these objectives. Design reviews and testing lprograms should confirm the safe-shutdown capability. SSCs important to safe shutdown should lbe protected in accordance with the enhanced cr iteria described above for light-water reactors.

ll8.6Fire Protection Program Implementation Schedule llSECY-05-0197, "Review of Operational Programs in a Combined License Application land Generic Emergency Planning Inspections, Tests, Analyses, and Acceptance Criteria,"

lidentifies fire protection as an "operation program." However, only those elements of the FPP lthat will not be implemented fully until the comp letion of the plant shoul d be addressed as an loperational program. This may include, but is not be limited to, the fire brigade, combustible and lignition source control program, procedures and prefire plans, and portable extinguishing lequipment. The COL application should identify the operational program aspects of the FPP and lthe implementation schedule for each. In lieu of the implementati on schedule, the applicant may lpropose inspections, tests, analyses, and acceptance criteria for these aspects of the program.

ll8.7Fire Protection for Nonpower Operation llNRC regulations and guidance do not specifically address fire protection during lnonpower modes of plant operation (e.g., during shutdown for maintenance and/or refueling) lexcept for existing plants that adopt an NFPA 805 FPP. However, the requirements for fire lprevention in Regulatory Position 7.5 is based on CMEB 9.5-1 and GL 93-06.

lD. IMPLEMENTATION2 of this guide apply to all modes of plant operation, including shutdown. License applications lfor new reactors should also address any special provisions to ensure that, in the event of a fire lduring a nonpower mode of operation, the plan t can be maintained in safe shutdown.

ll DG-1170, Page 174 9.Fire Protection for License Renewal llLicensees may apply for a license renewal to permit continued plant operation beyond the loriginal operating license peri od of operation, in accordance with the provisions of 10 CFR Part l54. The fire protection licensing and design basis under license re newal should not differ lsignificantly from that in effect before renewal with the exception that fire protection SSCs must lbe included in an aging management program as appropriate.

llAs stated in 10 CFR Part 54.21, "Contents of Application-Technical Information," those lcomponents with intended functions that are identified within the sc ope of license renewal, those lcomponents which are passive (i.e., they do not perform their functions with moving parts) and llong-lived (i.e., they are not subject to replacement based on qualified life or routine lreplacement) are subject to an aging management review (AMR). Examples of fire protection lcomponents that are passive and long-lived and, therefore, would be subject to an AMR, include lfire barrier assemblies (e.g., ceilings, damper housing, doors, fl oors, penetration seals walls),lsprinkler heads, fire suppression system piping and valves casings , and fire protection tanks and lpump casings, and fire hydrant casings. Activ e components are defined as components which lperform an intended function as described in 10 CFR 54.4, "Scope," with moving parts or with a lchange in configuration or properties; as such, they are excluded from the AMR. For example,lsmoke/heat detectors are c onsidered active components.

llCertain passive and long-liv ed components are considered consumables and, therefore,lare not subject to an AMR. System filters, fire extinguishers, fire hoses, and air packs (within the lscope of license renewal) may be excluded, on a plant-sp ecific basis, from an AMR under 10 lCFR 54.21(a)(1)(ii). These components are consider ed within the scope of license renewal and lare typically replaced based on specific performance and condition monitoring activities that lclearly establish a routine re placement practice based on a qualif ied life of the component. An lAMR may exclude these components based on specific performance a nd condition monitoring lactivities provided that the applicant (1) identifies and lists in the license renewal application leach component type subject to such replacement, and (2) identif ies the applicable monitoring land replacement programs that conform to appropriate standards (e.g., NFPA standards).

llFor all components identified w ithin the scope of license re newal and subject to an AMR,lprograms must be in place to maintain each co mponent's intended function throughout the period lof extended operation. For example, the intended function of fire suppression piping or the fire lpump casing is to provide a pressure boundary. Programs to manage the aging effects of the lpressure boundary can be existing plant programs, modified (or enhanced) programs, or new lprograms specifically created to address aging c oncerns. The development of modified or newly lcreated programs is dependent upon (1) the aging effect that needs to be managed, and (2) the lability of the current program to manage the aging effect throughout the period of extended loperation.

l lPlants that have installed Halon 1301 extinguishing systems that will be credited during lthe extended life of the plant should have a plan for continued access to an adequate supply of lreplacement Halon or a plan to replace the system.

l l

DG-1170, Page 175 lD. IMPLEMENTATION llThe purpose of this section is to provide information to applicants and licensees regardingl the NRC staff's plans for using this draft regulatory guide. No backfitting is intended orl approved in connection with the issuance of this guide.

lExcept inits issuance.

llThe NRC has issued this draft guide to encourage public participation in its development.

lExcept in those cases in which aan applicant or licensee proposes or has previously establishedl an acceptable alternative method for complying with specified portions of the NRC'slregulations, the methods to be described in thisthe active guide will will reflect public comments land will be used in the evaluation of licenseein evaluating compliance with the requirements ofl 10 CFR 50.48. This guide will also be usedCFR 50.48 for license applications, license lamendment applications, and exemption requests. The staff will also use this guide to evaluatelsubmittals from operating reactor licensees who initiate propose d changes to their fire protection lprograms that are initiated by the licenseeFPPs if there is a clear nexus between the proposedlchange and this guidance.GLOSSARYll lREGULATORY ANALYSIS llThe NRC published a regulatory analysis with the draft of this guide when it was loriginally issued for public comment as Draft Regulatory Guide DG-1097, in June 2000. No lchanges were necessary, so the NRC staff has not prepared a separate regulatory analysis for this ldraft revision of Regulatory Guide 1.189. A copy of the regulatory analysis is available for linspection or copying for a fee in the NRC's Public Document Room at 11555 Rockville Pike,lRockville, Maryland.

l l

lBACKFIT ANALYSIS lllText Moved Here: 12 lThis draft regulatory guide does not require a backfit analysis as described in 10 CFRl 50.109(c) because it does not impose a new or am ended provision in th e NRC's rules or aregulatory staff position interpreting the Commission rules that is either new or different from a previous applicable staff position. In addition, this draft regulatory guide does not require thel modification or addition to systems, structures, components, SSCs or design of a facility

, or thelprocedures or organization required to design, construct, or operate a facility. Rather, a licenseelcan select a preferred method for achieving compliance with a license or the rules or the orders of DG-1170, Page 176 the Commission as described in 10 CFR 50.109(a)(7). This draft regulatory guide provides an l opportunity to use the standa rds described herein if that is a licensee's preferred method.

thellicensee chooses to do so.

lEnd Of Moved Text ll l

lGLOSSARYllAdministrative Controls-Policies, procedures, and other elements that relate to the FPP.

lAdministrative controls include but are not limited to inspection, testing, and maintenance of fire lprotection systems and features; compensatory measures for fire protection impairments; review lof the impact of plant modifications on the FPP; fire prevention activities; fire protection lstaffing; control of combustible/flammable materials; and control of ignition sources.

llAlternative Shutdown - TheShutdown-The capability to safely shut down the reactor in thelevent of a fire using existing systems that have beenthat is required when it is not feasible to lprovide the required protection fo r redundant safe-shutdown trains in one or more fire areas or lwhere fire suppression activities, including in advertent operation or rupture of a water lsuppression system, could prevent safe shutdown. Appendix R to 10 CFR Part 50 allows an lexisting plant system to be rerouted, relocated, or modified

.lApproved - Tested (at the time the need for an alternative means of shutdown is identified but lnot during or after the fire) such that it can pe rform the required safe-shutdown function that the lfire- or water-damaged redundant system would normally perform. (See also DedicatedlShutdown and Success Path

.)llAny-and-All

-The scope of potential fire-i nduced circuit failures or s purious operations in a fire larea. The post-fire safe-shutdown circuit analysis should address any-and-all possible failures land spurious operations caused by the failures, including combinations of multiple lfailures/operations, that could prevent safe shutdown. (See RIS 2005-30 for a discussion of the lscope of spurious operation analysis.)

l lApproved-Tested and accepted for a specific purpose or application by a recognized testing llaboratory

.Associated Circuits

- Circuits that do not meet the se paration requirements for safe shutdownsystems and components and are associated with safe shutdown systems and components bycommon power supply, common enclosure, or th e potential to cause spurious operations thatcould prevent or adversely affect the capability to safely shut down the reactor as a result of fire-induced failures (hot shorts, open circuits, and short to ground).Automatic - Self-acting or reviewed and specifically approved by the NRC in accordance with lthe appropriate regulatory process (e.g., 10 CFR 50.12).

ll DG-1170, Page 177Automatic-Self-acting, operating by its own mechanism when actuated by some monitoredlparameter such as a change in current, pressu re, temperature, or mechanical configuration.Combustible Material - AnyMaterial-Any material that will burn or sustain the combustionlprocess when ignited or otherwise exposed to fire conditions.Common Enclosure - An Enclosure-An enclosure (e.g., cable tray, conduit, junction box)l that contains circuits requi red for the operation of safe

-shutdown components and circuits forl non-safe shutdown nonsafe-shutdown components.lCommon Power Supply - A Supply-A power supply that feeds safe

-shutdown circuits andl non-safe shutdown nonsafe-shutdown circuits.lControl Room Complex - TheComplex-The zone served by the control room emergencylventilation system.Dedicated Shutdown - The abilityShutdown-The capability to shut down the reactor andl maintain shutdown conditions using structures, systems, or co mponents dedicated to the purposeof accomplishingby adding new SSCs to an existing plant that are dedicated to performing post-lfire safe -shutdown functions. Like alternative shutdown, plant operators use dedicated lshutdown when it is not feasible to provide the required protection fo r redundant safe-shutdown ltrains in one or more fire areas. (See also Alternative Shutdown and Success Path

.)ll lText Moved Here: 11 lElectrical Raceway Fire Barrier

- Non-load-bearing System-Non-load-bearing partitionltype envelope system installe d around electrical components and cabling that are rated by test laboratories in hours of fire resistance and are used to maintain safe

-shutdown functions free oflfire damage.

