IR 05000245/1987019

Insp Rept 50-245/87-19 on 870817-21.No Violations Noted. Major Areas Inspected:Licensee Effort to Comply W/App R Section Iii.G,J & O Re Fire Protection Features & Maint Safe Shutdown.Two Items Remained Unresolved

ML20235J727
Person / Time
Site:	Millstone
Issue date:	09/15/1987
From:	Anderson C, Pullani S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235J723	List: IR 05000245/1987019 ML20235J721
References
50-245-87-19, NUDOCS 8710020070
Download: ML20235J727 (13)

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e U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 87-19 Docket N License N DRP-21 Priority Category C Licensee: Docket No. 50-245 Facility Name: Millstone Nuclear Power Station, Unit 1  !

Inspection At: Waterford, Connecticut Inspection Conducted: August 17-21, 1987 Inspectors: /) ani -

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S. Pullani, [ ire ,P,rptiction Tr gineer / datfe Also participating and contributing to the report were:

, M. Villaran, Mechanical Systems Specialist, BNL K. Sullivan, Electr+ cal Systems Specialist, BNL D. Kubicki, Fire Protection Engineer, NRR .

Approved by: 9 C. J. #nderson, Chief date Plant Systems Section, DRS Inspection Summary: Inspection on August 17-21, 1987 (Report N /87-19).

l Areas Inspected: Special, announced team inspection of the licensee's efforts

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to comply with the requirements of 10 CFR 50, Appendix R, Sections III.G, J an 0, concerning fire protection features to ensure the ability to achieve and maintain safe shutdown in the event of a fir Results: No violations were identified. Two items remained unresolved at the end of inspection (see Section 7.4 for details).

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8710020070 PDP 870923 G ADOCK 05000245

PDR

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DETAILS 1. Persor,s Contacted .

1.1 Northeast Nuclear Energy Company (NNECo)'

• R. Asafayco, Quality Service Supervisor

• D. LeDue, Senior Station Technician J. Nowell, Millstone Unit 1 Shift Supervisor

• R. Palmieri, Millstone Unit 1 Operations Supervisor l G. Sauer, Millstone Unit 1 Engineer

• S. Scace, Millstone Unit 1 Station Superintendent

• J. Stetz, Millstone Unit 1 Superintendent l J. Suma, Millstone Unit 1 Engineer )

• G. Syuer, Electrical Engineer 1.2 Northeast Utilities Service Company (NUSCo)

• R. A Mrew, Project Manager, Generation Protection

• M. Ciccone, Licensing Representative

• G. Cornelius, Supervisor, Reactor Plant Systems

• R. Hallek, Electrical Engineer G. Jonnson, Director, Generation Engineering l l * W. Lepper, Engineer T. Patrizz, Fire Protection Engineer

• G. Pitman, Manager, General Electrical Engineering

• B. Pckora, Reactor Plant Systems Engineer

• J. degan, Supervisor, General Electrical Engineering W. Romberg, Vice President, Nuclear Operation K. Shipman, Senior Engineering Technician l 1.3 Impell Corporation (IC)

• P. Blomberg, Millstone Unit 1 Engineer L. Cerroni, Lead Senior Designer

• G. Kelliher, Station Engineering, Barney R. Sergi, Supervising Engineer 1.4 Nuclear Regulatory Commission (NRC)

G. Grant, Resident Inspector

• R. Raymond, Senior Resident Inspector l- * Denotes those present at the Exit Meeting l

l Purpose This inspection was to ascertain that the licensee is in conformance with 10 CFR 50, Appendix R, Sections III.G, J and 0, including exemptions approved by the Office of Nuclear Reactor Regulation (NRR).

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. Background 1

10 CFR 50.48 and 10 CFR 50, Appendix R became effective on February 17, i 198 Section III.G of Appendix R requires that fire protection be  !

l provided to ensure that one train of equipment necessary to achieve and l l

maintain safe shut-down remains available in the event of.a fire at any .

