ML040160894

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Undated Input for St. Lucie Fire Protection Baseline Inspection on 03/10-14 and 24-28/2003
ML040160894
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 12/22/2003
From: Wiseman G
NRC/RGN-II/DRS/EB
To:
References
FOIA/PA-2003-0358, IR-03-002
Download: ML040160894 (12)


Text

FIRE71ROTECTION BASELINE INSPECTION ST. LUCIE POWER STATION INPUT FOR INSPECTION REPORT NO.: 50-335, 389/2003-02 INSPECTOR: Gerry Wiseman Sr. Reactor Inspector-Fire Protection Systems Engineering Branch, DRS INSPECTION DATES:

  • Week 1 of onsite inspection - March 10 - 14, 2003
  • Week 2 of onsite inspection - March 24 - 28, 2003 Type of Inspection: TRIENNIAL FIRE PROTECTION BASELINE INSPECTION: Fire Protection Features and Post-Fire Safe Shutdown Capability A. INSPECTION REPORT INPUT A. Inspector Identified Findings
  • Green. The Fire Hazards Analysis (FHA) for three Plant St. Lucie (PSL) Unit 2 fire areas/zones was inadequate. The PSL FHA failed to consider and evaluate the combustibility of 380 gallons of transformer silicone dielectric insulating fluid in each of six transformers installed in three Unit 2 fire zones as contributors to fire loading and effects on SSD capability as required by Fire Protection Program (FPP) commitments.

A non-cited violation of 10 CFR 50.48 and PSL Unit 2 Operating License Condition (OLC) 2.C.(20) was identified. The finding is greater than minor because it was associated with the uprotection against external factors" attribute and affected the objective of the initiating events cornerstone to limit the likelihood of those events that could upset plant stability and challenge critical safety functions relied upon for SSD from a fire. The previously unidentified six silicone oil-filled transformers represented an in an increase in the ignition frequency of the associated fire areas/zones. The finding was considered to have very low safety significance (Green) because It did not involve the impairment or degradation of NRC approved fire protection features and the overall SSD capabilities for the areas were evaluated by the licensee's SSA as adequate to ensure SSD capability. (Section 1R05.02)

  • TBD. Many local manual operator actions were used in place of the required physical protection of cables for equipment relied on for SSD during a fire, without obtaining NRC approval for these deviations from the approved fire protection program. This condition applied to all areas that were Inspected. This reliance on large numbers of local manual actions, in place of the required Page I of 12

physical protection of cables, could potentially result in an increased risk of loss of equipment that was relied upon for SSD from a fire.(Section I R05.XXXXX)

A violation of PSL Unit 2 (OLC) 2.C.(20) and the Fire Protection Program was identified. However, this finding is unresolved pending completion of a significance determination. The finding is greater than minor because it could potentially result in an increased risk of loss of equipment that was relied upon for SSD from a fire. (Section 1R05.XXXXX)

1. REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems and Barrier Integrity 1R05 FIRE PROTECTION

.02 Fire Protection of Safe Shutdown Capability

a. Insoection Scope For the selected fire areas, the team evaluated the frequency of fires or the potential for fires, the combustible fire load characteristics and potential fire severity, the separation of systems necessary to achieve safe shutdown (SSD), and the separation of electrical components and circuits located within the same fire area to ensure that at least one train of redundant safe shutdown systems is free of fire damage. The team also inspected the fire protection features to confirm they were installed in accordance with the codes of record to satisfy the applicable separation and design requirements of Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50), Appendix R,Section II.G, and Appendix A of Branch Technical Position (BTP) Auxiliary and Power Conversion Systems Branch (APCSB) 9.5-1. The team reviewed the following documents which establish the controls and practices to prevent fires and to control combustible fire loads and ignition sources to verify that the objectives established by the NRC-approved fire protection program (FPP) were satisfied:
  • Plant St. Lucie (PSL) Individual Plant Examination of External Events (IPEEE)
  • Administrative Procedure 1800022, Fire Protection Plan
  • Administrative Procedure 0010434, Plant Fire Protection Guidelines
  • Electrical Maintenance Procedure 52.01, Periodic Maintenance of 4160 Volt Switchgear The team toured the selected plant fire areas to observe whether the licensee had properly evaluated in-situ compartment fire loads and limited transient fire hazards in a manner consistent with the fire prevention and combustible hazards control procedures.