End Of Moved Text lEmergency Control Station - Location

-A location/device outside the main control rooml where actions are taken by operations personnel to can manipulate plant systems and controls tolachieve safe shutdown of the reactor. Emergency control stations can include control panels and lindividual devices such as valves, switches, and circuit breakers. III.G.1 protection for re dundantlsafe-shutdown systems may not be claimed for redundant systems in a III.G.2 area by cred itinglan operator manual action at an emergency control station.

Unless alternative or dedicated lshutdown capability is provided, redundant circu its credited for post-fire safe-shutdown and llocated in the same fire area must be protected in accordance with III.G.2 wit hout the use of lemergency control stations of any kind.

lExposure Fire - AFire-A fire in a given area that involves either in situ or transientlcombustibles and is external to any structures, systems, and componentsSSCs important to safety llocated in or adjacent to that same area. The effects of such fire (e.g., smoke smoke , heat, orlignition) can adversely affect those structures, systems, and components SSCs important to safety. l DG-1170, Page 178Thus, a fire involving one success path of safe

-shutdown equipment may constitute an exposure lfire for the redundant success path located in the same area, and a fire involving combustibles other than those in either redundant success path may constitute an exposure fire to both multiplelredundant trains success paths located in the same area.

lFire Area - The Area-The portion of a building or plant that is separated from other areas by lrated fire barriers adequate for the fire hazard.Fire Barrier - ComponentsBarrier-Components of construction (wa lls, floors, and their lsupports), including beams, joists, columns, pene tration seals or closures, fire doors, and fire dampers , that are rated by approving laborat ories in hours of resistance to fire

, that are used to lprevent the spread of fire.Fire Brigade - A Brigade-A team of on

-site plant personnel that have been is qualified and lequipped to perform manual fire suppression activities.Fire Hazard - The existence of conditionsHazards-Conditions that involve the necessary lelements to initiate and support combustion, including in situ or transient combustible materials,ignition sources (e.g., heat, sparks, open flames), and an oxygen environment.Fire Hazard Analysis - An Analysis-An analysis used to evaluate the capability of a nuclear lpower plant to perform safe

-shutdown functions and minimize radioactive releases to the lenvironment in the event of a fire. The analysis includes the following features:

la.I identification of fixed and transient fire hazards

.llb.I i dentification and evaluation of fire prevention and protection measures relative to the lidentified hazards

.lc.E evaluation of the impact of fire in any plant area on the ability to safely shut down the lreactor and maintain shutdown conditions, as well as to minimize and control the release lof radioactive material llFire Protection Feature-Administrative controls, emergency lighting, fire barriers, fire ldetection and suppression systems, fire brigade personnel, and ot her features provided for fire lprotection purposes

.llFire Protection Program - TheProgram-The integrated effort involving components,lprocedures, analyses, and personnel utilized in defining and carrying out all activities of fire lprotection. It includes system and facility design, fire preven tion, fire detec tion, annunciation, confinement, suppression, administrative controls, fire brigade organization, inspection andmaintenance, training, quality assurance, and testing.

DG-1170, Page 179Fire Protection System-Fire detection, notification, and suppression systems designed,linstalled, and maintained in accordance with the applicable nationally recognized codes and lstandards endorsed by the NRC.

l lFire Resistance

- -The ability of an element of building construction, component, or structurelto fulfill, for a stated period of time, the required load-bearing functions, integrity, thermal insulation, or other expected duty specified in a standard fire-resistancefire resistance test.lFire -Resistance Rating - TheRating-The time that materials or assemblies have withstood alfire exposure as established in accordance with the test procedures of NFPA 251 , "Standard lMethods of Tests of Fire Endurance of Building Construction and Materials

."lFire Retardant Material - Means material-Material that has been coated or treated withlchemicals, paints, or other materials that are designed to reduce the combustibility of the treated material.Fire Risk - Refers to the Risk-The combination of the probability and consequences of algiven fire event occurring and the estimated conseque nces of the event should it occur.Fire Stop - Abased on consideration of (1) What can go wrong? (2) How likely is it? and (3) lWhat are the consequences if it occurs?

l lFire Stop-A feature of construction that prevents fire propagation along the length of cables orl prevents fire from spreading of fire to nearby combustibles within a given fire area or fire zone.lFire Suppression - ControlSuppression

-Control and extinguishing of fires (firefighting). l Manual fire suppression is the use of hoses, portable extinguishers, or manually actuated fixedsystems by plant personnel. Automatic fire suppression is the use of automatically actuated fixedsystems such as water, Halon, or carbon dioxide CO 2 systems.lFire Watch - Individuals Watch-Individuals responsible for providing additional (e.g.,lduring hot work) or compensatory (e.g., for for system impairments) coverage of plant activitieslor areas for the purposes of detecting fires or for identifying activities and conditions that presenta potential fire hazard. The individuals should be trained in identifying conditions or activitiesthat present potential fire hazards, as well as the use of fire extinguishers and the proper fire notification procedures.Fire Zones - SubdivisionsZones-Subdivisions of fire areas.lFree of Fire Damage - The structure, system, or componentDamage-The SSCs (including lelectrical circuits) under consideration is are capable of performing its intendedtheir required lpost-fire safe-shutdown function s during and after the postulated fi re, as needed, without repair.

lThe crediting of operator actions to restore damaged SSCs or to mitigate the consequences of the lfire-induced damage should be in accordance with Regulatory Position 5.3.3 of this guide.

l DG-1170, Page 180Hazardous Material - AMaterial-A substance that, upon release, has the potential oflcausingto cause harm to people, property, or the environment.

lHigh -Impedance Fault - AFault-A circuit fault condition resulting in a short

-to -ground, or lconductor -to -conductor hot short, where re sidual resistance in the fa ulted connection maintains lthe fault current level below the component's circuit breaker long-term setpoint.Hot Short - IndividualShort-Individual conductors of the same or different cables come in lcontact with each other and may result in an impressed voltage or current on the circuit being lanalyzed.Hot Work - Activities Work-Activities that involve the use of heat, sparks, or open flame lsuch as cutting, welding, and grinding.lImpairment

- TheImpairment

-The degradation of a fire protection system or feature that ladversely affects the ability of the system or feature to perform its intended function.

lImportant to Safety - NuclearSafety-Nuclear power plant structures, systems, and lcomponents SSCs "important to safety" are those requi red to provide reasonable assurance that lthe facility can be operated without undue risk to the health and safety of the public.

of the public.

lIn Appendix R to Part 50, "important to safety" and "safety related" apply to all safety functions.

lInterrupting Device - A Device-A breaker, fuse, or similar device installed in an electrical lcircuit to isolate the circuit (or a portion of the circuit) from the remainder of the system in the levent of an overcurrent or fault downstream of the interrupting device.

lIn situ Combustibles - CombustibleCombustibles

-Combustible materials that constitute lpart of the constr uction, fabrication, or installation of plant structures, systems, and lcomponents SSCs and as such are fixed in place.

lIsolation Device - A Device-A device in a circuit that prevents malfunctions in one section of la circuit from causing unacceptable influences in other sections of the circuit or other circuits.

lListed - EquipmentListed-Equipment or materials included on a list published by a lrecognized testing laboratory, inspection agency, or other organization concerned with product evaluation that maintains periodi c inspection of production of liste d equipment or materials, andwhose listing states that certain specific equipment or materials meet nationally recognized

standards and have been te sted and found suitable for use in a specified manner.

lMitigate-Performance of an action that stops the progression of or reduces the severity of an lunwanted condition. With respect to nuclear plant fire protection, mitigation generally refers to loperator actions inside or outside the main control room to restore the capability to achieve and lmaintain safe shutdown where a fire has degraded that capability.

l l

DG-1170, Page 181New Reactors-Those reactors that are significantly different in operation from the current lgeneration light-water reactors and provide enhanced margins of safety or utilize simplified,linherent, or other innovative means to accomplish their safety functions.

llNoncombustible Material - Material-(a) Material that, in the form in which it is used andl under conditions anticipated, will not ignite, burn, support com bustion, or release flammable vapors when subjected to fire or heat

, or (b) material having a structural base of noncombustiblelmaterial, with a surfacing not over 1/8 inch 3 mm (c inch) thick that has a flame spread ratinglnot higher than 50 when measured in accordance with ASTM E

--84, "Standard"Standard TestlMethod for Surface Burning Characteristics of Building Materials.

