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'f + I. UNITED STATES NUCLEAR REGULATORY COMMISSION inen1Y M"'[,"
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MEMORANDUM FOR: Those on Attached List
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FROM: James G. Partlow, Director '
Division of Inspection Programs Office of Inspection and Enforcement A0N b
SUBJECT:
INTERIM USAGE OF THE STEERING COM'i!TTEE REPO P 1
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The Fire Protection Steering Comittee Report (FPSCR), issued as Generic Letter 85-01, has not been fonnally revie ed and approved by the Comission. It is possible the ongoing sais ativicown inspections will result in findings which involve the issues addressed in the FPSCR, enclosure 3. "Interpretations of Appendix R". 'Such findings can, while waiting for Comission approval of the interpretations, be appropriately placed in an "unresolved" or "open item" cate- l go ry. Subsequent to Comission review and approval of the FPSCR, the findings I would be reevaluated and action taken as appropriate.
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- Jame , G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement cc: T. T. Martin, RI P. R. Bemis, RII 6
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Multiole Addressees for Memo Dated Richard W. Starostecki, Director Division of Project and Resident Programs Region I Roger Walker, Director Division of Reactor Projects Region II Charles E. Norelius, Director Division of Reactor Projects Region III Richard P. Denise, Director Division of Reactor Safety and Projects
. Region IV Dennis F. Kirs~ch, Acting Director Division of Reactor Safety and Projects Region V
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MEMORANDUM FOR: Williar J. Dircks Executive Director for Operations FROM: Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
UPDATED RECOMMENDATIONS Oh FIRE PROTECT 10h POLICY AND PROGRAM I.CTION!
Tnis re crancur contains responses to the June 8, 1984 letter froe the CorrMssion corcerning irclementation of fire protection recuirements (re' MSAC530E;. the Deceeber 10, 1984 letter from W. Dircks to V. Stelle, F. Denter and F. Detoung on the Fire Protection Policy Steering Coccittee
_ Reccerencatiors; anc the May 3,1985 letter from the Fire Protection Policy Steering Corrittee to H. Denton.
A Corrission paper with eight enclosures (Attachment A) is provided in response to the Cornission's direction. Attachment B provides the response to the recuestec actions and related questions in the December 10, 1984 mer.c.
The NRE corrents on the updated Steering Cornittee Report are provided as Attachment C.
w Harold R. Denton, Director Office of Nuclear Reactor Regulation i i
Attachments' I A. Coenission Paper, with 8 Enclosures E. Response to W. Dircks 12/10/84 reno, with 3 Enclosures C. Corrnents on Steering Cosmittee l Report cc: Regional Acministrators ') ,
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4 For: The Commissioners From: William J. Dircks Executive Director for Operations
Subject:
STAFF RECOMPENDATIONS REGARDING THE IMPLEMENTATION OF APPENDIX R TO 10 CFR 50
Purpose:
To provide the Commission with recommendations for expediting and improving the implementation of Appendix R (Fire Protec. *
-~ tion), and to provide a discussion of related issues raised
, by a member of OGC anc by several fire protection staff
( members.
Background:
The initial inspections for compliance with the safe shutdewn provisions of Appendix R to 10 CFR Part 50, at facilities where compliance with Appendix R was believed to be complete by the licensee, revealed a number of instances of noncom-pliance and enforcement actions were being proposed. In late 1983, the EDO initiated a consultation between headquarters and the regions which concluded that uncertainty still existed over the staff requirements and suggested that a series of regional workshops be organized to discuss fire protection and answer questions from the licensees. The Nuclear Utility Fire Protection Group (NUFPG) organized a meeting to precede these workshops to solicit industry experience in fire protec-tion programs and compile for the NRC questions which they felt needed answering.
1 The NUFPG also initiated discussions with the staff on whether a licensee may propose an alternative means of complying with certain Appendix R issues covered by Generic Letter 83-33 if backed by a technical justification. in such cases, an
! exemption request need not be made if an alternative means
' intact: 4. Johnston Lat. 27331 I
The Comissioners h AM\
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S.g . N^ of compliance is provided in areas where Appendix R are 4T/yA.Inon-specific. The result of these discussions was a document "M called "Interpretations of Appendix R."* -
N,rb % Y gb ~ IJhe workshops workshops wereofheld a package NRCinguidance the spring was of 1984. At distributed to these y 'k k t Q. each attendee which included NRC staff responses to industry jd gf O.u# ~ 04 7 questions and the "Interpretations" document. The cover memo for the package explained that it was a draft package which would be issued in final form via a generic letter following wNhMO .
n o.,sRtheworkshops.
W.D s 16 On May 30, 1984, the staff briefed the Comission on the status t of the irplementation of Appendix R and discussed the issues raised by several NRC fire protection engineers in a Differing Professional Opinion (DPO) and by a member of OGC. At this meeting, the Comission requested that the implementation guidance be submitted for Comission approval prior to its issuance to industry.
,7 ,, Following the Comission meeting. NRR was requested by the EDO
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to font a Steering Comittee on Fire Protection Policy to
' examine all current licensing, inspection and technical issues, and to develop policy recentrendations aimed at expediting Appendix R compliance for pre-lg79 plants. The Steering Comittee drew its membership from three of the Regions, IE, and ELD. Richard Vollmer, then of NRR was Chairran. Follow-ing a series of intetings, which included discussions with all agency fire protection engineers, the Steering Comittee issued a report to the EDO (Enclosure 1) in October 1984 containing a num.ber of recommendations for improving the consistency of the levels of fire protection safety and for enhancing i the implementation of Appendix R. ,
I' Following coment by the Program Offices and the regions, the EDO directed in December 1984 that the Steering Comittee Report be issued for public coment. Coments were received from the NUFPG, utilities, and consultants. On May 3, 1985, the Fire Protection Steering Comittee issued updated recomendations which reflect resolution of these coments (Enclosure 2).
- This document was later disputed by a member of OGC, and several staff mer.bers initiated a differing professional opinion.
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4 The Corriissioners l Current Status i
Although Appendix R became an effective rule in 1981, approximately half of the operating reactors still have outstanding material in for staff review and some facili-ties are not currently scheduled for compliance until the late 1980s. This situation, as discussed with the Consnis-sion in May 1984, has arisen partially because of the com-plexity of achieving compliance with the Rule for older facilities despite the exemption provisions, and partially because industry did not manage its approach to Appendix R effectively, nor did the NRC fully anticipate the impact of Comission-required backfitting of certain portions of Appendix R. The staff believes that implementation of this guidance, which has been generated in response to industry defined needs, will help bring to closure outstanding issues.
The backlog of licensing review extends well into 1986. Some of this could be given back for licensee action, based on this gui c.' nc e . However, the staff recognizes that additional review work :y also be generated.
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- As dis. ssed previously, the development of this guidance and regional meetings in 1984 resulted from early inspections showing noncoepliance with Appendix R. This situation has changed sorrewhat for the better. Based on a larger sample of ten pre-1979 and twenty post-1979 safe shutdown inspections, irrprovement has rkcently been noted in licensee understanding of the analyses needed to establish required post-fire safe shutdown capabilities. Recent inspections have resulted in a significant reduction in the number of deficiencies observed.
50ee cf this is attributable tc a better uncerstanding of the requirerrents as discussed in the regional workshops.
In the past year, we have been inspecting NTOL plants prior to issuing an operating license specifically for the safe shutdown items of Appendix R. Based on the information given out at the workshops, the applicant usually makes a submittal prior to the inspection identifying additional deviations from Appendix R or the staff guidelines. The staff then uses the time before or during the inspection to come to resolution on these deviations.
The increased understanding since the workshops has reduced significantly the open items to be resolved at the time of licensing. The inspection results for these new plants show substa.ntial compliance with regulatory requirements.
Discussion: The staff proposes to adopt positions reconsnended by the Fire Protection Policy Steering Comittee for the guidance of the licensees in the irplementation of Appendix R.
The Comissioners The Steering Comittee's principal recomendations are as follows: .
- 1. Promptly issue a generic letter (Enclosure 3) informing all licensees that:
- a. Extensions to 50.48c schedules will no longer be granted except where a licensee has an approved "living schedule."
- b. Inspections will include plants with uncompleted modifications as well as plants with completed modifications. In addition, licensees may request an inspection to help avoid costly design and implementa-tion decisions with which the staff may disagree.
4 c. Documentation of valid analysis supporting fire protection features must be available for inspection.
- d. Quality assurance measures should be in effect to e assure that fire protection systems will function as
{ intended.
- e. Licensees are required to notify the NRC wt an deficiencies are discovered pursuant to 10 CFR 50.72 and 50.73.
- f. A standard fire protection license condition is available which will clarify the licensee's options in making modifications to the fire protection program.
- 2. Accompany the generic letter with the following guidance documents; o Interpretations of Appendix R (Enclosure 4).*
o Appendix R Questions and Answers (Enclosure 5).
o Fire Protection License Condition (Enclosure 6).
The Steering Comittee carefully reviewed the "Interpretations" and concluded that they will provide an improved means of l
- These interpretations represent staff positions, and shculd '
not be considered as official agency interpretations issued I by the General Counsel. See 10 CFR 1.32; 10 CFR Part 8.
The comissioners achieving compliance with Appendix R. Concurreece with this position was received from,the Regional Administrators and ~
there were no substantive coments on this document received from the public. The Appendix R Questions and Answers include the questions posed by the industry and are supplemented with additional questions identified at the regional workshops.
, These responses may be used as guidance for design, review, and inspection activities. Minor revisions have been made in consideration of public coments and for consistency with the "Interpretations" document.
The Steering Comittee also recomended adoption of pro-posed Guidance For Enforcement Actions Concerning Fire Protection Rect. .ements (Enclosure 7).
The objective in issuing the generic letter and accompany-ing documents is to bring together all of the remaining issues which have been identified by the staff or by the industry as requiring resolution.
The Comission also requested that the staff coment on the OGC memorandum and the differing professional opinions.
( Mr. Trubatch raises objections to five parts of the Inter-pretations document: fire boundaries, cold shutdown, automatic detection and suppression, fire damage, and alternate shutcown. A response to Mr. Trubatch's legal concerns has been prepared by OELD (Enclosure 8).
Two coments from Mr. Trubatch relate to the staff's handling of fire damage and alternate or dedicated shutdown. The l
staff has not changed its position regarding the need for i licensees to consider the effect of suppressants when assuring I that "the structure, system, or component under consideratien is capable of perfonning its intended function during and af ter the postulated fire, as needed." The purpose of this inter-pretation of fire damage is to clarify that cosmetic damage, which does not interfere with the above capabilities, would not be a basis for rejection of an exemption request.
The position of the staff has also not changed in regard to the need for adequate separation of alternative shutdown equipment from normal shutdown equipment. However Appendix R. in mentioning "room, or zone" in addition to "area," clearly implies that compliance ma separation by fire areas. y be Theachieved staff hasby other thanthis recognized and has granted exemptions in the past. What is changing is the recognition that compliance with Appendix R can be established with adequate justification and exemptions need
4 The Corriissioners - 6-not be requested. The "room" concept must be justified by preparation of a detailed fire hazards analysis that demon-strates that a single fire will not disable both normal -
shutdown equipment and the alternate shutdown capability.
The staff DP0 is primarily concerned with Section 4. Fire Area Boundaries, and Section 5. Automatic Detection and Suppression, of'the Interpretations of Appendix R. The Interpretations allow penetrations in fire area boundaries and partial area coverage for fire suppression and detection if it can be established by analysis that adequate protection is provided for the fire hazards associated with the area. Such positions have previously been approved by the staff as exemptions.
However, the "Interpretations" do not require submission of fire hazards analyses for staff review cr the filing of exemption requests prior to fire protection inspections; but the analysis must ce available fer NRC audit. The DP0 states that not requiring exemption requests is in conflict with Generic Letter 83-33 which was issued previously to clarify staff positions on these and other issues, and which is deered preferable.
The Steering Comittee has reviewed the positions defined in the "Interpretations" and has concluded that they are techni-t cally and legally consistent with the requirements of Appendix R.
It is expected that the DP0 will be resolved accordingly.
However, formal resolution of the DP0 is being deferred perd-ing Comission action on the recomendations of the Steering Comi ttee.
Sucrary and The Steering Comittee on Fire protection Policy which was Conclusiens: established by the E00 has made a number of recomendations for impnvirg the consistency of the levels of fire protection safety and for enhancing the implementation of Appendix R. These recomendations, having received public coment, have been incorporated as a generic letter with attachments which the l
staff proposes to send to the licensees. The staff believes 1 that the recomendations will provide the most consistent and workable means of enhancing the implementation of Appendix R and intends to proceed expeditiously with their issuance.
1 Recomendations: That the Comission direct the staff to:
- 1. Issue the generic letter with atttAhments.
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- 2. Conduct fire protection inspections in accordance with currently allocated fire protection resources l and as described in Section 8 of the generic letter.
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The Comissioners 3. Utilize the guidance in Enclosure 7 as the criteria for enforcement of Appendix R requirements.
- 4. Encourage licensees to adopt the standard fire pro-tection license condition set out in Enclosure 6.
- 5. Proceed with modifications of fire protection Technical Specifications in conjunction with the ongoing effort on Technical Specification improvements.
William J. Dircks Executive Director for Operations
Enclosures:
- 1. Memo dtd 10/26/B4 to Dircks fm Fire Protection Policy ;
Steering Comittee - 1
- 2. Memo etc 5/3/85 to Denton 1 8
fm Vollmer i
- 3. Generic Ltr on Fire Protection i
- 4. Interpretations of Appencia R l
- 5. Appendix R Questions & Answers l
- 6. Fire Protection License Concition i
- 7. Guicance for Enforcement Actions Concerning Fire Protection Requirerents
- 8. Memo dtd 6/27/84 to Vollmer fm l Olmsteae l OFC :DE:ADM T :DE: CME 5 ELD
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DATE :6721/85 6/d/85 :6/ /85 :
0FFICIAL RECORD COPY
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ENCLOSURE 1 RESOLUTION OF COMMENTS ON THE RECOMMENDATIONS 07 THE FIRE PROTECTION POLICY STEERING COMMITTEE (50FR2056 JAh, 15, 1985; G.L. 55-01) 1.0 PUBLIC COMMENTS:
1.1 Nuclear Utility Fire Protection Group: Letter from J. J4. McGarry to H. R. Denton dated February 14. 1985.
1.1.1 Comment (A.1): Schedular Relief
'The discussion at pages 12 of the draft Generic Letter indicates that schedular relief under 10 C.F.R. I 50.48 can no longer be obtained. The Group is concerned that this discussion could be read as precluding the filing of schedular exemption requests under 10 C.F.R. I 50.12. It is the Group's understanding from discussions with the Staff that schedular exemptions under 10 C.F.R. I 50.12 continue to be available despite the expiration of the Section 50.48 deadlines. To avoid any misunderstanding, the Group would recommend that the Staff's Generic Letter state explicitly that the filing of a f
schedular exemption request under Section 50.12 is not l
- precluded by the expiration of the Section 50.48 deadlines."
Resolution:
The NUFPG conrent indicates a misunderstanding of the Steering Committee recommendation on schedular exemptions, which have always been issued under 10 CFR 50.12. The Steering Commit *ee recommended that no furtherwhose (for licensees schedular 50.48 exemptions deadlinet have be granted,)andpassed vill be that setschedules in the enforcement context. Therefore, their understanding that l schedule exemptions would still be available if this recommentation ,
is adopted is not correct. However, this does not preclude the l filing of a schedular exemption request under 10 CFR 50.12 based on l a justif:ed "living schedule" which has been approved by the NRC. i The proposed Generic Lester has been revised (footnote. Pg. 2) to clarify this point.
1.1.2 Comment (A.2): Inspection Process ,
1 a) This consent addresses the Steering Comnittee recoupendation for an accelerated fire protection inspection program and presents reasons why such inspections should be postponed until the new guidance package has been reviewed and approved by the Cosnission. The conclusion of this comment states:
'For these reasons, we believe that the most efficient use ,
of Staff and licensee resources would result from postponing the inspections (absent a safety concern or an indication of readiness on the part of the licensee) until the new interpretations and guidance have been reviewed and approted by the Commission. 2/"
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2 b) The above cited footnote states:
"2/ In connection with the discussion of the inspection .
Focess,theGroupstronglysupportstheSteeringCostnittee's reconsnendation regarding the establishment of a referee team, headed by senior NRR management, to resolve significant differences between inspection personnel and the licensee. The Group understands that the resolution of such differences will be ac omplished expeditiously by the referee team, with a decisica issued generally within one week, but in any event before the inspection report would be relet id.' l Resolution: I a) The inspection program will be conducted as expeditiously as present resources allow with priority given to utilities not yet inspected and these requesting early inspections.
.b) The understandf99 of the NUFPG regarding the composition and expected perforvance of the ' referee" team is correct. If the recofwendation for formation of a referee team is approved b the Costnission, the substance of this connent will be in-c uded in its Charter.
1.1.3 Corrent (A.3): Documentation Required to Demonstrate Compliance
'---TheproposedGenericLetterstates(atpage3):
Ftilure to have such an evaluation available for at area where compliance with Appendix R is not readily demonstrated will be taken as prima facie evidence that the area does not comply with NRC requirements and may result in enforcement action. 3/ (Emphasis added.)
It is the Group's understanding from our discussions with !
the staff that the tenn "readily demonstrated" is intended to include situations where compliance is apparent by I observation. Thus, if compliance with Appendix R is apparent l by observation of the features in question, failure to have an I evaluation available will not be considered evidence of noncompliance. With this understanding expressly incorporated into the Generic Letter, the Group has no objection to this part of the proposed Generic Letter." i h
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l 3-Resolution:
The understanding is correct. The proposed W neric Letter and the -
Guida'ce for Er.forcement Actions have been revised to incorportte l the NUFPG understanding. l 1.1.4 Coment (A.4): Quality Assurance Requirescnts j This coment takes exception to the introductory sentence to section D of the proposed Generic Letter which states: "Fire protection systems must meet the requirements of General Design ,
Criterion 1 ef Appendix A to 10 CFR Part 50." Specifically, the objection is to the citation to GDC 1 because this impacts the current rulemaking regarding the safety classification issue, i.e.,
the important-to-safety vs. safety-related controversy. It further states that the QA guidance provided in BTP CMEB 9.5-1 (also cited in the proposed Generic letter) is adequate for this purpose and has generally been followed in the industry. Therefore, it recom-mends deletion of the citation to GDC-1.
Resolution:
, This coment is considerec valid. The references to GDC-1 can be deleted without loss of the point being made regarding adequate QA
(- for fire protection equipment. The rulemaking now in progress on the safety classification issue will clarify that licensees are expected to carry out GA comitments already present in the FSAR and other licensing documents. The proposed Generic Letter has been revised to delete rei'erence to GDC 1 and to more completely
- descrioe the appropriate QA guidance.
1.1.5 Coment (B.1J1 Size of the Fire This comment recommends that the interpretations of Appendix R be revised to include guioance concerning the size of an assumed initiating fire. Specifically, it is recomended that the following footnote be added to Section 3. Fire Damage:
"For purposes of the fire protection program, Staff pactice has been to assume a relatively small amount of combustible material as the initiation source, i.a., absent special considerations indicating high or low potential combustible initiators, typically in the range of 5 gallons of flamable liquid."
4 Resolution:
We do not concur in this reconinendation. Guidance concerning the .
size of an assumed initiating fire 'could be helpfal in evaluating the fire severity within a fire area in a mechanistic way. How.
ever, the proposed guidance is not representative of expected transient combustibles in most plant areas, does not specify the configuration of the transient fuel and incorrectly states the staff practice.
The expected transient combustibles vary throughout the plant.
For example, in some areas, the expected transient combustible may be oil; however, the amount anc configuration of the oil would be dependent on the reason for it to be there. I, the control room, paper (drawings and conputer ruas) and plastic scrap is the expected transient. In cable spreading rooms, cables and cable drums have been the most prevalent transient combustibles identified. On the refueling deck, wood and polyethylene sheets would be expected. In ,
other areas, drums of plastic (protective clothing) are cresent.
Each configuration of these transient combustibles poses a different threat because of the differing characteristics of fire growth, fire duration and heat release rate.
The present g tidelines recomend that the appropriate transient com-bustible for the particular area be considered. The Fire Hazard Analyses are based on this assumption. Therefore, the proposed addition was not incorporated.
1.1.6 Coment (B.2): Fire Area Boundaries This coment questioned whether each individual unsealed opening in a fire barrier must be evaluated, and stated that it was their understanding ".... that the staff would pemit an evaluation of openings by groups, e.g., according te size of the openings and distance from combustible material."
Resolution:
The stated understanding is not correct. Unsealed openings should be grouped by the fire barrier which they penetrate. The evaluation of the overall effectiveness of the barrier should then consider the size and distribution of these openings, the combustible loading, and the proximity of such loading on both sides of the barrier.
A clarifying revision to the Interpretations has been made.
1.1.7 Coernent (C.1): General Guidance The coment stated the understanding that Section IB of the Guidance for Enforcement Actions Concerning Fire Protection Requirements does not require a separate list of safe shutdown equipment; that "the necessary equipment need only be identifiable from the fire hazards analysis and SERs."
Resolution:
This understanding is correct. No revision is considered necessary. ,
1.1.8 Corrrent (C.2): Severity Categories The consent stated the understanding that the word "dedicated" used in Sections 2,A, 2.8 and 2.C of the Guidance for Enforcement Actions Concerning Fire Protection Requirements "is meant to refer to the equiteent identified in the fire hazards analysis for safe hot or cold shutdown." l l
Resolution:
This understanding is correct. A clarifying revision to that effect has been made.
1.1.9 Connent (D.1): Current Requirements The consnent states that the proposed license condition is uanecessary for plants licensed prior to January 1, 1979 because license condi-tions were issued upon completion o' the staff's review of con- ,
- formance to the positions in Appendix A to BTP APCSB 9.5-1; that for plants licensed after January 1, 1979, a license condition has been
( imposed; that all modificatiens must be reviewed and reported pur-suant to 10 CFR 50.59; and that 10 CFR 50.72 and 50.73 provide relevant reporting requirements. Therefort, adequate enforceability 1 is already present without additional actions.
The convnent also reconvnended that the response to Question 8.3 (which inquired whether an exemption is required from Appendix R sections other than III.G, III.J and III.0 for future modifications that do not comply with such sections) be changed from "yes" to "no." This was based on the interpretation of Appendix R as not requiring exemptions fcr modifications that were made to features which were approved by the staff under Appendix A of BTP APCSB 9.5-1. The Statement of Considerations to Appendix R (45FR76602, Nov. 19, 1980) was cited to support this. l Resolution:
A standard license condition is considered necessary for the allowing reasons. The license conditions which were imposed on plants licensed prior to January 1, 1979 only addressed the modifications that were required. Those parts of a plant's fire protection program including the fire hazards analysis, found acceptable by the staff in the Fire Protection Safety Evaluation Report with no modifications necessary were not addressed by the license condition.
l The NRC has found during inspections that some licensees do not con-sider the Appendix A to BTP APCSB 9.5-1 items of theie fire pro-tection programs as binding and have either changed them or ignored .
them. For plants licensed after January 1,1979, while all such plants have a license condition regarding fire protection, the scope of what is covered by the condition and the wording of the condition varies widely. This results in varying degrees of compliance and uneven enforcement. Therefore, we believe that a "standard license condition" is necessary for consistent and fair regulation. How-ever, the license condition has been revised to include specific identification of the documents providing the basis for the ifcense ,
condition, l Regardirg the applicability of 10 CFR 50.59, in many cases, includ-ing all plants licensed prior to January 1,1979, the fire protection program and the fire hazards analysis are not described in the FSAR.
Therefore, the provisions of 10 CFR 50.59 are not directly appli-cable. Accordingly, the license condition has been revised to I specify the applicabilit cess and 10 CFR 50.71(e)y (2) for of the10 CFR 50.59 reporting for the process. evaluation pro-Addf- '
tional revisions are described in consnent resolutions 1.1.10 and ~ '
.- 1.1.11.
Regarding the consnent on Question 8.3, this comment is not con-sidered valid. The cited Statement of Considerations does not address the applicability of Appendix R in regard to modifica-tions made to features previously approved by the staff. The staff position in this regard is clearly supported by 10 CFR 50.48(b). A revision to the. response to Question 8.3 has been made to clarify this point.
1.1.10 Coment (D.2): Hearing Requirements Under the proposed license condition, any change to the program must be analyzed for its effect on overall fire protection safety.
Even minor modifications such as adding one cable to a room or a 3 change in the location of a fire extinguisher would have to be analyzed, and, if found to lower the level of fire protection, no ;
matter how minor, would require a license amendnent with full notice and hearing rights, an expensive and time-consuming process with-out a comensurate benefit to safety. Therefore, the proposed license condition should not be adopted.
Resolution:
The proposed license condition has been revised to make it clear '
I that only those changes to the fire protect 1cn program that
'significantly" decrease the level of fire protection would require prior Comission approval and a license amendment; changes which do not "significantly" decrease the level of fire protection may be
- 1 7-made in accordance with 10 CFR 50.59 and reported annually with FSAR revisions as required by 10 CFR 50.71(e).
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1.1.11 Coment (0.3)_. Section 50.59 In regard to paragraph 3 of the proposed license condition the coment states:
a) " ---that the requirement to submit the supporting analyses would impose an undue paperwork burden on both the licensees and the Staff. Significantly,' Section 50.59 does not require ,
actual submittal of the analyses performed in accordance with !'
that section. Instead, licensees re pursuant to 10 C.F.R. I 50.71(e) on (2)what portSection to the50.59 NRC annually l changes have been made. We would recomend that a similar procedure be used for fire protection changes, and therefore would recomend not imposing a requirement for actual submittal of the analyses." l I
---there is no safety reason to require that "All changes to
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b) the approved program" be reported to the NRC annually. For ,
example, changing the location of a fire extinguisher or adding !
one cable to a room may have no practical bearing on safety.
( Yet, pursuant to the license condition as postured, it may need to be reported. We maintain that such a requirement is unjusti-fied and unwarranted."
R,esolution:
a) The proposed license condition has been revised to remove the requirement for submittal cf the analyses and to specify the applicability of 10 CFR 50.59 and 10 CFR 50.71(e),
b) It is not intended that changes that "---have no practical bear-ing on safety" be reported; it is expected that licensees would exercise reasonable judgment in this regard. A revision was made to indicate this intent.
1.1.12 Coment (E): Standard Technical Specifications The coment supports the Steering Comittee effort to revise the fire protection Technical Specifications to the extent that it is directed toward simplifying and generalizing them to be more workable. It recoarnends that any proposed TS changes be reviewed as part of the overall staff consideration of Technical Specifications in general, and requests an opportunity to ccament on proposed changet.
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Resolution:
The course of action to be followed should ba defined by the Steering Committee. The options available are: ~
(1) Include the revised fire protection Technical Specifications in the package being submitted for CRGR review and subsequently for Commission approval.
This option would provide a complete package for "resolution" of the fire protection issue; the "Commission approved" fire protection TS could theri be incorporated in the STS without delay, and implementation in OLs and ors could proceed immediately.
