NRC Generic Letter 1980-45
| ML070220190 | |
| Person / Time | |
|---|---|
| Issue date: | 05/19/1980 |
| From: | Eisenhut D G Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| GL-80-045 | |
| Download: ML070220190 (46) | |
__ UNITED STATESNUCLEAR REGULATORY COMMISSIONWASHINGTON. D. C. 2056May 19, 1980ALL LICENSEES WITH REACTOR OPERATING LICENSES ISSUED PRIOR TO JANUARY 1, 1979Enclosed with this letter is a proposed rule entitled "Fire Protection Programfor Nuclear Power Plants Operating Prior to January 1, 1979". This proposedrule adds a new Section 50.48 and Appendix R to 10 CFR Part 50, and is expectedto be published in the Federal Register by the end of May. A thirty-daycomment period is provided. We are, therefore, transmitting copies of theproposed rule in order to expedite your review and comments.incerely,Darrell G. isenhut, DirectorDivision o LicensingEnclosure:Proposed Rule -FireProtection
[7590-011U. S. NUCLEAR REGULATORY COMMISSION10 CFR Part 50Fire Protection Program for Nuclear Power PlantsOperating Prior to January 1, 1979AGENCY: U. S. Nuclear Regulatory CommissionACTION: Proposed RuleSUMMARY: The Nuclear Regulatory Commission (NRC) is proposing to amendits regulations to require certain minimum provisions for fire protectionin operating nuclear power plants.DATES: Comment period expires (no extension of the commentperiod will be granted).ADDRESSES: Written comments should be submitted to the Secretary of theCommission, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555,Attention: Docketing and Service Branch.FOR FURTHER INFORMATION
CONTACT
- David P. Notley, Office of StandardsDevelopment, U. S. Nuclear Regulatory Commission, Washington, D. C. 20555,phcne 301-443-5921.SUPPLEMENTARY INFORMATION: On March 22, 1975, the Browns Ferry NuclearPower Plant, owned and operated by the Tennessee Valley Authority, hadthe worst fire to date in an operating commercial nuclear power plant.The fire was eventually controlled, there was no release of radioactive1Enclosure "A"
[7590-01Jmaterial to the environment, and the reactor was safely shut down. How-ever, many of the systems relied on for shutdown of the reactor underboth normal und emergency conditions were'not available because of exten-sive damage to control cabling of redundant systems. Although this firewas not a particularly large or serious fire in terms of insurance under-writing loss, it was very serious in terms of the type of equipment thatwas rendered inoperative. Also of concern following this fire was theattitude and belief among those responsible for managing the fire thatwater should ,aot be used on burning electrical cables because the result-ant electrical faults would be worse than ttw fire damage. As a conse-quence, the fire was allowed to burn for more than seven hours before itwas extinguished with water.Two recommendations made by the Special Review Group that investi-gated the Browns Ferry fire pertained to assurance that the fire protec-tion programs at operating nuclear power plants conform to General DesignCriterion 3, Fire Protection, contained in Appendix A to this part (GDC 3).One of the recommendations was that NRC should develop additional specificguidance for implementation of GOC 3 requirements. The other was thatNRC should make a detailed review of the fire protection program at eachoperating plant comparing it to the guidance developed per the aboverecommendation.In response to the first recommendation, NRR developed Branch Tech-nicai Position Auxiliary Power Conversion Systems Branch 9.5-1 (BTP 9.5-1),"Guidelines for Fire Protection for Nuclear Power Plants" and Appendix Ato BTP 9.5-1, "Guidelines for Fire P',:tection For Nuclear Power PlantsDocketed Prior to July 1, 1976.,"1 The guidance contained in BTP 9.5-1'Branch Technical Position 9.5-1 and its Appendix A are available fromDavid P. Notley, Office of Standards Development.2Enclosure "A"
[7590-01]was published for public comment in June 1976 as Regulatory Guide 1.120,"Fire Protection Guidelines for Nuclear Power Plants." As a result ofpublic comments received, the staff proposed extensive changes to theguide and presented the proposed changes to the ACRS in an open meetingin May 1977. Additional written comments were solicited from the publicfollowing that meeting. Nineteen additional comment letters were receivedand they were also considered in Revision 1 of Regulatory Guide 1.120,which was published for a new one-year public comment period in Novembe'1977. Comments received on Revisir, 1 of Regulatory Guide 1.120 weregenerally restatements of comments received during earlier comment per;odsand had already been considered and evaluated by the staff.The guidelines in both the BTP 9.5-1 and Appendix A to BTP 9.5-1were developed to provide a fire protection program that has two basicobjectives:1. to identify and distinguish between those- consequences of firethat are acceptable and those consequences that are not.2. to provide necessary means to minimize all consequences of fireand to prevent unacceptable consequences from occurring.With respect to the first objective, the phenomenon of fire isbelieved to be sufficiently well understood to permit evaluation of exist-ing and potential fire hazards and probable extent of damage should afire occur. Such evaluations are useful in assessing the possible con-sequences of fire in a given area. However, the phenomenon of fire isso unpredictable in occurrence and development that measures to preventunacceptable consequences may not be omitted on the basis of low probabil-ity of occurrence. The minimum fire protection requirements for nuclear3Enclosure "A"
[7590-01Jpower plants must be established not only to Identify fire hazards butalso to protect against unacceptable consequences of fire.In response to the second recommendation of the Special Review Group,the NRC re,.uested every operating plant to (1) compare its fire protectionprogram with the above guidelines and (2) analyze the consequences offire in each plant area. The NRC then reviewed the licensee's analysisagainst the guidance contained in Appendix A to BTP 9.5-1 and visited,each plant to examine the relationship of the structures, systems, andcomponents important to safety with both in situ and transient fire hazards,the potential consequences of fire, and the associated fire protectionfeatures.Appendix A to BTP 9.5-1 has been used by the staff as a basis forevaluating the adequacy of fire protection provided at all of the pres-ently operating nuclear power plants in the United States. Most of thelicensees have accepted most of the staff positions and interpretationsof this Appendix A. However, 17 generic issues exist in the fire protec-tion safety analysis reports for 32 plants where agreement has not beenreached between the staff and some licensees. In each case the disagree-ment turns on how to satisfy the basic protection requirement. For instance,all agree on the need for a fire brigade on all shifts. The disagreementis "how large?" The staff says that five should be the minimum sizepermitted while some licensees say that a brigade of only three or fourwill be adequate. Similar disagreements exist with each of the basicrequirements covered by this proposed rule. Where the staff's safetyevaluations contain open items, the position of the staff and the licenseesare documented and well known.4Enclosure "A"