! location within a licensed operating facility. For hot shutdow )

l conditions, one train of the systems necessary must be free of fire damage i (III.L.1.a). For cold shutdown conditions, repair is allowed using

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i inplace procedures and materials available onsite, with the provision that cold shutdown be achievable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the initiating event (III.G.I.b).Section III.G.2 lists specific options to provide adequate protection for redundant trains of' equipmen If the protection required by Section III.G.2 is not provided or the systems of concern are subject to damage from. fire suppression activities, l Section III.G.3 of the rule requires that an alternate or dedicated i

shutdown capability be provided which is independent of the area of concern. Any alternate or dedicated system requires NRC review and approval prior to implementatio . Correspondence Correspondence between the licensee and the NRC concerning compliance with-Sections III.G. J and 0 was reviewed by the inspection team in preparation l for the site visit. Attachment I to this report is a listing of the I correspondence reviewe . Post-Fire Safe Shutdown Capability In the event of a fire concurrent with a loss of offsite power, three options are ;vailable to achieve safe shutdow Reactor shutdown is initiated by a manual scram of the control rods if an automatic scram has not already occurred.

Option 1 provides hot shutdown decay heat removal via overpressure relief and the isolation condenser system and cold shutdown using control rod-drive hydraulic system and the shutdown cooling system. Reactor makeup is

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provided by the control rod drive hydraulic system from the condensate storage tank. The isolation condenser is the primary means of achieving and maintaining hot shutdown. Makeup to the shell side of the isolation condenser is normally~ provided by the fire protection system. Makeup can also be supplied from the condensate storage tank via the condensate transfer cystem. Cold shutdown can be achieved within 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Option 2 achieves shutdown via the autcmatic depressurization system, the-low pressure coolant injection system and the containment cooling syste Option 3 utilizes the safety relief valves and the feedwater coolant j injection system.

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The above systems are normally controlled and monitored from the control roo In the event of a fire in the control room, alternate means of controlling and monitoring these systems are provided. The licensee has completed a plant modification to provide Unit 2 emergency AC power to the Unit 1 emergency buse A summary of dif ferent shutdown methods for the worst case fire in each l fire area is given in Section 3.5 of the licensee's Fire Hazard Analysis (FHA) entitled Millstone Unit 110 CFR 50 Appendix R compliance Review, October 1986 (see also Attachment 2 of this inspection report). Detailed i lists of equipment and instruments utilized for the post-fire safe '

shutdown are given in Sections 3.2 and 3.3 of the FHA. In addition, the operator actions to compensate for system / component degradation reruiting from a fire in different fire areas are listed in Section 3.6 of the FH ;

6. Inspection Methodology The inspection team examined the licensee's capabilities for separating and protecting equipment, cabling and associated circuits necessary to achieve and maintain lot and cold shutdown conditions. This inspection sampled selected fire areas which the licensee had identified as bein; in l compliance with Section II The inspection team examined the licensee's capability to achieve and  !

maintain hot shutdown and the capability to bring the plant to cold shutdown conditions in the event of a fire in various areas of the plan The examination included a review of selected drawings, safe shutdown i procedures and other documents. Drawings were reviewed to verify i electrical independent ? from the fire areas of concern. Procedures were I reviewed for general content and feasibilit The inspection team examined the licensee's fire protection features provided to maintain one train of equipment needed for safe shutdown free of fire damage. Included in the scope of this effort were fire area boundaries, including walls, floors and ceilings, 'and fire protection of I openings such as fire doors, fire dampers, and penetration seals. Also included were fire detectior, and suppression systems, manual fire fighting equipment and fire-rated cable wrap The inspection team also examined the licensee's compliance with Section III.J Emergency Lightin . Inspection of Protection Provided to Safe Shutdown Systems 7.1 Protection in Various Fire Areas The team reviewed the protection provided for selected safe shutdown systems and components in the following fire areas / zones for compliance with Appendix R,Section III.G.1, 2 and 3.