(2) Handle the fire protection Technical Specifications separately (from the CRGR/Coenission package), i.e., submit the proposed revisien to the Technical Specification Review Group (TSRG)
(E. Butcher) for eventual inclusion in the STS.
It is our understanding that the TSRG is presently revising the
^
STS to include all clarifying changes which reflect present practice and which will not require CRGR review. The TSRG
( .
intends to make substantive type changes, which will then be submitted to the CRGR on a single issue basis, at a later date.
The proposed fire protection TS changes are in this second category. Therefore, CRGR approval and subsequent implementa-tion of the TS on Ol.s and ors would be delayed significantly.
Also, the direct Commission approval afforded by option (1) would not be available to support backfitting the revised TS on ors.
(3) Defer action on fire protection TS until some action is taken by NRR on the recommendations of the Technical Specification Improvement Project (TSIP) (S. Bryan (formerly under D. Beckham]) which are scheduled for September 1985.
This option has the same detrimental aspects in regard to implementation of the TS as option (2) except that the delay involved would probably be greater.
It is recoenended that option (1) be selected.* It is also recom-mended that the TS not be issued for public cossent, unless so directed by the Coemission. Substantive changes to Technical Specifications normally only require CRGR review.
- The Steering Coenittee recommended instead that the proposed TS be used as appropriate in future OLs, and that they be transmitted to the TSIP. However, MRR is forwarding only the latter portion of this recommendation for Commission approval.
9 1.1.13 Coment (F.1): Question 3.2.3 (Fire Door Modifications)
The comment notes that according to UL and FM any modliication of a fire door will invalidate its label. Therefore, the following -
portion of the response to Q3.2.3, "An exemption is required if fire doors installed in a fire barrier used to satisfy Section III.G.2 are modified such that the labeled rating no longer applies," could be interpreted to require an exemption for modifi-cations to incorporate security hardware or flooding protection.
It is reconsended that the response be revised to state that an' exemption is required only after a boundary analysis which considers the fire loading on both sides of the boundary shows that adequate margin no longer exists.
Resolution:
The cossent is valid. To be consistent with Section f4 of the "Interpretations," the response to Q3.2.3 has been revised to in-dicate that evaluation of fire door alterations is part of a fire boundary analysis not requiring an exemption.
1.1.14 Comment (F.2): Question 3.6.2 (Intervening Combustibles)
The comment notes that the response to Q3.6.2 classifies cables in
(' covered cable trays as "intervening combustibles" while the response to Q3.6.3 states that cables in conduit are not considered inter-vening combustibles. It is reconsended that the response to Q3.6.2 be revised to state that "--cable in fully enclosed cable trays does not constitute an intervening combustible for Appendix R purposes."
Resolution:
The response to Q3.6.2 has been revised to affirm that cables in cable trays which have solid sheet metal bottom sides and top (and cables coated with a fire retardant material) are considered intervening combustibles. However, the response also describes the design and documentation conditions under which these "intervening combustibles" have been found acceptable under the axemption process, 1.1.15 Cosnent (F.3): Question 3.6.3 (Unexposed Combustibles)
"The response to this question states that oil in closed containers that conform to NFPA Standard 30 is not considered an intervening combustible, while oil in sumps is so considered. The Group believes that oil in closed sumps should be treated as equivalent to oil in NFPA Standard 30 containers, and therefore should not be classified as an intervening combustible. The Group does not object, however, to
- classifying oil in open sumps as an intervening combustible."
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Resolution:
The coment is valid. The requested revision has been made. -
1.1.16 Consnent (F.4): Question 5.3.8(HighImpedanceFaults)
The consnent questioned the need for including multiple high l impedance faults in associated circuits subject to fire damage in short circuit coordination studia3;Section III.G.2 of Appendix R was cited as expressly "not" requiring consideration of multiple high impedance faults.
Resolution:
The contnent is not valid.Section III.G.2 does require considera-tion of "hot shorts" and "shorts to ground," and these terms encom-pass high impedance faults. Given a major cable fire, multiple high impedance faults will probably occur. However, the response to Q5.3.8 was revised to clarify staff practice in regard to when short circuit coordination studies need or need not be performed. The revision also corrected the typographical error identified in the coninent.
1.1.17 Coment (F.5): Question 8.11 (Plants Licensed After January 1, 1979) l "The response to Question 8.11 states that plants licensed I after January 1, 1979 are subject to, inter alia, BTP CMEB 9.5-1. Some plants in this category, however, were licensed to the APCSB version of BTP 9.5-1 rather than the CMEB version.
There are some material differences between the two versions, and if a plant that was licensed to the APCSB version were required to follow the CMEB version, exemption requests and modifications could be necessary. We expect the response was merely an oversight on the Staff's part. We would reconinend modifying the response to Question 8.11 to read: 'BTP CMEB 9.5-1 or BTP APCSB 9.5-1, if so provided as part of a license condi-tion or licensing connitment, which includes....'"
Resolution:
The comment is valid. A revision has been made to clarivy this point.
1.1.18 Coment (F.6): Question 8.19(a)(ExemptionRequests)
"There appears to be an oversight in the response to Question 8.19(a). That response contains a cross-reference to the responses to Question 8.21.1 through 8.21.6, but the -
responses referred to do not appear in the document. We understand that the Staff will add the promised responses. The Group reserves the right to coment when these responses are provided."
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Resolution:
The cited cross-reference has been corrected to read "--response to Questions 8.19.1 through 8.19.4."
1.2 Duke Power Company: Letter from H. 8. Tucker to the Secretary of the Commission dated February 14, 1985. (Endorses the NUFPG comments and provides the following specific comments) 1.2.1 Coment (1): Quality Assurance Requirements The comment stt 9s that reference to GDC 1 of Appendix A to 10 CFR 50 in Section D of the proposed Generic Letter is clearly inappropriate, j and that "The QA program for fire protection should be reviewed to i requirements of the GDC 3, BTP or SRP as applicable."
l Resolution:
This is ir.cluded in the resolution of comment 1.1.4 above.
1.2.2 Coment (2): Question 3.2.1 (Fire Barrier Qualification -
Acceptance Criteria l
[
"Staff Position is that maximum heat transfer (sic) across a penetration seal, subjected to ASTM-E119 Fire Endurance test, is 325"F.
Comment - 1) ASTM-#119 criteria is 250*F above ambient which frequently is greater than 75'F. 2) Appendix R, Section IIY.M. states acceptance criteria for temperature as
...sufficiently below the cable insulation ignition temper-ature...'. This interpretation (the staff's position [added))
is clearly contrary to the intent and verbage of Appendix R."
Resolution:
- 1) The response to Q3.2.1 clearly states that 75'F is generally recognized as an acceptable nors. No revision is warranted.
- 2) Question 3.2.1 addresses criteria for qualification of cable tray fire wrap saterial while Section III.M.2 of Appendix R addresses criteria for qualification of cable penetration ;
seals. While Section III.M.2 is not explicitly applicable to I cable wrap saterial, applicability is implied. Therefore, we have revised the response to Q3.2.1 to clarify that a qualifi-cation criterion different than 325'F may be justified by an r
analysis demonstrating that the maximum recorded temperature is I sufficiently below the cable insulation ignition temperature. '
Also see resolution 1.3.1.
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"Staff Position is that '... cable tra l protected regardless (emphasis added)y supports of whether there isshould a be 1 sprinkler system. .. '.
position. If There is nosystem a sprinkler technical basis forand is provided thisfunctions arbitrary (as it is apparently given credit in reducing fire barrier rating from 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to I hour), the environment will be cooled below the temperature at which cable tray supports will be affected by heat fatigue.
In addition, each area should be reviewed individually to assess combustible loadings and other factors to determine if a potential fire could generate sufficient heat to affect cable tray supports."
Resolution:
The coment is not entirely justified in that the quoted portion of the staff position is preceded by "In general," and is followed ~
by two conditions (one based on qualification tests performed and the other on structural analysis performed) under which cable tray
(' supports need not *e protected. However, the staff agrees that a clarification reg . Jing the analysis to be performed is desirable.
The response to Q3.3.4 his been revised accordingly.
1.2.4 Coment (4): Question 3.8.4 (Control Room Fire Considerations)
The staff position in the response to Q3.8.4 does not reflect sta'ff practice during Appendix R inspections. j "The Staff Position is '...that the only manual action usually credited in the control room by this analysis is the reactor trip. Any additional control room actions deemed necessary would have to be justified under the exemption process.'
Comment - During a recent Appendix R inspection we demonstrated the control room abandonment portion of our Hot Standby Opera-tions procedure to Region II, ONRR and BNL representatives.
We demonstrated reactor trip turbine trip and main feedwater manual trips (in case automatic signals did not function properly). This is reasonable since the control room does not instantly become uninhabitable. There was no question during the inspection about the capability to trip all of the' subject systems therefore the new interpretation should be changed to agree with actions which have been reviewed and accepted."
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Resolution:
The coment is only partly valid in that it does not present the -
complete staff position on this issue. In the Appendix R inspection cited, although the actions taken in the control room prior to evacu-ation were demonstrated and found acceptable, this was conditioned on assurance being provided that such actions would not be negated by subsequent spurious actuation signals resulting from the postulated fire. Additionally, because of problems outside the control room, a successful demonstration of a smooth departure from the control room to the Safe Shutdown Facility to attain and maintain hot stand-by conditions was not accomplished. Therefore, the overall issue of control room evacuation is an open item in this Appendix R inspection.
The response to Q 3.8.4 has been revised to clarify the staff post-tion including the removal of the sentence "Any additional control room actions deemed necessary would have to be justified under the exemption process."
1.2.5 Concent (5): Question 5.1.3 (III.L Backfit)
"The question is Why do Staff Interpretation memoranda f (emphasis added) regarding the criteria for satisfaction of I Section III.L. fonn the auditable basis for determining com-
\ pliance to Appendix R...?
Comment - The response fails to address the rationale for considering Staff interpretative memoranda as part of the Rule.
If necessary, the Rule should be so amended."
, Resolution:
The response does provide the basis for the applicability of Section III.L of Appendix R. Because the bases cited in the response are deemed sufficient, there is no need for a rule change. Addition-ally, it should be noted that the explicit portions of "interpretive memoranda" describe methods acceptable to the staff for demonstra-ting confonnance to Appendix R. This does not preclude licensees from proposing and justifying other methods, e.g., see Section 1 Process Monitoring Instrumentation, of the Interpretations of Appendix R.
1.2.6 Coment (6): Question 5.2.4 (Post Fire Procedures Guidance Documents)
"The question pertains to Staff guidance documents of post fire operating procedures. The response is that there is no guidance other than criteria of Section III.L.
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Coment - Licensees need to know the criteria used for evaluating post fire shutdown procedures. In addition, without criteria how do various inspection teams plan to conduct consistent reviews?" -
Resolution:
It is our judgement that the responses to Questions 5.2.1, 5.2.2, and l 5.2.2 are appropriate and that the criteria for operating procedures I in III.L are sufficient. As indicated in the aforementioned '
responses the methods for meeting these criteria are the option of each licensee. The inspection process will be flexible in this regard as long as the licensee can show compliance with the criteria of Section III.L. The preceeding sentence has been added to the re-sponse to Q5.2.4.
1.2.7 Connent (7): Question 9.3 (NTOL Inspections)
"Response states that MTOL's will be subject to Appendix R inspections.
Connent - This is inappropriate for stations reviewed to l technical requirements of Standard Review Plan 9.5.1 which '
, differ significantly from requirements of Appendix R, Sections III.G and III.L."
Resolution:
The staff is aware of only one significant difference between ,
Sections I!!.G and III.L of Appendix R and the corresponding posi- I tions in BTP CMEB 9.5-1 which is part of Standard Review Plan 9.5.1. '
See response to Question 8.11 in "Appendix R Questions and Answers."
1.2.8 Coment (8): General Question "For stations previously inspected, will inspection results be modified to meet these new interpretations (i.e., will addi-tional findings evolve based on new published interpretations)?"
Resolution:
For plants previously inspected and which have no remaining open fire protection items in an Inspection Report already issued, the answer is no. For previously inspected plants where open items reain in an issued Inspection Report, the new interpretations will be used in subsequent inspections perfonned to close out the open items. In plants where an inspection has been made but the Inspection Report has not yet been issued, the new interpretations will be used as a basis for any findings. It is reconnended that the .
Steering Connittee include the preceeding resolut% 'n its report.
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1.3 Toledo Edison company: Letter (#1127) from R. P. Crouse to H. R. Denton dated February 14, 1985. (Endorses the NUFPG connents j and provides the following specific connents) . ,
1.3.1 Connent (1): Question 3.2.1 (Acceptance Criteria)
"The discussion in response to Question 3.2.1 of the draft I Generic Letter 85-01 states as follows (page 14): I
' Conduit and cable tray enclosure materials accepted by the NRC as I hour barrier prior to Appendix R (e.g.,
some Kaowool and 3M materials) and already installed l by the licensee need not be replaced even though they may not have met the 325'F criteria. However, new material should meet the 325'F criterion. Justifiestion of temperatures which exceed 325'F is required.'
It is Toledo Edison's detennination that the final quoted sentences should be modified to read, 'However, newly identified conduit and cable trays requiring such wrapping should use new material which meets the 325'F criterion '
~ or justification should be provided of temperatures ex-g ceeding the 325'F criterion.' )
\
Utilizing the different wording would prevent situations occurring, such as one conduit undergoing repair being partially wrapped by two differing materials."
Resolution:
The connent is valid. The proposed revision, with an editorial change, has been made. Also see resolution 1.2.2.
1.3.2 Coment (2): Question 5.3.8 (Short Circuit Coordination Studies)
"The response to Question 5.3.8, concerning Short Circuit Coordination Studies, states:
' Clearing such faults on non-essential circuits may be accomplished by manual breaker trips governed by written procedures.'
The word non-essential may allow misinterpretation with regard to essential vs non-essential circuits, Class 1E vs. Non-Class 1E circuits, etc. It is Toledo Edison's understanding that all loads not required to achieve and maintain safe shutdown, which may fault and cause high impedance ground fault tripping of the
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I supply breaker may be opened allowing reenergizing of the bus supply power. Toledo Edison, therefore, recomends that the words 'non-essential circuits' be removed and replaced by .
' associated circuits which may effect safe shutdown'." ,
l Resolution: l The recomended revision has been made. Also see resolution 1.1.16.
1.4 Boston Edison Company: Letter (BEco 85-037) from W. D. llarrington I to H. L. Thompson, Jr. dated February 22, 1985. (Requests a 30-day extension of the contnent period and provides the following specific coments) !
1.4.1 Coment (1): Schedular Relief The coment points out that a "living schedule" including fire pro-tection modifications beyond the 10 CFR 50.48 deadlines has been approved by the NRC. And that, therefore, l "The Steering Comittee reconsnendation to follow the schedule
-. dictated by 10 CFR 50.48 without granting the extensions already 1 filed with the NRC will make the fire protection modifications )
(
the highest priority. This will preclude the evaluation of other safety issues which could be equal or higher in safety priority than fire protection."
Resolution: )
,I The coment is valid. Section A of the proposed Generic Letter has been revised to clarify that schedular exemptions based on NRC )
approved "living schedules" are available and would be issued under 10 CFR 50.12. Also see resolution 1.1.1.
1.4.2 Coment (2): Question 3.6.2 (Intervening Combustibles)
Same as coment 1.1.14.
Resolution:
Same as resolution 1.1.14.
1.4.3 Coment (3): Question 4.1(IlluminationLevels)
"Section 4.1, "Illumination Levels", the clarification states i
'where a licensee has provided emergency lighting per Section !
!!!.J of Appendix R, we would expect that the licensee verify I by field testing that this lighting is adequate to perfom the -
intended tasks'. The term 'edequate lighting' could be inter- i preted differently by the licensee and the NRC inspection staff." l l
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Resolution:
It is expected that the licensee and NRC inspection staff would use -
reasonable engineering judgement to arrive at a mutually acceptable assessment of "adequate lighting." No revision to the Q4.1 response was deemed necessary.
1.4.4 Connent (4): Question 7.1 (Fire Protaction and Seismic Events)
"Item 7.1 of Enclosure 5 clarifies the guidelines for the seismic design of fire protection systems in relation to the reactor coolant pump lube oil system, and those situa-tions where seismic events are assumed tr. be initiators of a fire. The NRC response does not addreis the intent of the question but establishes guidelines for ;he seismic design of fire protection systems. Boston Edisin takes exception to this clarification and states that a seismic event is not considered concurrent with a fire and '.he fire protection systems are not seismically designed.'
Resolution:
/
g It is agreed that all or parts of fire suppression systems are not s seismically designed. The BTP positions cited indicate what con-siderations should be given to seismic design of these systems (Also, see response to Q7.2). Certain items, such as the RCP lube oil system and the hydrogen lines, were addressed specifically with regard to seismically induced fire. In both these cases, the fire protection measures specified do not involve a fire suppression system. The BTP CMEB 9.5-1 cited in the response does not apply to plants reviewed and approved prior to the issuance of that BTP.
The responses to Q7.1 and 7.2 have been revised to make this clear.
1.5 Northeast Utilities: Letter (A04606) from W. G. Counsil to H. R. Denton dated March 1, 1985. (Endorses the NUFPG connents and provides the following specific connents) 1.5.1 Connent (1): Proposed License Condition a) This connent quotes the following excerpt from Section II.
Regulatory Philosophy of NUREG-0S85 Issue 4. U. S. Nuclear l Regulatory Comission Policy and Planning Guidance 1985:
"The Connission intends to shift its regulatory emphasis away from detailed, prescriptive requirements toward l general design and performanca criteria."
and states that "While much of the fire protection policy steering cosinitt'te report runs contrary to the above quoted Consnission policy, the proposed license condition is the most -
significant one."
b) Section 2 of the proposed license condition would require a license amendment for minor changes to the fire protection program having no safety significance (Essentially the same as cossnent 1.1.10),
c) Section 3 of the proposed license condition would impose ,
reporting and review requirements for fire protection greater !
than those associated with other elements of operating a '
nuclear facility (Essentially the same as cosinent 1.1.11).
Resolution:
a) The staff acknowledges the merit of the cited Comission policy l guidance in general. However, it should be recognized that in the case of fire protection GDC-3 has provided "general design and perfonnance criteria", and that the regulation of fire protection requirements solely on that basis has proven in- !
effective.
( 1 As a result, the Comission detennined, after analyzing the re-sults of the Browns Ferry fire, that the more prescriptive re-quirements embodied in the BTP and subsequently in Appendix R ;
to 10 CFR 50 were necessary, and established the present i regulatory requirements. The proposed license condition adds, no new requirements. It only identifies in the license the fire protection program cossnitted to by the licensee and ac-cepted by the staff in previous reviews. It also includes an allowance for changes to be made to that program by the licensee without Consnission approval, and a method for keeping record of such changes.
b) See resolution 1.1.10. 1 c) See resolution 1.1.11.
1.5.2 Coninent (2)/ Resolution: Schedular Relief Same as coment 1.1.1, and same resolution.
1.5.3 Cosinent (3)/ Resolution: Quality Assurance Requirements Same as cocinent 1.1.4, and same resolution.
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l-1.5.4 Connent (4)/ Resolution: Documentation Required to Demonstrate Compliance Same as connent 1.1.3, and same resolution. -
1.5.5 Coment (Sa)/ Resolution: Question 3.2.3 (Fire Door Modifications)
Same as coment 1.1.13, and same resolution.
1.5.6 Connent (Sb): Question 3.1.1 (Fire Area Definition)
"The response to this question, referring to 10CFR50 Appendix R Section III.G.3.b. indicates that, for safety-related equipment and associated cabling the licensee must '(p)rovide the design criteria for protection of such equipment against inadvertent operation, careless operation or rupture of extinguishing systems.' In contrast the regulation itself addresses
' rupture or inadvertent operation of fire suppression systems.'
Reference (3) quoting 10CFR50 Appendix A General Design Criterion 3 (GDC) states '(f) ire fighting systems shall be designed to ensure that their rupture or inadvertent operation does not significantly impair the safety capability' of g safety-related equipment. We believe that the inclusion of s the additional criterion of ' careless operation,' is inappropri-ate. It is not clear what additional concern the NRC intends for licensees to address by inclusion of this tem."
Resolution: ,
The coment is valid. The words "careless operation" have been deleted.
1.6 KMC. Inc.: Letter from P. F. 41ehm to H. R. Denton dated February 14, 1985.
Comment / Resolution:
Same as coment 1.1.4, and same resolution.
1.7 Virginia power: Letter (85-113) from W. L. Stewart to H. R. Denton dated February 14, 1985.
Coment:
The comnent focused on the approach the Comission should take in achieving its fire protection goals rather than on specific mech-anisms for doing so. It states, based on experience, that fire protection "---is a living evolving issue that does not lend itself -
to definitive guidance nor swift compliance."
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- 20 -
Favorable views on the Steering Comittee recomendations are expressed as follows: l "We are encouraged by such recomendations as: establishing referees to resolve significant differences that arise during inspections, inspection team workshops, expediting inspections ,
to obtain a clearer understanding of the status of industry in ;
achieving compliance, and designating a central point of con- l tact within NRC to resolve internal conflict. We believe that recomendations such as these reflect not only our experience with fire protection, Dut indicate that NRC also recognizes ,
that guidance must continue to evolve, that interpretations i will change, and that exceptions to the regulations will arise l and need to be addressed."
However, the following reservations in regard to the recomendations are cited:
"On the other hand, we are concerned by such racomendations as: elimination of schedular exemptions, more aggressive and expedited-enforcement actions, and more regulation (i.e.
standard license conditions) and apparent new requirements ,
(e.g.meetingGDC-1). We believe that recomendations such as I (s '
these fail to recognize the nature of the fire protection issue.
It is not reasonable to expect that fire protection issues will be resolved and compliance will be achieved solely through mandate. The history of fire protection in the nuclear industry provides ample evidence to support this. Rather, they will be resolved and achieved through better understanding and continued I active comunication between NRC and industry. The issuance of ;
the Steering Comittee's policy recommendations for coment is a positive step in that direction and we encourage the NRC to ,
continue in this manner." l In sumary, the coment states:
"---and we encourage the NRC to adopt the Steering Comittee's policy recomendations that support resolution of fire protection issues through understanding and communications."
Resolution:
The coment is acknowledged. The approach being taken by the Steering Comittee is, we believe, in accord with the thrust of this coment and is consistent with the overall fire protection objectives of the Comission.
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1.8 New York Power Authority: Letter (IPN-85-08, JPN-85-15) from C. A. Neheill to H. R. Denton dated February 23, 1985. (Endorses the NUFPG comments and provides the following specific comments). -
Cannent/ Resolution: .
The connents are essentially the same as connents 1.1.1 and 1.1.2 (and 1.2.8), and 1.1.3, and the same resolution.
i 1.9 Georgia Power Company: Letter (NED-85-088) from L. T. Gucwa to H. R. Denton dated February 14, 1984. (Endorses the NUFPG connents l and provides the following specific connent). I l
Cumnent/ Resolution. ;
i Same as comment 1.1.2, and the same resolution.
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' UNITED STATES
, , ,/ jo,, "
- e. y g , p, NUCLEAR REGULATORY COMMISSIOB.
WAsmNGTON. D. C. 20555 t; *-, ,//, y e l
- "* JW- 9 1985 )
i
/l TO ALL POWER REACTOR LICENSEES AND ALL APPLICANTS FOR POWER REACTOR LICENSE:,
/
/
Gentlemen: [
SUBJECT:
FIRE PRO 1ECTION POLICY STEERING COMMITTEE REPORT (Generic Letter 85-01) l
~
Enclosed is a copy of the NRC Fire Protection Policy Steering Committee Report, dated October 26, 1984. The background and purpose of the Steering Committee is described in the report. A notice will be published in the Federal Reaister in the near future that will provide an opportuiity for public comments on this report. No response to this letter is required.
k or el T *I
. Ei Tihu t , ir o Division of c_e.n s i ng _
Enclosure:
As stated l
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- v. am
- Q 7 am
- gg.sao3; cs a. s...m c,;,.
vs
,..g'F
. n.s r s.es . r. . s:s appraisel when the crepis nc4 ',ip Ovt u ,.
'** ~"
-'*"9M h-e4 b-J.~ harvested beIore tbe harvesting ofne'r - nm.' -
ta-
. . .,. r, ", u . ,'c: . , ....i.n
,z
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, . .w, c au y ,
' peache.s beeo=ea seneralin tu.e cct:r)- - .
- - - no -Wao.?.C.** c m 2, rw ' "; c . .'- 3 and delete Appendix B. :i. .ic.R " :,. e ' 9 -
6-ser
~',.'- I '. " B M wc@1"*-%,,' M '*/ ? . 0 50
- FCICis souciting ce=Unemts c= this . Av _..* ' ',.....
'* - 3o' s .9.14 Oy:' m r.
. nd7.~.28 t.~m
- ns- - %*% / 7)
' proposed rue for 60 days after /,e L-Q .
- ="
' m .w y em zas
,e sw . . .:-n s,o- w m1 .m e 4.f us ::, ,..c.W %
.C.m rso . 2o c publicatica is the Tederal Re1;ister.. AD t,-
,.f.
.- .z, 4 7..; 4 .
. . ac. , =,
,yitten comments =ade pu suant t,o this,< 3eo . .. , .
- am. =ao ns ' - re.s -:= .-T v , .
- aetion wiU be available for pubbc :
inspectien is th: 05ce of the Ma:Yg er. - ' 7 Q *: . g h" '
- i g'!!) " e*
'T;$,p.y
. . ;p Federal Crep ir.su ance Corporaben. , '-N **
.- -e.,,,, .~sy . c - . . * .; a ,o -
~~ ' w *'r = = "*- a= %= **
- C .. ,. - ,o s
- , vs~eey.'. .*'*
Room 40o1. U.S. Dec ' art :ent of.' f , ' '*"*' g - t.
Ag-icultur, Weshington. D C, r.CC.
- v.
. rei.u c EiW.*.Whr3e :. '#.- ','
. '. *. tT "- - l ,
~ bey %l'# aid en aoy in F~ d' e' du ing regvlar.eastness hces. Metday , . ,,c.. j.,p . , ,.I w~ '.'.' p' '.: p' '.'/..
- -w ,6 u.:w. , , .nte rest rate towiU vary with.tbi rate annocated b
, &msh Fydays,,,,,, ..,,,,,,,,g ,, ,
,,,. g,,,..,.. :
i4 P'ut u1W' . I'} *
- b [:. b: h....q._,* .3 :.Ir5.k Secttary be Pod = acc:r?.1- c! the7rus :.ry.lsteru d n ude ths sec-3e.s , -
.} 3f ,.c.Af.,.et313 CTR . .i .. e c. .. . (3) * * *, ,
f, 2
- iia!bC U" C7CP > ear. _ M; ~- .}
.. ep t:sra:
Peaa s f, c :. f g,);, gn g,rvested Nfo'd 'the hard,,... t1.' . N 'i ^!:
f ;
. : ej.. . = . ' cf pes:hes he:c=e, geze:nl in thw;~ M; s % -N%'r.:W ; 6.5 .v.3:- <$
. c., w :. : . '
l F ART c r- A u E N D E D 4'-9' . country, c rj, . :. :d gs'(.,)f$,JJ -TXp'penit.$1Qe'pchh cent'imid,} *
" - heve '* ,] .,; l IN E. ~-We u cy a pe h.*'for par.ng you .r:. -'k .N'I.C8 C3 %,,is, Ac.::-?.i hy,prsuant to the audo'rity 7 i Doc e t : Wa thi=r.cr. nn oc h e =kr 1.,,l .
ccetalsed in tbe Tedera] Crep'I surance .inde=:i y wiiis 30 dap of oct a..;w ' sur.,4. _ ; . . . . . < ;m;. l- - . y , ,"lU, 3'2,
.. l
- ~ l Aca. a: a= ended (7 USC.1501 et set). .
the Federal Cre;> 1rtsura:ca Corporauen approvel of yocr cJai =.cr e=try of a m. g 7,tr. T.ceCW"r' i #.'.'Sc:re::r !;
. finaW.g neet against us. We w-iU.isC
.- ; imposes to ame .d the Peach Crop . '. - . tnstarte. be liable ior the pa y=ent of ;. * ; co pm ies ' yuf ^ . .