In addition, the team reviewed fire protection inspection reports, and corrective action Page 2 of 12

program Condition Reports (CRs) resulting from fire, smoke, sparks, arcing, and equipment overheating incidents for the years 2001-2002 to assess the effectiveness of the fire prevention program and to identify any maintenance or material condition problems related to fire incidents.

The team reviewed the fire brigade response procedures, training procedures, and drill program procedures. The team reviewed Fire Brigade Initial Training and Fire Brigade Continuing Training course materials to verify appropriate training was being conducted for the station firefighting personnel. In addition, the team evaluated fire brigade drill training report records for the operating shifts from August 2001- February 2003. The reviews were performed to determine whether fire brigade drills had been conducted in high fire risk plant areas and whether fire brigade personnel qualifications, drill response, and performance met the requirements of the licensee's approved fire protection program.

The team walked down the fire brigade staging and dress-out areas in the turbine buildings and fire brigade house to assess the condition of fire fighting and smoke control equipment. The team examined the fire brigade's personal protective equipment, self-contained breathing apparatus (SCBA), portable communications equipment, and various other fire brigade equipment to determine accessibility, material condition and operational readiness of equipment. Also, the availability of supplemental fire brigade SCBA breathing air tanks, and the capability for refill, was evaluated.

Additionally, the team observed whether emergency exit lighting was provided for personnel evacuation pathways to the outside exits as identified in the National Fire Protection Association (NFPA) 101, Life Safety Code and Occupational Safety and Health Administration (OSHA) Part 1910, Occupational Safety and Health Standards.

This review also included an examination of backup emergency lighting availability on pathways to and within the dress-out and staging areas to support fire brigade operations during a fire-induced power failure. The fire brigade self-contained breathing apparatuses were examined and assessed for adequacy.

Team members walked down the selected fire areas to compare the associated fire fighting pre-fire strategies and drawings with as-built plant conditions. This was done to verify that fire fighting pre-fire strategies and drawings were consistent with the fire protection features and potential fire conditions described in the .UFSAR Fire Protection Program Report. Also, the team performed a review of drawings and engineering calculations for fire suppression caused flooding associated with the floor and equipment drain systems for the Train "B" Switchgear Room, Electrical Equipment Supply Fan Room, and Train "B" Electrical Penetration Room. The review focused on ensuring that those actions required for SSD would not be inhibited by fire suppression activities or leakage from fire suppression systems.

The team reviewed design control procedures to verify that plant changes were adequately reviewed for the potential impact on the fire protection program, SSD equipment, and procedures as required by PSL Unit 2 Operating License Condition 2.C(20). Additionally, the team performed an independent technical review of the Page 3 of 12

licensee's plant change documentation completed in support of 2002 temporary modification, TSA 2-02-006-3, that placed two exhaust fans on a fire damper opening between the cable spreading room and the Train B switchgear room. This change implemented by the licensee was evaluated in order to verify that modification to the plant were performed consistent with plant design control procedures.

b. Findings Inadequate Fire Hazards Analysis

Introduction:

The team identified a Green non-cited violation (NCV) associated with failure to meet the fire protection program plan requirements contained in the 10 CFR 50.48 and PSL Unit 2 Operating License Condition (OLC) 2.C.(20). The team found that six silicone oil filled transformers installed in three Unit 2 fire zones [Fire Zone 37, Train A Switchgear Room, Fire Zone 34, Train B Switchgear Room B, and Fire Zone 47, Turbine Building Switchgear Room] were not evaluated in the Fire Hazards Analysis (FHA) as contributors to fire loading and effects on safe shutdown (SSD) capability as required by Fire Protection Program commitments.

Description:

At PSL the indoor medium voltage power transformers installed in Unit 1 are of the dry type. However, six of the indoor medium voltage power transformers in Unit 2 are cooled and insulated by a silicone-type fluid. The licensee provided to the team information from the transformer manufacturer that the transformer insulating fluid was Dow Corning (DC) 561, a dimethyl silicone insulating fluid. The team performed an independent technical review of the licensee's engineering calculations and maintenance documentation, transformer vendor technical information manual, insulating fluid manufacturer information, Underwriters Laboratory (UL) and Factory Mutual (FM) listing agencies' documentation, and Institute of Electrical and Electronics Engineers (IEEE) Standards. Documents reviewed are listed in the Attachment.