""llOne-at-a-Time

-An approach to post-fire safe-shutdown circuit analysis that assumes only one lspurious operation can occur in any single fire or that multiple spurious operations will occur lonly one-at-a-time, permitting any required mitigation to achieve and maintain safe shutdown to lbe performed on an individual basis without c onsideration of possible simultaneous spurious loperations. This approach does not comply w ith fire protection regulatory requirements.

lOpen Circuit - ACircuit-A failure condition that results when a circuit (either a cable orl individual conductor within a cable) loses electrical continuity.Operator Action

-A normal action taken by an operator inside the main control room to lachieve and maintain post-fire safe-shutdown, not including repairs.

llOperator Manual Action-Actions performed by operators to manipulate components and lequipment from outside the main control room to achieve and maintain post-fire hot shutdown,lnot including "repairs." Operator manual actions comprise an integrated set of actions needed to lensure that hot shutdown can be accomplished for a fire in a specific plant area. Manual loperation of valves, switches, and circuit breakers is allowed to operate equipment and isolate lsystems in accordance with Regulatory Pos ition 5.3.3 and is not considered a repair.

llPost-Fire Safe-Shutdown Analysis

-A process or method of identifying and evaluating the lcapability of SSCs necessary to accomplish and ma intain safe-shutdown conditions in the event lof a fire.

l lPost-Fire Safe-Shutdown Circuits-Electrical circuits whose fire-induced failure (e.g., short lcircuit, short to ground) could pr event safe shutdown, either directly (e.g., loss of power to a lsafe-shutdown pump) or indirectly (e.g., spurious opening of a flow diversion path because of lone or more control circuit hot shorts; failure of a motor-operated valve to perform an active lpost-fire safe-shutdown function caused by fire-induced failure of a valve protective circuit).

llPost-Fire Safe-Shutdown System/Equipment-Systems and equipment that perform functions lneeded to achieve and maintain safe shutdown during and following a fire (regardless of whether lthe system or equipment is part of the success path for safe shutdown). This includes systems land equipment of which fire-induced spuri ous operation could pr event safe shutdown.

ll DG-1170, Page 182Pre-Fire Plans - DocumentationPlans-Documentation that describes the facility layout,laccess, contents, construction, hazards, hazardous materials, types a nd locations of fire protectionsystems, and other information important to the formulation and planning of emergency fire lresponse.Raceway - AnRaceway-An enclosed channel of metal or nonmetallic materials designed lexpressly for holding wires, cables, or busbars, with additional functions as permitted by code.

Raceways include, but are not limited to, rigid metal conduit, rigi d nonmetallic conduit, intermediate metal conduit, liquid-tight flexible conduit, flexible metallic tubing, flexible metal conduit, electrical nonmetallic tubing, electrical metallic tubing, underfloor raceways, cellularconcrete floor raceways, cellular metal floor raceways, surface raceways, wireways, and busways.Text Was Moved From Here: 11Radiant Energy (Heat) Shield - AShield-A noncombustible or fire

-resistive barrier linstalled to provide se paration protection of re dundant cables, equipment, and associated non

-safety circuits within containment

. or in the main control room.

llRedundant Train/System-One of two or more similar trains of equivalent capacity in the lsame system powered by separate electrical divisi ons or one of two or more separate systems that leach perform the same post-fire safe-shutdown function as its design function. With respect to lfire protection regulatory requirements and guidance, a redundant train or system is distinct from lan alternative or dedicated shutdown train or system. (See also Success Path

.)llRemote Shutdown - TheShutdown-The capability, including necessary instrumentation and lcontrols, to safely shut down the reactor a nd maintain shutdown conditions from outside the main control room. (See GDC 19.)

See GDC 19, "Control Room.")

llRepair-An action that may be credited with achieving and maintaining cold shutdown,lincluding the replacement of fuses and cabling. Selected equipment replacement is also allowed lif practical. Repairs not permitted include the use of clip leads in control panels (i.e., hard-wired lterminal lugs should be used) and the use of jumper cables other than those fastened with lterminal lugs.

lRestricted Area - Any Area-Any area to which access is controlled by the licensee controlslaccess for purposes of protecting individuals from exposure to radiation and radioactive lmaterials.Safe Shutdown - ForShutdown-For fire events, those plant conditions specified in the plant lT technical S specifications as Hot S hot standby, H h ot S s hutdown, or C c old S s hutdown.l DG-1170, Page 183 Safe -Shutdown Analysis - A Analysis-A process or method of identifying and evaluatinglthe capability of structures, systems, and components SSCs necessary to accomplish and maintainl safe -shutdown conditions in the event of a fire.l Safe -Shutdown System/Safe

-Shutdown Equipment - SystemsEquipment-Systems andlequipment that perform functions needed to achieve and maintain safe shutdown (regardless of whether or not the system or equipment is part of the success path for safe shutdown).Safety-Related Systems and Components - SystemsComponents-Systems and componentslrequired to mitigate the consequences of postulated design

-basis accidents.lSecondary Containment - TheContainment

-The combination of physical boundary andlventilation systems designed to limit the release of radioactive material.lShort Circuit - A failure condition that results when a circuit (either a cable or individualconductor within a cable) comes into electrical contact with another circuit.Circuit-An abnormal connection (including an arc) of relatively low impedance, whether made laccidentally or intentionally, between two points of different potential.

lShort-to-Ground

- A failure condition that results when a circuit (either a cable or individual conductor within a cable) comes in to electrical contact with aShort-to-Ground

-A short circuit lbetween a conductor and a grounded reference point (e.g., grounded conducting device such as a lcable tray, conduit, grounded equipment, or other grounded component.conductor, conduit or other raceway, metal enclosure, shield wrap, or drain wire within a cable).

lSpurious Operation - TheOperation-The undesired operation of equipment resulting from al fire that could affect the capability to achieve and maintain safe shutdown.lStandards (Code) of Record - The Record-The specific editions of the nationally recognized lcodes and standards endorsed by the NRC that constitute the licensing or and design basis for thel plant.Success Path - ThePath-The minimum set of structures, systems (including power,linstrument, and control circuits and instrument-sensing lines), and components necessarythatlmust remain free of fire damage in order to achieve and maintain safe shutdown in the event of alfire.

11All NRC regulations listed herein are available electronically through the Public Electronic Reading Room on theNRC's public Web site, at http://www.nrc.gov/reading-rm/doc-collections/cfr/. Copies are also available for inspectionor copying for a fee from the NRC's Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDR's mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209;fax (301) 415-3548; email PDR@nrc.gov

.DG-1170, Page 184 Success path is synonymous with the safe-shutdown "train free of fire damage" and includes lelectrical circuits whose fire-induced failure could prevent safe shutdown. In the context of lAppendix R,Section III.G, re dundant train (Section III.G.2) and alternative/dedicated system l(Section III.G.3) are both success paths and this definition is applicable.

lTemporary Structures - BuildingsStructures-Buildings , tents, shelters, platforms, trailers,lor other structures that are erected for the purpose of supporting to support plant operations and lmaintenance

, but are not permanent site facilities.Turnout Gear - PersonnelGear-Personnel protective clothing for fire fightingfirefighting lsuch as coats, pants, boots, helmets, gloves, and self-contained breathing apparatus(SCBA)apparatuses

.lTransient Combustibles - CombustibleCombustibles

-Combustible materials that are not lfixed in place or not an integral part of an operating system or component.

llREFERENCES llU.S. Nuclear Regulatory Commission Documents 1 Regulations llRegulations (from Title 10, "Energy," of the Code of Federal Regulations

)(11)ll10 CFR 1.43, "Office of Nuclear Reactor Regulation."

ll10 CFR Part 20, "Standards for Protection Against Radiation" Radiation."

ll10 CFR Part 50 , "Domestic Licensing of Production and Utilization Facilities"Facilities."

l10 CFR 50.

12, "Specific Exemptions."

l10 CFR 50.

