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Implementation of Fire Protection Requirements (Generic Letter No. 86-10)
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 April 24, 1986 To ALL POWER REACTOR LICENSEES AND APPLICANTS FOR POWER REACTOR LICENSES Gentlemen: SUBJECT: IMPLEMENTATION OF FIRE PROTECTION REQUIREMENTS (GENERIC LETTER 86-10) In the Spring of 1984, the Commission held a series of Regional Workshops on the implementation of NRC fire protection requirements at nuclear power plants. At those workshops, a package of recently developed NRC guidance was distributed to each attendee which included NRC staff responses to industry questions and a document titled "Interpretations of Appendix R." The cover memo for the package explained that it was a draft package which would be issued in final form via Generic Letter following the workshops. The guidance approved by the Commission is appended to this letter, and is in the same format as the draft package, i.e., "Interpretations of Appendix R" and responses have been modified from the draft package, and a number of industry questions raised at or subsequent to the workshops have been added and answered. This package represents recent staff assessment of these questions and provides guidance as to acceptable methods of satisfying Commission regulatory requirements. Other methods proposed by licensees for complying with Commission regulations may also be satisfactory and will be considered on their own merits. To the extent that this guidance may be inconsistent with prior guidance (including Generic Letter 83-33), it is intended that the current letter takes precedence. If you have any questions, you should contact the NRC Project Manager for your facility. In the lettered sections below, some additional topics are covered which also bear on the interpretation and implementation of NRC fire protection requirements. The topics are: (A) schedular exemptions, (B) revised inspection program, (C) documentation required to demonstrate compliance, (D) quality assurance requirements applicable to fire protection systems, (E) notification of the NRC when deficiencies are discovered, and (F) addition of fire protection program into FSAR. A. Schedular Exemption The Appendix R implementation schedule was established by the Commission in 10 CFR 50.48(c), promulgated together with Appendix R in November of 1980. Allowing time to evaluate the need for alternative or dedicated shutdown systems, which require prior NRC approval before installation, and time for design of and NRC review of such systems, the Commission envisioned that implementation of Appendix R would be complete in 4 to 5 years, or approximately by the end of 1985. Many schedule extensions were granted by the - 2 - staff under the "tolling provision" 50.48(c)(6), and under 10 CFR 50.12, the longest of which now extends into 1987. Some licensees have proceeded expeditiously to implement Appendix R and are now finished or nearly finished with that effort. Others have engaged in lengthy negotiations with the staff while continuing to file requests for schedule extensions, and thereby have barely begun Appendix R modifications needed to comply with Section III.G and III.L. Schedule extension requests have been received seeking implementation dates of 1990 or beyond. As the 50.48(c) schedule was intended to be a one-time schedule commencing in the 1980-1982 time frame and ending in the 1985 time frame, extensions well beyond this schedule (particularly where major modifications remain to be completed) undermine the purpose of the schedule, which was to achieve expeditious compliance with NRC fire Protection requirements. For that reason, additional schedular exemptions may be requested under 10 CFR 50.12, but such requests will be granted sparingly based on the following criteria: 1. The utility has, since the promulgation of Appendix R in 1980, proceeded expeditiously to meet the Commission's requirements. 2. The delay is caused by circumstances beyond the utility's control. 3. The proposed schedule for completion represents a best effort under the circumstances. 4. Adequate interim compensatory measures will be taken until compliance is achieved. The NRC is currently reviewing all dockets of plants covered by the 50.48 schedule to determine schedule deadlines. When this review is completed, each licensee will be informed of the deadlines. B. Revised Inspection Program In 1982, the NRC developed an inspection program to verify compliance with the requirements of 10 CFR 50, Appendix R. This program was primarily oriented towards reviewing safe shutdown features of those pre-1979 licensees that had completed Appendix R modifications and selected NTOL plants. From 1982 to the present, a number of Appendix R compliance inspections have been performed. In many of the initial inspections it was found that licensees had made significant errors in implementing a number of Appendix R requirements. The NRC will continue to conduct inspection of fire protection features. In the case of completed modifications, the inspection team will review compliance with applicable requirements. In the case of incomplete modification, the inspection team will review licensee approach to compliance, plans and schedules for completing such modifications. The NRC will attempt to review implementation of fire protection features on a schedule that will minimize the chances of licensees implementing features in a manner that does not meet with staff approval. Additionally, requests for this review and/or inspection by licensees will be granted within NRC resource constraints. C. Documentation Required to Demonstrate Compliance The "Interpretations" document attached to this letter states that, where the licensee chooses not to seek prior NRC review and approval of, for example, a fire area boundary, an evaluation must be performed by a fire protection engineer (assisted by others as needed) and retained for future NRC audit. Evaluations of this type must be written and organized to facilitate review by a person not involved in the evaluation. Guidelines for what such an evaluation should contain may be found in: (1) Section B of Appendix R and (2) Section C.1.b of Branch Technical Position (BTP) CMEB 9.5-1 Rev. 2 dated July 1981. All calculations supporting the evaluation should be available and all assumptions clearly stated at the outset. The NRC intends to initiate enforcement action where, for a given fire area, compliance with Appendix R is not readily demonstrable and the licensee does not have available a written fire hazard analysis for the area. The term "readily demonstrable" includes situations where compliance is apparent by observation of the potential fire hazard and the existing protective features. D. Quality Assurance Requirements Applicable For fire protection systems the licensee should have and maintain a quality assurance program that provides assurance that the fire protection system will be designed, fabricated, erected, tested, maintained and operated so that they will function as intended. Fire protection systems are not "safety-related" and are therefore not within the scope of Appendix B to 10 CFR Part 50, unless the licensee has committed to include these systems under the Appendix B program for the plant. NRC guidance for an acceptable quality assurance program for fire protection systems, given in Section C.4 of Branch Technical Position CMEB 9.5-1 Rev. 2 dated July 1981, has generally been used in the review and acceptance of approved fire protection programs for plants licensed after January 1, 1979. For plants licensed prior to January 1, 1979, similar guidance was referenced in footnotes 3 and 4 to 10 CFR 50.48. They are contained in BTP APCSB 9.5-1 and Appendix A thereto and in "Nuclear Plant Fire Protection Functional Responsibilities, Administrative Control and Quality Assurance" dated June 14, 1977. E. Notification of the NRC When Deficiencies are Discovered Licensees are reminded of their obligation to notify the NRC of fire protection deficiencies which meet the criteria of 10 CFR 50.72 or 10 CFR 50.73 as applicable. F. Addition of Fire Protection Program into FSAR Most licenses contain a section on fire protection. License conditions for plants licensed prior to January 1, 1979, contain a condition requiring implementation of modifications committed to by the licensee as a result of the BTP review. These license conditions were added by amendments issued between 1977 and February 17, 1981, the effective date of 10 CFR 50.48 and Appendix R. - 4 - Two points should be noted in regard to these conditions: (1) they did not explicitly cover required fire protection features where modifications to the existing plant configuration or procedures were not required, and (2) some of the provisions in these conditions may have been superseded by Sections III.G, J, O, and L of Appendix R. License conditions for plants licensed after January 1, 1979 vary widely in scope and content. Some only list open items that must be resolved by a specified date or event, such as exceeding five percent power or the first refueling outage. Some reference a commitment to meet Appendix R; some reference the FSAR and/or the NRC staff's SER. These variations have created problems for licensees and for NRC inspectors in identifying the operative and enforceable fire protection requirements at each facility. These license conditions also create difficulties because they do not specify when a licensee may make changes to the approved program without requesting a license amendment. If the fire protection program committed to by the licensee is required by a specific license condition or is not part of the FSAR for the facility, the provisions of 10 CFR 50.59 may not be applied to make changes without prior NRC approval. Thus licensees may be required to submit amendment requests even for relatively minor changes to the fire protection program. The aforementioned problems, in general, exist because of the many submittals that constitute the fire protection program for each plant. The Commission believes that the best way to resolve these problems is to incorporate the fire protection program and major commitments, including the fire hazards analysis, by reference into the Final Safety Analysis Report (FSAR) for the facility. In this manner, the fire protection program, including the systems, the administrative and technical controls, the organization, and other plant features associated with fire protection would be on a consistent status with other plant features described in the FSAR. Also, the provisions of 10 CFR 50.59 would then apply directly for changes the licensee desires to make in the fire protection program that would not adversely affect the ability to achieve and maintain safe shutdown. In this context, the determination of the involvement of an unreviewed safety question defined in 150.59(a)(2) would be made based on the "accident.... previously evaluated" being the postulated fire in the fire hazards analysis for the fire area affected by the change. The Commission also believes that a standard license condition, requiring licensees to comply with the provisions of the fire protection program as described in the FSAR, should be used to ensure uniform enforcement of fire protection requirements. Therefore, each licensee should include, in the FSAR update required by 10 CFR 50.71(e) that will fall due more than 6 months after the date of this letter, the incorporation of the fire protection program that has been approved by the NRC, including the fire hazards analysis and major commitments that form the basis for the fire protection program. This incorporation may be by reference to specific previous submittals and the NRC approvals where appropriate. Upon completion of this effort, including the certification required by 10 CFR 50.71(e)(2), the licensee may apply for an amendment - 5 - to the operating license which amends any current license conditions regarding fire protection and substitutes the following standard condition: Fire Protection (Name of Licensee) shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility (or as described in submittals dated _____________) and as approved in the SER dated ____________(and Supplements dated ____________) subject to the following provision: The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. The licensee may alter specific features of the approved program provided (a) such changes do not otherwise involve a change in a license condition or technical specification or result in an unreviewed safety question (see 10 CFR 50.59), and (b) such changes do not result in failure to complete the fire protection program as approved by the Commission. As with other changes implemented under 10 CFR 50.59, the licensee shall maintain, in auditable form, a current record of all such changes, including an analysis of the effects of the change on the fire protection program, and shall make such records available to NRC Inspectors upon request. All changes to the approved program shall be reported annually to the Director of the Office of Nuclear Reactor Regulation, along with the FSAR revisions required by 10 CFR 50.71(e). Temporary changes to specific fire protection features which may be necessary to accomplish maintenance or modifications are acceptable provided interim compensatory measures are implemented. At the same time the licensee may request an amendment to delete the technical specifications that will now be unnecessary. Inclusion of the fire protection program in the FSAR will be a prerequisite for licensing for all now under review. The standard license condition will be included in new licenses. Sincerely, Darrell G. Eisenhut,Deputy Director Office of Nuclear Reactor Regulation Enclosures: 1. Interpretations of Appendix R 2. Appendix R Questions and Answers 3. Fire Protection License Condition ENCLOSURE 1 INTERPRETATIONS OF APPENDIX R 1. Process Monitoring Instrumentation Section III.L.2.d of Appendix R to 10 CFR Part 50 states that "the process monitoring function shall be capable of providing direct readings of the process variables necessary to perform and control" the reactivity control function. In I&E Information Notice 84-09, the staff provides a listing of instrumentation acceptable to and preferred by the staff to demonstrate compliance with this provision. While this guidance provides an acceptable method for compliance with the regulation, it does not exclude other alternative methods of compliance. Accordingly, a licensee may propose to the staff alternative instrumentation to comply with the regulation (e.g., boron concentration indication). While such a submittal is not an exemption request, it must be justified based on a technical evaluation. 2. Repair of Cold Shutdown Equipment Section III.L.5 of Appendix R states that when in the alternative or dedicated shutdown mode, "equipment and systems comprising the means to achieve and maintain cold shutdown conditions shall not be damaged by fire; or the fire damage to such equipment and systems shall be limited so that the systems can be made operable and cold shutdown can be achieved within 72 hours." This is not to be confused with the requirements in Section III.G.1.b of Appendix R. Section III.G.1.b contains the requirements for normal shutdown modes utilizing the control room or emergency control station(s) capabilities. The fire areas falling under the requirements of III.G.1.b are those for which an alternative or dedicated shutdown capability is not being provided. For these fire areas, Section III.G.1.b requires only the capability to repair the systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station(s) within 72 hours, not the capability to repair and achieve cold shutdown within 72 hours as required for the alternative or dedicated shutdown modes by Section III.L (noted above). With regard to areas involving normal shutdown, however, Section I of Appendix R states that repairs must be made using only onsite capabilities. After repairs are made, cold shutdown can be achieved on a reasonable schedule using any available power source. 