'"""'i,,
1:su.rance Regulat'oss (? GR Pzn 4c3). t -
f, damages. attomey's fee. or other - ./ Appn,,,a gla .9.W t-
' e!!ective for the 19E5 and succeeding chargo in connecuen with amy cla,un im,y,,,;,, . w,3g,7 ,-M n , ,.
crep years,in the fol!owing instaoces: lnde=rJty, whether we approve.cf- , gN- . _2/ib. , f--
- 1. Tne Autho-ity citatien - .'
Ior 7 CR disapprove such clai=L We wiD pay. cs -
-MW-&r:-t k 2 . e ' - : - '
. p,.t 43 is' . -- I'D W' @,2 9 ' .W,*'
d- ' '. * : sir . pit interest. bowever. computed en p Doc W1,147 FM, py' e.45 a e,) ,
A utMty. Secs. E 51e. Pub 1. 77-4315: the net Lode = i*y tdti=ately found to be -
due to you by us or by a final judg=ent . ** CCM N J,-
Sist 73.7t. ase:r.enced (7 USC.1FA 1516)-
frem and including the 21st day sher the T 7 CTR 433.7 is arnended by revising . date de insced sips, dates and ?- . ,
the introdt cto y test of pars; aph (dJc NUCLEAR RECULATORY ,, .,
sub,rnits to us the, properly completed and rnising the followi .g parts of tne cla:= for inde=nity fw=. If the res son . Cou p lSSION , . ,. ,. , - .
Peach Crep Lnsurance Pohey, the table .
I
- UO"*E'FWU,1 is not due lo your .r.:
in 4.(b) 9 (e)(3)(a) and 91. .totead:- f ailure to pronce tafor=ationer other .
.10 C FR P a rt 50 . ,, , , .
6,.,., -
.]
Insterialnecessery fctr the ce=putab.en T.
s Avaf.a%ty of HRO Ftre Protection l m N epa n e po .ey.. r . ' or psy- .ent of the inde=nity.Tne
'" Pc recy Steering Cornentnee Report For.
inte-esi rste wiU be that established by - * !
the Se=stary of the Treasury under Cormnerit ,, ' ,
(d)Tne application for the 1M5 and succeedmt cre; yea :is found at section 12 eithe Contract D:sputes Act Acter Nuclear Reh$1 story *.
Rubpan D of Pan 4x. .Cenent (41 USC et1) and publisbed in the Cor .rds sim * - -
'minist ative Re;ulatiens (7 CTR Tederal Kerf.stes.Trds rite is referred to A:P ac. Notice of ava.dsbihty of and
- .37. 4'mo) and
- nav be a nended as the"Eenetotiatioc' Board Inte est re;uest f r e =ments or. B e protecuen -
som t:=e to time for :ubsequent crop Rate and is published se=J atsuaUy os pohey rect: tmemdebens.
years. ne pronnierts of the Peach or about ]snuary 1 and juiy 1.The 8
r cc e.ra s.c p .cc , w...~..~..., . . . . . . . . , . . . . _.
. Je '
constrained is approve the application
' sui.uamr.The staff of the Nudear FEDERAL. RESERVE SYSTEM e, e based on the laeral definition of the Reculatory Commission is requesting .
term-bank"In the Bas Holding I public comment on the
- 12 CFR Part 225
- Company Act.The Board expreued Ha.
h' recommendations reade by the Fire @**"" 5*:
concern that the o.se of these limited -
Protecuan Poucy Steerimg Cor==ittee for. . '
purpose banks to avoid the objecdves of expediting compUance with fire ~ RegulaDon Y; Permissdie the Bank Holding C=cpaoy Act la protection reqdrememts. Transact $ona Between Bank N'ording
- . incor.s: stent with the tetection of Comparuas and Their Nonbank Eank 1
oarc Comment pen. od expires February Cet;res: and that the proliferates of g, .idades a
1 similar transacdons would seriously
.: 14. Isas. Commenta received aflee ths under=ime 6e policies of the Bank -
.a' rog'wcr. Board of Co'veman of the ..
J, date wiU be considend if it is Hold'ag Company Act. The Board found ,
practicable to do so but assurance for Fede alResene System (TRB).
k
! considerstion carrot given except.ai tv AcTiom Solicitation of public comments. that use of this device pre.sents the ~
l potential for a s%-ht. haphazard.
- cc==ents received before this date. . suwwaar.The Federal Resene Board is' and possibly dangenus alte-ation of the .
I
nation's barking st :cture without* .
Anoaess: Mail ec=mests to: Harold' R' soliciting cornment on whether the
( Boa ed should per=it bank holding Congressional ac:fon on the under!)ing 7 Denton.D! rector.05ce of Nudear .
- Reactor Regulation. U.S. Nuclear coinpanie that own rienbank policy issues. In dew ef these concerns.
- banks the Scard (icstitutions that an charter oppmved the app!ication i Regula tory Commission. Wa shingtes.
.; subject to the'foUowi g ccnditioes:
3 D.C. :3555. A"I l'N:* Document Control ~ " ' but which either do not accept demand,0-d (1) Appucant wodd not op
' deposits or t!o notmake coc.mercial 1- Desk. ' . ".- .*" , . ..
-* n'onbank bank's demand deposit taki:g .
ji. .
FOR MW NN cCMR 7 leam.s) to e: gage in certain innsactiord or establbh or continu'e certain '
activities in tandem with cny o0er
-subsidiary or other financial institutiorm Tt o=a s V. Wa=b.a ch.12 a d Project .- "arrangements with their co= bank bank g J (2) AppUcant would not link !.s any '
Manager. nre Protection. Nuclear ' subsidiaries. SpenSc. Uy. such .
q transacdons or arrangemes.ts would wgy the demand deposit and a Regdatory Commission. Washington...
cor::. men:iallending senices thal de!ise
~j D.C. 'm Fhone: (M1] G2-7072. include:...
e provis on of certalQ blemal
.c .
- a bank under th e Act and .P I sum m Extary tem AAho8C T. he{.,' " ad=:rustrabve senices to a combank * (3)The nonbank bank would g ,,_ gen, ,;g ,. cot- .
f Nudear Reg"A' cry Cocteusssas is,.
- -- . g gg. . , , g affiliates. other thas the pay: neat of-intending 1o redew and approve a. 2. Cootinuation'of trust senice and '
Pobey (cf expediti:- g coc:pleifoo of. . gm.Let memeet.s that existed dividends to App!!aat crthe irlusion of 4
- g. ccepUacca mth the Err protedsa; . : between a bank holding campany and . capital by Applica tinto de conbank require =ests for nude as power plasts . ' Its trust compamy s'ubsidiary prior to the bank, without the Bcerd's approval.
$ . These cceditfor.s were estabUshed to s includ;03 Appe dix R to 10 CFR Part 50. trm i company's conversion to a '
A Steeri:g Ccyee was appoi:::d by co:back bask: and . ensun that a no: bank bank wou!d be
. f=depe dest ohts a.5]i.afes a nd thst its
- the Ftecutiv,e Di.-e.or for Ope-aS :.s . 3. 05:ar and dincter'bterlocks.. banking a'ctivities wou'd cot be .. ..
.( and the Stee .:g Co==ittee issusd ,: carc All comments should be received btegrated with ecse ofits aEaus
. ] , reco=me::dat!c:s for the poucy to be; by the Board by Febn:ary14.1s85.
such that the inst!Ntion wculd be a adopted by the Co:.missics in a nport Aconess:All coc:.=ects, whide should - bank" under the Ad. The e c:nditj,ocs dated October :A.19H. ne 05cm cf,. . ' icler to Doc.k e t No. R-c538. should be
"'" OU.cded to preyent es asion of , e.
Nude as Re a:!ct Rep!alico (ONRR) is ., mai]ed to Wima m W. Wiles. Secre.Lary. - basic pobey of the Act to separate .
seeii..; co-mts on the proposed, ,g,. Board of Governori of the Federal ' ..- ba .k!:g and commerce acd to r:e,in policy. Copies of th'e Steering r-me' Res erve System. Washington. D.C. compUance wie the Act,s Maws o,s
/ Report an as aliable for inspectico and 20551.ce deUvered to Room B -m 20th Inugtate ban &gmus. 6e hamwon
- - 'l - copying at the NRC Public Docu=ent. & Consititution Aveoue. NW, - . was miended to establish a set af.
- Room.1717 H Stree t ,NW, We shirgton. Washi:gton. D.C. be tween L45 a.m. and nqulutsents applicable to the
.-#' 5.15 p.m. weekd.ays. Comments may be acquisit2on and operation of nonbank .
D.CJand Document Re.o=s at esch of theb the'vicinit located local Pubuc. ' !=spected 'y. in Room B.112.2 between &45 ba:ks,by both banking and conbaating
" of eac.h nudea'r po'wer plamt lic s .m. and 5:15 p.m. w e ek da y i. ... a .- .
organuations that wmuld assun that I-- carAcr. . J. g ggg g g ,,g 3:
under constructoc.ns(The Steen.e: Fon mm mmunow sed oc_
j -., Cocu=sttee Report ts an enclosure to , , Virgil Mattingly. Associate General independent and not inteerated into the Generic letter e.5-01. dated January 9.- Counsel (:02H524430). Carl Howard, parent's operations in suih a manner as 19!L5.) triforrtation regarding the location Senior Counsel (202/452-3786). or . to effect a combication of banking and f Melanie 1. Fein. Senior Attorney (202/ cornt:erce or otherwise prohibited
/ of Local Public Document Rooms can be 452-324). Legal Division. interstate deposit taking and j obtained by caHing the local Public .
. suretz utwTm inron w anoic On commercial len ding.
4 Document Room Eranch's toll free March:3.19M. the Board approved the FoHowing the Board's approval of the nurnber: 80H33-8031. U.S. 7mst application. a number of bard application by 11.S. Trust Corporatico to Da ted at Bedesda. Mar >%d. this 96 day holding compar.ie: applied to acquite consett its state chartered Florida trust of January 1st ~ ,
company into a nabonally chartered si. .ilar nonbank banks.The Board has for the Weiear Regdatory Comeu,sados. nonbank bank'* that would accept approsed several cf these applications
-- dernand ceposits and make consumer, to date, subject to de same conditions i
- Harold R., Des nn. .
a but not eejnmercial. loans an defined by established in its U.S. 7mst order.'
Director. 0!fics o/Nyclear Reactor the Board. U.S. 7mst Corporotion. 70 Regulation. Federal Res erve Bulletin 371 (19M). La its order approving the U.S. Tmst 7,[,[, [ g9
.N. [,I, son,.
[rR Doc. 65-115r FMed 1 14-45. 8 45 abl C--
aa ts-a coce rsa e s.4e application. the Board stated that it was 6
p 7, ,
I l
. ENCLOSURE 2 l GENERIC LETTER ON FIRE PROTECTION t
TO ALL LICENSEES AND APPLICANTS FOR OPERATING LICENSES Gentlemen:
SUBJECT:
IMPLEMENTATION OF FIRE PROTECTION REQUIREMENTS In the Spring of 1984, the Comission held a series of Regional Workshops on the implementation of NRC fire protection requirements at nuclear ,
power plants. At those workshops, a package of recently-developed NRC ;
guidance was distributed to each attendee which included NRC staff responses I to industry questions and a document titled "Interpretations of Appendix R." 1 The cover memo for the package explained that it was a draft package which l would be issued in final form via Generic Letter following the workshops.
The guidance approved by the Comission is appended to this letter, and 1 is in the same fonnat as the draft package. i.e., "Interpretations of l Appendix R" and responses have been modified from the draft package, and .
a number of industry questions raised at or subsequent..to the workshops l have been added .and_ answered. This package icirl.,agancy postt1on on<41 M asuse. covered, and " fren' prwiously issued. guidance (including- ~this subject, l this guidance takes ~ precedence. ;
In the lettered soctions below, some additional topics are covered which also bear on the interpretation and implementation of NRC fire protection requirements. The topics are: (A)schedularexemptions,(B) revised <
inspection program, (C) documentation required to demonstrate compliance, )
(D) applicability of GDC-1 to fire protection systems, and (E) notification of the NRC when deficiencies are discovered.
A. Schedular Exemptions The Appendix R implementation schedule was established by the Comission in 10 CFR 50.48(c), promulgated together with Appendix R in November of 1980. Allowing time to evaluate the need for alternative or dedicated shutdown systems, which require prior NRC approval before installation, ano time for design of and NRC review of such systems, the Consission envisioned that implementation of Appendix R would be complete in four i to five years, or approximately by the end of 1985, le ex- )
tassi
.- .the staff under ,
- I SO M , ~ 0 CR 50.12.-Me" tends l iets '1M7, Some licensees have proceeded expeditiously to implement l
Enclosure to GL 85-01, Re: Fire Protection Policy
Appendix R and are now finished or nearly finished with that effort.
Others have engaged in lengthy negotiations with the staff while continuing to file requests for schedule extensions, and thereby have barely begun Appendix R modifications needed to comply with Sections III.G and III.L. Schedule extension requests have been received seeking implementatit,a dates of 1,990, 4 p . , .
As the 50.48(c) schedule was intended to be a one-time schedule comencing in the 1980-1982 time frame and ending in the 1985 time frame, extensions well beyond this schedule (particularly where
. major modifications remain to be completed) undermine the purpose of the schedule, which was to achieve expeditious compliance with NRC fire protection requirements. The NRC will therefore grant no further extenrions-to the-50.44(c) schedulegy* Whos A licent '
hedule expTNf"f9lep11anerWeipeetW aw app'ropriatst 6f/
wi1 Tbs %Idg IFco6ST4ance caiinEt"be ach'thvet!'fy tha e, g the licensee wifi be required to submit and justify a minimum schedule for completion of fire protection modifications, and to supply interim measures to compensate for the lack of compliance. In submitting a schedule which goes beyond the current 50.48 deadline *, the licensee wi'il be required to demonstrate that it has endeavored in good faith to complete modifications on schedule. A showing of good faith attempt to complete implementation on schedule may mitigate .
enforcement action for noncompliance with NRC requirements.
The NRC is currently reviewing all dockets of plants covered by the ;. ,
50.48 schedule to detennine schedule deadlines. When this review is -
completed, each licensee will be informed of the deadlines. -
! B. Revised Inspection Program In 1982, the NRC developed an inspection program to verify compliance with the requirements of 10 CFR 50, Appendix R. This program was primarily oriented towards reviewing safe shutdown features of those pre-1979 licensees that had completed Appendix 'R modifications and selected NTOL plants. From 1982 to the present, approximately seven Appendix R compliance inspections have been performed. In a number of .
cases, these inspections have discovered that licensees had made signi-ficant errors in implementing a number of Appendix R requirements.
In order to expedite compliance verification and to provide the NRC staff with earlier indication of problems associated with implementation of fire protection features, the NRC will conduct fire protection inspections of operating plants and plants currently under-going operating license review during 1985 to include at least one Licensees submitting "living schedules" for NRC approval should be aware that existing 50.48 schedules continue to apply. Lice _nsees intending to include fire protection modifications within a "living schedule" are expected to assign within such schedules the relative safety priorities of remaining fire protection modifications.
Enclosure to GL 85-01, Re: Fire Protection Policy
.- . . - . - ..~ , - . , . - - , - , , .
I
_ j l
site from each licensee who has not been subject to a previous NRC fire protection inspection. This inspection will review com the casa otJgcamplete modifications,' pleted review licensep, _ans.and schedules forysopleting such modifications.+
~
C. Documentation Required to Demonstrate Compliance The "Interpretations" document attached to this letter states that, where the licensee chooses not to seek prior NRC review and approval of, for example, a fire ' area boundary, an evaluation must be performed by a fire protection engineer (assisted by others as needed) and retained for future NRC audit. Evaluations of this type must be written and organized to facilitate review by a person n.ot involved in the evaluation. Guidelines for what such an evaluation should contain may be found in: (1) Section 8 of Appendix R and (2) Section C.1.b of Branch Technical Position (BTP) CNEB 9.5-1 Rev. 2 dated July 1981; All calculations supporting the evaluation should be available and all assumptions clearly stated at the outset. FaH ere to have such an.
hastica available for an area where compf fMt(sttFAppendix RJs ,
strated will be taken as ima'f 'evidenceFthekthe a ' WTy with MRC requir .M
.Meeenforce- .
D. Quality Assurance Requirements Applicable I
^
Fira Wties Criterien S I'of Ap'ystans pendixmust A to meet thePart 10 CFR requirements of General 50.'. For such Design systems the licensee is therefore required to have and maintain a quality assurance program adequate to assure that these systems will perform their functions when called upon. Fire protection systems are not "safety-related" and are therefore not within the scope of Appendix 5 to 10 CFR Part 50, unless the licensee has cosmitted to include these systems under the Appendix B program p
for the plant. Mhc guidance for an acceptable quality assurance en for.e fire, protection systems, given-ir Section C.4 W 9 ranch T' pteetterSEtt.$1 Rev.2 datdJJiim,b gunmily been u
acceptance of approve 4} ire protection programs.
E.
Notification of the NRC When Deficiencies are Discovered Licensees are reminded of their obligation to notify the NRC of fire protection deficiencies which meet the criteria of 10 CFR 50.72 or 10 CFR 50.73 as applicable.
Enclosure to GL 85-01, Re: Fire Protection Policy
_ _ , - _ _ , . . _ , . _ _ _ _ ~ , - _ . - -
l 1
1 l
P Enclosure to GL 85-01e Re.
. Fire Protection Policy
l l
, ENCLOSURE 3 4
INTERPRETATIONS OF APPENDIX R I i
- 1. Process Monitoring Instrumentation l
Section !!!.L.2.d of Appendix R to 10 CFR Part 50 states that "the prncess monitoring function shall be capable of providing direct readings of the process variables necessary to perform and control" the reactivity control function. In IM Informattan Notice 84-09, the staff provides a listing of instrumentation acceptable to and preferred by thersteff to demonstrate cod @ffence with this provision. While this guidance provides an acceptable method for compliance with the regulation, it does not exclude other alter- i native methods of compliance. Accordingly, a licensee may propose to the j staff alternative instrumentation to comply with the regulation. While i such a submittal is not an exemption request, it must be justified based l on a technical evaluation. The licensee may also propose alternatives to actual compliance with the regulation (e7 g 1 ion whicW etesA l not 3 ^tirect reading of the pivGo 4WT8874 ,fi W r an exemption i
'ed6guate justification.
~ ~ ~
l
- 2. Repair of Cold Shutdown Equipment Section II~I.L.5 of Appendix R states that when in the alternative or. dedicated shutdown mode, "equipment and systems comprising the means to achieve and maintain cold shutdown conditions shall not be damaged by fire; or the fire damage to such equipment and systems shall be limited so that the systems can be made operable and cold shutdown can be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />."
This is not to be confused with the requirements in Section III.G.l.b of Appendix R.
Section III.G.l.b contains the requirements for normal shutdown modes utilizing the control room or energency control station (s) capabilities.
The fire areas falling under the requirements of III.G.I.b are those for which an alternative or dedicated shutdown capability is not being provided.
For these fire areas.Section III.G.1.b requires only the capability to repair the systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station (s) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, not the capability to repair and achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as required for the alternative or dedicated shutdown modes by Section III.L (noted above).
With regard to areas involving normal shutdown, however.Section I of Appendix R states that repairs must be made using only onsite capabilities.
After repairs are made, cold shutdown can be achieved on a reasonable !
schedule using any available power source. ~
l Enclosure to GL 8' Fire Protection Policy
~
-2
- 3. Fire Dr g ) \
Appendix R udCFR Part 50 utilizes the tens "frire of fire damage."
In promulgating Appendix R, the Comission has provided methods acceptable for assuring that necessary structures, systems and components are free {
of fire damage (see Section !!!.G.2a, b and c), that is, the structure. '
system or component under consideration is capable of performing its intended l function during ind after the postulated fire, as needed. Licensees seeking j exemptions from Jection III.G.2 must show that the alternative proposed provides reasonable assurance that this criterion is met. (Note also that Section III.G.2 applies only to equipment needed for hot shutdown.
Therefore, an exemption from III.G.2 for cold shutdown equipment is not needed.)
4 Fire Area Boundaries The tana "fire area" as used'in Appendik R mesar an area slifficiently bounded to withstane.the, hazardh associated with the area and, asJecessary, to, protect tuDertent' equipment within' the irR'YReTfW110tlide thir~ .
ared* In order to meet the regulation, fire area boundaries need not be completely sealed floor-to-ceiling, wall-to-wall boundaries. Houpverball unsea?ed openings should be identified and evA]upted. Wharc fire area boundarie: were not approved under the BTP processi or such boundaries am. net wall-to-wall, floor-to-ceiling etrations semigeWpftps'.settag requirrtf of-tlpe. sust, perform an evaluatielt43ssess the adequacy of.f.fra_ plants to determine if the boundaries will withstand the. bazards associated with the area and protect important equipment within the area froc a fire outside the area. This analysis must be performed by at least a fire protection enqineer and, if required, a systems engineer. Although not required, licensees may subntit their evaluations for staff review and concurrence.
In any event, these analyses must be retained by the licensees for sub-sequent NRC audits.
- 5. Automatic Detection and Suppression Sections III.G.2.b and III.G.2.c of Appendix R state that "In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area...' Other provisions of Appendix R also use the phrase "fire detectors and an automatic fire suppression system in the fire area..."
(see e.g.,Section III.G.2.e).
In order ta comply with these provisions, suppression and detect'on suf- -
ficient t -otect against the hazards of tMe area must be installed. In
- t. J4anapd. suppression tub 6gsta c >e - a to ensply with ths- ft"1 area suppression and detection is not installed. T 'aso$ perfom an evaluation to assess the adequacy of partial-suppmssierastS5$rtsetion to prot ~ect against the hazards in,,the area. The evaluation must be performed Enclosure to GL 85-01, Re: Fire Protection Policy
l by a fire protection engineer and, if required, a systems engineer. Although not required, licensees may submit their evaluations to the staff for review and concurrence. In any event, tha, evaluations must be retained for subsequent hRC audits. Where alicensee 15 provfding w soppression~ or detection, an exa ptfan sust be requested.
- 6. Alternative er Dedicated Shutdown Section III.G.3 of Appendix R provides for "alternative or dedicated shutdovii capability and its associated circuits, independent of cables, systets or I components in the area, room, or zone under consideration." While "in-dependence" is. clearly achieved where alternative shutdown equipment is out-stem fire area under consideration, this is nettetended,testaply that alternative shutdown equipment in the same fire. area ksCindependent of the room or the zone cannot result in compliance with the regulation. The "room" concept must be justified by submission of a detailed fire hazards analysis that demonstrates a single fire will not disable both normal shutdowr. equipment and the alternative shutdown capability.
Enclosure to GL 85-01, Re: Fire Prrtection Policy
l Enclosure to G!. 85-01, Re: Fire Protection Policy
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- , ENCLOSURE 4 GUIDANCE FOR ENFORCEMENT ACTIONS CONCERNING FIRE PROTECTION REQUIREMENTS .
- 1. General Guidance A. Fire protection requirements are delineated by 10 CFR 50 Appendix A General Design Criterion 3, 10 CFR 50.48, 10 CFR 50 Appendix R Facility License Conditions, facility technical specifications and other legally binding requirements, as applicable. A Notice of Violation will be issued for violation of requirements. However, failure to meet fire protection com-mitments will be designated as deviations.
B. Failures to meet regulatory requirements for protecting trains of equipment required for achieving and maintaining safe hot or cold shutdown are serious violations. The specific violations should be reviewed individually and as a group to determine their root cause(s). This guidance gives examples of violations at various severity levels and should be used to determine the appropriate enforcement action. For purposes of this guidance, recgired structures, systems, and components are those which are necessary to achieve and maintain hot and/or cold safe shutdown and which require the application of fire protection features as described in the licensee's fire hazards analysis report and safety evalua-tion report.
C. Fire protection violations may involve inoperable or inadequate:
fire barriers, separation, suppression or detection systems, repair parts, procedures or other conditions or items required to protect safe shutdown equipment from fire and/or permit the operation of safe shutdown eqaipment during a fire or to restore safe shutdown equipment to service following an actual fire.
D. Numerous violations of fire protection requirements which in-dividually may be classified at lower severity levels may cumulatively be classified at a higher severity level due to inadequate implamentation of the fire protection program.
Enclosure to GL 85-01, Re: Fire Protection Policy
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- 2. Severity Cateoories A. Severity I. Violations of fire protection requirements estab-lished to protect or enable operation of safe hot shutdown equip-ment concurrent with an actual fire which damages that equipment such that safe hot shutdown could not be achieved or maintained using the equipment dedicated for the purpose.
B. Severity II. Violations of fire protection requirements established to protect or enable operation of safe cold shutdown equipment concurrent with an actual fire which damages that equipment such that safe cold shutdown could not have been achieved and maintained i
'using the equipment dedicated for this purpose in accordance with I the applicable requirements. l C. Severity III. Violations of fire protection requirements established '
to protect or enable operation of safe shutdown equipment such f that a fire in the area could damage that equipment to the extent that safe hot or cold shutdown could not have been achieved and maintained using the equipment dedicated for this purpose in accordance with applicable requirements. Failure to have a written 1 evaluation available for an area where compliance with Appendix R l is not readily demonstrated will be taken as prima facie evidence that the area does not comply with NRC requirements ano may result in enforcement action at the severity level.
D. Severity IV. Violations of one or more fire protection requirements that do not result in a Severity Level I, II or III violation and <
which have more than minor safety or environmental significance. l E. Severity V. Violations of one or more fire protection requirements 1 that have minor safety or environmental Significance.
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Enclosure to GL 85-01, Re: Fire Protection Pnlicy
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. ENCLOSURE 5 I 1
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i FIRE PROTECTION LICENSE CONDITION i I
- 1. The licensee shall implement and maintain in effect all provisions 1 of the approved fire protection program as described in the Final i Safety Analysis Report for the facility and as approved in the SER 1 subject to provisions 2 and 3 below. l
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- 2. The licensee may make no change to the approved fire protection program which would decrease the level of fire protection in the plant without prior approval of the Commission. To make such a charge the licensee must submit an application for license amendment pursuant to 10 CFR 50.90.
