NRC Generic Letter 1986-10
UNITED STATESNUCLEAR REGULATORY COMMISSIONE ,WASHINGTON, D. C. 20555April 24, 1986TO ALL POWER REACTOR LICENSEES AND APPLICANTS FOR POWER REACTOR LICENSESGentlemen:
SUBJECT: IMPLEMENTATTON OF FIRE PROTECTION REQUIREMENTS(GENERIC LETTER 86-10)In the Spring of 1984, the Commission held a series of Regional Workshopson the implementation of NRC fire protection requirements at nuclear powerplants. At those workshops, a package of recently developed NRC guidance:was distributed to each attendee which included NRC staff responses toindustry questions and a document titled "Interpretations of Appendix R."The cover memo for the package explained that it was a draft package whichwould be issued in final form via Generic Letter following the workshops.The guidance approved by the Commission is appended to this letter, and isin the same format as the draft package, i.e., "Interpretations of AppendixR" and responses have been modified from the draft package, and a number ofindustry questions raised at or subsequent to the workshops have been addedand answered. This package represents recent staff assessment of thesequestions and provides guidance as to acceptable methods of satisfyinaCommission regulatory requirements. Other methods proposed by licenseesfor complying' with Commission regulations may also be satisfactory and willbe considered on their own merits. To the extent that this guidance may beinconsistent with prior guidance (lincluding Generic Letter 83-33), it isintended that the current letter takes precedence.If you have any questions, you should contact the NRC Project Manager foryour lfacility.In the lettered sections below, some additional topics are covered whichalso bear on the interpretation and implementation of NRC fire protectionrequirements. The topics are: (A) schedular exemptions, (B) revisedinspection program, (C) documentation required to demonstrate compliance,(0) quality assurance requirements applicable to fire protection systems,(E) notification of the NRC when deficiencies are discovered, and (F) additionof fire protection program into FSAR.A. Schedular ExemptionsThe Appendix R Implementation schedule was established by the Commission in10 CFR 50.48(c), promulgated together with Appendix R in November of 1980.Allowing time to evaluate the need for alternative or dedicated shutdownsystems, which require prior NRC approval before installation, and time fordesiqn of and NRC review of such systems, the Commission envisioned thatimplementation of Appendix R would be complete in 4 to 5 years, or approxi-mately by the end of 1985. Many schedule extensions were granted by thejilDk-I8604290180) MFCe,
-2-staff under the "tolling provision" 50.48(c)(6), and under 10 CFR 50.12,the longest of which now extends into 1987. Some licensees have proceededexpeditiously to implement Appendix R and are now finished or nearly finishedwith that effort. Others have engaged in lengthy negotiations with the staffwhile continuing to file requests for schedule extensions, and thereby havebarely begun Appendix R modifications needed to comply with Section III.G andand III.L. Schedule extension requests have been received seeking implementa-tion dates of 1990 or beyond.As the 50.48(c) schedule was intended to be a one-time schedule commencing inthe 1980-1982 time frame and ending in the 1985 time frame, extensions wellbeyond this schedule (particularly where major modifications remain to becompleted) undermine 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 5n.12, but suchrequests will be granted sparingly based on the following criteria:1. The utility has, since the promulgation of Appendix R in 1980,proceeded expeditiously to meet the Commission's requirements.2. The delay is caused by circumstances beyond the utility's control.3. The proposed schedule for completion represents a best effortunder the circumstances.4. Adequate interim compensatory measures will be taken until com-pliance is achieved.The NRC is currently reviewing all dockets of plants covered by the 50.48schedule to determine schedule deadlines. When this review is completed,each licensee will be informed of the deadlines.B. Revised Inspection ProgramIn 1982, the NRC developed an inspection program to verify compliance withthe requirements of 10CFR50, Appendix R. This program was primarily orientedtowards reviewing safe shutdown features of those pre-1979 licensees that hadcompleted Appendix R modifications and selected NTOL plants. From 1982 to thepresent, a number of Appendix R compliance inspections have been performed.In many of the initial inspections it was found that licensees had madesignificant errors in implementing a number of Appendix R requirements.The NRC will continue to conduct inspection of fire protection features. Inthe 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 andschedules for completing such modifications. The NRC will attempt to reviewimplementation of fire protection features on a schedule that will minimizethe chances of licensees implementing features in a manner that does notmeet with staff approval. Additionally, requests for this review and/orinspection by licensees will be granted within NRC resource constraint C. Documentation Required to Demonstrate ComplianceThe "Interpretations" document attached to this letter states that, wherethe licensee chooses not to seek prior NRC review and approval of, forexample, a fire area boundary, an evaluation must be performed by a fireprotection engineer (assisted by others as needed) and retained for futureNRC audit. Evaluations of this type must be written and organized to facil-itate review by a person not involved in the evaluation. Guidelines for* what such an evaluation should contain may be found in: (1) Section B ofAppendix R and (2) Section C.1.b of Branch Technical Position (RTP) CMEB9.5-1 Rev. 2 dated July 1981. All calculations supporting the evaluationshould be available and all assumptions clearly stated at the outset. TheNRC intends to initiate enforcement action where, for a given fire area,compliance with Appendix R is not readily demonstrable and the licensee doesnot have available a written fire hazard analysis for the area. The term"readily demonstrable" includes situations;where compliance is apparent byobservation of the potential fire hazard and the existing protective features.D. Quality Assurance Requirements ApplicableFor fire protection systems the licensee should have and maintain a qualityassurance program that provides assurance that the fire protection systemswill be designed, fabricated, erected, tested, maintained and operated sothat they will function as intended. Fire protection systems are not"safety-related" and are therefore not within the scope of Appendix B to10 CFR Part 50, unless the licensee has committed to include these systemsunder the Appendix B program for the plant. NRC guidance for an acceptablequality assurance procram for fire protection systems, given in Section C.4of Branch Technical Position CMEB 9.5-1 Rev. 2 dated July 1981, has generallybeen used in the review and acceptance of approved fire protection programsfor plants licensed after January 1, 1979. For plants licensed prior toJanuary 1, 1979, similar guidance was referenced in footnotes 3 and 4 to10 CFR 50.48. They are contained in BTP APCSB 9.5-1 and Appendix A theretoand in "Nuclear Plant Fire Protection Functional Responsibilities, Adminis-trative Control and Quality Assurance" dated June 14, 1977.E. Notification of the NRC When Deficiencies are DiscoveredLicensees are reminded of their obligation to notify the NRC of fire protectiondeficiencies which meet the criteria of 10 CFR 50.72 or 10 CFR 50.73 asapplicable.F. Addition of Fire Protection Proqram into FSARMost licenses contain a section on fire protection. License conditions forplants licensed prior to January 1, 1979, contain a condition requiring imple-mentation of modifications committed to by the licensee as a result of theBTP review. These license conditions were added by amendments issued between1977 and February 17, 1981, the effective date of 10 CFR 50.48 and Appendix Two points should be noted in regard to these conditions: (1) they did notexplicitly cover required fire protection features where modifications tothe existing plant configuration or procedures were not required, and (2)some of the provisions in these conditions may have been superseded bySections III.G, J, 0, and L of Appendix R.License conditions'for plants licensed after January 1, 1979 vary wi dely inscope and content. Some only list open items that must be resolved by aspecified date or event, such as exceeding five percent power or the firstrefueling outage. Some reference a commitment to meet Appendix R; somereference the FSAR and/or the NRC staff's SER. These variations have createdproblems for licensees and for NRC inspectors in identifying the operativeand enforceable fire protection requirements at each facility.These license conditions also create difficulties because they do not specifywhen a licensee may make changes to the approved program without requesting alicense amendment. If the fire protection program committed to by the licenseeis required by a specific license condition or is not part of the FSAR for thefacility, the provisions of 10 CFR 50.59 may not be applied to make changeswithout prior NRC approval. Thus licensees may be required to submit amendmentrequests even for relatively minor changes to the fire protection program.The aforementioned problems, in general, exist because of the many submittalsthat constitute the fire protection program for each plant. The Commissionbelieves that the best way to resolve these problems is to incorporate thefire protection program and major commitments, including the fire hazardsanalysis, by reference into the Final Safety Analysis Report (FSAR) for thefacility. In this manner, the fire protection program, including thesystems, the administrative and technical controls, the organization, andother plant features associated with fire protection would be on a consistentstatus with other plant features described in the FSAR. Also, the provisionsof 10 CFR 50.59 would then apply directly for changes the licensee desiresto make in the fire protection program that would not adversely affect theability to achieve and maintain safe shutdown. In this context, the determina-tion of the involvement of an unreviewed safety question defined in550.59(a)(2) would be made based on the "accident.... previously evaluated"being the postulated fire in the fire hazards analysis for the fire areaaffected by the change. The Commission also believes that a standardlicense condition, requiring licensees to comply with the provisions of thefire protection program as described in the FSAR, should be used to ensureuniform enforcement of fire protection requirements.Therefore, each licensee should include, in the FSAR update required by10 CFR 50.71(e) that will fall due more than 6 months after the date of thisletter, the incorporation of the fire protection program that has been approvedby the NRC, including the fire hazards analysis and major commitments that formthe basis for the fire protection program. This Incorporation may be byreference to specific previous submittals and the NRC approvals whereappropriate. Upon completion of this effort, including the certificationrequired by 10 CFR 50.71(e)(2), the licensee may apply for an amendment to the operating license which amends any current license conditionsregarding fire protection and substitutes the following standard condition:Fire Protection(Name of Licensee) shall implement and maintain in effect all provisionsof the approved fire protection program as described in the FinalSafety Analysis Report for the facility (or as described in submittalsdated ------------) and as approved in the SER dated ------------(andSupplements dated ---- ----) subject to the following provision:The licensee may make changes to the approved fire protectionprogram without prior approval of the Commission only if those chanceswould not adverselyaffect the-ability to achieve and maintain safeshutdown in the event of a fire.'The licensee may alter specific features of the approved program provided(a) such changes do not otherwise involve a change in a license conditionor technical specification or result in an unreviewed safety question(see 10 CFR 50.59), and (b) such changes do not result in failure tocomplete the fire protection program as approved by the Commission. Aswith other changes implemented under 10 CFR 50.59, the licensee shallmaintain, in auditable form, a current record of all such changes,including an analysis of the effects of the chance on the fire protectionprogram, and shall make such records available to NRC inspectors uponrequest. All changes to the approved program shall be reported annuallyto the Director of the Office of Nuclear Reactor Regulation, along 'withthe FSAR revisions required by 10 CFR 50.71(e).Temporary changes to' specific fire protection features which may be neces-sary to accomplish maintenance or modifications are acceptable providedinterim compensatory measures are implemented.At the same time the licensee may request an amendment to delete the technicalspecifications that will now be unnecessary.Inclusion of the fire protection program in the FSAR will be a prerequisitefor licensing for all now under review. The standard license condition willbe included in new licenses.
