Regulatory guides are issued to describe and make available to the public such information as methods acceptable to the NRC staff for implementing specific parts

of the NRC’s regulations, techniques used by the staff in evaluating specific problems or postulated accidents, and data needed by the NRC staff in its review of

applications for permits and licenses. Regulatory guides are not substitutes for regulations, and compliance with them is not required. Methods and solutions different

from those set out in the guides will be acceptable if they provide a basis for the findings requisite to the issuance or continuance of a permit or license by the

Commission.

This guide was issued after consideration of comments received from the public. Comments and suggestions for improvements in these guides are encouraged

at all times, and guides will be revised, as appropriate, to accommodate comments and to reflect new information or experience. Written comments may be submitted

to the Rules and Directives Branch, ADM, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

Regulatory guides are issued in ten broad divisions: 1, Power Reactors; 2, Research and Test Reactors; 3, Fuels and Materials Facilities; 4, Environmental and Siting;

5, Materials and Plant Protection; 6, Products; 7, Transportation; 8, Occupational Health; 9, Antitrust and Financial Review; and 10, General.

Single copies of regulatory guides (which may be reproduced) may be obtained free of charge by writing the Distribution Services Section, U.S. Nuclear Regulatory

Commission, Washington, DC 20555-0001, or by fax to (301)415-2289, or by email to DISTRIBUTION@NRC.GOV. Electronic copies of this guide are available

on the internet at NRC’s home page at <WWW.NRC.GOV> in the Reference Library under Regulatory Guides. This guide is also in the Electronic Reading Room

at NRC’s home page, along with other recently issued guides, Accession Number ML011500010.

U.S. NUCLEAR REGULATORY COMMISSION May 2001

REGULATORY

GUIDE

OFFICE OF NUCLEAR REGULATORY RESEARCH

REGULATORY GUIDE 1.191

(Draft was DG-1069)

FIRE PROTECTION PROGRAM

FOR NUCLEAR POWER PLANTS DURING

DECOMMISSIONING AND PERMANENT SHUTDOWN

A. INTRODUCTION

This guide has been developed to describe methods acceptable to the NRC staff for complying with

the NRC’s regulations regarding fire protection programs for licensees who have certified that their plants

have permanently ceased operations and that the fuel has been permanently removed from the reactor

vessels.

The regulations that apply to fire protection programs for nuclear power plants during

decommissioning and permanent shutdown are in 10 CFR Part 50, “Domestic Licensing of Production and

Utilization Facilities.” The certification connected with decommissioning is described in 10 CFR 50.82,

“Termination of License.”

The licensee of a permanently shutdown nuclear power plant is required by 10 CFR 50.48(f) to

maintain a fire protection program to address the potential for fires that could result in the release or

spread of radioactive materials. The objectives of the fire protection program are to (1) reasonably prevent

fires from occurring, (2) rapidly detect, control, and extinguish fires that do occur, and (3) minimize the

risk of fire-induced radiological hazards to the public, the environment, and plant personnel.
1 As of the date of this regulatory guide, the NRC has not received any submittals of performance-based fire protection programs

nor has it reviewed any methods or approaches for developing or implementing performance-based programs. Moreover, the

NRC staff is not aware of the existence of specific methods or approaches for developing and implementing an acceptable

performance-based program. Nevertheless, as such methods and approaches are developed in the future, they could provide a

basis for meeting the requirements of 10 CFR 50.48(f).

1.191-2

This guide does not apply to independent spent fuel storage installations (ISFSIs) that are licensed

in accordance with the requirements of 10 CFR Part 72, “Licensing Requirements for the

Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste,” except for the fire

exposure risk to an ISFSI from a reactor during decommissioning. This guide does apply to spent

fuel storage facilities licensed under 10 CFR Part 50.

The regulations provide for a performance-based fire protection program that can readily

be modified during the decommissioning process to address residual hazards. The performance

goals and measures established by the licensee should be founded on established industry

standards and practices and should provide reasonable assurance that the fire protection objectives

of 10 CFR 50.48 will be met. If a licensee chooses to use fire protection methods different from

the guidelines recommended in this guide, the licensee should provide an equivalent level of fire

protection. The licensee is responsible for demonstrating the equivalency of proposed alternative

methods.1

Appendix A to this guide is a glossary of terms that have been used in this guide. These

definitions have been taken from existing regulatory documents and industry fire protection

standards when possible. If published definitions were not available, the staff defined the terms.

Appendix B to this guide provides examples of the level of fire protection that is acceptable to the

NRC staff for spent fuel areas.

The information collections contained in this regulatory guide are covered by the

requirements of 10 CFR Part 50, which were approved by the Office of Management and Budget,

approval no. 3150-0011. If a means used to impose an information collection does not display a

currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not

required to respond to, the information collection.

B. DISCUSSION

GENERAL

The fire protection requirements for operating reactors are provided by General Design

Criterion (GDC) 3 of Appendix A to 10 CFR Part 50, 10 CFR 50.48, and Appendix R to

10 CFR Part 50. Before the decommissioning rule was published on July 29, 1996, the NRC's fire

protection regulations did not address nuclear power plants that have permanently ceased

operations and are in the process of decommissioning.

The primary objectives of the fire protection program for operating reactors are to

minimize fire damage to structures, systems, and components (SSCs) important to safety; to ensure

the capability to safely shut down the reactor; and to maintain it in a safe shutdown condition. For
1.191-3

an initial period following shutdown, accidents that can challenge the 10 CFR Part 100 limits

remain credible. The fire protection program should continue to provide protection against these

events. The primary fire protection concern for permanently shutdown plants is protecting the

integrity of the spent fuel and preventing or minimizing the release of radioactive materials

resulting from fires involving contaminated plant SSCs or radioactive wastes. The radiation dose

limits specified in 10 CFR Part 20, "Standards for Protection Against Radiation," apply to plant

personnel and members of the public for fire incidents at permanently shutdown nuclear power

plants. Licensees should make every effort to maintain exposures to radiation resulting from a fire

as low as reasonably achievable.

The fire protection program for an operating reactor provides the basis for developing the

fire protection program for the decommissioning phase. The goal of the fire protection program

during decommissioning of nuclear power plants is to provide an appropriate level of defensein-depth protection against the threat of fires. Defense in depth, relative to fire protection,

involves a comprehensive program of administrative controls, physical fire protection features,

emergency response capabilities, and protection of SSCs necessary to prevent or mitigate the

potential of an unacceptable release of radioactive materials. This combination of fire protection

elements acts to reduce both the probability and consequences of fire events, and it provides

assurance that the failure of any one element within the fire protection program is adequately

compensated for by the others, thereby minimizing the risks to the public, environment, and plant

personnel.

Licensees that have permanently shut down their nuclear power plants, and have made the

submittals to the NRC required by 10 CFR 50.82, may either immediately begin decommissioning

and dismantling the facility or may choose to place the facility in a monitored storage condition for

some period of time before beginning final decommissioning and dismantlement activities. The

fire protection requirements may differ considerably, depending on the licensee's approach to

decommissioning.

