XI.M26 (NUREG-2191 R0)
XI.M26 FIRE PROTECTION
Program Description
The Fire Protection aging management program (AMP) includes a fire barrier inspection program. The fire barrier inspection program requires periodic visual inspection of fire barrier penetration seals; fire barrier walls, ceilings, and floors; fire damper assemblies; and periodic visual inspection and functional tests of fire-rated doors to provide reasonable assurance that their operability is maintained. The AMP also includes periodic inspection and testing of the halon/carbon dioxide (CO2) or clean agent fire suppression system. Additionally, this AMP is complemented by the Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report AMP XI.S6, “Structures Monitoring,” which consists of periodic visual inspections by personnel qualified to monitor structures and components (SCs) for applicable aging effects.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.48(a), each operating nuclear power plant licensee must have a fire protection plan that satisfies General Design Criteria 3, “Fire Protection,” of Appendix A, “General Design Criteria for Nuclear Power Plants,” to 10 CFR Part 50, “Domestic Licensing of Production and Utilization Facilities.”
Licensees of plants that were licensed to operate before January 1, 1979, must meet the requirements of Appendix R, “Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979,” to 10 CFR Part 50, except to the extent provided for in 10 CFR 50.48(b). Licensees of plants licensed to operate after January 1, 1979, must meet the plant-specific fire protection licensing basis. Regulatory Guide (RG) 1.189, “Fire Protection for Nuclear Power Plants,” provides guidance for compliance with 10 CFR 50.48(b) and plant-specific fire protection licensing basis.
As an alternative to 10 CFR 50.48(b) or to plant-specific fire protection licensing basis, licensees may also adopt and maintain a fire protection program that meets 10 CFR 50.48(c), “National Fire Protection Association Standard NFPA 805,” that incorporates by reference National Fire Protection Association (NFPA) 805, “Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition,” with certain exceptions. RG 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants,” provides guidance for compliance with 10 CFR 50.48(c).
The deterministic means for meeting these requirements come from 10 CFR Part 50, Appendix R, and 10 CFR 50.48 or from plant-specific requirements incorporated into the operating license of plants licensed after that date. The U.S. Nuclear Regulatory Commission (US NRC) deterministic fire protection requirements are documented in 10 CFR Part 50, Appendix R, and 10 CFR 50.48.
- 1. Scope of Program: This program manages the effects of loss of material and cracking, increased hardness, shrinkage and loss of strength on the intended function of the penetration seals; fire barrier walls, ceilings, and floors; fire damper assemblies; and other fire resistance materials (e.g., Flamemastic, 3M fire wrapping, spray-on fire proofing material, intumescent coating, etc.) that serve a fire barrier function; and all fire-rated doors (automatic or manual) that perform a fire barrier function. It also manages the aging effects on the intended function of the halon/CO2 or clean agent fire suppression system.
- 2. Preventive Actions: This is a condition monitoring program. However, the fire hazard analysis assesses the fire potential and fire hazard in all plant areas. It also specifies measures for fire prevention, fire detection, fire suppression, and fire containment and alternative shutdown capability for each fire area containing structures, systems, and components important to safety.
- 3. Parameters Monitored or Inspected: Visual inspection of penetration seals examines the surface condition of the seals for any sign of degradation. Visual inspection of the surface condition of the fire barrier walls, ceilings, and floors and other fire barrier materials detects any sign of degradation including structural steel fire proofing. Fire damper assemblies are inspected for signs of corrosion and cracking. Fire-rated doors are visually inspected to detect any degradation of door surfaces.
- The periodic visual inspections of the surface condition for the halon/CO2 or clean agent fire suppression system are performed.
- 4. Detection of Aging Effects: Visual inspection of penetration seals detects cracking, seal separation from walls and components, and rupture and puncture of seals. Visual inspection by fire protection qualified personnel of not less than 10 percent of each type of seal in walkdowns is performed at a frequency in accordance with an US NRC-approved fire protection program (e.g., Technical Requirements Manual, Appendix R program) or at least once every refueling outage. Visual inspection to detect cracking and loss of material are conducted by fire protection qualified personnel of the fire barrier walls, ceilings, floors, and doors (e.g., wear, missing parts); fire damper assemblies; and other fire barrier materials including structural steel fire proofing during walkdowns at a frequency in accordance with an US NRC-approved fire protection program. Periodic functional tests are conducted on fire doors.
- Visual inspections of the halon/CO2 or clean agent fire suppression system are performed to detect any sign of corrosion before the loss of the component intended function. Periodic testing of the halon/carbon dioxide (CO2) or clean agent fire suppression systems is conducted on a schedule in accordance with an US NRC-approved fire protection program.