Sincerely,.ise huty DirectorOffice of Puclear Reactor Regulation
Enclosures:
1. Interpretations of Appendix R2. Appendix R Questions and Answers3. Fire Protection License Condition ENCLOSURE 1INTERPRETATIONS OF APPENDIX R1. Process Monitoring InstrumentationSection III.L.2.d of Appendix R to 10 CFR Part 50 states that "the processmonitoring function shall be capable of providing direct readings of theprocess variables necessary to perform and control" the reactivity controlfunction. In I&E Information Notice 84-09, the staff provides a listing ofinstrumentation acceptable to, and preferred by the staff to demonstratecompliance with this provision. While this guidance provides an acceptablemethod for compliance with the regulation, it does not exclude otheralternative methods of compliance. Accordingly, a licensee may propose to thestaff alternative instrumentation to comply with the regulation (e.g., boronconcentration indication). While such a submittal is not an exemptionrequest, it must be justified based on a technical evaluation.2. Repair of Cold Shutdown EquipmentSection 11I.L.5 of Appendix R states that when in the alternative or dedicatedshutdown mode, "equipment and systems comprising the means to achieve andmaintain cold shutdown conditions shall not be damaged by fire; or the firedamage to such equipment and systems shall be limited so that the systems canbe 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 isnot to be confused with the requirements in Section III.G.1.b of Appendix R.Section III.G.1.b contains the requirements for normal shutdown modesutilizing the control room or emergency control station(s) capabilities. Thefire areas falling under the requirements of III.G.1.b are those for which analternative or dedicated shutdown capability is not being provided. For thesefire areas,Section III.G.1.b requires only the capability to repair thesystems necessary to achieve and maintain cold shutdown from either thecontrol 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 thecapability 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 forthe alternative or dedicated shutdown modes by Section III.L (noted above)..With regard to areas involving normal shutdown, however,Section I ofAppendix R states that repairs must be made using only onsite capabilities.After repairs are made, cold shutdown can be achieved on a reasonable scheduleusing any available power source.3. Fire DamageAppendix R to 10 CFR Part 50 utilizes the term "free of fire damage." Inpromulgating Appendix R, the Commission has provided methods acceptable forassuring that necessary structures, systems and comoonents are free of firedamage (see Section III.G.2a, b and c), that is, the structure, system or*These interpretations represent staff positions, and should not be consideredas official agency interpretations issued by the General Counsel. See10 CFR 1.32; 10 CFR Part component under consideration is capable of performing its intended functionduring and after the postulated fire, as needed. Licensees seeking exemptionsfrom Section III.G.2 must show that the alternative proposed providesreasonable assurance that this criterion is met. (Note also that SectionIII.G.2 applies only to equipment needed for hot shutdown. Therefore, anexemption from III.G.2 for cold shutdown equipment is not needed. The term"damage by fire" also includes damage to equipment from the normal orinadvertent operation of fire suppression systems.4. Fire Area BoundariesThe term "fire area" as used in Appendix R means an area sufficiently boundedto withstand the hazards associated with the area and, as necessary, toprotect important equipment within the area from a fire outside the area. Inorder to meet the regulation, fire area boundaries need not be completelysealed floor-to-ceiling, wall-to-wall boundaries. However, all unsealedopenings should be identified and considered the evaluating the effectivenessof the overall barrier. Where fire area boundaries are not wall-to-wall,floor-to-ceiling boundaries with all penetrations sealed to the fire ratingrequired of the boundaries, licensees must perform an evaluation to assess theadequacy of fire boundaries in their plants to determine if the boundarieswill withstand the hazards associated with the area. This analysis must beperformed by at least a fire protection engineer and, if required, a systemsengineer. Although not required, licensees may submit their evaluations forstaff review and concurrence. However, if certain cable penetrations wereidentified as open SER items at the time Appendix R became effective, SectionIII.M of the rule applies (see 10 CFR 50.48(b)), and any variation from therequirements of Section III.M requires an exemption. In any event, theseanalyses must be retained by the licensees for subsequent NRC audits.5. Automatic Detection and SuppressionSections III.G.2.b and III.G.2.c of Appendix R state that "In addition, firedetectors and automatic fire suppression system shall be installed in the firearea..." Other provisions of AppendixR also use the phrase "fire detectorsand an automatic fire suppression system in the fire area..." (see e.q.,Section III.G.2.e).In order to comply with these provisions, suppression and detection sufficientto protect against the hazards of the area must be installed. In this regard,detection and suppression providing less than full area coverage may beadequate to comply with the regulation. Where full area suppression anddetection is not installed, licensees must perform an evaluation to assess theadequacy of partial suppression and detection to protect against the hazardsin the area. The evaluation must be performed by a fire protection engineerand, if required, a systems engineer. Although not required, licensees maysubmit their evaluations to the staff for review and concurrence. In anyevent, the evaluations must be retained for subsequent NRC audits. Where alicensee is providing no suppression or detection, and exemption must berequeste . Alternative or Dedicated ShutdownSection III.G.3 of Appendix R provides for "alternative or dedicated shut-down capability and its associated circuits, independent of cables, systems orcomponents in the area, room, or zone under consideration." While"independence" is clearly achieved where alternative shutdown equipment isoutside the fire area under consideration, this is not intended to imply thatalternative shutdown equipment in the same fire area but independent of theroom or the zone cannot result in compliance with the regulation. The "room"concept must be justified by a detailed fire hazards analysis that demonstratesa single fire will not disable both normal shutdown equipment and the alterna-tive shutdown capabilit ENCLOSURE 2APPENDIX R QUESTIONS AND ANSWERS APPENDIX RQUESTIONS AND ANSWERS1. INTRODUCTION2. OVERVIEW3. III G, FIRE PROTECTION OF SAFE SHUTDOWN CAPABILITY3.1 Fire Area Boundaries3.1.1 Fire Area Definition3.1.2 Previously Accepted Fire Area Boundaries3.1.3 Exterior Walls3.1.4 Exterior Yards3.1.5 Fire Zones3.1.6 Documentation3.2 Fire Barrier Qualifications3.2.1 Acceptance Criteria3.2.2 Deviations from Tested Cpnfigurations3.2.3 Fire Door Modifications3.3 Structural Steel3.3.1 NFPA Approaches3.3.2 Previously Accepted Structural Steel3.3.3 Seismic Supports3.3.4 Cable Tray Support Protection3.4 Automatic Suppression System3.4.1 Water Density3.4.2 NRC Consultation3.4.3 Sprinkler Location3.4.4 Fixed Suppression System In Fire Area3.4.5 Sprinkler Head Location3.4.6 Previously Approved Suppression Systems3.5 Separation of Redundant Circuits3.5.1 Twenty-Foot Separation Criteria3.5.2 Floor-to-Floor Separation3.6 Intervening Combustibles3.6.1 Negligible Quantities of Intervening Combustibles3.6.2 In Situ Exposed Combustibles3.6.3 Unexposed CombustiblesAPPENDIX R QUESTIONS & ANSWERS1 3.7 Radiant Energy Shields3.7.1 Fire Rating3.8 Design Bases3.8.1 Fire Protection Features NFPA Conformance3.8.2 Design Basis Fire3.8.3 Redundant Trains/Alternate Shutdown3.8.4 Control Room Fire Considerations4. III J, EMERGENCY LIGHTING4.1 Illumination Levels5. III L, ALTERNATIVE AND DEDICATED SHUTDOWN CAPABILITY5.1 Safe and Alternative Shutdown5.1.1 Previously Accepted Alternative Shutdown Capability5.1.2 Pre-Existing Alternative Shutdown Capability5.1.3 III L Backfit5.2 Procedures5.2.1 Shutdown and Repair Basis5.2.2 Post Fire Operating Procedures5.2.3 Alternative Shutdown Capability5.2.4 Post Fire Procedures Guidance Documents5.3 Safe Shutdown and Fire Damage5.3.1 Circuit Failure Modes5.3.2 "Hot Short" Duration5.3.3 Hot Shutdown Duration5.3.4 Cooldown Equipment5.3.5 Pressurizer Heaters5.3.6 On-Site Power5.3.7 Torus Level Indication5.3.8 Short Circuit Coordination Studies5.3.9 Diagnostic Instrumentation5.3.10 Design Basis Plant Transients5.3.11 Alternate/Dedicated Shutdown vs. Remote Shutdown Systems6. III 0, OIL COLLECTION SYSTEMS FOR REACTOR COOLANT PUMP6.1 Lube Oil System Seismic Design6.2 Container7. BRANCH TECHNICAL POSITION CMEB 9.5-17.1 Fire Protection and Seismic Events7.2 Random Fire and Seismic EventsAPPENDIX R QUESTIONS & ANSWERS2 8. LICENSING POLICY8.1 Fire Hazards Analysis/Fire Protection Plan Updating8.2 Fire Protection License Condition8.3 III G. J and 0 Exemptions for Future Modifications8.4 Future Changes8.5 Schedular and Blanket Exemptions8.6 Trivial Deviations8.7 Revised Modifications8.8 Smallest Opening in,a Fire Barrier8.9 NFPA Code Deviations8.10 "ASTM E-119" Design'Basis Fire8.11 Plants Licensed After January 1, 19798.12 Cold Shutdown Equipment Availability8.13 Guidance Documents8.14 Deviations from Guidance Documents8.15 Staff Interpretations nf Appendix R8.16 Dissemination of New Staff Positions8.17 Equivalent Alternatives8.18 Coordination Study Updates8.19 Exemption Request Threshold8.19.1 Penetration Desiqns Not Laboratory Approved8.19.2 Individual vs. Package Exemptions8.19.3 Exemption Request Supporting Detail8.19.4 50.12 vs. 50.48 Exemption Requests8.20 Post January 1, 1979 Plants and Exemption Requests'8.21 NRC Approval for BTP CMEB 9.5-1 Deviations9. INSPECTION POLICY9.1 Safety Implications9.2 Uniform Enforcement9.3 NTOL Inspections9.4 Future TI 2515/62 Revisions9.5 Documentation Supplied by Lice'nsee9.6 Subsequent Inspections9.7 NRC List of Conforming Items9.8 Inspection Re-review9.9 List of Shutdown EquipmentAPPENDIX R QUESTIONS & ANSWERS3 1. INTRODUCTIONA major fire damaging safe shutdown equipment occurred at the Browns FerryNuclear Station in March 1975. The fire damaged over 1600 electrical cablesand caused the temporary unavailability of some core cooling systems. Becausethis fire did substantial damage, the NRC established a Special Review Groupwhich initiated an evaluation of the need for improving the fire protection pro-grams at all nuclear power plants. The group found serious design inadequaciesregarding fire protection at Browns Ferry, and its report, "RecommendationsRelated to Browns Ferry Fire" (NUREG-0050, February 1976), contained over fiftyrecommendations regarding improvements in fire prevention and control in exist-ing facilities. The report also called for~the development-of specific guidancefor implementing fire protection regulations, and for a comparison of that guid-ance with the fire protection program at each operating plant.NRC developed technical guidance from the technical recommendations in theSpecial Group's report, and issued those guidelines as Branch Technical PositionAuxiliary and Power Conversion Systems Branch 9.5-1 (RTP APCSB 9.5-1),l/ "Guide-lines for Fire Protection for Nuclear Power Plants." This guidance dia not applyto plants docketed at that time. Guidance to operating plants was provided laterin Appendix A 2/ to BTP APCSB 9.5-1 which, to the extent practicable, relies onBTP APCSB 9.5-1.In-May 1976, the NRC asked licensees to compare operating reactors with BTPAPCSB 9.5-1, and in September 1976, those licensees were informed that theguidelines in Appendix A would be used to analyze the consequences of a firein each plant area. In September 1976 the licensees, were also requested toprovide a fire hazards analysis that divided the plant into distinct fire areasand show that redundant systems required to achieve and maintain cold shutdownare adequately protected against damage by a fire. Early in 1977 each licenseeresponded with a Fire Protection Program Evaluation which included a Fire HazardAnalysis. These evaluations and analyses identifiled aspects of licensees' fireprotection programs that did not conform to the NRC guidelines.1/Rather than serving as inflexible, legal requirements that must be followedby licensees, issuances such as regulatory guides and branch technical posi-tions are meant to give guidance to licensees concerning those methods thestaff finds acceptable for implementing the general criteria embodied in theNRC's rules. See, e.g., Petition for Emergency & Remedial Action, CLI-78-6,7 NRC 400, 406 (1978); Gulf States Utilities Company (River Bend Station,Units 1 and 2) ALAR-444, 6 NRC 760, 772 (1977).2/Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior toJuly 1, 1976.APPENDIX R QUESTIONS & ANSWERS 1-..__ 1 1. .. ... -11 ----- -_. --- 1. I ... I --.... .__ _. ---- ..... --
Thereafter, the staff initiated discussions with all licensees aimed at achievingimplementation of fire protection guidelines by October 1980. The staff held ,many meetings with licensees, conducted extensive correspondence with them, andvisited every operating reactor. As a result, many fire protection items were-resolved, and agreements were included in Fire Protection Safety EvaluationReports issued by the NRC. Several fire protection issues remained unresolvedwith a number of licensees.By early 1980, most operating plants had implemented most of the guidelines inAppendix A. However, as the Commission noted in its Order of May 23, 1980,the fire protection program has had some significant problems with implementa-tion. Despite the staff's efforts, several licensees had expressed continuingdisagreement with, and refused to adopt recommendations relatinq to severalgeneric issues,'including the requirements for fire brigade size and training,water supplies for fire suppression systems, alternate and dedicated shutdowncapability, emergency lighting, qualifications of seals used to enclose placeswhere cables penetrated fire barriers, and the prevention of reactor coolantpump lubrication system fires. To establish a definitive resolution of thesecontested subjects in a manner consistent with the general guidelines in Appen-dix A to the BTP and to assure. timely compliance by licensees, the Commissionissued a proposed fire protection rule and its Appendix R, which was describedas setting out minimum fire protection requirements for the unresolved issues(45 Fed. Reg. 36082 May 29, 1980).3/ The fire protection features addressedincluded protection of safe shutdown capability, emergency lighting, fire bar-riers, associated circuits, reactor coolant pump lubrication system, and alter-nate shutdown systems. The Commission stated that it expected all modifications(except for alternate and dedicated shutdown capability) to be implemented byNovember 1, 1980.4/As originally proposed (Federal Register Vol. 45 No. 1&5, May 22, 1980), Appendix Rwould have applied to all'plants licensed prior to January 1, 1979 including thosefor which the staff had previously accepted other fire protection modifications.After analyzing comments on the rule, the Commission determined that only three ofthe fifteen items in Appendix R were of such safety significance that they shouldapply to all plants, including those for which alternative fire protection actionshad been approved previously by the staff. These items are protection of safeshutdown capability (including alternate shutdown systems), emergency lighting,and the reactor coolant pump lubrication system. Accordingly, the final rulerequired all reactors licensed to operate before January 1, 1979, to complywith these three Items even if the NRC had previously approved alternative fireprotection features in these areas (45 Fed. Reg. 76602 Nov. 19, 1980). However,the final rule is more flexible than the proposed rule because Item III.G nowprovides three alternative fire protection features which do not require anal-ysis to demonstrate the protection of redundant safe shutdown equipment, andreduces the acceptable distance in the physical separation