3. Fire Damage Appendix R to 10 CFR Part 50 utilizes the term "free of fire damage." In promulgating Appendix R, the Commission has provided methods acceptable for assuring that necessary structures, systems and components are free of fire damage (see Section III.G.2a, b and c), that is, the structure, system or _____________ /*/ These interpretations represent staff positions, and should not be considered as official agency interpretations issued by the General Counsel. See 10 CFR 1.32; 10 CFR Part 8. - 2 - component under consideration is capable of performing its intended function during and after the postulated fire, as needed. Licensees seeking exemptions from Section III.G.2 must show that the alternative proposed provides reasonable assurance that this criterion is met. (Note also that Section III.G.2 applies only to equipment needed for hot shutdown. Therefore, an exemption from III.G.2 for cold shutdown equipment is not needed. The term "damage by fire" also includes damage to equipment from the normal or inadvertent operation of fire suppression systems. 4. Fire Area Boundaries The term "fire area" as used in Appendix R means an area sufficiently bounded to withstand the hazards associated with the area and, as necessary, to protect important equipment within the area from a fire outside the area. In order to meet the regulation, fire area boundaries need not be completely sealed floor-to-ceiling, wall-to-wall boundaries. However, all unsealed openings should be identified and considered the evaluating the effectiveness of the overall barrier. Where fire area boundaries are not wall-to-wall, floor-to-ceiling boundaries with all penetrations sealed to the fire rating required of the boundaries, licensees must perform an evaluation to assess the adequacy of fire boundaries in their plants to determine if the boundaries will withstand the hazards associated with the area. This analysis must be performed by at least a fire protection engineer and, if required, a systems engineer. Although not required, licensees may submit their evaluations for staff review and concurrence. However, if certain cable penetrations were identified as open SER items at the time Appendix R became effective, Section III.M of the rule applies (see 10 CFR 50.48(b)), and any variation from the requirements of Section III.M requires an exemption. In any event, these analyses must be retained by the licensees for subsequent NRC audits. 5. Automatic Detection and Suppression Sections III.G.2.b and III.G.2.c of Appendix R state that "In addition, fire detectors and automatic fire suppression system shall be installed in the fire area..." Other provisions of Appendix R also use the phrase "fire detectors and an automatic fire suppression system in the fire area..." (see e.g., Section III.G.2.e). In order to comply with these provisions, suppression and detection sufficient to protect against the hazards of the area must be installed. In this regard, detection and suppression providing less than full area coverage may be adequate to comply with the regulation. Where full area suppression and detection is not installed, licensees must perform an evaluation to assess the adequacy of partial suppression and detection to protect against the hazards in the area. The evaluation must be performed by a fire protection engineer and, if required, a systems engineer. Although not required, licensees may submit their evaluations to the staff for review and concurrence. In any event, the evaluations must be retained for subsequent NRC audits. Where a licensee is providing no suppression or detection, and exemption must be requested. - 3 - 6. Alternative or Dedicated Shutdown Section III.G.3 of Appendix R provides for "alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room, or zone under consideration." While "independence" is clearly achieved where alternative shutdown equipment is outside the fire area under consideration. this is not intended to imply that alternative shutdown equipment in the same fire area but independent of the room or the zone cannot result in compliance with the regulation. The "room" concept must be justified by a detailed fire hazards analysis that demonstrates a single fire will not disable both normal shutdown equipment and the alternative shutdown capability. ENCLOSURE 2 APPENDIX R QUESTIONS AND ANSWERS APPENDIX R QUESTIONS AND ANSWERS 1. INTRODUCTION 2. OVERVIEW 3. III G, FIRE PROTECTION OF SAFE SHUTDOWN CAPABILITY 3.1 Fire Area Boundaries 3.1.1 Fire Area Definition 3.1.2 Previously Accepted Fire Area Boundaries 3.1.3 Exterior Walls 3.1.4 Exterior Yards 3.1.5 Fire Zones 3.1.6 Documentation 3.2 Fire Barrier Qualifications 3.2.1 Acceptance Criteria 3.2.2 Deviations from Tested Configurations 3.2.3 Fire Door Modifications 3.3 Structural Steel 3.3.1 NFPA Approaches 3.3.2 Previously Accepted Structural Steel 3.3.3 Seismic Supports 3.3.4 Cable Tray Support Protection 3.4 Automatic Suppression System 3.4.1 Water Density 3.4.2 NRC Consultation 3.4.3 Sprinkler Location 3.4.4 Fixed Suppression System In Fire Area 3.4.5 Sprinkler Head Location 3.4.6 Previously Approved Suppression Systems 3.5 Separation of Redundant Circuits 3.5.1 Twenty-Foot Separation Criteria 3.5.2 Floor-to-Floor Separation 3.6 Intervening Combustibles 3.6.1 Negligible Quantities of Intervening Combustibles 3.6.2 In Situ Exposed Combustibles 3.6.3 Unexposed Combustibles APPENDIX R QUESTIONS & ANSWERS 1 3.7 Radiant Energy Shields 3.7.1 Fire Rating 3.8 Design Bases 3.8.1 Fire Protection Features NFPA Conformance 3.8.2 Design Basis Fire 3.8.3 Redundant Trains/Alternate Shutdown 3.8.4 Control Room Fire Considerations 4. III J, EMERGENCY LIGHTING 4.1 Illumination Levels 5. III L, ALTERNATIVE AND DEDICATED SHUTDOWN CAPABILITY 5.1 Safe and Alternative Shutdown 5.1.1 Previously Accepted Alternative Shutdown Capability 5.1.2 Pre-Existing Alternative Shutdown Capability 5.1.3 III L Backfit 5.2 Procedures 5.2.1 Shutdown and Repair Basis 5.2.2 Post Fire Operating Procedures 5.2.3 Alternative Shutdown Capability 5.2.4 Post Fire Procedures Guidance Documents 5.3 Safe Shutdown and Fire Damage 5.3.1 Circuit Failure Modes 5.3.2 "Hot Short" Duration 5.3.3 Hot Shutdown Duration 5.3.4 Cooldown Equipment 5.3.5 Pressurizer Heaters 5.3.6 On-Site Power 5.3.7 Torus Level Indication 5.3.8 Short Circuit Coordination Studies 5.3.9 Diagnostic Instrumentation 5.3.10 Design Basis Plant Transients 5.3.11 Alternate/Dedicated Shutdown vs. Remote Shutdown Systems 6. III 0, OIL COLLECTION SYSTEMS FOR REACTOR COOLANT PUMP 6.1 Lube Oil System Seismic Design 6.2 Container 7. BRANCH TECHNICAL POSITION CMEB 9.5-1 7.1 Fire Protection and Seismic Events 7.2 Random Fire and Seismic Events APPENDIX R QUESTIONS & ANSWERS 2 8. LICENSING POLICY 8.1 Fire Hazards Analysis/Fire Protection Plan Updating 8.2 Fire Protection License Condition 8.3 III G, J and O Exemptions for Future Modifications 8.4 Future Changes 8.5 Schedular and Blanket Exemptions 8.6 Trivial Deviations 8.7 Revised Modifications 8.8 Smallest Opening in a Fire Barrier 8.9 NFPA Code Deviations 8.10 "ASTM E-119" Design Basis Fire 8.11 Plants Licensed after January 1, 1979 8.12 Cold Shutdown Equipment Availability 8.13 Guidance Documents 8.14 Deviations from Guidance Documents 8.15 Staff Interpretations of Appendix R 8.16 Dissemination of New Staff Positions 8.17 Equivalent Alternatives 8.18 Coordination Study Updates 8.19 Exemption Request Threshold 8.19.1 Penetration Designs Not Laboratory Approved 8.19.2 Individual vs. Package Exemptions 8.19.3 Exemption Request Supporting Detail 8.19.4 50.12 vs. 50.48 Exemption Requests 8.20 Post January 1, 1979 Plants and Exemption Requests 8.21 NRC Approval for BTP CMEB 9.5-1 Deviations 9. INSPECTION POLICY 9.1 Safety Implications 9.2 Uniform Enforcement 9.3 NTOL Inspections 9.4 Future TI 2515/62 Revisions 9.5 Documentation Supplied by Licensee 9.6 Subsequent Inspections 9.7 NRC List of Conforming Items 9.8 Inspection Re-review 9.9 List of Shutdown Equipment APPENDIX R QUESTIONS & ANSWERS 3 1. INTRODUCTION A major fire damaging safe shutdown equipment occurred at the Browns Ferry Nuclear Station in March 1975. The fire damaged over 1600 electrical cables and caused the temporary unavailability of some core cooling systems. Because this fire did substantial damage, the NRC established a Special Review Group which initiated an evaluation of the need for improving the fire protection programs at all nuclear power plants. The group found serious design inadequacies regarding fire protection at Browns Ferry, and its report, "Recommendations Related to Browns Ferry Fire" (NUREG-0050, February 1976), contained over fifty recommendations regarding improvements in fire prevention and control in existing facilities. The report also called for the development of specific guidance for implementing fire protection regulations, and for a comparison of that guidance with the fire protection program at each operating plant. NRC developed technical guidance from the technical recommendations in the Special Group's report, and issued those guidelines as Branch Technical Position Auxiliary and Power Conversion Systems Branch 9.5-1 (BTP APCSB 9.5-1), 1/ "Guidelines for Fire Protection for Nuclear Power Plants." This guidance did not apply to plants docketed at that time. Guidance to operating plants was provided later in Appendix A 2/ to BTP APCSB 9.5-1 which, to the extent practicable, relies on BTP APCSB 9.5-1. In May 1976, the NRC asked licensees to compare operating reactors with BTP APCSB 9.5-1, and in September 1976, those licensees were informed that the guidelines in Appendix A would be used to analyze the consequences of a fire in each plant area. In September 1976 the licensees, were also requested to provide a fire hazards analysis that divided the plant into distinct fire areas and show that redundant systems required to achieve and maintain cold shutdown are adequately protected against damage by a fire. Early in 1977 each licensee responded with a Fire Protection Program Evaluation which included a Fire Hazard Analysis. These evaluations and analyses identified aspects of licensees' fire protection programs that did not conform to the NRC guidelines. ____________ 1/ Rather than serving as inflexible, legal requirements that must be followed by licensees, issuances such as regulatory guides and branch technical positions are meant to give guidance to licensees concerning those methods the staff finds acceptable for implementing the general criteria embodied in the NRC's rules. See, e.g., Petition for Emergency & Remedial Action, CLI-78-6, 7 NRC 400, 406 (1978); Gulf States Utilities Company (River Bend Station, Units 1 and 2) ALAB-444, 6 NRC 760, 772 (1977). 2/ Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976. APPENDIX R QUESTIONS & ANSWERS 1 Thereafter, the staff initiated discussions with all licensees aimed at achieving implementation of fire protection guidelines by October 1980. The staff held many meetings with licensees, conducted extensive correspondence with them, and visited every operating reactor. As a result, many fire protection items were resolved, and agreements were included in Fire Protection Safety Evaluation Reports issued by the NRC. Several fire protection issues remained unresolved with a number of licensees. By early 1980, most operating plants had implemented most of the guidelines in Appendix A. However, as the Commission noted in its Order of May 23, 1980, the fire protection program has had some significant problems with implementation. Despite the staff's efforts, several licensees had expressed continuing disagreement with, and refused to adopt recommendations relating to several generic issues, including the requirements for fire brigade size and training, water supplies for fire suppression systems, alternate and dedicated shutdown capability, emergency lighting, qualifications of seals used to enclose places where cables penetrated fire barriers, and the prevention of reactor coolant pump lubrication system fires. To establish a definitive resolution of these contested subjects in a manner consistent with the general guidelines in Appendix A to the BTP and to assure timely compliance by licensees, the Commission issued a proposed fire protection rule and its Appendix R, which was described as setting out minimum fire protection requirements for the unresolved issues (45 Fed. Req. 36082 May 29, 1980).3/ The fire protection features addressed included protection of safe shutdown capability, emergency lighting, fire barriers, associated circuits, reactor coolant pump lubrication system, and alternate shutdown systems. The Commission stated that it expected all modifications (except for alternate and dedicated shutdown capability) to be implemented by November 1, 1980.4/ As originally proposed (Federal Register Vol. 45 No. 1&5, May 22, 1980), Appendix R would have applied to all plants licensed prior to January 1, 1979 including those for which the staff had previously accepted other fire protection modifications. After analyzing comments on the rule, the Commission determined that only three of the fifteen items in Appendix R were of such safety significance that they should apply to all plants, including those for which alternative fire protection actions had been approved previously by the staff. These items are protection of safe shutdown capability (including alternate shutdown systems), emergency lighting, and the reactor coolant pump lubrication system. Accordingly, the final rule required all reactors licensed to operate before January 1, 1979, to comply with these three items even if the NRC had previously approved alternative fire protection features in these areas (45 Fed. Reg. 76602 Nov. 19, 1980). However, the final rule is more flexible than the proposed rule because Item III.G now provides three alternative fire protection features which do not require analysis to demonstrate the protection of redundant safe shutdown equipment, and reduces the acceptable distance in the physical separation alternative from fifty feet to twenty feet. In addition, the rule now also provides an exemption procedure which can be initiated by a licensee's assertion that any required fire protection feature will not enhance fire protection safety in the facility or that such modifications may be detrimental to overall safety (10 CFR 50.48(c)(6)). If the Director, Nuclear Reactor Regulation determines _______________________ 3/11 NRC 707, 718 (1980) 4/Id. at 719 APPENDIX R QUESTIONS & ANSWERS 2 that a licensee has made a prima facie showing of a sound technical basis for such an assertion, then the implementation dates of the rule are tolled until final Commission action on the exemption request. Most licensees requested and were granted additional time to perform their reanalysis, propose modifications to improve post fire shutdown capability and to identify exemptions for certain fire protection configurations. In reviewing some exemption requests, the staff noted that some licensees had made significantly different interpretations of certain requirements. These differences were identified in the staff's draft SER's. These differences were also discussed on several occasions with the cognizant licensee as well as the Nuclear Utility Fire Protection Group. These discussions culminated in the issuance of generic letter 83-33. 