ML20148P173

Advises of Provisions of 10CFR50,App R,That Are Applicable to Fire Protection Features of Facility.Fr Notice & Summary of Staff Requirements to Resolve Open Items Encl

ML20148P173
Person / Time
Site:	Pilgrim
Issue date:	11/24/1980
From:	Eisenhut D Office of Nuclear Reactor Regulation
To:	BOSTON EDISON CO.
References
NUDOCS 8101130139
Download: ML20148P173 (4)

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f UNITED STATES , i

!% .- < { i NUCLEAR REGULATORY COMMISSION WASmGTON. D. C. 2u!55

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November 24, 1980

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Docket No. 50-293 Plant Name: Pilgrim Nuclear Power Station 4 TO ALL POWER REACTOR LICENSEES WITH PLANTS LICENSED PRIOR TO JANUARY 1,1979 i The Conmission published on November 19,1980 (45 FR 76602), a revised I Section 10 CFR 50.48 and a new Appendix R to 10 CFR 50 regarding fire protection features of nuclear nower plants. The revised Section 60.48 '

and Appendix R will become effe'ctive February 17, 1981, which is 90 days after publication. A copy of the Federal Register Notice is enclosed  ;

(Enclosure 1).

The provisions of Appendix R that are applicable to the fire protection f eatures of your f acility can be df vided into two catego-f es. The first category con:ists of those provisions of the Appendix that are required ,

to be backfit in their entirety by the new rule, regardless of whether or not alternatives to the specific requirements of these Sections have been  :

previously approved by the NRC staff. These requirements are set forth t in Sections III.G, Fire Pretection of Safe Shutdown Capnoility; III-J,  ;

Emergency Lighting; and 111-0, Oil Collection Systems for Reactor Coolant  ;

Pump. The fire protection features of your facility must satisfy the  ;

specific requirements of *.hese three Sections by the dates established  :

by Paragraph 50.48(c), unless an exemption from the Appendix R requirements  ;

it approved by the Commission. You should note the provisions for tolling  :

the time for conpleting the modifications required by these three Sections  !

of Appendix R set forth in Paragraph 50.48(c)(6). l The second category of Ap ndix R provisions applicable to the fire protection [

f eatures of your f acility consists of requirements concerning the "open" items t of previous NRC staff fire protection reviews of your facility. An open  !

item is defined as a fire protection feature that has not been previously approved by the NRC staff as satisfying the provisions of Appendix A to i Branch Technical Position BTP PCSB 9.5-1, as reflected in a staff fire -

oratection saf ety evaluation report. The fire protection features of your '

f acility that are in this category must satisfy the specific requirements of j Appendix R by the dates established by Paragraph 50.48(c), unless an exemp-tion from the Appendix R requirements on those features is approved by the C ocmi s s ion. (

i Enclosure 2 is a summary listing of tne open items concerning the fire s protection features of your f acility based on a review of our records. Also  !

included is Luc position on the specific requirements that cust be satisfied in erder to resolve these open items. If you have any questions or disagree-ments with this enclosure, please advise us within 30 days of your receipt of l this letter. [

THIS DOCUMENT CONTAINS  ;

8103?30 k, POOR QUAUTY PAGES l i

., .. 1 1

1 November 24, 1980 i

I With regard to the fire protection modifications that have been previously approved by the NRC staff, Paragraph 50.48(d) specifies a new schedul.e for their co@letion. This paragraph, when it becomes effective, will supersede .

the currently effective section of the regulations that temporarily suspends co@letion dates for previously approved fire protection modifications that ,

are given in facility license conditions (45 FR 71569, October 29,1980). ..

The Comission expects that all such modifications will be co@leted in accordance with this new schedule, unless an extension has been requested and granted by the Director of the Office of Nuclear Reactor Regulation

[see Paragraph 50.48(d)], or an exegtion has been requested and granted by the Comission pursuant to Section 50.12 cf the Comission's regulations.

If you have previously requested extensions of dates for completion of modifications that are required by license conditions for your facility ,

which were not approved, and you have determined that these extensions are j still necessary and justifiable, it will be necessary for you to reapply for any such extensions in accordance with the provisions of Paragr aph 50.48(d),

i All requests for Comission action resulting f rom this rule are subject 1 to the schedule of fees specified in 10 CFR 170.21. If you have any questions concerning the subject matters of this letter, please contact the NRC Project Manager for your facility.

Sincerely,

u. M k f ik--

Darrell G. Eisenhut, Director

[ Division of Licensing  !

Office of Nuclear Reactor Regulation

Enclosures:

l

1. Notice - Fire Protection l Rule

2. Summary of Staff Require-ments to Resolve Open Items cc w/ enclosures: I See next page l

Mr. A. Victor Morisi Boston Edison Company Novsaber 24, 1980 cc:

Mr. Richard D. Machon Pilgrim Station Manager Boston Edison Company RFD #1, Rocky Hill Road Plymouth, Massachusetts 02360 Henry Herrmann, Esquire Massachusetts Wildlife Federation 151 Tremont Street Boston, Massachusetts .02111 Plymouth Public Library North Street Plymouth, Massachusetts 02360 Resident Inspector c/o V. S. NRC P. O. Box 867 Plymouth, Massachusetts 02360 e

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.g UNITED STATES y g g NUCLEAR REGULATORY COMMISSION g g (j j WASHINGTON, D. C. 20555 c <f I

November 25, 1980  !

l TO ALL POWER REACTOR LICENSEES WITH PLANTS LICENSED PRIOR TO JANUARY 1,1979 l

The Federal Register Notice enclosed with my letter dated November 24,19R0 has a typographical error in the effective date. The effective date should l be February 17, 1981. A correction will be published in the Federal Register in the near future.

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.g (/ Darrell G. Eisenhut. Director Division of Licensing

Enclosurc 1 ove e 19,1980 f

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Part 11 Nuclear Regulatory Commission.

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76602 Federal Register / Vol. 45. No. 225 / Wednesday, November 19.1980 / Ruies and Regula'iors NUCLEAR REGULATORY inat toe comment periou snould nave a > already set iortn in Genera; Design COMMISSION been estended. t.riterion 3 of t\ppenda A to 10 CFR The Commissbn does not agree.The Part 50 and m the NRC guidance 10 CFR Part 50 NRC has been developmg fire nrote:: tion documents These general provisions requirements since 1975. The NRC gave rise to a number of disputes over Fire Protection Program for Operating pubh:thed comprehensive fire protection whether specific rnethods adequately Nuclear Power Plants guidehnes. Hranch Technical Position accomphshed the intended goal. The ,

J AGENCv: Nuclear Regulatory HTP APCSU 9.5-1. and its Appendis A in pr> posed rule is intended to provide Commission, 1970. Licensees lave compared their fire sufficient specific guidance to ensure pm tion programs against these satisfactory resolution of these issues.

OCTION: Final rule. ,Rus reverting to generahzed guidance

• guidelines and have discussed their CUMMARY:The Nuclear Regulatory deviations from these guidelines with would not accomplish the intended Commission is amending its regulations the NRC staff for the past four years purpose of the proposed rule.

to require certain provisions for fire during the NRC) fire protection reviews The second issue involved some protection in operating nuclear power of operating reactors. A Safety instances in which the specific wording plants. This action is being taken to Evaluation deport and,in most cases, used resulted in unnecessary and upgrade fire protection at nuclear power supplements to the Safety Evaluation u,nintended restrictions. For example, plants licensed to operate prior to Report, have been issued 'for each ine proposed rule called for a " fresh lanuary 1,1979, by requiring resolution operating reactor. These reports water" supply. For firefighting purposes, of certain contested generic issues in describe fire protection alternatives that brackish water is satisfactory and a fire protection safety evaluation reports. have been proposed by the licensee and " fresh" water supply is unnecessary.

found acceptable by the staff as well as Similarly, the proposed rule called for EFFECTIVE DATE: February 19,1981.

unresolved fire protection issues an " underground yard fire ma a loop.

Note -The Nuclear Regulatory Of ten portions of a fire main loop run Commission has submitted this rule to remaining between the staff and the the Comptroller General for review as licensee. Proposed Appendix R provided above ground m, and as they enter the Commission's requirements for structures. The Commission had not may be appropriate uncler the Federal resolving those issues. Thus, it concerns intended to prohibit running portions of Reports Act, as amendi d (44 U.S.C.

only a limited number of issues derived H fire main loop above ground. Other 3512). The date on whic i the reporting .

from the use of the earlier guides. The smular changes are discussed in Section requirement of this rule becomes effective, unless advised to the contrary, Commission believes that a 30-day Ill. " Specific Requirements." of this comment period was adequate under preamble, reflects inclusion of the 45-day period that statute allows for such review (44 these circumstances. O.e third issue relates to imposition of reqmrements on plants with presently U.S.C. 3512(c)(2)). 2. Many licensees questioned the need inst lied or with existmg commitments FOR FURTHER INFORMATION CONTACT: for backfitting all the requirements of to install fire prote David P. Notley, Office of Standards Appendix R. They commented that they previ usly determm,ction featuresed by the Development, U.S. Nuclear Regulatory had previously complied with staff fire Commission. Washington, D C. 20555, protection recommendations in " good sajisfy the guidance of Appendix A to D'IP APCSD 9.5-1.The Commission phone 301-44b5921 or Robert L faith" and have committed to or g e t for three Fergunm , Office of Nuclear Reactor completed certain modifications. They !e t on h yees t at '

Regulation, U.S. Nuclear Regulatory contend that the staff has properly Appendix R should not be retroactively Commission, Washmgton, D.C. 20555, determined that these modifications applied to features that have been phone 301-492-7090. provide at least the level of fire previously approved by the NRC staff as CueeuMENTARY INFORMATION: On May protection described by the guidance satisfying the provisions of Appendix A 29.19au the Nuclear Regulatory contamed in Appendix A to Branch to BTP APCSB 9.5-1.

Commission published in the Federal Technical Position BTP APCSB 9.5-1. The NRC staff had intended,in its Register (45 FR 30082) a notice of They also contend that these oiiginal proposal for Appendix R, that proposed rulemaking inviting written modifications provide a level of the requirements be applicable only for suggestions or comments on the protection at least eq ,ivalen' to that the resolution of unresolved disputed proposed rule by June 30,1980. The contamed in the proposed rult They fire protection featurcs. Thus, the staff notice concerned proposed amendments express the concern that the proposed had not intended the provisions of to 10 CFR Part 50, " Domestic Licensing rule was written in such specific Appendix R to require modi 3 cation of of Production and Utilization Facilities," language that fire protection issues that previously approved batures. This was which would require certain minimum were thought closed would be reopened not clearly described in the proposed provisions for fire protection in nuclear and new, but not necessarily better- rule as published for comment. in fact, power plants operating prior to January modifications would be required. These the supplementary information ,

modifications could be accomplished i 1,1979. Fifty-one comment letters were published with the proposed arule received regarding the proposed only by the expenditure of considerable explic tly indicated that "{alli licensees

• amendments. A number of comments engineering, design, and construction will be expected to meet the pertained to specific requirements in the effort and at great undue expense. The requirements of this rule. in its effective commenters request that the #

proposed Appendix R, and these will be form, including whatever changes result dealt with below. However, there were requirements in the proposed rule be from pubhc comments.' t 3 three substantive contentions which rewritten to specify only the general In determining whether the specific were raised by many of the commenters requirements of what needs to be requirements of Appendix R should be These three comments are summarized accomplished. imposed on licensees with presently i

as follows: These comments raise three related installed or existing commitmentr to

! 1. Most commenters stated that the 30 inues. The first relates to the need for install fire protection features previously l day comment period was too short to specific requirements. The general determined to satisfy Appendix A to permit adequate detailed response and requirements relating to fire protection Branch Technical Position BTP APCSD

Federal Resister i Vol. 45. No. 225 / Wednesday. November 19, 1980 / Rules and Regulations 76tm 9 5-1. It in Important to rvognlze that arrangements were accepted in some permitted either an oil collection system Appendix R eddresses only a portion of early fire protection reviews. As a result or a fire suppression s3 dem.The staff the specific Dems contained in the me.e of some separate effects tests, the staff has also accepted an automatic fire comprehensive document. Branch changed its position on this suppression system us an acceptable Technical Position BTP A:-CSB 951 configuration, and subsequent plans method of fire protection for this and its Appendix A. Appendix A to bTT have been required to provide application. The Cornmission has APCSD 9.5-1 has been the basic fire additional orotect!an m the form of fire concluded that fire suppression systems

- protection gudance used by the staffin barriers or' substantial physical do not give adequate protection for fires their f;ro protection reviews conducted separation for safe shutdown systems. that may be induced by seismic events.

for all operating plants during the past M. credit for such coatings as fire The Commission therefore believes that several years. For many plants, barriers is allowed by Section ll!.G of previously approved suppression

' evstems should be replaced with nil licensees prcposed systems and features Appendix R. Appendix A to Branch that satisfactorily achieveu the fire Technical Position BTP APCSB 9.5.1 and diection systems that can with isnd protection criteria set forth in Appendix the proposed %pendix R recognized seismic events.

