Text

FSAR Amendment 107, Fire Protection Report, Revision 30
	ML16180A429
Person / Time
Site:	Comanche Peak
Issue date:	02/01/2016
From:	; Luminant Generation Co
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML16042A346	List: ML16042A344; ML16180A424; ML16180A425; ML16180A426; ML16180A427; ML16180A428; ML16180A429; ML16180A430; ML16180A431; ML16180A432; ML16180A435; ML16180A436; ML16180A437; ML16180A438; ML16180A439; ML16180A440; ML16180A441; ML16180A442; ML16180A443; ML16180A444;
References
	txx-16006, CP-20160003
	Download: ML16180A429 (456)
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{{#Wiki_filter:COMANCHE PEAK NUCLEAR POWER PLANT FIRE PROTECTION REPORT UNIT 1 AND UNIT 2

CPNPP/FPR COMANCHE PEAK NUCLEAR POWER PLANT FIRE PROTECTION REPORT (FPR) EFFECTIVE LISTING FOR SECTIONS, TABLES, AND FIGURES BELOW IS A LEGEND FOR THE EFFECTIVE LISTING OF SECTIONS, TABLES, AND FIGURES: Original (Unit 1) Submitted September 22, 1987 Revision 1 (Unit 1) April 29, 1988 Revision 2 (Unit 1) July 19, 1989 Revision 3 (Unit 1) September 15, 1989 Revision 4 (Unit 1) February 15, 1991 Revision 5 (Unit 1) February 14, 1992 Revision 6 (Unit 1 and Unit 2) July 31, 1992 Revision 7 (Unit 1 and Unit 2) April 30, 1993 Revision 8 (Unit 1 and Unit 2) December 21, 1993 Revision 9 (Unit 1 and Unit 2) December 15, 1994 Revision 10 (Unit 1 and Unit 2) February 1, 1995 Revision 11 (Unit 1 and Unit 2) May 26, 1995 Revision 12 (Unit 1 and Unit 2) August 1, 1996 Revision 13 (Unit 1 and Unit 2) February 2, 1998 ERRATA (Unit 1 and Unit 2) AugustS, 1998 Revision 14 (Unit 1 and Unit 2) September 15, 1998 Revision 15 (Unit 1 and Unit 2) April 23, 1999 Revision 16 (Unit 2) October 27, 2000 Revision 17 (Unit 1 and Unit 2) January 31, 2001 Revision 18 (Unit 1 and Unit 2) September 25, 2001 Revision 19 (Unit 1 and Unit 2) January 31, 2002 Revision 20 (Unit 1 and Unit 2) August 1, 2002 Revision 21 (Unit 1) April 23, 2004 Revision 22 (Unit 1 and Unit 2) March 15, 2005 Revision 23 (Unit 2) April 22, 2005 Revision 24 (Unit 1 and Unit 2) December 15, 2005 Revision 25 (Unit 1 and Unit 2) January 31, 2006 Revision 26 (Unit 1 and Unit 2) August 28, 2007 Revision 27 (Unit 1 and Unit 2) December 20, 2007 Revision 28 (Unit 1 and Unit 2) January 27, 2011 Revision 29 (Unit 1 and Unit 2) December 12, 2011 Revision 30 (Unit 1 and Unit 2) February 1, 2016 CPNPP/FPR EL-1 Revision 30

CPNPP/FPR Section I Revision 30 Section II Revision 30 Section Ill Revision 30 Section IV Revision 29 Section V Revision 28 Appendix A Revision 28 Appendix B Revision 28 Appendix C Revision 30 Deviation 1a Revision 28 Deviation 1b Revision 28 Deviation 1b (2) Revision 28 Deviation 3a Revision 28 Deviation 3a (2) Revision 28 Deviation 3a-1 Revision 28 Deviation 3a-1 (2) Revision 28 Deviation 3b Revision 28 Deviation 3b (2) Revision 28 Deviation 3c Revision 28 Deviation 3c-1 Revision 28 Deviation 3d Revision 28 Deviation 3d (2) Revision 28 Deviation 3e Revision 28 Deviation 3e (2) Revision 28 Deviation 3g Revision 28 Deviation 3g (2) Revision 28 Deviation 3h Revision 28 Deviation 3ha (2) Revision 28 Deviation 3hb (2) Revision 28 Deviation 4a Revision 28 Deviation 4a (2) Revision 28 Deviation 4a-1 Revision 28 Deviation 4a-1 (2) Revision 28 Deviation 5a Revision 28 Deviation 8b Revision 28 Deviation 8c Revision 28 Deviation 8c (2) Revision 28 Deviation 10 Revision 28 Deviation 14 Revision 28 Deviation 2015-1 Revision 30 Deviation 2015-1 (2) Revision 30 Deviation 2015-2 Revision 30 Deviation 2015-2 (2) Revision 30 Deviation 2015-3 Revision 30 Technical Justification I Revision 28 Appendix D Revision 30 CPNPP/FPR EL-2 Revision 30

CPNPP/FPR EL-1 Revision 30 EL-2 Revision 30 EL-3 Revision 30 CPNPP/FPR EL-3 Revision 30

CPNPP/FPR COMANCHE PEAK NUCLEAR POWER PLANT UNIT 1 AND UNIT 2 FIRE PROTECTION REPORT REPORT INDEX SECTION SUBJECT I Introduction II Fire Hazards Analysis Report (FHAR) Ill Fire Safe Shutdown Analysis Report (FSSAR) IV Fire Protection Equipment/Systems Operational Administration v Appendices Revision 28

CPNPP/FPR COMANCHE PEAK NUCLEAR POWER PLANT FIRE PROTECTION REPORT SECTION I UNIT 1 AND UNIT 2 INTRODUCTION 1-1 Revision 30

CPNPP/FPR TABLE OF CONTENTS SECTION I SUBJECT

1.0 INTRODUCTION

3 1.1 General 3 1.1.1 Purpose 3 1.1.2 Report Organization 3 1.2 Definitions 4 2.0 REGULATORY REQUIREMENTS 14 2.1 Regulatory Requirements Applicable To CPNPP 14 2.1.1 General Design Criterion 3 14 2.1.2 10 CFR 50.48 14 2.2 Regulatory Guidance Applicable To CPNPP 14 2.2.1 Appendix A To BTP APCSB 9.5-1 14 2.2.2 Generic Letter 86-1 0 14 2.3 FSAR 14 2.4 Fire Protection Program 14 2.5 Summary 15 1-2 Revision 30

CPNPP/FPR

1.0 INTRODUCTION

1.1 GENERAL The overall Fire Protection Program for CPNPP is based upon an approach which considers preventing, detecting, and suppressing fires along with maintaining plant ability to perform fire safe shutdown functions. Fire hazards throughout the plant are evaluated in developing the Fire Hazards Analysis Report (Section II). The effects of postulated fires on the plant's ability to perform fire safe shutdown functions were examined in the Fire Safe Shutdown Analysis Report (Section Ill). 1.1.1 PURPOSE The purpose of the Fire Protection Report (FPR) is to conduct a comprehensive study of the fire protection features and fire safe shutdown capabilities for Comanche Peak Nuclear Power Plant, Units 1 and 2 in accordance with the guidelines outlined in Appendix A to Branch Technical Position (BTP)APCSB 9.5.1, "Guidelines for Fire Protection for Nuclear Power Plants" docketed prior to July 1, 1976: (referred to as Appendix A, henceforth) as augmented by a comparison matrix. The Fire Hazards and Fire Safe Shutdown Analyses were performed under the direction of qualified Fire Protection and Reactor Systems Engineers to: (1) Consider potential in-situ and transient fire hazards; (2) Determine the impact of fire in any location in the plant on the ability to safely shut down the reactor. (3) Specify measures for fire prevention, detection, suppression, containment, and an alternative shutdown capability as required for each fire area containing structures, systems, and components that are required for fire safe shutdown. 1.1.2 REPORT ORGANIZATION The Fire Protection Report (FPR) is organized into five parts, as summarized below: Section 1- INTRODUCTION This section consists of the definitions, fire protection guidelines, and methodology that are developed for the Fire Protection Program of CPNPP. Section II- FIRE HAZARDS ANALYSIS REPORT (FHAR) This section contains the fire hazards analysis of CPNPP which includes a description by building of the: plant design, Maximum Permissible Fire Load (MPFL), fire hazard classification, and fire protection and detection features. The 1-3 Revision 30

CPNPP/FPR impact of these factors on the fire safe shutdown equipment in the area and the overall effect on the plant's fire safe shutdown capability are also summarized. Section Ill- FIRE SAFE SHUTDOWN ANALYSIS REPORT (FSSAR) This section contains the fire safe shutdown assessment of CPNPP which includes a description of the design implementation and a list of the fire safe shutdown systems and components. Section IV- FIRE PROTECTION EQUIPMENT/SYSTEMS OPERATIONAL ADMINISTRATION This section contains the fire protection program administrative control requirements for the fire protection systems and equipment at CPNPP, which includes a description of the operability, testing and surveillance requirements. Section V- APPENDICES A) CPNPP Fire Protection Program Separation Criteria Comparison Table B) Fire Hazards Analysis Evaluations Matrix C) Deviations D) Fire Protection Report Figures 1.2 DEFINITIONS This subsection establishes the definitions of terms used for the Fire Protection Report of CPNPP. 1.2.1 ACTIVE FIRE PROTECTION FEATURE An active fire protection feature is defined as those fire protection systems (sprinkler, detection, halon, etc.) which detect a fire and/or suppress a fire by automatic actuation. 1.2.2 ACTIVE FIRE SAFE SHUTDOWN COMPONENTS Those components required to change their operating state or position from that for normal plant power operation to another for plant shutdown. 1.2.3 ACTUAL FIRE LOADING The actual fire loading for a Fire Area is the total combustible loading Btu/sq. ft.) of in-situ combustibles within the area rounded off to the nearest 100 Btu/sq. ft. This value is used in the supporting calculations to determine Fire Duration. 1-4 Revision 30

CPNPP/FPR 1.2.4 ALTERNATIVE (OR ALTERNATE) SHUTDOWN Alternative shutdown is defined as plant shutdown capability requiring the utilization of abnormal operation practices of rerouting power and/or control around or relocating it from the problem area, such as those conditions that result from: (1) evacuation of the Control Room following a damaging Control Room, Cable Spreading Room, or CR-HVAC Mechanical Equipment Room fire; (2) shutdown activities at alternative remote control system locations (e.g., Hot Shutdown Panel). 1.2.5 ALTERNATE SHUTDOWN AREA Plant areas requiring the utilization of alternate shutdown capability to achieve and maintain the fire safe shutdown goals of hot standby conditions. These areas include the Control Room, Cable Spreading Rooms, and Control Room HVAC Mechanical Equipment Room. 1.2.6 ASSOCIATED CIRCUITS (FIRE SAFE SHUTDOWN) Circuits which are not considered part of fire safe shutdown systems but whose fire-induced failure could prevent the proper performance of fire safe shutdown functions by the fire safe shutdown systems. Circuits can be associated by common power supply, common enclosure, or spurious operation. 1.2.7 ASSOCIATED CIRCUITS BY COMMON ENCLOSURE (1) Cables whose fire-induced failure could cause circuit faults in electrically unprotected cables such that secondary fires may occur in enclosures (raceways, panels etc.) outside the fire area of concern and thereby damage fire safe shutdown equipment or cables in the vicinity. (2) Cables that, by their burning, would allow fire to spread distances beyond the initial fire area and ultimately affect fire safe shutdown equipment or cables in another area. 1.2.8 ASSOCIATED CIRCUITS BY COMMON POWER SUPPLY Cables, whose fire-induced failure could cause the loss of a power source (power, control, or instrument bus), that are necessary to support fire safe shutdown. 1.2.9 ASSOCIATED CIRCUITS BY SPURIOUS OPERATION Those non-safe-shutdown circuits which could, by fire-induced failures, cause any equipment to maloperate in a way that defeats the function of safe shutdown systems or equipment. 1-5 Revision 30

CPNPP/FPR 1.2.10 ASSOCIATED CIRCUITS OF CONCERN In the event that an associated circuit (as defined in Section 1-1.2.6) is found to be detrimental to fire safe shutdown systems, it is then defined as a safe shutdown circuit and associated with the fire safe shutdown components it affects. 1.2.11 CABLE FAILURES Open circuits, short circuits, shorts to ground, and "hot shorts". (1) Short Circuit An individual conductor within a cable coming into electrical contact with another conductor within the same or another cable. (2) Short to Ground An individual conductor which comes in contact with a grounded conducting device, such as a cable tray or a conduit. (3) Hot Short An individual conductor within a cable shorting to another conductor which is energized, within the same or another cable, thus becoming an available source of outside power for the circuit being analyzed. (4) Open Circuit An individual conductor within a cable that loses electrical continuity. 1.2.12 COLD SHUTDOWN The plant condition in which the reactor is at zero power and borated, K-effective is less than 0.99, and the reactor coolant temperature is less than or equal to 200 degrees Fahrenheit. 1.2.13 COMPENSATORY MEASURE Action(s) implemented under the designated conditions stated in Section IV- 3.1 regarding fire protection equipment/systems which are not operable. 1.2.14 COMPONENT CATEGORY A fire safe shutdown component is classified into one of two categories. These categories are Active Safe Shutdown or Passive Safe Shutdown. The category determines the level of circuit analysis which is to be performed for each component. A component can exist in more than one category, depending on the fire safe shutdown stage. A component may also be assigned multiple categories when used in more than one system. 1-6 Revision 30

CPNPP/FPR 1.2.15 CONCENTRATED CABLE TRAY AREA A concentrated cable tray area is an area of cable trays which meets the following criteria: (1) Adjacent vertical tray runs with high cable densities, (2) Stacks of four (4) or more trays, or (3) Adjacent tray stacks with at least four (4) trays in one of the stacks. Each stack must be within five (5) feet and 30 degree angle from the other. 1.2.16 DESIGN BASIS FIRE A design basis fire is a fire postulated to occur in a fire area or fire zone assuming no manual, automatic, or other fire fighting action has been initiated. The fire burns at a rate modeling the standard time-temperature curve (ASTM E-119). 1.2.17 FIRE HARZARDS ANALYSIS (FHA) EVALUATION A FHA evaluation is an assessment of the impact of a single fire hazard on redundant components or systems used to provide fire safe shutdown functions for the plant. A Fire Hazards Analysis Evaluation is performed by a fire protection engineer and, if required, a systems engineer. The purpose of a Fire Hazards Analysis Evaluation is to demonstrate compliance with BTP APCSB 9.5-1 Appendix A 1.2.18 FIRE AREA The fire area is that section of a building or the plant that is separated from other areas of the plant by fire barriers with openings and penetrations protected by seals or closures having a fire resistance rating equal to the rating assigned to the barrier. The fire areas extend through more than one elevation where plant design requirements and low amounts of combustible material in a specific area allow. These areas are designated on FPR Figures (see Appendix D). 1.2.19 FIREBARRIERS Fire barriers are those components of construction (walls, floors, or protective covering) that are rated by approved laboratories or are constructed in accordance with the requirement stated by authorities having jurisdiction in hours of resistance to fire and are used to prevent spread of fire. 1.2.20 FIRE BREAK A fire break is a physical barrier that prevents fire propagation; that is, the spreading of fire from one component to another and/or direct exposure of a component to the heat and flames of a fire. 1-7 Revision 30

CPNPP/FPR 1.2.21 FIRE DURATION Fire duration is the approximate time (expressed in minutes), as determined and documented in the supporting calculations that the actual fire load will burn. The duration is based on the heat release that produces an exposure equivalent to the standard time-temperature curve (ASTM E-119). 1.2.21.1 FIRE LOAD CLASSIFICATION The fire load classifications listed below are based on conservative interpretation of the British Fire Loading Studies as described in the NFPA Handbook. These classifications are used in this Fire Protection Report to represent the relative potential fire severity of the in-situ combustible materials contained within the boundaries of a given fire area or fire zone. Low- Loading less than or equal to 80,000 Btu/sq.ft. which equates to a fire severity of less than or equal to 1 hour. Moderate- Loading greater than 80,000 Btu/sq.ft. but less than or equal to 160,000 Btu/sq.ft. which equates to a fire severity of greater than 1 hour but less than or equal to 2 hours. High - Loading greater than 160,000 Btu/sq.ft. but less than or equal to 240,000 Btu/sq.ft. which equates to a fire severity of greater than 2 hours but less than or equal to 3 hours.

        >High -        Loading greater than 240,000 Btu/sq.ft. which equates to a fire severity of greater than 3 hours.

1.2.22 FIRE RESISTANCE RATING The endurance period of a fire barrier which defines the period of resistance to a standard fire exposure before the occurrence of structural failure, passage of flame to the unexposed surface, or limiting temperatures of the unexposed surface as delineated on applicable fire test acceptance criteria. 1.2.23 FIRE SAFE SHUTDOWN The definition for fire safe shutdown used in this analysis assumed the plant to be in one of three states at any moment: hot standby, cold shutdown -or a transient condition when the unit is undergoing a change of mode from hot standby to cold shutdown. With a fire in any area of the plant, operations are performed to achieve the following fire safe shutdown performance goals: (1) reactor reactivity control; (2) reactor coolant inventory control; 1-8 Revision 30

CPNPP/FPR (3) reactor coolant pressure control; (4) decay heat removal; (5) process monitoring; and (6) support services. 1.2.24 FIRE SAFE SHUTDOWN CIRCUITS The electrical circuits including their associated circuits of concern that are related to fire safe shutdown equipment. 1.2.25 FIRE SAFE SHUTDOWN EQUIPMENT Equipment (i.e., primary components and support components) that is used to achieve and maintain fire safe shutdown. This is limited to mechanical and electrical equipment that could be prevented from performing its intended design function as a result of anticipated fire damage. As an example, this requires that MOVs, motors, and MCCs be included since fire could prevent these devices from performing as designed. An example of equipment associated with fire safe shutdown equipment but, as a rule, not included as fire safe shutdown equipment, would be heat exchangers, tanks, pipes, and manual (no operator other than a handwheel) valves. Neither of these examples is represented as being all inclusive, but presented rather to help clarify the overall selection criteria applied to fire safe shutdown equipment. See Section 111-4.0 for further details. 1.2.26 FIRE SAFE SHUTDOWN FUNCTIONS Fire safe shutdown functions are defined as those functions necessary to assure the performance goals required to achieve and maintain the fire safe shutdown condition. Combinations of redundant fire safe shutdown components, systems, and support systems are used as necessary to bring the plant to and maintain the plant in the hot standby mode, to cool the plant to the cold shutdown mode, and to maintain the plant in the cold shutdown mode. 1.2.27 FIRE SAFE SHUTDOWN SYSTEM A plant system or portions thereof that are used to achieve and maintain identified fire safe shutdown functions. 1.2.28 FIRE ZONE The fire zone is a subdivision or portion of a fire area that is designated on the FPR Figures (see Appendix D). Fire zone boundaries are shown on drawings M1-1920 through M1-1953 and M2-1920 through M2-1942. 1-9 Revision 30

CPNPP/FPR 1.2.29 FUNCTIONAL TEST A performance demonstration conducted to assure that fire protection equipment/ systems are in their proper working order including associated alarms, interlocks or trip functions of the system or device. 1.2.30 HIGH/LOW PRESSURE INTERFACE COMPONENTS Fire safe shutdown components which have the potential for causing uncontrolled or unrecoverable depressurization and/or loss of primary coolant. For CPNPP, the High/ Low Pressure Interface components are residual heat removal (RHR) suction valves, pressurizer power-operated relief valves (PORVs), and excess letdown isolation valves. 1.2.31 HOT SHUTDOWN The plant condition in which the reactor is at zero power, K-effective is less than 0.99, decay heat is removed via the SG relief valves and the reactor coolant temperature is less than 350 degrees Fahrenheit and greater than 200 degrees Fahrenheit. 1.2.32 HOT SHUTDOWN PANEL That portion of the Remote Shutdown Panel required to achieve and maintain hot standby conditions. The Remote Shutdown Panel (RSP) has controls for both hot and cold shutdown functions for Control Room evacuation events. The Fire Safe Shutdown Analysis uses the terms "HSP" and "RSP" in the same context, that is, as the location where Alternate Shutdown Control functions (those due solely to fires) are performed. 1.2.33 HOT STANDBY The plant condition in which the reactor is at zero power, K-effective is less than 0.99, the reactor coolant temperature is greater than or equal to 350 degrees Fahrenheit, and decay heat is removed via the SG relief valves. 1.2.34 IN-SITU COMBUSTIBLES Fixed combustible materials that are designed into the plant. This includes permanently located combustibles such as equipment, permanent storage, tables, chairs, shelves, exposed cable, etc. 1.2.35 ISOLATION DEVICE A device in an electrical circuit which prevents malfunctions in one section of the circuit from causing unacceptable effects in other sections of the circuit or other circuits. Acceptable isolation devices for power circuits are single isolation devices actuated by faults; for instrumentation circuits, acceptable isolation devices are those actuated by fault current (e.g., fuses or circuit breakers), or by relays, control switches, transducers, and isolation transformers. 1-10 Revision 30

CPNPP/FPR 1.2.36 LOCAL CONTROL Control activities at control stations other than the control room or the remote shutdown panel. 1.2.37 MANUAL OPERATION Human-powered, physical manipulation of an electrical or mechanical component. 1.2.38 MANUALLY ACTUATED PRE-ACTION SPRINKLER SYSTEM A system employing automatic sprinklers attached to a piping network containing low pressure supervisory nitrogen/air. For manual actuation, the system valve must be operated by a remote electrical or local mechanical actuation device. Water then flows into the sprinkler piping system and out any sprinklers opened by a fire. 1.2.39 MAXIMUM PERMISSIBLE FIRE LOAD The maximum permissible fire loading (MPFL) is the theoretical maximum fire loading which is expected to be contained within a fire area by the fire area boundaries without compromising fire safe shutdown capability. It is calculated by analyzing both the fire area boundaries and the features provided for protection of redundant safe shutdown equipment. Based on the most restrictive of these considerations, a maximum fire loading value (Btu/sq. ft.) is established for each plant area. The MPFL for each area is then classified as Low (allowable loading up to 80,000 Btu/sq.ft., for a fire severity of up to 1 hour.), Moderate (allowable loading up to 160,000 Btu/sq.ft., for a fire severity of up to 2 hours) or High (allowable loading up to 240,000 Btu/sq.ft., for a fire severity of up to 3 hours.). For example: If a fire area has boundaries which are capable of containing a 3 hour fire, but contains a 1 hour fire barrier for protection of redundant fire safe shutdown equipment, the MPFL for that area would be classified as Low (i.e., allowable loading up to 80,000 Btu/sq.ft.). 1.2.40 OPERABLE Fire protection equipment/systems are considered operable when they are capable of performing their specified function such as demonstrated by their respective functional test(s). 1.2.41 ONE HOUR FIRE RATED CABLE Electrical cabling which has been qualified to ASTM E-119 test criteria for a fire resistance rating of one hour. 1.2.42 PASSIVE FIRE PROTECTION FEATURES A passive fire protection feature is defined as those fire protection features (fire barriers, penetration seals, fire dampers, fire doors, radiant energy shields, spatial separation, etc.) which inhibit the propagation of the fire; in other words, no action is taken to suppress the fire. 1-11 Revision 30

CPNPP/FPR 1.2.43 PASSIVE FIRE SAFE SHUTDOWN COMPONENTS Fire safe shutdown components are those components whose normal operating position or state is identical to their required fire safe shutdown position or state, and for which the effects of fire damage could result in a change of position or state that is detrimental to fire safe shutdown. 1.2.44 PERFORMANCE GOALS A set of criteria which assure that the plant can achieve a hot standby condition, and subsequently can be cooled to and maintained in a cold shutdown condition. 1.2.45 POST-FIRE The time following the identification of a fire. 1.2.46 PRE-FIRE The time prior to the initiation of a fire (i.e., normal operating conditions). 1.2.47 PRIMARY FIRE SAFE SHUTDOWN COMPONENTS Fire safe shutdown components identified during the initial review of the plant systems, which represent the major mechanical components that are used to accomplish the fire safe shutdown functions. Examples of primary components are pumps and valves. 1.2.48 RACEWAY Any channel designed and used expressly for supporting or enclosing wires, cable or bus bars. Raceways consist primarily of, but are not restricted to, cable trays, conduit, and exposed paths. 1.2.49 RADIANT ENERGY SHIELD A shield designed to provide protection for redundant essential raceways or fire safe shutdown equipment against the radiant energy from an exposure fire. 1.2.50 RADIATION ZONE Radiation zone is the classification of an area based on the expected dose equivalent rate (mrem/hr) within that area. See FSAR Section 12.3 entitled "Radiation Protection Design Features" and FSAR Table 12.3-6. 1.2.51 REDUNDANT When used in the context of fire safe shutdown path, the word redundant is defined as those components and/or systems constituting a second fire safe shutdown path by which the plant can be safely shut down. 1-12 Revision 30

CPNPP/FPR 1.2.52 SPURIOUS OPERATION The maloperation of fire safe shutdown equipment caused by circuits energized or deenergized as a result of fire damage. Spurious operations include Maloperation of fire safe shutdown equipment due to control circuit interlocks between fire safe shutdown circuits and and other circuits. 1.2.53 SUPPORT COMPONENTS Equipment that is required to enable the primary fire safe shutdown components to operate. Examples of support components are relays, MCC compartments, switchgear, instruments, control room panels and the Hot Shutdown Panel. 1.2.54 TRAIN One of the redundant set of equipment capable of achieving at least one system function. 1.2.55 TRANSIENT COMBUSTIBLES Combustible materials not designed into the plant, but brought into the plant due to operation, maintenance, or plant modification activities. 1.2.56 TRANSITION TO COLD SHUTDOWN The plant conditions during the transient process of changing the plant state from hot standby to cold shutdown. 1.2.57 WATER SPRAY SYSTEMS These are special fixed pipe systems connected to a reliable source of fire protection water supply, and equipped with water spray nozzles for specific water discharge and distribution over the surfaces to be protected. The piping system is connected to the water supply through an automatically or manually actuated valve which initiates the flow of water. Water spray systems are subdivided into two categories based upon method of actuation; "Automatically Operated Water Spray" which is actuated by electrical signal from the fire detection system and "Manual Open Head Water Spray" which has water flow initiated by a manual actuation device. 1.2.58 WET-PIPE SYSTEM A system employing automatic sprinklers attached to a piping network containing pressurized water and connected to water supply so that water discharged immediately from sprinklers opened by a fire. At CPNPP, cable tray suppression is generally provided by closed water spray nozzles attached to wet-pipe sprinkler system piping. For the purposes of the FPR, these are considered part of the wet-pipe sprinkler system. 1-13 Revision 30

CPNPP/FPR 2.0 REGULATORY REQUIREMENTS 2.1 REGULATORY REQUIREMENTS APPLICABLE TO CPNPP 2.1.1 GENERAL DESIGN CRITERION 3 10 CFR Part 50, Appendix A, General Design Criterion 3 requires that: Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fire and explosions. 2.1.2 10 CFR 50.48 All nuclear power plants are required under 50.48(a) to have a fire protection plan as described in that section. In addition, CPNPP is required by 50.48(e) to complete fire protection modifications needed to satisfy General Design Criterion 3 according to the terms of the CPNPP license. 2.2 REGULATORY GUIDANCE APPLICABLE TO CPNPP 2.2.1 APPENDIX A TO BTP APCSB 9.5-1 Appendix A to the Branch Technical Position contains two sets of guidance, one set applicable to plants for which the construction permit was docketed prior to July 1, 1976, but not issued prior to August 23, 1976, the other set applicable to plants for which construction permits were issued prior to July 1, 1976, and operating plants. Because CPNPP's construction permits were issued in December of 1974, the latter set of guidance applies to CPNPP. 2.2.2 GENERIC LETTER 86-10 This generic letter, issued April 24, 1986, contains useful guidance on a number of fire protection technical and licensing topics. CPNPP has considered this guidance where applicable. 2.3 FSAR The CPNPP FSAR describes how CPNPP meets applicable regulatory requirements. The CPNPP fire protection program is set forth in Section 9.5.1. 2.4 FIRE PROTECTION PROGRAM The CPNPP Fire Protection Program provides administrative control, through CPNPP station procedures, for the fire protection systems and equipment associated with the fire safe shutdown and operation of the plant, to ensure that the fire protection systems and equipment are properly maintained and operational at all times. 1-14 Revision 30

CPNPP/FPR 2.5

SUMMARY

CPNPP is required to meet General Design Criterion 3 of 10 CFR Part 50, Appendix A, and sections (a) and (e) of 10 CFR 50.48. Appendix A to BTP APCSB 9.5-1 contains NRC staff guidance applicable to CPNPP. 1-15 Revision 30

CPNPP/FPR COMANCHE PEAK NUCLEAR POWER PLANT FIRE PROTECTION REPORT SECTION II UNIT 1 AND UNIT 2 FIRE HAZARDS ANALYSIS REPORT 11-1 Revision 30

CPNPP/FPR TABLE OF CONTENTS SECTION II SUBJECT PAGE

1.0 INTRODUCTION

6 2.0 DEFINITIONS 9 3.0 ASSUMPTIONS 9 4.0 METHOD OF ANALYSIS 10 5.0 FIRE HAZARDS ANALYSIS 14 5.1 UNIT 1 SAFEGUARDS BUILDING 14 5.1.1 FIRE AREA SA- RHR PUMP 14 5.1.2 FIRE AREA SB- MOTOR DRIVEN AFW PUMP/RHR PUMP 17 5.1.3 FIRE AREA SC- TURBINE DRIVEN AFW PUMP 21 5.1.4 FIRE AREA SO- ELECTRICAL EQUIPMENT ROOM/TRAIN A SWITCHGEAR 22 5.1.5 FIRE AREA SE- REMOTE SAFETY RELATED PANELS/TRAIN B SWITCHGEAR 24 5.1.6 FIRE AREA SF- EMERGENCY AIR-LOCK ACCESS 26 5.1.7 FIRE AREA SG- DIESEL GENERATOR 28 5.1.8 FIRE AREA SH- DIESEL DAY TANK ROOM 30 5.1.9 FIRE AREA Sl- DIESEL GENERATOR 32 5.1.10 FIRE AREA SJ- DIESEL DAY TANK ROOM 34 5.1.11 FIRE AREA SK- MAIN STEAM AND FEEDWATER PENETRATION AREA 36 5.1.12 FIRE AREA SM- STAIRWELL 38 5.1.13 FIRE AREA SN- STAIRWELL 39 5.1.14 FIRE AREA SO- STAIRWELL 40 5.2 AUXILIARY BUILDING 41 5.2.1 FIRE AREA AA- MISCELLANEOUS AREAS 41 11-2 Revision 30

CPNPP/FPR SECTION II SUBJECT PAGE 5.2.2 FIRE AREA AB- CENTRIFUGAL CHARGING PUMP 48 5.2.3 FIRE AREA AC- CENTRIFUGAL CHARGING PUMP 50 5.2.4 FIRE AREA AD- BORIC ACID STORAGE TANKS 52 5.2.5 FIRE AREA AE- CCW PUMP 54 5.2.6 FIRE AREA AF- CCW PUMP 55 5.3 ELECTRICAL AND CONTROL BUILDING 57 5.3.1 FIRE AREA EA- MECHANICAL ROOM 57 5.3.2 FIRE AREA EB- STAIRWELL 61 5.3.3 FIRE AREA EC- BATTERY ROOMS 62 5.3.4 FIRE AREA EH- BATTERY ROOMS 64 5.3.5 FIRE AREA EL- STAIRWAY 66 5.3.6 FIRE AREA EM- UNIT 2 CABLE SPREADING ROOM 67 5.3.7 FIRE AREA EN- UNIT 1 CABLE SPREADING ROOM 69 5.3.8 FIRE AREA EO- CONTROL ROOM 71 5.3.9 FIRE AREA EQ- UPS AC UNIT 74 5.3.10 FIRE AREA ER- UPS AC UNIT 75 5.3.11 FIRE AREA AA- CHILLER EQUIPMENT ROOM 76 5.4 TURBINE BUILDING 78 5.4.1 FIRE AREA TB 78 5.5 FUEL BUILDING 87 5.5.1 FIRE AREAAA 87 5.6 SERVICE WATER INTAKE STRUCTURE 90 5.6.1 FIRE AREA WA- DIESEL FIRE PUMP ROOM 90 5.6.2 FIRE AREA WB- SERVICE WATER PUMPS 92 11-3 Revision 30

CPNPP/FPR SECTION II SUBJECT PAGE 5.7 UNIT 1 CONTAINMENT BUILDING 94 5.7.1 FIREAREACA 94 5.8 YARD AREA 96 5.8.1 YARD FIRE AREA 96 5.9 UNIT 2 SAFEGUARDS BUILDING 100 5.9.1 FIRE AREA 2SA- RHR PUMP 100 5.9.2 FIRE AREA 2SB- MOTOR DRIVEN AFW PUMP/RHR PUMP 103 5.9.3 FIRE AREA 2SC- TURBINE DRIVEN AFW PUMP 107 5.9.4 FIRE AREA 2SD- ELECTRICAL EQUIPMENT ROOM/TRAIN A SWITCHGEAR 109 5.9.5 FIRE AREA 2SE- REMOTE SAFEY RELATED PANELS/TRAIN B SWITCHGEAR 111 5.9.6 FIRE AREA 2SF- EMERGENCY AIR-LOCK ACCESS 113 5.9.7 FIRE AREA 2SG- DIESEL GENERATOR 115 5.9.8 FIRE AREA 2SH- DIESEL DAY TANK ROOM 117 5.9.9 FIRE AREA 2SI- DIESEL GENERATOR 119 5.9.10 FIRE AREA 2SJ- DIESEL DAY TANK ROOM 121 5.9.11 FIRE AREA 2SK- MAIN STEAM AND FEEDWATER PENETRATION AREA 123 5.9.12 FIRE AREA 2SL- HIGH PRESSURE CHEMICAL FEED ROOM 125 5.9.13 FIRE AREA 2SM- STAIRWELL 127 5.9.14 FIRE AREA 2SN- STAIRWELL 128 5.9.15 FIRE AREA 2SO- STAIRWELL 129 5.10 UNIT 2 CONTAINMENT BUILDING 131 5.10.1 FIRE AREA 2CA 131 5.11 FIRE PROTECTION PUMP HOUSE 134 11-4 Revision 30

CPNPP/FPR SECTION II SUBJECT PAGE 5.11.1 FIRE AREA FP 134 6.0 FIRE PROTECTION FEATURES 136 7.0 CODES AND STANDARDS 150

8.0 REFERENCES

151 11-5 Revision 30

CPNPP/FPR

1.0 INTRODUCTION

1.1 PURPOSE OF THE FIRE HAZARDS ANALYSIS REPORT The Fire Protection Program at Comanche Peak Nuclear Power Plant (CPNPP) establishes the fire protection policy for the protection of structures, systems, and components important to safety; and the procedures, equipment and personnel required to implement the program. The Fire Protection Program extends the concept of defense-in-depth to fire protection in fire areas important to safety with the following objectives: To prevent fires from starting; To detect rapidly, control, and extinguish promptly those fires that do occur; To provide protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by the fire suppression activities will not prevent the fire safe shutdown of the plant. To satisfy, in part, the objectives listed above, a FHAR was generated. The FHAR was generated by qualified fire protection and systems engineers and:

1. Considered potential in-situ and transient fire hazards; and

2. Determined the impact of a fire in any location in the plant on the ability to safely shut down the reactors and on the ability to minimize and control the release of radioactive matter to the environment; and

3. Specified measures for fire prevention, fire detection, fire suppression, fire containment and alternative shutdown capability for each fire area containing structures, systems, and components important to safety.

