Issue Date: 07/01/08 1 65001.15 

ATTACHMENT 65001.15 

INSPECTION OF ITAAC-RELATED INSTALLATION OF 

FIRE PROTECTION EQUIPMENT 

PROGRAM APPLICABILITY: 2503 

65001.15-01 INSPECTION OBJECTIVES 

01.01 To determine whether fire protection equipment is being installed in accordance 

with design specifications and approved procedures. 

01.02 To evaluate the performance of ITAAC-related fire protection equipment 

installation, testing, documentation, and verification activities. 

01.03 To determine whether fire protection equipment configuration and records reflect 

work accomplishment consistent with the design specifications and approved procedures. 

01.04 To evaluate the adequacy of the implementation of the specific quality assurance 

program requirements related to fire protection equipment installation activities and records 

control and assure that any identified problems are entered into the corrective action 

process. 

65001.15-02 INSPECTION REQUIREMENTS AND GUIDANCE 

General Guidance: The commitments for Fire Protection Equipment (FPE) for 10 CFR part 

52 licensees will be found in the Design Control Documents (DCD) submitted to the NRC 

to support each power plant design certification. In the DCD, Tier 1 material contains a 

brief description of the fire protection equipment and the Inspections, Tests, Analyses, and 

Acceptance Criteria (ITAAC) that the fire protection equipment must meet. Tier 2 material 

contains a more detailed description of the design basis of the fire protection equipment. 

In preparation for this inspection the inspector should obtain a copy of the final NRC 

approved version of the DCD and review the Tier 1 and 2 material for fire protection 

equipment to gain an understanding of the design basis, configuration, operation, and 

expected performance of the fire protection equipment. Fire protection requirements in the 

DCD are located not only in sections labeled as such but in sections on electrical 

distribution, sections on buildings or structures, and potentially elsewhere. During 

inspection preparation the inspector shall perform an electronic search of the DCD to 

attempt to locate all the fire protection ITAAC requirements. Suggested search words or 

combination of words include fire, protection, hazards, zones, ignition sources, detection, 

suppression, barriers, manual actions, safe shutdown, alternate shutdown capability, hotshorts, circuit faults, separation, NFPA, etc. 

The ITAAC for fire protection equipment to be inspected will be generally described in the 

following paragraphs followed by guidance as to how to perform the inspections of the 

ITAAC. The inspector should adapt the guidance as needed to the specific plant design 

being inspected and the Tier 1 ITAAC for that design. If any discrepancies are identified 
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during these inspections they should be brought to the attention of licensee and NRC 

management as potential ITAAC inspection findings and resolved. 

02.01 Fire Protection Equipment Functional Arrangement. An ITAAC will require that the 

functional arrangement of the FPE is as described in a referenced figure in the Tier 1 DCD. 

 The inspector should perform a visual walkdown inspection of all of the FPE presented in 

the ITAAC to confirm that the functional arrangement is correct. 

Guidance: For efficiency of the field walkdowns, task 02.01, equipment functional 

arrangement, task 02.02, confirm seismic considerations, and task 02.03, confirm isolation 

capability of liquid fire protection, should be performed at the same time. Obtain a copy of 

the licensee=s final as-built piping and instrumentation diagram (P&ID) and a copy of the 

FPE figure from the Tier 1 DCD. In preparation for a field walkdown, do a comparison of 

the two drawings to detect any differences. Then using both drawings, perform a field 

walkdown of all the FPE on the Tier 1 drawing to confirm that the as-installed functional 

arrangement matches the Tier 1 drawing. Any discrepancies should be brought to the 

attention of licensee and NRC management as potential ITAAC inspection findings and 

resolved. There will be much more detail on the P&ID than the Tier 1 drawing and there 

may be some differences. That should not be a concern as the Tier 1 drawing is the 

ITAAC acceptance criteria. Any discrepancies between the P&ID and the as-built 

configuration should be brought to the attention of the licensee and NRC management. 

02.02 Fire Protection Equipment Seismic Considerations. An ITAAC will typically require 

that certain FPE described in the Tier 1 document will remain functional following a safe 

shutdown earthquake. This feature may be directly specified in the Tier 1 as an ITAAC 

requiring that certain FPE piping exists and a structural analysis has been performed on 

the as-built configuration to demonstrate that the FPE piping is capable of remaining 

functional following a safe shutdown earthquake. In that case, while performing inspection 

task 02.01, the inspector should also confirm that the FPE piping listed in the Tier 1 table is 

installed in the as-built plant. 

