Removal of Fire Protection Requirements from Technical Specifications

                               August 2, 1988

TO ALL POWER REACTOR LICENSEES AND APPLICANTS 

SUBJECT:  REMOVAL OF FIRE PROTECTION REQUIREMENTS FROM TECHNICAL 
          SPECIFICATIONS (Generic Letter 86-12) 

Generic Letter 86-10 requested that licensees incorporate the NRC-approved 
Fire Protection Program in their Final Safety Analysis Reports. Generic 
Letter 86-10 encouraged licensees, upon completion of this program, to apply
for an amendment to their operating licenses (1) to replace current license 
conditions regarding fire protection with a new standard condition and (2) 
to remove unnecessary fire protection Technical Specifications (TS). 

During the past two years, the staff has gained experience with 
implementation of Generic Letter 86-10 for new operating licenses. In 
addition, lead-plant proposals for this license change were submitted with 
the endorsement of the Westinghouse Owners Group and approved for Callaway 
and Wolf Creek. On the basis of this combined experience, the staff 
developed the enclosed guidance for the preparation of a license amendment 
request to implement Generic Letter 86-10. 

A conforming amendment would remove fire protection requirements from TS in 
four major areas: fire detection systems, fire suppression systems, fire 
barriers, and fire brigade staffing requirements. The existing 
administrative control requirements related to fire protection audits would 
be retained. Additional programmatic requirements have been included in the 
administrative controls to address the Fire Protection Program consistent 
with the requirements for other programs. 

Licensees and applicants are encouraged to propose changes to TS that are 
consistent with the guidance provided in the enclosures. Proposed license 
amendments conforming to this guidance will be expeditiously reviewed by the
NRC Project Manager for the facility. Proposed amendments that deviate from 
this guidance will require a longer, more detailed review. Please contact 
the Project Manager if you have questions on this matter. 

                              Sincerely, 




                              Frank J. Miraglia 
                              Associate Director for Projects 
                              Office of Nuclear Reactor Regulation 

Enclosures:
As stated
.
                                Enclosure 1

           GUIDANCE FOR REMOVAL OF FIRE PROTECTION REQUIREMENTS
                       FROM TECHNICAL SPECIFICATIONS

INTRODUCTION 

This enclosure provides guidance for the preparation of a license amendment 
request to implement Generic Letter 86-10. Such an amendment (1) institutes 
the standard license condition for a Fire Protection Program. (2) removes 
requirements for fire protection systems from Technical Specifications (TS),
(3) removes fire brigade staffing requirements from TS, and (4) adds 
administrative controls to TS that are consistent with those for other 
programs implemented by license condition. The submittal must also include 
the update of the Final Safety Analysis Report (FSAR) to include the Fire 
Protection Program, if this has not been completed as requested by Generic 
Letter 86-10. 

The staff's intent in Generic Letter 86-10 of recommending that fire 
protection requirements be removed from the TS was to further the goal of 
Technical Specification improvement as delineated in other NRC policy 
statements. It is not the staff's intent to reduce the level of fire safety.

This guidance was developed on the basis of the review of lead-plant 
proposals for Callaway and Wolf Creek and from staff experience in 
implementing Generic Letter 86-10 for recent operating licenses. 

DISCUSSION 

This section addresses the elements a licensee should include in a license 
amendment request to remove fire protection requirements from TS. 

First, the NRC-approved Fire Protection Program(1) must be incorporated into 
the FSAR and submitted with the certification required by 10 CFR 
50.71(e)(2). as requested by Generic Letter 86-10. The FSAR update includes 
the incorporation of the Fire Protection Program, including the fire hazards
analysis and major commitments that form the basis for the NRC-approved Fire
Protection Program. This clay be accomplished by referencing the documents 
which define the licensee's Fire Protection Program as identified in the 
NRC's Safety Evaluation Reports. 

The staff does not intend to repeat its review of the approved Fire 
Protection Program incorporated in the updated FSAR. The staff may audit the
updated FSARs to assure that they have incorporated the approved Fire 
Protection Program. Licensees should not use this FSAR incorporation as an 
opportunity to make changes in the approved Fire Protection Program. 
Licensees should 



     (1)  The NRC-approved Fire Protection Program includes the fire 
protection and post-fire safe shutdown systems necessary to satisfy NRC 
guidelines and requirements; administrative and technical controls; the fire 
brigade and fire protection related technical staff; and other related plant 
features which have been described by the licensee in the FSAR, fire hazards 
analysis, responses to staff requests for additional information, 
comparisons of plant designs to applicable NRC fire protection guidelines 
and requirements, and descriptions of the methodology for assuring safe 
plant shutdown following a fire. 
.