alternative fromfifty feet to twenty feet. In addition, the rule now also provides an exemp-tion procedure which can be initiated by a licensee's assertion that anyrequired fire protection feature will not enhance fire protection safety in thefacility or that such modifications may be detrimental to overall safety(10 CFR 50.48(c)(6)). If the Director, Nuclear Reactor Regulation determines3/11 NRC 707, 718 (1980)4/Id. at 719APPENDIX R QUESTIONS & ANSWERS2 that a licensee has made a Prima facie showing of a sound technical basis forsuch an assertion, then the implementation dates of the rule are tolled untilfinal Commission action on the exemption request.Most licensees requested and were granted additional time to perform theirreanalysis, propose modifications to improve post fire shutdown capability andto identify exemptions for certain fire protection configurations. In reviewingsome exemption requests, the staff noted that some licensees had made signifi-cantly different interpretations of certain requirements. These differenceswere identified in the staff's draft SER's. These differences were also dis-cussed on several occasions with the cognizant licensee as well as the NuclearUtility Fire Protection Group. These discussions culminated in the issuanceof generic letter 83-33.2. OVERVIEWSection 50.48 Fire Protection of 10 CFR Part 50 requires that each operatingnuclear power plant have a fire protection plan that satisfies General DesignCriterion 3 of Appendix A to 10 CFR 50. It specifies what should be containedin such a plan and lists the basic fire protection guidelines for this plan.It requires that the Fire Protection Safety Evaluation Report which has beenissued for each operating plant state how these guidelines were applied toeach facility.Section 50.48 also requires that all plants with operating licenses prior toJanuary 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 had notbeen obtained prior to the effective date of Appendix R. By a separate action,the Commission approved the staff's requirement that all plants to receivetheir operating license after January 1, 1979 also satisfy the requirements ofSections III.G, III.J and III.0 and that a fire protection license condition beestablished. Deviations, from Appendix R requirements for pre-1979 plants are,processed under the exemption process. Deviation from other guidelines areidentified and evaluated in the Safety Evaluation Report.A standard fire protection license condition has been developed and will beincluded in each new operating license. Holders of operating licenses will beencouraged tn adopt the standard license condition.The Regions initiated inspections of operating plants and identified severalsignificant items of non-compliance. The Nuclear Utility Fire ProtectionGroup requested interpretations of certain Appendix R requirements and provideda list of questions that they thought should be discussed with the industry.The NRC held workshops in each Region to assist the industry in understandingthe NRC's requirements and to improve the Staff's understanding of the industry'sconcerns.This document presents the NRC's response to the questions posed by the industryand supplemented with additional questions identified at the workshops as beingof interest to the industry or the staff. These responses may be used as guid-ance for design, review and inspection activities. The questions have beenreformatted according to their applicability to Sections of Appendix R,BTP CMEB 9.5-1, licensing policy or inspection policy.APPENDIX R QUESTIONS & ANSWERS 3--_-._..__._- 11 --I- -.-.1. --. I- .I-- ---I. -.-I I- -.1. ---I I3. SECTION III G, FIRE PROTECTION OF SAFE SHUTDOWN CAPABILITY3.1 Fire Area Boundaries3.1.1 Fire Area DefinitionQUESTIONSection III.G states the fire protection features required for cables andequipment or redundant trains of systems required to achieve and maintain hotshutdown that are located, within the same fire area. Is the fire area ofSection III.G, the same fire area referred to in BTP APCSB 9.5-1, Appendix A;and the supplementary guidance of September 1976?RESPONSEThe definition of a fire area given in the BTP is somewhat more restrictivethan that given in Section #4 of the "Interpretations of Appendix R." Clearly,where a licensee has reviewed its facility using the BTP criteria, this wouldmeet Appendix R requirements. The BTP criteria may continue to be used asguidance, but the minimum requirements for fire area boundaries are set out inSection #4 of the "Interpretations."3.1.2 Previously Accepted Fire Area BoundariesQUESTIONIf a fire area boundary was described as a rated barrier in the 1977 firehazards analysis (FHA), no open items existed in this area in the Appendix A SER,and the barriers have not been altered, then need those barriers be reviewedby licensees or the Staff under Appendix R?RESPONSEIf a fire area boundary was described as a rated barrier in the 1977 fire hazardsanalysis, and was evaluated and accepted in a published SER, the fire area boun-dary need not be reviewed as part of the re-analysis for compliance with Sec-tion III.G of Appendix R. Openings in the fire barriers, if any, should havebeen specifically identified and Justified in the fire hazards analysis per-formed in the Appendix A process. If openings in the fire area boundaries werenot previously evaluated, such an evaluation should be performed as a basis forassessing compliance with Appendix R. See Items #4 and #6 of the "Interpreta-tions of Appendix R," and the response to question 3.1.1.In BTP APCSB 9.5-1, Fire Barrier is defined as:"Fire Barrier -those components of construction (walls, floors, and roofs)that are rated by approving laboratories in hours for resistance to fire toprevent the soread of fire.The term "fire area" as used in Appendix R means an area sufficiently boundedto withstand the hazards associated with the fire area and, as necessary, toprotect important equipment within the fire area from a fire outside the area.In order to meet the regulation, fire area boundaries need not be completelyAPPENDIX R QUESTIONS & ANSWERS 4 sealed with floor to ceiling and/or wall-to-wall boundaries. Where fire areaboundaries were not approved under the Appendix A process, or where such bound-aries are not wall-to-wall or floor-to-ceiling boundaries with all penetrationssealed to the fire rating required of the boundaries, licensees must perform anevaluation to assess the adequacy of fire area boundaries in their plants todetermine if the boundaries will withstand the hazards associated with the areaand 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, ifrequired, a systems engineer. Although not required, licensees may submit theirevaluations for Staff review and concurrence. In any event, these analysesmust be retained by the licensees for subsequent NRC audits.3.1.3 Exterior WallsQUESTIONMust exterior walls to buildings and their penetrations be qualified as ratedbarriers?RESPONSEExterior walls and their penetrations should be qualified as rated barrierswhen (1) they are required to separate a shutdown-related division(s) insidethe plant from its redundant (alternate) counterpart outside the plant in theimmediate vicinity of the exterior wall, (2) they separate safety relatedareas from non-safety related areas that present a significant fire threat tothe safety related areas, or (3) they are designated as a fire barrier in theFSAR or FHA.Usually exterior walls are designated as a fire area boundary; therefore, theyare evaluated by the guidelines of Appendix A. A FHA should be performed todetermine the rating of exterior walls, if required by the above criteria.3.1.4 Exterior YardsQUESTIONHow should a utility define the boundaries of fire areas comprising exterioryards?RESPONSEAn exterior yard area without fire barriers should be considered as one firearea. The area may consist of several fire zones. The boundaries of the firezones should be determined by a FHA.The protection for redundant/alternate shutdown systems within a yard area wouldbe determined on the bases of the largest "design basis fire" (see response toquestion 3.8.2) that is likely to occur and the resulting damage. The boundariesof such damage would have to be justified with a fire hazards analysis. Theanalysis should consider the degree of spatial separation between divisions; thepresence of in-situ and transient combustibles, including vehicular traffic;grading; available fire protection; sources of ignition; and the vulnerabilityand criticality of the shutdown related systems. See Sections #3, #4 and #6 ofthe "Interpretations of Appendix R."APPENDIX R QUESTIONS & ANSWERS 5 I3.1.5 Fire ZonesQUESTIONAppendix R,Section III.G.3 states "alternative or dedicated shutdown capabilityand its associated circuits, independent of cables, systems or components inthe area room or zone under consideration...." What is the implied utilizationof a room or zone concept under Section III.G of Appendix R? The use of thephraseology "area, room or zone under consideration" is used again at the endof the Section III.G.3. Does the requirement for detection and fixed suppres-sion indicate that the requirement can be limited to a fire zone rather thanthroughout a fire area? Under what conditions and with what caveats can thefire zone concept be utilized in demonstrating conformance to Appendix R?RESPONSESection III.G was written after NRC's multi-discipline review teams had visitedall operating power plants. From these audits, the NRC recognized that it isnot practical and may be impossible to subdivide some portions of an operatingplant into fire areas. In addition, the NRC recognized that in some caseswhere fire areas are designated, it may not be possible to provide alternateshutdown capability independent of the fire area and, therefore, would have tobe evaluated on the basis of fire zones within the fire area. The NRC alsorecognized that because some licensees had not yet performed a safe shutdownanalysis, these analyses may identify new unique configurations.To cover the large variation of possible configurations, the requirements ofSection III.G were presented in three parts:o Section III.G.1 requires one train of hot shutdown systems be free offire damage and damage to cold shutdown systems be limited.o Section III.G.2 provides certain separation, suppression and detectionrequirements within fire areas; where such requirements are met, analysisis not necessary.o Section III.G.3 requires alternative dedicated shutdown capability forconfigurations that do not satisfy the requirements of III.G.2 or wherefire suppressants released as a result of fire fighting, rupture of thesystem or inadvertent operation of the system may damage redundant equip-ment. If alternate shutdown is provided on the basis of rooms or zones,the provision of fire detection and fixed suppression is only requiredin the room or zone under consideration.Section III.G recognizes that the need for alternate or dedicated shutdowncapability may have to be considered on the basis of a fire area, a room or afire zone. The alternative or dedicated capability should be independent ofthe fire area where it is possible to do so (See Supplementary Information forthe final rule Section III.G). When fire areas are not designated or where itis not possible to have the alternative or dedicated capability independent of =the fire area, careful consideration must be given to the selection and locationof the alternative or dedicated shutdown capability to assure that the performancerequirement set forth in Section III.G.1 is met. Where alternate or dedicatedshutdown is provided for a room or zone, the capability must be physically andAPPENDIX R QUESTIONS & ANSWERS6 11electrically independent of that room or zone. The vulnerability of the equip-ment and personnel required at the location of the alternative or dedicatedshutdown capability to the environments produced at that location as a resultof the fire or fire suppressant's must be evaluated. These environments may bedue to the hot layer, smoke, drifting suppressants, common ventilation systems,common drain systems or flooding. In addition, other interactions between thelocations may be possible in unique configurations.If alternate shutdown is provided on the basis of rooms or zones, the provisionof fire detection and fixed suppression is only required in the room or zoneunder consideration. Compliance with Section III.G.2 cannot be based on roomsor zones.See also Sections #5 and #6 of the "Interpretations of Appendix R."3.1.6 DocumentationQUESTIONIn Generic Letter 83-33 at pg. 2, the NRC Staff referred to the guidance inAppendix A to BTP 9.5-1 to establish the rating of the barrier. What level ofdocumentation must be provided to verify that the fire area meets the require-ments of Appendix R?RESPONSEThe documentation required to verify the rating of a fire barrier should in-clude the design description of the barrier and the test reports that verifyits fire rating. Reference can be made to UL listed designs.3.2 Fire Barrier Qualification3.2.1 Acceptance CriteriaQUESTIONRecently the Staff has applied a 3250F cold side temperature criterion to itsevaluation of the acceptability of one-hour and three-hour fire barrier cabletray wraps. This criterion is not in Branch Technical Position (BTP) APCSB 9.5-1,Appendix A as an acceptance criterion for fire barrier cable tray wraps and isnot 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 electricalcables where insulation degradation does not beqin until jacket temperaturesreach 450'F to 650'F?RESPONSEFire barriers relied upon to protect shutdown related systems to meet the re-quirements of III.G.2 need to have a fire rating of either one or three hours.§ 50.48 references BTP APCSB 9.5-1, where the fire protection definitions arefound. Fire rating is defined:"Fire Rating -the endurance period of a fire barrier or structure; it definesthe period of resistance to a standard fire exposure before the first criticalpoint in behavior is observed (see NFPA 251)."APPENDIX R QUESTIONS & ANSWERS7 The acceptance criteria contained in Chapter 7 of NFPA 251, "Standard Methodsof Fire Tests of Building Construction and Materials," pertain to non-bearingfire barriers. These criteria stipulate that transmission of heat through thebarrier "shall not have been such as to raise the temperature on its unexposedsurface more than 2500F above its initial temperature." The ambient air tem-perature at the beginning of a fire test usually is between 50'F and 90'F. Itis generally recognized that 750F represents an acceptable norm. The resulting3250F cold side temperature criterion is used for cable trav wraps because theyperform 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 damageat 3250F.During the Appendix A review, licensees began to propose fire barriers toenclose cable trays, conduit, fuel lines, coolant lines, etc. Industry didnot have standard rating tests for such components or for electrical, pipingor bus duct penetrations. The NRC issued a staff position giving acceptancecriteria for electrical penetration tests. These criteria require an analysisof any temperature on the unexposed side of the barrier in excess of 3250F.In the past, manufacturers designed their own qualification tests. NuclearInsurers, and the Institute of Electrical and Electronic Engineers have issuedtests for some of these components. These tests usually exposed the componentto the ASTM E-119 time temperature curve, but all had different acceptancecriteria. Conduit and cable tray enclosure materials accepted by the NRC as1 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) andalready installed by the licensee need not be replaced even thouqh they maynot have met the 3250F criteria. However, for newly identified conduit andcable trays requiring such wrapping new material which meets the 3250F crite-rion should be used, or justification should be provided for use of materialwhich does not meet the 325'F criterion. This may be based on an analysisdemonstrating that the maximum recorded temperature is sufficiently below thecable insulation ignition temperature.3.2.2 Deviations from Tested ConfigurationsQUESTIONDue to obstructions and supports, it is often impossible to achieve exact dupli-cation of the specific tested configuration of the one-hour fire barriers whichare to be placed