48 , "Fire Protection."

l10 CFR 50.59, "Changes, Tests and Experiments."

l10 CFR 50.72

, "Immediate Notification Requirements for Operating Nuclear lPower Reactors."10 CFR 50.73

, "Licensee Event Report System."

l DG-1170, Page 185GDC 3, "Fire Protection," of Appendix A10 CFR 50.82, "License lTermination."

l10 CFR 50.90, "Application for Amendment of License or Construction Permit."

l10 CFR 50.92, "Issuance of Amendment."

lAppendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50

."lGDC 3, "Fire Protection."

lGDC 5 ,"Sharing "Sharing of Structures, Systems, and Components," of Appendix lA to 10 CFR Part 50

."lGDC 19 , "Control"Control Room," of Appendix A to 10 CFR Part 50

."lGDC 23 ,"Protection "Protection System Failure Modes," of Appendix A to l10 CFR Part 50

."lGDC 56 , "Primary Containment Isolation

,." of Appendix A to 10 CFR Part l50.Appendix R , "Fire"Fire Protection Program for Nuclear Power FacilitieslOperating Prior to January 1, 1979," to 10 CFR Part 50.10 CFR Part 72,January 1, 1979."

ll10 CFR Part 52, "Early Site Permits; Standard Design Certifications; and Combined Licenses lfor Nuclear Power Plants."

l l10 CFR Part 54 , "Requirements for Renewal of Operating Licenses for Nuclear Power Plants."

ll10 CFR Part 72 , "Licensing Requirements for the Independent Storage of Spent Nuclear Fuell and High--Level Radioactive Waste."l 12All regulatory guides listed herein were published by the U.S. Nuclear Regulatory Commission. Where an ADAMSaccession number is identified, the specified regulatory guide is available electronically through the NRC's Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html. All other regulatory guides are available electronically through the Public Electronic Reading Room on the NRC'spublic Web site, at http://www.nrc.gov/reading-rm/doc-collections/reg-guides/. Single copies of regulatory guides mayalso be obtained free of charge by writing the Reproduction and Distribution Services Section, ADM, USNRC, Washington, DC 20555-0001, or by fax to (301) 415-2289, or by email to DISTRIBUTION@nrc.gov. Active guidesmay also be purchased from the National Technical Information Service (NTIS) on a standing order basis. Details on this service may be obtained by contacting NTIS at 5285 Port Royal Road, Springfield, Virginia 22161, online at http://www.ntis.gov, or by telephone at (703) 487-4650. Copies are also available for inspection or copying for a feefrom the NRC's Public Document Room (PDR), which is located at 11555 Rockville Pike, Rockville, Maryland; the PDR's mailing address is USNRC PDR, Washington, DC 20555-0001. The PDR can also be reached by tele phoneat (301) 415-4737 or (800) 397-4205, by fax at (301) 415-3548, and by email to PDR@nrc.gov

.DG-1170, Page 186Regulatory Guides l(12)llRegulatory Guide 1.6, "Independence Between Redundant Standby (Onsite) Power Sources and lBetween Their Distribution Systems," March 1971. (ADAMS Accession Number lML003739924) lRegulatory Guide 1.32, "Criteria for Safety-Related Electric Power Systems for Nuclear Power Plants," Revision 2 3 , February 1977 March 2004. (ADAMS Accession Number ML040680488) lRegulatory Guide 1.39, "Housekeeping Requirements for Water-Cooled Nuclear Power Plants,"

Revision 2, September 1977. (ADAMS Accession Number ML003740067) lRegulatory Guide 1.52, "Design, Testing, and Maintenance Criteria for Post-accidentInspection,land Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-lFeature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-CooledNuclear Power Plants," Revision 2"Revision 3 , March 1978.June 2001. (ADAMS Accession lNumber ML011710176) lRegulatory Guide 1.75, "Physical Indepe ndence of Electric al Systems," Revision 2, September 1978.3, February 2005. (ADAMS Accession Number ML043630448) llRegulatory Guide 1.91, "Evaluations of Explosions Post ulated To Occur on Transportation lRoutes Near Nuclear Power Plants," Revision 1, February 1978. (ADAMS Accession Number lML003740286) lRegulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors,"

lRevision 3, August 1992.

l 1 See the inside front cover of this guide for information on obtaining copies of NRC documents, printed copies or online electronic versions.5, June 2005. (ADAMS Accession Number lML050730286) l l

13All NUREG-series reports listed herein were published by the U.S. Nuclear Regulatory Commission. Most are availableelectronically through the Public Electronic Reading Room on the NRC's public Web site, at http://www.nrc.gov/reading-rm/doc-collections/nuregs/. Copies are also available for inspection or copying for a fee from the NRC'sPublic Document Room at 11555 Rockville Pike, Rockville, MD; the PDR's mailing address is USNRC PDR,Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209; fax (301) 415-3548; email PDR@nrc.gov. In addition, copies are available at current rates from the U.S. Government Printing Office, P.O. Box 37082, Washington, DC 20402-9328, telephone (202) 512-1800; or from the National Technical Information Service (NTIS),

5285 Port Royal Road, Springfield, VA 22161, http://www.ntis.gov, telephone (703) 487-4650.DG-1170, Page 187Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," July 1998.

Revision 1, November 2002. (ADAMS Accession Number ML023240437) llRegulatory Guide 1.188, "Standard Format and Content fo r Applications To Renew Nuclear lPower Plant Operating Licenses," Revision 1, September 2005. (ADAMS Accession Number lML051920430)?]

l lRegulatory Guide 1.191, "Fire Protection Program for Nuclear Power Plants During lDecommissioning and Permanent Shutdown," May 2001. (ADAMS Accession Number lML011500010) l lRegulatory Guide 1.205, "Risk-Informed, Performance-Based Fire Protection for Existing lLight-Water Nuclear Power Plants," May 2006. (ADAMS Accession Number ML061100174) llNUREG-Series Reports l(13)lNUREG-0050 , "Recommendations Related to Browns Ferry Fire,"

NUREG-0050, Report bylSpecial Review Group, February 1976.NUREG-0654 , "Criteria for Preparation and Evaluation of Radiological Emergency ResponselPlans and Preparedness in Support of Nuclear Power Plants," Revision 1, November 1980.l (Available at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr0654/

.)lNUREG-0800 , "Standard Review Plan for the Review of Safety Analysis Reports for NuclearlPower Plants , (LWR Edition

)," Section 9.5.1, "Fire Protection System," various dates andl revisions.NUREG-1022, D.P. Allison et al.

(Available at lhttp://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr0800/

.l DG-1170, Page 188NUREG-1022, "Event Reporting Guidelines:

10 CFR 50.72 and 50.73," Revision 1, January l1998.NUREG-1552, C.S. Bajwa and K. West2, D.P. Allison et al., (Available at lhttp://www.nrc.gov/reading-rm/doc-collections/ nuregs/staff/sr1022/r2/index.html

.)lNUREG-1552, "Fire Barrier Penetration Seals in Nuclear Power Plants," July 1996.

lSupplement 1 to NUREG-1552, C.S. Bajwa and K. West, July 1996. (Available at lhttp://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1552/

.)lNUREG-1552, Supplement 1, "Fire Barrier Penetration Seals in Nuclear Power Plants," Draft lfor Comment, June 1998.Report for Comment, C.S. Bajwa and K. West, June 1998. (Available at lhttp://www.nrc.gov/reading-rm/ doc-collections/nuregs/staff/sr1552/s1/sr1552s1.pdf

.)lNUREG-1800 , "Standard Review Plan for Review of License Renewal Applications for Nuclear lPower Plants," Revision 1, September 2005. (Available at lhttp://www.nrc.gov/reading-rm/doc-collections/ nuregs/staff/sr1800/

.)lNUREG-1801, "Generic Aging Lessons Learned (GALL) Report," Volumes 1 and 2, September l2005. (Available at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1801/.

)lNUREG-1805, "Fire Dynamics Tools (FDTs) Quantitative Fire Hazard Analysis Methods lfor the U.S. Nuclear Regulatory Commission Fire Protection Inspection Program," December l2004. (Available at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1805/

.)lNUREG-1824, "Verification and Validation of Selected Fire Models for Nuclear Power Plant lApplications," Draft for Comment January 2006. (Available at http://www.nrc.gov/reading-rm/

ldoc-collections/nuregs/staff/sr1824/

.)lNUREG-1852, "Demonstrating the Feasibility and Reliability of Operator Manual Actions lin Response to Fire," Draft Report for Comment, September 2006.

lNUREG/CR-6776, "Cable Insulation Resistance Measurements Made During Cable Fire Tests,"

lJune 2002. (Available at lhttp://www.nrc.gov/reading-rm/doc-c ollections/nureg s/contract/cr6776/

.)lNUREG/CR-6850, "EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities,"

lSeptember 2005. (Available at lhttp://www.nrc.gov/reading-rm/doc-c ollections/nureg s/contract/cr6850/

.)l 14Generic Letter 86-10, "Implementation of Fire Protection Requirements," USNRC, April 24, 1986.eAll Commission lpapers (SECYs) listed herein were published by the U.S. Nuclear Regulatory Commission. Where an ADAMS accession lnumber is identified, the specified paper is available electronically through the NRC's Agencywide Documents Access and lManagement System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html. All other listed Commission papers are lavailable electronically through the Public Electronic Reading Room on the NRC's public Web site,lat http://www.nrc.gov/reading-rm/doc-collections/commission/secys/. Copies are also available for inspection lor copying for a fee from the NRC's Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDR's lmailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209; lfax (301) 415-3548; email PDR@nrc.gov