Or in the case of other new reactor designs, this feature may be confirmed by verification 

that the as-built FPE conforms to the functional arrangement described in the Tier 1 DCD 

drawing. In that case, performing inspection task 02.01 adequately ensures that the FPE 

will remain functional following a safe shutdown earthquake. 

The inspector should obtain from the licensee a copy of their structural analysis report 

which demonstrates that the as-built FPE piping is capable of remaining functional 

following a safe shutdown earthquake and review it for adequacy. 

Guidance: For either case described above, as inspection preparation the inspector 

should review all the available Tier 1 and Tier 2 fire protection information to gain an 

understanding of what are the engineering design features of the installed FPE that make 

it capable to remain functional following a safe shutdown earthquake. Then during 

walkdown inspections, the inspector should verify that those important engineering design 

features are installed on the as-built FPE. 

The licensee piping structural analysis report which supports the ITAAC will probably be a 

summary of a much larger seismic analysis. It should not be necessary to perform an in 
Issue Date: 07/01/08 3 65001.15 

depth technical review of the larger analysis. The inspector should review the summary 

document for clarity, consistency, and to verify that it concludes that the as-built FPE piping 

is capable of remaining functional following a safe shutdown earthquake. If the inspector 

finds problems with the report, he may ask for support to refer it to an NRC specialist 

inspector for deeper review of acceptability 

02.03 Fire Protection Equipment Containment Isolation. An ITAAC will typically require 

that certain fire protection water supply systems that penetrate the containment building be 

capable of providing the safety related function of automatic isolation on demand to 

maintain containment integrity. In one design, that feature will be directly specified as an 

ITAAC described in the Tier 1 document. The ITAAC will typically refer to another section 

of the Tier 1 document having to do with Containment and there certain ITAAC will specify 

the requirements for containment isolation valves with redundancy, diversity and leak 

tightness. In another design, there is no direct fire protection ITAAC for containment 

isolation, and fire protection is treated as just one of many liquid systems that penetrate 

containment and must have isolation capability. In all cases, while performing inspection 

task 02.01, the inspector should verify that liquid fire protection systems that penetrate 

containment have the required isolation capability. 

Guidance: In preparation for this inspection, the inspector should review all the available 

Tier 1 and Tier 2 fire protection information to gain an understanding of the requirements 

for fire protection liquid systems that penetrate containment to have containment isolation 

capability. The fire protection information will typically point toward the containment section 

which will describe the requirements for containment isolation capability for the fire 

protection systems. 

02.04 Capability of Hose Stations for Manual Fire Fighting Capability. An ITAAC typically 

will require that there be installed a system of manual fire hose stations and associated 

water supply to provide manual fire fighting capability in plant areas containing safety 

related equipment. The ITAAC will typically specify a minimum capacity for the water 

supply tank and specify that the volume be verified. The ITAAC will typically require testing 

to demonstrate that the system can provide a minimum required flow at a minimum allowed 

discharge pressure from the most remote and/or highest elevation hose stations. The 

inspector should request and review for acceptability the licensee=s records of as-built 

water source useable volume verification and records of flow tests that demonstrate the 

ITAAC have been met. If the opportunity exists to witness the flow testing the inspector 

should do so, but records review is sufficient to complete this IP. 

Guidance: In preparation for this inspection, the inspector should review all the available 

Tier 1 and Tier 2 fire protection information to gain an understanding of the preparation for 

this inspection, the inspector should review all the available Tier 1 requirements for hose 

stations for manual fire fighting capability. The ITAAC will describe the dedicated source of 

water supply and the minimum volume needed, which the licensee should verify by 

confirming as-built dimensions and performing calculations of the useable volume. The 

system test should be either a construction test or preoperational test to demonstrate the 

system capability. The test should be a flow test to demonstrate that the system can 

provide a minimum required flow at a minimum allowed discharge pressure from the most 

remote and/or highest elevation hose stations. During the test the flow and discharge 
Issue Date: 07/01/08 4 65001.15 

pressure should be measured and confirmed to exceed the minimum of each 

simultaneously. 

02.05 Main Control Room (MCR)Instrumentation and Controls. The ITAAC will typically 

require that the instrumentation and controls described in the Tier 1 document actually 

exist in the MCR. The inspector should obtain a list of the instrumentation and controls 

described in the Tier 1 document and visually verify that that equipment is installed in the 

MCR and that the equipment is operable. 

Guidance: In preparation for this inspection, the inspector should review all the available 

Tier 1 and Tier 2 fire protection information to gain an understanding of what 

instrumentation and controls are committed to be installed in the MCR and what are the 

equipment attributes such as range, number, redundancy, diversity, etc. Then the 

inspector should go to the MCR and visually verify that the required equipment is installed. 