around either conduits or cable trays. For each specific in-stance where exact replication of a previously tested configuration is not andcannot be achieved, is an exemption necessary in order to avoid a citation fora violation?RESPONSENo. Where exact replication of a tested configuration cannot be achieved, thefield installation should meet all of the following criteria:1. The continuity of the fire barrier material is maintained.2. The thickness of the barrier is maintained.3. The nature of the support assembly is unchanged from the testedconfiguration.APPENDIX R OUESTIONS & ANSWERS8 4. The application or "end use" of the fire barrier is unchanged from thetested configuration. For example, the use of a cable tray barrier toprotect a cable tray which differs in configuration from those that weretested would be acceptable. However, the use of structural steel fireproofing to protect a cable tray assembly may not be acceptable.5. The configuration has been reviewed by a qualified fire protection engineerand found to provide an equivalent level of protection.3.2.3 Fire Door ModificationsQUESTIONWhere labeled and rated fire doors have been modified to incorporate securityhardware or for flooding protection, is an exemption from Appendix R required?RESPONSEWhere a door is part of a fire area boundary, and the modification does noteffect the fire rating (for example, installation of security "contacts"), nofurther analysis need be performed. If the modifications could reduce thefire rating (for example, installation a vision panel), the fire rating of thedoor should be reassessed to ensure that it continues to provide adequate mar-gin considering the fire loading on both sides. Since this reassessment per-tains to the establishment of a valid fire area boundary, an exemption is notrequired. See Section #4 of the "Interpretations of Appendix R."3.3 Structural Steel3.3.1 NFPA ApproachesQUESTIONDoes the NPC's definition of structural steel supporting fire barriers com-pletely accommodate approaches described in NFPA guidance documents and standards?RESPONSEThe NRC does not define the structural steel supporting fire barriers. Thissteel is identified by the licensee. Our position regarding the need to protectthe structural steel, which forms a part of or supports fire barriers, is con-sistent with sound fire protection engineering principles as delineated in bothNFPA codes and standards, and The Fire Protection Handbook.3.3.2 Previously Accepted Structural SteelQUESTIONIs it necessary to protect structural steel in exisitng fire barriers wherethose barriers were approved in an Appendix A SER?RESPONSENo.APPENDIX R QUESTIONS & ANSWERS I3.3.3 Seismic SupportsQUESTIONDoes structural steel whose sole purpose is to carry dynamic loads from a seismicevent require protection in accordance with Section III.G.2a of Appendix R?RESPONSENo, unless the failure of any structural steel member due to a fire could resultin significant degradation of the fire barrier. Then it must be protected.3.3.4 Cable Tray Support ProtectionQUESTIONShould cable tray supports be protected if there is a sprinkler system in thefire area? Under what conditions may cable tray supports be unprotected? Dounprotected supports require an exemption?RESPONSEIn general, cable tray supports should be protected, regardless of whether thereis a sprinkler system. However, they need not be protected if (1) the qualifi-cation tests were performed on wrapped cable trays with unprotected supports,and the supports are shown to be 'adequate, or (2) an analysis is performed,which takes into account the fire loading and automatic suppression availablein the area, and which demon-strates that the unprotected support(s) will notfail and cause a loss of the cable tray fire barrier required for the postulatedfire.An exemption is not required; however, the qualification tests and applicabilityor the structural evaluation should be documented and available for audit.3.4 Automatic Suppression System3.4.1 Water DensityQUESTIONStaff guidance provided in Generic Letter 83-33* concerning automatic suppressioncoverage of fire areas interprets the phrase "in the fire area" in Section III.Gas meaning "throughout the fire area." What delivered water density or occupancystandard as specified in NFPA-STD-13 must be achieved to meet this guidance?RESPONSEIndividual plant areas are diverse In nature. The designer should determinethe particular water density or occupancy classification. Those areas whichcontain a limited quantity of in-situ and anticipated transient combustibles*Superseded by Generic Letter 85-01, however the response to the question isuseful for other considerations.APPENDIX R QUESTIONS & ANSWERS10 and which feature contents such as tanks and piping, may be considered as"Ordinary Hazard (Group 1)," as defined by NFPA Standard No. 13. For thoseareas containing large amounts of cables or flammable liquids, an occupancyclassification of "Extra Hazard" may be warranted. The decision as to whichclassification should be applied should be made by a qualified fire protectionengineer.Once the occupancy classification is determined, the minimum water densityshould be based on the Density Curves in table 2.2.1(B) of NFPA 13. Any den-sity equal to or in excess of the curves would be in conformance with ourguidelines as delineated in Section C.6.c of BTP CMEB 9.5-1.3.4.2 NRC ConsultationQUESTIONSection 4.1.2 of NFPA-STD-13 allows for "partial installations'! or partialcoverage. The standard states that "the authority having jurisdiction shallbe consulted in each case." With the NRC as authority in this instance, mustconsultation occur only through the exemption process?RESPONSENo. The staff is always available to consult with utility representatives andprovide guidance as to the acceptability of a particular fire protection con-figuration in individual plant areas. See also Section #5 of the "Interpreta-tions of Appendix R."3.4.3 Sprinkler LocationQUESTIONHow does a suppression system designer know whether the term "throughout thearea' means that sprinkler heads must be above or below cable trays when, inhis judgment, the hazard of concern is a floor based fire?RESPONSESection C.6.c(3) of BTP CMEB 9.5-1 states:"(3) Fixed water extinguishing systems should conform to requirements ofappropriate standards such as NFPA-13, "Standard for the Installation ofSprinkler Systems," and NFPA-15, "Standard for Water Spray Fixed Systems"."This question pertains to those sprinkler systems covered by NFPA-13. Chapter 4of NFPA-13 provides guidance as to the location of sprinkler heads in relationto common obstructions. In general, to achieve complete area-wide coverage,sprinklers should be located at the ceiling, with additional sprinklers providedbelow significant obstructions such as wide HVAC ducts and "shielded" or solidbottom stacked cable trays. To the extent that an existing or proposed sprin-kler system design deviates from this concept, the design would have to bejustified by a fire hazards analysis. See also Section #5 of the "Interpreta-tions of Appendix R."APPENDIX R QUESTIONS & ANSWERS 11 3.4.4 Fixed Suppression System In Fire AreaQUESTIONAre fixed suppression systems required by Section III G.3 to be throughout thefire area, room or zone under consideration?RESPONSENo, 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 withthe regulation. Where full area suppression and detection is not installed,licensees must perform an evaluation to assess the adequacy and necessity ofpartial suppression and detection in an area. The evaluation must be performedby a fire protection engineer and, if required, a systems engineer. Althoughnot required, licensees may submit their evaluations to the staff for reviewand concurrence. In any event, the evaluations must be retained for subsequentNRC audits..."3.4.5 Sprinkler Head LocationQUESTIONIf stacks of horizontal or vertical cable trays extend from ceiling to floor,are sprinkler heads required (1) under the lowest horizontal trays, near thefloor for vertical trays; (2) at some intermediate level between the floor andceiling, and (3) at the ceiling?RESPONSESprinkler heads should be located at the ceiling. Sprinkler heads at otherlocations may be necessary depending upon the hazard and the cumulative effectof the obstructions to the discharge of water from the sprinkler head. Thesprinkler system design should meet NFPA 13.3.4.6 Previously Approved Suppression SystemsQUESTIONMust suppression systems approved and installed under BTP APCSB 9.5-1, Appen-dix 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 newinstallations?RESPONSESuppression systems installed in connection with Appendix A may or may not haveto be extended as a result of III.G. The licensee must analyze each area wheresuppression is required by III.G, and where only partial suppression has beenprovided, determine if the coverage is adequate for the fire hazard in the area.The licensee may consult with the staff during this review. In any event, theAPPENDIX R QUESTIONS & ANSWERS12 IAppendix R analysis showing that the suppression provided is adequate must beretained and available for NRC audit. See also Section #5 of the "Interpreta-,tions of Appendix R."3.5 Separation of Redundant Circuits3.5.1 Twenty-Foot Separation CriteriaQUESTIONAssuming that a licensee is utilizing the 20-foot separation for circuit protec-tion, could an exemption request be granted for a portion of the circuit thatdid not maintain the 20-foot minimum separation if that portion was protectedby one-hour barrier until 20-foot was achieved? -This barrier would not befirewall-to-firewall, and the circuit protection would not be claimed under the.one-hour barrier rule.RESPONSEWith the erection of a partial qualified one-hour rated barrie' for portionsof the circuits with less than 20 ft. separation, if 20 feet of horizontalseparation existed between the redundant unprotected portions of the circuitswithout intervening combustibles or fire hazards, and if the fire area was pro-tected by automatic fire detection and suppression, compliance with SectionIII.G.2.b would be achieved.These types of configuration have to be evaluated on a case-by-case basis bythe NRC.3.5.2 Floor-tb-Floor SeparationQUESTIONWhere redundant circuits are separated by floor elevation but are within thesame fire area due to open hatchways, stairs, etc., what is the NRC's positionwith rogard to separation criteria? If train A is located twenty feet from anopen hatchway on the lower elevation and train B is located ten feet from thesame opening on the next elevation, would this be considered adequate separation?RESPONSEIf a wall or floor/ceiling assembly contains major unprotected openings suchas hatchways and stairways, then plant locations on either side of such a bar-rier must be considered as part of a single fire area. Refer to Section #4 ofthe "Interpretations of Appendix R."As to the example provided, if train A was separated by a cumulative horizontaldistance of 20 feet from train B, with no intervening combustible materials orfire hazards, and both elevations were provided with fire detection and suppres-sion, the area would be in compliance with Section III.G.2.b.APPENDIX R QUESTIONS & ANSWERS 13 3.6 Intervening Combustibles3.6.1 Negligible Quantities of Intervening CombustiblesQUESTIONTwenty feet of separation with absolutely no intervening combustibles is a rarecase in most nuclear plants. What is the most acceptable method of addressingintervening combustibles? How are various utilities addressing this subject,and what would be sufficient justification to support an exemption request?RESPONSEIf more than negligible quantities of combustible materials (such as isolatedcable runs) exist between redundant shutdown divisions, an exemption requestshould be-filed. [Negligible quantity" is an admittedly judgmental criterion,and this judgment should be made by a qualified fire protection engineer anddocumented for later NRC audit.] Justifications for such exemptions have beenbased on the following factors:1. A relatively large horizontal spatial separation between redundant divi-sions; all cables qualified to IEEE-383.2. The presence of an automatic fire suppression system over the interveningcombustible (such as a cable tray fire suppression system);3. The presence of fire stops to inhibit fire propagation in interveningcable trays;4. -The likely fire propagation direction of burning intervening combustiblesin relation to the location of the vulnerable shutdown division;5. The availability of compensating active and passive fire protection.Any future changes in the cable configuration due to modifications could behandled under 50.59. See the provisions of the license condition in theresponse to question 8.2.3.6.2 In-Situ Exposed CombustiblesQUESTIONSWithin Appendix R,Section III.G.2.b, the phrase "twenty feet with no interven-ing combustible or fire hazards" is utilized. What is the definition of "nointervening combustible?" Is the regulation focused predominantly on theabsence of fixed combustibles?RESPONSEThere is no specific definition of "no intervening combustible." The regulationis focused on the absence of in-situ exposed combustibles. Non combustiblematerials would not be considered as intervening combustibles.In BTP CMEB 9.5-1, noncombustible material is defined as:APPENDIX R QUESTIONS & ANSWERS14
"Noncombustible Materiala. A material which in the form in which it is used and under the conditions,anticipated, will not ignite, burn, support combustion, or release flamma-ble vapors when subjected to fire or heat.b. Material having a structural base of noncombustible material, as definedin a., above, with a surfacing not over 1/8-inch thick that has a flamespread rating not higher than 50 when measured using ASTM E-84 Test"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 inter-vening combustibles ..." To meet this requirement,-plastic jackets and insula-tion of grouped electrical cables, including those which are coated, should beconsidered as intervening combustibles."For fire protection, "no intervening combustibles" means that there is no sig-nificant quantities of in-situ materials which will ignite and burn locatedbetween redundant shutdown systems. The amount of such combustibles that hassignificance is a judgmental decision. As with other issues, if the licenseesfire protection engineer is concerned that the quantity of combustibles betweenshutdown divisions may not be considered insignificant by an independentreviewer, an exemption could be requested, or the staff consulted.Transient materials are not considered as an intervening combustible; however,they must be considered as part of the overall fire hazard within an area.Cables that are in cable trays which are either open or fully enclosed shouldalso be considered as intervening combustibles. Cables coated with a fire retard-ant material are also considered as intervening combustibles.However, cables coated with a fire retardant material, or cables in cable trayshaving solid sheet metal bottom, sides and top, if protected by automatic firedetection and suppression systems and if the design is supported by a fire hazardsanalysis, have been found acceptable under the exemption process.3.6.3 Unexposed CombustiblesQUESTIONAre unexposed combustibles, such as oil in sumps, closed cans, or sealed drums,or electrical cable in conduits, considered as "intervening combustibles?"RESPONSEOnly oil in closed containers which are in accordance with NFPA 30 or electricalcables in metal conduits are not considered as intervening combustibles. In situoil in open sumps is considered to be an intervening combustible; in-situ oilin closed sumps equivalent to NFPA Standard-30 containers is not considered tobe an intervening combustible.APPENDIX R QUESTIONS & ANSWERS15 3.7 Radiant Energy Shield3.7.1 Fire RatingQUESTIONRecently, the NRC Staff indicated that non-combustible radiant energy shieldsshould be tested against ASTM-TD-E-119 based, apparently, on the requirementsof 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 BTPAPCSB 9.5-1 Appendix A. Could the Staff clarify the requirements in this area?RESPONSEDuring the Appendix A reviews, we observed that inside some containments, therewere large concentrations of cables converging at electrical penetration areas.In some cases, where the penetrations were