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l                                      U.S. NUCLEAR REGULATORYNovember                    COMMISSION 2001 6REGULATORY          April GUIDE l                                    OFFICE OF NUCLEAR REGULATORY RESEARCH                                                        Division 1 l
l                                          DRAFT REGULATORY GUIDE l
 
==Contact:==
R.F. Radlinski l                                                                                                                          (301) 415-3174 l
l                              DRAFT REGULATORY GUIDE 1.189 (Draft was issued as DG-1097)
FIRE PROTECTION l                                          FOR OPERATINGDG-1170 l                              (Proposed Revision 1 of Regulatory Guide 1.189, dated April 2001) l l                                                  FIRE PROTECTION l                                  FOR NUCLEAR POWER PLANTS This regulatory guide is being issued in draft form to involve the public in the early stages of the development of a regulatory position in this area. It has not received staff review or approval and does not represent an official NRC staff position.
Public comments are being solicited on this draft guide (including any implementation schedule) and its associated regulatory analysis or value/impact statement. Comments should be accompanied by appropriate supporting data. Written comments may be submitted to the Rules and Directives Branch, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. Comments may be submitted electronically through the NRCs interactive rulemaking Web page at http://www.nrc.gov/what-we-do/regulatory/rulemaking.html. Copies of comments received may be examined at the NRCs Public Document Room, 11555 Rockville Pike, Rockville, MD. Comments will be most helpful if received by December 24, 2006.
Requests for single copies of draft or active regulatory guides (which may be reproduced) or placement on an automatic distribution list for single copies of future draft guides in specific divisions should be made to the U.S. Nuclear Regulatory Commission, Washington, DC 20555, Attention: Reproduction and Distribution Services Section, or by fax to (301)415-2289; or by email to Distribution@nrc.gov. Electronic copies of this draft regulatory guide are available through the NRCs interactive rulemaking Web page (see above); the NRCs public Web site under Draft Regulatory Guides in the Regulatory Guides document collection of the NRCs Electronic Reading Room at http://www.nrc.gov/reading-rm/doc-collections/; and the NRCs Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under Accession No. ML063100359.
 
AVAILABILITY INFORMATION Single copies of regulatory guides, both active and draft, and draft NUREG documents may be obtained free of charge by writing the Reproduction and Distribution Services Section, OCIO, USNRC, Washington, DC 20555-0001, or by email to
    <DISTRIBUTION@NRC.GOV>, or by fax to (301)415-2289. Active guides may also be purchased from the National Technical Information Service on a standing order basis. Details on this service may be obtained by writing NTIS, 5285 Port Royal Road, Springfield, VA 22161.
Many NRC documents are available electronically in our Reference Library on our web site, <WWW.NRC.GOV>, and through our Electronic Reading Room (ADAMS, or PARS, document system) at the same site. Copies of active and draft guides and many other NRC documents are available for inspection or copying for a fee from the NRC Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDRs mailing address is USNRC PDR, Washington, DC 20555; telephone (301)415-4737 or (800)397-4209; fax (301)415-3548; email is
                          <PDR@NRC.GOV>.
Copies of NUREG-series reports are available at current rates from the U.S. Government Printing Office, P.O. Box 37082, Washington, DC 20402-9328 (telephone (202)512-1800); or from the National Technical Information Service by writing NTIS at 5285 Port Royal Road, Springfield, VA 22161; or telephone (703)487-4650; or on the internet at
<http://www.ntis.gov/ordernow> . Copies are available for inspection or copying for a fee from the NRC Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDRs mailing address is USNRC PDR, Washington, DC 20555; telephone (301)415-4737 or (800)397-4209; fax (301)415-3548; email is <PDR@NRC.GOV>.
TABLE OF CONTENTS A.INTRODUCTION1 B.DISCUSSION2 BACKGROUND2
 
REGULATORY REQUIREMENTS6 LICENSING AND DESIGN BASIS9 FIRE PROTECTION PROGRAM GOALS/OBJECTIVES11 C. REGULATORY POSITION14 1.FIRE PROTECTION PROGRAM14 1.1Organization, Staffing, and Responsibilities15 1.2Fire Hazards Analysis 17 1.3Safe Shutdown Analysis 20 1.4Fire Test Reports and Fire Data 21 1.5Compensatory Measures 21 1.6Fire Protection Training and Qualifications22 1.7Quality Assurance25 1.8Fire Protection Program Changes/Code Deviations32 2.FIRE PREVENTION39 2.1Control of Combustibles39 2.2Control of Ignition Sources42 2.3Housekeeping43 2.4Fire Protection System Maintenance and Impairments43 3.FIRE DETECTION AND SUPPRESSION44 3.1Fire Detection (Design Objectives and Performance Criteria)44 3.2Fire Protection Water Supply Systems (Design Objectives and Performance Criteria)46 3.3Automatic Suppression Systems (Design Objectives and Performance Criteria)49 3.4Manual Suppression Systems and Equipment52 3.5Manual Firefighting Capabilities53 4.BUILDING DESIGN/PASSIVE FEATURES58 4.1General Building and Building System Design58 4.2Passive Fire Resistive Features68 4.3Testing and Qualification of Electrical Raceway Fire Barrier Systems74 5.SAFE SHUTDOWN CAPABILITY83 5.1Safe Shutdown Performance Goals for Redundant Systems84 5.2Alternative or Dedicated Shutdown Design and Performance Goals 84 5.3Hot Standby (PWR) Hot Shutdown (BWR) Systems and Instrumentation85 5.4Cold Shutdown Systems and Instrumentation and Allowable Repairs87 5.5Fire Protection of Safe Shutdown Capability88
 
5.6 Alternative, Dedicated, or Backup Shutdown Capability93 5.7Post-Fire Safe Shutdown Procedures95 6.FIRE PROTECTION FOR AREAS IMPORTANT TO SAFETY96 6.1Areas Related to Power Operation96 6.2Other Areas102 7.PROTECTION OF SPECIAL FIRE HAZARDS EXPOSING AREAS IMPORTANT TO SAFETY104 7.1Reactor Coolant Pump Oil Collection104 7.2Turbine/Generator Building105 7.3Station Transformers105 7.4Diesel Fuel Oil Storage Areas106 7.5Flammable Gas Storage and Distribution106 D. IMPLEMENTATION107 GLOSSARY108 REFERENCES113 APPENDIX A: EQUIVALENCY122 REGULATORY ANALYSIS124 BACKFIT ANALYSIS 124 A. INTRODUCTION l
l A. INTRODUCTION                                                    l l
The primary objectives of fire protection programs(FPPs) at U.S. nuclear plants are to minimize both l the probability of occurrence and the consequences of fire. To meet these objectives, the fire protection programsFPPs for operating nuclear power plants are designed to provide reasonable assurance, through        l defense -in -depth, that a fire will not prevent the performance of necessary safe-shutdown functions, and    l that radioactive releases to the environment in the event of a fire will be minimized.                        l The NRCs regulatory framework that the U.S. Nuclear Regulatory Commission (NRC) has                l established for nuclear plant fire protection programs isFPPs consists of a number of regulations and        l supporting guidelines, including, but not limited to, General Design Criterion 3 (GDC 3), 10 CFR 50.48, Appendix R) 3, Fire Protection, as set forth in Appendix A, General Design Criteria for Nuclear Power      l Plants, to Title 10, Part 50, Domestic Licensing of Production and Utilization Facilities, of the Code of  l Federal Regulations (10 CFR Part 50); 10 CFR 50.48, Fire Protection; Appendix R, Fire Protection          l Program for Nuclear Power Facilities Operating Prior to January 1, 1979,to 10 CFR Part 50,; regulatory      l guides,; generic communications ([e.g., Ggeneric Letters, Bulletins, and Information Notices), NUREG          l reports, the Standardletters (GLs), regulatory issue summaries (RISs), bulletins, and information notices    l (INs)]; NUREG-series reports, including NUREG-0800, Standard Review Plan (NUREG-0800) and                    l associated Branch Technical Positions,for the Review of Safety Analysis Reports for Nuclear Power            l Plants (NUREG-0800 or SRP);and industry standards. Since allof the fire protection regulations              l
 
l promulgated by the NRC aredo not applicableapply to all plants, they havethis guide does not been l characterizedcategorize them as regulations in this guide. Licensees should refer to their plant-specific l licensing bases to determine the applicability of a specific regulation to a specific plant.
l        This draft regulatory guide is organized as shown on the following pages.
l                                                                                                                                                                  Page l
l A.      INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 l
l B.      DISCUSSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 l        Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 l        Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 l        Licensing and Design Basis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 l        Fire Protection Program Goals and Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 l
l C.      REGULATORY POSITION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 l
l        1.      FIRE PROTECTION PROGRAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                              20 l                  1.1      Organization, Staffing, and Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                            20 l                  1.2      Fire Hazards Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                22 l                  1.3      Safe-Shutdown Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                    25 l                  1.4      Fire Test Reports and Fire Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                    25 l                  1.5      Compensatory Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                    26 l                  1.6      Fire Protection Training and Qualifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                            27 l                  1.7      Quality Assurance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .              30 l                  1.8      Fire Protection Program Changes/Code Deviations . . . . . . . . . . . . . . . . . . . . . . . . . . .                                    37 l
l        2.      FIRE PREVENTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                  44 l                  2.1      Control of Combustibles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                  44 l                  2.2      Control of Ignition Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                  47 l                  2.3      Housekeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .              48 l                  2.4      Fire Protection System Maintenance and Impairments . . . . . . . . . . . . . . . . . . . . . . . . .                                      48 l
l        3.      FIRE DETECTION AND SUPPRESSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                                  49 l                  3.1      Fire Detection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .            49 l                  3.2      Fire Protection Water Supply Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                            50 l                  3.3      Automatic Suppression Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                        53 l                  3.4      Manual Suppression Systems and Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                                  55 l                  3.5      Manual Firefighting Capabilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                      57 l
l        4.      BUILDING DESIGN/PASSIVE FEATURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                                      61 l                  4.1      General Building and Building System Design . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                                61 l                  4.2      Passive Fire-Resistive Features . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                    71 l                  4.3      Testing and Qualification of Electrical Raceway Fire Barrier Systems . . . . . . . . . . . . .                                            76 l
l        5.      SAFE-SHUTDOWN CAPABILITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                              85 l                  5.1      Post-Fire Safe-Shutdown Performance Goals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                                86 l                  5.2      Cold Shutdown and Allowable Repairs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                            86 l                  5.3      Fire Protection of Safe-Shutdown Capability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                              87 l                  5.4      Alternative and Dedicated Shutdown Capability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                                90 l                  5.5      Post-Fire Safe-Shutdown Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                            93 l                  5.6      Shutdown/Low-Power Operation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                            94 l
DG-1170, Page 6
: 6.      FIRE PROTECTION FOR AREAS IMPORTANT TO SAFETY . . . . . . . . . . . . . . . . . . . . . . . 94                                                          l 6.1          Areas Related to Power Operation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 94                        l 6.2          Other Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 100          l l
: 7.      PROTECTION OF SPECIAL FIRE HAZARDS EXPOSING AREAS                                                                                                      l IMPORTANT TO SAFETY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                          101 l 7.1          Reactor Coolant Pump Oil Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                          101 l 7.2          Turbine/Generator Building . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                    102 l 7.3          Station Transformers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .              103 l 7.4          Diesel Fuel Oil Storage Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                    103 l 7.5          Flammable Gas Storage and Distribution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                            103 l 7.6          Nearby Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .            104 l l
: 8.      FIRE PROTECTION FOR NEW REACTORS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                                            104 l 8.1          General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .        104 l 8.2          Enhanced Fire Protection Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                      104 l 8.3          Passive Plant Safe-Shutdown Condition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                            105 l 8.4          Applicable Industry Codes and Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                            105 l 8.5          Other New Reactor Designs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                      105 l 8.6          Fire Protection Program Implementation Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . .                                  106 l 8.7          Fire Protection for Nonpower Operation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                          106 l l
: 9.      FIRE PROTECTION FOR LICENSE RENEWAL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106                                              l l
D.      IMPLEMENTATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108                l l
REGULATORY ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108                  l l
BACKFIT ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108          l l
GLOSSARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109 l l
REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 115  l l
APPENDIX A. EQUIVALENCY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1                    l l
APPENDIX B. FIRE PROBABILISTIC RISK ASSESSMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-1                                              l l
Section B,DiscussionDiscussion, of this guide provides a brief history and discussion of the                                                                  l development and application offire protection regulations and guidelines in the U.S. commercial nuclear                                                                  l power industry. The discussion includes summaries of the applicable regulations, the primary fire protection objectives, the varied licensing and design bases, and the primary assumptions relative to postulated fire events for nuclear power reactors.
Section C, RegulatoryRegulatory Position, provides identifies staff positions and guidance                                                                    l relativerelevant to providing an acceptable level of fire protection for operating nuclear power plants.                                                                l The positions and guidance provided are a compilation of the fire protection requirements and guidelines                                                                l from the existing regulations and staff guidance. In addition, as appropriate,                                          this section offersnew                          l guidance is providedwhere the existing guidance isweak or non-existent.                                                                                                  l Section D, ImplementationImplementation, describes how the NRC staff will use this guide.                                                                    l DG-1170, Page 7
 
l          ThisThe NRC staff developed this regulatory guide has been developed to provide a comprehensive fire protection guidance document and to identify the scope and depth of fire protection l that the staff would consider acceptable for nuclear plants currently operating as of Januarypower plants.
l The original issue of this guide addressed only plants operating as of January 1, 2001. This revision l provides guidance for new reactor designs. In addition, this revision incorporates the guidance previously l included in Branch Technical Position (BTP) SPLB 9.5-1, Guidelines for Fire Protection for Nuclear l Power Plants (Formerly BTP CMEB 9.5-1). This regulatoryguide may be used for licensee self-l assessments and as the deterministic basis for future rulemaking.
l l          Many existing nuclear plants are adopting risk-informed, performance-based FPPs in accordance l with 10 CFR 50.48(c) and National Fire Protection Association (NFPA) Standard 805, Performance-l Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants, 2001 Edition.
l While much of the guidance provided here has been incorporated in the FPP of these plants and will l continue to be appropriate for a risk-informed, performance-based FPP, the guidance provided l in Regulatory Guide 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water l Nuclear Power Plants, will take precedence over the guidance provided in this regulatory guide l for plants that adopt a risk-informed, performance-based FPP in accordance with 10 CFR 50.48(c).
l l          Risk-informed and performance-based alternatives to the guidance presented in this rdocument l that are in accordance with Regulatory gGuide 1.205 may be acceptable to the NRC staff.
l          The for plants that do not modify their licenses in accordance with 10 CFR 50.48(c). Licensees l that do not adopt a program based on NFPA 805 may use risk-informed, performance-based methods to l determine the acceptability of a plant change; however, licensees should submit the methodology, l including acceptance criteria, for NRC review and approval as a license amendment request in l accordance with 10 CFR 50.90, Application for Amendment of License or Construction Permit, before l implementing the change.
l l          Regulatory Guide 1.191, Fire Protection Program for Nuclear Power Plants During l Decommissioning and Permanent Shutdown, provides specific criteria and guidelines for FPPs l for shutdown and decommissioning of nuclear power plants.
l l          The NRC issues regulatory guides to describe to the public methods that the staff considers l acceptable for use in implementing specific parts of the agencys regulations, to explain techniques l that the staff uses in evaluating specific problems or postulated accidents, and to provide guidance l to applicants. Regulatory guides are not substitutes for regulations, and compliance with regulatory guides l is not required. The NRC issues regulatory guides in draft form to solicit public comment and involve l the public in developing the agencys regulatory positions. Draft regulatory guides have not received l complete staff review and, therefore, they do not represent official NRC staff positions.
l l          This regulatory guide contains information collections contained in this regulatory guidethat are l covered by the requirements of 10 CFR Part 50, which were approved by the Office of Management and l Budget, approval (OMB) approved under OMB control number 3150-0011. If a means used to impose an l information collection does not display a currently valid OMB control number,  Thet NRC maynotneither l conduct ornor sponsor, and a person is not required to respond to, the informationan information collection l request or requirement unless the requesting document displays a currently valid OMB control number.
l l
l                                            B. DISCUSSION DG-1170, Page 8
 
BACKGROUND Background                                                                                        l During the initial implementation of the U.S. nuclear reactor program, regulatory acceptance of fire protection programsof FPPs at nuclear power plants was based on the broad performance objectives of      l General Design Criterion 3 (GDC 3) in Appendix A to 10 CFR Part 50. Appendix A establishes the                l necessary design, fabrication, construction, testing, and performance requirements for structures, systems, and components (SSCs) important to safety. GDC 3 addresses fire protection requirements and          l specifies, in part, that (1) structures, systems, and components SSCs important to safety must be designed    l and located to minimize the probability and effects of fires and explosions, (2) noncombustible and heat-resistant materials must be used wherever practical, and (3) fire detection and suppression systems      l must be provided to minimize the adverse effects of fires on structures, systems, and componentsSSCs          l important to safety. However, during this early stage of nuclear power regulation, given the lack of detailed implementation guidance for this general design criterionGDC during this early stage of nuclear      l power regulation, the level of fire protection was generally found to beconsidered acceptable if the          l facility complied with local fire codes and received an acceptable rating from its fire insurance underwriter. Thus, the fire protection features installed in early U.S. nuclear power plants were very similar to those installed in conventional fossil-fuel power generation stations.
A fire at the Browns Ferry Nuclear Power Plant, Unit 1, on March 22, 1975, was a pivotal event that brought fundamental change to fire protection and its regulation in the U.S. nuclear power industry.
The fire started when plant workers in the cable spreading room used an open flame to test for air leakage through a non-fire-rated (polyurethane foam) penetration seal that led to the reactor building. The fire ignited both the seal material and the electrical cables that passed through it, and burned for almost 7 hours before it wasbeing extinguished usingby a water hose stream. The greatest amount of fire damage        l actually occurred on the reactor building side of the penetration, in an area roughly 12.2 mmeters (m) [40    l feet (ft)] by 6.1 m (20 feet). MThe fire affected more than 16001,600 cables, routed in 117 conduits and      l 26 cable trays, were; of the affected and, of those cables affected, 628 were important to safety. The fire  l damage to electrical power, control systems, and instrumentation cables impeded the functioning of both normal and standby reactor cooling systems and degraded plant monitoring capability for the operators.
Given the loss of multiple safety systems, operators had to initiate emergency repairs in order to restore the systems needed to place the reactor in a safe -shutdown condition.                                        l The investigations that followed the Browns Ferry fire identified significant deficiencies, in both l in the design of fire protection features and inthe licensees procedures for responding to a fire event. l The investigators concluded that the occupant safety and property protection concerns of fire insurance underwriters did not sufficiently encompass nuclear safety issues, especially in terms of the potential for fire damage to cause the failure of redundant success paths of systems and components important for safe reactor shutdown. In its report (NUREG-0050, February 1976, Recommendations Related to Browns Ferry FireFire, February 1976), the NRCs Browns Ferry special review team recommended that the            l NRCagency (1) develop detailed guidance for implementing the general design criterion for fire                l protection and (2) conduct a detailed review of the fire protection programFPP at each operating nuclear      l power plant, comparing itwhich would compare the FPP to the guidance developed.                              l In May 1976, the NRC issued Branch Technical Position (BTP) APCSB 9.5-1, Guidelines for            l Fire Protection for Nuclear Power Plants, dated May 1, 1976, which incorporated the recommendations          l from the Browns Ferry fire special review team and provided technical guidelines to assist licensees in preparing their fire protection programsFPPs. As part of this action, the staff requestedasked each          l DG-1170, Page 9
 
l licensee to provide an analysis that divideddividing the plant into distinct fire areas and l demonstrateddemonstratingthat redundant success paths of equipment required to achieve and maintain safe  -
l shutdown conditions for the reactor were adequately protected from fire damage. However, the l guidelines of APCSB 9.5-1 applied only to those licensees that filed for a construction permit after July 1, 1976.
l          In September 1976, in an effort to establish defense-in-depth fire protection programsFPPs, without significantly affecting the design, construction, or operation of existing plants that were either already operating or well past the design stage and into construction, the NRC modified the guidelines in APCSB 9.5-1 and issued Appendix A to APCSB 9.5-1. This guidance provided acceptable alternatives in areas where strict compliance with APCSB 9.5-1 would require significant modifications.
l Additionally, the NRC informed each plant that the staff would use the guidance in Appendix A would be used to analyze the consequences of a postulated fire within each area of the plant and requested licensees to provide results of the fire hazards analysis performed for each unit and the technical specifications for the present fire protection systems.
l          Early in 1977, each licensee responded with a fire protection programan FPP evaluation that l included a fire hazards analysis. TheseThe staff reviewed these analyses were reviewed by the staff l using the guidelines of Appendix A to APCSB 9.5-1. The staff also conducted inspections ofinspected l operating reactors to examine the relationship of structures, systems, and componentsSSCs important to safety with the fire hazards, potential consequences of fires, and the fire protection features. After l reviewing licensees responses to the BTP, the staff determined that additional guidance on the l management and administration of fire protection programsFPPs was necessary, and, in mid-1977, issued l Generic Letter 77-002,GL 77-02, Nuclear Plant Fire Protection Functional Responsibilities, l Administrative Controls and Quality Assurance, which provided criteria used by the staff into review of l specific elements of a licensees fire protection programFPP, including organization, training, l combustible and ignition source controls, firefighting procedures, and quality assurance (QA). MThe l BTP review process resolved many fire protection issues were resolved during the BTP review process, l and agreements were included, as reflected in the NRC-issued safety evaluation reports (SERs).
l          By the late 1970s to early 1980, the majority ofmost operating plants had completed their l analyses and implemented mostmuch of the fire protection programFPP guidance and recommendations specified in Appendix A to the BTP. In most cases, the NRC had found the licensees proposed l modifications resulting from these analyses to be acceptable. In certain instances, however, technical l disagreements between licensees and the NRC staff led to some licensees opposition to oppose tohe l adopt someion of thecertain specified fire protection recommendations, such as the requirements for fire brigade size and training; water supplies for fire suppression systems; alternative, dedicated, or backup shutdown capability; emergency lighting; qualifications of penetration seals used to enclose places where l cables penetrated fire barriers; and the prevention of reactor coolant pump (RCP) oil system fires.
Following deliberation, the Commission determined that, given the generic nature of some of the l disputed issues, a rulemaking was necessary to ensure proper implementation of the NRCs fire protection requirements.
l          In November 1980, the NRC published the "FireFire Protection" rule, 10 CFR 50.48, which specified broad performance requirements, as well as Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979," to 10 CFR Part 50, which specified detailed regulatory requirements for resolving the disputed issues.
l          As originally proposed (Federal Register, Vol.Volume 45, No. 1&5Numbers 1 and 5, May 22, l 1980), Appendix R would have applied to all plants licensed prior tobefore January 1, 1979, including DG-1170, Page 10
 
those for which the staff had previously accepted the fire protection features as meeting the provisions of Appendix A to APCSB 9.5--1. After analyzing comments on the proposed rule, the Commission                    l determined that only three3 of the fifteen15 items in Appendix R were of such safety -significance that      l they should apply to all plants (licensed prior tobefore January 1, 1979), including those for which the    l staff had previously approved alternative fire protection actions had been approved previously by the        l staff. These three items are fire protection of safe -shutdown capability (including alternative, dedicated, l or backup shutdown systems), emergency lighting, and the reactor coolant pumpRCP oil system.                l 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 (Federal Register, Vol.Volume 45, Nov.November 19, 1980).                                        l l
In addition, the rule provided an exemption process that can be requested by a. A licensee can      l request an exemption, provided that a required fire protection feature to be exempted would not enhance      l fire protection safety in the facility, or that such modifications may be detrimental to overall safety ([10 l CFR 50.48(c)(6))]. Under this process, if the Director, of the NRCs Office of Nuclear Reactor              l Regulation, (NRR) determineds that a licensee has made a prima facie showing of a sound technical basis      l for such an assertion, then thethe Commission would delay implementation dates of the rule were              l delayed until it took final Commission action on the exemption request. Appendix R to 10 CFR Part 50        l and 10 CFR 50.48 became effective on February 17, 1981.
During the initial backfit of the fire protection regulation, the NRC approved a large number ofmany plant-specific exemptions (i.e., alternative methods to achieve the underlying purpose of the        l regulation) at about 60 nuclear power plants. Since the mid-1980s, as licensees programs have becaome      l more compliant with the fire protection regulations, the number of exemptions requested and approved has decreased. Even so, the ongoing review of licensee fire protection programsFPPs, the licensee            l efforts to save costs while maintaining an acceptable level of safety, and the emergence of additional technical issues (such as the deliberations over the adequacy of Thermo-Lag as a fire protection barrier) have resulted in several hundred exemptions to specific elements of the NRC fire protection requirements. This progression, the broad provisions of the general design criterionGDC, the detailed        l implementing guidance, the plant-by-plant review, and finally the issuance and backfit of the fire protection regulation and the prescriptive requirements of Appendix R resulted in a complex regulatory framework for fire protection in U.S. nuclear power plants licensed prior tobefore 1979 and resulted in      l the issuance of a number of additional guidelines, clarifications, and interpretations, primarily as generic letters. Plants licensed after January 1, 1979, were not required to meet the provisions of Appendix R unless specifieddirected to do so in specific license conditions. These plants were typically reviewed      l tousing the guidelines of Section 9.5.1, Fire Protection Program, of the Standard Review PlanSRP          l (NUREG-0800), which subsumed the criteria specified in Appendix R. In July 1981, the NRC issued a major revision to NUREG-0800 for use in the review of new license applications. This revision included      l Standard Review PlanSRP Section 9.5.1 with Branch Technical PositionBTP CMEB 9.5-1 as an update              l to the earlier fire protection BTPs.
Following promulgation of 10 CFR 50.48 and Appendix R, the staff issued Generic LetterGL 81-        l 12, Fire Protection Rule (February 2045 FR 76602, November 19, 19810), and later its associated            l clarification letter (March 22, 1982). In these letters, the staff identified the information necessary to perform theirits reviews of licensee compliance with the alternative or dedicated shutdown requirements      l of Section III.G.3 of Appendix R. Staff guidance provided in these letters defined safe -shutdown            l objectives, reactor performance goals, necessary safe -shutdown systems and components, and associated      l circuit identification and analysis methods. Generic LetterGL 81-12 also requested that licensees            l develop technical specifications be developed for safe -shutdown equipment that waswere not already          l included in the existing plant technical specifications.
DG-1170, Page 11
 
l          Most licensees requested and were grantedreceived additional time to perform their reanalysis, l propose modifications to improve post -fire safe -shutdown capability, and identify exemptions for certain fire protection configurations. In reviewing some exemption requests, the staff noted that a l number of licensees had made significantly different interpretations of certain requirements. TheseThe l staff identified these differences were identified in the staff's draft SERs and were discussed them on several occasions with the cognizant licensees. These discussions culminated in the issuance of Generic l Letter 83-33 (October 19, 1983).GL 83-33, NRC Positions on Certain Requirements of Appendix R to l 10 CFR Part 50.
Certain licensees disagreed with, or found it difficult to implement, the interpretations provided l in Generic LetterGL 83-33. To pursue the matter with senior NRC management, the industry formed the Nuclear Utility Fire Protection Group. Subsequently, the staff formed the Steering Committee on Fire Protection Policy.
Following staff inspections of operating plants, which identified a number of significant items of l non-compliance,noncompliance and disagreements in the implementation of interpretations provided in l Generic LetterGL 83-33, the Nuclear Utility Fire Protection Group requested interpretations of certain l Appendix R requirements and providedprepared a list of questions to be discussed with the industry. The l NRC responded by holding workshops in each Rregion to assist the industry in understanding the NRCs l requirements and to improve the staffs understanding of the industrys concerns. The Fire Protection l Policy Steering Committee documented the results of these workshops and the Ssteering Ccommittees findings and recommendations for addressing ongoing fire protection issues were documented in Generic l Letter 85-01in the Fire Protection Policy Steering Committee Report. Generic Letter 85-01The report l included a proposed Ggeneric Lletter that provided additional interpretations related to compliance with Appendix R and staff answers to the industrys list of questions from the workshops. This proposed l Generic Letter wasThe staff revised and later issued as Gthis proposed generic Lletter as GL 86--10, Implementation of Fire Protection Requirements, on April 24, 1986.
l          Also included in Generic LetterGL 86-10 was a standard license condition for adoption by licensees. Through the implementation and adoption of a standard license condition, a licensee was l allowed to make changes to its fire protection programFPP without prior notification tofirst notifying the l NRC in accordance with the provisions of 10 CFR 50.59, Changes, Tests and Experiments, provided l that the changes did not adversely affect the plants ability to achieve and maintain post-fire safe l shutdown after a fire. The licensee, uUpon modification of the license to adopt the standard condition, l the licensee could also amend the license to remove the fire protection technical specifications. Generic l LetterGL 88-12, Removal of Fire Protection Requirements from Technical Specifications l (Specifications, dated August 2, 1988), gave licensees additional guidance for implementation l ofimplementing the standard license condition and removal ofremoving the technical specifications l associated with fire detection and suppression, fire barriers, and fire brigade staffing. TLicensees were to l retain the technical specifications associated with safe -shutdown equipment and the administrative controls related to fire protection audits were to be retained under the guidance of the generic letter.
l          As illustratedBeginning in the preceding discussionlate 1990s, the CommissionsCommission l provided the NRC staff with guidance for identifying and assessing performance-based approaches to l regulation. In SECY-98-0058, Development of a Risk-Informed, Performance-Based Regulation for l Fire Protection at Nuclear Power Plants, dated March 26, 1998, the NRC staff proposed to the l Commission that the staff work with the NFPA and industry to develop a performance-based, risk-l informed consensus standard for fire protection requirements and guidelines consist of a multitude of rules, generic communications, staff guidance, and other related documents. Current industry and DG-1170, Page 12
 
regulatory issues have prompted action on the part of the NRC to compile the current fire protection regulations and guidelines for operating reactors into this comprehensive guide.
REGULATORY REQUIREMENTS There are a number of regulatory requirements with applicability to the development and implementation of fire protection programs for nuclear power plants currently operating as of January 1, 2001. The primary requirements are summarized in this section.
Appendix A to 10 CFR Part 50 Appendix A, General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50 establishes for those plants for which its provisions apply, the necessary design, fabrication, construction, testing, and performance requirements for structures, systems, and components important to safety (see Glossary). The following subsections summarize those GDC with specific application to fire protection of nuclear power plants.
GDC 3, Fire Protection GDC 3 requires that structures, systems, and components important to safety be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. Noncombustible and heat resistant materials are required to be used wherever practical, particularly in locations such as the containment and control room. Fire detection and fighting systems of appropriate capacity and capability are required to be provided and designed to minimize the adverse effects of fires on structures, systems, and components important to safety. GDC 3 also requires that firefighting systems be designed to ensure that their failure, rupture, or inadvertent operation does not significantly impair the safety capability of these structures, systems, and components.
GDC 5, Sharing of Structures, Systems, and Components GDC 5 requires that structures, systems, and components important to safety not be shared among nuclear power units unless it can be shown that such sharing will not significantly impair their ability to perform their safety functions, including, in the event of an accident in one unit, an orderly shutdown and cooldown of the remaining units.
GDC 19, Control Room GDC 19 requires that a control room be provided from which actions can be taken to operate the nuclear power unit under normal and accident conditions, while limiting radiation exposure to control room personnel under accident conditions for the duration of the accident. GDC 19 also requires that equipment and locations outside the control room be provided with the design capability to accomplish hot shutdown of the reactor and with a potential capability for subsequent cold shutdown of the reactor.
GDC 23, Protection System Failure Modes GDC 23 requires that the protection system be designed to fail into a safe state or into a state demonstrated to be acceptable on some other defined basis if conditions such as disconnection of the system, loss of energy (e.g., electric power, instrument air), or postulated adverse environments (e.g.,
extreme heat or cold, fire, pressure, steam, water, radiation) are experienced.
DG-1170, Page 13
 
10 CFR 50.48 Section 50.48 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 Part 50. It specifies what should be contained in such a plan and lists the basic fire protection guidelines for the plan.
Section 50.48 also requires that all plants with operating licenses prior to January 1, 1979, satisfy the requirements of Sections III.G, III.J, and III.O, and other sections of Appendix R to 10 CFR Part 50, where approval of similar features had not been obtained prior to the effective date of Appendix R.
Plants licensed to operate after January 1, 1979, must meet the provisions of 10 CFR 50.48(a).
As discussed later in this guide in the Licensing and Design Basis section, deviations from NRC fire protection requirements are documented and reviewed under different processes depending on the date of the operating license. Appendix R requirements for pre-1979 plants are processed under the exemption process. Deviations from other applicable guidelines are identified and evaluated in the staffs Safety Evaluation Reports. For post-1979 plants, where fire protection features do not meet applicable NRC requirements or commitments, or alternative approaches are proposed, the condition is documented as a deviation.
Appendix R to 10 CFR Part 50 Appendix R to 10 CFR Part 50 applies to licensed nuclear power electric generating stations that were operating prior to January 1, 1979, except as noted in 10 CFR 50.48(b). With respect to certain generic issues for such facilities, Appendix R identifies fire protection features required to satisfy Criterion 3 of Appendix A. There are two categories of Appendix R provisions that are applicable to the fire protection features of these facilities.
The first category consists of those provisions that were required to be backfit in their entirety, regardless of whether alternatives to the specific requirements had been previously approved by the NRC. The requirements are identified in Sections III.G, Fire Protection of Safe Shutdown Capability; III.J, Emergency Lighting; and III.O, Oil Collection System for Reactor Coolant Pump. Those plants subject to the requirements of Section III.G.3 must also meet the requirements of Section III.L.
The second category consists of requirements concerning the open items of previous NRC staff fire protection reviews. Open items are defined as fire protection features that had not been previously approved by the NRC staff as satisfying the provisions of Appendix A to APCSB 9.5-1, as reflected in SERs.
Except as specified in the license conditions of individual plants, Appendix R was not required to be implemented by plants that were licensed to operate after January 1, 1979. Rather, fire protection programs at these later plants were typically reviewed against the licensing review guidelines of Section 9.5-1 to the Standard Review Plan (NUREG-0800). SRP Section 9.5-1 and the associated CMEB 9.5-1 consolidated the guidance of the previous BTP, Appendix A to APCSB 9.5-1, Appendix R, and other staff guidance.
10 CFR Parts 50.72 and 50.73 These regulations prescribe the notification and reporting requirements for nuclear power plant licensees, including those related to fire protection programs. Section 50.72 provides for immediate DG-1170, Page 14
 
notification requirements via the emergency notification system (ENS), and Section 50.73 provides for 60-day writtenthat, if the standard was acceptable, would be endorsed by the staff in a rulemaking. The      l NFPA Standards Council issued NFPA 805, 2001 Edition, on January 13, 2001. The NRC published                l 10 CFR 50.48(c) endorsing NFPA 805 on June 16, 2004 (69 FR 33536). Regulatory Guide 1.205                    l provides staff guidance for licensees that elect to adopt a risk-informed, performance-based FPP in          l accordance with 10 CFR 50.48(c) and NFPA 805.                                                                l l
In 1997, the NRC staff noticed that a series of licensee event reports (LERs).                      l The information reported under 10 CFR 50.72 and 50.73 is used by the NRC staff in responding to emergencies, monitoring ongoing events, confirming licensing bases, studying potentially generic safety problems, assessing trends and patterns of operational experience, monitoring performance, identifying precursors of more significant events, and providing operational experience to the industry.
The two rules have identical reporting thresholds and similar language whenever possible. They are complementary and of equal importance, with necessary dissimilarities in reporting requirements to meet their different purposes.
The regulation, 10 CFR 50.72, is structured to provide telephone notification of reportable events to the NRC Operations Center within a time frame established by the relative importance of the events.
Events are categorized as either emergencies (immediate notifications, but no later than 1 hour) or non-emergencies. Non-emergencies are further categorized into 1-hour and 4-hour notifications; non-emergency events requiring 4-hour notifications generally have slightly less urgency and safety significance than those requiring 1-hour notifications. Immediate telephone notification to the NRC Operations Center of declared emergencies is necessary so the NRC may immediately respond.
Reporting of non-emergency events and conditions is necessary to permit timely NRC follow-up via event monitoring, special inspections, generic communications, or resolution of public or media concerns.
According to 10 CFR 50.73, written LERs must be submitted on reportable events within 60 days of their occurrence, after a thorough analysis of the event, its root causes, safety assessments, and corrective actions are available, to permit NRC engineering analyses and studies.
LICENSING AND DESIGN BASIS The fire protection licensing and design basis is dependent on a number of factors that may differ considerably for individual plants. However, with the issuance of the fire protection rule, 10 CFR 50.48, and Appendix R to 10 CFR 50, the applicability of certain fire protection requirements, including those within the rule, was established on the basis of the licensing date for a given plant being before or after January 1, 1979.
Plants Licensed Prior to January 1, 1979 The primary licensing basis for plants licensed to operate prior to January 1, 1979, is comprised of the plant license conditions, Appendix R and any approved exemptions, and the staffs Safety Evaluation Reports (SERs) on the fire protection program.
Safety Evaluation Reports The SERs document the staff acceptance of the plant fire protection program or elements thereof.
For plants licensed to operate prior to January 1, 1979, the staffs SERs also establish the extent to which the requirements of Appendix R to 10 CFR Part 50 apply. Plants whose fire protection features were DG-1170, Page 15
 
accepted by the NRC as satisfying the provisions of Appendix A to Branch Technical Position (BTP)
APCSB 9.5-1, or were accepted in comprehensive SERs issued prior to publication of Appendix A to BTP APCSB 9.5-1 in August 1976, were only required to meet the provisions of Sections III.G (III.L),
III.J, and III.O of Appendix R.
Exemptions to Appendix R Effective February 17, 1981, the NRC amended its regulations by adding 10 CFR 50.48 and Appendix R to 10 CFR Part 50, requiring certain provisions for fire protection in nuclear power plants licensed to operate before January 1, 1979.
Plants with previously approved fire protection features (see Safety Evaluation Reports above) were exempted from the requirements of Appendix R with the exception of Sections III.G, III.J, and III.O.
The required schedules for licensees to comply with the provisions of Appendix R were established in 10 CFR 50.48(c). Provisions were also included in the rule to allow licensees to file exemptions from Appendix R requirements on the basis that the required modifications would not enhance fire protection safety in the facility or would be detrimental to overall facility safety. These exemptions, upon approval by the staff, become a part of the fire protection licensing basis. The provisions of 10 CFR 50.48(c) have since expired and have been deleted from the regulations. Future exemptions should be requested in accordance with 10 CFR 50.12, as discussed below. (See Regulatory Position 1.8.2.)
Exemptions from fire protection requirements may also be requested in accordance with the provisions of 10 CFR 50.12. Under 10 CFR 50.12, the Commission may grant exemptions from the requirements of the regulations in 10 CFR Part 50, which are:
: 1.      Authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security.
: 2.      The Commission will not consider granting an exemption unless special circumstances are present. Special circumstances are present whenever; C      Application of the regulation in the particular circumstances conflicts with other rules or requirements of the Commission; or C      Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule; or C      Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated; or C      The exemption would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemption; or DG-1170, Page 16
 
C      The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation; or C      There is present any other material circumstance not considered when the regulation was adopted for which it would be in the public interest to grant an exemption. If such condition is relied on exclusively for satisfying criteria (2) above, the exemption may not be granted until the Executive Director for Operations has consulted with the Commission.
Operating License Conditions Most operating plant licenses contain a section on fire protection. License conditions for plants licensed prior to January 1, 1979, typically contain a condition requiring implementation of modifications committed to by the licensee as a result of the fire protection program review with respect to the branch technical position. 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.
As a result of numerous compliance, inspection, and enforcement issues associated with the various plant license conditions, the staff developed a standard licensing condition. The standard license condition, and the NRCs recommendation that it be adopted by licensees, was transmitted to licensees in Generic Letter 86-10. Additional guidance regarding removal of the fire protection requirements from the plant technical specifications was provided to licensees in Generic Letter 88-12. The changes were promulgated to provide licensees greater flexibility in the management and implementation of the fire protection program and to clarify the fire protection licensing basis for the specific facility.
Plants Licensed After January 1, 1979 Plants licensed after January 1, 1979, are subject to the requirements of 10 CFR 50.48(a) only, and as such must meet the provisions of GDC 3 as specified in their license conditions and as accepted by the NRC in their SERs. These plants are typically reviewed to the guidance of SRP Section 9.5-1.
For these plants, where commitments to specific guidelines cannot be met, or alternative approaches are proposed, the differences between the licensees program and the guidelines are documented in deviations (see Regulatory Position 1.4.4).
FIRE PROTECTION PROGRAM GOALS/OBJECTIVES Defense in Depth Fire protection for nuclear power plants uses the concept of defense in depth to achieve the required degree of reactor safety by using echelons of administrative controls, fire protection systems and features, and safe shutdown capability. These defense-in-depth principles are aimed at achieving the following objectives.
C        To prevent fires from starting, C        To detect rapidly, control, and extinguish promptly those fires that do occur, and DG-1170, Page 17
 
C        To provide protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by the fire suppression activities will not prevent the safe shutdown of the plant.
Assumptions Postulated Fire Fire damage to safe shutdown equipment is assessed on the basis of a single fire, including an exposure fire. An exposure fire is a fire in a given area that involves either in situ or transient combustibles and has the potential to affect structures, systems, and components important to safety located in or adjacent to that same area. The effects of such fire (e.g., smoke, heat, or ignition) can adversely affect those structures, systems, and components important to safety. Thus, a fire involving one success path of safe shutdown equipment may constitute an exposure fire for the redundant success path located in the same area, and a fire involving combustibles other than either redundant success path may constitute an exposure fire to both redundant success paths located in the same area.
Three levels of fire damage limits are established according to the safety function of the structure, system, or component. Damage limits for hot shutdown and cold shutdown systems and components are described in Regulatory Positions 5.3 and 5.4, respectively. Redundant systems necessary for mitigation of consequences following design basis accidents, but not required for safe shutdown may be damaged by a single exposure fire as discussed below in the Safety-Related Structures, Systems, and Components section.
The most stringent fire damage limit should apply for those systems that fall into more than one category.
The fire event for considering the need for alternative or dedicated shutdown is a postulated fire in a specific fire area containing redundant safe shutdown cables/equipment where it has been determined that fire protection means specified in Regulatory Position 5.5 cannot be provided to ensure that safe shutdown capability will be preserved.
Conditions of Fire Occurrence It is assumed that a fire may occur at any time, but is not postulated to occur simultaneously with plant accidents or the most severe natural phenomena.
On multiple reactor sites, unrelated fires in two or more units need not be postulated to occur simultaneously. Fires involving facilities shared between units and fires caused by man-made site-related events that have a reasonable probability of occurring and affecting more than one reactor unit (such as an aircraft crash) should be considered.
Loss of Offsite Power/Station Blackout In evaluating the capability to accomplish post-fire safe shutdown, offsite power may or may not be available and consideration should be given to both cases. However, loss of offsite power need not be considered for a fire in non-alternative or dedicated shutdown areas if it can be shown that offsite power cannot be lost due to a fire in that area.
In accordance with the guidelines in Regulatory Position 5.6 of this guide, the capability to accomplish safe shutdown should be demonstrated for a loss of offsite power with a duration of 72 hours.
However, in evaluating safe shutdown circuits, including associated circuits, the availability of uninterrupted power (i.e., offsite power available) may impact the ability to control the safe shutdown of DG-1170, Page 18
 
the plant by increasing the potential for associated circuit interactions resulting from fire damage to energized power and control circuits.
Several licensees have alternative post-fire safe shutdown methodologies that may result in loss of all ac power (i.e., station blackout). Some of these plants voluntarily enter station blackout (SBO) as a means to cope with the potential for spurious operations and to provide positive (manual) control of safe shutdown equipment. Others have procedures that may cause a SBO condition to be created as a result of fire effects (e.g., procedures that direct operators to manually trip the credited safe shutdown emergency diesel generator (EDG) in the event of fire damage to circuits of vital EDG support systems).
The ability to cope with SBO as part of the post-fire safe shutdown methodology is dependent on such issues as timeline logic; assumptions and bases for plant and operator response relative to component realignment; the ability of plant operators to monitor and control plant parameters and align plant components before, during, and after SBO control room evacuation and abandonment; and the practicality and reliability of EDG start and load (and restart, if applicable) under post-fire safe shutdown SBO conditions. The relative risk of self-imposed SBO may greatly exceed the actual risk posed by the fire and should be given appropriate consideration when evaluating the plant safe shutdown design and procedures.
Fragility of Structures, Systems, and Components to Fire Damage Fire damage to structures, systems, and components can result from heat, smoke, or ignition.
Fire is assumed to damage safe shutdown structures, systems, and components within the fire area of concern as discussed in the Postulated Fire section above and subject to the guidelines in Regulatory Positions 5.3 and 5.4 of this guide and as determined by the fire hazards analysis. When using a performance-based or risk-informed alternative approach, the fragility of structures, systems, and components to fire damage, including the ability to repair affected structures, systems, and components, should be considered.
Fire Protection Program Performance Goals Safety-Related Structures, Systems, and Components Because fire may affect safe shutdown systems, and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.
Post-Fire Safe Shutdown The performance objectives of the fire protection program relative to post-fire safe shutdown are to ensure that one success path of structures, systems, and components necessary for hot shutdown is free of fire damage, and to limit fire damage such that one success path of structures, systems, and components necessary to achieve and maintain cold shutdown can be repaired or made operable within a specified time period using onsite capabilities (see Regulatory Position 5.3).
Prevention of Radiological Release The fire protection program, including the fire hazards analysis, should demonstrate that the plant will maintain the ability to minimize the potential for radioactive releases to the environment in the event of a fire. Fires are expected to occur over the life of a nuclear power plant and thus should be treated as anticipated operational occurrences. Requirements for protection against radiation during DG-1170, Page 19
 
normal operations are in 10 CFR Part 20. Anticipated operational occurrences should not result in radiological consequences, and the exposure criteria of 10 CFR Part 20 apply.
Post-Fire Safe Shutdown Reactor Safety/Performance Goals Power Operations l          One success path of cables and had identified plant-specific problems related to potential fire-l induced electrical circuit failures that could prevent operation or cause maloperation of equipment necessary to achieve and maintain hot shutdown is to be maintained free of fire damage. The reactor safety and performance goals for post-fire safe shutdown should ensure that the specified acceptable fuel design limits are not exceeded. Post-fire reactor safety and performance goals for alternative or l dedicated shutdown are. The NRC staff documented these problems in IN 99-17, Problems Associated l with Post-Fire Safe-Shutdown Circuit Analysis. Because of the number of similar LERs, the NRC l treated the issue generically. In 1998, the NRC staff began interacting with interested stakeholders to l understand the problem and develop an effective risk-informed solution to the circuit analysis issue.
l Because of the number of different stakeholder interpretations of the regulations, the NRC issued l Enforcement Guidance Memorandum (EGM) 98-002, which provided enforcement discretion for circuit-l related findings. Also, the NRC temporarily suspended circuit-related fire protection inspections in l 2000.
l l          In 2000, the NRC implemented the Reactor Oversight Process which included systematic l inspections of licensees safe-shutdown capability. During these inspections, fire protection inspectors l noticed that many licensees had not upgraded or replaced Thermo-Lag 330-1 fire barrier material(1) or l had not provided the separation distance between redundant safe-shutdown success paths necessary to l satisfy the requirements in Section III.G.2 of Appendix R to 10 CFR Part 50. Some licensees l compensated for the lack of or degraded fire barriers by relying on operator manual actions which had l not been reviewed and approved by the NRC through the exemption process of 10 CFR 50.12, Specific l Exemptions. Other licensees misinterpreted Section III.G.1 to allow the use of operator manual actions in l lieu of the meansspecified in Section III.LG.2 although redundant safe-shutdown success paths were in l the same fire area.
l          In 2001, the Electric Power Research Institute (EPRI) and Nuclear Energy Institute (NEI) l performed a series of cable functionality fire tests to advance the nuclear industrys knowledge of fire-l induced circuit failures, particularly the potential for spurious equipment actuations initiated by hot l shorts. EPRI coordinated this effort and issued the final report, Spurious Actuation of Electrical l Circuits Due to Cable Fires: Results of an Expert Elicitation (Report No. 1006961, May 2002). (2) NEI l considered the results of the testing in preparing an industry guidance document for circuit analysis, l NEI 00-01, Guidance for Post-Fire Safe-Shutdown Circuit Analysis.
l          The variety of interpretations with respect to circuit analysis issues stemmed partly from the l previous lack of knowledge of the potential for certain types of circuit failure mechanisms. The cable l fire tests performed by EPRI/NEI significantly increased the knowledge available to the industry and the l NRC with respect to fire-induced circuit failures and their potential to cause multiple spurious actuations 1
During the 1980s, many licensees used Thermo-Lag 330-1 as a fire barrier material to satisfy the requirements of Appendix R, Section III.G. In December 1992, the staff issued GL 92-08, Thermo-Lag 330-1 Fire Barriers, which discussed issues with the Thermo-Lag 330-1 fire barrier material.
2 The concept of using a potential heat release limit of 8141 kJ/kg (3500 Btu/lb) is similar to the "limited combustible" l          concept with its like limit, as set forth in NFPA 220, "Standard on Types of Building Construction."Additional analysis l          of the EPRI/NEI test results appears in NUREG/CR-6776, Cable Insulation Resistance Measurements Made During l          Cable Fire Tests, ML022600200 and ML022600307.
DG-1170, Page 20
 
that could affect safe shutdown after a fire. To bring closure to these issues and support the resumption    l of circuit analysis inspections, the NRC staff issued RIS 2005-30, Clarification of Post-Fire Safe-          l Shutdown Circuit Regulatory Requirements. The staff issued this generic communication to clarify            l regulatory requirements related to post-fire safe-shutdown circuit analyses and protection, particularly      l the requirements of Appendix R to 10 CFR 50.                                                                  l Shutdown/Refueling Operations Text Was Moved From Here: 1 C. REGULATORY POSITION
: 1.      FIRE PROTECTION PROGRAM In accordance with 10 CFR 50.48, a fire protection program must be established at each nuclear power plant. The program should establish the fire protection policy for the protection of structures, systems, and components important to safety at each plant and the procedures, equipment, and personnel required to implement the program at the plant site.
The fire protection program should extend the concept of defense in depth to fire protection in fire areas important to safety, with the following objectives.
C      To prevent fires from starting; C      To detect rapidly, control, and extinguish promptly those fires that do occur; C      To provide protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by the fire suppression activities will not prevent the safe shutdown of the plant.
In accordance with 10 CFR 50.48, the fire protection program must:
C      Identify the various positions within the licensees organization that are responsible for the program and state the authorities delegated to these positions (see Regulatory Position 1.1);
DG-1170, Page 21
 