 The inspector should obtain and review records of the construction or preoperational 

testing of the equipment to confirm that it has been tested and demonstrated to work 

properly. 

02.06 Fire Protection System Water Supply. The ITAAC will typically require that there be 

a water supply available. The inspector should review all the available Tier 1 and Tier 2 

fire protection information to determine the exact requirements and visually inspect the 

equipment to confirm that all the requirements are met 

Guidance: An example of a typical ITAAC requirement would be that the fire protection 

system provides two fire water storage tanks, each capable of holding at least 300,000 

gallons of water. The inspector should obtain a copy of the as-built drawings and the 

design specifications for the tanks. Review those documents to verify that they support 

that the installed tank size will meet the required minimum useable water volume. Then 

visually inspect the tanks to verify their installation is acceptable and agrees with the asbuilt drawings. 

02.07 Fire Pumps. The ITAAC will typically require that there be installed a number of fire 

pumps and that they are each capable of delivering a certain minimum flow at a certain 

minimum developed head differential pressure. The inspector should obtain a copy of the 

test and/or analysis documents that support the ITAAC completion and verify their 

adequacy. If vendor, construction or preoperational testing of the pumps was performed, 

review the records of those tests to verify that they show that the pumps can meet 

minimum flow and differential pressure requirements. If there were no verification tests, 

methods of validating capability should be discussed and resolved. Visually inspect the 

pumps to verify that the required number exists and they are adequately installed. If the 

opportunity exists to witness the pump testing the inspector should do so, but records 

review is sufficient to complete this IP. 

Guidance: Records of pump testing are more reliable than a system design analysis so 

the inspector should obtain and review records of whatever testing was done. The tests 

may be vendor tests performed at the pump manufacturer=s facility and/or construction or 

preoperational testing of the pumps performed on site. If the opportunity exists to witness 

all or part of the pump testing the inspector should do so, but records review is sufficient to 

verify the pumps= capabilities. 
Issue Date: 07/01/08 5 65001.15 

02.08 Fire Detection and Alarm Systems. The ITAAC will typically require that fire 

detection and alarm systems are installed in the plant and will initiate fire alarms in the 

areas specified in the Tier 1 documents. The inspector should review all the available Tier 

1 and Tier 2 fire protection information to determine the exact requirements and visually 

inspect the installed fire detection and alarm equipment to confirm that all the requirements 

are met. The ITAAC may require that the equipment be powered from an uninterruptible 

power supply. If so, the inspector should obtain and review as-built electrical drawings to 

confirm that the power supply requirements are met. The inspector should obtain and 

review records of the fire detection and alarm systems construction or preoperational 

testing to verify that the equipment is functional and performs correctly. If the opportunity 

exists to witness portions of the construction or preoperational testing of the fire detection 

and alarm systems the inspector should do so, but records review is sufficient to complete 

this IP 

Guidance: By review of the Tier 1 and 2 documentation the inspector can determine 

exactly what attributes the fire detection and alarm systems are required to have. 

Detectors are typically located in many places but the most important ones are where 

safety related equipment is located. The inspector can confirm by plant walkdown that all 

the required equipment is in place. A review of the records of construction and/or 

preoperational testing is the most reliable way to confirm that the equipment is functional. 

Such testing may include a test confirmation of the source of system power. 

02.09 Automatic Fire Extinguishing Systems. An ITAAC may require an installed 

automatic fire extinguishing system in various locations e.g. diesel generator, fuel oil day 

tank, cable spreading, battery room, etc. If such an ITAAC is to be inspected, the inspector 

should review all the available Tier 1 and Tier 2 fire protection information to determine the 

exact requirements and visually inspect the installed fire extinguishing equipment to 

confirm that all the requirements are met. The inspector should obtain and review records 

of the fire extinguishing systems construction or preoperational testing to verify that the 

equipment is functional and performs correctly. If the opportunity exists to witness portions 

of the construction or preoperational testing of the fire extinguishing systems the inspector 

should do so, but records review is sufficient to complete this IP. 

In the case of automatic sprinkler systems, design calculations should be verified to ensure 

proper flow, pressures, restrictions and sprinkler head limitations are accounted for. 

Additionally, for non-liquid fixed-suppression methods i.e. Halon, CO2 etc, subsystem 

integration should be verified to ensure proper concentration levels and duration. Such 

subsystems might include: damper response, valve position, alarm, ventilation etc. 