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l Turbine Building l Reactor Building l Gas Turbine Building Fire Pump House Condensate Pump House Screen House  ;

The team did not identify any unacceptable condition .P Safe Shutdown Procedures

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7. Procedure Review The team reviewed the following safe shutdown procedures:

ONP 525A, Degraded Fire in Control Room or Cable Vault, Revision 0,

ONP 5258, Degraded Fire in Turbine Building, Revision *

ONP 525C, Degraded Fire in Office Areas, Computer Room, and Chemistry Lab Areas, Revision 0,

ONP 5250, Degraded Fire in 1eacter B;ilding (Except Shutdown i Cooling Pump Room), Revision *

ONP 525E, Degraded Fire in Shutdown Cooling Pump Area, ;

Revision *

ONP 525F, Degraded Fire in Gas Turbine Building, Revision *

ONP 525G, Degraded Fire in Intake Structure, Revision *

ONP 525H, Degraded Fire ir, Condensate Transfer Pump House, Revision I i

The scope of this review was to ascertain that shutdown could be j attained in a safe and orderly manner, to determine the level of !

difficulty involved in operating equipment, and to verify that there '

was no dependence on repairs for achieving hot shutdow For the purpose of the review, a repair would include installing electrical or pneumatic jumpers, wires or fuses to perform an action required for hot shutdown. For cold shutdown, repair is allowed using in place procedures and materials available onsite with the provision the cold shutdown be achievable within 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> The tean: did not identify any unacceptable conditions. However, the licensee revised several procedures to incorporate the following suggested improvements identified during the review, Procedures ONP 525A, B and D were revised to interface the degraded fire procedures with the Emergency Plan Implementing Procedure EPIP 411 Procedure ONP 525A was revised to add a step omitted in a power restoration sequence in the procedure. Procedure ONP 5250 was revised to clarify l a note on page 2 referring to " multiple high impedance faults" by simplifying the term to " electrical faults." The revisions were initiated by the licensee prior to the inspection exit meetin _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ -

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7. Procedure Walk Through for ONP 525A, Revision 0 l A walk.through of procedure ONP 525A, Degraded Fire in the Control l or Cable Vault, Revision 0, was conducted on August 20, 1987 at 0900 i hours. The purpose of this exercise was to determine by simulation that alternate safe shutdown could be implemented in an orderly and timely fashion for a major control room or cable vault fire. The normal shift complement for Millstone Unit 1 consists of one Shift I Supervisor (SS), one Shift Supervisor Staff Assistant (SSSA), one Senior Control Operator (SCO), two Control Operators (COs), and three Plant Equipment Operators (PEOs). Four inspectors accompanied the SS in the switchgear area, the SCO in the reactor building, the Control l Room Panel 905 C0 in the reactor building, and the Balance of Plant C0 in the reactor building. The SSSA, who normally assists the SS, remained in the control room for this exercise to simulate'the inter-face with the Unit 2 control roo.n. The PE0s are normally assigned to fire brigade duty, so they were not required to participate in the walk through,

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The 'rocedure was initiated at 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> from the control room wita l the to11owing initial conditions:

Unit I at 100% power with systems lined up in normal full power configuratio Fire in Fire Zone A of Control Room of magnitude requiring evacuatio Loss of offsite power supply to Unit 1 .

No automatic actions of equipment in Fire 2.one A were given credit for No CRD pumps running No service water pumps running l

The operators were allowed to : ram the reactor from the control room and place the Appendix R isolation switches in the isolate position upon egress from the control room. The team paid particular atten-tion to the feasibility of each manual action, ease of access, emer-gency lighting along access paths, communication, and sequence of operatio The procedure walk through was halted during step 2.9.1.1 of the

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procedure, by which time the licensee had adequately demonstrated his capability to achieve simulated stable hot shutdown conditions,.

commence a stable controlled cooldown, and take steps to reenter the control room. The following items were identified by the inspection I

team:

' Radio communications with the operator at the LPCI heat exchanger in the southwest corner of the reactor building were inadequat Since this is not a permanent duty station, the licensee agreed to add a note to the procedure alerting the operator that radio communication may be difficult from the location. Voice communication or repositioning to a better reception area may be necessar _ -_ .

