U.S. NUCLEAR REGULATORY COMMISSION REGULATORY GUIDE 1.189, REVISION 3 Issue Date: February 2018 Technical Lead: Daniel Frumkin FIRE PROTECTION FOR NUCLEAR POWER PLANTS A. INTRODUCTION Purpose This regulatory guide (RG) describes an approach that is acceptable to the staff of the U.S. Nuclear Regulatory Commission (NRC) to meet the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.48, "Fire Protection," parts (a) and (b), and 10 CFR Part 50, Appendix R, “Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979” (Ref. 1). These regulations set forth the requirements governing a civilian nuclear power generating plant’s fire protection program. Applicability This RG applies to reactor licensees subject to 10 CFR Part 50, “Domestic Licensing of Production and Utilization Facilities,” and 10 CFR Part 52, “Licenses, Certifications, and Approvals for Nuclear Power Plants,” (Ref. 2). Since not all of the fire protection regulations promulgated by the NRC apply to all plants, licensees should refer to their plant-specific licensing bases to determine the applicability of a specific regulation to a specific plant. Applicable Regulations • 10 CFR Part 50, “Domestic Licensing of Production and Utilization Facilities” provides regulations for licensing production and utilization facilities. o 10 CFR Part 50, Appendix A, General Design Criteria (GDC) 3, "Fire Protection," requires that structures, systems, and components (SSCs) 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 shall be used wherever practical throughout the unit, particularly in locations such as the containment and control room. Fire detection and firefighting systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on SSCs important to safety. GDC 3 also requires that firefighting systems be designed to ensure that their rupture or inadvertent operation does not significantly impair the safety capability of these SSCs. Written suggestions regarding this guide or development of new guides may be submitted through the NRC’s public Web site in the NRC Library at http://www.nrc.gov/reading-rm/doc-collections/, under Document Collections, in Regulatory Guides, at http://www.nrc.gov/reading-rm/doc-collections/reg-guides/contactus.html, Electronic copies of this RG, previous versions of this guide, and other recently issued guides are also available through the NRC’s public Web site in the NRC Library at http://www.nrc.gov/reading-rm/doc-collections/, under Document Collections, in Regulatory Guides. This RG is also available through the NRC’s Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under ADAMS Accession Number (No.) ML17240A875. o 10 CFR Part 50, Appendix A, GDC 5, "Sharing of Structures, Systems, and Components," prohibits nuclear power units from sharing SSCs important to safety unless the licensees can show that such sharing will not significantly impair the units’ 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. o 10 CFR Part 50, Appendix A, GDC 19, "Control Room," requires that the licensee provide a control room from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions. Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 millirem (mrem) whole body, or its equivalent to any part of the body, for the duration of the accident. GDC 19 also requires that equipment at appropriate locations outside the control room have (1) a design capability for prompt hot shutdown of the reactor, including necessary instrumentation and controls to maintain the unit in a safe condition during hot shutdown, and (2) the potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures. o 10 CFR Part 50, Appendix A, GDC 23, "Protection System Failure Modes," 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 the plant experiences 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). o 10 CFR Part 50, Appendix R, “Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979” applies to licensed nuclear power electric generating stations that were operating before 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 GDC 3 of Appendix A. Two categories of Appendix R provisions apply to the fire protection features of these facilities. The first category consists of those provisions that licensees were required to backfit in their entirety, regardless of whether the NRC had previously approved alternatives to the specific requirements. The requirements appear in Section III.G, “Fire Protection of Safe-Shutdown Capability”; Section III.J, “Emergency Lighting”; and Section 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 fire protection reviews. Open items are defined as fire protection features that the NRC staff had not previously approved as satisfying the provisions in Appendix A to Branch Technical Position (BTP) APCSB 9.5-1, “Guidelines for Fire Protection for Nuclear Power Plants,” (Ref. 3), as reflected in NRC-issued safety evaluation reports (SERs). • 10 CFR 50.48, “Fire Protection” requires each operating nuclear power plant to have a fire protection plan that satisfies GDC 3 of Appendix A to 10 CFR Part 50. The regulation specifies what a fire protection plan should contain and lists the basic fire protection guidelines for the plan. Rev. 3 of RG 1.189, Page 2 o Paragraph 50.48(b), states that Appendix R to 10 CFR Part 50 established fire protection features required to satisfy GDC 3 of Appendix A to 10 CFR Part 50 with respect to certain general issues for nuclear power plants licensed to operate before January 1, 1979. o Paragraph 50.48(b)(1) states that, with the exception of the requirements in Sections III.G, III.J, and III.O of Appendix R to 10 CFR Part 50, the provisions of Appendix R do not apply to nuclear power plants licensed to operate before January 1, 1979, to the extent that: . Fire protection features proposed or implemented by the licensee have been accepted by the NRC staff as satisfying the provisions of Appendix A to BTP APCSB 9.5-1, reflected in NRC fire protection safety evaluation reports issued before the effective date of February 19, 1981; or . Fire protection features were accepted by the NRC staff in comprehensive fire protection safety evaluation reports issued before Appendix A to BTP APCSB 9.5-1was published in August 1976. o Paragraph 50.48(c) incorporates National Fire Protection Association (NFPA) Standard 805, “Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants,” (Ref. 4) by reference with certain exceptions and allows licensees to voluntarily adopt and maintain an FPP that meets the requirements of NFPA 805 as an alternative to meeting the requirements of 10 CFR 50.48(b) or the plant-specific fire protection license conditions. All currently licensed plants may voluntarily adopt a risk-informed, performance- based FPP in accordance with 10 CFR 50.48(c) and NFPA 805 (which the Commission adopted in 2004 (Ref. 5)). • 10 CFR Part 52, “Licenses, Certifications, and Approvals for Nuclear Power Plants,” governs the issuance of early site permits, standard design certifications, combined licenses, standard design approvals, and manufacturing licenses for nuclear power facilities. Related Guidance • BTP APCSB 9.5-1, “Guidelines for Fire Protection for Nuclear Power Plants”, provided technical guidelines to assist licensees in preparing their fire protection programs (FPPs) as a result of the Browns Ferry fire special review. • Enforcement Guidance Memorandum (EGM) 09-002, “Enforcement Guidance Memorandum - Enforcement Discretion for Fire Induced Circuit Faults,” describes conditions limiting enforcement discretion during the resolution of fire protection concerns involving multiple spurious operations (Ref. 6). • EGM 98-002, “Enforcement Guidance Memorandum - Disposition of Violations of Appendix R, Sections III.G and III.L Regarding Circuit Failures,” provided enforcement discretion for circuit- related findings (Ref. 7). • Generic Letter (GL) 77-02, “Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance” provides criteria used by the staff to review Rev. 3 of RG 1.189, Page 3 specific elements of a licensee’s FPP, including organization, training, combustible and ignition source controls, firefighting procedures, and quality assurance (QA) (Ref.