Guidance: By review of the Tier 1 and 2 documentation the inspector can determine 

exactly what attributes the fire extinguishing systems are supposed to have. There are 

various kinds of systems such as water sprinklers, foam-water, CO2 flooding and others so 

the inspector may have to do some research to determine the critical characteristics of a 

given type of system. The inspector can confirm by plant walkdown that all the required 

equipment is in place. A review of the records of construction and/or preoperational testing 

is the most reliable way to confirm that the equipment is functional. Such testing should be 

devised to verify that the system will actuate in response to the appropriate signals and will 

actually perform its intended function e.g. flood the room with CO2 to a concentration of 
Issue Date: 07/01/08 6 65001.15 

XXX in YYY minutes. These performance criteria may be found in the Tier 2 documents 

but may have to be obtained from more detailed plant design documents. 

02.10 FPE Secondary Functions. An ITAAC may specify a secondary function for FPE 

such as Aprovides safety-related containment spray for severe accident management@. For 

plants with secondary functions, the inspector should review all the available Tier 1 and 

Tier 2 fire protection information to determine the exact requirements and visually inspect 

the installed FPE to confirm that all the requirements are met. The inspector should 

determine if any construction or preoperational testing was performed on the secondary 

equipment. If testing was done, obtain the records and review them to confirm that the 

equipment is functional. 

Guidance: For secondary function, it may not be possible or practical to perform full 

performance testing, as it may be destructive to plant equipment. In the example of 

secondary containment spray, the acceptance criteria is spray headers are installed and 

they contain the correct number of nozzles at the correct elevation. The inspector can 

confirm that the acceptance criteria are met by a combination of visual inspection and 

review of as-built drawings. 

02.11 FPE Capacities. An ITAAC may require various capacities such as Athe fuel tank for 

the diesel-driven fire pump is capable of holding at least 240 gallons@. The inspector 

should obtain a copy of the as built drawings and compare them to visual examination of 

the installed equipment. The dimensions of the tank will confirm that the useable volume 

acceptance criteria are met. 

 

Guidance: Review of the design drawings will allow the inspector to determine that FPE 

capacities should be adequate. The inspector should confirm that the FPE installed in the 

plant matches the design drawings. 

02.12 Fire Hazards Analysis. An ITAAC may require Aa Fire Hazards Report exists for the 

as-built plant and concludes that for each postulated fire, the plant can be shutdown and 

maintained in a safe, cold shutdown condition@. The inspector should obtain a copy of the 

current Fire Hazards Report and review it on a sampling basis for accuracy and fidelity to 

the as-built plant. 

Guidance: The Fire Hazards Report will be submitted to the NRC as part of the 

application for the plant Combined License and will receive a detailed review as part of the 

licensing process. There may be numerous changes to the Fire Hazards Report by the 

licensee during the review process as a result of NRC interaction. The inspector should 

ensure that he has the latest and final approved version of the report for the inspection. 

The acceptability of the final Fire Hazards Report and its contained analysis and the means 

and method of achieving and maintaining cold shutdown for any fire situation will be 

approved by the NRC as part of the licensing process. The inspector=s role is to verify that 

the Fire Hazards Report is consistent with the actual plant as-built configuration. The 

inspector should review the Fire Hazards Report to understand its organization and 

content. Then on a sampling basis, the inspector should visually verify that FPE as 

installed in the plant agree with their description in the Fire Hazards Report and that the 
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actions and performance of the FPE is consistent with their description in the Fire Hazards 

Report. 

02.13 Electrical Distribution. An ITAAC will typically require for safety related electrical 

distribution that redundant safety related equipment is powered from their respective class 

1E division. Also, ITAAC will typically require for safety related electrical distribution that 

there is separation between the multiple class 1E divisions and between the class 1E 

divisions and non-class 1E electrical cable. ITAAC may require that certain specified 

physical separation is maintained between class 1E divisions and class 1E to non-class 1E 

cables in accordance with certain fire areas identified in a table in the Tier 1 documents. 

Guidance: This inspection should be performed by an inspector knowledgeable of 

electrical distribution design practices that apply to new reactor designs. The inspector 

should determine from site specific engineering design documents what electrical industry 

standards the plant is committed to meet. Obtain a copy and review those standards to 

understand the intended design requirements. Then obtain as-built one line electrical 

drawings for the plant electrical distribution. For one division, trace the electrical 

distribution path from source to powered equipment and verify that other divisions are 

identical layouts or verify that divisional differences if any exist are acceptable 

arrangements. Confirm that division designated equipment is powered only from its 

designated divisional source. 