- 5. Monitoring and Trending: The results of inspections of the aging effects of cracking and loss of material on fire barrier penetration seals, fire barriers, fire damper assemblies, and fire doors are trended to provide for timely detection of aging effects so that the appropriate corrective actions can be taken. Where practical, identified degradation is projected until the next scheduled inspection. Results are evaluated against acceptance criteria to confirm that the timing of subsequent inspections will maintain the components’ intended functions throughout the subsequent period of extended operation based on the projected rate of degradation. For sampling-based inspections, results are evaluated against acceptance criteria to confirm that the sampling bases (e.g., selection, size, frequency) will maintain the components’ intended functions throughout the subsequent period of extended operation based on the projected rate and extent of degradation. The performance of the halon/CO2 fire suppression system is monitored during the periodic test to detect any degradation in the system. These periodic tests provide data necessary for trending.
- 6. Acceptance Criteria: Inspection results are acceptable if there are no signs of degradation that could result in the loss of the fire protection capability due to loss of material. The acceptance criteria include (a) no visual indications (outside those allowed by approved penetration seal configurations) of cracking, separation of seals from walls and components, separation of layers of material, or ruptures or punctures of seals; (b) no significant indications of cracking and loss of material of fire barrier walls, ceilings, and floors and in other fire barrier materials; (c) no visual indications of missing parts, holes, and wear; (d) no visual indications of cracks or corrosion of fire damper assemblies; and (e) no deficiencies in the functional tests of fire doors. Also, inspection results for the halon/CO2 or clean agent fire suppression system are acceptable if there are no indications of excessive loss of material.
- 7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in the applicant’s corrective action program under those specific portions of the quality assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective actions element of this AMP for both safety-related and nonsafety-related SCs within the scope of this program.
- For fire protection SCs identified that are subject to an aging management review for license renewal, the applicant’s 10 CFR Part 50, Appendix B, program is used for corrective actions, confirmation process, and administrative controls for aging management during the subsequent period of extended operation.
- During the inspection of penetration seals, if any sign of degradation is detected within that sample, the scope of the inspection is expanded to include additional seals in accordance with the plant’s approved fire protection program. If any projected inspection results will not meet acceptance criteria prior to the next scheduled inspection, inspection frequencies are adjusted as determined by the site’s corrective action program.
- 8. Confirmation Process: The confirmation process is addressed through those specific portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation process element of this AMP for both safety-related and nonsafety-related SCs within the scope of this program.
- 9. Administrative Controls: Administrative controls are addressed through the QA program that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with managing the effects of aging. Appendix A of the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the administrative controls element of this AMP for both safety-related and nonsafety-related SCs within the scope of this program.
- 10. Operating Experience: Silicone foam fire barrier penetration seals have experienced splits, shrinkage, voids, lack of fill, and other failure modes (US NRC Information Notice (IN) 88-56, IN 94-28, and IN 97-70). Degradation of electrical raceway fire barrier such as small holes, cracking, and unfilled seals are found on routine walkdown (US NRC IN 91-47 and US NRC Generic Letter 92-08). Fire doors have experienced wear of the hinges and handles.
- The program is informed and enhanced when necessary through the systematic and ongoing review of both plant-specific and industry operating experience including research and development such that the effectiveness of the AMP is evaluated consistent with the discussion in Appendix B of the GALL-SLR Report.
References
10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.
10 CFR Part 50, Appendix R, “Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.
10 CFR 50.48, “Fire Protection.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.
NFPA. NFPA 805, “Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition.” Quincy, Massachusetts: National Fire Protection Association. 2001.
US NRC. Generic Letter 92-08, “Thermo-Lag 330-1 Fire Barrier.” Agencywide Documents Access and Management System (ADAMS) Accession No. ML031130425. Washington, DC: U.S. Nuclear Regulatory Commission. December 17, 1992.
_____. Information Notice 88-56, “Potential Problems with Silicone Foam Fire Barrier Penetration Seals.” ADAMS Accession No. ML031150042. Washington, DC: U.S. Nuclear Regulatory Commission. August 4, 1988.
_____. Information Notice 91-47, “Failure of Thermo-Lag Fire Barrier Material to Pass Fire Endurance Test.” ADAMS Accession No. ML031190452. Washington, DC: U.S. Nuclear Regulatory Commission. August 6, 1991.
_____. Information Notice 94-28, “Potential Problems with Fire-Barrier Penetration Seals.” ADAMS Accession No. ML031060475. Washington, DC: U.S. Nuclear Regulatory Commission. April 5, 1994.
_____. Information Notice 97-70, “Potential Problems with Fire Barrier Penetration Seals.” ADAMS Accession No. ML031050108. Washington, DC: U.S. Nuclear Regulatory Commission. September 19, 1997.
_____. Regulatory Guide 1.189, “Fire Protection for Nuclear Power Plants.” Revision 2. ADAMS Accession No. ML092580550. Washington, DC: U.S. Nuclear Regulatory Commission. October 27, 2009.
_____. Regulatory Guide 1.205, “Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants.” Revision 1. ADAMS Accession No. ML092730314. Washington, DC: U.S. Nuclear Regulatory Commission. December 31, 2009.