[7590-01OThere are, however, a few instances where the staff has acceptedcertain fire protection alternatives that would not satisfy some of therequirements of this proposed rule. The minimum requirements containedin this rule were developed over a 3 year period and, in each of theseinstances, the staff accepted a proposed alternative before these minimumrequirements were established. All licensees will be expected to meetthe requirements of this rule, in its effective form, including whateverchanges result from public comments.Because of the above-mentioned differences between the staff andthe licensees in the interpretation of the staff's guidelines, it istimely and necessary for the Commission to state what the minimum fireprotection requirements will be in each of these contested areas of con-cern. This proposed rule and its Appendix R have been developed to estab-lish the minimum acceptable fire protection requirements necessary toresolve these cnntested areas of concern for nuclear power plants operatingprior to January 1, 1979.Other fire protection criteria that have been used by the staff duringits plant-specific fire protection program reviews are contained in Appen-dix A to BTP 9.5-1. The combination of the guidance contained in Appen-dix A to BTP 9.5-1 and the requirements set forth in this proposed ruledefine the essential elements for an acceptable fire protection programat nuclear power plants docketed for Construction Permit prior to July 1,1976, for demonstration of compliance with General Design Criterion 3 ofAppendix A to 10 CFR Part 50. Similar acceptable guidance is providedin BTP 9.5-1 for nuclear power plants docketed for Constru-tion Permitafter July 1, 1976.5Enclosure "A"
[7590-011All modifications (except for alternate or dedicated shutdown capa-bility) would be required to be implemented by November 1; 1980, unlessfor good cause shown the Commission approves an extension. Since theissues involved or well-known and have been under discussion for seve-ilyears, the Commission anticipates approving few, if any, extensions. Noplant would be allowed to continue operating after November 1, 1980, orbeyond an extended date approved by the Commission, unless all modifica-tions (except for alternate or dedicated shutdown capability) have beenimplemented. The Commission recognizes that, in a few instances, approvalhas previously been given to particular licensees to extend the implementa-tion dates for some modifications beyond November 1, 1980. The Commissionwill review these extensions on a case-by-case basis to determine whethercontinued approval or some revision of the extension is appropriate.For alternate or dedicated shutdown capability, the proposed rulespecifies implementation deadlines which depend on which kind of capabilityis to be implemented and whether the plant is under review in the SystematicEvaluation Program (SEP).2 For non-SEP plants, the proposed implementationdeadlines are April 1, 1981 for alternate shutdown capability and December 1,1981 for dedicated shutdown capability. Licensees who have committed toearlier implementation dates will be expected to meet those commitments.For SEP plants, the proposed implementation deadlines are December 1,1981 for alternate shutdown capability and October 1, 1982 for dedicatedshutdown capability. The proposed rule requires licensees to submit plansand schedules to meet these implementation deadlines by August 1, 1980(non-SEP plants) and November 1, 1980 (SEP plants). The Commission mayzPlants under review in the SEP include Palisades, Dresden 1 and 2,Oyster Creek, Millstone 1, Ginna, Haddem Neck, San Onofre 1, La Crosse,Big Rock Point, and Yankee Rowe.6Enclosure "A"
[7590-01]revise the implementation deadlines for SEP plants to earlier dates follow-ing completion by the NRC staff of its review of the status of fire pro-tection at those plants. The staff review is expected to be completedin August 1980.A brief description of the major parts of the proposed rule, includingthe need for each of the specific requirements, follows.I. Introduction and ScopeThis section states that the basic objective of the proposed Appen-dix R is to specify the minimum fire protection requirements with respectto certain recurring generic issues for nuclear power plants operatingprior to January 1, 1979. It limits application to commercial nuclearpower electric generating stations and also states that the proposedAppendix R does not rescind any requirements set forth in any SafetyEvaluation Report for any nuclear power facility.II. General RequirementsThis section states in general terms the need for a comprehensivefire protection program at each nuclear power plant.A. Fire Protection ProgramThe concept of defense in depth is here extended to fire protec-tion (1) to prevent fires from starting, (2) to rapidly detect, control,and promptly extinguish those fires that do occur, and (3) to arrange thestructures, systems, and components Important to safety so that a firethat starts in spite of the fire prevention activities and that is notpromptly extinguished by the fixed automatic or manual fire suppressionactivities will not prevent the safe shutdown of the plant.7Enclosure "A"
dL[7590-01JB. Loss of Offsite PowerThis section requires that any fire detection or suppressionsystem protecting systems necessary to achieve and maintain safe plantshutdown be capable of functioning with or without offsite power.C. M4anual Fire FightingThis section requires that manual fire fighting capability (afire brigade) be provided in all areas containing or presenting a firehazard to structures, systems, or components important to safety.D. Access for Manual Fire FightinaThis section requires that access for effective functioning ofthe fire brigade be provided in all areas containing or presenting a firehazard to structures, systems, or components important to safety.E. Fire Hazard AnalysisThis section requires that the adequacy of fire protectionprovided in any area to ensur2 the ability (1) to safely shut down theplant or (2) to minimize and control the release of radioactivity tothe environment be determined by analysis of the effects of fires onstructures, systems, or components important to safety in the area.III. Specific RequirementsEach of the 17 specific fire protection requirements in the proposedAppendix R is described below.A. Fire Water Distribution SystemTwo of the lessons learned from tht Browns Ferry Fire are(1) that water is the best extinguishing agent available for most poten-tial fires in nuclear power plants and (2) that the sooner a fire is8Enclosure "A"
[7590-textinguished, the less total damage results. These two statements r%- C-nfze that extenuating circumstances in operating plants may preclude theindiscriminate use of water to fight fires in particular locations; how-ever, such circumstances are exceptions. In practical terms, this meansthat fires in electrical equipment (which may be subject to water damage)should be extinguished as quickly as possible. Water may not be excludedfrom an area as a fire extinguishant merely on the basis of potential waterdamage to safe shutdown equipment. If such water damage hazard is severe,other protective measures such as shields for equipment or alternate shut-down capability would be required.A separate fire water distribution system would be required at eachplant to ensure the necessary water supply with adequate pressure andvolume for any combination of automatic and manual fire suppression demands.A looped fire main with appropriate isolation valves provides ahigher reliability of furnishing this necessary water supply to firesuppression systems by providing alternate directions of flow duringmaintenance or repair on part of the system.Similarly, at least two water sources--tanks and pumps, or pumpsalone from a large body of water such as a lake or a river--are necessaryto ensure continuity of water supply. In the case of two intakes from asingle large body of water, the intakes must be separated from each otherso as to really ensure two separate sources.B. Sectional Control ValvesThis item requires the installation of approved visually indicatingsectional control valves, suchas Post Indicator Valves, to isolate portionsof the fire main for maintenance or repair without shutting off the entiresystem.9Enclosure "A"