The DC 561 technical manual described the DC 561 fluid as a silicone liquid that will burn, but was less flammable than paraffin-type insulating oils. The technical manual also stated that the DC 561 fluid had a flash point of 324 DC, a total heat release rate (HRR) of 140 kw/m2 (per ASTM E 1354-90), and a fire point of 357 "C. In their Fire Hazard Analysis the licensee evaluated the adequacy of their fire area/zone and electrical raceway fire barrier system (ERFBS) enclosure barrier features based on the combustible hazard content and overall fire loading (analyzed fire duration) present within the associated area/zone. Based on the above, the team concluded that the transformer insulating fluid was a in-situ combustible liquid not accounted for nor evaluated in the PSL FHA. Additionally, the team noted that the licensee had conducted an UFSAR Combustible Loading Update evaluation in 1997. This evaluation was documented in PSL-ENG-SEMS-97-070, but failed to identify that the transformers in fire zone 37 contained combustible silicone insulating fluid. Also a PSL Triennal Fire Protection Audit (documented in QA audit Report QSL-FP-01-07) conducted in 2001, reviewed the FHA but did not identify any fire loading discrepancies.

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The team determined that the previously unidentified six silicone oil-filled transformers represented an in an increase in the ignition frequency of the associated fire areas/zones. Also, the additional in-situ combustible fire load and fire severity represented by the combustible transformer insulating fluid increased the likelihood of a sustained fire event from a catastrophic failure of an effected transformer that may upset plant stability and challenge critical safety functions during SSD operations.

The l-T-E Unit Substation Transformers Instruction Manual recommended that the dielectric insulating fluid be sampled annually and the dielectric strength of the fluid be tested to ensure that it is at 26 KV or better. The licensee determined that except for four tests conducted during the period 1990-1992, there were no records of the transformers' fluid being sampled and tested. This issue was entered into the corrective action program as CR 2003-0978 and will followed up by the PSL Resident inspector staff.

Analysis: The team determined that this finding was associated with the "protection against external factors" attribute and affected the objective of the initiating events cornerstone to limit the likelihood of those events that could upset plant stability and challenge critical safety functions relied upon for SSD from a fire, and is therefore greater than minor. The previously unidentified six silicone oil-filled transformers in Unit 2 represented an in an increase in the ignition frequency of the associated fire areas/zones. The finding was considered to have very low safety significance (Green) because it did not involve the impairment or degradation of NRC approved fire protection features and the overall SSD capabilities for the areas were evaluated by the licensee's SSA as adequate to ensure SSD capability. However, when assessed in combination with other findings identified in this report, the significance could be greater than very low significance.

Enforcement: 10 CFR 50.48 states, in part, "Each operating nuclear power plant must have a fire protection program that satisfies Criterion 3 of Appendix A to this part." PSL Unit 2 Operating License NPF-16, Condition 2.C.(4) specifies, in part, that the licensee implement and maintain in effect all provisions of the approved FPP as described in the UFSAR for the facility and as approved by the NRC letter dated July 17,1984, and subsequent supplements. The approved FPP is maintained and documented in the PSL UFSAR, Appendix 9.5A, Fire Protection Program Report.

The UFSAR, Fire Protection Program Report, states, in part, that the PSL Fire Protection Program described in the report implements the philosophy of defense-in-depth protection against fire hazards and effects of fire on safe shutdown equipment.

The PSL fire protection program is guided by plant fire hazard analyses and by credible fire postulations. It further stated that the Fire Hazard Analyses performed for St. Lucie Unit 2 considered potential fire hazards and their possible effect on safe shutdown capability.

PSL administrative fire protection procedure, 1800022, Section 8.3 states that the FHA for Unit 2 are individual studies of each plant's designs, potential fire hazards in the Page5of 12

plant, potential of those threats occurring and the effect of postulated fires on safe shutdown capability. Further, Section 8.7.1.A of this procedure states that in-situ combustible features are evaluated in the fire hazards analysis as contributors to fire loading in the respective fire zones.

Contrary to the above, the FHA for fire zones 34, 37 or 47 was not adequate and did not meet FPP commitments. Specifically, 380 gallons of in-situ combustible transformer silicone dielectric insulating fluid in each of six transformers located in Unit 2 was not considered nor evaluated in the FHA as contributors to fire loading and possible effects on SSD capability. This condition was contrary to the requirements of the PSL FPP as outlined in UFSAR, Section 9.5A, and therefore did not meet the requirements as set forth in 10 CFR 50.48 and PSL OLC 2.C.(20).

Because the failure to evaluate in-situ combustible transformer silicone dielectric insulating fluid as a contributor to fire loading in the FHA is of very low safety significance and has been entered into the corrective action program as CR 2003-0637, this violation is being treated as an NCV in accordance with Section VI.A.1 of the NRC's Enforcement Policy. This item is identified as NCV 50-389/03-02-OX, Failure to Evaluate In-situ Combustible Transformer Dielectric Insulating fluid as a Contributor to Fire Loading in the FHA.

