Because of the new interpretations it will now be the staff's position that all that a utility needs to do to justify fire area boundaries and the extent of fire detection and suppression is an "evaluation". It is therefore likely that an individual utility will have some form of evaluation available for the audit team. If serious safety problems are discovered during an audit, the inspection team will not be in a position to efficiently resolve or cite the utility for the condition because they have literally done what the new interpretations require. Also, there is nothing specifically written or implied in the interpretations that utilities will be sanctioned or cited for inadequate evaluations. With the reduced likelikhood of enforcement action, utilities will be less inclined to take the Rule seriously and the staff itself will be increasingly frustrated in their efforts to achieve resolution of unresolved issues.

The new interpretation regarding the nature of fire area boundaries,
which states that boundary walls and floor/ceiling assemblies need
not be continuous, conflicts with previous staff criteria as defined
in the Branch Technical Positions. Therefore, the technical basis
for our review has been changed. This change has been effected as a
result of utility initiatives, via management directive, without
following usual appropriate NRC procedures or considering relevant staff
input.

At a meeting between the staff and the Nuclear Utilities Fire Protection
Group in March 1983, it was agreed that the Group would propose criteria
for the NRC acceptance of partial coverage suppression and detection
systems. To this date, the Group has been unable to provide any criteria
due to the number of variables that must be considered in each case.
It is therefore doubtful that the individual utilities will be able to
assess Appendix R compliance of such systems based on an evaluation, as
permitted by the recent interpretations.

Originators Assessment of Consequences

The adoption of the new "Interpretations of Appendix R" undermines
the Rule by causing significant delays associated with the identification
and resolution of fire protection related safety problems. It may also
result in a lack of consistency in the resolution of safety deviations.
The interpretations also change the technical basis of the Rule and
our review efforts by redefining the nature of fire area boundaries.

Related Efforts

None

Recommendations

5.

1.

2.

Do not issue the "Interpretations of Appendix R" as presently
written, but as amended in by Enclosure 1.

Re-affirm that the staff positions as delineated in Generic Letter 83-33 are the basis for resolving technical issues associated with compliance with Appendix R.

Robert Ferguson

3.

-5

Mandate that, to the extent utilities deviate from the positions of Generic Letter 23-33, they should justify such deviations via a detailed fire hazard analysis which must be submitted to the staff for review under the exemption process.

Enclosure 1

AMENDED INTERPRETATIONS OF APPENDIX R

2.

Section III.G of Appendix R sets forth the requirements for fire protection for safe shutdown capability on the basis of fire areas.

A fire area is defined in NUREG 75/087 and 0800 as that portion of a building or plant that is separated from other areas by boundary fire barriers (walls, floors and ceilings with any openings or penetrations protected with seals or closures having a fire resistance rating equal to that required of the barrier).

Based on the guidance in Appendix A to BTP ASB 9.5-1, the boundary fire barrier should have a 3-hour fire resistance rating or it should be shown by analysis that its fire rating exceeds with conservative margin, the fire loading in the fire areas on either side of the boundary fire barrier. The boundary fire barrier need not be rated at 3-hour unless the fire boundary warrants such a rating.

Where fire area boundaries were not approved during the Appendix A review, or where such boundaries are not continuous barriers with all penetrations sealed to prevent fire propagation, licensees must evaluate and justify the adequacy of the boundary construction. A11 unsealed openings must be identified and justified. Particular attention should be given to stairways and hatchways. This analysis must be performed by a fire protection engineer and, if required, a systems engineer. Licensees must submit their evaluations of these deviations for Staff review and must have these evaluations available for subsequent NRC audits.

Automatic Detection and Suppression Coverage

Sections III.G.2.b and III.G.2.c of Appendix R state that "In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area..." Other provisions of Appendix R also use the phrase "fire detectors and an automatic fire suppression system in the fire area..." (see e.g., Section III.G. 2. e).

To comply with these requirements, suppression and detection sufficient
to protect against the hazards of the area must be installed. Full
coverage fire detection and suppression systems fully comply with the
regulation. Detection and suppression systems with less than full area
coverage may be adequate to comply with the regulation. Where full
area suppression and detection is not installed, licensees must perform
an evaluation to assess the adequacy and necessity of partial suppression
and detection in an area. The evaluation must be performed by a fire
protection engineer and, if required, a systems engineer. Licensees
must submit their evaluations to the Staff for review. The evaluations
must be available for subsequent NRC audits.

Where a licensee is providing no suppression or no detection, an exemption must be requested.

4.

In Section 111.G of Appendix R, the Commission has specified means for
ensuring that structures, systems and components important to safe
are free of fire damage (see e.g., Section III.G. 2. a, b and c), that
is the structure, system or component under consideration is capable of
performing its intended function before, during and after the postulated
fire. Licensees seeking exemptions from these requirements of the
regulation must show that the alternative proposed will also provide
reasonable assurance that necessary structures, systems and components
are undamaged by the fire suppression agent and are therefore capable of
performing their intended functions before, during and after the
postulated fire.

Alternative or Dedicated Shutdown

Section III.G. 3 of Appendix R provides for "alternative or dedicated
shutdown capability and its associated circuits, independent of cables,
systems or components in the area, room, or zone under consideration".
While the supplementary information issued with the Rule has reflected
a preference for alternative shutdown to be independent of the fire area
under consideration, this is not always possible. In such cases alternative
shutdown in the same fire area but independent of the room or the zone
under consideration is acceptable if it can be demonstrated by detailed
fire hazard analysis that a single fire will not disable both trains
of redundant equipment and the alternate shutdown capability.