[7590-011C. Hydrant Block ValvesThis item requires block valves to be installed in hydrantlaterals if necessary to isolate a hydrant from the yard main withoutinterrupting fire water supply to areas containing safety-related or safeshutdown equipment.D. Manual Fire SuppressionThis item requires that a standpipe system with an adequatenumber of hose stations located throughout the plant to ensure that allareas containing safety-related cabling and equipment can be reached withat least one effective hose stream. The staff has relied on physicalseparation of safety-related cables and equipment and has made extensiveuse of automatic fire detection and suppression systems for additionalprotection of safety-related cabling and equipment. The staff recognizes,however, the limits of automaLic fire protection systems, and that suchautomatic protection, especially coupled with physical separation, is notalways feasible in operating plants. Prudence therefore dictates thatmanual firefighting capability be available throughout the plant toincrease the overall reliability of fire suppression capability.E. Hydrostatic Hose TestsThis item describes the frequency and severity of hydrostatictests to which all plant fire hose must be subjected in order to havereasonable assurance that it will function properly without rupture whenneeded during a fire.F. Automatic Fire DetectionThis item requires automatic fire detection systems in areascontaining combustibles and safe shutdown or safety-related systems orcomponents, in order to provide prompt notification and alarm in the event10.Enclosure "A"
P 590-01]of fire In these areas. This will permit prompt response bj the firebrigade to enable speedy extinguishment in those areas not protected byautomatic fire suppression systems and may enable the brigade to controlfires in areas that are so protected before the automatic systems operate.G. Protection of Safe Shutdown CapabilityA wide spectrum of fire hazards and shutdown equipment subjectto fire damage exists in operating nuclear power plants. This item listsseveral parameters (the combination of fire hazards, the susceptibilityof safe shutdown equipment to damage from both fire and fire suppressionactivities, fire suppression means available, and availability of alter-nate shutdown capability) that must be considered in evaluating the effec-tiveness of fire protection in areas containing safe shutdown equipment.Table 1 gives a summary of various conditions that mandate installationof manual or automatic fixed fire suppression systems.H. Fire BrigadeThe need for manual firefighting capability as backup to auto-matic fire detection and fixed fire suppression systems is established inItem 0, which requires that a standpipe and hose system be installed toprovide at least one effective hose stream in each area of the plant con-taining safety-related or safe shutdown equipment. This item specifiesthe minimum shift fire brigade size necessary to give reas3nable assuranceof effective manual firefighting capability. It requires that at leastfive persons be assigned to the fire brigade on each shift and that thesepersons have no duties during a fire except those directly related tomanual firefighting. It further requires that the brigade leader andat least two brigade members be operations personnel, and that the bri-gade leader be competent to assess potential safety consequences of a11Enclosure "A"
E7590-01Jfire and advise control room personnel. It also states some of theequipment that is to be provided for the brigade members.I. Fire Brigade TrainingThis item requires that training be provided for each indi-vidual brigade member and each shift brigade as a team in order to ensurethe necessary high degree of proficiency required of a fire brigade duringemergency response to an actual fire. The type and frequency of suchtraining (classroom instruction, hands on practice sessions, and simulateddrills) is specified.J. Emergency LightingThis ten requires that emergency lighting from individual eight-hour battery-powered units be provided in those areas needed for operationof safe shutdown equipment and access routes to safety-related areas. Firemay damage normal lighting in areas other than the area of the fire. Suchother areas may contain equipment or controls necessary for safe shutdownof the reactor. Emergency lighting is to be installed in all such areas inorder to facilitate operation of such equipment by operations personnel otherthan the fire brigade in the event of loss of normal lighting due to fire.K. Administrative ControlsThe first goal of a fire protection program is fire prevention.Therefore, this item specifies a number of administrative controls in aneffort to control the more common types of hazards. In addition, certainresponses to fire by the plant fire brigade and other plant (operations)personnel are also specified.L. Alternate Shutdown SystemsThis item requires that an alternate means of bringing thereactor to a safe shutdown be provided if the provision of other fire12Enclosure "A"
[7590-013protection does not give assurance that safe shutdown capability willsurvive a fire.M' Fire BarriersThis item discusses the need for fire barriers and the need toseal or close openfi'os through fire barriers using fire doors, dampers, orpenetration sealants depending on the type of opening. It discusses theneed to close such openings in order to maintain the required fire resistancerating of the barrier.N. Fire Barrier Penetration Seal QualificationOpenings are frequently required in fire barriers to permitpassage of cable trays and conduitL from- one area to another. Such openingsare degradations of the barrier and, per the requirements of Item M., areto be sealed with material that has fire retardant properties at leastequal to that required of the unpierced barrier. This item describesthe testing procedures that must be used to verify adequacy of a givenpenetration seal design.0. Fire DoorsPersonnel access openings in fire barriers require fire doorclosures with fire retardent properties at least equal to that requiredof the unpierced barrier. This item describes acceptable alternativemethods to ensure that fire doors will be closed in the event of fire.P. Reactor Coolant Pump-Lubrication SystemThe lubrication system for the reactor coolant pumps representsthe largest single fire hazard inside containment. This item describesthe arrangement of automatic fire suppression or oil collection systemsthat are to be provided for protection of this hazard.13Enclosure "A"
[7590-011Q. Associated CircuitsThis item specifies the level of fire protection to be providedfor electrical circuits that are not themselves safety circuits but thatare associated with safety circuits..IV. Extent of Coiient PeriodThe position of the staff and the licensees regarding the provisionsof this rule is documented and well known. In addition, the public hasbeen afforded several opportunities to comment on the provisions of therule during two extensive comment periods and in open meetings with theACRS in which a regulatory guide on fire protection was considered. Forthese reasons no extension of the comment period will be granted. Further,since the issues Involved are well known and have been under discussionfor several years, the Commission does not anticipate changes in the rule'saction deadline as a result of further comments received.Pursuant to the Atomic Energy Act of 1954, as amended, the EnergyReorganization Act of 1974, as amended, and section 553 of title 5 ofthe United States Code, notice is hereby given that adoption of thefollowing amendments to 10 CFR Part 50 is contemplated.PART 50 -DOMESTIC LICENSING OFPRODUCTION AND UTILIZATION FACILITIES1. A new Section 50.48 is added to read as follows:1 50.48 Fire Protection.(a) Each operating nuclear power facility shall have a fire protec-tion plan which meets the requirements of Criterion 3 of Appendix A tothis part. This fire protection plan should consist of two sections.The first section should describe the overall fire protection program14Enclosure "A"