A to BTP APCSB 9 54 and began to that there were plant unique The technical basis on which thesie promptly implement such features and configuratiou that requ ad fire three sections ate based are furtt.er systems. protection features that are not identical discussed in Section 111. " Specific Satisfactory features and systems are to those listed in Section Ill.G of Requirements." of 'his preamble.

already in place and in operation in Appendix R. For these cases, fire 3. Most commenters stated th.t the many plants. There is a reasonable protection features were developed by implementation schedule contained in degree of uniform!ty among most of the licensee and described in a fire the proposed rule is impossible to meet these approved features for all facilities hazards ana.ysis. Some of these for any of the operating fants.The sir.ce they were reviewed against the arrangements were accepted by the staff commenters further stated that if the same criteria of Appendix A to BTP as providing equivalent protection to the implementation schedule in the effective APCSB 9.5-1. In general, the features requirements of Section ill.G to rule is the same as that in the proposed previously approved by the NRC staffin Appendix R. rule, the Commission must be prepared its reviews of fire protection using the Requirements that account for all of t either shutdown each operating criteria of Appendix A to BTp APCSB the parameters that are important to fire nuclear power plant. or process 9 5-1 provide an equivalent level of fire protection and consistent with safety '**{pg. ong e9 ent' 'rs

!sthen concluded that protection safety to that provided under requirements for all plant unique the specific provisions of Appendix R. configurations have not been devel.oped. the imolementation schedule should be Thus, the further benefit that might be "

In light of the experience gained in fire l$ance, e pro o drule provided by requiring that previously protection evaluations over the past four p h7 comfl f approved features be modified to years, the Commission believes that the conform to the specific language set licensees should reexamine those

[ao 1i tions id ntifIe b he staff as forth in Appendix R is outweighed by necessary to satisfy Criterion 3 of previously approved configurations of tha overall benefit of the early Appendix A to th!s part, whether fire protc tion that do not meet the contained in Appendix R to this part or implementation of such previously requirements as specified in Section in other staff fire protection guidance approved features which in many cases lit,C to Appendix R. Based on this (except for alternate or dedicated are currently being installed.. reexamination the licensee must either shutdown capability) shall be completed Nevertheiess. as a result of.its meet the requirements of Section !!!.G of by November 1.1980 unless, for good continuing review of fire protection Appendix R or apply for an exemption c0use shown, the Cemmission approves matters, the NRC staff has indicated to that justifies alternatives by a fire an extension." (proposed paragranh the Commission that there are hazard analysis. However, based on requirements in threu ections in which present information, the Commission 50.481.(c)). The Commission went on to state its intention in the Statement of the protection afforded by Appendix R does not expect to be able to approve Consideration to the rule that " . . no over and above that previously exemptions for fire retardant ccatings plant would be allowed to continue to accepted. may be desirable. The used as fire barriers, operate siter November 1,1980, or Commission has decided that these The second relates to emergency beyond an extended date approved by requ!rements should be retroactively lighting. Section I!!.J of Appendix R calls the Comission, unless all modifications applied to all facilities. This decision is for 8-hour emergency lighting, whereas (except for alternate or dedicated not meant to reflect adversely on n some cases less than 8-hour shutdown capability) have been previous licensee or staff evaluations; t9ergency lighting has been accepted as implemented."

rather its purpose is to take fully into sat. ,tyeg Appendix A to BTP ApCSB The Commission has reconsidered the account the increased knowledge and 9.5- While an adequate level of safety implementation schedule and has experience developed on fire protection may be provided by less than an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> determir.ed thet it should be modified matters over the last several years. supply, an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> system would provide for the following reasons:

The first of these sections is related to added protection and would generally

• After reviewing the comments and fire prot.ction features for ensuring that involve only a small cost. The the information developed as a result of systems and associated circuits used to Commission therefore believes that completion of rire reviews over the past achieve and maintain safe shutdown are licensees should upgrade the previously 8 months the staff has tidormed the i free from fire damage. Appendix A to approved facilities to satisfy the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Commission that the date of November DTp APCSB 9.51 permits a combination lighting requirement of Appendix R. 1.1980. is r.vt possible because the cf fire retardan, coatings and fire The third relates to protection against effective date of the rule will be after detection and supression systems fires in noninerted containments that date.

without specifying a phys! cal separation involving reactor coolant pump

• The staff has informed the distance to protection redundant lubrication oil (Section 111.0 of Commission that it would expect systems (Appendix A. D.1(2)), and such Appendix R). Th . proposed rule virtually alllicensees to request

76604 Federal Register / Vol, 45, No. 225 / Wednesday, November 19. 1980 / Rules and Regulations l exemptions if tN new implementation Section 111, we provide a summary of the automatic water suppression system dates do not p ovide an appropriate Technical Basis for each requirement, throughout the plant.

perid of timt for complying with the followed by a summary of the oblic An ensured minimum volume of water requirements of Appendix R.The time comments and a statement of qe staff's is set aside and dedicated for fire and manpower resources needed by the disposition of those comments, protection uses to be available at all hcensees to prepare such requests and times regardless of other simultaneous

'Section I. /ntroduction and Scope by the staff to formulate water ures in the plant. T his water ,

recommendations on these requests is This section has been revised as a volume is dedicated for fire service by not warranted from the shnc; oint of result of comments to inch de a means of separate storage tanks or timely fire protection improvement. discussion of the importance of safe separate pmp suctions from a large

= The revised irrplementation shutdown capability and the distinction body of we ter. When common tankage ,

schedub provides a careful balance of between requirements for " safety- is employed for b service needs and these considerations, calling for the related" equipment and equipment other water services, the fW pump remair,ing fire protection modifications needed for " safe shutdown." suctions must be at the bottorr. of the to be implemented and installed on " tank and other water supp!v e actions Section H. General Requirements phased schedule that is as prompt as must be located at a higher !cvel to can be reasonably achieved, This section has been substantial ly ensure that the minimum dedicated The revised schedules distinguish rewritten a. a result of comments to water volume is set aside for fire between requirements imposed for the provide a concis, summary of general protection needs. Administrative first time on the licensee by Appendix R requirements. The specific requiremen;s controls by themselves, such as locked and those requirements already imposed were consolidated mth the appropriate valves to ensure adequate water supply in license conditions or TecFnical parts of Section 111. " Specific for fire fighting needs, are deemed Specifications issued prior to the Requirements." except that the credit unacceptable at nuclear power plants.

effective date of the rule. For given for 50-foot separation has been dropped. Comment Resc/ution requirements imposed by Appendix R, including the items "backfit" to all Section ///. Specific Reqwrements Many commenters stated that we plants, 'he schedule provides a were being too restrictive by stipulating reasonab!c time after publication of the The requirements .m this rule are an underground yard fire main loop and rule for completion of required based upo. principles long accepted fre a ws ., . uoplies. Our intent was modifications. For requiretants already within that portion of American industry only that a yard fire main loop be imposed by license conditions providing that has been classified by their . furnished. We have deleted the for implemention after November 1, insurance carriers as " Improved Risk" specification for an underground loop 1980, the Commission has reviewed or "llighly Protected Risk". In each of since special conditions may dictate that these cases, the Commission has part of the loop be above ground or these schedules and has found that in some instances the allotted time for decided that the overallinterest of inside safety.related buildings. Such completion of the required modificat:ons public safety is best served by arrangements are acceptable, may be excessive. Thus, for fire establishing some conservative level of With regard to the specification for a protection features other than those fire protection and ensuring thet level of fresh water supply, the staff was covered by Appendix R, although the Conipliance exists at all plants. The attempting to avoid potential plant Commission has extended the following is a list of the specific problems that are not associated with compbance dates beyond the ilovember technical cases and resolution of public fire protection. From a fire protection 1,1980, date in the proposed rule, the comments for each of the specific standpoint, salt or brackish water is Commission has added a requirement requirements in Appendix R. acceptable for fire suppression provided that limits the compliance schedule in A. Water Supplies for Fire the fire protection system is designed existing licenses if such schedules Suppression Systems TechnicalBasis. and maintained for salt or brackish extend beyond what we now believe One of the basic fire protection water The requirement for fresh water should have been a reasonable schedule requiremeats for a modern industrial supplies is therefore dropped. Other initially. Relief from such limitation may site in the United States is a separate operational problems unrelated to fire be granted by the Director of Nuclear water distribution system for fire protection that may result from the use Reactor Regulation upon a showing that protection with dual water supplies- of salt or brackish water for fire there is good cause for extending st.ch Duphcate water sun dies are required to suppression activities are outside the date and that public health and safety is ensure uninterrupted fire suppression scope of this regulation.

not udversely affected by such capability allowing for single failures Several commenters took issue with extension. and periodic maintenance and repair of the requirement for two separate It should also be noted that for vital portions of the systems. Duplicate redundant suctions, stating that some licensees whose license conditions water supplies may consist of separate plais we a single large intake structure l imposed a schedule with a compliance suctions for fire pumps from a large on a lake or a river for all water date of November 1, tomi, or other date body of water such as lake, river, or requiren.ents. The requirement for prior to the effective date of i 50 48, the pond or from two water storage tanks. separate inta,ke structures was not

• Commission has suspended such I'or nuclear power plants, the intended and the rule has been clarified.

compliance dates by promulgating ou distnbution system is required to consist Seveal comments called for deleting October 29, wao, a temporary rule of a loop around the plant with suitable the requirements for riedicated tanks or '

i 50.B (45 FR 71509), which will be valves for isolating portions of the use of "ertical standpipe for other water superseded by this rule. system for maintenance or repair services when storage tanks are used for To better uaderstand the nature of the without interrupting the water supply to combined service water / fire-water uses, public comments received and the staff's the various fire suppression systems in on the bacis that this is overly restrictive resolution of these coaments, the the plant.Thus, with dual supplies and a and other ways are available to ensure following section will consider each , loop concept. an adequate water supply a dedicated supply such as weirs.

section of Appendix R to this part, fa can be ensured to each manual or suction location, etc. Two separate but

i Federal Rgister / Vd 45, No. 225 / Wednesday, November p m / Rules and Regulations 76605 l

I related issua are involved here. The hour water supply is considered by a visually indicattnr nr bygmated first is the requirement for dedicated adequate. it should also be noted that (carb; vnive," and there was an water storage tanks for fire fighting this minimum dedicated water volume is opprtusty to comment on this purposes. The suggestien that the based on maximum flow rates. Since docu; ieno requirement for dedicated tanks be most fires are controlled and D. Manua/ Fire Suppr~ ssion Techeocal delehtd was rejected for the reasons extinguished with much smaller flow Basis. Considerable reliance is placed l '

ctated in the preceding Technical Basis, rates, this requirement realistically on automatic fire suppression systems I The other point deals with ensuring represents a dedicated water volume far tic m shout a nuclear power plant.

