United States Nuclear Regulatory Commission - Protecting People and the Environment

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.



Page Last Reviewed/Updated Thursday, June 27, 2013