C        Describe specific features such as administrative controls and personnel requirements for fire prevention (see Regulatory Position 2);
C        Outline the plans for fire detection and suppression capability, and limitation of fire damage (see Regulatory Positions 1.2, 3, and 4);
C        Describe personnel requirements for manual fire suppression activities (see Regulatory Position 3.5); and C        Describe the means to limit fire damage to structures, systems, and components important to safety so that capability to safely shut down the plant is ensured (see Regulatory Positions 1.3 and 5).
On reactor sites with an operating reactor and with construction, modification, or decommissioning of other units under way, the fire protection program should provide for continuing evaluation of fire hazards associated with these activities. Additional fire barriers, fire protection capability, and administrative controls should be provided as necessary to protect the operating unit from construction or decommissioning fire hazards.
The guidance in Regulatory Position 1 is based on 10 CFR 50.48, Appendix R to 10 CFR Part 50, and CMEB 9.5-1.
1.1      Organization, Staffing, and Responsibilities The fire protection program should be under the direction of an individual who has been l delegated authority commensurate with the responsibilities CFR Part 50, which licensees had interpreted l in a manner inconsistent with regulatory expectations. The bases of the position and who has available l staff personnel knowledgeable in bothpositions presented in the generic communication are the current l regulations applicable to these circuits, which are supported by the industry cable fire test results. The l NRC staff resumed inspection of fire-induced safe-shutdown circuits in January 2005.
l          The NRC issued RIS 2006-10, Regulatory Expectations with Appendix R Section III.G.2 l Operator Manual Actions, to inform the licensees about the staffs expectations, schedule, and l enforcement policy for resolving issues related to crediting operator manual actions and the subsequent l termination of EGM 98-02, Enforcement Guidance MemorandumDisposition of Violations of l Appendix R, Sections III.G and III.L Regarding Circuit Failures.
l          As illustrated in the preceding discussion, the Commissions fire protection and nuclear safety.
Responsibility for the overall fire protection program should be assigned to a person who has management control over all organizations involved in fire protection activities. Formulation and assurance of program implementation may be delegated to a staff composed of personnel prepared by training and experience in fire protection and personnel prepared by training and experience in nuclear DG-1170, Page 22
 
plant safety to provide a comprehensive approach in directing the fire protection program for the nuclear power plant.
The following positions or organizations should be designated.
: a.      The upper level management position that has management responsibility for the formulation, implementation, and assessment of the effectiveness of the nuclear plantrequirements and guidelines consist of rules, generic communications, staff            l guidance, and other related documents. Recent industry and regulatory issues have          l prompted the NRC to update this comprehensive guide to provide additional clarification    l of regulatory expectations with respect to FPPs. This revision reflects the staff positions l documented in the recent generic communications.                                            l l
For new reactor designs, the overall maturity of fire protection program.                          l
: b.      The management positions directly responsible for formulating, implementing, and periodically assessing the effectiveness of theregulations, the many years of nuclear plant l operating experience, the improvement of analysis methodologies, and the opportunity to    l incorporate these benefits in the original plant design provide the bases for enhanced fire l protection program for the licensee's.                                                      l l
DG-1170, Page 23
 
l Regulatory Requirements l
l          A number of regulatory requirements apply to the development and implementation of FPPs for nuclear power plant, including fire drills and training conducted by the fire brigade and plant personnel.
The results of these assessments should be reported to the upper level management position responsible for fire protection with recommendations for improvements or corrective actions as deemed necessary.
Text Was Moved From Here: 2
: d.      The onsite positions that:
Text Was Moved From Here: 3 ii. Are responsible for the firefighting training for operating plant personnel and the plant's fire brigade, design and selection of equipment, periodic inspection and testing of fire protection systems and equipment in accordance with established l                          proceduress. This section summarizes the primary requirements.
l l Appendix A to 10 CFR Part 50 l
l          Appendix A to 10 CFR Part 50 establishes, and evaluation of test results and determination of the acceptability of the systems under test.
iii. Assist in the critique of all fire drills to determine how well the training objectives have been met.
iv. Are responsible for the in-plant fire protection review of proposed work activities to identify potential transient fire hazards and specify required additional fire protection in the work activity procedure.
l                  v.      Implement a program for indoctrination of allthose plant contractor personnel in l                          appropriate administrative procedures that implements to which its provisions l                          apply, the fire protection program and the emergency procedures relative to fire protection.
vi. Implement a program for instruction of personnel on the proper handling of accidental events such as leaks or spills of flammable materials that are related to fire protection.
vii. Are responsible for review of hot work.
: e.      The onsite position responsible for fire protection quality assurance. This position is responsible for ensuring the effective implementation of the fire protection program by l                  planned inspections, scheduled auditsnecessary design, fabrication, construction, testing, and verification that the results of these inspections and audits are promptly reported to cognizant management personnel.
: f.      The positions that are part of the plant fire brigade (also see Regulatory Position 3.5.1).
DG-1170, Page 24
: i.      The plant fire brigade positions should be responsible for fighting fires. The authority and responsibility of each fire brigade position relativeperformance    l requirements for SSCs important to safety. The following subsections              l summarize those GDCs with specific application to fire protection should be      l clearly defined.
ii.      The responsibilities of each fire brigade position should correspond with the actions required by the firefighting procedures.
iii. Collateral responsibilities of the fire brigade members should not conflict with their responsibilities related to the fire brigade during a fire emergency.
iv.      The minimum number of trained fire brigade members available onsite for each operating shift should beof nuclear power plants.                                l l
GDC 3, Fire Protection                                                                                      l l
GDC 3 requires that SSCs important to safety be designed and located to minimize, consistent        l with the activities required to combat credible and challenging fires, but no less than 5 members. The size of the fire brigade should be based upon the functions required to fight fires with adequate allowance for injuries. Fire brigade staffing should account for all operational and emergency response demands on shift personnel in the event of a significant fire.
The guidance in Regulatory Position 1.1 is based on CMEB 9.5-1, IN 91-77, IN 95-48, and Stello Letter to Bixel (1978).
1.2      Fire Hazards Analysis A fire hazards analysis should be performed to demonstrate that the plant will maintain the ability to perform safe shutdown functions and minimize radioactive material releases to the environment in the event of a fire. This analysis should be revised as necessary to reflect plant design and operational changes.
The fire hazards analysis accomplishes the following objectives:
: a.      Considers potential in situ and transient fire hazards;
: b.      Determines the consequences of fire in any location in the plant on the ability to safely shut down the reactor or on the ability to minimize and control the release of radioactivity to the environment; and
: c.      Specifies measures for fire prevention, fire detection, fire suppression, and fire other  l safety requirements, the probability and effect of fires and explosions. Noncombustible    l and heat-resistant materials must be used wherever practical, particularly in locations    l such as the containment and alternative shutdown capability for each fire area containing  l structures, systems, and components important to safety in accordance with NRC guidelines and regulations.
Text Was Moved From Here: 4 DG-1170, Page 25
 
The fire hazards analysis should address the following elements and attributes.
C        The NRC fire protection requirements and guidance that apply.
C        Amounts, types, configurations, and locations of cable insulation and other combustible materials.
C        In situ fire hazards.
l        C        Automatic firecontrol room. Fire detection and suppression capability. The effects of lightning strikes should be included in the design of fire detection systems.
l        C        Layout and configurations of structures, systems, and componentsfirefighting systems of l                  appropriate capacity and capability must be provided and designed to minimize the l                  adverse effects of fires on SSCs important to safety. The protection for safe shutdown systems (see Regulatory Positions 5.5 and 5.6) within a fire area should be determined on the basis of the worst case fire that is likely to occur and the resulting damage. The extent of such damage should be justified in the fire hazards analysis. The analysis should consider the degree of spatial separation between redundant shutdown systems, the presence of in situ and transient combustibles, the available fire protection systems and features, sources of ignition, and the susceptibility to fire damage of the safe-shutdown-related cables, equipment, systems, and features in the area.
C        Reliance on and qualifications of fire barriers, including fire test results, the quality of the materials and barrier system, and the quality of the barrier installation.
C        Fire area construction (walls, floor, ceiling, dimensions, volume, ventilation, and congestion). The fire hazard analysis should be the mechanism to determine that fire areas have been properly selected. Guidelines for fire areas and zones are provided in Regulatory Position 4.1.2 of this guide.
C        Location and type of manual firefighting equipment and accessibility for manual fire fighting.
C        Potential disabling effects of fire suppression systems on shutdown capability. The term "damage by fire" in Appendix R also includes damage to equipment from the normal or inadvertent operation of fire suppression systems. The fire hazards analysis should address the effects of firefighting activities. GDC 3 of Appendix A to 10 CFR Part 50 l                  states that "Fire-fightingGDC 3 also requires that firefighting systems shall be designed l                  to assureensure that their failure, rupture, or inadvertent operation does not significantly impair the safety capability of these structures, systems, and components."
C        Availability of oxygen (for example, inerted containment).
C        Alternative, dedicated, or backup shutdown capability.
Fire initiation should be postulated at the location within each fire area/zone that will produce the l most severe fire with the potential to adversely impact structures, systems, and componentsSSCs.
l DG-1170, Page 26
 
GDC 5, Sharing of Structures, Systems, and Components                                                      l l
GDC 5 requires that nuclear power units do not share SSCs important to safety. Fire              l development should consider the potential for involvement of other combustibles, both fixed and transient, in the fire area. Where automatic suppression systems are installed, unless the licensees can  l show that such sharing will not significantly impair the units ability to perform their safety functions, l including, in the event of an accident in one unit, an orderly shutdown and cooldown of the remaining      l units.                                                                                                    l l
GDC 19, Control Room                                                                                      l l
GDC 19 requires that the licensee provide a control room from which personnel can operate the    l nuclear power unit under normal and accident conditions and which limits radiation exposure to control    l room personnel under accident conditions for the duration of the accident. GDC 19 also requires that      l equipment and locations outside the control room be designed to accomplish hot shutdown of the reactor    l and have a potential capability for subsequent cold shutdown of the reactor.                              l l
GDC 23, Protection System Failure Modes                                                                    l l
GDC 23 requires that the protection system be designed to fail into a safe state or into a state  l demonstrated to be acceptable on some other defined basis if the plant experiences conditions such as      l disconnection of the system, loss of energy (e.g., electric power, instrument air), or postulated adverse  l environments (e.g., extreme heat or cold, fire, pressure, steam, water, radiation).                        l l
10 CFR 50.48, Fire Protection                                                                            l l
In accordance with 10 CFR 50.48, each operating nuclear power plant must have an FPP that        l satisfies GDC 3 of Appendix A to 10 CFR Part 50. The regulation specifies what an FPP should contain      l and lists the basic fire protection guidelines for the plan.                                              l l
As stated in 10 CFR 50.48(b), all plants that had operating licenses before January 1, 1979, must l satisfy the requirements of Sections III.G, III.J, and III.O, and other sections of Appendix R to          l 10 CFR Part 50, in cases in which licensees had not obtained approval of similar features before the      l effective date of Appendix R. Plants licensed to operate after January 1, 1979, must meet the provisions  l of 10 CFR 50.48(a).                                                                                        l l
All currently licensed plants may voluntarily adopt a risk-informed, performance-based FPP in    l accordance with 10 CFR 50.48(c) and NFPA 805. The regulation in 10 CFR 50.48(c), which the                l Commission adopted in 2004 (69 FR 33536; June 16, 2004), incorporates NFPA 805 by reference, with          l certain exceptions, and allows licensees to voluntarily adopt and maintain an FPP that meets the          l requirements of NFPA 805 as an alternative to meeting the requirements of 10 CFR 50.48(b) or the plant-    l specific fire protection license conditions.                                                              l l
Appendix R to 10 CFR Part 50, Fire Protection Program for Nuclear Power Facilities Operating              l Prior to January 1, 1979                                                                                  l l
Appendix R to 10 CFR Part 50 applies to licensed nuclear power electric generating stations that  l were operating before January 1, 1979, except as noted in 10 CFR 50.48(b). With respect to certain        l generic issues for such facilities, Appendix R identifies fire protection features required to satisfy    l DG-1170, Page 27
 
l Criterion 3 of Appendix A. Two categories of Appendix R provisions apply to the fire protection l features of these facilities.
l l          The first category consists of those provisions that licensees were required to backfit in their l entirety, regardless of whether the NRC had previously approved alternatives to the specific l requirements. The requirements appear in Sections III.G, Fire Protection of Safe-Shutdown Capability; l III.J, Emergency Lighting; and III.O, Oil Collection System for Reactor Coolant Pump. Those plants l subject to the requirements of Section III.G.3 must also meet the requirements of Section III.L.
l l          The second category consists of requirements concerning the open items of previous NRC staff l fire protection reviews. Open items are defined as fire protection features that the NRC staff had not l previously approved as satisfying the provisions of Appendix A to BTP APCSB 9.5-1, as reflected in l SERs.
l l          Except as specified in the license conditions of individual plants, plants that were licensed to l operate after January 1, 1979, were not required to implement Appendix R. Rather, the NRC staff l typically reviewed the FPPs for these plants against the licensing review guidelines of SRP Section 9.5.1.
l Previous revisions of SRP Section 9.5.1 and the associated CMEB 9.5-1 consolidated the guidance of the l previous BTP, Appendix A to APCSB 9.5-1, Appendix R, and other staff guidance. (The staff has l removed that guidance from Revision 5 of SRP Section 9.5.1 and included it in this regulatory guide.)
l l 10 CFR 50.72 and 10 CFR 50.73 l
l          These regulations prescribe the notification and reporting requirements for nuclear power plant l licensees, including those related to FPPs. The regulation in 10 CFR 50.72, Immediate Notification l Requirements for Operating Nuclear Power Reactors, provides immediate notification requirements via l the Emergency Notification System (ENS), and 10 CFR 50.73, Licensee Event Report System, l provides for 60-day written LERs.
l l          The NRC staff uses the information reported under 10 CFR 50.72 and 10 CFR 50.73 in l responding to emergencies, monitoring ongoing events, confirming licensing bases, studying potentially l generic safety problems, assessing trends and patterns of operational experience, monitoring l performance, identifying precursors of more significant events, and providing operational experience to l the industry.
l DG-1170, Page 28
 
Licensing and Design Basis                                                                                  l l
The fire protection licensing and design basis depends on several factors that may differ          l considerably for individual plants. However, the issuance of the Fire Protection rule, 10 CFR 50.48, and    l Appendix R to 10 CFR Part 50 established the applicability of certain fire protection requirements,          l including those within the rule, on the basis of whether the licensing date for a given plant is before or  l after January 1, 1979 [except for plants that have adopted an NFPA 805 licensing basis in accordance        l with 10 CFR 50.48(c)].                                                                                      l l
The current licensing basis (CLB) is the set of NRC requirements applicable to a specific plant    l and a licensee's written commitments for ensuring compliance with and operation within applicable NRC        l requirements and the plant-specific design basis (including all modifications and additions to such          l commitments over the life of the license) that are docketed and in effect. The CLB includes the NRC          l regulations contained in 10 CFR Parts 2, 19, 20, 21, 26, 30, 40, 50, 51, 54, 55, 70, 72, 73, 100 and        l appendices thereto; orders; license conditions; exemptions; and technical specifications. It also includes  l the plant-specific design-basis information defined in 10 CFR 50.2 as documented in the most recent          l final safety analysis report (FSAR) as required by 10 CFR 50.71 and the licensees commitments              l remaining in effect that were made in docketed licensing correspondence such as licensee responses to        l NRC bulletins, generic letters, and enforcement actions, as well as licensee commitments documented in      l NRC safety evaluations or licensee event reports.                                                            l l
Design bases means that information which identifies the specific functions to be performed by a    l structure, system, or component of a facility, and the specific values or ranges of values chosen for        l controlling parameters as reference bounds for design. These values may be (1) restraints derived from      l generally accepted state-of-the-art practices for achieving functional goals, or (2) requirements derived  l from analysis (based on calculation and/or experiments) of the effects of the postulated fire should be      l evaluated with and without actuation of the automatic suppression system.
        "Worst case" fires need not be postulated to be concurrent with non-fire-related failures in safety systems, othera postulated accident for which a structure, system, or component must meet its functional    l goals.                                                                                                      l l
Plants Licensed before January 1, 1979                                                                      l l
The primary licensing basis for plants licensed to operate before January 1, 1979, comprises the    l plant license conditions, Appendix R, approved exemptions, and the staffs SERs on the FPP.                  l l
DG-1170, Page 29
 
l Safety Evaluation Reports l
l          The SERs document the staff acceptance of the plant FPP or its elements. For plants licensed to l operate before January 1, 1979, the staffs SERs also establish the extent to which the requirements of l Appendix R to 10 CFR Part 50 apply. Plants for which the NRC accepted the fire protection features as l satisfying the provisions of Appendix A to BTP APCSB 9.5-1, or were accepted in comprehensive SERs l issued before the publication of Appendix A to BTP APCSB 9.5-1 in August 1976, were required to meet l only the provisions of Sections III.G (III.L), III.J, and III.O of Appendix R.
l l          For pre-1979 licensees, a staff decision in an SER that approves an aspect of the FPP that does l not comply with regulatory requirements does not eliminate the need for an exemption. For example, l pre-1979 licensees who have SERs, but not a corresponding exemption that approves operator manual l actions credited with meeting the protection requirements of Appendix R, Section III.G.2, must request l an exemption under 10 CFR 50.12 by (1) highlighting the special circumstances of l 10 CFR 50.12(a)(2)(ii), (2) citing the SER as the safety basis, and (3) confirming that the safety basis l established in the SER remains valid.
l l Exemptions from Appendix R l
l          Effective February 17, 1981, the NRC amended its regulations by adding 10 CFR 50.48 and l Appendix R to 10 CFR Part 50, requiring certain provisions for fire protection in nuclear power plants l licensed to operate before January 1, 1979.
l l          Plants with previously approved fire protection features (see the above section on SERs) were l exempt from the requirements of Appendix R with the exception of Sections III.G, III.J, and III.O.
l l          The licensee may also request exemptions from fire protection requirements in accordance with l the provisions of 10 CFR 50.12. Under that regulation, the Commission may grant exemptions from the l requirements of the regulations in 10 CFR Part 50 in the following cases:
l a.      The exemption is authorized by law, will not present an undue risk to the public health and l          safety, and is consistent with the common defense and security.
l b.      The Commission will not consider granting an exemption unless special circumstances are l          present. Special circumstances include the following:
l          i.      Application of the regulation in the particular circumstances conflicts with other rules or l                  requirements of the Commission.
l          ii.      Application of the regulation in the particular circumstances would not serve the l                  underlying purpose of the rule or is not necessary to achieve the underlying purpose of l                  the rule.
l          iii. Compliance would result in undue hardship or other costs that significantly exceed those l                  contemplated when the regulation was adopted, or that significantly exceed those l                  incurred by others similarly situated.
l          iv.      The exemption would result in benefit to the public health and safety that compensates l                  for any decrease in safety that may result from granting the exemption.
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: v.      The exemption would provide only temporary relief from the applicable regulation, and      l the licensee or applicant has made good faith efforts to comply with the regulation.      l vi.      There is present any other material circumstance not considered when the regulation was    l adopted for which it would be in the public interest to grant an exemption. If the request l relies exclusively on such condition to satisfy criterion (2) above, the exemption may not l be granted until the Executive Director for Operations has consulted with the              l Commission.                                                                                l l
Operating License Conditions                                                                                l l
Fire protection license conditions for plants licensed before January 1, 1979, typically require    l implementation of modifications committed to by the licensee as a result of the FPP review with respect      l to the BTP. These license conditions appear in amendments issued between 1977 and February 17, 1981,        l the effective date of 10 CFR 50.48 and Appendix R.                                                          l l
As a result of numerous compliance, inspection, and enforcement issues associated with the          l various plant license conditions, the staff developed a standard licensing condition for fire protection. l The NRC transmitted this license condition, and the recommendation that licensees adopt it, in GL 86-10. l The licensees received additional guidance regarding removal of the fire protection requirements from        l the plant technical specifications in GL 88-12. The NRC promulgated these changes to give licensees          l greater flexibility in the management and implementation of the FPP and to clarify the fire protection      l licensing basis for the specific facility.                                                                  l l
Plants Licensed after January 1, 1979                                                                        l l
Existing plants licensed after January 1, 1979, are subject to the requirements of 10 CFR          l 50.48(a) [except those plants that have adopted a performance-based FPP in accordance with 10 CFR            l 50.48(c)] and, thus, must meet the provisions of GDC 3 as specified in their license conditions and as      l accepted by the NRC in the SERs. The NRC staff typically reviews these plants according to the              l guidance and acceptance criteria of SRP Section 9.5.1. For plants that cannot meet commitments to            l specific guidelines or that have proposed alternative approaches, the differences between the licensees    l program and the guidelines are documented in deviations. (See Regulatory Position 1.8 of this guide.)        l l
License Renewal                                                                                              l l
The fire protection licensing and design basis under license renewal should not differ              l significantly from that in effect before renewal, with the exception that licensees must include fire        l protection SSCs in license renewal scoping and aging management programs as appropriate. Licensees          l must submit an application for renewal of a nuclear power plant operating license in accordance with the    l provisions of 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power              l Plants. Regulatory Guide 1.188, Standard Format and Content for Applications To Renew Nuclear              l Power Plant Operating Licenses, provides additional information and guidelines on the renewal process.      l The regulatory guide endorses the methods contained in NEI 95-10, Industry Guideline for                    l Implementing the Requirements of 10 CFR Part 54The License Renewal Rule, Revision 6, issued in            l March 2005. Regulatory Position 9 of this document provides guidance regarding the fire protection          l aspects of license renewal.                                                                                  l l
DG-1170, Page 31
 
l Power Uprates l
l          The fire protection licensing and design basis for plants requesting power uprates should not l differ significantly from the basis in effect before the uprate request. The review of changes resulting l from the power uprate must ensure that the post-fire safe-shutdown capability is maintained and that l SSCs important to safety are protected from the effects of fire and explosion.
l l Shutdown and Decommissioned Plants l
l          For those plants that are permanently shutdown and/or are undergoing decommissioning, the l licensing basis changes in accordance with the requirements in 10 CFR 50.82. For permanently l shutdown reactors, 10 CFR Part 50, 10 CFR 50.48(f), and Regulatory Guide 1.191 govern fire protection.
l The fire protection objectives listed in 10 CFR 50.48(f) are to (1) reasonably prevent fires from l occurring, (2) rapidly detect, control, and extinguish those fires that do occur, and (3) minimize the risk l of fire-induced radiological hazards to the public, environment, and plant workers.
l l Code of Record l
l          When existing plants were originally licensed, the licensee generally committed to complying l with a specific edition of applicable industry codes and standards such as the NFPA fire codes. The l specific edition to which the licensee originally committed is still the code of record. Licensees are not l required to comply with later editions of these codes and standards, except when they specifically adopt a l later edition in accordance with regulatory guidelines or when new fire protection systems protecting l SSCs important to safety are installed. The code of record for the new fire protection system should be l the edition that is in effect when the system is designed or when a commitment to add the system is made l to the staff. The code of record for the unchanged fire protection systems will not change. In general, for l modifications to an existing fire protection system that are permitted by the code of record, the staff does l not require that the system be brought into compliance with the current edition of the code.
l l New Reactors l
l          The FPPs for new reactor plants that submit applications in accordance with 10 CFR Part 52, l Early Site Permits; Standard Design Certifications; and Combined Licenses for Nuclear Power Plants, l are subject to 10 CFR 50.48(a) and the criteria for enhanced fire protection in accordance with SECY l 016, Evolutionary Light-Water Reactor (LWR) Certification Issues and Their Relationship to Current l Regulatory Requirements; SECY-93-087, Policy, Technical, and Licensing Issues Pertaining to l Evolutionary and Advanced Light-Water Reactor (ALWR) Designs; and SECY-94-084, Policy and l Technical Issues Associated with the Regulatory Treatment of Non-Safety Systems in Passive Plant l Designs. SECY-90-016 established enhanced fire protection criteria for evolutionary light-water l reactors. SECY-93-087 recommended that the enhanced criteria be extended to include passive reactor l designs. The Commission approved SECY-90-016 and SECY-93-087 in staff requirements memoranda l (SRM). SECY-94-084, in part, establishes criteria defining safe-shutdown conditions for passive light-l water reactor designs. The NRC staff uses the guidance and acceptance criteria of SRP Section 9.5.1 in l reviewing new reactor FPPs.
l DG-1170, Page 32
 
Fire Protection Program Goals and Objectives                                                                l l
Defense-in-Depth                                                                                            l l
Fire protection for nuclear power plants uses the concept of defense-in-depth to achieve the        l required degree of reactor safety. This concept entails the use of echelons of administrative controls, fire l protection systems and features, and safe-shutdown capability to achieve the following objectives:          l
* to prevent fires from starting                                                                      l
* to detect rapidly, control, and extinguish promptly those fires that do occur                      l
* to protect SSCs important to safety so that a fire that is not promptly extinguished by the fire    l suppression activities will not prevent the safe shutdown of the plant or result in release of      l radioactive materials to the environment                                                            l l
Assumptions                                                                                                  l l
Postulated Fire                                                                                              l l
Analysts assess fire damage to safe-shutdown equipment or fires with the potential to result in    l release of radioactive materials to the environment on the basis of a single fire, including an exposure    l fire. An exposure fire is a fire in a given area that involves either in situ or transient combustibles and  l has the potential to affect SSCs important to safety or release of radioactive materials located in or      l adjacent to that same area. The effects of such fire (e.g., smoke, heat, or ignition) can adversely affect  l those SSCs important to safety, or the ability to prevent release of radioactive materials. Thus, a fire    l involving one success path of safe-shutdown equipment may constitute an exposure fire for the redundant      l success path located in the same area, and a fire involving combustibles not in either redundant success    l path may constitute an exposure fire for both redundant success paths located in the same area.              l l
There is no regulatory requirement to prevent fire-induced failure of redundant systems            l necessary for mitigation of consequences following design-basis accidents if the system is not required to  l operate for safe shutdown after a fire. However, the licensee is required to prevent (or mitigate, where    l permitted by regulatory requirements) fire-induced failures of these systems if the failure could prevent    l safe shutdown (e.g., because of spurious actuations). The most stringent fire damage limit should apply      l to those systems that fall into more than one category.                                                      l l
For the application of fire protection regulatory requirements, redundant trains of systems may be  l two or more similar trains of equivalent capacity in the same system powered by separate electrical          l divisions or they may be two or more separate systems designed to perform the same post-fire safe-          l shutdown function. In cases where the regulatory requirements for protection (e.g., fire barriers,          l separation, suppression, and/or detection) of at least one of the redundant trains in a single fire area    l cannot be met or where the post-fire safe-shutdown function of the train or system is not the design        l function, the regulatory requirements for alternative/dedicated shutdown systems apply. In the context of    l post-fire safe-shutdown, the redundant train or alternative/dedicated shutdown system credited with          l performing the required functions are also referred to as success paths.                                    l l
DG-1170, Page 33
 
l Conditions of Fire Occurrence l
l          The analysis assumes that a fire may occur at any time but does not postulate a fire occurring l simultaneously with and independently from plant accidents, or the most severe natural phenomena.
l          On multiple-reactor sites, such as floods or high winds. However, severe natural phenomena, l such as earthquakes, may initiate a fire event and should be considered in evaluating the design capability l of fire protection systems and features.
l          On multiple reactor sites, the analysis need not postulate the simultaneous occurrence of l unrelated fires in two or more units need not be postulated to occur simultaneously. F. The licensee l should consider fires involving facilities shared between units and fires caused by man-made site-l relatedrandom natural or manmade events that have a reasonable probability of occurring and affecting more than one reactor unit (such as an aircraft crash) should be considered.
The fire hazards analysis should separately identify hazards and provide appropriate protection in l locations where losses of structures, systems, and components .
l l Loss of Offsite Power/Station Blackout l
l          In evaluating the capability to accomplish safe shutdown after fires, the licensee should consider l whether offsite power will be available. However, the licensee need not consider loss of offsite power l for a fire in nonalternative or dedicated shutdown areas if it can show that offsite power cannot be lost l because of a fire in that area.
l          As described in Regulatory Position 5.4.1 of this guide, alternative shutdown capability should l accommodate post-fire conditions when offsite power is available and conditions when offsite power is l not available for 72 hours. In an evaluation of safe-shutdown circuits, the availability of uninterrupted l power (i.e., offsite power remains available) may impact the ability to control the safe shutdown of the l plant by increasing the potential for circuit interactions resulting from fire damage to energized power l and control circuits that may result in spurious actuations.
l          Several operating plant licensees have alternative methodologies that rely on intentional l disconnection of alternating current (ac) power to specific equipment or to the entire plant as a means to l achieve safe shutdown after a fire. The purpose of these self-induced station blackouts (SISBOs) is to l eliminate potential spurious actuations that could prevent safe shutdown and allow manual control of l required equipment. Some licensees have procedures that cause a SISBO condition to be created as a l result of fire effects [e.g., procedures that direct operators to manually trip the credited safe-shutdown l emergency diesel generator (EDG) in the event of fire damage to circuits of vital EDG support systems].
l The acceptability of safe-shutdown procedures that voluntarily enter, or otherwise create, a SISBO l condition is determined on a case-by-case basis.
l          The ability to cope with SISBO as part of the post-fire safe-shutdown methodology depends on l such issues as time-line logic; assumptions and bases for plant and operator response relative to l component realignment; the ability of plant operators to monitor and control plant parameters and align l plant components before, during, and after SISBO control room evacuation and abandonment; and the l practicality and reliability of EDG start and load (and restart, if applicable) under post-fire safe-shutdown l SISBO conditions.
l          The risk of self-imposed SISBO may greatly exceed the actual risk posed by the fire, and the l licensee should consider the risk carefully when evaluating the plant safe-shutdown design and l procedures. A plant typically uses this approach to avoid or minimize the need for operator manual DG-1170, Page 34
 
actions after a fire. However, acceptable operator manual actions that are implemented in accordance        l with Regulatory Position 5.3.3 and NUREG-1852, Demonstrating the Feasibility and Reliability of            l Operator Manual Actions in Response to Fire, may present a lower risk than the SISBO approach.            l New reactor designs should not rely on SISBO to mitigate potential fire damage to safe-            l shutdown systems.                                                                                          l l
Fragility of Structures, Systems, and Components Exposed to Fire Damage                                    l l
Fire damage to SSCs important to safety can occur as a result of the following.                    l
: 1.      Concentrations of combustible contents, including transient fire hazards of combustibles expected to be used in normal operations such as refueling, maintenance, and modifications,
: 2.      Continuity of combustible contents, furnishings, building materials, or combinations thereof in configurations conducive to fire spread,
: 3.      Exposures to fire,result from heat, smoke, or water, including those that may necessitate l evacuation from areas that are required to be attended for safe shutdown,
: 4.      Fire in control rooms or other locations having critical functions important to safety,
: 5.      Lack of adequate access or smoke removal facilities that impede plant operations or fire extinguishment in plant areas important to safety,
: 6.      Lack of explosion-prevention measures,
: 7.      Loss of electric power or control and instrumentation circuits,
: 8.      Inadvertent operation of fire suppression systems.
Theignition. Fire is assumed to damage safe-shutdown SSCs within the fire area of concern as      l discussed in the Postulated Fire section (above) and as determined by the fire hazards analysis should    l be performed by qualified fire protection and reactor systems engineers.
Experienced judgment is necessary to identify fire hazards and.                                    l l
Fire Protection Program Performance Goals                                                                  l l
Safety-Related Structures, Systems, and Components                                                          l l
GDC 3 of Appendix A to 10 CFR Part 50 requires that the FPP protect SSCs important to safety      l from the effects of fire. However, the post-fire loss of function of systems used to mitigate the          l consequences of a postulated fire starting at any location in the plant. Evaluation ofdesign-basis          l accidents does not per se impact public safety. The FPP must protect all equipment important to safety;    l however, the need to limit fire damage to systems required to achieve and maintain post-fire safe-          l shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate    l the consequences of the postulated fire on nuclear safety should be performed by persons thoroughly trained and experienced in reactor safety. The person conducting the analysis of fire hazards should be thoroughly trained and experienced in the principles of industrial fire prevention and control and in fire DG-1170, Page 35
 
phenomena from fire initiation, through its development, to propagation into adjoining spaces. The fire hazard analysis should be conducted by or under the direct supervision of an engineer with the l qualifications indesign-basis accidents.
l l Post-Fire Safe-Shutdown l
l          The performance objectives of the FPP related to safe shutdown after a fire are to ensure that one l success path of SSCs necessary for hot shutdown is free of fire damage and to limit fire damage such that l one success path of SSCs necessary to achieve and maintain cold shutdown can be repaired or made l operable within a specified time period using onsite capabilities.
l          For reactor designs certified in 10 CFR Part 52, the plant should achieve safe shutdown with the l assumption that fire will render all equipment in any one fire area inoperable, recognizing that post-fire l reentry for repairs or operator actions will not be possible. For passive light-water reactor designs that l rely on natural circulation and heat transfer to remove reactor decay heat, SECY-94-084 and Regulatory Position 1.6.1.a.
l          The guidance in Regulatory Position 1.2 is based on GDC 3,8.3 define safe shutdown.
l l Prevention of Radiological Release l
l          The FPP, including the fire hazards analysis, should demonstrate that the plant will maintain the l ability to minimize the potential for radioactive releases to the environment in the event of a fire. Fires l are expected to occur over the life of a nuclear power plant and, thus, should be treated as anticipated l operational occurrences as defined in Appendix A to 10 CFR Part 50. Requirements for protection l against radiation during normal operations appear in 10 CFR Part 20, Standards for Protection Against l Radiation. Anticipated operational occurrences should not result in unacceptable radiological l consequences, and the exposure criteria of 10 CFR Part 20 apply. Prevention of a radiological release l that could result in a radiological hazard to the public, environment, or plant personnel becomes the l primary objective for the shutdown and decommissioning FPP.
l DG-1170, Page 36
 
Post-Fire Safe-Shutdown Reactor Safety/Performance Goals                                                    l l
Power Operations                                                                                            l l
One success path of cables and equipment necessary to achieve and maintain safe shutdown          l should be maintained free of fire damage. The reactor safety and performance goals for safe shutdown        l after a fire should ensure that the specified acceptable fuel design limits are not exceeded. Section III.L  l of Appendix R to 10 CFR Part 50, ASB 9.5-1, CMEB 9.5-1, GL 86-10, IN 83-41, and IN 86-106.                  l 1.3      Safe Shutdown Analysis Part 50 specifies post-fire reactor safety and performance goals for alternative or dedicated shutdown.      l l
Shutdown/Refueling Operations                                                                                l l
l Text Moved Here: 1                                                                                          l During shutdown operations, particularly during maintenance or refueling outages, fire conditions can change significantly as a result of work activities. Redundant systems important to safety may not be available as allowed bydescribed in plant Ttechnical Sspecifications and plant procedures.        l Fire protection during shutdown or refueling conditions should minimize the potential for fire events to impact safety functions (e.g., reactivity control, reactor decay heat removal, spent fuel pool cooling), or result in the release of radioactive materials, under the differingunusual conditions that may be present    l during these operations.
End Of Moved Text                                                                                            l l
C. REGULATORY POSITION                                                    l l
: 1.        Fire Protection Program                                                                            l l
In accordance with 10 CFR 50.48, each operating nuclear power plant must providehave an FPP.      l The plan should establish the fire protection policy for the protection of SSCs important to safety at each  l plant and the procedures, equipment, and personnel required to implement the program at the plant site.      l l
The FPP should extend the concept of defense-in-depth to fire protection in fire areas important  l to safety, with the following three objectives:                                                              l
: a.        to prevent fires from starting                                                                    l
: b.        to detect rapidly, control, and extinguish promptly those fires that do occur                      l
: c.        to provide protection for SSCs important to safety so that if the fire suppressions activities are l unable to promptly extinguish a fire, safe shutdown of the plant can still be achieved            l l
In accordance with 10 CFR 50.48, the FPP must do the following:                                    l
: a.        Identify the various positions within the licensees organization that are responsible for the    l program and state the authorities delegated to these positions. (See Regulatory Position 1.1 of    l this guide.)                                                                                      l
: b.        Describe specific features such as administrative controls and personnel requirements for fire    l prevention. (See Regulatory Position 2 of this guide.)                                            l DG-1170, Page 37
 
l c.      Outline the plans for fire detection and suppression capability and limitation of fire damage.
l          (See Regulatory Positions 1.2, 3, and 4 of this guide.)
l d.      Describe personnel requirements for manual fire suppression activities.
l          (See Regulatory Position 3.5 of this guide.)
l e.      Describe the means to limit fire damage to structures, systems, and componentsSSCs important l          to safety so thatto ensure the capability to safely shut down the reactor is ensured.
A safe shutdown analysis should be developed that demonstrates the capability of the plant to safely shut down for a fire in any given area. The safe shutdown performance goals and reactor performance criteria applicable to safe shutdown are identified in Regulatory Positions 5.1 and 5.2 of this guide. Recommended systems and instrumentation for accomplishing safe shutdown are identified in Regulatory Positions 5.3 and 5.4 for hot shutdown and cold shutdown, respectively. The selected systems should be demonstrated to accomplish the safe shutdown functions within the fire damage guidelines of Regulatory Positions 5.3 and 5.4.
The analysis should identify the safe shutdown components and associated non-safety circuits for each fire area and demonstrate that the guidelines of Regulatory Position 5.5 are met or that alternative, dedicated, or backup shutdown is provided in accordance with Regulatory Position 5.6 of this guide. For each plant, the combinations of systems that provide the shutdown functions may be unique for each area; however, the shutdown functions provided should ensure that the safe shutdown performance objectives are achieved.
Procedures necessary to implement safe shutdown should also be developed and implemented as appropriate (see Regulatory Position 5.7).
1.4      Fire Test Reports and Fire Data Fire reports and data (e.g., fire barrier testing results and cable derating data) that are used to demonstrate compliance with NRC fire protection requirements should be evaluated to ensure that the information is applicable and representative of the conditions for which the information is being applied.
NFPA 251, "Standard Methods of Tests of Fire Endurance of Building Construction and Materials," advises that the test conditions should be evaluated carefully because variations from the construction of the test specimen or from the condition in which it is tested may substantially change the performance characteristics of the tested assembly.
Relative to testing of fire barrier assemblies, not all possible configurations can be tested, and l additional guidance is provided inplant. (See Regulatory Positions 1.8.3 and 4.2 of this guide for evaluation of installed configurations that deviate from tested conditions.
The guidance in Regulatory Position 1.4 is based on GL 92-08.
1.5      Compensatory Measures l          Temporary changes to specific3 and 5 of this guide.)
l l          For reactor sites that have both an operating reactor, as well as construction, modification, or l decommissioning of other units under way, the FPP should provide for continuing evaluation of fire l hazards associated with these activities. The licensee should provide additional fire barriers, fire DG-1170, Page 38
 
protection features that may be necessary to accomplish maintenance or modifications are acceptable provided interim compensatory measures, such as fire watches, temporary fire barriers, or backup suppression capability, are implemented. For common types of deficiencies, the specific compensatory measures are generally noted in technical specifications or the NRC-approvedcapability, and                l administrative controls as necessary to protect the operating unit(s) from any fire hazards associated with l construction or decommissioning activities.                                                                l l
1.1    Organization, Staffing, and Responsibilities                                                        l l
The FPP should describe the organizational structure and responsibilities for its establishment    l and implementation. These responsibilities include FPP policy; program management (including                l program development, maintenance, updating, and compliance verification); fire protection program.          l For unique situations, the appropriate compensatory measures are determined by the licensee.
Text Was Moved From Here: 5 The guidance in Regulatory Position 1.5 is based on CMEB 9.5-1, GL 86-10, GL 91-18, and IN 97-48.
1.6    Fire Protection Training and Qualifications The fire protection program should be under the direction of an individual staffing and            l qualifications; engineering and modification; inspection, testing, and maintenance of fire protection      l systems, features, and equipment; fire prevention; emergency response (e.g., fire brigades and offsite      l mutual aid); and general employee, operator, and fire brigade training.                                    l l
The licensee should assign direction of the FPP to an individual who has been delegated            l authority commensurate with the responsibilities of the position and who has available staff personnel      l knowledgeable in both fire protection and nuclear safety. Plant personnel should be adequately trained in  l l
The licensee should assign overall responsibility for the FPP to a person who has management        l control over all organizations involved in fire protection activities. Formulation and assurance of        l program implementation may be delegated to a staff composed of personnel prepared by training and          l experience in fire protection and personnel prepared by training and experience in nuclear plant safety to  l provide a comprehensive approach in directing the FPP for the nuclear power plant.                          l l
The following positions or organizations should be designated:                                      l
: a.      The upper-level management position has responsibility for the formulation, implementation, and    l assessment of the effectiveness of the nuclear plant FPP.                                          l
: b.      Other management positions have direct responsible for formulating, implementing, and              l periodically assessing the effectiveness of the FPP for the licensees nuclear power plant,          l including fire drills and training conducted by the fire brigade and plant personnel. The results  l of these assessments should be reported to the upper-level management position responsible for      l fire protection with recommendations for improvements or corrective actions as deemed              l necessary.                                                                                          l l
Text Moved Here: 2                                                                                          l DG-1170, Page 39
 
l        c. TheAn onsite management position is responsible for the overall administration of the plant operations and emergency plans that include the fire protection and prevention program and that provide a single point of control and contact for all contingencies. On l              sites with an operating reactor, and withs well as ongoing construction, modification, or decommissioning of other units under way, the superintendent of the operating plant should have the lead responsibility for site fire protection.
l End Of Moved Text l d. Additional onsite positions have responsibility for the following:
l l Text Moved Here: 3
: i.      Implement periodic inspections to minimize the amount of combustibles in plant areas important to safety; determine the effectiveness of housekeeping practices; ensure the availability and acceptable condition of all fire protection l                        systems/equipment, emergency breathing apparatuses, emergency lighting, communication equipment, fire stops, penetration seals, and fire retardant coatings; and ensure that prompt and effective corrective actions are taken to correct conditions adverse to fire protection and preclude their recurrence.
l End Of Moved Text l        ii. Provide firefighting training for operating plant personnel and the plants fire brigade; l              design and select equipment; periodically inspect and test fire protection systems and l              equipment in accordance with established procedures; and evaluate test results and l              determine the acceptability of the systems under test.
l        iii. Assist in the critique of all fire drills to determine how well the training objectives have l              been met.
l        iv. Review proposed work activities with regard to in-plant fire protection, identify potential l              transient fire hazards, and specify required additional fire protection in the work activity l              procedure.
l        v. Implement a program to indoctrinate all plant contractor personnel in appropriate l              administrative procedures that implement the fire protection programFPP and the emergency procedures relative to fire protection.
l        The guidance in Regulatory      vi.      Implement a program to instruct personnel on the proper l                                                  handling of accidental events such as leaks or spills of l                                                  flammable materials that are related to fire protection.
l        vii. Review hot work.
DG-1170, Page 40
: e.      An onsite position is responsible for fire protection QA. This position ensures the effective      l implementation of the FPP by planned inspections, scheduled audits, and verification that the      l results of these inspections and audits are promptly reported to cognizant management personnel. l
: f.      The plants fire brigade positions should be identified with the following in mind                  l (see also Regulatory Position 1.6 is based on Appendix R3.5.1 of this guide):                      l
: i.      The plant fire brigade positions should be responsible for fighting fires. The authority  l and responsibility of each fire brigade position relative to fire protection should be    l clearly defined.                                                                          l ii.      The responsibilities of each fire brigade position should correspond with the actions      l required by the firefighting procedures.                                                  l iii. Collateral responsibilities of the fire brigade members should not conflict with their    l responsibilities related to the fire brigade during a fire emergency.                      l iv.      The minimum number of trained fire brigade members available on site for each              l operating shift should be consistent with the activities required to combat credible and  l challenging fires, but should be no less than five members. The size of the fire brigade  l should be based upon the functions required to fight fires, with adequate allowance for    l injuries. Fire brigade staffing should account for all operational and emergency response  l demands on shift personnel in the event of a significant fire.                            l l
1.2      Fire Hazards Analysis                                                                              l l
A fire hazards analysis should be performed to demonstrate that the plant will maintain the        l ability to perform safe-shutdown functions and minimize radioactive material releases to the environment    l in the event of a fire. This analysis should be revised as necessary to reflect plant design and operational l changes.                                                                                                    l l
The fire hazards analysis accomplishes the following objectives:                                    l
: a.      considers potential in situ and transient fire hazards                                              l
: b.      determines the effects of a fire in any location in the plant on the ability to safely shut down    l the reactor or to minimize and control the release of radioactivity to the environment              l
: c.      specifies measures for fire prevention, fire detection, fire suppression, and fire containment      l and alternative shutdown capability for each fire area containing SSCs important to safety          l in accordance with NRC guidelines and regulations                                                  l l
l Text Moved Here: 4                                                                                          l The fire hazards analysis verifies that the applicable NRC fire protection program        l guidelinesregulatory requirements and guidance for the FPP have been met. The analysis lists        l applicable elements of the program, with explanatory statements as needed to identify location, type of system, and design criteria. The analysis should identify and justify any deviations from  l the regulatory guidelines. Justification for deviations from the regulatory guidelines should      l showdemonstrate that an equivalent level of protection will be achieved. (sSee Regulatory          l Position 1.8 of this guide regarding when such deviations are subject to the exemption request      l process.). Deletion of a protective feature without compensating alternative protection measures    l is typically unacceptable, unless it is clearly demonstrated that the protective measure is not needed because of the design and arrangement of the particular plant.
DG-1170, Page 41
 
l End Of Moved Text l
l        The fire hazards analysis should address the following elements and attributes:
l a. The applicability of NRC fire protection requirements and guidance should be evaluated.
l b. In situ and potential transient fire and explosion hazards, including amounts, types, l        configurations, and locations of flammable and combustible materials (e.g., electric cable l        insulation and jacketing material, lube oil, diesel fuel oil, flammable gases, chemicals, building l        materials and finishes) associated with operations, maintenance, and refueling activities should l        be identified. The continuity of combustible materials (e.g., exposed electrical cables that span l        the distance between redundant trains), the potential for fire spread, and sources of ignition l        should be identified and described in the analysis.
l c. External exposure hazards (e.g., flammable and combustible liquid or gas storage, auxiliary l        boiler units, adjacent industrial facilities or transportation systems, natural vegetation, and l        adjacent plant support facilities) that could potentially expose SSCs important to safety to l        damage from the effects (e.g., heat, flame, smoke) of fires should be identified. Wildfire hazards l        should be addressed if there is the potential for a wildfire to damage SSCs important to safety.
l d. The design, installation, operation, testing, and maintenance of automatic fire detection and l        suppression capability should be addressed. The fire hazards analysis should describe the level l        of automatic protection (e.g., water spray density, gaseous agent concentration) provided relative l        to the specific fire hazards that have been identified. The effects of lightning strikes should be l        included in the design of fire detection systems.
l e. The layout and configurations of SSCs important to safety should be depicted. The protection l        for safe-shutdown systems (see Regulatory Positions 5.3 and 5.4 of this guide) within a fire area l        should be determined on the basis of the worst-case fire that is likely to occur and the resulting l        damage. The fire hazards analysis should explain and document the extent of such damage. The l        analysis should consider the degree of spatial separation between redundant shutdown systems, l        the presence of in situ and transient combustibles, the available fire protection systems and l        features, sources of ignition, and the susceptibility to fire damage of the safe-shutdown-related l        cables, equipment, systems, and features in the area. Where automatic suppression systems are l        installed, the fire hazards analysis should evaluate the effects of the postulated fire with and l        without actuation of the automatic suppression system.
l f. Reliance on and qualifications of fire barriers, including fire test results, the quality of the l        materials and barrier system, and the quality of the barrier installation should be described.
l        Regulatory Position 4.3 of this guide provides detailed guidelines for testing and qualification of l        electrical raceway fire barrier systems.
l g. Fire area construction (walls, floor, and ceiling materials, including coatings and thicknesses; l        fireproofing of structural members; area dimensions and volume; normal ventilation and smoke l        removal capability; and level of congestion as it applies to access for manual firefighting l        activities) should be described. The fire hazards analysis should provide sufficient information l        to determine that fire areas have been properly selected based on the fire hazards present and the l        need for separation of SSCs important to safety. Regulatory Position 4.1.2 provides guidelines l        for fire areas and zones.
l h. Manual suppression capability, including systems (e.g., hydrants, standpipes, extinguishers), fire l        brigades, manual firefighting equipment, plans and procedures, training, drills, mutual aid, and l        accessibility of plant areas for manual firefighting should be identified. The fire hazards analysis DG-1170, Page 42
 
should list the location and type of manual firefighting equipment and accessibility for manual      l firefighting.                                                                                        l
: i.      Potential fire impacts on operations should be identified, including:                                l
: i.      fire in control rooms or other locations where operations important to safety are            l performed                                                                                    l ii.      fire conditions that may necessitate evacuation from areas that are required to be          l attended for safe shutdown                                                                  l iii. lack of adequate access or smoke removal facilities that impede plant operations or fire    l extinguishment in plant areas important to safety                                            l
: j.      Potential disabling effects of fire suppression systems on safe-shutdown capability should be        l identified. The term damage by fire in Appendix R also includes damage to equipment from            l the normal or inadvertent operation of fire suppression systems. The fire hazards analysis should    l address the effects of firefighting activities. GDC 3 of Appendix A to 10 CFR Part 50 and            l CMEB 9.5-1.
1.6.1 Fire Protection Staffstates that Fire-fighting systems shall be designed to assure that        l their rupture or inadvertent operation does not significantly impair the safety capability of these            l structures, systems, and components.                                                                          l
: k.      Explosion-prevention measures in areas subject to potential explosive environments from              l flammable gases or other potentially energetic sources (e.g., chemical treatment systems,            l ion exchange columns, high-voltage electrical equipment) should be listed.                            l
: l.      The availability of oxygen (e.g., inerted containment) should be identified.                          l
: m.      Alternative or dedicated shutdown capability for those fire areas where adequate separation of        l redundant safe-shutdown systems cannot be achieved should be identified.                              l l
Fire initiation should be postulated at the location within each fire area/zone that will produce the l most severe fire with the potential to adversely impact SSCs important to safety. Fire development            l should consider the potential for involvement of other combustibles, both fixed and transient, in the fire    l area. Where automatic suppression systems are installed, the effects of the postulated fire should be          l evaluated with and without actuation of the automatic suppression system.                                      l l
Worst-case fires need not be postulated to be concurrent with non-fire-related failures in safety  l systems, other plant accidents, or the most severe natural phenomena.                                          l l
On multiple-reactor sites, unrelated fires in two or more units need not be postulated to occur      l simultaneously. Fires involving facilities shared between units and fires caused by manmade site-related      l events that have a reasonable probability of occurring and affecting more than one reactor unit (such as      l an aircraft crash) should be considered.                                                                      l l
The fire hazards analysis should separately identify hazards and provide appropriate protection in    l locations where losses of SSCs important to safety can occur as a result of the following:                    l
: a.      concentrations of combustible contents, including transient fire hazards of combustibles expected    l to be used in normal operations, such as refueling, maintenance, and modifications                    l DG-1170, Page 43
 
l b.      continuity of combustible contents, furnishings, building materials, or combinations thereof in l          configurations conducive to fire spread l c.      exposures to fire, heat, smoke, or water, including those that may necessitate evacuation from l          areas that are required to be attended for safe shutdown l d.      fire in control rooms or other locations having critical functions important to safety l e.      lack of adequate access or smoke removal facilities that impede plant operations or fire l          extinguishment in plant areas important to safety l f.      lack of explosion-prevention measures l g.      loss of electric power or control and instrumentation circuits l h.      inadvertent operation of fire suppression systems l          Qualified fire protection and reactor systems engineers should perform the fire hazards analysis.
l Identifying fire hazards and the consequences of a postulated fire starting at any location in the plant l requires experienced judgment. Persons who are thoroughly trained and experienced in reactor safety are l able to evaluation the consequences of the postulated fire on nuclear safety. The person conducting the l analysis of fire hazards should be thoroughly trained and experienced in the principles of industrial fire l prevention and control and in fire phenomena from fire initiation, through its development, to l propagation into adjoining spaces. The fire hazards analysis should be conducted by or under the direct l supervision of an engineer with the qualifications listed in Regulatory Position 1.6.1.a of this guide.
l l 1.3      Safe-Shutdown Analysis l
l          In accordance with 10 CFR 50.48, each operating nuclear power plant must provide the means to l limit fire damage to SSCs important to safety so that the capability to safely shut down the reactor is l ensured.
l          Licensees should develop a safe-shutdown analysis to demonstrate the capability of the plant to l safely shut down for a fire in any given area. Regulatory Position 5.1 of this guide identifies the safe-l shutdown performance goals. The licensee should demonstrate the ability of the selected systems to l accomplish these performance goals.
l          The analysis should identify the safe-shutdown components and circuits for each fire area and l demonstrate that the guidelines of Regulatory Position 5.3 are met or that alternative, dedicated, or l backup shutdown is provided in accordance with Regulatory Position 5.4 of this guide. For each plant, l the combinations of systems that provide the shutdown functions may be unique for each area; however, l the shutdown functions provided should ensure that the safe-shutdown performance objectives are l achieved.
l          The licensee should also develop and implement procedures necessary to implement safe l shutdown as appropriate. (See Regulatory Position 5.5 of this guide.)
l l 1.4      Fire Test Reports and Fire Data l
l          The licensee should evaluate fire reports and data (e.g., fire barrier testing results and cable l derating data) that are used to demonstrate compliance with NRC fire protection requirements to ensure l that the information is applicable and representative of the conditions for which the information is being l applied.
l          NFPA 251 advises that test conditions should be evaluated carefully because variations from the l construction of the test specimen or from the condition in which it is tested may substantially change the l performance characteristics of the tested assembly.
DG-1170, Page 44
 