In general, the processes and activities associated with nuclear plant decommissioning can

be dynamic, with plant conditions and configurations continuously changing. Decommissioning

activities may increase fire hazards in the plant through mechanisms that include, but are not

limited to, increased hot work (e.g., welding, cutting, grinding), increased combustible loading,

erection of temporary structures to support decommissioning or dismantlement of the plant, and

deactivation or abandonment of plant systems. In addition to the physical changes to the plant, the

licensee's organizational structure and responsibilities are expected to be different during

decommissioning, with staffing levels significantly lower than during plant operations.
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C. REGULATORY POSITION

1. FIRE PROTECTION PROGRAM

1.1 Objectives

This regulatory guide describes a fire protection program for permanently shutdown

nuclear power plants that is acceptable to the NRC staff for meeting the requirements of 10 CFR

50.48(f) regarding fire protection for permanently shutdown nuclear power plants. Because of the

dynamics of the decommissioning process, the licensee's fire protection program should be

reevaluated at least annually and revised as necessary to reflect the facility condition through the

various stages of decommissioning in accordance with this regulatory guide. The fire protection

program should address the following performance objectives.

ˇ Prevent fires. Administrative controls and, where possible, physical features (e.g.,

barriers or other physical separation of combustibles from ignition sources) should be

implemented to provide reasonable assurance that fires will not occur.

ˇ Rapidly detect, control, and extinguish fires that do occur and could result in a

radiological hazard. Appropriate levels of fire protection, including detection systems,

automatic or manual fire suppression systems, water supplies, and emergency response

capability, should be provided based on the fire hazards present.

ˇ Minimize the risk to the public, environment, and plant personnel resulting from fires

that could result in a release of radioactive materials. Plant SSCs important to the

prevention or mitigation of fire-induced releases of radioactive materials should have an

appropriate level of fire protection. Plant personnel should be adequately trained in

emergency response procedures for fire events.

1.2 Fire Protection Program Standards

The fire protection program for decommissioning should be based on sound engineering

practices and established industry standards such as those provided by the National Fire Protection

Association (NFPA). This regulatory guide endorses several standards as guidance for

implementing various elements of the fire protection program. These standards are cited in this

guide as guidance, not NRC requirements. Deviations from industry codes and standards should

be justified on a case-by-case basis. The cited standards should be applied in a manner consistent

with the NRC's regulations. An individual plant's standards of record are generally established in

the operating plant's fire protection program and will also be considered to apply to the

decommissioning fire protection program as appropriate. Licensees may consider adoption of

standards more recent than the plant's standards of record when they are consistent with NRC's

regulations and with appropriate evaluations for reductions in protection.
1.191-5

1.3 Transition from Operating Plant Program

Operating plants are required to have a fire protection program in accordance with the

requirements of 10 CFR 50.48 and General Design Criterion 3, "Fire Protection," of Appendix A

to 10 CFR Part 50. The primary objective of the operating plant fire protection program is to

provide defense-in-depth protection of the capability to shut down the reactor and maintain it in a

safe shutdown condition. The safe shutdown objective is not applicable during decommissioning,

with the reactor permanently shut down and the fuel removed from the reactor vessel. However,

many of the elements of the operating plant fire protection program continue to be applicable

under plant decommissioning. The operating plant fire protection program provides the baseline

analysis and description of plant fire hazards, administrative controls, physical protection features,

and emergency response capabilities. Many of these elements will be carried over to the fire

protection program for decommissioning.

1.4 Fire Protection Program for Decommissioning

The fire protection program is expected to change throughout the various phases of

decommissioning. Initially, with spent fuel removed from the reactor and stored in the spent fuel

pool, it is appropriate to develop and maintain a comprehensive decommissioning fire protection

program to provide assurance that the probability of fires affecting the spent fuel or other

radiological hazards is minimized and that the consequences of fires, should they occur, are

adequately mitigated. As decommissioning progresses and the spent fuel is moved to an

independent storage facility or permanent repository, the fire protection requirements for the plant

may be scaled down in accordance with the diminishing radiological hazard. However, even in the

absence of spent fuel in the spent fuel pool, a fire protection program that ensures adequate

protection from the fire-induced release of radioactive material from contaminated plant areas and

combustible wastes should be maintained.

The decommissioning fire protection program described in this regulatory guide is limited

to decommissioning activities associated with the radiological hazards present in the plant or in the

ancillary facilities (e.g., onsite waste storage) that directly support the decommissioning process.

This guide does not provide guidance on fire protection for ISFSIs. The licensee alone will

determine fire protection requirements for plant areas that the licensee's fire hazards analysis has

shown to have property loss concerns.

The licensee should maintain a fire protection program as long as there are radiological

hazards on the site or until the Part 50 license is terminated and the site is released for restricted or

unrestricted use.

Subject to the requirements of 10 CFR 50.48(f)(3), a licensee may make changes to the fire

protection program without prior NRC approval provided the changes do not reduce the

effectiveness of fire protection for facilities, systems, and equipment that could result in a

radiological hazard, taking into account the plant conditions and activities during

decommissioning.
1.191-6

2. FIRE HAZARDS ANALYSIS

The fire hazards analysis provides a comprehensive evaluation of the facility's fire hazards,

the fire protection capability relative to the identified hazards, and the ability to protect spent fuel

and other radioactive materials from potential fire-induced releases. The fire hazards analysis in

place for plant operation may be used as the baseline, but it should be reevaluated and revised as

necessary to reflect the unique or different fire protection issues and strategies associated with

decommissioning. At a minimum, the fire hazards analysis should address the following items.

2.1 Fire Hazards

The fire hazards should be identified specifically, typically by fire area. The fire hazards

for a plant undergoing decommissioning may be significantly different from those for an operating

plant, and they may change as decommissioning progresses. The fire hazards analysis should

consider the potential for increased combustible loading from sources such as equipment lay down

areas, waste accumulation and storage areas, and materials necessary to support decontamination

and dismantlement activities. Hot work involving open flames or sparks is also likely to increase

during decommissioning. Other fire hazards may include temporary structures and support

systems (e.g., electrical, heating, and ventilation) that may impact the fire hazards in the plant.

2.2 Physical Plant Configuration and Condition

The fire hazards analysis should describe the layout, configuration, and condition of the

plant fire areas and should be updated to reflect any significant changes that occur through the

various decommissioning phases. Dismantlement of or modifications to facility structures and the

deactivation, modification, or removal of plant systems may impact fire protection program

elements.

2.3 Fire Protection Elements

The fire hazards analysis should describe the administrative controls, fire detection and

suppression systems, smoke exhaust systems, fire barriers, and any other pertinent elements of the

administrative and physical fire protection program that protect against the identified fire hazards.

2.4 Radiological Hazards and Systems Important to Safety

The fire hazards analysis should identify the radiological hazards by fire area and, as

appropriate, identify the SSCs such as the plant ventilation systems necessary to prevent or

mitigate the release of radioactive materials in the event of a fire. Consideration should be given

to the control of runoff from fire suppression activities in areas containing radioactive materials.

The onsite and offsite radioactive releases expected from a fire should be quantified or referenced

in the fire hazards analysis and compared to the dose acceptance criteria in 10 CFR Part 20.

As decommissioning progresses, the radiological hazards may change as areas and

structures are decontaminated, contaminated components are removed, the spent fuel storage

configuration is changed (e.g., from pool to dry cask or the fuel removed to an ISFSI), and
1.191-7

contaminated waste accumulates (before being transported to an offsite storage facility). System

configurations and requirements may also change with changing hazards and the general

progression of decommissioning activities; significant changes should be reflected in the analysis.

2.4.1 Spent Fuel

The SSCs necessary to protect the spent fuel should be identified and may include the spent

fuel storage enclosure and pool, spent fuel pool cooling and makeup systems, and any necessary

support systems such as instrumentation and control, ventilation, and electrical power systems.