- 3. The licensee may make changes to features of the approved fire pro- !
tection program which do not decrease the level of fire protection '
without prior Commission approval provided (a) such changes do not otherwise involve a change in a license condition or technical speci-fication or result in an unreviewed safety question (see 10 CFR 50.59), )
and (b) such changes do not result in failure to carry out the fire !
protection program approved by the-Commission prior to licence issuance. )
The licensee shall maintain, in an auditable form, a current record of i all such changes, including an analysis of thi effects of the change on the fire protection program, and shall make such records available to NRC inspectors upon request. All changes to the approved program made without prior Commission approval shall be reported annually to the Director of 1
-- the Office of Nuclear Reactor Regulation, together with supporting l analyses. )
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i Enclosure to Gl. 85-01, Re: Fire Protection Policy
APPENDIX R QUESTIONS AND ANSWERS d
- 1. INTRODUCTION -
- 2. OVERVIEW
- 3. III G, FIRE PROTECTION OF SAFE SHUTDOWN CAPABILITY 3.1 Fire Area Boundaries -
3.1.1 Fire Area Definition 3.1.2 Previously Accepted Fire Area Boundaries 3.1.3 Exterior Walls 3.1.4 Exterior Yards 3.1. 5 Fire Zones 3.1. 6 Documentation 3.2 Fire Barrier Qualifications 3.2.1 Acceptance Criteria 3.2.2 Deviations from Tested Cor. figurations 3.2.3 Fire Door Modiftcations
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3.3. Structural Steel ^-
3.3.1 NFPA Approaches 3.3.2 Previously Accepted Structural Steel 3.3.3 Seismic Supports 3.3.4 Cable Tray Support Protection 3.4 Automatic Suppression System I 3.4.1 Water Density 3.4.2 NRC Consultation 3.4.3 Sprinkler Location l 3.4.4 Fixed Suppression Systee In Fire Area 3.4.5 Sprinkler Head Location 3.4.6 {
Previously Approved Suppression Systees '
3.5 Separation of Redundant Circuits 3.5.1 Twenty-Foot Separation Criteria !
3.5.2 Floor-to-Floor Separation
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Appendix R 2 3.6 Intervening Combustibles 3.6.1 Negligible Quantities of Intervening Combustibles 3.6.2 In Situ Exposed Combustibles 3.6.3 Unexposed Combustibles 3.7 Radiant Energy Shields 3.7.1 Fire Rating
- 3. 8 Design Bases 3.8.1 Fire Protection Features NFPA Conformance 3.8.2 Design Basis Fire 3.8.3 Redundant Trains / Alternate Shutdown ;
3.8.4 Control Room Fire Considerations
- 4. I III J. EMERGENCY LIGHTING 4.1 Illumination Levels
- 5. III L, ALTERNATIVE AND DEDICATED SHUTDOWN CAPABILITY 5.1 Safe and Alternative Shutdown -
5.1.1 Previously Accepted Alternative Shutdown Capability 5.1. 2 Pre-Existing Alternative Shutdown Capability 5.1. 3 III L Backfit 5.2 Procedures 5.2.1 Shutdown and Repair Basis
- 5. 2. 2 Post Fire Operating Procedures 1 5.2.3 Alternative Shutdown Capability 5.2.4 Post Fire Procedures Guidance Documents 5.3 Safe Shutdown and Fire Damage
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5.3.1 Circuit Failure Modes 5.3.2 "Hot Short" Duration 5.3.3 Hot Shutdown Duration 5.3.4 Cooldown Equipment 5.3.5 Pressurizer Heaters 5.3.6 On-Site Power .
5.3.7 Torus Level Indication
. 5.3.8 Short Circuit Coordination Studies 5.3.9 Diagnostic Instrumentation 5.3.10 Design Basis P. lint Transients 5.3.11 Alternate / Dedicated Shutdown vs. Remote Shutdown Systems Enclosure to GL 85-01, Re: Fire Protection Policy F
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O ENCLOSURE 6 APPENDIX R QUESTIONS AND ANSWERS
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Appendix R 3 ,
- 6. III 0, OIL COLLECTION SYSTEMS FOR REACTOR COOLANT PUMP 6.1 Lube Oil System Seismic Design 6.2 Container
- 7. BRANCH TECHNICAL POSITION CMEB 9.5-1 l 7.1 Fire Protection and Seismic Events
- 7. 2 Randca Fire and Seismic Events !
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- 8. LICENSING POLICY I
8.1 Fire Hazards Analysis / Fire Protection Plan Updating 8.2 Fire Prote: tion License Condition -
8.3 III G. y and 0 Exemptions for Future Modifications 8.4 Future thenges
- 8. 5 Schedular and Blanket Exemptions 8.6 Trivial Deviations 8.7 Revised Modifications 8.8 Smallest Opening in a Fire Barrier 8.9 NFPA Code Deviations 8.10 "ASTM E-119" Design Basis Fire 8.11 Plants Licensed After January 1,1979 --
8.12 Cold Shutdown Equipment Availability 8.13 Guidance Documents -
8.14 Deviations from Guidance Documents 8.15 Staff Interpretations of Appendix R 8.16 Dissemination of New Staff Positions 8.17 Equivalent Alternatives 8.18 Coordination Study Updates 8.19 Exemption Request Threshold 8.19.L_. Panetration Designs Not Laboratory Approved 8.19.2 Individual vs. Package Exemptions 8.19.3 Exemption Request Supporting Detail . ,.
8.19.4 50.12 vs. 50.48 Exemption Requests I'"
8.21 Post January 1, 1979 Plants and Exemption Requests i l
8.22 NRC Approval for BTP CMEB 9.5-1 Deviations ;
- 9. INSPECTION POLICY 9.1 Safety Implications 9.2 Unifore Enforcement 9.3 NTOL Inspections Fnclosure to GL 85-01, Re: Fire Protection Policy
Appendix R 4
- 9. 4 Future TI 2515/62 Revisions -
9.5 Documentation Supplied by Licensee
- 9. 6 Subsequent Inspections
- 9. 7 NRC List of Conforming Items
- 9. 8 Inspection Re-review
- 9. 9 List of Shutdown Equipment a
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1 INTRODUCTION A major fire damaging safe shutdown equipment occurred at the Browns Ferry Nuclear Station in March 1975. The fire damaged over 1600 electrical cables and caused the temporary unavailability of some core cooling systems. Be-cause this fire did substantial damage, the NRC established a Special Review Group which initiated an evaluation of the need for improving the fire protection programs at all nuclear power plants. The group found serious design inadequacies regarding fire protection at Browns Ferry, and its report, "Recommendations Related to Browns Ferry Fire" (NUREG-0050, February 1976), contained over fifty recommendations regarding improve-ments in fire prevention and control in existing facilities. The rex .t also called for the development of specific guidance for imp.lementing fire protection regulations, and for a comparison of that guidance with the fire protection program at each operating plant.
NRC developed technical guidance from the technical recommendations in the Special Group's report, and issued those guidelines as Branch Technical Position Auxiliary Power Conversion Systems Branch 9.5-1 (BTP APCSB 9.5-1),
1/ "Guidelines for Fire Protection for Nuclear Power Plants." This guidance did not apply to plants operating at that time. Guidance to operating plants was provided later in Appendix A 2/ to BTP APCSB 9.5-1 which, to the extent practicable, relies on'BTP APESB 9.5-1. The guidance in these documen.ts was also published for public comment as Regulatory Guide 1.120, "Fire Protection for Nuclear Power Plants" (June 1976). In response to public comment, the NRC issued an extensively revised version of Regulatory Guide 1.120 for further public cosunent.
1/ Rather than serving as inflexible, legal requirements that must be followed by licensees, issuances such as regulatory guides and branch technical positions are meant to give guidance to licensees concerning those methods the sta'f finds acceptable for implementing the general criteria embodied in the NRC's rules. See
& Remedial Action, CLI-78-6, 7 NRC 400, E6 he. 8); -
. , Petition for Energency Gulf States Utilities Company (River Bend Station, Units 1 and 2) ALA8-444, 6 NRC 760, 772 (1977).
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- Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976. -
l Enclosure to GL 85-01, Re: Fire Protection Policy i _ . __ .. .. - - _ _ _ - - . - . . _ _ - - - - . - - - - - - -
2 In May 1976, the NRC asked licensees to compare operating reactors with BTP APCSB 9.5-1, and in September 1976, those licensees were informed that I the guidelines in Appendix A would be used to analyze the consequences of l a fire in each plant area. In September 1976 the licensees, were also requested to provide a fire hazards analysis that divided the plant into distinct fire areas and show that redundant systems required to achieve and maintain cold shutdown are adequately protected against damage by a fire. Early in 1977 each licensee responded with a Fire Protection Program I Evaluation which included a Fire Hazard Analysis. These evaluations and analyses identified aspects of licensnes' fire protection programs that did not conform to the NRC guidelines. Thereaf ter, the staff initiated discussions with all licensees aimed at achieving implementation of fire protection guidelines by October 1980. The staff held many meetings with licensees, conducted extensive correspondence with them, and visited every operating reactor. As a result, many fire protection items were resolved, and agreements were included in Fire Protection Safety Evaluation Reports issued by the NRC. Several fire protection issues remained unresolved with a number of licensees.
By early 1980, most operating plants had implemented most of the guidelines in Appendix A. However, as the Commission noted in its Order of May 23, 1980, the fire protection program has had some significant problems with implementation. Despite the staff's efforts, several licensees had expressed continuing disagreement with, and refused to adopt recommendations relating
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to several generic issues, including the requirements for fire brigade l size and training, water supplies for fire suppression systems, alternate I and dedicated shutdown capability, emergency lighting, qualifications of seals used to enclose places where cables penetrated fire barriers, and
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the prevention of reactor coolant pump lubrication systes fires. To estab-lish a definitive rosolution of these contested subjects in a manner con-sistent with the general guidelines in Appendix A to the BTP and to assure timely compliance by licensees, the Commission issued a proposed fire protection rule and its Appendix R, which was described as setting out l minimum fire protection requirements for the unresolved issues (45 Fed.
Reg. 36082 May 29, 1980). The fire protection features addressed included protection of safe shutdown capability, emergency lighting,. fire barriers, associated circuits, reactor coolant pump lubrication system, and alternate shutdown systems. The Commission stated that it expected all modifications (except for alternate and dedicated shutdown capability) to be implemented by November 1,1980.,4f 3/ 11 NRC 707, 718 (1980) 4/ Id. at 719 Enclosure to GL 85-01, Re: Fire Protection Policy 4
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3 As originally proposed (Federal Register Vol. 45. No. 1&S, May 22, 1980),
Appendix R would have applied to all plants including those for which the staff had previously accepted other fire protection modifications. After analyzing comments on the rule, the Commission determined that only three of the fifteen itees in Appendix R were of such safety significance that they should apply to all plants, including those for which alternative fire protection actions had been approved previously by the staff. These items are protection of safe shutdown capability (including alternate shut-down systees), emergency lighting, and the reactor coolant pump lubrication system. Accordingly, the final rule required ill reactors licensed to I operate before January 1, 1979, to comply with theaa three items even if the NRC had previously approved alternative fire protection features in However, the final rule these is moreareas flexible(45 than Fed. the Reg. proposed. 76602 ruleNov. 19, 1980)., Item III. G now p~rovides because three alternative fire protection features which do not require analysis to demonstrate the protection of redundant safe shutdown equipment, and )
reduces the acceptable distance in the physical separation alternative from fifty feet to twenty feet. In addition, the rule now also provides an exemption procedure which can be initiated by a licensee's as.sertion that any required fire protection feature will not enhance fire protection safety in the facility or that such modifications may be detrimental to overall safety (10 CFR 50.48(c)(6)). If the Director, Nuclear Reactor Regulation determines that a licensee has made a prima facie showing of a sound technical basis for such an assertion, then the implementation dates of the rule are tolled until final Commission action on the exemption request.
Most licensees requested and were granted additional time to perfom their reanalysis, propose modifications to improve post fire shutdown capability and to identify exemptions for certain fire protection configurations. In reviewing some exemption requests, the staff noted that some licensees had made significantly different interpretations of certain requirements.
These differences were identified in the staff's draft SER's. These differences were also discussed on several occasions with the cognizant l licensee as well as the Muclear Utility Fire Protection Group. These discussions culminated in'the issdince of generic letter 83-33. _ j Enclosure to GL 85-01, Re: Fire Prntection Policy
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- 2. OVERVIEW Section 50.48 Fire Protection 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 50. It specifies what should be contained in such a plan and lists the basic fire protection guidelines ,
for this plan. It requires that the Fire Protection Safety Evaluation l Report which has been issued for each operating plant state how these guidelines were applied to each facility. l Section 50.48 also requires that all plants with operating licenses prior l to January 1, 1979 satisfy the requirements of Section III.G, III.J and '
III.0, and other Sections of Appendix R where approval of similar features I had not been obtained prior to the effective date of Appendix R. By-a ,
separate action, the Commission approved the staff's requirement that all i plants to receive their operating license after January 1,1979 also sat- !
isfy the requirements of Sections III.G, III.J and III.0 and that a fire protection license condition be established. Deviations from Appendix R requirements for pre-1979 plants are processed under the exemption process. l Deviation from other guidelines are identified and evaluated in the Safaty '
Evaluation Report. --
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A standard fire protection license condition has been developed and will j be included in each new operating license. Present operating licenses ,
will be amended to include the standard license condition.
The Regions initiated inspections of operating plants and identified several significant items of non-compliance. The Nuclear Utility Fire Protection '
Group requested interpretations of certain Appendix R requirements and provided a list of questions that they thought should be discussed with j the industry. The NRC held workshops in each Region to assist the industry l in understanding the NRC's requirements and to improve the Staff's under- i standing of the industry's concerns. , a., ..
This document presents the NRC's response to the"qu'estions possd by the industry and supplemented with additional questions identified at the workshops as being of interest to the industry or the staff. These re-sponses may be used as guidance for design, review and inspection activi-ties. The questons have been reformatted according to their applic: ability to Sections of Appendix R, BTP t.MEB 9.5-1, licensing policy or inspection policy.
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- 3. SECTION III G, FIRE PROTECTION OF SAFE SHUTDOWN CAPABILITY 3.1 Fire Area Boundaries 3.1.1 Fire Area Definition Questien Section III.G states the fire protection features required for cables and equipment or redundant trains of systems required to achieve and maintain hot shutdown that are located within the same fire area. Is the fire area of Section III.G, the same fire area referred to in BTP APCSB 9.5-1, Appendix A; and the supplementary guidance of September 19767 ..
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Response
Yes. Prior to the issuance of Appendix R. fire area boundaries should have been established using the BTP guidelines. The concept of _ fire areas was described in BTP APCSB 9.5-1. Also, definitions were given for fire areas, fire barriers and fire ratings. The same fire areas were referred to in our supplementary guidance of 1977 and Appendix A to BTP APCS 8 9.5-1. The same fire areas concepts definitions are carried over to BTP CMEB 9.5-1.
During the "Appendix A" reviews, some licensees performed their fire hazards analysis using these definitions, some did not. Licensees sometimes called "fire zones" "fire areas."Section III.G sets forth fire protection alterna-tives within a fire area. If new fire areas are identified they should be established using the BTP guidelines.
The concept of fire areas was desc'ribed in BTP APCSB 9.5-1:
"C. Establishment and Use of Fire Areas The concept of separate fire areas for each division of safety equipment which requires redundancy will facilitate the installation of automatic water extinguishing systems since it will reduce the possibility of water damaging redundant safety-related equipment.
Fire areas should be established based upon the amount of combustible material present and considering suitably chosen design basis fires so that adequate protection can be provided for safety-related systems and equipuent. Design basis fires are those fires that result in the most severe exposure Enclosure tn GL 85-01, Re: Fire Protection Policy
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to the area or systems being considered. For this condition, it is assumed that no manual or automatic fire suppression action has been started and the fire has reached its peak I burning rate and involves all combustibles present.
Within each area special attention should be given to limiting the amount of combustible material and to providing effective barriers and fire resistive coatings to reduce the spreading of a fire in these areas. A design basis fire should be assumed and provisions should be made to limit the consequence of such a fire by providing fire barriers with suitable separation between redundant systems and components which are provided to carry out required safety functions. This separation is enhanced if the plant is divided into suitable fire areas since redundant safety equipment can then be placed in separate fire areas.
Particular design attention should be given to the use of separate isolated fire areas for redundant cables to avoid I loss of redundant safety-related cables. !
Provisions should also be made to limit the consequences of a fire by suitable design of the ventilation systems so that the spread of the products of combustion to other areas j of the plant is prevented. Means should be provided to :
ventilate or isolate the area as required. The power '
supply and controls for the area ventilation system should be from outside.the area, and the power and control cables should not pass through the area. l l
The fire detection systems should be designed using detectors of the right types at locations suitable to detect the l
particular type of fire expected in each area.
In the design, consideration should be given to provide personnel access to and escape routes from each fire area.
The emergency plans for all plants should lay out access and escape routes to cover the event of a fire in critical ,
areas of the plant."
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1 In addition, definitions of the basic fire area components l were given: i 1
"Fire Area - that portion of a building or plant that is l separated from other areas by boundary fire barriers (wells, i floors or roofs) with any openings or penetrations protected with seals or closures having a fire resistance rating equal to that of the barrier.
Fire Barrier - those components of construction (walls, floors and roofs) that are rated by approving laboratories in hours for resistance to fire to prevent the spread of fire.
Enclosure to GL 85-01, Re: Fire Protection Policy l
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Fire Rating - refers to the endurance period of a fire barrier or structure and defines the period of resistance to a standard fire exposure elapsing before the first critical point in behavior is observed. (Refer to NFPA 251).
Fire Zones - subdivisions of fire areas in which the fire suppression systems are designed to combat particular types of fires. The concept of fire zone aids in defining to the fire fighter the fire parameters and the actions which would be necessary."
The supplementary guidance, stated information to be provided in the fire hazards analysis for each fire area or fire zone established.
"In order to perform a proper fire hazards analysis, the services of a qualified fire protection engineer should be utilized. To demonstrate the results of the fire hazards
. analysis the following information must be provided:
- 1. Provide plan and elevation views of the plant that show the plant as divided into distinct fire areas.
Provide a description of the varicus systems, both safety-related and non-safety-related, which occupy the fire area and could provide cooling to the core to 1 safely shutdown the reactor, including decay heat removal. Provide a description of areas of the plant' l that contain radioactive material that may be released I to the exclusion area or beyond should a fire occur in those areas.
I For each fire area, provide the following:
a) Describe the fire barrier that defines the fire r area; the consequences of the design basis fire for that area; the consequences of the fire if the fire protection system functions as designed.
b) Identify the safety related equipment and associated cabling. Provide the design criteria for the fire protection related to such equipment. Provide the design criteria for protection of such equipment l against inadvertent operation, careless operation I or rupture of extinguishing systems, c) Provide a list of the type, quantity, and other pertinent characteristics of combustible materials i associated with each fire area. I d) Provide a list of the fire . loading which represent i the combustioles identified in (c) above for each fire area.
Enclosure to GL 85-01, Re: Fire Protection Policy
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v) Describe all the extinguishing and detection !
capabilities within each fire area. Discuss all l means for containing and inhibiting the progress of a fire, e.g. , the use of fire stops, coatings, curbs, walls, etc. Describe the extinguishing equipment outtide an area which has access to the area.
NOTE: If large fire areas are divided into fire zones for the purpose of fire protection, the above information should be provided for each zone. I l
- 2. Where redundant safety related equipment or cabling is !
located in a given fire area, describe the design features which prevent the loss of both redundant trains in a common fire, e.g., the separation provided by distance, physical barriers, and electrical isolation.
Where control, power or instrument cables of redundant systems used for bringing the reactor to safe, cold shutdown are located in the same cable trays, either ;
provide a bounding analysis demonstrating that the worst consequences as a result of a fire in the cable trays are acceptable or show that redundant systems -
recluired to achieve and maintain a cold shutdown are adequately protected against damage by the fire."
The guidelines for the fire rating of fire area bound-aries and their penetrations were given in Appendix A to BTP 9.5-1.
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"APPLICATION 00CKETED BUT CONSTRUCTION PLANTS UNDER CONSTRUCTION PERMIT NOT RECEIVED AS OF 7/1/76 AND OPERATING PLANTS (j) Floors, walls and ceilings enclosing (j) SAME. The fire hazard separate fire areas should have minism" in each eroa should be i fire rating of three hours. Penetrations evaluated to~ determine I in these fire barriers, including conduits barrier requirements.
and piping, should be sealed or closed to If barrier fire resis-provide a fire resistance rating at least tance cannot be made I equal to that of the fire barrier itself, adequate, fire detection Door openings should be protected with and suppression should be equivalent rated doors, frames and hardware provided, such as:
that have been tested and approved by a j nationally recognized laboratory. .Such (1) water curtain in doors should be normally closed and case of fire, locked or alarmed with alarm and annuncia- (ii) flame retardant tion in the control room. Penetrations for coatings, ventilation system should be protected by a (iii) additional fire l standard "fire door damper" where required. barriers." 1 (Refer to NFPA 80, "Fire Doors and Windows")
1 Enclosure to GL 85-01, Re: Fire Protection Policy l
9 3.1.2 Previously Accepted Fire Area Boundaries QUESTION If a fire area boundary was described as a rated barrier in the 1977 fire hazards analysis, no open itees existed in this area in the Appendix A SER, and the barriers have not been altered, then need those barriers be reviewed by licensees or the Staff under Appendix R?
RESPONSE
If a fire area boundary was described as a rated barrier in the 1977 fire hazards analysis, and was evaluated and accepted in a published SER, the fire ana boundary need not be reviewed as part of the re-analysis for compliance with Section III.G of Appendix R. Openings in the fire barriers, if any, should have been specifically identified and justified in the fire hazards analysis performed in the Appendix A process. If openings in the fire area boundaries were not previously evaluated, such an evaluation should be performed as a basis for assessing compliance with Appendix R. See Ites H of the "Interp n tations of Appendix R."
In BTP CMEB 9.5-1, Fire Barrier is defined as:
"Fire Barrier - those components of construction (walls, floors, and the supports), including beams, joists, columns, penetration seals or closures, fire doors, and fin dampers that are rated by approving laboratories in hours of resist-ance to fire and are used to prevent the spread of fire."
! The term "fire area" as used in Appendix R means an a na sufficiently bounded to withstand the hazards associated with the fire area and, as necessary, to protect important equipment within the fire area from a fire outside the area.
, In order to meet the regulation, fire area boundaries need not be completely sealed with floor-to-ceiling and/or 'vall-to-wall boundaries. Where fire area boundaries were not approved under the Appendix A process, or when such bound-artes an not wall-to-wall or floor-to-ceiling boundaries with all penetrations sealed to the fin rating nquired of the boundaries, licensees must perform an evaluation to assess the adequacy of fire area boundaries in their plants to determine if the boundaries will withstand ' % hazards associated with the area and protect important equipment within the area from a fire outside the area. This analysis
'; must be performed by at least a fire protection engineer .
and, if required, a systems engineer. Although not required, licensees may submit their evaluations for Staff review and concurrence. In any event, these analyses must be retained by the licensees for subsequent NRC audits.,
Enclosure to GL 85-01, Re: Fire Protection Policy
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3.1. 3 Exterior Walls QUESTION Must exterior walls to buildings and their penetrations be qualified as rated barriers?
RESPONSE
Exterior walls and their penetrations should be qualified )
as rated barriers when (1) they are required to separate a I shutdown-related division (s) inside the plant from its I redundant (alternate) counterpart outside the plant in the immediate vicinity of the exterior wall, (2) they separate safety related areas from non-safety related areas that present a significant fire threat to the safety related areas, or (3) they are designated as a fire barrier in the l FSAR or FHA. !
Usually exterior walls are designated as a fire area boundary; therefore, they are evaluated by the guidelines of Appendix A. A FHA should be performed to determine the rating of i exterior walls, if req'uired by the above criteria.
3.1. 4 Exterior Yards QUESTION How should a utility define the boundaries of fire areas comprising exterior yards?
RESPONSE
An exterior yard area without fire barriers should be con-sidered as one fire area. The area may consist of several firs zones. The boundaries of the fire zones should be '
determined by a FHA.
The protection for redundant / alternate shutdown systems-within a yard area would be determined on the bases of the !
largest credible fire that is likely to occur and the )
resulting damage. The boundaries of such damage would have I to bo justified with a fire hazards analysis. The analysis should consider the degree of spatial separation between 2 divisions; the presence of in-situ and transient combustibles. l including vehicular traffic; grading; available fire protec- l tion; sources of ignition; and the vulnerability and criti- I cality of the shutdown related systems. '
1 Enclosure to GL 85-01, Re: Fire Protection Policy
. 11 3.1.5 Fire Zones QUESTION Appendix R, Section !!!.G.3 states "alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area room or zone under consideration...." What is the implied utilization of a room or zone concept under Section III.G of Appendix R7 The use of the phraseology "area, room or zone under consideration" is used again at the end of the Section III.G.3. Does the requirement for detection and fixed suppression indicate that the requirement can be limited to a fire zone rather than throughout a fire area? Under what conditions and with what caveats can the fire zone concept be utilized in demonstrating conformance to Appendix R?
RESPONSE
Section III.G was written af ter NRC's multi-discipline review teams had visi+#r all operating power plants. From these audits, the NRC recognized that it is not practical and may be impossible to sebdivide some portions of an operating plant into fire areas. In addition, the NRC recognized that in some cases where fire areas are designated, it may not be possible to provide citernate shutdown capability
' independent of the fire area and, therefore, would have to be evaluated on the basis of fire zones within the fire area. The NRC also recognized that because some licensees had not yet performed a safe shutdown analysis, these analyses may identify new unique configurations.
To cover the large variation of pessible configurations, the requirements of Section III.G 'were presented in three parts:
Section III.G.1 requires one train of hot shutdown systems be free of fire damage and damage to cold shutdown systems be limited.
Section III.G.2 provides certain separation, suppression and detection requirements within fire areas; where such requirements are met, analysis is not necessary.
Section III.G.3 requires alternative dedicated shutdown capability for configurations that do not safisfy the requirements of III.G.2 or where fire suppressants released as a result of fire fighting, rupture of the system or inadvertent operation of the system may damage redundant equipment.
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Section !!!.G recognizes that the need for alternate or dedicated shutdown capability may have to be considered on the basis of a fire area, a room or a fire zone. The alter-native or dedicated capability should be independent of the ,
4 fire area where it is possible to do so (See Supplementary Information for the final rule Section III.G). When fire areas are not designated or where it is not possible to ;
have the alternative or dedicated capability independent of '
the fire area, careful consideration must be given to the selection and location of the alternative or dedicated shut- l down capability to assure that the performance requirement l set forth in Section III.G.) is met. Where alternate or dedicated shutdown is provided for a room or zone, the capability must be physically and electrically independent of that room or zone. The vulnerability of the equipment i and personnel required at the location of the alternative or dedicated shutdown capability to the envirtements pro-duced at that location as a result of the fire er fire suppressant's must be evaluated. These environments' may be dut to the hot layer, smoke, drifting suppressants, common ventilation systems, common drain systees or flooding. In addition, other interactions between the locations may be -
possible in unique configurations.
If alternate shutdown is provided on the basis of rooms or zones, the provision of fire detection and fixed suppression is only required in the room or zone under consideration.