2. OVERVIEW Section 50.48 Fire Protection of 10 CFR Part 50 requires that each operating nuclear power plant have a fire protection plan that satisfies General Design Criterion 3 of Appendix A to 10 CFR 50. It specifies what should be contained in such a plan and lists the basic fire protection guidelines for this plan. It requires that the Fire Protection Safety Evaluation Report which has been issued for each operating plant state how these guidelines were applied to each facility. Section 50.48 also requires that all plants with operating licenses prior to January 1, 1979 satisfy the requirements of Section III.6, III.J and III.O, and other Sections of Appendix R where approval of similar features had not been obtained prior to the effective date of Appendix R. By a separate action, the Commission approved the staff's requirement that all plants to receive their operating license after January 1, 1979 also satisfy the requirements of Sections III.G, III.J and III.O and that a fire protection license condition be established. Deviations from Appendix R requirements for pre-1979 plants are processed under the exemption process. Deviation from other guidelines are identified and evaluated in the Safety Evaluation Report. A standard fire protection license condition has been developed and will be included in each new operating license. Holders of operating licenses will be encouraged to adopt the standard license condition. The Regions initiated inspections of operating plants and identified several significant items of non-compliance. The Nuclear Utility Fire Protection group requested interpretations of certain Appendix R requirements and provided a list of questions that they thought should be discussed with the industry. The NRC held workshops in each Region to assist the industry in understanding the NRC's requirements and to improve the Staff's understanding of the industry's concerns. This document presents the NRC's response to the questions posed by the industry and supplemented with additional questions identified at the workshops as being of interest to the industry or the staff. These responses may be used as guidance for design, review and inspection activities. The questions have been reformatted according to their applicability to Sections of Appendix R, BTP CMEB 9.5-1, licensing policy or inspection policy. APPENDIX R QUESTIONS & ANSWERS 3 3. SECTION III G, FIRE PROTECTION OF SAFE SHUTDOWN CAPABILITY 3.1 Fire Area Boundaries 3.1.1 Fire Area Definition QUESTION Section III.G states the fire protection features required for cables and equipment or redundant trains of systems required to achieve and maintain hot shutdown that are located within the same fire area. Is the fire area of Section III.G, the same fire area referred to in BTP APCSB 9.5-1, Appendix A; and the supplementary guidance of September 1976? RESPONSE The definition of a fire area given in the BTP is somewhat more restrictive than that given in Section #4 of the "Interpretations of Appendix R." Clearly, where a licensee has reviewed its facility using the BTP criteria, this would meet Appendix R requirements. The BTP criteria may continue to be used as guidance, but the minimum requirements for fire area boundaries are set out in Section #4 of the "Interpretations." 3.1.2 Previously Accepted Fire Area Boundaries QUESTION If a fire area boundary was described as a rated barrier in the 1977 fire hazards analysis (FHA), no open items existed in this area in the Appendix A SER, and the barriers have not been altered, then need those barriers be reviewed by licensees or the Staff under Appendix R? RESPONSE If a fire area boundary was described as a rated barrier in the 1977 fire hazards analysis, and was evaluated and accepted in a published SER, the fire area boundary need not be reviewed as part of the re-analysis for compliance with Section III.G of Appendix R. Openings in the fire barriers, if any, should have been specifically identified and justified in the fire hazards analysis performed in the Appendix A process. If openings in the fire area boundaries were not previously evaluated, such an evaluation should be performed as a basis for assessing compliance with Appendix R. See Items #4 and #6 of the "Interpretations of Appendix R," and the response to question 3.1.1. In BTP APCSB 9.5-1, Fire Barrier is defined as: "Fire Barrier - those components of construction (walls, floors, and roofs) that are rated by approving laboratories in hours for resistance to fire to prevent the spread of fire. The term "fire area" as used in Appendix R means an area sufficiently bounded to withstand the hazards associated with the fire area and, as necessary, to protect important equipment within the fire area from a fire outside the area. In order to meet the regulation, fire area boundaries need not be completely APPENDIX R QUESTIONS & ANSWERS 4 sealed with floor to ceiling and/or wall-to-wall boundaries. Where fire area boundaries were not approved under the Appendix A process, or where such boundaries are not wall-to-wall or floor-to-ceiling boundaries with all penetrations sealed to the fire rating required of the boundaries, licensees must perform an evaluation to assess the adequacy of fire area boundaries in their plants to determine if the boundaries will withstand the hazards associated with the area and protect important equipment within the area from a fire outside the area. This analysis must be performed by at least a fire protection engineer and, if required, a systems engineer. Although not required, licensees may submit their evaluations for Staff review and concurrence. In any event, these analyses must be retained by the licensees for subsequent NRC audits. 3.1.3 Exterior Wall's QUESTION Must exterior walls to buildings and their penetrations be qualified as rated barriers? RESPONSE Exterior walls and their penetrations should be qualified as rated barriers when (l) they are required to separate a shutdown-related division(s) inside the plant from its redundant (alternate) counterpart outside the plant in the immediate vicinity of the exterior wall, (2) they separate safety related areas from non-safety related areas that present a significant fire threat to the safety related areas, or (3) they are designated as a fire barrier in the FSAR or FHA. Usually exterior walls are designated as a fire area boundary; therefore, they are evaluated by the guidelines of Appendix A. A FHA should be performed to determine the rating of exterior walls, if required by the above criteria. 3.1.4 Exterior Yards QUESTION How should a utility define the boundaries of fire areas comprising exterior yards? RESPONSE An exterior yard area without fire barriers should be considered as one fire area. The area may consist of several fire zones. The boundaries of the fire zones should be determined by a FHA. The protection for redundant/alternate shutdown systems within a yard area would be determined on the bases of the largest "design basis fire" (see response to question 3.8.2) that is likely to occur and the resulting damage. The boundaries of such damage would have to be justified with a fire hazards analysis. The analysis should consider the degree of spatial separation between divisions; the presence of in-situ and transient combustibles, including vehicular traffic; grading; available fire protection; sources of ignition; and the vulnerability and criticality of the shutdown related systems. See Sections #3, #4 and #6 of the "Interpretations of Appendix R." APPENDIX R QUESTIONS & ANSWERS 5 3.1.5 Fire Zones QUESTION Appendix R, Section III.G.3 states "alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area room or zone under consideration...." What is the implied utilization of a room or zone concept under Section III.G of Appendix R? The use of the phraseology "area, room or zone under consideration" is used again at the end of the Section III.G.3. Does the requirement for detection and fixed suppression indicate that the requirement can be limited to a fire zone rather than throughout a fire area? Under what conditions and with what caveats can the fire zone concept be utilized in demonstrating conformance to Appendix R? RESPONSE Section III.G was written after NRC's multi-discipline review teams had visited all operating power plants. From these audits, the NRC recognized that it is not practical and may be impossible to subdivide some portions of an operating plant into fire areas. In addition, the NRC recognized that in some cases where fire areas are designated, it may not be possible to provide alternate shutdown capability independent of the fire area and, therefore, would have to be evaluated on the basis of fire zones within the fire area. The NRC also recognized that because some licensees had not yet performed a safe shutdown analysis, these analyses may identify new unique configurations. To cover the large variation of possible configurations, the requirements of Section III.G were presented in three Parts: Section III.G.l requires one train of hot shutdown systems be free of fire damage and damage to cold shutdown systems be limited. Section III.G.2 provides certain separation, suppression and detection requirements within fire areas; where such requirements are met, analysis is not necessary. Section III.G.3 requires alternative dedicated shutdown capability for configurations that do not satisfy the requirements of III.G.2 or where fire suppressants released as a result of fire fighting, rupture of the system or inadvertent operation of the system may damage redundant equipment. If alternate shutdown is provided on the basis of rooms or zones, the provision of fire detection and fixed suppression is only required in the room or zone under consideration. Section III.G recognizes that the need for alternate or dedicated shutdown capability may have to be considered on the basis of a fire area, a room or a fire zone. The alternative or dedicated capability should be independent of the fire area where it is possible to do so (See Supplementary Information for the final rule Section III.G). When fire areas are not designated or where it is not possible to have the alternative or dedicated capability independent of the fire area, careful consideration must be given to the selection and location of the alternative or dedicated shutdown capability to assure that the performance requirement set forth in Section III.G.l is met. Where alternate or dedicated shutdown is provided for a room or zone, the capability must be physically and APPENDIX R QUESTIONS & ANSWERS 6 electrically independent of that room or zone. The vulnerability of the equipment and personnel required at the location of the alternative or dedicated shutdown capability to the environments produced at that location as a result of the fire or fire suppressant's must be evaluated. These environments may be due to the hot layer, smoke, drifting suppressants, common ventilation systems, common drain systems or flooding. In addition, other interactions between the locations may be possible in unique configurations. If alternate shutdown is provided on the basis of rooms or zones, the provision of fire detection and fixed suppression is only required in the room or zone under consideration. Compliance with Section III.G.2 cannot be based on rooms or zones. See also Sections #5 and #6 of the "Interpretations of Appendix R." 3.1.6 Documentation QUESTION In Generic Letter 83-33 at pg. 2, the NRC Staff referred to the guidance in Appendix A to BTP 9.5-1 to establish the rating of the barrier. What level of documentation must be provided to verify that the fire area meets the requirements of Appendix R? RESPONSE The documentation required to verify the rating of a fire barrier should include the design description of the barrier and the test reports that verify its fire rating. Reference can be made to UL listed designs. 3.2 Fire Barrier Qualification 3.2.1 Acceptance Criteria QUESTION Recently the Staff has applied a 325 F cold side temperature criterion to its evaluation of the acceptability of one-hour and three-hour fire barrier cable tray wraps. This criterion is not in Branch Technical Position (BTP) APCSB 9.5-1, Appendix A as an acceptance criterion for fire barrier cable tray wraps and is not contained in Appendix R. It appears to represent post-Appendix R guidance. What is the origin of this criterion and why is it applicable to electrical cables where insulation degradation does not begin until jacket temperatures reach 450 F to 650 F? RESPONSE Fire barriers relied upon to protect shutdown related systems to meet the requirements of III.G.2 need to have a fire rating of either one or three hours. 50.48 references BTP APCSB 9.5-1, where the fire protection definitions are found. Fire rating is defined: "Fire Rating - the endurance period of a fire barrier or structure; it defines the period of resistance to a standard fire exposure before the first critical point in behavior is observed (see NFPA 251)." APPENDIX R QUESTIONS & ANSWERS 7 The acceptance criteria contained in Chapter 7 of NFPA 251, "Standard Methods of Fire Tests of Building Construction and Materials," pertain to non-bearing fire barriers. These criteria stipulate that transmission of heat through the barrier "shall not have been such as to raise the temperature on its unexposed surface more than 250 F above its initial temperature." The ambient air temperature at the beginning of a fire test usually is between 50 F and 90 F. It is generally recognized that 75 F represents an acceptable norm. The resulting 325 F cold side temperature criterion is used for cable tray wraps because they perform the fire barrier function to preserve the cables free of fire damage. It is clear that cable that begins to degrade at 450 F is free of fire damage at 325 F. During the Appendix A review, licensees began to propose fire barriers to enclose cable trays, conduit, fuel lines, coolant lines, etc. Industry did not have standard rating tests for such components or for electrical, piping or bus duct penetrations. The NRC issued a staff position giving acceptance criteria for electrical penetration tests. These criteria require an analysis of any temperature on the unexposed side of the barrier in excess of 325 F. In the past, manufacturers designed their own qualification tests. Nuclear Insurers, and the Institute of Electrical and Electronic Engineers have issued tests for some of these components. These tests usually exposed the component to the ASTM E-119 time temperature curve, but all had different acceptance criteria. Conduit and cable tray enclosure materials accepted by the NRC as 1 hour barrier prior to Appendix R (e.g. some Kaowool and 3M materials) and already installed by the licensee need not be replaced even though they may not have met the 325 F criteria. However, for newly identified conduit and cable trays requiring such wrapping new material which meets the 325 F criterion should be used, or justification should be provided for use of material which does not meet the 325 F criterion. This may be based on an analysis demonstrating that the maximum recorded temperature is sufficiently below the cable insulation ignition temperature. 