Relative to testing of fire barrier assemblies, not all possible configurations can be tested;      l Regulatory Positions 1.8.3 and 4.3 of this guide provide additional guidance for evaluating installed        l configurations that deviate from tested conditions.                                                          l l
1.5      Compensatory Measures                                                                              l l
Temporary changes to specific fire protection features that may be necessary to accomplish          l maintenance or modifications are acceptable, provided interim compensatory measures, such as fire            l watches, temporary fire barriers, or backup suppression capability, are implemented. For common types        l of deficiencies, the technical specifications or the NRC-approved FPP generally note the specific            l compensatory measures. For unique situations or for measures that the approved FPP does not include,        l the licensee may determine appropriate compensatory measures. A licensee may opt to implement an            l alternative compensatory measure, or combination of measures, to the one stated in its FPP. A licensee      l may implement such alternative measures without prior approval of the Commission if all of the              l following are available:                                                                                    l
: a.      a documented evaluation showing the impact of the new compensatory measure                          l
: b.      a documented evaluation comparing the new compensatory measure to the compensatory                  l measure required by the licensees FPP                                                              l
: c.      evaluations showing that the new compensatory measure(s) will not adversely affect the ability      l of the plant to achieve and maintain safe shutdown in the event of a fire                          l l
Any change to the FPP must comply with the GDC and the requirements of 10 CFR 50.48(a) and          l must be retained as a record pursuant to 10 CFR 50.48(a). The licensees change to the FPP is subject to    l inspection by the NRC.                                                                                      l l
The evaluation of the alternate compensatory measure should incorporate risk insights regarding    l the location, quantity, and type of combustible material in the fire area; the presence of ignition sources  l and their likelihood of occurrence; the automatic fire suppression and fire detection capability in the fire l area; the manual fire suppression capability in the fire area; and the human error probability where        l applicable.                                                                                                  l l
l Text Moved Here: 5                                                                                          l CThe licensee may implement compensatory measures may also be implemented for degraded              l and nonconforming conditions. In its evaluation of the impact of a degraded or nonconforming condition on plant and individual SSC operation and on operability of structures, systems, and components, a          l licensee may decide to implement a compensatory measure as an interim step to restore operability or to otherwise enhance the capability of structures, systems, and componentsSSCs important to safety until        l the final corrective action is complete. Reliance on a compensatory measure for operability should be an important consideration in establishing the "reasonable time frame"reasonable timeframe to complete        l the corrective action process. As stated in Revision 1 of GL 91-18, tThe NRC would normally expect          l that conditions that require interim compensatory measures to demonstrate operability wouldto be            l resolved more promptly than conditions that are not dependent on compensatory measures to show operability, because; such reliance suggests a greater degree of degradation. Similarly, if an operability  l determination is based upon operator action, the NRC staff would expect the nonconforming condition to      l be resolved expeditiously. (See Regulatory Position 1.8.5 for additional guidance on operability            l assessments.)                                                                                                l End Of Moved Text                                                                                            l l
DG-1170, Page 45
 
l          NRC Inspection Manual Part 9900, Operability Determinations & Functionality Assessments l for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety provides l additional guidance on operability assessments that the Reactor Oversight Process will apply when l conducting inspections. This guidance supersedes the guidance provided in Revision 1 of GL 91-18, l Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded l and Nonconforming Conditions and on Operability.
l l 1.6      Fire Protection Training and Qualifications l
l l          The FPP should be under the direction of an individual who has available staff personnel l knowledgeable in both fire protection and nuclear safety. Plant personnel should be adequately trained in l the administrative procedures that implement the FPP and the emergency procedures relative to fire l protection.
l l 1.6.1    Fire Protection Staff Training and Qualifications l
l          Fire protection staff should meet the following qualifications:
l a.      The formulation and assurance of the fire protection programFPP and its implementation should be the responsibility of personnel prepared by training and experience in fire protection and in nuclear plant safety to provide a comprehensive approach in directing the fire protection l          programFPP for the nuclear power plant. A fire protection engineer (or a consultant) who is a graduate of an engineering curriculum of accepted standing and satisfies the eligibility l          requirements as a Member in the Society of Fire Protection Engineers (SFPE) should be a l          member of the organization responsible for the formulation and implementation of the fire l          protection programFPP.
l b.      The fire brigade members' qualifications should include satisfactory completion of a physical l          examination for performing strenuous activity and the fire brigade training as described in Regulatory Position 1.6.4.
: c.      The personnel responsible for the maintenance and testing of the fire protection systems should be qualified by training and experience for such work.
: d.      The personnel responsible for the training of the fire brigade should be qualified by knowledge, suitable training, and experience for such work.
The guidance in Regulatory Position 1.6.1 is based on CMEB 9.5-1.
l          1.6.2    General Employee Training l
l          Each nuclear plant employee has a responsibility into the preventionprevent, detectiondetect, and l suppression ofsuppress fires. Site gGeneral site employee training should introduce all personnel to the l elements of the site fire protection programs FPP, including the responsibilities of the fire protection l staff. InstructionTraining should be providedalso include information on the types of fires and related DG-1170, Page 46
 
extinguishing agents, specific fire hazards at the site, and actions in the event of a fire suppression system actuation.
General employee training should provide specific instruction to site and contractor personnel on the following:
: a.      Aappropriate actions to take upon discovering a fire, including, for example, notification of the    l control room, attemptattempting to extinguish the fire, and actuation of local fire suppression      l systems.
l
: b.      Aactions upon hearing a fire alarm;                                                                  l l
: c.      Aadministrative controls on the use of combustibles and ignition sources; and                        l l
: d.      The actions necessary in the event of a combustible liquid spill or gas release/leaks.
The guidance in Regulatory Position 1.6.2 is based on IP 64704.
1.6.3    release or leaks                                                                            l l
1.6.3    Fire Watch Training                                                                                  l l
Fire watches provide for observation and control of fire hazards associated with hot work, orand      l they may act as compensatory measures for degraded fire protection systems and features. Specific fire watch training should provide instruction on fire watch duties, responsibilities, and required actions for both 1-hour roving and continuous fire watches. Fire watch qualifications should include hands-on training on a practice fire with the extinguishing equipment to be used while on fire watch. If fire watches are to be used as compensatory actions, the fire watch training should include record-keeping requirements.
The guidance in Regulatory Position 1.6.3 is in GL 93-03 and IP 64704.
DG-1170, Page 47
 
l          1.6.4  Fire Brigade Training and Qualifications l
l          The fire brigade training program should ensure thatestablish and maintain the capability to fight credible and challenging fires is established and maintained. The program should consist of initial l classroom instruction followed by periodic classroom instruction, firefighting practice, and fire drills .
l (sSee Regulatory Position 3.5.1.4 for drill guidance.).
l          Numerous NFPA standards provide guidelines applicable to the training of fire brigades. TThe l NRC staff considers the training recommendations of NFPA 600, "Standard on Industrial Fire l Brigades," including the applicable NFPA publications referenced in NFPA 600, are consideredto be l appropriate criteria for training of the plant fire brigade. The licensee may also use NFPA 1410, l "StandardStandard on Training for Initial Fire Attack," may also be used as applicableEmergency Scene l Operations, and NFPA 1500, Standard on Fire Department Occupational Safety and Health Program l as appropriate. NFPA booklets and pamphlets listed in NFPA 600 may be used, as applicable, for l training references. In addition, the licensee should use courses in fire prevention and fire suppression that are recognized or sponsored by the fire protection industry should be used.
l          1.6.4.1          Qualifications.
l l          The brigade leader and at least two brigade members should have sufficient training in or l knowledge of plant systems to understand the effects of fire and fire suppressants on safe -shutdown capability. The brigade leader should be competent to assess the potential safety consequences of a fire and advise control room personnel. Such competence by the brigade leader may be evidenced by l possession of an operator's license or equivalent knowledge of plant systems. Nuclear power plants staffed with a dedicated professional fire department may utilize a fire team advisor to assess the potential safety consequences of a fire and advise the control room and incident commander. The fire l team advisor should possess an operator's license or equivalent knowledge of plant systems and be dedicated to supporting the fire incident commander during fire emergency events.
The qualification of fire brigade members should include an annual physical examination to determine their ability to perform strenuous firefighting activities.
DG-1170, Page 48
 
1.6.4.2          Instruction. The instruction                                                        l l
Instruction should be provided by qualified individuals who are knowledgeable, experienced, and      l suitably trained in fighting the types of fires that could occur in the plant and in using the types of equipment available in the nuclear power plant. IThe licensee should provide instruction should be            l provided to all fire brigade members and fire brigade leaders.
The initial classroom instruction should include the following:                                    l
: a.      Iindoctrination of the plant firefighting plan with specific identification of each individual 's    l responsibilities.
: b.      Iidentification of the type and location of fire hazards and associated types of fires that could    l occur in the plant.
: c.      Tthe toxic and corrosive characteristics of expected products of combustion                          l
: d.                                                                                                            l
: d.      Identification    identification of the location of firefighting equipment for each fire area and    l familiarization with the layout of the plant, including access and egress routes to each area.
l DG-1170, Page 49
 
l e.      Tthe proper use of available firefighting equipment and the correct method of fighting each type l          of fire, including the following:
l                    i.      Ffires involving radioactive materials, l
l          ii.      Ffires in energized electrical equipment, l
l          iii.      Ffires in cables and cable trays, l
l          iv.      Hhydrogen fires, l
l          v.        Ffires involving flammable and combustible liquids or hazardous process chemicals, l
l          vi.      Ffires resulting from construction or modifications (welding), and l
l          vii.      Rrecord file fires.
l l f.      Tthe proper use of communication, lighting, ventilation, and emergency breathing equipment.
l g.      Tthe proper method for fighting fires inside buildings and confined spaces.
l h.      Tthe direction and coordination of the firefighting activities (fire brigade leaders only) .
l i.      Ddetailed review of firefighting strategies and procedures.
l j.      Rreview of the latest plant modifications and corresponding changes in firefighting plans.
l          TrainingThe licensee should coordinate training of the plant fire brigade should be coordinated with the local fire department so that responsibilities and duties are delineated in advance. This coordination should be part of the training course and should be included in the training of the local fire department staff.
Instruction should provide the techniques, equipment, and skills for the use of water in fighting electrical cable fires in nuclear plants, particularly in areas containing a high concentration of electric cables with plastic insulation.
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RegularThe licensee should hold regularly planned meetings should be held at least quarterly for l all brigade members to review changes in the fire protection programFPP and other subjects as necessary. l PThe licensee should offer periodic refresher training sessions should be held to repeat the    l classroom instruction program for all brigade members over a two-year2-year period. These sessions        l may be concurrent with the regularly planned meetings.                                                    l RThe licensee should schedule retraining or broadened training for fire fightingfirefighting    l within buildings should be scheduled for all those brigade members whose performance records show deficiencies.
1.6.4.3          Fire Brigade Practice .                                                        l l
The Plicensee should hold practice sessions should be held for each shift fire brigade on the    l proper method of fighting the various types of fires that could occur in a nuclear power plant. These    l sessions should provide brigade members with experience in actual fire extinguishment and the use of self-contained breathing apparatuses under the strenuous conditions encountered in fire                  l fightingfirefighting. T The licensee should provide these practice sessions should be provided at least  l once per year for each fire brigade member.
1.6.4.4          Fire Brigade Training Records .                                                l l
The Ilicensee should maintain individual records of training provided to each fire brigade      l member, including drill critiques, should be maintained for at least 3 years to ensure that each member receives training in all parts of the training program. These records of training should be available for l NRC review.
The guidance in Regulatory Position 1.6.4 is based on Appendix R to 10 CFR Part 50, APCSB 9.5-1, and CMEB 9.5-1.
1.7      Quality Assurance                                                                                l The quality assurance (overall plant QA plan should include the QA) program for fire protection  l should be part of the overall plant QA program. For fire protection systems, the licensee should have and maintain a QA program that provides assurance that the fire protection systems are designed, fabricated, erected, tested, maintained, and operated so that they will function as intended. Fire protection systems are not "safety-related"safety-related and are, therefore, are not within the scope of Appendix B,      l Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50,    l unless the licensee has committed to include these systems under the plants Appendix B program for t. l The plant. NRC staff generally used guidance for an acceptable QA program for fire protection systems,    l previously given in Section C.4 of Branch Technical PositionBTP CMEB 9.5-1, Rev.Revision 2,              l datedissued July 1981, was generally used in the review and acceptance of approved fire protection        l programsFPPs for plants licensed after January 1, 1979. This regulatory guide incorporates that guidance  l and the NRC staff will continue to use it in the review and acceptance of approved FPPs for new          l reactors. For plants licensed prior to January 1, 1979, similar guidance is specified in APCSB 9.5-1 and  l Appendix A thereto and in Generic LetterGL 77-02, "NuclearNuclear Plant Fire Protection Functional      l Responsibilities, Administrative Controls and Quality Assurance, specify similar guidance."              l DG-1170, Page 51
 
l          The QA program should be under the management control of theplants QA organization should l manage the fire protection QA program. This control consists of (1) formulating and/or verifying that the fire protection QA program incorporates suitable requirements and is acceptable to the management l responsible for fire protection, and (2) verifying the effectiveness of the QA program for fire protection l through review, surveillance, and audits. Performance ofPersonnel outside the QA organization may l perform other QA program functions for meeting the fire protection program requirements may be performed by personnel outside of the QA organization.
l to meet the FPP requirements.
l          To implement the Ffire Pprotection QA Pprogram in this Regulatory Position, licensees have the option of either (1) including the fire protection QA program as part of the plants overall QA program l under Appendix B to 10 CFR Part 50, or (2) providing for NRC review a description of the fire l protection QA program and the measures for implementing tits implementation measure.
l          The fire protection QA program.
l          The fire protection QA program should satisfy the specific criteria. These criteria that apply to l items within the scope of the fire protection programFPP, such as fire protection systems and features, l emergency lighting, communication and self-contained breathing apparatuses, as well asand the fire protection requirements of applicable equipment important to safety.
l          1.7.1    Design and Procurement Document Control l
l          MeasuresThe licensee should be established establish measures to include the guidance l ofpresented in this gRegulatory Guide in its design and procurement documents and that deviations therefrom are controlled such that:
l a.      . The licensee should also control deviations from this guidance such that the following occurs:
l a.      Design and procurement document changes, including field changes and design deviations, are subject to the same level of controls, reviews, and approvals that were applicable to the original document.
l l b.      Quality standards are specified in tThe design documents, such as appropriate fire protection l          codes and standards, specify quality standards, and deviations and changes from these quality standards are controlled.
l c.      NQualified personnel review new designs and plant modifications, including fire protection systems, are reviewed by qualified personnel to ensure inclusion of appropriate fire protection l          requirements. These reviews should include items such as the following:
l
* D      i.      design reviews to verify adequacy of wiring isolation and cable separation criteria.
l
* D DG-1170, Page 52
 
ii.      design reviews to verify appropriate requirements for room isolation (sealing            l penetrations, floors floors, and other fire barriers).                                  l
: d.      A                                                                                                  l See Regulatory Position 1.8 for guidance on FPP changes and code deviations.                      l
: d.      Qualified personnel perform and document the review and approval of the adequacy of fire          l protection requirements and quality requirements stated in procurement documents are performed and documented by qualified personnel. This review should determine that fire protection requirements and quality requirements are correctly stated, inspectaible, and          l controllable; there are adequate acceptance and rejection criteria; and the procurement document has been prepared, reviewed, and approved in accordance with applicable QA program requirements.
1.7.2    Instructions, Procedures, and Drawings                                                    l l
IDocumented instructions, procedures, or drawings should prescribe inspections, tests,            l administrative controls, fire drills, and training that govern the fire protection program should be prescribed by documented instructions, procedures, or drawings and should be accomplished in accordance with these documents such that:
FPP and the licensee should ensure the following:                                                          l
: a.      Indoctrination and training programs for fire prevention and fire fightingfirefighting are        l implemented in accordance with documented procedures.
: b.      Activities such as design, installation, inspection, test, maintenance, and modification of fire protection systems are prescribed and accomplished in accordance with documented instructions, procedures, and drawings.
: c.      Instructions and procedures for design, installation, inspection, test, maintenance, modification, and administrative controls are reviewed to ensure that the proper fire protection requirements are addressed, such as control of ignition sources and combustibles, provisions for backup fire protection capability, disablingdisablement of a fire protection system, and the restriction on    l material substitution unless specifically evaluated.
: d.      The installation or application of penetration seals, fire barrier systems, and fire retardant coatings is performed by trained personnel using approved procedures.
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l        1.7.3    Control of Purchased Material, Equipment, and Services l
l        MeasuresThe licensee should be established establish the following measures to ensure that purchased material, equipment, and services conform to the procurement documents. These measures should include:
l a.      Pprovisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor, inspections at suppliers, or receipt inspections .
l b.      Ssource or receipt inspection, ast a minimum, for those items whose quality cannot be verified after installation.
1.7.4 Inspection l        Athat, once installed, cannot have their quality verified l
l 1.7.4  Inspection l
l        The licensee should establish and execute a program for independent inspection of activities l affecting fire protection should be established and executed by, or for,that allows the organization performing the activity to verify conformance to documented installation drawings and test procedures l for accomplishing activities. This program should include the following:
l a.      Iinspections of:
l
* Installation installation, maintenance, and modification of fire protection systems or l                  features l b.
l
* Emergency        inspection of emergency lighting and communication equipment to l                                    ensure conformance to design and installation requirements l c.
l b.      Inspection        inspection of penetration seals, fire barriers, and fire retardant coating installations to verify the activity is satisfactorily completed.
l c l d.      Iinspections of cable routing to verify conformance with design requirements.
l de. Iinspections to verify that appropriate requirements for room isolation (sealing penetrations, l        floors, and other fire barriers) are accomplished during construction l f.
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: e. Measures          measures to ensure that inspection personnel are independent from the            l individuals performing the activity being inspected and are knowledgeable in the design and installation requirements for fire protection.
f                                                                                                    l
: g. Iinspection procedures, instructions, and check lists that provide for the following:              l
* I        i.      identification of characteristics and activities to be inspected .      l
* I                                                                                        l ii.      identification of the individuals or groups responsible for performing the inspection    l operation.
* A                                                                                        l iii. acceptance and rejection criteria.                                                        l
* A                                                                                        l iv.      a description of the method of inspection.                                                l
* R                                                                                        l
: v.      recording of evidence of completingthe completion and verifyingverification of a          l manufacturing, inspection, or test operation.
* R                                                                                        l vi.      recording of inspector or data recorder and the results of the inspection operation      l
: h.                                                                                                    l
: g. Periodic          periodic inspections of fire protection systems, emergency breathing and        l auxiliary equipment, emergency lighting, and communication equipment to ensure the acceptable condition of these items.
h                                                                                                    l
: i. Pperiodic inspection of materials subject to degradation, such as fire barriers, stops, seals, and l fire retardant coatings to ensure that these items have not deteriorated or been damaged.          l DG-1170, Page 55
 
l          1.7.5    Test and Test Control l
l          A test programThe licensee should be established and implementedimplement a test program to ensure that testing is performed and verified by inspection and audit to demonstrate conformance with l design and system readiness requirements. The tests should be performed in accordance with written test l procedures; test results should be properly evaluated and corrective acted onions taken as necessary. The l test program should include the following:
l a.      Installation Testing  FollowingTestingFollowing construction, modification, repair or l          replacement, the licensee should perform sufficient testing should be performed to demonstrate that fire protection systems, emergency lighting, and communication equipment will perform satisfactorily in service and that design criteria are met. Written test procedures for installation l          tests should incorporate the requirements and acceptance limits contained in applicable design documents.
l b.      Periodic testing  TTestingThe licensee should develop and document the schedules and l          methods for periodic testing are developed and documented. FPeriodic testing of fire protection l          equipment, emergency lighting, and communication equipment are tested periodically towill ensure that the equipment will function properly and continue to meet the design criteria.
l c.      Programs are established for QA/QCc. Quality AssuranceThe licensee should establish l                                                    programs for QA and quality control (QC) to verify testing of fire protection systems and features and to l                                                    verify thatdetermine whether test personnel are effectively trained.
l d.      Test l d.      DocumentationA qualified individual or group should be responsible for ensuring that test results are documented, evaluated, and their acceptability determined by a qualified responsible individual or group.
l          1.7.6    acceptable.
l l 1.7.6    Inspection, Test, and Operating Status l
l          MeasuresThe licensee should be established establish measures to provide for the documentation l or identification of items that have satisfactorily passed required tests and inspections. These measures should include provisions for identification by means of tags, labels, or similar temporary markings to indicate completion of required inspections and tests and operating status.
l          1.7.7    Nonconforming Items l
l          MeasuresThe licensee should be established establish measures to control items that do not conform to specified requirements to prevent inadvertent use or installation. These measures l should include provisions to ensure thatthe following:
DG-1170, Page 56
: a. Nonconforming, inoperative, or malfunctioning fire protection systems, emergency lighting, and communication equipment are appropriately tagged or labeled.
: b. The identification, documentation, segregation, review disposition, and notification to the affected organization of nonconforming materials, parts, components, or services are procedurally controlled.
: c. Documentation identifies the nonconforming item, describes the nonconformance and the disposition of the nonconforming item, and includes signature approval of the disposition. l
: d. Provisions are established to identify those individuals or groups delegated the responsibility and authority for the disposition and approval of nonconforming items.
1.7.8    Corrective Action                                                                    l l
MeasuresThe licensee should be established establish measures to ensure that conditions        l adverse to fire protection, such as failures, malfunctions, deficiencies, deviations, defective components, uncontrolled combustible materials, and nonconformances, are promptly identified, reported, and corrected. These measures should ensure thatthe following:                              l
: a. Procedures are established for evaluation of conditions adverse to fire protection (such as nonconformance, failures, malfunctions, deficiencies, deviations, and defective material and equipment) to determine the necessary corrective action.
: b. In the case of significant or repetitive conditions adverse to fire protection, including fire incidents, the cause of the conditions is determined and analyzed, and prompt corrective actions are taken to preclude recurrence. The cause of the condition and the corrective        l action taken are promptly reported to cognizant levels of management for review and assessment.
DG-1170, Page 57
 
l        1.7.9 Records l
l        RecordsThe licensee should be prepared and maintainedmaintain records to furnish l evidence that the plant is meeting the criteria enumerated above are being met for activities l affecting the fire protection program suchFPP so that the following is true:
: a.      Records are identifiable and retrievable and should demonstrate conformance to fire l        protection requirements. The records should include results of inspections, tests, reviews, and audits; non-conformance and corrective action reports; construction, maintenance, l        and modification records; and certified manufacturers' data.
l b.      REstablished record retention requirements are established.
1.7.10 Audits l        Audits should be conducted and documentedexist.
l l 1.7.10 Audits l
l        The licensee should conduct and document audits to verify compliance with the fire l protection program such thatFPP and ensure the following:
: a.      Audits are performed to verify compliance with the administrative controls and l        implementation of quality assuranceQA criteria, including design and procurement documents, instructions, procedures, drawings, and inspection and test activities as they l        apply to fire protection features and safe -shutdown capability. These audits are l        performed by QA personnel perform these audits in accordance with preestablished l        written procedures or check lists and conducted by. The trained personnel who conduct l        the audits should not havinghave direct responsibilities in the areas being audited.
: b.      Audit results are documented and then reviewed with management that has responsibility l        inresponsible for the area audited.
: c.      Follow-up action is taken by responsible management to correct the deficiencies revealed by the audit.
: d.      Audits are performed annually to provide an overall assessment of conformance to fire protection requirements.
DG-1170, Page 58
 
FA qualified audit team should perform fire protection audits should be performed by a      l qualified audit team. The team should at the least include at least a lead auditor from the        l licensee's QA organization, a systems engineer, and a fire protection engineer. The lead auditor  l should be qualified, for example, per in accordance with American Society of Mechanical            l Engineers (ASME) NQA-1, Quality Assurance Program Requirements for Nuclear Facilities            l (or an alternative consistent with the general quality assuranceQA program requirements). The      l systems engineer should be knowledgeable in safety systems, operating procedures, and emergency procedures. The fire protection engineers (or engineering consultant) should meet the qualifications for membership in the Society of Fire Protection Engineers at the grade of mMember. in the SFPE The fire protection engineer can be a licensee employee who ishas not          l been directly responsible for the site fire protection programs FPP for two2 out of three3 years. l However, but should beevery third year an outside independent fire protection consultant every      l third yearshould be part of the audit team. This audit team approach will ensure that the          l technical requirements as well as theand QA requirements are adequately assessed.                  l Insurance company inspections typically do not satisfy any of the fire protection audit requirements because they do not evaluate plant fire protection programsFPPs against the NRC        l requirements, including the requirements for post-fire safe -shutdown. Insurance company            l inspections do not reassess or re-evaluate the fire protection programFPP, since the insurance      l company has already agreed to insure the licensee's program as it is being implemented.            l Insurance company inspections are generally limited to checking systems and materials for proper condition and maintenance, and inspecting hazardous conditions related to property protection and life. However, if the insurance company develops an inspection that has the proper scope and the inspection team includes a person knowledgeable in nuclear safety, an insurance company may perform these audits in conjunction with a lead auditor from the licensee's QA organization.                                                                        l ThreeThe following paragraphs specify three distinct fire protection audits are specified  l below. Originally, licensees were required to incorporate these audits into their Ttechnical        l Sspecifications, consistent with Standardized Technical Specification Section 6.5.2.8, iItems h, i, l and j. Some licensees may have elected to relocate technical specification requirements related to review and audit requirements to their QA plan. Incorporation of such requirements into the      l QA plan may revise existing technical specification audit frequencies by implementation of a performance-based schedule. Exceptions to the allowable use of performance-based audit frequencies include the triennial audit of fire protection plansFPPs, conducted by outside          l qualified fire consultants, which should be maintained in accordance with technical specification requirements.
1.7.10.1        Annual Fire Protection Audit.                                              l l
For those licensees who have relocated audit requirements from their Ttechnical            l Sspecifications to the QA program, "annual" fire protection audits may be changed to a              l "maximummaximum interval of 24 months" by implementation of a performance-based                  l schedule, if justified by performance reviews, provided that the maximum audit interval does not exceed the 2-year interval specified in ANSI N18.7.
DG-1170, Page 59
 
l        The elements that should be incorporated in theAmerican National Standards l Institute/American Nuclear Society (ANSI/ANS) 3.2-1994, Administrative Controls and Quality l Assurance for the Operational Phase of Nuclear Power Plants. The annual audit areshould l incorporate the following elements:
l a.      Purpose -- ThePurposeThe purpose of the annual audit is to assess the plant fire protection equipment and program implementation to verify that a level of safety consistent with NRC guidelines continues to be provided.
l b.      Scope -- EachScopeEach audit should verify that the commitments of the SARsafety l        analysis report and that the requirements of the Ttechnical Sspecifications and license conditions have been met and that modifications to systems and structures or changes in operating procedures have not decreased the level of safety in the plant. The audit should include inspection of all plant areas for which fire protection is provided and, in particular, examination of fire barriers, fire detection systems, and fire extinguishing l        systems provided for equipment important to safety. The audit should verify thatthe l        following:
DG-1170, Page 60
: i.      The installed fire protection systems and barriers are appropriate for the objects protected by comparing them to NRC guidelines and SER-approved alternatives and noting any deviations.
SSCs important to safety based on a comparison with NRC regulatory requirements and the            l approved FPP. Deviations should be noted.                                                          l ii.      The fire hazard in each fire area has not increased above that which wasthe safety l analysis report specified in the SAR.                                              l iii. Regularly scheduled maintenance is performed on plant fire protection systems.
iv.      Identified deficiencies have been promptly and adequately corrected.
: v.      Special permit procedures (hot work, valve positioning) are being followed.
vi.      Plant personnel are receiving appropriate training in fire prevention and firefighting procedures and the training program is consistent with approved standards. (The audit team should witness a typical training session.)            l vii. Plant response to fire emergencies is adequate by analyzingbased on an analysis of l incident records and witnessing an unplanned fire drill.
viii. Administrative controls are limiting transient combustibles in areas important to safety.
ix.      Problem areas identified in previous audits have been corrected.
The audit should analyze all problem areas identified by the audit and recommend appropriate fire protection measures to provide a level of safety consistent with NRC guidelines.
l 1.7.10.2        24-Month Fire Protection Audit.                                                    l l
The purpose of the 24-month audit of the fire protection programFPP and implementing        l procedures is toshould ensure that the requirements for design, procurement, fabrication,          l installation, testing, maintenance, and administrative controls for the respective programs continue to beare included in the plant QA program for fire protection and meet the criteria of the l QA/QC program established by the licensee, consistent with this guide. These audits should be performed by pPersonnel from the licensee's QA organization, who do not have direct                l DG-1170, Page 61
 
l responsibility for the program being evaluated, should perform these auditeds. These audits would normally encompass an evaluation of existing programmatic documents to verify continued adherence to NRC requirements.
l          1.7.10.3        Triennial Fire Protection Audit.
l l          The triennial audit is basically the same as the annual audit; the difference lies in the l source of the auditors. The annual audit may be performed by qQualified utility personnel who l are not directly responsible for the site fire protection programFPP or by an outside independent l fire protection consultant. T may perform the triennialannual audit should be performed by.
l However, an outside independent fire protection consultant should perform the triennial audit.
These audits would normally encompass an evaluation of existing documents (other than those l addressed under the 24-month audit) plusand an inspection of fire protection system operability, inspection of the integrity of fire barriers, and witnessing the performance of procedures to verify l that the fire protection programlicensee has been fully implemented the FPP and that the plan is l adequate for the objects protected. Duplicate audits are not required, (i.e., the 3-year audit l replaces the "annual audit" for the year in which it is performed).
The guidance in Regulatory Position 1.7 is based on CMEB 9.5-1, AL 95-06. GL 82-21, and GL 86-10.
l 1.8      Fire Protection Program Changes/Code Deviations This section provides guidance relative to the regulatory mechanisms for addressing changes, deviations, exemptions, and other issues affecting compliance with fire protection l regulatory requirements. Risk-informed, performance-based methodologies may be used to l evaluate the acceptability of FPP changes; however, the licensee should use NRC reviewed and l approved methodologies and acceptance criteria for this approach. Regulatory Guide 1.174 l includes guidance for risk-informed changes to a plants current licensing basis. This section l provides guidance with respect to fire modeling and Appendix B provides guidance with respect l to probabilistic risk assessment.
l          1.8.1 Safety Evaluations l
l          If thean existing plant licensee has adopted the standard license condition for fire l protection and incorporated the fire protection programFPP in the final safety analysis report l (FSAR), the licensee may make changes to the approved fire protection programFPP without the l Commissions 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 as documented in a safety evaluation. In addition to planned changes, a safety evaluation may also be required for l nonconforming conditions. An FPP change is any change to plant hardware or plant program l documents and procedures that impacts the FPP. In addition to changes directly related to fire l protection, this type of change may include plant changes that are not directly associated with the l fire protection system or procedures but that could, for example, impact the results of the post-l fire, safe-shutdown circuit analysis. Another example of an FPP change is an in situ condition l (physical or programmatic) that is an FPP regulatory noncompliance or a fire protection DG-1170, Page 62
 
licensing-basis noncompliance and which the licensee does not intend to correct via a plant or    l programmatic modification.                                                                        l Generic LetterGL 86-10 recommended that licensees incorporate the fire protection        l programFPP in the facility Final Safety Analysis Report (FSAR). Incorporation of the fire        l protection programFPP and major commitments, including the fire hazards analysis, by reference    l into the FSAR for the facility places the fire protection programFPP, including the systems, the  l administrative and technical controls, the organization, and other plant features associated with fire protection on a consistent status with other plant features described in the FSAR. Generic LetterGL 86-10 further recommended the adoption of the standard license condition (see            l Regulatory Position 1.8.1.2 of this guide), requiring licensees to comply with the provisions of  l the approved fire protection programFPP as described in the FSAR and establishing when NRC        l approval for changes to the program is required.
The licensee should maintain, in auditable form, a current record of all such changes, including an analysis of the effects of the change on thestandard fire protection program, and    l should make such records available to NRC Inspectors upon request. All changes to the approved program should be reported, along with the FSAR revisions required by 10 CFR 50.71(e).
1.8.1.1 Non-Standardlicense condition recommended by GL 86-10 is not applicable to        l the FPP for new reactors that are licensed in accordance with 10 CFR Part 52. Changes to new      l reactor FPPs that do not require exemption requests should be evaluated and processed in          l accordance with 10 CFR 50.59. The appendices to 10 CFR Part 52 include additional                l requirements for processing changes and exemptions for new reactors that are based on a          l certified design.                                                                                l l
1.8.1.1 Nonstandard License Condition.                                                            l l
If the fire protection programFPP committed to by the licensee is required by a specific  l license condition and is not part of the FSAR for the facility, the licensees may be required to  l submit amendment requests even for relatively minor changes to the fire protection programFPP. l DG-1170, Page 63
 
l        1.8.1.2          Standard License Condition.
l l        The TNRC transmitted the standard license condition for fire protection was transmitted l to licensees in April 1986 as part of Generic LetterGL 86-10 with information on its applicability to specific plants. The standard license condition reads as follows:
l                Fire Protection l                (Name of Licensee) shall implement and maintain in effect all provisions l                of the approved fire protection program as described in the Final Safety l                Analysis Report for the facility (or as described in submittals dated -------
l                ---) and as approved in the SER dated ----------- (and Supplements dated --
                  -------) subject to the following provision:
l                          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.
l        The adoptionGL 88-12 provides additional guidance for implementation of the standard license condition in conjunction with the incorporation of the fire protection program in the FSAR for the facility provides a more consistent approach to evaluating changes to the facility, l including thoseand removal of the technical specifications associated with the fire protection l programdetection and suppression, fire barriers, and fire brigade staffing.
Within the context of the standard fire protection license condition, the phrase not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire, means l to maintain sufficient safety margins. SeeRegulatory Guide 1.174, An Approach for Using l Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the l Licensing Basis, defines maintaining sufficient safety margins as either of the following:
l a.      Codes and standards or their alternatives approved for use by the NRC are met.
l b.      Safety analysis acceptance criteria in the licensing basis are met or proposed revisions l        provide sufficient margin to account for analysis and data uncertainty.
l l        It would be considered sufficient to maintain applicable safety margins by relating item l (a) above specifically to changes to the FPP under the standard license condition; changes that l maintain compliance with the applicable NFPA codes and standards endorsed by the NRC; l Appendix R to 10 CFR Part 50; this regulatory guide; and the applicable BTPs, NUREG-series l reports, and other NRC-approved or NRC-issued documents.
l l        Other documents approved or issued by the NRC that would provide a basis for l compliance would include topical reports endorsed by the staff or other staff-documented generic l positions or generic communications. If the licensee has an analysis in a retrievable and DG-1170, Page 64
 
auditable format that demonstrates compliance with the applicable NRC-approved document(s),          l the change is acceptable, provided that the change meets current regulations (e.g., 10 CFR 50.48,    l Appendix R to 10 CFR Part 50, where applicable, and GDC 3), and is consistent with the              l defense-in-depth philosophy for fire protection. (See Section II.A of Appendix R to 10 CFR Part      l 50.) The NRC would not require an assessment of the risk impact of the change to demonstrate        l compliance with Regulatory Position 1 of Regulatory Guide 1.174 for additional information.          l 1.8.1.3 Exemption/Deviation vs.                                                            l l
The NRC would find the substitution of repairs in lieu of installed fire protection systems l and features for systems and components required to achieve and maintain cold shutdown              l acceptable so long as the time to repair the cold shutdown capability did not exceed the limits      l prescribed in Appendix R to 10 CFR Part 50. An assessment of the risk impact may or may not          l be necessary for satisfying the provisions under item (b), above, depending upon the nature of the  l change and the analysis used to justify the change. Regulatory Position 5 of this guide provides    l additional guidance with respect to acceptable operator manual actions.                              l l
The licensee is responsible for demonstrating that the change has not resulted in an        l adverse effect on safe shutdown or noncompliance with the applicable NRC requirements. An            l appropriate analysis is required to demonstrate that the change is acceptable. The licensees        l failure to conduct the appropriate analysis is a failure to meet the plants fire protection license l condition. The depth and scope of the analysis depends upon the nature of the change and the        l type of analytical tool relied upon to justify the subject change. A change that does not maintain  l a sufficient margin of safety fails to meet the plants license condition.                          l l
FPP changes that adversely affect the ability to achieve and maintain safe shutdown in the  l event of a fire and are not in compliance with regulatory requirements need prior approval by the    l NRC. Changes submitted to the NRC for review and approval should include a technical                l justification for the proposed alternative approach.                                                l l
1.8.1.3 Exemptions, License Amendments, and the Standard License Condition                          l l
If a proposed change alters compliance with a rule then an exemption from the rule is      l required in accordance with 10 CFR 50.12. If a proposed change involves a change toalters a          l license condition or technical specification that was used to satisfy NRC requirements, the          l licensee should submit a license amendment request should be submitted. When a change that          l falls within the scope of the changes allowed under the standard fire protection license condition is planned, the licensees evaluation isshould be made in conformance with the standard fire        l protection license condition to determine whether the change would adversely affect the ability to achieve and maintain safe shutdown. The assessment should include the effect on the fire hazards analysis and the consideration ofshould consider whether circuits or components,            l including associated circuits, for a success path of equipment needed for safe shutdown are being affected or a new element introduced in the area. If thise evaluation concludes that there is no    l adverse affect, the licensee should document this conclusion and its basis should be documented      l and bemake it available for future inspection and reference. If the evaluation finds that there is  l an adverse affect, or that it is outside the basis for an exemption (or deviation) that was granted DG-1170, Page 65
 
(or approved) for the area involved, the licensee should make modifications to achieve conformance, justify and request an exemption, or seek a license amendment from the NRC.
l        1.8.1.4          Nonconforming Conditions.
l l        In addition to an evaluation of planned changes, a safetyan evaluation may also be required for nonconforming conditions.
l        In the case of a degraded or nonconforming condition, a safetyan evaluation is l dependentdepends on the licensees compensatory and corrective actions taken by the licensee.
l There are threeThree potential conditions exist for determining the need for performance of a l safetyan evaluation. These conditions are (1) the use of interim compensatory actions, or(2) l corrective actions that result in a change, or (3) corrective actions that restore the nonconforming or degraded condition to the previous condition.
l        If the licensee takes an interim compensatory action is taken to address the condition that l falls within the scope of the standard fire protection license condition, it should conduct a review l should be conducted andwhich may result in a safety evaluation. The intent of the review is to determine whether the compensatory action itself (not the degraded condition) impacts other aspects of the facility described in the FSAR.
In its evaluation of the impact of a degraded or nonconforming condition on plant operation and on operability of structures, systems, and components, a licensee may decide to implement a compensatory measure as an interim step to restore operability or to otherwise enhance the capability of structures, systems, and components until the final corrective action is complete. Reliance on a compensatory measure for operability should be an important consideration in establishing the "reasonable time frame" to complete the corrective action process. In accordance with GL 91-18, NRC would normally expect that conditions that require interim compensatory measures to demonstrate operability would be resolved more promptly than conditions that are not dependent on compensatory measures to show operability, because such reliance suggests a greater degree of degradation. Similarly, if an operability determination is based upon operator action, NRC would expect the nonconforming condition to be resolved expeditiously.
l        If the condition is accepted "as-isas-is," resulting in something different from that l described in the FSAR, or is modified to something differentthat differs from that described in the FSAR, the condition should be considered a change and subjected to a safety evaluation.
DG-1170, Page 66
 
1.8.1.5        Reporting Guidelines.                                                      l l
The licensee should maintain records of fire protection program-relatedFPP-related          l changes in the facility, of changes in procedures, and of tests and experiments made in accordance with the standard fire protection license condition. These records should include a written evaluation that provides the bases for the determination that the change does not adversely affect safe -shutdown capability.                                                          l The licensee should maintain, in auditable form, a current record of all such changes and  l should make such records available to NRC inspectors upon request. All changes to the                l approved program should be reported along with the FSAR revisions required by 10 CFR                l 50.71(e).                                                                                            l l
In accordance with 10 CFR 50.48, the licensee must maintain records of all changes in      l the facility must be maintained until the termination of the license. Records of superseded procedures must be maintained for a period of 3 years from the date the record was superseded.
The guidance in Regulatory Position 1.8.1 is based on 10 CFR 50.48, GL 86-10, and GL 91-18.
1.8.2          Exemptions to Appendix R ofto 10 CFR Part 50                                l l
For plants licensed prior tobefore January 1, 1979, the NRC requires requests for          l exemption requests from the requirements of Appendix R are required for modifications or            l conditions that do not comply with the applicable sections of Appendix R. The exclusion of the applicability of sections of Appendix R other than Sections III.G, III.J, and III.O (and Section    l III.L as applicable), 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 PositionBTP APCSB 9.5-1                  l reflected in staff fire protection safety evaluation reportsSERs issued prior tobefore the effective l date of the rule. For these previously approved features, an exemption request is not required except for proposed modifications that would alter previously approved features used to satisfy NRC requirements.
Plant-specific conditions may preclude compliance with one or more of the provisions specified in Appendix R. In such a case, the licensee should demonstrate, by means of a detailed fire hazards analysis, that the existing protection, or that the existing protection in conjunction with proposed modifications, will provide a level of safety equivalent to the technical requirements of Appendix R.
When the fire hazards analysis (see Regulatory Position 1.2 of this guide) shows that adequate fire safety can be provided by an alternative approach can provide adequate fire safety    l (i.e., an approach different from the specified requirement such as the use of a 1-hour fire -rated  l barrier where a 3-hour barrier is specified), licensees that are required to meet Appendix R may request NRC approval of an exemption from the technical requirements of Appendix R. Any exemption request should include a sound technical basis that clearly demonstratesdemonstrating      l that the fire protection defense-in-depth philosophy is appropriately maintained and that the DG-1170, Page 67
 
exemption is technically justified. As part of its evaluation, the licensee should provide sound technical justification if it does not propose to install or improve the automatic suppression l and/or detection capabilities in the area of concern, and/or if it does not intend to implement other more restrictive fire prevention, detection, or suppression measures.
l        Generally, the staff will accept an alternative fire protection configuration on the basis of l a detailed fire hazards analysis if the following conditions are met:
l a.      The alternative configuration ensures that one success path of equipment necessary to l        achieve hot shutdown from either the control room or emergency control stations is free l        of fire damage.
l l Text Moved Here: 6 l b.      The alternative configuration ensures that fire damage to equipment necessary to achieve l        cold shutdown is limited so that itand can be repaired within a reasonable time (minor l        repair using components stored on the site); and.
l End Of Moved Text l c.      Fire-retardant coatings are not used as fire barriers.
l d.      Modifications required to meet Appendix R requirements would not enhance fire l        protection safety levels above that provided by either existing or proposed alternatives.
l l        The staff will also accept an alternative fire protection configuration on the basis of a detailed fire hazards analysis if:
: a.      The alternative ensures that one success path of equipment necessary to achieve hot shutdown from either the control room or emergency control stations is free of fire damage; and Text Was Moved From Here: 6
: c.      Fire-retardant coatings are not used as fire barriers; and
: d.      Modification required to meet Appendix R would not enhance fire protection safety levels above that provided by either existing or proposed alternatives.
The staff will also accept an alternative fire protection configuration on the basis of a detailed fire hazards analysis when the licensee can demonstrate that modifications required to l meet the requirements of Appendix R would be detrimental to overall facility safety, the l alternative configuration satisfies the four aforementionedabove criteria, and the alternative configuration provides an adequate level of fire safety.
l        EThe licensee should file requests for exemptions to the requirements of 10 CFR 50.48 l and Appendix R are to be filed10 CFR Part 50 in accordance with 10 CFR 50.12.
DG-1170, Page 68
 
The guidance in Regulatory Position 1.8.2 is based on GL 86-10.
1.8.3          Appendix R Equivalency Evaluations                                        l l
The NRC interpretations of certain Appendix R requirements allow a licensee to choose      l not to seek prior NRC review and approval of, for example, a fire area boundary, in which case an evaluation should be performed by a fire protection engineer (assisted by others as needed) andshould perform an evaluation which should be retained for a future NRC audit. EThe              l licensee should ensure that such evaluations of this type should beare written and organized to    l facilitate review by a person not involved in the evaluation. All calculations supporting tThe      l evaluation should be availableinclude all supporting calculations and clearly state all assumptions l clearly stated at the outset. The licensee should retain these evaluations should be retained for  l subsequent NRC audits. Appendix A to this guide provides examples.
The guidance in Regulatory Position 1.8.3 is based on GL 86-10.
1.8.4  Deviations of previously accepted equivalency evaluations.                        l l
1.8.4    License Amendments                                                                        l l
Plants licensed after January 1, 1979, that have committed to meet the requirements of Sections III.G, III.J, and III.O of Appendix R to 10 CFR Part 50 or other NRC guidance (e.g.,      l CMEB 9.5-1), and are required to do so as a license condition, do not need to request exemptions for alternative configurations. However, the FSAR or fire hazards analysis should identify and      l justify deviations from the requirements of Sections III.G, III.J, and III.O or other applicable    l requirements or guidance should be identified and justified in the FSAR or FHA, and these          l deviations may require a license amendment to change the license condition. Deviations              l submitted to the NRC for review and approvalLicensees should include a technical justification      l for the proposed alternative approach in any license amendment it submits to the NRC for review    l and approval. The technical justification should address the criteria described in Regulatory      l Positions 1.8.1, S for safety Eevaluations, and 1.8.2 for exemptions.                              l The guidance in Regulatory Position 1.8.4 is based on GL 86-10.
1.8.5                                                                                      l l
1.8.5    Operability Assessments                                                                    l l
Structures, systems, and componentsThe licensee must subject SSCs that are relied upon    l in the licensees fire protection plan requiredFPP under 10 CFR 50.48 are to be subjected to        l operability assessments and prompt corrective action when inoperable, degraded, or nonconforming conditions are identified. The process of ensuring operability is continuous and consists of the verification of operability by surveillance activities and formal determinations of operability whenever a verification or other indication calls into question the ability of a structure, system, or componentn SSC to perform its specified function. Prompt action should be    l taken by the licensee any time a structure, system, or componentThe licensee should take prompt    l DG-1170, Page 69
 
l action any time an SSC important to safety is found to be inoperable. If an immediate threat to public health and safety is identified, action to place the plant in a safe condition should begin as soon as possible.
l          A structure, system, or componentn SSC is considered operable when it can perform its l intended function (e.g., a fire pump that is rated for 2500 GPMgpm at 120 psi is capable of meeting or exceeding that flow and pressure). The definition of operability includes the principle that a system can perform its specified safety functions only when all its necessary support systems are capable of performing their related support functions (e.g., an automatic fire suppression system is operable only if the detection system that is used to actuate the fire suppression system is also operable). If a necessary support system is inoperable, the l corresponding structure, system, or componentSSC should also be declared inoperable. The operability determination may be based on analysis, testing, operating experience, engineering judgment, or a combination of these methods. In the absence of a reasonable expectation that a l structure, system, or componentn SSC is operable, the structure, system, or componentSSC should be declared inoperable.
l          Full qualification of a required structure, system, or componentSSC is defined as conforming to all aspects of the current licensing basis, including the applicable codes and standards (e.g., NFPA), design criteria, and commitments (e.g., Branch Technical Positions).
l The fact that a structure, system, or componentn SSC is not fully qualified may render the l structure, system, or componentSSC degraded or nonconforming, but does not in all cases render l that structure, system, or componente SSC unable to perform its specified function. A degraded l condition exists when there has been ana loss of quality or functional capability of a structure, l system or componentn SSC (e.g., a fire test has determined that a fire barrier that was credited l with a fire -resistance rating of 3 hours has been determined by a fire test toonly provides a fire -
l resistance rating of only two2 hours) has occurred. A nonconforming condition exists when there is a failure to meet requirements or licensee commitments (e.g., missing the performance of l the weekly fire pump test as required by NFPA 20, Standard for the Installation of Centrifugal l Fire Pumps). If a structure, system, or componentn SSC important to safety is degraded or nonconforming but operable, the licensee should establish an acceptable basis for its continued operability. The licensee should promptly identify and correct the condition that resulted in the degraded or nonconforming condition.
l          Automatic actuation of structures, systems, or componentsa system is frequently provided as a design feature for mitigating fire events (e.g., automatic suppression systems). When the licensee is considering the substitution of a manual action for an automatic actuation, the l licenseesits determination of operability should consider the differences in the performance between the automatic and manual action and the ability of the manual action to accomplish the l specified function. The licensee should have written procedures in place and conduct training l prior tobefore the substitution of any manual action for the loss of an automatic feature.
l          CThe licensee may use compensatory measures may be used as an interim step to restore l operability or to enhance the capability of structures, systems, or componentsSSCs that are DG-1170, Page 70
 
degraded or nonconforming until the final corrective action is completed. Reliance on compensatory measures should be considered in establishing thea reasonable time                      l frametimeframe to complete the corrective action process. Generally, conditions that require          l compensatory measures to restore or enhance operability should be resolved more promptly than conditions that are not dependent upon compensatory measures. The compensatory measures selected should be appropriate to the adverse condition identified (e.g., use of mobile fire apparatuses to compensate for a fire pump that is degraded). (See Regulatory Position 1.5 for        l additional guidance regarding compensatory actions.
The guidance in Regulatory Position 1.8.5 is based on GL 91-18 and IM STS-10.
1.8.6  )                                                                                    l l
1.8.6    10 CFR 50.72 Notification and 10 CFR 50.73 Reporting                                        l The requirements of 10 CFR 50.72 and 10 CFR 50.73 have applicabilityapply to                l reporting certain events and conditions related to fire protection at nuclear power plants.
FLicensees should report fire events or fire protection deficiencies that meet the criteria of 10    l CFR 50.72 and 10 CFR 50.73 should be reported to the NRC as appropriate, and in accordance            l with the requirements of these regulations. Guidance for meeting the requirements of 10 CFR 50.72 and 50.73 is provided in NUREG-1022, Event Reporting Guidelines: 10 CFR 50.72 and              l 50.73, which was prepared by the NRC staff to clarifyRevision 1, issued January 1998 provides        l guidance for meeting the requirements of these two sections. The NRC staff prepared NUREG-            l 1022 to clarify the implementation of the 10 CFR 50.72 and 10 CFR 50.73 rules and consolidate        l important NRC reporting guidelines into one reference document. The document is structured to        l assist licensees in achieving prompt and complete reporting of specified events and conditions.
AThe Statements of Consideration for the rules include additional reporting guidance for    l 10 CFR 50.72 and 50.73 was contained in the Statements of Considerations for the rules.
The guidance in Regulatory Position 1.8.6 is based on 10 CFR 50.72, 10 CFR 50.73, and NUREG-1022.
1.8.7          NFPA Code and Standard Deviation Evaluations                                l l
For those fire protection structures, systems, and componentsSSCs installed to satisfy the  l NRC requirements and designed to NFPA codes and standards, the code of record is the code            l edition in force at the time of the design and installation is the code of record to which the design is evaluated. Deviationsor at the time the commitment is made to the NRC for a fire protection        l feature. The FSAR or the fire hazards analysis should identify and justify deviations from the        l codes should be identified and justified in the FSAR or FHA. Deviations should not degrade the performance of fire protection systems or features. The codestandards of record is determined by      l the licenseerelated to the design and installation of fire protection systems and features required  l to satisfy NRC requirements in all new reactor designs are those NFPA codes and standards in          l effect 180 days prior to the submittal of the application under 10 CFR Part 50 or 10 CFR Part 52. l DG-1170, Page 71
 
A licensee may apply the equivalency concept in meeting the provisions of the NFPA codes and standards. Nothing in the NFPA codes or standards is intended to prevent the use of methods, systems, or devices of equivalent or superior quality, strength, fire resistance, effectiveness, durability, and safety as alternatives to those prescribed by the codes or standards, provided technical documentation demonstrates equivalency and the method, system, or device is listed or approved for the intended purpose.
l        An exemption is not required for deviation from NFPA codes. The NRC guidelines l reference certain NFPA codes as providing guidance acceptable to the staff, and; therefore, such l codes may be accorded the same status as regulatory guides. More recent editions of the NFPA l codes require submittal of technical documentation to the authority having jurisdiction (AHJ) l to demonstrate equivalency of an alternative system, method or device for AHJ approval.
l Whether or not the code of record includes this requirement, the NRC does not require review l and approval of equivalency evaluations. However, the licensee should document these l evaluations and make them available for NRC review.
l        When the applicant/licensee states that its design "meetsmeets the NFPA code(s)" or l "meetsmeets the intent of the NFPA code(s)" and does not identify any deviations from such codes, the NRC expects that the design conforms to the codes and the design is subject to l inspection against the NFPA codescode of record.
l        The Authority Having Jurisdiction AHJ (as described in NFPA documents) refers to the l Director, of the NRCs Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory l Commission (or Director of the Office of New Reactors, for new reactors), or designee, consistent with the authority specified in 10 CFR 1.43.
The guidance in Regulatory Position 1.8.7 is based on GL 86-10.
: 2.      FIRE PREVENTION l        Administrative, Office of Nuclear Reactor Regulation.
l l 1.8.8  Fire Modeling l
l        Where the evaluation of an FPP change is based on fire modeling, licensees should l document that the fire models and methods used meet the NRC requirements. The licensee l should also document that the models and methods used in the analyses were used within their l limitations and with the rigor required by the nature and scope of the analyses. These analyses l may use simple hand calculations or more complex computer models, depending on the specific l conditions of the scenario being evaluated. Appendix C to NFPA 805 and Appendix D to NEI l 04-02, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection l Program Under 10 CFR 50.48(c), contain discussions that are useful in determining which fire l models to use and applying those fire models within their limitations. However, the NRC only l endorses the fire models, methodologies, data, and examples in these appendices to the extent l that they have been or can be adequately verified and validated or to the extent they are l appropriate for the specific application.
DG-1170, Page 72
 
The NRCs Office of Nuclear Regulatory Research (RES) and EPRI have documented the            l verification and validation (V&V) process for parts of five fire models in draft NUREG-                l 1824/EPRI 1011999, Verification and Validation of Selected Fire Models for Nuclear Power              l Plant Applications. The specific fire models documented are (1) NUREG-1805, Fire                    l Dynamics Tools (FDTs); (2) Fire-Induced Vulnerability Evaluation (FIVE), Revision 1; (3) the          l National Institute of Standards and Technology (NIST) Consolidated Model of Fire Growth and            l Smoke Transport (CFAST); (4) the Electricit&#xe9; de France (EdF) MAGIC code; and (5) the NIST              l Fire Dynamics Simulator (FDS).                                                                        l l
Licensees may propose the use of fire models that have not specifically undergone V&V          l by the NRC; however, licensees are responsible for providing evidence of acceptable V&V of            l these fire models. The V&V documents for licensee-proposed fire models are subject to NRC              l review and approval.                                                                                  l l
: 2.      Fire Prevention                                                                                l l
Fire prevention is the first line of defense-in-depth for fire protection. The fire prevention l attributes of the program are directly related to the fire protection objective to minimize the        l potential for fire to occur. These attributes involve design and administrative measures that          l provide a reasonable level of assurance that fire hazards are adequately protected and managed        l and that fire consequences will be limited for those fires that do occur.                              l l
The licensee should establish administrative controls and procedures should be                l established to minimize fire hazards in areas containing structures, systems, and componentsSSCs important to safety. Normal and abnormal conditions or other anticipated                l operations such as modifications (e.g., breaching fire barriers or fire stops, impairment of fire detection and suppression systems) and transient fire hazard conditions, such as those associated      l with maintenance activities, should be reviewed by appropriate levels of management, and. The          l licensee should implement appropriate compensatory measures such as fire watches or temporary          l fire barriers should be implemented to ensure adequate fire protection and reactor safety.
For plants that have permanently ceased operations and are in the process of                  l decommissioning, the fire hazards are constantly changing and fire protection systems and              l features are being dismantled. Fire prevention attributes of the program are key to minimizing        l the potential for fire and subsequent release of radioactive materials under these dynamic            l conditions.                                                                                            l l
The following sections provide guidance relative to fire prevention measures, including        l control of combustibles and ignition sources, and housekeeping inspections. ORegulatory                l Position 1.1 discusses organizational responsibilities for implementation of fire prevention          l measures are discussed in Regulatory Position 1.1. Portions of NFPA 1, "Uniform Fire                  l Prevention Code," including Chapters 3-8, 28, and 34, contain additional guidance that may be        l used in the development and implementation of fire prevention measures.
2.1    Control of Combustibles                                                                        l DG-1170, Page 73
 