[7590-01]for the facility, identify the various positions within the licensee'sorganization that are responsible for the program, state the authoritiesthat are delegated to each of these positions to impement those respon-sibilities, and outline the plans for fire protection, fire detectionand suppression capability, and limitation of fire damage. The secondsection should describe specific features necessary to implement the firstsection, such as: administrative controls and personnel requirementsfor fire prevention and manual fire suppression activities; automaticand manually operated fire detection and suppression systems; and meansto ensure capability to safely shutdown the plant in spite 'of fire damageto safety related or safe shutdown structures, systems or components.(b) For nuclear power facilities that commenced operation prior toJanuary 1, 1979, appropriate portions of Criterion 3 of Appendix A tothis part will be satisfied by meeting the requirements contained inAppendix R to this part.3(c) All fire protection modifications identified by the staff asnecessary to satisfy criterion 3 of Appendix A to this part, whethercontained in Appcndix R to this part or in other staff fire protectionguidance (except for alternate or dedicated shutdown capability) shallbe completed by November 1, 1980 unless, for good cause shown, the Commis-sion approves an extension. For alternate or dedicated shutdown capability,the following impelmentation schedule will apply.aThe combination of the guidance contained in Appendix A to Branch Tech-nical Position 9.5-1, "Guidelines for Fire Protection for Nuclear PowerPlants Docketed Prior to July 1, 1976," as implemented by the staff inits plant-specific fire protection program reviews of operating nuclearpower plants, and the requirements set forth in Appendix R to this Partdefine the minimum necessary conditions for demonstration of compliancewith General Design Criterion 3 of Appendix A to this Part for nuclearpower facilities that commenced operation prior to January 1, 197".15Enclosure "A"
[7590-011(1) PMints not Included in the Systematic Evaluation Program (SEP):2Licensees implementing alternate shutdown capability shall completeimplemntation by April 1, 1981. Licensees who have previouslycomitted to earlier Impleentation dates will be expected tomet the earlier dates. Licensees implementing dedicated shutdowncapability shall complete implementation by December 1, 1981.Licensees shall submit, by August 1, 1980, plans and schedulesfor meting these implementation deadlines.(0i) Plants included in the SEP: Licensees implementing alternateshutdown capability shall complete implementation by December 1,i981; licensees implementing dedicated shutdown shall completeimplementation by October 1, 1982. Licensees shall submit, byNovember 1, 1980, plant and schedules for meting these imple-mentation deadlines. The Commission may revise those implemn-tation deadlines to earlier dates following completion by theNRC staff of its review of the status of fire protection at SEPplants. The staff review is expected to be completed in August,1980.2. A new Appendix R to 10 CFR Part 50 is added to read as follows:APPENDIX R -FIRE PROTECTION PROGRAM FOR NUCLEAR POWER FACILITIESOPERATING PRIOR TO JANUARY 1, 1979I. INTRODUCTION AND SCOPEThis Appendix sets forth the minimum fire protection requirementsneeded for nuclear power facilities to satisfy Criterion 3 of Appendix A16Enclosure "A"
[7590-011to this part with respect to certain recurring generic issues for nuclearpower plants that were operating prior to January 1, 1979.3This Appendix applies only to licensed commercial nuclear powerelectric generating stations operating prior to January 1, 1979; it doesnot apply to production reactors, test reactors, research reactors, or-other licensed or unlicensed reactors used for other than electric powerp.roduction.This Appendix does not rescind any requirements set forth in anySafety Evaluation Report for any nuclear power facility.II. GENERAL REQUIREMENTSA. Fire Protection ProgramA fire protection program shall be established at each plant.The program shall establish the fire protection policy for the protectionof structures, systems, and components important to safety at each plantand the procedures, equipment, and personnel required to implement theprogram at the plant site.The fire protection program shall be under the direction of anindividual who has been delegated authority commensurate with the respon-sibilities of the position. The individual shall be knowledgeable in bothfire protection and nuclear safety.The fire protection program shall extend the concept of defenseIn depth to fire protection with the following objectives:* to prevent fires from starting;* to detect rapidly, control, and extinguish promptly those firesthat do occur;17Enclosure "A"
[7590-013to arrange the structures, systems, and components Important tosafety so that a fire that starts in spite of the fire preven-tion activities and that is not promptly extinguished by thefixed automatic or manual fire suppression activities will notprevent the safe shutdown of the plant.The fire protection program shall consist of an integratedeffort of procedures, equipment, and personnel necessary to carry out thethree-part defense-in-depth concept for each fire area containing combus-tibles and containing or presenting a fire hazard to structures, systems,and components important to safety. Measures for fire prevention; firedetection, suppression, and containment; and alternate shutdown capabilityshall be provided for each such area as follows:1. Fire Preventiona. In situ fire hazards shall be minimized by design andplant arrangement.b. Transient fire hazards associated with normal operation,maintenance, repair, or modification activities shall beidentified and minimized. Those transient fire hazardsthat can not be eliminated shall be controlled.2. Fire Oetection, Suppression, and Containmenta. Fire detection systems shall be Installed.b. Portable extinguishers and standpipe and hose stationsshall be installed.C. Manually actuated fixed suppression systems shall beInstalled where fire hazards of grouped electrical cablesare large or access for the fire brigade is restricted.isEnclosure "A"
E7590-011d. A site fire brigade shall be established, trained, andequipped.e. Automatic suppression systems shall be provided to controllarge fire hazards or to protect redundant systems or com-ponents important to safe shutdown.f. Fire retardants, heat shields, or local fire barriers shallbe provided where physical separation between redundant safeshutdown systems and components or between such systems andfire hazards is not adequate to ensure that automatic andmanual fire suppression can limit the fire damage to onedivision of shutdown systems.g. Fire barriers surrounding each ftire area shall have a 3-hourfire rating unless the fire hazards analysis demonstratesthat a lesser rating exceeds the duration of the in situfire load by at least one-half hour.h. Fire detection and suppression systems shall be designed,installed, maintained and tested by personnel properly quali-fied by experience and training in fire protection systems.i. Surveillance procedures shall be established to ensure thatfire barriers and automatic and manual fire suppressionsystems and components are operable.3. Alternate Shutdown CapabilityAlternate shutdown capability shall be provided when safe shut-down cannot be ensured by barriers and detection and suppression systems,because of the exposure of redundant safe shutdown equipment, cabling, orcomponents in a single fire area to an exposure fire, fire suppressionactivities, or rupture or inadvertent operation of fire suppression systems.19Enclosure "A"