1.2 CONTENT OF THE FIRE HAZARDS ANALYSIS REPORT The content of the FHAR follows the US Nuclear Regulatory Commission's "Supplementary Guidance on Information Needed for Fire Protection Program Evaluation" and Enclosure 2 of the NRC letter dated September 30, 1976. The following is a description of each section and subsection of the FHAR. 1.2.1 SECTION 2.0- DEFINITIONS All terms unique to the FHAR which are not included in Section I of, Branch Technical Position APCSB 9.5-1, "Guidelines For Fire Protection for Nuclear Power Plants", dated 5/1/76, are included in Section 2.0. 1.2.2 SECTION 3.0- ASSUMPTIONS Section 3.0 includes those assumptions made when generating the FHAR. Detailed assumptions made during the performance of each of the supporting calculations and 11-6 Revision 30

CPNPP/FPR analyses are included in those calculations and analyses and are not restated in this report. 1.2.3 SECTION 4.0- METHOD OF ANALYSIS Section 4.0 describes the method by which the FHAR was performed. The methodology for each of the supporting calculations and analyses is included in those calculations and analyses and is not restated in this report. 1.2.4 SECTION 5.0- FIRE HAZARDS ANALYSIS Section 5.0 contains the fire hazards analysis for each fire area within Unit 1, Unit 2 and the common buildings which contain equipment and components necessary to fulfill fire safe shutdown functions of the Unit 1 and/or Unit 2 reactor. The section is organized by building. Each fire hazards analysis includes the following information: Location -A description of the building and floor elevations where the fire area is located, a list of fire zones in the fire area and a list of FPR Figures on which the fire area is shown. Construction - A description of the fire resistance rating of the fire area boundary enclosing the fire area and the fire resistance rating of penetration seals, fire dampers and fire doors within the fire area boundary. A description of fire barriers with less than a three hour fire rating for fire area boundaries and two hours for stairwells; or penetration seals, or fire doors with fire ratings less than that of the barrier in which they are installed; or any non-rated fire barrier configurations. References to any deviations and rated barrier analysis which justifies the lack of a three hour rated fire barrier. CPNPP is a Branch Technical Position (BTP), Auxiliary and Power Conversion Systems Branch (APCSB), 9.5-1 licensed plant. The aforementioned Appendix states that "[D]oor openings should be protected with equivalent rated doors, frames and hardware that have been tested and approved by a nationally recognized laboratory." It is common for a fire door and its assemblies such as louvers, glazing, etc., to have a fire protection rating lower than the wall in which it is installed (Refer to NFPA-252 App B, B-4.4). For example, a 1.5 hour fire protection-rated door can be required in a wall having a fire resistance rating of 2 hours. This is justified in part by the fact that, under normal conditions of use, the potential fire exposure in the vicinity of a door opening is decreased since there will usually be a clear space (egress) on both sides of the opening for traffic purposes. Equivalent fire rated doors are defined by guidance criteria found in model building codes such as NFPA Fire Protection Handbook, Uniform Building Code, NFPA-252 App B, B-4.4. At CPNPP for three hour barriers dividing fire areas, three hour doors are used. For two hour fire barriers, One and one-half (1.5) hour fire rated doors are used. For one hour barriers, three-quarter (3/4) or one hour fire rated doors are used. Potentially Failed Fire Safe Shutdown Equipment- A list of any potentially failed fire safe shutdown equipment located within the fire area. This section of each fire area text refers to Section 111-5.0 for actual listing of equipment. For fire safe shutdown equipment, 11-7 Revision 30

CPNPP/FPR components and cabling, Appendix A identifies those areas having either no equipment or no redundant equipment, components and cabling. Cables required for fire safe shutdown are discussed in Section 111-4.2.2.1. Fire Protection Features for Fire Safe Shutdown -A description of fire protection features installed within or adjacent to the fire area to meet the criteria of Section 11-4.5. Reference to any deviations submitted to the NRC and any supporting Fire Hazards Analysis Evaluations for Fire Protection features are included. In addition, the consequences of the design basis fire and the potential for the release of radioactive products of combustion to the environment are discussed. Combustible Loading - Summary information for the fire area and/or each fire zone within the fire area: Maximum Permissible Fire Load (BTU/Sq. Ft.)- Fire Load Classification (Low, Moderate, High, > High)- MPFL Classification (Low, Moderate, High)- Area (Sq. Ft.)- 1.2.5 SECTION 6.0- FIRE PROTECTION FEATURES Section 6.0 contains the fire protection features section including descriptions of the following: Passive Fire Protection Features- A general description of the passive fire protection features (fire area boundaries, fire barrier penetration seals, one hour fire barriers, one hour fire rated cable, structural steel fire protection, and interior finish) is provided in this subsection. Active Fire Protection Features- A general description of the active fire protection features (fire suppression and fire detection) is provided in this subsection. Manual Fire Protection Features -A general description of the manual fire protection features (fire hose stations, manual suppression systems, and portable fire extinguishers), is provided in this subsection. Reactor Coolant Pump Lube Oil Collection System -A general description of the lube oil collection systems for each reactor coolant pump is provided in this subsection. Emergency Lighting -A description of the emergency lighting system provided to illuminate access/egress paths and the equipment for performing the manual actions needed for fire safe shutdown is provided in this subsection. Communications- The types of communication provided for plant operators to communicate during the fire safe shutdown procedures are described in this subsection. 11-8 Revision 30

CPNPP/FPR NFPA Code Compliance Deviations- A listing, description and justifications for deviations to NFPA Standards. 1.2.6 SECTION 7.0- CODES AND INDUSTRY STANDARDS Section 7.0 includes a list of the applicable codes and industry standards, which CPNPP has committed to comply with or which are to be used as reference. 1.2.7 SECTION 8.0- REFERENCES Documents providing technical input to the FHAR are listed in section 8.0. 2.0 DEFINITIONS See Section 1-1.2 for a list of definitions. 3.0 ASSUMPTIONS Detailed assumptions for each of the tasks and subtasks completed as input for this revision of the FHAR are contained in the supporting calculations and analyses. The assumptions listed below are those made in this revision of the FHAR. 3.1 If the fire protection features (1 hour fire barrier, one hour fire rated cable, 20 foot separation, fire suppression, and fire detection) identified in Section 11-4.5 are provided or a NRC approved deviation applies to the area, it is assumed that the Design Basis Fire has no impact on the ability to safely shut down either Unit. 3.2 The Maximum Permissible Fire Loading (MPFL) for a fire zone assumes a fire burning in the area which follows the characteristics of the Standard Time-Temperature Curve (ASTM E-119) except noted isolated cases where different burning curves (Fire Protection Handbook, 16th Ed.) were used based upon the burning characteristics of combustibles in the fire zone. 3.3 If any of the passive or active fire protection features which MPFL credits are inoperable and the compensatory actions identified in Section IV are implemented, then an equivalent level of protection has been provided. 3.4 The fire protection systems (sprinklers, detection, and hose stations) credited in this analysis are operable or appropriate compensatory actions have been established per Section IV which provide an equivalent level of protection. 3.5 If a fire area does not contain potentially contaminated equipment, materials, trash, etc., it is assumed that fire contained within this area will not cause a release of radioactive products of combustion to the environment. 3.6 Two hour fire resistance for stairwell boundaries satisfy the intent of Section 11-4.5 for fire area boundary separation. Where a stairwell separates two fire areas with redundant sets of fire safe shutdown equipment, a fire would have to breach two, two hour barriers to reach the redundant counterpart. 11-9 Revision 30

CPNPP/FPR 3.7 Separation criteria for cabling is addressed through the Fire Safe Shutdown Analysis and separation concerns are identified in Section Ill of this FPR. 4.0 METHOD OF ANALYSIS The following methods of analysis have been formulated and applied for each fire area containing fire safe shutdown equipment and components for the Unit 1 or Unit 2 reactor. 4.1 GENERAL The plant is divided into separate fire areas using plant walls and floors as barriers. Due consideration is given to the separation of major redundant safety related components from each other, from non-safety related components, and from large concentration of combustible materials. Consideration is also given to other area characteristics such as electrical cable routing into and through the area, ductwork supplying and exhausting the area, ingress and egress routes for the area, and vent areas for depressurization during a tornado or high energy line break. 4.2 LOCATION The location of each fire area is shown in the FPR Figures (see Appendix D). 4.3 CONSTRUCTION The fire resistance rating of the fire barriers enclosing each fire area was determined by performing a comparison of barrier construction to recognized barrier construction standards; Uniform Building Code, Underwriters Laboratory, etc. In addition, the fire resistance rating of each fire barrier penetration (fire dampers, fire doors, penetration seals) was reviewed to ensure the configuration provided an adequate fire resistance rating for the barrier in which it was installed. Where the portion of a Fire Area Boundary or penetration in the Fire Area Boundary was not rated, an FHA evaluation was performed which justified the non-rated configuration or established an equivalent level of protection. 4.4 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT The list of fire safe shutdown equipment within each fire area was determined by reviewing the CPNPP Fire Safe Shutdown Analysis. The Fire Safe Shutdown Analysis established the minimum set of equipment necessary to fulfill plant fire safe shutdown functions which must be protected from fire damage in accordance with Section 11-4.5. This actual list by Fire Area and zone is referenced in Section 111-5.0. For fire safe shutdown equipment, components and cabling, Appendix A identifies those areas having either no equipment or no redundant equipment, components and cabling. Cables required for fire safe shutdown are discussed in Section 111-4.2.2.1. 11-10 Revision 30

CPNPP/FPR 4.5 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN A detailed review of the suppression systems, detection systems, one hour barriers, radiant energy shields, manual suppression and spatial separation was performed in order to ensure that fire safe shutdown equipment is protected from fire damage. The following design basis fire protection features were used for protecting fire safe shutdown equipment and components. This clarifies the implementation of Sections D.1.j and D.1.a(2) of Appendix A to BTP APCSB 9.5-1. Fire protection of fire safe shutdown capability:

1. Fire protection features are provided for structures, systems and components important to fire safe shutdown. These features are capable of limiting fire damage so that:

a. One set of systems necessary to achieve and maintain hot standby conditions from either the control room or emergency control station(s) is free of fire damage; and

b. Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station(s) can be repaired within 72 hours.

2. Except as provided for in Item 3 of this section, where cables or equipment of redundant sets of systems necessary to achieve and maintain hot standby conditions are located within the same fire area outside of primary containment, at least one of the following means of ensuring that one of the redundant sets of systems needed is free of fire damage is provided:

a. Separation of cables and equipment and associated non-safety circuits of redundant sets of systems by a fire barrier having a 3 hour rating.

Structural steel forming a part of or supporting such fire barriers are protected to provide fire resistance equivalent to that of the barrier;

b. Separation of cables and equipment and associated non-safety circuits of components of redundant sets of systems by a horizontal distance of more than 20 feet with negligible intervening combustibles. In addition, fire detectors and automatic fire suppression systems adequate for the hazard in the fire area are installed in the fire area; or

c. Enclosure of cables (if not one hour fire rated cables) and equipment and associated non-safety circuits of components of redundant sets of systems in a fire barrier having a 1 hour rating. In addition, fire detectors and automatic fire suppressions systems adequate for hazards in the fire area are installed.

Inside containment one of the fire protection means specified above or one of the following fire protection means are provided: 11-11 Revision 30

CPNPP/FPR

d. Separation of cables and equipment and associated non-safety circuits of components of redundant sets of systems by a horizontal distance of more than 20 feet with negligible intervening combustibles.

e. Installation of fire detectors and automatic fire suppression systems adequate for the hazard in the fire area or

f. Separation of cables and equipment and associated non-safety circuits of components of redundant sets of systems by a noncombustible radiant energy shield.

3. Alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room or zone under consideration, are provided:

a. Where the protection of systems whose function is necessary for hot standby does not satisfy the criteria of above or

b. Where redundant Fire Safe Shutdown systems necessary for hot standby located in the same fire area may be subject to damage from fire suppression activities or from the inadvertent operation of fire suppression systems.

In addition, fire detection and fixed fire suppression adequate for the hazards are provided in the area, room, or zone under consideration for alternative or dedicated shutdown. In order to meet the criteria of section (11-4.5), it was determined whether or not the fire protection features listed above were provided for each fire area. Each fire suppression and detection system was reviewed to establish coverage. Each fire area, where one hour barriers, one hour fire rated cable, or spatial separation was credited for protection of fire safe shutdown components, was reviewed to meet the criteria of Section 11-4.5. For each fire area where the criteria was not met or it was not obvious that the criteria was met, a review of existing deviations was completed to determine if a deviation existed which justified the nonconforming item. For plant fire areas where the existing plant configuration and/or fire protection features are not obviously provided and a deviation did not exist, one of the following dispositions was implemented: a new deviation request justifying the nonconformances was drafted, an FHA evaluation was performed, or, a modification was implemented. The method of disposition selected is referenced within the body of the FHAR text. 11-12 Revision 30

CPNPP/FPR For each fire area, the consequences of the Design Basis Fire were determined based upon the assumptions made in Section 11-3.0 of this FHAR. In addition, the possibility of a radioactive release to the environment was evaluated based upon the Smoke Removal Study. 4.6 COMBUSTIBLE LOADING An evaluation of the combustible loading in each fire area was performed. Walkdowns were conducted of fire areas and fire zones containing Unit 1 or Unit 2 fire safe shutdown equipment and components to identify in-situ combustibles except cabling. The combustible loading due to cabling was determined by use of calculations for fixed exposed cabling. As-built combustible loading calculations were prepared for the different areas of the plant. For each fire area/fire zone, the heat of combustion for each in-situ combustible was calculated for each fire area/fire zone. The total heat of combustion for in-situ combustibles including cabling within the fire area/fire zone was then divided by the floor area to determine the actual fire load (BTU/Sq. Ft.) for the fire area/fire zone. In addition, the approximate fire duration (minutes) was determined based on a fire that burns at a rate of 80,000 BTU/Sq. Ft./hr. Actual fire load and fire duration values for each fire area/ fire zone were documented in the calculations. These calculations are maintained and are updated when changes to in-situ combustible loading warrant. For purposes of the FHAR, actual quantities of in-situ combustibles are not lised in the combustible loading sections of the report. Rather, the in-situ fire hazards contained within each fire area/fire zone were reported by fire load classifications (i.e., low, moderate, high or >high). As with determination of fire duration, fire load classifications were based on a fire that burns at a rate of 80,000 Btu/sq.ft./hr. The FHAR should be updated when changes to an area's in-situ combustible loading results in a change in fire load classification. The Maximum Permissible Fire Load (MPFL) for a fire area was calculated by two basic steps. First, the method of compliance with Section 11-4.5. was identified and the maximum fire loading which can be allowed without compromising fire safe shutdown capability was determined. Second, the fire area boundaries were reviewed (along with the results of any applicable non-rated evaluations) to determine the maximum fire loading which could be contained by the fire area boundaries. These two results were compared and the lower value became the governing MPFL. Additionally, to facilitate comparison to fire load classifications, the MPFL for each fire area/fire zone was classified as low, moderate or high, and reported in the FHAR. For each fire zone the type and quantity of in-situ combustibles was tabulated. The As-Built Combustible Loading Calculations may be reviewed for a detailed list of combustibles in each fire zone. The actual quantity of in-situ cabling is also not provided in the combustible loading sections of the FHAR. Rather, the vast majority of in-situ cabling is controlled by Electronic Data Management System (EDMS) software. The combustible loading due to these cables was completed by use of the EDMS software. The software includes heat of combustion values for each different cable type used in the plant. EDMS contains detailed quantities of cabling in each fire zone. 11-13 Revision 30

CPNPP/FPR Design review and control measures are utilized to regulate exposed cabling that is not traced by EDMS. Examples include cabling used for temporary modifications and specific low power service applications such as portions of the ERF and DATA Acquisition System (DAS) computers, between telephone junction boxes and handset stations, and cabling associated with the Integrated Communications System (ICS). The fire loads typically attributable to these applications are typically minimal in comparison to that of the fixed exposed cabling controlled by EDMS. In the event that any significant changes to fire load classifications result due to the addition of exposed cabling not tracked by EDMS, the Combustible Loading calculations are updated accordingly. Additionally, design review and control measures are utilized to restrict introduction of exposed cabling in areas with special separation of redundant sets of systems. Components or cables necessary to achieve and maintain hot standby conditions are credited to meet the criteria of Section 11-4.5, or to support the technical justification for certain deviations as described in Section V, Appendix C. For each fire area/fire zone, the FHAR identifies the MPFL value (Btu/sq.ft.), the MPFL classification (low, moderate or high) and the applicable fire load classification (low, moderate, high or >high). Fire areas or fire zones containing sufficient combustible material quantities such that the calculated MPFL value for that area is exceeded, are provided with adequate fire mitigation features, such as a fixed fire suppression system. These areas are identified in FPR Section 11-5, and the applicable mitigation features are described. The difference between MPFL values reported in the FHAR and actual fire load values (documented by supporting calculations) are considered in establishing administrative procedures for control of combustible materials within plant fire areas/fire zones. 5.0 FIRE HAZARDS ANALYSIS The following sections contain the fire hazards analysis for each fire area within plant buildings and areas containing equipment and/or components necessary to fulfill fire safe shutdown functions for the Unit 1 and/or Unit 2 reactor. 5.1 UNIT 1 SAFEGUARDS BUILDING The Unit 1 Safeguards Building is divided into fourteen fire areas. Some fire areas are further divided into fire zones and subzones. The following sections contain the fire hazards analysis for each fire area within the Safeguards Building. 5.1.1 FIRE AREA SA- RHR PUMP 5.1.1.1 LOCATION 11-14 Revision 30

CPNPP/FPR 5.1.1.2 CONSTRUCTION The walls, floors, and ceilings of Fire Area SA are constructed of materials providing an equivalent fire rating of three hours, except; exterior walls which are non-rated; the wall separating Fire Area SA from Fire Area SO which is two hour rated; and five non-rated solid concrete block wall access hatches between Fire Areas SA and SB on the 831 '-6" elevation. The five access hatches communicate between Fire Zones SA 142 and SB144. Deviation 3a-1 (See Appendix C) justifies the lack of a three hour rated barrier between the fire areas. The deviation justifications establish that adequate protection is provided for the hazards. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed, except twenty-four mechanical penetrations which are not fire rated. The non-rated mechanical penetrations communicate between Fire Area SA and Fire Area CA on the 785'-6" and 790'-6" elevations. Deviation 3g, (See Appendix C) justifies the existence of the non-rated mechanical penetrations. 5.1.1.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 fire safe shutdown equipment located within Fire Area SA 5.1.1.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-15 Revision 30

CPNPP/FPR 5.1.1.5 FIRE LOAD CLASSIFICATION Fire Area SA Fire Loading Summary Fire Load Classification Low Area 6,603 Sq. Ft. Fire Zone SA 1a Maximum Permissible Fire Load 80,000 BTU/Sq. Ft MPFL Classification Low Fire Load Classification Low Area 2,033 Sq. Ft. Fire Zone SA 1b Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1,179 Sq. Ft. Fire Zone SA 1c Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1,798 Sq. Ft. Fire Zone SA 1d Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 398 Sq. Ft. Fire Zone SA 142 Maximum Permissible Fire Load 37,300 BTU/Sq. Ft.* MPFL Classification Low Fire Load Classification Low Area 1,195 Sq. Ft.

This was established based on the combustibles in the area having burning characteristics of the "C" time-temperature curve.

11-16 Revision 30

CPNPP/FPR 5.1.2 FIRE AREA SB- MOTOR DRIVEN AFW PUMP/RHR PUMP 5.1.2.1 LOCATION 5.1.2.2 CONSTRUCTION The walls, floors, and ceiling of Fire Area SB are constructed of materials providing an equivalent fire rating of three hours, except exterior walls which are non-rated, and the wall separating Fire Area SB from Fire Area SA which contains five solid concrete block wall access hatches. The five access hatches communicate between Fire Zones SB144 and SA 142. Deviation 3a-1, (See Appendix C) justifies the lack of a three hour rated barrier between the fire areas. The justifications establish that adequate protection is provided for the hazards. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed, except for non-rated mechanical penetrations, containment air locks, and a non-rated missile resistant door. The twenty-two mechanical penetrations communicate between Fire Area SB and Fire Area CA. Deviation Request 3g, (See Appendix C) justifies the existence of the non-rated mechanical penetrations. The non-rated Containment Air-Lock communicates between Fire Area SB and Fire Area CA on the 832'-0" elevation. Deviation Request 3e, (See Appendix C) justifies the existence of the non-rated air-lock at this location. The missile resistant door communicates between Fire Area SB and the transformer area which presents an exposure hazard to the Safeguards Building. Deviation 3c, (See Appendix C) justifies the lack of a listed fire door at this location. The deviation justifications establish that adequate protection is provided for the hazards. 5.1.2.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 fire safe shutdown equipment located within Fire Area SB. 5.1.2.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-17 Revision 30

CPNPP/FPR 5.1.2.5 FIRE LOAD CLASSIFICATION Fire Area SB Fire Loading Summary Fire Load Classification Low Area 25,765 Sq. Ft. Fire Zone SB2a Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1,695 Sq. Ft. Fire Zone SB2b Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1,088 Sq. Ft. Fire Zone SB2c Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1,798 Sq. Ft. Fire Zone SB2d Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 430 Sq. Ft. 11-18 Revision 30

CPNPP/FPR Fire Zone SB2e Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 581 Sq. Ft. Fire Zone SB2f Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 606 Sq. Ft. Fire Zone SB2g Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 843 Sq. Ft. Fire Zone SB2h Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 201 Sq. Ft. Fire Zone SB4 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 4,831 Sq. Ft. Fire Zone SB5 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 406 Sq. Ft. Fire Zone SB6 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 364 Sq. Ft. 11-19 Revision 30

CPNPP/FPR Fire Zone SB8 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low** FireLoad Classification Moderate Area 4,094 Sq. Ft.

     **     See Section 11-5.1.2.4 for protection of this zone.

Fire Zone SB14 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 310 Sq. Ft. Fire Zone SB15 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 5,257 Sq. Ft. Fire Zone SB143 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1,195 Sq. Ft. Fire Zone SB144 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1,843 Sq. Ft. Fire Zone SB155 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 223 Sq. Ft. 11-20 Revision 30

CPNPP/FPR 5.1.3 FIRE AREA SC- TURBINE DRIVEN AFW PUMP 5.1.3.1 LOCATION 5.1.3.2 CONSTRUCTION The walls, floors, and ceilings of Fire Area SC are constructed of materials providing an equivalent fire rating of three hours, except exterior walls which are non-rated. Fire doors, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed. 5.1.3.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a list of the Unit 1 fire safe shutdown equipment located within Fire Area SC. 5.1.3.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 5.1.3.5 FIRE LOAD CLASSIFICATION Fire Area SC/Fire Zone SC7 Fire Loading Summary Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 510 Sq. Ft. 11-21 Revision 30

CPNPP/FPR 5.1.4 FIRE AREA SO- ELECTRICAL EQUIPMENT ROOM/TRAIN A SWITCHGEAR 5.1.4.1 LOCATION 5.1.4.2 CONSTRUCTION The walls and ceiling of Fire Area SO are constructed of materials providing an equivalent fire rating of three hours, except for the wall separating Fire Area SO from Fire Area SM, which is two hour rated, and exterior walls which are non-rated. Fire dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed, except twenty-seven non-rated electrical penetrations and two non-rated watertight doors. The twenty-seven non-rated electrical penetrations communicate between Fire Area SO and Fire Area CA. Deviation 3b, (See Appendix C) justifies the existence of the non-rated electrical penetrations. The watertight doors communicate between Fire Area SO and Fire Areas SG and Sl. Deviation 3d, (See Appendix C) justifies the lack of a rated fire door at these locations. The justifications establish that adequate protection is provided for the hazards. 5.1.4.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 fire safe shutdown equipment located within Fire Area SO. 5.1.4.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-22 Revision 30

CPNPP/FPR 5.1.4.5 FIRE LOAD CLASSIFICATION Fire Area SO/Fire Zone SD9 Fire Loading Summary Maximum Permissible Fire Load 37,300 BTU/Sq. Ft.* MPFL Classification Low Fire Load Classification Low Area 6,554 Sq. Ft.

This was based on the combustibles in the zone having the burning characteristics of the "C" time-temperature curve.

11-23 Revision 30

CPNPP/FPR 5.1.5 FIRE AREA SE- REMOTE SAFETY RELATED PANELS/TRAIN B SWITCHGEAR 5.1.5.1 LOCATION 5.1.5.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area SE are constructed of materials providing an equivalent fire rating of three hours, except exterior walls and ceilings which are non-rated and the walls separating Fire Area SE from Fire Area SN and Fire Area SM, which are of two hour rated construction. Fire dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed, except forty-seven non-rated electrical penetrations and one non-rated watertight door. The forty-seven non-rated electrical penetrations communicate between Fire Area SE and Fire Area CA on the 831 '-6" and 852'-6" elevations. Deviation 3b, (See Appendix C) justifies the existence of the non-rated electrical penetration. The non-rated watertight door communicates between Fire Area SE and Fire Area SK on the 852'-6" elevation. Deviation 3d, (See Appendix C) justifies the existence of the non-rated door at this location. The justifications establish that adequate protection is provided for the hazards. 5.1.5.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 fire safe shutdown equipment located within Fire Area SE. 5.1.5.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-24 Revision 30

CPNPP/FPR 5.1.5.5 FIRE LOAD CLASSIFICATION Fire Area SE Fire Loading Summary Fire Load Classification Low Area 13,728 Sq. Ft. Fire Zone SE16 Maximum Permissible Fire Load 37,300 BTU/Sq. Ft.* MPFL Classification Low** Fire Load Classification Low Area 5,105 Sq. Ft.

This was based on the combustibles in the zone having the burning characteristics of the "C" time-temperature curve.

            **     See Section 11-5.1.5.4 for protection of this zone.

Fire Zone SE18 Maximum Permissible Fire Load 37,300 BTU/Sq.* MPFL Classification Low Fire Load Classification Low Area 8,623 Sq. Ft.

This was based on the combustibles in the zone having the burning characteristics of the "C" time-temperature curve.

11-25 Revision 30

CPNPP/FPR 5.1.6 FIRE AREA SF- EMERGENCY AIR-LOCK ACCESS 5.1.6.1 LOCATION 5.1.6.2 CONSTRUCTION The walls, floors, and ceilings of the Fire Area SF are constructed of materials providing an equivalent fire rating of three hours, except for the wall separating Fire Area SF from Fire Area SO which is two hour rated and the exterior walls and ceiling of Fire Zone SF20 which are non-rated. Fire dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed, except one non-rated watertight door, and a non-rated Containment Air-Lock. The non-rated watertight door communicates between Fire Area SF and Fire Area SK on elevation 873'-6". Deviation 3d, (See Appendix C) justifies the existence of the non-rated door at this location. The non-rated Containment Air-Lock communicates between Fire Area SF and Fire Area CA on elevation 905'-0". Deviation 3e, (See Appendix C) justifies the non-rated air-lock at this location. The justifications establish that adequate protection is provided for the hazards. 5.1.6.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT No Unit 1 fire safe shutdown equipment is located within Fire Area SF. 5.1.6.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-26 Revision 30

CPNPP/FPR 5.1.6.5 FIRE LOAD CLASSIFICATION Fire Area SF Fire Loading Summary Fire Load Classification Low Area 1,077 Sq. Ft. Fire Zone SF19 Maximum Permissible Fire Load 160,000 BTU/Sq. Ft. MPFL Classification Moderate Fire Load Classification Low Area 751 Sq. Ft. Fire Zone SF20 Maximum Permissible Fire Load 160,000 BTU/Sq. Ft. MPFL Classification Moderate Fire Load Classification Low Area 326 Sq. Ft. 11-27 Revision 30

CPNPP/FPR 5.1.7 FIRE AREA SG- DIESEL GENERATOR 5.1.7.1 LOCATION 5.1.7.2 CONSTRUCTION The walls, floors, and ceilings of Fire Area SG are constructed of materials providing an equivalent fire rating of three hours, except exterior walls which are non-rated. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed, except for one non-rated watertight door. The non-rated watertight door communicates between Fire Areas SG and SO on elevation 81 0'-6". Deviation 3d, (See Appendix C) justifies the existence of the non-rated door at this location. The justifications establish that adequate protection is provided for the hazards. 5.1.7.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a list of the Unit 1 fire safe shutdown equipment located within Fire Area SG. 5.1.7.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-28 Revision 30

CPNPP/FPR 5.1.7.5 FIRE LOAD CLASSIFICATION Fire Area SG Fire Loading Summary Fire Load Classification Moderate Area 3,498 Sq. Ft. Fire Zone SG1 Oa Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High** Fire Load Classification >High Area 1,884 Sq. Ft.

            **     See Section 5.1.7.4 for protection of this zone.

Fire Zone SG1 Ob Maximum permissible Fire Load 240,000 BTU/Sq.Ft. MPFL Classification High Fire Load Classification Low Area 1,614 Sq. Ft. 11-29 Revision 30

CPNPP/FPR 5.1.8 FIRE AREA SH- DIESEL DAY TANK ROOM 5.1.8.1 LOCATION 5.1.8.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area SH are constructed of materials providing an equivalent fire rating of three hours, except an exterior wall which is non-rated. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed. 5.1.8.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 fire safe shutdown equipment located within Fire Area SH. 5.1.8.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-30 Revision 30

CPNPP/FPR 5.1.8.5 FIRE LOAD CLASSIFICATION Fire Area SH/Fire Zone SH11 Fire Loading Summary Maximum Permissible Fire Load 240,000 BTU/Sq.Ft. MPFL Classification High** Fire Load Classification >High Area 231 Sq. Ft.

            **     See Section 11-5.1.8.4 for protection of this zone.

11-31 Revision 30

CPNPP/FPR 5.1.9 FIRE AREA Sl- DIESEL GENERATOR 5.1.9.1 LOCATION 5.1.9.2 CONSTRUCTION The walls, floors, and ceilings of Fire Area Sl are constructed of materials providing an equivalent fire rating of three hours, except for exterior walls which are non-rated. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed, except one non-rated watertight door. The non-rated watertight door communicates between Fire Areas SO and Sl on elevation 81 0'-6". Deviation 3d, (See Appendix C) justifies the existence of the non-rated door at this location. The justifications establish that adequate protection is provided for the hazards. 5.1.9.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 fire safe shutdown equipment located within Fire Area S I. 5.1.9.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-32 Revision 30

CPNPP/FPR 5.1.9.5 FIRE LOAD CLASSIFICATION Fire Area Sl Fire Loading Summary Fire Load Classification Moderate Area 3,498 Sq. Ft. Fire Zone Sl12a Maximum Permissible Fire Load 240,000 BTU/Sq.Ft. MPFL Classification High** Fire Load Classification >High Area 1,884 Sq. Ft.

            **     See Section 11-5.1.9.4 for protection of this zone.

Fire Zone Sl12b Maximum Permissible Fire Load 240,000 BTU/Sq.Ft. MPFL Classification High Fire Load Classification Low Area 1,614 Sq. Ft. 11-33 Revision 30

CPNPP/FPR 5.1.10 FIRE AREA SJ- DIESEL DAY TANK ROOM 5.1.10.1 LOCATION 5.1.1 0.2 CONSTRUCTION The walls, floors, and ceiling of Fire Area SJ are constructed of materials providing an equivalent fire rating of three hours, except an exterior wall which is non-rated. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed. 5.1.1 0.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 fire safe shutdown equipment located within Fire Area SJ. 5.1.10.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-34 Revision 30

CPNPP/FPR 5.1.10.5 FIRE LOAD CLASSIFICATION Fire Area SJ/Fire Zone SJ13 Fire Loading Summary Maximum Permissible Fire Load 240,000 BTU/Sq.Ft. MPFL Classification High** Fire Load Classification >High Area 231 Sq. Ft.

           **     See Section 11-5.1.10.4 for protection of this area.

11-35 Revision 30

CPNPP/FPR 5.1.11 FIRE AREA SK- MAIN STEAM AND FEEDWATER PENETRATION AREA 5.1.11.1 LOCATION 5.1.11.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area SKare constructed of materials providing an equivalent fire rating of three hours, except the wall separating Fire Area SK from Fire Area SN which is 2 hour rated and exterior walls which are non-rated. Fire dampers, penetration seals, and fire doors have a fire rating equal to the barrier in which they are installed, except three watertight doors, which are not rated and one mechanical penetration seal, which is not three hour rated. Three non-rated watertight doors are in walls separating Fire Area SK from Fire Areas SE, SN, and SF. One mechanical penetration is installed in a wall separating Fire Area SK from CA. Deviations 3d and 3g, (See Appendix C) justifies the lack of fire rated doors and a rated penetration seal. The justifications establish that adequate protection is provided for the hazards. 5.1.11.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 fire safe shutdown equipment located within Fire Area S K. 5.1.11.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-36 Revision 30

CPNPP/FPR 5.1.11.5 FIRE LOAD CLASSIFICATION Fire Area SK Fire Loading Summary Fire Load Classification Low Area 6,337 Sq. Ft. Fire Zone SK17a Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 3,708 Sq. Ft. Fire Zone SK17b Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 2,629 Sq. Ft. Fire Zone SK17c Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 2,629 Sq. Ft. 11-37 Revision 30

CPNPP/FPR 5.1.12 FIREAREASM-STAIRWELL 5.1.12.1 LOCATION 5.1.12.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area SM are constructed of materials providing an equivalent fire rating of two hours (See Assumption 3.6). Fire dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed. 5.1.12.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT No Unit 1 fire safe shutdown equipment is located within Fire Area SM. 5.1.12.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 5.1.12.5 FIRE LOAD CLASSIFICATION Fire Area SM/Fire Zone SM157 Fire Loading Summary Maximum Permissible Fire Load 160,000 BTU/Sq. Ft. MPFL Classification Moderate Fire Load Classification Moderate Area 207 Sq. Ft. 11-38 Revision 30

CPNPP/FPR 5.1.13 FIREAREASN-STAIRWELL 5.1.13.1 LOCATION 5.1.13.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area SN are constructed of materials providing an equivalent fire rating of two hours. All fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed, except one door which is located in the wall separating Fire Area SN and SK which is non-rated. Deviation 3d, (See Appendix C) justifies the non-rated construction. The justifications establish that adequate protection is provided for the hazards. 5.1.13.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT No Unit 1 fire safe shutdown equipment is located within Fire Area SN. 5.1.13.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 5.1.13.5 FIRE LOAD CLASSIFICATION Fire Area SN/Fire Zone SM158 Fire Loading Summary Maximum Permissible Fire Load 160,000 BTU/Sq. Ft MPFL Classification Moderate Fire Load Classification Moderate Area 72 Sq. Ft. 11-39 Revision 30

CPNPP/FPR 5.1.14 FIREAREASO-STAIRWELL 5.1.14.1 LOCATION 5.1.14.2 CONSTRUCTION The walls, floors, and ceiling of Fire Area SO are constructed of materials providing an equivalent fire rating of two hours, except exterior walls which are non-rated. Fire dampers, penetration seals, and fire doors have a fire rating equal to the barrier in which they are installed. 5.1.14.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT No Unit 1 fire safe shutdown equipment is located within Fire Area SO. 5.1.14.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 5.1.14.5 FIRE LOAD CLASSIFICATION Fire Area SO/Fire Zone S03 Fire Loading Summary Maximum Permissible Fire Load 160,000 BTU/Sq. Ft MPFL Classification Moderate Fire Load Classification Low Area 539 Sq. Ft. 11-40 Revision 30

CPNPP/FPR 5.2 AUXILIARY BUILDING The Auxiliary Building is a common building which contains both Unit 1 and Unit 2 components, as well as most of the common systems. Internally, the building is divided into six fire areas (AA, AB, AC, AD, AE, AF). Fire Area AA extends into both the Electrical and Control Building and the Fuel Building. For the purposes of this FPR, Fire Area AA is addressed in each building FPR section. Only those fire areas located in the subject building are addressed in each FHA section. Some fire areas are further divided into fire zones and subfire zones. The following sections contain the fire hazards analysis for each fire area within the Auxiliary Building. 5.2.1 FIRE AREA AA- MISCELLANEOUS AREAS 5.2.1.1 LOCATION 5.2.1.2 CONSTRUCTION The walls, floors, and ceilings of Fire Area AA are constructed of materials providing an equivalent fire rating of three hours except non-rated exterior walls, and two removable non-rated concrete block walls located in the walls that separate Fire Area AA from Fire Area AC and Fire Area AA from Fire Area AB on the 81 0'-0" elevation. Deviation 3a and 3a(2) (See Appendix C) justify the lack of a rated fire barrier at these locations. The deviation justifications establish that adequate protection is provided for the hazards. All fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed. 5.2.1.3 POTENTIAL FAILED FIRE SAFE SHUTDOWN EQUIPMENT SeeSection 111-5.0 for a listing of the Unit 1 and Unit 2 fire safe shutdown equipment located within Fire Area AA. 5.2.1.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-41 Revision 30

CPNPP/FPR 11-42 Revision 30

CPNPP/FPR 5.2.1.5 FIRE LOAD CLASSIFICATION Fire Area AA Fire Loading Summary Fire Load Classification Low Area 111,183 Sq. Ft. Fire Zone AA21 a Maximum Permissible Fire Load 37,300 BTU/Sq. Ft.* MPFL Classification Low Fire Load Classification Low Area 19,768 Sq. Ft.

This was established based on the combustibles in the zone having the burning characteristics of the "C" time-temperature curve.

Fire Zone AA21 b Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 12,929 Sq. Ft. Fire Zone AA21 c Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 884 Sq. Ft. Fire Zone AA21 d Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 15,372 Sq. Ft. Fire Zone AA21 e Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 3,954 Sq. Ft. 11-43 Revision 30

CPNPP/FPR Fire Zone AA21f Maximum Permissible Fire Load 15,000 BTU/Sq. Ft. MPFL Classification Low** Fire Load Classification Low Area 24,975 Sq. Ft.