grouped by division, shields wereplaced between the divisions so that radiant energy from a fire Involving thecables 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 thesurviving division. These shields were usually constructed of 1/2-inch mariniteboard in a metal frame. Appendix R,Section III.G.f refers to these shields as"a noncombustible radiant energy shield." The guidelines in BTP CMEB 9.5-1,Section C.7.a(1)b. indicate that these shields should have a fire rating of1/2 hour. In our opinion any material with a 1/2 hour fire rating should becapable of performing the required function.The guidelines of BTP CMEB 9.5-1 relating to a fire-rated radiant energy shieldare being considered in our current reviews of NTOL plants. However, to theextent that an applicant can justify that a proposed radiant energy shield canachieve an equivalent level of safety, we have been accepting shields that havenot been tested against the acceptance criteria of ASTM E-119.In our Appendix R reviews, we have accepted non-fire-rated radiant energyshields that have been demonstrated by fire hazards analysis to provide anacceptable level of protection against the anticipated hazard of a localizedfire within the containment. We have also accepted fire-rated metal-sheathedmineral insulated cables, as a radiant energy shield in specific configurations.3.8 Design Bases3.8.1 Fire Protection Features NFPA ConformanceQUESTIONShould the fire protection features required by Section III.G conform to theNFPA Codes?RESPONSEYes. For example,Section III G.2 requires an automatic suppression system.Our guidelines would recommend that the system be in accordance with an NFPACode. If deviations are made from the Code, they should be identified in theFSAR or FHA.APPENDIX R QUESTIONS & ANSWERS16 3.8.2 Design Basis FireQUESTIONWhy isn't the industry allowed to design to protect against a design basisfire?RESPONSENeither the industry nor the Staff has been able to develop criteria for esta-blishing design basis fire conditions for a single "design basis fire" becausethe in-situ and potential transient combustibles vary widely in different areasof the plant. However, the establishment of a specific "design basis fire" forindividual fire areas or zones is a prerequisite to performance of a valid firehazards analysis (See Appendix R Section II.B(1) and BTP CMEB 9.5-1 Sections C.b(1)and (2)).3.8.3 Redundant Trains/Alternate ShutdownQUESTIONConfusion exists as to what will be classified as an alternate shutdown systemand thus what systems might be required to be protected by suppression anddetection under Section III.G.3.b. For example, while we are relYing upon theturbine-building condensate system for a reactor building fire and the RHR sys-tem for a turbine building fire, would one system be considered the alternativeto the other. If so, would suppression and detection be required for either orboth systems under III.G.3.b? An explanation of alternative shutdown needs tobe advanced for all licensees.RESPONSEIf the system is beinj used to provide its design function, it generally isconsidered redundant. If the system is being used in lieu of the preferredsystem because the redundant components of the preferred system does not meetthe separation criteria of Section III.G.2, the system is considered an alter-native shutdown capability. Thus, for the example above,*it appears that thecondensate system is providing alternative shutdown capability in lieu of sepa-rating redundant components of the RHR System. Fire detection and a fixed firesuppression system would be required in the area where separation of redundantcomponents of the RHR system is not provided. However, in the event of a tur-bine building fire, the RHR system would be used for safe shutdown and is notconsidered an alternative capability. However, one train of the RHR systemmust be separated from the turbine building.3.8.4 Control Room Fire ConsiderationsQUESTIONWhat considerations should be taken into account in a control room fire? Whatis the damage that is considered? What actions can the operators take beforeevacuating the CR? When can the control room be considered safe after a firefor the operator to return?APPENDIX R QUESTIONS & ANSWERS17 RESPONSEThe control room fire area contains the controls and instrumental redundantshutdown systems in close proximity (i.e. usually separation is a few inches).Because it is possible to provide shutdown capability that is physically andelectrically independent of the fire area, it is our opinion that alternativeor dedicated shutdown capability and its associated circuits for the controlroom be independent of the cables system and components in the control roomfire area.The damage to the system in'the control room for a fire that causes evacuationof'the control room cannot be predicted. A bounding analysis should be madeto assure that safe conditions can be maintained from outside the control room.This analysis is dependent to the specific design.' The usual assumptions are:1. The reactor is tripped in the control room.2. Offsite power is lost as well as automatic starting of the onsite a.c.generators and the automatic function of valves and pumps whose controlcircuits could be affected by a control room fire.The analysis should demonstrate that capability exists to manually achievesafe shutdown conditions from outside the control room by restoring a.c. powerto designated pumps, assuring that valve lineups are correct, and assumingthat any malfunctions of valves that permit the loss of reactor coolant can becorrected before unrestorable conditions occur.Note that the only manual action in the control room prior to evacuation usuallygiven credit for is the reactor trip. For any additional control room actionsdeemed necessary prior to evacuation, a demonstration of the capability of per-forming such actions would have to be provided. Additionally, assurance wouldhave to be provided that such actions could not be negated by subsequent spur-ious actuation signals resulting from the postulated fire.After the fire, the operators could return to the control room when the follow-ing conditions have been met:1. The fire has been extinguished and so verified by appropriate fire protec-tion personnel.2. The control room has been deemed habitable by appropriate fire protectionpersonnel and the shift supervisor.3. Damage has been assessed and, if necessary, corrective action has beentaken to assure necessary safety, control and information systems arefunctional (some operators may assist with these tasks) and the shiftsupervisor has authorized return of plant control to the control room.4. Turnover procedures which assure an orderly transfer of control from thealternate shutdown panel to the control room has been completed.After returning to the control room, the operators can take any actions compa-tible with the condition of the control room. Controls in any area (cabinet)where the fire occurred would not be available. Smoke and fire suppressantAPPENDIX R QUESTIONS & ANSWERS18 damage in other areas (cabinets) must also be assessed and corrective actiontaken before controls in such cabinets are deemed functional. Controls inundamaged area (cabinets) could be operated as required. Minor modificationsinside the control room may be performed to reach cold shutdown.4. EMERGENCY LIGHTING4.1 Illumination LevelsQUESTIONWhat is the requisite intensity level for emergency lighting for egress routesand areas where shutdown functions must be performed? What are the bases fordetermining these levels of lighting?RESPONSEThe level of illumination provided by emergency lighting in access routes toand in areas where shutdown functions must be performed is a level that issufficient to enable an operator to reach that area and perform the shutdownfunctions. At the remote shutdown panels the illumination levels should besufficient for control panel operators.The bases for estimating these levels of lighting are the guidelines containedin Section 9.5.3 of the Standard Review Plan, which are based on industrystandards (i.e., Illuminating Engineering Society Handbook).Where a licensee has provided emergency lighting per Section III.J Apoendix R,we would expect that the licensee verify by field testing that this lightingis adequate to perform the intended tasks.5. ALTERNATIVE AND DEDICATED SHUTDOWN CAPABILITY5.1 Safe and Alternative Shutdown5.1.1 Previously Accepted Alternative Shutdown CapabilityQUESTIONAs part of the Appendix A review process, some plants had committed to an alter-native shutdown system in the form of a remote shutdown panel or remote shutdownsystem. Footnote 2 to Appendix R describes alternative shutdown capability asbeing associated with "Rerouting, relocating, or modifying of existing systems."To the extent that an existing remote shutdown system previously reviewed andapproved 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 ofAppendix R backfit?RESPONSEYes. Existing remote shutdown capabilities previously reviewed and approvedunder Appendix A to BTP APCSB 9.5-1 do not categorically comply with SectionIII.G.3 of Appendix R. Licensees were requested to re-analyze their plants todetermine compliance with Section III.G. If the licensee chooses to use theAPPENDIX R QUESTIONS & ANSWERS 19I --------.I ...---.-'. -I ..
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 CapabilityQUESTIONSSome licensees defined safe shutdown capability for purposes of analysis toSection III.G criteria as being composed of both the normal safe shutdowncapability and the pre-existing redundant or remote safe shutdown capabilitywhich was previously installed as part of the Appendix A process. This defini-tion often took the form of two "safe shutdown trains" comprising (1) one ofthe two normal safe shutdown trains, and (2) a second safe shutdown train capa-bility which was being provided by the pre-existing remote shutdown capability.This definitional process, which was undertaken by a number of licensees, makesa significant difference in the implementation of Appendix R. Under such adefinition, doesSection III.L criteria apply when the Commission did not callout Section III.L as a backfit?RESPONSEThe definitional process mentioned considers an alternative shutdown capabilityprovided under the Appendix A review as a redundant shutdown capability underthe Appendix R review. This definitional process is incorrect. For the pur-pose of analysis to Section III.G.2 criteria, the safe shutdown capability isdefined as one of the two normal safe shutdown trains. If the criteria ofSection III.G.2 are not met, an alternative shutdown capability is required.The alternative shutdown capability may utilize existing remote shutdown capa-bilities and must meet the criteria of Sections III.G.3 and III.L of Appendix R.See also the response to 5.1.3.5.1.3 II.L BackfitQUESTIONWhy do the Staff interpretive memoranda regarding the criteria for satisfactionof Section III.L form the auditable basis for determining compliance to Appen-dix R when the Commission failed to backfit this section to all plants?RESPONSEAlthough 10 CFR 50.48(b) does not specifically include Section III.L withSections III.G, J, and 0 of Appendix R as a requirement applicable to all powerreactors licensed prior to January 1, 1979, the Appendix, read as a whole, andthe 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 II.1applies to-tFe alternative safe shutdown option under Section III.G if andwhere that option is chosen by the licensee. This does not preclude licenseesfrom proposing and Justifying other methods, e.g., see Section #1, Process Moni-toring Instrumentation, of the "Interpretations of Appendix R."APPENDIX R OUESTIONS & ANSWERS 20*r I I 5.2 Procedures5.2.1 Shutdown and Repair BasisQUESTIONWith regard to the term "post-fire procedures" the Commission states that itis impossible to predict the course and extent of a fire. Given this, how doesone write post-fire shutdown and repair procedures that are both symptomaticand usable to an operator?RESPONSESafe shutdown capabilities including alternative shutdown capabilities are alldesigned for some maximum level of fire-damage (system unavailabilities, spur-ious actuations). Since the extent of the fire cannot be predicted, it seemsprudent to have the post-fire shutdown procedures guide the operator from fullsystem availability to the minimum shutdown capability. As for repair procedure,similar conditions exist. A repair procedure can be written based on the maxi-mum level of damage that is expected. This procedure would then provide shut-down capability without accurately predicting likely fire damage.5.2.2 Post Fire Operating ProceduresQUESTIONDoes the NRC have any requirements regardinq whether post-fire operatinq proce-dures should be based upon fire areas, systems, or be symptom-based?RESPONSEThe NRC does not have requirements, nor do we propose any requirements regard-ing whether post-fire operating procedures should be based upon fire areas, sys-tems or be symptom-based. We suggest that the post-fire shutdown capabilitiesdesigns be reviewed with the plant operation staff and procedures written withtheir input. See also responses to 5.2.1 and 5.2.3.5.2.3 Alternative Shutdown CapabilityQUESTIONIs it acceptable to develop post-fire operating procedures only for those areaswhere alternative shutdown is required? (For other areas standard, emergencyoperating procedures would be utilized in the presence of potential fire damageto a single train.)RESPONSEYes. The only requirement for post-fire operating procedures is for thoseareas where alternative shutdown is required. For other areas of the plant,shutdown would be achieved utilizing one of the two normal trains of shutdownsystem. Shutdown in degraded modes (one train unavailable) should be coveredby present operator training and abnormal and emergency operating procedures.If the degraded modes of operation are not presently covered, we would suggestAPPENDIX R QUESTIONS & ANSWERS21 that the operation staff of the plant determine whether additional training orprocedures are needed.5.2.4 Post Fire Procedures Guidance DocumentsQUESTIONDo any NRC Staff guidance documents exist relative to the extent, form, nature,etc. of Appendix R post-fire operating procedures?RESPONSENo. Other than the criteria of Section III.L, no specific post-fire shutdownprocedure guidance has been developed. See also responses to 5.2.1, 5.2.2 and5.2.3. The inspection process will be flexible in this regard as long as thelicensee can show compliance with the criteria of Section III.L.5.3 Safe Shutdown and Fire Damage5.3.1 Circuit Failure ModesQUESTIONWhat circuit failure modes must be considered in identifying circuits associatedby spurious actuation?RESPONSESections III.G.2 and III.L.7 of Appendix R define the circuit failure modes ashot shorts, open circuits, and .shorts to ground. For consideration of spuriousactuations, all possible functional failure states must be evaluated, that is,the component could be energized or de-energized by one or more of the abovefailure modes. Therefore, valves could fail open or closed; pumps could failrunning or not running; electrical distribution breakers could fail open orclosed. For three-phase AC circuits, the probability of getting a hot short onall three phases in the proper sequence to cause spurious operation of a motoris considered sufficiently low as to not require evaluation except for any casesinvolving Hi/Lo pressure interfaces. For ungrounded DC circuits, if it can beshown that only two hot shorts of the proper polarity without grounding couldcause spurious operation, no further evaluation is necessary except for anycases involving Hi/Lo pressure interfaces.5.3.2 "Hot Short" DurationQUESTIONIf one mode of fire damage involves a "hot short" how lona does that conditionexist as a result of fire damage prior to terminating in a ground or opencircuit and stopping the spurious actuation?RESPONSEWe would postulate that a "hot short" condition exists until action has beentaken to isolate the given circuit from the fire area, or other actions asAPPENDIX R QUESTIONS & ANSWERS22 appropriate have been taken 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 DurationQUESTIONSince hot shutdown cannot be maintained indefinitely, hot shutdown equipmentneeds to be protected for only a limited period of time. How long