3.2.2 Deviations from Tested Configurations QUESTION Due to obstructions and supports, it is often impossible to achieve exact duplication of the specific tested configuration of the one-hour fire barriers which are to be placed around either conduits or cable trays. For each specific instance where exact replication of a previously tested configuration is not and cannot be achieved, is an exemption necessary in order to avoid a citation for a violation? RESPONSE No. Where exact replication of a tested configuration cannot be achieved, the field installation should meet all of the following criteria: 1. The continuity of the fire barrier material is maintained. 2. The thickness of the barrier is maintained. 3. The nature of the support assembly is unchanged from the tested configuration. APPENDIX R QUESTIONS & ANSWERS 8 4. The application or "end use" of the fire barrier is unchanged from the tested configuration. For example, the use of a cable tray barrier to protect a cable tray which differs in configuration from those that were tested would be acceptable. However, the use of structural steel fire proofing to protect a cable tray assembly may not be acceptable. 5. The configuration has been reviewed by a qualified fire protection engineer and found to provide an equivalent level of protection. 3.2.3 Fire Door Modifications QUESTION Where labeled and rated fire doors have been modified to incorporate security hardware or for flooding protection, is an exemption from Appendix R required? RESPONSE Where a door is part of a fire area boundary, and the modification does not effect the fire rating (for example, installation of security "contacts"), no further analysis need be performed. If the modifications could reduce the fire rating (for example, installation a vision panel), the fire rating of the door should be reassessed to ensure that it continues to provide adequate margin considering the fire loading on both sides. Since this reassessment pertains to the establishment of a valid fire area boundary, an exemption is not required. See Section #4 of the "Interpretations of Appendix R." 3.3 Structural Steel 3.3.1 NFPA Approaches QUESTION Does the NRC's definition of structural steel supporting fire barriers completely accommodate approaches described in NFPA guidance documents and standards? RESPONSE The NRC does not define the structural steel supporting fire barriers. This steel is identified by the licensee. Our position regarding the need to protect the structural steel, which forms a part of or supports fire barriers, is consistent with sound fire protection engineering principles as delineated in both NFPA codes and standards, and The Fire Protection Handbook. 3.3.2 Previously Accepted Structural Steel QUESTION Is it necessary to protect structural steel in existing fire barriers where those barriers were approved in an Appendix A SER? RESPONSE No. APPENDIX R QUESTIONS & ANSWERS 9 3.3.3 Seismic Supports QUESTION Does structural steel whose sole purpose is to carry dynamic loads from a seismic event require protection in accordance with Section III.G.2a of Appendix R? RESPONSE No, unless the failure of any structural steel member due to a fire could result in significant degradation of the fire barrier. Then it must be protected. 3.3.4 Cable Tray Support Protection QUESTION Should cable tray supports be protected if there is a sprinkler system in the fire area? Under what conditions may cable tray supports be unprotected? Do unprotected supports require an exemption? RESPONSE In general, cable tray supports should be protected, regardless of whether there is a sprinkler system. However, they need not be protected if (1) the qualification tests were performed on wrapped cable trays with unprotected supports, and the supports are shown to be adequate, or (2) an analysis is performed, which takes into account the fire loading and automatic suppression available in the area, and which demonstrates that the unprotected support(s) will not fail and cause a loss of the cable tray fire barrier required for the postulated fire. An exemption is not required; however, the qualification tests and applicability or the structural evaluation should be documented and available for audit. 3.4 Automatic Suppression System 3.4.1 Water Density QUESTION Staff guidance provided in Generic Letter 83-33* concerning automatic suppression coverage of fire areas interprets the phrase "in the fire area" in Section III.G as meaning "throughout the fire area." What delivered water density or occupancy standard as specified in NFPA-STD-13 must be achieved to meet this guidance? RESPONSE Individual plant areas are diverse in nature. The designer should determine the particular water density or occupancy classification. Those areas which contain a limited quantity of in-situ and anticipated transient combustibles ________________ *Superseded by Generic Letter 85-01, however the response to the question is useful for other considerations. APPENDIX R QUESTIONS & ANSWERS 10 and which feature contents such as tanks and piping, may be considered as "Ordinary Hazard (Group 1)," as defined by NFPA Standard No. 13. For those areas containing large amounts of cables or flammable liquids, an occupancy classification of "Extra Hazard" may be warranted. The decision as to which classification should be applied should be made by a qualified fire protection engineer. Once the occupancy classification is determined, the minimum water density should be based on the Density Curves in table 2.2.1(B) of NFPA 13. Any density equal to or in excess of the curves would be in conformance with our guidelines as delineated in Section C.6.c of BTP CMEB 9.5-1. 3.4.2 NRC Consultation QUESTION Section 4.1.2 of NFPA-STD-13 allows for "partial installations" or partial coverage. The standard states that "the authority having jurisdiction shall be consulted in each case." With the NRC as authority in this instance, must consultation occur only through the exemption process? RESPONSE No. The staff is always available to consult with utility representatives and provide guidance as to the acceptability of a particular fire protection configuration in individual plant areas. See also Section #5 of the "Interpretations of Appendix R." 3.4.3 Sprinkler Location QUESTION How does a suppression system designer know whether the term "throughout the area" means that sprinkler heads must be above or below cable trays when, in his judgment, the hazard of concern is a floor based fire? RESPONSE Section C.6.c(3) of BTP CMEB 9.5-1 states: "(3) Fixed water extinguishing systems should conform to requirements of appropriate standards such as NFPA-13, "Standard for the Installation of Sprinkler Systems," and NFPA-15, "Standard for Water Spray Fixed Systems". This question pertains to those sprinkler systems covered by NFPA-13. Chapter 4 of NFPA-13 provides guidance as to the location of sprinkler heads in relation to common obstructions. In general, to achieve complete area wide coverage, sprinklers should be located at the ceiling, with additional sprinklers provided below significant obstructions such as wide HVAC ducts and "shielded" or solid bottom stacked cable trays. To the extent that an existing or proposed sprinkler system design deviates from this concept, the design would have to be justified by a fire hazards analysis. See also Section #5 of the "Interpretations of Appendix R." APPENDIX R QUESTIONS & ANSWERS 11 3.4.4 Fixed Suppression System In Fire Area QUESTION Are fixed suppression systems required by Section III G.3 to be throughout the fire area, room or zone under consideration? RESPONSE No, but partial coverage must be properly justified and documented. See Item #5 of the "Interpretations of Appendix R." "...suppression less than full area coverage may be adequate to comply with the regulation. Where full area suppression and detection is not installed, licensees must perform an evaluation to assess the adequacy and necessity of partial suppression and detection in an area. The evaluation must be performed by a fire protection engineer and, if required, a systems engineer. Although not required, licensees may submit their evaluations to the staff for review and concurrence. In any event, the evaluations must be retained for subsequent NRC audits..." 3.4.5 Sprinkler Head Location QUESTION If stacks of horizontal or vertical cable trays extend from ceiling to floor, are sprinkler heads required (1) under the lowest horizontal trays, near the floor for vertical trays; (2) at some intermediate level between the floor and ceiling, and (3) at the ceiling? RESPONSE Sprinkler heads should be located at the ceiling. Sprinkler heads at other locations may be necessary depending upon the hazard and the cumulative effect of the obstructions to the discharge of water from the sprinkler head. The sprinkler system design should meet NFPA 13. 3.4.6 Previously Approved Suppression Systems QUESTION Must suppression systems approved and installed under BTP APCSB 9.5-1. Appendix A be extended or altered to meet the total area requirements of Section III.G (as interpreted by the Staff) or does this "requirement" only apply to new installations? RESPONSE Suppression systems installed in connection with Appendix A may or may not have to be extended as a result of III.G. The licensee must analyze each area where suppression is required by III.G, and where only partial suppression has been provided, determine if the coverage is adequate for the fire hazard in the area. The licensee may consult with the staff during this review. In any event, the APPENDIX R QUESTIONS & ANSWERS 12 Appendix R analysis showing that the suppression provided is adequate must be retained and available for NRC audit. See also Section #5 of the "Interpretations of Appendix R." 3.5 Separation of Redundant Circuits 3.5.1 Twenty-Foot Separation Criteria QUESTION Assuming that a licensee is utilizing the 20-foot separation for circuit protection, could an exemption request be granted for a portion of the circuit that did not maintain the 20-foot minimum separation if that portion was protected by one-hour barrier until 20-foot was achieved? This barrier would not be firewall-to-firewall, and the circuit protection would not be claimed under the one-hour barrier rule. RESPONSE With the erection of a partial qualified one-hour rated barrier for portions of the circuits with less than 20 ft. separation, if 20 feet of horizontal separation existed between the redundant unprotected portions of the circuits without intervening combustibles or fire hazards, and if the fire area was protected by automatic fire detection and suppression, compliance with Section III.G.2.b would be achieved. These types of configuration have to be evaluated on a case-by-case basis by the NRC. 3.5.2 Floor-to-Floor Separation QUESTION Where redundant circuits are separated by floor elevation but are within the same fire area due to open hatchways, stairs, etc., what is the NRC's position with regard to separation criteria? If train A is located twenty feet from an open hatchway on the lower elevation and train B is located ten feet from the same opening on the next elevation, would this be considered adequate separation? RESPONSE If a wall or floor/ceiling assembly contains major unprotected openings such as hatchways and stairways, then plant locations on either side of such a barrier must be considered as part of a single fire area. Refer to Section #4 of the "Interpretations of Appendix R." As to the example provided, if train A was separated by a cumulative horizontal distance of 20 feet from train B, with no intervening combustible materials or fire hazards, and both elevations were provided with fire detection and suppression, the area would be in compliance with Section III.G.2.b. APPENDIX R QUESTIONS & ANSWERS 13 3.6 Intervening Combustibles 3.6.1 Negligible Quantities of Intervening Combustibles QUESTION Twenty feet of separation with absolutely no intervening combustibles is a rare case in most nuclear plants. What is the most acceptable method of addressing intervening combustibles? How are various utilities addressing this subject, and what would be sufficient justification to support an exemption request? RESPONSE If more than negligible quantities of combustible materials (such as isolated cable runs) exist between redundant shutdown divisions, an exemption request should be filed. [Negligible quantity" is an admittedly judgmental criterion, and this judgment should be made by a qualified fire protection engineer and documented for later NRC audit.] Justifications for such exemptions have been based on the following factors: 1. A relatively large horizontal spatial separation between redundant divisions; all cables qualified to IEEE-383. 2. The presence of an automatic fire suppression system over the intervening combustible (such as a cable tray fire suppression system); 3. The presence of fire stops to inhibit fire propagation in intervening cable trays; 4. The likely fire propagation direction of burning intervening combustibles in relation to the location of the vulnerable shutdown division; 5. The availability of compensating active and passive fire protection. Any future changes in the cable configuration due to modifications could be handled under 50.59. See the provisions of the license condition in the response to question 8.2. 3.6.2 In-Situ Exposed Combustibles QUESTIONS Within Appendix R, Section III.G.2.b, the phrase "twenty feet with no intervening combustible or fire hazards" is utilized. What is the definition of "no intervening combustible?" Is the regulation focused predominantly on the absence of fixed combustibles? RESPONSE There is no specific definition of "no intervening combustible." The regulation is focused on the absence of in-situ exposed combustibles. Non combustible materials would not be considered as intervening combustibles. In BTP CMEB 9.5-1, noncombustible material is defined as: APPENDIX R QUESTIONS & ANSWERS 14 "Noncombustible Material a. A material which in the form in which it is used and under the conditions anticipated, will not ignite, burn, support combustion, or release flammable vapors when subjected to fire or heat. b. Material having a structural base of noncombustible material, as defined in a., above, with a surfacing not over 1/8-inch thick that has a flame spread rating not higher than 50 when measured using ASTM E-84 Test "Surface Burning Characteristics of Building Materials." In Generic Letter 83-33, we state: "Staff Position: Section III.G.2.b requires the "separation ...with no intervening combustibles ..." To meet this requirement, plastic jackets and insulation of grouped electrical cables, including those which are coated, should be considered as intervening combustibles." For fire protection, "no intervening combustibles" means that there is no significant quantities of in-situ materials which will ignite and burn located between redundant shutdown systems. The amount of such combustibles that has significance is a judgmental decision. As with other issues, if the licensees fire protection engineer is concerned that the quantity of combustibles between shutdown divisions may not be considered insignificant by an independent reviewer, an exemption could be requested or the staff consulted. Transient materials are not considered as an intervening combustible; however, they must be considered as part of the overall fire hazard within an area. Cables that are in cable trays which are either open or fully enclosed should also be considered as intervening combustibles. Cables coated with a fire retardant material are also considered as intervening combustibles. However, cables coated with a fire retardant material, or cables in cable trays having solid sheet metal bottom, sides and top, if protected by automatic fire detection and suppression systems and if the design is supported by a fire hazards analysis, have been found acceptable under the exemption process. 