17590-013B. Loss of Offsite PowerFire detection and suppression systems protecting systems neces-sary to'achieve and maintain safe plant shutdown shall be capable of func-tioning with or without offsite power.C. Mpnual Fire FightinaManual fire fighting capability shall be provided in all areascontaining or presenting a fire hazard to structures, systems, or com-ponents important to safety.D. Access for Manual Fire FithtinaAccess shall be provided to all areas containing or presentinga fire hazard to structures, systems, or components important to safetyto permit affective functioning of the fire brigade.E. Fire Hazard AnalysisThe adequacy of fire protection for any particular plant areashall be determined by analysis of the effects of postulated exposurefires involving both in situ and transient combustibles on the abilityto safely shut down the reactor, or the ability to minimize and controlthe release of radioactivity to the environment. Separation of redundantsystems and components by three-hour rated fire barriers or at least 50 feetboth horizontal and vertical of clear air space shall be deemed adequate.Lesser ratings or distances shall be justified by analysis or test.Ill. SPECIFIC REQUIREMENTSA. Fire Water Distribution SystemAn underground yard fire main loop shall distribute fire protectionwater from the fire water supplies to the automatic and manual suppression20Enclosure "A"
C 7590-01, Jsystms. Two fresh water supplies shall be provided to furnish necessarywater volume and pressure to the yard fire main loop. Each supply shallconsist of a storage tank, pump, piping, and appropriate isolation andcontrol valves. These supplies shall be separated so that a failure ofone supply will not result in a failure of the other supply.Two separate redundant suctions from a large body of freshwater will satisfy the requirement for two separated water storage tanks.Each supply of the fire water distribution system shall becapable of providing for a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> the maximum expected waterdemands as determined by the fire hazards analysis for safety-relatedareas or other arias that present a fire exposure hazard to safety-relatedareas.Minimum fire water storage shall be ensured by means of dedi-cated tanks or by means of a vertical standpipe for other water-servicewhen storage tanks are used for combined service-water/fire-water uses.Other water systems used as a fire water supply shall be per-manently connected to the fire main system and shall be capable of auto-matic alignment to the fire main system. Pumps, controls, and powersupplies in these systems shall satisfy the requirements for the mainfire pumps. The use of other water' systems for fire protection shallnot be incompatible with their functions required for safe plant shut-down. Failure of the other system shall not degrade the fire mainsystem.B. Sectional Control ValvesApproved visually indicating sectional control valves such asPost Indicator Valves shall be provided to isolate portions of the firemain for maintenance or repair without shutting off the entire system.21Enclosure "A"
(7590-01JC. Iydrant Block ValvesBlock valves shall be Installed in hydrant laterals if neces-sary to permit isolation of outside hydrants from the yard fire mainwithout interrupting the fire water supply to any area containing orpresenting a fire hazard to safety-related or safe shutdown equipment.D. Manual Fire SuppressionStandpipe and hose systems shall be installed so that at leastore effeLLive hose stream will be able to reach any location that con-tains or could present an exposure fire hazard to safety-related equipment.Standpipe and hose stations shall be inside PWR containments and largeBWR containments that are not inerted. For BWR dry wells, standpipe andhose stations shall be placed outside the dry well with adequate lengthsof hose to reach any location inside the dry well with an effective hosestream.E. Hydrostatic Hose TestsFire hose shall be hyd'ostatically tested at a pressure 50 psiabove maximum service pressure. Hose stored in outside hose houses shallbe tested annually. Interior standpipe hose shall be tested every threeyears.F. Automatic Fire DetectionAutomatic fire detection systems shall be installed in allareas of the plant that contain combustibles and safe shutdown or safety-related systems or components.G. Protection of Safe Shutdown CapabilittProtective features shall be provided for fire areas that con-tain cables or equipment of redundant systems important to achieving and22Enclosure "A"
(7590-011maintaining safe shutdown conditions to ensure that at least one means ofachieving said conditions survives postulated fires. The protectivefeatures may consist of a combination of automatic and manual fire suppres-sion capability, fire propagation retardants, physical separation, partialfire barriers, or alternate shutdown capability independent of the fire area.1. The design of the protective features shall consider:a. The zone of influence of postulated fires and the fire extin-quishing system used in the fire area.b. The access for manual firefighting.C. The potential disabling effects of water on shutdown capability.d. The limitations of fixed suppression systems.e. The separation between redundant divisions.f. The in situ and transient combustibles.g. The propagation rate of fire in the configuration.h. The availability of shutdown capability independent of the firearea.I. That all organic cable insulation and Jacket material iscombustible.J. That metal conduit, covered cable trays, or solid bottom cabletrays retard fire propagation but do not by themselves serve asa fire barrier to prevent the loss of function of the cables.k. That fire retardant coatings retard fire propagation but do notprevent organic cable Insulation and Jacket materials fromburning.1. That oxygen is available to support combustion.m. The failure of automatic fire suppression systems.n. That the response of the fire brigade may be delayed.23Enclosure "A"
[7590O1o. That room ir coolers do not provide adequate protection forshutdown systems by removing heat generated by a fire.2. The following minimum fire protective features shall be provided:a. An early warning fire detection system.be Manual fire suppression capability.c. Fixed fire suppression systems and alternate shutdown capabilityas shown on Table 1.4h. Fire BrigadeA site fire brigade trained and equipped for firefighting shallbe established to ensure adequate manual firefighting capability for allareas of the plant containing structures, systems, or components importantto safety. The minimum size of the fire brigade shall be at least fivemembers on each shift. The brigade leader and at least two brigade membersshall be operations personnel or have equivalent knowledge of plant safetysystems. The fire brigade members' qualifications shall include an annualphysical examination for performing strenuous firefighting activity.The shift supervisor shall not be a member of the fire brigade. Thebrigade leader shall be competent to assess the potential safety con-sequences of a fire and advise control room personnel. Such competenceby the brigade leader may be evidenced by possession of an operator'slicense or equivalent knowledge of plant safety systems. Equipmentprovided for the brigade will consist of at least the following:A fire hazards analysis acceptable to the staff shall be used to deter-mine whether the plant can be shut down from the Control Room and whetheraccess for manual firefighting is good.24Enclosure "A"
TABLE 1FIRE PROTECTION FEATURESFOR SAFE SHUTDOWN CAPABILITIESTypeFt reFire/Water DisablesINormal ShutdownCapabilityShutdown fromControl RoomAvailableShutdown fromAlternate PanelRequiredFixed SuppressionSystems. RequiredAccess for ManualFire FightingNOYESNOGOODPOORIN-SITUYESNOYES'GOODPOORNO.YES- MANUAL.YES. AUTOMATIC-YES -AUTOMATIC -NO UALYES -NOYESNOGOODPOOREXPOSUREYESNOYES1GOODPOORYES -AAUTOMATiCSYES -AUTOMATICNote 1 -When the alternate shutdown capability is provided by an independent system dedicated to achievingand maintaining safe shutdown conditions, manually actuated fixed water systems or automatic gassuppression systems shall be provided for large concentrations of grouped electrical cables.Note 2 -Requirement for fixed suppression may be waived if (a) only in-situ combustible is cable insulation,(b) measures are provided to retard propagation, and (c) separation between redundant systems is atleast 10 feet horizontal and vertical of clear air space.