.lDG-1170, Page 189NUREG/CR-6866, "Technical Basis for Regulatory Guidance on Lightning Protection in lNuclear Power Plants," January 2006. (Available at lhttp://www.nrc.gov/reading-rm/doc-collections/nuregs/

contract/cr6866/

.)llBranch Technical Positions lAPCSB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants," May 1, 1976.Appendix A to APCSB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants,Docketed Prior to July 1, 1976," February 24, 1977.ASB 9.5-l, "Guidelines for Fire Protection for Nuclear Power Plants

," Revision 1, March 1979.CMEB 9.5-1 (Formerly ASB 9.5-1) llSPLB 9.5-1, "Guidelines for Fire Protection fo r Nuclear Power Plants," Revision 2, July 1981.

lGeneric LettersGL 77-02, 4, October 2003. (Available at lhttp://adamswebsearch2.nrc.gov/idmws/doccontent.dll?library=PU_ADAMS l^PBNTAD01&ID=033090136:3

).llAPCSB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants," May 1, 1976.

llAPCSB 9.5-1, Appendix A, "Guidelines for Fire Protection for Nuclear Power Plants, Docketed lPrior to July 1, 1976," February 24, 1977.

l lASB 9.5-l, "Guidelines for Fire Protection for Nu clear Power Plants," Revision 1, March 1979.

llCommission Papers (SECYs)

(14)llSECY-90-016, "Evolutionary Light-Water Reactor (LWR) Certification Issues and Their lRelationship to Current Regulatory Requirements," January 12, 1990. (ADAMS Accession lNumber ML003707849) l l

15All generic letters (GLs) listed herein were published by the U.S. Nuclear Regulatory Commission and are availableelectronically through the Public Electronic Reading Room on the NRC's public Web site, at http://www.nrc.gov/reading-rm/doc-collections/gen-comm/gen-letters/. Copies are also available for inspectionor copying for a fee from the NRC's Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDR's mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209;fax (301) 415-3548; email PDR@nrc.gov

.DG-1170, Page 190 SECY-93-087, "Policy, Technical, and Licensing Issues Pertaining to Evolutionary and lAdvanced Light-Water Reactor (ALWR) Designs," April 2, 1993. (ADAMS Accession Number lML003707849) l lSECY-94-084, "Policy and Technical Issues Associated with the Regulatory Treatment of Non-lSafety Systems in Passive Plant Designs," March 28, 1994. (ADAMS Accession Number lML003708068) l lSECY-98-058, "Development of a Risk-Informed, Performance-Based Regulation for Fire lProtection at Nuclear Power Plan ts," March 26, 1998. (Available at lhttp://www.nrc.gov/reading-rm/doc-collections/

lcommission/secys/1998/secy1998-058/1998-058scy.html.

)l lSECY-05-0197, "Review of Operational Programs in a Combined License Application and lGeneric Emergency Planning Inspections, Tests, Analyses, and Acceptance Criteria," October 28,l2005. (Available at http://www.nrc.gov/reading-rm/doc-collections/commission/secys/2001/

lsecy2001-0197/2001-0197scy.pdf

.)l lGeneric Letters (15)llGL 77-02 , "Nuclear Plant Fire Protection Functi onal Responsibilities, Ad ministrative Controls land Quality Assurance," Generic Letter 77-02, August 29, 1977.

lGL 81-12, "Fire Protection Rule (45 FR 76602, November 19, 1980)," February 20, 1981, and l Clarification Letter, March 1982.

lGL 82-21, "Technical Specifications for Fire Protection Audits," October 6, 1982.

lGL 83-33 , "NRC Positions on Certain Requirements of Appendix R to 10 CFR Part 50,"lOctober 19, 1983 1983. lGL 85-01, "Fire Protection Policy Steering Committee Report," January 9, 1985.

lGL 86-10 , "Implementation of Fire Protection Requirements,"April" April 24, 1986.

lGL 86-10, Supplement 1 to GL 86-10

, "Fire Endurance Test A cceptance Criteria for Fire lBarrier Systems Used To Separate Re dundant Safe

-Shutdown Trains Within the Same Fire lArea," March 25, 1994.

16All information notices (INs) listed herein were published by the U.S. Nuclear Regulatory Commission and areavailable electronically through the Public Electronic Reading Room on the NRC's public Web site, at http://www.nrc.gov/reading-rm/doc-collections/gen-comm/info-notices/. Copies are also available for inspectionor copying for a fee from the NRC's Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDR's mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209;fax (301) 415-3548; email PDR@nrc.gov

.DG-1170, Page 191GL 88-12, "Removal of Fire Protecti on Requirements from Technical Specifications," August 2,l 1988.GL 89-13, Supplement 1 to GL 89-13, "Service Water System Problems Affecting Safety-l Related Equipment," April 4, 1990 1990. lGL 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections onl Resolution of Degraded and Nonconforming Conditions and on Operability,"

Revision 1,lOctober 8, 1997 (Superseded)

. lGL 92-08 , "Thermo-Lag 330-1 Fire Barriers," December 17, 1992.

lGL 93-03, "Verification of Plant Records," October 20, 1995.lGL 93-06, "Research Results on Generic Safety Issue 106, 'Piping and the Use of Highlyl Combustible Gases in V ital Areas,'" October 25, 1993.GL 06-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations," April 10,l2006.l l

lInformation Notices (16)llIN 83-41, "Actuation of Fire Suppression System Causing Inoperability of Safety-RelatedSafety-Related Equipment," June 22, 1983.l IN 83-69, "Improperly Installed Fire Dampers at Nuclear Power Plants," October 21, 1983.

IN 84-09, "Lessons Learned F from NRC Inspections of Fire Protection Safe

-Shutdown Systemsl (10 CFR CFR Part 50, Appendix R)," February 13, 1984.

lIN 86-106, "Feedwater Line Break," December 16, 1986.

IN 88-04, "Inadequate Qualification and Documentation of Fire Barrier Penetration Seals,"February 5, 1988 1988. lIN 88-45, "Problems in Protective Relay and Circuit Breaker Coordination," July 7, 1988.

IN 88-56, "Potential Problems with Silicone Foam Fire Barrier Penetration Seals," August 4, 1988.

DG-1170, Page 192 IN 89-52, "Potential Fire Damper Operational Problems," June 8, 1989.

IN 91-17, "Fire Safety of Temporary Insta llations or Services," March 11, 1991.

IN 91-37, "Compressed Gas Cylinder Missile Hazards," June 10, 1991.

IN 91-77, "Shift Staffing at Nuclear Power Plants," November 26, 1991.

IN 92-28, "Inadequate Fire Suppression System Testing," April 8, 1992.

IN 95-36, "Potential Problems with Post-Fire Emergency Lighting," August 29, 1995.

IN 95-48, "Results of Shift Staffing Study," October 10, 1995.

IN 97-48, "Inadequate or Inappropriate Interim Fire Protection Compensatory Measures," July 9, 1997.July 9, 1997.

l lIN 99-17, "Problems Associated with Post-Fire Safe-Shutdown Circuit Analyses," June 3, 1999.

llIN 00-12, "Potential Degradation of Firefighter Primary Protective Garm ents," September 21,l2000.llIN 02-24, "Potential Problems with Heat Collectors on Fire Protection Sprinklers," July 19,l2002.l lIN 03-19, "Unanalyzed Condition of Reactor Coolant Pump Seal Leakoff Line During Postulated lFire Scenarios or Station Blackout," October 6, 2003.

llIN 05-03, "Inadequate Design and Installation of Seismic-Gap Fire Barriers," February 10, 2005.

llIN 05-04, "Single-Failure and Fire Vulnerability of Redundant Electrical Safety Buses,"

lFebruary 14, 2005.

l lIN 05-14, "Fire Protection Findings on Loss of Seal Cooling to Westinghouse Reactor Coolant lPumps," June 1, 2005.

l l

17All regulatory issue summaries (RISs) listed herein were published by the U.S. Nuclear Regulatory Commission andare available electronically through the Public Electronic Reading Room on the NRC's public Web site,at http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/. Copies are also available for inspectionor copying for a fee from the NRC's Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDR's mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209;fax (301) 415-3548; and email PDR@nrc.gov

.DG-1170, Page 193Regulatory Issue Summaries (17)llRIS 2004-03,"Risk-Informed Approach for Post-Fire Safe-Shutdown Circuit Inspection,"

lRevision 1, December 29, 2004.

l lRIS 2005-07, "Compensatory Measures to Satisfy the Fire Protection Program Requirements,"

lApril 19, 2005.

l lRIS 2005-30, "Clarification of Post-Fire Safe-Shutdown Circuit Regulatory Requirements,"

lDecember 20, 2005.