     **     See Section 11-5.2.1.4 for protection of this zone.

Fire Zone AA21 g Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 799 Sq. Ft. 11-44 Revision 30

CPNPP/FPR Fire Zone AA21 h Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 260 Sq. Ft. Fire Zone AA22 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1,200 Sq. Ft. Fire Zone AA23 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 378 Sq. Ft. Fire Zone AA25 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 560 Sq. Ft. Fire Zone AA26 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 523 Sq. Ft. Fire Zone AA27 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 523 Sq. Ft. Fire Zone AA28 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 560 Sq. Ft. 11-45 Revision 30

CPNPP/FPR Fire Zone AA30 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 378 Sq. Ft. Fire Zone AA34 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 230 Sq. Ft. Fire Zone AA35 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 230 Sq. Ft. Fire Zone AA36 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 230 Sq. Ft. Fire Zone AA37 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 230 Sq. Ft. Fire Zone AA38 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 12,258 Sq. Ft. Fire Zone AA39 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 7,448 Sq. Ft. 11-46 Revision 30

CPNPP/FPR Fire Zone AA40 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 7,448 Sq. Ft. Fire Zone AA46 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 46 Sq. Ft. 11-47 Revision 30

CPNPP/FPR 5.2.2 FIRE AREA AB- CENTRIFUGAL CHARGING PUMP 5.2.2.1 LOCATION 5.2.2.2 CONSTRUCTION The walls, floor, and ceiling are constructed of materials providing an equivalent fire rating of three hours, except for a portion of the wall which includes an access hatch. This hatch is constructed of solid concrete block and is not rated. Deviation Request 3a(2), (See Appendix C) justifies the nonrated access hatch. Fire dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed. 5.2.2.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT No Unit 1 fire safe shutdown equipment is located within Fire Area AB. See Section 111-5.0 for a listing of Unit 2 fire safe shutdown equipment located within Fire Area AB. 5.2.2.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-48 Revision 30

CPNPP/FPR 5.2.2.5 FIRE LOAD CLASSIFICATION Fire Area AB/Fire Zone AB24 Fire Loading Summary Maximum Permissible Fire Load 160,000 BTU/Sq. Ft. MPFL Classification Moderate Fire Load Classification Low Area 429 Sq. Ft. 11-49 Revision 30

CPNPP/FPR 5.2.3 FIRE AREA AC- CENTRIFUGAL CHARGING PUMP 5.2.3.1 LOCATION 5.2.3.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area AC are constructed of materials providing an equivalent fire rating of three hours, except for a portion of the wall which includes a non-rated, solid concrete block, access hatch. Deviation Request 3a, (See Appendix C) justifies the non-rated access hatch. The deviation justifications establish that adequate protection is provided for the hazards. Fire dampers, penetration seals, and fire doors have a rating equivalent to that of the boundary in which they are installed. 5.2.3.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 fire safe shutdown equipment located within Fire Area AC. No Unit 2 safe shutdown equipment is located within Fire Area AC. 5.2.3.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-50 Revision 30

CPNPP/FPR 5.2.3.5 FIRE LOAD CLASSIFICATION Fire Area AC/Fire Zone AC29 Fire Loading Summary Maximum Permissible Fire Load 160,000 BTU/Sq. Ft. MPFL Classification Moderate Fire Load Classification Low Area 429 Sq. Ft. 11-51 Revision 30

CPNPP/FPR 5.2.4 FIRE AREA AD- BORIC ACID STORAGE TANKS 5.2.4.1 LOCATION 5.2.4.2 CONSTRUCTION The walls, floors, and ceiling of Fire Area AD are constructed of materials providing an equivalent fire rating of three hours. Fire dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed. 5.2.4.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT No Unit 1 or Unit 2 fire safe shutdown equipment is located within Fire Area AD. 5.2.4.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 5.2.4.5 FIRE LOAD CLASSIFICATION Fire Area AD Fire Loading Summary Fire Load Classification Low Area 2,488 Sq. Ft. 11-52 Revision 30

CPNPP/FPR Fire Zone AD31 a Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 1,244 Sq. Ft. Fire Zone AD31 b Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 1,244 Sq. Ft. 11-53 Revision 30

CPNPP/FPR 5.2.5 FIRE AREA AE- CCW PUMP 5.2.5.1 LOCATION 5.2.5.2 CONSTRUCTION The walls, floor, and ceilings of Fire Area AE are constructed of materials providing an equivalent fire rating of three hours. Fire dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed. 5.2.5.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT No Unit1 fire safe shutdown equipment is located within Fire Area AE. See Section 111-5.0 for a listing of the Unit 2 fire safe shutdown equipment within Fire Area AE. 5.2.5.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 5.2.5.5 FIRE LOAD CLASSIFICATION FireArea AE/Fire Zone AE32 Fire Loading Summary Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 670 Sq. Ft. 11-54 Revision 30

CPNPP/FPR 5.2.6 FIRE AREA AF- CCW PUMP 5.2.6.1 LOCATION 5.2.6.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area AF are constructed of materials providing an equivalent fire rating of three hours. Fire dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed. 5.2.6.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 fire safe shutdown equipment is located within Fire Area AF. No Unit 2 fire safe shutdown equipment is located within Fire Area AF. 5.2.6.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-55 Revision 30

CPNPP/FPR 5.2.6.5 FIRE LOAD CLASSIFICATION Fire Area AF/Fire Zone AF33 Fire Loading Summary Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 670 Sq. Ft. 11-56 Revision 30

CPNPP/FPR 5.3 ELECTRICAL AND CONTROL BUILDING The Electrical and Control Building is a common building which contains both Unit 1 and Unit 2 components, and some common systems. Internally, the building is divided into eleven fire areas (EA, EB, EC, EH, EL, EM, EN, EO, EQ, ER, AA). One fire Area (AA) extends into both the Auxiliary Building and the Fuel Building. For the purposes of this FPR, Fire Area AA is addressed in each FPR section. Some fire areas are further divided into fire zones and subfire zones. The following sections contain the fire hazards analysis for each fire area within the Electrical and Control Building. 5.3.1 FIRE AREA EA- MECHANICAL ROOM 5.3.1.1 LOCATION 5.3.1.2 CONSTRUCTION The walls, floors, and ceilings of Fire Area EA are constructed of materials providing an equivalent fire rating of three hours. Fire dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed. 5.3.1.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 and Unit 2 fire safe shutdown equipment located within Fire Area EA. 5.3.1.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-57 Revision 30

CPNPP/FPR 5.3.1.5 FIRE LOAD CLASSIFICATION Fire Area EA Fire Loading Summary Fire Load Classification Low Area 23,188 Sq. Ft. Fire Zone EA43 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 9,480 Sq. Ft. Fire Zone EA44 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 713 Sq. Ft. Fire Zone EA47 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 409 Sq. Ft. Fire Zone EA54 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 516 Sq. Ft. 11-58 Revision 30

CPNPP/FPR Fire Zone EA57 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 516 Sq. Ft. Fire Zone EA58 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 226 Sq. Ft. Fire Zone EA59 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 443 Sq. Ft. Fire Zone EA60 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 443 Sq. Ft. Fire Zone EA61 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 226 Sq. Ft. Fire Zone EA73 Maximum Permissible Fire Load 37,300 BTU/Sq. Ft.* MPFL Classification Low Fire Load Classification Low Area 3,622 Sq. Ft.

This was established based on the combustibles in the zone having the burning characteristics of the "C" time-temperature curve.

11-59 Revision 30

CPNPP/FPR Fire Zone EA74 Maximum Permissible Fire Load 37,300 BTU/Sq. Ft.* MPFL Classification Low Fire Load Classification Low Area 3,622 Sq. Ft.

This was established based on the combustibles in the zone having the burning characteristics of the "C" time-temperature curve.

Fire Zone EA75 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 2,644 Sq. Ft. Fire Zone EA161 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 328 Sq. Ft. 11-60 Revision 30

CPNPP/FPR 5.3.2 FIRE AREA EB- STAIRWELL 5.3.2.1 LOCATION 5.3.2.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area EB are constructed of materials providing an equivalent fire rating of two hours. Fire dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed. 5.3.2.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT No Unit 1 or Unit 2 fire safe shutdown equipment is located within Fire Area EB. 5.3.2.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 5.3.2.5 FIRE LOAD CLASSIFICATION Fire Area EB/Fire Zone EB45 Fire Loading Summary Maximum Permissible Fire Load 160,000 BTU/Sq. Ft. MPFL Classification Moderate Fire Load Classification Low Area 126 Sq. Ft. 11-61 Revision 30

CPNPP/FPR 5.3.3 FIRE AREA EC- BATTERY ROOMS 5.3.3.1 LOCATION 5.3.3.2 CONSTRUCTION The walls, floor, and ceiling are constructed of materials providing an equivalent fire rating of three hours. In addition, the three interior walls separating the four fire zones within Fire Area EC are one hour fire resistance rated. Fire dampers, penetration seals, and fire doors have a rating equal to the barrier in which they are installed. 5.3.3.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 and Unit 2 fire safe shutdown equipment located within Fire Area EC. 5.3.3.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-62 Revision 30

CPNPP/FPR 5.3.3.5 FIRE LOAD CLASSIFICATION Fire Area EC Fire Loading Summary Fire Load Classification Low Area 1,205 Sq. Ft. Fire Zone EC48 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 294 Sq. Ft. Fire Zone EC49 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low** Fire Load Classification Moderate Area 261 Sq. Ft.

            **     SeeSection 11-5.3.3.4 for protection of this zone.

Fire Zone EC50 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 325 Sq. Ft. Fire Zone EC51. Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 325 Sq. Ft. 11-63 Revision 30

CPNPP/FPR 5.3.4 FIRE AREA EH- BATTERY ROOMS 5.3.4.1 LOCATION 5.3.4.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area EH are constructed of materials providing an equivalent fire rating of three hours. In addition, four interior walls separating the four fire zones within Fire Area EH are one hour fire resistance rated. Fire dampers, penetration seals, and fire doors have a rating equal to the barrier in which they are installed. 5.3.4.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 and Unit 2 fire safe shutdown equipment located within Fire Area EH. 5.3.4.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-64 Revision 30

CPNPP/FPR 5.3.4.5 FIRE LOAD CLASSIFICATION Fire Area EH Combustible Loading Summary Fire Load Classifcation Low Area 1,243 Sq. Ft. Fire Zone EH52 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 342 Sq. Ft. Fire Zone EH53 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 341 Sq. Ft. Fire Zone EH55 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 280 Sq. Ft. Fire Zone EH56. Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low** Fire Load Classification Moderate Area 280 Sq. Ft.

            **     See Section 11-5.3.4.4 for protection of this zone.

11-65 Revision 30

CPNPP/FPR 5.3.5 FIRE AREA EL- STAIRWAY 5.3.5.1 LOCATION 5.3.5.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area EL are constructed of materials providing an equivalent fire rating of two hours. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed. 5.3.5.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT No Unit 1 or Unit 2 fire safe shutdown equipment is located within Fire Area EL. 5.3.5.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 5.3.5.5 FIRE LOAD CLASSIFICATION Fire Area EL/Fire Zone EL62 Fire Loading Summary Maximum Permissible Fire Load 160,000 BTU/Sq. Ft. MPFL Classification Moderate Fire Load Classification Low Area 110 Sq. Ft. 11-66 Revision 30

CPNPP/FPR 5.3.6 FIRE AREA EM- UNIT 2 CABLE SPREADING ROOM 5.3.6.1 LOCATION 5.3.6.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area EM are constructed of materials providing an equivalent fire rating of three hours. Fire dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed. 5.3.6.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT No Unit 1 fire safe shutdown equipment is located within Fire Area EM. See Section 111-5.0 for listing of the Unit 2 fire safe shutdown equipment located within Fire Area EM. 5.3.6.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-67 Revision 30

CPNPP/FPR 5.3.6.5 FIRE LOAD CLASSIFICATION Fire Area EM/Fire Zone EM63 Fire Loading Summary Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification High Area 7,184 Sq. Ft. 11-68 Revision 30

CPNPP/FPR 5.3.7 FIRE AREA EN- UNIT 1 CABLE SPREADING ROOM 5.3.7.1 LOCATION 5.3.7.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area EN are constructed of materials providing an equivalent fire rating of three hours. Fire dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed, except a one hour non-rated bullet resistant-penetration resistant door. The non-rated bullet resistant-penetration resistant door communicates between Fire Areas EN and TA on the 81 0'-6" elevation. Deviation 3h, (See Appendix C) justifies the lack of a rated fire door at this location. The justifications establish that the protection provided is adequate for the hazard. 5.3.7.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT SeeSection 111-5.0 for a listing of the Unit 1 fire safe shutdown equipment located within Fire Area EN. No Unit 2 fire safe shutdown equipment is located within Fire Area EN. 5.3.7.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-69 Revision 30

CPNPP/FPR 5.3.7.5 FIRE LOAD CLASSIFICATION Fire Area EN/Fire Zone EN64 Fire Loading Summary Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification High Area 7,184 Sq. Ft. 11-70 Revision 30

CPNPP/FPR 5.3.8 FIRE AREA EO- CONTROL ROOM 5.3.8.1 LOCATION 5.3.8.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area EO are constructed of materials providing an equivalent fire rating of three hours. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed, except a non-rated door. The non-rated door communicates between Fire Area EO and the Turbine Deck on the 830'-0" elevation. Deviation 3c-1, (See Appendix C) justifies the lack of a listed fire damper installation and listed fire door at these location. The justifications establish that adequate protection is provided for the hazard. 5.3.8.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 and Unit 2 fire safe shutdown equipment located within Fire Area EO. 5.3.8.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-71 Revision 30

CPNPP/FPR 5.3.8.5 FIRE LOAD CLASSIFICATION Fire Area EO Fire Loading Summary Fire Load Classification Low Area 17,944 Sq. Ft. Fire Zone E065 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 13,373 Sq. Ft. Fire Zone E066 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Moderate Area 487 Sq. Ft. Fire Zone E067 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 320 Sq. Ft. Fire Zone E068 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification High Area 200 Sq. Ft. Fire Zone E069 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Moderate Area 575 Sq. Ft. 11-72 Revision 30

CPNPP/FPR Fire Zone E070 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Moderate Area 867 Sq. Ft. Fire Zone E071 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 867 Sq. Ft. Fire Zone E072 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 586 Sq. Ft. Fire Zone E0140 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 95 Sq. Ft. Fire Zone E0141 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 115 Sq. Ft. Fire Zone E0162 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 255 Sq. Ft. Fire Zone E0163. Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Clasification Low Area 204 Sq. Ft. 11-73 Revision 30

CPNPP/FPR 5.3.9 FIRE AREA EQ- UPS AC UNIT 5.3.9.1 LOCATION 5.3.9.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area EQ are constructed of materials providing an equivalent fire rating of three hours. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed. 5.3.9.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 and Unit 2 fire safe shutdown equipment located within Fire Area EQ. 5.3.9.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 5.3.9.5 FIRE LOAD CLASSIFICATION Fire Area EQ/Fire Zone EQ149 Fire Loading Summary Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 316 Sq. Ft. 11-74 Revision 30

CPNPP/FPR 5.3.10 FIRE AREA ER- UPS AC UNIT 5.3.10.1 LOCATION 5.3.1 0.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area ER are constructed of materials providing an equivalent fire rating of three hours. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed. 5.3.10.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 and Unit 2 fire safe shutdown equipment located within Fire Area ER. 5.3.10.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 5.3.10.5 FIRE LOAD CLASSIFICATION Fire Area ER/Fire Zone ER150 Fire Loading Summary Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 316 Sq. Ft. 11-75 Revision 30

CPNPP/FPR 5.3.11 FIRE AREA AA- CHILLER EQUIPMENT ROOM 5.3.11.1 LOCATION 5.3.11.2 CONSTRUCTION The walls, floors, and ceilings of Fire Area AA are constructed of materials providing an equivalent fire rating of three hours, except for exterior walls which are not rated. Fire dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed. 5.3.11.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 and Unit 2 fire safe shutdown equipment located within Fire Area AA. 5.3.11.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-76 Revision 30

CPNPP/FPR 5.3.11.5 FIRE LOAD CLASSIFICATION Fire Area AA Fire Loading Summary Fire Load Classification Moderate Area 3,344 Sq. Ft. Fire Zone AA 153 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low** Fire Load Classification Moderate Area 1,672 Sq. Ft.

           **     See Section 11-5.3.11.4 for protection of this zone.

Fire Zone AA 154 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1,672 Sq. Ft. 11-77 Revision 30

CPNPP/FPR 5.4 TURBINE BUILDING The Turbine Building is separated from other plant buildings by three hour rated fire barriers. Internally, the Unit 1 and Unit 2 sides are partially separated by a fire rated gypsum board wall. This barrier is in place for risk management purposes. The Unit 1 and Unit 2 Turbine Building consists of one fire area (TB), divided into fire zones and subzones. The following sections contain the fire hazards analysis for the Unit 1 and Unit 2 Turbine Building. 5.4.1 FIRE AREA TB 5.4.1.1 LOCATION 5.4.1.2 CONSTRUCTION The boundaries of Fire Area TB separate TB from the Electrical and Controls, Auxiliary, and Safeguards Buildings and are constructed of materials providing an equivalent rating of three hours. Exterior walls are three hour rated where an exterior hazard exists outside the Turbine Building. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed, except for two non-rated Bullet Resistant-Penetration Resistant doors. One door communicates between Fire Area EN and Fire Area TB and is identified in deviation 3h (See Appendix C). The other door communicates between Fire Area EM and Fire Area TB and is identified in deviations 3ha (2) and 3hb (2) (See Appendix C). The deviations justify the lack of rated fire doors at these locations. The deviation justifications establish that the protection provided is adequate for the hazards. 5.4.1.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 and Unit 2 fire safe shutdown equipment located within Fire Area TB. 5.4.1.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-78 Revision 30

CPNPP/FPR 5.4.1.5 FIRE LOAD CLASSIFICATION Fire Area TB Fire Loading Summary Fire Load Classification Low Area 327,579 Sq. Ft. Fire Zone TB1 05a Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 5,214 Sq. Ft. Fire Zone TB1 05b Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 9,802 Sq. Ft. Fire Zone TB1 05c Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 4,349 Sq. Ft. 11-79 Revision 30

CPNPP/FPR Fire Zone TB1 05d Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 54,738 Sq. Ft. Fire Zone TB1 05e Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 52,721 Sq. Ft. Fire Zone TB1 05f Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 7,138 Sq. Ft. Fire Zone TB1 05g Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 20,558 Sq. Ft. Fire Zone TB1 05h Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL- Classification High Fire Load Classification Low Area 1,196 Sq. Ft. Fire Zone TB106 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 64 Sq. Ft. 11-80 Revision 30

CPNPP/FPR Fire Zone TB1 07 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classifcation High** Fire Load Classification >High Area 1,473 Sq. Ft.

     **     See Section 11-5.4.1.4 for protection of this zone.

Fire Zone TB108 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 139 Sq. Ft. Fire Zone TB109 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High** Fire Load Classification >High Area 1,173 Sq. Ft.

     **     See Section 11-5.4.1.4 for protection of this zone.

Fire Zone TB11 0 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 8,136 Sq. Ft. Fire Zone TB111 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 7,138 Sq. Ft. Fire Zone TB112 Maximum Permissible Fire Load 240,000 BTU/Sq.Ft. MPFL Classification High Fire Load Classification Low Area 1,983 Sq.Ft 11-81 Revision 30

CPNPP/FPR Fire Zone TB113 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 116 Sq. Ft. Fire Zone TB114 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 64 Sq. Ft. Fire Zone TB138 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 432 Sq. Ft. Fire Zone TB139 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Moderate Area 75 Sq. Ft. Fire Zone TB148 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 294 Sq. Ft. Fire Zone TB151 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 234 Sq. Ft. Fire Zone TB186 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 274 Sq. Ft. 11-82 Revision 30

CPNPP/FPR Fire Zone TB187 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 378 Sq. Ft. Fire Zone TB201 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 396 Sq. Ft. Fire Zone TB201 a Maximum Permissible Fire Load 240,000 BTU Sq. Ft. MPFL Classification High Fire Load Classification Low Area 144 Sq. Ft. Fire Zone TB202 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 396 Sq. Ft. Fire Zone TB202A Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 144 Sq. Ft. Fire Zone TB205A Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 5214 Sq. Ft. Fire Zone TB205B Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 9802 Sq. Ft. 11-83 Revision 30

CPNPP/FPR Fire Zone TB205C Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 4349 Sq. Ft. Fire Zone TB205D Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 54,738 Sq. Ft. Fire Zone TB205E Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 52,721 Sq. Ft. Fire Zone TB205F Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 7,138 Sq. Ft. Fire Zone TB207 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High** Fire Load Classification >High Area 1,473 Sq. Ft.

     **     See Section 11-5.4.1.4 for protection of this zone.

Fire Zone TB208 Maximum Permissible Fire Load 160,000 BTU/Sq. Ft. MPFL Classification Moderate Fire Load Classification Low Area 139 Sq. Ft. 11-84 Revision 30

CPNPP/FPR Fire Zone TB209 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High** Fire Load Classification >High Area 1,173 Sq. Ft.

     **     See Section 11-5.4.1.4 for protection of this zone.

Fire Zone TB21 0 Maximum Permissible Fire Load 160,000 BTU/Sq. Ft. MPFL Classification Moderate Fire Load Classification Low Area 8,136 Sq. Ft. Fire Zone TB213 Maximum Permissible Fire Load 160,000 BTU/Sq. Ft. MPFL Classification Moderate Fire Load Classification Low Area 116 Sq. Ft. Fire Zone TB238 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 800 Sq. Ft. Fire Zone TB251 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 234 Sq. Ft. Fire Zone TB286 Maximum Permissible Fire Load 160,000 BTU/Sq. Ft. MPFL Classification Moderate Fire Load Classification Low Area 274 Sq. Ft. 11-85 Revision 30

CPNPP/FPR Fire Zone TB287 Maximum Permissible Fire Load 160,000 BTU/Sq. Ft. MPFL Classification Moderate Fire Load Classification Low Area 378 Sq. Ft. 11-86 Revision 30

CPNPP/FPR 5.5 FUEL BUILDING The Fuel Building is a common building which is entirely made of Fire Area AA. The fire area with the Fuel Building is further divided into fire zones and subfire zones. Fire Area AA extends into both the Auxiliary Building and the Electrical and Control Building. The following sections contain the fire hazards analysis for Fire Area AA within the Fuel Building. 5.5.1 FIRE AREA AA 5.5.1.1 LOCATION 5.5.1.2 CONSTRUCTION The walls of Fire Area AA are three hour rated, except the exterior walls which are not rated. Within Fire Area AA, Fire Zone AA 100 and Fire Zone AA 188 are enclosed within three hour rated walls and Fire Zones AA96 and AA97 are completely enclosed within a one hour fire barrier. Fire dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed, except 4 mechanical penetrations which are not rated. Two of these penetrations communicate with the Unit 1 Containment Building (Fire Area CA). The other two communicate with the Unit 2 Containment Building (Fire Area 2CA). Deviations 3g and 3g (2) (See Appendix D) justify the lack of three hour rated penetration seals at these locations. The justifications establish that adequate protection is provided for the hazards. 5.5.1.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT No Unit 1 or Unit 2 fire safe shutdown equipment is located within the Fuel Building section of Fire Area AA. 5.5.1.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-87 Revision 30

CPNPP/FPR 5.5.1.5 FIRE LOAD CLASSIFICATION Fire Area AA (Fuel Building) Fire Loading Summary Fire Load Classification Low Area 24,787 Sq. Ft. Fire Zone AA96 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 438 Sq. Ft. Fire Zone AA97 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 438 Sq. Ft. Fire Zone AA98 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 87 Sq. Ft. Fire Zone AA99a Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 7,957 Sq. Ft. 11-88 Revision 30

CPNPP/FPR Fire Zone AA99b Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1,257 Sq. Ft. Fire Zone AA99c Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1,025 Sq. Ft. Fire Zone AA99d Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 5,353 Sq. Ft. Fire Zone AA99e Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 7,121 Sq. Ft. Fire Zone AA 100 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 760 Sq. Ft. Fire Zone AA 188 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Moderate Area 351 Sq. Ft. 11-89 Revision 30

CPNPP/FPR 5.6 SERVICE WATER INTAKE STRUCTURE The Service Water Intake Structure is a remotely common building. Internally, it is divided into two fire areas. Both fire areas contain one fire zone and one fire area is further divided into subfire zones. The following sections contain the fire hazards analysis for each fire area within the Service Water Intake Structure. 5.6.1 FIRE AREA WA- DIESEL FIRE PUMP ROOM 5.6.1.1 LOCATION 5.6.1.2 CONSTRUCTION The walls, floors, and ceilings of Fire Area WA are constructed of materials providing an equivalent fire rating of three hours except exterior walls which are nonrated. Fire dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed. 5.6.1.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT No Unit 1 or Unit 2 fire safe shutdown equipment is located within Fire Area WA. 5.6.1.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-90 Revision 30

CPNPP/FPR 5.6.1.5 FIRE LOAD CLASSIFICATION Fire Area WA/Fire Zone WA 103 Fire Loading Summary Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High** Fire Load Classification Low Area 219 Sq. Ft.

            **    See Section 11-5.6.1.4 for protection of this zone.

11-91 Revision 30

CPNPP/FPR 5.6.2 FIRE AREA WB- SERVICE WATER PUMPS 5.6.2.1 LOCATION 5.6.2.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area WB are exterior boundaries and are not rated except the walls and floor separating Fire Area WB from Fire Area WA which are three hour rated. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed. 5.6.2.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 and Unit 2 fire safe shutdown equipment located within Fire Area WB. 5.6.2.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-92 Revision 30

CPNPP/FPR 5.6.2.5 FIRE LOAD CLASSIFICATION Fire Area WB Fire Loading Summary Fire Load Classification Low Area 11,317Sq.Ft. Fire Zone WB104a Maximum Permissible Fire Load 15,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 3,910 Sq. Ft. Fire Zone WB1 04b Maximum Permissible Fire Load 15,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 7,407 Sq. Ft. 11-93 Revision 30

CPNPP/FPR 5.7 UNIT 1 CONTAINMENT BUILDING The Unit 1 Containment Building is separated from other plant buildings by a three hour rated fire barrier. The building is entirely contained in one fire area which is represented by one zone, divided into several subfire zones. The following sections contain the fire hazards analysis for the fire area within the Containment Building. 5.7.1 FIRE AREA CA 5.7.1.1 LOCATION 5.7.1.2 CONSTRUCTION The walls of Fire Area CA are constructed of materials providing an equivalent fire rating of three hours, except exterior walls which are not considered to be rated for the purpose of the FHA Electrical penetration assemblies and the mechanical penetration assemblies are not tested fire seals but are constructed of materials which are noncombustible. Deviation 3b and 3g, (See Appendix C) justify the existence of the non-rated electrical and mechanical penetrations seals in the Containment Building wall. In addition, the personnel and emergency air-locks into the containment are not of fire rated construction. The construction of the air-lock is substantial and of noncombustible materials. Deviation Request 3e, (See Appendix C) justifies the lack of a fire rated door at these locations. The justifications establish that adequate protection is provided for the hazards. 5.7.1.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the fire safe shutdown equipment located within Fire Area CA. 5.7.1.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-94 Revision 30

CPNPP/FPR 5.7.1.5 FIRE LOAD CLASSIFICATION Fire Area CA Fire Loading Summary MPFL Classification High Fire Load Classification Low Area 22,300 Sq. Ft. 11-95 Revision 30

CPNPP/FPR 5.8 YARD AREA The Yard is the exterior area within fifty feet of Unit 1, Unit 2 and Common Buildings containing fire safe shutdown equipment and the Unit 1 and Unit 2 Train A and B electrical duct banks which communicate underground between the Safeguards Buildings and the Service Water Intake Structure. For the Purposes of the Fire Protection Report, the Yard has been considered as one fire area. The following sections contain the fire hazards analysis for the Yard Fire Area. 5.8.1 YARD FIRE AREA 5.8.1.1 LOCATION 5.8.1.2 CONSTRUCTION The walls of the electrical duct banks are constructed of materials providing an equivalent fire rating of three hours. In addition, each unit's Train A and Train B Electrical Duct Banks are separated from each other by a minimum of 2 feet of soil. The manhole covers controlling access to the duct banks are not rated; however, a nonrated barrier FHA evaluation has been performed which justifies the existence of this non-rated feature in the fire barrier. Additionally, administrative controls ensure that only one manhole cover will be removed at a time to mitigate the possibility of a flammable liquid spill draining into the duct banks and damaging redundant fire safe shutdown raceways. For remaining yard areas, boundaries which define the limits of the fire area are established at 50 feet from the exterior walls of Unit 1, Unit 2 and Common Buildings containing equipment, components and raceways necessary to fulfill fire safe shutdown functions. The exterior walls of the buildings are constructed of materials providing an equivalent fire rating of three hours when equipment in the Yard Area represent an exposure hazard to the building. In the case of the Unit 1 main transformers in Fire Zones 128 and 129 and the Unit 2 main transformers in Fire Zones 228 and 229, three hour rated fire barriers are provided between the transformers and the Turbine Building. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed. 11-96 Revision 30

CPNPP/FPR 5.8.1.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 1 and Unit 2 fire safe shutdown equipment located within the Yard Fire Area. 5.8.1.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 5.8.1.5 FIRE LOAD CLASSIFICATION Yard Area Fire Loading Summary Fire Load Classification >High Area 50,161 Sq. Ft. The following is the combustible loading in the Yard Fire Area by fire zone: Fire Zone 127 Maximum Permissible Fire Load BTU/Sq. Ft.* Fire Load Classification >High Area 740 Sq. Ft. Fire Zone 128 Maximum Permissible Fire Load BTU/Sq. Ft.* Fire Load Classification >High Area 1,905 Sq. Ft.

      *Note: MPFL has not been considered for the Yard Areas.

11-97 Revision 30

CPNPP/FPR Fire Zone 129 Maximum Permissible Fire Load BTU/Sq. Ft.* Fire Load Classification >High Area 1,900 Sq. Ft. Fire Zone 130 Maximum Permissible Fire Load BTU/Sq. Ft.* Fire Load Classification >High Area 660 Sq. Ft. Fire Zone 131 Maximum Permissible Fire Load BTU/Sq. Ft.* Fire Load Classification >High Area 928 Sq. Ft. Fire Zone -Gas Cylinder Area Maximum Permissible Fire Load BTU/Sq. Ft.* Fire Load Classification Moderate Area 50 Sq. Ft. Fire Zone - Electrical & Control Building Roof Maximum Permissible Fire Load BTU/Sq. Ft.* Fire Load Classification Low Area 16,665 Sq. Ft. Fire Zone 228 Maximum Permissible Fire Load BTU/Sq. Ft.* Fire Load Classification >High Area 1,905 Sq. Ft. Fire Zone 229 Maximum Permissible Fire Load BTU/Sq. Ft.* Fire Load Classification >High Area 1,900 Sq. Ft. Fire Zone 230 Maximum Permissible Fire Load BTU/Sq. Ft.* Fire Load Classification >High Area 660 Sq. Ft.

Note: MPFL has not been considered for the Yard Areas.

11-98 Revision 30

CPNPP/FPR Fire Zone 231 Maximum Permissible Fire Load BTU/Sq. Ft.* Fire Load Classification Low Area 110 Sq. Ft. Fire Zone 2GBSA Maximum Permissible Fire Load BTU/Sq. Ft.* Fire Load Classification Low Area 25 Sq. Ft. Fire Zone 201 RP Maximum Permissible Fire Load BTU/Sq. Ft.* Fire Load Classification Low Area 5,520 Sq. Ft. Fire Zone YC232 Maximum Permissible Fire Load BUT/Sq. Ft.* Fire Load Classification >High Area 218 Sq. Ft.

Note: MPFL has not been considered for the Yard Areas.

11-99 Revision 30

CPNPP/FPR 5.9 UNIT 2 SAFEGUARDS BUILDING The Unit 2 Safeguards Building is divided into fifteen fire areas. Some fire areas are further divided into fire zones and subzones. The following sections contain the fire hazards analysis for each fire area within the Safeguards Building. 5.9.1 FIRE AREA 2SA - RHR PUMP 5.9.1.1 LOCATION 5.9.1.2 CONSTRUCTION The walls, floors, and ceilings of Fire Area 2SA are constructed of materials providing an equivalent fire rating of three hours, except; exterior walls which are non-rated; the wall separating Fire Area 2SA from Fire Area 2SO which is two hour rated; and five non-rated solid concrete block wall access hatches between Fire Areas 2SA and 2SB on the 831 '-6" elevation. The five access hatches communicate between Fire Zones 2SA 142 and 2SB144. Deviation 3a-1 (2) (See Appendix C) justifies the lack of a three hour rated barrier between the fire areas. The deviation justifications establish that adequate protection is provided for the hazards. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed, except twenty-two mechanical penetrations which are not fire rated. The non-rated mechanical penetrations communicate between Fire Area 2SA and Fire Area 2CA on the 790'-6" and 81 0'-6" elevations. Deviation 3g(2) (See Appendix C) justifies the existence of the non-rated mechanical penetrations. 5.9.1.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 2 fire safe shutdown equipment located within Fire Area 2SA. 5.9.1.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-100 Revision 30

CPNPP/FPR 5.9.1.5 FIRE LOAD CLASSIFICATION Fire Area 2SA Fire Loading Summary Fire Load Classification Low Area 6,603 Sq. Ft. Fire Zone 2SA1A Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 2,033 Sq. Ft. Fire Zone 2SA1 B Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1,179 Sq. Ft. Fire Zone 2SA 1C Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1, 798 Sq. Ft. Fire Zone 2SA1 D Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 398 Sq. Ft. 11-101 Revision 30

CPNPP/FPR Fire Zone 2SA142 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1,195 Sq. Ft. 11-102 Revision 30

CPNPP/FPR 5.9.2 FIRE AREA 2SB- MOTOR DRIVEN AFW PUMP/RHR PUMP 5.9.2.1 LOCATION 5.9.2.2 CONSTRUCTION The walls, floors, and ceiling of Fire Area 2SB are constructed of materials providing an equivalent fire rating of three hours, except exterior walls which are non-rated, and the wall separating Fire Area 2SB from Fire Area 2SA which contains five solid concrete block wall access hatches. The five access hatches communicate between Fire Zone 2SB144 and 2SA142. Deviation 3a-1 (2) (See Appendix C) justifies the lack of a three hour rated barrier between the fire areas. The justifications establish that adequate protection is provided for the hazards. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed, except for non-rated mechanical penetrations and the Containment Air Locks. The twenty-four mechanical penetrations communicate between Fire Area 2SB and Fire Area 2CA. Deviation Request 3g (2) (See Appendix C) justifies the existence of the non-rated mechanical penetrations. The non-rated Containment Air-Lock communicates between Fire Area 2SB and Fire Area 2CA on the 832'-0" elevation. Deviation Request 3e (2) (See Appendix C) justifies the existence of the non-rated air-lock at this location. The deviation justifications establish that adequate protection is provided for the hazards. 5.9.2.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 2 fire safe shutdown equipment located within Fire Area 2SB. 5.9.2.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-103 Revision 30

CPNPP/FPR 5.9.2.5 FIRE LOAD CLASSIFICATION Fire Area 2SB Fire Loading Summary Fire Load Classification Low Area 25,765 Sq. Ft. Fire Zone 2SB2A Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1,695 Sq. Ft. Fire Zone 2SB2B Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1,088 Sq. Ft. Fire Zone 2SB2C Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1,798 Sq. Ft. Fire Zone 2SB2D Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 430 Sq. Ft. 11-104 Revision 30

CPNPP/FPR Fire Zone 2SB2E Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 581 Sq. Ft. Fire Zone 2SB2F Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 606 Sq. Ft. Fire Zone 2SB2G Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Clasification Low Area 843 Sq. Ft. Fire Zone 2SB2H Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 201 Sq. Ft. Fire Zone 2SB4 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 4,831 Sq. Ft. Fire Zone 2SB5 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 406 Sq. Ft. Fire Zone 2SB6 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 364 Sq. Ft. 11-105 Revision 30

CPNPP/FPR Fire Zone 2SB8 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low** Fire Load Classification Moderate Area 4,094 Sq. Ft.

     **     See Section 11-5.9.2.4 for protection of this area.

Fire Zone 2SB14 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 310 Sq. Ft. Fire Zone 2SB15 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 5,257 Sq. Ft. Fire Zone 2SB143 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1,195 Sq. Ft. Fire Zone 2SB144 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 1,195 Sq. Ft. Fire Zone 2SB155 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 233 Sq. Ft. 11-106 Revision 30

CPNPP/FPR 5.9.3 FIRE AREA 2SC- TURBINE DRIVEN AFW PUMP 5.9.3.1 LOCATION 5.9.3.2 CONSTRUCTION The walls, floors, and ceilings of Fire Area 2SC are constructed of materials providing an equivalent fire rating of three hours, except exterior walls which are non-rated. Fire doors, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed. 5.9.3.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a list of the Unit 2 fire safe shutdown equipment located within Fire Area 2SC. 5.9.3.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-107 Revision 30

CPNPP/FPR 5.9.3.5 FIRE LOAD CLASSIFICATION Fire Area 2SC/Fire Zone 2SC7 Fire Loading Summary Maximum Permissible Fire Load 37,300 BTU/Sq. Ft.* MPFL Classification Low Fire Load Classification Low Area 510 Sq. Ft.

This was established based on the combustibles in the zone having the burning characteristics of the "c" time-temperature curve.