must aplant remain in that condition in order to meet the requirement for achievinghot shutdown with a single train of equipment?RESPONSESection III.G.1 requires that the one train of systems needed to achieve andmaintain hot shutdown be free of fire damage. Thus, the systems needed are tobe completely protected from the fire regardless of time. If the intent ofthe question concerns how long these systems must operate, these systems mustbe capable of operating until the systems needed to achieve and maintain coldshutdown are available.5.3.4 Cooldown EquipmentQUESTIONCertain equipment is necessary only in the cooldown phase when the plant isneither in hot nor cold shutdown condition as defined by technical specifica-tions. Is this equipment considered hot or cold shutdown in nature?RESPONSEAs stated in Section III.G.1, one train of systems needed to achieve and main-tain hot shutdown conditions must be free of fire damage. Systems necessaryto achieve and maintain cold shutdown 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 toachieve 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 certainequipment is maintaining hot shutdown while repairs are being made, one trainmust be free of fire damage. See also Section #2 of the "Interpretations ofAppendix R."5.3.5 Pressurizer HeatersQUESTIONMost PWRs do not require pressurizer heaters to maintain stable conditions. Infact, the Commission does not consider heaters to be important to safety andthey are not required to meet Class IE requirements. Are they required for hotshutdown under Appendix R? If yes, then how does a plant meet the separationrequirements of Section III.G.2.d,e. or f without major structural alterationsto the pressurizer?APPENDIX R QUESTIONS & ANSWERS 23 RESPONSEOne train of systems necessary to achieve and maintain hot shutdown conditionsmust be free of fire damage. PWR licensees have demonstrated the capabilityto achieve and maintain stable hot shutdown conditions without the use of pres-surizer heaters by utilizing the charging pump and a water solid pressurizerfor reactor coolant pressure control.5.3.6 On-Site PowerQUESTIONAppendix R,Section III.L.4 states in part, "If such equipment and systems willnot be capable of being powered by both on-site and off-site electrical powersystems because of fire damage,, an independent on-site power system shall beprovided." Again, in Appendix R, Section'III.L.5, the statement is made;"Ifsuch 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 becapable of being powered by both. onsite and offsite electrical power systemsbecause of fire damage, an independent onsite power system shall be provided."An Interpretation is needed of the meaning and the applicability of these twoquotes relative to alternative shutdown capabilities.RESPONSEThese statements are meant to indicate that the alternative shutdown capabilityshould be powered from an onsite power system independent (both electrically ;and physically) from the area under consideration. Further, if the normalemergency onslte4"power supplies (diesel generators) are not available becauseof fire damage, then a separate and independent onsite power system shall be'provided. As an example, some plants are utilizing a dedicated onsite dieselgenerator or gas turbine to power instrumentation and control panels which area part of the-alternative shutdown capability.5.3.7 Torus Level IndicationQUESTIONFor BWRs, I&E Information Notice 84-09 suggests that licensees need to havetorus level indication post-fire. If an analysis shows that a' level does notchange significantly during any operational modes or worse case conditions, islevel indication still required? Is an analysis in file adequate or is anexemption request required?RESPONSEIt continues to be our position that torus (suppression pool) level indicationis the preferred post-fire monitoring instrumentation in order to confirm theavailability of the torus (suppression pool) as a heat sink. We recognize thatexisting analyses indicate that suppression pool level is not significantlychanged during emergency shutdown conditions. However, we believe the operatorshould be able to confirm that spurious operations or other unanticipated occur-rences have not affected the torus function. An analysis of torus level chanqeby Itself is not considered an acceptable basis.APPENDIX R QUESTIONS & ANSWERS24 5.3.8 Short Circuit Coordination StudiesQUESTIONShould circuit coordination studies consider hiqh impedance faults?RESPONSETo meet the separation criteria of Section III.G.2 and III.G.3 of Appendix R,high impedance faults should be considered for all associated circuits locatedin the fire area of concern. Thus, simultaneous high impedance faults (belowthe trip point for the breaker on each individual circuit) for all associatedcircuits located in the fire area should be considered in the evaluation of thesafe shutdown capability. Clearing such faults on associated circuits whichmay affect safe shutdown may be accomplished by manual breaker trips governedby written procedures. Circuit coordination studies need not be performed ifit is assumed that shutdown capability will be disabled by such high impedancefaults and appropriate written procedures for clearing them are provided.5.3.9 Diagnostic InstrumentationQUESTIONWhat is diagnostic instrumentation?RESPONSEDiagnostic instrumentation is instrumentation, beyond that previously identifiedin Attachment 1 to I&E Information Notice 84-09, needed to assure proper actua-tion and functioning of safe shutdown equipment and support equipment (e.g.,flow rate, pump discharge pressure). The diagnostic instrumentation neededdepends on the design of the alternative shutdown capability. Diagnostic in-strumentation, if needed, will be evaluated during the staff's review of thelicensee's proposal for the alternative shutdown capability.5.3.10 Design Basis Plant TransientsQUESTIONWhat plant transients should be considered in the design of the alternative ordedicated shutdown systems?RESPONSEPer the criteria of Section III.L of Appendix R a loss of offsite power shallbe 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 onespurious actuation or signal resulting from a fire in any plant area;andAPPENDIX R QUESTIONS & ANSWERS 25 b. The safe shutdown capability should not be adversely affected by a firein any plant area which results in the loss of all automatic function(signals, logic) from the circuits located in the area in conjunctionwith one worst case spurious actuation or signal resulting from the fire;andc. The safe shutdown capability should not be adversely affected by a firein any plant area which results in spurious actuation of the redundantvalves in any one high-low pressure interface line.5.3.11 Alternative/Dedicated Shutdown v. Remote Shutdown SystemsQUESTIONWhat is the difference between the alternate/dedicated shutdown systems requiredfor fire protection and the!remote shutdown systems recommended under Chapter 7of the SRP?RESPONSEThe remote shutdown systems recommended under Chapter 7 of the SRP are neededto meet GDC 19. These remote shutdown systems need to be redundant and physi-cally 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 forAppendix R need not be redundant but must be both physically and electricallyindependent of the control room.6. OIL COLLECTION SYSTEMS FOR REACTOR COOLANT PUMP6.1 Lube Oil System Seismic DesignQUESTIONIf the reactor coolant pump lube oil system and associated appurtenances are-seismically designed, does the lube oil collection system also require seismicdesign? Is an exemption required?RESPONSEWhere the RCP lube oil system is capable of withstanding the safe shutdownearthquake (SSE), the analysis should assume that only random oil leaks fromthe joints could occur during the lifetime of the plant. The oil collectionsystem, therefore, should be designed to safely channel the quantity of oilfrom 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 non-seismically designed oil collection system.The basis for this exemption would be that random leaks are not assumed tooccur simultaneously with the seismic event, since the lube oil system isdesigned to withstand the seismic event. However, the Rule, as written, doesnot make this allowance.APPENDIX R QUESTIONS & ANSWERS26 6.2 ContainerQUESTIONIt would appear that a literal reading of Section III.0 regarding the oil col-lection system for the reactor coolant pump could be met by a combination ofseismically designed splash shields and a sump with sufficient capacity to con-tain the entire lube oil system inventory. If the reactor coolant pump isseismically designed and the nearby piping hot surfaces are protected by seis-mically designed splash shields such that any spilled lube oil would contactonly cold surfaces, does this design concept conform to the requirements of therule?RESPONSEIf the reactor coolant pump, including the oil system, is seismically designedand the nearby hot surfaces of piping are protected by seismically designedsplash shields such that any spilled lube oil would contact only cold surfaces,and it could be demonstrated by engineering analysis that sump and splashshields would be capable of preventing a fire during normal and design basisaccident 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 thatoil from all potential pressurized and unpressurized leakage points would besafely collected and drained to the sump. The sump should be shown capable ofsafely containing all of the anticipated oil leakage. The analysis shouldverify that there are no electric sources of ignition.7 BRANCH TECHNICAL POSITION CMEB 9.5-17.1 Fire Protection and Seismic EventsQUESTIONFor which situations other than the reactor coolant pump lube oil system areseismic events assumed to be initiators of a fire?RESPONSEThe guidelines for the seismic design of fire protection systems which coverother general situations is delineated in BTP CMEB 9.5-1 C.1.C(3) and (4):"(3) As a minimum, the fire suppression system should be capable of deliveringwater to manual hose stations located within hose reach of areas contain-ing equipment required for safe plant shutdown following the safe shutdownearthquake (SSE). In areas of high seismic activity, the staff will con-sider on a case-by-case basis the need to design the fire detection andsuppression systems to be functional following the SSE.(4) The fire protection systems should retain their original design capabilityfor (a) natural phenomena of less severity and greater frequency than themost severe natural phenomena (approximately once in 10 years) such astornadoes, hurricanes, floods, ice storms, or small-intensity earthquakesAPPENDIX R QUESTIONS & ANSWERS 27 that are characteristic of the geographic region, and (b) potential man-made site-related events such as oil barge collisions or aircraft crashes,that have a reasonable probability of occurring at a specific plant site.The effects of lightning strikes should be included in the overall plantfire 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 system failures need not be consideredconcurrent with other plant accidents or the most severe natural phenomena."Our guidelines on the seismic design of fire protection systems installed insafety related areas are delineated in Regulatory Guide 1.29 "Seismic DesignClassification," paragraph C.2. The failure of any system should not affect asystem from performing its safety function.Our guidelines on the seismic design of hydrogen lines is delineated in BTPCMEB 9.5-1 Section C.5.d(5):(5) Hydrogen lines in safety-related areas should be either designed to seismicClass I requirements, or sleeved such that the outer pipe is directlyvented to the outside, or should be equipped with excess flow valves sothat in case of a line break, the hydrogen concentration in the affectedareas will not exceed 2%.All PWR's have a hydrogen line going to the Volume Control Tank (Make-up Tank)that needs to be protected.To identify plant specific situations in which seismic events could initiate afire in a specific plant area, the fire protection engineer and systems engineerperforming the fire hazards analysis should be concerned with in-situ combusti-ble materials which can be released in a manner such that they could contactin-situ ignition sources by a seismic event. An example of this would be therupture of the RCP lube oil line directly above the hot reactor coolant piping.The fire protection engineer should also be concerned with seismic inducedignition sources, electrical or mechanical, which could contact nearby in-situcombustible materials.It should be noted that the guidelines cited above from BTP CMEB 9.5-1 are notapplicable to plants reviewed and approved under BTP APCSB 9.5-1.7.2 Random Fire and Seismic EventsQUESTIONIs a random fire to be postulated concurrent with a seismic event?RESPONSEOur position, as stated in Section C.1.6 of BTP CMEB 9.5-1, is "Worst casefire need not be postulated to be simultaneous with nonfire-related failuresin safety systems, plant accidents, or the most severe natural phenomena."APPENDIX R QUESTIONS & ANSWERS 28 Where plant systems are designed to prevent the release of combustible materialscaused by a seismic event, such as a dike around a fuel oil tank transformer, orseismic supports for hydrogen lines, then no fire need to be arbitrarily assumedto take place in the fire hazards analysis.Because it is impossible to completely preclude the occurrence of a seismicallyinduced fire, Section C.6.c(4) of CMEB 9.5-1 states:"Provisions should be made to supply water at least to standpipes andhose connections for manual firefighting in areas containing equipmentrequired for safe plant shutdown in the event of a safe shutdown earth-quake. The piping system serving such hose stations should be analyzedfor SSE loading and should be provided with supports to ensure systempressure integrity. The piping and valves for the portion of hose stand-pipe system affected by this functional requirement should, as a minimum,satisfy ANSI B31.1, 'Power Piping.' The water supply for this conditionmay be obtained by manual operator actuation of valves in a connectionto the hose standpipe header from a normal seismic Category I water sys-tem such as the essential service water system. The cross connectionshould be (a) capable of providing flow to at least two hose stations(approximately 75 gpm per hose station), and (b) designed to the samestandards as the seismic Category I water system; it should not degradethe performance of the seismic Category I water system."The post-seismic procedures should include a damage survey, and a determinationof whether any fires were initiated as a result of the seismic event. See alsothe response to Question 7.1.It should be noted that the guidelines cited above from BTP CMEB 9.5-1 are notapplicable to plants reviewed and approved under BTP APCSB 9.5-1.8. LICENSING POLICY8.1 Fire Hazard Analysis/Fire Protection Plan UpdatingQUESTIONWhat constitutes the fire protection plan required by 50.48(a)? Should licens-.ees have programs to maintain the fire hazards analysis and the fire protectionplan current or updated periodically? How often should the plan be updated?Must revisions be provided to the NRC?RESPONSEThe basic elements required in the fire protection plan are described inIn CFR 50.48(a). The fire protection program that Implements that plan shouldinclude the details of the fire hazards analysis. The plan and program may beseparate or combined documents and must be kept current with the fire hazardsanalysis updated prior to making modifications. We would expect that the fireprotection plan and program will be Incorporated as part of the FSAR and therefore,would be updated and submitted to the NRC in conformance with the requirementsof 10 CFR 50.71(e).APPENDIX R QUESTIONS & ANSWERS29 8.2 Fire Protection License ConditionQUESTIONWhat is the significance of the fire protection license condition?RESPONSESee Generic Letter Section F8.3 III G, J and 0 Exemptions for Future ModificationsQUESTIONIs an exemption required from Appendix R Sections other than III.G, III.J andIII.0 for future modifications that do not comply with such sections?RESPONSEYes, for plants licensed prior to January 1, 1979 and for those modificationswhich deviate from the previously accepted fire protection configurations. Theexclusion of the applicability of Sections of Appendix R other than III.G, III.J,and III.0 is limited to those features "accepted bv the NRC staff as satisfyingthe provisions of Appendix A to Branch Technical Position BTP APCSB 9.5-1 reflectedin staff fire protection safety evaluation reports issued prior to the effectivedate of the rule." No reanalysis is required except for proposed modificationswhich would alter previously approved features. This position is based directlyon CFR 50.48(b). Also see response to Question 8.1.8.4 Future ChangesQUESTIONWill future changes (no matter how minor) to approved configurations be requiredto be reviewed by the Staff in an exemption request? At what point may theprocess of 10 CFR 50.59 be invoked?RESPONSEIf a future modification involves a change to a license condition or technicalspecification, a license amendment request must be submitted. When a modifica-tion not involving a technical specification or license condition is planned,APPENDIX R OUESTIONS & ANSWERS30