l lRIS 2006-10, "Regulatory Expectations with Appendix R Section III.G.2 Operator Manual lActions," June 30, 2006.

l lLetters and Memoranda lDenton Letter, Harold R. Denton, Letter to S. A. Bernsen, Bechtel Power Corporation, (No subject), April 30, 1982.

llEGM 98-02 , "Enforcement Guidance Memorandum-Disposition of Violations of Appendix R,lSections III.G and III.L Regarding Circuit Failures," February 2, 2000. (ADAMS Accession lNumber ML003710123) llHolahan Memo, Gary Holahan, Memo to Dennis Crutchfield,

Subject:

"Request F forlAssistance: Determine Whether Two Hot Shorts in a Multiconductor Cable Associated with aNon-Hi/Low Pressure Interface Should Be Analyzed for Fire Induced Spurious Actuation(Generic Letter 86-10, Section 5.3.1

., Non-Hi/Low'Non-Hi/Low Pressure Interfaces inlUndergroundedUngrounded AC and DC Circuits

') (AITS 205-89)," December 4, 1990. l(ADAMS Accession Number ML062300013) lMattson Memo July 1982, Roger J. Mattson, Memo to Richard H. Vollmer,

Subject:

"Position lStatement on Allowable Repairs for Alterna tive Shutdown and on the Appendix R Requirement lfor Time Required to Achieve Cold Shutdown," July 2, 1982. (ADAMS Accession Number lML050140106) l l

DG-1170, Page 194Mattson Memo March 1982, Roger J. Mattson, Memo to Richard H. Vollmer,

Subject:

l"Position Statement on Allowable Repairs for Alternative Shutdown and on the Appendix R Requirement for Time Required To Achieve Cold Shutdown," July 2 March 22 , 1982. l (ADAMS Accession Number ML050140137) lMattson Memo 1983, RRoger J. Mattson, Memo to DDarrel G. Eisenhut,

Subject:

"Task lInterface Agreement #83-53 'Physical Independence of Electrical Systems,' TAC No. 51567,"July 22, 1983.Rubenstein Memo 1982, L.S. Rubenstein, Memo to Roger J. Mattson.

Subject:

"Use of theAutomatic Depressurization System (ADS) and Low Pressure Coolant Injection (LPCI) To MeetAppendix R, Alternate Shutdown Goals," December 3, 1982. Rubenstein Memo 1983, L.S. Rubenstein, Memo to Roger J. Mattson.

Subject:

"Statement ofStaff Position Regarding Source Range Flux, Reactor Coolant Temperature, and SteamGenerator Pressure Indication to Meet Appendix R, Alternate Shutdown Capability," January 7, 1983. (ADAMS Accession Number ML062300010) lStello Letter to Bixel, Victor Stello, Jr., Letter to David Bixel, Consumers Power Company,

Subject:

"Manpower Requirements for Operating Reactors, Docket No. 50-255," June 8, 1978.Vollmer Memo 1983a, R.H. Vollmer, Memo to Darrell G.

Eisenhut,

Subject:

"Oil CollectionSystem Reactor Coolant Pumps, Florida Power and Light Company St. Lucie 2 - Docket No.50-389 From J. Olshinski to D. Eisenhut," April 1, 1983.Vollmer Memo 1983b (ADAMS Accession Number ML031280307) lVollmer Memo

, R.H. Vollmer, Memo to Darrel G. Eisenhut,

Subject:

"Emergency Lighting lRequirements (TIA 83-87; TAC 52308)," December 21, 1983. (ADAMS Accession Number ML062300012) lRichards Letter 2000 , S.A. Richards, Letter to J.M. Kenny, BWR Owners Group, "BWROGAppendix R Fire Protection Committee Position on SRVs and Low

-Pressure Systems Used as lRedundant Shutdown Systems Under Appendix R," December 12, 2000. (ADAMS Accession Number ML003775385ML003776828

)lMiscellaneous NRC Documents l

DG-1170, Page 195 AL 95-06, Dennis M. Crutchfield, "Relocation of Technical Specification AdministrativeControls Related to Quality Assurance," Administrative Letter 95-06, Dennis M. Crutchfield,lDecember 12, 1995.

l (Available at lhttp://www.nrc.gov/reading-rm/doc-collections/gen-comm/admin-letters/1995/al95006.html

.)lBL 77-08, "Assurance of Safety and Safeguards During A an Emergency - -Locking Systems,"l IE Bulletin 77-08, December 28, 1977.l (Available at http://www.nrc.gov/reading-rm/doc-collections/

lgen-comm/bulletins/1977/bl77008.html

.)lBL 81-03, "Flow Blockage of Cooling Water to Safety System Components by Corbicula Sp.(Asiatic Clam) and Mytilus Sp. (Mussel)," EI Bulletin 81-03, April 10, 1981.l (Available at lhttp://www.nrc.gov/reading-rm/doc-collections/gen-comm/bulletins/1981/bl81003.html

.)lIM STS-10, NRC Inspection Manual, Part 9900, "Tec hnical Guidance," Standard TechnicalSpecification, Section 1.0, "Operability," p. 31, 1986.IP 64100, "Postfire Safe Shutdown (Available at http://www.nrc.gov/reading-rm/

ldoc-collections/insp-manual/technical-guidance/tgsts10.pdf

.)lIP 64100, "Post-Fire Safe-Shutdown, Emergency Lighting and Oil Collection Capability atlOperating and Near-term Operating Reactor Facilities," Inspection Procedure 64100 , Octoberl18, 1999.l (ADAMS Accession Number ML062360048) lIP 64704, "Fire Protection Program," Inspection Procedure 64704, June 24, 1998.

(Available at lhttp://www.nrc.gov/reading-rm/doc-collec tions/insp-manual/inspec tion-procedure/ip64704.pdf

.)lTI 2515/62, "Post -Fire Safe -Shutdown, Emergency Lighting and Oil Collection Capability atlAll Operating Plants," Temporary Instruction 2515/62, Revision 2, February 14, 1985. (ADAMS Accession Number ML062360044) lInspection Manual Chapter 0609, Appendix F, "Fire Protection Significance Determination lProcess," February 28, 2005. (Available at lhttp://www.nrc.gov/reading-rm/doc-collec tions/insp-manual/ ma nual-chapter/mc0609f.pdf

.)l 18Copies may be purchased from the NFPA, 1 Batterymarch Park, Quincy, MA [phone: (800) 344-3555;fax: (800) 593-NFPA (6372)]. Purchase information is available through the NFPA's Web-based store at http://www.nfpa.org/Catalog/

.DG-1170, Page 196National Fire Protection Association Codes and StandardsNFPA 1, "Fire Prevention (18)llThe following listed NFPA code names and titles are based on the current editions of the codes.

lThe "code of record" for an existing plant will typically be an earlier edition and/or may be an ledition with a different title and/or number that addresses the same subject. The code of record lfor fire protection system modi fications and for new reactors s hould be in accordance with the l"Code of Record" subsection in Section B of this Regulatory Guide.

llNFPA 1, "Uniform Fire Code."lNFPA 10, "Standard for Portable Fire Extinguishers."NFPA 11, "Standard for Low-Expansion Foam."

lNFPA 11A-1970 11 , "Standard for Low-, Medium-, and High-Expansion Foam Systems."

lNFPA 11C, "Standard for Mobile Foam Apparatus

."NFPA 12, "Standard on Carbon Dioxide Extinguishing Systems."NFPA 12A, "Standard on Halon 1301 Fire Extinguishing Systems."NFPA 13, "Standard for the Installation of Sprinkler Systems."NFPA 14, "Standard for the Installation of Standpipe and Hose Systems."

NFPA 15, "Standard for Water Spray Fixed Systems for Fire Protection."NFPA 16, "Standard for the Installation of Deluge Foam-Water Sprinkler and Foam-Water SpraySystems."NFPA 16A, "Standard for the Installation of Closed-Head Foam-Water Sprinkler Systems."NFPA 20, "Standard for the Installation of CentrifugalStationary Pumps for FirelPumpsProtection

." lNFPA 22, "Standard for Water Tanks for Private Fire Protection."