11-108 Revision 30

CPNPP/FPR 5.9.4 FIRE AREA 2SD- ELECTRICAL EQUIPMENT ROOM/TRAIN A SWITCHGEAR 5.9.4.1 LOCATION 5.9.4.2 CONSTRUCTION The walls, ceiling and a portion of the floor of Fire Area 2SD are constructed of materials providing an equivalent fire rating of three hours, except for the wall separating Fire Area 2SD from Fire Area 2SM, which is two hour rated, exterior walls and the portion of the floor over unexcavated areas which are non-rated. Fir dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed, except twenty-seven non-rated electrical penetrations and two non-rated watertight doors. The twenty-seven non-rated electrical penetrations communicate between Fire Area 2SD and Fire Area 2CA. Deviation 3b (2) (See Appendix C) justifies the existence of the non-rated electrical penetrations. The watertight doors communicate between Fire Area 2SD and Fire Areas 2SG and 2SI. Deviation 3d (2) (See Appendix C) justifies the lack of a rated fire door at these locations. The deviation justifications establish that adequate protection is provided for the hazards. 5.9.4.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 2 fire safe shutdown equipment located within Fire Area 2SD. 5.9.4.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-109 Revision 30

CPNPP/FPR 5.9.4.5 FIRE LOAD CLASSIFICATION Fire Area 2SD/Fire Zone 2SD9 Fire Loading Summary Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 6,554 Sq. Ft. 11-110 Revision 30

CPNPP/FPR 5.9.5 FIRE AREA 2SE- REMOTE SAFEY RELATED PANELS/TRAIN B SWITCHGEAR 5.9.5.1 LOCATION 5.9.5.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area 2SE are constructed of materials providing an equivalent fire rating of three hours, except exterior walls and ceilings which are non-rated and the walls separating Fire Area 2SE from Fire Area 2SN and Fire Area 2SM, which are of two hour rated construction. Fire dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed, except forty-seven non-rated electrical penetrations and one non-rated watertight door. The forty-seven non-rated electrical penetrations communicate between Fire Area 2SE and Fire Area 2CA on the 831 '-6" and 852'-6" elevations. Deviation 3b (2) (See Appendix C) justifies the existence of the non-rated electrical penetrations. The non-rated watertight door communicates between Fire Area 2SE and Fire Area 2SK on the 852'-6" elevation. Deviation 3d (2) (See Appendix C) justifies the existence of the non-rated door at this location. The deviation justifications establish that adequate protection is provided for the hazards. 5.9.5.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 2 fire safe shutdown equipment located within Fire Area 2SE. 5.9.5.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-111 Revision 30

CPNPP/FPR 5.9.5.5 FIRE LOAD CLASSIFICATION Fire Area 2SE Fire Loading Summary Fire Load Classification Low Area 13,728 Sq. Ft. Fire Zone 2SE16 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 5,105 Sq. Ft. Fire Zone 2SE18 Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 8,623 Sq. Ft. 11-112 Revision 30

CPNPP/FPR 5.9.6 FIRE AREA 2SF- EMERGENCY AIR-LOCK ACCESS 5.9.6.1 LOCATION 5.9.6.2 CONSTRUCTION The walls, floors and ceilings of the Fire Area 2SF are constructed of materials providing an equivalent fire rating of three hours, except for the wall separating Fire Area 2SF from Fire Area 2SO which is two hour rated and the exterior walls and ceiling of Fire Zone 2SF20 which are non-rated. Fire dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed, except one non-rated watertight door, and a non-rated Containment Air-Lock. The non-rated watertight door communicates between Fire Area 2SF and Fire Area 2SK on elevation 873'-6". Deviation 3d (2) (See Appendix C) justifies the existence of the non-rated door at this location. The non-rated Containment Air-Lock communicates between Fire Area 2SF and Fire Area 2CA on elevation 905'-0". Deviation 3e (2) (See Appendix C) justifies the non-rated air-lock at this location. The justifications establish that adequate protection is provided for the hazards. 5.9.6.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT No Unit 2 fire safe shutdown equipment is located within Fire Area 2SF. 5.9.6.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-113 Revision 30

CPNPP/FPR 5.9.6.5 FIRE LOAD CLASSIFICATION Fire Area 2SF Fire Loading Summary Fire Load Classification Low Area 1,077 Sq. Ft. Fire Zone 2SF19 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 751 Sq. Ft. Fire Zone 2SF20 Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 326 Sq. Ft. 11-114 Revision 30

CPNPP/FPR 5.9.7 FIRE AREA 2SG- DIESEL GENERATOR 5.9.7.1 LOCATION 5.9.7.2 CONSTRUCTION The walls, floors, and ceilings of Fire Area 2SG are constructed of materials providing an equivalent fire rating of three hours, except floors over unexcavated areas and exterior walls which are non-rated. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed, except for one non-rated watertight door. The non-rated watertight door communicates between Fire Areas 2SG and 2SD on elevation 81 0'-6". Deviation 3d (2) (See Appendix C) justifies the existence of the non-rated door at this location. The deviation justifications establish that adequate protection is provided for the hazards. 5.9.7.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a list of the Unit 2 fire safe shutdown equipment located within Fire Area 2SG. 5.9.7.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-115 Revision 30

CPNPP/FPR 5.9.7.5 FIRE LOAD CLASSIFICATION Fire Area 2SG Fire Loading Summary Fire Load Classification High Area 3,498 Sq. Ft. Fire Zone 2SG1 OA Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High** Fire Load Classification >High Area 1,884 Sq. Ft.

            **     See Section 5.9.7.4 for protection of this zone.

Fire Zone 2SG1 OB Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 1,614 Sq. Ft. 11-116 Revision 30

CPNPP/FPR 5.9.8 FIRE AREA 2SH- DIESEL DAY TANK ROOM 5.9.8.1 LOCATION 5.9.8.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area 2SH are constructed of materials providing an equivalent fire rating of three hours, except an exterior wall which is non-rated. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed. 5.9.8.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a list of the Unit 2 fire safe shutdown equipment located within Fire Area 2SH. 5.9.8.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-117 Revision 30

CPNPP/FPR 5.9.8.5 FIRE LOAD CLASSIFICATION Fire Area 2SH/Fire Zone 2SH11 Fire Loading Summary Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High** Fire Load Classification >High Area 231 Sq. Ft.

            **     See Section 5.9.8.4 for protection of this zone.

11-118 Revision 30

CPNPP/FPR 5.9.9 FIRE AREA 2SI- DIESEL GENERATOR 5.9.9.1 LOCATION 5.9.9.2 CONSTRUCTION The walls, floors, and ceiling of Fire Area 2SI are constructed of materials providing an equivalent fire rating of three hours, except for floors over unexcavated areas and exterior walls which are non-rated. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed, except one non-rated watertight door. The non-rated watertight door communicates between Fire Areas 2SD and 2SI on elevation 81 0'-6". Deviation 3d(2) (See Appendix C) justifies the existence of the non-rated door at this location. The deviation justifications establish that adequate protection is provided for the hazards. 5.9.9.3 POTENTIALLLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 2 fire safe shutdown equipment located within Fire Area 2SI. 5.9.9.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-119 Revision 30

CPNPP/FPR 5.9.9.5 FIRE LOAD CLASSIFICATION Fire Area 2SI Fire Loading Summary Fire Load Classification High Area 3,498 Sq. Ft. Fire Zone 2SI12A Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High** Fire Load Classification >High Area 1,884 Sq. Ft.

            **     See Section II 5.9.9.4 for protection of this zone.

Fire Zone 2SI12B Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High Fire Load Classification Low Area 1,614 Sq. Ft. 11-120 Revision 30

CPNPP/FPR 5.9.10 FIRE AREA 2SJ- DIESEL DAY TANK ROOM 5.9.10.1 LOCATION 5.9.1 0.2 CONSTRUCTION The wall, floors, and ceiling of Fire Area 2SJ are constructed of materials providing an equivalent fire rating of three hours, except an exterior wall which is non-rated. Fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed. 5.9.10.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 2 fire safe shutdown equipment located within Fire Area 2SJ. 5.9.10.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-121 Revision 30

CPNPP/FPR 5.9.10.5 FIRE LOAD CLASSIFICATION Fire Area 2SJ/Fire Zone 2SJ13 Fire Loading Summary Maximum Permissible Fire Load 240,000 BTU/Sq. Ft. MPFL Classification High** Fire Load Classification >High Area 231 Sq. Ft.

           **     See Section 5.9.1 0.4 for protection of this zone.

11-122 Revision 30

CPNPP/FPR 5.9.11 FIRE AREA 2SK- MAIN STEAM AND FEEDWATER PENETRATION AREA 5.9.11.1 LOCATION 5.9.11.2 CONSTRUCTION The walls, floor, and ceiling of Fire Area 2SK are constructed of materials providing an equivalent fire rating of three hours, except the wall separating fire Area 2SK from Fire Area 2SN which is 2 hour rated and exterior walls and ceiling which are non-rated. Fire dampers, penetration seals, and fire doors have a fire rating equal to the barrier in which they are installed, except four watertight doors, which are not rated and eight mechanical penetration seals, which are not three hour rated. Four non-rated water tight doors are in walls separating Fire Area 2SK from Fire Areas 2SE, 2SN, 2SF and 2SL. Eight mechanical penetrations are installed in a wall separating Fire Area 2SK from 2CA. Deviations 3d(2) and 3g(2) (See Appendix C) justifies the lack of fire rated doors and rated penetration seals. The deviation justifications establish that adequate protection is provided for the hazards. 5.9.11.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 2 fire safe shutdown equipment located within Fire Area 2SK. 5.9.11.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-123 Revision 30

CPNPP/FPR 5.9.11.5 FIRE LOAD CLASSIFICATION Fire Area 2SK Fire Loading Summary Fire Load Classification Low Area 6,337 Sq. Ft. Fire Zone 2SK17A Maximum Permissible Fire Load 1,761 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 3,708 Sq. Ft. Fire Zone 2SK17B Maximum Permissible Fire Load 1,761 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 2,629 Sq. Ft. Fire Zone 2SK17C Maximum Permissible Fire Load 1,761 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 2,629 Sq. Ft. 11-124 Revision 30

CPNPP/FPR 5.9.12 FIRE AREA 2SL- HIGH PRESSURE CHEMICAL FEED ROOM 5.9.12.1 LOCATION 5.9.12.2 CONSTRUCTION The walls, floor and ceiling of Fire Area 2SL are constructed of materials providing an equivalent fire rating of three hours, except the wall separating Fire Area 2SL from Fire Area 2SO which is 2 hour rated and the exterior walls which are non-rated. Fire dampers, penetration seals, and fire doors have a fire rating equal to the barrier in which they are installed, except a water-tight door which is not rated. The watertight door is in the wall separating Fire Area 2SL from Fire Area 2SK. Deviation 3d(2) (See Attachment C) justifies the lack of a fire rated door. The deviation justification establishes that adequate protection is provided for the hazard. 5.9.12.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 2 fire safe shutdown equipment located within Fire Area 2SL. 5.9.12.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-125 Revision 30

CPNPP/FPR 5.9.12.5 FIRE LOAD CLASSIFICATION Fire Area 2SL/Fire Zone 2SLSK1 00 Fire Loading Summary Maximum Permissible Fire Load 80,000 BTU/Sq. Ft. MPFL Classification Low Fire Load Classification Low Area 751 Sq. Ft. 11-126 Revision 30

CPNPP/FPR 5.9.13 FIRE AREA 2SM- STAIRWELL 5.9.13.1 LOCATION 5.9.13.2 CONSTRUCTION The walls, floors, and ceiling of Fire Area 2SM are constructed of materials providing an equivalent fire rating of two hours except exterior walls which are non-rated (See Assumption 3.6). Fire dampers, penetration seals, and fire doors have a rating equal to the boundary in which they are installed. 5.9.13.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT No Unit 2 fire safe shutdown equipment is located within Fire Area 2SM. 5.9.13.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 5.9.13.5 FIRE LOAD CLASSIFICATION Fire Area 2SM/Fire Zone 2SM157 Fire Loading Summary Maximum Permissible Fire Load 160,000 BTU/Sq. Ft. MPFL Classification Moderate** Fire Load Classification High Area 207 Sq. Ft.

            **      See Section 11-5.9.13.4 for protection of this zone.

11-127 Revision 30

CPNPP/FPR 5.9.14 FIRE AREA 2SN- STAIRWELL 5.9.14.1 LOCATION 5.9.14.2 CONSTRUCTION The walls, floors, and ceilings of Fire Area 2SN are constructed of materials providing an equivalent fire rating of two hours (See Assumption 3.6). All fire dampers, penetration seals, and fire doors have a fire rating equal to the boundary in which they are installed, except one watertight door which is located in the wall separating Fire Area 2SN and 2SK which is non-rated. Deviation 3d(2) (See Appendix C) justifies the non-rated construction. The deviation justifications establish that adequate protection is provided for the hazards. 5.9.14.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT No Unit 2 fire safe shutdown equipment is located within Fire Area 2SN. 5.9.14.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 5.9.14.5 FIRE LOAD CLASSIFICATION Fire Area 2SN/Fire Zone 2SN158 Fire Loading Summary Maximum Permissible Fire Load 160,000 BTU/Sq. Ft. MPFL Classification Moderate Fire Load Classification Moderate Area 72 Sq. Ft. 11-128 Revision 30

CPNPP/FPR 5.9.15 FIRE AREA 2SO- STAIRWELL 5.9.15.1 LOCATION 5.9.15.2 CONSTRUCTION The walls and floors of Fire Area 2SO are constructed of materials providing an equivalent fire rating of two hours, except exterior walls and ceiling which are non-rated. Fire dampers, penetration seals, and fire doors have a fire rating equal to the barrier in which they are installed. 5.9.15.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT No Unit 2 potentially failed fire safe shutdown equipment is located within Fire Area 2SO. 5.9.15.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-129 Revision 30

CPNPP/FPR 5.9.15.5 FIRE LOAD CLASSIFICATION Fire Area 2SO/Fire Zone 2S03 Fire Loading Summary Maximum Permissible Fire Load 160,000 BTU/Sq. Ft.* MPFL Classification Moderate Fire Load Classification Low Area 539 Sq. Ft.

This was based on the combustibles in the zone having the burning characteristics of the "C" time-temperature curve.

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CPNPP/FPR 5.10 UNIT 2 CONTAINMENT BUILDING The Unit 2 Containment Building is separated from other plant buildings by a three hour rated fire barrier. The building is entirely contained in one fire area which is represented by one zone, divided into several subfire zones. The following sections contain the fire hazards analysis for the fire area within the Containment Building. 5.10.1 FIREAREA2CA LOCATION 5.1 0.1.2 CONSTRUCTION The walls of Fire Area 2CA are constructed of materials providing an equivalent fire rating of three hours, except exterior walls which are not considered to be rated for the purpose of the FPR. Electrical penetration assemblies and the mechanical penetration assemblies are not tested fire seals but are constructed of materials which are noncombustible. Deviations 3b (2) and 3g (2) (See Appendix C) justify the existence of the non-rated electrical and mechanical penetrations in the Containment Building wall. In addition, the personnel and emergency air-locks into the containment are not of fire rated construction. The construction of the air-lock is substantial and of noncombustible materials. Deviation Request 3e (2) (See Appendix C) justifies the lack of a fire rated door at these locations. The deviation justifications establish that adequate protection is provided for the hazards. 5.1 0.1.3 POTENTIALLY FAILED FIRE SAFE SHUTDOWN EQUIPMENT See Section 111-5.0 for a listing of the Unit 2 fire safe shutdown equipment located within Fire Area 2CA. 5.10.1.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 11-131 Revision 30

CPNPP/FPR 5.10.1.5 FIRE LOAD CLASSIFICATION Fire Area 2CA Fire Loading Summary Maximum Permissible Fire Load (1) Fire Load Classification Low Area 22,300 Sq. Ft. Fire Zone 2CA101A Maximum Permissible Fire Load (1) MPFL Classification High Fire Load Classification Low Fire Zone 2CA 101 B Maximum Permissible Fire Load (1) MPFL Classification High Fire Load Classification Low Fire Zone 2CA 101 C Maximum Permissible Fire Load (1) MPFL Classification High Fire Load Classification Low Fire Zone 2CA 101 D Maximum Permissible Fire Load (1) MPFL Classification High Fire Load Classification Low (1) MPFL for Containment is the actual combustible loading during operations and 240,000 BTU/Sq. Ft. during outage. 11-132 Revision 30

CPNPP/FPR Fire Zone 2CA 101 E Maximum Permissible Fire Load (1) MPFL Classification High Fire Load Classification Low Fire Zone 2CA 101 F Maximum Permissible Fire Load (1) MPFL Classification High Fire Load Classification Low Area Fire Zone 2CA 101 G Maximum Permissible Fire Load (1) MPFL Classification High Fire Load Classification Low Fire Zone 2CA 101 H Maximum Permissible Fire Load (1) MPFL Classification High Fire Load Classification Low (1) MPFL for Containment is the actual combustible loading during operations and 240,000 BTU/Sq. Ft. during outage. 11-133 Revision 30

CPNPP/FPR 5.11 FIRE PROTECTION PUMP HOUSE The Fire Protection Pump House is a remotely located common building. The pump house contains one fire area. This fire area consists of five (5) fire zones. The following sections provide the Fire Hazards Analysis for the Fire Protection Pump House. 5.11.1 FIREAREAFP 5.11.1.1 LOCATION 5.11.1.2 CONSTRUCTION The exterior walls of Fire Area FP are nonrated. The interior walls separating the main fire pumps and the roof assembly are constructed of materials providing an equivalent fire rating of three hours. The fire dampers, penetration seals and fire doors that are installed in the above barriers have a rating equal to the fire barrier in which they are installed. 5.11.1.3 POTENTIALLY FAILED SAFE SHUTDOWN EQUIPMENT No Unit 1 or Unit 2 fire safe shut down equipment is located within this area. 5.11.1.4 FIRE PROTECTION FEATURES FOR FIRE SAFE SHUTDOWN 5.11.1.5 FIRE LOAD CLASSIFICATION Fire Area FP Fire Loading Summary Maximum Permissible Fire Load

Fire Load Classification Low Area 1,757 Sq. Ft.

Fire Zone FP200 Maximum Permissible Fire Load

MPFL Classification Moderate Fire Load Classification Moderate Area 420 Sq. Ft.

             *Note: MPFL has not been considered for the FP Fire Areas.

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CPNPP/FPR Fire Zone FP200a Maximum Permissible Fire Load

MPFL Classification Moderate Fire Load Classification Moderate Area 420 Sq. Ft.

Fire Zone FP200b Maximum Permissible Fire Load

MPFL Classification Low Fire Load Classification Low Area 420 Sq. Ft.

Fire Zone FP200c Maximum Permissible Fire Load

MPFL Classification Low Fire Load Classification Low Area 245 Sq. Ft.

Fire Zone FP200d. Maximum Permissible Fire Load

MPFL Classification Low Fire Load Classification Low Area 252 Sq. Ft.

     *Note: MPFL has not been considered for the FP Fire Areas.

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CPNPP/FPR 6.0 FIRE PROTECTION FEATURES

6.1 INTRODUCTION

The fire protection features installed at CPNPP contribute to the defense in depth concept and aid in the protection of structures, systems, and components important to fire safe shut down, against the effects of fire. The fire protection features are provided to the extent practical as identified in Appendix A of BTP APCSB 9.5-1. The fire protection features section is divided into seven categories: passive features, active features, manual fire suppression, emergency lighting, communications, Reactor Coolant Pump Oil Collection System and NFPA Code Deviations. Passive fire protection features include plant layout, barriers, radiant energy shields, fire rated cable, fire doors, and dampers, penetration seals, explosion prevention, smoke removal, and interior finish. Active fire protection features include automatically and manually actuated fixed fire suppression systems, and the fire detection system. Manual fire suppression systems include standpipe and hose stations, and portable fire extinguishers. The Reactor Coolant Pump lubricating Oil Collection System, Emergency Lighting, Emergency Communication Systems and NFPA Code Deviations are discussed in separate subsections. 6.2 PASSIVE FIRE PROTECTION FEATURES 6.2.1 PLANT LAYOUT Plant layout is the passive fire protection feature which establishes 50 internal and 2 external fire areas. Layout aids in separation of redundant fire safe shut down components and is a contributing factor in assuring equivalent protection to that described in Section 11-4.5. Plant layout also separates equipment, processes, and systems that are inherently hazardous and establishes the location of fire rated barriers which separate fire areas. 6.2.2 FIRE RATED BARRIERS Fire rated barriers are provided to separate fire areas from each other to meet the criteria of Appendix A of BTP APCSB 9.5-1 and Section 11-4.5 of this FHAR, except where justifications for the lack of adequately rated barriers have been provided. Fire barrier deviations are contained in the FSAR Section 9.5.1.6.2. and Appendix C of this FPR. Fire rated assemblies are tested in accordance with ASTM E-119 and are designed in accordance with a U.L. listed or Uniform Building Code design. Walls, floors, ceilings, roofs and their supports (beams, columns or joints) are constructed to have adequate fire resistance for the intended occupancy. In addition, fire areas containing safety related systems or equipment are separated by barriers with ratings commensurate with the hazard identified in the Fire Protection Report Section 11-5.0. All structural elements are composed of noncombustible materials. Structural walls, floors and ceilings consist of either reinforced concrete, concrete block or structural steel framing with precast concrete panels or metal siding. Steel members which form or support wall, floor or ceiling structures are provided with fireproofing material having ratings commensurate with that of the barrier. Where such fireproofing materials are combustible, appropriate heat of combustion values are reflected in the combustible loading calculations for applicable fire areas/fire zones. Interior walls and partitions, 11-136 Revision 30

CPNPP/FPR which are not load bearing and designated as fire barriers are constructed of concrete block or noncombustible steel studs and gypsum drywall, or both. Stairwells outside primary containment serving as access and egress routes, as well as the elevator, are enclosed with barriers having at least a two hour fire rating. Radiant energy shielding is provided in containment where redundant sets of fire safe shut down equipment and components are separated by less than 20' horizontally with negligible intervening combustibles. Radiant energy shielding, called the HEMYC system, is a fire resistant blanket that surrounds the protected electrical cables, raceways, and components. HEMYC blanket consists of a ceramic fiber mat sewn into an envelope of fire resistant fabric using a quartz thread. The envelope is secured to commodities using stainless steel strapping. Justification for the use of HEMYC as radiant energy shielding is provided in Technical Justification I (See Appendix C). One hour wraps and one hour fire rated cables are used outside containment to protect redundant sets of fire safe shut down equipment and components. One hour wrap is water based fire proofing, thermally activated, subliming and insulative coating. When exposed to flame the material volatizes at fixed temperatures; exhibits a small volume increase through formation of a multi-cellular matrix; absorbs and blocks heat to protect the substrate material. Heat of combustion values for one hour wrap are reflected in the combustible loading calculations for applicable fire areas/fire zones. 6.2.3 ONE HOUR FIRE RATED CABLE One hour fire rated rated cable has been qualified to ASTM E-119 test criteria for a fire resistance rating of one hour and may be provided outside of containment for fire safe shutdown power and control circuits where the total integrated radiation dose is less than or equal to 50 MRADS (gamma) over the 40 year plant service life. One hour fire rated cable consists of stranded high temperature nickel-clad conductors and the insulation is composed of a silicone rubber layer and composite mica/ceramic outer layer. The cable is provided with a continuously welded seam corrugated stainless steel sheath. The cable has been tested for operation at a temperature of 1700°F. The cable is also designed to allow wetting down without electrical faulting. Due to its fire resistance characteristics, this cable does not require application of a fire barrier wrap. 6.2.4 INTERIOR FINISH Interior finishes, protective coatings and thermal insulation materials, and suspended ceilings are noncombustible or are listed by a nationally recognized laboratory. Interior finish materials have a flame spread rating less than or equal to 25, or are approved to exceed this limit when installed in a given configuration except as noted in Section 9.5.1.6.2., D.1.d of the FSAR. Interior finish tests are conducted per ASTM E-84 "Standard Test Method for Surface Characteristics of Building Materials" 1976. U.L. subject 992, "Test Method for Measuring the Flame Propagating Characteristics of Flooring and Floor Covering Materials" is used only for vinyl asbestos floor tile. 6.2.5 DAMPERS AND FIRE DOORS Ductwork that penetrates a barrier with a two hour or greater fire rating is equipped with an Underwriter's Laboratories, Inc. labeled fire damper installed in accordance with 11-137 Revision 30

CPNPP/FPR manufacturer's instructions that has a rating at least commensurate with the barrier in which it is installed. Deviations to BTP APCSB 9-5.1, Appendix A for dampers and fire doors installed in an untested configuration are contained in the FSAR Section 9.5.1.6.2. or Appendix C of this FPR. Dampers are equipped with either fusible links or electro-thermal links. Electro-thermal links are provided in areas such as those protected by HALON 1301 extinguishing systems to isolate the ventilation system to maintain the HALON concentration. Fusible links are used in other areas. Fire doors are provided and surveyed and meet the criteria of Section 11-4.5, except where justifications for deviations have been provided. The fire rating of each door is at least commensurate with the rating of the barrier in which it is installed. Fire doors are Underwriters Laboratories, Inc. listed except where justification is provided. In some particular locations the fire doors are normally open to provide air flow paths for tornado venting and high energy line breaks. These doors automatically close in the event of a fire through the release of fusible links or magnetic hold open devices. 6.2.6 PENETRATION SEALS Fire doors and fire dampers are discussed in Section 11-6.2.5. Penetration seals are used to seal openings through interior fire barriers for pipe, conduit, instrumentation, bus ducts, ductwork, and cable trays. Seals provide a fire rating greater than or equal to the barriers in which they are installed except where justifications for deviations have been written. Penetrations in exterior walls provide equivalent ratings to the barrier in which they are installed only when there is a potential exposure fire hazard within 50 feet of the barrier. Penetration seals are qualified by fire test reports which specify their fire resistance rating or are evaluated for an equivalent fire rating. Fire tests are conducted per ASTM E-119 and where applicable, IEEE 634. Cable penetration seals meet the criteria in Appendix A of BTP APCSB 9.5-1. or exceptions have been provided. Deviations from BTP APCSB 9.5-1., Appendix A, exist for penetration seals installed in an un-tested configuration. These deviations are contained in the FSAR Section 9.5.1.6.2. or Appendix C of the FPR. Conduits that penetrate barriers necessary for fire safe shut down and other necessary fire rated barriers are sealed as follows:

1. For conduits which are greater than four (4) inches nominal size, internal seals are installed either at the barrier or on both sides of the barrier at the first opening in the direction of the barrier. These internal seals have fire rating equal to or greater than that of the fire barrier rating.

2. For conduits which are less than or equal to four (4) inches nominal size and automatic suppression (manually actuated suppression for switchgear and adjacent rooms in Unit 2) and detection are provided on both sides of the barrier, internal seals with a fire rating equivalent to that of the barrier are installed in the barrier or at the first opening on either side of the barrier, or gas and smoke seals are installed at the first opening on both sides of the barrier, unless identified and justified in FSAR Section 9.5.1.6.2 or Appendix B of the FPR.

3. For conduits which are less than or equal to four (4) inches nominal size, and 11-138 Revision 30

CPNPP/FPR automatic suppression (manually actuated suppresion for switchgear and adjacent rooms in Unit 2) and detection are not provided on both sides of the barrier, fire seals are installed at the barrier with a fire rating equivalent to that of the barrier, or gas and smoke seals are installed at the first opening on both sides of the barrier unless identified and justified in FSAR Section 9.5.1.6.2 or Appendix B of the FPR. Spare conduits: Spare conduits were tested in accordance with ANI acceptance criteria and not ASTM E-119. Deviation 14, (See Appendix C) justifies the alternate testing method. Structural seals: Seismic gaps between buildings and construction components are sealed to give a fire resistance rating commensurate with the barrier in which it is installed. Structural seals are designed, qualified and documented by testing, or are evaluated for equivalent rating. Testing is conducted per ASTM E-119. Hatches: Hatches are provided in certain areas to provide access to equipment. In areas where hatches are located in a rated fire barrier, the rating of the hatches is justified in the FSAR Section 9.5.1.6.2. Concrete and metal hatches are located in fire barriers. Metal hatches are coated with a fire resistive material to provide a rating commensurate with the fire barrier rating. 6.2.7 EXPLOSION PREVENTION Safety related battery rooms have HVAC systems that are designed to maintain hydrogen levels below two per cent by volume. Each battery room has air flow monitors that alarm in the Control Room to alert operators to a loss of ventilation situation. 6.2.8 SMOKE REMOVAL Smoke removal is achieved through the use of portable smoke ejectors and natural ventilation. Directions for approach, placement and routing of the ejector trunk are profiled in the fire protection pre-plans. The information is based on the Smoke Removal Study. Primary smoke removal is accomplished using electric smoke ejectors, while backup smoke ejection is accomplished using gas powered smoke ejectors. Products of combustion are evaluated by Health Physics to determine whether or not the radiation level is within the allowable limits. If the products of combustion have an acceptable radiation level, smoke ejection may proceed. If the radiation level of the smoke is not acceptable, one of the following actions must be taken: The smoke is contained in the fire area and allowed to decay until it is below the acceptable radiation limit. Smoke is then released directly to the atmosphere. The smoke is passed through the atmospheric cleanup units before it is released to the atmosphere. Smoke control venting in the Turbine Building is accomplished by power venting of the mezzanine level using twelve 75,500 cfm exhaust fans. Ventilation is also possible using eight 50,000 cfm roof mounted exhaust fans and four inlet louvers for makeup air. 11-139 Revision 30

CPNPP/FPR Basement venting occurs through natural draft rising up through gratings and equipment hatches. 6.3 ACTIVE FIRE PROTECTION FEATURES 6.3.1 FIRE DETECTION SYSTEM A station fire alarm signaling system has been provided. The fire alarm signaling system contributes to the defense in depth concept by detecting any postulated fire in a safety related area. The system consists of local smoke, heat, and flame detectors strategically placed throughout the plant. Fire detectors in a given area are tied into local control panels. The local control panels exist throughout the plant and tie into the main control panel and sequential events recorder. Automatic fire detection is provided in accordance with Appendix A of BTP APCSB 9.5-1 and Section 11-4.5. Fire Hazards Analysis Evaluations are provided which establish that adequate protection is provided for the hazards and the level of protection provided is equivalent to the criteria of Section 11-4.5. (See FPR Appendix B, FHA Evaluation Matrix). The fire detection system is in accordance with NFPA 72D 1975 ed., and the placement of fire detectors is in accordance with the guidelines of NFPA 72E 1978 ed., except where special conditions do not permit such as the atmospheric cleanup units (A.C.U.'s). In such cases, a registered professional fire protection engineer located the detectors on the basis of engineering judgement except in atmospheric cleanup units in which the manufacturer has designed and installed detection in accordance with ANSI 509 which meets the criteria of Regulatory Guide 1.52. Upon activation of any fire water flow or valve monitor signal initiating device circuit, the proper functions occur as follows: A During manual fire alarm, area or duct smoke detection, heat detection, flame detection, waterflow device or HALON system activation:

1. Zone indicator lamps illuminate at the local and main control panels.

2. Fire alarm audible signaling occurs at the local and main control panels.

3. The main control panel sequential events recorder records status changes.

B. If a trouble situation occurs on any of the signal circuits for the above devices, such as a circuit open or ground, then the following takes place:

1. Zone trouble lamp on the fire protection local panel illuminates. Also, a common trouble lamp for the local fire protection panel illuminates on the panel.

2. A local fire protection panel trouble lamp on the main control panel 11-140 Revision 30

CPNPP/FPR illuminates.

3. A trouble audible alarm signal activates on both the fire protection local and main control panels.

4. The sequential events recorder records event status change at the main fire protection control panel.

The fire detection system uses the on-site primary generators (1 G and 2G) or off-site power as its primary power source. Diesel generators serve as the back-up power supply. 6.3.2 WATER SUPPLIES The Fire Protection Water Supply System capacity was designed using NFPA 13 and BTP APCSB 9.5-1. Appendix A as guidance. The capacity is based on supplying water to the largest fixed extinguishing system and the necessary adjacent hose stations with the shortest portion of the fire protection yard-loop out of service. Two dedicated, 100 percent capacity, atmospheric fire water storage tanks are provided to supply water to the Fire Protection Water Supply System. Each storage tank has a nominal capacity of 524,500 gallons. The tanks are interconnected to facilitate suction from either or both tanks. Refill capability with a separate pump which takes suction from the Safe Shut down Impoundment (SSI) is provided to allow either tank to be refilled within 8 hours after using its contents to extinguish a fire. 6.3.3 FIRE PUMPS Fire pumps are provided to supply the water demand for fire protection. The fire pumps are designed and installed per NFPA 20, 1983 ed. Three 50% capacity pumps are provided. The pumps are each rated to deliver the necessary water flow and pressure to the largest fixed suppression system and adjacent hose stations with the shortest portion of the yard loop out of service. Fire pump connections to the underground distribution loop are separated by approximately 15 feet and are located outside the Fire Pump House. Each fire pump has its own prime movers, power supply, and controller. One fire pump is driven by an electric motor while the other two are diesel engine driven. The pumps are located in separate rooms divided by a three hour fire rated barrier. Alarms initiated by fire pump functions which annunciate locally, in the Fuel Building, and in the Control Room on the main fire detection panel, are provided as follows: Diesel fire pump operating for each diesel. Diesel fire pump engine failure to start for each diesel. Diesel fire pump switch not in "auto" position for each diesel. Diesel fire pump fuel oil level low. 11-141 Revision 30

CPNPP/FPR Electric motor driven fire pump operating. Electric motor driven fire pump switched to "off" position or loss of line power. Jockey pump failure alarm. Jockey pump extended run time. 6.3.4 DISTRIBUTION SYSTEM The water distribution system is designed to supply water through an underground yard main looped piping network. The yard main loop circles the entire plant and was designed using NFPA 24 "Private Fire Service Mains" as a guideline. Cement lined ductile iron piping is used for the distribution network. Fire hydrants are provided throughout the plant yard at an average of 300 feet. Each hydrant can be isolated from the yard loop by a key operated (curb box) auxiliary gate valve. Post indicator valves are installed on the main loop and each branch connection extending off the loop, except where justification for deviations have been prepared. Valving is arranged such that sections of the distribution network can be isolated in the event of pipe failure or the need for maintenance, without interrupting the entire water supply. Valves in the Fire Protection Water System are electrically supervised in accordance with NFPA 26, "Supervision of Valves", or administratively controlled using procedures. 6.3.5 FIXED FIRE SUPPRESSION SYSTEMS Fixed fire suppression systems are installed throughout the plant to meet the criteria of Appendix A of BTP APCSB 9.5-1. and Section 11-4.5. Fire Hazards Analysis Evaluations are provided which establish that adequate protection is provided for the hazards and the level of protection provided is equivalent to the criteria of Section 11-4.5. (See FPR Appendix B, FHA Evaluation Matrix). Fixed automatic water suppression systems comply with either NFPA 13, 1978 and 1985 editions or NFPA 15, 1979 edition except where identified in Section 11-6.8. Fixed manual and automatic HALON suppression systems are installed using NFPA 12A (1980 edition) with concentration in accordance with those suggested in NFPA 12A. The types of fixed fire suppression systems installed in the plant are: automatic wet-pipe sprinkler systems, manually actuated preaction sprinkler systems, automatic water spray systems, manually actuated water spray systems, automatic preaction sprinkler systems, manually actuated deluge sprinkler system, manual and automatic total flooding HALON systems. Automatic wet-pipe sprinkler systems are installed in plant areas to provide floor area and concentrated cable tray coverage except for the Electrical Equipment Rooms, Cable Spreading Rooms and the Containment Buildings. Manually actuated preaction sprinkler systems are installed to provide floor area and/or concentrated cable tray coverage in the Electrical Equipment Rooms and Cable 11-142 Revision 30

CPNPP/FPR Spreading Rooms which contain safety related equipment that could be damaged by inadvertent water sprays. With the exception of the pre-access filtration units there are no fixed suppression systems installed inside the Containment Buildings. Automatic Preaction Sprinkler Systems are installed in each of the Diesel Generator Fuel Oil Day Tank Rooms. Automatic open head water spray systems are installed to provide protection to specific hazards, which necessitate the application of directional water impingement. Manual open head water spray systems are installed in specific areas to provide protection for specific hazards. Automatic total flooding HALON 1301 suppression systems are designed and installed using NFPA 12A 1980 edition as guidance and are provided as primary protection in the Cable Spreading Rooms. HALON concentrations are in accordance with suggested concentrations as discussed in NFPA 12A. HALON systems in the Cable Spreading Rooms are activated by a detection system provided with Class "A" supervision. In the Cable Spreading Room, the HALON 1301 systems are backed up by manually actuated preaction sprinkler systems. With the exception of manufacturer designed and installed water spray systems in the atmospheric cleanup units, fixed fire suppression systems consist of an indicating control valve, water flow pressure switch, deluge valve, swing check valve or alarm check valve, a hydraulically balanced piping network, and open or closed heads, accordingly. 6.3.6 INADVERTENT OPERATIONS Evaluations have been performed to demonstrate the ability to maintain fire safe shut down capability in the event of an inadvertent actuation of a suppression system or hose stream damage to equipment during fire fighting. The evaluations determined that inadvertent actuation of an automatic suppression system does not impair fire safe shut down capability. Measures have been taken to prevent a fire fighter from inadvertently damaging fire safe shut down capability from hose stream damage. 6.4 MANUAL FIRE SUPPRESSION EQUIPMENT Manual fire suppression equipment is provided to meet the criteria of Appendix A of BTP APCSB 9.5-1. and Section 11-4.5., except where justification for deviations has been provided. Standpipe and hose stations have been designed and installed using NFPA 14, 1978 ed.,

     "Standpipe and Hose Stations" as guidance. Deviations to NFPA 14 are identified in Section 11-6.8. of this FPR. Interior hose stations reach safety related locations in the plant with at least one hose stream. Standpipes with hose stations are equipped with a shutoff valve at the base of each rise, 100 feet 1-1/2 inch woven jacket lined fire hose and a fog nozzle.