The fire hazards analysis should describe the fire threats, the associated measures to protect the

spent fuel, and any associated SSCs that are important to maintaining spent fuel integrity.

Appendix B to this guide provides examples of the level of fire protection acceptable to the NRC

staff for spent fuel areas.

2.4.2 Contaminated Plant Areas and Waste Storage

The fire hazards analysis should identify areas of the plant that contain significant

radioactive contamination that might be released or spread by the effects of a fire. As the plant is

decontaminated and dismantled, contaminated waste (including combustible and potentially

contaminated plant equipment such as electrical cables) may accumulate. The fire hazards

analysis should include an assessment of the potential for this material to be involved in a fire and

of the protective measures provided to minimize the potential for fire-induced releases or spread of

radioactive material. Appendix B to this guide contains an example of the level of fire protection

acceptable to the staff for radioactive waste storage areas.

2.5 Exposure Risks from Co-Located Facilities

The fire hazards analysis should evaluate the risks of exposure associated with fires at the

same site or at nearby facilities. Consideration should be given to the effects of a fire on shared

systems for multi-unit sites and to the potential for fires to propagate from one facility to the other.

Decommissioning may require erecting temporary onsite structures for the storage of

radioactive and other wastes generated by the decommissioning and dismantlement activities. The

fire hazards associated with fires in these facilities should be analyzed in conjunction with the

potential for such fires to propagate to other plant areas and result in radiological releases.

3. ADMINISTRATIVE CONTROLS

Administrative controls involve the policies, procedures, and practices that govern the

performance or execution of fire protection program activities necessary to ensure that the fire

protection objectives are met. These controls establish the necessary fire prevention measures and

contain the requirements for maintenance, testing, inspection, and availability of physical fire

protection features (e.g., barriers, detection, and suppression); organizational responsibilities; and

the training or qualification requirements for general employees, emergency responders, and

licensee contractors.
1.191-8

3.1 Organization

Licensees' decommissioning organizations are likely to be significantly smaller than those

necessary for an operating plant. The fire protection program should identify and clearly establish

the organizational responsibilities for management and implementation of the fire protection

program. The fire protection responsibilities of licensee contractors should also be established.

Organizations or positions responsible for the following fire protection activities should be

identified:

ˇ Management of the overall fire protection program,

ˇ Development, maintenance, updating, and verification of compliance of the fire protection

program,

ˇ Implementation of fire protection program requirements (including policies and

procedures, training, fire protection system controls, system inspection, testing,

maintenance and design, control of combustibles, and hot work),

ˇ The leadership, staffing, and training of the emergency response team (e.g., fire brigade)

and agreements with offsite responders.

The organizations responsible for implementing the fire protection program should include

an individual (or individuals), adequately qualified in nuclear safety and fire protection

engineering, who will ensure that the fire protection program is implemented in accordance with

applicable industry standards and NRC regulations.

3.2 Fire Protection Procedures

Procedures should be provided to formally establish the organizational responsibilities and

administrative practices of the fire protection program.

Emergency procedures should be provided to describe emergency response actions,

including the operational actions (e.g., ventilation system lineups and operational requirements),

necessary to mitigate the consequences of fires. Fire pre-plans should identify the fire fighting

strategy to be employed according to the fire location and the hazards involved. Coordination with

offsite responders and the fire response leadership and command structure for both the onsite fire

brigade and offsite responders should be explained.

The activities associated with decommissioning and dismantling a plant result in constantly

changing hazards. Maintaining adequate fire protection and safety in this changing environment

requires constant vigilance on the part of the fire protection staff, plant personnel, and

decommissioning contractors. For this reason, the fire protection program should be integrated

with the work control processes and should provide for proper review and authorization of work

activities involving fire hazards or fire system maintenance, testing, impairments, or deactivation.
1.191-9

3.3 Training

Training is necessary to ensure that the licensee's employees, contractors, and emergency

responders have the necessary knowledge and skills to properly execute their responsibilities

regarding the fire protection program.

3.3.1 General

Plant personnel and contractor employees should be informed of the proper procedures for

reporting a fire, responding to plant fire alarms, preventing fires at the plant, locating and using

fire extinguishers, and of the hazards of incipient-stage fire fighting. Personnel who are

designated to use a fire extinguisher as part of an emergency action plan should receive training in

the appropriate use of the available equipment. Additional guidance and information is provided

in NFPA 1, "Fire Prevention Code."

3.3.2 Fire Watch

Fire watch personnel for buildings and hot work operations should be informed of their

specific duties and responsibilities. Fire watch personnel should be trained in the use of fire

extinguishers and should practice on training fires. Additional information and guidance is given

in Chapter 34, "Welding, Cutting, and Use of Torches," and Chapter 41, "Safeguarding Building

Construction and Demolition Operations," of NFPA 1 and in Chapter 3, "Fire Prevention

Precautions," of NFPA 51B, "Standard for Fire Prevention in Use of Cutting and Welding

Processes."

3.3.3 Fire Brigade and Offsite Support

Plant personnel who are assigned manual fire fighting responsibilities should receive

training commensurate with their responsibilities. Fire brigade members and responding offsite

emergency services personnel should receive training on facility layout, fire hazards, fire pre-plans,

fire fighting equipment, radiation hazards, and health physics relevant to fire fighting operations.

Periodic drills should be conducted to determine the readiness and capability of fire brigade

personnel and offsite responders. The plant training program should be described in writing, and

written records of all plant fire brigade training should be maintained. Fire protection standards

NFPA 600, "Standard on Industrial Fire Brigades," NFPA 801, "Standard for Facilities Handling

Radioactive Materials," and NFPA 1500, "Fire Department Occupational Safety and Health

Program," provide information and guidance on training for fire suppression personnel.

3.4 Control of Combustible Materials

Combustible materials, including flammable and combustible liquids, compressed gases,

construction materials, and refuse, should be used, stored, and disposed of in a manner that

minimizes the occurrence of fire. Chapter 3-11, "Combustible Waste and Refuse," and Part V,

"Special Processes and Material Handling," of NFPA 1 and Chapter 3, "Processes and Hazards," of

NFPA 241, "Standard for Safeguarding Construction, Alteration, and Demolition Operations,"

provide information and guidance on the control of combustible materials. NFPA 30, "Flammable

and Combustible Liquids Code," and NFPA 55, "Use and Handling of Compressed and Liquefied

Gases in Portable Cylinders," provide information and guidance on the handling, storage, and use

of flammable and combustible liquids and gases.
1.191-10

3.4.1 Transient Combustibles

Transient fire hazards associated with decommissioning activities should be minimized to

the extent possible, and they should be removed promptly upon completion of the activities.

In particular:

ˇ The quantity of transient combustible materials should not exceed actual needs and should

be separated from ignition sources. Accumulation and storage of combustible wastes

should be minimized.

ˇ Wood should not be used for permanent applications in plant areas with a potential for a

radiological release. The use of wood for temporary purposes should be minimized and, if

used, the wood should be listed as pressure impregnated fire retardant lumber.

ˇ The use of plastic sheeting should be minimized and, if used, the plastic sheeting should be

fire retardant. NFPA 701, "Standard Methods of Fire Tests for Flame-Resistant Textiles

and Films," provides additional guidance.