, rainimum water storage capacity for fire in excess of two hours. How ever, manual fire fighting adivities suppression activities when storage D. Sectionallso/ation Valves. often can control and extinguish slowly 9 tanks are used for combined service. C. Hydrant Isolation Valves developing fires before an automatic fire water / fire water uses.The term TechnicalBasis. These two suppression eystem is actuated. In

" vertical standpipe for other water requirements are similar and can be addition. fires that are controlled or service" simply mm.s that the suction treated together. Proper valving is extinguished by automatic systems for Lther water uws in common storage required to isolate portions of the water require a certain amount of rn :nual tanks will be located sufficiently Hgh to distribution system for maintenance or response. Also, some areas of the plan

• ensure the minimum water volume repair without interrupting the water do not warrent the installation of needs for fire wpprission activi'ies. If supply to manual or automatic fire automatic fire suppressien systems.

the commenters were soumire. that suppression systems inside the plant. Manual response is the only fire

" vertical standpipe" refeired niy to Valves are similarly required to permit suppression available for these areas:

pipes inside the tank. this 3 ,ot the is lation of outside yard hydrants from thus, it is important that manual fire case. In fact a standpipe er.crior to the the water distribution system for fighting capabili+v be present in all storage tank is more desinble since any maintenance or repair without areas of the plant, and that standpipe leakage would be immer'.ately evident. interrupting water supply to fire and hose stations be located throughout On an internal standpipe a leak in the suppression systems inside the plant. the plant. The standpipe and hose pipe could actually allow depletion of Visually indicating valves such as post stations are to be located so that at least the water otherwise to be reserved for indicator valves are preferred so that one effective hose stream can be fire uses. The rule has been clattfled to the position of the valve ca t be readily brought to bear at any location in the allow physical alternatives for water datermined. However, key operated plant containing or presenting a hszard ly dedication but to preclude valves (commonly known as curb to structu.es, systrms, or components supbusive use of administrative controla valves) are acceptable for these exc n aportant to safety.They are to be for this purpose. p s c

[p' d a arn 9 applied from the fire water supply Sorne commenters objected to the system except for those inalde requiremot that other water systems B. Section Control Valves-Comment Re2olution. Many commenters stated containment, which may be connected used as a backup water supply for fire tc, other reliable water supplies if a that the requirement for Mpproved protection should be permanently visually indicating" sectional control separete penetration into containment connected to the fire rt.em eystem und valves was overly restrictive, cannot be made for fire water service suggested that it would be aufficient t needs.

unnecessary, and not specific with provide a water supply capable of being respect to who should give the approval. Comment Resolution connected to the fire main system within The Commission has accepted this ten minutes of the loss of normal wale' suggestion: the rule now requires that Several commenters suggested adding cupply or pumps. The rule does not a sentence reading Standpipe and hose sectional control valves shall be address backup water supplies. The provided to isolate portions of the fire stations are not required if suff!clent requirement means that,if anMher main for maintenance or repair without fu.dfication can be provided tha'

' water system is used as one of the shutting off the entire system. Post adequate fire protection features have '

redundant water supplies,it must satisfy indicator or key operated valves are been provided to account for a given fire allof the requirements of the fire mentioned as two examples of area." This suggestion was rejected. The protection water supplies. Additional acceptable valves. staff has taken the position that the backup supplies need not meet these C. Hydrant Block Valves-Comment minimum requirements are that at least requirements. one effective hose stream that will be Resolution. A number of commenters One commenter asked why only a made suggestions for rewording this able to reach any location that contains two hour water supply is required when section. This section has been clarified or could present an exposure fire hazard i the Drowns Ferry Fire lasted well over to state the requirement for capability to to the safety related equipment.The i two hours. All of the investigations of isolate hydrants from the fire main Commission concluded that no analyses the Browns Ferry Fire clearly show that without disrupting the water supply to can identify hazards so carefully that if water had been used immediately, the automatic or manual fire suppression this minimum requirement can be fire would have been extinguished much systems in any area containing or further reduced.

, earlier. Indeed once the manual fire presenting a fire hazard to safety related E. Hydrostatic Hose Test Technical fighting activities were started with the or safe shutdown equipment. Basis. Fire hoses should be uce of only one fire hose stream, the fire One commenter suggested that this hydrostatically tested periodically to was extinguished within one half hour. requirement be dropped in its entitiety ensure that they will not rupture during The staff would find unacceptable any since it "is a new requirement which has use. The requirement for a minimum test condition in which a postulated fire that not been subjected to the peer review pressure of 300 pal comes from NFPA could threaten safe shutdown capability process." This suggestion was rejected No.196 (National Fire Protection could not be controlled and extinguished ,n the basis that Appendix A to BTP Association Standard No.196-within two hours with any combination APCSB 9.5-1 contains the following Standard for Fire Hose), a nationally of manual and automatic fire sentence:"The lateral to each hydrant recognized consensus standard.This suppression activities. Therefore, a two- from the yard main should be controlled standard contains other guidance for the

76fiO6 Federal Register Vol 45. No. 225 ! Wednesday. Nm ember 19 19Hh Ruh s and Regn. buns use and care of hre ho . that most systen .n all suc h areas should be 1. Em B.wle 7,umne Tm % :u/

industrms hnd uwetul. re'ained The fue hazards unah m may na3 , Most modern mdustne. plants call for a separate suppression system a uh rept.u ement cost value Comment ResoluDon approachmg thuse of a moo ;rn nuclear but this would be m addition to the hre Many comrnenters pomted out the 'h tect " W "" pow ned e'iec tnc generatmg station bas e erroneous usage of the term Ners it E ," " ' " """ " "4"'EE"U fi'"

pressure" rather than " operating -" " N"" #" * "[" a lhe"#'.^ * " department incluchng motorized fire pressure" m this requirement. The W e em n of safe app m atut ause of th > reduced intended m"aning for this requirement is shutdewn capab.ht) is to ensure that at ses enty of fue hazards m a nuclear that all hoses would be tested at a a one means o achiesing and generatmg station as compared to a pressure greater than the maumum rn nta ning sa e shutdown condinons manufacturing plant. the Commission g pressure found in the fire protectior, wiU remain a ada e dunng and aber behesee that it is not necessary to water distnbution systems. The correct any pos m plant cause manc a staUn e depatnent termmologs is "operatmg pressure. The a b not ponible to predict the specific flowever. manual D e response rule has been so changed. In adddie,' con ons under which hres rnay occur capabihty is required at a nuclear plant the staff added a specific minimam test " " "E "4* EW " "

pressure requirement of 3h0 psi to meet

"" E " E"*"'"' " "E" """ trained fire hrigade will satisfy this protechse features are specified ra,her the NFpA standard an the design basis fire. Three need. The C,ommission has determined One commenor also pointed ota that Mnent rneans for proh'chng Hu safe War o briude of five oersons constitutes hoses should be inspected for mildew. shuMown capaMay outsMe of We nuninmm sue sufhmn' to pufonn rot. cuts. or other damage. Although this con tain ent are acceptable. The first the actions that may be required by the is a valid comment. it is not an brigade iiurmg the hre and to proude

• """8 I" "E"'" h"" "I "'d unda n t sa fe unresolved issue with any hcensee so it shutdown trains and r;actated circmts some margin for unanticipated esents>

need not be covered by this rule. In Sunda4 the trainig requirenurnts addition. such inspections are alreadv bv nwans of %our hn rated barrins.

.lhe second means is a combination of bsted are considered the minimum being performed in accordance with the' needed to ensure that the fire brigade separation of redundant safe shutdown plant's Techmcal Specificanons trains and associated circuits by a 1 wdi be able to function effectively F. Automatic Are Detection Techmco/ hour fire rated barrier and automatic ' ire durmg a fire emergency.

hosts. The requirement that automauc ,Ihe proposed rule required emergency suppression and detection capability for fire detection systems be installad in all both redundant trains.The third n.eans, breathing apparatus without specifymg areas that contain safe shutdown or !he number of such pieces of apparatus.

which may be used only when safety relat 'd sistems or components ,

l}e rule has been modified to specify fol lows gentr.dly accepted fue rodundant trains and associated circuits the personnel for whom such apparatus are separated by 20 feet or more of clear protechon prachce. Installation of such is to be provided and to specify reserve fire detection capability is independent spam reginres automahc fn air requirements.

of any requirements for automatic or suppren on and detection systems m 11. hre Brigade-C,omment manual fire suppression capabihtv in an the area. At ahernatiee or dedicated N"olutum. Many comn, enters suggested

~

area.The purpose of these detection safe shutdown capability independent of changing this requirement ta a simple systems is to give early warning of fire the hre area is twuired if fire protection statNnent that a 'rmned and equipped.

condit!ons in an area so that the bre for safe shutdown capability cannc.i be nominal size. site fire brigade of five brigade can initiate prompt actions to prcwided as outlined above. For cables pusons be provided on each shift unless minimite fire damage withm the plant. and equiprnent treded for safe a kssa number is justified. This shutdown located inside of noninerted recommended change was rejected by C,omment Reso/ution containments, a lesser degree of fire the Con 1 mission for the reasons stated Many commenters suggested that the protechan is permitted because m the ltrhnical Basis, words " automatic fire detection transient exposure fires are less likely me UmnmentNs obkctm, to the capability" he substituted for inside containment during plant eu usio, of the shif t supers sor from

' automatic fire detection systems" on operation Section Hl.M. Tire Barriers / gade. Me commenters felt the basis that. as worded, the discusses the technical basis for the 3 at e Muh supensor should go to the requirements are too limiting They hour barrier, and Section litL an provide the bmnefit of bia stated that an automatic sprinkler' " Alternative and Dedicated Shutdown apMtu>e and authon$ b rule would system with appropriate alarm c heck Capab:hty." discusses the technical not pn;u ni this. However. the shift vals es and ( entral alarm features basis for safe shutdown capabihty' -

supansor rnay have to go elsewhere prosides acceptable detechon/alarnung , omen nt Ruon,itum dunng the muse of a fire that adwrsely capabibty Several conunenters claimed aHN P ant opnahon. u: fue brigade that a s"parate detectmn system n, not Many commenters suggested that the 'r must stay with the fire brigade needed in areas cosered b) sprinkler first paragraph be changed shghtly and ~ anc ie a gned no othm systems equy ped with fusible hnk the rest of this section deieted. The "" "# " b "' """2""CF '

sprinkler heads A fusible hnk has a basis for their contention is that the rule therefore. the shif t superusor must be ,

time Jelo before it actuates lloweser. should state simply the reqmrement to u mm membership on the hre protect caF :s or equipment of ss stems more importantly a smoldering locabzed bre that could do damage mas necessars tar safe shutdown of the plant (Y9"' " ."" . """"'

and leave specific implementation not generate enough heat to melt the ' f um an mmmentes have fusible lino While we do nol disagree details m some other type of document that the alarm from an automatic fire We have modihed this sechon by ' N n abea .a lenx.h m ihe NRc siafr.

suppression sistem serves as remnving the hsting of consideratu$ns, haauon of hmom bre nnaaae shin sue notibcation that a fue custs. we deletmg Table 1. and revismg the d "ed I "w 3 w" ( orn are milaNe from un ur

" N"'* """ "' * "d"as omt,meni u s conclud"d that the mmimum wording to provide clarificahon. "'"""" ""' "h # N'"" U C' requirement [or a Beparate [ Ire detechon l{. Nre Orgade, jj

Federal Register / Vol. 45 Nrt 225 / Wednesday, November 19, 1980 / Rules and Regulations 76807 stated St NRC used unnecessary detah fire emergenc> and operators invnive? modifications tu proude ulternatne in spelhng out specific requirements for in safe plant shutdown should not also shutdown eystems are extensive. ti classroom mstruction. fire fighting have to be concerned with lightmg in the dedicated system that is essentia!!y a procrice and fire drills. Some ' area. The small cost differential minimum capabihty safe shutdown train commenters felt that these requirements between 2. hour supply and the and is independent of those alread>

5 *ere more detailed then anythin the substantial additional protection existing may be provided.This minimum

. Commtssion has published wit!. re gard afforded by the 8. hour supply does not capability is required to maintain the to operator training. The Com ~'ision warrant reducing this requirement. The process variabtea within those values here points out that most of the Commission has decided to require an 8 pvr'icted for a loss of offsite power.The investigations of the TMI accident hour battery power supply in all areas case of loss of offsite power is assumed

1. identified inadequately trained needed for operation of safe shutdown 'oecause fires in certaM circurnstances operators as an important factor and equipment and in access and egress (e g., electrical distrlbution system <)

that work is now being done in this routes, could cause or be related to such a lov.