DG-1170, Page 197NFPA 24, "Standard for the Installation of Private Fire Service Mains and Their Appurtenances."NFPA 25, "Standard for the Inspection, Testing, and Maintenance of Water-Based FireProtection Systems."NFPA 30, "Flammable and Combustible Liquids Code."NFPA 50A, "Standard for Gaseous Hydrogen Systems at Consumer Sites."NFPA 50B, "Standard for Liquefied Hydrogen Systems at Consumer Sites."NFPA 51B, "Standard for Fire Prevention in Use ofDuring Welding, Cutting and WeldinglProcessesOther Hot Work."lNFPA 54, "National Fuel Gas Code."NFPA 55, "Standard for the Storage, Use, and Handling of Compressed and Liquefied Gases inPortable CylindersGases and Cryogenic Fluids in Portable and Stationary Containers, Cylinders,land Tanks."lNFPA 58, "Liquefied Petroleum Gas Code."NFPA 69, "Explosion"Standard on Explosion Prevention Systems."lNFPA 70, "National Electrical Code."NFPA 72, "National Fire Alarm Code."NFPA 75, "Standard for the Protection of Electronic Computer/Data ProcessingInformation lTechnology Equipment."lNFPA 78, "Lightning Protection Code" llNFPA 80, "Standard for Fire Doors and WindowsOther Opening Protectives."lNFPA 80A, "Recommended Practice for Protection of Buildings from Exterior Fire Exposures."NFPA 90A, "Standard for the Installation of Air

-Conditioning and Ventilating Systems."lNFPA 92A, "Recommended Practice for Smoke Control Systems."NFPA 204M, "Guide"Standard for Smoke-Control Systems Utilizing Barriers and Pressure lDifferences."

l lNFPA 204, "Standard for Smoke and Heat Venting."l DG-1170, Page 198NFPA 220, "Standard on Types of Building Construction."NFPA 221, "Standard for High-Challenge Fire Walls and Fire Barrier Walls."

lNFPA 251, "Standard Methods of Tests of Fire Endurance of Building Construction and Materials."NFPA 253, "Standard Method of Test for Critical Radiant Flux of Floor Covering Systems Using a Radiant Heat Energy Source."

llNFPA 259, "Standard Test Method for Potential Heat of Building Material

."lNFPA 299, "Standard for Protection of Life and Property from Wildfire

."NFPA 600, "Standard on Industrial Fire Brigades."NFPA 701, "Standard Methods of Fire Tests for Flame-ResistantFlame Propagation of Textilesland Films."NFPA 703, "Standard for Fire

-Retardant ImpregnatedTreated Wood and Fire

-RetardantlCoatings for Building Materials."

lNFPA 750, "Standard on Water Mist Fire Protection Systems."NFPA 804, "Standard for Fire Protection for Advanced Light-Water Reactor Electric Generating lPlants."l lNFPA 805, "Performance-Based Standard for Fire Protection for Light-Water Reactor Electric lGenerating Plants."

l lNFPA 1144, "Standard for Protection of Life and Property from Wildfire."

llNFPA 1404, "Standard for a Fire Department Self-Contained Breathing ApparatusServicelRespiratory Protection Program."

lNFPA 1410, "Standard on Training for Initial Fire Attack." Emergency Scene Operations."

llNFPA 1500, "Standard on Fire Depar tment Occupational Safety and Health Program."

lNFPA 1620, "Recommended Practice for Pre-Incident Planning."NFPA 1961, "Standard on Fire Hose."NFPA 1962, "Standard for the Inspection, Care, Use, and ServiceUse of Fire Hose, Couplings land Nozzles and the Service Testing of Fire Hose Including Couplings and Nozzles

."l 19Copies may be obtained from the American Nuclear Society, 555 North Kensington Avenue, La Grange Park, Illinois 60526; telephone (708) 352-6611; fax (708) 352-0499. Purchase information is available through the ANS Web-based store at http://www.ans.org/store/vi-240198.20This standard is available on CD-ROM. Contact IEEE Customer Service at 1-800-678-IEEE or by email tocustomer.service@ieee.org to order.

21Copies of ASME standards may be purchased from the American Society of Mechanical Engineers, Three Park Avenue, New York, New York 10016-5990; phone (800) 843-2763. Purchase information is available through the ASME Web-based store at http://www.asme.org/Codes/Publications/

.DG-1170, Page 199NFPA 2001, "Clean"Standard on Clean Agent Fire Extinguishing Systems."lNFPA Fire Protection Handbook, Volume II, Section 6 10, Chapter 1 , 1 8 9 th Edition, Nationall Fire Protection Association, Quincy, Massachusetts , 2003.lOther DocumentsANI Test, "Standard Fire Endurance Test Method to Qualify a Protective Envelope for Class 1E Electrical Circuits," American Nuclear Insurers, Property Engineering Department, July 1979.

ANSI N18.7, lThe following list of industry standards and guides is based on the current editions of the codes.

lThe "code of record" for an existing plant will typically be an earlier edition and/or may be an ledition with a different title and/or number that addresses the same subject. The code of record lfor fire protection system modifications for existing plants and for new reactor fire protection lsystems should be determined in accordance with the "Code of Record" subsection of Section B lof this Regulatory Guide.

l lANSI/ANS 3.2 , "Administrative Controls and Quality Assurance/Nuclear," American National lStandards Institute, ANSI Standard N18.7.Assurance for the Operational Phase of Nuclear Power lPlants" (Formerly ANSI N18.7).

(19)lANSI/IEEE C.2, "National Electrical Safety Code" (On CD-ROM. Contact IEEE Customer lService at 1-800-678-IEEE or email to customer.service@ieee.org to order.)ASME/ANSI."(20)llASME B31.1, American Society of Mechanical Engineers/American National Standards lInstituteEngineers , ASME/ANSIASME Standard B31.1, "Power Piping.""Power Piping "

lAmerican Society of Mechanical Engineers, New York New York.

(21)lASME NQA-1, "Quality Assurance Program Requirements for Nuclear Facilities," AmericanSociety of Mechanical Engineers Standard NQA-1 , New York New York

.l 22Copies of ASTM standards may be purchased from the American Society for Testing and Materials, 100 Barr HarborDrive, P.O. Box C700, West Conshohocken, Pennsylvania 19428-2959; phone (610) 832-9585. Purchase information is available through the ASTM Web site at http://www.astm.org

.23Copies of the listed EPRI standards may be purchased from the Electric Power Research Institute (EPRI),3420 Hillview Ave., Palo Alto, California 94304; telephone (800) 313-3774; fax (925) 609-1310.

24Copies are available from Factory Mutual Research Corporation, 1301 Atwood Avenue, P.O. Box 7500, Johnston,Rhode Island 02919; phone (401) 275-3000; fax (401) 275-3029. Purchase information is available through the Web-based FM Global Resource Catalog at http://www.fmglobalcatalog.com/ProductInfo.aspx?productid=P7825CD

.DG-1170, Page 200ASTM D-2859, "Standard"Standard Test Method for Flammability of Finished Textile Floor lCovering Materials,"" American Society for Testing and Materials, West Conshohocken,lPennsylvania

.(22)lASTM D-3286, "Standard Test Method for Gross Calorific Value of Coal and Coke by theIsoperibol Bomb Calorimeter,"

Annual Book of ASTM Standards , American Society for Testing land Materials, Annual Book of ASTM StandardsWest Conshohocken, Pennsylvania

.lASTM E-84, "Standard Test Method for Surface Burning Characteristics of Building Materials,"

Annual Book of ASTM Standards , American Society for Testing and Materials, Annual Book of lASTM StandardsWest Conshohocken, Pennsylvania

.lASTM E-119, "Standard Test Methods for Fire Tests of Building Construc tion and Materials,"

Annual Book of ASTM Standards , American Society for Testing and Materials, Annual Book of lASTM StandardsWest Conshohocken, Pennsylvania

.lASTM E-814, "Standard Test Method for Fire Tests of Through-Penetration Fire Stops,"

Annual Book of ASTM Standards , American Society for Testing and Materials, Annual Book of lASTM StandardsWest Conshohocken, Pennsylvania

.lEPRI NP-5283-SR-ANP-5283-SR-A, "Guidelines for Permanent BWR Hydrogen Water lChemistry Installations-1987 Revi sion," Special ReportInstallations," Electric Power Research lInstitute, Palo Alto, California, 1987 Revision.

(23)llEPRI/NEI, "Spurious Actuation of Electrical Circuits Due to Cable Fires: Results of an Expert lElicitation,"

Report No. 1006961, Electric Power Research Institute, September 1987Palo Alto,lCalifornia, May 2002

.lFACTORY MUTUAL APPROVAL GUIDEFactory Mutual Approval Guide

, "FactorylMutual Research Approval Guide

- -Equipment, Materials, Se rvices for Conservation of lProperty," Factory Mutual Research Corp., <http://www.factorymutualJohnston, Rhode Island,lSeptember 2000

.com> .(24)l 25Copies of the listed IEEE standards may be obtained from the Institute of Electrical and Electronics Engineers, Inc.,IEEE Service Center, 445 Hoes Lane, P.O. Box 1331, Piscataway, New Jersey 08855.DG-1170, Page 201 IEEE 242, "IEEE"IEEE Recommended Practices for Protection and Coordination of Industrialland Commercial Power Systems,"" Institute of Electrical and Electronics Engineers, ANSI/IEEElStandard 242Piscataway, New Jersey

. (25)lIEEE 383, "IEEE"IEEE Standard for Type Test of Class IE Electric Cables, Field Splices, andl Connections for Nuclear Power Generating Stations," Institute of Electrical and ElectronicslEngineers, IEEE Standard 383Piscataway, New Jersey

