ML071550408

NFPA 805 Transition Pilot Plant FAQ 06-0007, Revision 3

ML071550408
Person / Time
Site:	Harris
Issue date:	05/21/2007
From:	Holder A Progress Energy Carolinas
To:	Office of Nuclear Reactor Regulation
References
FAQ 06-0007, Revision 2, NEI 04-02
Download: ML071550408 (3)

Text

FAQ Number 06-0007 FAQ Revision 2 FAQ Title NFPA 805 Section 3.4.1, Specific Clarification Plant: Harris Date:May 21, 2007 Contact: Alan Holder Phone:919.546.3372 Email:Alan.Holder@pgnmail.com Distribution: (NEI Internal Use) 805 TF FPWG RATF RIRWG BWROG PWROG Purpose of FAQ:

The purpose of this FAQ is to clarify the applicable NFPA code for fire brigades and fire departments as may be used in association with NFPA 805.

Is this Interpretation of guidance? Yes / No Proposed new guidance not in NEI 04-02? Yes / No Details: NEI 04-02 guidance needing interpretation (include section, paragraph, and line numbers as applicable):

NEI 04-02, Section 4.3.1, Fundamental Fire Protection Program and Design Elements Transition Review, appendices to list acceptable interpretations to the NFPA 805 standard (future).

Circumstances requiring guidance interpretation or new guidance:

Clarification of NFPA 805, Chapter 3 applicability requirements for fire brigades.

Detail contentious points if licensee and NRC have not reached consensus on the facts and circumstances:

NA Potentially relevant existing FAQ numbers:

NA

FAQ Number 06-0007 FAQ Revision 2 FAQ Title NFPA 805 Section 3.4.1, Specific Clarification Response Section:

Proposed resolution of FAQ and the basis for the proposal:

Clarification to questions as presented.

If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:

As follows; From NFPA-805, Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)

3.4 Industrial

Fire Brigade 3.4.1 On-Site Fire-Fighting Capability. All of the following requirements shall apply. (a) A fully staffed, trained, and equipped fire-fighting force shall be available at all times to control and extinguish all fires on site. This force shall have a minimum complement of five persons on duty and shall conform with the following NFPA standards as applicable: (1) NFPA 600, Standard on Industrial Fire Brigades (interior structural fire fighting) (2) NFPA 1500, Standard on Fire Department Occupational Safety and Health Programs (3) NFPA 1582, Standard on Medical Requirements for Fire Fighters and Information for Fire Department Physicians

Clarification of NFPA 805, Chapter 3 specific sections as applied under NEI 04-02, will be included in (New) Appendix K, to NEI 04-02 upon approval of specific clarification. (final formatting to be provided by NEI contract writers). Appendix K will be prefaced with the following, which shall be applicable to all future specific clarifications unless specifically excluded.

Appendix K, Specific Clarifications While recognizing that Regulatory Guide 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants, or NEI 04-02, Nuclear Energy Institute, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c), does not provide interpretations to the standard NFPA 805, there are instances where implementation of the standard does require further specific clarification as to what is an acceptable method or process to the AHJ. These instances are collectively presented in this Appendix, and referenced to the FAQ Number 06-0007 FAQ Revision 2 FAQ Title NFPA 805 Section 3.4.1, Specific Clarification Frequently Asked Question (FAQ) in which they were originally presented during the pilot plant process and subsequent plant transitioning processes.

Specific clarification to NFPA section 3.4, from FAQ #06-0007:

The NFPA standards divide fire brigades into two types, based on organization and duties: "Industrial Fire Brigades" and "Industrial Fire Departments." Practically, this means that a fire fighting organization at a nuclear power plant must comply with either NFPA 600 (for an Industrial Fire Brigade) or both NFPA 1500 and NFPA 1582 (for an Industrial Fire Department)

Reference in section 3.4.1(a)(1), to "(interior structural fire fighting)" indicates that for interior fire fighting, at a minimum, the licensee shall meet the requirements noted in NFPA 600, Chapter 5, Industrial Fire Brigades That Perform Interior Structural Fire Fighting Only. For exterior fire that could jeopardize the ability to meet the performance criteria described in NFPA 805, Section 1.5.1 the licensee shall be able to demonstrate their ability to control and extinguish those fires.