ˇ Combustible waste materials that are radioactively contaminated or that present a fire risk

to radioactive material should be handled, packaged, and stored in a manner that minimizes

the threat of fire. Such waste materials should be protected by an active fire suppression

system or fire barriers or by limiting quantities.

ˇ Oily rags and materials susceptible to spontaneous ignition should be stored in a listed

disposal container and should be removed daily from areas containing radioactive materials

or contamination.

ˇ Good housekeeping practices should be maintained, with particular attention to areas

containing radioactive materials or contaminated waste and equipment. Accumulations of

combustible material, including waste and debris, should be removed from the work

location at the end of each shift. Spills of combustible or flammable liquids should be

contained and cleaned up immediately, with appropriate consideration for the safety of

personnel. The cleaning materials and waste should be removed from the area daily and

disposed of appropriately. General housekeeping practices should be implemented to

remove trash and clutter and to maintain clear access and egress routes throughout the

plant.

3.4.2 Storage of Flammable and Combustible Liquids and Gases

Flammable and combustible liquids and flammable compressed gases should be stored

where they do not present a fire risk to areas containing radioactive materials, contamination, or

SSCs important to the prevention or mitigation of radioactive material releases. Refer to NFPA 30

and NFPA 55 for additional information and guidance.

Smoking and working with open flame should not be permitted in areas used for the

storage of flammable and combustible liquids or compressed gases.
1.191-11

3.5 Control of Ignition Sources

3.5.1 Control of Hot Work

Cutting, welding, grinding, and work involving open flame should be controlled so that it

does not present an undue risk of fire. Chapter 34, "Welding, Cutting, and Use of Torches," of

NFPA 1, NFPA 51B, and NFPA 241 provide information and guidance for minimizing the risk of

fires from hot work. A qualified fire watch should be provided during the hot work activity and

for at least one-half hour after completion of the hot work.

3.5.2 Control of Temporary or Portable Heat-Producing Equipment

The fire protection program should identify the measures necessary to prevent portable

heat-producing equipment from causing a fire. Listed heat-producing equipment should be used.

Temporary heating devices should be secured to prevent tip-over and separated from combustible

materials, equipment, and construction in accordance with their listing. For fuel-fired heating, the

fuel storage, transfer and refueling systems, and operations should be in accordance with

applicable NFPA standards. The use of portable heat-producing equipment should be controlled in

areas with radiological hazards or significant quantities of combustible material that presents an

exposure hazard to radioactive materials or systems important to safety. Additional guidance and

information is contained in Chapter 41 of NFPA 1 and in Chapter 3 of NFPA 241.

3.5.3 Control of Smoking

Smoking should be permitted only in designated areas. Where smoking is permitted, safe

receptacles for smoking materials should be provided. Smoking should be prohibited in other

areas of the plant, specifically in the vicinity of hazardous operations or combustible or flammable

materials. No Smoking signs should be posted in these areas.

3.6 Control of Fire Protection Systems and Equipment

3.6.1 Control of Fire Protection Equipment

Personnel protective equipment for fire brigades, including turnout gear and self-contained

breathing apparatus, should regularly be inventoried, inspected, tested, and maintained to ensure

proper performance.

Manual fire fighting equipment, including extinguishers, hoses, nozzles, tools, fittings,

portable lighting, and communication and ventilation devices, should be regularly inventoried,

inspected, tested, and maintained to ensure proper operation in the event of a fire.

3.6.2 Fire Protection System and Features Operability, Inspection, Testing, and

Maintenance

A program for inspection, testing, and maintenance should be provided to verify the

operability of installed fire protection systems and features. Fire protection features include

passive fire protection systems such as fire barrier components and fire barrier seals. Fire

protection systems include fire alarm systems, fire suppression systems, and fire water supply

systems. The program for inspection, testing, and maintenance should be based on vendor

recommendations, insurance standards, or fire protection engineering judgment, as well as on

criteria specified in industry codes and standards such as those published by the NFPA.
1.191-12

Inspection, testing, and maintenance should be documented by means of written procedures, with

results and follow up actions recorded.

Personnel performing inspection, testing, and maintenance of installed fire protection

systems and features should be trained and qualified for the type of system to which they are

assigned.

3.6.3 Control of Fire Protection System Outages and Impairments

The fire protection program should provide the necessary controls to minimize the duration

and impact of impairments to the fire protection systems. Additional guidance and information is

provided in Chapter 11, "Impairments," of NFPA 25, "Standard for the Inspections, Testing, and

Maintenance of Water-Based Fire Protection Systems." The controls should provide for

identifying, prioritizing, and promptly correcting fire protection impairments, informing fire

protection staff of the impairment, and establishing compensatory measures for the duration of the

impairment. Compensatory measures may include, but are not limited to, conducting fire watch

tours of affected areas, limiting work activities involving fire hazards, providing alternative fire

protection features, and requesting special fire department support.

Work control practices during decommissioning should avoid scheduling activities that

involve hot work, the use of flammable or combustible materials, or other fire hazards in areas

with impaired fire protection systems.

3.6.4 Control of Fire Area Boundaries or Barriers

The fire protection program should address the control of fire area boundaries or barriers

and the maintenance of these structures as the facility is modified or dismantled during

decommissioning. Breaches in the fire barriers, caused by the removal of penetration seals or

other modifications, should be protected in accordance with the modified barrier's fire resistance

capability and the associated fire hazards. A program for inspecting, testing, and maintaining fire

doors, fire dampers, and fire walls or separations should be developed and implemented to ensure

these devices will perform as intended. The barrier control program should allow for

redesignation, modification, or removal of barriers, based on changes to the facility and hazards

(i.e., fire and radiological) as the facility is decommissioned. NFPA 221, "Standard for Fire Walls

and Fire Barrier Walls," contains additional information and guidance.

3.7 Control of Structures, Enclosures, and External Areas

3.7.1 Control of Temporary Enclosures and Structures

The fire protection program should address fire hazards created by the construction and

location of temporary enclosures and structures. The fire protection program should evaluate the

need for automatic or manual fire suppression capability inside and outside each temporary

structure. The use of combustible construction materials should be minimized and controlled in

accordance with Regulatory Position 3.4, "Control of Combustible Materials," of this guide.

Chapter 2, "Temporary Construction, Equipment and Storage," of NFPA 241 provides additional

information and guidance for controlling the fire hazards associated with temporary structures.
1.191-13

Temporary structures should not present a fire exposure hazard to plant structures

containing radioactive materials or radioactive contamination, or to contaminated waste material

accumulation or storage areas. NFPA 80A, "Recommended Practice for Protection of Buildings

From Exterior Fire Exposures," provides guidance for the appropriate separation of structures to

minimize the fire exposure.

Tents or other membrane-type structures should be constructed of noncombustible, fireretardant material. Membrane-type materials should be certified as conforming to the

requirements of the large-scale test described in NFPA 701.

3.7.2 Preventing Fire From Exposing Structures and Materials

The fire protection program should identify controls to protect structures containing

radioactive materials from an exposure fire. The fire hazard presented by transient combustibles,

including stored materials, debris, vegetation, and nearby or contiguous structures, should be

considered. Additional information can be found in NFPA 80A.

4. PHYSICAL FIRE PROTECTION FEATURES

The ability to rapidly detect, control, and suppress fires is one of the primary defense-indepth objectives of the fire protection program. The need for physical protection features is

governed by the plant's fire hazards and by the potential of these hazards to result in the release or

spread of radioactive materials.