11-143 Revision 30

CPNPP/FPR Hose houses are equipped with hose and combination nozzles, as well as other fire fighting accessories. They are provided for protection of the enclosed equipment and located adjacent to fire hydrants such that exterior areas of the plant can be reached with an effective hose stream. Portable fire extinguishers are provided in accordance with NFPA 10, 1981 ed. Portable extinguishers are provided commensurate with the hazards they are provided to protect. 6.5 REACTOR COOLANT PUMP LUBRICATING OIL COLLECTION SYSTEM The Unit 1 and Unit 2 Reactor Coolant Pump Lubricating Oil Collection Systems are designed and installed so that failure does not result in an unacceptable interaction with safety related structures, systems and components. Each reactor coolant pump is equipped with a lubricating oil collection system that is designed and installed to meet the criteria of Appendix A of BTP APCSB 9.5-1 and Section 11-4.5., except where justifications for deviations have been written. Each system is capable of collecting lubricating oil from potential pressurized and unpressurized leak points. Leakage is collected and drained to a vented closed collection tank sized to contain the entire pump capacity. 6.6 EMERGENCY LIGHTING Emergency lighting is provided to meet the criteria of Appendix A of BTP APCSB 9.5-1, except as in Deviation 10 [Reference Appendix C] which justified the lack of DC emergency 8 hour battery pack lighting in the Control Room. DC emergency 8 hour battery pack lighting is provided at fire safe shut down equipment for operator action(s) and their respective access and egress routes during hot standby or hot shut down; except for the Control Room where DC emergency lighting is provided and power supplied from remote 8 hour battery power sources. Battery powered sealed beam portable hand lights are provided for emergency use. 6.7 EMERGENCY COMMUNICATION SYSTEM A comprehensive intraplant communication system is provided to ensure two way voice communication vital to fire safe shut down and emergency response in the event of a design basis fire. A portable radio communication system is provided for use by the fire brigade and the plant operators to coordinate manual actions during a fire. As secondary methods of communication, the plant GAl-Tronics system or other communications systems are available. The portable radio communication system includes hand held portable radios which are powered by rechargeable batteries. This system includes fixed repeaters with redundant repeaters physically separated to limit the possibility of damage to both sets due to a single fire. In the event the comparator and/or combiner of the radio repeater system is lost, the GAI-Tronics system is available. The "talk around" feature of the portable radios can be used by the Fire Brigade, with a limited range, during a loss of both the GAl-Tronics system and the repeater system. 11-144 Revision 30

CPNPP/FPR The combination of the portable radio system, the plant GAl-Tronics system or other plant communication systems provide the necessary communication vital to fire safe shut down and emergency response in the event of fire. The intra-plant emergency public notification is provided through the use of the GAl-Tronic Paging System. A multi-functional tone generator, connected to the paging system provides the annunciation of the fire alarm when activated by the shift supervisor. As an addition, announcements may be made via this paging system. In areas where the fire alarm cannot be heard, visual alarm in the form of rotating beam lights is provided. A local audible alarm is used as a backup in the event of an evacuation of the Control Room if fire damages the GAI-Tronics system. During this event, communication is provided through the use of the two way portable radio repeater system. The plant-to-off-site emergency public notification system is provided through the use of the normal or dedicated telephone lines or the hi-band radio (CAS/SAS). The notification of the necessary public officials and off-site support personnel in the event of an emergency is achieved at CPNPP. 6.8 CODE DEVIATIONS The following is a list of deviations from the applicable codes and standards listed in 11-7.1 for systems and equipment installed in safety-related areas. Section 6.8.3 lists those codes and standards for which compliance has been demonstrated by separate supporting evaluation. Minor code deviations have been identified and documented with suitable justification provided accordingly within these evaluations. 6.8.1 NFPA 131NSTALLATION OF SPRINKLER SYSTEM Code Deviations Description Section 2-1 The preaction systems in the electrical equipment rooms and the Cable 1978 Edition Spreading Room necessitate manual activation, therefore an automatic water supply is not available. Applicable to both Units 1 and 2). Justification: Manual actuation only is provided due to the concern that accidental water discharge may damage safety-related electrical equipment in the area. Sections 3-13.3 Bushings are commonly used in place of available reducing fittings in the 1978 & 1985 sprinkler systems. (Applicable to both Units 1 and 2). Editions Justification: The fittings which use bushings to reduce the size of openings need not be replaced with standard reducing fittings. The main concern for using bushings is that they have a greater tendency to leak, especially during hydrostatic testing of the system. Since the systems have been hydrostatically tested in accordance with the code (no visible sign of leakage allowed), leakage after turnover of a system is not expected to be a concern. 11-145 Revision 30

CPNPP/FPR Section 4-4.11 Sheet metal covers placed over a number of cable trays which do not 1978 & 1985 permit direct spray impingement by suppression nozzles on the cables. Editions (Applicable to both Units 1 and 2). Justification: The sheet metal covers are installed either to eliminate electromagnetic interference for level 4 cable trays or for electrical separation per Reg. Guide 1.75. The sprinkler protection provided is effective in controlling a fire originating in a cable tray and keeping it from spreading to other cable trays in the area. Section 4-4.11 Automatic sprinklers are not installed beneath open grating walkways over 4 feet in width in the Feedwater Isolation and Main Steam Penetration Rooms. (Applicable to both Units 1 and 2). Justification: The existing automatic sprinkler protection at the ceiling level provides adequate coverage without installing sprinklers under the walkways. The only combustible loading in these rooms is the minor amount of lube oil contained in the feedwater and main steam isolation valves. These valves are located near the center of the rooms, away from the walkways and the ceiling sprinklers will provide unobstructed spray coverage. Additionally, the openings in the grating are of sufficient size to allow effective penetration of sprinkler water spray to adequately protect areas under the walkways. Designation of these areas as "No Storage" areas and associated administrative controls ensure the walkways will not be used for storage of materials that could affect sprinkler discharge. Section 4-4.13 Sprinkler systems installed in the Cable Spreading Room (Rooms 133 1978 Edition and 134) have sprinklers installed at the ceiling level only. There are numerous obstructions requiring sprinkler installation beneath to comply with the code. (Applicable to both Units 1 and 2). Justification: Two (2) manually actuated preaction sprinkler systems provide back up suppression capability to automatic HALON 1301 total flooding systems installed in each Cable Spreading Room. The sprinkler systems are installed at the ceiling level only. The sprinkler systems employ a conservative hydraulic design equivalent to an NFPA 13 occupancy classification of extra hazard. A fire in such an occupancy is postulated to exhibit rapid development with a high rate of heat release. Such a fire is not postulated to occur in the cable spreading rooms. The rooms contain negligible in-situ floor level combustibles and administrative controls effectively limit transient combustibles. The major fire hazard is exposed IEEE-383 cabling. Overhead cable trays are installed a minimum of seven feet above the floor. Therefore, given the cable tray arrangement, lack of floor based combustibles and the density of water application the sprinkler systems are designed to deliver, the installation of sprinkler systems at the ceiling level results in a high level of protection in the cable spreading rooms that is adequate for the hazards in the area. 11-146 Revision 30

CPNPP/FPR Section 4-4. Automatic sprinklers are not installed inside a trench below the Unit 2 4.3(b) Safeguards Building 81 0'-6" corridor in Fire Zone 2SB8. The trench 1978 Edition measures 8-10" wide by 3'-0" deep and contains piping, conduit and two 12" wide cable trays with exposed cabling. (Applicable to Unit 2 only). Justification: Sprinkler protection is not required in the trench due to the reinforced concrete construction and negligible combustible material which consists of a minor amount of exposed IEEE-383 cabling. The combustible loading from the cabling results in a fire duration of approximately 3 minutes. The cables are not required for fire safe shutdown for a postulated fire in Fire Area 2SB. Steel plate access panels are provided as covers for the trench. Complete automatic sprinkler and detection system coverage is provided throughout the corridors both above and below the trench. In addition, hose stations and portable fire extinguishers are provided throughout the fire area for use by the fire brigade in manual fire fighting activities. Section 7-1.2 Hydraulic placards have not been provided at system valve assembly 1978 & 1985 locations. (Applicable to both Units 1 and 2). Editions Justification: The intent of the code criteria for placards is to preclude a change in occupancy overwhelming an existing sprinkler system. This is not applicable at CPNPP given the inherent control of combustible materials and loading for any given area. 6.8.2 NFPA 14- STANDPIPE AND HOSE SYSTEMS Code Deviations Description Section 3-2.2 The number of hose stations for Class II service in each building divided 1978 Edition by fire walls are not sufficient to ensure that all portions of the building are within 30 feet of a nozzle when attached to not more than 100 feet of hose. (Applicable to both Units 1 and 2). 11-147 Revision 30

CPNPP/FPR Justification: Those portions of safety related buildings that are not within 30 feet of a nozzle when attached to 100 feet of hose are listed below. No structures, systems or components necessary for fire safe shut down are located in any of the building areas which exceed allowable travel distances. Portable fire extinguishers that meet the travel distance stipulations of NFPA 10 are provided for each area. Combustible loading in each area is negligible and adequate automatic ionization smoke detection is provided to alert fire brigade personnel. In addition an additional length of fire hose is provided at each of the hose stations listed below which provides the coverage for the respective areas listed below. The hose station inspection procedure assures that the required additional length of fire hose is maintained at each of the respective hose stations. Sufficient water pressure is available in each case for utilization of the fire hose. FA/FZ Room FA/FZ Room SF20 1-111 AA21f x-239 2SF20 2-111 AA21f x-240 AA21d x-211 AA21g x-243 AA21f x-217 WB104b x-277 AA21f x-234 AA21f x-238 HOSE STATION CP1-FPFESH-19 CPX-FPFEXH-1 0 CP2-FPFESH-19 Section 6-2.2 In some instances, valves are not provided to permit isolating a standpipe 1978 Edition riser without interrupting the supply to other risers (Applicable to both Units 1 and 2.). Justification: The intent of this code section is met by the compensatory measures which require that an alternate source of hose station coverage be provided when one or more hose stations is inoperable. 6.8.3 OTHER CODES AND STANDARDS Compliance with the following codes and standards has been assessed by separate supporting FHA Evaluations (see Sec. 1.2.17), including deviations and corresponding justifications: 11-148 Revision 30

CPNPP/FPR

1. NFPA 10, 1981 Edition, "Portable Fire Extinguishers". (Applicable to both Units 1 and 2).

2. NFPA 12A, 1980 Edition, "Halon 1301 Fire Extinguishing Systems". (Applicable to both Units 1 and 2.

3. NFPA 20, 1983 Edition, "Standard for the Installation of Centrifugal Fire Pumps".

(Applicable for Units 1 and 2).

4. NFPA 720, 1975 Edition, "Standard for the Installation, Maintenance and Use of Proprietary Signaling Systems". (Applicable to both Units 1 and 2).

5. NFPA 72E, 1978 Edition, "Standard on Automatic Fire Detectors". (Applicable to both Units 1 and 2).

11-149 Revision 30

CPNPP/FPR 7.0 CODES AND STANDARDS 7.1 COMPLIANCE CODES AND STANDARDS Listed below are the codes and standards applicable to CPNPP. The year following the code and the edition of the code or standard, if applicable, is listed .. NFPA 10 -1981, "Portable Fire Extinguishers" NFPA 13 -1978 "Automatic Sprinkler Systems"

                   & 1985, NFPA 15        -1979,         "Water Spray Fixed Systems" NFPA 20        -1983,         "Centrifugal Fire Pumps" NFPA49         -1975,         "Hazardous Chemical Data" NFPA 72D       -1975,         'Proprietary Protective Signaling Systems" NFPA 72E       -1978,         "Automatic Fire Detectors" NFPA 72        -1999,         "National Fire Alarm Code"*

NFPA 80 -1977, "Fire Doors and Windows" IEEE 383 -1974, "IEEE Standard for Type Test of IE Electric Cables, Field Splices, and Connections" IEEE 634 -1978, "IEEE Standard Cable Penetration Fire Stop Qualification Test" UL Subject 992, "Test Method for measuring the Flame Propagating Characteristics of floor and Floor Covering Materials" ASTM E-84 -1976, "Surface Burning Characteristics of Building Materials" ASTM E-119 -1976, Fire Test of Building Construction and Materials" NEL-PIA guideline titled "Basic F.P. for Nuclear Power Plants" (1976) Underwriters "Building Materials Directory" Laboratories effective edition at time of design (U.L.) Procurement

The 1999 edition of NFPA 72 applies only to periodic functional testing of fire detectors and supervised circuits presented in Section IV.

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CPNPP/FPR 7.2 GUIDANCE CODES AND STANDARDS NFPA4 1977, "Organization for Fire Services" NFPA4A -1969, "Organization for a Fire Department" NFPA6 -1974, "Industrial Fire Loss Prevention" NFPA 7 -1974, "Management of Fire Emergencies" NFPA8 -1974, "Management Responsibilities for Effects of Fire on Operations" NFPA12A -1980, "HALON 1301 Fire Extinguishing Systems" NFPA 14 -1978 "Standpipe and Hose Systems" NFPA 22 -1985 "Water Tanks for Private Fire Protection" NFPA24 -1973, "Outside Protection" NFPA 25 -1998, "Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems" NFPA26 -1976, "Supervision of Valves" NFPA 27 -1975, "Private Fire Brigades" NFPA 30 -1984, "Flammable Combustible Liquid Code" NFPA 50a -1973, "Gaseous Hydrogen Systems" NFPA69 -1973, "Explosion Prevention Systems" NFPA 70 -1987, "National Electrical Code" NFPA 90A -1999, "Installation of Air-Conditioning and Ventilating Systems"

8.0 REFERENCES

8.1 REGULATORY DOCUMENTS

1. 10CFR50, Appendix A, "Licensing of Production and Utilization Facilities, General Design Criterion 3, Fire Protection.

2. Branch Technical Position APCSB 9.5-1., Appendix A, "Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to 1976."

3. 10 CFR 50, Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979."

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CPNPP/FPR COMANCHE PEAK NUCLEAR POWER PLANT FIRE PROTECTION REPORT SECTION Ill UNIT 1 AND UNIT 2 FIRE SAFE SHUTDOWN ANALYSIS REPORT 111-1 Revision 30

CPNPP/FPR TABLE OF CONTENTS SECTION Ill SUBJECT PAGE

1.0 INTRODUCTION

3 1.1 Purpose 3 1.2 Scope 3 1.3 Overview 3 2.0 REGULATORY REQUIREMENTS 4 3.0 ANALYSIS BASES AND INFORMATION REQUIREMENTS 4 3.1 Fire Safe Shutdown Assumptions 5 3.1.1 Manual Operations and Repairs 6 3.1.2 Post-Fire Plant Equipment Capability 6 3.1.3 Associated Circuits of Concern 7 3.1.4 Manpower Availability and Manual Operations 10 4.0 FIRE SAFE SHUTDOWN ANALYSIS METHODOLOGY 11 4.1 Overview 11 4.1.1 Fire Safe Shutdown Plant Configuration Methodology 11 4.2 Fire Safe Shutdown Plant Configuration 12 4.2.1 Fire Safe Shutdown Performance Goals 12 4.2.2 Component Functional Operability Status Categorization 14 4.2.3 Fire Safe Shutdown Transient Analysis 16 4.2.4 High/Low Pressure Interface Analysis 17 4.2.5 Common Power Supply Cables 17 4.3 CPNPP Fire Safe Shutdown Criteria 17 4.3.1 Fire Area Compliance Mechanisms 17 4.3.2 Alternative Shutdown Capability (Fire in the Control Room, One of the Spreading Rooms or in the Control Room-HVAC Mechanical Equipment Room) 18 5.0 FIRE SAFE SHUTDOWN EQUIPMENT LIST 24

6.0 REFERENCES

67 111-2 Revision 30

CPNPP/FPR

1.0 INTRODUCTION

1.1 PURPOSE The purpose of the Fire Safe Shutdown Analysis Report (FSSAR) is to present the analysis of the fire safe shutdown capability for Comanche Peak Nuclear Power Plant (CPNPP) in accordance with the guidelines outlined in Appendix A to Branch Technical Position ABCSB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants" docketed prior to July 1, 1976 (referred to as Appendix A, henceforth). The Fire Safe Shutdown Analysis (FSSA) is performed to: (1) Determine the impact of a fire in any location in the plant on the ability to safely shut down the reactor and limit releases of radioactivity. (2) Specify the minimum equipment and capability required for each fire area to meet the identified fire safe shutdown performance goals. 1.2 SCOPE The scope of this document includes the regulatory criteria and operating license commitments pertaining to the FSSA, the analysis bases and supporting information, the CPNPP plant configuration for fire safe shutdown, the analysis methodology, and a summary of the important analysis results that establish the design for CPNPP Fire Safe Shutdown. 1.3 OVERVIEW The design basis for CPNPP fire safe shutdown capability in the event of a fire includes an extensive set of engineering considerations and detailed analyses. This overview summarizes the steps used in analyzing the plant configuration as it relates to fire safe shutdown capability in order to document compliance with applicable regulatory criteria. Under the provisions of 10CFR50.48, CPNPP is required to establish a fire protection program that, among other things, provides " ... the means to limit fire damage structures, systems, or components important to safety so that the capability to safely shut down the plant is assured." Performing the FSSA requires the establishment of certain analysis basis. The fundamental basis for the FSSA is that a single fire occurs in any plant area coincident with a 72-hour loss of off-site power. However, off-site power is conservatively assumed to be present for those situations where availability of off-site power could adversely impact fire safe shutdown. Section 111-3.0 outlines the details for other bases established for the FSSA. The methodology for performing the FSSA is described in Section 111-4.0; it consists of establishing the plant configuration for fire safe shutdown and then performing a fire area separation analysis using automated routines. The tasks required to develop the plant configuration baseline for the FSSA are to establish the performance goals for fire safe shutdown, identify the functions required and the systems that need to be available to 111-3 Revision 30

CPNPP/FPR achieve them, and to determine the equipment, cables and associated circuits that are required by or affect those systems. Understanding the network of interdependence among these various elements that comprise the plant configuration is the key to the development of the Boolean Logic statements used by the analysis routines in performing the automated portion of the FSSA. The CPNPP Electronic Data Management System (EDMS) uses various databases that function as an integrated system in performance of the FSSA. The FSSA routines of EDMS extract data from these databases to construct the configuration data that represents the plant's capability to achieve safe shutdown in response to a damaging fire in a fire area. The analysis routines of EDMS are programmed to determine the entire cascade of effects resulting from a fire in a particular plant area. The automated portion of the FSSA consists of a series of calculations that evaluate the impact of the loss of unprotected cables or components on the achievement of the fire safe shutdown performance goals. These cables or components are either destroyed by fire or are dependent on components or cables damaged by fire. The process continues until the full effect of a fire in each area has been determined. For those fire areas where the analysis indicates that the required fire safe shutdown functions cannot be accomplished with the resulting plant configuration, an examination of the results of the FSSA is conducted to determine other possible redundant components, or smaller areas (e.g., zones) for analysis. For these areas that contain required redundant fire safe shutdown components, one or more of the separation means identified in Section 11-4.5 is provided, which may be augmented with manual operations. A shutdown is postulated for each unit operation when fire safe shutdown equipment and/ or cabling unique to each unit and/or common to each unit, is physically located within the same fire area. In the special case of a significant fire in the Control Room, the respective unit's Cable Spreading Room or the Control Room-HVAC Mechanical Equipment Room, personnel evacuate the Control Room and Carry out fire safe shutdown procedures from local stations and the Hot Shutdown Panel associated with each unit. Procedures for control of the plant from the Hot Shutdown Panel requires a coordinated sequence of manual operations described in Section 111-4.3.2, on "Alternative Shutdown". 2.0 REGULATORY REQUIREMENTS See Section 11-4.5. 3.0 ANALYSIS BASES AND INFORMATION REQUIREMENTS The FSSA considers the effects of fire on plant equipment and identifies methods for achieving safe shutdown. The fundamental basis for this analysis is that a single fire occurs in any plant area coincident with a 72-hour loss of off-site power. Equipment normally present in the plant is assumed to be functional at design capability and available for use in fire safe shutdown and may be lost only as a result of fire damage or the loss of off-site power. Other external events, accidents or failures are not assumed to 111-4 Revision 30

CPNPP/FPR occur concurrently with the postulated fire or any subsequent activities to achieve cold shutdown conditions. 3.1 FIRE SAFE SHUTDOWN ASSUMPTIONS The FSSA performed for the CPNPP design assessment employs the following assumptions: The unit(s) is/are operating at 100% power and equilibrium xenon conditions (end of core life) at the onset of the fire. The unit(s) is/are tripped (i.e., reactor and turbine) during the course of a fire. Neither unit takes credit for the other unit providing system support in order to achieve and maintain safe shutdown. Total loss of off-site power occurs (with reactor coolant pump trip) during the course of a fire, and is restored 72 hours later. Independent failures or single failures (i.e., failures that are not a direct consequence of fire damage) of systems, equipment, active or passive components, instrumentation, controls, or power supplies, do not occur before, during or following a fire. No abnormal system transients or behavior, or design basis accidents, precede the onset of the fire; nor do any of these events, that are not a direct consequence of fire damage, occur during or following a fire. Independent damaging external events (i.e., another separate fire, an earthquake, flooding, lightning, tornadoes or other severe weather, an act of sabotage, etc.) do not occur before, during or following a fire. The Reactor Protection System and the associated reactor trip breakers are designed to be fail-safe, so the FSSA takes credit for the automatic trip function. A manual back-up action, consisting of the operator manually tripping the reactor and manually tripping the turbine in the Control Room is also assumed. The "worst case" fire-induced plant transient considers the following for a fire in any single CPNPP fire area: (a) the loss of all automatic function (signal, logic) from the circuits located in the fire area in conjunction with one worst case spurious actuation or signal; and (b) spurious actuation of the redundant valves in any one high/low pressure interface line. 111-5 Revision 30

CPNPP/FPR 3.1.1 MANUAL OPERATIONS AND REPAIRS The FSSA is subject to the following analysis bases regarding manual operations and repairs: Manual operations are allowed to achieve hot standby following a reactor trip and to maintain hot standby conditions. Credit is not taken for repair procedures to achieve hot standby conditions. Manual operations, repairs and temporary modifications are allowed in order to perform the transition from hot standby to cold shutdown and to maintain cold shutdown, as long as transition to cold shutdown can be initiated within 72 hours after the tripping of the unit or, for alternate shutdown, cold shutdown is achieved within 72 hours after tripping the unit. Deenergization can be utilized to prevent spurious operation. Manual operations include the following activities: manual reposition of valves, switches and circuit breakers fuse removal from the control circuitry of switchgear as a means of assuring that a tripped breaker does not close fuse removal from the control circuitry of a de-powered, air-operated valve that fails in a safe position fuse removal from the control circuitry of automated system safety functions to control potentially adverse spurious operations Repairs comprise the following activities: replacement of damaged components to restore operability of equipment fuse removal and subsequent replacement for a control circuit to recover from the effects of a fire 3.1.2 POST-FIRE PLANT EQUIPMENT CAPABILITY This subsection describes the basic assumptions made with regard to fire damage to plant equipment. 3.1.2.1 ELECTRICAL CABLE DAMAGE The FSSA assumes that the functional integrity of electrical cables is immediately lost, except one hour fire rated cable when cables are exposed to a postulated fire in a fire area, except where protected by acceptable methods (e.g., rated barriers, or radiant energy shields, etc.) within the fire area. Electrical cable failures are limited by the following considerations: 111-6 Revision 30

CPNPP/FPR (a) The fire damage occurs throughout the fire area of fire zone under consideration. (b) The fire damage results in a cable that is unusable with respect to assuring that proper fire safe shutdown functions are being achieved. (c) The fire-damaged cable conductor(s) shorts either to other conductors in the same cable or conductors in other cables; or shorts to ground through the enclosure; or the conductor(s) separates, causing an open circuit. 3.1.2.2 ELECTRICAL EQUIPMENT DAMAGE Electrical equipment located in a given fire area is assumed to fail as a result of the postulated fire in the fire area, and is considered unavailable to assure completion of fire safe shutdown functions, unless protected by one or more of the means identified in Section 11-4.5, or addressed in FHA evaluations/deviations. 3.1.2.3 MECHANICAL EQUIPMENT DAMAGE Fire Damage to piping, heat exchangers, tanks and noncombustible tubing has no adverse impact on their ability to function as pressure boundaries or as fire safe shutdown components. 3.1.2.4 INSTRUMENT DAMAGE Instruments exposed to a fire (e.g., resistance temperature detectors, thermocouples, pressure transmitters and flow transmitters) suffer damage which results in failure. The instrument fluid boundary, however, remains undamaged. Sight glasses and mechanically linked tank-level indicators are unaffected by fire. 3.1.2.5 EVOLUTION OF SMOKE AND TOXIC/CORROSIVE GASES Corrosive gas build-up from a fire in a small area and chloride deposition within a general plant area is not sufficient to affect plant equipment adversely while fire safe shutdown is achieved and maintained. 3.1.3 ASSOCIATED CIRCUITS OF CONCERN 3.1.3.1 ASSOCIATED CIRCUITS BY SPURIOUS OPERATION Circuits associated by spurious operation are those that can, as a result of fire-induced failures, cause equipment to maloperate in a way that defeats the required functions of fire safe shutdown systems or equipment. Examples include the uncontrolled opening or closing of valves due to fire-induced damage to control circuit cables (e.g., high/low pressure interface valves), or fire-induced damage to instrument or control circuits that may affect the safeguard circuit interlocks associated with these components (e.g., containment isolation logic). Should spurious actions affecting designated fire safe shutdown equipment occur, such actions are terminated and/or corrected by one of the following methods: 111-7 Revision 30

CPNPP/FPR (1) Use of equipment assigned to a redundant safety system to perform the required function (2) Use of a redundant component that is assigned to a different safety system to isolate or bypass the affected component (3) Removal of control power from equipment control circuits (4) Removal of motive power from components (5) Manual operations (e.g., to re-align valves, to restart systems, etc.) (6) Any appropriate combination of the above methods The following bases are utilized for spurious operations concerns: (a) Two types of cable short conditions are considered of sufficiently low likelihood that they are not credited as producing spurious component actuations. (1) Three-phase AC power circuit cable-to-cable faults (6.9kV and 480V) (2) Two-wire ungrounded DC circuits cable-to-cable faults (125V/250V) (b) The following bases apply to the normal plant conditions of potentially spuriously operating components and their associated circuits, and are the basis for the circuit failure mode and affects analysis: (1) Potential spuriously operating components are assumed to be in their normal operating position. (2) Relay, position switch, and control switch contacts in the control circuits of potentially spuriously operating components are assumed to be in the position that corresponds to the normal operating condition of that device. (3) Test switches in the control circuits are in their normal operating positions. (4) Automatic logic interlocks from other circuits are in a permissive condition with respect to the potential spurious operation, although this condition may involve additional fire-induced failures affecting external circuits. (5) Transfer switches in the control circuits are in their required position (Control Room control or Hot Shutdown Panel control). (i) The Control Room position is used to determine the spurious operations when the operation to shut the plant down is from the Control Room. (ii) The Hot Shutdown Panel position is used to determine the spurious operations when the operation to shut the plant down is from the Hot Shutdown Panel. 111-8 Revision 30

CPNPP/FPR 3.1.3.2 ASSOCIATED CIRCUITS BY COMMON POWER SUPPLY (BREAKER FUSE/ COORDINATION AND MULTIPLE HIGH IMPEDANCE FAULT CONSIDERATIONS) Circuits and cables associated by common power supply are those whose fire-induced failure may cause the loss of power source (bus, distribution panel, motor control center) that is necessary to support fire safe shutdown. The issue of associated circuits of concern by common power supply is resolved by assuring adequate electrical coordination between the fire safe shutdown power source supply breaker or fuse and the feeder breakers or fuses at the various fire safe shutdown power supplies. Uncoordinated branch circuits are included in the FSSA database as associated cables for the FSSA power supply under consideration. Corrected measures for potential losses due to common power supplies concerns (e.g., breaker uncoordination and high impedance faults discussed below) are resolved by determining them to be: (1) inconsequential with no adverse affects fire safe shutdown functions, (2) restorable with manual operation and procedures (e.g., with symptom based procedures), (3) precluded by adequate separation identified in Section 11-4.5, or in FHA evaluations/deviations, or (4) corrected by modification/fixes implemented such that common power supply conditions can be addressed by the above corrective measures. The following assumptions are utilized for common power supply concerns: (1) No single failure criterion is applied to electrical protection devices. Electrical protection devices are assumed to operate in accordance with their corresponding time-current characteristics, unless their failure is directly attributable to a fire. (2) The CPNPP position on Multiple High Impedance Faults is that the likelihood of simultaneous multiple threshold faults, without grounds occurring, is sufficiently low that it is not considered a credible event. The basis of this position is that the inherent separation provided in the existing system; (e.g., due to use of separation discussed in Section 11-4.5, conduits, the adherence to Regulatory Guide 1.75 criteria, etc.) is adequate to preclude the coincidental occurrence of multiple high impedance fault conditions without simultaneous grounds. A multiple high impedance fault study was performed. The problem circuits that represented potential unacceptable common power supply conditions, were evaluated against the FSSA results to determine if these common power supplies are performing required fire safe shutdown functions when challenged. Unacceptable common power supply conditions were addressed by the appropriate corrective measures, as discussed above. (3) Only one electrical fault at any given time effects a common power supply feeder branch. Coordination is verified against the line side protection for each required load side feeder circuit breaker or fuse. Electrical faults are considered bolted phase-to-phase or phase-to-ground. 111-9 Revision 30

CPNPP/FPR (4) Any feeder circuit that is defined as SPARE in the corresponding electrical circuit drawings (single lines, panel schedules) is assumed isolated from external circuit cables. 3.1.3.3 ASSOCIATED CIRCUITS BY COMMON ENCLOSURE An enclosure includes sealed fire areas, cable trays, cabinets, conduits, and other such structures that may contain electrical circuits. Circuits can be associated by common enclosure in two ways. First, fire-induced damage to cables could create circuit faults in electrically unprotected cables. Such faults could be of sufficient magnitude to create secondary fires in the cables due to the fault currents. If such secondary fires were to occur in an enclosure, these fires could impact fire safe shutdown cables or equipment contained within the common enclosures. The second type of associated circuit by common enclosure is related to cable jacket fire propagation. The concern is that fires may spread due to cables burning beyond the immediate area of concern, ultimately affecting fire safe shutdown cables that share raceways with the ignited cables. The following are the bases used to address common enclosure concerns. (a) Rated fire seals at fire area barriers prevent direct propagation of the fire from one fire area to the next fire area. This assures that redundant fire safe shutdown enclosures separated by required fire area barriers remain independent. (b) Propagation within the same fire area is reduced by the IEEE-383 rated features of the cable insulation used on power, control and instrumentation circuits and by the use of cable raceway fire breaks at CPNPP. Fire propagation within the same area is also retarded by the use of conduit. Since conduit is totally enclosed along its rout, fire cannot propagate along the conduit. (c) The enclosures in a power plant that contain instrumentation loop cables are either instrumentation racks, control panels, cable trays, conduits or remotely located devices. Instrumentation panels are rigid metal cabinets on which the individual instrumentation loop modules are mounted. Cable trays and conduits form the raceways in which field-run cables are routed. Remotely located devices include process measurement racks that contain transmitters, controllers and/or indicators. These enclosures, along with instrumentation cables, are arranged such that these cables do not become secondary ignition sources. (d) Over-current devices are used on power and control circuits. These devices assure that the electrical faults are cleared before they create a fire hazard remote from the location of the fault. The exception to this is low energy instrumentation loop conductors (as discussed above). 3.1.4 MANPOWER AVAILABILITY AND MANUAL OPERATIONS The activities requiring participation of operations personnel in the event of a fire include fire fighting and plant operation. To plan the allocation of personnel, the basic fire scenario is combined with the shutdown scenario to assure the proper coordination of 111-10 Revision 30

CPNPP/FPR activities. A time-line/manpower concept is employed to establish that sufficient time is available for achievement of the fire safe shutdown system functions. 4.0 FIRE SAFE SHUTDOWN ANALYSIS METHODOLOGY 4.1 OVERVIEW This section provides a discussion of the methodology for analyzing the units for POST-FIRE safe shutdown capability. This analysis first defines the plant configuration baseline. The plant description provides the basis for the Boolean Logic statements that EDMS uses to perform the automated separation analysis for the FSSA. This separation analysis is performed on an area-by-area basis. The details provided by the analysis reports are used to establish potential compliance strategies. 4.1.1 FIRE SAFE SHUTDOWN PLANT CONFIGURATION METHODOLOGY The process for identifying the plant configuration baseline for POST-FIRE safe shutdown is described briefly in this section as a sequence of discrete steps. The structure of the EDMS database is defined, as applicable, as part of the over description. (1) Relate the fire safe shutdown performance goals in Section 4.2.1 to corresponding FSSA fire safe shutdown functions. These function definitions identify the systems, and primary components required to shut down the plant and maintain it in a safe condition. (2) Evaluate or perform shutdown transient analyses. Evaluation of existing plant-specific analyses or performance of new analyses is required to demonstrate that the performance goals in Section 4.2.1 are met. (3) Identify fire safe shutdown cables and support components required for proper operation of each fire safe shutdown component identified in step 1. (4) Identify associated circuits and cables. Damage to these circuits and cables may indirectly inhibit fire safe shutdown through a variety of mechanisms (i.e., associated by common power supply, common enclosure and spurious operation). (5) Identify cable routing and fire zone location of components. The physical location of cables within the plant is determined by the raceways through which they are routed. (6) Identify the related fire zone and geometric location of plant raceways. (7) Identify the relationship between fire zones and fire areas as defined in Section I of the Fire Protection Report. (8) Identify common equipment utilized by both Unit 1 and Unit 2 for shutdown. (9) Identify fire areas involved in shutdown scenarios for both units. 111-11 Revision 30

CPNPP/FPR After the configuration baseline has been defined by the steps outlined above, the results are translated into Boolean logic statements to perform the separation analysis. 4.2 FIRE SAFE SHUTDOWN PLANT CONFIGURATION 4.2.1 FIRE SAFE SHUTDOWN PERFORMANCE GOALS The fire safe shutdown performance goals are the overall plant performance requirements needed to safely shut down CPNPP Unit 1, Unit 2, or both units following a fire. The achievement of these goals assures that the reactors are safely shut down, cooled down, and maintained in a cold shutdown condition. The specific performance goals that satisfy the criteria for fire safe shutdown in the event of a fire are listed below: (1) Reactor Reactivity Control (2) Reactor Coolant Inventory Control (3) Reactor Coolant Pressure Control (4) Decay Heat Removal (5) Process Monitoring (6) Support Services 4.2.1.1 REACTOR REACTIVITY CONTROL Reactivity control is maintained from the initial reactor trip to cold shutdown conditions. Following control rod insertion, hot subcritical conditions can be maintained for approximately 24 hours without the addition of boron, assuming all control rods are inserted into the core and the reactor trip has occurred at worst case conditions with equilibrium xenon. The cooldown transition form hot standby to cold shutdown required additional boration to maintain the required margin of shutdown reactivity. FIRE SAFE SHUTDOWN SYSTEMS UTILIZED TO ACHIEVE REACTOR REACTIVITY CONTROL (1) Reactor Protection System (2) Chemical and Volume Control System 4.2.1.2 REACTOR COOLANT INVENTORY CONTROL This performance goal is achieved by maintaining pressurizer level within the acceptable limits. 111-12 Revision 30

CPNPP/FPR FIRE SAFE SHUTDOWN SYSTEMS UTILIZED TO ACHIEVE REACTOR COOLANT INVENTORY CONTROL (1) Chemical and Volume Control System (2) Reactor Coolant System 4.2.1.3 REACTOR COOLANT PRESSURE CONTROL Reactor coolant pressure control allows the reactor coolant system to be operated: (a) within the technical specifications for reactor coolant system pressure-temperature requirements; (b) to prevent peak reactor coolant system pressure from exceeding 100% of system design pressure; and (c) with a sufficient subcooling margin to minimize void formation with the reactor vessel during natural circulation decay heat removal conditions. FIRE SAFE SHUTDOWN SYSTEMS UTILIZED TO ACHIEVE REACTOR COOLANT PRESSURE CONTROL (1) Reactor Coolant System (2) Chemical and Volume Control System 4.2.1.4 DECAY HEAT REMOVAL Decay heat removal is required to remove both decay and latent energy from the reactor core and primary systems at a rate such that overall system temperature can be maintained within acceptable limits. This function is to achieve cold shutdown conditions within a 72-hour period and maintain cold shutdown thereafter. FIRE SAFE SHUTDOWN SYSTEMS UTILIZED TO ACHIEVE DECAY HEAT REMOVAL (1) Main Steam System (2) Auxiliary Feedwater System (3) Residual Heat Removal System 4.2.1.5 PROCESSING MONITORING Processing monitoring is required to identify the status of process variables in order to modify system alignments and/or control fire safe shutdown equipment. Those plant process variables necessary for plant operator to perform the previously identified performance goals are monitored by remote indication in the Control Room or at the Hot Shutdown Panel. Local indication is utilized on a limited basis. 111-13 Revision 30