Compliance with Section III.G.2 cannot be based on rooms or zones.
3.1.6 Documentation i
1 QUESTION l
In Generic Letter 83-33 at pg. 2, the NRC Staff referred to the guidance in Appendix A to BTP 9.5-1 to establish the i . rating of the barrier. What level of documentation must be l
, provided to verify that the fire area meets the requirements of Appendix R?
RESPONSE
The documentation required to verify the rating of a fire barrier should include the design description of the barrier and the test reports that verify its fire rating.
Reference can be made to UL listed designs.
Enclosure to GL 85-01, Re: Fire Protection Policy l
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13 3.2 Fire Barrier Qualification 3.2.1 Acceptance Criteria QUESTION Recently the Staff has applied a 325'F cold side temperature criterion to its evaluation of the acceptability of one-hour and three-hour fire barrier cable tray wraps. This criterion is not in Branch Technical Position (BTP) APCSB 9.5-1, Appendix A as an acceeptance criterion for fire barrier cable tray wraps and is not contained in Appendix R. It ,
appears to represent post-Appendix R guidance. What is the !
origin of this criterion and why is it applicable to elec- l trical cables where insulation degradation does not begin i until jacket temperatures reach 450*F to 650*F? '
RESPONSE
Fire barriers relied upon to protect shutdown related systems to meet the requirements of III.G.2 need to have a fire rating of either one or three hours. 550.48 references BTP APCSB 9.5-1, where the fire protection definitions are found.
Fire rating. is defined:
"Fire Rating - the endurance period o' a fire barrier or structure; it defines the period of resistance to a standard fire exposure before the 'first critical point in behavior is observed (see NFPA 251)."
The acceptance criteria contained in Chapter 7 of NFPA 251, "Standard Methods of Fire Tests of Building Construction and Materials," pertains to non-bearing fire barriers. l Thes*e criteria stipulate that transmission of heat through !
the barrier "shall not have been such as to raise the tem-perature on its unexposed surface more than PSO'F above its initial temperature." The ambient' air temperature at the beginning of a fire test usually is between 50*F and 90'F.
It is generally recognir.ed that 75'F represents an accept-able norm. The resulting 325'F cold side temperature criterion is used for cable tray wraps because they perform the fire barrier function to preserve the cables free of fire damage. It is clear that cable that begins to degrade at 450*F is free of fire, damage at 325'F.
Enclosure to GL 85-01, Re: Fire Protection Policy
14 During the Appendix A review, licensees began to propose i fire barriers to enclose cable trays, conduit, fuel lines, l coolant lines, etc. Industry did not have standard rating tests for such components or for electrical, piping or bus ,
. duct penetrations. The NRC issued a staff position giving l acceptance criteria for electrical penetration tests. These i criteria require an analysis of any temperature on the l unexposed side of the barrier in excess of 325'F. In the l past, manufacturers designed their own qualification tests. l Nuclear Insurers, and the Institute of Electrical and Electronic Engineers have issued tests for seen of these components. These tests usually exposed the component to the ASTM E-119 time temperature curve, but all had different acceptance criteria. Conduit and cable tray enclosure materials accepted by the NRC as 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> barrier prior to Appendix R (e.g. some Kaowool and 3M materials) and already installed by the licensee need not be replaced even though they may not have met the 325'F criteria. However, new material should meet the 325'F criterion. Justification of temperatures which exceed 325'F is required.
- 3. 2. 2, Deviations from Tested Configurations 00ESTION .
Due to obstructions.and supports, it is often impossible to achieve exact duplication of the specific tested configura- '
tion of the one-hour fire barriers which are to be placed around either conduits or cable trays. For each specific instance where exact replication of a previously tested configuration is not and cannot be achieved, is an exemption necessary in order to avoid a citation for a violation?
RESPONSE
No. Where exact replication of a tested configuration cannot ,
be achieved, the field installation should meet all of the l following crite'ria: ,
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- 1. The continuity of the fire barrier material is maintained.
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- 2. The thickness of the barrier is maintained. I l
- 3. The nature of the support assembly is unchanged from i the tested configuration.
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- 4. The application or "and use" of the fire barrier is unchanged from the tested configuration. For example, the use of a cable tray barrier to protect a cable tray which differs in configuration from those that were tested would be acceptable. However, the use of structural steel fire proofing to protect a cable tray assembly would not be acceptable.
- 5. The configuration has been reviewed by a qualified fire protection engineer and found to provide an equivalent level of protection. -
3.2.3 Fire Door Modifications QUESTION Where labeled and rated fire doors have been modified to incorporate security hardware or for flooding protection, is an exemption from Appendix R required?
R F.S PONS E Where a door is part of a fire area boundary, and the modf'-
fication does not effect the fire rating (for example, installation of security "contacts"), no further analysis need be performed. If the modifications could reduce the fire rating (for example, installation of a vision panel),
the fire rating of the door should be reassessed to ensure that it continues to provide adequate margin considering the fire loading on both sides.
An exemption is required if fi.re doors installed iii a fire barrier used to satisfy Section III.G.2 are modifitd such that the labeled rating no longer applies.
3.3 Structural Steel 3.3.1 NFPA Approaches QUESTION 2
Does the NRC's definition of structural steel supporting fire barriers completely accomodete approaches described in NFPA guidance documents and standards?
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RESPONSE
The NRC does not define the structural steel supporting fire barriers. This steel is identified by the licensee.
Our position regarding the need to protect the structural steel, which forms a part of or supports fire barriers, is consistent with scund fire protection engineering principles as delineated in both NFPA codes and standards, and The Fire Protection Handbook.
3.3.2 Previously Accepted Structural Steal QUESTION e
Is it necessary to protect structural steel in existing fire barriers where those barriers were approved in sn Appendix A SER?
RESPONSE
No.
3.3.3 Seismic Supports OVESTION Does structural steel whose sole purpose is to carry dynamic loads from a seismic event require protection in accordance with Section III.G.2a of Appendix R7
RESPONSE
No3 unless the failure of any structural steel member due to a fire could result in significant degradation of the fire barrier. Then it must be protected.
3.3.4 Cable Tray Support Protection QUESTION Should cable tray supports be protected if there is a sprinkler system in the fire area? Under what conditions ,
l G- cable tray supports be unprotected? Do unprotected I supports require an exemption?
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RESPONSE !
In general, cable tray ;npports should be protected, regard- ,
less of whether there is a sprinkler system. If (1) the ;
qualification tests were performed on wrapped cable trays J with unprotected supports, and the supports are shown to be adequate, or (2) a structural analysis is perfomed which deionstrates failure of the unprotected support (s) will not cause a loss of the cable tray fire barrier, then they need not be protected.
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An exemption is not required; however, the qualification tests and applicability or the structural evaluation should -
be documented and available for audit.
3.4 Automatic Suppression System 3.4.1 Water Density QUESTION l
Staff guidance provided in Generic Letter 83-33 concerning I automatic suppression coserage of fire areas interprets the phrase "in the fire area" in Section III.G as meaning "throughout the fire area." What dalivered water density or occupancy standard as specified in NFPA-STO-13 must be l achieved to meet this guidance? j 1
RESPONSE
l Individual plant areas are diverse in nature. The desi;;ner should determine the particular water density or occupancy classification. Those areas which contain a limited quan- l tity of in-situ and anticipated transient combustibles and l which feature contents such at tanks and piping, may be considered as "Ordinary Hazard (Group 1)", as defined by NFPA Standard No. 13. For those areas containing large amounts of cables or fiammable ldquids, an occupancy class-ification of "Extra Hazard" may be warranted. The decision as to which classification should be applied should be made by a qualified fire protection engineer.
Once the cccupancy classification is determined, th minimum water density should be f ted on the Density Curvu in table 2.2.l(B) of NFPA 13. An; -nsity equal to or in excess of the curves would be in conformance with our guidelinas as delineated in Section C.6.c of BTP CMEB 9.5-1.
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3.4.2 NRC Consultation QUESTION Section 4.1.2 of NFPA-STD-13 allows for "partial installa-tions" or partial coverage. The standard states that "the authority having jurisdiction shall be consulted in each case." With the NRC 'as authority in this instancs, must consulation occur only through the exemption process?
RESPONSE
No. The staff is always available to consult with utility representatives and provide guidance as to the acceptability of a particular fire protection configuration in individual plant arets.
3.4.3 Sprinkler Location QUESTION How does a suppression system designer know whether th*
term "throughout the area" means that sprinkler heads c it be above or below cable trays when, in his judgment, the hazard of concern is a floor based fire?
RESPONSE
Section C.6.c(3) of BTP CMEB 9.5-1 states:
"(3) Fixed water extinguishing systies should conform to requirements of appropriate standards such as NFPA-13 "Standard for the Installation.of Sprinkler Systems,"
and NFPA-15. "Standard for Water Spray Fixed Systems"."
This question pertains to those sprinkler systems covered
, by NFPA-13. Chapter 4 of NFPA-13 provides guidance as to the location of sprinkler heads in relation to common obstructions. In general, to achieve complete area-wide coverage, sprinklers should be located at the ceiling, with additional sprinklers provided below significant obstructions such as wide HVAC ducts and "shielded" or solid bottoe stacked cable trays. To the extent that an existing or proposed i sprinkler system design deviates from this concept, the l design would have to be justified by a fire hazards analysis. i Enclosure to GL 85-01, Re: Fire Protection Policy
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19 3.4.4 Fixed Suppressinn System In Fire Area QUESTION Are fixed supprossion systems required by Section III G.3 to be throughout the fire area, room or zone under consideration?
RESPONSE
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No, but partial coverage must be properly justified and documented.
See Item #5 of the "Interpretations of Appendix R."
... suppression less than full area coverage may be adequate to comply with the regulation. Where full area suppression and detection is not installed, licensees -must perform an evaluation to assess the adequacy and necessity of partial suppression and detection in an area. The evaluation must be performed by a fire protect'on engineer and, if required, a systems engineer. Although not required, licensees may submit their evaluations to the staff for review and concurrence. In a'ny event, the evaluations mu:2 ne retained for subsequent NRC audits..."
3.4.5 Sprinkler Head Location QUESTION If stacks of horizontal or vertical cable trays extend from ceiling to fl. , are sprinkler heads required (1) under the lowest horizontal trays, near the floor for vertical trays; (2) at some intermediate level between the floor and ceiling, and (3) at the ceiling? ,
Rf5PONSE Sprinkler heads should be located at the ceiling. Sprinkler heads at other locations may be necessary depending upon the hazard and the cumulative effect of the obstructions to the discharge of water from the sprinkler head. The sprinkler system design should meet NFPA 13.
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3.4.6 Previously Approved Suppression Systems QUESTION i Must suppression systems approved and installed under BTP APCS 8 9.5-1, Appendix A be extended or altered to meet the total area requirements of Section III.G (as interpreted by the Staff) or does this "requirement" only apply to new .
installations? ]
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RESPONSE
feuppression systems installed in connection with Appendix A may or may not have to be extended as a result of III.G.
The licensee must analyze each area where suppression is required by III.G and where only partial suppression has 1 been provided, determine if the coverage is adequate for i the fire hazard in the area. The licensee may consult with '
the staff during this review. In any event, the Appendix R ,
analysis showing that the suppression provided is adequate i must be retained and available for NRC audit.
3.5 Separation of Redundant Circuits 3.5.1 Twenty-Foot Separation Criteria QUESTION i
Assuming that a licensee is utilizing the 20-foot separation for circuit protection, could an exemption equest be granted '
for a portion of the circuit that did not maintain the 20-foot minimum separation if that portion was protected by one-hour barrier until 20-foot was achieved? This barrier
. would not be firewall-to-firewall, and the circuit protection !
would not be claimed under the one-hour barrier rule. '
RESPONSE
l With the erection of a partial qualified one-hour rated barrier for portiont of the circuits with less than 20 ft.
separation, if 20 feet of horizontal separation existed between the redundant unprotected portions of the circuits without intervening combustibles or fire hazards, and if I the fire area was protected by automatic fire detection and suppression, compliance with Section III.G.2.b would be achieved.
These types of configuration have to be evaluated on a j case-by-case basis, l I
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. l 21 3.5.2 Floor-to-Floor Separatic, QUESTION Where redundant circuits are separted by floor elevation
. but are within the same fire area due to open hatchways, stairs, etc., what is the NRC's position with regard to separation criteria? If train A is located twenty feet from an open hatchway on the lower elevation and train B is located' ten feet from the same' opening on the next elevation, would this be considered adequate separation?
RESPONSE
If a wall or floor / ceiling assembly contains major unprotected ,
openings such as natchways and stairways, then plant loca- l tions on either side of such a barrier must be considered !
as part of a single fire area. Refer to the staff position I on Fire Areas in Generic Letter 83-33.
1 As tc the example provided, if train A was separated by a j cumulative horizontal distance of 20 feet from train B, .
with no intervening combustible materials or fire hazards, !
and both elevations were provided with fire detection and '
suppression, the area would be in compliance with Section III.G.2.b.
3.6 Intervening Combustibles .
3.6.1 Negligible Quantities of Intervening Combustibles QUESTION 1
Twenty feet of separation with absolutely no intervening '
combustibles is a rare case in most nuclear plants. What !
is the most acceptable method of addressing intervening '
combustibles? How are various utilities addressing this subject, and what would be sufficient justification to support an exemption request?
RESPONSE
If more than negligible quantities of combu:tible materials (such as isolated cable runs) exist between redundant shut-down divisions, an exemption request should be filed.
["Negliaible quantity" is an admittedly 'udgmental j criterion, and this judgment should be made by a qualified fire protec-tion engineer and documented for later NRC audit.] Justif-ications for such exemptions have been based on the following factors:
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- 1. A relatively large horizon}al spatial separation between redundant divisions; all cables qualified to IEEE-383.
- 2. The presence of an automatic fire suppression systee over the intervening combustible (such as a cable tray fire suppression systes);
- 3. The presence of fire stops to inhibit fire propagation in intervening cable trays;
- 4. The likely fire propagation direction of burning inter-vening combustibles in relation to the location of the vulnerable shutdown division;
- 5. The availability of compensating acti,ve and passive fire protection.
Any future changes in the cable configuration due to modif-ications could be handled under 50.59. See the provisions of the license condition in the response to question 8.2.
3.6.2 In-Situ Exposed Combustibles -
QUESTION Within Appendix R,Section III.G.2.b, the phrase "twenty feet with no intervening combustible or fire hazards" is utilized. What is the definition of "no intervening combus-tible"? Is the regulation focused predominantly on the absence of fixed combustibles?
RESPONSE
There is no specific definition of "no intervening combus-tible." The regulation is focused on the absence of in-situ exposed combustibles. Non combustible materials would not be considered as intervening combustibles.
In BTP CMEB 9.5-1, noncombustible material is defined as:
"Noncombustible Material
- a. A material which in the form in which it is used and under the conditions anticipated, will not ignite, burn, support combustion, or release flammable vapors when subjected to fire or heat.
Enclosure to GL 85-01, Re: Fire Protection Policy
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' b. Material having a structural base of noncombustible material, as. defined in'a. , above, with a surfacing g'
T not over 1/8-inch thick that has a flame spread rating G not higher than 50 when measured using ASTM E-84 Test g
"Surface Burning Characteristics of Building Materials."
In Generic Letter 83-33, we state:
) "Staff Position: Section III.G.2.b requires the "separation
... with no intervening combustibles ..." To meet this Q M requirement, plastic jackets and insulation of grouped
,a Q h electrical cables, including those which are coated, should be considered as intervening combustibles." -
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For fire protection, "no intervening combustibles" means g
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that there is no significant quantities of in-situ materials which will ignite and burn located between redundant shutdown systems. The amount of such combustibles that has signifi-
\ cance is 7. judgmental decision. As with other issues, if the licensees fire protection engineer is concerned that i '
5 the quantity of combustibles between shutdown divisions may D([
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.r not be considered insignificant by an independent reviewer, an exemption could be requested, or the staff consulted.
Transient materials are not considered as an intervening i combustible; however, they must be considered as part of l
$ the overall fire hazard within an area.
Coated cables with a fire retardant material are also considered as intervening combustibles.
3.6.3 Unexposed Combustibles
,UESTION Q
Are unexposed combustibles, such as oil in sumps, closed cans, or sealed drums, or electrical cable in conduits, considered as "intervening combustibles"?
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RESPONSE
Only oil in closed containers which are in accordance with l NFPA 30 or electrical cables in conduits are not considered as intervening combustibles. In situ oil in sumps is con-sidered to be an intervening combustible. l Enclosure to GL 85-01, Re: Fire Protection Policy
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3.7 Radiant Energy Shield 3.7.1 Fire Rating QUESTION Recently, the NRC Staff indicated that non-combustible radiant energy shields should be tested against ASTM-TD-E-119 based, apparently, on the requirements of BTP CMEB 9.5-1, Rev. 3, a document issued after Appendix R was promulgated.
This new requirement would not appear to be required by Appendix R or BTP APCSB 9.5-1 Appendix A. Could the Staff clarify the requirements in this area?
ANSWER During the Appendix A reviews, we observed that inside some containments, there were large concentrations of cables ,
converging at electrical penetration areas. In some !
cases, where the penetrations were grouped by division, shields were placed between the divisions so that radiant l energy from a fire involving the cables of one division would not degrade or ignite cables of the other divisions.
These shields also directed the convective energy from the fire away from the surviving division. These shields were usually constructed of 1/2-inch marinite board in a metal frame. Appendix R,Section III.G.f refers to these shields i as "a noncombustible radiant energy shield." The guidelines in BTP CMEB 9.5-1, Section C.7.a(1)b. indicate that these l shields should have a fire rating of 1/2 hour. In our '
opinion any material with a 1/2 hour fire rating should be capable of performing the required function.
The guidelines of BTP CHEB 9.5-1 relating to a firerated radiant energy shield are being considered in our current reviews of NTOL plants. However, to the extent that an I applicant can justify that a proposed radiant energy shield can achieve an equivalent level of safety, we have been accepting shields that have not been tested against the acceptance criteria of ASTM E-119.
In our Appendix R reviews, we have accepted non-fire rated radiant energy shields that have been demonstrated by fire hazards analysis to provide an acceptable level of protection against the anticipated hazard of a localized fire within the containment. We have also accepted fire-rated metal-sheathed mineral insulated cables, as a radiant energy shield in specific configurations.
Enclosure to GL 85-01, Re: Fire Protection Policy
25 3.8 Desian Bases 3.8.1 Fire Protection Features NFPA Conformance QUESTION Should the fire protection features required by Section III.G conform to the NFPA Codes?
RESPONSE
Yes. For example,Section III G.2 requires an automatic suppression system. Our guidelines would recommend that i the system be in accordance with an NFPA Code. If deviations are made from the Code, they should be identified in the ,
3.8.2 Design Basis Fire QUESTION Why isn't the industry allowed to design to protect against a design basis fire?
RESPONSE -
Neither the industry nor the Staff has been able to develop criteria for establishing design basis fire conditions because the in-situ and potential transient combustibles vary widely in different areas of the plant. l 3.8.3 Redundant Trains / Alternate Shutdown QUESTION Confusion exists as to what will be classified as an alternate shutdown system and thus what systems might be required to be protected by suppression and detection under Section III.G.3.b. For example, while we are relying upon the turbine-building condensate system for a reactor building fire and the RHR system for a turbine building fire, would one system be considered the alternative to the other. If so, would suppression and detection be required for either or both systems under III.G.3.b? An explanation of alternative shutdown needs to be advanced for all licensees.
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RESPONSE -
If the system is being used to provide its design function, it generally is considered redundant. If the system is being used in lieu of the. preferred system because the redundant components of the preferred system does not meet the separation criteria of Section III.G.2, the system is considered an alternative shutdown capability. Thus, for the example above, it appears that the condensate system is providing alternative shutdown capability in lieu of separa-ting redundant components of the RHR System. Fire detection and a fixed fire suppression system would be required in the area where separation of redundant components of the RHR system is not provided. However, in the event of a turbine building fire, the RHR system would be used for safe shutdown and is not considered an alternative capability.
However, one train of the RHR system must be separated from the turbine building.
3.8.4 Control Room Fire Considerations QUESTION What considerations should be taken into account in a control room fire? What is the damage that is considered? What actions can the operators take before evacuating the CR?
When can the control room be considered safe after a fire for the operator to return?
RESPONSE
The control room fire area contains the controls and instru-mental redundant shutdown systems in close proximity (i.e.
usually separation is a few inches). Because it is possible to provide shutdown capability that is physically and electrically independent of the fire area, it is our opinion that alternative or dedicated shutdown capability and its associated circuits for the control room be indepen-dent of the cables system and components in the control room fire area.
The damage to the system in the control room for a fire that causes evacuation of the control room cannot be pre- i dicted. A bounding analysis should be made to assure that l safe conditions can be maintained from outside the control l room. This analysis is dependent to the specific design. l The usual assumptions are: '
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- 1. The reactor is tripped in the control room.
- 2. Of fsite power is lost as well as automatic starting of the onsite a.c. generators and the automatic function of valves and pumps whose control circuits could be -
affected by a control room fire.
The analysis should demonstrate that capability exists to manually achieve safe shutdown conditions from outside the control room by restoring a.c. power to designated pumps,
, assuring that valve lineups are correct, and assuming that any malfunctions of valves that permit the loss of reactor coolant can be corrected before unrestoreable conditions occur. -
Note that the only manual action usually credited in the control room by this analysis is the reactor trip. Any additional control room actions deemed necessary would have to be justified under the exemption process.
After the fire, the operators could return to the control room when the following conditions have been met.
- 1. The fire has been extinguished and so verified by 4 appropriate fire protection personnel.
- 2. The control room has been deemed habitable by appropriate fire protection personnel and the shift supervisor.
- 3. Damage has been assessed and, if necessary, corrective ,
action has been taken to assure necessary safety, I control and information systees are functional (some I operators may assist with these tasks) and the shift supervisor has authorized return of plant control to the control room.
- 4. Turnover procedures which assure an orderly transfer of control from the alternate shutdown panel to the control room has been completed.
Af ter 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 would not be available. Smoke and fire suppressant damage in other areas (cabinets) must also be assessed and correc- i tive action taken before controle in such cabinets are deemed functional. Controls in undamaged area (cabinets) could be operated as required. Minor modifications inside the control room may be parformed to reach cold shutdown.
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- 4. EMERENCY LIGHTING 4.1 Illumination Levels QUESTION What is the eequisite intensity level for emergency lighting for egress routes and areas where shutdown functions must be performed? What are the bases for determining these levels of lighting? j 1
ANSWER The level of illumination provided by emergency lighting in access ;
routes to and in areas where shutdown functions must be performed is l a level that is sufficient to enable an operator to reach that area '
and perform the shutdown functions. At the remote shutdown panels !
the illumination levels should be sufficient for control panel ;
operators.
The bases for estimating these levels of lighting are the guidelines contained in Section 9.5.3 of the Standard Review Plan, which are based on industry standards (i.e. , Illuminating Engineering Society Handbook).
Where a licensee has provided emergency lighting per Section III.J of
. Appendix R, we would expect that the licensee verify by field testing that this lighting is adequate to perform the ir. tended tasks.
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29
- 5. ALTERNATIVE AND DEDICATE 0 SHUTOOWN CAPABILITY 5.1 Safe and Alternative Shutdown 5.1.1 Previously Accepted Alternative Shutdown Capability QUESTION -
As part of the Appendix A review process, some plants had ,
committed to an alternative shutdown system in the form of a remote shutdown panel or remote shutdown system. Footnote 2 to Appendix R describes alternative shutdown capability as being associated with "Rerouting, relocating, or modifying of existing systems;" To the extent that an existing remote shutdown system previously reviewed and approved under Appendix A to BTP 9.5-1 does not require modifications, rerouting, or relocating of existing. systems, are the requirements of Section III.L of Appendix R backfit?
RESPONSE
Yes. Existing remote shutdown capabilities previously re-viewed and approved under Appendix A to BTP APCSB 9.5-1 do not categorically comply with Section III.G.3 of Appendix R.
Licensees were requested to re-analyze their plants to deter-mine compliance with Section III.G. If the licensee chooses to use the option of III.G.3 for provision of safe shutdown capability for certain areas, the criteria of Section III.L.
are applicable to that capability for that area. See also the response to 5.1.3.
5.1. 2 Pre-Existing Alternative Shutdown Capability QUESTION Some licensees defined safe shutdown capability for purposes of analysis to Section III.G criteria as being composed of both the normal safe shutdown capability and the pre-existing redundant or remote safe shutdown capability which was previously installed as part of the Appendix A process.
This definition often took the form of two "safe shutdown trains" comprising (1) one of the two normal safe shutdown trains, and (2) a second safe shutdown train capability which was being provided by the pre-existing remote shutdown capability. This definitional process, which was undertaken by a number of licensees, makes a significant difference in the implementation of Appendix R. Under such a definition, doesSection III.L criteria apply when the Commission did not call out Section III.L as a backfit?
Enclosure tn CL 85-01, Re: Fire Protection Policy .
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RESPONSE
The definitional process mentioned considers an alternative shutdown capability provided under the Appendix A review as a redundant shutdown capability under the Appendix R review.
This definitional process is incorrect. For the purpose of analysis to Section III.G.2 criteria, the safe shutdown capability is defined as one of the two normal safe shut-down trains. If the criteria of Section III.G.2 are not met, an alternative shutdown capability is required. The alternative shutdown capability may utilize existing remote shutdown I capabilities and must meet the criteria of Sections III.G.3 j and III.L of Appendix R. See also the response to 5.1.3. <
5.1.3 III.L Backfit QUESTION !
l Why do the Staff interpretive memoranda regarding the criteria for satisf action of Section III.L form the audit-able basis for determining compliance to Appendix R when the Commission failed to backfit this section to all plants?
RESPONSE
l Although 10 CFR 50.48(b) does not specifically include Section !
III.L. with Sections III.G., J., and O. of Appendix R as a l I
requirement applicable to all power reactors licensed prior to January 1,1979, the Appendix, read as a whole, and the l Court of Appeals decision on the Appendix, Connecticut Light and Power, et al. v. NRC, 673 F2d. 525 (D.C. Cir., ,
1982), demonstrate that Section III.L. applies to the alter- I native safe shutdown option under Section III.G. if and l where that option is chosen by the licensee.
5.2 Procedures 5.2.1 Shutdown and Repair Basis QUESTION 1
With regard to the term "post-fire procedures" the Commission states that it is impossible to predict the course and extent of a fire. Given this, how does one write post-fire shutdown and repair procedures that are both symptomatic and usable to an operator?
Enclosure to GL 85-01, P.e: Fire Protection Policy
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RESPONSE
l Safe shutdown capabilities including alternative shutdown )
capabilities are all designed for some maximum level of l
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fire-damage (system unavailabilities, spurious actuations). l Since the extent of the fire can not be predicted, it seems l prudent to have the post-fire shutdown procedures guide the l operator from full system availability to the minimum shutdown i capability. As for repair procedure, similar conditions I exist. A repair procedure can be written based on the maxi- l mum level of damage that is expected. This procedure would '
then provide shutdown capability without accurately predic- ;
ting likely fire damage. I 5.2.2 Post Fire Operating Procedures QUESTION Does the NRC have any requirements regarding whether post-fire operating procedures should be based upon fire areas, systems, or by symptom-based?