.Ithe evaluation made in conformance with 10 CFR 50.59 to determine whether anunreviewed safety question is involved must include an assessment of the modi-!fication's impact on the existing fire hazards analysis for the area. Thispart of the evaluation must be performed by the person responsible for the firesafety program for the plant. The assessment must include the effect on com-bustible loading and distribution and the consideration of whether circuits orcomponents, including asociated circuits, for a train of equipment needed forsafe shutdown are beinq affected or a new element introduced in the area. Ifthis evaluation concludes that there is no significant impact, this conclusionand its basis must be documented as part of the 50.59 evaluation and be avail-able for future inspection and reference. If the evaluation finds that thereis an impact that could result in the area either not being in conformancewith Appendix R, or some other aspect of the approved fire protection program,or being outside the basis for an exemption that was granted for the areainvolved, the licensee must either make modifications to achieve conformance orjustify and request exemption (or, for the post 1979 plants, approval) from theNRC. See also responses to Questions 8.1 and 8.2.8.5 Schedular and Blanket ExemptionsQUESTIONIf an exemption is warranted and at the same time the provisions of the ruleindicate that the appropriate schedular deadlines have vassed, should a sched-uler exemption be filed at the same time as the technical exemption request?If as part of the exemption request the utility is proposing to make modifica-tions to achieve a reasonable level of conformance with Appendix R. and if theassociated "clock" has run out for that type of modification, should the tech-nical exemption request and the description of the modification be filed witha schedular exemption?When filing a schedular exemption under §50.12, it is not always clear fromwhat specific paragraphs of §50.48 an exemption should be sought. Is it ac-ceptable to request a blanket exemption from the schedular provisions of10 CFR §50.48 without a specification by paragraph?If an exemption request is submitted to meet newly published interpretationsof Appendix R, when does the licensee need to be in compliance? Is the sched-ule presented in Appendix R still the guideline or must a new schedule bedeveloped under a different criteria?RESPONSEIn response to the first two questions above, once the time period allowedby a schedule in ¶50.48 has run out, the schedule cannot be reinstituted byexemption. In such a situation the licensee is in violation of the recula-tion and should notify the Region proposing compensatory measures and aschedule for gaining compliance either with the provisions of Appendix R orwith the provisions of an approved technical exemption. If a technicalexemption is involved but is not yet applied for, the schedule for thataction should be included and the licensee runs the risk that if the techni-cal exemption is denied, a violation of the regulation has been incurred.APPENDIX R QUESTIONS & ANSWERS 31 Requests for schedular exemptions may be made under 10 CFR 50.12, but suchrequests will be granted sparingly based upon the following criteria:1. The utility has, since the promulgation of Appendix R in 1980, proceededexpeditiously to meet the Commission's requirements.2. The delay is caused by circumstances beyond the utility's control, orimmediate implementation would cause undue hardship (e.g., plant shut-down to effect a minor modification).3. The proposed schedule for completion represents a best effort underthe circumstances.4. Adequate interim compensatory measures will be taken until complianceis achieved.This policy is further explained in the generic letter transmitting thispackage.8.6 Trivial DeviationsQUESTIONWhat guidance can the NRC Staff give the industry regarding when a deviationfrom the literal interpretation of Appendix R is sufficiently trivial as tonot require a specific exemption?RESPONSEThe significance of a deviation must be Judged as part of a fire hazards anal-ysis. The conclusion of this analysis is always subject to review by the NRCinspector.8.7 Revised ModificationsQUESTIONWhat is the process for alterino configurations not yet implemented for plantswith Appendix R SERs?RESPONSEIf licensees propose changes to their NRC approved modifications, they must sub-mit their new proposal and revised schedule for implementation for NRC approval.This change must be justified as to (1) the reason for the change, (2) thebasis for the revised schedule, and (3) the interim measures that will be pro-vided to assure post fire shutdown capability until the final modifications areimplemented. Whether or not enforcement action will be taken based upon con-tinued noncompliance with Appendix R will be decided by the NRC RegionalAdministrator in consultation with NRC Headquarters.APPENDIX R QUESTIONS & ANSWERS32
- -8.8 Smallest Opening in a Fire BarrierQUESTIONWhat is the smallest opening allowed in a fire area barrier for which anexemption request is not needed?RESPONSEUnsealed openings in the configuration for which approval was obtained by anapproved 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 whichseparate fire areas should be sealed or closed to provide a fire resistancerating at least equal to that required of the barrier itself. Openingsinside conduit larger than 4 inches in diameter should be sealed at thefire barrier penetration. Openings inside conduit 4 inches or less indiameter should be sealed on each side of the fire barrier and sealedeither at both ends or at the fire barrier with non-combustible materialto prevent the passage of smoke and hot gases. Fire barrier penetrationsthat must maintain environmental isolation or pressure differentialsshould be qualified by test to maintain the barrier integrity under suchconditions."The unsealed opening(s) allowed in a fire area boundarv 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 redundantshutdown divisions on the other side. The licensee should assess the adequacyof existing protection and should determine the minimum size based on a firehazards analysis and conservative fire protection engineering Judgment. If thesignificance of openings in fire barriers is marginal, a formal exemption requestcould be submitted or the staff consulted. The basis for the lack of signifi-cance should be available for review by NRC Inspectors.Our acceptance of unprotected openings in fire barriers would depend upon thequantity and nature of combustible materials on either side of the barrier; thelocation of the opening(s) in relation to the ceiling (for openings in walls);the location, vulnerability and importance of shutdown systems on either sideof the barrier; and compensating fire protection.See also Section #4 of the "Interpretations of Appendix R."8.9 NFPA Code DeviationQUESTIONIs an exemption/deviation required for deviations from NFPA Codes?RESPONSEDeviations from the codes should be identified and Justified in the FSAR orFHA.APPENDIX R QUESTIONS & ANSWERS33 IAn exemption is not required for NFPA codes. NRC guidelines reference certainNFPA codes as guidelines to the systems 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 identify any deviations fromsuch codes, NRR and the Regions expect that the design conforms to the codeand the design is subject to inspection against the NFPA codes.8.10 "ASTM E-119" Design BasisQUESTIONIs an exemption/deviation required, if components are designed to withstand an'ASTM E-119" fire?RESPONSESome cables are being developed for high temperature (e.g., 17000F) applications.An exemption would be required if such cable is used in lieu of the alternativesof III.G.2 or III.G.3 in a pre-1979 plant. A deviation from the guidelineswould be required for similar applications in a post 1979 plant.8.11 Plants Licensed After January 1, 1979QUESTIONWhat fire protection guidelines and requirements apply to the plants licensedafter January 1, 1979?RESPONSEPost-1979 plants are subject to:GDC 310 CFR 50.48(a) and (e)The guidelines identified in the footnotes to 50.48(a)Guidelines documents issued after January 1, 1979.Commitments made to meet the requirements of Appendix R; or specific sec-tions such as III.G, III.J, III.0; and Appendix A to BTP APSCB 9.5-1; orBTP CMEB 9.5-1, which includes the requirements of Appendix R* and theprevious guidance documents incorporated into the Branch Technical Position.The license for each plant licensed after January 1, 1979 contains a licensecondition which identifies by reference the approved fire protection programfor that plant.*A deficiency in the BTP CMEB 9.5-1 has been noted in that a requirement inAppendix R Section III.G.3.b to provide alternative or dedicated shutdown cap-ability in an area where both redundant safe shutdown trains could be damagedAPPENDIX R QUESTIONS & ANSWERS34 by suppression activities or inadvertent operation or rupture of fire suppres-sion systems is not included. This requirement will be added in the next revi-sion of the BTP.8.12 Cold Shutdown Equipment AvailabilityQUESTIONA. Can a licensee achieve compliance with III.G.1(b) by demonstrating thatone train of cold shutdown equipment will remain free of fire damage?B. In demonstrating that one train of cold shutdown equipment will remainfree of fire damage, is a licensee limited to the three alternatives inIII.G.2?RESPONSEA. Yes.B. No.8.13 Guidance DocumentsQUESTIONPlease list all NRR guidance documents and position papers issued since Appendix Rwas promulgated.RESPONSEFire Protection Guidance Issued Since January 1, 1975:IE Information NoticesNo. 83-41: Actuation of fire suppression systems causing inoperabili ofsafety related equipment.No. 83-69: Impronerly installed fire dampers at nuclear power plants.No. 83-83: Use of portable radio transmitters inside nuclear power plants.*No. 84-09: Lessons Learned From NRC Inspections of Fire Protection SafeShutdown Systems (10 CFR 50, Appendix R)Standard Review Plan9.5.1, Rev. 1 Fire Protection System, dated 5/1/769.5.1, Rev. 2 Fire Protection Program, dated 03/789.5.1, Rev. 3 Fire Protection Program, July 1981.APPENDIX R QUESTIONS & ANSWERS 35 Reaulations10 CFR Part 50: Proposed fire protection program for nuclear power plantsoperating prior to January 1, 1979, dated May 29, 1980. Federal RegisterVol. 45, No. 105, 36082.10 CFR Part 50: Fire protection program for operating nuclear power plants,dated November 19, 1980. Federal Register Vol. 45, No. 225, 76602.10 CFR Part 50: Fire protection rule corrections, dated September 8, 1981.Federal Register Vol. 46, No. 173, 44734.Generic LettersNOTE: The following documents were obtained from the Palisades file DocketNo. 50-255. Similar documents should be in the file for other operating facil-ities. The dates may vary slightly.1. Letter dated 9/28/76 -Enclosing App. A to BTP APCSB 9.5-1 and supplementaryguidance on information needed for fire protection program evaluation.2. Letter dated 12/1/76 -Enclosing sample Technical Specifications and anerrata sheet.3. Letter dated 8/19/77 -Enclosing "Nuclear Plant Fire Protection FunctionalResponsibilities, Administrative Controls and Quality Assurance."4. Letter dated 6/8/78 -Re: Manpower requirements for operating reactors.5. Letter dated 9/7/79 -Re: Minimum fire brigade shift size.6. Letter dated 9/14/79 -Enclosing staff positions -safe shutdown capability.7. Letter dated 10/31/80 -Enclosing new 10 CFR 50.48 regarding fire protectionschedules for operating nuclear power plants.8. Letter dated 11/24/80 -Enclosing a copy of revised 10 CFR 50.48 and newApp. R to 10 CFR 50, and a summary of open items from the SER for the BTPAPCSB 9.5-1 review.9. Letter dated 2/20/81 -Generic Letter 81-12 identifying information neededfor NRC review of modifications for alternative shutdown capability.10. Letter dated 4/7/82 -Provided clarification to Generic Letter 81-12 andguidance on information needed for NRC review of exemption requests.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 CertainRequirements of Appendix R to 10 CFR 50.APPENDIX R QUESTIONS & ANSWERS36 Staff Generic Positions1. 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 12/30/83 -Physical independence ofelectrical systems.4. Memo, Eisenhut to Jordan, dated 10/24/83 -Bullet resistant fire doors.*Staff positions regarding the need for certain exemptions delineated in thisguidance document have been revised per the "Interpretations of Appendix R".8.14 Deviation From Guidance DocumentsQUESTIONIf a utility determines that a deviation from a guidance document exists, doesan exemption request need to be filed? If so, what is the legal basis forthis requirement?RESPONSENo.8.15 Staff Interpretation of Appendix RQUESTIONHow does the Staff initiate interpretation% of Appendix R in a manner whichensures their technical adequacy'and consistency with the rule's objectives(e.g., presentation to ACRS, issue for comment as in draft regulatory guides,etc.)?RESPONSEStaff positions are initiated when our experience shows that generic issuesare identified that require clarification. These positions are reviewed foraccuracy and consistency by the cognizant Division Directors. Usually, theyare not issued for comment. However, Generic Letter 83-33 was commented on bythe NUFPG since it was initiated, in part, at their request.8.16 Dissemination of New Staff PositionsQUESTIONWill licensees be automatically sent a copy of new Staff position papers asthey are developed?RESPONSEThe Staff positions on generic subjects are considered for issuance in GenericLetters from ONRR and Information Notices or Bulletins from OI&E. StaffAPPENDIX R QUESTIONS & ANSWERS37 positions issued for specific questions on specific plants are not givengeneric promulgation because they normally involve plant specific designconsiderations.8.17 Equivalent AlternativesQUESTIONHow does a licensee demonstrate that alternative measures are equivalent tothe measures of Section III.G.2 in order to obtain an exemption lacking aformal definition of the term "free of fire damage"?RESPONSESee Item #3 of "Interpretations of Appendix R."8.18 Coordination Study UpdateQUESTIONCircuit modifications are an ongoing process. How recent must a coordinationstudy be in order to be valid in protecting circuits associated by commonpower source?RESPONSEWe would expect that as circuit modifications are made, the design packagewould address the electrical protection required and the effects of thisprotection on the coordination of the protection for the power distributionsystem. This type of consideration should be included in the evaluationrequired by 10 CFR 50.59 Changes, Tests and Experiments. The design packageand modification evaluation could not be complete without consideration of thecoordination study. Therefore, we would expect that the coordination studieswould be current with the last circuit modification made.8.19 Exemption Request ThresholdQUESTION(a) What is the threshold for exemption requests? (b) Is it necessary tofile a request for each and every possible deviation from Appendix R?RESPONSETypical examples are discussed in the response to Questions 8.19.1 through8.19.4.(a) The licensee must develop its criteria for an exemption request threshold.(b) No.8.19.1 Penetration Designs Not Laboratory ApprovedAPPENDIX R QUESTIONS & ANSWERS 38.-.I , -----." ....