area. The fact is not that the training K. Administrative Controis Technical Fire damage to cold shutdown capability requirements spelled out here for the fire Posts. The fire protection program uses a 4mited to damage that can be brigade members are excessive when administrative controls for fire repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to provide a campared to tralning requirements for prevention and preflre planning. The tr.crgin in r:hiwing cold shutdown reactor operators, but that fire brigade items listed in this section are generally conditions. Consideration is given to training is further along in development. accepted within the fire protection ascociated circuits because most plants and training parameters that are community as minin um requirements were not designed with this concept in essential to a comprehensive program for an effective administration of the fire mind. Should either the alternative or have been identified. protection program. Coatrols are placed dedicated capability be required to J. Emergency Lighting Technical on the storage and use of combustible function because of a fire. It must not be Basis. Emergency lighting is required in materials to reduce the fire loading in disabled by fire damage to associated 1 all nuclear power plants. Battery- safety related areas and on ignition circuits. Also, this capab'lity does tot I powered lights with capacities of1% to sources to avoid careless operations, have to meet the single failure criterion 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is usually sufficient for Procedures are used to control actions because it is only one of seve:a! levels emergency egress. However, the postfire to be taken by individuals who discover of defense. Seismic l's ter,ory I criteria is emergency lighting requirements in a a fire and by the fire brigade for the not imposed because i.rss that svould nuclear power plant are of a different development of preplanned fire fighting require the installatie of alternative or kind. The need is for lighting that aids strategies and actual fire fighting dedicated shutdown capabihty are not l the access to equipment and techniques. seismically induced.  !

op ra e by a t perso n 1 o ff ct omment eso uuon Comment Resoludon safeplant shutdown during plant Many commenters stated that this Many of the commenters stated tnat i emergencies. Because such activities requirement was much too detailed for a this requirement exceeded the scope of may extend over a considerable period regulation. Some stated that the Appendix R by defining alternative of time both during rnd after the fire,it requirements should apply only to those shutdown requirements. They stated is prudent to provide 8. hour battery areas havind safe shutdown equipment, that the time requirements are excessive emergency lighting capability to allow Other commenters stated that a simple and should be dropped. They also sufficient time for normal lighting to be statement that administrative contend that this regulation does not restored with a margin for unanticipated procedures should be established to take into account the many plant events, control the various fire hazards reviews being conducted under the throughout the plant was sufficient, and Systematic Evaluation Program (SEp).

Comment Resolution that the details could be spelled out in a It is generally understood that co'd Many commenters stated that the regulatory guide or some other similar shutdown is the ultimate safe shutdown requirement for emergency lighting is document, condition and that, for each fire area, overly restrictive in three specifics. first, Minor changes have been made in the different means may be used and may that emergency lighting is unnecessary wording of this requirement for be recessary to achieve cold shutdown.

In many of the designated areas; second, clarification. Because a fire in certain areas at some that the requirement for sealed beam or L Alternative andDedicated plants would have the capability of fluorescent units is overly restrictise; Shutdown Capability. disabling systems required to achieve third, that the requirement for individual Technical Basis. In some locations both hot and cold shutdown,it is 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery pcwer supply is (such as the cable spreading room) necessary to specify the minimum excessive. Three commenters within operating nuclear power plants it capability and tirne requirement for each recommended a 2. hour battery power is not always possible or practicable to condition necessary to achieve safe supoly; five commenters recommended a protect redundant safe shutdown shutdown. We agree that evaluations plant.specuic power supply; and one systems against adverse effects of fire or being made under the Systematic commenter recommended that there be fire suppression activities only through Evaluation Program (SEp) may also call no permanent installation, the use of fire prutection features for alternative or dedicated shutdown These suggestions have been accepted because the redundant safe shutdown capability for reasons other than fire

, in part. Lighting units with 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> systems in a given fire area are too clcse protection. For example, seismic, battery supplies are to be provided in all to each other. Alternative shutdown flooding or emergency core cooling areas needed for operation of safe capability has usually been required to requirements resulting from the SEP may chutdown equipment and in access and be independent of the control room, require add"lonal modifications. Each emess routes thereto. The reasoning cable spreading room, switchgear rooms licensee should be aware of the status of behind the requirement for an 8-hour and cable riser areas becausa redundant the SEP so that the requirements battery power supply is that there can systems in these areas are not resulting from SEP can be effectively be a great deal of other activity during a adequately separated. When pl' ant integrated with those relating to fire

76608 Federal Register / WL il No. 225 / Wedn .iday Nm ember 19. 1980 / Rules and Regut tions j protection lo the extent pos$ible required to chsJte sak shuldOWn the national consensus standard used flowever. the Commasion has decided capabihty. The use of a 1-hour barrier m for testmg and ralog these cable )

that the modd cations required to conjunction with automatic fire penetration soals. Since the cables  ;

complete the fire pr( tecimn program suppression and detectivu capabihty for conduct the heat through the barner.

Should not be deferred until the SEp each redundant train of safe shutdown and smce the cable insulation is review is completed. equipment is based on the following combustible the acceptance criteria of M. Are Barriers. consideraticns. Automatic suppression the ASTM Standard E-119 relating to .

Techmro/ /lons The best fire is required to ensure prompt, effective temperature on the imexposed side must protection for redundant trains of safe applicat'on of suppressant to a fire that be appropriately modified.

shutdown systems is separation by could endanger safe shutdown unpierced fire barn,ers--walls and commera Resolution e capability. The activation of an ceihng-floor assemblics. Ilecause these automatic fire detection or suppression Some commentern suggested that this barners are passive fire potection system does not occur until sufficient entire section be deleted and replaced features they are inherently reliable smoke or heat has been developed by with the following two sentences:

provided they are properly inste!!ed and the fire. Therefore, the Commission is " Penetration seals shall provide the maintained. Fire barriers have been requiring a 1. hour barrier to ensure that equivalent protection which is required used successfully for many years to fire damage will be limited to one train of the fire barrier. Evaluation of the subdivide large potential fire losses into until the fire is extinguished. penetration seals based upon a design smaller, mme acceptable nsks. Even fire These requirements have now been review and relevant test data or barriers with openmgs have successfully incorporated in Section Ill.G. " Fire qualification tests may be made." The interrupted the progress of many fires protection of Safety Functions.' commenters felt that sufficient test data provided the openings were properly are available to permit evaluation of C"** C"# N## I"U "

protected by fire doors or other design requirements without full-scale acceptable means. Several commenters made a number mockup testing and that many of the Fire barriers are " rated" for fire of suggestions of an editorial nature. items spelled out in the regulation, such resistance by being exposed to a One suggestion was to add "or unless as the water hose stream test, were too

" standard test fire". This standard test other fire protection features have been detailed and did not belong in the fire is defined by the American Society provided to ensure equivalent regulation.The Commission has for Testing and Materials in ASTN E- protection" in the first paragraph, where reconsidered this issue and revised the 119. "Sta.Jard for Fhe Resistance of three. hour rated fire barriers were rule to (a) require the use of fluilding Materials." Fire barriers are stipulated unless a lower rating was noncombustible materials only in the commonly rated as having a fire justified by the fire hazards analysis. construction of fire barrier pe,etration resistance of from 1 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Most The Commission feels that this adds seals. (b) require fire barrier penetration

" Improved Risk" or "llighly Protected nothing in the way of clarification and seals to be qualified by test; and (c)

Hisk"(as classified by insurance the suggestion was not adopted. The require such tests to satisfy certain carriersl industrial properties in the second paragraph requires that acceptance criteria.

linited Siales require tire barriers to structural steel forming a nart of or O. Fire Doors base a resistance mting of 2 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> supporting any fire barrier have a fire Technica/ Basis. Door openings in fire While a nuclear power plant has a resistance equivalent to that required of walls constitute another breach that low fire load, the potential the barrier. An example was given of must be protected. Fire doors that have consequences of fire are serious, metallath and plaster covering as being been tested and rated for certain fire Therefore. the Commission has selected one means of providing equivaient exposures are installed to protect these a hours has been as an acceptable protection. Several commenters stated openings. Fire doors frequently fail to minimum fire resistance rating for fire that they thought this was too narrow protect the openings in which they are barriers separating redundant trains for and would be interpreted by some installed because they are not fully safe shutdown systems. This will give people as the only acceptable method closed. Various methods are available to ample time for automatic and manual permitted. Since the example seemed to bcensees to ensure that fire doors are in fire suppression activities to control any be coafusing, a decision has been made proper operating condition and that they potential fire and for safe shutdown to ehminate it. Other comments to the will be closed during a fire. These activities to properly control the reactor. effect that the requirement was options are listed in Appendix R.

Many operating plants, or plants that excessis ely restrictive with regard to C"S**"'R*80l" hod are already built but that are not yet fire barrier penetrations. including fire operulin4 have both trains of safe doors and their associated frames and Many commenters stated that this shutdown equipment located in close hardware, and ventilation systems have requirement is too detailed and shou 3 proximity and a single fire could been acted upon by the staff and the be deleted. Minor editorial changes have damage or destroy the functional requirement, as it had affected these been made in order to more clearly state capabihty of both redundant trains. If items, was deleted. the iequirements.

specific plant cand tiuus preclude the N. Fire Barrier Cable Penetration Seal P. Reactor Coolant Pump Lubrication ,

t installation of a Moer fire barrier to Qualification. System.

l separate the redmint trains, a 1-hour Techmca/ Basis. Unpierced fire Technica/ Basis. Each reactor coolant fire burier and autemtic fire barriers offer the best protection for pump motor assembly typically contains a ippression system ior e ch redundant separating redundant trains of safety. 140 to 220 gallons of tube oil. Oil leaking ti iin wdl be coraidered the equivalent related or safe shutdown equipment. from some portions of the lube oil of thour barner flowes er, these barriers must be pierced system may come in contact with Il the 1. hour fire barrier and automatic for both control and power cables surfaces that are hot enough to ignite the fire suppressio, h r e ach redundant These penetrations must be sealed to oil The resulting fire could be large, and train cannot be provided because of achieve a degree of fire resistance access to the fire would be delayed plant-specific conditions, aMernative or equivalent to that required of the barrier because of the time required to enter the dedicated shutdowns capability will be that is pierced. ASTM Standard E-119 is containment. Containent rir temperature

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l Federal Register / Vol. 45. No. 225 / Wednesday, November 19. 1980 / Rules and Regulatiens 76609 1

L -- .- - - -

I would increase, set ere localized pump oil collection system is cm ered by Capabihty."lIn the fue hazards anaksis

' environments would develop in the area paragraph C.2 because its function is for a plant, the equipment rehed upon to 1 of the fire, and a large araount of smoke required to protect safety related perform both functions must be would be generated. These conditions systems rather than to perform a safety identified for each fire area. It follows could affect operability of safety related function. Because the failure of the oil that any associated non safety circuits equipment loside containment. collection system for a seisn.ically in the fire area that could adversely Therefore, an oil collection system is induced oil fire should not prevent a affect the identified shutaarn f

necessary to confine any oil discharged safety related system from performing equipment by feeding back potentiaily due to leadkage or failure of the its safety function (Regulatory Guide disabling conditions (e.g. hot shorts or lubrication system and to prevent it 1.29, " Seismic Design Classification " shorts to ground) to the power supphes from becoming a fire hazard by draining paragraph C.21. the oil collection system or control circuits of that equipment it to a safe location. These occurrences should be designed, engineered, and must also be evaluated.Of course such could be random or cocid be seismically installed so that its failure will not lead disabling conditions must be prevented induced because the existing Nbe oil to a fire affecting safety related to provide assurance that the identified system piping and oil collection systems equipment as a rt:sult of an earthquake.