                                   - 2 -

wait until the standard license condition is in place and then use the 
procedures described in the license condition to make any necessary changes 
in the Fire Protection Program. 

Second, the Limiting Conditions for Operation (LCO) and Surveillance 
Requirements associated with fire detection systems, fire suppression 
systems, fire barriers, and the administrative controls that address fire 
brigade staffing would be relocated from the TS. An index of these 
specifications is provided in Enclosure 2. The existing administrative 
controls related to fire protection audits are to be retained in TS. Also, 
any specifications related to the capability for safe shutdown following a 
fire, e.g., see Item 8(j) in Enclosure 1 to Generic Letter 61-12, are to be 
retained in TS. 

Third, all operational conditions, remedial actions, and test requirements 
presently included in the TS for these systems, as well as the fire brigade 
staffing requirements, shall be incorporated into the Fire Protection 
Program. In this manner, the former TS requirements will become an integral 
part of the Fire Protection Program and changes subsequent to this amendment
will be subject to the standard license condition. These remedial actions 
include shutdowns currently required by TS 3.0.3 when an LCO and its 
associated Action Requirements cannot be met. An example of such a 
requirement is the shutdown required for the loss of the fire suppression 
water system and failure to establish a backup water supply within 24 hours.

Fourth, the standard fire protection license condition in Generic Letter 
86-10 must be included in the license. Any other current fire protection 
license conditions shall be removed. This license condition precludes 
changes to the approved Fire Protection Program without prior Commission 
approval if those changes would adversely affect the ability to achieve and 
maintain safe shutdown conditions in the event of a fire. The shutdown 
requirement that applies because of a failure to establish a backup water 
supply within 24 hours after a loss of the fire suppression water system is 
an example of a Fire Protection Program requirement that would be subject to 
the license condition and could be changed in accordance with the standard 
license condition. However, the staff believes that any change to the 
shutdown requirement would also require the implementation of extraordinary 
compensatory measures. Absent such extraordinary measures, changes to this 
requirement are likely to have an adverse effect on the ability to achieve 
and maintain safe shutdown in the event of a fire and, therefore, could not 
be made without prior Commission approval. 

Finally, the Administrative Controls section of the TS shall be augmented to
support the Fire Protection Program. This shall be accomplished by additions
to two specifications. First, the Unit Review Group (Onsite Review Group) 
shall be given responsibility for the review of the Fire Protection Program 
and implementing procedures and the submittal of recommended changes to the 
Company Nuclear Review and Audit Group (Offsite or Corporate Review Group). 
Second, Fire Protection Program implementation shall be added to the list of
elements for which written procedures shall be established, implemented, and
maintained. 

The Emergency Plan and the Security Plan were used as models to determine 
the appropriate administrative control for the Fire Protection Program. 
These additions will provide administrative controls for the Fire Protection
Program that are equivalent to those for other programs that are implemented
by license condition. The enclosed marked pages of the Westinghouse Standard
Technical 
.

                                   - 3 -

Specifications (STS) serve as a model for the changes to the administrative 
controls. If the plant's TS differ from the STS, additions to the 
administrative controls for the Fire Protection Program should be proposed 
that are consistent with the administrative controls for the Emergency and 
Security Plans. 

In Generic Letter 86-10, licensees were reminded of their responsibilities 
to report deficiencies in the Fire Protection Program which meet the 
criteria of 10 CFR 50.72 and 10 CFR 50.73. Other conditions which represent 
deficiencies of this program and are not encompassed by the above reporting 
criteria should be evaluated by the licensees to determine appropriate 
corrective action. 

Summary 

The implementation of Generic Letter 86-10 to remove fire protection TS will
entail (1) a revision to the FSAR to incorporate the approved Fire 
Protection Program, (2) incorporation into the Fire Protection Program of 
the operational conditions, remedial actions, tests, and fire brigade 
staffing requirements for fire protection removed from the TS, and (3) a 
license amendment. The license amendment will (1) institute the standard 
fire protection license condition, (2) remove the fire protection systems 
and fire brigade staffing TS, and (3) add administrative controls to support 
the Fire Protection Program. 

Any questions on this matter should be directed to the NRC Project Manager 
for your facility.