CPNPP/FPR 4.2.1.6 SUPPORT SERVICE The systems and equipment used to achieve the fire safe shutdown performance goals require miscellaneous support systems and equipment, such as AC/DC power, lubrication, HVAC, and process cooling. This support is provided by auxiliary equipment that assures acceptable performance by the fire safe shutdown systems. FIRE SAFE SHUTDOWN SYSTEMS UTILIZED TO PROVIDE SUPPORT SERVICES (1) Safety Chilled Water System (2) UPS and Distribution Rooms HVAC System (3) Component Cooling Water System (4) Control Room HVAC System (5) Station Service Water System (6) Diesel Generator Ventilation System (7) Service Water Intake Structure Ventilation System (8) Emergency Power Distribution System (including the Emergency Diesel Generators) 4.2.2 COMPONENT FUNCTIONAL OPERABILITY STATUS CATEGORIZATION The components identified as required for fire safe shutdown are categorized as: (1) Active Fire Safe Shutdown Components Components required to change their operating state or position from a normal one for plant power operation to another for plant shutdown. (2) Passive Fire Safe Shutdown Components Safe Shutdown components whose normal operating position or state is identical to their required fire required fire safe shutdown position or state and for which the effects of fire damage could result in a change of position or state that is detrimental to fire safe shutdown. These status categories apply only to the component's function within a particular fire safe shutdown success path. A fire safe shutdown component maybe assigned a different status category for each block diagram in which it appears. Components assigned to categories (1) and (2) may require cables and support components to assure correct operation. By definition, only components assigned to the active status category require support systems (e.g., electrical power supplies) for proper operation. 111-14 Revision 30

CPNPP/FPR 4.2.2.1 FIRE SAFE SHUTDOWN CABLES AND SUPPORTING COMPONENTS Each fire safe shutdown component may require a variety of electrical cables and supporting components to operate properly. Some components (e.g., hand valves) do not require cables or support components. Other components (e.g., large pumps) require extensive networks of power and control cables, power supplies, protective or control relays and switches, lube oil cooling, etc. The purpose of this analysis step is to identify the configuration of support components and cables required to operate each primary component. The identification may be complicated by the fact that there may exist several possible configurations of support equipment fore each fire safe shutdown component. Each configuration supports proper operation of the component but may use cables or support components which are less susceptible to fire damage. Component operating configurations which require evaluation include normal control (Control Room), alternate control (Hot Shutdown Panel or local panels), manual component operation, and the use of an alternate power source. The connection between the components associated with a fire safe shutdown performance goals and the support equipment is made by identifying the electrical power sources required to properly operate each fire safe shutdown component. The principal sources of control power and motive power are identified for each powered component assigned to the active analysis category. Power supplies are not required for analyzing passive fire safe shutdown components. Components for which the loss of power results in misalignment (with respect to fire safe shutdown performance goals) are categorized as active fire safe shutdown components. 4.2.2.2 SUPPORT REQUIREMENTS FOR ACTIVE COMPONENTS For each selected electrical circuit, cables required for the component to perform as required for fire safe shutdown are identified. The circuit analysis identifies the power and control cables for active components. If a device is required to either be operable or energized to assure the operability of a fire safe shutdown component, then the entire control circuit is included to assure the integrity of the control and power circuit's fuses and breakers, including its associated circuits of concern. If a fire safe shutdown component required for hot standby has an alternate control station, a redundant set of control power fuses is required. The original fuses may be "blown" due to the effects of the fire. When manual transfer to the alternate control station is accomplished, the redundant fuses automatically provide control power, thus assuring the integrity of the control circuits once transferred. 4.2.2.3 SUPPORT REQUIREMENTS FOR PASSIVE FIRE SAFE SHUTDOWN COMPONENTS For components that are required to maintain their normal operating position or state, only the control cables which could cause the fire safe shutdown component to change position or state are identified and included in the separation analysis. Passive fire safe shutdown components are analyzed to assure that they remain in the required position. For "open" components, the "close" circuits are analyzed; for "closed" components, the 111-15 Revision 30

CPNPP/FPR "open" circuits are analyzed. These analyses extend back through the circuit until either a normally open control switch contact or a control source is encountered. 4.2.2.4 EXCLUDED CIRCUITS AND CABLES Typical circuits and associated cables that are not required for component operation are those exclusively related to annunciator circuits, computer event monitoring, motor winding heaters, and external monitoring circuits that are electrically isolated from the circuits of concern. These types of circuits are not included in the fire safe shutdown separation analysis. In addition, wiring and cables only installed within the Control Room/Cable Spreading Room areas are not usually included in the FSSA (e.g., interconnections between NSSS panels), where the effects of their loss due to a fire is bounded by the previous cable selection up to the interfacing panels. 4.2.2.5 FIRE SAFE SHUTDOWN SYSTEMS A system or component may be assigned to more than one fire safe shutdown performance goal. This commonly occurs when a valve is used for selecting the alignment of redundant equipment or when one position is required for hot standby and one for transition to cold shutdown. The following is a list of systems required for fire safe shutdown: (1) Auxiliary Feedwater System (2) Chemical and Volume Control System (3) Emergency Power Distribution System (4) Main Steam System (5) Process Monitoring System (6) Reactor Coolant System (7) Reactor Protection System (8) Residual Heat Removal System 4.2.3 FIRE SAFE SHUTDOWN TRANSIENT ANALYSIS A minimum configuration of CPNPP equipment is selected to achieve each fire safe shutdown performance goal. Appropriate analyses are performed to assure that safe conditions are not exceeded when the plant is being shut down with the minimum set of fire safe shutdown equipment selected for the FSSA. 111-16 Revision 30

CPNPP/FPR 4.2.4 HIGH/LOW PRESSURE INTERFACE ANALYSIS High/low pressure interfaces consist of two redundant series valves which have a minimum separation that meets the requirements of IEEE-384 and Regulatory Guide

1. 75. Either valve is capable of preventing the spurious operation of the other from impairing proper fire safe shutdown. Such redundant devices are analyzed in the following manner. For CPNPP, the High/Low pressure interfaces are residual heat removal (RHR) suction valves, pressurizer power-operated relief valves (PORVs), and excess letdown isolation valves.

For fire areas other than the Control Room, Control Room HVAC Equipment Room, or the Cable Spreading Rooms, one of the redundant devices is analyzed for protection from coincident fire-induced spurious operations. In most cases adequate protection or separation is provided for raceways containing cables capable of initiating the spurious operations of redundant devices simultaneously in fire areas for which the operator has to perform manual operations in order to respond to fire-induced spurious operations of high/low pressure interfaces. The minimum separation provided by IEEE-384 and Regulatory Guide 1.75 forms a bases for assuring that coincident fire induced spurious operations of series redundant valve sets is sufficiently low, to ensure that adequate time is available to mitigate this type of potential spurious operation (e.g., high/low pressure interfaces). 4.2.5 COMMON POWER SUPPLY CABLES Cables which are powered from a power supply without properly coordinated protection may lose their power if another cable powered from the same supply is damaged and forces a breaker to open upstream of the common power supply. A coordinated protection device is installed so that the fault can be cleared downstream of the required power supply in most branch circuits fed by fire safe shutdown power supplies. Uncoordinated branch circuits are included as associated circuits in the INOMS database. 4.3 CPNPP FIRE SAFE SHUTDOWN CRITERIA The results of the fire area/zone separation analysis are used to determine the fire safe shutdown criteria status of all fire areas. Listings, printed out as part of the EDMS-generated separation analysis, guide the engineer in identifying the source of the discrepancy and in designing options to eliminate it. Modifications are considered where applicable. Fire Hazards Analysis evaluations are used to assess the significance of discrepancies identified during the fire area/zone separation analysis. 4.3.1 FIRE AREA COMPLIANCE MECHANISMS In order to meet the criteria stated in Section 11-4.5 within an area (fire area, fire zone, room, etc.), the following mechanisms are utilized: (1) One or three hour rated barriers: A fire barrier which separates an area (e.g., a room) or one which encapsulates raceways containing fire safe shutdown components or cables. This mechanism is used to meet the separation criteria of item 2 of Section 11-4.5. 111-17 Revision 30

CPNPP/FPR (2) Twenty (20) foot separation areas: A separation distance which is used in place of rated barriers to provide separation between required fire safe shutdown components of redundant systems. (3) Manual operation: See the definition in Section 1-2. This resolution is used in situations where the time required to perform this resolution does not preclude fire safe shutdown. (4) Repair: See the definition in Section 1-2. This resolution is utilized for cold shutdown or transition to cold shutdown only. FHA evaluations are provided in situations where compliance with these mechanisms is not readily evident, or deviations are provided and documented in Appendix C. 4.3.2 ALTERNATIVE SHUTDOWN CAPABILITY (FIRE IN THE CONTROL ROOM, ONE OF THE SPREADING ROOMS OR IN THE CONTROL ROOM-HVAC MECHANICAL EQUIPMENT ROOM) The alternate shutdown scenario is based on the effects from a worst-case fire requiring evacuation of the Control Room and the use of an alternative shutdown method independent of these fire areas. The equipment and personnel included in this scenario represent the minimum necessary to achieve hot standby. The scenario presented in this section is integrated into the CPNPP Abnormal Operating procedures. However, in the event of an actual fire, operators are not bounded by the specific event assumptions given in this analysis, but are allowed the latitude to use any available indications, controls, components, and systems that remain free of fire damage to safely shut down the facility. 4.3.2.1 ALTERNATIVE SHUTDOWN AREAS (1) (2) 4.3.2.2 BASIS Written procedures are required to assure the orderly transfer of control between the Control Room and remote stations for operation of alternate shutdown systems. 111-18 Revision 30

CPNPP/FPR 4.3.2.3 ACTIVITIES TO BE ACCOMPLISHED To achieve hot standby, transition to cold shutdown, and to maintain cold shutdown, a number of tasks must be accomplished. The following subsections outline the steps required to configure fire safe shutdown systems for fire safe shutdown. 4.3.2.3.1 Plant Shutdown Upon the confirmation of a fire requiring the evacuation of the Control Room the reactors are tripped manually by personnel in the Control Room prior to Control Room evacuation. Additional operator actions are taken prior to Control Room evacuation to better configure plant safety systems (if they are operable) as a first immediate action to optimize the response to safety system challenge caused by a fire. However, no credit is taken for these manual actions that provide additional margins of safety. The potential for spurious operations of components is assumed, but the undesirable consequences of such potential operations that can not be precluded are mitigated by corrective operator actions. The selection of potential spuriously operated valves is based on a least one of the following criteria: (1) The valves is a high/low pressure interface (2) The valve, although not required to configure fire safe shutdown systems, could prevent achieving and/or maintaining hot standby. These potential spuriously operated valves can be resolved by deenergizing and manually repositioning as required. As a PRE-FIRE strategy, the following are examples of preluding spurious actuations: (1) (2) 111-19 Revision 30

CPNPP/FPR (3) 4.3.2.3.2 Steam Generator Inventory Control Water is initially available in the secondary system to provide for the removal of decay heat. The steam generator code safety relief valves provide the path for initial decay heat removal. The auxiliary feedwater pumps, taking suction from the condensate storage tank, replenish the steam generator water inventory as steam is relieved through the relief valves. Once the condensate storage tank water inventory is depleted, station service water provides the water source for auxiliary feedwater. The following components are required to establish steam generator inventory control: (1) Motor-driven auxiliary feedwater pump (2) Motor-driven auxiliary feedwater pump discharge valves (3) Steam generator power-operated relief valves (4) Motor-driven auxiliary feedwater pump suction valves (5) Condensate storage tank level indication (6) Steam generators pressure and level indication (7) Reactor coolant system Tc and Th indication (8) Station service water supply to the auxiliary feedwater system 4.3.2.3.3 Primary System Inventory and Boration 111-20 Revision 30

CPNPP/FPR 4.3.2.3.4 Process Monitoring System Maintenance and control of various operating modes require indication of certain parameters. A minimum set of instruments provide a redundant method of indication for: pressurizer level, reactor coolant system pressure, hot and cold leg temperatures, and steam generator level and pressure. Pressurizer level, pressurizer pressure, hot and cold leg temperature, and steam generator level and pressure indication are available at the hot shutdown panel. Nuclear instrumentation source range indication is also available at the hot shutdown panel. 4.3.2.3.5 Support System Component cooling water is required for cooling the safety chillers, uninterruptible power supply A/C condensers, and the residual heat removal system pumps and residual heat removal system heat exchangers (for cold shutdown). One component cooling water pump is available to provide the required cooling for the fire safe shutdown loads. Manual operator action may be required to isolate the redundant Component Cooling Water loop and the Containment Spray heat exchangers. Service water is required for cooling the component cooling water exchanges, the diesel generator package, and the centrifugal charging pump lube oil cooler. A service water pump, which is sufficient to supply service water to these fire safe shutdown loads, is available. Safety chilled water is required to supply several safety-related cooling units for the purpose of cooling the Component Cooling Water, Centrifugal Charging, Motor-Driven Auxiliary Feedwater, and Residual Heat Removal Pump Rooms and essential electrical areas. The Uninterruptible Power Supply and Distribution Rooms air conditioning unit is required to remove heat ejected by the battery chargers and the static inverters. Emergency Diesel Generator A is available for each unit to maintain hot standby and cold shutdown conditions for Control Room and Cable Spreading Room fires. As necessary, Emergency Diesel Generator A is started and controlled locally. 4.3.2.4 ALTERNATIVE SHUTDOWN PROCESS AND MANPOWER REQUIREMENTS The activities described in Section 4.3.2.4.2 are used for achieving hot standby and an orderly transition to cold shutdown in the event of a fire requiring the evacuation of the control room. The actions presented use the minimum set of fire safe shutdown equipment to achieve cold shutdown. Within the first hour following a fire, specific operator actions are performed to achieve and maintain hot standby conditions. Performance of these identified actions within the designated time frame assures that the plant does not reach an undesirable plant condition. 111-21 Revision 30

CPNPP/FPR 4.3.2.4.1 Actions Required to Achieve Hot Standby and Transition to Cold Shutdown The actions required to achieve and maintain hot standby conditions and transition to cold shutdown are accomplished with the normal shift compliment of operators (which includes 2 licensed Reactor Operators and 2 Plant Equipment Operators per unit) within approximately the first hour after control room evacuation. Plant Equipment Operators are, at a minimum, equipment attendant qualified personnel. Communications are maintained between operators to coordinate valve alignments and system startups/ operations. 4.3.2.4.2 Hot Standby Condition The hot standby condition of the plant is controlled in accordance with CPNPP Operations Procedures. Completion of the activities described above is capable of establishing the following conditions: 111-22 Revision 30

CPNPP/FPR The hot standby conditions accomplished by these actions can be maintained until transition to cold shutdown. 4.3.2.4.3 Actions Required to Achieve Cold Shutdown The fire safe shutdown scenario presented thus far has assumed a fire requiring use of alternative methods for fire safe shutdown using available fire safe shutdown systems. The remainder of this section explains the alternative methods used to achieve cold shutdown from outside the Control Room. Plant cooldown would generally be initiated when: (1) hot standby conditions have been achieved, and (2) the condition(s) of the plant established. The cooldown phase requires the availability of additional systems and components, and the potential of manual alignment of valves. The residual heat removal system is also required for the second phase of cooldown. Primary system heat is removed by the controlled release of main steam to the atmosphere coupled with the continued supply of feedwater from an auxiliary feedwater pump. The rate of cooldown can be controlled by the operator at the hot shutdown panel using the steam generator power operated relief valve controller (when air supply is available) or coordinating with the operator stationed at the auxiliary feedwater inlet or outlet isolation valves. The cooldown rate can be maintained within Technical Specifications limits and within the limits of the fire safe shutdown system capabilities. Cool down, using the steam generator power operated relief valves and the auxiliary feedwater pump, continues until the primary system pressure and temperature are within the operating limits of the residual heat removal system pressure and temperature. Prior to lining up the residual heat removal system, primary system pressure is reduced as necessary by opening the pressurizer power operated relief valves. The component cooling water and station service water systems are required to support residual heat removal system operation. The component cooling water system is required to support cold shutdown. Component cooling water flow is from the component cooling water pumps through the component cooling water exchangers, then back to the suction of the component cooling water 111-23 Revision 30

CPNPP/FPR pumps. Station service water is used as the cooling medium for the component cooling water heat exchangers. The residual heat removal system is placed in operation when the reactor coolant system pressure and temperature reach approximately 350 psig and 350 degrees Fahrenheit. Fire-induced damage may have caused spurious changes in valves position, which may require valve alignment or repair before initiation of residual heat removal. When the residual heat removal system is aligned, the residual heat removal pumps provide primary system heat removal capability with reactor coolant circulating form the reactor vessel through two (2) of the respective loops cold legs and back into the reactor vessel. The primary system cooldown rate can be controlled by operating the residual heat removal heat exchanger bypass flow control valve, using the backup air supply. 5.0 FIRE SAFE SHUTDOWN EQUIPMENT LIST The following is a compiled list of fire safe shutdown equipment located by Fire Area/Fire Zone (FZ). Fire Area 2CA: 111-24 Revision 30

CPNPP/FPR 111-25 Revision 30

CPNPP/FPR 111-26 Revision 30

CPNPP/FPR Fire Area 2SA: 111-27 Revision 30

Fire Area 258: 111-28 Revision 30

CPNPP/FPR 111-29 Revision 30

CPNPP/FPR w w 111-30 Revision 30

CPNPP/FPR 111-31 Revision 30

CPNPP/FPR Fire Area 2SC: 111-32 Revision 30

CPNPP/FPR Fire Area 250: 111-33 Revision 30

CPNPP/FPR Fire Area 2SE: 111-34 Revision 30

Fire Area 2SH: Fire Area 251: Fire Area 2SJ: 111-35 Revision 30

CPNPP/FPR Fire Area 2SK: 111-36 Revision 30

CPNPP/FPR 111-37 Revision 30

CPNPP/FPR Fire Area 2SL: Fire Area AA: w w w w w 111-38 Revision 30

CPNPP/FPR w w w 111-39 Revision 30

CPNPP/FPR 111-40 Revision 30

111-41 Revision 30 w 111-42 Revision 30

CPNPP/FPR Fire Area AC: Fire Area AE: Fire Area AF: Fire Area CA: 111-43 Revision 30

CPNPP/FPR 111-44 Revision 30

CPNPP/FPR 111-45 Revision 30

CPNPP/FPR Fire Area EA: 111-46 Revision 30

CPNPP/FPR 111-47 Revision 30

CPNPP/FPR 111-48 Revision 30

CPNPP/FPR 111-49 Revision 30

CPNPP/FPR Fire Area EC: Ill-50 Revision 30

CPNPP/FPR Fire Area EH Ill-51 Revision 30

CPNPP/FPR Ill-52 Revision 30

CPNPP/FPR Fire Area EM: Fire Area EN: Ill-53 Revision 30

CPNPP/FPR Fire Area EO: Fire Area EQ: Ill-54 Revision 30

CPNPP/FPR Fire Area ER: Fire Area SA: Ill-55 Revision 30

Fire Area SB: Ill-56 Revision 30

CPNPP/FPR w w Ill-57 Revision 30

CPNPP/FPR Ill-58 Revision 30

CPNPP/FPR Ill-59 Revision 30

CPNPP/FPR 111-60 Revision 30

CPNPP/FPR Fire Area SD: Fire Area SE: 111-61 Revision 30

CPNPP/FPR Fire Area SG: Fire Area SH: Fire Area 51: 111-62 Revision 30

CPNPP/FPR Fire Area SJ: Fire Area SK: 111-63 Revision 30

CPNPP/FPR 111-64 Revision 30

CPNPP/FPR Fire Area TB: 111-65 Revision 30

CPNPP/FPR Fire Area WB: w w w w w w w 111-66 Revision 30

CPNPP/FPR 5 Fire Area YARD:

6.0 REFERENCES

The documents listed in this section are information sources for the Fire Safe Shutdown Analysis Report: (1) CPNPP Electronic Data Management System (EDMS) (2) Design Basis Document DBD-ME-020, "Fire Safe Shutdown Analysis", (3) Calculation ME-CA-0000-1 086 R/2, "FSSA for CPNPP Unit 1 and Unit 2", (4) Calculation 3-A-8-003 R/0, "H2 Distribution in Battery Rooms". 111-67 Revision 30

CPNPP/FPR COMANCHE PEAK NUCLEAR POWER PLANT FIRE PROTECTION REPORT SECTION IV UNIT 1 AND UNIT 2 Fire Protection Equipment/Systems Operational Administration IV-1 Revision 29

CPNPP/FPR TABLE OF CONTENTS SECTION SUBJECT PAGE

1.0 INTRODUCTION

3 2.0 TESTS/INSPECTIONS 3 3.0 COMPENSATORY MEASURES 10 4.0 OPERABILITY CRITERIA 13 5.0 SYSTEM BASES 14 6.0 EQUIPMENT TABLES 15 IV-2 Revision 29

CPNPP/FPR

1.0 INTRODUCTION

The administrative control of the fire protection program is provided through CPNPP station procedures to assure that the fire protection equipment/systems are operable and properly maintained. This includes periodic tests/inspections, compensatory measures concerning items which may be inoperable, and quality assurance audits. The program applies to fire protection equipment/systems that protect fire areas which contain safe shutdown equipment. 2.0 TESTS/INSPECTIONS Plant fire protection equipment/systems are subjected to pre-operational tests/ inspections after the initial installation is complete. Acceptance criteria is based on the applicable codes as described in the FSAR. The fire protection equipment/systems that protect fire areas which contain safe shutdown equipment are subjected to periodic tests/ inspections to assure the reliability and operability of the equipment/systems. The following types of fire protection equipment/systems are subjected to the tests/ inspections listed in section 2.1. Fire Alarm and Detection Systems Fire Protection Water Supply Pumps Fire Protection Water Storage Tanks Fire Protection Water Distribution System Wet Pipe Sprinkler Systems Deluge/Water Spray Systems Preaction Sprinkler Systems Halon Systems Manual Suppression Systems(i.e. hydrants, hoses, hydrant hose houses, hose stations, etc.) Fire Rated Assemblies(i.e. walls, floors, doors, dampers, penetration seals, etc.) Battery Operated Emergency Lighting Units (EBLs) Each test/inspection is performed within the specified time interval with a maximum allowable extension not to exceed 25% of the test/inspection interval. It is not intended that this provision be used repeatedly as a convenience to extend test/inspection intervals beyond that specified for tests/inspections that are not performed during refueling outages. IV-3 Revision 29

CPNPP/FPR 2.1 The following tests/inspections are performed on the fire protection equipment/systems that protect the safe shutdown equipment in each respective area. a.) Fire Detection Instrumentation 1.) Thermistor Strip Detectors Each of the thermistor strip detection zones listed in Table 1 which are accessible during plant operation are demonstrated operable at least once per 12 months by in-place functional testing of each strip detector in each zone using a suitable heat source (i.e. heat gun, etc.). Thermistor detection zones listed in Table 1 which are not accessible during plant operation are demonstrated operable by the above described test method during each cold shutdown exceeding 24 hours unless performed in the last 12 months. 2.) Spot Thermal Detectors Each of the spot thermal detection zones listed in Table 1 which are accessible during plant operation are demonstrated operable at least once per 12 months by in-place functional testing of 20% of the detectors in each zone using a suitable heat source (i.e. heat gun, etc.). Spot thermal detection zones listed in Table 1 which are not accessible during plant operation are demonstrated operable by the above described test method during each cold shutdown exceeding 24 hours unless performed within the last 12 months. 3.) Ionization Detectors Each of the ionization detection zones listed in Table 1 which are accessible during plant operation are demonstrated operable at least once per 12 months by in-place functional testing of each detector in each zone using a suitable test gas accompanied by a visual inspection. Ionization detection zones listed in Table 1 which are not accessible during plant operation are demonstrated operable by the above described test method during each cold shutdown exceeding 24 hours unless performed in the last 12 months. 4.) Ultraviolet Detectors Each of the ultraviolet detection zones listed in Table 1 which are accessible during plant operation are demonstrated operable at least once per 12 months by in-place functional testing of each detector in each zone using a suitable ultraviolet light source. Ultraviolet detection zones listed in Table 1 which are not accessible during plant operation are demonstrated operable by the above described test method during each cold shut down exceeding 24 hours unless performed within the last 12 months. IV-4 Revision 29

CPNPP/FPR 5.) The supervised circuits, associated with the detector alarms of each of the above fire detection instruments is demonstrated operable at least once per 12 months. 6.) The nonsupervised circuits, associated with detector alarms, between the instrument and the control room are demonstrated operable at least once per 31 days. b.) Fire Suppression System 1.) The Fire Suppression Water System is demonstrated operable: a.) At least once per 7 days by verifying the contained water supply volume in each tank, b.) At least once per 31 days by starting the electric motor driven fire pump and operating it for at least 15 minutes on recirculating flow, c.) At least once per 92 days by verifying that each valve (manual, power-operated, or automatic) in the flow path is in its correct position, d.) At least once per 12 months by cycling each accessible and testable valve in the flow path through at least one complete cycle of travel, e.) At least once per 18 months by cycling each testable valve in the flow path that is not accessible during plant operation through at least one complete cycle of travel, f.) At least once per 18 months by performing a system functional test which includes simulated actuation of the system throughout its operating sequence, and: 1.) Confirming that each pump develops at least 2000* gpm at a system head of 358* feet, and 2.) Confirming that each fire suppression pump starts sequentially to maintain the fire suppression water system pressure greater than or equal to 140* psig, and g.) At least once per 3 years by performing a flow test of the system in accordance with Chapter 5, Section 11 of the Fire Protection Handbook, 14th Edition, published by the National Fire Protection Association. IV-5 Revision 29

CPNPP/FPR 2.) Each diesel engine driven fire pump is demonstrated operable: a.) At least once per 14 days by verifying: 1.) Each fuel storage tank contains at least 100 gallons of fuel, and 2.) Each diesel engine starts from ambient conditions and operates for at least 30 minutes on recirculating flow, b.) At least once per 92 days by confirming that a sample of the diesel fuel from each fuel storage tank, obtained in accordance with ASTM-D-4057-1981 is within the acceptable limits specified in Table 1 of ASTM-0975-1981 when checked for viscosity and water sediment; and c.) At least once per 18 months, by subjecting each diesel engine to an inspection in accordance with procedures prepared according to the manufacturer's recommendations for the class of service. 3.) The 24 volt battery banks and chargers for starting the two diesel fire pumps are demonstrated operable: a.) At least once per 92 days by confirming that: 1.) The electrolyte level of each battery is above the plates, and 2.) The overall battery voltage of each battery is greater than or equal to 24 volts, with the battery chargers off for at least 15 minutes, b.) At least once per 92 days by confirming that the specific gravity is appropriate for continued service of the battery, and c.) At least once per 18 months by confirming that: 1.) The batteries, and battery racks show no visual indication of physical damage or abnormal deterioration, and 2.) The battery-to-battery and terminal connections are clean, tight, free of corrosion, and coated with anti-corrosion material. 4.) Spray and/or Sprinkler Systems a.) Each of the Spray and/or Sprinkler Systems listed in Table 2 is demonstrated operable: IV-6 Revision 29

CPNPP/FPR 1.) At least once per 92 days by confirming that each valve (manual, power-operated, or automatic) in the flow path is in its correct position, 2.) At least once per 12 months by cycling each testable valve in the flow path through at least one complete cycle of full travel, 3.) At least once per 18 months: a.) By performing a system functional test which includes simulated normal actuation of the system, and: 1.) Confirming that the automatic or manual valves in the flow path actuate to their correct position on a manually initiated test signal, and 2.) Cycling each valve in the flow path that is not testable during plant operation through at least one complete cycle of full travel, b.) By visually inspecting the dry pipe spray and sprinkler headers to confirm their integrity, and c.) By visually inspecting each nozzle's spray area to confirm that the spray pattern is not obstructed. 5.) Halon Systems a.) The Cable Spread Room Halon Systems are demonstrated operable: 1.) At least once per 6 months by confirming Halon storage tank liquid content to be at least 95% of full charge weight or level and the pressure to be at least 90% of full charge pressure, and 2.) At least once per 24 months by confirming that the systems actuate manually and automatically upon receipt of a simulated signal, confirming the actuation of the fire door releases, confirming the receipt of fire damper ETL release signal, confirming associated ventilation fan shutdown, and by visually inspecting fire dampers. 6.) Fire Hose Stations a.) Each of the fire hose stations listed in Table 3 is demonstrated operable: IV-7 Revision 29

CPNPP/FPR 1.) At least once per 92 days, by visually inspecting the fire hose stations accessible during plant operations to assure that the required equipment is at the station. 2.) At least once per 18 months by: a.) Visually inspecting the stations not accessible during plant operations to assure that the required equipment is at the station, b.) Removing the hose for inspection and re-racking, c.) Inspecting the gaskets and replacing any degraded gaskets in the couplings, and d.) Confirming that each automatic valve in the flow path actuates to its correct position on a manual initiation test signal, and 3.) At least once per 3 years by: a.) Partially opening each hose station valve, except Containment and Control Room hose stations, to confirm valve operability and no flow blockage, b.) Performing an air flow test on the Containment and Control Room hose stations to assure that the flow path of each hose station is unobstructed, and c.) Conducting a hose hydrostatic test at a pressure of 150 psig or at least 50 psig above the maximum fire main operating pressure, whichever is greater. 7.) Yard Fire Hydrants and Hydrant Hose Stations a.) Each of the yard fire hydrants and associated hydrant hose houses listed in Table 4 is demonstrated operable: 1.) At least once per 6 months by: a.) Visually inspecting each hydrant hose house to assure that the required equipment is at each hose house, b.) Visually inspecting each yard fire hydrant and confirming that the hydrant barrel is dry and that the hydrant is not damaged, and IV-8 Revision 29

CPNPP/FPR 2.) At least once per 12 months by: a.) Conducting a hose hydrostatic test at a pressure of 150 psig or at least 50 psig above the maximum fire main operating pressure, whichever is greater, b.) Inspecting the gaskets and replacing any degraded gaskets in the couplings, and c.) Performing a flow check of each hydrant to assure operability. c.) Fire Rated Assemblies 1.) The required fire rated assemblies and penetration sealing devices are confirmed operable by visually inspecting: a.) The exposed surfaces of fire rated walls, floors, etc. and structural steel fireproofing using a site approved sampling plan every 18 months, b.) Fire rated dampers and associated hardware every 24 months, c.) The exposed surfaces of 1-hour rated raceway wrap in plant areas determined by the CPNPP IPEEE to be risk significant every 18 months, d.) The exposed surfaces of 1-hour rated raceway wrap in plant areas determined by the CPNPP IPEEE not to be risk significant using a site approved sampling plan every 18 months, e.) The exposed surfaces of RES wrap inside the containment structure during each refueling outage, and f.) The exposed surfaces of sealed penetrations using a site approved sampling plan every 18 months. 2.) Each of the required fire doors are confirmed operable by inspecting the automatic hold-open, release, and closing mechanism and latches at least once per 6 months, and by confirming: a.) That each locked closed fire door is closed at least once per 7 days, b.) That doors with automatic hold-open and release mechanisms are free of obstructions at least once per 7 days, and a functional test is performed at least once per 18 months, and c.) That each unlocked fire door without electrical supervision is closed at least once per 7 days. IV-9 Revision 29

CPNPP/FPR d.) Battery Operated Emergency Lighting Units (EBLs) 1.) The EBLs required for fire safe shutdown are confirmed operable: a.) At least once per month by spot energizing various emergency lights by pressing the test button to ensure that they illuminate as designed, and by checking light fixture heads for physical damage, b.) At least once per 12 months by performing a visual inspection and cleaning, functional test, battery voltage test, and lamp position and orientation verification, and c.) By replacing the Emergency Lighting Battery Packs: 1.) At each refueling outage for EBLs inside Reactor Containment. 2.) At approximately 3-year intervals for EBLs outside Reactor Containment. 3.0 COMPENSATORY MEASURES The fire protection equipment/systems that protect fire areas which contain safe shutdown equipment, when inoperable, have the compensatory measures implemented as detailed in Section IV-3.1. These compensatory measures provide an alternate source of fire protection when the primary fire protection equipment/systems are not available for use. Station procedures are used to control inoperable fire protection equipment/systems. These procedures assure that inoperable conditions are identified and that sufficient notification is given to the operations shift supervisor. The operations shift supervisor determines the severity of the proposed inoperable condition in relation to the imposed fire hazard. As delineated in Section IV-3.1 and station procedures, compensatory measures are implemented to assure that an alternate source of fire protection is maintained. The fire protection supervisor is consulted by the operations shift supervisor in addressing unique situations. Efforts and work activities conducted by individuals associated with an inoperable condition are conducted in an expeditious manner so that the fire protection equipment/systems are promptly restored to service. 3.1 The following compensatory measures are implemented when fire protection equipment/ systems are determined inoperable as described above. a.) Fire Detection Instrumentation The fire detectors installed in Unit 1 and Unit 2 areas perform one of two functions.