3.6.3 Unexposed Combustibles QUESTION Are unexposed combustibles, such as oil in sumps, closed cans, or sealed drums, or electrical cable in conduits, considered as "intervening combustibles?" RESPONSE Only oil in closed containers which are in accordance with NFPA 30 or electrical cables in metal conduits are not considered as intervening combustibles. In situ oil in open sumps is considered to be an intervening combustible; in-situ oil in closed sumps equivalent to NFPA Standard-30 containers is not considered to be an intervening combustible. APPENDIX R QUESTIONS & ANSWERS 15 Radiant Energy Shield 3.7.1 Fire Rating QUESTION Recently, the NRC Staff indicated that non-combustible radiant energy shields should be tested against ASTM-TD-E-119 based, apparently, on the requirements of BTP CMEB 9.5-1, Rev. 3, a document issued after Appendix R was promulgated. This new requirement would not appear to be required by Appendix R or BTP APCSB 9.5-1 Appendix A. Could the Staff clarify the requirements in this area? RESPONSE During the Appendix A reviews, we observed that inside some containments, there were large concentrations of cables converging at electrical penetration areas. In some cases, where the penetrations were grouped by division, shields were placed between the divisions so that radiant energy from a fire involving the cables of one division would not degrade or ignite cables of the other divisions. These shields also directed the convective energy from the fire away from the surviving division. These shields were usually constructed of 1/2-inch marinite board in a metal frame. Appendix R, Section III.G.f refers to these shields as "a noncombustible radiant energy shield." The guidelines in BTP CMEB 9.5-1, Section C.7.a(1)b. indicate that these shields should have a fire rating of 1/2 hour. In our opinion any material with a 1/2 hour fire rating should be capable of performing the required function. The guidelines of BTP CMEB 9.5-1 relating to a fire-rated radiant energy shield are being considered in our current reviews of NTOL plants. However, to the extent that an applicant can justify that a proposed radiant energy shield can achieve an equivalent level of safety, we have been accepting shields that have not been tested against the acceptance criteria of ASTM E-119. In our Appendix R reviews, we have accepted non-fire-rated radiant energy shields that have been demonstrated by fire hazards analysis to provide an acceptable level of protection against the anticipated hazard of a localized fire within the containment. We have also accepted fire-rated metal-sheathed mineral insulated cables, as a radiant energy shield in specific configurations. 3.8 Design Bases 3.8.1 Fire Protection Features NFPA Conformance QUESTION Should the fire protection features required by Section III.G conform to the NFPA Codes? RESPONSE Yes. For example, Section III G.2 requires an automatic suppression system. Our guidelines would recommend that the systems be in accordance with an NFPA Code. If deviations are made from the Code, they should be identified in the FSAR or FHA. APPENDIX Q QUESTIONS & ANSWERS 16 3.8.2 Design Basis Fire QUESTION Why isn't the industry allowed to design to protect against a design basis fire? RESPONSE Neither the industry nor the Staff has been able to develop criteria for establishing design basis fire conditions for a single "design basis fire" because the in-situ and potential transient combustibles vary widely in different areas of the plant. However, the establishment of a specific "design basis fire" for individual fire areas or zones is a prerequisite to performance of a valid fire hazards analysis (See Appendix R Section II.B(l) and BTP CMEB 9.5-1 Sections C.b(1) and (2)). 3.8.3 Redundant Trains/Alternate Shutdown QUESTION Confusion exists as to what will be classified as an alternate shutdown system and thus what systems might be required to be protected by suppression and detection under Section III.G.3.b. For example, while we are relying upon the turbine building condensate system for a reactor building fire and the RHR system for a turbine building fire, would one system be considered the alternative to the other. If so, would suppression and detection be required for either or both systems under III.G.3.b? An explanation of alternative shutdown needs to be advanced for all licensees. RESPONSE If the system is being used to provide its design function, it generally is considered redundant. If the system is being used in lieu of the preferred system because the redundant components of the preferred system does not meet the separation criteria of Section III.G.2, the system is considered an alternative shutdown capability. Thus, for the example above, it appears that the condensate system is providing alternative shutdown capability in lieu of separating redundant components of the RHR System. Fire detection and a fixed fire suppression system would be required in the area where separation of redundant components of the RHR system is not provided. However, in the event of a turbine building fire, the RHR system would be used for safe shutdown and is not considered an alternative capability. However, one train of the RHR system must be separated from the turbine building. 3.8.4 Control Room Fire Considerations QUESTION What considerations should be taken into account in a control room fire? What is the damage that is considered? What actions can the operators take before evacuating the CR? When can the control room be considered safe after a fire for the operator to return? APPENDIX R QUESTIONS & ANSWERS 17 RESPONSE The control room fire area contains the controls and instrumental redundant shutdown systems in close proximity (i.e. usually separation is a few inches). Because it is possible to provide shutdown capability that is physically and electrically independent of the fire area, it is our opinion that alternative or dedicated shutdown capability and its associated circuits for the control room be independent of the cables system and components in the control room fire area. The damage to the system in the control room for a fire that causes evacuation of the control room cannot be predicted. A bounding analysis should be made to assure that safe conditions can be maintained from outside the control room. This analysis is dependent to the specific design. The usual assumption are: 1. The reactor is tripped in the control room. 2. Offsite power is lost as well as automatic starting of the onsite a.c. generators and the automatic function of valves and pumps whose control circuits could be affected by a control room fire. The analysis should demonstrate that capability exists to manually achieve safe shutdown conditions from outside the control room by restoring a.c. power to designated pumps, assuring that valve lineup is correct, and assuming that any malfunctions of valves that permit the loss of reactor coolant can be corrected before unrestorable conditions occur. Note that the only manual action in the control room prior to evacuation usually given credit for is the reactor trip. For any additional control room actions deemed necessary prior to evacuation, a demonstration of the capability of performing such actions would have to be provided. Additionally, assurance would have to be provided that such actions could not be negated by subsequent spurious actuation signals resulting from the postulated fire. After the fire, the operators could return to the control room when the following conditions have been met: 1. The fire has been extinguished and so verified by appropriate fire protection personnel. 2. The control room has been deemed habitable by appropriate fire protection personnel and the shift supervisor. 3. Damage has been assessed and, if necessary, corrective action has been taken to assure necessary safety, control and information systems are functional (some operators may assist with these tasks) and the shift supervisor has authorized return of plant control to the control room. 4. Turnover procedures which assure an orderly transfer of control from the alternate shutdown panel to the control room has been completed. After returning to the control room, the operators can take any actions compatible with the condition of the control room. Controls in any area (cabinet where the fire occurred would not be available. Smoke and fire suppressant APPENDIX R QUESTIONS & ANSWERS 18 damage in other areas (cabinets) must also be assessed and corrective action taken before controls in such cabinets are deemed functional. Controls in undamaged area (cabinets) could be operated as required. Minor modifications inside the control room may be performed to reach cold shutdown. 4. EMERGENCY LIGHTING 4.1 Illumination Levels QUESTION What is the requisite intensity level for emergency lighting for egress routes and areas where shutdown functions must be performed? What are the bases for determining these levels of lighting? RESPONSE The level of illumination provided by emergency lighting in access routes to and in areas where shutdown functions must be performed is a level that is sufficient to enable an operator to reach that area and perform the shutdown functions. At the remote shutdown panels the illumination levels should be sufficient for control panel operators. The bases for estimating these levels of lighting are the guidelines contained in Section 9.5.3 of the Standard Review Plan, which are based on industry standards (i.e., Illuminating Engineering Society Handbook). Where a licensee has provided emergency lighting per Section III.J Appendix R, we would expect that the licensee verify by field testing that this lighting is adequate to perform the intended tasks. 5. ALTERNATIVE AND DEDICATED SHUTDOWN CAPABILITY 5.1 Safe and Alternative Shutdown 5.1.1 Previously Accepted Alternative Shutdown Capability QUESTION As part of the Appendix A review process, some plants had committed to an alternative shutdown system in the form of a remote shutdown panel or remote shutdown system. Footnote 2 to Appendix R describes alternative shutdown capability as being associated with "Rerouting, relocating, or modifying of existing systems." To the extent that an existing remote shutdown system previously reviewed and approved under Appendix A to BTP 9.5-1 does not require modifications, rerouting, or relocating of existing systems, are the requirements of Section III.L of Appendix R backfit? RESPONSE Yes. Existing remote shutdown capabilities previously reviewed and approved under Appendix A to BTP APCSB 9.5-1 do not categorically comply with Section III.G.3 of Appendix R. Licensees were requested to re- analyze their plants to determine compliance with Section III.G. If the licensee chooses to use the APPENDIX R QUESTIONS & ANSWERS 19 option of III.G.3 for provision of safe shutdown capability for certain areas, the criteria of Section III.L are applicable to that capability for that area. See also the response to 5.1.3. 5.1.2 Pre-Existing Alternative Shutdown Capability QUESTIONS Some licensees defined safe shutdown capability for purposes of analysis to Section III.G criteria as being composed of both the normal safe shutdown capability and the pre-existing redundant or remote safe shutdown capability which was previously installed as part of the Appendix A process. This definition often took the form of two "safe shutdown trains" comprising (1) one of the two normal safe shutdown trains, and (2) a second safe shutdown train ability which was being provided by the pre-existing remote shutdown capability. This definitional process, which was undertaken by a number of licensees, makes a significant difference in the implementation of Appendix R. Under such a definition, does Section III.L criteria apply when the Commission did not call out Section III.L as a backfit? RESPONSE The definitional process mentioned considers an alternative shutdown capability provided under the Appendix A review as a redundant shutdown capability under the Appendix R review. This definitional process is incorrect. For the purpose of analysis to Section III.G.2 criteria, the safe shutdown capability is defined as one of the two normal safe shutdown trains. If the criteria of Section III.G.2 are not met, an alternative shutdown capability is required. The alternative shutdown capability may utilize existing remote shutdown capabilities and must meet the criteria of Sections III.G.3 and III.L of Appendix R. See also the response to 5.1.3. 5.1.3 III.L Backfit QUESTION Why do the Staff interpretive memoranda regarding the criteria for satisfaction of Section III.L form the auditable basis for determining compliance to Appendix R when the Commission failed to backfit this section to all plants? RESPONSE Although 10 CFR 50.48(b) does not specifically include Section III.L with Sections III.G, J, and O of Appendix R as a requirement applicable to all power reactors licensed prior to January 1, 1979, the Appendix, read as a whole, and the Court of Appeals decision on the Appendix, Connecticut Light and Power, et al. v. NRC, 673 F2d. 525 (D.C. Cir., 1982), demonstrate that Section III.L applies to the alternative safe shutdown option under Section III.G if and where that option is chosen by the licensee. This does not preclude licensees from proposing and justifying other methods, e.g., see Section #1, Process Monitoring Instrumentation, of the "Interpretations of Appendix R." APPENDIX R QUESTIONS & ANSWERS 20 5.2 Procedures 5.2.1 Shutdown and Repair Basis QUESTION With regard to the term "post-fire procedures" the Commission states that it is impossible to predict the course and extent of a fire. Given this, how does one write post-fire shutdown and repair procedures that are both symptomatic and usable to an operator? RESPONSE Safe shutdown capabilities including alternative shutdown capabilities are all designed for some maximum level of fire damage (system unavailabilities, spurious actuations). Since the extent of the fire cannot be predicted, it seems prudent to have the post-fire shutdown procedures guide the operator from full system availability to the minimum shutdown capability. As for repair procedure, similar conditions exist. A repair procedure can be written based on the maximum level of damage that is expected. This procedure would then provide shutdown capability without accurately predicting likely fire damage. 5.2.2 Post Fire Operating Procedures QUESTION Does the NRC have any requirements regarding whether post-fire operating procedures should be based upon fire areas, systems, or be symptom-based? RESPONSE The NRC does not have requirements, nor do we propose any requirements regarding whether post-fire operating procedures should be based upon fire areas, systems or be symptom-based. We suggest that the post-fire shutdown capabilities designs be reviewed with the plant operation staff and procedures written with their input. See also responses to 5.2.1 and 5.2.3. 