Fire prevention administrative controls should include procedures to control handling and l use of combustibles, prohibit storage of combustibles in plant areas important to safety or, establish designated storage areas with appropriate fire protection, and control use of specific combustibles (e.g., wood) in plant areas important to safety.
l l        2.1.1  Transient Fire Hazards l
l        Bulk storage of combustible materials should be prohibited inside or adjacent to buildings or systems important to safety during all modes of plant operation. Procedures should govern the handling of and limit transient fire hazards such as combustible and flammable liquids, wood and l plastic products, high-efficiency particulate air (HEPA) and charcoal filters, dry ion exchange resins, or other combustible materials in buildings containing systems or equipment important to l safety during all phases of operation, and especiallyparticularly during maintenance, modification, or refueling operations.
Transient fire hazards that cannot be eliminated should be controlled and suitable l protection should be provided. Specific controls and protective measures include the following:
: a.      Unused ion exchange resins should not be stored in areas that contain or expose equipment important to safety.
l
: b.      Hazardous chemicals should not be stored in areas that contain or expose equipment important to safety.
l
: c.      Use of wood inside buildings containing systems or equipment important to safety should be permitted only when suitable noncombustible substitutes are not available. All wood l        smaller than 152 mmmillimeters (mm) x 152 mm ([6 inch (in.) x 6 inch).] used in plant areas important to safety during maintenance, modification, or refueling operation (such l        as lay-down blocks or scaffolding) should be treated with a flame retardant. (For l        guidance, see NFPA 703, "StandardStandard for Fire -Retardant ImpregnatedTreated l        Wood and Fire -Retardant Coatings for Building Materials," for guidance.). Wood should be allowed into plant areas important to safety only when it is to be used immediately.
l C l d.      The use of plastic materials should be minimized. Halogenated plastics such as polyvinyl chloride (PVC) and neoprene should be used only when substitute noncombustible materials are not available. All plastic materials, including flame and fire retardant DG-1170, Page 74
 
materials, will burn with an intensity and BTU production in a range similar to that of ordinary hydrocarbons. When burning, they produce heavy smoke that obscures visibility and can plug air filters, especially charcoal and HEPA filters. The hHalogenated plastics l also release free chlorine and hydrogen chloride when burning, which are toxic to humans and corrosive to equipment. NFPA 701, "StandardStandard Methods of Fire Tests for        l Flame-ResistantFlame Propagation of Textiles and Films," provides guidance on fire      l testing of flame -resistant plastic films (e.g., plastic sheeting, tarpaulins).          l l
: e. Use of combustible material such as HEPA and charcoal filters, dry ion exchange resins, or other combustible supplies in areas important to safety should be controlled. Such materials should be allowed into areas important to safety only when they are to be used immediately.
l
: f. Equipment or supplies (such as new fuel) shipped in untreated combustible packing containers may be unpacked in areas containing equipment or systems important to safety if required for valid operating reasons. However, all combustible materials should be    l removed from the area immediately following unpacking. Such transient combustible        l material, unless stored in approved containers, should not be left unattended. Loose combustible packing material, such as wood or paper excelsior or polyethylene sheeting, should be placed in metal containers with tight-fitting, self-closing metal covers.      l C                                                                                            l
: g. Materials that collect and contain radioactivity, such as spent ion exchange resins,      l charcoal filters, and HEPA filters, should be stored in closed metal tanks or containers  l that are located in areas free from ignition sources or combustibles. These materials should be protected from exposure to fires in adjacent areas as well. Consideration should be given to requirements for removal of decay heat from entrained radioactive materials.
2.1.2  Modifications The                                                                                      l
: h. Temporary power cables used during maintenance outages are transient combustibles and    l potential ignition sources. Procedures should adequately address fire protection for      l temporary electrical power supply and distribution.                                      l l
DG-1170, Page 75
 
l 2.1.2  Modifications l
l        Fire prevention elements of the FPP should be maintained when plant modifications are l made. The modification procedures should contain provisions that evaluate the impacts of l modifications on the fire prevention design features and programs. The licensee should follow l the guidelines of Regulatory Position 4.1.1 should be followed in the design of plant modifications. Modifications of structures, systems, and components should be reviewed by l pPersonnel in the fire protection organization should review modifications of SSCs to ensure that fixed fire loadings are not increased beyond those accounted for in the fire hazards analysis, or if increased, suitable protection is provided and the fire hazards analysis is revised accordingly.
l        2.1.3 Flammable and Combustible Liquids and Gases l
l        Flammable and combustible liquids and gases are potentially significant fire hazards and l procedures should clearly define the use, handling, and storage of these hazards. The handling, use, and storage of flammable and combustible liquids should, as a minimum, comply with the l provisions of NFPA 30, "FlammableFlammable and Combustible Liquids Code."
Miscellaneous storage and piping for flammable or combustible liquids or gases should not create a potential fire exposure hazard to systems important to safety.
Systems important to safety should be isolated or separated from combustible materials.
When this is not possible because of the nature of the safety system or the combustible material, special protection should be provided to prevent a fire from defeating the safety system function.
Such protection may involve a combination of automatic fire suppression and construction capable of withstanding and containing a fire that consumes all combustibles present. Examples of such combustible materials that may not be separable from the remainder of its system are l emergency diesel generatorEDG fuel oil day tanks, turbine-generator oil and hydraulic control l fluid systems, and reactor coolant pumpRCP lube oil systems.
Diesel fuel oil tanks should meet the guidelines of Regulatory Positions 6.1.8 and 7.4 of l this guide.. Turbine-generator lube oil and hydraulic systems should meet the guidelines in l Regulatory Position 7.2. Reactor coolant pumpRegulatory Position 7.1 provides guidelines for l RCP oil collection system guidelines are provided in Regulatory Position 7.1systems.
Bulk gas storage and use should meet the guidelines of Regulatory Position 7.5 of this guide.
l        2.1.4  External/Exposure Fire Hazards l
l        When a structure, system or componentn SSC important to safety is near installations, l such as flammable liquid or gas storage, the licensee should evaluate the risk of exposure fires l (originating in such installations) to the structures, systems,SSCs and components should be l evaluated andtake appropriate protective measures taken. NFPA 80A, l "RecommendedRecommended Practice for Protection of Buildings from Exterior Fire l Exposures," provides guidance on such exposure protection. NFPA 30 provides guidance DG-1170, Page 76
 
relative to minimum separation distances from flammable and combustible liquid storage tanks.
NFPA 50A5, Standard for Gaseous Hydrogen Systems at Consumer Sites, and NFPA 50B,                  l Standard for Liquefied Hydrogen Systems at Consumer Sites, providethe Storage, Use, and            l Handling of Compressed Gases and Cryogenic Fluids in Portable and Stationary Containers,            l Cylinders, and Tanks, provides separation distances for gaseous and liquefied hydrogen,            l respectively. (sSee Regulatory Position 7.5 of this guide.). NFPA 58, Liquefied Petroleum Gas      l Code, provides guidance for liquefied petroleum gas.
Miscellaneous areas, such as shops, warehouses, auxiliary boiler rooms, fuel oil tanks,      l radwaste buildings, and flammable and combustible liquid storage tanks, should be located and        l protected such that a fire or the effects of a fire, including smoke, will not adversely affect any  l systems or equipmentSSCs important to safety. (See the previous section for guidelines              l relativerelated to location oflocating diesel fuel oil tanks and compressed gas supplies external to l structures important to safety.)                                                                    l In geographic areas where there is a potential for damage from wildfires (i.e., forest, brush, vegetation), the licensee should evaluate the risk potential from wildfire should be          l evaluated for structures that contain systems or componentsSSCs important to safety, and take        l appropriate measures should be taken. NFPA 2991144, Standard for Protection of Life and            l Property from Wildfire, provides guidance on assessing wildfire severity and appropriate protection measures.
The guidance in Regulatory Position 2.1 is based on Appendix R to 10 CFR Part 50 and CMEB 9.5-1.
2.2    Control of Ignition Sources                                                                  l Fire protection administrative controls should establish procedures to govern use of        l l
Electrical equipment (permanent and temporary), hot work activities (e.g., open flame,      l welding, cutting and grinding), high-temperature equipment and surfaces, heating equipment          l (permanent and temporary installation), reactive chemicals, static electricity, and smoking are all  l potential ignition sources. Design, installation, modification, maintenance, and operational        l procedures and practices should control potential ignition sources.                                  l l
Engineering design practices should provide assurance that electrical equipment is          l properly designed and installed in accordance with industry standards, heat generating equipment    l or equipment with hot surfaces is properly cooled or separated from combustible materials, and      l systems containing flammable and combustible liquids or gases are properly designed and              l located to minimize the exposure of these materials to ignition sources.                            l l
Regulatory Position 3.5 of Regulatory Guide 1.191 contains similar guidelines for those      l plants that have permanently ceased operation.                                                      l l
2.2.1  Open Flame, Welding, Cutting, and Grinding (Hot Work)                                l DG-1170, Page 77
 
l l        Work involving ignition sources such as welding and flame cutting should be done under closely controlled conditions. Persons performing and directly assisting in such work should be trained and equipped to prevent and combat fires. If this is not possible, a person qualified in fire protection should directly monitor the work and function as a fire watch.
The use of ignition sources should be governed by use of a hot work permit system to control open flame, welding, cutting, brazing, or soldering operations. A separate permit should be issued for each area where work is to be done. If work continues over more than one shift, the permit should be valid for not more than 24 hours when the plant is operating or for the duration l of a particular job during plant shutdown. NFPA-51BNFPA 51B, "StandardStandard for Fire l Prevention in Use ofDuring Welding, Cutting and Welding ProcessesOther Hot Work," includes guidance for safeguarding the hazards associated with welding and cutting operations.
l        2.2.2    Temporary Electrical Installations l
l        The use of temporary services at power reactor facilities is routine, especially into support of maintenance and other activities during outages. In view of the magnitude and complexity of some temporary services, proper engineering and, once installed, maintenance of the design basis become significant. Plant administrative controls should provide for engineering review of temporary installations. These reviews should ensure that appropriate precautions, limitations, and maintenance practices are established for the term of such installations. The Institute of l Electrical and Electronics Engineers (IEEE) Standard 835, "StandardStandard Power Cable l Ampacity Tables," ANSI/IEEE C.2, National Electrical Safety Code,  and NFPA 70, l "NationalNational Electrical Code," provide guidance on temporary electrical installations, including derating of closely spaced cables.
l        2.2.3 Other Sources l
l        Leak testing and similar procedures such as airflow determination should not use one of l the commercially available techniques. Openopen flames or combustion-generated smoke should not be permitted.
l        .
l l        Procedures and practices should provide for control of temporary heating devices. Use of l space heaters and maintenance equipment (e.g., tar kettles for roofing operations) in plant areas l should be strictly controlled and reviewed by the plants fire protection staff. Engineering l procedures and practices should provide assurance that temporary heating devices are properly l installed according to the listing, including required separations from combustible materials and l surfaces. Temporary heating devices should be placed so as to avoid overturning and installed in accordance with their listing, including clearance to combustible material, equipment, or construction. Asphalt and tar kettles should be located in a safe place or on a fire-resistive roof at a point where they avoid ignition of combustible material below. Continuous supervision should be maintained while kettles are in operation and metal kettle covers and fire extinguishers should be provided.
DG-1170, Page 78
 
The guidance in Regulatory Position 2.2 is based on ASB 9.5-1, CMEB 9.5-1, IN 91-17, and IP 64704.
2.3    Housekeeping                                                                              l AThe licensee should establish administrative controls should be established to minimize  l fire hazards in areas containing structures, systems, and componentsSSCs important to safety. l These controls should establish procedures to govern removal of waste, debris, scrap, oil spills, and other combustibles after completion of a work activity or at the end of the shift.            l Administrative controls should also include procedures for performing and to maintain            l housekeeping inspections. Periodic maintaining periodic housekeeping inspections should be        l performed to ensure continued compliance with fire protection administrative controlscontrols. l Housekeeping practices should ensure that drainage systems, especially drain hub grills, in areas l containing fixed water-based suppression systems remain free of debris to minimize flooding if    l the systems discharge. Regulatory Guide 1.39, Housekeeping Requirements for Water-Cooled        l Nuclear Power Plants, Revision 2, issued September 1977, provides guidance on housekeeping,      l including the disposal of combustible materials.
The guidance in Regulatory Position 2.3 is based on Appendix R to 10 CFR Part 50, CMEB 9.5-1, and Regulatory Guide 1.39.
2.4    Fire Protection System Maintenance and Impairments                                        l FThe licensee should establish fire protection administrative controls should be          l established to address the following:
: a.      Fire protection features should be maintained and tested by qualified personnel. (see    l Regulatory PositionSee Regulatory Position 1.6.1.c of this guide.).                      l
: b.      Impairments to fire barriers, fire detection, and fire suppression systems should be controlled by a permit system. Compensatory measures (see Regulatory Position 1.5 of      l this guide) should be established in areas where systems are so disarmed.                l DG-1170, Page 79
: c.      Successful fire protection requires inspection, testing, and maintenance of the fire protection equipment. A test plan that lists the individuals and their responsibilities in connection with routine tests and inspections of the fire protection systems should be l        developed. The test plan should contain the types, frequency, and detailed procedures for testing. Frequency of testing should be based on the code of record for the applicable fire protection system. Procedures should also contain instructions on maintaining fire protection during those periods when the fire protection system is impaired or during l        periods of plant maintenance, (e.g., fire watches).
: d.      Fire barriers, including dampers, doors, and penetration seals, should be routinely inspected. Penetration seals may be inspected on a frequency and relative sample basis that provides assurance that the seals are functional. Sample size and inspection frequency should be determined by the total number of penetrations and observed failure rates. Inspection frequency should ensure that all seals will be inspected every 10 years.
The guidance in Regulatory Position 2.4 is based on Appendix R to 10 CFR Part 50 and CMEB 9.5-1.
: 3.      FIRE DETECTION AND SUPPRESSION l 3.13. Fire Detection (Design Objectives and Performance Criteria) l        Fireand Suppression l
l 3.1    Fire Detection l
l        In general, the fire hazards analysis and regulatory requirements determine the scope of l fire detection and suppression in the plant, whereas the applicable industry codes and standards l (generally NFPA codes, standards, and recommended practices) determine the design, l installation, and testing requirements of the systems and components. The design of fire detection systems should be designed to minimize the adverse effects of fires on structures, l systems, and componentsSSCs important to safety. Automatic fire detection systems should be installed in all areas of the plant that contain or present an exposure fire hazard to structures, l systems, and componentsSSCs important to safety. These fire detection systems should be capable of operating with or without offsite power.
l        With regard to protection of safe -shutdown systems, Regulatory Positions 5.5.b and 5.5.c l of this guide state that "In, In addition, fire detectors and an automatic fire suppression system l should be installed in the fire area." See Regulatory Position 1.8.3 and the information in l Appendix A for guidance relative toWhere automatic fire detection is installed, it should provide l complete protection throughout the fire area. For those areas where less than full-area coverage is provided.
DG-1170, Page 80
 
3.1.1 only partial coverage is installed, the fire hazards analysis should demonstrate the l adequacy of the design to provide the necessary protection.                                        l l
3.1.1  Fire Detection and Alarm Design Objectives and Performance Criteria                        l l
The fire detection and alarm system should be designed with the following objectives.      l
:                                                                                                  l
: a.      Detection systems are to be provided for all areas that contain or present a fire exposure to equipment important to safety.
: b.      Fire detection and alarm systems should comply with the requirements of Class A            l systems as defined in NFPA 72, "NationalNational Fire Alarm Code," and Class I          l circuits as defined in NFPA 70.
: c.      Fire detectors are selected and installed in accordance with NFPA 72. Pre-operational and periodic testing of pulsed -line-type heat detectors demonstrate that the frequencies  l used will not affect the actuation of protective relays in other plant systems.
: d.      Fire detection and alarm systems give audible and visible alarm and annunciation in the control room. Where zoned detection systems are used in a given fire area, local means are provided to identify which detector zone has actuated.
: e.      Fire alarms are distinctive and unique so they will not be confusedto avoid confusion with l any other plant system alarms.
: f.      Primary and secondary power supplies are provided for the fire detection system and for electrically operated control valves for automatic suppression systems. Such primary and secondary power supplies are toshould satisfy the provisions of NFPA 72. This can be      l accomplished by using normal offsite power as the primary supply with a 4-hour battery supply as a secondary supply and by providing the capability for manual connection to the  l Class 1E emergency power bus within 4 hours of loss of offsite power. Such connection should follow the applicable guidance in Regulatory Guides 1.6, 1.32, and 1.75.
Independence Between Redundant Standby (Onsite) Power Sources and Between Their                  l Distribution Systems, issued March 1971; 1.32, Criteria for Power Systems for Nuclear Power      l Plants, Revision 3, issued March 2004; and 1.75, Physical Independence of Electric Systems,    l Revision 3, issued February 2005.                                                                  l
: g.      In areas of high seismic activity, the need to design the fire detection and alarm systems to be functional following thea safe -shutdown earthquake should be considered.            l DG-1170, Page 81
: h.      The fire detection and alarm systems should retain their original design capability for (1) 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 l        storms, or small-intensity earthquakes that are characteristic of the geographic region, and (2) 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.
: i.      Redundant cable systems important to safety located in cable trays should be provided with fire detection. (Also see Regulatory Positions 4.1.3.3 and 6.1.3.)
l ji. Containment fire detection systems should be provided for non-inerted containments in l        accordance with the guidance in Regulatory Position 6.1.1.3 of this guide.
l kj. Control room fire detection and alarms should be provided in accordance with the l        guidance in Regulatory Position 6.1.2 of this guide.
l lk. The following areas that contain equipment important to safety should be provided with l        automatic fire detectors that alarm and annunciate in the control room: plant computer rooms, switchgear rooms, remote shutdown panels, battery rooms, diesel generator areas, l        pump rooms, new and spent fuel areas, and radwaste and decontamination areas. (ASee l        also see Regulatory Positions 6.1 and 6.2.)
The guidance in Regulatory Position 3.1 is based on GDC 3, Appendix R to 10 CFR Part 50, and CMEB 9.5-1.
l 3.2      of this guide.)
l l 3.2    Fire Protection Water Supply Systems (Design Objectives and Performance l        Criteria) l        3.2.1 Fire Protection Water Supply l
l        NFPA 22, "StandardStandard for Water Tanks for Private Fire Protection," and NFPA l 24, "StandardStandard for the Installation of Private Fire Service Mains and Their l Appurtenances," provide guidance for fire protection water supplies. The fire protection water supply system should meet the following criteria.
l a.      Two separate, reliable freshwater supplies should be providedavailable. Saltwater or brackish water should not be used unless all freshwater supplies have been exhausted.
DG-1170, Page 82
: b. The fire water supply should be calculated on the basis of the largest expected flow rate for a period of 2 hours, but not less than 1,136,000 liters (L) (300,000 gallons). This flow l rate should be based (conservatively) on 1900 liters per meter (L/m) (500 gpm) for          l manual hose streams plus the largest design demand of any sprinkler or deluge system as determined in accordance with NFPA 13, "StandardStandard for the Installation of            l Sprinkler Systems," or NFPA 15, "StandardStandard for Water Spray Fixed Systems            l for Fire Protection." The fire water supply should be capable of delivering this design demand over the longest piping route of the water supply system.
l
: c. If tanks are used for water supply, two 100%100-percent system capacity tanks [minimum of    l 1,136,000 L (300,000 gallons) each] should be installed. They should be so interconnected thatto allow pumps canto take suction from either or both. However, a        l failure in one tank or its piping should not cause both tanks to drain. Water supply capacity should be capable of refilling either tank in 8 hours or less.                      l
: d. Common water supply tanks are acceptable for fire and sanitary or service water storage. l When this is done, however, minimum fire water storage requirements should be dedicated by passive means, for example, use of a vertical standpipe for other water services. Administrative controls, including locks for tank outlet valves, are unacceptable  l as the only means to ensure minimum water volume.
: e. Freshwater lakes or ponds of sufficient size may qualify as the sole source of water for fire protection but require separate redundant suctions in one or more intake structures.
These supplies should be separated so that a failure of one supply will not result in a failure of the other supply.
: f. When a common water supply is permitted for fire protection and the ultimate heat sink, the following conditions should also be satisfied:                                          l
: i.      The additional fire protection water requirements are designed into the total storage capacity, and
.                                                                                              l ii.      Failure of the fire protection system should not degrade the function of the ultimate heat sink.
: g. Other water systems that may be used as one of the two fire water supplies should be permanently connected to the fire main system and should be capable of automatic alignment to the fire main system. Pumps, controls, and power supplies in these systems should satisfy the requirements for the main fire pumps. The use of other water systems DG-1170, Page 83
 
for fire protection should not be incompatible with their functions required for safe plant shutdown. Failure of the other system should not degrade the fire main system.
: h.      For multi-unit nuclear power plant sites with a common yard fire main loop, common water supplies may be utilized.
: i.      Fire water supplies should be filtered and treated as necessary to prevent or control biofouling or microbiologically induced corrosion of fire water systems. If the supply is raw service water, fire water piping runs should be periodically flushed and flow tested.
: j.      Provisions should be made to supply water to at least two standpipes and hose connections for manual firefighting in areas containing equipment required for safe plant l        shutdown in the event of a safe -shutdown earthquake. The piping system serving such l        hose stations should be analyzed for safe -shutdown earthquake loading and should be provided with supports to ensure system pressure integrity. The piping and valves for the l        portion of hose standpipe system affected by this functional requirement should, ast a l        minimum, satisfy ASME/ANSIASME 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 l        essential service water system. The cross -connection should be (a1) capable of providing flow to at least two hose stations [approximately 284 L/m (75 gpm) per hose station], and l        (b2) designed to the same standards as the seismic Category I water system; (i.e., it l        should not degrade the performance of the seismic Category I water system).
l        3.2.2    Fire Pumps l
l        Fire pump installations should conform to NFPA 20, "Standard for the Installation of Centrifugal Fire Pumps," and should meet the following criteria.
l :
: a.      If fire pumps are required to meet system pressure or flow requirements, a sufficient l        number of pumps is provided to ensure that 100%100-percent capacity will be available l        assuming failure of the largest pump or loss of offsite power (e.g., three 50%50-percent l        pumps or two 100%100-percent pumps). This can be accomplished, for example, by providing either electric motor-driven fire pumps and diesel-driven fire pumps or two or more seismic Category I Class 1E electric motor-driven fire pumps connected to l        redundant Class 1E emergency power buses. (sSee Regulatory Guides 1.6, 1.32, and 1.75.)
l Independence Between Redundant Standby (Onsite) Power Sources and Between Their l Distribution Systems, issued March 1971; 1.32, Criteria for Power Systems for Nuclear Power l Plants, Revision 3, issued March 2004; and 1.75, Physical Independence of Electric Systems, l Revision 3, issued February 2005.)
DG-1170, Page 84
: b. Individual fire pump connections to the yard fire main loop are separated with sectionalizing valves between connections. Each pump and its driver and controls are located in a room separated from the remaining fire pumps by a fire wall with a minimum rating of 3 hours.
: c. The fuel for the diesel fire pumps is separated so that it does not provide a fire source exposing equipment important to safety.
l
: d. Alarms or annunciators to indicate pump running, driver availability, failure to start, and l low fire-mainfire main pressure are provided in the control room.                          l l
3.2.3  Fire Mains                                                                                  l l
An underground yard fire main loop should be installed to furnish anticipated water        l requirements. NFPA 24 provides appropriate guidance for such installation. NFPA 24 references other design codes and standards developed by such organizations as the American National Standards Institute (ANSI) and the American Water Works Association (AWWA). The following specific criteria should be addressed:
: a. TypeThe type of pipe and water treatment are design considerations with tuberculation as    l one of the parameters.
: b. MThe means for inspecting and flushing the fire main are provided.                          l
: c. Sectional control valves should be visually indicating, (e.g., post--indicator valves). l
: d. Control and sectionalizing valves in fire mains and water-based fire suppression systems are electrically supervised or administratively controlled (e.g., locked valves with key control, tamper-proof seals). The electrical supervision signal indicates in the control    l room. All valves in the fire protection system are periodically checked to verify position. l (For guidance, see NFPA 25, "StandardStandard for the Inspection, Testing, and            l Maintenance of Water-Based Fire Protection Systems," for guidance.).                      l
: e. The fire main system piping is separate from service or sanitary water system piping, except as described in Regulatory Position 3.2.1 of this guide with regard to providing    l seismically designed water supply for standpipes and hose connections.
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: f. A common yard fire main loop may serve multi-unit nuclear power plant sites if cross-connected between units. Sectional control valves permit maintaining independence of the individual loop around each unit. For multiple-reactor sites with l        widely separated plants [approaching 1.6 kmkilometer (km) (1 mile (mi)) or more],
separate yard fire main loops are used.
: g. Sectional control valves are provided to isolate portions of the fire main for maintenance or repair without shutting off the supply to primary and backup fire suppression systems serving areas that contain or expose equipment important to safety.
: h. Valves are installed to permit isolation of outside hydrants from the fire main for maintenance or repair without interrupting the water supply to automatic or manual fire suppression systems in any area containing or presenting a fire hazard to equipment important to safety.
: i. Sprinkler systems and manual hose station standpipes have connections to the yard main system so that a single active failure or a line break cannot impair both the primary and backup fire suppression systems. Alternatively, headers fed from each end are permitted inside buildings to supply both sprinkler and standpipe systems, provided steel piping and l        fittings meeting the requirements of ASME/ANSIASME B31.1 are used for the headers l        up to and including the first valve supplying the sprinkler systems wheren such headers are part of the seismically analyzed hose standpipe system. When provided, such headers l        are considered an extension of the yard main system. Each sprinkler and standpipe l        system should be equipped with OS&Y (an outside screw and yoke) gate valve or other approved shutoff valve and water flow alarm.
The guidance in Regulatory Position 3.2 is based on Appendix R to 10 CFR Part 50, CMEB 9.5-1, Supplement 1 to GL 89-13, and IE Bulletin BL 81-03.
l 3.3    Automatic Suppression Systems (Design Objectives and Performance Criteria)
Automatic suppression should be installed as determined by the fire hazards analysis and l as necessary to protect redundant systems or components necessary for safe shutdown and SSCs l important to safety. (sSee Regulatory Positions 5.5.b, 5.5.c, and 16 of this guide.3.1).
In areas of high seismic activity, the need to design the fire suppression systems to be l functional following the safe -shutdown earthquake should be considered.
The fire suppression systems should retain their original design capability for (1) 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 l small-intensity earthquakes that are characteristic of the geographic region, and (2) potential DG-1170, Page 86
 
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.
l For water suppression systems and fire detection systems that use metal plates for heat    l collection above individual sprinkler heads or detectors that are located well below the ceiling of l a fire area (e.g., at some intermediate height in the room, below ceiling-mounted pipe and cable    l tray), it should be demonstrated that this design will ensure acceptable actuation times. IN 2002-  l 24, Potential Problems with Heat Collectors on Fire Protection Sprinklers, provides a            l discussion of this issue. In general, the use of such plates has not been demonstrated to provide  l adequate heat collection to effectively activate the sprinkler head or detector and may impair      l system response.                                                                                    l l
3.3.1  Water-bBased Systems                                                              l l
Equipment important to safety that does not itself require protection by water-based      l suppression systems, but is subject to unacceptable damage if wetted by suppression system          l discharge, should be appropriately protected (e.g., water shields or baffles). Drains should be    l provided as required to protect equipment important to safety from flooding damage.                l l
3.3.1.1        Sprinkler and Spray Systems.                                              l l
Water sprinkler and spray suppression systems are the most widely used means of            l implementing automatic water-based fire suppression. Sprinkler and spray systems should, ast a      l minimum, conform to requirements of appropriate standards such as NFPA 13 and NFPA15NFPA 15.                                                                                      l 3.3.1.2        Water Mist Systems.                                                        l l
Water mist suppression systems may be useful in specialized situations, particularly in    l those areas where the application of water needs to be restricted. Water mist systems should        l conform to appropriate standards such as NFPA 750, "StandardStandard on Water Mist Fire            l Protection Systems."                                                                              l 3.3.1.3        Foam-Water Sprinkler and Spray Systems.                                    l l
Certain fires, such as those involving flammable liquids, respond well to foam            l suppression. Consideration should be given to the use of foam sprinkler and spray systems.
Foam sprinkler and spray systems should conform to appropriate standards such as NFPA 16, "StandardStandard for the Installation of Deluge Foam-Water Sprinkler and Foam-Water Spray        l Systems," NFPA 16A, "Standard for the Installation of Closed-Head Foam-Water Sprinkler Systems," NFPA 11, "Standard and NFPA 11, Standard for Low-Expansion Foam," and NFPA              l 11A, "Standard for Medium- and High-Expansion Foam Systems."
3.3.2  Low-, Medium-, and High-Expansion Foam.                                          l DG-1170, Page 87
 
l 3.3.2 Gaseous Fire Suppression l
l        Gaseous systems should be evaluated for potential impacts on the habitability of areas l containing equipment important to safety where operations personnel perform safe-shutdown l actions or where fire-fighting activities may become necessary. Where gas suppression systems are installed, openings in the area should be adequately sealed or the suppression system should be sized to compensate for the loss of the suppression agent through floor drains and other l openings. (ASee also see Regulatory Position 4.1.5.) of this guide.)
l l        The design of gaseous suppression systems should consider the following, as applicable:
l a.      the minimum required gas concentration, distribution, soak time, and ventilation control l b.      the anoxia and toxicity hazards associated with the gas l c.      the possibility of secondary thermal shock (cooling) damage l d.      conflicting requirements for venting during system discharge to prevent l        overpressurization versus sealing to prevent loss of agent l e.      location and selection of the activating detectors l f.      the toxicity and corrosive characteristics of the thermal decomposition products of the l        agent Where total flooding gas extinguishing systems are used, area intake and exhaust ventilation dampers should be controlled in accordance with appropriate standards to maintain l the necessary gas concentration. (See NFPA 12, "StandardStandard on Carbon Dioxide l Extinguishing Systems," NFPA 12A, "StandardStandard on Halon 1301 Fire Extinguishing l Systems,"  and NFPA 2001, "StandardStandard on Clean Agent Fire Extinguishing Systems.)
l (Also, see Regulatory Position 4.1.4.4 of this guide.)
The adequacy of gas suppression systems and protected area boundary seals to contain the l gas suppressant should be tested as specified in the applicable NFPA Sstandards.
Manually actuated gaseous suppression systems should not be used as the primary l suppression system for protecting structures, systems, and componentsSSCs important to safety.
Manually actuated gaseous systems are acceptable as a backup to automatic water-based fire suppression systems.
l        3.3.2.1        Carbon Dioxide (CO2) Systems.
l l        Carbon dioxide extinguishing systems should comply with the requirements of NFPA 12, "Carbon Dioxide Extinguishing Systems." Where automatic carbon dioxide systems are used, they should be equipped with a pre-discharge alarm system and a discharge delay to permit personnel egress. Provisions for locally disarming automatic carbon dioxide systems should be key locked and under strict administrative control. Automatic carbon dioxide extinguishing l systems should not be disarmed unless controls as described in Regulatory Position 2.4 of this l guide are provided.
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In addition to the guidelines of NFPA 12, preventive maintenance and testing of the systems, including verifying agent quantity of high-pressure CO2 cylinders, should be done.
Particular consideration should also be given to:
: a.      The minimum required CO2 concentration, distribution, soak time, and ventilation control;
: b.      The anoxia and toxicity hazards associated with CO2;
: c.      The possibility of secondary thermal shock (cooling) damage;
: d.      Conflicting requirements for venting during CO2 injection to prevent over pressurization versus sealing to prevent loss of agent; and
: e.      Location and selection of the activating detectors.
3.3.2.2        Halon.                                                                  l l
Halon fire extinguishing systems should comply with the requirements of NFPA 12A.        l Where automatic Halon systems are used, they should be equipped with a pre-discharge alarm and a discharge delay to permit personnel egress. Provisions for locally disarming automatic Halon systems should be key locked and under strict administrative control. Automatic Halon extinguishing systems should not be disarmed unless controls as described in Regulatory Position 2.4 of this guide are provided.                                                                  l In addition to the guidelines of NFPA 12A, preventive maintenance and testing of the systems, including verifying agent quantity of the Halon cylinders, should be done.
Particular consideration should also be given to:
: a.      The minimum required Halon concentration, distribution, soak time, and ventilation control,
: b.      The toxicity of Halon,
: c.      The toxicity and corrosive characteristics of the thermal decomposition products of Halon, and
: d.      The location and selection of the activating detectors.
3.3.2.3        Clean Agents.                                                            l l
Halon alternative (or "cleanclean agent") fire extinguishing systems should comply    l with applicable standards such as NFPA 2001. Only listed or approved agents should be used.      l Provisions for locally disarming automatic systems should be key locked and under strict        l DG-1170, Page 89
 
administrative control. Automatic extinguishing systems should not be disarmed unless controls l as described in Regulatory Position 2.4 of this guide are provided.
In addition to the guidelines of NFPA 2001, preventive maintenance and testing of the systems, including verifying agent quantity of the clean agent cylinders/containers, should be done.
Particular consideration should also be given to:
: a.      The minimum required clean agent concentration, distribution, soak time, and ventilation control,
: b.      The toxicity of the clean agent,
: c.      The toxicity and corrosive characteristics of the thermal decomposition products of the clean agent,
: d.      Conflicting requirements for venting during clean agent injection to prevent over pressurization versus sealing to prevent the loss of agent, and
: e.      The effectiveness of the particular clean agent at its design concentration for the protected hazard.
: f.      The location and selection of the activating detectors.
The guidance in Regulatory Position 3.3 is based on Appendix R to 10 CFR Part 50, CMEB 9.5-1, and IN 92-28.
l 3.4    Manual Suppression Systems and Equipment l        AThe licensee should provide a manual firefighting capability should be provided throughout the plant to limit the extent of fire damage. Standpipes, hydrants, and portable equipment consisting of hoses, nozzles, and extinguishers should be provided for use by properly trained firefighting personnel.
l        3.4.1  Standpipes and Hose Stations l
l        Interior manual hose installations should be able to reach any location that contains, or could present a fire exposure hazard to, equipment important to safety with at least one effective hose stream. To accomplish this, standpipes with hose connections equipped with a maximum of l 30.5 m (100 feet) of 38 -mm (1-1/2-inches1.5-in.) woven-jacket, lined fire hose and suitable nozzles should be provided in all buildings on all floors. These systems should conform to l NFPA 14, "StandardStandard for the Installation of Standpipe and Hose Systems," for sizing, spacing, and pipe support requirements for Class III standpipes.
l  Water supply calculations should demonstrate that the water supply system can meet the l standpipe pressure and flow requirements of NFPA 14.
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Hose stations should be located as dictated by the fire hazards analysis to facilitate access l and use for firefighting operations. Alternative hose stations should be provided for an area if the fire hazard could block access to a single hose station serving that area.
The proper type of hose nozzle to be supplied to each area should be based on the fire hazards analysis. The usual combination spray/straight-stream nozzle should not be used in areas      l where the straight stream can cause unacceptable mechanical damage. Fixed fog nozzles should be provided at locations where high-voltage shock hazards exist. All hose nozzles should have shutoff capability. GVolume II, Section 10, Chapter 1, of the 19th Edition of the  NFPA Fire          l Protection Handbook, provides guidance on safe distances for water application to live electrical    l equipment may be found in the "NFPA Fire Protection Handbook," Chapter 6, Eighteenth Edition.
Fire hose should meet the recommendations of NFPA 1961, "StandardStandard on Fire            l Hose,"  and should be hydrostatically tested in accordance with the recommendations of NFPA          l 1962, "StandardStandard for the Inspection, Care, and Use, of Fire Hose Couplings and Nozzles        l and the Service Testing of Fire Hose Including Couplings and Nozzles."                                l 3.4.2  Hydrants and Hose Houses                                                              l l
Outside manual hose installations should be sufficient to provide an effective hose stream    l to any onsite location where fixed or transient combustibles could jeopardize equipment important to safety. Hydrants should be installed approximately every 76 m (250 ft) on the yard main system. A hose house equipped with hose and combination nozzle and other auxiliary equipment recommended in NFPA 24 should be provided as needed, but at least every 305 m (1,000 ft). Alternatively, a mobile means of providing hose and associated equipment, such as          l hose carts or trucks, may be used. When provided, such mobile equipment should be equivalent to the equipment supplied by three hose houses.
Mobile equipment should be maintained in good working order and should be readily available          l for fire-fighting activities.                                                                          l Threads compatible with those used by local fire departments should be provided on all hydrants, hose couplings, and standpipe risers. Alternatively, a sufficient number of hose thread adapters may be provided.
Fire hose should be hydrostatically tested in accordance with the recommendations of NFPA 1962. Fire hose stored in outside hose houses should be tested annually.
l DG-1170, Page 91
 
l          3.4.3  Manual Foam l
For flammable and combustible liquid fire hazards, consideration should be given to the use of foam systems for manual fire suppression protection. These systems should comply with the requirements of NFPA 11, NFPA 11A, and NFPA 11C, "Standard for Mobile Foam Apparatus," as applicable.
l l
l          3.4.4  Fire Extinguishers l
l          Fire extinguishers should be provided in areas that contain or could present a fire l exposure hazard to equipment important to safety. Dry chemical eExtinguishers should be installed with due consideration given to possible adverse effects on equipment important to l safety installed in the area. NFPA 10, "StandardStandard for Portable Fire Extinguishers,"
l provides guidance on the installation (including location and spacing) and the use and application of fire extinguishers.
l          The guidance in Regulatory Position 3.4 is based on3.4.5      Fixed Manual Suppression l
l          Some fixed fire suppression systems may be manually actuated (e.g., fixed suppression l systems provided in accordance with Section III.G.3 of Appendix R to 10 CFR Part 50 and CMEB 9.5-1.
l 3.5      ). Manual actuation is generally limited to water spray systems and should not be used l for gaseous suppression systems except when the system provides backup to an automatic water l suppression system. Fixed manual suppression systems should be designed in accordance with l applicable guidance of the appropriate NFPA standards. A change from an automatic system to a l manually actuated system should be supported by an appropriate evaluation.
l l 3.5      Manual Firefighting Capabilities l          3.5.1  Fire Brigade l
l          A site fire brigade trained and equipped for fire fightingfirefighting should be established and should be on site at all times to ensure adequate manual firefighting capability for all areas of l the plant containing structures, systems, and componentsSSCs important to safety. The fire brigade leader should have ready access to keys for any locked doors.
l          GRegulatory Position 1.6.4 of this guide provides guidance on fire brigade training and l qualification is provided in Regulatory Position 1.6.4qualifications.
The guidelines of NFPA 600 are considered appropriate criteria for organizing, training, and operating a plant fire brigade.
l          3.5.1.1        Fire Brigade Staffing.
l DG-1170, Page 92
 
The fire brigade should beinclude at least five members on each shift. The shift          l supervisor should not be a member of the fire brigade.
3.5.1.2        Equipment.                                                                l l
The equipment provided for the brigade should consist of personal protective equipment    l such as turnout coats, bunker pants, boots, gloves, hard hats, emergency communications equipment, portable lights, portable ventilation equipment, and portable extinguishers.
Self-contained breathing apparatuses using full-face positive-pressure masks approved by          l NIOSH (the National Institute for Occupational Safety and Health  (approval formerly given        l by the U.S. Bureau of Mines) should be provided for fire brigade, damage control, and control room personnel. At least 10 masks should be available for fire brigade personnel. Control room personnel may be furnished breathing air by a manifold system piped from a storage reservoir if practical. Service or rated operating life should be at least one-half hour30 minutes for the      l self-contained units. Additional guidance is provided in NFPA 1404, Standard for a Fire Department Self-Contained Breathing Apparatus Program.
Service Respiratory Protection Program, provides additional guidance.                            l l
Fire brigade equipment should be stored in accordance with manufacturers                l recommendations (e.g., firefighter clothing should not to be stored where it will be subjected to  l ultraviolet light from the sun, welding, or fluorescent lights).                                  l l
At least a 1-hour supply of breathing air in extra bottles should be located on the plant l site for each unit of self-contained breathing apparatus. In addition, an onsite 6-hour supply of reserve air should be provided for the fire brigade personnel and arranged to permit quick and complete replenishment of exhausted air supply bottles as they are returned. If compressors are usedserve as a source of breathing air, only units approved for breathing air should be used and  l the compressors should be operable assumingin the event of a loss of offsite power. Special care  l should be taken to locate the compressor in areas free of dust and contaminants.
During refueling and maintenance periods, adequate self-contained breathing apparatuses  l should be provided near the containment entrances for firefighting and damage control personnel.
These units should be independent of any breathing apparatuses or air supply systems provided      l for general plant activities and should be clearly marked as emergency equipment.
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l        3.5.1.3          Procedures and Pre-fire Plans.
l l        Procedures should be established to control actions by the fire brigade onupon notification by the control room of a fire, and to define firefighting strategies. These procedures l should include the following:
l a.      Aactions to be taken by control room personnel to notify the fire brigade upon report of a l        fire or receipt of an alarm on the control room fire alarm panel, for example (e.g.,
l        announcing the location of the fire over the PApublic address system, sounding fire alarms, and notifying the shift supervisor and the fire brigade leader of the type, size, and location of the fire.
l )
l b.      Aactions to be taken by the fire brigade after notification by the control room of a fire l        (e.g., for example, assembling assembling in a designated location, receiving directions l        from the fire brigade leader, and discharging specific firefighting responsibilities, l        including selection and transportation of firefighting equipment to the fire location, selection of protective equipment, operating instructions for use of fire suppression l        systems, and use of preplanned strategies for fighting fires in specific areas.
l )
: c.      Define the strategies for fighting fires in all plant areas. These strategies should l        designate, including the following:
l        i.      Ffire hazards in each area covered by the specific pre-fire plans.
l        ii.      FSSCs credited for fire safe shutdown.
l        iii. fire suppression agents best suited for extinguishing the fires associated with the fire hazards in that area and the nearest location of these suppression agents.
l l        iiiv. Mmost favorable direction from which to attack a fire in each area in view of the ventilation direction, access hallways, stairs, and doors that are most likely to be l                  free of fire, and the best station or elevation for fighting the fire. A, as well as all l                  access and egress routes that involveinvolving locked doors should be specifically l                  identified in the procedure withand the appropriate precautions and methods for access specified.
l        ivv. Pplant systems that should be managed to reduce the damage potential during a local fire and the location of local and remote controls for such management (e.g.,
DG-1170, Page 94
 
any hydraulic or electrical systems in the zone covered by the specific firefighting procedure that could increase the hazards in the area because of over pressurizationoverpressurization or electrical hazards).                                l vi. Vvital heat-sensitive system components that need to be kept cool while fighting a      l local fire. I, in particular, hazardous combustibles that need cooling should be        l designated.
vii. Oorganization of firefighting brigades and the assignment of special duties            l according to job title so that all firefighting functions are covered by any complete shift personnel complement. These duties include(including command control of          l the brigade, transporting fire suppression and support equipment to the fire scenes, applying the extinguishing agent to the fire, communication with the control room, and coordination with outside fire departments.
vii. Potential, according to job title so that all firefighting functions are covered by any l complete shift personnel complement                                                    l viii. potential radiological and toxic hazards in fire zones.                                l viiiix. Vventilation system operation that ensures desired plant air distribution when the      l ventilation flow is modified for fire containment or smoke clearing operation.
ixx. Ooperations requiring control room and shift engineer coordination or                  l authorization.
xi. Iinstructions for plant operators and general plant personnel during fire.              l xii. Ccommunications between the fire brigade leader, fire brigade, offsite mutual aid      l responders, control room, and licensees emergency response organization.
Appropriate firefighting procedures should identify the techniques and equipment for the use of water in fighting electrical cable fires in nuclear plants, particularly in areas containing a high concentration of electric cables with plastic insulation. Additional guidance on pre-fire planning is provided in NFPA 1620NFPA 1620, "RecommendedRecommended Practice for                      l Pre-Incident Planning, provides additional guidance on prefire planning."                              l l
3.5.1.4        Performance Assessment/Drill Criteria.                                                  l l
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l        Fire brigade drills should be performed in the plant so that the fire brigade can practice as a team. Drills should be performed quarterly for each shift fire brigade. Each fire brigade l member should participate in at least two drills per yearannually.
l        A sufficient number of these drills, but not less than one for each shifts fire brigade per l year, should be unannounced to determine the firefighting readiness of the plants fire brigade, brigade leader, and fire protection systems and equipment. Persons planning and authorizing an unannounced drill should ensure that the responding shift fire brigade members are not aware that a drill is being planned until it has begun. At least one drill per year should be performed on l a "backback shift" for each shifts fire brigade.
l        The drillslicensee should be preplannedpreplan the drills to establish the training l objectives of the drill and should be critiqued critique them to determine how well the training l objectives have been met. Unannounced drills should be planned and critiqued by m Members of l the management staff responsible for plant safety and fire protection should plan and critique l unannounced drills. Performance deficiencies of a fire brigade or of individual fire brigade members should be remedied by scheduling additional training for the brigade or members.
Unsatisfactory drill performance should be followed by a repeat drill within 30 days.
l        The local fire department should be invited to participate in drills at least annually.
At 3-year intervals, a randomly selected unannounced drill should be critiqued by l qualified individuals independent of the licensee's staff should critique a randomly selected l unannounced drill. A copy of the written report from such individuals should be available for NRC review.
Drills should include the following:
l a.      Assessment of fire alarmThe effectiveness of the fire alarms, time required to notify and assemble the fire brigade, and selection, placement, and use of equipment and firefighting strategies.
l  should b.      Assessment of eache assessed.
l b.      Each brigade member's knowledge of his or her role in the firefighting strategy for the l        area assumed to contain the fire. Assessment of, and the brigade members'members conformance with established plant firefighting procedures and use of firefighting l        equipment, including self-contained emergency breathing apparatuses, communication, l        lighting, and ventilation should be assessed.
: c.      The simulated use of firefighting equipment required to cope with the situation and type l        of fire selected for the drill should be evaluated. The area and type of fire chosen for the drill should differ from those used in the previous drills so that brigade members are trained in fighting fires in various plant areas. The situation selected should simulate the DG-1170, Page 96
 
size and arrangement of a fire that could reasonably occur in the area selected, allowing for fire development during the time required to respond, obtain equipment, and organize for the fire, assuming loss of automatic suppression capability.
: d.      Assessment of tThe brigade leader's direction of the firefighting effort asshould be          l assessed with regard to thoroughness, accuracy, and effectiveness.                              l Drill records should be retained for a period of 3 years and made available for NRC inspection. (See Regulatory Position 1.6.4 of this guide for additional guidancedirection on drill      l records.)
3.5.2    Offsite Manual Fire-Ffighting Resources                                                l l
Onsite fire brigades typically fulfill the role of first responder, but may not have sufficient l personnel, equipment, and capability to handle all possible fire events. Arrangements with offsite fire services may be necessary to augment onsite firefighting capabilities, consistent with the fire hazards analysis and pre-fire planning documents. The FPP should describe the                  l capabilities (e.g., equipment compatibility, training, drills, and command control) of offsite          l responders.                                                                                              l 3.5.2.1          Capabilities.                                                                  l l
The local offsite fire departments providingthat provide back up manual firefighting            l resources should have the following capabilities:
: a.      Ppersonnel and equipment with capacities consistent with those assumed in the plant's          l fire hazards analysis and pre-fire plans.
: b.      Hhose threads or adapters to connect with onsite hydrants, hose couplings, and standpipe        l risers. (Regulatory Position 3.4.2 states that onsite fire suppression water systems should have threads compatible with those used by local fire departments or a sufficient number of thread adapters available.)
3.5.2.2          Training.                                                                      l l
Local offsite fire department personnel providingwho provide back up manual                    l firefighting resources should be trained in the following:                                              l
: a.      Ooperational precautions when fighting fires on nuclear power plant sites and the need          l for radiological protection of personnel and the special hazards associated with a nuclear power plant site.
l DG-1170, Page 97
 
l b.      Tthe procedures for notification and expected roles of the offsite responders.
l c.      Ssite access procedures and the identity (by position and title) of the individual in the l        onsite organization who will control the responders' support activities. O (offsite response support personnel should be provided with appropriate identification cards where required.
l )
l d.      Ffire protection authorities, responsibilities, and accountabilities with regard to responding to a plant fire, including the fire event command structure between the plant fire brigade and offsite responders.
l l e.      Pplant layout, plant fire protection systems and equipment, plant fire hazards, and pre-fire response plans and procedures.
l        3.5.2.3          Agreement/Plant Exercise.
l l        The Wlicensee should establish written mutual aid agreements should be established l between the utility and the offsite fire departments that are assumedlisted in the fire hazards l analysis and pre-fire plans toas providing a support response to a plant fire. These agreements should delineate fire protection authorities, responsibilities, and accountabilities with regard to responding to plant fire or emergency events, including the fire event command structure between the plant fire brigade and offsite responders.
The plant fire brigade drill schedule should provide for periodic local fire department participation (at least annually). These drills should effectively exercise the fire event command structure between the plant fire brigade and offsite responders. (See Regulatory Position 3.5.1.4 for guidance on conduct and evaluation of fire brigade drills.) Offsite fire department response should be tested periodically in conjunction with the required exercises of the radiological emergency response plan required by 10 CFR 50.47.
The guidance in Regulatory Position 3.5 is based on Appendix R to 10 CFR Part 50, NUREG-0654, and CMEB 9.5-1.
: 4.      BUILDING DESIGN/PASSIVE FEATURES l 4.1    , Emergency Plans.
l l 4.      Building Design/Passive Features l
l 4.1    General Building and Building System Design DG-1170, Page 98
 
This section provides guidance on building layout (e.g., fire areas and zones), materials of construction, and building system design (e.g., electrical, HVAC, lighting, and communication systems) important to effective fire prevention and protection. GRegulatory Position 4.2            l provides guidance for passive fire barriers is provided in Regulatory Position 4.2.                  l 4.1.1  Combustibility of Building Components and Features                                  l l
According to GDC 3, noncombustible and heat -resistant materials must be used                l wherever practical throughout the unit. Interior wall and structural components, thermal insulation materials, radiation shielding materials, and soundproofing should be noncombustible. l The fire hazards analysis should identify in situ combustible materials used in plant SSCs and      l specify suitable fire protection.                                                                    l Metal deck roof construction should be noncombustible and listed as "acceptableacceptable for fire" in the UL BuildingUnderwriters Laboratories, Inc. (UL),            l Building Materials Directory, or listed as Class I in the Factory Mutual Research Approval        l Guide.
DG-1170, Page 99
 
l        4.1.1.1        Interior Finish.
l l        Interior finishes should be noncombustible. The following materials are acceptable for use as interior finish without evidence of test and listing by a recognized testing laboratory:
l a.      Pplaster, acoustic plaster, and gypsum plasterboard (gypsum wallboard), either plain, wallpapered, or painted with oil- or water-base paint, l
l b.      Cceramic tile, and ceramic panels, l
l c.      Gglass, and glass blocks, l
l d.      Bbrick, stone, and concrete blocks, plain or painted, l
l e.      Ssteel and aluminum panels, plain, painted, or enameled, and l
l f.      Vvinyl tile, vinyl-asbestos tile, linoleum, or asphalt tile on concrete floors.
l l        Suspended ceilings and their supports should be of noncombustible construction.
l Concealed spaces should be devoid of combustibles except as noted in Regulatory Position 6.1.2, l Control Room Complex of this guide.
In situ fire hazards should be identified and suitable protection provided.
DG-1170, Page 100
 
4.1.1.2              Testing and Qualification.                                                                          l l
Interior finishes should be noncombustible (see Definitionsthe Glossary section of this                                l guide) or listed by an approving laboratory for the following:                                                                    l
: a.      Ssurface flame spread rating of 25 or less, and a smoke development rating of 450 or less,                                l when tested under American Society for Testing and Materials (ASTM) E-84,                                                l "StandardStandard Test Method for Surface Burning Characteristics of Building                                            l Materials," and Materials                                                                                                l
: b.      Ppotential heat release of 8141 kilojoules per kilogram (kJ/kg) (3500 Btu/lb3,500 Btu per                                l pound/) or less when tested under ASTM D3286 or NFPA 259, "StandardASTM D-3286,                                          l Standard Test Method for Gross Calorific value of Coal and Coke by the Isoperibol                                        l Bomb Calorimeter, or NFPA 259, Standard Test Method for Potential Heat of Building                                      l Materials."(3)                                                                                                          l
: c.      Ffloor covering critical radiant flux should beas determined by testing in accordance with                                l NFPA 253, TestStandard Method of Test for Critical Radiant Flux of Floor Covering                                      l Systems Using a Radiant Heat Energy Source.
The guidance in Regulatory Position 4.1.1 is based on GDC 3, Appendix R to 10 CFR Part 50, ASB 9.5-1, and CMEB 9.5-1.
4.1.2      CompartmentationSource                                                                                        l l
4.1.2  Compartmentalization, Fire Areas, and Zones                                                                              l l
In accordance with GDC 3, structures, systems, and componentsSSCs important to safety                                    l must be designed and located to minimize the probability and effect of fires and explosions. The concept of compartmentationcompartmentalization meets GDC 3, in part, by utilizing passive                                        l fire barriers to subdivide the plant into separate areas or zones. These fire areas or zones serve the primary purpose of confining the effects of fires to a single compartment or area, thereby minimizing the potential for adverse effects from fires on redundant structures, systems, and componentsSSCs important to safety.                                                                                              l 3
Trays exceeding 610 mm (24 inches) should be counted as two trays; trays exceeding 1220 mm (48 inches) should be counted as three trays, regardless of tray fill.The concept of using a potential heat release limit of 8141 kJ/kg (3,500  l Btu/lb) is similar to the limited combustible concept with its like limit, as set forth in NFPA 220, Standard on Types l of Building Construction.                                                                                                l DG-1170, Page 101
 
l          4.1.2.1          Fire Areas.
l l          A fire area is defined as that portion of a building or plant that is separated from other areas by fire barriers, including components of construction such as beams, joists, columns, penetration seals or closures, fire doors, and fire dampers. Fire barriers that define the l boundaries of a fire area should have a fire -resistance rating of 3 hours or more and should be l providedachieve the following:
l a.      To separate structures, systems, and componentsseparation of SSCs important to safety from any potential fires in non-safety-related areas that could affect their ability to perform their safety function; l b.      To separateseparation of redundant success pathstrains of systems and components important to safety from each other so that both are not subject to damage from a single fire; l c.      To separateseparation of individual units on a multiple-unitmultiunit site unless the l          requirements of General Design Criterion 5GDC 5, Sharing of Structures, Systems, and l          Components, are met with respect to fires.
l          Fire areas should be established on the basis of tThe fire hazards analysis should be used l to establish fire areas. Particular design attention to the use of separate, isolated fire areas for redundant cables will help to avoid loss of redundant cables important to safety. Separate fire areas should also be employed to limit the spread of fires between components, including high concentrations of cables important to safety that are major fire hazards within a safety division.
Where fire area boundaries are not 3-hour rated, or not wall-to-wall or floor-to-ceiling l boundaries with all penetrations sealed to the fire rating of the boundaries, the licensee should l perform an evaluation should be performed to assess the adequacy of the fire area boundaries (i.e., barriers) to determine whether the boundaries will withstand the hazards associated with the area and, as necessary, protect important equipment within the area from a fire outside the area.
Unsealed openings should be identified and considered when evaluating the overall effectiveness l of the barrier (See Regulatory Position 1.4.3 for positions related to barrier evaluations. (See l Regulatory Position 4.2.1 of this guide for positions related to fire barrier testing and acceptance.)
l          If a wall or floor/ceiling assembly contains major unprotected openings, such as hatchways and stairways, plant locations on either side of such a barrier should be considered as part of a single fire area. If success path A is separated by a cumulative horizontal distance of 6.1 m (20 feet) from success path B, with no intervening combustible materials or fire hazards, and both elevations are provided with fire detection and suppression, the area would be considered acceptable.
DG-1170, Page 102
 