The proposed rule perm:tted tw safe shutdown equipment wil10 nction may not be designed to withstand a as designed. These requiremenM have design basis seimic event, alternatives-an od collection s3 stem or i p s sse now been incorporated in Section !!!L AppenJix A to DTP APCSB 9.5-1 states 1 hat for operating plants, Qautoma ey " Alternative and Dedicated Shutdown Capability."

postulated fires or fire protection suPPrusion aYstem because system failures need not be considered unacceptable damage may result to the Comment Resolution concurrent with other plant accidents or safety.related systems from the burning Many commenters stated that this i Ih ,,

f oil before the suppression system is actuated and because the fire water requirement should be deleted because the a s or hat stater er t is o old. supply system is not designed to First, nuclear power plants are massive rr any older plant designs did not ,,

structures, and essential services are withstand seismic events. In addition, umsider associated circuits and this is, designed to withstand earthquakes and these pumps are located within the there2 ore, a new design requirement other natural phenom, a. Second, the biological sh' eld intnde containment, The commenters felt that the analyms history of many fires associated with therefore, timely fire brigade action that will be required to satisfy this recent carthquakes have been would be difficult if the suppression requirement will be both long and system malfunctions. Further,if the complico.,ed and the requirement should evaluated. These evaluations showed that such fires usually are due to failure suppression system becomes inoperable therefc.e ne deleted.

of piping or tanks of flammable gasses during operation, a fire watch or patrol The Cor<. mission rejected these or liquids such as municipal natural gas cann t enter the area during operation. suggestions for the following reasons.

distribution systems or gasoline storage Comment Resolution 1. Virtually all of the fiee protection and/or dispensing stations. Where such A number of comranters suggested modifications made to date have been potential fire hazards exist in nuclear required to correct deficiencies that that this section is too detailed and power plants (e g., hydrogen for should be substantially modified. Tnis resulted from lack of consideration of generator cooling, or oil fuel for the requirement was changed to delete the certain specific items during initial emergency diesel genertitor or station option of protecting the reactor coolant design and construction.

space heating boilers) they are designed pump lubrication system with an 2.The Browns Ferry fire showed the and installed to withstand the damaging automatic fire suppression system. We necessity of divisional separation of the effects of various natural phenomena, have modified the rule to indicate that associated circuit of the control cables and other special fire protection features the requirement that the oil collection to prevent the disabling of safety 4 are provided as necessary, flowever, system be designed to provide systems by a single fire. This las been General Design Criterion 2 Design Bases reasonable assurance that it will discussed with licensees during forProtection Against Natural withstand the Safe Shutdown Phenomena requires that structures. evaluations of alternative and dedicated Earthquake can be met by satisfying shutdown capability and is necessary to -

systems, and components important to paragraph C.2. of Regulatory Guide 1.29.

safety be designed to withstand the ensure that safe shutdown systems will

" Seismic Design Classification," as be able to function properly in the event effects of earthquakes without loss of described above.

capability to perform their safety of fire' Q. AssociatedCircuits.

function. Regulatory Guide 1.29, 7'echnical Basis. When considering 1 W stan consb hmph any fire hazard analysis that does not

" Seismic Design Classification." the consequences of a fire in a given fire describes an acceptable method for area during the evaluation of safe consider the effects of fire damage to identifying and classifying those shutdown capabilities of a plant, the circu,ts i that are associated with safe features of light. water-cooled nuclear staff must be able to conclude that one shutdowa systems.

power plants that should be designed to train of equipment that can be used As indicated above, as a result of the withstand the effects of the Safe immediately to bring the res.ctor to a hot comments received on this issue,it is Shutdown Earthquake. In this guide, shutdown condition remains unaffected unclear that associated circuits have in paragraph C.1 applies to systems that by that fire.The staff must also be able fact been adequately considered by

. are required to remain functional to to conclude that damage to one train of licensees in their reviews using the ensure heat removal capability; equipment used for achieving cold guidance of Appendix A to BTP ApCSB paragraph C.2 applies to systems that do shutdown will be limited so that the 9.5-1. To ensure that the associated not have to remain frunctional for that equipment can be returned to an circuits are considered, all operating purpose, but whose failure could reduce operable condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. (See nuclear power plants will be required to the functioning of those systems covered Technical Basis for Section Ill.C. meet the requirements of Section !!1.G of by paragraph C.1. The reactor coolant " Protection of Safe Shutdown Appendix R.

k _ _ _ _ _ _ _ _ . - _ - _ . . - . . _ . . _ - . - . , . . - , . . . . _ . . . , . _ , _..m ....s.-,_,,.om,,. , __m._,_-- _..._,-y,. m

76MO Federal Register / Vol. 45. No. 225 / Wednesday, November 19, 1980 / Rules and Regulationa Generu! Comments Resolution: shutdown capabihty. The Commission comments received on the proposed Several commenters contended that does ot agree. We believe that the regulations. other commenters Comnussion regubitions mandate that Commiscian's overall hre protection demonstrated a thorough understanding an adjudit atory hearing be conducted program invoMng ntensive plan - of the proposed requiremercs.

rior to a Imal decision. One commenter specific fire protection m dif cations Punuant to the Atomic Energy Act of abeled the regulation an " order" within that are based on guidance set forth in 19M. as artended, ihe E,nergy the meamng of the Admmistrative Branch Technical Position BTP APCSD Reorga nization Act of 1974. as amended.

9.5-1 and its Appendix A and the and Sections 552 and 553 of Title 5 of the Procedure Act (5 U.S.C. 551(6)) ( APAl United States Code, notice is herw by and asserted that 10 CFR 2.204 of the specific requirements of Appendix R to Commission's regulations, " Order for res Ive dispu'ed issues provide given that the followmg amendmers to Modification of 1.icense." applies to this adequate fire protection. Title 10. Chapter 1. Code of Federal ,

rulemaking proceeding. One commenter stated that the Regulations. Part 50. are published as a The Commission disagrees with these ambiguity of the proposed regulation document subtect to codification.

comments. A Sule"is defined in the with regard to critical items requires L A new i 50.48 is added to read as f Al'A to mean the whole or a part of an that it be renoticed. The commenter follows:

agency statem mt of general or referenced three portions of 'he partic'uIat appiicability and future eIfect prop sed Appendix R as examples of

, or They were Section !!!.G, (a) Each operating nuclear power designed to implement presr ibe law or policy , , (5U.SL,. Section Ill.N. and Section Ill.Q. We have plant shall have a fire protection plan reviewe these examples. that satisfies Criterion 3 of Appendix A 55t[41) 'Ibe agency action questioned to this part. This fire protec' ion plan here is clearly one inat treats similarly in reference to the first example, the commenter stated that the first shall describe the overall f.re protection situated boensees equally and that program for the facility, identify the prescribes future conduct or paragraph of Section III G identifies alternative shutdown capability as au various positions within the licensee's requinments. For those licensees who iM i Nture and that organization that are 4eaponsibile for the have not already provided an equivalent paragraph 111 G.2.c then identifies program, state the authorities that are les el of fire protection, certam specioc delegated to each of these positions to fire protection features are required. alternative shutdown capabihty as a j minimum fire protection feature. We do implement those responsibilities, and Varicas of these requirements would not agree with this statement.The first outline the plans for fire protection, fire apply to approximately 40 facilities. The commenter,a characterization of the rule paragraph of Section Ill.G identifies detection and suppression capability, l

as an order, along with the assertion alternative shutdswn capability ma one una limitation of fire damage. The plan l option in a combination of fir- shall also describe specific features

tha 10 CFR 2204 inandates a hearing protection features for a specific fire necessary to implement the program

) before the rule becomm Imal is described above, such as administrative area. paragraph !!I.GJ ndicates when incorrect. On its face, that regulation this option should be used. controls and personnel requirements for (which does grant a hearing right)

In reference to the second exampk fire prevention and manual fire apphes only to Commission orders that the commenter stated that Section Ill.N suppression ae ovities, automatic and modify a hcense 21t does not apply to requires a pressure differential across manually operated fire detection and reqmtements promulg.*d through a the test specimen during the testing of suppression systems, and the means to rulemaking action conducted in I re barrier penetration seals but fails to limit fire damage to structures, systems, accordance with the requirements of define the pressure d 4erential. This applicable law, or compon,nts important to safety so

t. ament is incoriect. The pressure that the capability to safely shut down bes eral commenters contended that differential called for by the proposed the environmentalimpact had not been the phnt is ensured.8 provision was the maximum pressure (b) Appendix R to this part establishes adequately addressed. One commenter, differential that the barrier would fire protectic,n features required to citmg the requirements in Section Ill.A experience in the specific plant of Appendix R for two water supphes satisfy Criterion 3 of Appendix A to this nstallation. In any event, the part with respect to certain generic and two nparate redundant sections as requirement for pressure differential issues for nuclear power plants licensed examples of roquirements mvolving during such testing has been deleted environmentu issues, contended that to operate prior to January 1.1979.

since only noncombustible material is Except for the requirements of Sections the Commission relied upon its staff's now being used for such seals. 111 G. Ill4 and 111.0, the provisions of

, unsupported determination that. In reference to the 'hird example, the Appendix R to this part shall not be pursuant to to CFR { 5t.5(d) an commenter stated that Sectmn Ill.Q is applicable to nuclear power plants enviromnental impact statement- totally lacking in definition. We do not appraisal. or negative declaration is not hcensed to operate prior to january 1.

agree. Footnote 6 references Regulatory w79. to the extent that fire protection required! the Lommission has Guide 1.75 and IEEE Std 384-1974 The features proposed or i.nplemented by considered Section til A and has further latter document is a commonly used considered the remaining requirements industry standard that dehnes h be prochon guidance for nudent power of Appendix R and renians convinced associated circuits and provides plants is contamed m two NRc documents that the regulations are not substantive guidance for ensuring that such circuits

• Hunch Technal Posthon Audhary Power and are insigotricant from the standpoint do not compromise the independence of cenmn % stem erar h ;rrP APCS 8 9 5-1.

or enuronmentalimpact. the shutdown circuits they are *""*""I"'F"**"'*"'"'N"*'P"*"

One commen'er suggested that all " '"

• associated with.

I plants be required to mstall dedicated Based on the above examples and our re"iew of the other provisions cf the NN3"$ "'" ^* ' t cuidehnes

. wpene A io sTp APcsn e 5 for hre Protechon for Nuclear Power Plants 81: should alm be noted int i 12t4 is cuddett in proposed rule, we dG not believe that Dohn) Nr ta july 1 19W for plants that were seui n of m uw ari 2 The ope of subpart a the rule as propoted was ambiguous so *"*""""""d""""'^*"dd***""'

is spenfa sth limned t 3 r ases mitiated by the staff constructmn tiefu e July 1.19m dated August 21

• 10 impme regernents by oder un a as to require renoticing Moreover. :i me brensee l10 0K 2 21sy my (F.mphasis eupphed j should be noted that, based on other Aiw see we 4

i

(

t l

Federal Register / Vol 45, No. 225 / Wednesday, November 13, 1980 / Rules and Regulations 76611 the hcensee hue been accepted by the after the effective date of this section determines. upon a showing by the NRC staff as satisfying the provisions of and Appendix R to this part: licensee, that there is good cause for Appendix A lo Branch Technical (t) the first refueling outage: extending such date and that the public Position DTP APCSU 9 5-lirellected in (ii) another planned outage that lasts health and safety is not adversely J staff fire protection safety evaluation foi at least 80 days: or affected by su.h extension Extensions I reports issued prior to the effective date (th) an ur. planned outage that lasts for of such date shall not exceed the dates of this rule. or to the extent that fire at least 120 days. determined by paragraphs lc)(1) through i protMtion features were accepted by (4) Those fire protection features that' (c)(4) of this section.

the stag Li comprehensive fire require prior NKC approval by (1) Those fire protection features that i protection safety evaluation reports paragraph (c)(5) of this section, shall be involve revisions of adminierative 1,. sued before Appendix A to Branch implemented within the following controls, manpower changes, and Technical Position DTP APCSB 9.5-1 schedule: Dedicated shutdown training shall be implemented within 4 was published in A . gust 1976. With systems-30 months after NRC months after the date of the NRC staff 1 respect to all other fae protection approvel, modificetions requir;ng plant Fire Protection Evaluation Report ,

features covered by Appendix R. all shutdown-before startup after the accepting or requiring such features. l nuclear power plants licensed to operate earliest of the events given in paragraph (2) Those fire protection features prior to lanuary 1.1979 shall satisfy the (c)(3) commencing 180 days after NRC involving installation of modifications applicable requirements of Appendix R approval; niodifications not sequiring not requiring prior approval or plant to this part. including a cifically the plant shutdown--a months after NRC shutdown shall be implemented within requirements of Sections !!!.G. :ll4 and approval. 12 months after the date of the NRC 111. 0 .

(5) Licensees shall make any staff Fire Protection Safety Evaluation (c) All tire protection modifications m difications necessary to comply with Report accepting or requiring such these requirements in accordance with features.

requne to satisfy the provisions of the above schedule without prior review (3) Those fire protection features.