4.1 Fire Detection and Alarms Systems

Detection systems in operating reactor facilities are generally placed in locations where fire

hazards present an exposure threat to safety-related equipment. Alarm systems are provided to

alert plant staff in the event of a detected fire or operation of an automatic suppression system.

During decommissioning, the fire hazards and the associated detection and alarm requirements

may change significantly. The change in priorities from protecting safety-related equipment

required for safe shutdown to protecting against the release or spread of radioactive material may

require reevaluation of the detection and alarm system design to ensure that decommissioning fire

hazards are adequately protected.

Fire alarm and supervisory signals should be annunciated in a constantly attended location.

The fire alarm system should provide a signaling system for notifying plant personnel. Refer to

NFPA 72, "National Fire Alarm Code." The fire alarm system should meet the following criteria.

ˇ The operation of an automatic fire suppression system initiates a fire alarm.

ˇ Automatic fire detection systems using smoke, heat, or flame detectors, as appropriate, are

maintained for early detection of fires.

ˇ Supervision of automatic fire suppression system control functions maintained, as

appropriate, by the alarm system.
1.191-14

4.2 Fire Barriers

4.2.1 Designating Fire Areas

Fire areas are established to prevent or restrict the propagation of fires from one area of a

facility to another, to protect personnel, and to limit the consequences of a fire. For operating

reactors, fire area boundaries are generally based on the need to separate and protect safe shutdown

systems. Based on a fire hazards analysis, fire areas may be redesignated to address the unique

hazards and protection requirements of the decommissioning process. The designation of fire

areas should be based on consideration of the hazards present; the potential for a fire in a given

area to result in an unacceptable release of radioactive materials; the ability to effectively contain,

fight, and control the fire using manual suppression; and the ability of personnel to safely evacuate

the plant.

4.2.2 Fire Barrier Requirements

Fire areas should be separated by fire-rated barriers. The fire resistance rating of a fire

barrier should be commensurate with the potential fire severity in each fire area. The components

of fire barriers are walls, ceilings, and floors, along with structural supports such as beams, joists,

and columns. Openings in a fire barrier should be sealed by the installation of fire dampers, fire

door assemblies, fire window assemblies, fire-rated penetration seals, and special floor drains.

Fire barrier components and seals should be qualified by testing. The design and installation of

fire barriers should be based on the applicable guidance in NFPA 80, "Standard for Fire Doors and

Fire Windows," NFPA 221, and NFPA 801. Any unprotected openings in a fire barrier should be

identified and justified in the Fire Hazards Analysis.

4.3 Fire Suppression Systems

4.3.1 Fire Water Supply

During decommissioning, the plant fire water supply system should be maintained, and the

system should be capable of providing the maximum water flow needed to supply automatic fire

suppression systems and manual fire fighting. The system should be capable of delivering the

maximum water flow demand for a minimum of 2 hours. The following factors should be

considered in determining the adequacy of the water supply:

ˇ Reliability of the water supply source

ˇ Availability of tanks or other water sources, pumps, fire hydrants, and distribution system

ˇ Adequate flow and pressure to meet water flow demands of automatic or manual fire

suppression, or both, at the point of delivery

ˇ Capacity of the water supply source and distribution system. If the water system is a

combined domestic, process, and fire system, the system should be capable of supplying

the maximum daily consumption or the peak hourly flow rate, whichever is higher, plus the

maximum required fire flow.

Decommissioning activities may result in the isolation, removal, or abandonment of

portions of the distribution system. Any system changes should be reviewed to ensure that

adequate flow and coverage is provided for the remaining plant areas that contain radioactive
1.191-15

materials, present a fire exposure threat to areas containing radioactive materials, or include

systems necessary to mitigate the release of radioactive materials.

Where temperatures cannot reliably be maintained at or above 4C (40F), water-based

fire suppression system components should be protected against freezing in accordance with the

applicable NFPA code. Freeze protection for sprinkler system components should be reviewed

regularly during decommissioning activities.

Decommissioning activities should not be allowed to affect the water supply to the

operating units or the fire water supplies and distribution systems that are shared at multi-unit

sites, and the capability to isolate the units should be maintained.

The design and installation of the water supply systems should be based on the applicable

guidance in NFPA 20, "Standard for the Installation of Centrifugal Fire Pumps"; NFPA 22,

"Standard for Water Tanks for Private Fire Protection"; NFPA 24, "Standard for the Installation of

Private Fire Service Mains and their Appurtenances"; and NFPA 801.

4.3.2 Automatic Fire Suppression Systems

Automatic fire suppression systems that exist when a plant enters the decommissioning

phase should be maintained operable based on the fire hazards analysis; these systems should be

able to protect plant egress routes for evacuation of plant personnel in the event of a fire.

Automatic fire suppression systems should be provided where flammable or combustible

materials are used or stored. Construction of new or temporary structures to support

decommissioning may require the installation of automatic systems based on the fire and

radiological hazards of the structures. Some factors to consider in selecting the type of

suppression system to be installed are the types of fire hazards and health hazards, cleanup of the

suppression agent, and the effect of the suppression agent on vital systems, structures, and

components in the area. NFPA 11, "Standard for Low-Expansion Foam"; NFPA 11A, "Standard

for Medium- and High-Expansion Foam Systems"; NFPA 12, "Standard on Carbon Dioxide

Extinguishing Systems"; NFPA 12A, "Halon 1301 Fire Extinguishing Systems"; NFPA 13,

"Installation of Sprinkler Systems"; NFPA 15, "Standard for Water Spray Fixed Systems for Fire

Protection"; NFPA 16, "Standard for the Installation of Deluge Foam-Water Sprinkler, and

Foam-Water Spray Systems"; NFPA 16A, "Standard for the Installation of Closed-Head

Foam-Water Sprinkler Systems"; NFPA 17, "Standard for Dry Chemical Extinguishing Systems";

NFPA 17A, "Standard for Wet Chemical Extinguishing Systems"; and NFPA 75, "Standard for the

Protection of Electronic Computer/Data Processing Equipment," should be used as the bases for

the design, installation, and operation of automatic fire protection systems.

The need for automatic fire protection systems in plant areas during decommissioning

activities may change, depending on the type of operations being performed in an area, the

addition or removal of combustible materials, or the removal of radioactive materials and

contamination. Plant areas should be reviewed for changing conditions that could affect the need

for automatic fire suppression systems.
1.191-16

4.3.3 Manual Fire Suppression Systems

Manual fire suppression systems should be provided in the plant to supplement automatic

fire protection systems and to provide suppression coverage to areas not protected by automatic

systems. Decommissioning activities may change the plant configuration and fire hazards, may

require the construction of temporary enclosures or structures, and may necessitate the

abandonment or removal of automatic systems as facilities are dismantled or modified and

radiological hazards are removed. Adequate manual fire suppression capability must be provided

or maintained based on the decommissioning fire hazards analysis to ensure protection against

fire-induced radioactive material releases.

The following considerations are important in evaluating the manual fire protection

systems:

ˇ Standpipe and hose systems should be maintained to provide manual fire suppression

capabilities. Standpipe and hose systems should be maintained in areas of the plant that are

above or below grade, that require long hose lays from the nearest hydrant, or that are

required to maintain the confinement of airborne radioactive materials. Refer to NFPA 14,

"Standard for the Installation of Standpipe and Hose Systems."