RESPONSE
The NRC does not have requirements, nor do we propose any requirements regarding whether post-fire operating procedures should be based upon fire areas, systems or be symptom-based.
We suggest that the post-fire shutdown capabilities designs be reviewed with the plant operation staff and procedures written with their input. See also responses to 5.2.1 and 5.2.3.
5.2.3 Alternative Shutdown Capability QUESTION Is it acceptable to develop poit-fire operating procedures only for those areas where alternative shutdown is required? l (For other areas standard, emergency operating procedures I would be utilized in the presence of potential fire damage ;
to a single train.) '
Enclosure to GL 85-01, Re: Fire Protection Policy
4 32
- RESPONSE Yes. The only requirement for post-fire operating procedures is fcr those areas where alternative shutdown is required.
For other areas of thi plant, shutdown would be achieved utilizing one of the two normal trains of shutdown system.
Shutdown in degraded modes (one train unavailable) should be covered by present operator training and abnormal and emergency operating procedures. If the degraded modes of operation are not presently covered, we would suggest that I the operation staff of the plant determine whether additional training or procedures are needed.
5.2.4 Fost Fire Procedures Guidance Documents )
OVESTION 1
Oo any NRC Staff guidance docuwents exist relative to the l extent, form, nature, etc. of Appendix R post-fire operating I procedures?
RESPONSE -
No. Other than the criteria of Sect. ion III.L, no specific l post-fire shutdown procedure guidance has been developed. 1 I
See also responses to 5.2.1, 5.2.2 and 5.2.3.
5.3 Safe Shutdown and Fire Damage 5.3.1 Circuit Failure Modes QUESTION What circuit failure modes must be considered in identifying i circuits associated by spurious actuation?
l
RESPONSE
Sections III.G.2 and III.L.7 of Appendix R define the circuit failure modes as hot shorts, open circuits, and shorts to ground. If the concern is spurious actuation of equipment, actual circuit failure modes could be bypassed by assuming all possible failure states for the equipment (valves could fail either open or closed).
Enclosure to GL 85-01, Re: Fire Protection Policy
l 33 l
5.3.2 "Hot Short" Duration '
QUESTION If one mode of fire damage involves a "hot short" how long !
does that condition exist as a result of fire damage prior l to terminating in a ground or open circuit and stopping the l spurious actuation?
RESPONSE
We would postulate that a "hot short" condition exists until action has been taken to. isolate the given circuit from the l fire area, or other actions as approprtate have been taken l to negate the effects of the spurious actuation. We do not postulate that the fire would eventually clear the "hot short."
5.3.3 Hot Shutdown Duration QUESTION Since hot shutdown cannot be maintained indefinitely, hot shutdown equipinent needs to be protected for only a limited i period of time. How long must a plant remain in that condi- l tion in order to meet the requirement for achieving hot shutdown with a single train of equipment?
RESPONSE
Section III.G.1 requires that the one train of systems needed to achieve and maintain hot shutdown be free of fire damage.
Thus, the systems needed are to be completely protected from the fire regardless of time. If the intent of the
. question concerns how long these systems must operate, these systems must be capable of operating until the systems needed to achieve and maintain cold shutdown.are available.
5.3.4 Cooldown Equipment QUESTION Certain equipment is necessary only in the cooldown phase when the plant is neither in hot nor cold shutdown condition as defined by technical specifications. Is this equipment considered hot or cold shutdown in nature?
Enclosure to GL 85-01, Re: Fire Protection Policy
34 '
RESPONSE
As stated in Section III'.G.1, one train of systems needed to achieve and maintain hot shutdown conditions must be free of fire damage. Systems necessary to achieve and maintain cold shut-down can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Thus, if this certain equipment necessary only in the cooldown phase, is used to achieve cold shutdown, it can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If the certain equipment is maintaining hot shutdown while repairs are being made, one train must be free of fire damage.
5.3.5 Pressurizer Heaters -
QUESTION Most PWRs do not require pressurizer heaters to maintain stable conditions. In fact, the Commission does not con-sider heaters to be important to safety and they are not required to meet Class IE requirements. Are they required for hot shutdown under Appendix R? If yes, then how does a plant meet the separation requirements of Section III.G.2.d.
- e. or f without major structural alterations to the pressurizer? -
RESPONSE
One train of systems necessary to achieve and maintain hot shutdown conditions must be free of fire damage. PWR lican-sees have demonstrated the capability to achieve and maintain stable hot shutdown conditions without the use of pressurizer heaters by utilizing the charging pump and a water solid pressurizer for reactor coolant pressure control.
5.3.6 On-Site Power QUESTION Appendix R,Section III.L.4 states in part, "If such equipment and systems will not be capable of being powered by both on-site and off-site electrical power systems because of fire damage, an independent on-site power system shall be provided." Again, in Appendix R,Section III.L.5, the statement is made "If such equipment and systems used prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the fire will not be capable of being powered by both onsite and offsite electrical power systems because of fire damage, an independent onsite power system shall be pr6vided." An interpretation is needed of the meaning and the applicability of these two quotes relative to alternative shutdown capabilities. '
Enclosure to GL 85-01, Re: Fire Protection Policy
I 35 .
RESPONSE
These statements are meant to indicate that the alternative shutdown capability should be powered from an onsite power system independent (both electrically and physically) from the area under consideration. Further, if the normal emergency onsite power supplies (diesel generators) are not available because of fire damage, then a separate and independent
. onsite power system shall be provided. As an example, some plants are utilizing a dedicated onsite diesel generator or gas turbine to power instrumentation and control panels which are a part of the alternative shutdown capability.
5.3.7 Torus Level Indication QUESTION For BWRs, I&E Information Notice 84-09 suggests that licen-sees need to have torus level indication post-fire. If an analysis shows that a level does not change significantly during any operational modes or worse case conditions, is level indication still required? Is an analysis in file adequate or is an exemption request required?
RESPONSE
It continues to be our position that torus (suppression pool) level indication is the preferred post-fire monitoring instrumentation in order to confirm the availability of the torus (suppression pool) as a heat sink. We recognize that existing analyses indicate that suopression pool level ;
is not significantly changed during emergency shutdown conditions. However, we believe the operator should be able to confirm that spurious operations or other unantici-pated occurrences have not affected the torus function. An analysis of torus level change by itself is not considered an acceptable basis.
5.3.8 Short Circuit Coordination Studies QUESTION Should circuit coordination studies consider high impendance faults? ,
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Enclnsure to GL 85-01, Re: Fire Protection Policy
36 RESPONSE ,
Yes. To meet the separation criteria of Section III.G.2 and II.G.7 of Appendix R,' high impedance faults should be considered for all associated circuits located in the fire area of concern. Thus, simultaneous high impedance faults (below the trip point for the breaker on each individual ciruit) for all associated circuits located in the fire area should be considered in the evaluation of the safe shutdown capability. Clearing such faults on non-essential circuits may be accomplished by manual breaker trips governed by written procedures.
5.3.9 Diagnostic Instrumentation QUESTION What is diagnostic instrumentation?
RESPONSE
Diagnostic instrumentation'is instrumentation, beyond that previously identified in Attachment 1 to I&E Information Notice 84-09, needed to assure proper actuation and func-tioning of safe shutdown equipment and support equipment (e.g. , flow rate, pump discharge pressure). The diagnostic instrumentation needed depends on the design of the alter-native shutdown capability. Diagnostic instrumentation, if needed, will be evaluated during the staff's review of the licensee's proposal for the alternativ2 shutdown capability.
5.3.10 Design Basis Plant Transients QUESTION What plant transients should be considered in the design of the alternative or dedicated shutdown systees?
RESPONSE ,
Per the criteria of Section III.L of Appendix R. a loss of offsite power shall be assumed for a fire in any fire area concurrent with the following assumptions:
- a. The safe shutdown capability should not be adversely affected by any one spurious actuation or signal resulting from a fire in any plan +. area; and Enclnsure to GL 85-01, Re: Fire Protection Policy
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- b. The safe shutdown capability should not be adversely affected by a fire in any plant area which results in '
the loss of all automatic function (signals, logic) ;
from the circuits located in the area in conjunction with one worst case spurious actuation or signal resulting from the fire; and
- c. The safe shutdown capability should not be adversely affected by a fire in any plant area which results in simultaneous spurious actuation of all valves in high-low pressure interface lines.
1 5.3.11 Alternative / Dedicated Shutdown vs. Remote Shutdown Systems QUESTION 1
What is the difference between the alternate / dedicated i shutdown systems required for fire protection and the remote I shutdown systems recommended under Chapter 7 of the SRP? j
RESPONSE
The remote shutdown systems recommended under Chapter 7 of the SRP are needed to meet GOC 19. These remote shutdown systems need to be redundant and physically independent of the control room in order to meet GDC 19. For GDC 19, damage to the control room is not considered. Alternate shutdown systems for Appendix R need not be redundant but must be both physically and electrically independent of the control room.
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- 6. OIL COLLECTION SYSTEMS FOR REACTOR COOLANT PUMP 6.1 Lube Oil System Seismic Desian QUESTION If the reactor coolant purp lube oil system and associated appurtenances are seismically designed, does the lube cil collection system also require seismic design? Is an exemption reqeired?
RESPONSE
Where the RCP lube oil system is capable of withstanding the safe shutdown earthquake (SSE), the analysis should assume that only random oil leaks from the joints could occur during the lifetime of the plant.
The oil collection system, therefore, should be designed to safeiy channel the quantity of oil from one pump to a vented closed container.
Under this set of circumstances, the oil collection system would not have to be seismically designed.
An exemption is required for a reon-seismically designed oil collection system. The basis for this exemption would be that random leaks are not assumed to occur simultaneously with the seismic event, since the lube oil system is oesigned to withstand the seismic event. However, the Rule, as written, does not make this allowance. ,
j 6.2 Container QUESTION It would appear that a literal reading of Section III.0 regarding the ,
oil collection system for the reactor coolant pump could be met by a J combination of seismically designed splash shields and a sump with sufficient capacity to contain the entire lube oil system inventory.
If the reactor coolant pump is seismically designed and the nearby piping hot surfaces are protected by seismically designed splash shields such that any spilled lube oil would contact only cold surfaces, does this design concept cunform to the requirements of the rule?
RESPONSE
If the reactor coolant pump, including the oil system, is seismically designed and the nearby hot surfaces of piping are protected by seismically designed splash shields such that any spilled lube oil would contact only cold surfaces, and it could be demonstrated by engineering analysis that sump and splash shields would be capable
.- of preventing a fire during normal and design basis accident conditions, the safety objective of Section 111.0 would be achieved. Such a design concept would have to be evaluated under the exemption process.
The. justification for the exemption should provide reasonable assurance that oil from all potential pressurized and unpressurized leakage Enclosure to GL 85-01, Re: Fire Protection Policy d
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points would be safely collected and drained to the sump. The sump should be shown capable of safely containing all of the anticipated oil leakage. The analysis should verify that there are no electric ;
sources of ignition.
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I 40
- 7. BRANCH TECHNICAL POSITION CMEB 9.5-1 7.1 Fire Protection and Seismic Events QUESTION For which situations other than the reactor coolant pump lube oil system are seismic events assumed to be initiators of a fire? )
. 1 RESPONSE I Tts guidelines for the seismic design of fire protection systems which I c .'er other general situations is delineated in ETP CMEB 9.5-1 C.1.C(3) and (4):
"(3) As a minimum, the fire suppression system should be capable of delivering water to manual hose stations located within hose )
reach of areas containing equipment required for safe plant shut- 1 down following the safe shutdown earthquake (SSE). In areas of high seismic activity, the staff will consider on a case-by-cas( ,
basis the need to design the fire detection and suppression systeus j to be functional following the SSE. l (4) The fire protection systems should retain their original design capability for (a) natural phenomena of less severity and greater frequency than the most severe natural phenomena (approximately once in 10 years) such as tornadoes, hurricanes, floods, ice stores, or small-intensity earthquakes that are characteristic of the geographic region, and (b) potential sansade site-related I events such as oil barge collisions or aircraft crashes that i have a reasonable probability of occurring at a specific plant i site. The effects of lightning strikes should be included in the overall plant fire protection program."
We have considered California as being a high seismic activity area.
For those plants reviewed under Appendix A, our position is (A.4):
"Postulated fires or fire protection systee failures 'need not be considered concurrent with other plant accidents or the most severe natural phenomena" Our guidelines on the seismic design of fire protection systems installed in safety related areas a*e delineated in Regulatory Guide I 1.29 "Seismic Design Classification", paragraph C.2. The failure of I any system should not affect a system from performing its safety function.
Enclosure to GL 85-01, Re: Fire Protection Policy
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Our guidelines on the seismic design of' hydrogen lines is delineated l in BTP CMEB 9.5-1 C.S.d(5):
(5) Hydrogen lines in safety-related Sreas should be either designed to seismic Class I requireevnts, or sleeved such that the outer pipe is directly vented to the out:ide, or should be equipped with excess flow valves so.that in case of a line break, the hydrogen concentration in the affected areas will not exceed 2%.
Al'1 PWR's hav' e a hydrogen 1ine going tu the Volume Control Tank (Make-up Tank) that needs to be, protected.
l To identify plant specific situations in which seismic events could initiate a fire in a specific plant area, the fire protection enginear and systems engineer performing the fire hazards analysis should be concerned with in-situ combustible materials which can be released in a manner such that they could cortact in-situ ignition sources by a seismic event. An example of this would be the rupture of the RCP lube oil line directly above the hot reactor coolant piping. The fire protection engineer should also be concerned with seismic induced ignition sources, electrical or mechanical, which could contact nearby in-situ combustible materials.
7.2 Random Fire und Seismic Events QUESTION Is a randde fire to be postulated concurrent with a seismic event?
RESPONSE
I Our pcsition, as stated in Section C.l.6 of BTP CME 8 9.5-1, is "Worst case fire need not be postulated to be simultaneous with nunfire-related failures in safety systems, plant accidents, or the most severe natural phenomena."
Where plant systems are designed to prevent the release of combustible materials caused by a s*ismic event, such as a dike around a fuel oil tank trcnsformer, or seismic supports for hydrogen lines, then no I fire need to be arbitrarily assumed to take place in the fire hazards ;
analysis. )
1 Because it is impossible to completely preclude the occurrence of a I seismically induced fire, Section C.6.c(4) of CMEB 9.5-l' states:
"Provisions should be made to supply water at least to standpipes and hose connections for manual firefighting in areas containing equipment required for safe plant shutdown in the event of a safe shutdown earthquake. The piping system serving such hose stations should be analyzed for SSE loading and should be provided with supports to ensure system pressure integrity. The piping Enclosure to GL 85-01, Re: Fire Protection Policy I
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this functional requirement should, as a minimum, satisfy ANSI B31.1, ' Power Piping.' The water supply for this condition may be obtained by manual operator actuation of valves in a connection to the hose standpipe header from a normal seismic Category I water system such as the essential service water system. The cross connection should be (a) capable of providing flow to at l least two hose stations (approximately 75 gpa per hose station), l and (b) designed to the same s'tandards as the seismic Category I water system; it should not degrade the performance of the seismic Category I water system."
The post-seismic procedures should include a damage survey, and a I determination of whether any fires were initiated as a result of the l seismic event. See also the response to Question 7.1.
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- 8. LICENSING POLICY 8.1 Fire Hazard Analysis / Fire Protection Plan Updatino QUESTION d
What constitutes-the fire protection plan required by 50.48(a)?
Should licensees have programs to maintain the fire hazards analysis
, and the fire protection plan current or updated periodically? How often should the plan be updated? Must revisions be provided to the
. NRC?
RESPONSE . . , ,
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The basic elements required in the fire protedtion plan are described in 10 CFR 50.48(a). The fire protection program that implements that plan should include the details of the fire hazards analysis. The plan and program may be separate or combined documents and must be kept current with the fire hazards analysis updated prior to making modifications. We would expect that for most plants lictnsed after January 1,1979, the fire protection plan and program would be part of the FSAR and therefore, would be updated and submitted to the NRC in conformance with the requirements of 10 CFR 50.71(e). For plants whose fire protection plans and programs are not part of the FSAR, we would expect that they would be updated prior to making modifications and kept at the site in an auditable form for NRC inspection.
8.2 Fire Protection License Condition -
QUESTION What is the significance of the fire protection license condition?
RESPONSE
For those plants licensed prior to January 1,1979 (Appendix R plants),
the license ccndition is the legally enforceable requirement for the fire prntection features other than those equired by III.G, III.J. and III.0 that were accepted by the NRC staff as satisfying the provisions of Appendix A to Branch Technical Position BTP APCSB 9.5-1.
For those plants licensed after January 1,1979, the license condition is the legally enforceable requirement for all fire protection features at the facility.
Appendix R is only enforceable on Post 1979 plants through the license condition. 10 CFR 50.48 makes Appendix R applicable only to p'lants licensed prior to January 1, 1979. Refer to 10 CFR 50.48(e).
Enclosure to GL 85-01, Re: Fire Protection Policy
l 44 l The NRC has drafted new language for this license condition which delineates the circumstances under which the fire protection plan may -
be revised. We are now including this language in all new licenses and are considering amending preser.t licenses. The revised language is as follows.
"9.5 Fire Protection Proaram (Section 9.5, SER) l
- a. The licensee shall maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility through Amendment __ and as approved in the SER through Supplement __, subject to orovisions b & c below,
- b. The licensee may make no change to the approved fire protection program which would decrease the level of fire protection in the plant without prior approval of the Commission. To make such a change the licensee must submit an application for license amend-ment pursuant to 10 CFR 50.90.
- c. The licensee may make changes to features of the approved fire protection program which do not decrease the level of fire pro-tection without prior Commission approval after such features -
have been installed as approved, provided such changes do not .
otherwise involve a change in a license condition or technical specification or result in an unreviewed safety question (see 10 i CFR 50.59). However, the licensee shall maintain, in an auditable form, a current record of all such changes including an analysis of the effects of the change on the fire protection program and shall make such records available to NRC inspectors upon request.
All changes to the approved program made without prior Commission approval shall be reported annually to the Director of the Office of Nuclear Reactor Regulation, together with supporting analyses."
8.3 III G J and 0 Exemptions for Future Modifications
~
QUESTION Is an exemption required from Appendix R Sections o...er than III.G.
III.J and III.0 for future modifications that do not comply with such sections?
RESPONSE
Yes. The exclusion of the applicability of Sections of Appendix R other than III.G., III.J., and Ill.0 is limit 9d to those features "accepted by the NRC staff as satisfying the provisions of Appendix A to Branch Technical Position BTP APCSB 9.5-1 reflecteo in staff fire protection safety evaluation reports issued prior to the effective date of the rule."
Reference:
Enclosure to GL 85-01, Pe: Fire Protection Policy
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45 8.4 Futu,re Changes.
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QUESTION Will future changes (no matter how minor) to approved configurations be required to be reviewed by the Staff in an exemption request? At what point may the process of 10 CFR 50.59 be invoked?
RESPONSE
If a futtre modification involves a change to a license condition or technical specification, a license amendment request must be submittet, When a modification not involving a technical specifica-tion or license condition is planned, the evaluation made in conforsr ance with 10 CFR 50.59 to determine whether an unreviewed safety question is involved must include an assessment of the modification's impact on the existing fire hazards analysis for the area. This part of tne evaluation must be performed by the person resoonsible for the fire safety program for the plant. The assessment must include the effect on combustible loading and distribution and the consideration of whether circuits or components, including associated circuits, for a train of equipment needed for safe shutdown are being affected or a new element introduced in the area. If this evaluation concludes
, that there is no significant impact, this conclusion and its basis must be documented as part of the 50.59 evaluation and be available for future inspection and reference. If the evaluation finds that there is an impact that could result in the area either not being in conformanck with Appendix R, or some other aspect of the approved firc protect 8cn program, or being outside the basis for an exemption i that was gra-Led for the area involved, the licensee must either make modifications to achieve crnformance or justify and request exemption 1 (or, for the post 1979 plants, approval) from the N*C. See also responses to Questions 8.1 and 8.2.
8.5 Schedular and Blanket Exemptions .
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QUESTION )
1 If an exemption is warranted and at the same time the provisions of the rule indicate that the appropriate schedular deadlines have passed, should a scheduler exemption be filed at the same time as the technical er.emption request?
If as part of the exemption request the utility is proposing to make modifications to achieve a reasonable level of conformance with Appendix R, and if the associated "clock" has run out for that type of modification, should the technical exemption request and the description of the modification be filed with a scheoular exemption?
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46 When filing a schedular exemption under $50.12, it is not always clear from what specific paragraphs of $50.48 an exemption should be sought.
Is it acceptable to request a blanket exemption from the schedular provisions of 10 CFR 550.48 without a specification by paragraph?
If an exemption request is submitted to meet newly published interpre-tations of Appendix R, when does the licensee need to be in compliance?
Is the schedule presented in Appendix R still the guideline or must a new schedule be developed under a different criteria?
RESPONSE
We do not intend to issue any further extensions of the 50 -?(c) schedules. When a licensee determines that a 50.48(c) schecal- cannot be met, the appropriate NRC Region must be notified. This r- cy is further explained in the generic letter transmitting this p m. age.
8.6 Trivial Deviations QUESTION What guidance can the NRC Staff give the industry regarding when c -
deviation from the literal interpretation of Appendix R is sufficiently trivial as to not require a specific exemption?
RESPONSE
The significance of a deviation must be judged as part of a fire hazards analysis. The conclusion of this analysis is always subject to review by the NRC inspector.
8.7 Revised Modifications QUESTION What is the process for alterin2 configurations not yet implemented for plants with Appendix R SERs?
RESPONJE If licensees propose changes to their NRC approved modifications, they must submit their new proposal and revised schedule for imple-mentation for NRC approval.
This exchange must be justified as to (1) the reason for the change.
(2) the basis for the revised schedule, and (3) the interim measures that will be provided to assure post fire snutdown capability until the final modifications are implemented. Whether or not enforcement action will be taken based upon continued noncompliance with Appendix R will be decided by the NRC Regional Administrator in consultation with NRC. Headquarters. ~
Enclosure to GL 85-01, Re: Fire Protection Policy
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47 8.8 Smallest Opening in a Fire Barrier QUESTION What is the smallest opening allowed in a fi. a area barrier for which an exemption request is not needed?
RESPONSE
Unsealed' openings in the configuration for which approval was obtained
~
by an approved laboratory or the NRC staff would be acceptable.
Our position on openings is given in Section 5.a(3) of BTP CMEB 9.5-1:
"(3) Openings through fire barriers for pipe, conduit, and cable trays which separate fire areas should be sealed or closed to provide a fire resistance rating at least equal to that required of the barrier itself. Openings inside conduit larger than 4 inches in diameter should be sealed at the fire barrier penetration. Open-ings inside conduit 4 inches or less in diameter should be sealed at the fire barrier unless the conduit extends at least 5 feet on each side of the fire barrier and is sealed either at both ends or at the fire barrier with non-combustible material to prevent the passage of smoke and hot gases. Fire barrier pene-trations that must maintain environmental isolation or pressure differentials should be qualified by test to maintain the barrier integrity under such conditions."
The unsealed opening (s) allowed in a fire area boundary or a barrier which separates redundant shutdown divisions should not permit flame, radiant energy, smoke and hot gases to pass through the barrier and cause damage to redundant shutdown divisions on the other side. The licensee should assess the adequacy of existing protection and should determine the minimum size based on a fire hazards analysis and con-servative fire protection engineering judgment. If the significance of openings in fire barriers is marginal, a formal exemption request could be submitted or the rtaff consulted. The basis for the lack of signif'cance should be available for review by NRC Inspectors.
Our acceptance of unprotected openings in fire barriers would depend upon the quantity and nature of combustible materials on either side of the barrier; the location of the opening (s) in relation to the ceiling (for openings in walls); the locrtion, vulnerability and importance of shutdown systems on either side of the barrier; and compensating fire. protection.
Enclosure to GL 85-01, Re: Fire Protection Policy
48 8.9 NFPA Code' Deviation QUESTION Is an wxemption/ deviation required for deviations from NFPA Codes?
RESPONSE
Deviations from the codes should be identified and justified in the FSAR or FHA.
An exemption is not required for NFPA codes. NRC guidelines reference certain NFPA codes as guidelines to the systees acceptable to the staff, and therefore such codes may be accorded the same status as Regulatory Guides.
When the applicant / licensee states that its design "meets the NFPA codes" or, "meets the intent of the NFPA Codes" and does not iden.tify any deviations from such codes, NRR and the Regions expect that the design conforms to the code and the design is subject to inspection against the NFPA codes.
8.10 "ASTM E-119" Design Basis Fire QUESTION -
Is an exemption / deviation required, if components are designed to withstand an "ASTM E-119" fire?
RESPONSE
Some cables are being developed for high temperature (e.g., 1700*F) applications. An exemption would be required if such cable is used in lieu of the alternatives of III.G.2 or III.G.3 in a pre-1979 plant.
A deviation from the guidelines would be required for similar applications in a post 1979 plant.
8.11 Plants licensed After January 1. 1979 QUESTION What fire protection guidelines and requirements apply to the plants licensed after January 1, 19797
RESPONSE
Post-1979 plants are subject to:
GDC 3 10 CFR 50.48(a') and (e)
Enclosure to GL 85-01, Re: Fire Protection Policy r ,. --.--,s- r- e .-, n- -,
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- ~. The guidelines identified in the footnotes to 50.48(a) 1
- Guidelines documents issued after January 1,1979.
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- Com9itments made to re the requirements of Append!x R or j specific sections such as ta'.G III.J and III.O.
- BTP CMEB 9.5-1, which includes the requirements of Appendix R and the previous guidance documents incorporated into the Branch l Technical Position. -
The license for each plant licensed af ter January 1,1979 contains a license . condition which identifies by referent.e the approved fire protection program for that plant.
8.12 Cold Shutdow- Equipment Availability QUESTION A. Can a licensee achieve compliance with III.G.1(b) by demonstrating that one train of cold shutdown equipment will remain free of fire damage?
B. In demonstrating that one train of cold shutdown equipment will remain free of fire damage, is a licensee limited to the three alternatives in 111.3.27
RESPONSE
1 A. Yes.
B. No.
8.13 Guidance Documents QUESTION Please list all NRR guidance documents and pesition papers issued since Appendix R was promulgated.
RESPONSE
Fire Protection Guidance Issued Since January 1,1975:
IE Information Notices Nc. 83-41: Actuation of fire suppression systems causing inoperability of safety related equipment.
No. 83-69: Improperly installed fire dampers at nuclear power plant .
Enclosure to GL 85-01, Re: Fire Protection Policy i
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No. 83-83: Use of portable radio transmitters inside nuclear power plants.
"No. 84-09: Lessons Learned From NRC Inspections of Fire Protection Safe Shutdown Systems (10 CFR 50, Appendix R)
Standard Review Plan 9.5.1, Rev. 1 Fire Protection System, dated 5/1/76 9.5.1, Rev. 2 Fire Protection Program, dated 03/78 9.5.1, Rev. 3 Fire Protection Program, July 1981.
Regulations
, 10 CFR Part 50: Proposed fire protection program for nuclear power plants operating prior to January 1,1979, dated May 29, 1980.
Federal Register Vol. 45, No. 105, 36082.