Appendix R to this part or directly and approval by NRC except for affected by such requirements shall be including alternative shutdown m difications required by Section lil.G.3 capability, involving installation of completed on the following schedule:

of Appendix R to this part. Licensees modifications requirmg plant shutdown (1) Those fire protection featurce that shall submit plans and schedules for shall be implemented before the startup involve revisions of administrative meeting the provisions of paragraphs after tne earliest of the following events controls, manpower changes, and (c)(2), (c)(3), and (c)(4) within 30 days comm.ncing 9 months or more after the tralmng, shall be implemented within 30 after the effective date cf this section date of the NRC staff Fire Protection days after the effective date of this and Appendix R to this part. Licerisees Safety Evaluation Report accepting or section and Appendix R to this part- shall submit design descriptions of requiring such features:

(21 Those fire protection features that modifications needed to satisfy Section (i) The first r fueling outage; involve installation of modifications that Ill.G.3 of Appendix R to this part within (ii) Another planned outage that lasts do not require prior NRC approval or 30 days after the the effective date of for at least 60 days; or plant shutdown shall be implemented within 9 months after the effective date this section and Appendix R to this part.

(0)In ti e event that a request for (iii) An unplanned cutage that lasts for 9t least 120 days.

)

of this section and Appendix R to this exemption fram a requirement to comply (4) Tbose fire protection features part. with one or more of the provisions of involving dedicated shutdown capability (3) Those fire protection features. Appendh R filed withm 30 days of the requiring new buildings and systems except for those requiring prior NRC effective date of this rule is based on an shall be implemented within 30 mor.ths approval by paragraph (c)(5) of this assertion by the licensee that such of NRC approval. Other modifications section, that involve installation of required modificatiors would not . requiring NRC approval prior to modifications that do require plant enhance fire protection safety in the installation shall be implemented within shutdown the need for which is justified facility or that such modifications may 6 months after NRC approval.

in the plans and schedules required by be detrimental to overall facility safety, (e) Nuclear power plants licensed to the provisions of paragraph (c)(5) of this the schedule requirements of paragraph operate after January 1.1979, shall I section, shall be implemented before (c) shall be tolled until final Commission complete all fire protection startup after the earliest of the following action on the exemption request upon a modifications needed to satisfy events commencing 180 days or more determination by the Director of Nuclear Criterion 3 of Appendix A to this part in .

Reactor Regulation that the licensee has accordance with the provisions of their

'clanricatmn and suidance with respect to provided a so'md technical basis for licenses.

permiemble alternahves to sat ofy Appenda A to such assertion that warrants further 2. A new Appendix R is added to HTP APCSH 9 5-1 has been provided in four other sta[( review cf the request. 10 CFR Part 50 to read as follows:

m niary cuidance on intornanon re Proiechan Evaluenonf da 'd e Rf "

f nF eP Appendix R-Fire Protection Propm for df uclear Powe Facilities Operating Pr%t to 3 ,

. * " sample Technical specificahon." dated 19 Paragraph (b) of this section and it ten supplements to such reports, other than / Introductmn ond scope

. %d 3ar Plani Fire Protectmn Funcho . , [eatures covered by paragraph (c). shall This Appendix applies to hcensed nuclear Responsrul.nes Adnunktranve Control r ..d power electnc generahng stations that were Quahiy Aswrma dated June R tr7 be completed as soon as pradicable but g operat ng prior to lanuary 1 1979. except to no is e than the cornpletion date e .rrently specified in license conditions the extent set forth in paragraph 50 48(b) of Re$c rNIiEd 1 s A Dre Prmecimn safeiy balu.shon Report thai dr t?chnical specifications for such $'u s $r u' h ((dibs e' a IIf<Eh fi e hn been issued for each operahr.g plant states how facility, or the date determined by protechon features required to satisfy .

de$kf n die o$c$t au h I'l y paragraphs (d)(1) through (d)(4) of this Critenon 3 of Appendix A to this part?

reseed when he fanhty unities the appropnaie section, whichever is sooner, unless the reqmremems of Appenda R to thm pct Director of Nuclear Reactor Regulathn 'see footnote 4

.-.. ~ - - .-.-, _ .-._- _ -... ,_.,---

76f312 &deral Register / Vol. 45. No. 225 / Wednesday. November 19, 1980 / Rules and Regulations ._-

Crder.on J of Appenda A to this part nrog am she'l estabhsh the fue protection D. Alternatae or Ikdgued Shstda n specifm that Structures, systems and pohc) for 'he protection of structures. Capabehty compcnents important to safet> shall be systems. and c amponerts important to safety In areas where the fire protection features designed and located to mmimize. consistent at ead plant and the procedures, equipment. cannot ensure safe shutdown capabihty m i with other safety requirements. the and personnel required to implement the the event of a fire in that area. altername or l probabdity and effed of fires and program ut the plant site. dedicated safe shutdown capabihty shall be

! e uplosions " The fire protection program shall be m der prouded. I When considering the effects of fire. those the direction of an mdmdul who has been g gg , , j systems assm wied with achievmg und delegated . 4thority commensurate with the i maintaining safe shutdown conditions respons;bihties of the position and who has A. Water Sopphes /or Fre Suppressmo I assume maior importance to safety because avadable staff penonnel knowledgeable m Srstera l damage to them can lead to core damage both fire protection and naclear safety. Two separate water supplies shall be I resulting from loss of coolant thrugh boiloff The fire protection program shall nieno provided to furnish nuessary water s olume i The phrases "important to safety." or the concept of defease-in-debth to fire and p tesur- to the fire main loop

" safety-rm ited." will be used throughout this protection in fire areas impo tant to safety. Each supply shall consist of a stora2e tank.

Appendix R as applying to all safety with the follorc.g objectnes; pump, piping, and appropriate isolation and functions The phrase " safe shutdowr? will a to prevent fires fram startmg: control salves. Two aparate redundant be used thrw thout this Appenwx R as e to detect rapidly, centrol. and extinguish suctions in ene or more intake structures applying to both hot and cold nhutdown promptly those fires that do occur: from a la.ge body of water (river, lake, etc )

functions

• to provide protection for structures. Will satisfy the requirement for two separated Decause fire may affect safe shutdown systems, and components im,nrtant to safety water storage tanks. These supphes shall be systems and because the loss of function nf so that a fire that is not prompily separated so that a failure of one supply wdl systeins used to mitigate the consequences of extinguished by the fire suppression activities not result in a failure of the other supply.

design basis accidents under postfire will not prevent the safe shutdawn of the Each supply of the fire water distribution conditmns does not per se impact public pla n t. system shall be capable of providing for a safety. the need to hnut fire damage to B Mre Hurords Analysis period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> the maximum expected systems required to achieve and maintain A fire hazards analysis shall be performed water demands as determined by the fire safe shutdown conditions is greater than the by qualified fire protection and reactor hazards analysis for safety-related areas or need to limit fire damage to those systems systems engineers to (1) conside potential in other ereas that prt sent a fire exposure required to mitigate the consequences of situ and transient fire hazards. [2) determine hazard to safety related areas.

design basis accidents Three levels of fire the consequences of fire in any loca: ion in When storage tanks are used for comt ired damage limits are estubbshed accordmg to the plant on the abihty to safely shut down service-water / fire water uses the mmimum the safety functions of the structure, system, the reactor or on the abihty to minimize anJ volume for rae uses shall be ensured n or component. control the release of radioactivity to the means of fedicated tanks or by some

_ _ _ _ _ _ _ . . _ environment; and (3) epecify measures for physical means such as a vertical tandp je seen suncunn r,. cam.g. nnois fire prevention, fire detection fire for other water service. Administrative suppression, and fire contamment and controls, including locks for tank outlet noi snumn one vs.n e %=meni w..w, io alternative shutdown capabihty as required valves. are unacceptable as the only means actwev. mot snumo=n kom o v' for each fire area containing structures, to ensure minimum water volume.

or e it a systems, and components important to safety Other water systems used as one of the n e tv. o. mage t> in accordance with NRC guidelines and two fire water supplies shall be permar ently uutna en wow.v .ka' s.ngi. w.. regulations. connected to the fire main system and shall C# 6*'""*"

"'"g*]*

, 7 7 g '"*  %** y C. Fire Prevent,on Features be capable of automatic alignment to the fire on.gw t,, a .,nus. k. incunna Fire protection features shal) racet the main system. Pumps, controls, and power an emow. fr. toi aamage muni following general requirements for all fire supplies in these systems shall satisfy the tm nmn.o so mai si teesi on. .a areas that contain or present a fire bazard to requirements for the main fire pumps. The

• • [n,[*d,*3gN['

, structures, systems, or components important use of other water systems for fire protection ey to safety. sha!! not be incompatible with their functions twinnpaws Nm tem os meant wessaw 1. In situ fire hazards shall be identified required for safe plant shutdown. Failure of

• * " ' ' "*U and suitabl' protection provided the other system shall not degrade the fire l [*]ly'*

te damage tav a sew. emusu,. 1 Transient fire hazards associated with mam system.

we normal operation, mamterance, repair, or R SectionalIsolafen Valves modification actmtres shall be identified and Sectional isolation valves soch as post 2EE .E ["n 'sU.'uI/s/ni cNs'tg '

sjad eliminated where possible. Those transient indicator vahes or key operated valves shall I .m o.,n io em inueue. .v% o, compon.nis ioce.o fire hazards that can not be eliminated shall be installed in the fire main loop to permit

' be controlled and suitable protection isolatior. )f portions of the fire main loop for vr an a$.

ms. o, MY,m as 9

inwuo sw.ei compo men provided. mair..enance or repair without inteirupting inut a w ~uvmo c,ne vain of w. .mi,m to =ni 3. Fire detection systems, pr ' abit the entire water supply.

m., can nu n inm,o

m. ouno n %.n+i von iorew .n m.e a oenue wu anwe so, extinguishers. and standpipe and hose C Hydrant / solation valves om. ma, * ,%nnant v.d a w. moev.ng come.co..

we io icm ,.aunow ven. nioce.o ma, concu.

in me i. an m.

mu.a*

v stahons shall be instailed Vaives shall be installed to penmt isolation 4 Fire barriers or automatic suppression ,f outside hydrants from the fire main for l The most strmgent fire damage hmit shall systems or both shall be instulled as maintenance or repair without interrupting l apply for those systems that fa!Iinto more necessary to proteci redundant systen s or the water supp'y to automatic or manual fire l than one category Redundant s> stems used components necessary for safe shutdowr suppression systems in any area contammg to nutigate the consequences of other design 5. A site fire brigade shall be estabbshed. or presenting a fire hazard to safety-related ,

basis acudents but not necessary for safn tramed. and equipped and shall be on site at or safe shutdown equipment.

l shutdov n may be lost to a single exposure all times O Manual Fire Suppression fire floweser. protection shall be prouded so 1 Fire de -tion and suppression s> stems Standpipe and hose systems shall be that a fire within only one such system will shall be des.gned, installed naintained and installed so that at least one effective hose I not damage the redundant sutem. tested by personnel prc;>erly qualified by stream will be able to reach any location that experience and traminx in fire protection contams or presents an exposure fire hazard

// Gextu/ Requrements systems to structures. systems. or components A Fire Protection Program 7. Sui tedlance procedures shall be impcrtant to safety.