Exterior walls, including penetrations, should be qualified as rated fire barriers if they are required to separate safe -shutdown equipment on the interior of the plant from the redundant          l equipment located in the immediate vicinity of the exterior wall, if they separate plant areas important to safety from non-safety-related areas that present a significant fire exposure to the areas important to safety, or if otherwise designated by the FSAR or fire hazards analysis.
An exterior yard area without fire barriers should be considered as one fire area. The area    l may consist of several fire zones. (sSee Regulatory Position 4.1.2.2 of this guide.).                  l 4.1.2.2        Fire Zones.                                                                    l l
Fire zones are subdivisions of a fire area and are typically based on fire hazards analyses    l that demonstrate that the fire protection systems and features within the fire zone provide an appropriate level of protection for the associated hazards. Fire zone concepts may be used to establish zones within fire areas where further subdivision into additional fire areas is not practical on the basis of existing plant design and layout (e.                                          l g., inside containment).                                                                                l Evaluations by some licensees made prior tobefore Appendix R to 10 CFR Part 50 was            l published were based on fire zones that do not meet the strict definition of fire areas. In some        l cases, the separation of redundant success paths within the fire zone boundaries and the separation between fire zones do not comply with the separation requirements of Appendix R.
Such configurations may be acceptable under the exemption process.
An exterior yard area considered as one fire area may consist of several fire zones. The fire hazards analysis should be used to determine the boundaries of the fire zones should be            l determined by a fire hazards analysis. The protection for redundant, alternative, dedicated, or backup shutdown systems within a yard area should be determined on the basis of the largest postulated fire that is likely to occur and the resulting damage. The boundaries of such damage should be justified with a fire hazards analysis. The analysis should consider the degree of            l 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.                                                          l DG-1170, Page 103
 
l        4.1.2.3        Access and Egress Design. Provisions should be made for personnel access to and escape routes from each fire area. Under emergency conditions, prompt l ingress into certain areas important to safety should be ensured to enable l
l        The plant layout should provide adequate means of access to all plant areas for manual fire suppression and safe shutdown of a nuclear power plant.
l . The plant layout should also allow for safe access and egress to areas for personnel performing l safe-shutdown operations. Considerations should include fire and post-fire habitability in safe-l shutdown areas, protection or separation from fire conditions of access and egress pathways to l safe-shutdown SSCs, and potential restrictions or delays to safe-shutdown area access potentially l caused by security locking systems.
Stairwells outside primary containment serving as escape routes, access routes for firefighting, or access routes to areas containing equipment necessary for safe shutdown should be enclosed in masonry or concrete towers with a minimum fire rating of 2 hours and self-closing Class B fire doors. Fire exit routes should be clearly marked.
Prompt emergency ingress into electrically locked areas by essential personnel should be ensured through the combined use and provision of the following features.
l a.      Rreliable and uninterruptible auxiliary power to the entire electrical locking system, including its controls.
l l b.      Eelectrical locking devices that are required to fail in the secure mode for security purposes, with secure mechanical means and associated procedures to override the devices upon loss of both primary and auxiliary power (e.g., key locks with keys held by appropriate personnel who know when and how to use them).
l c.      Pperiodic tests of all locking systems and mechanical overrides to confirm their operability and their capability to switch to auxiliary power.
l        Also see Regulatory Positions 4.1.6 and 4.1.7 for guidanceof this guide provide direction l related to emergency lighting and communication capabilities during fires.
The guidance in Regulatory Position 4.1.2 is based on GDC 3, Appendix R to 10 CFR Part 50, CMEB 9.5-1, GL 83-33, GL 86-10, BL 81-03, and IN 84-09.
DG-1170, Page 104
 
4.1.3    Electrical Cable System Fire Protection Design                                      l 4.1.3.1        Cable Design.                                                                l l
Electric cable construction should pass the flame test in IEEE Standard 383, "IEEE          l Standard for Type Test of Class IE Electric Cables, Field Splices, and Connections for Nuclear      l Power Generating Stations," or IEEE Standard 1202, "IEEE Standard for Flame Testing of            l Cables for Use in Cable Trays in Industrial and Commercial Occupancies." (This does not            l imply that cables passing either test will not require additional fire protection.) For cable        l installations in operating plants and plants under construction prior tobefore July 1, 1976, that do l not meet the IEEE Standard 383 flame test requirements, all cables should be covered with an approved flame retardant coating and properly derated, or be protected by automatic suppression.
4.1.3.2 Although cable coatings have been shown to reduce flame spread, coated cables        l are considered intervening combustibles when determining the protection requirements of              l Section III.G.2 of Appendix R to 10 CFR Part 50. Coated cables do not have higher damage            l thresholds and, therefore, are not equivalent to IEEE 383 cables. In addition, coated cables can    l and do ignite in fires.                                                                              l l
New reactor fiber optic cable insulation and jacketing should also meet the fire and flame  l test requirements of IEEE 383 or IEEE 1202.                                                          l l
4.1.3.2 Raceway/Cable Tray Construction.                                                            l l
Only metal should be used for cable trays. Only metallic tubing should be used for          l conduit. Thin-wall metallic tubing should not be used. Flexible metallic tubing should only be used in short lengths to connect components to equipment. Other raceways should be made of noncombustible material. Cable raceways should be used only for cables.
4.1.3.3        Electrical Cable System Fire Detection and Suppression.                      l l
Redundant cable systems important to safety outside the cable spreading room should be      l separated from each other and from potential fire exposure hazards in non-safety-related areas by fire barriers with a minimum fire rating of 3 hours to the extent feasible. Theose fire areas that  l contain cable trays important to safety should be provided with fire detection. Cable trays should be accessible for manual fire fightingfirefighting and cables should be designed to allow wetting    l down with fire suppression water without electrical faulting. Manual hose stations and portable hand extinguishers should be provided.
Manual hose standpipe systems may be relied upon to provide the primary fire suppression (in lieu of automatic water suppression systems) for cable trays of a single division important to safety that are separated from redundant safety divisions by a fire barrier with a minimum rating of 3 hours and are normally accessible for manual fire fightingfirefighting if all    l of the following conditions are met.
:                                                                                                    l DG-1170, Page 105
 
l a.      The number of equivalent(4) standard 610-mm- (24-inch-24-in.-) wide cable trays (both l        important to safety and non-safety-related) in a given fire area is 6six or less; l .
: b.      The cabling does not provide instrumentation, control, or power to systems required to achieve and maintain hot shutdown; and l .
: c.      Smoke detectors are provided in the area of these cable routings, and continuous line-type heat detectors are provided in the cable trays.
In other areas where it may not be possible because of other overriding design features necessary for reasons of nuclear safety to separate redundant cable systems important to safety by 3-hour-rated fire barriers, or if cable trays are not accessible for manual firefighting, cable trays should be protected by an automatic fire suppression system.
l        4.1.3.4              Electrical Cable Separation.
l l        Redundant systems used to mitigate the consequences of design -basis accidents but not necessary for safe shutdown may be lost to a single exposure fire. However, protection should be provided so that a fire within only one such system will not damage the redundant system.
l Therefore, the separation criteriaguidelines of Regulatory Position 5.53 of this guide apply only l to the electrical cabling needed to support the systems that are used for post-fire safe -shutdown.
All other redundant Class 1E and associated electrical cables should meet the separation l criteriaguidelines of Regulatory Guide 1.75.
l        When the electrical cabling is covered by separation criteria required for both post-fire l safe -shutdown and accident mitigation, the more stringent criteria of Regulatory Position 5.53 l apply. [Note that compliance with post-fire safe -shutdown requirements may be achieved without separation of redundant Class 1E cabling by providing alternative, dedicated, or backup l shutdown capability (see Regulatory Position 5.64); however, this does not preclude the separation criteria of Regulatory Guide 1.75 for redundant Class 1E and associated cables used in accident mitigation.]
l        For plants with a Cconstruction Ppermit issued prior tobefore July 1, 1976, where cables important to safety do not satisfy the provisions of Regulatory Guide 1.75, all exposed cables should be covered with an approved fire retardant coating or a fixed automatic water fire suppression system should be provided.
l        4.1.3.5              Transformers.
l 4
The 181&deg;C [325&deg;F] temperature condition was established by allowing the temperature of the unexposed side of the fire barrier to rise 139&deg;C [250&deg;F] above the assumed 24&deg;C [75&deg;F] ambient air temperature, as measured by the l        thermocouples within the test specimen at the onset of the fire exposure during the fire test.orays exceeding 610 mm l        (24 in.) should be counted as two trays; trays exceeding 1,220 mm (48 in.) should be counted as three trays, regardless l        of tray fill.
DG-1170, Page 106
 
Transformers that present a fire hazard to equipment important to safety should be            l protected as described in Regulatory Position 7.3 of this guide.
4.1.3.6          Electrical Cabinets.                                                          l l
Electrical cabinets present an ignition source for fires and a potential for explosive        l electrical faults that can result in damage not only to the cabinet of origin, but also to equipment, cables, and other electrical cabinets in the vicinity of the cabinet of origin. Fire protection systems and features provided for the general area containing the cabinet may not be adequate to prevent damage to adjacent equipment, cables, and cabinets following an energetic electrical fault. Energetic electrical faults are more of a concern with high-voltage electrical cabinets ([i.e., l 480 volts (V) and above)]. High- voltageHigh-voltage cabinets should be provided with                  l adequate spatial separation or substantial physical barriers to minimize the potential for an energetic electrical fault to damage adjacent equipment, cables, or cabinets important to safety.
Rooms containing electrical cabinets important to safety should be provided with area-wide automatic fire detection, automatic fire suppression, and manual fire suppression capability.
Electrical cabinets containing a quantity of combustible materials (e.g., cabling) sufficient to propagate a fire outside the cabinet of fire origin should be provided with in-cabinet automatic fire detection.
The guidance in Regulatory Position 4.1.3 is based on APCSB 9.5-1, CMEB 9.5-1, and Mattson Memo 1983.
4.1.4    HVAC Design                                                                          l l
Suitable design of the ventilation systems can limit the consequences of a fire by            l preventing the spread of the products of combustion to other fire areas. It is important that means be provided to ventilate, exhaust, or isolate the fire area as required and that consideration be given to the consequences of failure of ventilation systemssystem failure caused by the fire,      l causingresulting in a loss of control for ventilating, exhausting, or isolating a given fire area. l Special protection for ventilation power and control cables may be necessary. The power supply and controls for mechanical ventilation systems should be run outside the fire area served by the system where practical.
Release of smoke and gases containing radioactive materials to the environment should be monitored in accordance with emergency plans as described in the guidelines of Regulatory Guide 1.101, Emergency Planning and Preparedness for Nuclear Power Reactors. Any                    l ventilation system designed to exhaust potentially radioactive smoke or gases should be evaluated to ensure that inadvertent operation or single failures will not violate the radiologically controlled areas of the plant design. This should include containment functions for protecting the public and maintaining habitability for operations personnel.
DG-1170, Page 107
 
Fresh air supply intakes to areas containing equipment or systems important to safety l should be located remoteaway from the exhaust air outlets and smoke vents of other fire areas to minimize the possibility of contaminating the intake air with the products of combustion.
l        Where total -flooding gas -extinguishing systems are used, area intake and exhaust l ventilation dampers should be controlled in accordance with NFPA 12 and, NFPA 12A, or NFPA l 2001 to maintain the necessary gas concentration. (ASee also see Regulatory Position 3.3.2 of l this guide.)
l l 4.1.4.1          Combustibility of Filter Media.
l l        Filters for particulate and gaseous effluents may be fabricated of combustible media (e.g.,
HEPA and charcoal filters). The ignition and burning of these filters may result in a direct release of radioactive material to the environment, or may provide an unfiltered pathway upon failure of the filter. Filter combustion may spread fire to other areas.
Engineered safety feature filters should be protected in accordance with the guidelines of l Regulatory Guide 1.52, Design, Inspection, and Testing Criteria for Air Filtration and l Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup System l Light-Water-Cooled Nuclear Power Plants. Any filter that includes combustible materials and is a potential exposure fire hazard that may affect components important to safety should be protected as determined by the fire hazards analysis.
l l
l        4.1.4.2          Smoke Control/Removal.
l l        Smoke from fires can be toxic, corrosive, and may obscure visibility for emergency egress and access to plant areas. Smoke control and removal may be necessary to support l manual suppression activities and safe -shutdown operations.
Consideration should be given to the installation of automatic suppression systems as a l means of limitingto limit smoke and heat generation. Smoke and corrosive gases should generally be discharged directly outside to an area that will not affect plant areas important to l safety. The normal plant ventilation system may be used for this purpose, if capable and available. To facilitate manual firefighting, separate smoke and heat vents should be l providedconsidered in specific areas such as cable spreading rooms, diesel fuel oil storage areas, l switchgear rooms, and other areas where the potential exists for heavy smoke conditions. (sSee l NFPA 204, "GuideStandard for Smoke and Heat Venting," for additional guidance on smoke l control.).
l        4.1.4.3          Habitability.
l l        Protection of plant operations staff from the effects of fire and fire suppression (e.g.,
gaseous suppression agents) may be necessary to ensure safe shutdown of the plant. For control room evacuation, egress pathways and remote control stations should also be habitable.
DG-1170, Page 108
 
Consideration should be given to protection of safe -shutdown areas from infiltration of gaseous    l suppression agents. The capability to ventilate, exhaust, or isolate is particularly important to ensure the habitability of rooms or spaces that should be attended in an emergency. In the design, provision should be made for personnel access to and escape routes from each fire area.
Habitability of the following areas should be considered.:                                          l C      Ca. control room                                                                        l l
: b.      Ppost-fire safe -shutdown areas                                                            l l
: c.      Ppersonnel access and egress pathways                                                      l l
Stairwells should be designed to minimize smoke infiltration during a fire. Staircases may serve as escape routes and access routes for fire fightingfirefighting. Fire exit routes should l be clearly marked. Stairwells, elevators, and chutes should be enclosed in fire-rated construction with automatic fire doors at least equal to the enclosure construction, at each opening into the building. Elevators should not be used during fire emergencies.
4.1.4.4        Fire Dampers.                                                              l l
Redundant safe -shutdown components may be separated by fire-resistant walls, floors,      l enclosures, or other types of barriers. For the fire barriers to be effective in limiting the propagation of fire, ventilation duct penetrations of fire barriers should be protected by means of fire dampers that are arranged to automatically close in the event of fire. Additional guidance is provided in NFPA 90A, "StandardStandard for the Installation of Air Conditioning and              l Ventilating Systems, provides additional guidance." (ASee also see Regulatory Position            l 4.2.1.3.)
The guidance in Regulatory Position 4.1.4 is based on CMEB 9.5-1 and IN 83-69.
4.1.5 Drainage of this guide.)                                                              l l
4.1.5  Drainage                                                                                    l l
Floor drains sized to remove expected firefighting water without flooding equipment important to safety should be provided in areas where fixed water fire suppression systems are installed. Floor drains should also be provided in other areas where hand hose lines may be used if such firefighting water could cause unacceptable damage to equipment important to safety in the area. Facility design should ensure that fire water discharge in one area does not impact equipment important to safety in adjacent areas. Housekeeping procedures should ensure that        l drains are not blocked by accumulated dirt or other debris.                                        l Where gasgaseous suppression systems are installed, the drains should be provided with      l adequate seals or the gas suppression system should be sized to compensate for the loss of the suppression agent through the drains. (sSee Regulatory Position 3.3.2 of this guide.).              l DG-1170, Page 109
 
l        DrainsDrainage in areas containing combustible liquids should have provisions for l preventing the backflow ofequipment important to safety should be designed to minimize the l potential to propagate fire from areas containing flammable or combustible liquids to plant areas l important to safety throughvia the interconnected drain drainage systems.
Water drainage from areas that may contain radioactivity should be collected, sampled, and analyzed before discharge to the environment.
The guidance in Regulatory Position 4.1.5 is based on CMEB 9.5-1.
l        4.1.6 Emergency Lighting l
l        Emergency lighting should be provided throughout the plant as necessary to support fire l suppression actions, and safe -shutdown operations, including access and emergency egress l pathways to safe-shutdown areas during a fire event.
l        4.1.6.1        Egress Safety.
l l        Emergency lighting should be provided in support of the emergency egress design l guidelines in outlined in Regulatory Position 4.1.2.3 of this guide.
DG-1170, Page 110
 
4.1.6.2        Post-Fire Safe -Shutdown.                                                    l l
Lighting is vital to post-fire safe -shutdown and emergency response in the event of fire. l SThe licensee should provide suitable fixed and portable emergency lighting should be provided,        l as follows.
:                                                                                                      l
: a.      Fixed, self-contained lighting consisting of fluorescent or sealed-beam units with            l individual 8-hour minimum battery power supplies should be provided in areas needed for operation of safe -shutdown equipment and for access and egress routes thereto.          l The level of illumination provided by emergency lighting in access routes to and in areas where shutdown functions are 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, NUREG-0800. If a licensee has provided emergency lighting perin accordance with Section III.J of Appendix R to 10 CFR Part 50, the licensee should      l verify by field testing that this lighting is adequate to perform the intended tasks.
Routine maintenance and initial and periodic field testing of emergency lighting systems should ensure their ability to support access, egress, and operations activities for the full 8-hour period accounting for anticipated environmental conditions, battery conditions, and bulb life.
: b.      Suitable sealed-beam battery-powered portable hand lights should be provided for emergency use by the fire brigade and other operations personnel required to achieve safe plant shutdown.
If emergency lights are powered from a central battery or batteries power the emergency      l lights, the distribution system should contain such protective devices thatnecessary to preclude a    l fire in one area will not causefrom causing a loss of emergency lighting in any unaffected area        l neededrequired for safe -shutdown operations.                                                          l The guidance in Regulatory Position 4.1.6 is based on Appendix R to 10 CFR Part 50, CMEB 9.5-1, GL 86-10, IN 95-36, IP 64100, TI 2515/62, and Vollmer Memo 1983b.
4.1.7  Communications                                                                        l l
The communication system design should provide effective communication between                l plant personnel in all vital areas during fire conditions under maximum potential noise levels.
DG-1170, Page 111
 
Two-way voice communications are vital to safe shutdown and emergency response in l the event of fire. Suitable communication devices should be provided, as follows.:
: a.      Fixed emergency communications independent of the normal plant communication system should be installed at preselected stations.
: b.      A portable radio communications system should be provided for use by the fire brigade l        and other operations personnel required to achieve safe plant shutdown. This system should not interfere with the communications capabilities of the plant security force.
Fixed repeaters installed to permit use of portable radio communication units should be l        protected from exposure fire damage. Pre-operational and periodic testing should demonstrate that the frequencies used for portable radio communication will not affect the actuation of protective relays.
The guidance in Regulatory Position 4.1.7 is based on NUREG-0800 and CMEB 9.5-1.
l        4.1.8    Explosion Prevention l
l        In situ and transient explosion hazards should be identified and suitable protection provided. Transient explosion hazards that cannot be eliminated should be controlled and l suitable protection provided. (See Regulatory Position 2.1 of this guide regarding control of combustibles.)
Miscellaneous storage and piping for flammable or combustible liquids or gases should not create a potential exposure hazard to systems important to safety or the fire protection l systems that serve those areas. (ASee also see Regulatory Positions 2.1.3 and 7.5 of this guide.)
Systems or processes that involve hydrogen supplies (e.g., generator cooling systems and reactor coolant hydrogen addition systems) and those that may evolve hydrogen or explosive gases (e.g., waste gas and solid radioactive waste processing systems) should be designed to prevent development of explosive mixtures by limiting the concentration of explosive gases and l vapors within enclosures to less than 50%50 percent of the lower explosive limit, or by limiting oxygen within systems containing hydrogen. Hydrogen distribution and supply systems should include design features that mitigate the consequences of system damage, such as excess flow valves or flow restrictors, double-walled pipe with annulus leak detection, and rupture l diaphragms. (ASee also see Regulatory Position 7.5 of this guide.)
The construction, installation, operation, and maintenance of bulk gas (including liquefied gas) storage and the related loading and dispensing systems should comply with good l industry practice and the relevant NFPA Sstandards, as applicable (e.g., NFPA 50A, Standard for Gaseous Hydrogen Systems at Consumer Sites, NFPA 50B, "Standard for Liquefied l Hydrogen Systems at Consumer Sites,"54 and NFPA 54, "National Fuel Gas Code"55).
l        If the potential for an explosive mixture of hydrogen and oxygen exists in off gasoffgas systems, the systems should either be designed to withstand the effects of a hydrogen explosion DG-1170, Page 112
 
or be provided with dual gas analyzers with automatic control functions to preclude the formation or buildup of explosive mixtures.
The guidance in Regulatory Position 4.18 is in NUREG-0800 and CMEB 9.5-1.
4.2    Passive Fire ResistiveNFPA 69 is the applicable standard for explosion prevention            l systems.                                                                                            l l
Revision 1of Regulatory Guide 1.91, Evaluations of Explosions Postulated to Occur on        l Transportation Routes Near Nuclear Power Plants, provides guidance for the assessment of            l explosion hazards related to transportation near the plant site.                                    l l
4.2    Passive Fire-Resistive Features                                                              l l
4.2.1  Structural Fire Barriers                                                            l l
Fire barriers are those components of construction (walls, floors, and their supports),      l including beams, joists, columns, penetration seals or closures, fire doors, and fire dampers that are rated by approving laboratories in hours of resistance to fire and are used to prevent the spread of fire.
Where exact replication of a tested configuration cannot be achieved, the field installation should meet all of the following criteria.
:                                                                                                    l
: a.      The continuity of the fire barrier material is maintained; .                        l
: b.      The thickness of the barrier is maintained;.                                        l
: c.      The nature of the support assembly is unchanged from the tested configuration;.      l
: d.      The application or "endend use" of the fire barrier is unchanged from the tested  l configuration;.                                                                      l
: e.      The configuration has been reviewed by a qualified fire protection engineer and found to provide an equivalent level of protection.
l New reactor designs should be based on providing structural barriers between redundant      l safe-shutdown success paths wherever feasible and should minimize the reliance on localized          l electrical raceway fire barrier systems, as described in Regulatory Position 4.2.3 of this guide. l This approach is in accordance with the enhanced fire protection criteria for new reactors          l described in Regulatory Position 8.2 of this guide.                                                  l DG-1170, Page 113
 
l l        See Regulatory Position 4.1.2 of this guide for additional guidance on the design of fire l barriers relative to compartmentationcompartmentalization and separation of equipment.
l        4.2.1.1          Wall, Floor, and Ceiling Assemblies.
l l        Wall, floor, and ceiling construction should be noncombustible. (sSee Regulatory l Position 4.1.1 of this guide.). NFPA 221, "StandardStandard for High-Challenge Fire Walls and l Fire Barrier Walls," can be used as guidance for construction of fire barrier walls. Materials of construction for walls, floors, and ceilings serving as fire barriers should be rated by approving laboratories in hours of resistance to fire.
Building design should ensure that openings through fire barriers are properly protected.
Openings through fire barriers that separate fire areas should be sealed or closed to provide a fire l -resistance rating at least equal to that required of the barrier itself. The construction and installation techniques for penetrations through fire barriers should be qualified by fire endurance l tests. (see RegulatorySee Regulatory Position 4.2.1.5, Testing and Qualification of this guide.).
l        4.2.1.2          Fire Doors.
l l        Building design should ensure that door openings are properly protected. These openings should be protected with fire doors that have been qualified by a fire test. The construction and installation techniques for doors and door openings through fire barriers should be in l accordanceconsistent with the door manufacturers recommendations and the tested configuration.
Modifications to fire doors should be evaluated. Where a door is part of a fire area l boundary, and a modification does not affect the fire rating (for examplee.g., installation of l security "contacts"contacts), no further analysis need be performed. If the modifications could l reduce the fire rating (for examplee.g., installation of a vision panel), the fire rating of the door l should be reassessed to ensure that it continues to provide an equivalenta level of protection l equivalent to a rated fire door.
Fire doors should be self-closing or provided with closing mechanisms and should be inspected semiannually to verify that automatic hold-open, release, and closing mechanisms and l latches are operable. One of the following measures should be provided to ensure theythat the l fire doors will protect the opening as required in case of fire.:
: a.      Fire doors should be kept closed and electrically supervised at a continuously manned l        location;.
: b.      Fire doors should be locked closed and inspected weekly to verify that the doors are in the closed position; DG-1170, Page 114
 
.                                                                                                    l
: c.      Fire doors should be provided with automatic hold-open and release mechanisms and            l inspected daily to verify that doorways are free of obstructions; or.                        l
: d.      Fire doors should be kept closed and inspected daily to verify that they are in the closed position.
Areas protected by automatic total flooding gas suppression systems should have electrically supervised self-closing fire doors or should satisfy option (a) above.
Additional guidance for fire doors is provided in NFPA 80, "StandardStandard for Fire        l Doors and Fire Windows."                                                                            l 4.2.1.3        Fire Dampers.                                                                l l
Building design should ensure that ventilation openings are properly protected. These        l openings should be protected with fire dampers that have been fire tested. In addition, the construction and installation techniques for ventilation openings through fire barriers should be qualified by fire endurance tests. For ventilation ducts that penetrate or terminate at a fire wall, guidance in NFPA 90A indicates that ventilation fire dampers should be installed within the fire wall penetration for barriers with a fire rating greater than or equal to 2 hours. NFPA 90A requires that fire dampers be installed in all air transfer openings within a rated wall.
Until recently, the only industry standard governing the design, fabrication, and testing of fire dampers was Underwriters Laboratories, Inc. (UL)UL Standard 555, "FireFire Dampers and          l Ceiling Dampers." The standard does not evaluate whether or not fire dampers will close under        l air flowairflow conditions. Therefore, the UL fire damper rating only indicates whether a fire        l damper in the closed position will maintain its integrity under fire conditions for a specific time period.
Fire damper testing methods that do not simulate the actual total differential pressure at the damper (i.e., visual inspection or drop testing with duct access panels open) may not show operability under air flowairflow conditions. Fire damper surveillance testing should model air      l flowairflow to ensure that the dampers will close fully when called upon to do so. This can be        l addressed by (1) type testing "worst-case" air flowworst-case airflow conditions of                l plant-specific fire damper configurations, (2) testing under air flowairflow conditions all dampers  l installed in required fire barriers, or (3) administratively shutting down the ventilation systems to an area upon confirmation of a fire. The last approach should be incorporated into plant emergency procedures should incorporate the latter approach.                                          l DG-1170, Page 115
 
l        4.2.1.4          Penetration Seals.
l l        Openings through fire barriers for pipe, conduit, and cable trays that separate fire areas l should be sealed or closed to provide a fire -resistance rating at least equal to that required of the l barrier itself. Openings inside conduit larger than 102 mm (4 inchesin.) in diameter should be l sealed at the fire barrier penetration. Openings inside conduit 102 mm (4 inches4 in.) or less in diameter should be sealed at the fire barrier unless the conduit extends at least 1.5 m (5 feet) on each side of the fire barrier and is sealed either at both ends or at the fire barrier with material to prevent the passage of smoke and hot gases. Fire barrier penetrations that maintain environmental isolation or pressure differentials should be qualified by test to maintain the barrier integrity under such conditions.
l        Penetration seals should be installed by qualified individuals, who are trained and l acertified by the manufacturer. Appropriate quality assurance/quality controlQA/QC methods should be in force during installation. As part of the installation process, penetration seals should l be specifically labeled and documented then inspected to ensure that the seal does not contain l voids, gaps, and splitshas been installed in accordance with its design.
l        4.2.1.5          Testing and Qualification l
l a.              Structural Ffire Barriers l        ThebarriersThe design adequacy of fire barrier walls, floors, ceilings, and enclosures l        should be verified by fire endurance testing. The NRC fire protection guidance refers to l        the guidance of NFPA 251 and ASTM E-119, "StandardStandard Test Methods for Fire l        Tests of Building Construction and Materials," as acceptable test methods for demonstrating fire endurance performance. The guidance of NFPA 251 and ASTM E-119 should be consulted with regard to construction, materials, workmanship, and details such as dimensions of parts and the size of the specimens to be tested. In addition, NFPA 251 and ASTM E-119 should be consulted with regard to the placement of thermocouples on the specimen.
l        The following represent the fire endurance test acceptance criteria for wall, floor, ceiling, and enclosure fire barriers are:
l        C        i.      The fire barrier design has withstood the fire endurance test without the passage of flame or the ignition of cotton waste on the unexposed side for l                          a period of time equivalent to the fire -resistance rating required of the barrier; l .
l        C        ii. The temperature levels recorded on the unexposed side of the fire barrier l                          are analyzed and demonstrablte that the maximum temperature does not l                          exceed 139&deg; EC [250&deg;F](250 EF) above the ambient; and DG-1170, Page 116
 
atmosphere.                                                                                      l C      iii. The fire barrier remains intact and does not allow projection of water    l beyond the unexposed surface during the hose stream test.
If the above criteria are met for fire barrier walls, floors, ceilings, and free -  l standing equipment enclosures separating safe -shutdown functions within the        l same fire area, the barrier is acceptable.
: b.            Penetration Ffire Barriers                                                          l PenetrationbarriersPenetration fire barriers should be qualified by tests conducted by an l independent testing authority in accordance with the provisions of NFPA 251 and ASTM E-119, "Standard Test Methods for Fire Tests of Building Construction and Materials."or    l ASTM E-119. In addition, ASTM E-814, "StandardStandard Test Method for Fire Tests        l of Through-Penetration Fire Stops," or IEEE Standard 634, "IEEE Standard Cable          l Penetration Fire Stop Qualification Test," could be used in the development of a          l standard fire test.
DG-1170, Page 117
 
l The acceptance criteria for the test are as follows:
l C        i. The fire barrier design has withstood the fire endurance test without passage of flame or the ignition of cables on the unexposed side for a l                period of time equivalent to the fire resistance -rating required of the barrier.
l C        ii. The temperature levels recorded for the unexposed side of the fire barrier are analyzed and demonstrate that the maximum temperature does not l                exceed 181&deg; EC (325&deg; EF) or 139&deg; EC (250&deg; EF) above the ambient l                temperature. Higher temperatures at through -penetrations may be permitted when justified in terms of cable insulation ignitability.
l C        iii. The fire barrier remains intact and does not allow projection of water l                beyond the unexposed surface during the hose stream test. The stream l                should be delivered through(1) through a 38 -mm (1-1/2-inch1.5-in.)
l                nozzle set at a discharge angle of 30%30 percent with a nozzle pressure of 517 kPa (75 psi) and a minimum discharge of 284 L/m (75 gpm) with the l                tip of the nozzle a maximum of 1.5 m (5 ft) from the exposed face;, or the l                stream should be delivered(2) through a 38 -mm (1-1/2-inch1.5-in.) nozzle l                set at a discharge angle of 15%15 percent with a nozzle pressure of 517 kPa (75 psi) and a minimum discharge of 284 L/m (75 gpm) with the tip of l                the nozzle a maximum of 3 m (10 ft) from the exposed face;, or the stream l                should be delivered(3) through a 64 -mm (2-1/2-inch2.5-in.) national l                standard playpipe equipped with 29 -mm (1-1/8-inch1c-in.) tip, nozzle l                pressure of 207 kPa (30 psi), located 6.1 m (20 ft) from the exposed face.
l                The construction and installation techniques for door and ventilation openings and other penetrations through fire barriers should be qualified by fire endurance tests. The test specimen should be truly representative of the construction for which classification is desired as to materials, workmanship, and details such as dimensions of parts, and should be built under conditions representative of those obtaining as practically applied in building construction and operation. The physical properties of the materials and ingredients used in the test specimen should be determined and recorded.
In view of the large number of possible penetration seal configurations, it may not be practical to test every penetration configuration. The following section provides l guidance on evaluation ofevaluating penetration seal designs against the results of limited fire test programs.
l l
l 4.2.1.6        Evaluation of Penetration Seal Designs with Limited Testing.
DG-1170, Page 118
 
The results of fire test programs that include a limited selection of test specimens that    l have been specifically designed to encompass or bound the entire population of in-plant penetration seal configurations may be acceptable. In such cases, the engineering evaluation performed to justify the seal designs should consider the following.
:                                                                                                    l
: a. Size of sealed opening  InopeningIn some cases, a successful fire endurance test of a      l particular fire barrier penetration seal configuration for a particular size opening may be used to justify the same configuration for smaller openings.
: b. Penetrating items  AitemsA satisfactory test of a seal configuration that contains a        l particular pattern of penetrating items can be used to qualify variations on the tested pattern. Variations that are acceptable include eliminating or repositioning one or more of the penetrating items, reducing the size (cross-sectional area) of a particular penetrating item, or increasing the spacing between penetrating items. However, since penetrating items provide structural support to the seal, the free area of the seal material and the dimensions of the largest free span may also be factors that affect the fire-resistive performance of the seal assembly. The thickness of the seal material needed to obtain a particular fire rating may also be a function of the free area or the distance between the penetrating items and the outside edge of the seal assembly. In other cases, consideration of the penetrating items takes on special performanceimportance because of      l the heat sink they provide.
: c. Cable type and fill  AfillA satisfactory test of a seal configuration with certain          l electrical penetrations containing a specified fill ratio and cable type can be used to qualify similar configurations containing the same or a smaller cable fill ratio and the same cable jacket material or a less combustible jacket material. The thermal conductivity of the penetrating cables is also important.
: d. Damming materials  ThematerialsThe fire -resistive performance of a given seal              l configuration can be improved if a fire-resistant damming material covers one or both surfaces of the seal. A satisfactory test of a seal configuration without a permanent fire-resistant dam can be used to qualify the same configuration with a permanent fire-resistant dam, all other seal attributes being equal. The converse is not true.
: e. Configuration orientation  AorientationA satisfactory test of a particular seal            l configuration in the horizontal orientation (with the test fire below the seal) can be used to qualify the same configuration in a vertical orientation if the symmetry of the design configurations are comparable. For example, if a non-symmetric penetration seal configuration (e.g., a seal with a damming board on the bottom, but not on the top) is qualified for a floor-ceiling orientation with the damming board on the fire side of the test DG-1170, Page 119
 
specimen, the configuration could only be qualified for a wall orientation if a damming board was installed on both sides of the seal or if the potential fire hazard is limited to the side with the damming board.
l f.      Material type and thickness  SatisfactorythicknessSatisfactory testing of a particular seal configuration with a specific seal material thickness can be used to qualify the same configuration with a greater seal material thickness of the same type of seal material. The converse is not true.
l g.      Type testing  IntestingIn cases in which a single test of a particular seal configuration is to serve as a qualification test for the same or similar design configurations with different design parameters, the tested configuration should be the worst-case design configuration with the worst-case combination of design parameters. This would test and l          qualify a condition that would fail first, if failure occurs at all. Successful testing of the l          worst-case condition can then serve to qualify the same or similar design configurations for design parameters within the test range. It would be appropriate to conduct multiple tests to assess a range of design parameters.
The guidance in Regulatory Position 4.2.1 is based on Appendix R to 10 CFR Part 50, CMEB 9.5-1, NUREG-1552, Supplement 1 to NUREG 1552, GL 86-10, Supplement 1 to GL 86-10, IN 83-69, IN 88-04, IN 88-56, and IN 89-52.
l          4.2.2 4.2.2      Structural Steel Protection.
l l          Structural steel forming a part of or supporting fire barriers should be protected to provide fire resistance equivalent to that required of the barrier. Where the structural steel is not protected and has a lower fire rating than the required rating of the fire barrier, the configuration l should be justified by a fire hazards analysis that showsshould justify the configuration by l demonstrating the temperature that the steel will reach during fire and the ability of the steel to carry the required loads at that temperature. The need to protect structural steel that forms a part of or supports fire barriers is consistent with sound fire protection engineering principles as l delineated in NFPA codes and standards and the NFPA FireFire Protection Handbook.
Structural steel whose sole purpose is to carry dynamic loads from a seismic event need not be protected solely to meet fire barrier requirements, unless the failure of any structural steel member owing to a fire could result in significant degradation of the fire barrier.
The guidance in Regulatory Position 4.2.2 is based on CMEB 9.5-1, GL 88-33, and GL 86-10.
l          4.2.3 Fire Resistive l
DG-1170, Page 120
 
4.2.3  Fire-Resistive Protection for Electrical Circuits                                            l l
4.2.3.1        Electrical Raceway Fire Barrier Systems.                                              l l
Redundant cable systems important to safety should be separated from each other and          l from potential fire exposure hazards in non-safety-related areas in accordance with the separation means of Regulatory Position 5.5.a-ca-c of this guide. ForIn areas where the separation of            l electrical circuits important to post-fire safe -shutdown cannot be accomplished viaby means of      l rated structural fire barriers, cable protection assemblies haveshould been applied to conduit and    l cable trays to meet 1-hour and 3-hour separation requirements, as required. Where 1-hour fire-        l resistive barriers are applied, automatic fire detection and suppression should also be installed. l The design of fire barriers for horizontal and vertical cable trays should meet the requirements of ASTM E119,E-119 including a hose stream test. TRegulatory Position 4.3.2 of          l this guide discusses the acceptance criteria for raceway fire barriers is discussed in Regulatory    l Position 4.3.2 to this guide.
4.2.3.2          Fire -Rated Cables.                                                          l l
Licensees should request an exemption or deviation, as appropriate, when relying on fire -    l rated cables to meet NRC requirements for protection of safe -shutdown systems or components          l from the affectseffects of fire. (See Regulatory Position 1.8 of this guide.)                        l 4.2.3.3          Fire Stops for Cable Routing.                                                l l
Fire stops should be installed every 6.1 m (20 feet) along horizontal cable routings in      l areas important to safety that are not protected by automatic water systems. Vertical cable routings should have fire stops installed at each floor/-ceiling level. Between levels or in vertical l cable chases, fire stops should be installed at the mid-height if the vertical run is 6.1 m (20 feet) or more, but less than 9.1 m (30 feet) or at 4.6 -m (15-foot) intervals in vertical runs of 9.1 m (30 l feet) or more unless such vertical cable routings are protected by automatic water systems directed on the cable trays. Individual fire stop designs should prevent the propagation of a fire for a minimum period of 30 minutes when tested for the largest number of cable routings and maximum cable density.
4.3    Testing and Qualification of Electrical Raceway Fire Barrier Systems                          l 4.3.1  Electrical Raceway Fire Barrier Systems: General Guidelines                          l l
Fire barriers relied upon to protect post-fire shutdown-related systems and to meet the      l separation means ofdiscussed in Regulatory Position 5.53 should have a fire rating of either 1 or    l 3 hours. Fire rating is defined as the endurance period of a fire barrier or structure; it defines,  l which relates to the period of resistance to a standard fire exposure before the first critical point l in behavior is observed.
DG-1170, Page 121
 
Fire endurance ratings of building construction and materials are demonstrated by testing fire barrier assemblies in accordance with the provisions of the applicable sections of NFPA 251 and ASTM E-119. Assemblies that pass specified acceptance criteria (e.g., standard time-temperature fire endurance exposure, unexposed side temperature rise, and hose stream l impingement) are considered to have a specific fire -resistance rating.
l        The basic premise of the fire -resistance criteria is that those fire barriers that do not l exceed 181&deg; EC [325&deg;F](325 EF) cold -side temperature(5) and pass the hose stream test provide reasonable assurance that the shutdown capability is protected without further analyses. If the temperature criterion is exceeded, sufficient additional information is needed to perform an engineering evaluation to demonstrate that the shutdown capability is protected.
l        4.3.2      Fire Endurance Test Acceptance Criteria for Electrical Raceway and l                    Component Fire Barrier Systems for Separating Safe -Shutdown Functions l                    Wwithin the Same Fire Area l
l        The fire endurance qualification test for fire barrier materials applied directly to a raceway or component is considered to be successful if all three of the following conditions are l met.:
l 1.      a.        The average unexposed side temperature of the fire barrier system, as measured l                    on the exterior surface of the raceway or component, did not exceed 139&deg; EC l                    [250&deg;F](250 EF) above its initial temperature; and l .
(NFPA 251 and ASTM E-119 allow this temperature to be determined by averaging l        thermocouple temperature readings. For the purposes of this criterion, the licensee may l        use thermocouple averaging can be used providedif similar series of thermocouples (e.g.,
cable tray side rail) are averaged together to determine temperature performance of the raceway fire barrier system. In addition, conditions of acceptance are placed on the temperatures measured by a single thermocouple. If any single thermocouple exceeds 30 l        percent of the maximum allowable temperature rise (i.e., 139&deg; EC + 42&deg; EC = 181&deg; EC l        [(250&deg; EF + 75&deg; EF = 325&deg;F]325 EF), the test exceeded the temperature criteria limit.)
l 2.      b.        Irrespective of the unexposed side temperature rise during the fire test, if cables or components are included in the fire barrier test specimen, a visual inspection is l 5 WhenThe 181 EC (325 EF) temperature condition was established by allowing the temperature criteria are exceeded or l        damage occurs, component operability at the temperatures experiencedof the unexposed side of the fire barrier to rise l        139 EC (250 EF) above the assumed 24 EC (75 EF) ambient air temperature, as measured by the thermocouples within l        the test specimen at the onset of the fire exposure during the fire test should be assessed. Fire endurance tests that are judged acceptable on the basis of a visual inspection of specific components or cables included in the test specimen may not be applied to other components or cables without a specific evaluation.
DG-1170, Page 122
 
performed.(6) Cables should not show signs of degraded conditions(7) resulting from the thermal effects of the fire exposure; and
.                                                                                                                              l (When signs of thermal degradation are present, the fire barrier did not perform its intended fire-resistive function. For barriers that are not capable of performing their intended function, an engineering analysis that demonstrates that the functionality of thermally degraded cables or components was maintained and that the cables or components would have adequately performed their intended functions during and after a                                l postulated fire exposure should be performed. A methodology for demonstrating the functionality of cables during and after a fire test exposure is provided below. The purpose of the functionality tests is to justify observed deviations in fire barrier performance. For fire barrier test specimens that are tested without cables, an engineering analysis justifying internal fire barrier temperature conditions greater than allowed can be based on a comparison of the fire barrier internal temperature profile measured during the fire endurance test to existing cable specific performance data, such as environmental qualification (EQ) tests.)
: 3.      c.          The cable tray, raceway, or component fire barrier system remained intact during                          l the fire exposure and water hose stream test without developing any openings through which the cable tray, raceway, or component (e.g., cables) is visible. (See                        l Regulatory Position 4.3.3 of this guide regarding acceptable hose stream test                              l methods.)
l The test specimen should be representative ofrepresent the construction for which the fire                            l rating is desired as to materials, workmanship, and details, such as dimensions of parts, and                                  l should be built under representative conditions. Raceway fire barrier systems being subjected to qualification fire endurance tests should be representative ofrepresent their end use. For                                    l example, if it isthe licensee intendeds to install a cable tray fire barrier system in the plant                              l without protecting the cable tray supports, the test program should duplicate these field conditions. In addition, the fire test program should encompass or bound raceway sizes and the various configurations for those fire barrier systems installed in the plant. It should be noted that sSeveral test specimens will be required in order to qualify various sizes of horizontal and                                  l 6
Examples of thermal cable degradation are jacket swelling, splitting, cracking, blistering, melting, or discoloration; shield exposed; conductor insulation exposed, degraded, or discolored; bare copper conductor exposed. When the        l temperature criteria are exceeded or damage occurs, component operability at the temperatures experienced during the  l fire test should be assessed. Fire endurance tests that are judged acceptable on the basis of a visual inspection of  l specific components or cables included in the test specimen may not be applied to other components or cables without  l a specific evaluation.                                                                                                l 7
For the thermocouples installed on conduits, cable tray side rails,Examples of thermal cable degradation are jacket    l swelling, splitting, cracking, blistering, melting, or discoloration; shield exposed; conductor insulation exposed,    l degraded, or discolored; and bare copper conductors, a +13 mm [+ 1/2 inch] installation tolerance is                    l acceptable.conductor exposed.                                                                                          l DG-1170, Page 123
 
l vertical runs of cable trays and conduits, junction boxes and pull boxes, etcand similar l configurations. The cable tray or raceway design used for the tests should be constructed with materials and configurations representative of in-plant conditions (e.g., the mass associated with l typical steel conduits and cable trays, representative internal and external penetration seals). If cables are included in the raceway fire barrier test specimen, these cables should be l representative ofrepresent the installed plant-specific cables.
Measuring cable temperatures is not a reliable means for determining excessive temperature conditions that may occur at any point along the length of the cable during the fire test. In lieu of measuring the unexposed surface temperature of the fire barrier test specimen, methods that will measure the surface temperature of the raceway (e.g., exterior of the conduit, side rails of cable trays, bottom and top of cable tray surfaces, junction box external surfaces) can be considered as equivalent if the raceway components used to construct the fire test specimen l represent plant-specific components and configurations. The metal surfaces of the raceway, under fire test conditions, exhibit good thermal conductivity properties. Temperatures measured on these surfaces provide an indication of the actual temperature rise within the fire barrier system.
In 1979, American Nuclear Insurers (ANI) issued a fire endurance test method for raceway fire barrier systems for insurance purposes. This method, "Fire Endurance Protective Envelope Systems for Class 1E Electrical Circuits" (ANI Test), specified that cable temperatures be monitored by thermocouples. Since cable jackets have a low thermal conductivity, the actual local temperatures of the cable jackets indications of barrier failure and internal fire barrier temperature rise conditions during the fire exposure are masked. Monitoring cable temperatures can give indications of low internal fire barrier temperature conditions during the fire endurance test. Using this temperature monitoring approach, cable damage can occur without indication of excessive temperatures on the cables. This, linked with no loss of circuit integrity, would give l indications ofindicates a successful test. The staff considers monitoring the cable temperature as the primary means of determining cable tray or raceway fire barrier performance to be l nonconservative. Therefore, the staff has incorporated the provision for a post--fire visual inspection of cables that are installed in fire barrier test specimens. As discussed above, temperatures monitored on the exterior surface of the raceway provide a more representative indication of fire barrier performance.
l        Fire endurance tests of raceway fire barrier systems shouldmay be performed with or l without cables in the raceway. This method is preferred because by eExcluding cables from the l test specimen it eliminates bias in the test results created by the thermal mass of the cables and is l the NRC-preferred method. Without thise thermal mass of the cables, the internal temperature conditions measured by the test specimen thermocouples during the fire exposure will provide a l more accurate determination of fire barrier thermal performance. The following sections provide l guidance for both approaches.
l DG-1170, Page 124
 
4.3.2.1            Thermocouple Placement  TestPlacementTest Specimens Containing                                      l Cables.                                                                                                                  l l
The following are acceptable placements of thermocouples for determining the thermal                            l performance of raceway or cable tray fire barrier systems that contain cables during the fire exposure.:                                                                                                              l
: a.      Conduits  TheConduitsThe temperature rise on the unexposed surface of a fire                                  l barrier system installed on a conduit should be measured by placing the thermocouples every 152 mm [(6 inches]in.)(8) on the exterior conduit surface underneath the fire barrier                      l material. The thermocouples should be attached to the exterior conduit surface located                          l opposite the test deck and closest to the furnace fire source. Thermocouples should also                        l be placed immediately adjacent to all structural members, supports, and barrier                                  l penetrations.                                                                                                    l
: b.      Cable traysThe temperature rise on the unexposed surface of a fire barrier system                              l installed on a cable tray should be measured by placing the thermocouples on the exterior                        l surface of the tray side rails between the cable tray side rail and the fire barrier material.                  l In addition to placing thermocouples on the side rails, thermocouples should be attached                        l to two AWG 8-stranded bare copper conductors. The first copper conductor should be                              l installed on the bottom of the cable tray rungs along the entire length and down the                            l longitudinal center of the cable tray run. The second conductor should be installed along                        l the outer top surface of the cables closest to the top and toward the center of the fire                        l barrier. Thermocouples should be placed every 152 mm (6 in.) down the longitudinal                              l center along the outside surface of the cable tray side rails and along the bare copper                          l conductors. Thermocouples should also be placed immediately adjacent to all structural                          l members, supports, and barrier penetrations.
: b.      Cable Trays  c.                Junction boxesThe temperature rise on the unexposed surface of                  l a fire barrier system installed on junction boxes should be                      l measured by placing thermocouples on either the inside or the                    l outside of each junction box surface. Each junction box surface or              l face should have a minimum of one thermocouple, located at its                  l geometric center. In addition, one thermocouple should be                        l installed for every 0.9 m2 (1 ft2) of junction box surface area.                l These thermocouples should be located at the geometric centers of                l the 0.9-m2 (1-ft2) areas. At least one thermocouple should also be              l placed within 25 mm (1 in.) of each penetration                                  l connector/interface.                                                            l 8
The review guidance for Megger and Hi-Pot test voltages was derived from IEEE 383-1974 and IEEE 690-1984.For    l the thermocouples installed on conduits, cable tray side rails, and bare copper conductors, a +13 mm [+ 0.5 in.] l installation tolerance is acceptable.                                                                            l DG-1170, Page 125
 
l d. AirdropsThe internal airdrop temperatures should be measured by thermocouples l    placed every 305 mm (12 in.) on the cables routed within the airdrop and by a stranded l    AWG 8 bare copper conductor routed inside and along the entire length of the airdrop l    system with thermocouples installed every 152 mm (6 in.) along the length of the copper l    conductor. The copper conductor should be in close proximity to the unexposed surface l    of the fire barrier material. Thermocouples should also be placed immediately adjacent to l    all supports and barrier penetrations.
l DG-1170, Page 126
 