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. The key to warehouse 3 Appendix R storage area was located in a control room key locker. The SS had to reenter the control room with SCBA to obtain the key from the locker, but it was already signed out. The licensee later demonstrated that this would not be a problem because the shift supervisor keyring also contained the warehouse 3. key engraved with the combination of the .

i Appendix R storage area-loc ' The note preceding step 2.8.1 of the procedure could be taken to l imply that drywell cooling need not be initiated until the

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on-call personnel have arrived to supplement the on-shift cre The licensee initiated a revision .to the note to clarify the statement in questio l

, The fire water connection at the LPCI heat exchanger presently.

I is equipped for a 2 1/2" hose which must be obtained from

! warehouse 3. The licensee has provided a 1 1/2" hose adaptor at i the LPCI heat exchanger connection, so that the 1 1/2" fire hose at station 0-1-79 could be utilize ' Step 2.6.2 of the procedure directs the SS to secure the diesel generator if service water is unavailable. The diesel is ;

required to assure that 1-IC-1 and 1-IC-4 will not spuriously I close. Licensee initiated a procedure revision to add a note I to the proceoure cautioning the operator to assure that 1-IC-1- !

and 1-IC-4 are opened and isolated from their power supply prior i to securing the diesel cencrato .

All the items above were resolved by the licensee as described prior I to the exit meeting and were found acceptabl .3 Prot:ction for Associated Cicuits Appendix R,Section III.G, requires that protection be provided for associated circuits that could prevent operation or cause maloperation of redundant trains of systems necessary for safe shutdown. The circuits of concern are generally associated with safe shutdown circuits in one of three ways:

Common bus concern Spurious signals concern Common enclosure concern The associated circuits were evaluated by the team for common bus, spurious signals, and common enclosure concerns. Power, control, and instrumentation circuits were examined for potential problem .3.1 Common Bus Concern The common bus concern is fo md in circuits, either safety >

related or non-safety relateu, where there is a common power

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source with shutdown equipment and the power source is not :j electrically protected from the circuit of concer ]

The team examined, on.a sampling basis, 4160V, 480V, 120V AC and 125V DC bus protective relay co-ordination. .The team also examined, on a. sampling basis, the protection-for specific

. instrumentation, controls, and power circuits, including the coordination of fuses and circuit breakers. The licensee has been performing breaker / relay settings at approximately 18/36 month interval l No unacceptable conditions were identifie '

7.3.2 Spurious Signals Concern l l

The spurious signals concern is made up of 2 item False motor, control, and instrument indications can occur i such as those encountered during 1975 Browns Ferry fire, i These could be caused by fire initiated grounds, short or open circuits.

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Spurious operation of safety related or non-safety related components can occur that would adversely affect shutdown capability (e.g., RHR/RCS isolation valves).

The team examined, on a sampling basis, the following araas to-ascertain that no spurious signal concerns exist:

Currer t transformer secondaries l High/ low pressure interface '

General fire instigated spurious signals No unacceptable conditions were identifie .3.3 Common Enclosure Concern l

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The common enclosure concern is found when redundant circuits are routed together a raceway or enclosure and- they are no !

electrically protected or when fire can destroy both circuits due to inadequate fire barrier penetration A number of circuits, selected on a sampling basis, were examined for this concer No unacceptable conditions were identifie .4 General Fire Protection Features The team examined the general fire protection features in the plant provided to maintain one train of safe shutdwn equipment free of fire damage. Included in the scope of this effort were: fire area w_____-_- - _

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boundaries, including walls, floors and ceilings; fire protection of openings such as fire doors, fire dampers, and penetration seals; fire protection systems, and other fire protection features. Also included were fire detection and suppression. systems, manual fire fighting equipment and fire-rated cable wrap Deficient conditions were identified as follow )

1 NFPA Code Conformance .j i

In Generic Letter 86-10, the staff indicated that the National ]

Fire Protection association (NFPA) codes, referenced in NRC fire i protection guidelines, should be followed in the design.of fire protection system Deviations from these codes should be l identified by licensees in the Final Safety Analysis Report (FSAR) or Fire Hazard Analysis Report (FHAR).