. lIEEE 634, "IEEE Standard Cable Penetration Fire Stop Qualification Test," Institute ofElectrical and Electronics Engineers, IEEE Standard 634Piscataway, New Jersey

. lIEEE 690-1984, "IEEE Standard for the Design and Installation of Cable Systems for Class 1ECircuits in Nuclear Power Generating Stations," IEEE Standard 690Institute of Electrical and lElectronics Engineers, Piscataway, New Jersey

.lIEEE 835, "Standard Power Cable Ampacity Tables," Institute of Electrical and ElectronicsEngineers, IEEE Standard 835Piscataway, New Jersey

. lIEEE 1202, "IEEE Standard for Flame Testing of Cables for Use in Cable Trays in Industrialand Commercial Occupancies," Institute of Electrical and Electronics Engineers, IEEE Standard 1202. Piscataway, New Jersey.

llNEI 00-01, "Guidance for Post-Fire Safe-Shutdown Circuit Analysis," Revision 1, Nuclear lEnergy Institute, Washington, DC, January 2005. (ADAMS Accession Number ML050310295) llNEI 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection lProgram Under 10 CFR 50.48(c)," Revision 1, Nuclear Energy Institute, Washington, DC,lSeptember 2005. (ADAMS Accession Number ML052590476) lUL 555, "Fire Dampers," Underwriters Laboratories, Inc., Northbrook, Illinois (see http://www. l ul.com/info/standard.htm

).lUL Directory, "Building Materials Directory," Underwriters Laboratories, Inc., Northbrook,Illinois (see http://www. comm-2000.com/

).lUL Subject 1724, Appendix B, "Qualification Test for Circuit Integrity of Insulated ElectricalWires and Cables in Electrical Circuit Protection Systems" (Paragraph B3.16), to "Outline oflInvestigation for Fire Tests for Electrical Circuit Protective Systems," Issue No. 2, August 1991l(see http://www

.comm-2000.com/

). l Appendix A to DG-1170, Page A-1APPENDIX A

llEQUIVALENCY lThis appendix provides information and previously accepted examples from Generic Letterl 86-10 (1)86-10, "Implementation of Fire Protection Requirements," with regard to the use oflequivalency in evaluating fire protection and safe

-shutdown features.l A-1.Process Monitoring Instrumentation lSectionParagraph III.L.2.d of Appendix R to 10 CFR Part 50 states that "The, "FirelProtection Program for Nuclear Power Facilities Operating Prior to January 1, 1979," to Title 10,lPart 50, "Domestic Licensing of Production and Utilization Facilities," of the Code of Federal lRegulations (10 CFR Part 50) states, "The process monitoring function shall be capable oflproviding direct readings of the process variables necessary to perform and control

"" thelreactivity control function. Regulatory Positions 5.3 and 5.4 of this guide provide a list ofinstrumentation acceptable to and preferred by the staff to demonstrate compliance with this provision. While this guidance provides an acceptable method for compliancecomplying withlthe regulation, it does not exclude other alternative methods of compliance.

AThe licensee lshould justify alternative instrumentation to comply with the regulation (e.g., boron concentrationl indication) should be justified based on a technical evaluation.l A-2.Fire Area Boundaries lThe term "fire"fire area"" as used in Appendix R means an area sufficiently bounded tolwithstand the hazards associated with the area and, as necessary, to protect important equipmentlwithin the area from a fire outside the area. In order t To meet the regulation, fire arealboundaries need not be completely sealed floor-to-ceiling, wall-to-w all boundaries. However,the licensee should identify and consider all unsealed openings should be identified and lconsidered in evaluating the effectiveness of the overall barrier. Where fire area boundaries arenot wall-to-wall, floor-to-ceiling boundaries with all pe netrations sealed to the fire rating required of the boundaries, licensees shoul d perform an evaluation to assess the adequacy of fire boundaries in their plants to determine whet her the boundaries will withstand the hazardsassociated with the area. This analysis should be performed by at least a A fire protectionlengineer and, if required, a systems engineer should perform this analysis. However, if the safety levaluation report had identified certain cable penetrations were identified as open SER items atlthe time Appendix R became effective,Section III.M of the rule applies

([see 10 CFRl 50.48(b))], and any variation from the requirements of Section III.M requires an exemption. Inlany event, these analyseslicensees should be retained by the licenseesretain these analyses forlsubsequent NRC audits by the NRC

.lA-3.Automatic Detection and Suppression lSections III.G

.2.b and III.G.2.c of Appendix R state that "In, "In addition, fire detectorsland an automatic fire suppression system shall be installed in the fire area.

"" Other provisions ofl Appendix B to DG-1170, Page B-1Appendix R (e.g.,Section III.G

.2.e) also use the phrase "fire"fire detectors and an automatic firelsuppression system in the fire area.

""lIn order to To comply with these provisions, the licensee should install suppression andldetection sufficient to protect against the hazards of the area should be installed. In this regard, detection and suppression providing less than full area coverage may be adequate to comply withthe regulation. Where full ar ea suppression and detection is are not installed, licensees shouldl perform an evaluation to assessevaluate the adequacy of partial suppression and detection tol protect against the hazards in the area. The evaluation should be performed by a A firelprotection engineer and, if required, a systems engineer should perform this evaluation. Thellicensee should retain evaluations should be retained for subsequent NRC audits. If a licenseelis providing no suppression or detection, the licensee should request an exemption or licenselamendment should be requested.REGULATORY ANALYSISA regulatory analysis was published with the draft of this guide when it was issued forpublic comment (Task DG-1097, June 2000). No changes were necessary, so a separateregulatory analysis for

.lAPPENDIX B llFIRE PROBABILISTIC RISK ASSESSMENTS llIn addition to an existing plant that has not adopted a risk-inf ormed, performance-based lfire protection program (FPP) in accordan ce with Title 10, Section 50.48(c), of the Code oflFederal Regulations [10 CFR 50.48(c)], licensees that have not adopted 10 CFR 50.48(c) and llicensees preparing new reactor FPPs may apply risk-informed methodologies, including fire lprobabilistic risk assessment (PRA), to the evaluation of an FPP change. However, the U.S.

lNuclear Regulatory Commission (NRC) must re view and approve the proposed methodologies,lincluding the acceptance criteria, before the implementation of the plant change.

l lAccording to 10 CFR 52.47(a)(v), new reactor applications submitted under 10 CFR Part l52, "Early Site Permits; Standard Design Certifications; and Combined Licenses for Nuclear lPower Plants," must include a design-specific PRA. A detaile d fire PRA is not necessarily lrequired for a new reactor FPP. However, if an applicant for a combined operating license l(COL) references a certified design and if that certified design developed a fire PRA, then the COL lapplicant, per proposed 10 CFR 52.80(a), should use that PRA and update it to reflect site- and lplant-specific information that may not have been available at the design stage. In addition, a llicensee that has a risk-informed, performance-based FPP [similar to a National Fire Protection lAssociation (NFPA) 805 program] or that plans to evaluate plant changes using a risk-informed lapproach must have a detailed fire PRA.

ll Appendix B to DG-1170, Page B-2The term "fire PRA" encompasses all levels and types of PRAs, ranging from a lsimplified bounding analysis to a detailed analysis in accordance with NUREG/CR-6850,l"EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Fac ilities," and the draft American lNuclear Society Fire PRA Standard. NUREG/CR-6850 should be the basis for the review of the lproposed methodologies. Chapte r 19, "Probabilistic Risk Assessm ent," of the Standard Review lPlan (SRP) (NUREG-1800) contains additional guidance on the re view of nuclear power plant lPRAs.l lA fire PRA should receive a peer review to the extent that adequate industry guidance is lavailable. The NRC will review and accept the industry guidance before its application to lspecific fire PRAs. The NRC should also review the results of the plant-specific peer reviews. All ltypes and levels of fire PRAs should be subject to a peer review. If adequate industry guidance is not lavailable for conducting a fire PRA peer review, the NRC s hould review the fire PRA for lacceptability.

l lLicensees may use PRA and/or risk insights gained from other methods in support of lproposed changes to the plant licensing basis, such as license amendment requests per 10 CFR l50.90, "Application for Amendment of License or Construction Permit," and 10 CFR 50.92,l"Issuance of Amendment." Regulatory Guide 1.189 has not been prepared. A copy of the lregulatory analysis is available for inspection or copying for a fee in the NRC's Public Document Room at 11555 Rockville Pike, Rockville, Maryland.BACKFIT ANALYSISText Was Moved From Here: 1274, "An Approach for Using Probabilistic Risk Assessment In Risk-Informed Decisions on Plant-lSpecific Changes to the Licensing Basis," provides guidelines for the use of PRA in support of lplant changes that require NRC approval. Plant changes that are not subject to NRC approval are lnot within the scope of Regulatory Guide 1.174. Where licensees use PRA in support of lsubmittals to change the plant licensing basis, they should follow the guidelines of SRP Chapter l19.l l

l l