ˇ Manually operated fire suppression systems may be provided to supplement automatic fire

suppression systems or in areas where automatic fire suppression systems are not installed

and are not needed to rapidly control a fire. The need for manually operated fire

suppression systems should be based on consideration of the hazards present; the potential

that a fire in a given area could result in release of radioactive materials; the ability to

effectively contain, fight, and control the fire using manual suppression; and the ability of

personnel to safely evacuate the area.

ˇ Outside hydrants and hose houses should be maintained to support manual fire suppression

of internal fires and to provide protection from the threat of external exposure fires to those

plant areas that contain radioactive materials or SSCs necessary for the prevention or

mitigation of radioactive material releases. Refer to NFPA 24 for additional information

and guidance.

4.3.4 Onsite Fire Brigade and Offsite Fire Emergency Response

Manual fire fighting capability should be provided by an onsite fire brigade or by offsite

emergency services, or by both. A fire emergency plan should be developed describing the

response to fire alarms and the responsibilities assigned to emergency response personnel (see

Regulatory Positions 3.1, 3.2, 3.3, and 5.2). Refer to NFPA 600, NFPA 801, and NFPA 1500 for

information and guidance on fire fighting activities, training, equipment, and fire emergency plans.

The following factors should be considered in determining the manual fire fighting capability:

ˇ The magnitude and complexity of potential fires in and around plant areas where

radioactive materials or contamination are present

ˇ The availability of onsite staffing for a fire brigade at any time

ˇ The availability of offsite emergency services, the capability of their staff and equipment,

the response time, the staff’s training, and access to the plant site
1.191-17

ˇ The compatibility of the plant's fire system connections and fittings with the fire apparatus

and equipment of offsite responders.

Fire fighting equipment should be provided for manual fire fighting, including hoses,

nozzles, protective clothing, breathing apparatus, communications equipment, salvage equipment,

ladders, smoke removal equipment, portable lighting, portable radiation monitoring equipment,

extinguishers, and miscellaneous tools. (See Regulatory Position 3.6.1.)

Periodic drills and exercises should be performed by the onsite fire brigade and offsite

emergency services. See Regulatory Position 3.3.3 regarding the training of the fire brigade and

offsite personnel.

5. RISK MANAGEMENT

5.1 Personnel Safety

The fire protection program should provide for personnel safety in the event of a fire.

Egress and evacuation routes should be clearly established and maintained as the plant

configuration changes. The effect of smoke on exiting personnel should be considered.

Emergency lighting and alarms should be provided, and personnel should be appropriately trained

in fire response. Policies and procedures should establish radiological control and security

practices to be implemented under emergency fire evacuation scenarios. NFPA 101, "Code for

Safety to Life from Fire in Buildings and Structures," provides additional information and

guidance on ensuring personnel safety.

5.2 Emergency Response

For operating reactors, early detection and application of manual suppression can be

critical in minimizing the fire damage to safe shutdown systems that are necessary to prevent

damage to the reactor core and subsequent releases of radioactive material. When a reactor is

permanently shutdown and the spent fuel is stored in the spent fuel pool or dry cask storage, fire

suppression response times may not be as critical. The necessary fire emergency response

capability should be determined by the fire hazards and the potential for those hazards to involve

radioactive material.

The fire protection program should identify the responsibilities of the licensee's

organization and of offsite responders in the event of a fire emergency. Although an adequately

prepared, trained, and equipped plant fire brigade may suppress small fires and provide the initial

assault on and control of larger fires, a fully equipped fire service should be the primary force in

the manual suppression of large structure or site-area fires. This fire service may be provided by

offsite agencies provided the offsite responders have the necessary qualifications and capabilities,

as described in Regulatory Positions 3.1, 3.2, 3.3, and 4.3.4. If the licensee maintains an onsite

fire brigade, the assignment of personnel to the brigade should not impair the ability of the

remaining plant staff to respond to the event and maintain plant functions such as security,

radiation control, and operations.
1.191-18

The event management and command structure should be clearly established, including the

fire attack roles and responsibilities of the onsite brigade and offsite responders. Security control

and radiation dosimetry requirements for offsite emergency responders should be clearly

established and should not delay the response.

D. IMPLEMENTATION

The purpose of this section is to inform licensees and applicants of the NRC staff's plans

for using this regulatory guide.

Except when the applicant or licensee proposes an acceptable alternative method for

complying with specified portions of the NRC's regulations, the methods described in this guide

will be used in evaluating submittals for licensing-basis documents and periodic revisions or

updates to the decommissioning fire protection program that is submitted in accordance with the

required updates to the final safety analysis report.
1.191-19

REFERENCES

The following is a list of the National Fire Protection Association (NFPA) standards

referenced in this regulatory guide. The existing fire protection program for a given plant may

include additional NFPA and industry standards. Continued compliance with existing program

standards should be reviewed with due consideration of existing license commitments and

conditions, and the fire protection design basis of the specific plant. NFPA standards may be

purchased from the National Fire Protection Association, 1 Batterymarch Park, P.O. Box 9146,

Quincy, MA 02269-9959 (telephone 1-800-344-3555).

NFPA 1, "Fire Prevention Code."

NFPA 11, "Standard for Low-Expansion Foam."

NFPA 11A, "Standard for Medium- and High-Expansion Foam Systems."

NFPA 12, "Standard on Carbon Dioxide Extinguishing Systems."

NFPA 12A, "Halon 1301 Fire Extinguishing Systems."

NFPA 13, "Installation of Sprinkler Systems."

NFPA 14, "Standard for the Installation of Standpipe and Hose Systems."

NFPA 15, "Standard for Water Spray Fixed Systems for Fire Protection."

NFPA 16, "Standard for the Installation of Deluge Foam-Water Sprinkler, and Foam-Water Spray

Systems."

NFPA 16A, "Standard for the Installation of Closed-Head Foam-Water Sprinkler Systems."

NFPA 17, "Standard for Dry Chemical Extinguishing Systems."

NFPA 17A, "Standard for Wet Chemical Extinguishing Systems."

NFPA 20, "Standard for the Installation of Centrifugal Fire Pumps."

NFPA 22, "Standard for Water Tanks for Private Fire Protection."

NFPA 24, "Standard for the Installation of Private Fire Service Mains and Their Appurtenances."

NFPA 25, "Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection

Systems."

NFPA 30, "Flammable and Combustible Liquids Code."
1.191-20

NFPA 51B, "Standard for Fire Prevention in Use of Cutting and Welding Processes."

NFPA 55, "Use and Handling of Compressed and Liquefied Gases in Portable Cylinders."

NFPA 72, "National Fire Alarm Code."

NFPA 75, "Standard for the Protection of Electronic Computer/Data Processing Equipment."

NFPA 80, "Standard for Fire Doors and Fire Windows."

NFPA 80A, "Recommended Practice for Protection of Buildings from Exterior Fire Exposures."

NFPA 101, "Code for Safety to Life from Fire in Buildings and Structures."

NFPA 221, "Standard for Fire Walls and Fire Barrier Walls."

NFPA 241, "Standard for Safeguarding Construction, Alteration, and Demolition Operations."

NFPA 600, "Standard on Industrial Fire Brigades."

NFPA 701, "Standard Methods of Fire Tests for Flame-Resistant Textiles and Films."

NFPA 801, "Standard for Facilities Handling Radioactive Materials."

NFPA 1500, "Fire Department Occupational Safety and Health Program."
1.191-21

APPENDIX A

GLOSSARY

The following definitions have been taken from existing regulatory documents and industry

fire protection standards when possible. When published definitions were not available, the staff

defined the terms.