[7590-01J1. Personal protective equipment such as turnout coats,boots, gloves, hard hat, and pressure demand full-visionself-contained breathing apparatus with a minimum one-half hour rated capacity and approved by National Instituteof Occupational Safety and Health (NIOSH) for firefightingpurposes.2. Manual suppression equipment such as portable extinguishersand standpipe and hose with nozzles suitable for thelocation.3. Other systems and equipment necessary for efficient utiliza-tion of the brigade, such as emergency lighting in accessroutes to areas containing safety-related systems or compo-nents, and emergency communication capability throughoutthe plant that is Independent of the normal communicationsystems. Emergency communication equipment shall notinterfere with other plant equipment or controls.I. Fire Brigade TrainingThe fire brigade training program shall ensure that the capa-bility to fight potential fires is established and maintained. Th. programshall consist of an Initial classroom instruction program followed byperiodic classroom instruction, practice in firefighting, and fire drills:1. Instructiona. The initial Llassroom instruction shall include:(1) Indoctrination of the plant firefighting planwith specific coverage of each individual'sresponsibiliti i.26Enclosure "A"
E7590-01J(2) Identification of the fire hazards and associatedtypes of fires that could occur in the plant.and an identification of the location of suchhazards.(3) The toxic characteristics of expected productsof combustion.(4) Identification of the location of fire fightingequipment for each fire area and familiarizationwith the layout of the plant, including accessand egress routes to each area.(5) The proper use of available fire fighting equip-ment and the correct method of fighting eachtype of fire. The types of fires covered shouldinclude electrical fires, fires in cables andcable trays, hydrogen fires, fires involvingflammable and combustible liquids or hazardousprocess chemicals, construction fires, and recordfile fires.(6) The proper use of communication, lighting, ven-tilation, and emergency breathing equipment.(7) The proper method for fighting fires inside build-ings and confined spaces.(8) The direction and coordination of the firefightingactivities (fire brigade leaders only).I~h " ' "AllII
E7590-013(9) Detailed review of firefighting strategies andprocedures.(10) Review of the latest plant modifications andcorresponding changes In firefighting plans.Note: Items (9) and (10) may be deleted from thetraining of non-operations personnel who may beassigned to the fire brigade.b. The instruction shall be provided by qualified indi-viduals who are knowledgeable, experienced, andsuitably trained in fighting the types of fires thatcould occur in the plant and in using the types ofequipment available in the nuclear power plant.c. Instruction shall be provided to all fire brigademembers and fire brigade leaders.d. Regular planned meetings shall be held at least every3 months for all brigade members to review changesin the fire protection program and other subjects asnecessary.e. Periodic refresher training sessions shall be heldto repeat the classroom instruction program for allbrigade members over a two year period. These sessionsmay be concurrent with the regular planned meetings.2. PracticePractice sessions shall be held for each shift fire brigadeon the proper method of fighting the various types of fires28 Fntloetilra "A"
(7590-01]that could occur in a nuclear power plant. These sessionsshall provide brigade members with experience in actualfire extinguishment and the use of emergency breathingapparatus under strenuous conditions encountered in fire-fighting. These practice sessions shall be provided atleast once per year for each fire brigade member.3. DrIllsa. Fire brigade drills shall be performed in the plantso that the fire brigade can practice as a team.b. Drills shall be perfor'med at regular intervals notto exceed 3 months for each shift fire brigade. Eachfire brigade member should participate in each drill,but must participate in at least two drills per year.A sufficient number of these drills, but not lessthan one for each shift fire brigade per year, shallbe unannounced to determine the fire-fighting readi-ness of the plant fire brigade, brigade leader, andfire protection systems and equipment. Personsplanning and authorizing an unannounced drill shallassure that the responding shift fire brigade membersare not aware of the time or location of the drilluntil it is begun.At least one drill per year shall be performed on a"back shift" for each shift fire brigade.29Enclosure "A"
[7590-01]c. The drills shall belpreplanned to establish the train-Ing objectives of the drill and shall be critiquedto determine how well the training objectives havebeen met. Unannounced drills shall be planned andcritiqued by members of the management staff respon-sible for plant safety and security. Performancedeficiencies of a fire brigade or of individual firebrigade members shall be remedied by scheduling addi-tional training for the brigade or members. Unsatis-factory drill performance shall be followed by a repeatdrill within 30 days.d. At 3 year intervals, drills shall be critiquedby qualified individuals independent of the licensee'sstaff. A copy of the written report from such indi-viduals shall be submitted to NRC for evaluation.e. Drills shall as a minimum include the following:(1) Assessment of fire alarm effectiveness, timerequired' to notify and assemble fire brigade,and selection, placement and use of equipment,and firefighting strategies.(2) Assessment of each brigade member's knowledgeof his role in the firefighting strategy forthe area assumed to contain the fire. Assess-ment of the brigade member's conformance withestablished plant firefighting procedures and30Enclosure "A"
E7590-011use of firefighting equipment, including self-contained emergency breathing apparatus, communi-cation equipment, and ventilation equipment, tothe extent practicable.(3) The simulated use of firefighting equipmentrequired to cope with the situation and type offire selccted for the drill. The area and typeof fire chosen for the drill should be variedsuch that brigade members are trained in fightingfires in all safety-related areas. The situationselected should simulate the size and arrangementof a fire which coild reasonably occur in thearea selected, allowing for fire developmentdue to the time required to respond, to obtainequipment, and organize for the fire, assumingloss of automatic suppression capability.(4) Assessment of brigade leader's direction of thefirefighting effort, as to thoroughness, accuracy,and effectiveness.4. RecordsIndividual records of training provided to each fire bri-gade member, including drill critiques, shall be maintainedfor at least 4 years to ensure that each member receivestraining in all parts of the training program. These recordsof training shall be available for review. Retraining or31Enclosure "A"
[7590-01]broadened training for fire fighting within buildings shallbe scheduled for all those brigade members whose performancerecords show deficiencies.3. Emergency LightingEmergency lighting shall be provided in all areas needed foroperation of safe shut down equipment and in access routes to all safety-related areas and other areas presenting a fire hazard to safety-relatedareas. Such emergency lighting may be provided by the normal lightingIf It is connected to an emergency bus and the fire hazard analysis showsthat It will not be damaged by any fire. Otherwise permanently installedsealed beam or florescent units with individual 8-hour minimum batterypower supply shall be provided.K. Administrative ControlsAdministrative controls shall be established to minimize firehazards in areas containing structures, systems, and components importantto safety. These controls shall establish procedures to:1. Govern the handling and limitation of the use of ordinarycombustible materials, combustible and flammable gasesand liquids, high efficiency particulate air and charcoalfilters, dry Ion exchange resins, or other combustiblesupplies in safety-related areas.2. Prohibit the storage of combustibles in safety-relatedareas or establish designated storage areas and fire protec-tion therefor.32Enclosure "A"
