Post-Fire Safe Shutdown Capability. An Inspector's Handbook. Draft Report
The Nuclear Regulatory Commission's (NRC) current fire protection regulatory framework was initiated in response to a cable fire that occurred at the Browns Ferry Nuclear Power Station in 1975. Following the issuance of several guidance documents, in 1981 the Commission codified deterministic requirements to provide reasonable assurance that fire would not jeopardize reactor safety (10 CFR 50.48 "Fire Protection" and Appendix R to 10 CFR 50). Since then, the results of plant operating experience, NRC inspection activities and cable fire testing programs have served to clarify the application of these requirements. In 2004, the NRC amended 10 CFR Part 50.48 to add a new subsection, 10 CFR 50.48(c), that endorses, with exceptions, the National Fire Protection Association's 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants — 2001 Edition," as a voluntary alternative for demonstrating compliance with Appendix R. To date, approximately half of all operating plants have transitioned to a risk-informed approach under 10 CFR 50.48(c). Regardless of the selected approach, each operating nuclear power plant should establish a comprehensive fire protection program that includes features needed to minimize the likelihood and consequence of firesl. To achieve this objective, fire protection programs integrate the NRC's long-held safety concept of defense-in-depth (DID) by providing multiple barriers against potentially unacceptable consequences of fire. To minimize the frequency and size of fires, the first lines of defense include controls for fire prevention, such as controlling combustibles and ignition sources and fire mitigation features, such as fire detection and suppression systems. In the unlikely event that a fire should start and continue to grow in spite of these features, appropriate fire protection features, such as fire-rated barriers are provided as necessary to ensure the accomplishment of essential shutdown functions. This handbook was specifically developed for NRC inspectors that may be assigned to perform elements of Inspection Procedure (IP) 71111.05T, "Fire Protection (Triennial)," including, (a) "Protection of Safe Shutdown Capabilities," (e) "Alternative Shutdown Capability," and (f) "Circuit Analyses." Thus, the document concentrates solely on the final element of defense-in-depth— ensuring reactor safety will not be compromised in the event of a serious fire. In addition to describing how the NRC's regulatory framework has evolved since the Browns Ferry Fire, the handbook illustrates the content and scope of various analyses typically referenced in a plant's fire protection licensing basis and includes techniques and insights for assessing the plant's conformance to those criteria.