5.2.3 Alternative Shutdown Capability QUESTION Is it acceptable to develop post-fire operating procedures only for those areas where alternative shutdown is required? (For other areas standard, emergency operating procedures would be utilized in the presence of potential fire damage to a single train.) RESPONSE Yes. The only requirement for post-fire operating procedures is for those areas where alternative shutdown is required. For other areas of the plant, shutdown would be achieved utilizing one of the two normal trains of shutdown system. Shutdown in degraded modes (one train unavailable) should be covered by present operator training and abnormal and emergency operating procedures. If the degraded modes of operation are not presently covered, we would suggest APPENDIX R QUESTIONS & ANSWERS 21 that the operation staff of the plant determine whether additional training or procedures are needed. 5.2.4 Post Fire Procedures Guidance Documents QUESTION Do any NRC Staff guidance documents exist relative to the extent, form, nature, etc. of Appendix R post-fire operating procedures? RESPONSE No. Other than the criteria of Section III.L, no specific post-fire shutdown procedure guidance has been developed. See also responses to 5.2.1, 5.2.2 and 5.2.3. The inspection process will be flexible in this regard as long as the licensee can show compliance with the criteria of Section III.L. 5.3 Safe Shutdown and Fire Damage 5.3.1 Circuit Failure Modes QUESTION What circuit failure modes must be considered in identifying circuits associated by spurious actuation? RESPONSE Sections III.G.2 and III.L.7 of Appendix R define the circuit failure modes as hot shorts, open circuits, and shorts to ground. For consideration of spurious actuations, all possible functional failure states must be evaluated, that is, the component could be energized or de-energized by one or more of the above failure modes. Therefore, valves could fail open or closed; pumps could fail running or not running; electrical distribution breakers could fail open or closed. For three- phase AC circuits, the probability of getting a hot short on all three phases in the proper sequence to cause spurious operation of a motor is considered sufficiently low as to not require evaluation except for any cases involving Hi/Lo pressure interfaces. For ungrounded DC circuits, if it can be shown that only two hot shorts of the proper polarity without grounding could cause spurious operation, no further evaluation is necessary except for any cases involving Hi/Lo pressure interfaces. 5.3.2 "Hot Short" Duration QUESTION If one mode of fire damage involves a "hot short" how long does that condition exist as a result of fire damage prior to terminating in a ground or open circuit and stopping the spurious actuation? RESPONSE We would postulate that a "hot short" condition exists until action has been taken to isolate the given circuit from the fire area, or other actions as APPENDIX R QUESTIONS & ANSWERS 22 appropriate have been taken to negate the effects of the spurious actuation. We do not postulate that the fire would eventually clear the "hot short." 5.3.3 Hot Shutdown Duration QUESTION Since hot shutdown cannot be maintained indefinitely, hot shutdown equipment needs to be protected for only a limited period of time. How long must a plant remain in that condition in order to meet the requirement for achieving hot shutdown with a single train of equipment? RESPONSE Section III.G.1 requires that the one train of systems needed to achieve and maintain hot shutdown be free of fire damage. Thus, the systems needed are to be completely protected from the fire regardless of time. If the intent of the question concerns how long these systems must operate, these systems must be capable of operating until the systems needed to achieve and maintain cold shutdown are available. 5.3.4 Cooldown Equipment QUESTION Certain equipment is necessary only in the cooldown phase when the plant is neither in hot nor cold shutdown condition as defined by technical specifications. Is this equipment considered hot or cold shutdown in nature? RESPONSE As stated in Section III.G.1, one train of systems needed to achieve and maintain hot shutdown conditions must be free of fire damage. Systems necessary to achieve and maintain cold shutdown can be repaired within 72 hours. Thus, if this certain equipment necessary only in the cooldown phase, is used to achieve cold shutdown, it can be repaired within 72 hours. If the certain equipment is maintaining hot shutdown while repairs are being made, one train must be free of fire damage. See also Section #2 of the "Interpretations of Appendix R." 5.3.5 Pressurizer Heaters QUESTION Most PWRs do not require pressurizer heaters to maintain stable conditions. In fact, the Commission does not consider heaters to be important to safety and they are not required to meet Class IE requirements. Are they required for hot shutdown under Appendix R? If yes, then how does a plant meet the separation requirements of Section III.G.2.d,e. or f without major structural alterations to the pressurizer? APPENDIX R QUESTIONS & ANSWERS 23 RESPONSE One train of systems necessary to achieve and maintain hot shutdown conditions must be free of fire damage. PWR licensees have demonstrated the capability to achieve and maintain stable hot shutdown conditions without the use of pressurizer heaters by utilizing the charging pump and a water solid pressurizer for reactor coolant pressure control. 5.3.6 On-Site Power QUESTION Appendix R, Section III.L.4 states in part, "If such equipment and systems will not be capable of being powered by both on-site and off-site electrical power systems because of fire damage, an independent on-site power system shall be provided." Again, in Appendix R, Section III.L.5, the statement is made "If such equipment and systems used prior to 72 hours after the fire will not be capable of being powered by both onsite and offsite electrical power systems because of fire damage, an independent onsite power system shall be provided." An interpretation is needed of the meaning and the applicability of these two quotes relative to alternative shutdown capabilities. RESPONSE These statements are meant to indicate that the alternative shutdown capability should be powered from an onsite power system independent (both electrically and physically) from the area under consideration. Further, if the normal emergency onsite power supplies (diesel generators) are not available because of fire damage, then a separate and independent onsite power system shall be provided. As an example, some plants are utilizing a dedicated onsite diesel generator or gas turbine to power instrumentation and control panels which are a part of the alternative shutdown capability. 5.3.7 Torus Level Indication QUESTION For BWRs, I&E Information Notice 84-09 suggests that licensees need to have torus level indication post-fire. If an analysis shows that a level does not change significantly during any operational modes or worse case conditions, is level indication still required? Is an analysis in file adequate or is an exemption request required? RESPONSE It continues to be our position that torus (suppression pool) level indication is the preferred post-fire monitoring instrumentation in order to confirm the availability of the torus (suppression pool) as a heat sink. We recognize that existing analyses indicate that suppression pool level is not significantly changed during emergency shutdown conditions. However, we believe the operator should be able to confirm that spurious operations or other unanticipated occurrences have not affected the torus function. An analysis of torus level change by itself is not considered an acceptable basis. APPENDIX R QUESTIONS & ANSWERS 24 5.3.8 Short Circuit Coordination Studies QUESTION Should circuit coordination studies consider high impedance faults? RESPONSE To meet the separation criteria of Section III.G.2 and III.G.3 of Appendix R, high impedance faults should be considered for all associated circuits located in the fire area of concern. Thus, simultaneous high impedance faults (below the trip point for the breaker on each individual circuit) for all associated circuits located in the fire area should be considered in the evaluation of the safe shutdown capability. Clearing such faults on associated circuits which may affect safe shutdown may be accomplished by manual breaker trips governed by written procedures. Circuit coordination studies need not be performed if it is assumed that shutdown capability will be disabled by such high impedance faults and appropriate written procedures for clearing them are provided. 5.3.9 Diagnostic Instrumentation QUESTION What is diagnostic instrumentation? RESPONSE Diagnostic instrumentation is instrumentation, beyond that previously identified in Attachment 1 to I&E Information Notice 84-09, needed to assure proper actuation and functioning of safe shutdown equipment and support equipment (e.g., flow rate, pump discharge pressure). The diagnostic instrumentation needed depends on the design of the alternative shutdown capability. Diagnostic instrumentation, if needed, will be evaluated during the staff's review of the licensee's proposal for the alternative shutdown capability. 5.3.10 Design Basis Plant Transients QUESTION What plant transients should be considered in the design of the alternative or dedicated shutdown systems? RESPONSE Per the criteria of Section III.L of Appendix R a loss of offsite power shall be assumed for a fire in any fire area concurrent with the following assumptions: a. The safe shutdown capability should not be adversely affected by any one spurious actuation or signal resulting from a fire in any plant area; and APPENDIX R QUESTIONS & ANSWERS 25 b. The safe shutdown capability should not be adversely affected by a fire in any plant area which results in the loss of all automatic function (signals, logic) from the circuits located in the area in conjunction with one worst case spurious actuation or signal resulting from the fire; and c. The safe shutdown capability should not be adversely affected by a fire in any plant area which results in spurious actuation of the redundant valves in any one high-low pressure interface line. 5.3.11 Alternative/Dedicated Shutdown v. Remote Shutdown Systems QUESTION What is the difference between the alternate/dedicated shutdown systems required for fire protection and the remote shutdown systems recommended under Chapter 7 of the SRP? RESPONSE The remote shutdown systems recommended under Chapter 7 of the SRP are needed to meet GDC 19. These remote shutdown systems need to be redundant and physically independent of the control room in order to meet GDC 19. For GDC 19, damage to the control room is not considered. Alternate shutdown systems for Appendix R need not be redundant but must be both physically and electrically independent of the control room. 6. OIL COLLECTION SYSTEMS FOR REACTOR COOLANT PUMP 6.1 Lube Oil System Seismic Design QUESTION If the reactor coolant pump lube oil system and associated appurtenances are seismically designed, does the lube oil collection system also require seismic design? Is an exemption required? RESPONSE Where the RCP lube oil system is capable of withstanding the safe shutdown earthquake (SSE), the analysis should assume that only random oil leaks from the joints could occur during the lifetime of the plant. The oil collection system, therefore, should be designed to safely channel the quantity of oil from one pump to a vented closed container. Under this set of circumstances, the oil collection system would not have to be seismically designed. An exemption is required for a non-seismically designed oil collection system. The basis for this exemption would be that random leaks are not. assumed to occur simultaneously with the seismic event, since the lube oil system is designed to withstand the seismic event. However, the Rule, as written, does not make this allowance. APPENDIX R QUESTIONS & ANSWERS 26 6.2 Container QUESTION It would appear that a literal reading of Section III.O regarding the oil collection system for the reactor coolant pump could be met by a combination of seismically designed splash shields and a sump with sufficient capacity to contain the entire lube oil system inventory. If the reactor coolant pump is seismically designed and the nearby piping hot surfaces are protected by seismically designed splash shields such that any spilled lube oil would contact only cold surfaces, does this design concept conform to the requirements of the rule? RESPONSE If the reactor coolant pump, including the oil system, is seismically designed and the nearby hot surfaces of piping are protected by seismically designed splash shields such that any spilled lube oil would contact only cold surfaces, and it could be demonstrated by engineering analysis that sump and splash shields would be capable of preventing a fire during normal and design basis accident conditions, the safety objective of Section III.O would be achieved. Such a design concept would have to be evaluated under the exemption process. The justification for the exemption should provide reasonable assurance that oil from all potential pressurized and unpressurized leakage points would be safely collected and drained to the sump. The sump should be shown capable of safely containing all of the anticipated oil leakage. The analysis should verify that there are no electric sources of ignition. 7 BRANCH TECHNICAL POSITION CMEB 9.5-1 7.1 Fire Protection and Seismic Events QUESTION For which situations other than the reactor coolant pump lube oil system are seismic events assumed to be initiators of a fire? RESPONSE The guidelines for the seismic design of fire protection systems which cover other general situations is delineated in BTP CMEB 9.5-1 C.1.C(3) and (4): "(3) As a minimum, the fire suppression system should be capable of delivering water to manual hose stations located within hose reach of areas containing equipment required for safe plant shutdown following the safe shutdown earthquake (SSE). In areas of high seismic activity, the staff will consider on a case-by-case basis the need to design the fire detection and suppression systems to be functional following the SSE. (4) The fire protection systems should retain their original design capability for (a) natural phenomena of less severity and greater frequency than the most severe natural phenomena (approximately once in 10 years) such as tornadoes, hurricanes, floods, ice storms, or small intensity earthquakes APPENDIX R QUESTIONS & ANSWERS 27 that are characteristic of the geographic region, and (b) potential man- made site related events such as oil barge collisions or aircraft crashes that have a reasonable probability of occurring at a specific plant site. The effects of lightning strikes should be included in the overall plant fire protection program:" We have considered California as being a high seismic activity area. For those plants reviewed under Appendix A, our position is (A.4): "Postulated fires or fire protection system failures need not be considered concurrent with other plant accidents or the most severe natural phenomena." Our guidelines on the seismic design of fire protection systems installed in safety related areas are delineated in Regulatory Guide 1.29 "Seismic Design Classification," paragraph C.2. The failure of any system should not affect a system from performing its safety function. Our guidelines on the seismic design of hydrogen lines is delineated in BTP CMEB 9.5-1 Section C.5.d(5): (5) Hydrogen lines in safety-related areas should be either designed to seismic Class I requirements, or sleeved such that the outer pipe is directly vented to the outside, or should be equipped with excess flow valves so that in case of a line break, the hydrogen concentration in the affected areas will not exceed 2%. All PWR's have a hydrogen line going to the Volume Control Tank (Make-up Tank) that needs to be protected. To identify plant specific situations in which seismic events could initiate a fire in a specific plant area, the fire protection engineer and systems engineer performing the fire hazards analysis should be concerned with in-situ combustible materials which can be released in a manner such that they could contact in-situ ignition sources by a seismic event. An example of this would be the rupture of the RCP lube oil line directly above the hot reactor coolant piping. The fire protection engineer should also be concerned with seismic induced ignition sources, electrical or mechanical, which could contact nearby in-situ combustible materials. It should be noted that the guidelines cited above from BTP CMEB 9.5-1 are not applicable to plants reviewed and approved under BTP APCSB 9.5-1. 