10 CFR Part 50: Fire protection program for operating nuclear power plants, dated November 19, 1980. Federal Register Vo. 45, No. 225, 76602.
10 CFR Part 50: Fire protection rule corrections, dated September 8, 1981. Federal Register Vo. 46, No. 173, 44734.
Generic Letters Note: The following documents were obtained from the Palisades file Docket No. 50-255. Similar documents should be in the file for other operating facilities. The dates may vary slightly.
- 1. Letter dated 9/28/70 - Enclosing App. A to BTP APCS 8 9.5-1 and supplementary guidance on information needed for fire protection program evaluation. ,
- 2. Letter dated 12/1/76 - Enclosing sample Technical Specifications and n.7 errata sheet.
- 3. Letter dated 8/19/77 - Enclosing "Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance."
- 4. i.etter datid 6/8/78 - Re: Manpower requirements for operating .
reactors.
- 5. Lttter dated 9/7/79 - Re: Minimum fire brigade shift size.
- 6. Letter dated 9/14/79 - Enclosing staff positions - safe shutdown capability.
Enclosure to GL 85-01, Re: Fire Protection Policy
51 l
- 7. Letter dated 10/31/80 - Enclosing new 10 CFR 50.48 regarding fire protection schedules for operating melear power plants.
- 8. Letter dated 11/24/80 - Enclosing a copy of revised 10 CFR 50.48 !
and new App. Reto 1r> CFR 50, and a sununary of open items from the SER for the 8TP APCS 8 9.5-1 review, i
- 9. Letter dated 2/20/81 - Generic Letter 81-12 identifying informa-tion needed for NRC review of modifications for alternative l shutdown capability. i 1
- 10. Letter dated 4/7/82 - Provided. clarification to Generic Letter ;
81-12 and guldsnce on information needed for NRC review of ;
- 11. Letter dated 10/6/82 - Generic Letter 82-21; provided criteria for annual, biennial, and triennial audits required by Technical Specifications.
- 12. Letter dated 10/19/83 - Generic Letter 83-33; NRC Positions on I Certain Requirements of Appendix R to 10 CFR 50. ;
Staff Generic Positions
- 1. Letter, Denton to Bernsen, dated 4/20/82 - Control room fires.
- 2. SECY 83-269, dated July 5, 1983 - Attachments B and C.
- 3. Memo, Eisenhut to Olshinski, dated 12/20/83 - Physical independ-ence of electrical systems.
- 4. Memo, Eisenhut to Jordan, dated 10/24/83 - Bullet resistant fire doors.
"Staff positions regarding the need for certain exemptions delineated in this guidance document have been revised per the "Interpretations of Appandix R".
8.14 Deviation From Guidance Documents QUESTION If a utility determines that a deviation from a guidance document exists, does an exemption request need to be filed? If so, what is the legal basis for this requirement?
RESPONSE
No.
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l Enclosure tn GL 85-01, Re: Fire Protection Policy l l
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8.15 Staff Interpretation of Appendix R QUESil0N-How does the Staff initiate interpretations of Appendix R in a manner which ensures their technical adequacy and consistency with the rule's objectives le 42s, presentation to ACRS, issue for comment as in draft regulatory guides, etc. )?
RESPONSE
Staff positions are initiated when our experience shows that generic issues are identified that require clarification. These positions are reviewed for accuracy and consistency by the cognizant Division Directors. Usually, they are not issued for comment. However, Generic Letter 83-33 was commented on by the NUFPG since it was initiated, in part, at their request.
8.16 Dissemination of New Staff Positions 00ESTION Will licensees be automatically sent a copy of new Staff position papers as they are developed?
. RESPONSE The Staff positions on generic subjects are considered for issuance in Generic Letters from ONRR and Information Notices or Bulletins from OI&E. Staff positions issued for specific questions on specific plants are not given generic promulgation because they normally involve plant specific deisgn considerations.
8.17 Equivalent Alternatives QUESTION ,
How does a licensee demonstrate that alternative measures are equiva-lent to the measures of Section III.G.2 in order to obtain an exemp-tion lacking a formal definition of the term "free of fire damage"?
RESPONSE
See Item #3 of "Interpretations of Appendix R."
Enclosure to GL 85-01, Re: Fire Protection Policy
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S3 8.18 Coordination Study Update QUESTION Circuit modifications are an ongoing process. How recent must a i coordination study be in order to be valid in protecting circuits )
associated by common power source? )
1 RESPONSE I We would expect that as circuit modifications are made, the design package would address the electrical protection recuired and the effects of this ~ protection on the coordination of the protection for i the power distribution system. This type of consideration should be . l included in the evaluation required by 10 CFR 50.59 Changes, Tests )
and Experiments. The design package and modification evaluation could not be complete without consideration of the coordination study. l Therefore, we would expect that the coordination studies would be !
current with the last circuit modification made.
8.19 Exemptior. Request Threshold QUESTION (a) What is the threshold for exemption requests? (b) Is it necessary to file a request for each and every possible deviation from Appendix R?
RESPONSE
Typical examples are discussed in the response to Questions 8.21.1 through 8.21.6.
(a) The licensee must develop its criteria for an exemption request threshold. 1 1
(b) No.
G.19.1 Penetration Designs Not Laboratory Approved QUESTION Where penetration designs nave been reviewed and approved by NRC but have not been classified by an approval laboratory, will it be necessary to submit an exemption request?
RESPONSE
No.
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Enclosure to GL 85-01, Re: Fire Protection Policy
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1 8.19.2 Individual vs. Package Exemptions QUESTION 1
How do we submit future modification exemption requests, etc.? Would NRC prefer them individually, or developed and submitted in packages for review and approval?
RESPONSE
Future exemptions should be submitted individually, if they are independent of each other, j 8.19.3 Exemption Request Supporting Detail i
QUESTION When an exemption request is filed, what criteria are used to determine the level of detail needed to support the request?
RESPONSE
See Enclosure 2 of NRC's letter to all licensees dated April-May 1982.
8.19.4 50.12 vs. 50.48 Exemption Requests QUESTION With regard to exemption requests for future modifications, will they be submitted under 50.12 or 50.487
RESPONSE
10 CFR 50.12. - -
1 8.20 Post January 1, 1979 Plants and Enesotion Requests QUESTION -
Do plants licensed after January 1,1979 which have committed to meet I the requirements of Section III.G III.J and III.0 and are required I to do.so as a license condition, need to request exemptions for '
alternative configu. rations?
1 RE.CPONSE No; however, deviations from the requirements of Section III.G, III.J and III.0 should be identified and justified in the FSAR or FHA and the deviation would probably require a licensa amendment to change the license condition. See responses 8.1 and 8.2. -
l Enclosure to Gl. 85-01, Re: Fire Protection Policy 1
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55 8.21 NRC Approval for BTP CHEB 9.5-1 Deviations QUESTION Do future deviations from BTP CHEB 9.5-1 guidelines require approval by the NRC7 Do such deviations constitute a violation of license conditions? ,
RESPONSE
Compliance with guidelines in the BTP is only required to the extent that they were icorporated in the approved Fire Protection Program as identified in the license condition.
When the new license condition is in place (See Response 8.2), future deviations may be made in accordance with the procedure stated therein.
With present nonuniform license conditions, such deviations may or may not require a licenso amendment. In the absence of a license amendment, a violation may exist.
Enclosure to GL 85-01, Re: Fire Protection Policy
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- 9. INSPECTION POLICY l
9.1 Safety Implicatiuns QUESTION Since the Commission states that fire damage cannot be defined and fire spread cannot be predicted, how does the Commission determine which Appendix R violations have "important safety implications?"
RESPONSE
i III.G.2 provides alternatives to ensure that one of the redundant trains is free of fire damage. Fire spread within one area cannot be predicted, but damage is limited to one fire area.
Determination of the Appendix R violations that have "impoitant safety implications" are based on the equipment, components, and systems l that are located in the same fire area that are needed for safe shut- 1 down or can adversely affect safe shutdown, and are not protected by the features of III.G.2, III.G.3 or an approved alternative.
9.2 Uniform Enforcement
~
QUESTION How does the Commission ensure that violations of the rule are uniformly treated between regions?
RESPONSE I Each Region evaluates violations in accordance with the NRC Enforcement Policy, 10 CFR 2, Appendix C. The Policy provides guidance for the determination of appropriate enforcement sanctions for violations.
The Office of Inspection and Enforcement provides guidance for and l monitors Regional implementation of the Policy- to ensure a uniform application. In addition, the policy requires that all escalated enforcement actions be approved by the Director of the Office of .
Inspection and Enforcement. -
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- 9. 3 NTOL Inspections 00EST!0N l
5 Will NT0Ls be subject to an Appendix R audit now being performed on I plants licensed to operate prior to January 1, 19797 Or, will the l current review and analysis being performed by the Staff be satisfactory?
l Enclosure to GL 85-01, Re: Fire Protection Policy
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. __ l 57 RESPONSE I Yes, NTOLs will be subject to the Appendix R audit; the TI 2515/62 !
is being revised to reflect the appropriate requirements for NTOLs' l and it is our intent to conduct such inspections prior to issuing '
the operating license.
10 CFR 50.48 requires each such plant to have a fire protection plan.
Their operating 1icense will contain a specific license condition to implement their approved fire protection program which must identify l deviations from Appendix R. The fire protection inspections will be against.the particular license conditions.
9.4 Future TI 2515/62 Revisions QUESTION Does the NRC plan to issue a new or revised version of Temporary Instruction 2515/62 for future Appendix R audits?
RESPONSE
Yes.
- 9. 5 Documentation Supplied by Licensee QUESTION Temporary Instruction 2515/62 provided a list of documentation that the NRC needs to review as part of the audit process. In past audits, the NRC has tequested additional information other than that contained on the list. Will a new list of documentation be developed?
RESPONSC ,
y The documentation listing provided in TI-2515/62 does not restrict the inspection team from enhancing inspection efficiency by requesting a licensee to provide additional relevant documentation. A new listing of documentation for TI-2515/62 is not being developed. l 9.6 Subsequent Inspections QUESTION To what extent will Appendix R issues be raised at future Regional I&E Fire Protection audits after a successful Appendix R audit? For example, if an area has already been reviewed and no noncompliance found, will it be subject to later review and reinterpretation by the Staff? l l
Enclosure to GL 85-01, Re: Fire Protection Policy l
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RESPONSE
The Appendix R inspections are conducted on a sample basis. These !
inspections do not certify that all possible items of noncompliance ;
with Appendix R have been identified. The inspection results do I provided a basis for a determination of the adequacy of a licensee's Appendix R reanalysis, modification and preparation. When a noncom-pliance with Appendix R requirements is identified, a notice of viola-tion will be issued to ensure adequate corrective action. In those cases in which the licensee believes that the staff has invoked a reinterpretatio.n of adequa y in areas which had previously been reviewed, NRC's procedures for appeal would be applicable. )
- 9. 7 NRC List of Conforming Itees QUESTION At the end of the audit, will the NRC provide a list of items that had been reviewed and found in conformance with Appendix R7 To dat ,
only areas of nonconformance have been specifically identified in exit interviews.
RESPONSE
Subsequent to an Appendix R inspection, the NRC will not provide a list of items reviewed and found to be in conformance with Appendix R. '
l We do list the areas inspected and where non-compliances were not found.
9.8 Inspection Re-review QUESTION Where assumptions are made and clearly stated within the analysis submitted to NRR for review, will such assumptions be subject to a second review by 01&E during the inspection process? l Where assumptions are made in conjunction with the analysis, should exemption requests be filed just to provide protection for the licensee?
If NRR accepts a licensee's selection of equipment and shutdown paths as being sufficient to meet the Appendix R shutdown criteria, will OI&E review and have the right to challenge the approved shutdown '
paths and approved equipment selection? Or will they only check the shutdown paths and equipment in question to see that they meet the Appendix R requirements, i.e., separation?
Enclosure to GL 85-01, Re: Fire Protection Policy
l 1
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RESPONSE
To the extent that a licensee's submittal to NRR is comprehensive and sufficiently detailed, the basis for the OI&E Appendix R inspection will ba the assumptions, shutdown paths and equipment selections approved by NRR. If the inspection results in new information that casts doubt upon the approved configuration, the Regional inspectors have the responsibility to resolve such doubts.
9.9 List of Shutdown Equipment QUESTION What lists of shutdown equipment will be used by the Regional inspectors, if the shutdown analysis has not been reviewed and approved by NRR?
RESPONSE
Regional Inspectors will use the lists of shutdown equipment the licensee has identified in his fire protection plan.
Generic Letter 81-12 and its clarification documents expect licensees to show how they will shutdown if a fire area is not provided with redundant train separation. Inherent within this expectation is the assumption that the licensee will identify the equipment to be used.
It is because the licensees have not had fire hazard analyses at all for non-alternative shutdown fire areas that the inspectors to date have resorted to using the only lists available (the alternative shutdown equipment list used by NRR in their reviews).
It is unlikely there would not be a list of at least those systems to be used for alternate shutdown, since 10 CFR 50.48 requires NRR review and approval of the means of alternate shutdown.
L Enclosure to GL 85-01, Re: Fire Protection Policy
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Enclosure to GL 85-01, Re: Fire Protection Policy l l
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i Because of z.pparerd sciicsion regarding the practical implementation of certain Appendix R rcquiiments, it was deemed prudent to develop clarifying guidance and conouct I;egior.cl workshops on Appendix R. The feedback I have received is that the recently completed workshops were very beneficial to
. . ~ - - - ~ . . . - s both the staff and utilities and went a long way to clarifying any I51sunderstandi5gs. Prompt promulgation of the guidance in writing should put an end to any further claims of confusion nthepartoftheindusj}r};;Asyou are aware, the subsequent: proposed staff plan for review of Appendix R implementation by the utilities resulted in submittal of Differing .
Professional Opinions by several staff members. The DP0s are in the process of being resolved.
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AGENDA FOR FIRE PROTECTION MEETING AT HADDAM NECK 1
o_ Discussion of existing and proposed fire detection systems and manual and automatic fire suppression systems. -
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- 0 Design of new instrument panel and safety system lockout display panel.
o Discussion of "customized administrative controls" in the control room
.to limit conbustibles. -
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1 o Discussion of revised operating procedures to identify and remove flammable materials.
- j o Installation of ramps and seals to mitigate flamable liquid spills. l k ara b.7
. o Extent of Appendix R noncompliance in other plant areas -(also at Millstoneplants).
l o Discussion of compensating measures (or lack of) pending Appendix R compliance.
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o Schedule for implementing fire protection and systems modifications.
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NRC P O -22049 4
l 2056 Federal Registir / Vol. 50. No.10 / luesday. january 16. Iwas / Proposeo murs .m I proposed to be corrected hereby.This is Insurance Policy for the 1985 and b.The doDer asEant'elinsmnei per scre Amendment No. 2. succeeding crop years are as follows: for uch crop year 6s detersuned by reference The changes herein proposed for the * * * *
- to the followins table. -
Peach Crop Insurance Regulations.
3l l
)
4,... . -
j effective for the 198"a and succeeding ,
. , 1. , ..
rop years. involve the clarification of .
the heading of the Amount oflasurance . .
^"0L M C' " = = Tasca ,,p., ,
, , . ,q ' l Table !!!ustrating the dollar arnount of . - - . om .=wse = == e=a . - :..- .. .o
,a ;
I"g'fj,",m ""* * * **'""*"'
n ng o amended language now defines when th
'*""*'"'""O*"?"*""""'""'-VW em s.- os c om e cm cm a. , M the amount is applicable as being the cat a-*===e ren u e p.= . soo = a-m t_n.E se ee.m
.a . e -ie ,t earlier of(a) the time of harvest. or (b) ; ,. . v O EJ". 0.7. m*.". ' . " . * .
- 1, .*' i the date ofinspection when damage is ~ "
. .- due to bsII.This changv allows FCIC 80'*a==' * - ' I M* *
~ "
7- L.
i _' .' svHicient time to inspecs for. hall : . * '
'E 'E 'y.'E . ~ ~ y.s -1 '"$ *,- [bE 7(
. damage.These changes also define * '-
a ,.
La= s : see . ass . suo . me , , ,,an ' E.o e [. 5 '. 1 suo E
<. production to count. for purposes of. . -
... appraisal, when the crop is not 9 at
",",," 1 -- *. ,,; ,,g ,,, i 7 pig as-g
, . , , y, n=m,. ,. ass aus os . ee . ...m m ans :. harvested before the harvesting of-rw a ta= - 'm c. m im * .mubm um, w.rs y b
- f. ', peaches becomes eneralin the countyt '" ,*J' '"*'"#'"
O 'n' '."see ..." he 4(,O'"'Das e
us J'ees. .pd and delete Appen ix B. . . .g. L. ... . tasa"r -
- se ase 4.* ass M 3
- 7+ *'N FCICis soliciting comments on this ^ m M;; .~** '~$ ..* " ' " E.8N ).* /~'"
- ~.......E '" & .
% ;" : rj )
proposed rule for 60 days after ,,, .. . y em .. '. ese su "J.ais' Cm s2 s ' * : sis' ' f publication in the Federal Register. All ***" .m m -m t .sn ' : suo ass m- e
,, written comments made pursuant to this e O ."e
- action wiD be available fof public F w
.**< ~ ass-
?"
' j' ,'"$." ~d,*'
see ' sus ~ ses ' an . ..
. . '" . i i ins F
on inibt O! Flee of the eral Crop insurancerations Corpo.Maia'ger.: 7 Y
- E' N' du, " M" Ifi " " ";E e ' .j Room 4096. UA Department of. '
A,nceure. washmgion. u.c. 2am -
J'
*"*",'r'8m"**"'"**"'e'****=L".,,,
4= . . . - m. m . -c. -
-]*O[:},,";,..g.g;. .!
.,g. .;..,, . ,.t.E !.e % W .';.g @; n, .
'~ '
duttng regular business hours. Monday .
O'0"8 @ d'Y' w .\.w ;.v.e m - .. e. * *
- r ^ ** W'd h . (' dead " f 9
' . .' 14: of subjeces *.a 7 Cnt ran ao' s 's ' I4 * .* '7
[3} * * ' '
u.lM,, esg.M
. g. seeetary * , am,eQI semumy, int.sener,. eary with -
g Crop insurance. Peach . ~. ...,.
. . y,: .4 , , g.) g,'f,'t h'4rvesEbefore [Q. lie paid in econdance bastaning wt& Aa3ses evith crop this year.sect . f[ K hs >o
, . wi.:..J. .7%.'# . " of peaches becomes general ha t%. .. {; e k the Sh'i F$-e ."Jd-M -
pART 403.-AMENDED W r-l';.. *
- country; orj *"M .. ~ . . ; ,-,O:dh.2,'.' **3"Npp'endidi$polley contsined*- ef Accordi. gly, pursuant to the subo'rkey ' *- N N:I"I Cm omtd)is ,magnd. ,;f ,;
. ..- contahed in the Federal Crop Insurance ' .I * -have a polley for paying youren. -
- h We ?'
Act, a amended (7 U.S.C.1501 et seq.). , indemnity within 30 days of sura ;.s,.0.. test.. Done in washdessen -
" ': ? _ , Dr. se November ;&
. '; M,
' ,~
the Federal Crop lasurance Corporstion approval of your claim.or entry of a m ; pose F. Cele; '
7^ "
proposes to amend the Peach Crop - final Judgment against me. We wGl. in no. .ssmenry.rederato6p $emoe *. * ' "" .
insurance Regulations (7 Cm Part 403). . tnatance, be liable for the peyment af s , c;. g ;;.#,- ,w e. &. . ' * '-
- a .
effective for the 1985 and succeeding damages. attorney's fee. or other - .. Approved by.f D **' ' '
crop yeart. In the following instancea: charges in connection with any claim -for nearren W.sM*2 9 ~
1.The Authority citation for 7 Cm indemnity, whether we approve.or .% --
disappove such claim. We will pay . e.- ** %:n Part 403 is. . .
- - "-. simple interest. however. computod on . De W oomary7.asN m. .
Authodtp Sees Soe. 316. Pub.'1. 3-430. Mthe cet Lodemnity ultimately found to be (M Doc. 85-1147 FUed Stat. n. fr. et amended (7 UAC 150s,15161- due to you by us or by a final judgment . amassa coes omh, ,1-14-45. "* .
445 emJ 2.7 CR 403.7 is amendN by revising from and including h 81st day after the the introductory test of parsgraph (d). . date the insured signs. dates and -
and revising the following parts of the subrnits to us b properly completed NMR RENTOM Peach Crop insurance Policyt the table claim for indernalty form. lf the reason COMM!SSION .... . .
in 4.(b). 9 (e)(3)(a) and 8Lh. totisad: . for non psyment la not due toyour .2 ...- - -
.; . y failure to provide information er other 1C CFR Part 50. , , ~
material necusary for the computation' N * *PP***"*" *d P'**Y'. '
orpayment of theindemnity.The s AveBehmty of NRC Ptre Protectk>n
- * *- * * * * ~
interest rate will be that established by . P8887 Stwtng Comedttee Report For (d) The application for the 1965 and the Secretary of h Trsasury under Cosment ,.
succeeding crop years is found at section 12 of the Contract Disputee Act Subpart D of Part 400-General (41 USC 611] and pwblished in h
,,,,gyy,,j,,,it,",,j,,,,y ~
Administrative Regulations (7 CR Federal Register.This rate is referred to Coerenion. .
400.37.40038) and may be amended as b "Renegotiation Board interest Actioet Notice of evallebility of an'd from time to time for subsequent crop Rate" and is published semi-annually on ]c icy ue81I r comment 8 on fire protec' on years The provisions of the Peach p recommendations.
or about January 1 and July 1."The
. e py d l - --
\
l j
'. i Federal Resister / Vol. 50. No.10 / Tuesday. january 15. 1985 / Propoord Rules 3657 suuuanc.no sta!!of the Nuclear FEDERAL RESTRVE SYgTEM constrained to apprese the application Regulatory Ceauniusos is requesting ,
based en the liters) deruunon of M public comment on the 12 CFR Part 225 term "bank"in the Ba.nk Holding recommendations made by the Fire Company Act.ne Board expreseed its Protection Pohey Steering Csamittee for gm ,,, my concem that the ese of these limited i expediung comphance with fire Regulation Y; Permissible purpose banks to avoid the objectives of 1 protection requirements. tne Bank Holding Compeny Act la Traneoctiona Between Bank Holding j sava: Comment period expires February Companies and Dok WA M b Co andt t the prol os of !
14.1965. Commacts received afler this
- t slmi tramanecons would serlo4.aly e date will be considered ifit is acancy: Board of Covernors of the
' undermine the policies of the Bank practicable to do so but assurance for Federal Reserve System (FRB). Hol6ng Company Act. The Board found ,
! considerstion cannot given except as te actioet Solicitettoo of public comments, that use of this device presents the I
commenta received before this date. potential for a y Ar=at. haphazard.
I '
suunsanyt ne Federel Reserve Board le and possibly dangerous alterauon of the d soonasa Ma11 comunents to: Harold R- soliciting comment on wkther the nacon's banking structure without P Denton. Director. Office of Nuclear Board should pennit bank holdint Cc ngrusional sebon on the under!ying i Reactor Regulation. U.S. Nuclear companies ht os m conbank banks policy Lasues.la view of these concems.
j Regulatory Commlasion. Washington. (insututions Cat am chartered se banks the Board sporoved the application
- D.C. 20555, ATIN: Document Control but which either do not accept demand subject to the following conditiens: I l -
Desk. ' '", -
deposits or tio not make commercial (1) Applicant would not operate the 1 1
loana) to engage in certain transactiona nonbank bank's demand deposit takieg '
POR PWIrflest NW'omatafsoed coerfaCT*.
j Thomas V.Wambach.1 mad Project Manager. Fire Protecuon. Nuclear or totabhah or contLaue certain arrangements with bir nonbank bank act3vities in tenflem with any other subsidia or other anancialinantutions.
l subsidiaries. SpeciBeauy. such (2) Ap cant would not link to any ~
"} Regulatory rhta= ton. Washington.. transactions or arrangements would wey the mand deposit and l
i
- 9 D.C. 30555. Pheme: (301) 492-M2- include: . .
.. . commerdal leading services tha1 danne '
eumauertasry e' pones'anose s ne v*-
- 1. ne provialon of ceitala toternal . a bank ander the Act: and .o
- Nuclear Regulatory Conslasses is ,. administrative services to a noebank s (3) The nonbank bank would not - "-
laten &ng to mytew and approve a.
bad subisary- s engese in any tramasc6ons with -
Poucy br expediting complation of. . 2. Continuation of trust terrice and affiliates, other than the payment of invaatment arrangements that axisted dividends to t er the infusionef
- compliance wie the $m protacusaj . between a bank holding mapany and capital by into the nonbank mquirements for maclear power planta '. Its trust company subsidiary prior to tho' bank. without the Board's approval.
i j
' War APPendia R to 14 CHL Part 30' trust com 's conversion to a ' Tbm candluomo nere ntabushed to 4 A Steerios Comunates was appolated bT nonbank and . ensure that a acabeak bana would be i
, i the F.necutive Director for Operations... 3. OfBear and director laterlocks. Independent of its ambtes and that 6ta
'. and the Steenne Committee leased ,, , nats: AU comuments ahodd be steelved banking activides would not be .
re-amadations for the policy to be; by the Board by February 14.1s86. Integrated with thoes olita aTilletes l edopted by the twawaataa la s toport such that the spatitution would be a dated Ociober =.1 ne Om. f.. . acoassa
,,f,, ,o ooast AllNo.comm.en.ts. .,oo be@abodd -bea end-as . Aa nese condium l Nuclea/ Reactor Regula tion (QNRR) la ,, malled to Willians W. Wiles. Secretary. - wen inunded to pmvent puion M es ,
- seeking comments em the proposed . e.,. - basic poucy M me Act to sepamte policy. Copies of the Steering Committee Board of Covernare of the Federal ' ' - bading and commerce and to m@as Reserves Washington D.C.
/ Report an avallable for inspection and L 20651.or arod to Room S-2223. 20th inuntaa ***P U '"C* *I* ** ACU
- D" **
- - copying at the NRC Public Document & Consititution Avenue NW.
unpus.'% hamM '
l Room.1717 H Street NW. Wasblaston. Washington. D.C. betwesa 8:45 a.m. and was latended to establish a set of . !
D.C and at each of the Iacal Public . . . 535 p.m. weekdays. Comments may be mquimmuta a pucaW to 2e
-l Document Rooms louted in the vicinity inspected in Room S-1122 between 4:45 i an opee fgf, of each nuclear power plant .icensed or, i s.m. and 5.15 p.sa weekdays. ndig a nhdW under construction. (ne Steering organisations that would assun thet pon ruotsen sospoessanon oostfacTt . J.