During the inspection, the team. discovered the following )j conditions which deviate from the referenced code:

l The smoke detectors la a number of plant locations, including but not limited to: makeup system area (T-15A), i switchgear area (T-15E), turbine. lube oil room (T-2), and l the CR0 rebuild room (R-20), appear not to have been installed in accordance with the installation criteria of NFPA 7,2E in that number or spacing of detectors were not !

sufficient to assure complete coverage of the area;. The sprinkler system in the machine shop area (T-7) is obstructed by suspended ~ ceiling tiles (NFPA 13); Certain fire alarm system circuits, such as those from local control panels to the control room are not electrically supervised per NFPA 72D.

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The licensee had not previously identified these deviations in the FSAR or FHAR. However, these conditions do not adversely impact the systems necessary to achieve and maintain safe shutdown conditions following a fir The licensee has implemented a comprehensive NFPA code confor--

mance audit'at the plant. This effort is still underway. The-licensee has committed to provide the results of this audit to NRR, with planned corrective actions and implementation sche-dules, within 60 days of receipt of this report. Pending receipt of this submittal and evaluation by NRR, this issued is considered unresolved (50-245/87-19-01). Fire Barrier Penetration Seals In Appendix A to Branch Technical Position APCSB9.5-1, the staff stipulated that penetrations of fire barriers should be sealed ,

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with a fire resistant material with an equivalent fire rating to that of the barrier itsel The fire resistance rating of the seal'should be determined on the basis of a standard fire test conducted on a seal' assembly representative of in plant configuration The audit team observed several seal configurations, such a's those in the floor of the cable spreading room, which appear to i exceed the size limitations of.the sealant as stipulated in the i Underwriters Laboratories listin l i

The licensee has been conducting a comprehensive review of fire l barrier penetration seals in the plant. This effort is still l underwa The licensee has committed to provide the results of

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this review to NRR, with planned corrective action and implementation schedule, within 60 days of receipt of this j repor Pending receipt of this submittal and evaluation by j NRR, this issue is considered unresolved (50-245/87-19-2). ' Emergency !ghting 10 CFR 50, Appendix R, Section III.J, requires that emergency lighting units with at least an 8-hour battery power supply shall be provided in-all areas needed for operation of safe shutdown equipment and in access l and egress routes theret ;l

The team examined the plant emergency lighting system to ascertaia the '1 l licensee's compliance with the above requiremen The team did not identify any unacceptable condition l Oil Collection System for Reactor Coo' ant Pump 10 CFR 50, Appendix R, Section III.0, requires that the reactor coolant pump shall be equipped with an oil collection system if the containment is not inerted during normal operation. As the Millstone 1 containment is inerted during normal operations, the above requirement does not apply to this plan Therefore, no inspection was conducted in this are . Quality Assurance During the course of the inspection, the team reviewed several drawings, the fire hazard analysis, fire protection modification packages, procedures and other fire protection documents. The scope of review included verification of their technical adequacy, appropriate -reviews, design and procurement controls, and other Quality Assurance requirements for the licensee's fire protection progra The team did not identify any unacceptable condition .q

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.1 Unresolved Items ]

l Unresolved items are matters for which more information is required in 1 order to ascertain whether they are acceptable, violations, or deviation I Unresolved item identified during the inspection is discussed in - J Section . Exit Interview  ;

The inspection team met with the licensee representatives denoted in Paragraph 1, at the conclusion of the inspection on August 21, 1987. The .)

team leader summarized the scope and findings of the ir.spection at that .{

tim The team leader and the licensee discussed the contents of this inspection ;

( report to ascertain that it did not contain any proprietary informatio l The licensee agreed that the inspection report may be placed in the Public

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Document Room without prior licensee review for proprietary information (10 CFR 2.790).