.05 Emergency Communications

a. Inspection Scooe The team verified that adequate communication system equipment relied upon to coordinate the shutdown of the unit and fire brigade duties, including the site paging (PA), portable radio, and sound-powered phone systems was available consistent with the licensing basis. The team reviewed the licensee's communications features to assess whether they were properly evaluated in the licensee's SSA (protected from exposure fire damage) and properly integrated into the post-fire SSD procedures. The team walked down sections of the post-fire SSD procedures and checked if adequate communications equipment would be available to adequately support the safe shutdown process. The team also reviewed the periodic testing of the site fire alarm and PA systems; maintenance checklists for the sound-powered phone circuits and amplifiers; and inventory surveillance of post-fire SSD operator equipment to assess whether the maintenance/surveillance test program for the communications systems was sufficient to verify proper operation of the systems.
b. Findings No findings of significance were identified.

.06 Emergency Lighting

a. Inspection Scope Page 6of 12

Section IIU.J. of 10CFR50 Appendix R requires eight hour emergency lighting coverage in any area where manual operator actions are required during post-fire safe shutdown operations, including the ingress and egress routes. The team verified that emergency lighting requirements were evaluated in the licensee's SSA and properly integrated into the Appendix R safe shutdown procedures as described in UFSAR Appendix 9.5A, Section 3.7. During plant walk downs of selected areas where operators performed local manual actions defined in the post-fire SSD procedures, the team inspected area emergency lighting units (ELUs) for operability and checked the aiming of lamp heads to determine if adequate illumination was available to correctly and safely perform the actions required by the procedures. The team also inspected emergency lighting features along access and egress pathways used during SSD activities for adequacy and personnel safety. The team checked if the ELUs' battery power supplies were rated with at least an 8-hour capacity. In addition, the team reviewed the manufacturer's information and the licensee's licensee periodic maintenance tests to verify that the ELUs were properly designed and were being maintained in an operable manner.

b. Findings No findings of significance were identified.

.08 Fire Barriers and Fire Area/Zone/Room Penetration Seals

a. Inspection Scope The team walked down the selected fire zones/areas to evaluate the adequacy of the fire resistance of barrier enclosure walls, ceilings, floors, and cable protection. The team randomly selected several fire barrier features for detailed evaluation and inspection to verify proper installation and qualification. This evaluation included fire barrier penetration fire stop seals, fire doors, fire dampers, fire barrier partitions, and Thermo-Lag electrical raceway fire barrier system (ERFBS) enclosures to ensure that at least one train of SSD equipment would be maintained free of fire damage from a single fire.

The team observed the material condition and configuration of the selected fire barrier features and also reviewed construction details and supporting fire endurance tests for the installed fire barrier features. The team compared the observed fire barrier penetration seal and ERFBS configurations to the design drawings and tested configurations. The team also compared the penetration seal and ERFBS ratings with the ratings of the barriers in which they were installed.

The team reviewed licensing documentation, engineering evaluations of Generic Letter 86-10 fire barrier features, and NFPA code deviations to verify that the fire barrier installations met design requirements and license commitments. In addition, the team reviewed surveillance and maintenance procedures for selected fire barrier features to verify the fire barriers were being adequately maintained.

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b. Findings No findings of significance were identified.

.09 Fire Protection Systems. Features, and Equipment

a. Inspection Scope The team reviewed flow diagrams, electrical schematic diagrams, periodic test procedures, engineering technical evaluations for NFPA code deviations, operational valve lineup procedures, and cable routing data for the power and control circuits of the electric motor-driven fire pumps and the fire protection water supply system yard mains.

The review evaluated whether the common fire protection water delivery and supply components could be damaged or inhibited by fire-induced failures of electrical power supplies or control circuits and subsequent possible loss of fire water supply to the plant.

Additionally, team members walked down the fire protection water supply system piping and actuation valves for the selected fire areas to assess the adequacy of the system material condition, consistency of the as-built configuration with engineering drawings, and operability of the system in accordance with applicable administrative procedures and NFPA standards.

The team walked down accessible portions of the fire detection and alarm systems in the selected fire areas to evaluate the engineering design and operation of the installed configurations. The team also reviewed engineering drawings for fire detector spacing and locations in the four selected fire areas for consistency with the licensee's fire protection plan, engineering evaluations for NFPA code deviations, and the requirements in NFPA 72A and 72D.