7.2 Random Fire and Seismic Events QUESTION Is a random fire to be postulated concurrent with a seismic event? RESPONSE Our position, as stated in Section C.1.6 of BTP CMEB 9.5-1, is "Worst case fire need not be postulated to be simultaneous with non-fire related failures in safety systems, plant accidents, or the most severe natural phenomena." APPENDIX R QUESTIONS & ANSWERS 28 Where plant systems are designed to prevent the release of combustible materials caused by a seismic event, such as a dike around a fuel oil tank transformer, or seismic supports for hydrogen lines, then no fire need to be arbitrarily assumed to take place in the fire hazards analysis. Because it is impossible to completely preclude the occurrence of a seismically induced fire, Section C.6.c(4) of CMEB 9.5-1 states: "Provisions should be made to supply water at least to standpipes and hose connections for manual fire fighting in areas containing equipment required for safe plant shutdown in the event of a safe shutdown earthquake. The piping system serving such hose stations should be analyzed for SSE loading and should be provided with supports to ensure system pressure integrity. The piping and valves for the portion of hose standpipe system affected by this functional requirement should, as a minimum, satisfy ANSI B31.1, 'Power Piping.' The water supply for this condition may be obtained by manual operator actuation of valves in a connection to the hose standpipe header from a normal seismic Category I water system such as the essential service water system. The cross connection should be (a) capable of providing flow to at least two hose stations (approximately 75 gpm per hose station), and (b) designed to the same standards as the seismic Category I water system; it should not degrade the performance of the seismic Category I water system." The post-seismic procedures should include a damage survey, and a determination of whether any fires were initiated as a result of the seismic event. See also the response to Question 7.1. It should be noted that the guidelines cited above from BTP CMEB 9.5-1 are not applicable to plants reviewed and approved under BTP APCSB 9.5-1. 8. LICENSING POLICY 8.1 Fire Hazard Analysis/Fire Protection Plan Updating QUESTION What constitutes the fire protection plan required by 50.48(a)? Should licensees have programs to maintain the fire hazards analysis and the fire protection plan current or updated periodically? How often should the plan be updated? Must revisions be provided to the NRC? RESPONSE The basic elements required in the fire protection plan are described in 10 CFR 50.48(a). The fire protection program that implements that plan should include the details of the fire hazards analysis. The plan and program may be separate or combined documents and must be kept current with the fire hazards analysis updated prior to making modifications. We would expect that the fire protection plan and program will be incorporated as part of the FSAR and therefore, would be updated and submitted to the NRC in conformance with the requirements of 10 CFR 50.71(e). APPENDIX R QUESTIONS & ANSWERS 29 8.2 Fire Protection License Condition QUESTION What is the significance of the fire protection license condition? RESPONSE See Generic Letter Section F 8.3 III G, J and O Exemptions for Future Modifications QUESTION Is an exemption required from Appendix R Sections other than III.G, III.J and III.O for future modifications that do not comply with such sections? RESPONSE Yes, for plants licensed prior to January 1, 1979 and for those modifications which deviate from the previously accepted fire protection configurations. The exclusion of the applicability of Sections of Appendix R other than III.G, III.J, and III.O is limited to those features "accepted by the NRC staff as satisfying the provisions of Appendix A to Branch Technical Position BTP APCSB 9.5-1 reflected in staff fire protection safety evaluation reports issued prior to the effective date of the rule." No reanalysis is required except for proposed modifications which would alter previously approved features. This position is based directly on CFR 50.48(b). Also see response to Question 8.1. 8.4 Future Changes QUESTION Will future changes (no matter how minor) to approved configurations be required to be reviewed by the Staff in an exemption request? At what point may the process of 10 CFR 50.59 be invoked? RESPONSE If a future modification involves a change to a license condition or technical specification, a license amendment request must be submitted. When a modification not involving a technical specification or license condition is planned, APPENDIX R QUESTIONS & ANSWERS 30 the evaluation made in conformance with 10 CFR 50.59 to determine whether an unreviewed safety question is involved must include an assessment of the modification's impact on the existing fire hazards analysis for the area. This part of the evaluation must be performed by the person responsible for the fire safety program for the plant. The assessment must include the effect on combustible loading and distribution and the consideration of whether circuits or components, including associated circuits, for a train of equipment needed for safe shutdown are being affected or a new element introduced in the area. If this evaluation concludes that there is no significant impact, this conclusion and its basis must be documented as part of the 50.59 evaluation and be available for future inspection and reference. If the evaluation finds that there is an impact that could result in the area either not being in conformance with Appendix R, or some other aspect of the approved fire protection program, or being outside the basis for an exemption that was granted for the area involved, the licensee must either make modifications to achieve conformance or justify and request exemption (or, for the post 1979 plants, approval) from the NRC. See also responses to Questions 8.1 and 8.2. 8.5 Schedular and Blanket Exemptions QUESTION If an exemption is warranted and at the same time the provisions of the rule indicate that the appropriate schedular deadlines have passed, should a schedular exemption be filed at the same time as the technical exemption request? If as part of the exemption request the utility is proposing to make modifications to achieve a reasonable level of conformance with Appendix R, and if the associated "clock" has run out for that type of modification, should the technical exemption request and the description of the modification be filed with a schedular exemption? When filing a schedular exemption under 50.12, it is not always clear from what specific paragraphs of 50.48 an exemption should be sought. Is it acceptable to request a blanket exemption from the schedular provisions of 10 CFR 50.48 without a specification by paragraph? If an exemption request is submitted to meet newly published interpretations of Appendix R, when does the licensee need to be in compliance? Is the schedule presented in Appendix R still the guideline or must a new schedule be developed under a different criteria? RESPONSE In response to the first two questions above, once the time period allowed by a schedule in 50.48 has run out, the schedule cannot be reinstituted by exemption. In such a situation the licensee is in violation of the regulation and should notify the Region proposing compensatory measures and a schedule for gaining compliance either with the provisions of Appendix R or with the provisions of an approved technical exemption. If a technical exemption is involved but is not yet applied for, the schedule for that action should be included and the licensee runs the risk that if the technical exemption is denied, a violation of the regulation has been incurred. APPENDIX R QUESTIONS & ANSWERS 31 Requests for schedular exemptions may be made under 10 CFR 50.12, but such requests will be granted sparingly based upon the following criteria: 1. The utility has, since the promulgation of Appendix R in 1980, proceeded expeditiously to meet the Commission's requirements. 2. The delay is caused by circumstances beyond the utility's control, or immediate implementation would cause undue hardship (e.g., plant shut-down to effect a minor modification). 3. The proposed schedule for completion represents a best effort under the circumstances. 4. Adequate interim compensatory measures will be taken until compliance is achieved. This policy is further explained in the generic letter transmitting this package. 8.6 Trivial Deviations QUESTION What guidance can the NRC Staff give the industry regarding when a deviation from the literal interpretation of Appendix R is sufficiently trivial as to not require a specific exemption? RESPONSE The significance of a deviation must be judged as part of a fire hazards analysis. The conclusion of this analysis is always subject to review by the NRC inspector. 8.7 Revised Modifications QUESTION What is the process for altering configurations not yet implemented for plants with Appendix R SERs? RESPONSE If licensees propose changes to their NRC approved modifications, they must submit their new proposal and revised schedule for implementation for NRC approval. This change must be justified as to (l) the reason for the change, (2) the basis for the revised schedule, and (3) the interim measures that will be provided to assure post fire shutdown capability until the final modifications are implemented. Whether or not enforcement action will be taken based upon continued noncompliance with Appendix R will be decided by the NRC Regional Administrator in consultation with NRC Headquarters. APPENDIX R QUESTIONS & ANSWERS 32 8.8 Smallest Opening in a Fire Barrier QUESTION What is the smallest opening allowed in a fire area barrier for which an exemption request is not needed? RESPONSE Unsealed openings in the configuration for which approval was obtained by an approved laboratory or the NRC staff would be acceptable. Our position on openings is given in Section 5.a(3) of BTP CMEB 9.5-1: "(3) Openings through fire barriers for pipe, conduit, and cable trays which separate fire areas should be sealed or closed to provide a fire resistance rating at least equal to that required of the barrier Itself. Openings inside conduit larger than 4 inches in diameter should be sealed at the fire barrier penetration. Openings inside conduit 4 inches or less in diameter should be sealed on each side of the fire barrier and sealed either at both ends or at the fire barrier with non-combustible material to prevent the passage of smoke and hot gases. Fire barrier penetrations that must maintain environmental isolation or pressure differentials should be qualified by test to maintain the barrier integrity under such conditions." The unsealed opening(s) allowed in a fire area boundary or a barrier which separates redundant shutdown divisions should not permit flame, radiant energy, smoke and hot gases to pass through the barrier and cause damage to redundant shutdown divisions on the other side. The licensee should assess the adequacy of existing protection and should determine the minimum size based on a fire hazards analysis and conservative fire protection engineering judgment. If the significance of openings in fire barriers is marginal, a formal exemption request could be submitted or the staff consulted. The basis for the lack of significance should be available for review by NRC Inspectors. Our acceptance of unprotected openings in fire barriers would depend upon the quantity and nature of combustible materials on either side of the barrier; the location of the opening(s) in relation to the ceiling (for openings in walls); the location, vulnerability and importance of shutdown systems on either side of the barrier; and compensating fire protection. See also Section #4 of the "Interpretations of Appendix R." 8.9 NFPA Code Deviation QUESTION Is an exemption/deviation required for deviations from NFPA Codes? RESPONSE Deviations from the codes should be identified and justified in the FSAR or FHA. APPENDIX R QUESTIONS & ANSWERS 33 An exemption is not required for NFPA codes. NRC guidelines reference certain NFPA codes as guidelines to the systems acceptable to the staff, and therefore such codes may be accorded the same status as Regulatory Guides. When the applicant/licensee states that its design "meets the NFPA codes" or, "meets the Intent of the NFPA Codes" and does not identify any deviations from such codes, NRR and the Regions expect that the design conforms to the code and the design is subject to inspection against the NFPA codes. 8.10 "ASTM E-119" Design Basis QUESTION Is an exemption/deviation required, if components are designed to withstand an "ASTM E-119" fire? RESPONSE Some cables are being developed for high temperature (e.g., 1700 F) applications. An exemption would be required if such cable is used in lieu of the alternatives of III.G.2 or III.G.3 in a pre-1979 plant. A deviation from the guidelines would be required for similar applications in a post 1979 plant. 8.11 Plants Licensed After January 1, 1979 QUESTION What fire protection guidelines and requirements apply to the plants licensed after January 1, 1979? RESPONSE Post-1979 plants are subject to: o GDC 3 o 10 CFR 50.48(a) and (e) o The guidelines identified in the footnotes to 50.48(a) o Guidelines documents issued after January 1, 1979. o Commitments made to meet the requirements of Appendix R; or specific sections such as III.G, III.J, III.O; and Appendix A to BTP APCSB 9.5-1; or BTP CMEB 9.5-1, which includes the requirements of Appendix R* and the previous guidance documents incorporated into the Branch Technical Position. The license for each plant licensed after January 1, 1979 contains a license condition which identifies by reference the approved fire protection program for that plant. * A deficiency in the BTP CMEB 9.5-1 has been noted in that a requirement in Appendix R Section III.G.3.b to provide alternative or dedicated shutdown capability in an area where both redundant safe shutdown trains could be damaged APPENDIX R QUESTIONS & ANSWERS 34 . by suppression activities or inadvertent operation or rupture of fire suppression systems is not included. This requirement will be added in the next revision of the BTP. 8.12 Cold Shutdown Equipment Availability QUESTION A. Can a licensee achieve compliance with III.G.l(b) by demonstrating that one train of cold shutdown equipment will remain free of fire damage? B. In demonstrating that one train of cold shutdown equipment will remain free of fire damage, is a licensee limited to the three alternatives in III.G.2? RESPONSE A. Yes. B. No. 8.13 Guidance Documents QUESTION Please list all NRR guidance documents and position papers issued since Appendix R was promulgated. RESPONSE Fire Protection Guidance Issued Since January 1, 1975: IE Information Notices No. 83-41: Actuation of fire suppression systems causing inoperability of safety related equipment. No. 83-69: Improperly installed fire dampers at nuclear power plants. No. 83-83: Use of portable radio transmitters inside nuclear power plants. *No. 84-09: Lessons Learned From NRC Inspections of Fire Protection Safe Shutdown Systems (10 CFR 50, Appendix R) Standard Review Plan 9.5.1, Rev. 1 Fire Protection System, dated 5/1/76 9.5.1, Rev. 2 Fire Protection Program, dated 03/78 9.5.1, Rev. 3 Fire Protection Program, July 1981. APPENDIX R QUESTIONS & ANSWERS 35 Regulations 10 CFR Part 50: Proposed fire protection program for nuclear power plants operating prior to January 1, 1979, dated May 29, 1980. Federal Register Vol. 45, No. 105, 36082. 