.\t no time daring this inspection was written material provided to the l licensee by the team, i l

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t ATTACHMENT 1 List of Correspondence Reviewe .) ,

l July 16,1982 (A02497), W. G. Counsil to D. G. Eisenhut, Millstone Nuclear Power Station Unit No.1, Control Room, Fire Review supporting exception from 10 CFR 50, Appendix j

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i July 30,.1982 (A02608 and A02636), W. G. Counsil to R. A. Clark, Haddam  ;

Neck Plant, Millstone Nuclear Power Station Unit Nos. I and 2, l clarifications of~ Appendix R Review I April 15, 1983'(810757), W. G. Counsil to D. G. Eisenhut, Millstone-Nuclear Power Station Unit No.1, Control- Roo Fire Review supportin exemption from 10 CFR 50, Appendix J August 7,1985 (B11637), J. F. Opeka' to H. L. Thompson, Jr. , Millstone i'

Nuclear Power Station Unit Nos. 1 and 2, additional information regarding Appendix R, Exemption Requests, i

August 23,1985 (B11644), J. F. Opeka to H. L. Thompson, Jr. , Millstone Nuclear Power Station Unit No. 1, Appendix R Control Room, Exemption Reques November 6,1985 (L505-85-11-012), J. A. Zwolinski to J. F. Opeka, exemption from requirements of Appendix R to 10 CFR Part 50, Section III. ,

November 21,1985 (B11678), J. F. Opeka to H. L. Thompson, Jr., Millstone Nuclear Power Station Unit No. 1, Fire Protectio !

February 12, 1986, Summary of telephone conference, Millstone Unit No. 1, i Fire Protection Exemption Requests for January 27, 1986 (with attachments), between NRC staff and N ,

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-). EIL&ayM Mart Iniff a user Cass FIM Assa aarrestal stageAav e -

e f o re Area tot $betdusse leveet ory Cont rol ' Cold Sheldene , ,

e bes t r ept see = Method Nethod Retted . Ilects&tal Powei Caessets +

f-l Costrel Beam laes e Iselet see Ceedoneet Costrei and prive Py lloutdove Ceelses $yetse Deesel Generator sed / 1. Centrol tone tg he e.exeeted (lee Caed) (Uttlattag feeAetaes (Peuered by lectfeed) tremesed by D6esel et llett 2 to ML 4 2. Operate App B isolettae evttCb Lesal Costsel) af Avettable) . Beckf eed for 408 MIV & SWCU velvee 3. kbfeed see be ettlaasd as sa alternative to diesel generater 4. Drywell coettes can be provided 1 by esana of sostatsmeet apsey by .

' fire water Zeee 8 laslat ten Ceedesset Centrol Red Desee Pp theideve Coeltag Systee cett 2 te West i l< Coetret been to be evacosted '

illec Sectase) (Meeuel 44taeol (Powered by Beatfeed) Powered by ternfeed via Sectfeed (llet) 3. Secere paesel Get.esatee af ever*

statse bese . Attempt to reestablish heettog seters se prewest damage dsesel generator and . to egwipose masselly slage bseekers ). Drywell seeltag cae he proveiled by

. (Cold) (llet/ Cold) esame of eastmasseet sprey by = 1

. f are wate #eee C leolataea Ceedesser Castrel ted Oreve Pp bholdeve Ceeises Bretee be2tohti 1. Centre! he to be evsenated -

(neesel Actsee) (feuered by Sec4 feed) Pourt by berkleed vae hechised (Not); Gas ' , 2. Bactfeed see he ettlesed es se stei6ae seees (Powered Terbtee and Dassel alternative to see terbase by D6esel af Reestet- NeanssL!p Altgeed sed /or esase lasises) (Cold)

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3. Drywell coeleeg ese he provided by asses eP eestateneet sprey by f are wate Rune D laelatsoa Ceedesser Centrel God Dreve Pp Shutdows Ceelseg System Diesel Generator and T - 1. Castrel As to be eescosted (Messel Artnee) (Powered by Seckfeed) IPouesed by paesel af liest 2 to 418:11 8 2 Operate Apr B teetaties swatte Aves tat te n Ber k f eed , for 405, istlV & 3MCU eatsee 3. Sec6 deed sea be stilased em se -

saternetsee te dtesen. .