The team also walked down the selected fire zones/areas with automatic sprinkler suppression systems installed to assure proper type, placement and spacing of the heads/nozzles and the lack of obstructions. The team examined vendor information, engineering evaluations for NFPA code deviations, and design calculations to verify that the required suppression system density for each protected area was available.

The team reviewed the adequacy of the design, installation and operation of the manual suppression standpipe and fire hose system for the selected fire areas. The team examined design flow calculations and evaluations to verify that the required fire hose water flow and sprinkler system density for each protected area were available. The team checked a sample of manual fire hose lengths to determine whether they would reach the SSD equipment. Additionally, the team observed placement of the fire hoses and extinguishers to assess consistency with the fire fighting pre-plan drawings.

b. Findings No findings of significance were identified.

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SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee personnel:

P. Barnes, Fire Protection Engineering Supervisor R. McDaniel, Fire Protection Supervisor V. Rubano, Engineering Design Manager J. Hoffman, Plant Engineering Manager K. Frehafer, Licensing Engineer LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-389/03-02-OX NCV Failure to Evaluate In-situ Combustible Transformer Dielectric Insulating fluid as a Contributor to Fire Loading in the FHA. (Section 1R05.02)

Closed 50-389/03-02-OX NCV Failure to Evaluate In-situ Combustible Transformer Dielectric Insulating fluid as a Contributor to Fire Loading in the FHA. (Section 1R05.02)

Discussed None ATTACHMENT

LIST OF DOCUMENTS REVIEWED Section 1R05: Fire Protection Procedures:

Administrative Procedure 0005729, Fire Protection Training, Qualification, and Requalification, Rev. 17 Administrative Procedure 0010239, Fire Protection System Impairment, Rev. 13B Administrative Procedure 0010434, Plant Fire Protection Guidelines, Rev. 37C Administrative Procedure 1800022, Fire Protection Plan, Rev. 35 Electrical Maintenance Procedure 50.10, Self-Contained Emergency Lighting Unit Maintenance and Inspection, Rev. 9 Electrical Maintenance Procedure 52.01, Periodic Maintenance of 4160 Volt Switchgear, Rev.

14 General Maintenance Procedure 2-M-0018F, Safety-Related Preventive Maintenance Program (Fire PM's), Rev. 25B Protection Services Guidelines, PSG-15.01, Monitoring Fire Protection System Failures, Rev. 0 Calculations and Evaluations:

PSL-FPER-00-004, Disposition of Unit 2 Fire Detection System Nonconformance, Rev. 1 PSL-BFSM-98-004, Hose Station Supply Piping (Standpipe) Hydraulic Analysis, Rev. 0 PSL-ENG-97-070, UFSAR Combustible Loading Update for Unit 2, Rev. 0 PSL-FPER-99-008, Two-sided Cable Tray Fire Stop Redesign, Rev. 1 PSL-FPER-99-01 1, Disposition of Unit 2 NFPA Code Nonconformance, Rev. 1 PSL-FPER-00-0126, Evaluation of Fire Barrier Rating for Barriers Containing Two-sided Fire Stops, Rev.0 Calculation to determine the capacity of diked areas surrounding Unit 2 transformers 2A5, 2B5 and 2B2, dated March 12, 2003 Evaluation to determine compliance with DC 561 Technical Manual "use restrictions" for Unit 2 transformers 2A5, 2B5 and 2B2, dated March 10, 2003 Drawings:

2988-G-275 series, 480 V. Switchgear One Line Wiring Diagrams, Rev. 4 2988-G-424, Reactor Auxiliary Building Fire Detectors and Emergency Lights, Rev 9 2988-G-890, Reactor Auxiliary Building Plumbing and Drainage, Plan, Rev 8 2988-G-891, Reactor Auxiliary Building Plumbing and Drainage Plan El. 43', Rev 10 2998-B-733, Unit 2 Fire Protection Penetration Schedule, Rev. 6 2998-G-785, Reactor Auxiliary Building Room and Door Schedule, Rev. 8 2998-G-882, HVAC Equipment Schedule and Details, Rev. 1 2998-16082, Air Balance Inc. SL-2121 List of Materials, 319 ALV & 319 ALH Fire Dampers, Rev. 0 8770-B-327, Control Wiring Diagrams for Fire Water Pumps, Rev. 14 ATTACHMENT

Applicable Codes and Standards:

IEEE Standard 100, Standard Dictionary of Electrical and Electronics Terms, Fourth Edition NFPA 13, Standard for the Installation of Sprinkler Systems, 1973 Edition.