Abandonment. Permanently ceasing the use, operation, and maintenance of a structure, system,

or component through deactivation and isolation without intent to return the structure, system, or

component to service.

Co-located facilities. Facilities that share a common site with the nuclear power plant, including

any temporary structures.

Combustible material. Any material that will burn or sustain the combustion process when

ignited or exposed to fire conditions.

Contamination. Fixed or loose residual radioactive material deposited inside or outside

structures, systems, and components where it presents a potential radiological hazard.

Deactivation. Shutting down or otherwise idling plant systems and components to prevent their

operation, particularly in preparation for abandonment or removal.

Decommissioning. Safely removing a facility or site from service and reducing residual

radioactivity to a level that permits releasing the property for unrestricted use and terminating the

license or releasing the property under restricted conditions and terminating the license.

Dismantlement. Physically disassembling and removing plant structures, systems, and

components.

Emergency responders. Organizations and individuals who respond to plant emergency events

(including licensee emergency management and response staff, security personnel, and fire

brigades) and offsite responders (including law enforcement officials, medical personnel, and fire

departments).

Fire apparatus. A vehicle specifically designed to respond to fire events and provided with fire

fighting tools, equipment, and fire suppression capability.

Fire area. A part of a structure that is separated from other areas by fire barriers.

Fire barrier. Construction components (e.g., walls, floors, and ceilings, and their supports, such

as beams, joists, and columns; penetration seals; fire doors; and fire dampers) that are used to

prevent the spread of fire and that are rated by approving laboratories in hours of fire resistance.
1.191-22

Fire brigade. A team of onsite plant personnel who have been specifically assigned the

responsibility for fire fighting and who are adequately equipped for and trained in fighting fires.

Fire exposure hazard. A fire hazard that is external to a structure, system, or component in or

adjacent to the same area. The exposure to fire effects (e.g., smoke, heat, ignition) may impact the

capabilities of adjacent structures, systems, and components to prevent or mitigate the release of

radioactive material.

Fire hazard. Conditions necessary to initiate and support combustion, including in situ or

transient combustible materials, ignition sources (e.g., heat, sparks, open flames), and an oxygen

environment.

Fire-retardant material. Material that has been coated or treated with chemicals, paints, or other

materials designed to reduce the combustibility of the material.

Fire risk. The combination of the probability of a fire event and the estimated consequences of

the event.

Fire watch. One or more persons responsible for providing additional coverage (e.g., during hot

work) or compensatory coverage (e.g., for system impairments) of plant activities or areas for the

purpose of detecting fires or identifying activities and conditions that present a potential fire

hazard. The person or persons should be trained in identifying conditions or activities that present

potential fire hazards and in the use of fire extinguishers and the proper fire notification

procedures.

Hot work. Activities (such as cutting, welding, and grinding) that involve the use of heat, sparks,

or open flame and that are typically controlled by a formalized work permit system controlled or

reviewed by a fire protection engineer.

Impairment. Degradation of a fire protection system that decreases the ability of the system to

perform its intended functions.

Independent spent fuel storage installation (ISFSI). A facility designed and constructed for the

interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel

storage.

Lay down areas. Areas used for the temporary staging of materials before their use or disposal.

Listed. Equipment or materials on a list published by a nationally recognized testing laboratory,

inspection agency, or some other product evaluation organization that periodically inspects

production of the listed equipment or materials. The listing states that the equipment or materials

meet nationally recognized standards and have been tested and found suitable for use in a specified

manner.

Monitored storage. The operations and conditions associated with a permanently shutdown plant

that has no fuel in the reactor and for which decommissioning has been deferred to the future.
1 ASTM E-84 is available from the American Society for Testing and Materials, 100 Barr Harbor Drive, West Conshohocken, PA

19428-2959.

1.191-23

Noncombustible material. A material which, in the form it is used and under anticipated

conditions, will not ignite, burn, support combustion, or release flammable vapors when subjected

to fire or heat. Also a material with a structural base of noncombustible material, as defined

above, with a surfacing not over 1/8 inch thick, that has a flame-spread rating not higher than 50

when measured using ASTM E-84 (1997), "Standard Test Method for Surface Burning

Characteristics of Building Materials."1

Performance-based approach. A method of implementation based on measurable performance

goals and objectives.

Permanently ceased operations. Operations have permanently ceased when a licensee certifies

to the NRC that it has permanently ceased or will permanently cease reactor operations, or a final

legally effective order to permanently cease operations has come into effect.

Permanent fuel removal. Fuel has been permanently removed when all fuel assemblies have

been removed from the reactor vessel and the licensee has certified to the NRC that it has

permanently removed all fuel assemblies from the reactor vessel.

Pre-plan. A document that describes the facility layout, access, contents, construction, hazards,

hazardous materials, types and locations of fire protection systems, and other information

important to the planning of emergency fire response.

Radiological hazard. The presence of radioactive material, including sources, contamination,

wastes, and spent fuel, that presents a radiological exposure hazard that may be released in the

event of a fire and that is in excess of the dose limits to plant personnel specified in 10 CFR Part

20.

Safe shutdown. For fire events, the sequence of plant conditions specified in the plant technical

specifications as hot standby, hot shutdown, or cold shutdown.

Spent fuel. Reactor fuel assemblies that have been irradiated in the reactor core.

Standards of record. The standards, including specific editions, that constitute the licensing or

design basis for the plant.

Structures, systems, and components (SSCs). Structural elements, plant systems, and

components whose function is to prevent or mitigate the release of radioactive materials in the

event of a fire, including physical confinement barriers (building walls, floors, ceilings),

ventilation systems, spent fuel cooling systems and support systems, and waste storage containers.

Temporary structures. Buildings, tents, shelters, platforms, and other structures that are erected

during decommissioning activities. They are not permanent site facilities.
1.191-24

Turnout gear. Protective clothing for fire fighting such as coats, pants, boots, helmets, gloves,

and self-contained breathing apparatus (SCBAs).

Transient combustibles. Combustible materials that are not fixed in place or an integral part of

an operating system or component.

Unrestricted use. Areas in which the licensee neither limits nor controls access by the general

public and to which the public exposure requirements of 10 CFR Part 20 apply.
1.191-25

APPENDIX B

EXAMPLES OF FIRE PROTECTION FOR SELECTED

FIRE AREAS, STRUCTURES, SYSTEMS, AND COMPONENTS

The following examples describe acceptable fire protection for selected plant areas that

may contain radiological hazards. These examples are generic and do not encompass all possible

radiological and fire hazards for a plant undergoing decommissioning. These examples are

provided for guidance and information and are not NRC requirements.

Spent Fuel Pool Area

The fire hazards in the spent fuel pool area and those in adjacent areas should be quantified

if they present an exposure hazard or could propagate to the spent fuel pool area. The potential for

these fire hazards to impact radioactive materials, including the spent fuel, should be evaluated.

The radiological hazards in the area should be quantified, including hazards of the spent

fuel and any radioactive waste or contamination that may contribute to a radiological release if

exposed to fire. Potential releases of radioactive materials should be quantified by a conservative

analysis of the fire-related source term, the capabilities of mitigating systems, and emergency

response actions. Exposures resulting from the fire-induced release of radioactive materials

should not exceed the limits of 10 CFR Part 20.