QUESTIONWhere penetration designs have been reviewed and approved by NRC but have notbeen classified by an approval laboratory, will it be necessary to submit anexemption request?RESPONSENo.8.19.2 Individual vs. Package ExemptionsQUESTIONHow do we submit future modification exemDtion requests, etc.? Would NRCprefer them individually, or developed and submitted in packages for reviewand approval?RESPONSEFuture exemptions should be-submitted individually, if they are independent ofeach other.8.19.3 Exemption Request Supporting DetailQUESTIONWhen an exemption request is filed, what criteria are used to determine thelevel of detail needed to support the request?RESPONSESee Enclosure 2 of NRC's letter to all licensees dated April-May 1982.8.19.4 50.12 vs. 50.48 Exemption RequestsQUESTIONWith regard to exemption requests for future modifications, will they besubmitted under 50.12 or 50.48?RESPONSE10 CFR 50.12.8.20 Post January 1, 1979 Plants and Exemption RequestsQUESTIONDo plants licensed after January 1, 1979 which have committed to meet therequirements of Section III.G, III.J and III.0 and are required to do so as alicense condition, need to request exemptions for alternative configurations?APPENDIX R QUESTIONS & ANSWERS39-.. ----_ ..--~~ 1 .---.. -1 -1.. .... A..I.... .. .. ..... .I___E_
RESPONSENo; however, deviations from the requirements of Section III.G, III.J andIII.0 should be identified and Justified in the FSAR or FHA and the deviationwould probably require a license amendment to change the license condition.See responses 8.1 and 8.2.8.21 NRC Approval for BTP CMEB 9.5-1 DeviationsQUESTIONDo future deviations from BTP CMEB 9.5-1 guidelines require approval by theNRC? Do such deviations constitute a violation of license conditions?RESPONSErCompliance with guidelines in the BTP is only required to the extent that theywere incorporated in the approved Fire Protection Program as identified in thelicense condition. (See Response 8.2)9. INSPECTION POLICY9.1 Safety ImplicationsQUESTIONSince the Commission states.that fire damagecannot be predicted, how does the Commissiontions have "important safety implications?"cannot be defined and fire spreaddetermine which Appendix R viola-RESPONSEIII.G.2 provides alternatives to ensure thatfree of fire damage. Fire spread within onedamage is limited to one fire area.one of the redundant trains isarea cannot be predicted, butDetermination of the Appendix R violations that have "important safety implica-tions" are based on the equipment, components, and systems that are located inthe same fire area that are needed for safe shutdown or can adversely affectsafe shutdown, and are not protected by the features of III.G.2, III.G.3 or anapproved alternative.9.2 Uniform EnforcementQUESTIONHow does the Commission ensure that violations of the rule are uniformly treatedbetween regions?APPENDIX R QUESTIONS & ANSWERS40 RESPONSEEach Region evaluates violations in accordance with the NRC Enforcement Policy,10 CFR 2, Appendix C. The Policy provides guidance for the determination ofappropriate enforcement sanctions for violations. The Office of Inspection andEnforcement provides guidance for and monitors Regional implementation of thePolicy to ensure a uniform application. In addition, the policy requires thatall escalated enforcement actions be approved by the Director of the Office ofInspection and Enforcement.9.3 NTOL InspectionsQUESTIONWill NTOLs be subject to an Appendix R audit now being performed on plantslicensed to operate prior to January 1, 1979? Or, will the current review andanalysis being performed by the Staff be satisfactory?RESPONSEYes, NTOLs will be subject to the Appendix R audit; the TIrevised to reflect the appropriate requirements for NTOLs'to conduct such inspections prior to issuing the operating2515/62 is beingand it is our intentlicense.10 CFR 50.48 requires each such plant to have a fire protection plan. Theiroperating license will contain a specific license condition to implement theirapproved fire protection program which must identify deviations from Appendix R.The fire protection inspections will be against the particular license conditions.9.4 Future TI 2515/62 RevisionsQUESTIONDoes the NRC plan to issue a new or revised version of Temporary Instruc-tion 2515/62 for future Appendix R audits?RESPONSEYes.9.5 Documentation Supplied by LicenseeQUESTIONTemporary Instruction 2515/62 provided a list of documentation that the NRCneeds to review as part of the audit process. In past audits, the NRC hasrequested additional information other than that contained on the list. Willa new list of documentation be developed?APPENDIX R QUESTIONS & ANSWERS41 RESPONSEThe documentation listing provided in TI-2515/62 does not restrict the inspectionteam from enhancing inspection efficiency by requesting a licensee to provideadditional relevant documentation. A new listing of documentation for TI-2515/62is not being developed.9.6 Subsequent InspectionsQUESTIONTo what extent will Appendix R issues be raised at future Regional I&E FireProtection Audits after a successful Appendix R audit? For example, if anarea has already been reviewed and no noncompliance found, will it be subjectto later review and reinterpretation by the Staff?RESPONSEThe Appendix R inspections are conducted on a sample basis. These inspectionsdo not certify that all possible items of noncompliance with Appendix R havebeen identified. The inspection results do provide a basis for a determina-tion of the adequacy of a licensee's Appendix R reanalysis, modification andpreparation.When a noncompliance with Appendix R requirements is identified, a notice ofviolation will be issued to ensure adequate corrective action. In those casesin which the licensee believes that the staff has invoked a reinterpretation ofadequacy in areas which had previously been reviewed, NRC's procedures forappeal would be applicable.9.7 NRC List of Conforming ItemsQUESTIONAt the end of the audit, will the NRC provide a list of items that had beenreviewed and found in conformance with Appendix R? To date, only areas ofnonconformance have been specifically identified in exit interviews.RESPONSESubsequent to an Appendix R inspection, the NRC will not provide a list ofitems reviewed and found to be in conformance with Appendix R.We do list the areas inspected and where non-compliances were not found.APPENDIX R QUESTIONS & ANSWERS42 9.8 Inspection Re-reviewQUESTIONWhere assumptions are made and clearly stated within the analysis submitted toNRR for review, will such assumptions be subject to a second review by OI&Eduring the inspection process?Where assumptions are made in conjunction with the analysis, should exemptionrequests be filed just to provide protection for the licensee?If NRR accepts a licensee's selection of equipment and shutdown paths as beingsufficient to meet the Appendix R shutdown criteria, will OI&E review and havethe right to challenge the approved shutdown paths and approved equipment selec-tion? Or will they only check the shutdown paths and equipment in question tosee that they meet the Appendix R requirements, i.e., separation?RESPONSETo the extent that a licensee's submittal to NRR is comprehensive and suffi-ciently detailed, the basis for the OI&E Appendix R inspection will be theassumptions, shutdown paths and equipment selections approved by NRR. If theinspection results in new information that casts doubt upon the approved con-figuration, the Regional inspectors have the responsibility to resolve suchdoubts.9.9 List of Shutdown EquipmentQUESTIONWhat lists of shutdown equipment will be used by the Regional inspectors, ifthe shutdown analysis has not been reviewed and approved by NRR? TRESPONSERegional Inspectors will use the lists of shutdown equipment the licensee hasidentified in his fire protection plan.Generic Letter 81-12 and its clarification documents expect licensees to showhow they will shutdown if a fire area is not provided with redundant trainseparation. Inherent within this expectation is the assumption that the licen-see will identify the equipment to be used. It is because the licensees havenot had fire hazard analyses at all for non-alternative shutdown fire areas thatthe inspectors to date have resorted to using the only lists available (thealternative 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 usedfor alternate shutdown, since 10 CFR 50.48 requires NRR review and approval ofthe means of alternate shutdown.APPENDIX R QUESTIONS & ANSWERS 43 ENCLOSURE 3Fire Protection(Name of licensee) shall implement and maintain in effect all provisionsof the approved fire protection program as described in the Final SafetyAnalysis Report for the facility (or as described in submittals dated------------) and as approved in the SER dated ------------(and Supplementsdated----------------) subject to the following provision:The licensee may make changes to the approved fire protection programwithout prior approval of the Commission only if those chanqes would notadversely affect the ability to achieve and maintain safe shutdown in theevent of a fir amendment to the operating license which amends any current license conditionsregarding fire protection and substitutes the following standard condition:Fire Protection(Name of Licensee) shall implement and maintain in effect all provisionsof the approved fire protection program as described in the FinalSafety Analysis Report for the facility (or as described in submittalsdated -------------) and as approved in the SER dated ------------(andSupplements dated ------------) subject to the following provision:The licensee may make changes to the approved fire protectionprogram without prior approval of the Commission only if those changeswould not adversely affect the ability to achieve and maintain safeshutdown in the event of a fire.The licensee may alter specific features of the approved program provided(a) such changes do not otherwise involve a change in a license conditionor technical specification or result in an unreviewed safety question(see 10 CFR 50.59), and (b) such changes do not result in failure tocomplete the fire protection program as approved by the Commission. Aswith other changes implemented under 10 CFR 50.59, the licensee shallmaintain, in auditable form, a current record of all such changes,including an analysis of the effects of the change on the fire protectionprogram, and shall make such records available to NRC inspectors uponrequest. All changes to the approved program shall be reported annuallyto the Director of the Office of Nuclear Reactor Regulation, along withthe FSAR revisions required by 10 CFR 50.71(e).Temporary changes to specific fire protection features which may be neces-sary to accomplish maintenance or modifications are acceptable providedinterim compensatory measures are implemented.At the same time the licensee may request an amendment to delete the technicalspecifications that will now be unnecessary.Inclusion of the fire protection program in the FSAR will be a prerequisitefor licensing for all now under review. The standard license condition willbe included in new licenses.
Sincerely,Darrell G. Eisenhut, Deputy DirectorOffice of Nuclear Reactor Regulation
Enclosures:
1. Interpretations of Appendix R2. Appendix R Questions and Answers3. Fire Protection License Condition*See previous concurrenceDRL:PD#1* DBL:PD#1* DBL:PD#1* D:DBL* DCJamerson JStang:tm JZwolinski RBernero ut04/21/86 04/21/86 04/21/86 04/21/86 6 6 5amendment to the operating license which amends any current license on tionsregarding fire protection and substitutes the following standard ndition:Fire Protection(Name of Licensee) shall implement and maintain in effect a0 provisionsof the approved fire protection program as described in to FinalSafety Analysis Report for the facility (or as describey1in submittalsdated ------------) and as approved in the SER dated ------------(andSupplements dated ------------) subject to the follotrng provision:/The licensee may make changes to the approve>& fire protectionprogram without prior approval of the Comm ~sion only If those changeswould not adversely affect the ability tQ achieve and maintain safeshutdown in the event of a fire. /The licensee may alter specific features of tbe approved program provided(a) such changes do not otherwise involve a ange in a license conditionor technical specification or result in an nreviewed safety question(see 10 CFR 50.59), and (b) such changes o not result in failure tocomplete the fire protection program as, approved by the Commission. Aswith other changes implemented under $ CFR 50.59, the licensee shallmaintain, in auditable form, a current record of all such changes,including an analysis of the effec s of the change on the fire protectionprogram, and shall make such rec ids available to NRC inspectors uponrequest. All changes to the appfoved program shall be reported annuallyto the Director of the Office ,6f Nuclear Reactor Regulation, along withthe FSAR revisions required 10 CFR 50.71(e).Temporary changes to speci ic fire protection features which may be neces-sary to accomplish maint ance or modifications are acceptable providedinterim compensatory m sures are implemented.At the same time th icensee may request an amendment to delete the technicalspecifications that will now be unnecessary.Inclusion of th~ fire protection program in the FSAR will be a prerequisitefor licensing or all now under review. The standard license condition willbe included id new licenses.Harold R. Denton, DirectorOffice of Nuclear Reactor RegulationEnc osures:1./Interpretations of Appendix R2 Appendix R Quest' ns nd Answsers r 'Fire Protection I se Conditi , c9 c"'DBL:PD#1 OIL4I1 DBL D#1 @ D:DBL 96 DD:NRR D:NRRCJamerso K ti :tm JZwolinski RBernero DEisenhut HDenton/2A /8 /86 % 8/i'/86 sj /v/86 / /86 / /86
-I-5-amendment to the operating license which amends any current license co itonsregarding fire protection and substitutes the following standard con tion:Fire Protection(Name of Licensee) shall implement and maintain in effect all rovisionsof the approved fire protection program as described in the inalSafety Analysis Report for the facility (or as described ' submittalsdated -------------) and as approved in the SER dated ---------(andSupplements dated ------------) subject to the followi provision:The licensee may make changes to the approved ire protectionprogram without prior approval of the Commis on only if those changeswould not adversely affect the ability to hieve and maintain safeshutdown in the event of a fire.The licensee may alter specific features of the pproved program provided(a) such changes do not otherwise involve a ch ge in a license conditionor technical specification or result in an u eviewed safety question(see 10 CFR 50.59), and (b) such changes do ot result in failure tocomplete the fire protection program as a roved by the Commission. Aswith other changes implemented under 10 R 50.59, the licensee shallmaintain, in auditable form, a current ecord of all such changes,including an analysis of the effects the change on the fire protectionprogram, and shall make such records available to NRC inspectors uponrequest. All changes to the approved program shall be reported annuallyto the Director of the Office of clear Reactor Regulation, along withthe FSAR revisions required by 1 CFR 50.71(e).Temporary changes to specific ire protection features which may be neces-sary to accomplish maintenance or modifications are acceptable providedinterim compensatory measur s are implemented.At the same time the lic see may request an amendment to delete the technicalspecifications that wil now be unnecessary.Inclusion of the fir protection program in the FSAR will be a prerequisitefor licensing for a now under review. The standard license condition willbe included in ne licenses.
Sincerely,Harold R. Denton, DirectorOffice of Nuclear Reactor RegulationEnclosu es:1. Int pretations of Appendix R2. A endix R Questions and Answsers3. ire Protection License Condition*se previous concurrenceDB :PD#1 DBL:P DBL:PD#1 D:DBL DD:NRR D:NRRCmerson J :tm JZwolinski RBernero DEisenhut //enton/ /86- 4 '6 / /86 / /86 / /86 / /86