E7590-01]3. Govern the handling of and limit transient fire loads suchas combustible and flammable liquids, wood and plasticproducts, or other combustible materials in buildings con-taining safety-related systems or equipment during main-tenance, modification, or refueling operations.4. Designate the onsite staff member responsible for thein-plant fire protection review of proposed work activitiesto identify potential transient fire hazards and specifyrequired additional fire protection in the work activityprocedure.5. Govern the use of ignition sources by means of a flamepermit system that controls welding, flame cutting, braz-ing, or soldering operations. A separate permit shall beissued for each area where work is to be done, and if workcontinues over more than one shift, the permit shall bevalid for not more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.6. Govern the removal from the area of all waste, debris, scrap,oil spills, or other combustibles resulting from the workactivity immediately following completion of the activity,or at the end of each work shift, whichever comes first.7. Govern the periodic housekeeping inspections to ensurecontinued compliance with these administrative controls.8. Govern the use of specific combustibles in safety-relatedareas. All wood used in safety-related areas during main-33Enclosure "A"
[7590-01Jtenance, modification, or refueling operations (such aslay-down blocks or scaffolding) shall be flame-retardanttreated. Equipment or supplies (such as new fuel) shippedin untreated combustible packing containers may be unpackedin safety-related areas if required for valid operatingreasons. However, all combustible materials shall beremoved from the area immediately following the unpacking.Combustible material shall not be left unattended duringlunch breaks, shift changes, or other similar periods.Loose combustible packing material such as wood or paperexcelsior shall be placed in metal containers with tight-fitting self-closing metal covers.9. Govern actions to be taken by individual discovering thefire, such as notification of control room, attempt toextinguish fire, and actuation of local fire suppressionsystems.10. Govern actions to be taken by the control room operator todetermine the need for brigade assistance upon report ofa fire or receipt of alarm on control room annunciatorpanel, such as announcing location of fire over PA system,sounding fire alarms, and notifying the shift supervisorand the fire brigade leader of the type, size, and locationof the fire.11. Govern actions to be taken by the fire brigade after notifi-cation by the control room operator of a fire, such as34Enclosure "A"
r759 0-01Jassembling in a designated location, receiving directionsfrom the specific fire fighting fire brigade leader, and,discharging specific fire fighting responsibilities includingselection and transportation of fire fighting equipment tofire location, selection of protective equipment, use offire suppression systems operating instructions, and use ofpreplanned strategies for fighting fires in specific areas.12. Oeftne the strategits for fighting fires in all safety-related areas and areas presenting a hazard to safety-related equipment. These strategies shall designate:a. Fire hazards in each area covered by the specificfire fighting procedures.b. Fire extinguishants best suited for controlling thefires associated with the fire hazards in that areaand the nearest location of these extinguishants.c. Most favorable direction from which to attack a firein each are&, in view of the ventilation direction,access hallways, stairs, and doors that are most likelyto be fire free, and the best station or elevation forfighting the fire. All access and egress routes thatinvolve locked doors should be specifically identifiedin the procedure with the appropriate precautions andmethods for access specified.d. Plant systems that should be managed to reduce thedamage potential during a local fire; location of35Enclosure "A"
[7590-01Jlocal and remote controls for such management (e.g.,any hydraulic or electrical systems in the zonecovered by the specific fire fighting procedure thatcould increase the hazards in the area because ofoverpressurization or electrical hazards).a. Vital heat-sensitive system components that need to bekept cool while fighting.a local fire. Particularlyhazardous combustibles should be designated to receivecooling.f. Organization of firefighting brigades and the assign-ment of special duties according to job title so thatall fire fighting functions are covered by any completeshift personnel complement. These duties include com-mand control of the brigade, transporting fire suppres-sion and support equipment to the fire scenes, applyingthe extinguishant to the fire, communication with thecontrol room, and coordination with outside firedepartments.g. Radiological and toxic hazards in fire zones.h. Ventilation system operation that ensures desired plantpressure distribution when the ventilation flow is modi-fied for fire containment or smoke clearing operations.i. Operations requiring control room and shift engineercoordination or authorization.36Enclosure "A"
C7590-OlilJ. Instructions for plant operators and general plant-personnel during fire.L. Alternate Shutdown Capabilitv1. If the combination of fire protection features required for safeshutdown includes alternate shutdown capability independent of a specificfire area, the design for such alternate shutdown capability shall accomo-date postfire conditions where offsite power is available and where offsitepower is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.If there are several such areas, the combinations of systemsthat provide the shutdown capability may be unique for each critical area.However, the shutdown capability provided for each such area shall be ableto achieve and maintain subcritical reactivity conditions in the reactor,maintain reactor coolant inventory, achieve and maintain hot standbys condi-tions for a PWR (hot shutdown5 for a BWR) for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, achieve coldshutdown& conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and maintain cold shutdown conditionsthereafter. The reactor coolant system process variables shall be main-tained within those predicted for a loss of normal ac power. The fissionproduct boundary integrity shall not be affected; i.e., there shall beno fuel clad damage, rupture of any primary coolant boundary, or ruptureof the containment boundary.2. The performance goals for the shutdown functions shall be:a. The reactivity control function shall be capable of achiev-ing and maintaining cold shutdown reactivity conditions.As defined in the Standard Technical Specifications.37Enclosure "A"
E 7590-01Jb. The reactor coolant makeup function shall be capable ofmaintaining the reactor coolant level above the top ofthe core for BWRs and in the pressurizer for PWRs.c. The reactor heat removal function shall be capable ofachieving and maintaining decay heat removal.d. The process monitoring function shall be capable ofproviding direct readings of the process variables neces-sary to perform and control the above functions.e. The supporting functions shall be capable of providingthe process cooling, lubrication, etc., necessary to permitthe operation of the equipment used for safe shutdownfunctions.3. Various safety-related and non safety-related equipment and/orsystems may be identified by the licensee and accepted by the staff toprovide alternative means to achieve and maintain hot standby conditions(hot shut down for a SWR). The fire hazards analysis shall show that atleast one means to achieve and maintain hot standby conditions (hot shut-down for a BWR) is undamaged by any fire anywhere in the plant. inaddition, the equipment and systems comprising that means of hot standbyor hot shut down condition shall be capable of maintaining such conditionsfor at -least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if the equipment required to achieve and maintaincold shutdown is not available because of fire damage. They shall alsobe capable of being powered by both ons:te and offsite electric powersystems or by onsite power systems that are independent of the onsiteand offsite electric power systems. The number of operating shift personnel,38Enclosure "A"
[7590-01)exclusive of fire brigade members, requ'red to operate the equipment andsystems shall be onsite at all times.4. The fire hazards analysis shall show that either (a) any equip-ment and/or systems necessary to achieve and maintain cold shut down conditionswill not be damaged by any fire; or (b) that any equipment and/or systemsnecessary to achieve and maintain cold shutdown conditions that are damagedby fire can be repaired and cold shut down achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.Materials for such repairs shall be readily available onsite and proceduresshall be in effect to implement such repairs. Equipment and systemsused prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the fire shall be capable of being poweredby both onsite and offsite electric power systems or by onsite powersystems that are independent of the onsite and offsite electric powersystems; equipment and systems used after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be powered byoffsite power.These shutdown systems need not be designed to meet seismicCategory I criteria or single failure criteria; or to cope with otherplant accidents such as pipe breaks or stuck valves except where requiredfor other reasons, e.g., because of interface with or impact on existingsafety systems.M. Fire BarriersFire barriers (floors, walls, ceilings, or other enclosures)separating fire areas, or equipment or components of redundant systemsimportant to safe shutdown within an area, shall have a fire rating of3 hours unless a lower rating is Justified by the fire hazard analysts.Structural steel forming a part of or supporting such firebarriers shall have fire resistance equivalent to that required of the39Enclosure "A"