            "Function A" detection instruments are used for early warning fire detection and notification only. "Function B" detection instruments are used for actuation of Fire Suppression Systems and early warning and notification. Detection instruments, listed inc, Table 1, which are discovered to be inoperable shall be subjected to the following compensatory measures:

IV-10 Revision 29

CPNPP/FPR 1.) When any, but not more than one half, of the "Function A" detection instruments in any given Fire Zone is inoperable, the inoperable instrument(s) is restored to an operable status within 14 days or a) within one hour, an hourly fire watch patrol is established to inspect the Fire Zone until the inoperable instrument(s) is restored to an operable status, or b) if the instrument(s) is located in a Zone V radiation area outside containment, the Fire Zone is inspected at least once per 8 hours until the inoperable instrument(s) is restored to an operable level, or c) if the instrument(s) is located inside containment, the air temperature is monitored at least once per hour at the locations listed in 3 below. 2.) When more than one-half of the "Function A" detection instruments in any given Fire Zone are inoperable, or when two or more adjacent detection instruments are inoperable, or when any single "Function B" detection instruments is inoperable a) within one hour, an hourly fire watch patrol is established to inspect the Fire Zone until the inoperable instrument(s) is restored to an operable status or b) if the instrument(s) is located in a Zone V radiation area outside containment, the Fire Zone is inspected at least once per 8 hours until the inoperable instrument(s) is restored to an operable status, or c) if the instrument(s) is located inside containment, the air temperature is monitored at least once per hour at the locations listed in 3 below. 3.) Containment air temperature monitor locations. a.) Containment Dome Elevation 1000'-6". b.) Containment Floor Elevation 860'-0". b.) Fire Suppression Water System 1.) With one pump and/or one water supply tank inoperable, the inoperable equipment is restored to an operable status within 7 days or an alternate backup pump or supply is provided, and 2.) With the fire suppression water system otherwise inoperable, a backup fire suppression system is established within 24 hours. c.) Spray and/or Sprinkler Systems With one or more of the required Spray and/or Sprinkler Systems Protecting areas listed in Table 2 inoperable, within 1 hour a continuous fire watch is established with backup fire suppression equipment for those areas in which redundant systems or components could be damaged. For Containment, the thermal detectors are determined to be operable in the containment pre-access filtration units; for Zone V radiation areas outside containment, the area is inspected at least once per 8 hours. IV-11 Revision 29

CPNPP/FPR d.) HALON With one or more of the HALON Systems listed in Table 5 (which include both main and reserve cylinders) inoperable, within 1 hour a continuous fire watch is established with backup fire suppression equipment. e.) Fire Hose Stations With one or more of the fire hose stations listed in Table 3 inoperable, a gated wye(s) is provided on the nearest operable hose station(s). One outlet of the wye is connected to the standard length of hose provided for the hose station. The second outlet of the wye is connected to a length of hose sufficient to provide coverage for the area left unprotected by the inoperable hose station. Where it can be demonstrated that the physical routing of the hose would result in a recognizable hazard to operating technicians, plant equipment, the hose itself, or due to security requirement, the fire hose is stored at the outlet of the operable hose station. Signs are mounted above the gated wye(s) to identify the proper hose to use. Where a gated wye on the nearest operable hose station cannot be provided, a hose capable of providing an equivalent quantity of water and pressure is provided. It is also acceptable to provide coverage to the area left unprotected by the inoperable hose station by using a hose from a station not listed in Table 3, if that hose can provide an equivalent quantity of water and pressure. The above action requirement is accomplished within 1 hour if the inoperable fire hose is the primary means of fire suppression; otherwise, additional fire hose is routed within 24 hours. f.) Yard Fire Hydrants and Hydrant Hose Houses 1.) With one or more of the yard fire hydrants or associated hydrant hose houses listed in Table 4 inoperable, within 1 hour sufficient additional lengths of 2 & 1/2" diameter hose are located in an adjacent operable hydrant hose house to provide service to the unprotected area(s) if the inoperable fire hydrant or associated hydrant hose house is the primary means of fire suppression; otherwise, the additional fire hose is provided within 24 hours, and 2.) It is also acceptable to provide coverage to the area left unprotected by an inoperable yard fire hydrant or associated hydrant hose house by using a yard fire hydrant not listed in Table 4, if that hydrant can provide an equivalent quantity of water and pressure. g.) Fire Rated Assemblies With one or more of the required fire rated assemblies and/or sealing devices inoperable, within 1 hour either a continuous fire watch is established on at least one side of the affected assembly, or the operability of the fire detectors is confirmed on at least one side of the inoperable assembly and an hourly fire watch patrol is established. IV-12 Revision 29

CPNPP/FPR h.) Unit 2 Chiller Room The Unit 2 safety chiller room fire suppression system has a "water curtain" added to the area over the one hour fire barriers located between the two safety chiller trains. The purpose of this water curtain is to augment the rating of the barriers to a one hour rating. Operability of the one hour barrier in the room depends on the operability of the water curtain portion of the suppression system since the water curtain is relied upon as part of the barrier design. The water curtain and area wide suppression system can be isolated from one another by use of manually operated shut off valves. This arrangement results in a potential need for varied compensatory measures depending on the type or extent of impairment. 1.) Fire Barrier and/or Water Curtain Inoperable- Within one hour ensure detection system operability and establish an hourly fire watch. If detection is inoperable establish a continuous fire watch. 2.) Area Wide Suppression System Inoperable- Within one hour establish a continuous fire watch. 3.) Detection System Inoperable- See Section 3.1.a. 4.) Barrier and Suppression System Inoperable- Within one hour establish a continuous fire watch. 5.) Suppression and Detection System Inoperable- Within one hour establish a continuous fire watch. 4.0 OPERABILITY CRITERIA The fire protection equipment/systems that are located in fire areas which contain safe shutdown equipment are expected to be operable as follows. 1.) The fire protection equipment/systems referenced in Section 2.0, except the fire suppression water system, are operable whenever the safe shutdown equipment in each respective area is required to be operable. 2.) The Fire Suppression Water System is operable, at all times, under the following conditions. a.) At least three (3) Fire Suppression Pumps, each with the capacity of 2000 gpm, with their discharge aligned to the Fire Suppression Water Supply Header which routes water to the Fire Protection Water Supply Distribution Piping, and b.) Two (2) separate water supply tanks, each with a minimum contained volume of 464,400 U.S. Gallons, and c.) An operable flow path capable of taking suction from either of the fire protection water supply tanks and transferring the water through the distribution piping with operable sectional control or isolation valves to the IV-13 Revision 29

CPNPP/FPR yard hydrant curb valve boxes and the last valve ahead of the water flow alarm valve on each spray and/or sprinkler system or hose station system. 5.0 SYSTEM BASES The following bases are used for establishing the functional capabilities of the fire protection equipment/systems. a.) Fire Detection Instrumentation The operability of the fire detection instrumentation assures that both adequate warning capability is available for prompt detection of fires and that fire suppression systems, that are actuated by fire detectors, discharge extinguishing agents in a timely manner. Prompt detection and suppression of fires reduce the potential for damage to safe shutdown equipment and is an integral element in the overall CPNPP Fire Protection Program. Fire detectors that are used to actuate fire suppression systems represent a more critically important component of the CPNPP Fire Protection Program than detectors that are installed solely for early warning and notification. Consequently, the minimum number of operable fire detectors must be greater. The loss of detection capability for fire suppression systems, actuated by fire detectors, represents a significant degradation of fire protection for any area. As a result, the establishment of a fire watch patrol is initiated at an earlier stage than is warranted for the loss of detectors that provide only early fire warning. The establishment of frequent fire patrols in the affected areas is employed to provide detection capability until the inoperable instrumentation is restored to an operable status. b.) Fire Suppression Systems The operability of the fire suppression systems assures that adequate fire suppression capability is available to confine and extinguish fires occurring in any portion of the plant where safe shutdown equipment is located. The fire suppression system consists of the water system, spray and/or sprinkler systems, Halon systems, fire hose stations, and yard fire hydrants. In the event that portions of the fire suppression systems are inoperable, alternate backup fire fighting equipment is made available in the affected areas until the inoperable equipment is restored to service. When the inoperable fire-fighting equipment is intended for use as a backup means of fire suppression, a longer period of time is allowed before an alternate means of protection is provided. Inspection/Testing procedures provide assurance that the minimum operability criteria of the fire suppression systems are met. An allowance is made for assuring a sufficient volume of Halon content in the Halon storage tanks by confirming either the weight or the liquid level of the tanks. IV-14 Revision 29

CPNPP/FPR In the event that the fire suppression water supply system becomes inoperable, immediate corrective measures are taken since this system provides the major fire suppression capability of the plant. c.) Fire Rated Assemblies The functional integrity of the fire rated assemblies and barrier penetrations assures that fires are confined or adequately retarded from spreading to adjacent portions of the facility. These design features minimize the possibility of a single fire rapidly involving several areas of the facility prior to detection and extinguishing of the fire. The fire barrier penetrations are a passive element in the CPNPP Fire Protection Program and are subject to periodic inspections. Fire barrier penetrations, including cable penetration barriers, fire doors and dampers are considered functional when the visually observed condition is the same as the as-designed condition. For those fire barrier penetrations that are not in the as-designed condition, an evaluation is performed to show that the modification has not degraded the fire rating of the fire barrier penetration. During periods of time when a barrier is inoperable either: (1) a continuous fire watch is maintained in the vicinity of the affected barrier, or (2) the fire detectors on at least one side of the affected barrier are confirmed operable and an hourly fire watch patrol is established until the barrier is restored to a functional status. 6.0 EQUIPMENT TABLES The fire protection equipment/systems, listed in the following tables, are subjected to the tests/inspections, compensatory measures and operability requirements mentioned in Sections 2.0, 3.0, and 4.0. a.) Table 1 p. 16 b.) Table 2 p. 35 c.) Table 3 p. 38 d.) Table 4 p. 43 e.) Table 5 p. 44 IV-15 Revision 29

Table 1 FIRE DETECTION INSTRUMENTATION Page 1 of 19 TOTAL NUMBER OF INSTRUMENTS* FIRE DETECT HEAT FLAME SMOKE INSTRUMENT LOCATION ZONE ZONE ROOM ELEV. (x/y) (x/y) (x/y) Unit 1 Safeguards Building 1a 1a 1-060 773' 0" 1/0 Unit 1 Safeguards Building 1a 1a 1-056a 773' 0" 3/0 Unit 1 Safeguards Building 1a 1a 1-051 773' 0" 1/0 Unit 1 Safeguards Building 1a 1a 1-052# 773' 0" 1/0 Unit 1 Safeguards Building 2a 2a 1-062 773' 0" 1/0 Unit 1 Safeguards Building 2a 2a 1-056B 773' 0" 3/0 0

                                                                                                         -u z

< Unit 1 Safeguards Building 2a 2a 1-054 773' 0" 1/0 -u I

                                                                                                         -u (J)

Unit 1 Safeguards Building 2a 2a 1-053# 773' 0" 1/0 "Tl

                                                                                                         -u Unit 1 Safeguards Building 1c       1c       1-063        790' 6"                       2/0       :::0 Unit 1 Safeguards Building 1c       1c       1-066#       790' 6"                       2/0 Unit 1 Safeguards Building 1c       1c       1-068#       790' 6"                       2/0 Unit 1 Safeguards Building 2c       2c       1-069#       790' 6"                       2/0 Unit 1 Safeguards Building 2c       2c       1-067#       790' 6"                       2/0

0 Unit 1 Safeguards Building 2c 2c 1-065 790' 6" 2/0 CD
_ Unit 1 Safeguards Building 4 4 1-070 790' 6" 15/0 a*

(/)

J Unit 1 Safeguards Building 4 4 1-071 790' 6" 710 N

<D Unit 1 Safeguards Building 4 4 1-064 790' 6" 2/0 Unit 1 Safeguards Building 4 4 Vent Chase 831' 6" 1/0 Unit 1 Safeguards Building 4 4 1-085D 796' 0" 11/0

Table 1 FIRE DETECTION INSTRUMENTATION Page 2 of 19 TOTAL NUMBER OF INSTRUMENTS* FIRE DETECT HEAT FLAME SMOKE INSTRUMENT LOCATION ZONE ZONE ROOM ELEV. (x/y) (x/y) (x/y) Unit 1 Safeguards Building 5 5 1-072 790' 6" 3/0 Unit 1 Safeguards Building 6 6 1-073 790' 6" 3/0 Unit 1 Safeguards Building 7 7 1-074 790' 6" 4/0 Unit 1 Safeguards Building 8 8 1-078 810' 6" 1/0 Unit 1 Safeguards Building 8 8 1-082 810' 6" 18/0 Unit 1 Safeguards Building 8 8 1-079 810' 6" 3/0 0

                                                                                                           -u z

< Unit 1 Safeguards Building 142 142 1-077A# 810' 6" 5/0 -u I

-u

-..J Unit 1 Safeguards Building 142 142 1-077A 831' 6" 2/0 "Tl

                                                                                                           -u 810' 6"                                   :::0 Unit 1 Safeguards Building 143      143      1-077B#                                      5/0 Unit 1 Safeguards Building 143      143      1-077B       831' 6"                         1/0 Unit 1 Safeguards Building 2d       143      1-076        800' 6"                         1/0 Unit 1 Safeguards Building 1d       142      1-075        800' 6"                         1/0 Unit 1 Safeguards Building 2e       143      1-080        810' 6"                         1/0

0 Unit 1 Safeguards Building 10a 10a 1-084 810' 6" 14/0 CD Unit 1 Safeguards Building 10b 10b 1-099B 844' 0" 710 a*

(/)

J Unit 1 Safeguards Building 11 11 1-099D 844'0" 0/2 N

<D Unit 1 Safeguards Building 12a 12a 1-085 810' 6" 14/0 Unit 1 Safeguards Building 12b 12b 1-099A 844' 0" 710 Unit 1 Safeguards Building 13 13 1-099C 844'0" 0/2

Table 1 FIRE DETECTION INSTRUMENTATION Page 3 of 19 TOTAL NUMBER OF INSTRUMENTS* FIRE DETECT HEAT FLAME SMOKE INSTRUMENT LOCATION ZONE ZONE ROOM ELEV. (x/y) (x/y) (x/y) Unit 1 Safeguards Building 9 9 1-083 810' 6" 27(1 )(6)/0 Unit 1 Safeguards Building 9 9 1-085A 810' 6" 1/0 Unit 1 Safeguards Building 15 15 1-094 831' 6" 23(1 )/0 Unit 1 Safeguards Building 15 15 1-095 831' 6" 6/0 Unit 1 Safeguards Building 14 15 1-089# 831' 6" 2/0 (Vol. Con. Tank Rm.) 0

                                                                                                           -u Unit 1 Safeguards Building 16       16       1-096        831' 6"                       28(1 )(6)/0 z

< -u I (X) Unit 1 Safeguards Building 144 144 1-088 831' 6" 5/0 -u "Tl

                                                                                                           -u Unit 1 Safeguards Building 155      15       1-090        831' 6"                       2/0         :::0 Unit 1 Safeguards Building 2g       144      1-092        831' 6"                       1/0 Unit 1 Safeguards Building 2g       144      1-093        831' 6"                       1/0 Unit 1 Safeguards Building 17a      17a      1-1 OOA-H    859' 6"                       8/0 Unit 1 Safeguards Building 17a      17a      1-100        852' 6"                       3/0 Unit 1 Safeguards Building 18       18       1-103        852' 6"                       32(1 )(6)/0

0 CD
_ Unit 1 Safeguards Building 18 18 1-104 852' 6" 6/0 a*

(/)

J Unit 1 Safeguards Building 18 18 1-105 852' 6" 1/0 N

<D Unit 1 Safeguards Building 17c 17c 1-11 OA-D 880' 6" 4/0 Unit 1 Safeguards Building 17c 17c 1-109A-D 880' 6" 4/0 Unit 1 Safeguards Building 19 17c 1-107 873' 6" 3/0

Table 1 FIRE DETECTION INSTRUMENTATION Page 4 of 19 TOTAL NUMBER OF INSTRUMENTS* FIRE DETECT HEAT FLAME SMOKE INSTRUMENT LOCATION ZONE ZONE ROOM ELEV. (x/y) (x/y) (x/y) Unit 1 Safeguards Building 2g 144 1-097 841' 6" 1/0 Unit 1 Safeguards Building 2h 144 1-099 841' 6" 2/0 Unit 1 Safeguards Building 15 144 1-098 841' 6" 1/0 Unit 1 Safeguards Building 0 20 1-111 896' 6" 1/0 (Emer. Air Lock Access) Unit 1 Safeguards Building 3 3 1-106 873' 6" 1/0 0

                                                                                                         -u Auxiliary Building         21a      21a     X-179         790' 6"                       710       z

< -u I Auxiliary Building 21a 21a X-175 790' 6" 12/0 -u <D "Tl

                                                                                                         -u Auxiliary Building         21a      21a     X-162         790' 6"                       1/0       :::0 Auxiliary Building         21a      21a     X-166         790' 6"                       1/0 Auxiliary Building         21a      21a     X-176#        790' 6"                       2/0 Auxiliary Building         21a      21a     X-180         790' 6"                       19/0 Auxiliary Building         21a      21a     X-167#        790' 6"                       1/0 Auxiliary Building         21a      21a     X-165         790' 6"                       2/0

0 CD
_ Auxiliary Building 21a 21a X-163# 790' 6" 1/0 a*

(/)

J Auxiliary Building 21a 21a X-172 790' 6" 1/0 N

<D Auxiliary Building 21a 21a X-173 790' 6" 1/0 Auxiliary Building 21a 21a X-174 790' 6" 16/0 Auxiliary Building 21a 21a X-177 790' 6" 1/0

Table 1 FIRE DETECTION INSTRUMENTATION Page 5 of 19 TOTAL NUMBER OF INSTRUMENTS* FIRE DETECT HEAT FLAME SMOKE INSTRUMENT LOCATION ZONE ZONE ROOM ELEV. (x/y) (x/y) (x/y) Auxiliary Building 21a 21a X-178 790' 6" 1/0 Auxiliary Building 21a 21a X-184# 790' 6" 1/0 Auxiliary Building 21a 21a X-185# 790' 6" 1/0 Auxiliary Building 21b 21b X-207 810' 6" 45/0 Auxiliary Building 21b 21b X-202 810' 6" 1/0 Auxiliary Building 21b 21b X-203 810' 6" 1/0 0

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< Auxiliary Building 21b 21b X-188# 810' 6" 1/0 -u N I

                                                                                                               -u 0                                                                       810' 6" Auxiliary Building                   21b     21b     X-189#                                      1/0       "Tl
                                                                                                               -u 810' 6"                                 :::0 Auxiliary Building                   21b     21b     X-190                                       3/0 Auxiliary Building                   21b     21b     X-193#        810' 6"                       1/0 Auxiliary Building                   21c     21b     X-208         822' 0"                       1/0 Auxiliary Building                   21c     21b     X-209         822' 0"                       1/0 Auxiliary Building                   21d     21d     X-226         831' 6"                       28/0

0 Auxiliary Building 21d 21d X-219 & 831' 6" 17/0 CD
_ X-219A a*

(/) Auxiliary Building 21d 21d X-223 831' 6" 3/0

J N

<D Auxiliary Building (Stair No. A-11) 21d 21d X-214 831' 6" 2/0 Auxiliary Building (Stair No. A-1 0) 21d 21d X-212 831' 6" 2/0 Auxiliary Building 21d 21d X-210A# & B 831' 6" 2/0

Table 1 FIRE DETECTION INSTRUMENTATION Page 6 of 19 TOTAL NUMBER OF INSTRUMENTS* FIRE DETECT HEAT FLAME SMOKE INSTRUMENT LOCATION ZONE ZONE ROOM ELEV. (x/y) (x/y) (x/y) Auxiliary Building 21d 21d X-213# 831' 6" 14/0 Auxiliary Building 21d 21d X-218# 831' 6" 2/0 Auxiliary Building 21d 21d X-216# 831' 6" 2/0 Auxiliary Building 21e 21e X-230# 842'0" 10/0 Auxiliary Building (Stair No. A-12) 21e 21e X-232 842'0" 2/0 Auxiliary Building (Stair No. A-13) 21e 21e X-233 842'0" 2/0 0

                                                                                                                -u z

< Auxiliary Building 21f 21f X-235 & 852' 6" 39/0 -u N I X-234 -u "Tl Auxiliary Building 21f 21f X-241 852' 6" 31/0

-u

0 Auxiliary Building 21f 21f X-236 852' 6" 4/0 Auxiliary Building 21g 21g X-243 862'6" 3/0 Auxiliary Building 21f 21g X-239 852' 6" 4/0 Auxiliary Building 22 22 X-181A/B 810' 6" 1/0 X-207A/B

0 Auxiliary Building 23 23 X-194# 810' 6" 1/0 CD Auxiliary Building 24 24 X-195# 810' 6" 1/0 a*

(/)

J N Auxiliary Building 25 25 X-196# 810' 6" 1/0

<D Auxiliary Building 26 26 X-197 810' 6" 1/0 Auxiliary Building 27 27 X-198 810' 6" 1/0

Table 1 FIRE DETECTION INSTRUMENTATION Page 7 of 19 TOTAL NUMBER OF INSTRUMENTS* FIRE DETECT HEAT FLAME SMOKE INSTRUMENT LOCATION ZONE ZONE ROOM ELEV. (x/y) (x/y) (x/y) Auxiliary Building 28 28 X-199# 810' 6" 1/0 Auxiliary Building 29 29 X-200# 810' 6" 1/0 Auxiliary Building 30 30 X-201# 810' 6" 1/0 Auxiliary Building 31b 21d X-225 831' 6" 6/0 Auxiliary Building 32 32 X-204 810' 6" 1/0 Auxiliary Building 33 33 X-205 810' 6" 1/0 0

                                                                                                         -u z

< Auxiliary Building 38 38 X-245 873' 6" 48/0 -u N I

                                                                                                         -u N

Auxiliary Building 39 39 X-244 873' 6" 28/0 "Tl

                                                                                                         -u 886' 6"                                 :::0 Auxiliary Building            40       40      X-246                                       19/0 Electrical & Control Building 43       43      X-113         778' 0"                       40(1 )/0 Electrical & Control Building 43       44      X-113         778' 0"                       3/0 Electrical & Control Building 44       44      X-114         778' 0"                       5/0 Electrical & Control Building 47       43      X-115         778' 0"                       3/0

0 Electrical & Control Building 49 49 X-117 792' 0" 2/0 CD Electrical & Control Building 51 51 X-119 792' 0" 2/0 a*

(/)

J Electrical & Control Building 153 43 X-115A 778' 0" 6/0 N

<D Electrical & Control Building 154 43 X-115B 778' 0" 8/0 Electrical & Control Building 149 149 X-115D 778' 0" 2/0 Electrical & Control Building 150 150 X-115C 778' 0" 2/0

Table 1 FIRE DETECTION INSTRUMENTATION Page 8 of 19 TOTAL NUMBER OF INSTRUMENTS* FIRE DETECT HEAT FLAME SMOKE INSTRUMENT LOCATION ZONE ZONE ROOM ELEV. (x/y) (x/y) (x/y) Electrical & Control Building 48 48 X-116 792' 0" 2/0 Electrical & Control Building 50 50 X-118 792' 0" 2/0 Electrical & Control Building 52 52 X-120 792' 0" 2/0 Electrical & Control Building 53 53 X-121 792' 0" 2/0 Electrical & Control Building 54 54 X-122 792' 0" 3/0 Electrical & Control Building 55 55 X-123 792' 0" 2/0 0

                                                                                                           -u z

< Electrical & Control Building 56 56 X-124 792' 0" 2/0 -u N I

-u

(,V Electrical & Control Building 57 57 X-125 792' 0" 3/0 "Tl

                                                                                                           -u 792' 0"                                   :::0 Electrical & Control Building 58       58      X-126                                       2/0 Electrical & Control Building 59       59      X-128         792' 0"                       2/0 Electrical & Control Building 60       60      X-127         792' 0"                       2/0 Electrical & Control Building 61       61      X-129         792' 0"                       2/0 Electrical & Control Building 63       63      X-134         807' 0"                       0/35(1 )(6)

0 Electrical & Control Building 64 64 X-133 807' 0" 0/35(1 )(6)

CD Electrical & Control Building 65 65 X-135 830' 0" 11/0 a* (/)

J (Unit 1 MCB)

N <D Electrical & Control Building 65 65 X-135 830' 0" 11/0 (Unit 2 MCB)

Table 1 FIRE DETECTION INSTRUMENTATION Page 9 of 19 TOTAL NUMBER OF INSTRUMENTS* FIRE DETECT HEAT FLAME SMOKE INSTRUMENT LOCATION ZONE ZONE ROOM ELEV. (x/y) (x/y) (x/y) Electrical & Control Building 65 65 X-135 830' 0" 34/0 (Unit 1 Relay Rack) Electrical & Control Building 65 65 X-135 830' 0" 34/0 (Unit 2 Relay Rack) Electrical & Control Building 65 65 X-135 830' 0" 9/0 (Underside of slab above suspended ceiling) 0

                                                                                                                   -u Electrical & Control Building        65       65      X-135         839' 4"                       710       z

< -u N I .j::>.. (In suspended ceiling) -u "Tl Electrical & Control Building 65 65 X-135 830' 0" 32(1 )/0 -u

0 (Underside of slab at Elev. 854' 4")

Electrical & Control Building 65 70 X-148 840' 6" 1/0 Electrical & Control Building 70 70 X-149A 840' 6" 4/0 (Above false ceiling) Electrical & Control Building 71 71 X-148A 840' 6" 4/0 (Above false ceiling)

0 CD Electrical & Control Building 72 72 X-148B 840' 6" 4/0 (Above false ceiling) a*

(/)

J N

Electrical & Control Building 140 140 X-148C 840' 6" 4/0 <D Electrical & Control Building 141 141 X-148D 840' 6" 4/0 Electrical & Control Building 74 65 X-150A 854' 4" 2(2)/0 (Mech. Equip. Room)

Table 1 FIRE DETECTION INSTRUMENTATION Page 10 of 19 TOTAL NUMBER OF INSTRUMENTS* FIRE DETECT HEAT FLAME SMOKE INSTRUMENT LOCATION ZONE ZONE ROOM ELEV. (x/y) (x/y) (x/y) Electrical & Control Building 74 65 X-150A 854' 4" 1(3)/0 Electrical & Control Building 74 65 X-150A 854' 4" 2(5)/0 Electrical & Control Building 74 65 X-150A 854' 4" 1(5)/0 Electrical & Control Building 74 65 X-150A 854' 4" 1(7)/0 Electrical & Control Building 73 65 X-150 854' 4" 1(2)/0 Electrical & Control Building 73 65 X-150 854' 4" 1(4)/0 0

                                                                                                         -u z

< Electrical & Control Building 73 65 X-150 854' 4" 2(5)/0 -u N I

                                                                                                         -u (J1 Electrical & Control Building 73       65      X-150         854' 4"                       1(7)/0    "Tl
                                                                                                         -u 830' 0"                                 :::0 Electrical & Control Building 66       66      X-136                                       0/4 Electrical & Control Building 66       66      X-136         Above                         0/1 false ceiling Electrical & Control Building 65       67      X-140         830' 0"                       1/0 Electrical & Control Building 67       67      X-137         830' 0"                       1/0

0 Electrical & Control Building 45 67 X-138 830' 0" 1/0 CD Electrical & Control Building 68 68 X-146 830' 0" 1/0 a*

(/)

J N Electrical & Control Building 69 69 X-147 830' 0" 0/4

<D Electrical & Control Building 69 69 X-147 Above 0/1 false ceiling

Table 1 FIRE DETECTION INSTRUMENTATION Page 11 of 19 TOTAL NUMBER OF INSTRUMENTS* FIRE DETECT HEAT FLAME SMOKE INSTRUMENT LOCATION ZONE ZONE ROOM ELEV. (x/y) (x/y) (x/y) Electrical & Control Building 70 70 X-149A 840' 0" 2/0 Electrical & Control Building 71 71 X-148A 840' 0" 2/0 Electrical & Control Building 72 72 X-148B 840' 6" 1/0 Electrical & Control Building 73 73 X-150 854' 4" 14/0 Electrical & Control Building 74 74 X-150A 854' 4" 14/0 Electrical & Control Building 75 75 X-151 854' 4" 11/0 0

                                                                                                           -u z

< Electrical & Control Building 75 75 X-151A 854' 4" 2/0 -u N I (J)

                                                                                                           -u Electrical & Control Building 161      75      X-151B        854' 4"                         2/0       "Tl
                                                                                                           -u 830' 0"                                   :::0 Electrical & Control Building 162      67      X-144                                         1/0 Electrical & Control Building 162      65      X-144         830' 0" 1/0 Electrical & Control Building 162      65      X-143         830' 0" 1/0 Electrical & Control Building 163      65      X-142         830' 0" 1/0 Electrical & Control Building 163      67      X-142         830' 0"                         1/0

0 Electrical & Control Building 65 65 X-139 830' 0" 1/0 CD
_ (Prod. Supv. Office) a*

(/)

J Fuel Building 96 96 X-249 810' 6" 2/0 N

<D Fuel Building 97 97 X-249A 810' 6" 2/0 Fuel Building 99a 21f X-255 810' 6" 1/0 Fuel Building 99a 99a X-255 810' 6" 710

Table 1 FIRE DETECTION INSTRUMENTATION Page 12 of 19 TOTAL NUMBER OF INSTRUMENTS* FIRE DETECT HEAT FLAME SMOKE INSTRUMENT LOCATION ZONE ZONE ROOM ELEV. (x/y) (x/y) (x/y) Fuel Building 99a 99b X-255 810' 6" 3/0 Fuel Building 99a 99a X-256 810' 6" 1/0 Fuel Building 99a 99a X-247A 802' 0" 2/0 Fuel Building 99a 99a X-248 810' 6" 6/0 Fuel Building 99a 99a X-249B 810' 6" 2/0 Fuel Building 188 99a X-250A 810' 6" 4/0 0

                                                                                                         -u z

< Fuel Building 99b 99b X-247 800' 2" 2/0 -u N I

-u

-..J Fuel Building 99c 99a X-253 810' 6" 2/0 "Tl

                                                                                                         -u 810' 6"                                 :::0 Fuel Building                  99c     99a     X-251                                       2/0 Fuel Building                  99c     99a     X-252         810' 6"                       1/0 Fuel Building                  99a     99a     X-262#        824' 6"                       2/0 Fuel Building                  99c     99a     X-261         822' 6"                       1/0 Fuel Building                  99d     99d     X-270         841' 0"                       2/0

0 Fuel Building 99d 99d X-264 831' 9" 4/0 CD Fuel Building 99d 99d X-265 838' 4" 3/0 2/0 a*

(/)

J Fuel Building 99d 99d X-268 841' 0" 3/0 1/0 N

<D Fuel Building (Spent Fuel Pool 99e 99d X-263 844'6" 1/0 Area) Fuel Building 99e 99e X-272 860' 0" 12/0

Table 1 FIRE DETECTION INSTRUMENTATION Page 13 of 19 TOTAL NUMBER OF INSTRUMENTS* FIRE DETECT HEAT FLAME SMOKE INSTRUMENT LOCATION ZONE ZONE ROOM ELEV. (x/y) (x/y) (x/y) Fuel Building (Powdered Hot Phase 99e 99e X-272A 860' 0" 3/0 Separator Area) Fuel Building 99e 99e X-272B 860' 0" 1/0 Fuel Building 99b 99b X-257 810' 6" 1/0 Fuel Building 99b 99b X-257A 810' 6" 1/0 Service Water Intake Structure 103 103 X-276 796' 0" 4/0 0

                                                                                                               -u Service Water Intake Structure    104b     104b    X-275         796' 0" 4/0                     8/0       z

< -u N I (X) Service Water Intake Structure 104b 104b X-278 810' 6" 3/0 2/0 -u "Tl

                                                                                                               -u Unit 1 Containment Area (Steam    101d                           832' 6" 3/0                               :::0 Generator Compartments RCP)

Unit 1 Containment Area (Steam 101f 860' 0" 3/0 Generator Compartments RCP) Unit 1 Containment Area (Steam 101h 905' 0" 3/0 Generator Compartments RCP) Unit 1 Containment Area 101f 860' 0" 1/0

0 CD (Rod Position Indicator Room) a*

(/) Unit 1 Containment Area 101b 808' 0" 3/0

J (General Area Protection)

N <D Unit 1 Containment Area 101d 832' 0" 3/0 (General Area Protection)

Table 1 FIRE DETECTION INSTRUMENTATION Page 14 of 19 TOTAL NUMBER OF INSTRUMENTS* FIRE DETECT HEAT FLAME SMOKE INSTRUMENT LOCATION ZONE ZONE ROOM ELEV. (x/y) (x/y) (x/y) Unit 1 Containment Area 101f 860' 0" 3/0 (General Area Protection) Unit 1 Containment Area 101f 860' 0" 1/0 (Reactor Area) Unit 2 Safeguards Building 1a 76a 2-060 773' 0" 2/0 Unit 2 Safeguards Building 1a 76a 2-056A 773' 0" 3/0 0 Unit 2 Safeguards Building 1a 76a 2-051 773' 0" 2/0 -u z < -u N I Unit 2 Safeguards Building 1a 76a 2-052# 773' 0" 1/0 -u <D "Tl Unit 2 Safeguards Building 2a 77a 2-062 773' 0" 2/0 -u

0 Unit 2 Safeguards Building 2a 77a 2-056B 773' 0" 3/0 Unit 2 Safeguards Building 2a 77a 2-054 773' 0" 2/0 Unit 2 Safeguards Building 2a 77a 2-053# 773' 0" 1/0 Unit 2 Safeguards Building 1c 76c 2-063 790' 6" 2/0 Unit 2 Safeguards Building 1c 76c 2-066# 790' 0" 2/0

0 Unit 2 Safeguards Building 1c 76c 2-068# 790' 6" 2/0 CD a*

(/) Unit 2 Safeguards Building 2c 77c 2-069# 790' 6" 2/0

J N Unit 2 Safeguards Building 2c 77c 2-067# 790' 6" 2/0

<D Unit 2 Safeguards Building 2c 77c 2-065 790' 6" 2/0 Unit 2 Safeguards Building 4 79 2-070 790' 6" 14/0

Table 1 FIRE DETECTION INSTRUMENTATION Page 15 of 19 TOTAL NUMBER OF INSTRUMENTS* FIRE DETECT HEAT FLAME SMOKE INSTRUMENT LOCATION ZONE ZONE ROOM ELEV. (x/y) (x/y) (x/y) Unit 2 Safeguards Building 4 79 2-071 790' 6" 10/0 Unit 2 Safeguards Building 4 79 2-064 790' 6" 2/0 Unit 2 Safeguards Building 4 79 Vent Chase 831' 6" 1/0 Unit 2 Safeguards Building 4 79 2-085D 796' 0" 11/0 Unit 2 Safeguards Building 5 80 2-072 790' 6" 3/0 Unit 2 Safeguards Building 6 81 2-073 790' 6" 3/0 0

                                                                                                       -u z

< Unit 2 Safeguards Building 7 82 2-074 790' 6" 4/0 -u I (,V -u 0 810' 6" Unit 2 Safeguards Building 8 83 2-078 1/0 "Tl

                                                                                                       -u 810' 6"                                 :::0 Unit 2 Safeguards Building 8         83      2-082                                       17/0 Unit 2 Safeguards Building 8         83      2-079         810' 6"                       3/0 Unit 2 Safeguards Building 142       145     2-077A#       810' 6"                       5/0 (Rad. Pen. Area)

Unit 2 Safeguards Building 142 147 2-077A 831' 6" 2/0 (Pipe Chase)

0 Unit 2 Safeguards Building 143 146 2-077B# 810' 6" 5/0 CD (Rad. Pen. Area) a*

(/)

J Unit 2 Safeguards Building 143 147 2-077B 831' 6" 1/0 N

<D (Pipe Chase) Unit 2 Safeguards Building 2d(143) 146 2-076 800' 6" 1/0 Unit 2 Safeguards Building 1d(142) 145 2-075 800' 6" 1/0

Table 1 FIRE DETECTION INSTRUMENTATION Page 16 of 19 TOTAL NUMBER OF INSTRUMENTS* FIRE DETECT HEAT FLAME SMOKE INSTRUMENT LOCATION ZONE ZONE ROOM ELEV. (x/y) (x/y) (x/y) Unit 2 Safeguards Building 2e 146 2-080 812'6" 1/0 Unit 2 Safeguards Building 10a 85a 2-084 810' 6" 12/0 Unit 2 Safeguards Building 10b 85b 2-099B 844' 0" 710 Unit 2 Safeguards Building 11 86 2-099D 844'0" 0/2 Unit 2 Safeguards Building 12a 87a 2-085 810' 6" 12/0 Unit 2 Safeguards Building 12b 87b 2-099A 844' 0" 710 0

                                                                                                             -u z

< Unit 2 Safeguards Building 13 88 2-099C 844'0" 0/2 -u I (,V

                                                                                                             -u Unit 2 Safeguards Building 9        84      2-083         810' 6"                         29(1 )(6)/0 "Tl
                                                                                                             -u 810' 6"                                     :::0 Unit 2 Safeguards Building 9        84      2-085A                                        1/0 Unit 2 Safeguards Building 15       90      2-094         831' 6"                         20(1 )/0 Unit 2 Safeguards Building 15       90      2-095         831' 6"                         5/0 Unit 2 Safeguards Building 14       90      2-089#        831' 6"                         2/0 (Vol. Con. Tank Rm)

Unit 2 Safeguards Building 16 91 2-096 831' 6" 29(1 )(6)/0

0 CD
_ Unit 2 Safeguards Building 2g 90 2-093 831' 6" 1/0 a*

(/)

J Unit 2 Safeguards Building 144 147 2-088 831' 6" 5/0 N

<D Unit 2 Safeguards Building 2g 90 2-091 831' 6" 1/0 Unit 2 Safeguards Building 2g 147 2-092 831' 6" 1/0 Unit 2 Safeguards Building 17a 92a 2-100A-H 859' 6" 8/0

Table 1 FIRE DETECTION INSTRUMENTATION Page 17 of 19 TOTAL NUMBER OF INSTRUMENTS* FIRE DETECT HEAT FLAME SMOKE INSTRUMENT LOCATION ZONE ZONE ROOM ELEV. (x/y) (x/y) (x/y) Unit 2 Safeguards Building 17a 92a 2-100 852' 6" 4/0 Unit 2 Safeguards Building 18 93 2-103 852' 6" 36(1 )(6)/0 Unit 2 Safeguards Building 18 93 2-104 852' 6" 6/0 Unit 2 Safeguards Building 18 93 2-105 852' 6" 1/0 Unit 2 Safeguards Building 17c 92c 2-11 OA-D 880' 6" 4/0 Unit 2 Safeguards Building 17c 92c 2-109A-D 880' 6" 4/0 0

                                                                                                              -u z

< Unit 2 Safeguards Building 19 92c 2-107 873' 6" 3/0 -u I (,V -u N Unit 2 Safeguards Building 3 92c 2-106 873' 6" 2/0 "Tl

                                                                                                              -u 831' 6"                                     :::0 Unit 2 Safeguards Building     155      90      2-090                                         2/0 Unit 2 Safeguards Building     15       90      2-098         841' 6"                         1/0 Unit 2 Safeguards Building     2h       90      2-099         841' 6"                         2/0 Unit 2 Safeguards Building     20       95      2-111         896' 6"                         1/0 (Emer. Air Lock Access)

Unit 2 Containment Area (Steam 101d 832' 6" 3/0

0 Generator Compartments- RCP)

CD a* (/) Unit 2 Containment Area (Steam 101f 860' 0" 3/0

J Generator Compartments- RCP)

N <D Unit 2 Containment Area (Steam 101h 905' 0" 3/0 Generator Compartments- RCP)

Table 1 FIRE DETECTION INSTRUMENTATION Page 18 of 19 TOTAL NUMBER OF INSTRUMENTS* FIRE DETECT HEAT FLAME SMOKE INSTRUMENT LOCATION ZONE ZONE ROOM ELEV. (x/y) (x/y) (x/y) Unit 2 Containment Area (Rod 101f 860' 0" 1/0 Position Indicator Room) Unit 2 Containment Area 101b 808' 0" 3/0 (General Area Protection) Unit 2 Containment Area 101d 832' 0" 3/0 (General Area Protection) Unit 2 Containment Area 101f 860' 0" 3/0 0

-u

< (General Area Protection) z

                                                                                                       -u I

(,V (,V Unit 2 Containment Area 101f 860' 0" 1/0

                                                                                                       -u "Tl (Reactor Area)                                                                                     -u

0

0 CD a*

(/)

J N

<D

CPNPP/FPR Table 1 (continued) TABLE NOTATIONS Page 19 of 19

(x/y): xis a number of "Function A" (early warning fire detection and notification only instruments).

y is number of "Function B" (actuation of fire Suppression Systems and early warning and notification).

Zone V radiation area outside containment.