NFPA 14, Standard for the Installation of Standpipe and Hose Systems, 1973 Edition.

NFPA 20, Standard for the Installation of Centrifugal Fire Pumps, 1972 Edition.

NFPA 72A, Standard on Local Protective Signaling Systems, 1972 Edition NFPA 72D, Standard for the Installation, Maintenance, and Use of Proprietary Protection Signaling Systems, 1973 Edition.

NFPA 80, Standard on Fire Doors and Windows, 1973 Edition.

NFPA 90A, Standard on Air Conditioning and Ventilating Systems, 1981 Edition NUREG-1552, Supplement 1, Fire Barrier Penetration Seals in Nuclear Power Plants, dated January 1999 Underwriters Laboratories, Fire Resistance Directory, January 1998 OSHA Standard 29 CFR 1910, Occupational Safety and Health Standards, Reports, Audits, and Self Assessments Reviewed:

Report QSL-FP-01-07, PSL Triennal FP Audit, dated 2001 Other Documents:

IPEEE Submittal for St. Lucie Units 1 and 2, Rev. 0, dated December 15, 1994 UFSAR, Appendix 9.5A, Fire Protection Program Report Administrative Procedure 0005729, Fire Protection Training , Qualification and Requlification, Rev. 17 Administrative Procedure 1800022, Fire Protection Plan, Rev. 35 Administrative Procedure 0010434, Plant Fire Protection Guidelines, Rev. 37C Electrical Maintenance Procedure 52.01, Periodic Maintenance of 4160 Volt Switchgear Fire Brigade Drill Training Reports for operating shifts for the period August 2001- February 2003 Pre-fire Strategy No. 4, A Switchgear Room, Fire Area A, Rev. 23 Pre-fire Strategy No. 6, Cable Spread Room, Fire Area B, Rev. 23 Pre-fire Strategy No. 7, B Switchgear Room, Fire Area C, Rev. 23 Pre-fire Strategy No. 8, Electrical Equipment Supply Fan Room, Fire Area C, Rev. 23 Pre-fire Strategy No. 25, Personnel Monitoring Area and Health Physics Area, Fire Area I, Rev.

23 Pre-fire Strategy No. 26, Electrical Penetration Room B, Fire Area I, Rev. 23 Pre-fire Strategy No. 57, Turbine Building, Fire Area QQ, Rev. 23 Letter from Ebasco, to Florida Power and Light, on the subject of U.L. Qualifiaction Test for Pullman Industries Internal Expansion Damper Assembly, dated April 16,1986 Underwriters Laboratories, Report File R4708, Fire Test of 3HR Curtain Type Fire Damper Utilizing an Alternate Method of Installation, Air Balance, Inc., dated December 5, 1984 Consumer Product Safety Commission (CPSC) Recall Alert, Invensys Building Systems Recall of Siebe Actuators in Building Fire/Smoke Dampers, dated October 2, 2002 TECHNICAL MANUALSIVENDOR INFORMATION Dow Corning 561 Silicone Transformer Liquid, Material Safety Data Sheet -01496247, ATTACHMENT

1/27/97 Dow Corning 561 Silicone Transformer Fluid Technical Manual,10-453-97, 1997 Data Sheet Issue C Duraspeed, Automatic Sprinklers, Grinnell Sprinkler Corporation Data Sheet Model F950, Upright and Pendent Sprinklers, Grinnell Sprinkler Corporation Data Sheet Model L-205-EB, Industrial Electrical Non-Shock Fog Nozzles, Elkhart Brass Manufacturing Co. Inc.

IB-PD-1 001, Gould Inc. l-T-E Unit Substation Transformers Instruction Manual S2000, Protecto-wire Fire Systems Fire System 2000 Fire Alarm Control Panel, Rev. 1998 Sheet 5-4/14-8, Factory Mutual Research Approval Guide-Transformer Fluids CR REPORTS. AUDITS. AND SELF ASSESSMENTS REVIEWED CR 98-0260, Evaluate Deviations from NFPA 72 Code CR 98-0405, Evaluate Deviations from NFPA 13-1975 Code CR 98-0563, Assess Currently Installed Fire Hose Nozzles in Both Units CR 01-2296, Assess Deviations from NFPA 72 Code addressed in QA Audit QSL-FP-01-07 CR 02-0396, Assess Qualifications of Thermo-Lag Walls at PSL ATTACHMENT