(7590-01Jbarrier. Such fire resistance shall be provided by protection equivalentto metal lath and plaster covering.Penetrations in these fire barriers, including conduits, cabletrays, and piping, shall be sealed or closed to provide fire resistancerating equivalent to that required of the barrier. Door openings shallbe protected with doors, frames, and hardware that have been tested andapproved by a nationally recognized testing laboratory to have a fireresistance rating equivalent to that required of the barrier.Penetrations for ventilation systems shall be protected by astandard "fire door damper."N. Fire Barrier Penetration Seal QualificationPenetration seal designs shall be qualified by an independenttesting laboratory in accordance with American Society for Testing Materials,ASTM E-119 and the following conditions:1. The cables used in the test shall be of the same type ofconstruction as those used in the facility.2. The test arrangement shall be representative of the worst-case configuration of cable loading, cable tray arrangement,anchoring, and penetration ftire barrier size and design.The test sample shall also be representative of the cablesizes in the facility. Testing of the penetration firebarrier in the floor configuration will qualify the firestop for use in the wall configuration also.3. Cables penetrating the fire barrier shall extend at least3 feet on the unexposed side and at least 1 foot on theexposed side.40Enclosure "A"
E759001]The fire barrier shall be tested in both directions unlessthe fire barrier is symmetrical.5. The fire barrier shall be tested with a pressure differen-tial across it (higher pressure on the exposed side) thatis equivalent to the maximum pressure differential a firebarrier in the plant is expected to experience unless suchpressure differentials are shown to have no effect on theperfomance of the penetration seal.6. The temperature levels of the cable Insulation, cable con-ductor, cable tray, conduit, and fire stop material shallbe recorded for the unexposed side of the fire barrier.7. As an alternative to the standard straight-stream hosetest stipulated in Section 9.4 and 9.5 of ASTM E-119,either of the following tests may be used:a. Two identical test specimens are exposed to the stand-ard fire. After 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, one speciien is subjectedto the standard straight-stream hose test stipulatedin ASTH E119, while the other continues to be exposedto the standard fire for the full 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />; orb. The single test specimen, immediately after the 3-hourstandard fire exposure, is subjected to a water fogtest using a high-velocity fog nozzle having an Includedangle of spray no larger than 300 and supplied by ahose no smaller than 1h inches at a pressure of at least41Enclosure "A"
[7590-01J75 pstg measured at the base of the nozzle for anapplication time of at least 2A minutes per 100 sq ftof test specimen.8. Acceptance Criteria -The test is successful if:a. The cable penetration fire barrier has withstood thefire endurance test without passage of flame or igni-tion of cables on the unexposed side for a period of3 hours,b. Thetemperature levels recorded for the unexposedside are analyzed and demonstrate that the maximumtemperature is sufficiently below the cable insula-tion ignition temperature, andc. The fire barrier remains intact and does not allowprojection of water beyond the unexposed surfaceduring the hose stream test.0. Fire DoorsFire doors shall be self-closing or provided with closing mech-anisms and shall be inspected semiannually to verify that automatic hold-open, release, and closing mechanisms and latches are operable. Firedoors shall be kept closed unless provided with automatic hold-open,release, and closing mechanisms.One of the following measures shall also be provided:1. Fire doors shall be electrically supervised at a conti-nuously manned location; ora42Enclosure "A"
[7590-01J2. F, re doors shall be locked closed and inspected weekly to* verify that the doors are in the closed position; or3. Fire doors shall be provided with automatic hold-open and.-release mechanisms and inspected daily to verify that door-ways are free of obstructions; or4. Fire doors shall be kept closed and inspected daily toverify that they are in the closed position.The fire brigade commander shall have ready access to keys forany locked fire doors.Areas protected by automatic total flooding gas suppressionsystems shall have electrically supervised self-closing fire doors.P. Reactor Coolant Pump Lubrication SystemThe reactor coolant pump lubrication system shall be protectedby either an oil collection system or an automatic fire suppression system.Oil collection systems shall be capable of collecting lube oilt* from all potential pressurized and unpressurized leakage sites in the* reactor coolant pumps' lube oil systems, and draining the oil to a vented' closed container. A flame arrestor is required in the vent if the flashpoint characteristics of the oil present the hazard of fire flashback.Leakage points to be protected shall include lift pump and piping, over-flow lines, lube oil cooler, oil fill and drain lines and plugs, flangedconnections on oil lines and lube oil reservoirs where such features existon the reactor coolant pumps. Leakage shall be collected and drained to aclosed container that can hold the entire lube oil system inventory. Thedrain line shall be large enough to accommodate the largest potential oil leak.43 Enclosure "A"
[7590-011To provide adequate protection for a design basis Safe ShutdownEarthquake (SSE), one of the following should be provided:1. The lube oil system components whose failure could resultin leakage should be designed to withstand an SSE withoutleakage and the dropping of oil collection system compo-nents during an SSE should not cause loss of operabilityof safety-related equipment; or2. The oil collection system should be designed to withstandan SSE and continue to be able to collect and drain leakagethat may occur during an SSE. In this case the oil collectionsystem should be adequate to collect oil from any externallube oil piping not designed to withstand an SSE in additionto leakage from points identified above.If an automatic fire suppression system is selected, either theautomatic and manual fire suppression system or the lube Pil system compo-nents whose failure could result in leakage should be designed to with-stand the SSE.Q. Associated CircuitsAssociated circuits shall. be electrically isolated from safetyequipment so that hot shorts, open circuits, or shorts to ground in theassociated circuit will not prevent operation of the safety equipment.If associated circuits are not known to be so electricallyisolated, they shall be considered safe shutdown circuits. The separationand barriers between trays and conduits containing associated circuits ofone safe shutdown division and trays and conduits containing associated&ALA Ftw1nqtira "All
[7590-01)circuits or safe shutdown cables from the redundant division shall besuch that a postulated fire involving associated circuits will not preventsafe shutdown.eAll interested persons who desire to submit written comments orsuggestions concerning the proposed rulemaking should send their commentsto the Secretary of the Commission, U.S. Nuclear Regulatory Commission,Washington, D.C. 20555, Attention: Docketing and Service Branch, on orbefore .Copies of comments received on the proposedamendments may be examined in the Comnmission's Public Document Room at1717 H Street, N.W., Washington, u.C.(Sec. 161b, Pub. Law 83-703, 68 Stat. 948; Sec. 201, Pub. Law 93-438,88 Stat. 1242 (42 U.S.C. 2201(b), 5841).)Dated at this day of 198.For the Nuclear Regulatory Commission.Samuel C. ChilkSecretary of the CommissionOAn acceptable method of, complying with this alternative would be to meetRegulatory Guide 1.75 position 4 related to associated circuits and IEEE384-1974 (Section 4.5) where trays from redundant safety divisions are soprotected that postulated fires affect trays from only one safety division.45Enclosure "A"