4.3.2.2 Thermocouple PlacementTest Specimens without Cables                                          l l
The following are acceptable thermocouple placements for determining the thermal              l performance of raceway or cable tray fire barrier systems that do not contain cables.                l l
Text Moved Here: 7                                                                                    l
: a.      Conduits  The          ConduitsThe temperature rise of the unexposed surface of a fire      l barrier system installed on a conduit should be measured by placing thermocouples every 152 mm [(6 inches]in.) on the            l exterior conduit surface between the conduit and the unexposed surface of the fire barrier material. These thermocouples should be attached to the exterior conduit surface opposite the test deck and closest to the furnace fire source. The internal raceway temperatures should be measured by a stranded AWG 8 bare copper conductor routed through the entire length of the conduit system with thermocouples installed every 152 mm [(6 inches]in.)      l along the length of the copper conductor. Thermocouples should also be placed immediately adjacent to all structural members, supports, and barrier penetrations.
: b.      Cable traysTheEnd Of Moved Text                                                              l The temperature rise on the unexposed surface of a fire barrier system installed on a cable tray should be measured by placing the thermocouples every 152 mm (6 in.) on the exterior surface of      l theeach trays side rails between the cable tray side rail and the fire barrier material. In addition l to placing thermocouples on the side rails, thermocouples should be attached to two AWG 8 strandedInternal raceway temperatures should be measured by a stranded AWG 8 bare copper              l conductors. The first copper conductor should be installed routed on the bottomtop of the cable      l tray rungs along the entire length and down the longitudinal center of the cable tray run. The second conductor should be installed along the outer top surface of the cables closest to the top and toward the center of the fire barrier with thermocouples installed every 152 mm (6 in.) along    l the length of the copper conductor. Thermocouples should be placed every 152 mm (6 inches)            l down the longitudinal center along the outside surface of the cable tray side rails and along the bare copper conductors. Thermocouples should also be placed immediately adjacent to all structural members, supports, and barrier penetrations.
: c.      Junction Boxes (JBs)  TheboxesThe temperature rise on the unexposed surface of a            l fire barrier system installed on junction boxes should be measured by placing thermocouples on either the inside or the outside of each JBjunction box surface. Each        l JBjunction box surface or face should have a minimum of one thermocouple, located at          l its geometric center. In addition, one thermocouple should be installed for every one square foot0.9 m2 (1 ft2) of JBjunction box surface area. These thermocouples should be      l located at the geometric centers of the one square foot0.9-m2 (1-ft2) areas. At least one    l thermocouple should also be placed within 25 mm (1 inch.) of each penetration                l connector/interface.
DG-1170, Page 127
 
l d.      Airdrops  TheAirdropsThe internal airdrop temperatures should be measured by thermocouples placed every 305 mm (12 inches) on the cables routed within the air drop and by a stranded AWG 8 bare copper conductor routed inside and along the entire length l          of the airdrop system with thermocouples installed every 152 mm (6 inchesin.) along the length of the copper conductor. The copper conductor should be in close proximity l          withto the unexposed surface of the fire barrier material. Thermocouples should also be placed immediately adjacent to all supports and barrier penetrations.
4.3.2.2 Thermocouple Placement -- Test Specimens Without Cables. The following are acceptable thermocouple placements for determining the thermal performance of raceway or cable tray fire barrier systems that do not contain cables.
Text Was Moved From Here: 7
: b.      Cable Trays  The temperature rise on the unexposed surface of a fire barrier system installed on a cable tray should be measured by placing thermocouples every 152 mm [6 inches]
on the exterior surface of each tray side rails between the side rail and the fire barrier material.
Internal raceway temperatures should be measured by a stranded AWG 8 bare copper conductor routed on the top of the cable tray rungs along the entire length and down the longitudinal center of the cable tray run with thermocouples installed every 152 mm [6 inches] along the length of the copper conductor. Thermocouples should be placed immediately adjacent to all structural members, supports, and barrier penetrations.
: c.      Junction Boxes  The temperature rise on the unexposed surface of a fire barrier system installed on junction boxes (JBs) should be measured by placing thermocouples on either the inside or the outside of each JB surface. Each JB surface or face should have a minimum of one thermocouple, located at its geometric center. In addition, one thermocouple should be installed for every one square foot of JB surface area. These thermocouples should be located at the geometric centers of the one square foot areas. At least one thermocouple should also be placed within 25 mm [1 inch] of each penetration connector/interface.
: d.      Airdrops  The internal airdrop temperatures should be measured by a stranded AWG 8 bare copper conductor routed inside and along the entire length of the airdrop system with thermocouples installed every 152 mm [6 inches] along the length of the copper conductor. The copper conductor should be in close proximity with the unexposed surface of the fire barrier material. Thermocouples should also be placed immediately adjacent to all supports and penetrations.
l          4.3.2.3        Criteria for Averaging Temperatures.
l l          Temperature conditions on the unexposed surfaces of the fire barrier material during the fire test will be determined by averaging the temperatures measured by the thermocouples l installed in or on the raceway. In determining To determine these temperature conditions, the thermocouples measuring similar areas of the fire barrier should be averaged together.
DG-1170, Page 128
 
Acceptance will be based on the individual averages. The following methods of averaging should be followed.
: a.      Conduits  The            ConduitsThe thermocouples applied to the outside metal surface      l of the conduit should be averaged together.
: b.              Cable Trays  ThetraysThe thermocouples on each cable tray side rail should          l be averaged separately. For example, thermocouples placed on one side rail will be averaged separately from the other side rail. In addition, the temperature          l conditions measured by thermocouples on the bare copper conductor should be averaged separately from the side rails.
: c.              Junction Boxes  For JBsboxesFor junction boxes that have only one                    l thermocouple on each JBjunction box surface, the individual JBjunction box            l surface thermocouples should be averaged together. For JBsjunction boxes that          l have more than one thermocouple on each JBjunction box surface, the                    l thermocouples on the individual JBjunction box surfaces should be averaged            l together.
: d.      Airdrops  The            AirdropsThe thermocouples placed on the copper conductor            l within the airdrop fire barrier should be averaged together.
The average of any thermocouple group should not exceed 139&deg; EC [250&deg;F](250 EF)                l above the unexposed side temperature within the fire barrier test specimen at the onset of the fire endurance test. In addition, the temperature of each individual thermocouple will be evaluated.
Individual thermocouple conditions should not exceed the 139&deg; EC [250&deg;F](250 EF) temperature            l rise by more than 30 percent ([i.e., 181&deg; EC [375&deg;F(325 EF)]).                                          l If a fire barrier test specimen without cables does not meet the average or maximum single point temperature criteria, the internal raceway temperature profile as measured by the instrumented bare copper conductors during the fire exposure can be used to assess cable functionality through air oven tests of plant -specific cable types and construction, as discussed      l below.
4.3.3    Hose Stream Tests                                                                      l l
NFPA 251 and ASTM E-119 allow flexibility in hose stream testing. The standards                l allow the hose stream test to be performed on a duplicate test specimen subjected to a fire endurance test for a period equal to one-half of that indicated as the fire -resistance rating, but not l for more than 1 hour (e.g., 30-minute 30-minute fire exposure to qualify a 1-hour fire -rated          l barrier).
DG-1170, Page 129
 
l        For safe -shutdown-related fire barrier systems and duplicate electrical cable tray or l raceway and component fire barrier test specimens that have been exposed to the 1/2-durationone-l half-duration test fire exposure, the staff finds the hose stream application specified by NFPA l 251 to be acceptable. NFPA 251 requires the stream of water to be delivered through a 64-mm l [21/2-inch](2.5-in.) hose discharging through a standard 29-mm [11/2-inch](1.5-in.) playpipe nozzle onto the test specimen after the fire exposure test. The stream is applied with the nozzle l orifice positioned 6.1 meters [(20 feet]ft) away from the center of the test specimen at a pressure l of 207 kPa [(30 psi]). The application of the stream is to all exposed parts of the specimen for a l duration of at least 1 minute for a 1-hour barrier and 21/2.5 minutes for a 3-hour barrier.
l        As an alternative forto electrical raceway fire barrier test specimens, the application of the hose stream test can be performed immediately after the completion of the full fire endurance test l period. If this method is used to satisfy the hose stream test criteria, any one of the following l hose stream applications is acceptable.:
: a.      The stream applied at random to all exposed surfaces of the test specimen through a 64-l        mm [21/2-inch](2.5-in.) national standard playpipe with a 29-mm [(11/2- inch].5-in.) orifice l        at a pressure of 207 kPa [(30 psi]) at a distance of 6.1 meters [(20 feet]ft) from the l        specimen. (Durations of the hose stream applications = 1 minute for a 1-hour barrier l        and 21/2.5 minutes for a 3-hour barrier.) or
: b.      The stream applied at random to all exposed surfaces of the test specimen through a 38-l        mm [11/2-inch](1.5-in.) fog nozzle set at a discharge angle of 30 degrees with a nozzle l        pressure of 517 kPa [(75 psi]) and a minimum discharge of 284 lpm [L/m (75 gpm]) with l        the tip of the nozzle at a maximum of 1.5 meters [(5 feet]ft) from the test specimen.
l        (Duration of the hose stream application = 5 minutes for both 1-hour and 3-hour barriers.) or
: c.      The stream applied at random to all exposed surfaces of the test specimen through a 38-l        mm [11/2-inch](1.5-in.) fog nozzle set at a discharge angle of 15 degrees with a nozzle l        pressure of 517 kPa [(75 psi]) and a minimum discharge of 284 lpm [L/m (75 gpm]) with l        the tip of the nozzle at a maximum of 3 meters [m (10 feet]ft) from the test specimen.
l        (Duration of the hose stream application = 5 minutes for both 1-hour and 3-hour barriers.)
l l        4.3.4  Demonstrating Functionality of Cables Protected by Raceway Fire Barrier l                Systems Dduring and Aafter Fire Endurance Test Exposure l
During fire tests of raceway fire barrier systems, thermal damage to the cables has led to cable jacket and insulation degradation without the loss of circuit integrity as monitored using l ANI criteria ([applied voltage of 8 to 10 volts 8-10V direct current (dc)]. Since cable voltages l used for ANI circuit integrity tests do not replicate cable operating voltages, loss of cable insulation conditions can exist during the fire test without a dead short occurring. It is expected DG-1170, Page 130
 
that if the cables were at rated power and current, a fault would propagate. The use of circuit integrity monitoring during the fire endurance test is not a valid method for demonstrating that the protected shutdown circuits are capable of performing their required function during and after the test fire exposure. Therefore, the NRC does not require circuit integrity monitoring using the  l ANI criteria is not required to satisfy NRCits acceptance criteria for fire barrier qualification. l The following approaches are acceptable for evaluation ofevaluating cable functionality.            l l
4.3.4.1          Use of Environmental Qualification Data.                                          l l
Comparison of the fire barrier internal time-temperature profile measured during the fire  l endurance test to existing cable performance data, such as data from environmental qualification (EQ) tests, could be proposed to the staff as a method for demonstrating cable functionality. EQ testing is typically performed to rigorous conditions, including rated voltage and current. By correlating the EQ test time-temperature profile to the fire test time-temperature profile, the EQ  l test data would provide a viable mechanism to ensure cable functionality. A large body of EQ test data for many cable types exists today. The use of EQ data represents a cost-effective approach for addressing cable functionality for fire tests for those cases wherein which the        l 181&deg; EC [325&deg;F](325 EF) limit is exceeded. A comparison of fire test temperature profiles to        l existing EQ and loss-of-coolant accident (LOCA) test results or air oven test results is an acceptable approach to demonstratedemonstrating cable functionality provided that the subject      l analysis incorporates the anticipated temperature rise that is due tocaused by the self heating    l effects of installed power cables with the fire test results.
4.3.4.2        Cable Insulation Tests.                                                    l l
The nuclear industry uses two principal materials used as cable insulation and cable      l jackets by the nuclear industry are, thermoplastics and thermosetting polymeric materials. A        l thermoplastic material can be softened and re-softened by heating and reheating. Conversely, thermosetting cable insulation materials cure by chemical reaction and do not soften when heated. Under excessive heating, thermosetting insulation becomes stiff and brittle. Electrical    l faults may be caused by softening and flowing of thermoplastic insulating materials at temperatures as low as 149&deg; EC [300&deg;F](300 EF). Thermosetting electrical conductor insulation      l materials usually retain their electrical properties under short-term exposures to temperatures as high as 260&deg; EC [500&deg;F](500 EF). Insulation resistance (Megger) tests provide indications of the    l condition of the cable insulation resistance, whereas the high -potential (Hi-Pot) test provides    l assurance that the cable has sufficient dielectric strength to withstand the applied rated voltage.
A cable insulation failure usually results from two breakdown modes:. One failure mode is          l excessive dielectric loss that is due toresulting from low insulation resistance, and the other    l failure mode is overpotential stress that is due tocaused by loss of dielectric strength of the    l insulation material.
DG-1170, Page 131
 
To provide reasonable assurance that the cables would have functioned during and after the fire exposure, Megger tests need to be performed before the fire test, at multiple time intervals during the fire exposure (i.e., every 20 minutes during the 1-hour fire test and every hour during the 3-hour fire test) for instrumentation cables only, and immediately after the fire l endurance test to assess the cable insulation resistance levels. This testing will assureensure that the cables will maintain the insulation resistance levels necessary for proper operation of instruments.
l          The Megger tests ([pre-fire, during the fire [(if performed]), and immediately after the fire l test conditions)] should be done conductor-to-conductor for multi-conductor and conductor-l to-ground for all cables. The minimum acceptable insulation resistance (IR) value, using the test voltage values as shown in the table below, is determined by using the following expression:
l                    IR (Mega-ohms) = {[K+1 Mega-ohm ]
* 1000 (ft) } / Length/Length (ft)
Where K = 1 Mega-ohm/KV
* Operating Voltage (expressed in KV) l          In addition, to determine the insulation resistanceIR levels required for nuclear l instrumentation cables, an assessment of the minimum insulation resistanceIR value (e.g., one l mega-ohm) and its potential impact on the functionality of these cables should be evaluated. An ac or dc high potential (Hi-Pot) test for power cables greater than 1000 volts (V) should also be l performed after the post--fire Megger tests to assess the dielectric strength. This test provides assurance that the cable will withstand the applied voltage during and after a fire. The high l potentialHi-Pot test should be performed for a 5 -minute duration at 60 percent of either 80 V/mil ac or 240 V/mil dc (e.g., 125 mil conductor insulation thickness x 240 V/mil dc x 0.6 = 18,000 V dc).
l          The table belowTable 1 summarizes the Megger and Hi-Pot test voltages(9) that, when applied to power, control, and instrumentation cables, would constitute an acceptable cable functionality test.
l                                        Table 1. Functionality Test Voltages 9
A Megger test voltage of 1000 V dc is acceptable provided a Hi-Pot test is performed after the Megger test for power l          cables rated at less than 1000 V ac.The review guidance for Megger and Hi-Pot test voltages was derived from IEEE l          383 and IEEE 690, IEEE Standard for the Design and Installation of Cable Systems for Class 1E Circuits in Nuclear l          Power Generating Stations.
DG-1170, Page 132
 
TYPE OPERATING VOLTAGE MEGGER TEST VOLTAGE                                                      HIGH -POTENTIAL              l TEST VOLTAGE Power            >1000 V ac                  2500 V dc          60% x 80 V/mil (ac) 60% x 240 V/mil (dc)
Power            <1000<1,000 V ac            15001,500 V dc(10)            None                                            l Instrument and Control                <250 V dc
<120 V ac          500 V dc            None The electrical cable functionality tests recommended above are one acceptable method.
Alternative methods to assess degradation of cable functionality. The NRC staff will be                                      l evaluated evaluate alternative methods on a case-by-case basis. The above table                                              l summarizingsummarizes the typical Megger and Hi-Pot test voltages are "typical", and the                                    l applicant can follow the applicable industry standards and manufacturer's recommendations for                                l the specific cable application in the performance of the insulation resistanceIR and Hi-Pot tests.                            l 4.3.4.3              Air Oven Tests.                                                                                l l
Air oven tests can be used to evaluate the functionality of cables for those cable tray or                            l raceway fire barrier test specimens tested without cables. This testing method consists of exposing insulated wires and cables at rated voltage to elevated temperatures in a circulating air oven. The temperature profile for regulating the temperature in the air oven during this test is the temperature measured by the AWG 8 bare copper conductor during the fire exposure of those cable tray or raceway test specimens that were tested without cables.
The test method described by UL Subject 1724, "OutlineOutline of Investigation for Fire                              l Tests for Electrical Circuit Protective Systems," Issue Number 2, August 1991, Appendix B,                                  l "QualificationQualification Test for Circuit Integrity of Insulated Electrical Wires and Cables in                          l Electrical Circuit Protection Systems," is acceptable, with the following modifications.:                                    l
: a.      a.        During the air oven test the cables are to be energized at rated voltage. The cables                        l are to be monitored for conductor-to-conductor faults in multi-conductor cables and conductor-to-ground faults in all conductors.
: b.                                                                                                                            l
: b.      The cables being evaluated should be subjected to the Megger and high potentialHi-Pot                                l tests, previously recommended above in Regulatory Position 4.3.4.2, "Cable Insulation                                l Tests."
: c.                                                                                                                            l 10 A Megger test voltage of 1,000 V dc is acceptable provided a Hi-Pot test is performed after the Megger test for power cables rated at less than 1,000 V ac.
DG-1170, Page 133
 
l c.      The impact force test, which simulates the force of impact imposed on the raceway by the l        solid stream test, described in UL 1724, Appendix B, paragraph B3.16, isdoes not l        requiredneed to be performed.
l        4.3.4.4        Cable Thermal Exposure Threshold.
l l        The following analysis, which is based on determining whether a specific insulation material will maintain electrical integrity and operability within a raceway fire barrier system during and after an external fire exposure, is an acceptable method for evaluating cable l functionality. In order tTo determine cable functionality, it is necessary to consider the operating cable temperatures within the fire barrier system at the onset of the fire exposure and the thermal exposure threshold (TET) temperature of the cable. For example, if the TET of a specific l thermoplastic cable insulation (Brand X) is 149&deg; EC [300&deg;F](300 EF) and the normal operating l temperature within the fire barrier system is 66&deg; EC [150&deg;F](150 EF), the maximum temperature l rise within the fire barrier system should not exceed 83&deg; EC [150&deg;F](150 EF) during exposure to l an external fire of a duration equal to the required fire -resistance rating of the barrier. For this l example, the TET limit for Brand X cable is 83&deg; EC [150&deg;F](150 EF) above the cable operating temperatures within the fire barrier system at the onset of the external fire exposure. The cable TET limits in conjunction with a post-test visual cable inspection and the Hi-Pot test described above should readily demonstrate the functionality of the cable circuit during and after a fire.
The normal cable operating temperature can be determined by loading cable specimens installed within a thermal barrier system in the test configuration with rated voltage and current.
l The TET temperature limits for most cable insulation may be obtained from the manufacturer's l published data, which isare given as the short-circuit rating limit. With the known TET and normal operating temperature for each thermal barrier system configuration, the maximum temperature rise limit within a fire barrier system may then be determined.
The guidance in Regulatory Position 4.3.4 is based on Appendix R to 10 CFR Part 50, APCSB 9.5-1, ASB 9.5-1, CMEB 9.5-1, GL 86-10, and Supplement 1 to GL 86-10.
4.3.5 Cable Qualification Electric cable construction should, as a minimum, pass the flame test in IEEE Standard 383 or IEEE Standard 1202. (This does not imply that cables passing either test will not require additional fire protection.) For cable installations in operating plants and plants under construction prior to July 1, 1976, that do not meet the IEEE 383 flame test requirements, the cables should be covered with an approved flame retardant coating and properly derated.
Non-qualified cable that is not covered with an approved flame retardant coating should be protected with an automatic fire suppression system.
l 5.      SAFE SHUTDOWN CAPABILITY l
DG-1170, Page 134
: 5.      Safe-Shutdown Capability                                                                    l When considering the consequences of a fire in a given fire area during the evaluation of safe -shutdown capabilities of the plant, it should be demonstrated that one success path of        l equipment and electrical circuits that can be used to bring the reactor to hot shutdown conditions  l in the case of BWRs, or hot standby in the case of PWRs, remains unaffected by the fireshutdown/standby conditions, remains free of fire damage. It should also be demonstrated        l that fire damage to one success path of equipment needed for achieving cold shutdown will be limited so that equipment will be returned to an operating condition within 72 hours, or for areas requiring alternate, dedicated, or backup shutdown, the licensee should demonstrate that cold        l shutdown capability can be restored and cold shutdown achieved within 72 hours.
One of the objectives of the fire protection program is to demonstrate that one success path of systems necessary to achieve and maintain hot shutdown (e.g., hot standby for a PWR, hot shutdown for a BWR) are maintained free of fire damage. The For reactor designs that            l cannot safely remain in hot standby/shutdown for 72 hours, it should be demonstrated that a cold    l shutdown condition can be achieved and maintained within the required period of time.                l l
For existing reactor plants, the success path of safe -shutdown systems should be capable  l of meeting Regulatory Positions 5.1 andor 5.2 of this guide and performing the necessary            l shutdown functions. The capability of the required shutdown functions should be based on a previous analysis, if possible (e.g., those analyses in the FSAR). The equipment required for alternative or dedicated shutdown should have the same or equivalent capability as that relied on in the above-referenced analysis.
5.1      Safe Shutdownanalyses.                                                                      l l
The FPP should include an analysis to demonstrate that the SSCs important to safety can    l accomplish their respective post-fire safe-shutdown functions. The safe-shutdown analysis            l should demonstrate that redundant safe-shutdown systems and components, including electrical        l circuits for which fire-induced failure could directly or indirectly prevent safe shutdown, are      l adequately protected such that one success path remains free of fire damage in the event of          l postulated fires. This protection should be provided by fire barriers, physical separation with no  l intervening combustibles, and/or automatic detection and suppression, as required by applicable      l regulations. Where one redundant success path cannot be adequately protected, an alternative or      l dedicated shutdown success path should be identified and protected to the extent necessary to        l ensure post-fire safe-shutdown.                                                                      l l
The safe-shutdown analysis for new reactor designs must demonstrate that safe shutdown      l can be achieved assuming that all equipment in any one fire area (except for the control room and    l containment) will be rendered inoperable by fire and that reentry into the fire area for repairs and l operator actions is not possible. (See Regulatory Position 8.2 of this guide.) Consequently, new    l reactors should not credit physical separation or local fire barriers (e.g., electrical raceway fire l barrier systems) within these fire areas as providing adequate protection. The control room is      l excluded from this approach, provided the design includes an independent alternative shutdown        l capability that is physically and electrically independent of the control room. New reactors must    l DG-1170, Page 135
 
l provide fire protection for redundant shutdown systems in the reactor containment building that l will ensure, to the extent practicable, that at least one post-fire shutdown success path will be free l of fire damage.
l l          The safe-shutdown analysis should evaluate a fire in each fire area containing SSCs l important to safety and identify a post-fire safe-shutdown success path (i.e., all trains or systems l that are required to remain free of fire damage to perform the necessary safe-shutdown l functions). The analysis also identifies all fire-induced circuit failures that could directly or l indirectly (e.g., by causing a spurious actuation) prevent safe shutdown.
l DG-1170, Page 136
 
5.1    Post-Fire Safe-Shutdown Performance Goals for Redundant Systems                                l Ensure that fuel integrity is maintained and that there are no adverse consequences on the reactor pressure vessel integrity or the attached piping. Fuel integrity is maintained provided the fuel design limits are not exceeded.
The guidance in Regulatory Position 5.1 is based on the Richards Letter (2000).
5.2    Alternative or Dedicated Shutdown Design and Performance Goals 5.2.1 Alternative or Dedicated Safe Shutdown System Design Goals During the                                                                                    l l
During post-fire shutdown, the reactor coolant system process variables shouldmust be          l maintained within those predicted for a loss of normal ac power, and the fission product boundary integrity shouldshall not be affected;, i.e., there shouldshall be no fuel clad damage,      l rupture of any primary coolant boundary, or rupture of the containment boundary.
The systems used for alternative or dedicated Licensees should ensure that fire protection    l features are provided for structures, systems, and components important to safe shutdown that are      l capable of limiting fire damage so that one success path of systems necessary to achieve and          l maintain hot shutdown conditions from either the control room or emergency control station(s) is      l free of fire damage.                                                                                  l l
As noted in IN 84-09, Lessons Learned from NRC Inspections of Fire Protection Safe-          l Shutdown Systems (10 CFR Part 50, Appendix R), the post-fire safe-shutdown performance                l goals are the same for both redundant success paths and alternative/dedicated shutdown need not        l be designed to (1) seismic Category I criteria, (2) single failure criteria, or (3) other design basis accident criteria, except the portions of these systems that interface with or impact existing safety systems.
5.2.2  Safe Shutdown Performance Goals for Alternative or Dedicated Systems The systems. Section III.L of Appendix R provides the following specific performance          l goals forto achieve the shutdown functions should bepost-fire safe-shutdown goals:                    l
: a.      The reactivity control function should be capable of achieving and maintaining cold shutdown reactivity conditions.
l
: b.      The reactor coolant makeup function should be capable of maintaining the reactor coolant level above the top of the core for boiling-water reactors (BWRs) and within the level        l indication of the pressurizer for pressurized-water reactors (PWRs).                          l DG-1170, Page 137
 
l
: c.      The reactor heat removal function should be capable of achieving and maintaining decay heat removal.
l
: d.      The process monitoring function should be capable of providing direct readings of the process variables necessary to perform and control the above functions.
l
: e.      The supporting functions should be capable of providing the process cooling, lubrication, l          etc.,and other activities necessary to permit the operation of the equipment used for safe -
l          shutdown functions.
The guidance for Regulatory Position 5.2 is in Appendix R to 10 CFR Part 50 and CMEB 9.5-1.
5.3      Hot Standby (PWR) Hot Shutdown (BWR) Systems and Instrumentation One success path of equipment necessary to achieve hot standby (PWR) or hot shutdown (BWR) from either the control room or emergency control stations should be maintained free of fire damage by a single fire, including an exposure fire. Manual operation of valves, switches, and circuit breakers is allowed to operate equipment and isolate systems and is not considered a repair. Damage considerations should also include damage to equipment from the normal or inadvertent operation of fire suppression systems.
Recovery actions are allowed to systems and components not used for hot shutdown, but whose fire or fire suppressant-induced maloperations may adversely affect hot shutdown capability. These recovery actions should be achievable prior to the maloperations causing an unrecoverable plant condition.
5.3.1 PWR Systems and Instrumentation l          In accordance with GL 81-12, l
l          GL 81-12 describes the systems and instrumentation with the following capabilitiesthat are generally necessary for achieving hot standby of PWRs.
5.3.1.1 Reactivity Control. Reactor trip capability (scram) and boration capability (e.g., charging pump, makeup pump or high-pressure injection pump taking suction from concentrated borated water supplies, as well as letdown system if required).
DG-1170, Page 138
 
5.3.1.2 Reactor Coolant Makeup. Reactor coolant makeup capability, e.g., charging pumps or the high-pressure injection pumps. Power-operated relief valves may be required to reduce pressure to allow use of the high-pressure injection pumps.
5.3.1.3 Reactor Coolant System Pressure Control. Reactor pressure control capability, e.g., charging pumps or pressurizer heaters and use of the letdown systems if required.
5.3.1.4 Decay Heat Removal. Decay heat removal capability, e.g., power-operated relief valves (steam generator) or safety relief valves for heat removal with a water supply and emergency or auxiliary feedwater pumps for makeup to the steam generator. Service water or other pumps may be required to provide water for auxiliary feed pump suction if the condensate storage tank capacity is not adequate for 72 hours.
5.3.1.5 Process Monitoring Instrumentation. The following instrumentation is considered necessary to achieve hot standby for PWRs.
C        Pressurizer pressure and level C        Reactor coolant cold leg temperature and core exit thermocouples or hot leg temperature C        Steam generator pressure and wide-range level C        Source-range flux monitor C        Diagnostic instrumentation for shutdown systems C        Level indication for all tanks used (e.g., CST).
5.3.1.6 Support. The equipment required to support operation of the above described shutdown equipment, e.g., instrument air, component cooling water, service water, and onsite power sources (ac, dc), and associated electrical distribution systems.
5.3.2 BWR Systems and Instrumentation In accordance with GL 81-12,post-fire safe-shutdown for existing PWRs and BWRs. The        l systems and instrumentation with the following capabilities are generally necessary for achieving hot shutdown of BWRs.
5.3.2.1 Reactivity Control.. Reactor trip capability (scram).
5.3.2.2 Reactor Coolant Makeup. Reactor coolant inventory makeup capability, e.g.,
reactor core isolation cooling system (RCIC), the high-pressure coolant injection system (HPCI),
low pressure coolant injection (LPCI), and core spray.
5.3.2.3 Reactor Pressure Control and Decay Heat Removal. Depressurization system valves or safety relief valves for venting to the suppression pool. The residual heat removal system in steam condensing mode and the service water system may also be used for heat removal to the ultimate heat sink.
5.3.2.4 Suppression Pool Cooling. Residual heat removal system (in suppression pool cooling mode) service water system to maintain hot shutdown.
DG-1170, Page 139
 
5.3.2.5 Process Monitoring. The following instrumentation is considered necessary to achieve hot shutdown for BWRs.
C        Reactor water level and pressure, C        Suppression pool level and temperature, C        Emergency or isolation condenser level, C        Diagnostic instrumentation for shutdown systems, C        Level indication for all tanks used.
5.3.2.6 Support. The equipment required to support operation of the above described shutdown equipment, e.g., instrument air, closed loop cooling water, service water, and onsite power sources (ac and dc), and associated electrical distribution systems.
The guidance in Regulatory Position 5.3 is based on Appendix R to 10 CFR Part 50, GL 81-12, GL 86-10, and Richards Letter (2000).
l 5.4    Cold Shutdown Systems and Instrumentation required for specific plants is included l in the plant licensing basis and the operating parameters that determine post-fire safe-shutdown l are included in the plant Technical Specifications.
l l 5.2    Cold Shutdown and Allowable Repairs For normal safe shutdown, redundant systems necessary to achieve cold shutdown may be damaged by a single fire, but damage should be limited so that at least one success path can be l repaired or made operable within 72 hours using onsite capability or within the time period l required to achieve a safe-shutdown condition, if less than 72 hours.
For alternative or dedicated shutdown, equipment or systems that are the means to achieve and maintain cold shutdown conditions should not be damaged by fire, or the fire damage to such equipment and systems should be limited so that the systems can be made l operable and cold shutdown achieved within 72 hours (or less, if required) using only onsite l power. Systems and components used for safe shutdown after 72 hours (or less, if required) may be powered from offsite power only.
Cold shutdown capability repairs (e.g., the replacement of fuses and the replacement of cabling) are permitted. Selected equipment replacement is also allowed if practical. Procedures l should be prepared for repairing damaged equipment (see Regulatory Position 5.75.3 of this l guide), and dedicated replacement equipment should be stored on site and controlled. Repairs should be of sufficient quality to ensure safe operation until the normal equipment is restored to an operating condition.
l          Repairs not permitted include the use of clip leads in control panels (i.e., hard-wired terminal lugs should be used) and the use of jumper cables other than those fastened with terminal lugs.
DG-1170, Page 140
 
When repairs are necessary in the fire area, the licensee should demonstrate that sufficient time is available to allow the area to be re-entered, that expected fire and fire suppressant damage will not prevent the repairs from taking place, and that the repair procedures will not adversely impact operating systems.
5.4.1 PWR Systems and Instrumentation for Cold Shutdown Regulatory Position 5.4.1 provides guidance on equipment and capability that is generally necessary to achieve cold shutdown, in addition to that already described in Regulatory Positions 5.3.1 and 5.3.2, to maintain hot standby (PWR) or hot shutdown (BWR).
5.4.1.1 Reactor Coolant System Pressure Reduction to Residual Heat Removal System (RHR) Capability. Reactor coolant system pressure reduction by cooldown using steam generator power operated relief valves or atmospheric dump valves.
5.4.1.2 Decay Heat Removal. Decay heat removal capability, e.g., residual heat removal system, component cooling water system, and service water system to remove heat and maintain cold shutdown.
5.4.1.3 Support. Support capability, e.g., offsite power and the associated electrical distribution system to supply the above equipment.
5.4.2 BWR Systems and Instrumentation At this point the equipment necessary for hot shutdown has reduced the primary system pressure and temperature to the point that the RHR system may be placed in service in RHR cooling mode. Decay heat removal and associated support systems are generally needed The            l combination of an automatic depressurization system and low-pressure safety injection system        l can provide cold shutdown capability. The application of regulatory allowance for repairs or        l manual actions for cold shutdown.                                                                    l 5.4.2.1 Decay Heat Removal. Residual heat removal system in the RHR cooling mode, service water system.
5.4.2.2 Support. Support capability, e.g., offsite power and the associated distribution systems, to provide for shutdown equipment.
The guidance in Regulatory Position 5.4 is based on Appendix R to 10 CFR Part 50, CMEB 9.5-1, GL 81-12, GL 86-10, IN 84-09, and Mattson Memo (1982).
5.5      systems does not extend to these systems when they are credited for achieving and          l maintaining hot shutdown.                                                                            l l
5.3    Fire Protection of Safe -Shutdown Capability                                                l Fire barriers or automatic suppression, or both, should be installed as necessary to protect redundant systems or components necessary for safe shutdown. Except wherein those                    l DG-1170, Page 141
 
l circumstances in which alternative or dedicated shutdown systems are required, or where cables l or equipment, or cables (including associated non-safetyelectrical circuits that could prevent l operation or cause maloperation due to hot shorts, open circuits, or shorts to ground) of redundant success paths of systems necessary to achieve and maintain hot shutdown conditions l are located within the same fire area outside of primary containment, the licensee should provide l for currently operating reactor plants one of the following means of ensuring that one of the success paths (of equipment for hot shutdown) is free of fire damage should be provided.
l (Regulatory Position 8.2 of this guide provides the protection requirements for redundant post-l fire safe-shutdown success paths in new reactor plants):
l a.      Separation of cables and equipment and associated non-safety circuitsof redundant l        success paths by a fire barrier having a 3-hour rating should be achieved. Structural steel forming part of or supporting the fire barrier should be protected to provide fire resistance equivalent to that of the barrier.
: b.      Separation of cables and equipment and associated non-safety circuits of redundant success paths by a horizontal distance of more than 6.1 m (20 feet) with no intervening l        combustible or fire hazards should be achieved. In addition, fire detectors and an automatic fire suppression system should be installed in the fire area.
l        Insulation of electrical cables, including those with fire -resistive coatings, should be considered as intervening combustibles in other than negligible quantities (i.e., isolated l        cable runs) as determined by engineering and fire hazards analysis. Cables in conduit are not considered intervening combustibles.
l c.      Enclosure of cable and equipment and associated circuitsof one redundant success path in l        a fire barrier having a 1-hour rating should be achieved. In addition, fire detectors and an l        automatic fire suppression system should be installed in the area where the fire areais l        postulated.
l        In meeting the provisions of Iitems b and c above, the installation of fire suppression and detection in a fire area should be sufficient to protect against the hazards of the area. In this regard, detection and suppression providing less than full area coverage may be evaluated as l adequate to comply with the regulation. (sSee Regulatory Position 1.8.3.).
l        Inside non-inerted containments, the licensee should provide fire protection should be provided that is in accordance with the criteria above, or as specified in Regulatory Position 6.1.1.1 of this guide.
The guidance in Regulatory Position 5.5 is in Appendix R to 10 CFR Part 50, CMEB 9.5-1, GL 83-33, GL 86-10, and IN 84-09.
DG-1170, Page 142
 
5.5.1 Associated Circuits of Concern Any (associated) non-safety or safety circuits in a fire area that could adversely affect the identified shutdown equipment by feeding back potentially disabling conditions (e.g., hot shorts or shorts to ground) to power supplies or control circuits of that equipment should be evaluated.
Such disabling conditions should be prevented to provide assurance that the identified safe shutdown equipment will function as designed.
Circuits within a fire area may be subject to fire damage that can affect or prevent post-fire safe shutdown capability. Associated circuits of concern are defined as those cables (safety-related, non-safety-related Class 1E and non-Class 1E) that have a physical separation less than that specified in a through c of Regulatory Position 5.5 and have one of the following.
: a.      A common power source with the shutdown equipment (redundant or alternative) and the power source is not electrically protected from the circuit of concern by coordinated breakers, fuses, or similar devices.
: b.      A connection to circuits of equipment whose spurious operation would adversely affect the shutdown capability (e.g., RHR/RCS isolation valves, ADS valves, PORVs, steam generator atmospheric dump valves, instrumentation, steam bypass).
Text Was Moved From Here: 8 Hot short conditions are assumed to exist until action has been taken to isolate the circuit from the fire area, or other actions as appropriate have been taken to negate the effects of the spurious actuation.
: c.      A common enclosure (e.g., raceway, panel, junction) with the shutdown cables (redundant or alternative) (1) that is not electrically protected by circuit breakers, fuses, or similar devices or (2) will allow propagation of the fire into the common enclosure.
The guidance in Regulatory Position 5.5.1 is based on GL 81-12, GL 86-10, and Holahan Memo (1990).
5.5.2  of this guide.                                                                        l l
DG-1170, Page 143
 
l 5.3.1  Identification and Evaluation of Associated Circuits of Concern It is recognized that there are different approaches that may be used to reach the same objective of determining the interaction of associated circuits with shutdown systems. One approach is to start with the fire area, identify what is in the fire area, and determine the interaction between what is in the fire area and the shutdown systems that are outside the fire area. This approach has been designated the Fire Area Approach. A second approach, designated the Systems Approach, would be to identify the shutdown systems outside a fire l area and then determine those circuits that are located in the fire area and that arePost-Fire l Safe-Shutdown Circuits l
l        The post-fire safe-shutdown analysis must ensure that one success path of shutdown l SSCs remains free of fire damage for a single fire in any single plant fire area. The NRC l acknowledges Chapter 3 of industry guidance document, NEI-00-01, Revision 1, in RIS 2005-30, l as providing an acceptable deterministic methodology for analysis of post-fire safe-shutdown l circuits, when applied in conjunction with the RIS. (The guidance provided in RIS 2005-30 is l also included in this regulatory guide.) All circuits for which fire-induced failure could prevent l safe shutdown must be addressed in the analysis and appropriate protection must be provided.
l l 5.3.2 Hi/Low Pressure Interface l
l        The licensee should evaluate the circuits associated with the shutdown system.
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 that l mayHi/Low pressure interfaces for the potential to adversely 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.
5.5.2.1 Fire Area Approach.
: a.      For each fire area, identify (1) the power cables that connect to the same power supply of the alternative, dedicated, or backup shutdown system and the function of each power cable, (2) the cables that are considered for possible spurious operation that could adversely affect safe shutdown and the function of each cable, and (3) the cables that share a common enclosure with circuits of the alternative or dedicated shutdown systems and the function of each cable.
: b.      Demonstrate that fire-induced failures (e.g., hot shorts, open circuits, or shorts to ground) of each of the cables identified above will not prevent operation or cause maloperation of the alternative or dedicated shutdown method.
DG-1170, Page 144
: c.      For each cable where electrical isolation has been provided, drawings should be developed that illustrate how electrical isolation is accomplished.
5.5.2.2 Systems Approach.
: a.      Develop a methodology to assess the potential of associated circuits that adversely affect the alternative or dedicated shutdown systems. The methodology should provide for identification of circuits that share a common power supply or common enclosure with the alternative or dedicated shutdown system and the circuits whose spurious operation would affect shutdown. Additionally, the method for determining whether these circuits are associated circuits of concern for the fire area should be included.
: b.      Identify the associated circuits of concern in the fire area and demonstrate that fire-induced failures (e.g., hot shorts, open circuits, or shorts to ground) of each of the cables will not prevent operation or cause maloperation of the alternative or dedicated shutdown method.
: c.      For each cable where electrical isolation has been provided, drawings should be developed that illustrate how electrical isolation is accomplished.
The guidance in Regulatory Position 5.5.2 is based on GL 81-12 and GL 86-10.
5.5.3 Hi/Low Pressure Interface For either approach described in Regulatory Position 5.5.2.1 or 5.5.2.2, an evaluation of Hi/Low pressure interfaces should be performed. Circuits associated with Hi/Low pressure interfaces should be evaluated for the potential to adversely affect safe shutdown. For example, the residual heat removal (RHR) system is generally a low-pressure system that interfaces with        l the high-pressure primary coolant system. Thus, the interface most likely consists of two redundant and independent motor-operated valves. TBoth of these two motor-operated valves            l and their associatedpower and control cables may be subject to damage from a single fire. This        l single fire could cause the two valves to spuriously open, resulting in an interfacing system LOCA through the subject Hi/Low -pressure system interface. To ensure that this interface and        l other Hi/Low pressure interfaces are adequately protected from the effects of a single fire, the followinglicensee should be performed.                                                                l perform an evaluation, as follows:                                                                    l
: a.      Identify each Hi/Low -pressure interface that uses redundant electrically controlled          l devices (such as two series motor -operated valves) to isolate or preclude rupture of any    l primary coolant boundary.
DG-1170, Page 145
: b.      For each set of redundant valves identified in this Regulatory Position 5.5.3, verify that l          the redundant cabling (power and control) haves adequate physical separation as stated by l          Regulatory Position 5.53 of this guide.
l c.      For each case wWhere adequate separation is not provided, demonstrate that fire-induced l          failures (multiple hot shorts, open circuits, and shorts to ground) of the cables will not cause maloperation and result in an interfacing systems LOCA.
The guidance in Regulatory Position 5.5.3 is based on GL 81-12.
5.5.4 Protection of Associated Circuits of Concern The shutdown capability may be protected from the adverse effect of damage to associated circuits of concern by the separation and protection guidelines of Regulatory Position 5.5 of this guide, or alternatively by the following methods as applied to each type of associated circuit.
Text Was Moved From Here: 9 l 5.3.3 Operator Manual Actions l C l          The associated circuit of concern interrupting devices (breakers or fuses) time-overcurrent l trip characteristic for all circuit faultspost-fire safe-shutdown analysis should causedescribe the interrupting device to interrupt the fault current prior to initiation of a trip of any upstream interrupting device that will cause a loss of the common power source.
l C        The power source should supply themethodology necessary fault current for sufficient l          time to ensure the proper coordination without loss of function of theaccomplish safe shutdown loads.
l          The acceptability of a particular interrupting device is considered demonstrated if, l including any operator actions required. Manual actions may not be credited in lieu of providing the following criteria are met:
l C        The interrupting device design should be factory tested to verify overcurrentrequired l          protection as designedof redundant systems located in the same fire area required by l          Section III.G.2 of Appendix R to 10 CFR Part 50, unless the NRC has reviewed and l          approved a specific operator manual action for a specific plant through the exemption l          process of 10 CFR 50.12. If permitted by the plant license, plants that were licensed after l          January 1979 may credit operator manual actions for these areas if it can be shown that l          the use of the operator manual action does not adversely affect safe shutdown.
l l          If one of the redundant success paths in the same fire area is maintained free of fire l damage by one of the specified means in Appendix R, Section III.G.2, then the use of operator l manual actions, or other means necessary, to mitigate fire-induced operation or maloperation to l the second success path may be considered in accordance with the applicable UL, ANSI, or NEMA standards.
DG-1170, Page 146
 
C      For low and medium voltage switchgear (480V and above), circuit breaker/protective relay periodic testing should demonstrate that the overall coordination scheme remains within the limits specified in the design criteria. This testing may be performed as a series of overlapping tests.
C Text Was Moved From Here: 10 C      Fuses, when used as interrupting devices, do not require periodic testing because of their stability, lack of drift, and high reliability. Administrative controls should ensure that replacement fuses with ratings other than those selected for proper coordinating are not accidentally used.
5.5.4.2 Spurious Operation Circuits. Provide a means to isolate the equipment and components from the fire area prior to the fire (i.e., remove power, open circuit breakers).
Provide electrical isolation that prevents spurious operation. Potential isolation devices include breakers, fuses, amplifiers, control switches, current transformers, fiber optic couplers, relays, and transducers.
Provide a means to detect spurious operations and develop procedureslicensees FPP and      l license condition because Section III.G.2 has been satisfied (e.g., to stop a pump that spuriously  l starts and could prevent or adversely impact safe shutdown if allowed to continuously operate).      l Operator manual actions may also be credited when alternate or dedicated shutdown capability is      l provided.                                                                                            l l
For pre-1979 licensees, a staff decision in an SER that approves the use of operator        l manual actions, in lieu of one of the means specified in Section III.G.2 of Appendix R, does not    l eliminate the need for an exemption. Pre-1979 licensees that have SERs, but not a corresponding      l exemption, and that approve operator manual actions must request an exemption under 10 CFR          l 50.12, highlighting the special circumstances of 10 CFR 50.12(a)(2)(ii), citing the SER as the      l safety basis, and confirming that the safety basis established in the SER remains valid.            l l
RIS 2006-10 provides additional guidance on regulatory expectations for operator manual      l actions. All fire-related operator manual actions must be feasible and reliable. NUREG-1852          l provides technical bases in the form of criteria and technical guidance for justifying that operator l manual actions are feasible and can reliably be performed under a wide range of plant conditions    l that an operator might encounter during a fire. NUREG-1852 only addresses operator manual            l actions and does not address the additional regulatory requirements associated with operator        l manual actions, e.g., requirements for detection and suppression. Use of operator manual actions    l does not obviate the detection and automatic suppression capabilities that are required by the      l regulations. In addition, the omission or elimination of these capabilities in an area containing    l SSCs (including circuits) important to safety would generally be considered an adverse effect on    l safe shutdown since it would reduce, at a minimum, fire protection defense-in-depth.                l l
DG-1170, Page 147
 
l          Because the fire protection requirements, including the protection of safe-shutdown l capability and the prevention of radiological release, can be integrated in the planning and design l phase, a new reactor plant should have minimal reliance on operator manual actions and l alternative/dedicated shutdown systems (protection for fires in the main control room will require l alternative shutdown capability).
l l 5.3.4    Spurious Actuations l
l          The post-fire safe-shutdown circuit analysis must address all possible fire-induced l failures, including multiple spurious actuations. Although some licensees have based this l analysis on the assumption that multiple spurious actuations will not occur simultaneously or in l rapid succession, cable fire testing performed by the industry had demonstrated that multiple l spurious actuations occurring in rapid succession (without sufficient time to mitigate the maloperation of equipment (e.g., closure of the block valve if a PORV spuriously operates, l opening of the breakers to removeconsequences) have a relatively high probability of occurring.
l The success path SSCs, including circuits, must be protected from fire damage that could prevent l safe shutdown.
l l          Note that the crediting of operator manual actions is not an acceptable approach for l mitigating spurious operation of safety injection).
5.5.4.3 Common Enclosures. Provide appropriate measures to prevent propagation of the fire.
Provide electrical protection (e.g., breakers, fuses, or similar devices).
l          The guidanceoperations of components in redundant safe-shutdown trains or systems l (i.e., the primary, not the alternative/dedicated, safe-shutdown trains or systems), except as l previously discussed in Regulatory Position 5.5.4 is based on GL 81-12 and IN 88-45.
l 5.6      Alternative, Dedicated, or Backup3.3. (Also, refer to RIS 2005-30 for further l discussion of this issue.) See the Glossary section of this regulatory guide for a definition of l redundant trains/systems.
l DG-1170, Page 148
 
5.4    Alternative and Dedicated Shutdown Capability                                              l 5.64.1          General Guidelines                                                          l Alternative, dedicated, or backup shutdown capability and its associated circuits, independent of cables, systems, or components in the area, room, or zone under consideration, should be provided:
: a.      In areas where the fire protection features cannot ensure safe shutdown capability in the event of a fire in that area (i.e., where the protection of systems whose functions are required for hot shutdown does not satisfy the criteria of Regulatory Position 5.5) or
: b.      Where redundant success paths of systems required for hot shutdown located in the same fire area may be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems.
Fire detection and a manually actuated fixed water suppression system or an automatically actuated gaseous suppression system should be installed in the area, room, or zone under consideration.
While independence is clearly achieved where alternative shutdown equipment is outside the fire area under consideration, alternative shutdown equipment in the same fire area but independent of the room or the zone under consideration may be acceptable. Where alternative, dedicated, or backup shutdown is provided for a room or zone, the capability should be physically and electrically independent of that room or zone. The vulnerability of the equipment and personnel required at the location of the alternative, dedicated, or backup shutdown capability to the environments produced at that location as a result of the fire or fire suppressants should 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.
Therefore, the room concept should be justified by a detailed fire hazards analysis that demonstrates a single fire will not disable both normal shutdown equipment and the                  l l
Appendix R to 10 CFR Part 50 defines alternative shutdown capability as being provided      l by rerouting, relocating, or modifying existing systems, whereas dedicated shutdown is defined      l as being provided by installing new structures and systems for the function of post-fire shutdown. l Since post-fire repairs cannot be credited for achieving and maintaining hot shutdown, the          l licensee should implement the required rerouting, relocating, or modifying of the existing system  l for alternative shutdown capability in existing plants when the need for additional alternative    l shutdown capability is identified.                                                                  l l
For those fire areas where alternative or dedicated shutdown capability is required, the    l licensee should provide fixed fire suppression and detection for the fire area containing the      l redundant success paths (detection and suppression are not necessarily required for the area        l containing the alternative/dedicated shutdown system except where required by the fire hazards      l analysis).                                                                                          l l
The safe-shutdown analysis must demonstrate that alternate or dedicated shutdown            l DG-1170, Page 149
 
l systems, components, including electrical circuits, necessary to achieve and maintain hot l shutdown are free of fire damage and capable of performing the necessary safe-shutdown l functions or prevented from causing actions that prevent safe shutdown.
l        The alternative, /dedicated, or backup shutdown capability for specific fire areas may be unique for each such area, or it may be one unique combination of systems for all such areas. In either case, the alternative shutdown capability should be independent of the specific fire areas l and should accommodate post-fire conditions wheren offsite power is available and wheren l offsite power is not available for 72 hours. PThe licensee should provide procedures to l implement the alternative or dedicatedalternative/dedicated shutdown capability should be l provided, as described in Regulatory Position 5.75 of this guide.
l 5.4.2 The performance goals and criteria forAssociated Circuits of Concern l
l        When alternative or dedicated shutdown are described in systems are credited for l achieving post-fire safe-shutdown, a specific category of circuits has been defined (referred to as l associated circuits of concern) and acceptable approaches to mitigating the consequences of l fire-induced failure of these circuits have been identified. These circuits are nonsafety or safety l circuits that could adversely affect the identified shutdown equipment by feeding back potentially l disabling conditions (e.g., hot shorts or shorts to ground) to power supplies or control circuits of l that equipment and should be evaluated. Such disabling conditions should be prevented to l provide assurance that the identified safe-shutdown equipment will function as designed.
l l        Associated circuits of concern are defined as those cables (safety-related, nonsafety-l related Class 1E and non-Class 1E) that have a physical separation less than that specified in l Regulatory Positions 5.3.a through 5.3.c of this guide, and have one of the following:
l a.      a common power source with the shutdown equipment (redundant or alternative) that is l        not electrically protected from the circuit of concern by coordinated breakers, fuses, or l        similar devices l b.      a connection to circuits of equipment that would adversely affect the shutdown capability l        if spuriously operated (e.g., RHR/reactor coolant system isolation valves, automatic l        depressurization system valves, power-operated relief valves, steam generator l        atmospheric dump valves, instrumentation, steam bypass)
DG-1170, Page 150
 
l Text Moved Here: 8                                                                                    l For consideration of spurious actuations, the licensee should evaluate all possible          l functional failure states should be evaluated, that is, the component could be energized or de-energized by one or more circuit failure modes (i.e., hot shorts, open circuits, and shorts to ground). Therefore, valves could fail open or closed;, pumps could fail running    l or not running;, or electrical distribution breakers could fail open or closed. For three-    l 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 itthe licensee can be shown that onlyat least two hot shorts of    l the proper polarity without grounding couldare required to cause spurious operation, no      l further evaluation is necessary except for any cases involving Hi/Lo pressure interfaces.
However, two proper polarity faults in ungrounded multi-conductor dc circuits should be considered.
End Of Moved Text                                                                                    l Hot short conditions are assumed to exist until action has been taken to isolate the circuit  l from the fire area or other actions as appropriate have been taken to negate the effects of  l the spurious actuation.                                                                      l
: c.      a common enclosure (e.g., raceway, panel, junction) with the shutdown cables (redundant      l or alternative) that (1) is not electrically protected by circuit breakers, fuses, or similar l devices, or (2) will allow propagation of the fire into the common enclosure                  l l
5.4.3  Protection of Associated Circuits of Concern                                                  l l
The shutdown capability may be protected from the adverse effect of damage to                l associated circuits of concern by the separation and protection guidelines of Regulatory Position    l 5.2 of this guide.
The guidance in Regulatory Position 5.6.1 is based on Appendix R to 10 CFR Part 50, CMEB 9.5-1, GL 81-12, GL 86-10, and IN 84-09.
5.6.2 3 of this guide or, alternatively, by the following methods as applied to each type    l of associated circuit of concern.                                                                    l l
5.4.3.1 Common Power Source                                                                          l l
Text Moved Here: 9                                                                                    l 5.5.4.1 Common Power Source. ProvideA load fuse/breaker (i.e., interrupting devices)          l to feeder fuse/breaker coordination to prevent loss of the redundant or alternative shutdown power source may be necessary. IEEE Standard 242, "IEEEIEEE Recommended Practices for                l Protection and Coordination of Industrial and Commercial Power Systems," provides detailed          l guidance on achieving proper coordination.
DG-1170, Page 151
 