A fire protection program shall be estabbshed to enoure that fire barriers are in Access to permit effective functioning of estabbshed at each nuclear power riar.c The place and that fira suppression systems and the fire brigade shall be provided to all areas components are operable. that contain or present an exposure fire

Federal Register / Vol 45, No. 225 / Wednesday. November 19, 1980 / Rules and Regulations 76613 hazard to structures, systems. or components hour rating. In addition. fire detectors and an Institute for Occupational Safety and important to safety. autorratic hre suppression system shall be Health-approval former!y given by the U.S Standpipe and hose stations shall be inside instal;ed in the fire area: Bureau of Mines) shall be provided for fire PWR containments and BWR containments inside noninerted contamments one of the brigade, damage control, and control room that are not inerted. Standpipe and hose fire protection means specified above or one personnel. At least 10 masks shall be stations inside containment may be of the following fire protection means shall available for fire brigade personnel. Control connected to a high quality water supply of be provided: room personnel may be furnished breathing sufficient quantity and pressure other than d. Separation rsi cables and equipment and air by a manifold system piped from e the fire main loop.if plant-specific features associated non-safety ciri.uits of redundant storage reservoir if practical. Service or rated prevent extending the fire main supply ins;de trains by a honzontal distance of more than operating life shall be a minimum of one-half containment. For BWR drywells, standpipe 20 feet with no intervening combustibles or hour for the self-contained units.

and hose stations shall be placed outside the fire hazards; At least two extra air bottles shah be I dry well with adequate lenrhs of b7se to e. Installation of fire detectors and an located on site for each self-contamed reach any location inside the dry well with automatic fire suppression system in the fire breathing unit. In addition, an onsite e hour an effective hose s' ream. area: or supply of reserve air shall be provided and E. Hydrostatic Hose Test, f. Separation of cables and equipment and arranged to permit quick and complete Fire hose shall be hydrostatical.ly tested at associated non. safety circuits of redundant replenishment of exhausted supply air bottles a pressure of 300 pd or 50 psi above trains by a noncombustible nadiant energy as they are returned. If compressors are used maximum fire main operating pressure, shield. as a source of breathing air, only units whichever is grea.er. Hose stored in outside 3, Alternative or dedicated shutdown approved for breathing air shall be usedr hose houses shat be tested annually, Interior capabihty and its assocuted circuits? compressors shall be operable assuming a standpipt hose shall be tested every three independent of cables, systems or loss of offsite power. Special care must be years. components in the area, room or zone under taken to locate the compressor in areas free I

F. Automatic The Detection consideration, shall be p:ovided: of dust and contamir .nts.

Automatic fire detectiun systems shall be a. Where the protection of systems whose 1. Fire Briscde TroiW installed <n all areas of the plant that contain function is required for hot shutdown does The fire brigade trnrds program shalt or present an exposure fire hazard to safe not satisfy the requirement of paragrrph G.2 ensure that the capability to fight potential shutdown or safety-related systems or of this sectinn; or fires is eu iblished and maintained. The components. These fire detection syrterns b. Where redundant trains of systeres program shall consiet of an initial classroom shall be capable of operating with or wl nout required for hot shuteawn located in the instruction program followed by periodic offsite power. same fire area may be subject to daenage classroom instruction, fire fightmg practice, G. Are Protection o/ Sofa Shutdown

' are suppression activities or tom tqe and i:re drills:

Capabihty rupture or inadvertent operation of fire 1. Instruction

1. Fire protection features shall be provide j 'uppression systems. a. The initial classroom instruction shall for structures, systems, and components in addition, fire detection and a fixed fire include:

important to safe shutdown. These feetures suppression system shall be installed in the (1) Indoctrination of the plant fire fighting ,

sha!! be capable of limiting fire damage so area, room, or zone under consideration, plan with specific identification of each that: H. Are Brigade individual's responsibihties,

s. One train of systems necessary to A site fire brigade trained and equipped fr (211dentification of the type and loc tion of achieve and maintain hot shutdown fire fighting shall be established : - ensure fire bazards and associated types of fires that conditions from either the control room or adequate manual fire fighting capability for could occur in the plant.

emergency control station (s) is free of fire all areas of the plant containing structures. (3) The toxic and corrosive characteristics damage; and systemw or rx mponents important to safety, of expected products of conbustion.

b. Systems necessary to achieve and De fire brigade shall be at least five (4) Identification of the location of fire maintain cold shutdown from either the members on each shift.The brigade leader fighting equipment for each fire area and control room or emergency control station (s) and at least two brigade members shall have fariliarization with the layout of the plant, can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. sufficient trainir.g in or knowledge of plant incading access and egress routes to eac.h 2 Except as provided for paragraph G.3 of safety-related systems to understand the a rea.

this section, where cables or equipment, effects of fire and fire suppressants on safe (5) The proper use oiavailable fire fighting including associated non safety drcuits ti;at shutdown capability. The qualification of fire equipment and the correct method of fighting could prevent operation or cause brigade members shallinclude an annual each type of fire.The types of fires covered maloperation due to hot shorts, open circuits, physical examination to determine their should include fires in energized electrical or shorts to ground. or redundant trains of ability to perform stenuous fire fighting equipment, fires in cables and cable trays, systems necessary to achieve and maintain activities. The shift supervisor shall not be a hydrogen fires fires involving flammable and member of the fire brigade. The brigade combust 61e liquids or hazardous pro :ess hot shutdown conditions are located withii leader shall be competent to assess the the same fire area outside of primary chemicals, fires resulting from construction or containment, one of the following means of p tential safety c nsequences I a fire and modifications (welding), and record file fires.

ensuring that one of the redundant trains is addse control mom pusonnet Such (6) The proper use of communication, free of fire damage shall be provided: c mpetence by the brigade leader may be lighting. ventilation, and emergency breathing ev denced by possession of an operator s equipment.

a Separation of cables and equipment and license r equivalent knowledge of plant (7) The proper method fo'r lighting fires aosociated non safety circuits of redundant safety-related systems-trains by a fire barrier having a 3. hour rating. inside buildings and cortfined spaces.

Structural steel forming a part of or """*'9" * *"' E" I '.the (8) The direction and cooidination of the brigade shall consist of personal pretective fire fighting activities (fire brigade leaders supporting such fire barriers shall be equipment such as turnout coats. boots.

' protected to provide fire resistance only).

g! ves. hard hats. emergency commurications p) Detailed review of fire fighting equivalent to that required of the barrier- " '

b Separation of cables and equipment and 'j Portable strategies and procedures.

acnociated non-safety circuits of redundant "

l trains by a horizontal distance of more than

[iNI* guishe : e cor5ta ned re thing .

l% apparatus using full-face positive-pressure 20 feet with no intervening combustible or [re 8 "8 1*

masks approved by NIOSH (National fire hazards. In addition, fire detectors and an Nota-Items (9) and (10) may be deleted automatic fire suppression system shall be

• Alternanve shutdown espability is provided by installed in the fire area: or rerouang relocating or modincating of extsiing n n- Perations personnel who may be

c. Enclosure of cable and equipment and systems. dedicated shutdown capability is provided assigned to the fire brigade, accociated non-safety circuits of one by insialling new s'ructures and systems for the b. The instruction shall be provided by redundant train in a fire barner having a 1 funchon of post fire shutdown. qualified individuals who are knowledgeable.

76614 l'oderal Register / Vol. 45. No 225 / Wednesday. Nowmber 1R 1980 / Rules and Regulations

___ _ ..___ _ ___ _.._ ___ __ ___ __- __J espenem ed , n.! smiaSi ramed in fightmg bngade. and select on placement and uw of reqmred additional fire protection m the the 13; es M % 'ha's oald ottur m the plant eqmpment. and fire huhtmg stralegies w mk o inity procedure

,ml in im ra a, a pes of eq opment aunlable (2) Assessment of cat h bngade member s S Gos ern the use of igmtion soon es bs use m ihi nm le o ww er pbm' knowledge of his or her role in the hre ol a flame primit system 'o r unirol weldmg.

r lneur hon shall t,e prmidcd to all fire huhtmg strategs for the area assumed to flaine cutting brazing. or soldering bnoele members and fire bngade leaders contam the bre Assessment of the brigade operatmns A separate pernut shall be issued 4 Hegular planned nieetmgs shall be held member's conformam e with estabbshed for each area w here vmrk is to be done If al bont es e rv 3 rnonths for all bngade plant fire hghtmg procedures and use of bre work contmues user more than one shifi. .he 4 mornhers in revier changes m the hre fightmg equipment. indudmg selfs ontamed permit shall be sahd for not more than 24 proiettion program and other sub ects l as emergency breathing apparatus, hours when the plant is operatmg or for the netenarv (ommunication eqmpment, and sentilation duratmn of a particular job durmg plant e penodic ehesher f rammg sessions shall eqmpment. to the extent practicable shu'down f be held tu repeat the classroom mstruttmn (3) The simulated use of fire fightmg 6 Control the removal from the area of all program for all bngade memlmrs on er a two- eqmpment requoed to cope with the situation waste debris, scrap. mi spdis or other 3 car penod. 'I hese sessmns may be smd typa of fire . elected for the dnli The combustibles resultmg from the work actiutv vmr unent with the regular planned area and type of fire thosen for the dnll immetbately followmg completion of the meetion should differ frorn those used m the preuous actnity. or at the end of each work shift.

2 l'nMn e dnli so that bngade members are tramed m w hRhes er comes first.

prat tice wssmns shall be held for ear h hghtmg bres m varmus plant areas The 7. Mamtam the penodic housekeepmg shifi fue bnenic on the proper method of situanon selected dould simulate the size mspections to ensure contmued compbance hghtmg the sanous types of hres that could and arrangement of a hre that could with these athnimstratne controls.

urcur m a nm. lear power plant. These reasonably occur in the area selet ted. N Control the use of specific combustitdes sessions shall proside bngade members with allowing for hre development due to the time in safeis-related ureas. All wood used m enqicnre m actual hre extmguishment and required to respond. to obtain eqmpment. and safety related areas dunna mamienance the de of enwrgency breathmg apparatus organize for the fire. assummg loss of modihcatmn. or refuebng aperations fsuch as mler strenuous conditions encountered m automatic suppression tapability lay-down blocks or scaffolding) shall be hre fightmg 'T hese practice sessions shall be ( O Assessment of bngade leader's Iteated with a flame retardant Eqmpment or prusided at least once per year for each fire direr finn of the hre fightmg effort as to suppbes (such as new fuell shipped m bngade member thoroughnest accuracy and effectiveness. ontreated combustible packmg contamers J Dn#s 4. Records may be unpacked m safetprelated areas if a hre bngade drilk shall be penormed in Individual records of traming prouded to icquired for vahd operating reason

• the plant so that the fire bngade can practice cath fire brigade member. mcludmg dnll flowes er. all combustible mavals shall be as a team critiques. shall be mamtamed for at least 3 remosed from the area immedmt dv following b Dolls shall be performed at regular years to ensure that each member recenes the unpackmg. Such transient r nbustible miers als not to exceed 3 months for each traimng m all parts of the traimng program matenal unlear stored in appiused shift fire bngade. Each fire bngade member These records of traimng shall be asadable containers. sFall not be left unattended should participate in each dnll. but must for NRC reuew. Retraming or uroadened durmg lunch breaks. shift thangen or other parhapale in at least two dnlls per year trainmg for hre hghtmg withm buddmus shall sirmlar penods I..oose combustdele packmg A sufficient number of these dnlis, but not be scheduled for all those brigade members mn nal such as wood or paper excelsior, or less than one for each shih fire bngade per whose performance records show pol, 'hylene sheetmg shall tr placed m sear, shall be unannounted to determme the dehciencies metal containers with tight fitting self<losma f ue fighhng tradiness of the plant fire l Emergengl.wh!my metal covers bngde, brigade leader, and hre protection Emergency bahtmg umts with at least an & 9 Control actions to be taken by an systems and eqmpment. persons planmaa hour battery power supply shall be prouded mdnidual discovering a fire. for example, and authormng an unannounted urill shau m all areas needed for operahon of safe notihcation of control room attempt to ensure that the respondmg shift hre bngade shutdown equipment and in access and estmguish fire. and actuation of local hre members are not aware that a dnllis being egress routes thereto. suppression systems.

planned untd it is begun Unannourced dnbs k Admmistratae Controls 10 Control achons to be taken by the shall not be sr heduled closer than four Admmetralis e controls shall be control room operator to determme the need weeks estab? abed 'o minirmze hre hazards in areas for bngade assistance upon report of a fire or At least one drd! per '. car shall be containr 3 truciees. sg stems. and rererpt of alarm on control room annunciator perlormed on a ' back shift" for each shift hre components importa0t to safety These panel, for e sample. announcmg locahon of bngade controls shall estabbsi procedures to hre oser pA system, sounchng hre alarms, e The dnits shall be preplanned to 1 Gmern the hand' r y and bmitation of the and nonfving the shdt superusor and the hre ntabhsh the traimng obi ettnes of the dnll use of ordinary cornbusuble matenals bngade leader of the type size, and locahon and shall be cntniued to delernune how well combustible and flamrm ble gases and of the fire the training ob iccines bas e been met hquids. huh efficieng ; articulaic an and 11 Control actions to be taken by the fire Iinannoum.ed dnlls shall be planned and charcoal inters. dry ion m hane resins or bngade after notihcation by the control room rnhqued by members of the management other combustible supphes m safety related operator of a hre, for example, assembbng m caff mponoble for plant safety and fire a re n a designated locahon. receiving direttmns pmin hon performance deficiencies of a fire 1 prohibit the storagr of < omh nt ibles m f rom the fire bngade leader. and discharging brede or of mdnidual fire bngade members safets related areas or estabbsh designated specihc bre huhting .esponsibihhes includmg shall be remedied by u hedubng addihonal storage areas with appropnate fue seierhon and transportahon of hre fighting honung for the bngade or members protechon. eqmpment to hre location. selechon of I:nsainf a< tors dnll performant e shall be 3 Govern the handbng of and lima proterine equ pment, operatmg matruc tions fo!bmed by a repeat dnll withm 30 days transient fire loads such as tomhust ble and for use of bre suppression s>siems. and use d At 3 3 car miervals. a randomly selected flammable bqmdt wood and plutic of preplanned strategies for fighhng fires m unmnounced dnll shall be cnhqued by products or other combustible materods m speuf:c areas y quahfied indn nloals independent of the bmldmgs containmg safety-related $ssims 11 Defme the strategies for fightmg hres in b< enseei staff A copy of the wntten report or equipment dunng all phaws of operatmg. all safeterelated areas and areas prewntmg from sm h mdniduale shall be avadable for and especially dunng maintenam e. a hazard to safety-related eqmpment These i