Structures, systems, and components (SSCs) that are necessary to provide protection of the

spent fuel and mitigate any radiological release should be evaluated and protected from the effects

of fire, as appropriate. These systems may include building ventilation, spent fuel pool cooling

and makeup, instrumentation and controls, and electrical power. Rated fire barriers should be

maintained that provide separation between significant fire hazards and SSCs important to the safe

operation of the spent fuel pool. Where adequate separation cannot be provided, the use or storage

of combustible materials should be minimized and controlled.

If a fire in the spent fuel pool area could result in a loss of the normal spent fuel pool

cooling and makeup systems or a rapid loss of pool inventory, the capability to maintain spent fuel

integrity and minimize the potential for radiological release should be evaluated and alternative

cooling and makeup capabilities should be provided. The response time for reestablishing cooling

and makeup capability for the spent fuel pool should be quantified according to the need to ensure

that fuel integrity is maintained and radiological exposure limits for emergency response

personnel, including fire-fighters, are not exceeded.

Procedures should be developed that describe equipment configurations and necessary

operator actions in response to a fire in the spent fuel pool area. For example, ventilation systems

and any other building openings such as access doors should be configured to confine radioactive

materials and minimize the potential for their release to the environment. Spent fuel cooling and

makeup system components may have to be de-energized or operated from outside the fire area if

electrical and control systems are subject to potential fire damage.
1.191-26

Administrative controls for housekeeping, transient combustibles, and hot work in the

spent fuel area should be established by procedures. The work control procedures should ensure

that decommissioning activities associated with spent fuel pool operations and maintenance,

including any fuel movement or handling operations such as cask loading and shipment, are

subject to appropriate fire protection reviews.

Smoke detection and fire suppression capability for the spent fuel pool area should be

provided. Fire alarms and emergency lighting for personnel evacuation should be provided. As a

minimum, manual suppression capability should be available from portable fire extinguishers and

stand pipes or hose stations, or both. Manual fire suppression systems should provide adequate

coverage according to the fire hazards, evacuation routes, and fire attack strategies. Water

supplies should be sufficient to meet suppression system demands.

Fire pre-plans should be developed for the spent fuel pool area that identify the area layout,

access and egress points, type and location of suppression systems, significant fire hazards,

radioactive and toxic material hazards, and SSCs important to the prevention or mitigation of

releases of radioactive material that should be protected from the effects of fires. Onsite fire

brigades and offsite responders should be adequately trained and drilled on the pre-plans and

general fire attack strategy for the spent fuel pool area.

Radioactive Waste Storage and Accumulation Areas, Including Temporary Structures

Specific plant areas or separate structures should be provided for the storage of radioactive

wastes. Waste accumulation areas within the plant may be necessary to support certain

decommissioning activities. Combustible waste should be moved daily from accumulation areas

to designated storage areas. The waste storage and accumulation areas should provide adequate

separation and protection of the waste from exposure fire hazards. Temporary structures provided

for interim waste storage should comply with the appropriate fire codes and should be designed to

prevent or minimize the potential for radioactive material releases in the event of a fire.

The fire hazards in the radioactive waste storage and accumulation areas and fire exposure

hazards in adjacent areas that could propagate to the waste storage and accumulation areas should

be quantified. The potential for fire hazards to impact radioactive materials should be evaluated.

Special hazards such as contaminated electrical cables and plastics that, if ignited, can be difficult

to suppress and can emit considerable quantities of acrid smoke and toxic gases and hamper fire

fighting and evacuation efforts should be evaluated. Confinement measures should be provided as

necessary to mitigate release of radioactive materials entrained in the smoke and gases.

Conservative estimates of the radioactive material content for stored wastes should be

established, to the extent possible, based on standard survey and measurement requirements.

These estimates, combined with any contamination in the area, should be used as the basis for

estimating potential radioactive material releases in the event of a fire. Potential releases of

radioactive materials should be quantified by conservative analyses of the fire-related source term,

the capabilities of mitigating systems, and emergency response actions. Exposures resulting from

the fire-induced release of radioactive materials must not exceed the limits in 10 CFR Part 20.
1.191-27

Radioactive waste storage areas within existing plant structures should provide adequate

fire protection to minimize the potential for fire and the subsequent release of radioactive

materials. SSCs necessary to protect radioactive waste and mitigate any radiological release

should be evaluated and protected from the effects of fire, as appropriate. These SSCs include

structures that provide separation and confinement, building ventilation, instrumentation and

controls, and electrical power. Rated fire barriers should be maintained that separate significant

fire hazards, the waste storage and accumulation areas, and SSCs important to the safe storage of

the contaminated waste materials. Where adequate separation cannot be provided, the use and

storage of combustible materials should be minimized and controlled.

Temporary structures used for radioactive waste storage areas should be constructed with

noncombustible materials to the extent possible. Radioactive waste packaging should be

fabricated of noncombustible or fire-retardant materials. Activities and equipment that are a

potential ignition source should be prohibited or strictly controlled within waste storage areas.

Smoke detection and fire suppression capability should be provided for areas in which

radioactive waste materials will be accumulated or stored. Fire alarms and emergency lighting for

personnel evacuation should be provided. As a minimum, manual suppression capability,

including portable fire extinguishers, should be available. Confinement measures should be

provided to control potentially contaminated runoff from automatic or manual fire suppression,

including inadvertently actuated automatic systems. For temporary structures, automatic or

manual fire suppression or both should be provided according to the fire hazards and the need to

maintain adequate confinement to prevent or minimize the potential release of radioactive

materials. Automatic and manual fire suppression systems should provide adequate coverage

according to the fire hazards, evacuation routes, and fire attack strategies. Water supplies should

be sufficient to meet automatic (if applicable) and manual suppression system demands.

Administrative controls for housekeeping, transient combustibles, and hot work in

radioactive waste storage and accumulation areas should be established by procedures.

Noncombustible or fire-resistant materials should be used for packaging radioactive waste

materials. The work control procedures should ensure that decommissioning activities associated

with the removal and storage of radioactive waste, including packaging and shipment of

radioactive materials, are subject to appropriate fire protection reviews.

Procedures that describe necessary actions in response to a fire in the radioactive waste

storage and accumulation areas should be developed. For example, ventilation systems and any

other building openings such as access doors should be configured to confine and minimize the

potential for a release of radioactive materials to the environment. Consideration should be given

to the waste storage area layout and the availability of stand pipes (i.e., to avoid hose lays through

doors) to allow fire fighting activities and at the same time maintain adequate confinement.

Fire pre-plans should be developed for the radioactive waste storage and accumulation

areas. The pre-plans should identify the area layout, access and egress points, type and location of

suppression systems, radiological hazards, and SSCs important to the prevention or mitigation of

releases of radioactive material that should be protected from the effects of fires. Onsite fire

brigades and offsite responders should be adequately trained and drilled on the pre-plans and

general fire attack strategy for the radioactive waste storage and accumulation areas.
1.191-28

REGULATORY ANALYSIS

A separate regulatory analysis was not prepared for this regulatory guide. The regulatory

basis for this guide is the regulatory analysis prepared for the amendments to Parts 2, 50, and 51,

"Decommissioning of Nuclear Power Reactors," issued on July 29, 1996 (61 FR 39278), which

examines the costs and benefits of the rule as implemented by the guide. A copy of this regulatory

analysis is available for inspection and may be copied for a fee at the NRC's Public Document

Room at One White Flint North, 11555 Rockville Pike, Rockville, Maryland, telephone (301) 415-

4737; fax (301) 415-3548.