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' messe of contesseest sprey by -

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lestat see Coedeemer Castrel Red Desee Py Bautd sme Ce*4 ens Bretse West 2 Le Gest b ( Aceual Act nee) (powered by Backfeed) Powesed by Deenet af . 't., Operate ter.4DS, W!V.AyF S .eeelaties sed switch SWCll welwee eveelable er by 6an t- Sectfeed Diesel Aeestableen (Het/Cald) ' 2. Sectfeed ces.be stilised se sa deed ves stat ice buse Generator end Massally olderseteve te diese Allga $reatere (Coldt 3. Drywell teelleg des be provided , by seems of restatement aptay by l6se water y , ~

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f3 2 esse A N lestaties Coedesser Ceestet god Drive Pp shetouwe Cuelses 5ye.ee unit 2 to bt 1 If Se aere Gee Teresse to step seestos forts.se Sids latert (Messel Art see) (Peuered by Bestleed) (sepaare & Sartfeed) Set tleed feeduster pump Aree F-] .* (Supported by Iere Water) 2. *. rap Of f-Sat,e Power les fire 5-f eeh6 ese pffice Area mereel Shetdeve tareal itethod meree! Shutdeve Geo forbase end F4 Dsesel Geeerster Beatter Sids FWCl and $8ve FWCl f eelantes Ceedeneer (Rep- Diesel Generator sed ' 3. Secure Aas venees f *S test A estel Shuteews Coeling Gee forb&ee

Syases (tepears) 2. hennelly evolestedses salve 8-FW4C setpelata et pre b (351 fell speel taupported by f are beter) 3. Drywell seelaag ese be preveded by messe of sustainment sprey by beep fill erstes, or fire water syste % tese b tesistsee Ceedesser Centael and Orsve Py LPCl/sDC Deeest Generator, &as ten east oo Presedwe 1 serbsee .ed uset 2 se 1. LPCI/40s.operaales per Statses g Preced r sorste preesdes =

citP%ME ) bl 1 Bectfeed alternate mothed of achievseg told ebundow Gas forbase laelettee Ceedessee Castrel Red betve Pp htdeve Coolseg System Diesel Geoereter end F -4 I. FWCl will set be seetlebte due le llant 2 Le Well I loss of Gas Turbsse tact feed a

Sc reeneme ll laoletaea Coedeoeer teatrol Bed Drave PP shutdeus Coolseg systee see Terbsee and ceAt 2 1. secure all egetpeest regetraes f*f (supported by Stre keter) Le ht i Rockfeed Service tester, ftCCW, ftsCCir er BBCC . Gas ferties or bec4 feed will be olismed to remee Electrical Davistee $2 3. Drywell seeltag ese be preveded by aeses of eestsamenes sprey by Isre vetor

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Ceedessate Treaafes leetetase Ceedesser Normel Rethod Aereal Sheldews Gee Turblee aed Pump Bones g Diesel Generater

f are Pump Nieuse kernel Shendeve Noveel flethod borest sketdows Gas forbene eed 1. West 2 f ere Water ese be uts tased f4 (ney towire ht i fire Pump) Diesel Geeerster to Sepply feelettee Ceedesser Shell nake Up

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nadwsste Olds Weessa Shutdeve Nureal fletlied Normal Bhutdeve Gas Terbase and I-10 Danel Generator

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Drywell merest 56stdeve . Wernal nethod Noveel shotdeve Cas forbtoe end I. Drywell is toerted, therefere a Dsesel Gewrator f ase esenet scour