With the help of licensee engineers, obtain access to the electrical cable routing record 

system for the plant. From the electrical drawings, select for inspection sample cable runs 

from source to risk significant equipment. From cable routing records, confirm that those 

runs are isolated from other 1E division cables and from any non-class 1E cable runs. For 

the sample cable runs, perform a visual inspection in the plant to confirm that cable routing 

records are accurate and the specified separations exist. 

. 

02.14 Remote Shutdown Equipment. One or more ITAAC will typically exist on remote 

shutdown equipment which would be used to shutdown the plant from outside the main 

control room (MCR) if the MCR were to become inaccessible. An ITAAC will typically 

require that the remote shutdown room or station contain controls and displays and alarms 

specified in a Tier 1 table. There may also be ITAAC on the location and characteristics of 

the enclosure in which the equipment is located, e.g. fire proof barriers, ventilation, 

separation, security etc. 

Guidance: The inspector should review the Tier 1 and Tier 2 documents to determine 

the ITAAC requirements for the remote shutdown equipment (RSE) and enclosures. The 

inspectors should obtain as-built plant drawings of the RSE and enclosures and then 

perform a visual inspection of all of the ITAAC specified attributes to verify that the 

drawings conform to the as-built plant and both fully conform to the ITAAC requirements. 

02.15 Structures. An ITAAC will typically require for various structures containing safety 

related equipment that the inter-divisional walls, floors, doors, penetrations and external 

wall penetrations have a three-hour fire rating capability. This is the typical requirement for 

the control building, reactor containment building, auxiliary equipment building, diesel 

generator building, and possibly the turbine building and other buildings. 
Issue Date: 07/01/08 8 65001.15 

Guidance: Concrete walls will typically provide adequate fire barrier protection so 

inspections should focus on doors and penetrations. Obtain as-built structural drawings of 

the plant and determine if a three hour fire rating is specified for doors and penetrations 

into areas containing safety related equipment. Select a sample of doors and penetrations 

for inspection and verify by procurement records review that the equipment possesses the 

specified fire rating. For that same sample, visually inspect the equipment in the plant to 

verify that it conforms to the drawings and procurement records and provides the required 

fire resistance. 

02.16 Integration with other Systems. During walkdowns, observe if the fire protection 

water systems are vulnerable to voiding or water hammers. Also observe if fire protection 

water system piping were to rupture could this make other risk significant systems 

inoperable. Also observe if activated, could the Halon system affect personnel routes for 

manual actions or to the alternate safe shutdown system equipment. 

Guidance: During walkdowns inspectors should be alert to detect any potential negative 

interactions between fire protection water systems and other risk significant equipment in 

the same area. 

02.17 Problem Identification and Resolution. Those problems identified by the inspector 

shall be discussed with the licensee and the licensee shall enter the problems into a 

corrective action system. 

Guidance: The inspector shall ensure that the licensee is entering problems into a 

corrective action system and appropriate corrective actions are being developed. 

65001.15-03 RESOURCE ESTIMATE 

Inspection resources necessary to complete this inspection procedure are estimated to be 

80 hours of direct inspection effort over the course of plant construction. 

65001.15-04 REFERENCES 

10 CFR 50 Appendix A, Criterion 3, AFire Protection@

10 CFR 50.48 AFire Protection@

10 CFR 50 Appendix R AFire Protection Program for Nuclear Power Facilities Operating 

Prior to January 1, 1979.@

National Fire Protection Association (NFPA) NFPA 1 AUniform Fire Code@, 2006 Edition or 

the Revision/ Edition to which the licensee is committed 

NFPA 805 APerformance-Based Standard for Fire Protection for Light Water Reactor 

Electric Generating Plants, 2001 Edition 

NFPA 804 AStandard for Fire Protection for Advanced Light Reactor Electric Generating 

Plants, 2006 Edition 
Issue Date: 07/01/08 9 65001.15 

NUREG-800, Revision 3, AStandard Review Plan for the Review for Nuclear Power Plants, 

A March, 2007 

Inspection Procedure 40504, APart 52, Identification and Resolution of Construction 

Problems” 

END 

Attachment 1: Revision History for IP 65001.15 
Issue Date: 07/01/08 Att1-1 

Attachment 1 

Revision History For 65001.15 

Commitment Tracking Number 

Issue Date Description of Change Training 

Needed 

Training Completion Date 

CoAc

07/01/08 CN 08-019 

1. Initial issue to support ITAAC related New Reactor Construction Inspections under 10CFR52 2. Researched commitments for 4 years and found none. 

None N/A N/A