10 CFR Part 50: Fire protection program for operating nuclear power plants, dated November 19, 1980. Federal Register Vol. 45, No. 225, 76602. 10 CFR Part 50: Fire protection rule corrections, dated September 8, 1981. Federal Register Vol. 46, No. 173, 44734. Generic Letters NOTE: The following documents were obtained from the Palisades file Docket No. 50-255. Similar documents should be in the file for other operating facilities. The dates may vary slightly. 1. Letter dated 9/28/76 - Enclosing App. A to BTP APCSB 9.5-1 and supplementary guidance on information needed for fire protection program evaluation. 2. Letter dated 12/1/76 - Enclosing sample Technical Specifications and an errata sheet. 3. Letter dated 8/19/77 - Enclosing "Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance." 4. Letter dated 6/8/78 - Re: Manpower requirements for operating reactors. 5. Letter dated 9!7/79 - Re: Minimum fire brigade shift size. 6. Letter dated 9/14/79 - Enclosing staff positions - safe shutdown capability. 7. Letter dated 10/31/80 - Enclosing new 10 CFR 50.48 regarding fire protection schedules for operating nuclear power plants. 8. Letter dated 11/24/80 - Enclosing a copy of revised 10 CFR 50.48 and new App. R to 10 CFR 50, and a summary of open items from the SER for the BTP APCSB 9.5-1 review. 9. Letter dated 2/20/81 - Generic Letter 81-12 identifying information needed for NRC review of modifications for alternative shutdown capability. 10. Letter dated 4/7/82 - Provided clarification to Generic Letter 81-12 and guidance on information needed for NRC review of exemption requests. 11. Letter dated 10/6/82 - Generic Letter 82-21; provided criteria for annual, biennial, and triennial audits required by Technical Specifications. *12. Letter dated 10/19/83 - Generic Letter 83-33; NRC Positions on Certain Requirements of Appendix R to 10 CFR 50. APPENDIX R QUESTIONS & ANSWERS 36 Staff Generic Positions 1. Letter, Denton to Bernsen, dated 4/20/82 - Control room fires. *2. SECY 83-269, dated July 5, 1983 - Attachments B and C. 3. Memo, Eisenhut to Olshinski, dated 12/30/83 - Physical independence of electrical systems. 4. Memo, Eisenhut to Jordan, dated 10/24/83 - Bullet resistant fire doors. *Staff positions regarding the need for certain exemptions delineated in this guidance document have been revised per the "Interpretations of Appendix R". 8.14 Deviation From Guidance Documents QUESTION If a utility determines that a deviation from a guidance document exists, does an exemption request need to be filed? If so, what is the legal basis for this requirement? RESPONSE No. 8.15 Staff Interpretation of Appendix R QUESTION How does the Staff initiate interpretations of Appendix R in a manner which ensures their technical adequacy and consistency with the rule's objectives (e.g., presentation to ACRS, issue for comment as in draft regulatory guides, etc.)? RESPONSE Staff positions are initiated when our experience shows that generic issues are identified that require clarification. These positions are reviewed for accuracy and consistency by the cognizant Division Directors. Usually, they are not issued for comment. However, Generic Letter 83-33 was commented on by the NUFPG since it was initiated, in part, at their request. 8.16 Dissemination of New Staff Positions QUESTION Will licensees be automatically sent a copy of new Staff position papers as they are developed? RESPONSE The Staff positions on generic subjects are considered for issuance in Generic Letters from ONRR and Information Notices or Bulletins from OI&E. Staff APPENDIX R QUESTIONS & ANSWERS 37 positions issued for specific questions on specific plants are not given generic promulgation because they normally involve plant specific design considerations. 8.17 Equivalent Alternatives QUESTION How does a licensee demonstrate that alternative measures are equivalent to the measures of Section III.G.2 in order to obtain an exemption lacking a formal definition of the term "free of fire damage"? RESPONSE See Item #3 of "Interpretations of Appendix R." 8.18 Coordination Study Update QUESTION Circuit modifications are an ongoing process. How recent must a coordination study be in order to be valid in protecting circuits associated by common power source? RESPONSE We would expect that as circuit modifications are made, the design package would address the electrical protection required and the effects of this . protection on the coordination of the protection for the power distribution system. This type of consideration should be included in the evaluation required by 10 CFR 50.59 Changes, Tests and Experiments. The design package and modification evaluation could not be complete without consideration of the coordination study. Therefore, we would expect that the coordination studies would be current with the last circuit modification made. 8.19 Exemption Request Threshold QUESTION (a) What is the threshold for exemption requests? (b) Is it necessary to file a request for each and every possible deviation from Appendix R? RESPONSE Typical examples are discussed in the response to Questions 8.19.1 through 8.19.4. (a) The licensee must develop its criteria for an exemption request threshold. (b) No. 8.19.1 Penetration Designs Not Laboratory Approved APPENDIX R QUESTIONS & ANSWERS 38 QUESTION Where penetration designs have been reviewed and approved by NRC but have not been classified by an approval laboratory, will it be necessary to submit an exemption request? RESPONSE No. 8.19.2 Individual vs. Package Exemptions QUESTION How do we submit future modification exemption requests, etc.? Would NRC prefer them individually, or developed and submitted in packages for review and approval? RESPONSE Future exemptions should be submitted individually, if they are independent of each other. 8.19.3 Exemption Request Supporting Detail QUESTION When an exemption request is filed, what criteria are used to determine the level of detail needed to support the request? RESPONSE See Enclosure 2 of NRC's letter to all licensees dated April-May 1982. 8.19.4 50.12 vs. 50.48 Exemption Requests QUESTION With regard to exemption requests for future modifications, will they be submitted under 50.12 or 50.48? RESPONSE 10 CFR 50.12. 8.20 Post January 1, 1979 Plants and Exemption Requests QUESTION Do plants licensed after January 1, 1979 which have committed to meet the requirements of Section III.G, III.J and III.O and are required to do so as a license condition, need to request exemptions for alternative configurations? APPENDIX R QUESTIONS & ANSWERS 39 RESPONSE No; however, deviations from the requirements of Section III.G, III.J and III.O should be identified and justified in the FSAR or FHA and the deviation would probably require a license amendment to change the license condition. See responses 8.1 and 8.2. 8.21 NRC Approval for BTP CMEB 9.5-1 Deviations QUESTION Do future deviations from BTP CMEB 9.5-1 guidelines require approval by the NRC? Do such deviations constitute a violation of license conditions? RESPONSE Compliance with guidelines in the BTP is only required to the extent that they were incorporated in the approved Fire Protection Program as identified in the license condition. (See Response 8.2) 9. INSPECTION POLICY 9.1 Safety Implications QUESTION Since the Commission states that fire damage cannot be defined and fire spread cannot be predicted, how does the Commission determine which Appendix R violations have "important safety implications?" RESPONSE III.G.2 provides alternatives to ensure that one of the redundant trains is free of fire damage. Fire spread within one area cannot be predicted, but damage is limited to one fire area. Determination of the Appendix R violations that have "important safety implications" are based on the equipment, components, and systems that are located in the same fire area that are needed for safe shutdown or can adversely affect safe shutdown, and are not protected by the features of III.G.2, III.G.3 or an approved alternative. 9.2 Uniform Enforcement QUESTION How does the Commission ensure that violations of the rule are uniformly treated between regions? APPENDIX R QUESTIONS & ANSWERS 40 RESPONSE Each Region evaluates violations in accordance with the NRC Enforcement Policy, 10 CFR 2, Appendix C. The Policy provides guidance for the determination of appropriate enforcement sanctions for violations. The Office of Inspection and Enforcement provides guidance for and monitors Regional implementation of the Policy to ensure a uniform application. In addition, the policy requires that all escalated enforcement actions be approved by the Director of the Office of Inspection and Enforcement. 9.3 NTOL Inspections QUESTION Will NTOLs be subject to an Appendix R audit now being performed on plants licensed to operate prior to January 1, 1979? Or, will the current review and analysis being performed by the Staff be satisfactory? RESPONSE Yes, NTOLs will be subject to the Appendix R audit; the TI 2515/62 is being revised to reflect the appropriate requirements for NTOLs' and it is our intent to conduct such inspections prior to issuing the operating license. 10 CFR 50.48 requires each such plant to have a fire protection plan. Their operating license will contain a specific license condition to implement their approved fire protection program which must identify deviations from Appendix R. The fire protection inspections will be against the particular license conditions. 9.4 Future TI 2515/62 Revisions QUESTION Does the NRC plan to issue a new or revised version of Temporary Instruction 2515/62 for future Appendix R audits? RESPONSE Yes. 9.5 Documentation Supplied by Licensee QUESTION Temporary Instruction 2515/62 provided a list of documentation that the NRC needs to review as part of the audit process. In past audits, the NRC has requested additional information other than that contained on the list. Will a new list of documentation be developed? APPENDIX R QUESTIONS & ANSWERS 41 RESPONSE The documentation listing provided in TI-2515/62 does not restrict the inspection team from enhancing inspection efficiency by requesting a licensee to provide additional relevant documentation. A new listing of documentation for TI-2515/62 is not being developed. 9.6 Subsequent Inspections QUESTION To what extent will Appendix R issues be raised at future Regional I&E Fire Protection Audits after a successful Appendix R audit? For example, if an area has already been reviewed and no noncompliance found, will it be subject to later review and reinterpretation by the Staff? RESPONSE The Appendix R inspections are conducted on a sample basis. These inspections do not certify that all possible items of noncompliance with Appendix R have been identified. The inspection results do provide a basis for a determination of the adequacy of a licensee's Appendix R reanalysis, modification and preparation. When a noncompliance with Appendix R requirements is identified, a notice of violation will be issued to ensure adequate corrective action. In those cases in which the licensee believes that the staff has invoked a reinterpretation of adequacy in areas which had previously been reviewed, NRC's procedures for appeal would be applicable. 9.7 NRC List of Conforming Items QUESTION At the end of the audit, will the NRC provide a list of items that had been reviewed and found in conformance with Appendix R? To date, only areas of nonconformance have been specifically identified in exit interviews. RESPONSE Subsequent to an Appendix R inspection, the NRC will not provide a list of items reviewed and found to be in conformance with Appendix R. We do list the areas inspected and where non-compliances were not found. APPENDIX R QUESTIONS & ANSWERS 42 9.8 Inspection Re-review QUESTION Where assumptions are made and clearly stated within the analysis submitted to NRR for review, will such assumptions be subject to a second review by OI&E during the inspection process? Where assumptions are made in conjunction with the analysis, should exemption requests be filed just to provide protection for the licensee? If NRR accepts a licensee's selection of equipment and shutdown paths as being sufficient to meet the Appendix R shutdown criteria, will OI&E review and have the right to challenge the approved shutdown paths and approved equipment selection? Or will they only check the shutdown paths and equipment in question to see that they meet the Appendix R requirements, i.e., separation? RESPONSE To the extent that a licensee's submittal to NRR is comprehensive and sufficiently detailed, the basis for the OI&E Appendix R inspection will be the assumptions, shutdown paths and equipment selections approved by NRR. If the inspection results in new information that casts doubt upon the approved configuration, the Regional inspectors have the responsibility to resolve such doubts. 9.9 List of Shutdown Equipment QUESTION What lists of shutdown equipment will be used by the Regional inspectors, if the shutdown analysis has not been reviewed and approved by NRR? RESPONSE Regional Inspectors will use the lists of shutdown equipment the licensee has identified in his fire protection plan. Generic Letter 81-12 and its clarification documents expect licensees to show how they will shutdown if a fire area is not provided with redundant train separation. Inherent within this expectation is the assumption that the licensee will identify the equipment to be used. It is because the licensees have not had fire hazard analyses at all for non-alternative shutdown fire areas that the inspectors to date have resorted to using the only lists available (the alternative shutdown equipment list used by NRR in their reviews). It is unlikely there would not be a list of at least those systems to be used for alternate shutdown, since 10 CFR 50.48 requires NRR review and approval of the means of alternate shutdown. APPENDIX R QUESTIONS & ANSWERS 43 ENCLOSURE 3 Fire Protection (Name of licensee) shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility (or as described in submittals dated ____________) and as approved In the SER dated__________(and Supplements dated_______________) subject to the following provision: The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
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