NRC renew mmbhcahon or refuehng operaimns strategies shall designate:

e 1)nlis shall as a muumum mclude the 4 Designate the onsite staff meniber a f ire hazards m each area cosered b) the f ollow mg responsible for the mplant hre pr tectan spn ihr prehre plans (1) Aumment of fire alarm effectnenen reuen of proposed work at imbes to idenhf3 h hre eshngmshants best suited for t me requped to nohfv and assemble fire potenhal transunt hre hazards and spn ify ( untmlhog the hres anociated with the hre l

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Federal Register / Vol 45, No 225 / Wednesday, November 19, 1980 / Rules and Regulations 76615

.wrie m that area and the nearest lor.ation coolant lesel above the ton of the core fr separation and brners between travs and o' mese estinguishants BWRs and be within the levelindicatioa in conduits containing associated circuits of one t Most fasorable directmn from which to the pressurizer fcr PWRs. safe shutdown division and trays and eMaf k a fire in each ared m view of the c Tne reactor heat removal function shall conduite contataing associated circuits or s enT.ation direction, access halNay s. stairs. be capable of achieving and maintaining safe shutdown cables from the redundant anc coors that are most I kely to be free of decay heat removal. division, or the isolation of hese t associated fire and the best station or elesation for d The procass monitoring function shall be circui.ts from the safe shutdown equipment, fighung the fue All access and egress routes capable of providing direct readings of the shall be such that a postulated fire insolving

, that ins olve locked doors should be process s anables necessary to perform and associated circuits will not prevent safe specifically identified in the procedure with control the above functions. shutdown >

ttm appropnate precautions and methods for e. The supporting functions shall be M. Fire Barrier Cable Penetration Seo/

access specified capable of providing the process cooling. Quahfication g d Plant systems that should be managed to lubrication. etc, necessary to permit the Penetration seal designs shall utilize only reduce the damage potential dunng a local operation of the equipment used for safe noncombustible materials ar.d shall be fire and the location of local and remote shutdown functions. qualified by tests that are comparable to tests controls for such management (e g , any 3. The shutdown capability for specific fire used to rate fire barners. The acceptance hydraulle or electncal systems in the zone areas may be unique for each such area or it criteria for the test shallinclude:

covered by the specific fire fighting procedure may be one unique combination of systems 1. The cable fire barrier penetration seal that could increase the hazards in the area for all such areas. In either casa, the has withstood the fire endurance test without because of overpressurization or electrical alternative shutdown capability shall be passage of flame or !gnition of cables on the hazards)- independent of the specific fire area (s) and unexposed side for a period of time e Vital heat sensitive system components shall accommodate postfire conditions where equivalent to the fire resistance rating that need to be kept cool while fighting a offsite power is available and where offsite required of the barrier; local fire. Particularly hazardous power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. 2. The temperature levels recorded for the combustibles that need cooling should be Procedures shall be in effect to implement unexposed side are analyzed and designated. this capability. demonstrate that the maximum temperature f Organization of fire fighting brigades and 4. If the capability to achieve and maintain is sufficiently below the cable insulation the assignment of special duties according to cold shutdown will not be available because ignition temperature; and job title so that all fire fighting functions are of fire damage. the equipment and systems 3. The fire brrrkt penetration seal remains s

coscred by any complete shift personnel comprising the means to achieve and intact and does not allow projection of water '

complement. These duties include command beyond the unexposed surface during the control of the brigade, transporting fire maintain the hot standb> or hot shutdown condition shall be capable of maintaining hose stream test, )

suppression and support equipment to the fire such conditions until cold shutdown can be N. Fire Doors scenes, applying the extinguishant to the fire, achieved. If such equipment and systems will Fire doors shall be self closing or provided communication with the control room, and not be capable of being powered by both with closing mechanisms and shall be coordination with outside fire departments. onsite and offsite electric power systems inspected semiannually to venfy that

g. Potential radiological and toxic hazards because of fire damage, an independent automatic hold-open, release, and closing in fire zones. onsite power system shall be provided. The mechanisms and latches are operable.

h Ventilation system operation that number of operating shift personnel, One of the following measures shall be ensures desired plant air distnbution when exclusive of fire brigade members, required provided to ensure they will protect the the ventilation flow is modtfied for fire to operate such equipment and systems shall opening as required in case of fire:

containment or smoke clearing operations. be on site at all times. L Fire doors shall be kept closed and L Operations requinng control room and 5. Equipment and systems comprising the electrically supervised at a continuously shift engineer coord: nation or authonzation. means to achieve and maintain cold manned location; i l Instructions for plant operators and shutdown conditions shall not be damaged 2. Fire doors shall be locked closed and general plant personnel during fire. by fire; or the fire damage to such equipment inspected weekly to verify that the doors are L. Alternative and Dedicated Shutdown and systems shall be limited so that the in the closed position; Capabihty systems can be made operable and cold 3. Fire doors shall be provided with t Alternative or dedicated shutdown shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. automatic hold.open and release mechanisms capability provided for a specific fire area Materials for such repairs shall be readily and inspected daily to venfy that doorways shall be able to achieve and maintain available on site and procedures shall Fe in are free of obstructions; or subcritical reactivity conditions in the effect to implement such repairs. Il such 4. Fire doors shall be kept closed and reactor, maintain reactor coolant inventory 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 /> inspected daily to verify that they are in the achieve and maintain hot standb> ' after the fire will not be capable of being closed position.

I

' conditions for a PWR (hot shutdown 'for a powered by both onsite and offsite electric The fire brigade leader shall have ready 11WR) and achieve cold shutdown ' power systems because of fire damage, an access to keys for any locked fire doors.

conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and mamtain cold independnet onsite power system shall be Areas protected by automatic total flooding shut:fown conditions thereafter. Dunng the provided Equipment and systems used after gas suppression systems shall have .

postfire shutdown, the reactor coolant system 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be powered by offsite power electrically supervised self. closing fire doors process variables shall be maintained within only. or shall satisfy option 1 above. l l

those predicted for a loss of normal a c. 8, Shutdown systems installed to ensure O. Oil Collection System for Reactor power, and the fission product boundary postfire shutdown capability need not be oolont Pump intepnty shall not be affected;i e., there shall designed to meet seismic Category I criteria, The reactor coolant pump shall be be no fuel clad damage, rupture or any single failure criteria, or other design basis equipped with an od collection system if the primary coolant boundary, or rupture of the accident criteria, except where required for c ntainment is not inerted during normal containment boundary. other reasons. e s., because of interface with operation. The oil collection system shall be

2. The performance goals for the shutdown or impact on existing safety systems, or e designed engineered, and installed that functions shall be: because of adverse valve actions due to fire failure will n t lead to fire dunng normal or a The reactivity control function shall be damage. design basis accident conditions and that I

capable cf achieving and rnaintaining cold 7. The safe shutdown equipment and shutdown reactivity conditions systems for each fire area shall be known to ' An acceptable method of complying with this

b. The reactor coolant makeup function be isolated from associated non-safety "I'""ve w uld be to meet Hegulatory Guide us shall be capable of maintaming the reactor circuits in the fire area so that hot shorts. $d 94 ct on 4 5) re trays from open circuits. or shorts to ground in the redundant safety dmsions are so proiected that As defined in the Standard Techrucal associated circuits will not prevent operation postulated fires affect trays from only one salsty Specifwauons of the safe shutdown equipment.The dmsion.

76C16 Federal Register / Vol. 45. No. 225 / Wednesday. November 19. 1980 / Rules and Regulations there si reasonable assurance that the system wdi withstand the Jafe Shutdown l'arthquakr Suc h collecuan systenis tha!! be capable of collecting lube oil from all potential pressurized and unpressurized leakage sites in the reactor coolant pump lube o:t systems.

Leakage shall be collected and drained to a

• vented closed container that can hold the '

entire luSe oil system inventory. A flame arrenter is required in the vent f the flash ,

pona characteristics of the od present the g horard of f're flashbuck. l.cakage points to be protected shall include hit pump urid piping.

overflow lines, lobe od cooler. oil fut and drain lines and plugs. flanged connections on oil hnes, and lube oil reservoirs where such features exist on the reactor coolant pumps.

The drain line shall be large enough to accommodate the largest potential oil leak.

(Sec.161b. Pub. L 83-701 M Stat. 948. sec. 201. Pub. L 93-438. M Stat.1242 (42 U.S.C.

2201(b). 5841))

Dated at Washington, D.C., this 17th day of November 19tn For the Nuclear Regulatory Commission.

Samuel 1. Chilk, Secretary of the Commission.

lFN Dm. av 3a175 Filed 11-16.an; a 45 mmj 9tLLING CODE 7690-01-M e'

O

• See Hegulatary Guide 1.N "Saismic Design Classificahon" Paragraph C 2.

'. *

• Enclosure 2 PILGRIMNUCLEARPOWERSTATION,UNITNO. 1 l

SUMMARY

OF STAFF REOUIRE*fENTS TO RESOLVE OPEN ITEMS l

CO2 System Discharoe Test, Section 3.2.8 In the SER, we requested the licensee to provide calculations and reference prototype testing of the CO2 system in the Cable Spreading Room to verify that a design concentration of 50% is achieved in all parts of the room, and a concentration of 30% is achieved within 1 minute and 30 seconds of actuation. If calculations and prototype testing are inconclusive, an in-situ discharge test should be preformed. .

By letter dated February 29, 1980, the licensec. expressed concern regarding the deleterious effects that are reported to have occurred to sensitive electronic / electric equipment and associated cabling in cable. spreading rooms at other plants where full-scale CO2 discharge tests have taken place.

We agreed with the licensee. We recommended that the discharge test be performed during the next' refueling outage.

The licensee indicated that the concerns expressed in their letter included potential long range effects that the CO2 discharge test may have on the various types of coatings and insulation on electrical cables. We requestad that the licensee provide the design informatier, on the CO2 system for the cable spreading room and indicated that we were unaware of any long term effects that may result from a CO2 discharge test. By letter dated October

20. 1980, the licensee provided the design criteria and calculations for the CO2 system protecting the cable spreading room. The CO2 system is the only automatic fixed system provided in the cable spreading room.

The licensee has not indicated specifically what potential long range effects that the CO2 discharge test may have on their cables or coatings.

The licensee has not provided any. technical data to je:tify their position

..nat a CO2 discharge test will have long range deleterious effects on cables or coatings. The licensee!s design calculations indicate that a 30% concentration should be achieved in 1-1/2 minutes. Further, the ,

calculations indicate that the system is designed with an adoitional amourt of CO2 to ccmpensate for leakage. This amount of compensating gas is )

approximately 10% of.the total discharge. In Section 4-11, " Carbon Dioxide l Extinguishing Systems", of the Factory Mutual loss Prevention Data, it . 1 recomends that for total. flooding systems in which additional compensating gas of 10% or more is provided, a concentration test should be performed.

It also reccmmends that where conditions make difficult to predict the adequacy of design methods a full discharge test should be perf ormed to verify t.ut the design concentration is attained within the specified time limit.

The. licensee's design calculations indicte that the system is designed to provide an adequate CO2 concentration. However, because of the uncertainty of such calculations for systems of this size and configuration the licensee l should perform a CO2 discharge test for the cable spreading room to verify i that the system is capable of providing design concentration within the i specific time limit.

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