1. External Operations Experience Update: NRC Information Notices: Qualification of Safety-Related Components and Antifreeze Agents in Fire Water Sprinklers Department of Energy Operating Experience Work Group July 14, 2015 Larry Stirling, Office of Analysis (AU-23)

2. Two NRC Information Notices IN 2014-11, Recent Issues Related to the Qualification and Commercial Grade Dedication of Safety-Related Components IN 2015-02, Antifreeze Agents in Fire Water Sprinkler Systems 2

3. IN 2014-11, Recent Issues Related to the Qualification and Commercial Grade Dedication of Safety-Related Components Notices, not requirements- for consideration Applies to applicants for an operating license for a non-power reactor or nuclear power reactor, applicants for a fuel cycle facility license, a special nuclear materials license, or a gaseous diffusion plant certificate of compliance NRC recognizes that nonreactor facilities have Quality Assurance (QA) requirements that differ from nuclear power plants, but it encourages licensees and managers review the IN for awareness and consider its applicability to their facilities. 3

4. IN 2014-11, Recent Issues Related to the Qualification and Commercial Grade Dedication of Safety-Related Components Such facilities must establish measures to verify the adequacy of design by – performance reviews – calculation methods – or a suitable testing program 4

5. IN 2014-11, Recent Issues Related to the Qualification and Commercial Grade Dedication of Safety-Related Components Equipment important to safety must be qualified by – Testing an identical item of equipment under identical conditions, – Testing a similar item with a supporting analysis to show that the equipment to be qualified is acceptable, – Experience with identical or similar equipment under similar conditions with supporting analysis, – Analysis in combination with partial type test data. 5

6. Information Notice (IN) 2014-11, Recent Issues Related to the Qualification and Commercial Grade Dedication of Safety-Related Components Structures, systems, and components important to safety are required to be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, and hurricanes, without loss of capability to perform their safety functions The IN contains a comprehensive list of applicable industry standards 6

7. IN 2015-02, Antifreeze Agents in Fire Water Sprinkler Systems Existing research and testing performed by NFPA suggests that under certain conditions, antifreeze-water mixtures discharged from fire sprinklers can accelerate a fire when sprayed onto a flame. For nuclear power plants, non-power reactors, medical radioisotope production facilities, and fuel cycle facilities in areas where temperatures are routinely likely to go below freezing, licensees may have determined that antifreeze is necessary. 7

8. Information Notice 2015-02, Antifreeze Agents in Fire Water Sprinkler Systems In that case, annual maintenance and testing should be performed to determine the concentration of antifreeze present For areas where the new antifreeze concentration limits are not sufficient to prevent sprinklers’ freezing, the NFPA suggests pipe insulation, heating systems, or the use of dry-pipe or pre-action systems 8

9. Information Notice 2015-02, Antifreeze Agents in Fire Water Sprinkler Systems The intent of antifreeze sprinkler systems is to protect piping that passes through areas that could be exposed to freezing temperatures. This would include piping in heated warehouses, loading docks, and elevator shafts NRC-IN points out, although such sprinkler systems that use antifreeze agents may be present at some facilities, they would not typically be installed in safety-related areas. Issued the IN to heighten awareness that the issue may exist 9

10. Information Notice 2015-02, Antifreeze Agents in Fire Water Sprinkler Systems Concentrations of 70 per cent glycerin or 60 per cent propylene glycol in water may be ignited when discharged through sprinkler systems, resulting in a substantial fire event NFPA completed full-scale fire tests, it issued Tentative Interim Amendments (TIA) 10

11. Information Notice 2015-02, Antifreeze Agents in Fire Water Sprinkler Systems NFPA 13 and NFPA 25 that may be applicable include changes such as, “With limited exceptions, all new antifreeze systems (systems installed after September 30, 2012) are required to use listed antifreeze solution. The listing of the antifreeze solution must indicate that the solution will not ignite when discharged from a sprinkler.” 11

12. Information Notice 2015-02, Antifreeze Agents in Fire Water Sprinkler Systems Systems installed before September 30, 2012 will also be required to use only listed antifreeze solutions but have until September 2022 to come into compliance. Until then, solutions must be tested annually prior to the onset of freezing weather. After September 2022, facilities must either replace all traditional antifreeze solutions or use alternative freeze protection methods 12

13. Information Notice 2015-02, Antifreeze Agents in Fire Water Sprinkler Systems These industry and NRC requirements and guidelines are for information only and do not supersede requirements in DOE Orders or supplemental guidance in Guides and Standards. http://www.nrc.gov/reading-rm/doc-collections/gen- comm/info-notices/ http://www.nrc.gov/reading-rm/doc-collections/gen- comm/info-notices/ 13

14. References NRC Information Notice 2014-11, Recent Issues Related to the Qualification and Commercial Grade Dedication of Safety- Related Components NRC Information Notice 2015-02, Antifreeze Agents in Fire Water Sprinkler Systems 10 CFR 830, Subpart A, Quality Assurance 10 CFR 830, Subpart B, Safety Basis 14

15. References DOE Order 414.1D, Quality Assurance DOE Order 420.1C, Facility Safety DOE STD 1066-2012, Fire Protection DOE STD 1104-2014, Review and Approval of Nuclear Facility Safety Basis and Safety Design Basis Documents 15

16. References DOE STD 1137-2014, Fire Protection DOE STD 1189-2008, Integration of Safety into the Design Process Tentative Interim Amendments to NFPA Standard 13, Standard for the Installation of Sprinkler Systems, and Standard 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems 16

17. Contact Information: Larry Stirling Office of Analysis (AU-23) 202-586-2417 john.stirling@hq.doe.gov 17