To ensure that the coordination criteria are met, the following should apply:
l End Of Moved Text l a.      The associated circuit of concern interrupting devices (breakers or fuses) time-overcurrent l        trip characteristic for all circuit faults should cause the interrupting device to interrupt the l        fault current before initiation of a trip of any upstream interrupting device that will cause l        a loss of the common power source.
l b.      The power source should supply the necessary fault current for sufficient time to ensure l        the proper coordination without loss of function of the shutdown loads.
l l        The acceptability of a particular interrupting device is considered demonstrated if the l following criteria are met:
l a.      The interrupting device design should be factory tested to verify overcurrent protection as l        designed in accordance with the applicable UL, ANSI, or National Electrical l        Manufacturers Association standards.
l b.      For low- and medium-voltage switchgear (480V and above), circuit breaker/protective l        relay periodic testing should demonstrate that the overall coordination scheme remains within l        the limits specified in the design criteria. This testing may be performed as a series of l        overlapping tests.
l c.
l Text Moved Here: 10 Molded case circuit breakers should periodically be manually exercised and inspected to ensure ease of operation. On a rotating refueling outage basis, a sample of these breakers should be tested to determine that breaker drift is within that allowed by the design criteria. Breakers l should be tested in accordance with an accepted quality controlQC testing methodology.
l l End Of Moved Text l d.      Fuses, when used as interrupting devices, do not require periodic testing because of their l        stability, lack of drift, and high reliability. Administrative controls should ensure that l        replacement fuses with ratings other than those selected for proper coordinating are not l        accidentally used.
l l 5.4.3.2 Spurious Operation Circuits l
l        Spurious operation is considered mitigated if one of the following criteria are met:
l a.      A means to isolate the equipment and components from the fire area before the fire l        (i.e., remove power, open circuit breakers) is provided.
l b.      Electrical isolation that prevents spurious operation is provided. Potential isolation l        devices include breakers, fuses, amplifiers, control switches, current transformers, fiber l        optic couplers, relays, and transducers.
DG-1170, Page 152
: c.      A means to detect spurious operations and develop procedures to mitigate the              l maloperation of equipment (e.g., closure of the block valve if a power-operated relief    l valve spuriously operates, opening of the breakers to remove spurious operation of safety  l injection) is provided.                                                                    l l
5.4.3.3 Common Enclosures                                                                          l l
Appropriate measures to prevent propagation of the fire should be provided.                l l
Electrical protection (e.g., breakers, fuses, or similar devices) should also be provided. l l
5.4.4  Control Room Fires                                                                        l l
The control room fire area contains the controls and instruments for redundant shutdown systems in close proximity. (usually sSeparation is usually a few inches.). Remote shutdown        l capability and its associated circuits for the control room and its required circuits should be    l independent of the cables, systems, and components in the control room fire area.
The damage to systems in the control room for a fire that causes evacuation of the control room cannot be predicted. AThe licensee should conduct a bounding analysis should be made to      l assureensure that safe conditions can be maintained from outside the control room. This analysis  l is dependent on the specific design. The usual assumption areThe following assumptions usually    l apply:                                                                                            l C      a.      The reactor is tripped in the control room.                                        l l
: b.      Offsite power is lost as well as automatic starting of the onsite ac generators and the automatic function of valves and pumps whosewith control circuits that could be affected  l by a control room fire.
l The analysis should demonstrate that the capability exists to manually achieve safe -      l shutdown conditions from outside the control room by restoring ac power to designated pumps,      l assuring that valve lineups are correct, and assuming that any malfunctions of valves that permit the loss of reactor coolant can be corrected before un-restorable conditions occur.
DG-1170, Page 153
 
l        The only manual action in the control room prior tobefore evacuation for which credit is usually given credit for is reactor trip. For any additional control room actions deemed necessary l prior tobefore evacuation, a demonstration of the capability of performing such actions should be l provided for staff review. Additionally, the licensee should provide assurance would have to be provided that such actions could not be negated by subsequent spurious actuation signals resulting from the postulated fire.
l        Post-fire return to the control room should be governed by those procedures and l conditions as described in Regulatory Position 5.75.2 of this guide.
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) may not be available. Smoke and fire suppressant damage in other areas (cabinets) should also be assessed and corrective action taken before controls in such cabinets are deemed functional.
Controls in undamaged areas (cabinets) may be operated as required. Repairs inside the control room may be performed to reach cold shutdown.
The guidance in Regulatory Position 5.6.2 is based on GL 86-10.
l 5.75    Post-Fire Safe -Shutdown Procedures Procedures for effecting safe shutdown should reflect the results and conclusions of the l safe -shutdown analysis. Implementation of the procedures should not further degrade plant l safety functions. Time-critical operations for effecting safe shutdown identified in the safe -
l shutdown analysis and incorporated in post-fire procedures should be validated.
l        5.75.1          Safe -Shutdown Procedures l
l        The only requirement for pPost-fire safe -shutdown operating procedures isshould be l developed for those areas where alternative or dedicated shutdown is required. For other areas of the plant, shutdown would normally be achieved using the normal operating procedures or plant emergency operating procedures.
l        5.75.2          Remote Shutdown Procedures l
l        Procedures should be in effect that describe the tasks to implement remote shutdown l capability wheren offsite power is available and wheren offsite power is not available for 72 hours. These procedures should also address necessary actions to compensate for spurious l operations and high -impedance faults if such actions are necessary to effect safe shutdown.
Procedures governing return to the control room should consider the following conditions:
: a.      The fire has been extinguished and so verified by appropriate fire protection personnel; DG-1170, Page 154
 
.                                                                                                      l
: b.      The control room has been deemed habitable by appropriate fire protection personnel and the shift supervisor;
.                                                                                                      l
: c.      Damage has been assessed and, if necessary, corrective action has been taken to ensure that 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;
.                                                                                                      l
: d.      Turnover procedures that ensure an orderly transfer of control from the remote shutdown panel to the control room have been completed.
l 5.75.3          Repair Procedures                                                            l l
PThe licensee should develop procedures should be developed for performance of repairs        l necessary to achieve and maintain cold shutdown conditions. For alternative shutdown, procedures should be in effect to accomplish repairs necessary to achieve and maintain cold shutdown within 72 hours. For plants that must proceed to cold shutdown prior to 72 hours, the        l procedures should support the required time for initiation of cold shutdown.                          l The performance of repair procedures should not adversely impact operating systems needed to maintain hot shutdown.
The guidance in Regulatory Position 5.7 is based on Appendix R to 10 CFR Part 50, CMEB 9.5-1, GL 81-12, GL 86-10, IN 84-09, and IP 64100.
: 6.      FIRE PROTECTION FOR AREAS IMPORTANT TO SAFETY5.6                                              l Shutdown/Low-Power Operations                                                                          l l
Safe-shutdown requirements and objectives are focused on achieving shutdown                  l conditions for fires occurring during normal at-power operations. During shutdown operations          l (i.e., maintenance or refueling outages), fire risk may increase significantly as a result of work    l activities. In addition, redundant systems important to safety may not be available as allowed by      l plant technical specifications and plant procedures. The FPP should be reviewed to verify that        l fire protection systems, features, and procedures will minimize the potential for fire events to      l impact safety functions (e.g., reactivity control, reactor decay heat removal, spent fuel pool        l cooling) or result in the unacceptable release of radioactive materials, under the differing          l conditions that may be present during shutdown operations.                                            l l
DG-1170, Page 155
 
l 6.      Fire Protection for Areas Important to Safety Several areas within a nuclear power plant present unique hazards or design issues l relative to fire protection and safe shutdown. GThis section provides guidance applicable to specific plant areas is provided in this section.
l 6.1    Areas Related to Power Operation l        6.1.1    Containment l
Fire protection for the primary and secondary containment areas should be provided for l the hazards identified in the fire hazards analysis. Under normal conditions, containment fire hazards may include lubricating oils, hydraulic fluids, cables, electrical penetrations, electrical cabinets, and charcoal filters. During refueling and maintenance operations, additional hazards may be introduced, including contamination control and decontamination materials and supplies, l scaffolding, plastic sheathing, wood planking, chemicals, and hot work. The fire hazards l analysis should evaluate the effects of postulated fires within the primary containment should be evaluated in the Fire Hazard Analysis to ensure that the integrity of the primary coolant system l and containment is not jeopardized and the safe -shutdown performance objectives described in Regulatory Position 5.1 of this guide are met, assuming no action is taken to fight the fire.
Guidance for reactor coolant pump oil collection is provided in Regulatory Position 7.1 of l this guideprovides guidance for RCP oil collection.
l        6.1.1.1          Containment Electrical Separation.
l l        For secondary containment areas, cable fire hazards that could affect safety should be l protected against as described in Regulatory Position 4.1.3.3 of this guide.
DG-1170, Page 156
 
Inside non-inerted containments, one of the fire protection means specified in Regulatory Position 5.53, or one of the following, should be provided.:                                          l C      Separationa. separation of cables and equipment and associated non-safety circuits of    l redundant success pathstrains by a horizontal distance of more than 6.1 m    l (20 ft) with no intervening combustibles or fire hazards; l
: b.      Iinstallation of fire detectors and an automatic fire suppression system in the fire area; or l l
: c.      Sseparation of cables and equipment and associated non-safety circuits of redundant          l success pathstrains by a noncombustible radiant energy shield having a minimum fire          l rating of one-half hour. The fire protection capability of the radiant energy shield may be demonstrated30 minutes, as demonstrated by testing or analysis.                              l DG-1170, Page 157
 
l        6.1.1.2        Containment Fire Suppression.
l l        The licensee Fshould provide fire suppression systems should be provided on the basis of l a fire hazards analysis. During normal operations, containment is generally inaccessible and, l therefore, fire protection should be provided by automatic fixed systems.
Automatic fire suppression capability need not be provided in primary containment atmospheres that are inerted during normal operations. However, inerted containments should have manual firefighting capability, including standpipes, hose stations, and portable extinguishers, to provide protection during refueling and maintenance operations.
Standpipe and hose stations should also be installed inside PWR containments and BWR containments that are not inerted. Standpipe and hose stations inside containment may be connected to a high-quality water supply of sufficient quantity and pressure other than the fire main loop if plant-specific features prevent extending the fire main supply inside containment.
For BWR drywells, standpipe and hose stations should be placed outside the drywell with l adequate lengths of hose, no longer than 30.5 m (100 ft), to reach any location inside the drywell with an effective hose stream.
The containment penetration of the standpipe system should meet the isolation l requirements of GDC 56, Primary Containment Isolation, of Appendix A to 10 CFR Part 50 l and should be Sseismic Category 1 and Quality Group B.
Operation of the fire protection systems should not compromise the integrity of the containment or other systems important to safety. Fire protection activities in the containment areas should function in conjunction with total containment requirements such as ventilation and control of contaminated liquid and gaseous release.
l        AThe licensee should place adequate self-contained breathing apparatus should be l providedes near the containment entrances for firefighting and damage control personnel. These l units should be independent of any breathing apparatuses or air supply systems provided for general plant activities and should be clearly marked as emergency equipment.
l        6.1.1.3        Containment Fire Detection.
l l        Fire detection systems should alarm and annunciate in the control room. In primary containment, fire detection systems should be provided for each fire hazard. For primary and secondary containment, the type of detection used and the location of the detectors should be the l most suitable for the particular type of fire hazard identified by the fire hazards analysis.
A general area fire detection capability should be provided in the primary containment as l backup forto the above described hazard detection. To accomplish this, suitable smoke or heat detectors compatible with the radiation environment should be installed in the air recirculation system ahead of any filters.
DG-1170, Page 158
 
The guidance in Regulatory Position 6.1.1 is based on Appendix R to 10 CFR Part 50, CMEB 9.5-1, and GL 86-10.
6.1.2    Control Room Complex                                                              l l
The control room complex (including galleys, and office spaces, etc.) should be protected  l against disabling fire damage and should be separated from other areas of the plant by floors, walls, and roof having minimum fire -resistance ratings of 3 hours. Peripheral rooms in the        l control room complex should have automatic water suppression and should be separated from the control room by noncombustible construction with a fire -resistance rating of 1 hour.          l Ventilation system openings between the control room and peripheral rooms should have automatic smoke dampers that close onupon operation of the fire detection or suppression          l system. If a gas extinguishing system is used for fire suppression, these dampers should be strong enough to support the pressure rise accompanying the agent discharge and seal tightly against infiltration of the agent into the control room. Carbon dioxide total flooding systems are not acceptable for these areas.
Breathing apparatuses for control room operators should be readily available.              l All cables that enter the control room should terminate in the control room. That is, no cabling should be routed through the control room from one area to another. Cables in under-floor and ceiling spaces should meet the separation criteria necessary for fire protection.
Equipment that is important to safety should be mounted on pedestals or the control room  l should have curbs and drains to direct water away from such equipment. Such drains should be provided with a means for closing to maintain integrity of the control room in the event of other  l accidents requiring control room isolation.
There should be no carpeting in theThe control room should not be carpeted. Where          l carpeting has been installed (e.g., for sound abatement or other human factors), the carpetingit  l should be tested to standards such as ASTM D2859, "StandardStandard Test Method for              l Flammability of Finished Textile Floor Covering Materials," to establish the flammability        l characteristics of the material. These characteristics should be addressed in theThe fire hazards  l analysis should address these characteristics.                                                    l 6.1.2.1          Control Room Fire Suppression.                                            l l
Manual firefighting capability should be provided for both of the following:              l
: a.      Ffire originating within a cabinet, console, or connecting cables; and                    l
: b.      Eexposure fires involving combustibles in the general room area.                          l DG-1170, Page 159
 
Portable Class A and Class C fire extinguishers should be located in the control room. A hose station should be installed inside or immediately outside the control room.
Nozzles that are compatible with the hazards and equipment in the control room should l be provided for the manual hose station. The nozzles chosen should satisfymeet actual firefighting needs, satisfy electrical safety, and minimize physical damage to electrical equipment from hose stream impingement.
Fully enclosed electrical raceways located in under-floor and ceiling spaces, if over 0.09 l m (1 sq ft1 ft2) in cross-sectional area, should have automatic fire suppression inside. Area 2
l automatic fire suppression should be provided for under-floor and ceiling spaces if these spaces l are used for cable runs, unless all cable is run in 10 cm-centimeter (4-inch.) or smaller steel conduit or the cables are in fully enclosed raceways internally protected by automatic fire suppression.
l        6.1.2.2        Control Room Fire Detection.
l l        Smoke detectors should be provided in the control room, cabinets, and consoles. If l redundant safe -shutdown equipment is located in the same control room cabinet or console, additional fire protection measures should be provided. Alarm and local indication should be provided in the control room.
The outside air intake(s) for the control room ventilation system should be provided with smoke detection capability to alarm in the control room to enable manual isolation of the control l room ventilation system and, thus, prevent smoke from entering the control room.
l l 6.1.2.3        Control Room Ventilation.
l l        Venting of smoke produced by fire in the control room by means of the normal ventilation system is acceptable; however, provision should be made to permit isolation of the recirculating portion of the normal ventilation system. Manually operated venting of the control room should be available to the operators.
Air-handling functions should be ducted separately from cable runs in ceiling and floor l spaces. If cables are routed in under-floor or ceiling spaces, these spaces should not be used as air plenums for ventilation of the control room.
The guidance in Regulatory Position 6.1.2 is based on APCSB 9.5-1 and CMEB 9.5-1.
l        6.1.3 6.1.3    Cable Spreading Room l
DG-1170, Page 160
 
A separate cable spreading room should be provided for each redundant division. Cable spreading rooms should not be shared between reactors. Each cable spreading room should be separated from the others and from other areas of the plant by barriers with a minimum fire rating of 3 hours. If this is not possible, an alternative, dedicated, or backup shutdown capability should be provided.
Cable spreading rooms should have the following:                                          l
: a.      Aat least two remote and separate entrances for access by fire brigade personnel;          l
: b.      Aan aisle separation between tray stacks at least 0.9 m (3 ft) wide and 21.45 m (85 ft)    l high;
: c.      Hhose stations and portable extinguishers installed immediately outside the room; and      l
: d.      Aarea fire detection.                                                                      l If division cables are not separated by 3-hour barriers, separation should meet the guidelines of Regulatory Guide 1.75 and the cables should have a suitable fire retardant coating. l (New reactor cables should meet the fire and flame test requirements of IEEE 383 or IEEE 1202.)    l The primary fire suppression in the cable spreading room should be an automatic water system, such as closed-head sprinklers, open-head deluge system, or open directional water spray  l system. Deluge and open spray systems should have provisions for manual operation at a remote station; however, there should be provisions to preclude inadvertent operation. Determination of the location of sprinkler heads or spray nozzles should consider cable tray arrangements and possible transient combustibles to ensure adequate water coverage for areas that could present exposure hazards to the cable system. Cables should be designed to allow wetting down with water supplied by the fire suppression system without electrical faulting.
Open-head deluge and open directional spray systems should be zoned so that a single failure will not deprive the entire area of automatic fire suppression capability.
The use of foam is acceptable providedso long as it is of a type capable of beingthat can  l be delivered by a sprinkler or deluge system.                                                      l Alternative gas systems (Halon, clean agent, or CO2) may be used for primary fire suppression if they are backed up by an installed water spray system and hose stations and portable extinguishers immediately outside the room and if t. The access requirements stated      l above areshould also be met.                                                                      l DFloor drains should be provided to remove firefighting water should be provided.          l When gas systems are installed, drains should have adequate seals or the gas extinguishing systems should be sized to compensate for losses through the drains.
DG-1170, Page 161
 
The ventilation system to each cable spreading room should be designed to isolate the area upon actuation of any gas extinguishing system in the area. Separate manually actuated l smoke venting that is operable from outside the room should be providedconsidered for the cable spreading room.
The guidance in Regulatory Position 6.1.3 is based on APCSB 9.5-1 and CMEB 9.5-1.
l        6.1.4 6.1.4    Plant Computer Rooms l
l        Computer rooms for computers performing functions important to safety that are not part of the control room complex should be separated from other areas of the plant by barriers having l a minimum fire -resistance rating of 3 hours and should be protected by automatic detection and l fixed automatic suppression. Computers that are part of the control room complex but are not l located in the control room should be separated and protected as described in Regulatory Position 6.1.2 for peripheral rooms. Computer cabinets located in the control room should be protected as other control room equipment and cable runs therein. Non-safety-related computers outside the control room complex should be separated from plant areas important to safety by fire barriers with a minimum rating of 3 hours and should be protected as needed to prevent fire and smoke damage to equipment important to safety. Manual hose stations and portable extinguishers should be located in areas containing equipment important to safety. NFPA 75, l "StandardStandard for the Protection of Electronic Computer/Data ProcessingInformation l Technology Equipment," provides additional guidance.
The guidance in Regulatory Position 6.1.4 is based on CMEB 9.5-1.
l        6.1.5 l
l 6.1.5 Switchgear Rooms l
l        Switchgear rooms containing equipment important to safety should be separated from the remainder of the plant by barriers with a minimum fire rating of 3 hours. Redundant switchgear safety divisions should be separated from each other by barriers with a 3-hour fire rating.
Automatic fire detectors should alarm and annunciate in the control room and alarm locally.
Cables entering the switchgear room that do not terminate or perform a function there should be kept at a minimum to minimize the fire hazard. These rooms should not be used for any other purpose. Automatic fire suppression should be provided consistent with other safety considerations. Fire hose stations and portable fire extinguishers should be readily available outside the area.
l        Some high-voltage electrical equipment (e.g., switchgear and transformers) have the l potential for an energetic electrical fault that can damage SSCs important to safety. The fire l hazards analysis should consider the potential for this type of fault.
Equipment should be located to facilitate access for manual firefighting. Drains (see l Regulatory Position 4.1.5 of this guide) should be provided to prevent water accumulation from l damaging equipment important to safety. Remote, manually actuated ventilation should be DG-1170, Page 162
 
providedconsidered for venting smoke when manual fire suppression effort is needed. (sSee          l Regulatory Position 4.1.4).
The guidance in Regulatory Position 6.1.5 is based on CMEB 9.5-1.
6.1.6  of this guide.)                                                                    l l
6.1.6  Remote Shutdown Panels                                                                    l l
Panels providing remote shutdown capability should be separated from the control room complex by bBarriers having a minimum fire rating of 3 hours should separate panels providing      l remote shutdown capability from the control room complex. Panels providing remote shutdown        l capability should be electrically isolated from the control room complex so that a fire in either area will not affect shutdown capability from the other area. The general area housing remote panels important to safety should be provided with automatic fire detectors that alarm locally and alarm and annunciate in the control room. Combustible materials should be controlled and limited to those required for operation. Portable extinguishers and manual hose stations should be readily available in the general area.
The guidance in Regulatory Position 6.1.6 is based on CMEB 9.5-1.
6.1.7                                                                                      l l
Locations containing remote shutdown panels must be habitable under fire and post-fire    l conditions that require their use. Habitability should also be addressed for remote shutdown      l panels protected by or adjacent to areas with gaseous fire suppression systems.                    l l
6.1.7  Station Battery Rooms                                                                      l l
Battery rooms important to safety should be protected against fires and explosions.        l Battery rooms should be separated from each other and other areas of the plant by barriers having a minimum fire rating of 3 hours inclusive of all penetrations and openings. DCThese battery      l rooms should not house dc switchgear and inverters should not be located in these battery rooms. l Automatic fire detection should be provided to alarm and annunciate in the control room and alarm locally. VBattery room ventilation systems in the battery rooms should be capable of        l maintaining the hydrogen concentration well below 2%2 percent. Loss of ventilation should be      l alarmed in the control room. Standpipes, hose stations, and portable extinguishers should be readily available outside the room.
The guidance in Regulatory Position 6.1.7 is based on CMEB 9.5-1.
6.1.8                                                                                      l l
6.1.8  Diesel Generator Rooms                                                                    l l
DG-1170, Page 163
 
l        Diesel generators important to safety should be separated from each other and from other l areas of the plant by fire barriers that have a fire resistancefire-resistance rating of at least 3 l hours. Diesel generators that are not important to safety should be separated from plant areas l containing equipment and circuits important to safety by fire barriers that have a fire-resistance rating of at least 3 hours.
Automatic fire suppression should be installed to suppress or control any diesel generator or lubricating oil fires. Such systems should be designed for operation when the diesel is l runningto operate without affecting the diesel when it is running. Automatic fire detection should be provided to alarm and annunciate in the control room and alarm locally. Hose stations and portable extinguishers should be readily available outside the area. Drainage for firefighting l water should be provided and a means for local manual venting of smoke should be l providedconsidered.
l        Day tanks with a total capacity of up to 41644,164 L (11001,100 gallons) may be located l in therooms with diesel generator areas important to safety under the following conditions:
l a.      The day tank is located in a separate enclosure with a fire -resistance rating of at least 3 hours, including doors or penetrations. These enclosures should be capable of containing the entire contents of the day tanks and should be protected by an automatic fire suppression system; or l .
: b.      The day tank is located inside the diesel generator room in a diked enclosure that has l        sufficient capacity to hold 110%110 percent of the contents of the day tank or is drained to a safe location.
The guidance in Regulatory Position 6.1.8 is based on CMEB 9.5-1.
DG-1170, Page 164
 
6.1.9  Pump Rooms                                                                          l l
Pump houses and rooms housing redundant pump trains important to safety should be          l separated from each other and from other areas of the plant by fire barriers having at least 3-hour ratings. These rooms should be protected by automatic fire detection and suppression unless a fire hazards analysis can demonstrate that a fire will not endanger other equipment required for safe plant shutdown. Fire detection should alarm and annunciate in the control room and alarm locally. Hose stations and portable extinguishers should be readily accessible.
Equipment pedestals, curbs, and floor drains should be provided to prevent water accumulation from damaging equipment important to safety. (sSee Regulatory Position 4.1.5 of        l this guide.).                                                                                      l Provisions should be made for manual control of the ventilation system to facilitate smoke removal if required for manual firefighting operation. (sSee Regulatory Position 4.1.4).      l The guidance in Regulatory Position 6.1.9 is based on CMEB 9.5-1.
6.2    Other Areas of this guide.)                                                                l l
6.2    Other Areas                                                                                l Other areas within the plant may contain hazards or equipment that warrant special consideration relative to fire protection, including areas containing significant quantities of radioactive materials, yard areas containing water supplies or systems important to safety, and the plant cooling tower.
6.2.1  New Fuel Areas                                                                      l l
Portable hand extinguishers should be located near this area. Also, hose stations should    l be located outside but within hose reach of this area. Automatic fire detection should alarm and annunciate in the control room and alarm locally. Combustibles should be limited to a minimum in the new fuel area. The storage area should be provided with a drainage system to preclude accumulation of water.
The storage configuration of new fuel should always be maintained to preclude criticality for any water density that might occur during fire water application.
The guidance in Regulatory Position 6.2.1 is based on CMEB 9.5-1.
6.2.2                                                                                      l l
6.2.2  Spent Fuel Areas                                                                            l l
DG-1170, Page 165
 
l        Protection for the spent fuel pool area should be provided by localLocal hose stations l and portable extinguishers should provide protection for the spent fuel pool. Automatic fire detection should be provided to alarm and annunciate in the control room and to alarm locally.
The guidance in Regulatory Position 6.6.2 is based on CMEB 9.5-1.
l        6.2.3 Regulatory Guide 1.191 provides additional guidelines relative to fire protection l of spent fuel areas for permanently shut down reactors that have not completed removal of the l spent fuel to an independently licensed storage facility.
l l 6.2.3 Radwaste Building/Storage Areas and Decontamination Areas l
l        Radioactive waste buildings, storage areas, and decontamination areas should be separated from other areas of the plant by fire barriers having at least 3-hour ratings. Automatic sprinklers should be used in all areas where combustible materials are located. Alternatively, l manual hose stations and portable extinguishers (hand-held and large -wheeled units sized according to the hazards) are acceptable. Automatic fire detection should be provided to annunciate and alarm in the control room and alarm locally. Ventilation systems in these areas should be capable of being isolated to prevent the release of radioactive materials to other areas or the environment. Water from firefighting activities should drain to liquid radwaste collection systems.
Materials that collect and contain radioactivity, such as spent ion exchange resins, charcoal filters, and HEPA filters, should be stored in closed metal tanks or containers that are located in areas free from ignition sources or combustibles. These materials should be protected from exposure to fires in adjacent areas as well. Consideration should be given to requirements for removal of decay heat from entrained radioactive materials.
The guidance in Regulatory Position 6.2.3 is based on CMEB 9.5-1.
l        6.2.4 Dry Cask          Independent Spent Fuel Storage Areas l
l        FThe requirements of 10 CFR 72.122(c) address fire protection of dry cask storage is l addressed byand other independent spent fuel storage facilities. The fire protection provided for l these facilities should be commensurate with the potential fire hazards and with the potential for l an unacceptable release of radiation during and following a fire. In addition to the requirements l of 10 CFR Part 7210 CFR Part 72, Licensing Requirements for the Independent Storage of l Spent Nuclear Fuel and, High-Level Radioactive Waste. In addition to the requirements of 10 l CFR Part 72, and Reactor-Related Greater Than Class C Waste, fire protection for independent spent fuel storage installations should ensure that fires involving such installations will not impact plant operations and plant areas important to safety.
l        6.2.5    Water Tanks l
l        Storage tanks that supply water for safe shutdown should be protected from the effects of an exposure fire. Combustible materials should not be stored next to outdoor tanks.
DG-1170, Page 166
 
The guidance in Regulatory Position 6.2.5 is based on CMEB 9.5-1.
6.2.6    Cooling Towers                                                                        l l
Cooling towers should beconstructed of noncombustible construction or sobe located and        l protected in such a way that a fire will not adversely affect any systems or equipment important      l to safety. Cooling towers should be of noncombustible construction when the basins are used for the ultimate heat sink or for the fire protection water supply.
The guidance in Regulatory Position 6.2.6 is based on CMEB 9.5-1.
: 7.      PROTECTION OF SPECIAL FIRE HAZARDS EXPOSING AREAS IMPORTANT TO SAFETY 7.1    For the latter, provisions should be made to ensure a continuous supply of fire protection    l water whenever the cooling tower basin is drained for cleaning or other maintenance.                  l l
: 7.      Protection of Special Fire Hazards Exposing Areas Important to Safety                          l l
7.1    Reactor Coolant Pump Oil Collection                                                            l The reactor coolant pump (RCP)External RCPs with oil lubrication systems should be            l equipped with an oil collection system if the containment is not inerted during normal operation.
The oil collection system should be so designed, engineered, and installed to ensure that failure      l will not lead to fire during normal or design -basis accident conditions and that there is            l reasonable assurance that the system will withstand the safe -shutdown earthquake.                    l Such collection systems should be capable of collecting lube oil from all potential pressurized and unpressurized leakage sites in the RCP lube oil systems. Leakage should be collected and drained to a vented closed container that can hold the entire lube oil system inventory. A flame arrester is required in the vent if the flashpoint characteristics of the oil present the hazard of fire flashback. Leakage points to be protected should include, but are not limited to, lift pump and piping, overflow lines, lube oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and lube oil reservoirs wheren such features exist on the RCPs.      l The drain line should be large enough to accommodate the largest potential oil leak.
DG-1170, Page 167
 
One or more tanks need to be provided with sufficient capacity to collect the total lube oil inventory from all RCPs draining to the container.
l        Alternatives that may be acceptable areinclude the following:
: a.      One or more tanks are provided with sufficient capacity to hold the total lube oil inventory of one RCP with margin if the tank is located such that any overflow from the tank will be drained to a safe location where the lube oil will not present an exposure fire hazard to or otherwise endanger equipment important to safety; or l .
l b.      Where the RCP lube oil system is shown, by analysis, to be capable of withstanding the l        safe -shutdown earthquake (SSE) (eliminating the consideration of simultaneous lube oil system ruptures from a seismic event), protection is provided for random leaks at l        mechanical joints in the lube oil system (e.g., flanges, RTDresistance temperature l        detectors connections, sightglasses). Alternative methods of protection may be deemed acceptable for such designs. In RCP lube oil collection systems of such designs, one or more tanks need to be provided with sufficient capacity to hold the total lube oil inventory of one RCP with margin. Because protection is required only against possible leakage resulting from random leaks from the one pump at a time, any overflow from the l        tanks need not be considered; or .
: c.      For pumps with the lube oil contained entirely within the pump casing, an oil collection system may not be required provided it can be shown that there are no potentially significant leakage points.
The guidance in Regulatory Position 7.1 is based on Appendix R to 10 CFR Part 50, CMEB 9.5-1, GL 86-10, IN 84-09, and Vollmer Memo (1983a).
l 7.2    Turbine/Generator Building The turbine building should be separated from adjacent structures containing equipment important to safety by a fire barrier with a rating of at least 3 hours. The fire barriers should be designed to maintain structural integrity even in the event of a complete collapse of the turbine structure. Openings and penetrations in the fire barrier should be minimized and should not be located where the turbine oil system or generator hydrogen cooling system creates a direct fire l exposure hazard to the barrier. Considering the severity of the fire hazards, defense -in -depth may dictate additional protection to ensure barrier integrity.
The guidance in Regulatory Position 7.2 is based on CMEB 9.5-1.
l        7.2.1 Oil Systems and the potential effect of a major turbine building fire on the ability l to maintain operator control of the plant and safely shut down should be evaluated.
DG-1170, Page 168
 
7.2.1  Oil Systems                                                                                l l
Turbine buildings contain large sources of combustible liquids, including reservoirs and piping for lube oil, seal oil, and electro-hydraulic systems. These systems should be separated from systems important to safety by 3-hour rated barriers. Additional protection should be provided on the basis of the hazard, or where fire barriers are not provided. (See Regulatory Position 2.1.3.)
The guidance in Regulatory Position is based on ASB 9.5-1.
7.2.2 Hydrogen System Turbine-generators of this guide.)                                                        l l
7.2.2  Hydrogen System                                                                            l l
Turbine generators may use hydrogen for cooling. Hydrogen storage and distribution        l systems should meet the guidelines provided in Regulatory Position 7.5 of this guide.
7.2.3  Smoke Control                                                                      l l
Smoke control should be provided in the turbine building to mitigate potential heavy      l smoke conditions associated with combustible liquid and cable fires. Specific guidance is provided in Regulatory Position 4.1.4 of this guideprovides specific guidance.                    l 7.3    Station Transformers                                                                      l Transformers installed inside fire areas containing systems important to safety should be of the dry type or insulated and cooled with noncombustible liquid. Transformers filled with combustible fluid that are located indoors should be enclosed in a transformer vault. ANFPA 70    l offers additional guidance is provided in NFPA 70.                                                l Outdoor oil-filled transformers should have oil spill confinement features or drainage away from the buildings. Such transformers should be located at least 15.2 m (50 ft) distant from the building, or building walls within 15.2 m (50 ft) of oil-filled transformers should be without openings and have a fire -resistance rating of at least 3 hours.                                  l The guidance in Regulatory Position 7.3 is based on CMEB 9.5-1.
7.4    Diesel Fuel Oil Storage Areas                                                              l Diesel fuel oil tanks with a capacity greater than 41644,164 L (1,100 gallons) should not  l be located inside buildings containing equipment important to safety. If above-ground tanks are used, they should be located at least 15.2 m (50 ft) from any building containing equipment important to safety, or if located within 15.2 m (50 ft), they should be housed in a separate building with constructionconstructed with materials having a minimum fire -resistance rating of  l 3 hours. Potential oil spills should be confined or directed away from buildings containing DG-1170, Page 169
 
l equipment important to safety. Totally buried tanks are acceptable outside or under buildings.
l (sSee NFPA 30 for additional guidance.).
l          Above-groundAn automatic fire suppression system should protect aboveground oil storage, including those tanks located in a separate building, should be protected by an automatic fire suppression system.
The guidance in Regulatory Position 7.4 is based on CMEB 9.5-1.
l 7.5      Flammable Gas Storage and Distribution Bulk gas storage (either compressed or cryogenic) should not be permitted inside structures housing equipment important to safety. Storage of flammable gas such as hydrogen l should be located outdoors or in separate, detached buildings so that a fire or explosion will not adversely affect any systems or equipment important to safety. NFPA 50A and 50B provide additional guidance.
Care should be taken to locate high-pressure gas storage containers with the long axis parallel to building walls. This will minimize the possibility of wall penetration in the event of a l container failure. Acetylene-Ooxygen gas cylinder storage locations should not be in areas that contain or expose equipment important to safety or the fire protection systems that serve those equipment areas. A permit system should be required for use of l Acetylene-Oxygenacetylene-oxygen gas storage cylinders in areas of the plant important to safety. NFPA 55, "Standard for the Storage, Use, and Handling of Compressed and Liquefied Gases in Portable Cylinders," provides additional guidance.
Risks to equipment important to safety from hydrogen supply systems can be minimized l by designing hydrogen lines in plant areas important to safety to Sseismic Class I requirements, l sleeving the piping such that the pipe is directly vented to the outside, or. Risks can also be l minimized through the use of restricting orifices or excess flow valves to limit the maximum flow rate from the storage facility to the areas of concern so that in case of a line break, the l hydrogen concentration in the affected areas will not exceed 2%2 percent. This approach includes pre-operational testing and subsequent retesting of excess flow valves and measures to prevent buildup of unacceptable amounts of trapped hydrogen and inadvertent operation with the safety features bypassed. A somewhat less cost-effective alternative involves use of a normally l isolated supply with intermittent manual makeup. AEPRI NP-5283-SR-A, Guidelines for l Permanent BWR Hydrogen Water Chemistry Installations, provides additional guidelines and criteria for the design, installation, and operation of flammable cryogenic and compressed gas systems are provided in EPRI NP-5283-SR-A.
l          The guidance.
l DG-1170, Page 170
 
7.6    Nearby Facilities                                                                                l l
The FPP should address plant support facilities (e.g., offices, maintenance shops,              l warehouses, temporary structures, equipment storage yards), collocated power generating units            l (e.g., nuclear, coal, natural gas), and nearby industrial facilities (e.g., chemical plants, refineries, l manufacturing facilities) to the extent that fires and or explosions in these facilities may affect      l equipment important to safety. Fire protection systems and features should be adequate to                l protect against potential exposure fires and explosions from nearby facilities.                          l l
: 8.      Fire Protection for New Reactors                                                                l l
8.1    General                                                                                          l l
Many of the current fire protection requirements and guidelines for operating reactors          l were issued after Commission approval of construction permits and/or operating licenses. The            l backfit of these requirements and guidelines to existing plant designs created the need for              l considerable flexibility in the application of the regulations on a plant-by-plant basis. New            l reactor designs should integrate fire protection requirements, including the protection of safe-        l shutdown capability and the prevention of radiological release, into the planning and design            l phase for the plant. In addition, new reactor designs should minimize or eliminate the use of            l alternative/dedicated shutdown systems and should only rely on such systems when it is not              l feasible to provide the required protection for redundant safe-shutdown systems, such as in the          l main control room. Similarly, when practical, reliance on operator manual actions should be              l avoided and reliance on localized electrical raceway fire barrier systems should be minimized.          l l
Unless specifically noted otherwise, the guidance in this regulatory guide is applicable to      l the FPP for new reactor plants. DG-1145, Combined License Applications for Nuclear Power                l Plants (LWR Edition), provides guidance regarding the scope and content of the COL                      l application for new reactors.                                                                            l l
8.2    Enhanced Fire Protection Criteria                                                                l l
New reactor designs should ensure that safe-shutdown can be achieved assuming that all          l equipment in any one fire area will be rendered inoperable by fire and that reentry into the fire        l area for repairs and operator actions is not possible. Because of its physical configuration, the        l control room is excluded from this approach, provided the design includes an independent                l alternative shutdown capability that is physically and electrically independent of the control          l room. The control room should be evaluated to ensure that the effects of fire do not adversely          l affect the ability to achieve and maintain safe shutdown. New reactors should provide fire              l protection for redundant shutdown systems in the reactor containment building that will ensure,          l to the extent practicable, that one shutdown division will be free of fire damage. Additionally,        l new reactor designs should ensure that smoke, hot gases, or the fire suppressant will not migrate        l into other fire areas to the extent that they could adversely affect safe-shutdown capabilities,        l including operator actions.                                                                              l l
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l 8.3    Passive Plant Safe-Shutdown Condition l
l        As discussed in SECY-94-084, the definitions of safe shutdown contained in the l Commissions regulations and guidelines do not address the inherent limitations of passive RHR l systems.
l l        In GDC 34, Residual Heat Removal, of Appendix A to 10 CFR Part 50, the NRC l regulations require that the design include an RHR system to remove residual heat from the l reactor core so that specified acceptable fuel design limits are not exceeded. GDC 34 further l requires suitable redundancy of the components and features of the RHR system to ensure that l the system safety functions can be accomplished, assuming a loss of offsite power or onsite l power, coincident with a single failure.
l l        Passive reactor designs are limited by the inherent ability of the passive heat removal l processes and cannot reduce the temperature of the reactor coolant system below the boiling l point of water for heat transfer to occur between the reactor coolant and the heat sink. The plant l designs include cooling systems to bring the reactor to cold shutdown or refueling condition; l however, these systems are not safety grade. These nonsafety-grade systems (i.e., makeup water l to the heat sink and cool-down capability) are necessary to maintain long-term cooling (i.e.,
l beyond 72 hours) and must be capable of accomplishing their respective functions without l damage to the fuel as demonstrated by design and analysis.
l l        Based on the discussion and recommendations of SECY-94-084, the passive decay heat l removal systems must be capable of achieving and maintaining 215.6 EC (420 EF) or below for l non-LOCA events. This safe-shutdown condition is predicated on demonstration of acceptable l passive safety system performance.
l l 8.4    Applicable Industry Codes and Standards l
l        In general, the FPP for new light-water reactor designs should comply with the provisions l specified in NFPA 804, Standard for Fire Protection for Advanced Light-Water Reactor Electric l Generating Plants, as they relate to the protection of post-fire safe-shutdown capability and the l mitigation of a radiological release resulting from a fire. However, the NRC has not formally l endorsed NFPA 804 and some of the guidance in the NFPA standard conflicts with regulatory l requirements. When conflicts occur, the applicable regulatory requirements and guidance, l including the guidance in this regulatory guide, will govern. The standards of record related to l the design and installation of fire protection systems and features required to satisfy NRC l requirements in all new reactor designs are those NFPA codes and standards in effect 180 days l before the submittal of the application under 10 CFR Part 50 or 10 CFR Part 52.
l l 8.5    Other New Reactor Designs l
l        Fire protection programs for proposed new non-light-water reactor designs should meet l the overall fire protection objectives and guidance provided in the applicable regulations and this l regulatory guide as they relate to safe shutdown and radiological release, as well as the specific l fire protection requirements, as applicable. Fire hazards should be identified, evaluated, and an DG-1170, Page 172
 
appropriate level of protection provided to meet these objectives. Design reviews and testing      l programs should confirm the safe-shutdown capability. SSCs important to safe shutdown should      l be protected in accordance with the enhanced criteria described above for light-water reactors. l l
8.6    Fire Protection Program Implementation Schedule                                            l l
SECY-05-0197, Review of Operational Programs in a Combined License Application            l and Generic Emergency Planning Inspections, Tests, Analyses, and Acceptance Criteria,            l identifies fire protection as an operation program. However, only those elements of the FPP      l that will not be implemented fully until the completion of the plant should be addressed as an    l operational program. This may include, but is not be limited to, the fire brigade, combustible and l ignition source control program, procedures and prefire plans, and portable extinguishing          l equipment. The COL application should identify the operational program aspects of the FPP and      l the implementation schedule for each. In lieu of the implementation schedule, the applicant may    l propose inspections, tests, analyses, and acceptance criteria for these aspects of the program. l l
8.7    Fire Protection for Nonpower Operation                                                    l l
NRC regulations and guidance do not specifically address fire protection during            l nonpower modes of plant operation (e.g., during shutdown for maintenance and/or refueling)        l except for existing plants that adopt an NFPA 805 FPP. However, the requirements for fire          l prevention in Regulatory Position 7.5 is based on CMEB 9.5-1 and GL 93-06.                        l D.      IMPLEMENTATION 2 of this guide apply to all modes of plant operation, including shutdown. License applications    l for new reactors should also address any special provisions to ensure that, in the event of a fire l during a nonpower mode of operation, the plant can be maintained in safe shutdown.                l l
DG-1170, Page 173
 
l 9.      Fire Protection for License Renewal l
l          Licensees may apply for a license renewal to permit continued plant operation beyond the l original operating license period of operation, in accordance with the provisions of 10 CFR Part l 54. The fire protection licensing and design basis under license renewal should not differ l significantly from that in effect before renewal with the exception that fire protection SSCs must l be included in an aging management program as appropriate.
l l          As stated in 10 CFR Part 54.21, Contents of ApplicationTechnical Information, those l components with intended functions that are identified within the scope of license renewal, those l components which are passive (i.e., they do not perform their functions with moving parts) and l long-lived (i.e., they are not subject to replacement based on qualified life or routine l replacement) are subject to an aging management review (AMR). Examples of fire protection l components that are passive and long-lived and, therefore, would be subject to an AMR, include l fire barrier assemblies (e.g., ceilings, damper housing, doors, floors, penetration seals walls),
l sprinkler heads, fire suppression system piping and valves casings, and fire protection tanks and l pump casings, and fire hydrant casings. Active components are defined as components which l perform an intended function as described in 10 CFR 54.4, Scope, with moving parts or with a l change in configuration or properties; as such, they are excluded from the AMR. For example, l smoke/heat detectors are considered active components.
l l          Certain passive and long-lived components are considered consumables and, therefore, l are not subject to an AMR. System filters, fire extinguishers, fire hoses, and air packs (within the l scope of license renewal) may be excluded, on a plant-specific basis, from an AMR under 10 l CFR 54.21(a)(1)(ii). These components are considered within the scope of license renewal and l are typically replaced based on specific performance and condition monitoring activities that l clearly establish a routine replacement practice based on a qualified life of the component. An l AMR may exclude these components based on specific performance and condition monitoring l activities provided that the applicant (1) identifies and lists in the license renewal application l each component type subject to such replacement, and (2) identifies the applicable monitoring l and replacement programs that conform to appropriate standards (e.g., NFPA standards).
l l          For all components identified within the scope of license renewal and subject to an AMR, l programs must be in place to maintain each components intended function throughout the period l of extended operation. For example, the intended function of fire suppression piping or the fire l pump casing is to provide a pressure boundary. Programs to manage the aging effects of the l pressure boundary can be existing plant programs, modified (or enhanced) programs, or new l programs specifically created to address aging concerns. The development of modified or newly l created programs is dependent upon (1) the aging effect that needs to be managed, and (2) the l ability of the current program to manage the aging effect throughout the period of extended l operation.
l l          Plants that have installed Halon 1301 extinguishing systems that will be credited during l the extended life of the plant should have a plan for continued access to an adequate supply of l replacement Halon or a plan to replace the system.
l DG-1170, Page 174
 
l D. IMPLEMENTATION                                              l l
The purpose of this section is to provide information to applicants and licensees regarding l the NRC staffs plans for using this draft regulatory guide. No backfitting is intended or          l approved in connection with the issuance of this guide.                                            l Except inits issuance.                                                                      l l
The NRC has issued this draft guide to encourage public participation in its development. l Except in those cases in which aan applicant or licensee proposes or has previously established    l an acceptable alternative method for complying with specified portions of the NRCs                l regulations, the methods to be described in thisthe active guide willwill reflect public comments  l and will be used in the evaluation of licenseein evaluating compliance with the requirements of    l 10 CFR 50.48. This guide will also be usedCFR 50.48 for license applications, license              l amendment applications, and exemption requests. The staff will also use this guide to evaluate      l submittals from operating reactor licensees who initiate proposed changes to their fire protection  l programs that are initiated by the licenseeFPPs if there is a clear nexus between the proposed      l change and this guidance.
GLOSSARY l
l l
REGULATORY ANALYSIS                                            l l
The NRC published a regulatory analysis with the draft of this guide when it was            l originally issued for public comment as Draft Regulatory Guide DG-1097, in June 2000. No            l changes were necessary, so the NRC staff has not prepared a separate regulatory analysis for this  l draft revision of Regulatory Guide 1.189. A copy of the regulatory analysis is available for        l inspection or copying for a fee in the NRCs Public Document Room at 11555 Rockville Pike,          l Rockville, Maryland.                                                                                l l
l BACKFIT ANALYSIS                                            l l
l Text Moved Here: 12                                                                                l This draft regulatory guide does not require a backfit analysis as described in 10 CFR      l 50.109(c) because it does not impose a new or amended provision in the NRCs rules or a regulatory staff position interpreting the Commission rules that is either new or different from a previous applicable staff position. In addition, this draft regulatory guide does not require the  l modification or addition to systems, structures, components,SSCs or design of a facility, or the    l procedures or organization required to design, construct, or operate a facility. Rather, a licensee l can select a preferred method for achieving compliance with a license or the rules or the orders of DG-1170, Page 175
 
l  the Commission as described in 10 CFR 50.109(a)(7). This draft regulatory guide provides an l  opportunity to use the standards described herein if that is a licensees preferred method.the l licensee chooses to do so.
l End Of Moved Text l
l l
l                                              GLOSSARY l
l Administrative ControlsPolicies, procedures, and other elements that relate to the FPP.
l Administrative controls include but are not limited to inspection, testing, and maintenance of fire l protection systems and features; compensatory measures for fire protection impairments; review l of the impact of plant modifications on the FPP; fire prevention activities; fire protection l staffing; control of combustible/flammable materials; and control of ignition sources.
l l Alternative Shutdown  TheShutdownThe capability to safely shut down the reactor in the l event of a fire using existing systems that have beenthat is required when it is not feasible to l provide the required protection for redundant safe-shutdown trains in one or more fire areas or l where fire suppression activities, including inadvertent operation or rupture of a water l suppression system, could prevent safe shutdown. Appendix R to 10 CFR Part 50 allows an l existing plant system to be rerouted, relocated, or modified.
l Approved  Tested (at the time the need for an alternative means of shutdown is identified but l not during or after the fire) such that it can perform the required safe-shutdown function that the l fire- or water-damaged redundant system would normally perform. (See also Dedicated l Shutdown and Success Path.)
l l Any-and-AllThe scope of potential fire-induced circuit failures or spurious operations in a fire l area. The post-fire safe-shutdown circuit analysis should address any-and-all possible failures l and spurious operations caused by the failures, including combinations of multiple l failures/operations, that could prevent safe shutdown. (See RIS 2005-30 for a discussion of the l scope of spurious operation analysis.)
l l ApprovedTested and accepted for a specific purpose or application by a recognized testing laboratory.
Associated Circuits  Circuits that do not meet the separation requirements for safe shutdown systems and components and are associated with safe shutdown systems and components by common power supply, common enclosure, or the potential to cause spurious operations that could prevent or adversely affect the capability to safely shut down the reactor as a result of fire-induced failures (hot shorts, open circuits, and short to ground).
l Automatic  Self-acting or reviewed and specifically approved by the NRC in accordance with l the appropriate regulatory process (e.g., 10 CFR 50.12).
l DG-1170, Page 176
 
AutomaticSelf-acting, operating by its own mechanism when actuated by some monitored              l parameter such as a change in current, pressure, temperature, or mechanical configuration.
Combustible Material  AnyMaterialAny material that will burn or sustain the combustion            l process when ignited or otherwise exposed to fire conditions.
Common Enclosure  AnEnclosureAn enclosure (e.g., cable tray, conduit, junction box)              l that contains circuits required for the operation of safe -shutdown components and circuits for    l non-safe shutdownnonsafe-shutdown components.                                                      l Common Power Supply  ASupplyA power supply that feeds safe -shutdown circuits and                l non-safe shutdownnonsafe-shutdown circuits.                                                        l Control Room Complex  TheComplexThe zone served by the control room emergency                    l ventilation system.
Dedicated Shutdown  The abilityShutdownThe capability to shut down the reactor and                l maintain shutdown conditions using structures, systems, or components dedicated to the purpose of accomplishingby adding new SSCs to an existing plant that are dedicated to performing post-      l fire safe -shutdown functions. Like alternative shutdown, plant operators use dedicated            l shutdown when it is not feasible to provide the required protection for redundant safe-shutdown    l trains in one or more fire areas. (See also Alternative Shutdown and Success Path.)                l l
l Text Moved Here: 11                                                                                l Electrical Raceway Fire Barrier  Non-load-bearing SystemNon-load-bearing partition                l type envelope system installed around electrical components and cabling that are rated by test laboratories in hours of fire resistance and are used to maintain safe -shutdown functions free of  l fire damage.
End Of Moved Text                                                                                  l Emergency Control Station  LocationA location/device outside the main control room                l where actions are taken by operations personnel tocan manipulate plant systems and controls to      l achieve safe shutdown of the reactor. Emergency control stations can include control panels and    l individual devices such as valves, switches, and circuit breakers. III.G.1 protection for redundant l safe-shutdown systems may not be claimed for redundant systems in a III.G.2 area by crediting      l an operator manual action at an emergency control station. Unless alternative or dedicated          l shutdown capability is provided, redundant circuits credited for post-fire safe-shutdown and        l located in the same fire area must be protected in accordance with III.G.2 without the use of      l emergency control stations of any kind.                                                            l Exposure Fire  AFireA fire in a given area that involves either in situ or transient              l combustibles and is external to any structures, systems, and componentsSSCs important to safety    l located in or adjacent to that same area. The effects of such fire (e.g., smoke smoke, heat, or    l ignition) can adversely affect those structures, systems, and componentsSSCs important to safety. l DG-1170, Page 177
 
l Thus, a fire involving one success path of safe -shutdown equipment may constitute an exposure fire for the redundant success path located in the same area, and a fire involving combustibles l other than those in either redundant success path may constitute an exposure fire to bothmultiple l redundant trainssuccess paths located in the same area.
l Fire Area  TheAreaThe portion of a building or plant that is separated from other areas by rated fire barriers adequate for the fire hazard.
l Fire Barrier  ComponentsBarrierComponents of construction (walls, floors, and their supports), including beams, joists, columns, penetration seals or closures, fire doors, and fire l dampers, that are rated by approving laboratories in hours of resistance to fire, that are used to prevent the spread of fire.
l Fire Brigade  ABrigadeA team of on-site plant personnel that have beenis qualified and equipped to perform manual fire suppression activities.
l Fire Hazard  The existence of conditionsHazardsConditions that involve the necessary elements to initiate and support combustion, including in situ or transient combustible materials, ignition sources (e.g., heat, sparks, open flames), and an oxygen environment.
l Fire Hazard Analysis  AnAnalysisAn analysis used to evaluate the capability of a nuclear l power plant to perform safe -shutdown functions and minimize radioactive releases to the l environment in the event of a fire. The analysis includes the following features:
l a.      Iidentification of fixed and transient fire hazards.
l l b.      Iidentification and evaluation of fire prevention and protection measures relative to the identified hazards.
l l c.      Eevaluation of the impact of fire in any plant area on the ability to safely shut down the l          reactor and maintain shutdown conditions, as well as to minimize and control the release l          of radioactive material l
l Fire Protection FeatureAdministrative controls, emergency lighting, fire barriers, fire l detection and suppression systems, fire brigade personnel, and other features provided for fire l protection purposes.
l l Fire Protection Program  TheProgramThe integrated effort involving components, l procedures, analyses, and personnel utilized in defining and carrying out all activities of fire protection. It includes system and facility design, fire prevention, fire detection, annunciation, confinement, suppression, administrative controls, fire brigade organization, inspection and maintenance, training, quality assurance, and testing.
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Fire Protection SystemFire detection, notification, and suppression systems designed,                l installed, and maintained in accordance with the applicable nationally recognized codes and            l standards endorsed by the NRC.                                                                        l l
Fire Resistance  The ability of an element of building construction, component, or structure        l to fulfill, for a stated period of time, the required load-bearing functions, integrity, thermal insulation, or other expected duty specified in a standard fire-resistancefire resistance test.        l Fire -Resistance Rating  TheRatingThe time that materials or assemblies have withstood a            l fire exposure as established in accordance with the test procedures of NFPA 251, Standard            l Methods of Tests of Fire Endurance of Building Construction and Materials.                            l Fire Retardant Material  Means materialMaterial that has been coated or treated with                l chemicals, paints, or other materials that are designed to reduce the combustibility of the treated material.
Fire Risk  Refers to theRiskThe combination of the probability and consequences of a                l given fire event occurring and the estimated consequences of the event should it occur.
Fire Stop  Abased on consideration of (1) What can go wrong? (2) How likely is it? and (3)            l What are the consequences if it occurs?                                                                l l
Fire StopA feature of construction that prevents fire propagation along the length of cables or      l prevents fire from spreading of fire to nearby combustibles within a given fire area or fire zone. l Fire Suppression  ControlSuppressionControl and extinguishing of fires (firefighting).              l Manual fire suppression is the use of hoses, portable extinguishers, or manually actuated fixed systems by plant personnel. Automatic fire suppression is the use of automatically actuated fixed systems such as water, Halon, or carbon dioxideCO2 systems.                                            l Fire Watch  IndividualsWatchIndividuals responsible for providing additional (e.g.,                  l during hot work) or compensatory (e.g., for for system impairments) coverage of plant activities      l or areas for the purposes of detecting fires or for identifying activities and conditions that present a potential fire hazard. The individuals should be trained in identifying conditions or activities that present potential fire hazards, as well as the use of fire extinguishers and the proper fire notification procedures.
Fire Zones  SubdivisionsZonesSubdivisions of fire areas.                                            l Free of Fire Damage  The structure, system, or componentDamageThe SSCs (including                    l electrical circuits) under consideration isare capable of performing its intendedtheir required        l post-fire safe-shutdown functions during and after the postulated fire, as needed, without repair. l The crediting of operator actions to restore damaged SSCs or to mitigate the consequences of the      l fire-induced damage should be in accordance with Regulatory Position 5.3.3 of this guide.              l DG-1170, Page 179
 
l Hazardous Material  AMaterialA substance that, upon release, has the potential of l causingto cause harm to people, property, or the environment.
l High -Impedance Fault  AFaultA circuit fault condition resulting in a short -to -ground, or l conductor -to -conductor hot short, where residual resistance in the faulted connection maintains the fault current level below the components circuit breaker long-term setpoint.
l Hot Short  IndividualShortIndividual conductors of the same or different cables come in l contact with each other and may result in an impressed voltage or current on the circuit being analyzed.
l Hot Work  ActivitiesWorkActivities that involve the use of heat, sparks, or open flame l such as cutting, welding, and grinding.
l Impairment  TheImpairmentThe degradation of a fire protection system or feature that l adversely affects the ability of the system or feature to perform its intended function.
l Important to Safety  NuclearSafetyNuclear power plant structures, systems, and l componentsSSCs important to safety are those required to provide reasonable assurance that l the facility can be operated without undue risk to the health and safety of the public.of the public.
l In Appendix R to Part 50, important to safety and safety related apply to all safety functions.
l Interrupting Device  ADeviceA breaker, fuse, or similar device installed in an electrical l circuit to isolate the circuit (or a portion of the circuit) from the remainder of the system in the l event of an overcurrent or fault downstream of the interrupting device.
l In situ Combustibles  CombustibleCombustiblesCombustible materials that constitute l part of the construction, fabrication, or installation of plant structures, systems, and l componentsSSCs and as such are fixed in place.
l Isolation Device  ADeviceA device in a circuit that prevents malfunctions in one section of l a circuit from causing unacceptable influences in other sections of the circuit or other circuits.
l Listed  EquipmentListedEquipment or materials included on a list published by a recognized testing laboratory, inspection agency, or other organization concerned with product evaluation that maintains periodic inspection of production of listed equipment or materials, and whose listing states that certain specific equipment or materials meet nationally recognized l standards and have been tested and found suitable for use in a specified manner.
l MitigatePerformance of an action that stops the progression of or reduces the severity of an l unwanted condition. With respect to nuclear plant fire protection, mitigation generally refers to l operator actions inside or outside the main control room to restore the capability to achieve and l maintain safe shutdown where a fire has degraded that capability.
l DG-1170, Page 180
 