Committee Report la en enclosum to
- these institutions would remain Virgil Matungly, Associate Cenwal independent and not integrated sto the Generic Latter 85-01. dated January S. - Couns el (202 / 452-3430). Ca rl Howard, 1s85.)Information regarding the locat'on Senior Counsel (202/452-37461. o' parent's operstions in such a mannee as to effect a combtnation of'canking and of Local Public Document Rooms can be Melanie 1. Fetc. Senjor Attorney (2C2/
obtained by calling the local Public . commerce or otherwise prohibited 3 452-3564). Lesel Division. intentaw deposit taking and s
, Document Room Branch's toll free suppt.ausertany suponasatioet On commerciallending.
numben 800-436-40e1. March 23.1964, the Board opproved the Following the Board's approval of the
- Dewd at Besada. Maryland. ei@ day applicauon by U.S.TrustCorporetion to U.S Treat application, a number of bank g I****'Y , ,
convert its state chartated florida trust bolding compenin a plied to acquim company into a nationaDy chartered simiier nor. bank be The Board ha e
.For the Nacieer Reguistory Commiss.on-
- 'nonbank bank" that would accept approved severalof these applications
' . .- demand deposits and make consumer.
Harold R. Destem. to date, subject to the same conditions it Derectar. 05ce e/NuckerReoro, but not cejnmercial. loans as defined by utablished in its U.S. Trust order.'
gym' the Board. U.S. Trust Corporation. To Fedetal Raserve Bulletin 371 (1964). In wm te M ere r1
[n Doc as.ns? Fited 1-16-as. ass am) its order approdng the U.S Tivst ns,,o a,w,, se u tmn sw er Am-ami.no ecoe resee a application, the Board stated that it was c- = w i 1
l l
\
/* jo, f3 g
.( }t UNITED STATES NUCLEAR REGULATORY COMMISSION e
.e*
! WASHING TON, D. C. 20656
[ k h --- NC
~
D Y. _lM
~
NOV 2 ? 1985 Q w ,
MEMORANDUM FOR:
( pm[
Harold R. Denton Director ro Office of Nuclear, Reector Regulation !
FROM:
Faust Rosa, Chief y
Division of PWR Licensing AElectrical, anch g instrument
SUBJECT:
RECOMMENDED RESOLUTION OF THE DP0 ON "INTERPRETATIONS OF APPENDIX R" As requested by your memorandum of June 15 DP0 was filed jointly by five staff fire protectipenden onal opinion (DPO). The D. J.ofKubicki, Ulle RIII and J. F. Stang, Jr. of CMEB/NRR on engineers R. Eberly. * !
which are con)s. idered by these staff membe sppendix tThe DP0 conce 1 r R Based on my assessment, I have cation cf a mana of Appendix concluded R issues. that thj "ggency practice.gement decision, policy position, or a propo Rhat the DP0 be considered resolved in Section G.1.c.
paragraphs.
a enaccordance wit i.e.,
of relevantEncle.sure reference documents.1 provides a chronology e following of DP0 d i n ation and a list i The DPO, which was filed on May 2,1984 "Interpretations of Appendix R" Facilities Operating Prior To Fire Protection Jan(uary
,1979).
1 Program for Nuclear Pow ELD and DEDROGR.were developedThe byproposed mar.sgement level fire protectio(
interpretations ;
Fire Protection held duringegional the rMarch-April uted to Workshops on 1 ashops later datethebeing draft was characterized as considered. beingAttentative me frame. these work-
, with femal issuance at Section 5. Automatic Detection and SuppressionThe Appendix R. on 4. Fire Area Boundaries, and
, of the Interpretations of partial area coverage for fire by analysis that ad suopressionre area boundaries and and detThe Int ated with the area.
as exemptions. Such analequate protection is provided for the fire hazar Additionally, yses have previously been approved by the staff -
tions" do rot require submission in contrast ofwith fire prior haza practice, d the "Interp the e filing of exemption requests orterr s to fi analyses for staff review reta-or re protection inspections; but the Qpy snnVW0 Op mUoh '"'
, * *. ..~
H. Denton 2 analysis must be available for NRC audit. The DP0 states that not requiring exemption requests is in conflict with Generic Letter 83-33 which was issued prevfously to clarify staff positions on these and other issues, and which is deemed preferable.
The issues raised by the DP0 are not of a technical nature but relate to NRC fire protection policy, Therefore, a resolution could only come about as a result of a comprehensive review of this policy undertaken by an appropriate level of NRC management. Such a review has been perforined by the Steering Committee on Fire Protection Policy which was convened for this purpose in September 1984 This comittee, which was composed of individuals at the Division Director level of management, drew its membership from NRR, ELD, IE, and three of the Regions. The recomendations and the fire protection guidance package contained in the Steering Comittee final report were incorporated in SECY-85-306 (Enclosure 2) which was submitted to the Comission by the EDO on September 17, 1985 Enclosure 2, in addition to the staff recomendations and the guidance package, includes discussions of all aspects of the fire protection issue including the DP0 and, with its enclosures, documents the scope and depth of the policy and program review performed by the Steering Comittee.
The "Interpretations of Appendix R" which are included in the guidance package do not differ significantly from the original version on which the DP0 was based. The Steering Comittee reviewed the positions defined in the "Inter-9 pretations" and concluded that they are technically and legally consistent with the requirements of Appendix R. Enclosure 2 includes a staff recomendation to the Comission to fonnally issue the "Interpretations."
In making my assessment of the DP0 I have: (1)evaluatedtheOP0 documentation and references listed in Enclosure 1, (2) met with the DP0 originators and other senior staff embers involved in fire protection to explore the technical, legal l and procedural aspects of the issue, and (3) participated in the discussions of the DP0 and related fire protection concerns in the meetings of the Steering ;
Comittee (as Chairman of its Working Group). I concur in the Steering Com-mittee's conclusion that the positions defined in the "Interpretations" are i
technically and legally consistent with Appendix R. I further conclude that i this issue has received the management review comensurate to its importance l to safety. My recoernendation for resolution of the DP0 is based on this i assessment. '
l A Comission meeting was held on October 3,1985 to discuss the staff recom-mendations. At this meeting the Comission requested that the originators of the DP0 provide a written sumary statement of their position in view of the staff's recomendation in regard to the DPO. (It is noted that to date the Comission has not taken Etion en the staff recomendations.)
In a response to the Comission's request, Mr. Stang stated that the proposed resolution adequately satisfies his concerns raised in the DP0 and that he considers the DP0 resolved.
i 1
1
i k . )
H. Denton Mr. Ulie's response provided additional coments on the possible adverse
~
effects of implementing the "Interpretations." He also indicated that the intent of his OP0 was to make NRC management aware that the "Interpretations" represented a significant change in NRC policy and practice, and that this ob-jective had been achieved. In a recent telephone conversation with me, Mr. Ulie ;
confinned that he now considers the DP0 issue closed. !
Mr. Ramsey's response provides detailed coments primarly expressing disagree.
ment with the staff reconsnendations in the following areas: adequacy of current guidance to the industry, documentation required to demonstrate compliance, Interpretations of Appendix R. Appendix R Questions and Answers, QA require-ments, and fire hazard anclysis. Most of these coments extend beyond the ]
scope of the original DPO. However, in my view, they do not change the basic j character of the DP0 which relates to matters of NRC fire protection policy. l The Steering Committee review of fire protection policy encompassed the areas !
addrrssed by these additfor.al coments. Therefore, I conclude that the resolu-tion of the DP0 on the basis described above remains valid.
Mr. Kubickt has not provided a written response to the Comission's request.
However, in a recent conversation with me on this satter he indicated that his ,
views as expressed in the DP0 remain unchanged.
It should also be noted, as a matter of record, that Mr. Eberly has left the l Comission for employment in the private sector. No further action is required by Manual Chapter 4125 in this case.
In sumary, my resolution of the OP0 is based on the premise that the OP0 is i
primarily concerned with NRC fire protection policy and, therefore, its re- l solution could only come about thrcug;. a comprehensive review of this policy by l an appropriate level of NRC management. Such a review has been completed by the l Steering Comittee on Fire Protection Policy. The conclusion reached by the :
Steering Comittee is that the "Interpretations of Appendix R" is technically !
and legally consistent with Appendix R. Based on this the staff has recom- i mended to the Comission that the "Interpretations" be fomally issued.
This in effect, states, that the OP0 fails to justify modification of a manage-ment decision, policy position, or a proposed or existing agency practice.
Therefore, I recomend that no action need be taken, i.e., that the DP0 be considered resolved in acccrdance with NRC Manual Appendix 4125. Section G.I.c.
l N
Faust Rosa, Chief Electrical, Instrumentation &
Control Systems Branch Division of PWR Licensing A Enclosures /cc: See next page i I
l l
l l
l l
l
_ _ _ . . _ _ - ~ _ _ . _ . _ _ . . _ _ _ _ _ . _ , _ _ . _ , _ _ _ _ _
l
H. Denton o -4
Enclosures:
- 1) Chronology of OP0 Documentation and Listing of Relevant References
- 2) SECY-85-306, Staff Recomendations Regarding the Implementation of Appendix R to 10CFR50 dated September 17, 1985 cc: w/o Enclosure 2:
D. G. Eisenhut T. E. Murley, R!
J. N. Grace, RII J. G. Keppler, RI!!
R. H. Vollmer H. Thompson W. V. Johnston J. L. Funches J. E. Lyons V. Benaroya R. L. Ferguson W. M. Shields T. V. Wambach cc: w/
Enclosures:
D. J. Kubicki C. B. Ramsey, Rl!!
J. F. Stang, Jr. ~
J. M. Ulie, RIII 4
4 e
ENCLOSURE 1 CHRONOLOGY OF DP0 DOCUMENTATION AND LISTING OF RELEVKNT REFERENCES CHRONOLOGY:
- 1. May 2,1984, Memo from R.andy Eberly, Dennis Kubicki. Chuck Ramsey, John Stang and Joe Ulie to R. L. Ferguson; Differing Professional Opinion "Interpretations of Appendix R."
- 2. May 3,1984, Memo from R. H. Vollmer to the other NRR Division Directors, DP0 and Interpretations of Appendix R.
- 3. May 7,1984, Memo from R. L. Ferguson to Randy Eberly, Dennis Kubicki, ,
Chuck Ramsey, John Stang and Joe Ulie; Differing Professional Opinion - '
"Interpretations of Appendix R."
- 4. May 11, 1984, Memo from V. Benaroya to R. H. Vollmer Differing Professional Opinion "loterpretations of Appendix R."
- 5. May 30, 1984, Memo from R. L. Ferguson to H. R. Denton, Differing Professienal Opinion "Interpretations of Appendix R."
- 6. Undattd/ Copy delivered by originator May 31, 1984 Memo from G. Harrison to Commission Victor Gilinsky, Differing Professional Opinion -
"Interpretations of Appendix R" dated May 2,1984. Eberly, et al.
- 7. May 30, 1984 Memo from R. H. Vollmer to H. R. Denton, Differing Professional Opinion "Interpretations of Appendix R."
- 8. June 15, 1984 Memo from H. R. Denton to F. Rosa, Differing Professional Opinion - Interpretation of Appendix R.
- 9. I
. July 6,1964, Memo from F. Rosa to H. R. Denton, Differing Professional Opinion - Interpretation of Appendix R. l
- 10. July 12, 1984, Mero from H. R. Denton to F. Rosa, Differing Professional Dpinion - Interpretation of Appendix R. l
- 11. July 17, 1984, Memo from J. G. Keppler to R. C. DeYoung, Commissioners' Request For Information on Fire Protection Diffeeing Professional Opinion and Inspection Experience.
- 12. August 9, 1984 Memo from H. R. Denton to F. Rosa, Differing Professional Opinion - Interpretations of Appendix R.
1 1
\g 3
- 13. Oct. 4, 1984, Memo from H. n. r n w W. J. Dircks, Differing Professional Opinion On Inte,* cions of Appendix R; Action Plan.
- 14. November 9,1984, Memo from r,. w. Denton to L. W. Barry, Quarterly Report: Differing Professional Opinion.
- 15. February 7, 1985, Memo from F. Rosa to H. R. Denton, Differ'ng Professional Opinion on Interpretations of Appendix R. Status enc Action Plan Update.
- 16. February 26, 1985, Nemo from H. R. Denton t) W. J. Dircks, RequM t for Extension For P.esolution of the Differing Professional Opinion On Interpretations of Appendix R.
I
- 17. September 17,1985, SEC-85-306, Staff Recomendations Regarding the Implementation of Appendix R. -
- 18. September 20, 1985, Memo from J. Stang to J. A. Zwolinski, Differing Professional Opinion "Interpretations of Appendix R." May 2,1984,
- 19. October 25, 1985, Memo from J. M. Ulie to J. G. Keppler, Request by the Comissinners for the DP0 Originators to Write a Sumary Statement O Regarding Their Position On the Fire Protection Policy Steering Comittee's Proposea Resolution of the DPO.
- 20. October 25, 1985, Memo from '. Ramsey to J. G. Keppler Request by the Comissioners for the DP0 Originators to Write a Jumary Statemert Regarding Their Position On the Fire Protection Policy Steering Comittee's Recomendations Contained in Generic Letter 85-01.
- 21. November 14, 1985, Memo from C. Ramsey to R. Ferguson, Supplemental Response to Generic letter No. 85-01 and SECY Paper No.85-306.
REFERENCES l
l
- 1. 10 CFR 50.48 Fire Protection.
- 2. 10 CFR 50, Appendix R - Fire Protection Program for Nuclear Power Facilities Operating Pric,r To January 1,1979.
- 3. NijREG-0800 Section 9.5.1, Fire Protection Progra , Pov. 3 - July 1981.
- 4. Branch Technical Position CHEB 9.5-1 (Fomerly BTP ASB 9.5-1),
Guidelines for Fire Protection for Nuclear Power Plants, Rev. 2 -
July 1981.
- 5. Generic Letter 83-53, NRC Positions On Certe.in Rectirements ?f Appendix R to 10 CFR 50, October 19, 1983.
...o -- -e
-. , , -.-f -
m.s.m.-. wr --- -w - - --
,.. ~ . , ;
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I *....
POLICY ISSUE (Notation Vote)
December 19, 1985 SECY-85-306p I
1 For: The Comissioners From: William .1. Dircks Executive Director for Operations
Subject:
STAFF RECOMMENDATIONS REGARDING THE IMPLEMENTATION OF APPENDIX R TO 10 CFR 50 j Discussion: At the October 3 briefing of the Comission on SECY-85-306, Staf f Recomendations Regarding the Implementation cf Appendix R to 10 CFR Part 50, we discussed and recomended an approach not specifically identified in the SECY pacer. We indicated that
, the best aporoach would be to encourage licensees to include )
their fire protection program commitants (including certain of current fire protection technical specifications) into an FSAR update and adopt a standard license condition requiring adherence to the FSAR but providing flexibility for making changes under 50.59. This approach would make the fire protection commitments enforceable, yet lessen the number of technical specification )
requirements.
A revision of Enclosure 3 to SECY-85-306, the proposed Generic Letter on Fire Protection, which would implement this approach is enclosed. Changes, in comparative text, are containec only in Section F.
The standard license condition has been modified somewha' from that provided in SECY-85-306. The condition enclosed would i allow changes to be made within the amt 't of 50.59, but would CONTACT:
Richard H. Vollmer, IE 49-28177 C
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p t ers,1
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i 2 require a license amndment where the proposed change to the approved program would adversely affect the ability to achieve and maintain safe shutdowri in the event of a fire. This recuire-ment ensures that all facilities will be held to the level of protection required by Appendix R unless the Comission speci-fically allows otherwise after prior review.
\
fgl iam J. Dircks Qxecutive s
Director for Operations
Enclosures:
- 1. Revision to Enclosure 3, SECY-85-306
- 2. Revision to Enclosure 6, SECY 85-306 Commissioners' comments or consent should be provided directly to the Office of the Secretary along with their votes on SECY-85-306 and by c.o.b. Monday, January 13, 1986.
Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Monday, Januarv 6, 1986, with an information copy to the Office of the Secretary. If the paper is of such a nature that it requires additiorial time for : nalytical review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.
DISTRIBUTION: l Commissioners l OGC OPE OI OCA OIA OPA REGIONAL OFFICES EDG ELD ACRS ASLBP ASLAP SECY
l GENERIC LETTER ON FIRE PROTECTION TO ALL LICENSEES AND APPLICANTS FOR OPERATING LICENSES Genciesen:
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SUBJECT:
IMPLEMENTATION OF FIRE PROTECTION REQUIREMENTS In the Spring of 1984, the Comission held a series of Regional Workshops on the implementation of NRC fire protection requirements at nuclear powr plants.
At those workshops, a package of recently-developed NRC guidance was dis- ,
tributed to each attendee which included NRC staff responses to industry ;
questions and a document titled "Interpretations of Appendix R." The cover i memo for the package explained that it was a draf t package which would be f issued in final fonn via Generic Letter following the workshops, l l
The guidance approved by the Comission is appended to this letter, and is in the same format as the draft package, i.e., "Interpretations of Appendix R" and responses have been modified from the draft package, and a number of in-dustry questions raised at or subsequent to the workshops have been added and )
answered. This package represents recent staff assessment of these questions ,
and provides guidance as to acceptable methMs of satisfying Comission regu- !
latory requirements. Other methods proposed by licensees for complying with l Comission regulations may also be satisfactory and will be considered on their own merits. To the extent that this guidance may be inco"-istent with prior guidance (including Generic Letter 83-33), it is intende at the current letter takes pre:edence, i I
If you have any questions, you should contact the NRC Project Manager for your I facility. !
In the lettered sections below, some additional topics are covered which also )
bear on the interpretation and implementation of NRC fire protection require-ments. The topics are: ( A) schedular exemptions, (B) revised inspection program, 'C) documentation required to demonstrate compliance, (D) quality I assurance requirements applicable to fire protection systems, and (E) notifi- !
cation of the NRC when deficiencies are discovered.
A. Schedular Exemptions The Appendix R implementation schedule was established by the Comission in 10 CFR 50.48(c), oromulgated together with Appendix R in November of 1980.
Allowing time to evaluate the need for alternative or dedicated shutdown systems, which require prior NRC approval before installation, and time for i design of and NRC review of such systems, the Comission envisioned that implementatiot, of Appendix R would be complete in four to five years, o-approximately by the and of 1985. Many schedule extensions ware granteo by i the staff under the "tolling provision," 50.48(c)(6), and under 10 CFR S0.12, I the longest of which now extends into 1987. Some licensees have proceeded expeditiously to implement Append) ' and are now finished or nearly finished with that effort. Others hava enga g in lengthy negotiations with the staff while continuing to file requests for chedule extensions, and thereby have barely begun Appendix R modifications needed to comply with Sections III.G
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and III.L. Schedule extension recuests base been received seeking implementa-tion dates of 1990 or beyerd.
As the 50.48(c) schedule was intended to be a one-time schedule correncinc in the 1980-1982 time frame and ending in the 1985 time frame, extensions weil beyond this schedule (particularly where major modifications remain to De completed) undennine the purpose of the schedule, which was to achieve ex.
peditious compliance with NRC fire protection requirements. For that reason, additional schedular exemptions may be requested under 10 CFR 50.12, but such requests will be granted sparingly based on the following criteria:
- 1. The utility has, since the promulgation of Appenoix R in 1980, proceeded expeditiously to meet the Comission's requirements.
- 2. The delay is caused by circumstances beyond the utility's control.
- 3. The proposed schedule for completion represents a best effort under the circumstances.
4 Adequate interim cotrpensatory measures will be taken until com- i pliance is achieved. ,
The NRC is currently reviewing all dockets of plants covered by the 50.48 schedule to determine schedule deadlines. When this review is completed, I oach licensee will be informed of the deadlines.
B. Revised Inspe: tion Procram 1 1
In 1982, the NRC developed an insiection program to verify compliance with the requirements of 10CFR50, Appendix R. This program was primarily oriented towards reviewing safe shutdcwn features of those pre-1979 licensees that had completed Appendix R modifications and selected NT0L plants. From 1982 to the ,
present, a number of Appendix R cunpliance inspections have been performed.
In many of the initial inspections it was found that licensees had made significant errors in implementing a number of Appendix R requirements.
The NRC will continue to conduct inspection of fire protection features. In the case of completed modifications, the inspection team will review com-pliance with applicable requirements. In the case of incomplete modification, the inspection team will review licensee approach to compliance, plans and l schedules for completing such modifications. The NRC will attempt to review implementation of fire protection features on a schedule that will minimize the chances of licensees implementing features in a manner that does not meet with staff approval. Additionally, reouests for this review and/or inspection by licensees will be granted within NRC resource constraints.
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C. Documentation Reauired to Demonstrate Comoliance The "Interpretations" document attached to this letter states that, where the Ifcr.nsee chooses not to seek prior NRC review and approval of, for example, a fire area boundary, an evaluation must be perfore,ed by a fire protoction engineer (assisted by others as needed) and retained for future NRC audit. Evaluations o' this tvpe must be written and organized to facil-itate review by a person net involved in the evaluation. Guidelines for what such an evaluation should contain may be found in: (1) Section B of Appendix R and (2) Section C..,b of Branch Technical Position (BTP) CMEB 9.5-1 Rev. 2 dated July 1981. All calculations supporting the evaluation should be available and all assumptions clearly stated at the outset. The NRC intends to initiate enforcement action where, for a given fire area, l compliance with Appendis. R is not readily demonstrable and the licensee does ;
riot have available a written fire hazard analysis for the area. The terin i "readily demonstrable' includes situations where compliance is apparent by observation of the potential fire hazard and the existing protective features. l i
D. Quality As'surance Reauirements Applicable For fire protection systems the licensee should have and maintain a quality l assurance program that provides assurance that the fire protection systems will be designed, fabricated, erected, tested, maintained and operated so-that they will function as intended. Fire protection systems are not "safety-related" and are therefore not within the scope of Appendix B to 10 CFR Part 50, unless the licensee has comitted to include these systems under the Appendix B program for the plant. NRC guidance for an acceptable quality assurance program for fire protection systems, given in Section C 4 of Branch Technical Position CMEB 9.5-1 Rev. 2 dated July 1981, has generally been used in the review and acceptance of approved fire protection programs for plants licensed after January 1, ' 979. For plants licensed prior to January 1,1979, similar guidance was referenced in footnotes 3 and 4 to 10 CFR 50.48. They are contained in BTp APCSB 9.5-1 and Appendix A thereto and in "Nuclear Plant Fire Protection Functional Responsibilities, Admini-strative Control and Quality Assurance" dated June 14, 1977 E. Notification of the NRC When Deficiencies are Discovered Licensees are reminded of their obligation to notify the NRC of fire protection !
deficiencies which meet the criteria of 10 CFR 50.72 or 10 CFR 50.73 as I applicable.
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F. Addition of Fire Protection procram into FSAR Most licenses contain a section on fire protection. License conditions for plants licensed prior to January 1,1979, contain a condition requiring imple-mentation of modifications comitted to by the licensee as a result of the BTP review. 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.
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4 Two points should be noted in regard to these conditions: (1) they did not explicitly cover required fire protection features where modifications to the existing plant configuration or procedures were not required, and (2) I some of the provisions in these conditions may have been superseded by l Sections Ill.G, J. O, and L of Appendix R. I License conditions for plants licensed af ter January 1,1979 vary widely in scope and content. Some only list open items that must be resolved by a specified date or event, such as exceeding fiva percent power or the first refueling outage. Some reference a comitment to meet Appendix R; some reference the FSAR and/or the NRC staff's SER. These variations have created l problems for licensees and for NRC inspectors in identifying the operative and enforceable fire protection requirements at each facility.
These license conditions also create difficulties because they do not specify l when a licensee may make changes to the approved program without requesting a i license amendment. If the fire protection program comitted to 'y o the licensee is required by a specific license condition or is not part of the FSAR for the facility, the provisions of 10 CFR 50.59 may not be applied to make changes ,
without prior NRC approval. Thus licensees may be required to submit amendment l requests even for relatively minor changes to the fire protection program.
The aforementioned problems, in general, exist because of the many submittals that constitute the fire protection program for each plant. The Comission believes that the best way to resolve these problems is to incorporate the I fire protection program, including the fire hazards analysis and the fire protection Technical Soecifications, into the Final Safety Analysis Report (FSAR) for the facility. In this manner, the fire protection program, including i tne systems, the administrative and technical controls, the organization, and i other plant features associated with fire protection would be on a consistent '
status with other plant features described in the FSAR. Also, the provisions of 10 CFR 50.59 would then apply directly for changes the licensee desires to i make in the fire protection program that would not adversely affect the 1 ability to achieve and maintain safe shutdown. In this context, the ceter-mination of tne involvement of an unreviewed safety question defined in 850.59(a)(2) would be made based on the "accident....previously evaluated" l being the postulated fire in the fire hazards analysis for the fire area affected by the change. The Comission also believes that a standard )
I license condition, requirinc licensees to comply with the provisions of the f_ ire orotection program as cescribed in the FSAR, should be used to ensure uniform enforcement of fire protection requirements.
Therefore, each licensee should include, in the FSAR update required by 10 CFR 50.71(e) that will fall due more than 6 months after the date of this letter, the incorporation of the fire protectTon program that has been approved by the NRC, ircluding the fire hazards analysis that foms the basis for the fire protection program , and the fire protection Technical Specifications. This incorporation may be by reference to specific previous submittais ano the NRC approvals where appropriate. Upon completion of this effort, including the certification required by 10 CFR 50.71(e)(2), the licensee may apply for an
h 5-amendmenttotheoperatinglicensewhich(deletes] amends (thepresent]any I current license conditions regarding (the] fire protection [ program] and
[ completed fire protection features. Inclusion of the fire protection program in the FSAR will be a prerequisite for licensing for all applications now under l review. No license condition would then be required.]
substitutes the following standard condition:
- 1. The licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility (or as described in submittals dated
) and as approved in the SER dated ---------(and Supplements dated ---------) subject to the following provision.
- 2. Tre licensee may not make changes to the approved fire protection program which would adversely affect the ability to achieve and maintain safe shutdown in the event of a fire without prior approval of the Commission.
The licensee may alter specific features of the approved program provided l (a) such changes do not otherwise involve a change in a license condition or l technical specification or result in an unreviewed safety question l (see 10 CFR 50.59), and (b) such changes do not result in failure to complete . l the fire protection program as approved by the Commission. As with other changes implemented under 10 CFR 50.59, the licensee shall maintain, in auditable form, a current record of all such changes, including an analysis of the effects of the change on the fire protection program, and shall make such records available to NRC inspectors upon request. All changes to the approved program shall be reported annually to the Director of the Office of Nuclear Reactor Regulation, along with the F5AR revisions required by l 10 CFR 50.71(e) . l l
Temporary changes t) sDecific fire protection features which may be necessar,y to accomolish maintenance or modifications are acceptable proviced interim compensatory measures are imolemented.
At the same time the licensee may request an amendment ~to delete the technical specifications that will now be unnecessary. If licensees fail to reouest amendments to their licenses to add this condition, the Connission will consider whether such changes should be required by c.' der or by rule.
Inclusion of the fire protection program in the FSAR will be a prerequisite for licensing for all applications now under review. The standard license condition will be included in new licenses.
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Enclosure 6 FIRE PROTECTION LICENSE CONDITION
- 1. The licensee shall implement and maintain in effect all provisions of the apprcved fire protection program as described in the Final Safety Analysis Report for the facility (or as described in submittals dated
) and as approved in the SER dated ---------( and Supplements )
dated ---------) subject to the following provision, ;
- 2. The licensee may not make changes to the approved fire protection program which would adversely affect the ability to achieve and maintain safe shutdown in the event of a fire without prior approval of the Conynission.
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