New ReactorsThose reactors that are significantly different in operation from the current        l generation light-water reactors and provide enhanced margins of safety or utilize simplified,    l inherent, or other innovative means to accomplish their safety functions.                        l l
Noncombustible Material  Material(a) Material that, in the form in which it is used and        l under conditions anticipated, will not ignite, burn, support combustion, or release flammable vapors when subjected to fire or heat, or (b) material having a structural base of noncombustible l material, with a surfacing not over 1/8 inch3 mm (c inch) thick that has a flame spread rating    l not higher than 50 when measured in accordance with ASTM E--84, "StandardStandard Test          l Method for Surface Burning Characteristics of Building Materials."                              l l
One-at-a-TimeAn approach to post-fire safe-shutdown circuit analysis that assumes only one      l spurious operation can occur in any single fire or that multiple spurious operations will occur  l only one-at-a-time, permitting any required mitigation to achieve and maintain safe shutdown to  l be performed on an individual basis without consideration of possible simultaneous spurious      l operations. This approach does not comply with fire protection regulatory requirements.          l Open Circuit  ACircuitA failure condition that results when a circuit (either a cable or        l individual conductor within a cable) loses electrical continuity.
Operator ActionA normal action taken by an operator inside the main control room to              l achieve and maintain post-fire safe-shutdown, not including repairs.                              l l
Operator Manual ActionActions performed by operators to manipulate components and                l equipment from outside the main control room to achieve and maintain post-fire hot shutdown,      l not including repairs. Operator manual actions comprise an integrated set of actions needed to  l ensure that hot shutdown can be accomplished for a fire in a specific plant area. Manual          l operation of valves, switches, and circuit breakers is allowed to operate equipment and isolate  l systems in accordance with Regulatory Position 5.3.3 and is not considered a repair.              l l
Post-Fire Safe-Shutdown AnalysisA process or method of identifying and evaluating the            l capability of SSCs necessary to accomplish and maintain safe-shutdown conditions in the event    l of a fire.                                                                                        l l
Post-Fire Safe-Shutdown CircuitsElectrical circuits whose fire-induced failure (e.g., short      l circuit, short to ground) could prevent safe shutdown, either directly (e.g., loss of power to a  l safe-shutdown pump) or indirectly (e.g., spurious opening of a flow diversion path because of    l one or more control circuit hot shorts; failure of a motor-operated valve to perform an active    l post-fire safe-shutdown function caused by fire-induced failure of a valve protective circuit). l l
Post-Fire Safe-Shutdown System/EquipmentSystems and equipment that perform functions            l needed to achieve and maintain safe shutdown during and following a fire (regardless of whether  l the system or equipment is part of the success path for safe shutdown). This includes systems    l and equipment of which fire-induced spurious operation could prevent safe shutdown.              l l
DG-1170, Page 181
 
l Pre-Fire Plans  DocumentationPlansDocumentation that describes the facility layout, access, contents, construction, hazards, hazardous materials, types and locations of fire protection l systems, and other information important to the formulation and planning of emergency fire response.
l Raceway  AnRacewayAn enclosed channel of metal or nonmetallic materials designed expressly for holding wires, cables, or busbars, with additional functions as permitted by code.
Raceways include, but are not limited to, rigid metal conduit, rigid nonmetallic conduit, intermediate metal conduit, liquid-tight flexible conduit, flexible metallic tubing, flexible metal conduit, electrical nonmetallic tubing, electrical metallic tubing, underfloor raceways, cellular concrete floor raceways, cellular metal floor raceways, surface raceways, wireways, and busways.
Text Was Moved From Here: 11 l Radiant Energy (Heat) Shield  AShieldA noncombustible or fire -resistive barrier installed to provide separation protection of redundant cables, equipment, and associated non-safety circuits within containment.
l or in the main control room.
l l Redundant Train/SystemOne of two or more similar trains of equivalent capacity in the l same system powered by separate electrical divisions or one of two or more separate systems that l each perform the same post-fire safe-shutdown function as its design function. With respect to l fire protection regulatory requirements and guidance, a redundant train or system is distinct from l an alternative or dedicated shutdown train or system. (See also Success Path.)
l l Remote Shutdown  TheShutdownThe capability, including necessary instrumentation and controls, to safely shut down the reactor and maintain shutdown conditions from outside the main control room. (See GDC 19.)
l See GDC 19, Control Room.)
l l RepairAn action that may be credited with achieving and maintaining cold shutdown, l including the replacement of fuses and cabling. Selected equipment replacement is also allowed l if practical. Repairs not permitted include the use of clip leads in control panels (i.e., hard-wired l terminal lugs should be used) and the use of jumper cables other than those fastened with l terminal lugs.
l Restricted Area  AnyAreaAny area to which access is controlled by the licensee controls l access for purposes of protecting individuals from exposure to radiation and radioactive materials.
l Safe Shutdown  ForShutdownFor fire events, those plant conditions specified in the plant l Ttechnical Sspecifications as Hot S hot standby, Hhot Sshutdown, or Ccold Sshutdown.
DG-1170, Page 182
 
Safe -Shutdown Analysis  AAnalysisA process or method of identifying and evaluating            l the capability of structures, systems, and componentsSSCs necessary to accomplish and maintain    l safe -shutdown conditions in the event of a fire.                                                l Safe -Shutdown System/Safe -Shutdown Equipment  SystemsEquipmentSystems and                    l equipment that perform functions needed to achieve and maintain safe shutdown (regardless of whether or not the system or equipment is part of the success path for safe shutdown).
Safety-Related Systems and Components  SystemsComponentsSystems and components                  l required to mitigate the consequences of postulated design -basis accidents.                      l Secondary Containment  TheContainmentThe combination of physical boundary and                  l ventilation systems designed to limit the release of radioactive material.                        l Short Circuit  A failure condition that results when a circuit (either a cable or individual conductor within a cable) comes into electrical contact with another circuit.
CircuitAn abnormal connection (including an arc) of relatively low impedance, whether made      l accidentally or intentionally, between two points of different potential.                        l Short-to-Ground  A failure condition that results when a circuit (either a cable or individual conductor within a cable) comes into electrical contact with aShort-to-GroundA short circuit    l between a conductor and a grounded reference point (e.g., grounded conducting device such as a    l cable tray, conduit, grounded equipment, or other grounded component.
conductor, conduit or other raceway, metal enclosure, shield wrap, or drain wire within a cable). l Spurious Operation  TheOperationThe undesired operation of equipment resulting from a          l fire that could affect the capability to achieve and maintain safe shutdown.                      l Standards (Code) of Record  TheRecordThe specific editions of the nationally recognized        l codes and standards endorsed by the NRC that constitute the licensing orand design basis for the  l plant.
Success Path  ThePathThe minimum set of structures, systems (including power,                  l instrument, and control circuits and instrument-sensing lines), and components necessarythat      l must remain free of fire damage in order to achieve and maintain safe shutdown in the event of a  l fire.
DG-1170, Page 183
 
l    Success path is synonymous with the safe-shutdown train free of fire damage and includes l electrical circuits whose fire-induced failure could prevent safe shutdown. In the context of l Appendix R, Section III.G, redundant train (Section III.G.2) and alternative/dedicated system l (Section III.G.3) are both success paths and this definition is applicable.
l Temporary Structures  BuildingsStructuresBuildings, tents, shelters, platforms, trailers, l or other structures that are erected for the purpose of supportingto support plant operations and maintenance, but are not permanent site facilities.
l Turnout Gear  PersonnelGearPersonnel protective clothing for fire fightingfirefighting such as coats, pants, boots, helmets, gloves, and self-contained breathing apparatus l (SCBA)apparatuses.
l Transient Combustibles  CombustibleCombustiblesCombustible materials that are not l fixed in place or not an integral part of an operating system or component.
l l                                                    REFERENCES l
U.S. Nuclear Regulatory Commission Documents 1 l Regulations l
l Regulations (from Title 10, Energy, of the Code of Federal Regulations)(11) l l 10 CFR 1.43, Office of Nuclear Reactor Regulation.
l l 10 CFR Part 20,              Standards for Protection Against RadiationRadiation.
l l 10 CFR Part 50,              Domestic Licensing of Production and Utilization FacilitiesFacilities.
l        10 CFR 50.12, Specific Exemptions.
l        10 CFR 50.48,                  Fire Protection.
l        10 CFR 50.59, Changes, Tests and Experiments.
l        10 CFR 50.72,                  Immediate Notification Requirements for Operating Nuclear Power Reactors.
l        10 CFR 50.73,                  Licensee Event Report System.
11 All NRC regulations listed herein are available electronically through the Public Electronic Reading Room on the NRCs public Web site, at http://www.nrc.gov/reading-rm/doc-collections/cfr/. Copies are also available for inspection or copying for a fee from the NRCs Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDRs mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209; fax (301) 415-3548; email PDR@nrc.gov.
DG-1170, Page 184
 
GDC 3,        Fire Protection, of Appendix A    10 CFR 50.82, License            l Termination.                                                          l 10 CFR 50.90, Application for Amendment of License or Construction Permit.        l 10 CFR 50.92, Issuance of Amendment.                                              l Appendix A, General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50. l GDC 3, Fire Protection.                                                    l GDC 5,        "Sharing Sharing of Structures, Systems, and Components," of Appendix l A to 10 CFR Part 50.                                                  l GDC 19,      "ControlControl Room," of Appendix A to 10 CFR Part 50.      l GDC 23,      "Protection Protection System Failure Modes," of Appendix A to l 10 CFR Part 50.                                                l GDC 56,        Primary Containment Isolation,. of Appendix A to 10 CFR Part l 50.
Appendix R, "FireFire Protection Program for Nuclear Power Facilities        l Operating Prior to January 1, 1979," to 10 CFR Part 50.
10 CFR Part 72,      January 1, 1979.                                              l l
10 CFR Part 52, Early Site Permits; Standard Design Certifications; and Combined Licenses  l for Nuclear Power Plants.                                                                  l l
10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants. l l
10 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel  l and High--Level Radioactive Waste.                                                        l DG-1170, Page 185
 
l Regulatory (12)
Guides l
l l Regulatory Guide 1.6, Independence Between Redundant Standby (Onsite) Power Sources and l Between Their Distribution Systems, March 1971. (ADAMS Accession Number l ML003739924)
Regulatory Guide 1.32, Criteria for Safety-Related Electric Power Systems for Nuclear Power l Plants, Revision 23, February 1977March 2004. (ADAMS Accession Number ML040680488)
Regulatory Guide 1.39, Housekeeping Requirements for Water-Cooled Nuclear Power Plants, l Revision 2, September 1977. (ADAMS Accession Number ML003740067) l Regulatory Guide 1.52, Design, Testing, and Maintenance Criteria for Post-accidentInspection, l and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled l Nuclear Power Plants, Revision 2Revision 3, March 1978.June 2001. (ADAMS Accession l Number ML011710176)
Regulatory Guide 1.75, Physical Independence of Electrical Systems, Revision 2, September l 1978.3, February 2005. (ADAMS Accession Number ML043630448) l l Regulatory Guide 1.91, Evaluations of Explosions Postulated To Occur on Transportation l Routes Near Nuclear Power Plants, Revision 1, February 1978. (ADAMS Accession Number l ML003740286) l Regulatory Guide 1.101, Emergency Planning and Preparedness for Nuclear Power Reactors, l Revision 3, August 1992.
1 See the inside front cover of this guide for information on obtaining copies of NRC documents, l printed copies or online electronic versions.5, June 2005. (ADAMS Accession Number l ML050730286) l 12 All regulatory guides listed herein were published by the U.S. Nuclear Regulatory Commission. Where an ADAMS accession number is identified, the specified regulatory guide is available electronically through the NRCs Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html.
All other regulatory guides are available electronically through the Public Electronic Reading Room on the NRCs public Web site, at http://www.nrc.gov/reading-rm/doc-collections/reg-guides/. Single copies of regulatory guides may also be obtained free of charge by writing the Reproduction and Distribution Services Section, ADM, USNRC, Washington, DC 20555-0001, or by fax to (301) 415-2289, or by email to DISTRIBUTION@nrc.gov. Active guides may also be purchased from the National Technical Information Service (NTIS) on a standing order basis. Details on this service may be obtained by contacting NTIS at 5285 Port Royal Road, Springfield, Virginia 22161, online at http://www.ntis.gov, or by telephone at (703) 487-4650. Copies are also available for inspection or copying for a fee from the NRCs Public Document Room (PDR), which is located at 11555 Rockville Pike, Rockville, Maryland; the PDRs mailing address is USNRC PDR, Washington, DC 20555-0001. The PDR can also be reached by telephone at (301) 415-4737 or (800) 397-4205, by fax at (301) 415-3548, and by email to PDR@nrc.gov.
DG-1170, Page 186
 
Regulatory Guide 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, July 1998.
Revision 1, November 2002. (ADAMS Accession Number ML023240437)                                                              l l
Regulatory Guide 1.188, Standard Format and Content for Applications To Renew Nuclear                                      l Power Plant Operating Licenses, Revision 1, September 2005. (ADAMS Accession Number                                        l ML051920430)?]                                                                                                              l l
Regulatory Guide 1.191, Fire Protection Program for Nuclear Power Plants During                                            l Decommissioning and Permanent Shutdown, May 2001. (ADAMS Accession Number                                                  l ML011500010)                                                                                                                l l
Regulatory Guide 1.205, Risk-Informed, Performance-Based Fire Protection for Existing                                      l Light-Water Nuclear Power Plants, May 2006. (ADAMS Accession Number ML061100174)                                            l l
NUREG-Series Reports                                                                                                        l (13) l NUREG-0050, Recommendations Related to Browns Ferry Fire, NUREG-0050, Report by                                            l Special Review Group, February 1976.
NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response                                      l Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, November 1980.                                      l (Available at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr0654/.)                                        l NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear                                      l Power Plants, (LWR Edition), Section 9.5.1, Fire Protection System, various dates and                                    l revisions.
NUREG-1022, D.P. Allison et al. (Available at                                                                                l http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr0800/.                                                          l 13 All NUREG-series reports listed herein were published by the U.S. Nuclear Regulatory Commission. Most are available electronically through the Public Electronic Reading Room on the NRCs public Web site, at http://www.nrc.gov/
reading-rm/doc-collections/nuregs/. Copies are also available for inspection or copying for a fee from the NRCs Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDRs mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209; fax (301) 415-3548; email PDR@nrc.gov.
In addition, copies are available at current rates from the U.S. Government Printing Office, P.O. Box 37082, Washington, DC 20402-9328, telephone (202) 512-1800; or from the National Technical Information Service (NTIS),
5285 Port Royal Road, Springfield, VA 22161, http://www.ntis.gov, telephone (703) 487-4650.
DG-1170, Page 187
 
l NUREG-1022, Event Reporting Guidelines: 10 CFR 50.72 and 50.73, Revision 1, January 1998.
l NUREG-1552, C.S. Bajwa and K. West2, D.P. Allison et al., (Available at l http://www.nrc.gov/reading-rm/doc-collections/ nuregs/staff/sr1022/r2/index.html.)
l NUREG-1552, Fire Barrier Penetration Seals in Nuclear Power Plants, July 1996.
l Supplement 1 to NUREG-1552, C.S. Bajwa and K. West, July 1996. (Available at l http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1552/.)
l NUREG-1552, Supplement 1, Fire Barrier Penetration Seals in Nuclear Power Plants, Draft for Comment, June 1998.
l Report for Comment, C.S. Bajwa and K. West, June 1998. (Available at l http://www.nrc.gov/reading-rm/ doc-collections/nuregs/staff/sr1552/s1/sr1552s1.pdf.)
l NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear l Power Plants, Revision 1, September 2005. (Available at l http://www.nrc.gov/reading-rm/doc-collections/ nuregs/staff/sr1800/.)
l NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Volumes 1 and 2, September l 2005. (Available at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1801/.)
l NUREG-1805, Fire Dynamics Tools (FDTs) Quantitative Fire Hazard Analysis Methods l for the U.S. Nuclear Regulatory Commission Fire Protection Inspection Program, December l 2004. (Available at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1805/.)
l NUREG-1824, Verification and Validation of Selected Fire Models for Nuclear Power Plant l Applications, Draft for Comment January 2006. (Available at http://www.nrc.gov/reading-rm/
l doc-collections/nuregs/staff/sr1824/.)
l NUREG-1852, Demonstrating the Feasibility and Reliability of Operator Manual Actions l in Response to Fire, Draft Report for Comment, September 2006.
l NUREG/CR-6776, Cable Insulation Resistance Measurements Made During Cable Fire Tests, l June 2002. (Available at l http://www.nrc.gov/reading-rm/doc-collections/nuregs/contract/cr6776/.)
l NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, l September 2005. (Available at l http://www.nrc.gov/reading-rm/doc-collections/nuregs/contract/cr6850/.)
DG-1170, Page 188
 
NUREG/CR-6866, Technical Basis for Regulatory Guidance on Lightning Protection in                                              l Nuclear Power Plants, January 2006. (Available at                                                                              l http://www.nrc.gov/reading-rm/doc-collections/nuregs/ contract/cr6866/.)                                                        l l
Branch Technical Positions                                                                                                      l APCSB 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants, May 1, 1976.
Appendix A to APCSB 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants, Docketed Prior to July 1, 1976, February 24, 1977.
ASB 9.5-l, Guidelines for Fire Protection for Nuclear Power Plants, Revision 1, March 1979.
CMEB 9.5-1 (Formerly ASB 9.5-1)                                                                                                l l
SPLB 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants, Revision 2, July 1981.                                  l Generic Letters GL 77-02, 4, October 2003. (Available at                                                                                        l http://adamswebsearch2.nrc.gov/idmws/doccontent.dll?library=PU_ADAMS                                                            l
^PBNTAD01&ID=033090136:3).                                                                                                      l l
APCSB 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants, May 1, 1976.                                            l l
APCSB 9.5-1, Appendix A, Guidelines for Fire Protection for Nuclear Power Plants, Docketed                                    l Prior to July 1, 1976, February 24, 1977.                                                                                      l l
ASB 9.5-l, Guidelines for Fire Protection for Nuclear Power Plants, Revision 1, March 1979.                                  l l
Commission Papers (SECYs)(14)                                                                                                  l l
SECY-90-016, Evolutionary Light-Water Reactor (LWR) Certification Issues and Their                                            l Relationship to Current Regulatory Requirements, January 12, 1990. (ADAMS Accession                                            l Number ML003707849)                                                                                                            l l
14 Generic Letter 86-10, Implementation of Fire Protection Requirements, USNRC, April 24, 1986.eAll Commission          l papers (SECYs) listed herein were published by the U.S. Nuclear Regulatory Commission. Where an ADAMS accession        l number is identified, the specified paper is available electronically through the NRCs Agencywide Documents Access and l Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html. All other listed Commission papers are          l available electronically through the Public Electronic Reading Room on the NRCs public Web site,                      l at http://www.nrc.gov/reading-rm/doc-collections/commission/secys/. Copies are also available for inspection            l or copying for a fee from the NRCs Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDRs              l mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209;                        l fax (301) 415-3548; email PDR@nrc.gov.                                                                                  l DG-1170, Page 189
 
l SECY-93-087, Policy, Technical, and Licensing Issues Pertaining to Evolutionary and l Advanced Light-Water Reactor (ALWR) Designs, April 2, 1993. (ADAMS Accession Number l ML003707849) l l SECY-94-084, Policy and Technical Issues Associated with the Regulatory Treatment of Non-l Safety Systems in Passive Plant Designs, March 28, 1994. (ADAMS Accession Number l ML003708068) l l SECY-98-058, Development of a Risk-Informed, Performance-Based Regulation for Fire l Protection at Nuclear Power Plants, March 26, 1998. (Available at l http://www.nrc.gov/reading-rm/doc-collections/
l commission/secys/1998/secy1998-058/1998-058scy.html.)
l l SECY-05-0197, Review of Operational Programs in a Combined License Application and l Generic Emergency Planning Inspections, Tests, Analyses, and Acceptance Criteria, October 28, l 2005. (Available at http://www.nrc.gov/reading-rm/doc-collections/commission/secys/2001/
l secy2001-0197/2001-0197scy.pdf.)
l l Generic Letters(15) l l GL 77-02, Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls l and Quality Assurance, Generic Letter 77-02, August 29, 1977.
l GL 81-12, Fire Protection Rule (45 FR 76602, November 19, 1980), February 20, 1981, and l  Clarification Letter, March 1982.
l GL 82-21, Technical Specifications for Fire Protection Audits, October 6, 1982.
l GL 83-33, NRC Positions on Certain Requirements of Appendix R to 10 CFR Part 50, l October 19, 1983 1983.
l GL 85-01, Fire Protection Policy Steering Committee Report, January 9, 1985.
l GL 86-10, Implementation of Fire Protection Requirements,April April 24, 1986.
l GL 86-10, Supplement 1 to GL 86-10, Fire Endurance Test Acceptance Criteria for Fire l Barrier Systems Used To Separate Redundant Safe -Shutdown Trains Within the Same Fire Area, March 25, 1994.
15 All generic letters (GLs) listed herein were published by the U.S. Nuclear Regulatory Commission and are available electronically through the Public Electronic Reading Room on the NRCs public Web site, at http://www.nrc.gov/reading-rm/doc-collections/gen-comm/gen-letters/. Copies are also available for inspection or copying for a fee from the NRCs Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDRs mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209; fax (301) 415-3548; email PDR@nrc.gov.
DG-1170, Page 190
 
GL 88-12, Removal of Fire Protection Requirements from Technical Specifications, August 2,                            l 1988.
GL 89-13, Supplement 1 to GL 89-13, Service Water System Problems Affecting Safety-                                    l Related Equipment, April 4, 1990 1990.                                                                                  l GL 91-18, Information to Licensees Regarding Two NRC Inspection Manual Sections on                                      l Resolution of Degraded and Nonconforming Conditions and on Operability, Revision 1,                                    l October 8, 1997 (Superseded).                                                                                            l GL 92-08, Thermo-Lag 330-1 Fire Barriers, December 17, 1992.                                                          l GL 93-03, Verification of Plant Records, October 20, 1995.                                                            l GL 93-06, Research Results on Generic Safety Issue 106, Piping and the Use of Highly                                  l Combustible Gases in Vital Areas, October 25, 1993.
GL 06-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations, April 10,                                l 2006.                                                                                                                    l l
l Information Notices(16)                                                                                                  l l
IN 83-41, Actuation of Fire Suppression System Causing Inoperability of Safety-RelatedSafety-Related Equipment, June 22, 1983.                                                                        l IN 83-69, Improperly Installed Fire Dampers at Nuclear Power Plants, October 21, 1983.
IN 84-09, Lessons Learned Ffrom NRC Inspections of Fire Protection Safe -Shutdown Systems                              l (10 CFR CFR Part 50, Appendix R), February 13, 1984.                                                                    l IN 86-106, Feedwater Line Break, December 16, 1986.
IN 88-04, Inadequate Qualification and Documentation of Fire Barrier Penetration Seals, February 5, 1988 1988.                                                                                                  l IN 88-45, Problems in Protective Relay and Circuit Breaker Coordination, July 7, 1988.
IN 88-56, Potential Problems with Silicone Foam Fire Barrier Penetration Seals, August 4, 1988.
16 All information notices (INs) listed herein were published by the U.S. Nuclear Regulatory Commission and are available electronically through the Public Electronic Reading Room on the NRCs public Web site, at http://www.nrc.gov/reading-rm/doc-collections/gen-comm/info-notices/. Copies are also available for inspection or copying for a fee from the NRCs Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDRs mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209; fax (301) 415-3548; email PDR@nrc.gov.
DG-1170, Page 191
 
IN 89-52, Potential Fire Damper Operational Problems, June 8, 1989.
IN 91-17, Fire Safety of Temporary Installations or Services, March 11, 1991.
IN 91-37, Compressed Gas Cylinder Missile Hazards, June 10, 1991.
IN 91-77, Shift Staffing at Nuclear Power Plants, November 26, 1991.
IN 92-28, Inadequate Fire Suppression System Testing, April 8, 1992.
IN 95-36, Potential Problems with Post-Fire Emergency Lighting, August 29, 1995.
IN 95-48, Results of Shift Staffing Study, October 10, 1995.
IN 97-48, Inadequate or Inappropriate Interim Fire Protection Compensatory Measures, July 9, 1997.
l July 9, 1997.
l l IN 99-17, Problems Associated with Post-Fire Safe-Shutdown Circuit Analyses, June 3, 1999.
l l IN 00-12, Potential Degradation of Firefighter Primary Protective Garments, September 21, l 2000.
l l IN 02-24, Potential Problems with Heat Collectors on Fire Protection Sprinklers, July 19, l 2002.
l l IN 03-19, Unanalyzed Condition of Reactor Coolant Pump Seal Leakoff Line During Postulated l Fire Scenarios or Station Blackout, October 6, 2003.
l l IN 05-03, Inadequate Design and Installation of Seismic-Gap Fire Barriers, February 10, 2005.
l l IN 05-04, Single-Failure and Fire Vulnerability of Redundant Electrical Safety Buses, l February 14, 2005.
l l IN 05-14, Fire Protection Findings on Loss of Seal Cooling to Westinghouse Reactor Coolant l Pumps, June 1, 2005.
l DG-1170, Page 192
 
Regulatory Issue Summaries(17)                                                                                          l l
RIS 2004-03,Risk-Informed Approach for Post-Fire Safe-Shutdown Circuit Inspection,                                    l Revision 1, December 29, 2004.                                                                                          l l
RIS 2005-07, Compensatory Measures to Satisfy the Fire Protection Program Requirements,                              l April 19, 2005.                                                                                                        l l
RIS 2005-30, Clarification of Post-Fire Safe-Shutdown Circuit Regulatory Requirements,                                l December 20, 2005.                                                                                                      l l
RIS 2006-10, Regulatory Expectations with Appendix R Section III.G.2 Operator Manual                                  l Actions, June 30, 2006.                                                                                                l l
Letters and Memoranda                                                                                                  l Denton Letter, Harold R. Denton, Letter to S. A. Bernsen, Bechtel Power Corporation, (No subject), April 30, 1982.
l l
EGM 98-02, Enforcement Guidance MemorandumDisposition of Violations of Appendix R,                                    l Sections III.G and III.L Regarding Circuit Failures, February 2, 2000. (ADAMS Accession                                l Number ML003710123)                                                                                                    l l
Holahan Memo, Gary Holahan, Memo to Dennis Crutchfield,
 
==Subject:==
Request Ffor                                          l Assistance: Determine Whether Two Hot Shorts in a Multiconductor Cable Associated with a Non-Hi/Low Pressure Interface Should Be Analyzed for Fire Induced Spurious Actuation (Generic Letter 86-10, Section 5.3.1., Non-Hi/LowNon-Hi/Low Pressure Interfaces in                                    l UndergroundedUngrounded AC and DC Circuits) (AITS 205-89), December 4, 1990.                                          l (ADAMS Accession Number ML062300013)                                                                                    l Mattson Memo July 1982, Roger J. Mattson, Memo to Richard H. Vollmer,
 
==Subject:==
Position                                l Statement on Allowable Repairs for Alternative Shutdown and on the Appendix R Requirement                              l for Time Required to Achieve Cold Shutdown, July 2, 1982. (ADAMS Accession Number                                      l ML050140106)                                                                                                            l l
17 All regulatory issue summaries (RISs) listed herein were published by the U.S. Nuclear Regulatory Commission and are available electronically through the Public Electronic Reading Room on the NRCs public Web site, at http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/. Copies are also available for inspection or copying for a fee from the NRCs Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDRs mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209; fax (301) 415-3548; and email PDR@nrc.gov.
DG-1170, Page 193
 
l Mattson Memo March 1982, Roger J. Mattson, Memo to Richard H. Vollmer,
 
==Subject:==
 
Position Statement on Allowable Repairs for Alternative Shutdown and on the Appendix R l Requirement for Time Required To Achieve Cold Shutdown, July 2March 22, 1982.
l  (ADAMS Accession Number ML050140137) l Mattson Memo 1983, RRoger J. Mattson, Memo to DDarrel G. Eisenhut,
 
==Subject:==
Task Interface Agreement #83-53 Physical Independence of Electrical Systems, TAC No. 51567, July 22, 1983.
Rubenstein Memo 1982, L.S. Rubenstein, Memo to Roger J. Mattson.
 
==Subject:==
Use of the Automatic Depressurization System (ADS) and Low Pressure Coolant Injection (LPCI) To Meet Appendix R, Alternate Shutdown Goals, December 3, 1982.
Rubenstein Memo 1983, L.S. Rubenstein, Memo to Roger J. Mattson.
 
==Subject:==
Statement of Staff Position Regarding Source Range Flux, Reactor Coolant Temperature, and Steam Generator Pressure Indication to Meet Appendix R, Alternate Shutdown Capability, January 7, 1983.
l  (ADAMS Accession Number ML062300010)
Stello Letter to Bixel, Victor Stello, Jr., Letter to David Bixel, Consumers Power Company,
 
==Subject:==
Manpower Requirements for Operating Reactors, Docket No. 50-255, June 8, 1978.
Vollmer Memo 1983a, R.H. Vollmer, Memo to Darrell G. Eisenhut,
 
==Subject:==
Oil Collection System Reactor Coolant Pumps, Florida Power and Light Company St. Lucie 2 - Docket No.
50-389 From J. Olshinski to D. Eisenhut, April 1, 1983.
l Vollmer Memo 1983b (ADAMS Accession Number ML031280307) l Vollmer Memo, R.H. Vollmer, Memo to Darrel G. Eisenhut,
 
==Subject:==
Emergency Lighting Requirements (TIA 83-87; TAC 52308), December 21, 1983.
l  (ADAMS Accession Number ML062300012)
Richards Letter 2000, S.A. Richards, Letter to J.M. Kenny, BWR Owners Group, BWROG l Appendix R Fire Protection Committee Position on SRVs and Low -Pressure Systems Used as Redundant Shutdown Systems Under Appendix R, December 12, 2000. (ADAMS Accession l Number ML003775385ML003776828) l Miscellaneous NRC Documents DG-1170, Page 194
 
AL 95-06, Dennis M. Crutchfield, Relocation of Technical Specification Administrative Controls Related to Quality Assurance, Administrative Letter 95-06, Dennis M. Crutchfield,  l December 12, 1995.                                                                          l (Available at                                                                              l http://www.nrc.gov/reading-rm/doc-collections/gen-comm/admin-letters/1995/al95006.html.)    l BL 77-08, Assurance of Safety and Safeguards During Aan Emergency - Locking Systems,      l IE Bulletin 77-08, December 28, 1977.                                                        l (Available at http://www.nrc.gov/reading-rm/doc-collections/                                l gen-comm/bulletins/1977/bl77008.html.)                                                      l BL 81-03, Flow Blockage of Cooling Water to Safety System Components by Corbicula Sp.
(Asiatic Clam) and Mytilus Sp. (Mussel), EI Bulletin 81-03, April 10, 1981.                l (Available at                                                                              l http://www.nrc.gov/reading-rm/doc-collections/gen-comm/bulletins/1981/bl81003.html.)        l IM STS-10, NRC Inspection Manual, Part 9900, Technical Guidance, Standard Technical Specification, Section 1.0, Operability, p. 31, 1986.
IP 64100, Postfire Safe Shutdown (Available at http://www.nrc.gov/reading-rm/              l doc-collections/insp-manual/technical-guidance/tgsts10.pdf.)                                l IP 64100, Post-Fire Safe-Shutdown, Emergency Lighting and Oil Collection Capability at      l Operating and Near-term Operating Reactor Facilities, Inspection Procedure 64100, October  l 18, 1999.                                                                                    l (ADAMS Accession Number ML062360048)                                                        l IP 64704, Fire Protection Program, Inspection Procedure 64704, June 24, 1998.
(Available at                                                                              l http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/ip64704.pdf.) l TI 2515/62, Post -Fire Safe -Shutdown, Emergency Lighting and Oil Collection Capability at  l All Operating Plants, Temporary Instruction 2515/62, Revision 2, February 14, 1985.
(ADAMS Accession Number ML062360044)                                                        l Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination      l Process, February 28, 2005. (Available at                                                  l http://www.nrc.gov/reading-rm/doc-collections/insp-manual/ manual-chapter/mc0609f.pdf.)      l DG-1170, Page 195
 
National Fire Protection Association Codes and Standards l NFPA 1, Fire Prevention(18) l l The following listed NFPA code names and titles are based on the current editions of the codes.
l The code of record for an existing plant will typically be an earlier edition and/or may be an l edition with a different title and/or number that addresses the same subject. The code of record l for fire protection system modifications and for new reactors should be in accordance with the l Code of Record subsection in Section B of this Regulatory Guide.
l l NFPA 1, Uniform Fire Code.
NFPA 10, Standard for Portable Fire Extinguishers.
NFPA 11, Standard for Low-Expansion Foam.
l l NFPA 11A-197011, Standard for Low-, Medium-, and High-Expansion Foam Systems.
NFPA 11C, Standard for Mobile Foam Apparatus.
NFPA 12, Standard on Carbon Dioxide Extinguishing Systems.
NFPA 12A, Standard on Halon 1301 Fire Extinguishing Systems.
NFPA 13, Standard for the Installation of Sprinkler Systems.
NFPA 14, Standard for the Installation of Standpipe and Hose Systems.
NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection.
NFPA 16, Standard for the Installation of Deluge Foam-Water Sprinkler and Foam-Water Spray Systems.
NFPA 16A, Standard for the Installation of Closed-Head Foam-Water Sprinkler Systems.
l NFPA 20, Standard for the Installation of CentrifugalStationary Pumps for Fire l PumpsProtection.
NFPA 22, Standard for Water Tanks for Private Fire Protection.
18 Copies may be purchased from the NFPA, 1 Batterymarch Park, Quincy, MA [phone: (800) 344-3555; fax: (800) 593-NFPA (6372)]. Purchase information is available through the NFPAs Web-based store at http://www.nfpa.org/Catalog/.
DG-1170, Page 196
 
NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances.
NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems.
NFPA 30, Flammable and Combustible Liquids Code.
NFPA 50A, Standard for Gaseous Hydrogen Systems at Consumer Sites.
NFPA 50B, Standard for Liquefied Hydrogen Systems at Consumer Sites.
NFPA 51B, Standard for Fire Prevention in Use ofDuring Welding, Cutting and Welding          l ProcessesOther Hot Work.                                                                      l NFPA 54, National Fuel Gas Code.
NFPA 55, Standard for the Storage, Use, and Handling of Compressed and Liquefied Gases in Portable CylindersGases and Cryogenic Fluids in Portable and Stationary Containers, Cylinders, l and Tanks.                                                                                    l NFPA 58, Liquefied Petroleum Gas Code.
NFPA 69, ExplosionStandard on Explosion Prevention Systems.                                l NFPA 70, National Electrical Code.
NFPA 72, National Fire Alarm Code.
NFPA 75, Standard for the Protection of Electronic Computer/Data ProcessingInformation        l Technology Equipment.                                                                        l NFPA 78, Lightning Protection Code                                                          l l
NFPA 80, Standard for Fire Doors and WindowsOther Opening Protectives.                      l NFPA 80A, Recommended Practice for Protection of Buildings from Exterior Fire Exposures.
NFPA 90A, Standard for the Installation of Air -Conditioning and Ventilating Systems.        l NFPA 92A, Recommended Practice for Smoke Control Systems.
NFPA 204M, GuideStandard for Smoke-Control Systems Utilizing Barriers and Pressure          l Differences.                                                                                  l l
NFPA 204, Standard for Smoke and Heat Venting.                                              l DG-1170, Page 197
 
NFPA 220, Standard on Types of Building Construction.
l NFPA 221, Standard for High-Challenge Fire Walls and Fire Barrier Walls.
NFPA 251, Standard Methods of Tests of Fire Endurance of Building Construction and Materials.
NFPA 253, Standard Method of Test for Critical Radiant Flux of Floor Covering Systems l Using a Radiant Heat Energy Source.
l l NFPA 259, Standard Test Method for Potential Heat of Building Material.
NFPA 299, Standard for Protection of Life and Property from Wildfire.
NFPA 600, Standard on Industrial Fire Brigades.
l NFPA 701, Standard Methods of Fire Tests for Flame-ResistantFlame Propagation of Textiles and Films.
l NFPA 703, Standard for Fire -Retardant ImpregnatedTreated Wood and Fire -Retardant l Coatings for Building Materials.
NFPA 750, Standard on Water Mist Fire Protection Systems.
l NFPA 804, Standard for Fire Protection for Advanced Light-Water Reactor Electric Generating l Plants.
l l NFPA 805, Performance-Based Standard for Fire Protection for Light-Water Reactor Electric l Generating Plants.
l l NFPA 1144, Standard for Protection of Life and Property from Wildfire.
l l NFPA 1404, Standard for a Fire Department Self-Contained Breathing ApparatusService l Respiratory Protection Program.
l NFPA 1410, Standard on Training for Initial Fire Attack. Emergency Scene Operations.
l l NFPA 1500, Standard on Fire Department Occupational Safety and Health Program.
NFPA 1620, Recommended Practice for Pre-Incident Planning.
NFPA 1961, Standard on Fire Hose.
l NFPA 1962, Standard for the Inspection, Care, Use, and ServiceUse of Fire Hose, Couplings l and Nozzles and the Service Testing of Fire Hose Including Couplings and Nozzles.
DG-1170, Page 198
 
NFPA 2001, CleanStandard on Clean Agent Fire Extinguishing Systems.                                                    l NFPA Fire Protection Handbook, Volume II, Section 610, Chapter 1, 189th Edition, National                                l Fire Protection Association, Quincy, Massachusetts, 2003.                                                                l Other Documents ANI Test, Standard Fire Endurance Test Method to Qualify a Protective Envelope for Class 1E Electrical Circuits, American Nuclear Insurers, Property Engineering Department, July 1979.
ANSI N18.7,                                                                                                              l The following list of industry standards and guides is based on the current editions of the codes.                        l The code of record for an existing plant will typically be an earlier edition and/or may be an                          l edition with a different title and/or number that addresses the same subject. The code of record                          l for fire protection system modifications for existing plants and for new reactor fire protection                          l systems should be determined in accordance with the Code of Record subsection of Section B                              l of this Regulatory Guide.                                                                                                l l
ANSI/ANS 3.2, Administrative Controls and Quality Assurance/Nuclear, American National                                  l Standards Institute, ANSI Standard N18.7.Assurance for the Operational Phase of Nuclear Power                            l Plants (Formerly ANSI N18.7).(19)                                                                                        l ANSI/IEEE C.2, National Electrical Safety Code" (On CD-ROM. Contact IEEE Customer                                        l Service at 1-800-678-IEEE or email to customer.service@ieee.org to order.)
ASME/ANSI.(20)                                                                                                          l l
ASME B31.1, American Society of Mechanical Engineers/American National Standards                                          l InstituteEngineers, ASME/ANSIASME Standard B31.1, "Power Piping."Power Piping                                          l American Society of Mechanical Engineers, New York New York.(21)                                                          l ASME NQA-1, Quality Assurance Program Requirements for Nuclear Facilities, American Society of Mechanical Engineers Standard NQA-1, New York New York.                                                        l 19 Copies may be obtained from the American Nuclear Society, 555 North Kensington Avenue, La Grange Park, Illinois 60526; telephone (708) 352-6611; fax (708) 352-0499. Purchase information is available through the ANS Web-based store at http://www.ans.org/store/vi-240198.
20 This standard is available on CD-ROM. Contact IEEE Customer Service at 1-800-678-IEEE or by email to customer.service@ieee.org to order.
21 Copies of ASME standards may be purchased from the American Society of Mechanical Engineers, Three Park Avenue, New York, New York 10016-5990; phone (800) 843-2763. Purchase information is available through the ASME Web-based store at http://www.asme.org/Codes/Publications/.
DG-1170, Page 199
 
l ASTM D-2859, "StandardStandard Test Method for Flammability of Finished Textile Floor l Covering Materials," American Society for Testing and Materials, West Conshohocken, l Pennsylvania.(22)
ASTM D-3286, Standard Test Method for Gross Calorific Value of Coal and Coke by the l Isoperibol Bomb Calorimeter, Annual Book of ASTM Standards, American Society for Testing l and Materials, Annual Book of ASTM StandardsWest Conshohocken, Pennsylvania.
ASTM E-84, Standard Test Method for Surface Burning Characteristics of Building Materials, l Annual Book of ASTM Standards, American Society for Testing and Materials, Annual Book of l ASTM StandardsWest Conshohocken, Pennsylvania.
ASTM E-119, Standard Test Methods for Fire Tests of Building Construction and Materials, l Annual Book of ASTM Standards, American Society for Testing and Materials, Annual Book of l ASTM StandardsWest Conshohocken, Pennsylvania.
ASTM E-814, Standard Test Method for Fire Tests of Through-Penetration Fire Stops, l Annual Book of ASTM Standards, American Society for Testing and Materials, Annual Book of l ASTM StandardsWest Conshohocken, Pennsylvania.
l EPRI NP-5283-SR-ANP-5283-SR-A, Guidelines for Permanent BWR Hydrogen Water l Chemistry Installations-1987 Revision, Special ReportInstallations, Electric Power Research l Institute, Palo Alto, California, 1987 Revision.(23) l l EPRI/NEI, Spurious Actuation of Electrical Circuits Due to Cable Fires: Results of an Expert l Elicitation, Report No. 1006961, Electric Power Research Institute, September 1987Palo Alto, l California, May 2002.
l FACTORY MUTUAL APPROVAL GUIDEFactory Mutual Approval Guide, Factory l Mutual Research Approval Guide - Equipment, Materials, Services for Conservation of l Property, Factory Mutual Research Corp., <http://www.factorymutualJohnston, Rhode Island, l September 2000.com> .(24) 22 Copies of ASTM standards may be purchased from the American Society for Testing and Materials, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, Pennsylvania 19428-2959; phone (610) 832-9585. Purchase information is available through the ASTM Web site at http://www.astm.org.
23 Copies of the listed EPRI standards may be purchased from the Electric Power Research Institute (EPRI),
3420 Hillview Ave., Palo Alto, California 94304; telephone (800) 313-3774; fax (925) 609-1310.
24 Copies are available from Factory Mutual Research Corporation, 1301 Atwood Avenue, P.O. Box 7500, Johnston, Rhode Island 02919; phone (401) 275-3000; fax (401) 275-3029. Purchase information is available through the Web-based FM Global Resource Catalog at http://www.fmglobalcatalog.com/ProductInfo.aspx?productid=P7825CD.
DG-1170, Page 200
 
IEEE 242, "IEEEIEEE Recommended Practices for Protection and Coordination of Industrial                                      l and Commercial Power Systems," Institute of Electrical and Electronics Engineers, ANSI/IEEE                                  l Standard 242Piscataway, New Jersey. (25)                                                                                      l IEEE 383, "IEEEIEEE Standard for Type Test of Class IE Electric Cables, Field Splices, and                                    l Connections for Nuclear Power Generating Stations, Institute of Electrical and Electronics                                    l Engineers, IEEE Standard 383Piscataway, New Jersey.                                                                            l IEEE 634, IEEE Standard Cable Penetration Fire Stop Qualification Test, Institute of Electrical and Electronics Engineers, IEEE Standard 634Piscataway, New Jersey.                                                l IEEE 690-1984, IEEE Standard for the Design and Installation of Cable Systems for Class 1E Circuits in Nuclear Power Generating Stations, IEEE Standard 690Institute of Electrical and                                  l Electronics Engineers, Piscataway, New Jersey.                                                                                l IEEE 835, Standard Power Cable Ampacity Tables, Institute of Electrical and Electronics Engineers, IEEE Standard 835Piscataway, New Jersey.                                                                            l IEEE 1202, IEEE Standard for Flame Testing of Cables for Use in Cable Trays in Industrial and Commercial Occupancies, Institute of Electrical and Electronics Engineers, IEEE Standard 1202. Piscataway, New Jersey.                                                                                                  l l
NEI 00-01, Guidance for Post-Fire Safe-Shutdown Circuit Analysis, Revision 1, Nuclear                                        l Energy Institute, Washington, DC, January 2005. (ADAMS Accession Number ML050310295)                                          l l
NEI 04-02, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection                                      l Program Under 10 CFR 50.48(c), Revision 1, Nuclear Energy Institute, Washington, DC,                                          l September 2005. (ADAMS Accession Number ML052590476)                                                                          l UL 555, Fire Dampers, Underwriters Laboratories, Inc., Northbrook, Illinois (see http://www.                                l ul.com/info/standard.htm).                                                                                                    l UL Directory, Building Materials Directory, Underwriters Laboratories, Inc., Northbrook, Illinois (see http://www. comm-2000.com/).                                                                                    l UL Subject 1724, Appendix B, Qualification Test for Circuit Integrity of Insulated Electrical Wires and Cables in Electrical Circuit Protection Systems (Paragraph B3.16), to Outline of                                  l Investigation for Fire Tests for Electrical Circuit Protective Systems, Issue No. 2, August 1991                              l (see http://www.comm-2000.com/).                                                                                              l 25 Copies of the listed IEEE standards may be obtained from the Institute of Electrical and Electronics Engineers, Inc.,
IEEE Service Center, 445 Hoes Lane, P.O. Box 1331, Piscataway, New Jersey 08855.
DG-1170, Page 201
 
APPENDIX A:                                              l l
EQUIVALENCY                                                l This appendix provides information and previously accepted examples from Generic Letter    l (1) 86-10 86-10, Implementation of Fire Protection Requirements, with regard to the use of              l equivalency in evaluating fire protection and safe -shutdown features.                                l A-1.      Process Monitoring Instrumentation                                                          l Section          Paragraph III.L.2.d of Appendix R to 10 CFR Part 50 states that "The, Fire          l Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979, to Title 10,    l Part 50, Domestic Licensing of Production and Utilization Facilities, of the Code of Federal        l Regulations (10 CFR Part 50) states, The process monitoring function shall be capable of            l providing direct readings of the process variables necessary to perform and control" the            l reactivity control function. Regulatory Positions 5.3 and 5.4 of this guide provide a list of instrumentation acceptable to and preferred by the staff to demonstrate compliance with this provision. While this guidance provides an acceptable method for compliancecomplying with            l the regulation, it does not exclude other alternative methods of compliance. AThe licensee            l should justify alternative instrumentation to comply with the regulation (e.g., boron concentration  l indication) should be justified based on a technical evaluation.                                      l A-2.      Fire Area Boundaries                                                                        l The term "firefire area" as used in Appendix R means an area sufficiently bounded to      l withstand the hazards associated with the area and, as necessary, to protect important equipment      l within the area from a fire outside the area. In order tTo meet the regulation, fire area            l boundaries need not be completely sealed floor-to-ceiling, wall-to-wall boundaries. However, the licensee should identify and consider all unsealed openings should be identified and              l considered in 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 should perform an evaluation to assess the adequacy of fire boundaries in their plants to determine whether the boundaries will withstand the hazards associated with the area. This analysis should be performed by at least aA fire protection            l engineer and, if required, a systems engineer should perform this analysis. However, if the safety    l evaluation report had identified certain cable penetrations were identified as open SER items at      l the time Appendix R became effective, Section III.M of the rule applies ([see 10 CFR                  l 50.48(b))], and any variation from the requirements of Section III.M requires an exemption. In        l any event, these analyseslicensees should be retained by the licenseesretain these analyses for      l subsequent NRC audits by the NRC.                                                                    l A-3.      Automatic Detection and Suppression                                                        l Sections III.G.2.b and III.G.2.c of Appendix R state that "In, In addition, fire detectors l and an automatic fire suppression system shall be installed in the fire area." Other provisions of  l Appendix A to DG-1170, Page A-1
 
Appendix R (e.g., Section III.G.2.e) also use the phrase "firefire detectors and an automatic fire  l suppression system in the fire area."                                                              l In order to    To comply with these provisions, the licensee should install suppression and        l detection sufficient to protect against the hazards of the area should 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 isare not installed, licensees should      l perform an evaluation to assessevaluate the adequacy of partial suppression and detection to        l protect against the hazards in the area. The evaluation should be performed by aA fire              l protection engineer and, if required, a systems engineer should perform this evaluation. The        l licensee should retain evaluations should be retained for subsequent NRC audits. If a licensee      l is providing no suppression or detection, the licensee should request an exemption or license        l amendment should be requested.
REGULATORY ANALYSIS A regulatory analysis was published with the draft of this guide when it was issued for public comment (Task DG-1097, June 2000). No changes were necessary, so a separate regulatory analysis for.                                                                            l APPENDIX B                                              l l
FIRE PROBABILISTIC RISK ASSESSMENTS                                        l l
In addition to an existing plant that has not adopted a risk-informed, performance-based    l fire protection program (FPP) in accordance with Title 10, Section 50.48(c), of the Code of          l Federal Regulations [10 CFR 50.48(c)], licensees that have not adopted 10 CFR 50.48(c) and          l licensees preparing new reactor FPPs may apply risk-informed methodologies, including fire          l probabilistic risk assessment (PRA), to the evaluation of an FPP change. However, the U.S.          l Nuclear Regulatory Commission (NRC) must review and approve the proposed methodologies,              l including the acceptance criteria, before the implementation of the plant change.                    l l
According to 10 CFR 52.47(a)(v), new reactor applications submitted under 10 CFR Part        l 52, Early Site Permits; Standard Design Certifications; and Combined Licenses for Nuclear          l Power Plants, must include a design-specific PRA. A detailed fire PRA is not necessarily            l required for a new reactor FPP. However, if an applicant for a combined operating license            l (COL) references a certified design and if that certified design developed a fire PRA, then the COL  l applicant, per proposed 10 CFR 52.80(a), should use that PRA and update it to reflect site- and      l plant-specific information that may not have been available at the design stage. In addition, a      l licensee that has a risk-informed, performance-based FPP [similar to a National Fire Protection      l Association (NFPA) 805 program] or that plans to evaluate plant changes using a risk-informed        l approach must have a detailed fire PRA.                                                              l l
Appendix B to DG-1170, Page B-1
 
l        The term fire PRA encompasses all levels and types of PRAs, ranging from a l simplified bounding analysis to a detailed analysis in accordance with NUREG/CR-6850, l EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, and the draft American l Nuclear Society Fire PRA Standard. NUREG/CR-6850 should be the basis for the review of the l proposed methodologies. Chapter 19, Probabilistic Risk Assessment, of the Standard Review l Plan (SRP) (NUREG-1800) contains additional guidance on the review of nuclear power plant l PRAs.
l l        A fire PRA should receive a peer review to the extent that adequate industry guidance is l available. The NRC will review and accept the industry guidance before its application to l specific fire PRAs. The NRC should also review the results of the plant-specific peer reviews. All l types and levels of fire PRAs should be subject to a peer review. If adequate industry guidance is not l available for conducting a fire PRA peer review, the NRC should review the fire PRA for l acceptability.
l l        Licensees may use PRA and/or risk insights gained from other methods in support of l proposed changes to the plant licensing basis, such as license amendment requests per 10 CFR l 50.90, Application for Amendment of License or Construction Permit, and 10 CFR 50.92, l Issuance of Amendment. Regulatory Guide 1.189 has not been prepared. A copy of the regulatory analysis is available for inspection or copying for a fee in the NRCs Public Document Room at 11555 Rockville Pike, Rockville, Maryland.
BACKFIT ANALYSIS Text Was Moved From Here: 12 l 74, An Approach for Using Probabilistic Risk Assessment In Risk-Informed Decisions on Plant-l Specific Changes to the Licensing Basis, provides guidelines for the use of PRA in support of l plant changes that require NRC approval. Plant changes that are not subject to NRC approval are l not within the scope of Regulatory Guide 1.174. Where licensees use PRA in support of l submittals to change the plant licensing basis, they should follow the guidelines of SRP Chapter l 19.
l l
l Appendix B to DG-1170, Page B-2}}

Latest revision as of 05:00, 15 January 2025

DG-1170 Redline/Strikeout Version (Enclosure 4)
ML063260007
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Issue date: 11/22/2006
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