(1) Two or more adjacent inoperable detectors are not permitted unless all points within the affected area are within 21 feet (horizontal distance of an OPERABLE detector). (2) The detection instrument is located in the return air ductwork for the Control Room HVAC System. (3) These detection instruments are located in HVAC ductwork and detect smoke entering the fresh air supply to the Control Room (Fire Zone 65) from the south side of the electrical and Control Building. (4) These detection instruments are located in HVAC ductwork and detect smoke entering the fresh air supply to the Control Room (Fire Zone 65) from the north side of the electrical and Control Building). (5) These detection instruments are located in HVAC ductwork and detect smoke entering the air supply to the Control Room (Fire Zone 65) from the HVAC units serving that system. (6) Detectors initiate an alarm in the Control Room for manual actuation of the preaction system in this area. (7) These detection instruments are located in the Emergency Filtration Filter Units discharge ductwork. IV-34 Revision 29

CPNPP/FPR Table 2 SPRAY/SPRINKLER SYSTEMS Page 1 of 3 BUILDING AREA DESCRIPTION FIRE ZONES AFFECTED Electrical Control Unit 1 Cable Spreading Rm. 64 North Half El. 807'-0" Unit 1 Cable Spreading Rm. 64 South Half El. 807'-0" Unit 2 Cable Spreading Rm. 63 South Half El. 807'-0" Unit 2 Cable Spreading Rm. 63 North Half El. 807'-0" Unit 1 Diesel Generator Diesel Day Tank Enclosure- 13 Train B. El. 844' -0" Diesel Generator Rm.- Train B 12 El. 810'-6" Diesel Day Tank Enclosure - 11 Train A El. 844'-0" Diesel Generator Rm.- Train A 10 El. 810'-6" Unit 2 Diesel Generator Diesel Day Tank Enclosure- 13 Train B El. 844'-0 Diesel Generator Rm.- Train B 12 El. 810' -6" Diesel Day Tank Enclosure - 11 Train A El. 844' -0" Diesel Generator Rm.- Train A 10 El. 810'-6" Unit 1 Safeguards Corridor & Pipe Penetration Area 15,144 El. 831'-6" Corridor & Chem. Tank Rm. 1C, 4, 2C El. 790'-6" Corridor El. 81 0'-6" 8 IV-35 Revision 29

CPNPP/FPR Table 2 SPRAY/SPRINKLER SYSTEMS Page 2 of 3 BUILDING AREA DESCRIPTION FIRE ZONES AFFECTED Pipe Penetration Area 17a, 17b, 17c El. 852'-6", 873'-6", 880'-6" Radioactive Penetration Area 142, *** 143*** (Cable Trays Only) El. 81 0'-6" Electrical Equipment Rooms 9,16,18 El. 81 0'-6", 831 '-6", 852'-6" Unit 2 Safeguards Corridor & Pipe Penetration Area 15,144 El. 831'-6" Corridor & Chem. Tank Rm. 1C, 4, 2C El. 790'-6" Corridor El. 81 0'-6" 8 Pipe Penetration Area 17a, 17b, 17c El. 852'-6", 873'-6", 880'-6" Radioactive Penetration Area 142, *** 143*** (Cable Trays Only) El. 81 0'-6" Electrical Equipment Rooms 9, 16, 18 El. 81 0'-6", 831 '-6", 852'-6" Auxiliary South Half Corr. El. 852'-6" 21f North Half Corr. El. 852'-6" 21f, 73** South Half Corr. El. 831 '-6" 21d North Half Corr. El. 831 '-6" 21d North Half Corr. El. 81 0'-6" 21b South Half Corr. El. 81 0'-6" 21b Heat Exchange & Tube Removal 21a Area El. 790'-6" North Aux. Corr. El. 790'-6" 21a Chiller Eq. Area (Unit 2) 154** El. 778'-0" Batt. Rm. Corr. 54** IV-36 Revision 29

CPNPP/FPR Table 2 SPRAY/SPRINKLER SYSTEMS Page 3 of 3 BUILDING AREA DESCRIPTION FIRE ZONES AFFECTED El. 792'-0" & Mech. Eq. Area 43** El. 778'-0" 44** South Aux. Corr. El. 790'-6" 21a Chiller Eq. Area (Unit 1) 153** El. 778'-0" Batt. Rm. Corr. 57** El. 792'-0" & Mech. Eq. Area 43** El. 778'-0" 47** Stair Area A-11 Filter Storage 21 d, 19*, 21f El. 831'-6", El. 842'-0" & El. 852'-6" Service Water Intake Structure SWIS (General Area) 104a, 104b El. 796'-0", El. 81 0'-6" TABLE NOTATIONS

Fire zones are located in Safeguards Building.

**     Fire zones are located in E&C Building.

- - Zone V Radiation Area.

IV-37 Revision 29

CPNPP/FPR Table 3 FIRE HOSE STATIONS Page 1 of 5 TAG NO BUILDING HOSE STATION ELEVATION ZONES AFFECTED Fuel CPX-FPFEFH-02 81 0'-6" 99A, 99C CPX-FPFEFH-03 81 0'-6" 96, 97, 99A, 998 CPX-FPFEFH-04 81 0'-6" 98, 99a CPX-FPFEFH-01 841 '-0" 98, 99d, 100 CPX-FPFEFH-05 841 '-0" 96, 99b, 99d, 100 CPX-FPFEFH-06 860'-0" 99e CPX-FPFEFH-07 860'-0" 99e Electrical & Control CP1-FPFEEH-01 778'-0" 43,44,45, 149,150 CP1-FPFEEH-06 778'-0" 43,47, 149,150 CP2-FPFEEH-01 792'-0" 45, 48, 50, 52, 53, 54, 55, 58, 59 CP1-FPFEEH-02 792'-0" 49, 51, 53, 56, 57, 60, 61,62 CP1-FPFEEH-03 807'-0" 62,64, 75 CP1-FPFEEH-04 807'-0" 64 CP2-FPFEEH-02 807'-0" 45, 63, 161 CP2-FPFEEH-03 807'-0" 63 CPX-FPFEEH-03 830'-0 45, 62, 65, 66, 67, 68, 69, 162, 163 CPX-FPFEEH-01 830'-0" 65 CPX-FPFEEH-02 830'-0" 65 CPX-FPFEEH-04 840'-6" 45, 65, 70, 71, 72, 140, 141 , 142 CP2-FPFEEH-04 854'-4" 45, 73, 75, 161 CP1-FPFEEH-07 854'-4" 45, 74, 75 Unit 1 Diesel CP1-FPFESH-16 81 0'-6" 10a Generator CP1-FPFESH-17 844'-0" 12b, 13, 1Ob, 11 Unit 1 Safeguards CP1-FPFESH-11 773'-6" 2a,4 CP1-FPFESH-12 773'-6" 1a,3 CP1-FPFESH-01 790'-6" 2c, 2d, 4, 2b, 7, 3 CP1-FPFESH-02 790'-6" 1c, 1d, 3, 4, 1b IV-38 Revision 29

CPNPP/FPR Table 3 FIRE HOSE STATIONS Page 2 of 5 TAG NO BUILDING HOSE STATION ELEVATION ZONES AFFECTED CP1-FPFESH-13 790'-6" 1c, 4, 1b CP1-FPFESH-14 790'-6" 2c, 4, 5,6, 7, 2b CP1-FPFESH-20 790'-6" 4 CP1-FPFESH-21 796'-6" 4 CP1-FPFESH-22 796'-6" 4 CP1-FPFESH-03 81 0'-6" 9, 12a CP1-FPFESH-04 81 0'-6" 9, 157 CP1-FPFESH-05 81 0'-6" 3, 8, 1d CP1-FPFESH-15 81 0'-6" 2e, 2f, 8, 142, 143, 3 CP1-FPFESH-06 831 '-6" 16, 157 CP1-FPFESH-07 831 '-6" 15, 16 CP1-FPFESH-08 831 '-6" 2g, 3, 14, 15, 16 144, 155, 2h CP1-FPFESH-09 852'-6" 17a, 18, 158 CP1-FPFESH-10 852'-6" 18, 157 CP1-FPFESH-18 852'-6" 17a, 17c CP1-FPFESH-19 873'-6" 3, 19, 20, 17b, 17c, 158 Unit 2 Diesel CP2-FPFESH-17 844'-0" 12b, 13, 11, 1Ob Generator Unit 2 Safeguards CP2-FPFESH-12 773'-6" 1a,3 CP2-FPFESH-11 773'-6" 2a, 4 CP2-FPFESH-02 790'-6" 1c, 1d, 3, 4, 1b CP2-FPFESH-13 790'-6" 1c, 4, 1b CP2-FPFESH-01 790'-6" 2c,2d,4,2b, 7, 3 CP2-FPFESH-14 790'-6" 2c, 4, 5, 6, 7, 2b CP2-FPFESH-05 81 0'-6" 3, 8, 1d CP2-FPFESH-15 81 0'-6" 2e, 2f, 8, 142, 143, 3 CP2-FPFESH-03 81 0'-6" 9, 12a CP2-FPFESH-04 81 0'-6" 9, 157 CP2-FPFESH-16 81 0'-6" 10a, 9 CP2-FPFESH-07 831 '-6" 15, 16 IV-39 Revision 29

CPNPP/FPR Table 3 FIRE HOSE STATIONS Page 3 of 5 TAG NO BUILDING HOSE STATION ELEVATION ZONES AFFECTED CP2-FPFESH-08 831 '-6" 2g, 3, 14, 15, 16, 144, 155, 2h CP2-FPFESH-06 831 '-6" 16, 157 CP2-FPFESH-09 852'-6" 17a,18,3 CP2-FPFESH-1 0 852'-6" 18, 157 CP2-FPFESH-18 852'-6" 17a, 100 CP2-FPFESH-19 873'-6" 3, 19, 20, 17b, 17c CP2-FPFESH-20 790'-6" 4 CP2-FPFESH-21 796'-6" 4 CP2-FPFESH-22 796'-6" 4 CP2-FPFESH-23 852'-6" 18, 158, 17a Service Water Intake CPX-FPFEIH-01 796'-0" 104b, 103, 104a Structure Auxiliary CPX-FPFEXH-01 790'-6" 21a, 154* CPX-FPFEXH-02 790'-6" 21 a, 153*, 46 CPX-FPFEXH-03 790'-6" 21a CPX-FPFEXH-18 790'-6" 21a CPX-FPFEXH-19 790'-6" 21a CPX-FPFEXH-04 81 0'-6" 21b, 31a, 46 CPX-FPFEXH-05 81 0'-6" 21b, 21c, 27, 28,29, 30, 33 CPX-FPFEXH-06 81 0'-6" 21b, 21c, 23,24 25,26, 32 CPX-FPFEXH-07 81 0'-6" 21b,22 CPX-FPFEXH-09 831 '-6" 21d, 34, 36 CPX-FPFEXH-08 831 '-6" 21 d, 21 h, 31 b, 35, 37, 46 CPX-FPFEXH-20 831 '-6" 21d CPX-FPFEXH-21 831 '-6" 21d CPX-FPFEXH-22 842'-0" 21d,21e CPX-FPFEXH-23 842'-0" 21d,21e CPX-FPFEXH-1 0 852'-6" 21f, 21 g, 46 IV-40 Revision 29

CPNPP/FPR Table 3 FIRE HOSE STATIONS Page 4 of 5 TAG NO BUILDING HOSE STATION ELEVATION ZONES AFFECTED CPX-FPFEXH-11 852'-6" 21f CPX-FPFEXH-24 852'-6" 21d, 21f CPX-FPFEXH-12 873'-6" 39 CPX-FPFEXH-13 873'-6" 39 CPX-FPFEXH-14 873'-6" 38 CPX-FPFEXH-15 873'-6" 38 CPX-FPFEXH-16 886'-6" 40 CPX-FPFEXH-17 886'-6" 40 Unit 1 Containment CP1-FPFECH-01 808'-0" 101 b, 101 c CP1-FPFECH-02 808'-0" 101b, 101c CP1-FPFECH-03 808'-0" 101b, 101c CP1-FPFECH-04 832'-6" 101d CP1-FPFECH-05 832'-6" 101d CP1-FPFECH-06 832'-6" 101d, 101e CP1-FPFECH-07 852'-6" 101f CP1-FPFECH-08 852'-6" 101f, 101e CP1-FPFECH-09 852'-6" 101f CP1-FPFECH-1 0 905'-0" 101h CP1-FPFECH-11 905'-0" 101h Unit 1 Turbine CP1-FPFETH-13 81 0'-6" 111 CP1-FPFETH-24 81 0'-6" 110,111 CP1-FPFETH-21 81 0'-6" 110 Unit 2 Turbine CP2-FPFETH-07 81 0'-6" 111,210 CP2-FPFETH-15 81 0'-6" 210 Unit 2 Containment CP2-FPFECH-01 808'-0" 101b, 101c CP2-FPFECH-02 808'-0" 101 b, 101 c CP2-FPFECH-03 808'-0" 101b, 101a, 101c, 101e CP2-FPFECH-04 832'-0" 101d, 101c IV-41 Revision 29

CPNPP/FPR Table 3 FIRE HOSE STATIONS Page 5 of 5 TAG NO BUILDING HOSE STATION ELEVATION ZONES AFFECTED CP2-FPFECH-05 832'-0" 101d, 101f, 101b, 101c, 101h CP2-FPFECH-06 832'-6" 101d, 101c, 101e CP2-FPFECH-07 852'-6 101f, 101c, 101e CP2-FPFECH-08 852'-6" 101f, 101h CP2-FPFECH-09 852'-6" 101f CP2-FPFECH-1 0 905'-0" 101h, 101c CP2-FPFECH-11 905'-0" 101h, 101c TABLE NOTATIONS

Fire zones are located in Safeguards Building.

**  Fire zones are located in E&C Building.

- - Zone V Radiation Area.

IV-42 Revision 29

CPNPP/FPR Table 4 YARD FIRE HYDRANTS AND ASSOCIATED HYDRANT HOSE HOUSES LOCATION HYDRANT NUMBER Adjacent to service water intake CPX-FPFEHY-01 structure Adjacent to Unit 1 condensate CPX-FPFEHY-12 storage tank Adjacent to Unit 2 condensate CPX-FPFEHY-05 storage tank IV-43 Revision 29

CPNPP/FPR Table 5 HALON SUPPRESSION SYSTEMS BUILDING AREA DESCRIPTION ZONE AFFECTED Electrical & Control Unit 1 Cable Spreading Room 64 Elev. 807'-0" Unit 2 Cable Spreading Room 63 Elev. 807'-0" IV-44 Revision 29

CPNPP/FPR COMANCHE PEAK NUCLEAR POWER PLANT FIRE PROTECTION REPORT SECTION V UNIT 1 AND UNIT 2 APPENDICES V-1 Revision 28

CPNPP/FPR SECTION V TITLE

1. Appendix A, CPNPP Fire Protection Program Separation Criteria Comparison Table 2 Appendix B, Fire Hazards Analysis Evaluation Matrix 3 Appendix C, Deviations 4 Appendix D, Fire Protection Report Figures V-2 Revision 28

CPNPP/FPR APPENDIX A CPNPP FIRE PROTECTION PROGRAM SEPARATION CRITERIA COMPARISON TABLE

CPNPP/FPR CPNPP FIRE PROTECTION PROGRAM FIRE AREA COMPARISON TABLE NOTES Comparison of Fire Areas to CPNPP F.P. Program Section II 4.5 (1) The basis for this deviation/barrier analysis is: (a) Full suppression and detection. (b) Low in-situ combustibles. (c) Sufficient separation exists. (d) Partial height concrete barriers between pumps and exhaust fans. (e) Control of transient combustibles. (f) Exhaust fans qualified at temperatures higher than temperature developed by a postulated fire. (2) The basis for this deviation barrier analysis is: (a) Alternate shutdown exists for the main control room. (b) Low combustible loading on each side of the barrier separating the safe shutdown equipment. (c) A barrier presently exists between the redundant safe shutdown equipment. (d) Full area detection. (e) Partial suppression. (3) The basis for this deviation/analysis is: (a) Sufficient separation. (b) Partial barrier exists. (c) Low combustible loading. (4) Deviation justification includes: (a) Manual operation of steam generator PORVs as required. (b) Goods separation including concrete wall. VA-1 Revision 28

CPNPP/FPR (c) Low combustible loading (all cables routed in conduits). (d) Suppression and detection. (5) Several specific instances exist where the level of conformance does not directly meet the specified criteria of Section II 4.5. Evaluations are utilized for justifying equivalent protection of safe shutdown configurations. (6) The deviation justification is based on: (a) Partial height barriers. (b) Adequate spatial separation. (c) Low combustible loading throughout the fire area with lack of continuous intervening combustibles. (d) In-situ hazards are limited to the Reactor Coolant Pumps Lubricating Oils and the electrical raceways addressed in C. The lubricating oil is eliminated by the installation design of the reactor coolant pumps oil collection system. (e) Area wide detection system along with hose station and portable fire extinguishers are available for fire brigade utilization. (f) Administrative controls are implemented to ensure no transient combustibles are stored in the fire area during power operations. (7) Deviation justification includes: (a) Negligible in-situ combustibles (b) Control of transient combustibles (c) Area wide detection (d) Manual suppression VA-2 Revision 28

COMANCHE PEAK NUCLEAR POWER PLANT FIRE PROTECTION PROGRAM SEPARATION CRITERIA FIRE AREA COMPARISON TABLE SEPARATION METHOD NO PER SECTION II 4.5 SECTION ANALYSIS/ FIRE REDUNDANT 114.5.3 EVALUATION DEVIATION AREA COMPONENTS 2b 2c 2d 2f APPLIES REQUIRED RECOMMENDED REMARKS AA X X YES YES Refer to note (5) AB X AC X AD X 0

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COMANCHE PEAK NUCLEAR POWER PLANT FIRE PROTECTION PROGRAM SEPARATION CRITERIA FIRE AREA COMPARISON TABLE SEPARATION METHOD NO PER SECTION II 4.5 SECTION ANALYSIS/ FIRE REDUNDANT 114.5.3 EVALUATION DEVIATION AREA COMPONENTS 2b 2c 2d 2f APPLIES REQUIRED RECOMMENDED REMARKS EM X EN X EO X EQ X 0 ER X -u z

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COMANCHE PEAK NUCLEAR POWER PLANT FIRE PROTECTION PROGRAM SEPARATION CRITERIA FIRE AREA COMPARISON TABLE SEPARATION METHOD NO PER SECTION II 4.5 SECTION ANALYSIS/ FIRE REDUNDANT 114.5.3 EVALUATION DEVIATION AREA COMPONENTS 2b 2c 2d 2f APPLIES REQUIRED RECOMMENDED REMARKS SJ X SK X(4) YES YES SM X NO SAFE SHUTDOWN EQUIPMENT SN X NO SAFE SHUTDOWN 0

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COMANCHE PEAK NUCLEAR POWER PLANT FIRE PROTECTION PROGRAM SEPARATION CRITERIA FIRE AREA COMPARISON TABLE SEPARATION METHOD NO PER SECTION II 4.5 SECTION ANALYSIS/ FIRE REDUNDANT 114.5.3 EVALUATION DEVIATION AREA COMPONENTS 2b 2c 2d 2f APPLIES REQUIRED RECOMMENDED REMARKS XC X NO SAFE SHUTDOWN EQUIPMENT YARD X(3) YES 2SA X 2SB X X YES 0

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COMANCHE PEAK NUCLEAR POWER PLANT FIRE PROTECTION PROGRAM SEPARATION CRITERIA FIRE AREA COMPARISON TABLE SEPARATION METHOD NO PER SECTION II 4.5 SECTION ANALYSIS/ FIRE REDUNDANT 114.5.3 EVALUATION DEVIATION AREA COMPONENTS 2b 2c 2d 2f APPLIES REQUIRED RECOMMENDED REMARKS 2SL X YES 2SM X NO SAFE SHUTDOWN EQUIPMENT 2SN X NO SAFE SHUTDOWN EQUIPMENT 0

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CPNPP/FPR APPENDIX B FHA EVALUATIONS MATRIX

CPNPP/FPR FHA EVALUATIONS MATRIX The FHA Evaluations Matrix provides a list of the FHA evaluations (See definition in Section 1-1.2.17) performed in safety related areas of the plant. A legend of the justification numbers associated with each type of FHA evaluation is given on page VB-6. VB-2 Revision 28

CPNPP/FPR FHA EVALUATIONS MATRIX UNIT 1 JUSTIFICATION NUMBER FOR LOCATION TYPE OF FHA EVALUATION FIRE FIRE AREA ZONE ROOM SUP DET CTH ICS AA 21a 162 X 3 X X AA 21a 168 X X X AA 21a 169 X X X AA 21a 170 X X X AA 21a 171 X X X AA 21a 172 X X X AA 21a 173 X X X AA 21a 174 4 1 8 X AA 21a 175 3 1 7 X AA 21a 176 X 2 X X AA 21a 179 3 X 7 X AA 21a 180 3 4 7 X AA 21a 182 X 1 X X AA 21b 191 X 1 X X AA 21b 192 X 1 X X AA 21b 202 X 2 X X AA 21b 203 3 X X X AA 21b 207 3 X 7 X AA 21c 208 X 2 X X AA 21c 209 4 2 X X AA 21d 210 X 2 X X AA 21d 211 X 1 X X AA 21d 214 3 X 7 X AA 21d 215 X 1 X X AA 21d 217 X 1 X X AA 21d 226 X X 7 X AA 21f 235 X 3 X X AA 21f 238 X 1 X X AA 21f 240 X 1 X X AA 21f 241 3 3 7 X AA 21f 242 X X X AA 22 207A X X X AA 22 181 X X X AA 27 198 4 X X X AA 34 220 X 1 X X X or N = No FHA evaluation of that type in the listed area. Y or numeric entry = FHA evaluation of that type in the listed area. VB-3 Revision 28

CPNPP/FPR FHA EVALUATIONS MATRIX UNIT 1 JUSTIFICATION NUMBER FOR LOCATION TYPE OF FHA EVALUATION FIRE FIRE AREA ZONE ROOM SUP DET CTH ICS AA 35 221 X X X AA 36 222 X X X AA 37 224 X X X AA 98 254 X X X AA 98 269 X 1 X X AA 99b 247 X 3 X X AA 99b 247 X 3 X X AA 99b 271A X 1 X X AA 99b 271A X 1 X X AA 99b 2718 X 1 X X AA 99d 270 X 3 X X AA 100 271 X 1 X X AA 153 115a X X 6 X EA 43 113 X X 5 X EA 54 122 X 3 X X EA 57 125 3 3 3 X EA 73 150 4 X 7 X EA 74 150a 4 X 8 X EC 50 118 4 X 8 X EC 51 119 4 X X X EH 52 120 4 X X X EH 53 121 4 X X X EN 64 133 X X 6 X EO 65 135 4 X X X SA 1a 57 X X X SA 1a 58 X X X SA 1a 61 X X X SA 1c 63 3 X 7 X SA 142 77N 4 3 8 X SB 2a 568 X 2 X X SB 2c 65 3 X 7 X SB 2c 67 4 X 7 X SB 2e 81 X 1 X X SB 2f 86 X 1 X X SB 2f 87 X X X X or N = No FHA evaluation of that type in the listed area. Y or numeric entry = FHA evaluation of that type in the listed area. VB-4 Revision 28

CPNPP/FPR FHA EVALUATIONS MATRIX UNIT 1 JUSTIFICATION NUMBER FOR LOCATION TYPE OF FHA EVALUATION FIRE FIRE AREA ZONE ROOM SUP DET CTH ICS SB 4 64 3 X 7 X SB 4 70 3 X 7 X SB 4 71 3 X 7 X SB 8 79 3 X 7 X SB 8 82 3 X 7 X SB 15 94 3 X 7 X SB 15 95 3 X 7 X SB 143 77s 4 X 7 X SB 144 88 3 X 7 X so 9 83 4 X 7 X SE 16 96 4 X 8 X SE 18 103 4 X 8 X SE 18 104 4 X 8 X SK 17a 100 X X 6 X SK 17a 100a X X 6 X WB 104b 275 X 3 X X X or N = No FHA evaluation of that type in the listed area. Y or numeric entry = FHA evaluation of that type in the listed area. VB-5 Revision 28

CPNPP/FPR FHA EVALUATIONS MATRIX UNIT 2 JUSTIFICATION NUMBER FOR LOCATION TYPE OF FHA EVALUATION FIRE FIRE AREA ZONE ROOM SUP OET CTH ICS 2SA 1A 2-057 X X X 2SA 1A 2-058 X 1 X X 2SA 1A 2-061 X 1 X X 2SA 1C 2-063 3 X 6 X 2SA 1C 2-066 4 X 8 X 2SB 2C 2-067 4 X X X 2SB 4 2-070 3 X 6 X 2SB 4 2-071 3 X 6 X 2SO 3 2-074A 4 X 8 X 2SA 142 2-077A 3 X 5 X 2SB 8 2-079 3 X 6 X 2SB 2E 2-081 X 1 X X 2SB 8 2-082 3 X 6 X 2SO 9 2-083 4 X 6 X 2SB 4 2-0850 4 X X X 2SB 2F 2-086 X 1 X X 2SB 2F 2-087 X 1 X X 2SB 144 2-088 3 X 5 X 2SB 15 2-094 3 X 6 X 2SE 16 2-096 4 X 6 X 2SL SK100 2-100 3 X 5 X 2SK 17A 2-100A 3 X X X 2SK 17A 2-1008 3 X 5 X 2SK 17A 2-100C 3 X X X 2SK 17A 2-1000 3 X X X 2SK 17A 2-100E 3 X X X 2SK 17A 2-100F 3 X 5 X 2SK 17A 2-100G 3 X X X 2SK 17A 2-100H 3 X X X 2SE 18 2-103 4 X 6 X 2SK 178 2-108A 3 X X X 2SK 178 2-1088 3 X 5 X 2SK 178 2-108C 3 X X X 2SK 178 2-108E 3 X X X 2SK 178 2-108F 3 X X X X or N = No FHA evaluation of that type in the listed area. Y or numeric entry = FHA evaluation of that type in the listed area. VB-6 Revision 28

CPNPP/FPR FHA EVALUATIONS MATRIX UNIT2 JUSTIFICATION NUMBER FOR LOCATION TYPE OF FHA EVALUATION FIRE FIRE AREA ZONE ROOM SUP DET CTH ICS 2SK 178 2-108G 3 X X X 2SK 178 2-108H 3 X X X 2SK 17C 2-109A 3 X X X 2SK 17C 2-1098 3 X 5 X 2SK 17C 2-109C 3 X X X 2SK 17C 2-11 OA 3 X X X 2SK 17C 2-11 OB 3 X X X 2SK 17C 2-11 oc 3 X X X 2SK 17C 2-1100 3 X X X EA 43 X-113 3 X 5 X AA 154 X-1158 3 X 5 X EA 54 X-122 3 X 5 X EA 73 X-150 4 X X X EA 74 X-150A 4 X X X AA 21a X-165 4 X 8 X AA 21a X-170 4 1 X X AA 21a X-171 4 1 X X AA 21a X-172 4 X 8 X AA 21a X-173 4 X 8 X AA 21a X-174 4 X 8 X AA 21a X-180 3 X 6 X AA 21b X-202 3 X X X AA 21b X-207 3 X 6 X AA 21c X-208 4 X 8 X AA 21d X-219 3 X 6 X AA 21d X-219A 4 X 8 X AA 21d X-226 3 X 6 X AA 21f X-234 4 X X X AA 21f X-238 4 X X X AA 21f X-239 4 X X X AA 21f X-240 4 X X X AA 21f X-241 3 X 6 X AA 21g X-243 4 X X X AA 38 X-245 4 X 8 X WB 104b X-275 3 X X X X or N = No FHA evaluation of that type in the listed area. Y or numeric entry = FHA evaluation of that type in the listed area. VB-7 Revision 28

CPNPP/FPR JUSTIFICATIONS FOR: SUPPRESSION (SUP) FHA EVALUATIONS

3. Automatic suppression is provided adequate for the hazards of the area. The abundant water supply coupled with early warning fire detection ensure that a fire will not propagate beyond or encroach on the boundaries of the sprinkler system protecting fire safe shutdown equipment. The design densities provide enough water to keep a fire which has grown beyond its incipient stages from overpowering the system from an adjoining unsprinkled area.

4. Automatic suppression is not provided. The hazards of the area are not severe enough to warrant the installation of an automatic fire suppression system. Redundant trains of equipment are located in different rooms which are separated by tortuous paths created by reinforced concrete walls. Fire detection adequate for the hazards of the area is provided and manual fire suppression is available. Combustible loading is not extreme and administrative controls address transient combustibles.

DETECTION (DET) FHA EVALUATIONS

1. No detection is provided in the room this is however, adequate to meet the intent of NFPA 72E, based on the following. There is no fire safe shutdown equipment in the room.

Generally combustible loading is insignificant and substantial reinforced concrete construction separates the rooms. Detection is provided in surrounding areas such that a fire originating in the subject room would be detected before spreading to other areas. Manual fire suppression is available.

2. Detection is provided, however, it does not meet the spacing requirements of NFPA 72E.

The detection provided is acceptable and meets the intent of NFPA 72E. When the fire protection features of the area are considered. In-situ combustible loading is low, smoke detectors are installed in adjacent area room configurations readily permit the detection of smoke by the misplaced detections. Manual fire suppression is readily available.

3. Detection is provided, however, it is not provided in accordance with the spacing requirements of NFPA 72E. The improper spacing is acceptable because there are not any significant amounts of combustibles, the smoke accumulating in unprotected areas would migrate to detectors and areas of ceiling bays are within the limitations of smoke detector coverage for the devices. Manual fire suppression is available.

VB-8 Revision 28

CPNPP/FPR JUSTIFICATIONS FOR: CABLE (CTH) TRAY HANGER FHA EVALUATIONS

5. Unprotected cable tray hangers are acceptable based on the fact that automatic fire suppression is provided throughout the fire zone.

6. Unprotected cable tray hangers are acceptable because the room that houses them is covered by automatic fire suppression adequate for the hazards of the area.

7. Unprotected cable tray hangers are acceptable based on the combustible loading of the fire zone which when consumed by the design basis fire cannot produce enough heat to raise the temperature of the room above the failure point for the cable tray hangers.

8. Unprotected cable tray hangers are acceptable based on the type of combustible material and the heat release characteristics of the combustible material in the area. Accordingly the combustibles in the area are not expected to burn at a rate as great as the "E-curve" and as a result the temperature of the room does not reach the failure temperature for the steel cable tray hangers.

INTERNAL CONDUIT SEAL (ICS) FHA EVALUATIONS Justifications are based on the "Conduit Fire Protection Research Program" as promulgated by Wisconsin Electric Power Company. These justifications pertain to conduits less than or equal to four (4) inch nominal size which penetrate fire (only) barriers and are not provided with internal conduit fire seals.

1. Conduit runs continuously through an area, i.e. no junction or pull boxes and does not terminate in that area.

2. Conduit terminates in noncombustible, non-ventilated enclosure (i.e. metal junction box, pull box or condulet).

3. Conduit is less than one (1) inch nominal size and terminates one (1) foot or more from the fire barrier.

4. Conduit is one (1) inch nominal size having a cable fill of 40% or greater and terminates one (1) foot or more from the fire barrier.

5. Conduit is one (1) inch nominal size having a cable fill of less than 40% and terminates five (5) feet or more from the fire barrier.

6. Conduit is one (1) inch nominal size having a cable fill of less than 40% and terminates between on ( 1) foot and five (5) feet from the fire barrier and a gas and smoke seal is installed at the first opening on that side of the fire barrier.

7. Conduit is greater than one (1) inch nominal size, but less than or equal to two (2) inch nominal size having a cable fill of 40% or greater and terminates three (3) feet or more from the fire barrier.

VB-9 Revision 28

CPNPP/FPR JUSTIFICATIONS FOR: INTERNAL CONDUIT SEAL (ICS) FHA EVALUATIONS (cont'd)

8. Conduit is greater than one (1) inch nominal size, but less than or equal to two (2) inch nominal size having a cable fill of less than 40% and terminates three (3) feet or more from the fire barrier and a gas and smoke seal is installed at the first opening on that side of the fire barrier.

9. Conduit is greater than two (2) inch nominal size, but less than or equal to four (4) inch nominal size having a cable fill of 40% or greater and terminates three (3) feet or more from the fire barrier and a gas and smoke seal is installed at the first opening on that side of the fire barrier.

VB-10 Revision 28

CPNPP/FPR APPENDIXC DEVIATIONS

CPNPP/FPR TABLE OF CONTENTS DEVIATION NO. SUBJECT OF DEVIATION 1a Unit 1 and Unit 2 Service Water Pumps 1b Unit 1 Chiller Units and Pumps 1b (2) Unit 2 Chiller Units and Pumps 3a Room X-200/X-207, Removable Concrete Block 3a (2) Room X-195/X-207, Removable Concrete Block 3a-1 Room 1-077A/1-088, Removable Concrete Block 3a-1 (2) Room 2-077A/2-088, Removable Concrete Block 3b Unit 1 Containment Penetration Seals 3b (2) Unit 2 Containment Penetration Seals 3c Unit 1 Safeguards Missile Resistant Door 3c-1 Control Room Missile Resistant Door 3d Unit 1 Water Tight Doors 3d (2) Unit 2 Water Tight Doors 3e Unit 1 Containment Air-Locks 3e (2) Unit 2 Containment Air-Locks 3g Unit 1 Containment Mechanical Penetration Seals 3g (2) Unit 2 Containment Mechanical Penetration Seals 3h Unit 1 Cable Spreading Room BR-PR Door 3ha (2) Unit 2 Cable Spreading Room BR-PR Door (Door E-24) 3hb (2) Unit 2 Cable Spreading Room BR-PR Door (Door E-23) 4a Unit 1 Pressurizer Relief Valves 4a (2) Unit 2 Pressurizer Relief Valves 4a-1 Unit 1 Containment Building RHR Valves 4a-1 (2) Unit 2 Containment Building RHR Valves 5a Non-IEEE 383 Cable 8b Auxiliary Building Elev 852'-6" UPS Vent. MCC's 8c Unit 1 Main Steam Isolation Valves 8c (2) Unit 2 Main Steam Isolation Valves 10 Emergency Lighting 14 2 Hour Rated Penetration Seals 2015-1 Unit 1 Operator Manual Action - Battery Charger Alignment 2015-1 (2) Unit 2 Operator Manual Action - Battery Charger Alignment 2015-2 Unit 1 VCT to CCP Level Control and RWST to CCP Suction Valves 2015-2 (2) Unit 2 VCT to CCP Level Control and RWST to CCP Suction Valves 2015-3 Shorting Switches Technical Justification I Radiant Energy Shields VC-1 Revision 30

CPNPP/FPR Deviation 1a Location: Bldg. SWIS Elev. 796 Room 275 F.A. WB F.Z. WB104B Col N-S Systems Path A Safety Water E-W Systems Path B Safety Water Reference Drawings: Grinnell Fire Protection Drawing 7 M 1-1946, Figure FPR-24 2323-E1-1103 2323-E1-1104 2323-E 1-2025 Deviation: Appendix R of 10CFR50 Section III.G.2.b.

== Description:== Redundant safety water pumps and raceways, service water exhaust fans and their associated raceways, service water isolation valves and their associated raceways, branch circuits from redundant Unit 1 MCC's 1EB4-3 and 1 EB3-3 and Unit 2 MCC's CP2-EPMCEB-08 and CP2-EPMCEB-07 are located in the same fire area. This deviation has been revised to reflect Unit 2 operation. Justification: 1. Partial barriers constructed of 3 hour fire-rated materials with "A" label doors and concrete curbs separate pumps and MCC's for Unit 1 and Unit 2 Train A from Pumps and MCC's for Unit 1 and Unit 2 Train B. The barriers are 14'-6" high 1'-6" thick reinforced concrete. The pumps are 12'-0" high while the MCC's are less than 12' high.

2. General area detection and automatic sprinkler coverage is provided.

Ceiling level ionization detection and spot-type thermal detectors provide early warning in the event of a fire.

3. There is a negligible amount of exposed cabling and the fire loading is low.

Transient hazards are controlled by MPFL and designation as a "No Storage" area which ensures that transient combustibles will not be left unattended without appropriate compensatory measures.

4. Cables supplying each pump and associated MCC enter the pump bay from the underground through the north wall.

5. Raceways supplying exhaust fans are embedded in the north wall of the structure until they penetrate through the wall and join the fans. The fans are totally enclosed with class H insulation. The motors were qualification tested for 30 days at 212° F with a continuous water spray of 1 OF 4 Revision 28

CPNPP/FPR Deviation 1a

            .15 GPM/Sq. ft. applied. The limiting temperature is 266° F. Therefore, the lack of twenty foot separation of the fans will not result in the loss of fans for both Train A and Train B in the postulated fire.

6. A fire caused by transient combustibles is mitigated because the area is designated "No Storage" area. This ensures that the credible postulated fire would be a fire involving service water pump lube oil. However, a service water pump lube oil fire is highly unlikely because the oil is enclosed in the pump motor bearing housing and if the oil did spill, the spill would be contained by curbs and drained.

7. A fire at the ceiling level involving one of the fan units will not adversely affect the redundant counterpart for either Unit 1 or Unit 2 which is separated as a minimum by 2'-6" thick concrete beam providing a physical barrier between the redundant essential fans.

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DEVIATION 1A SERVICE WATER INTAKE STRUCTURE ELEVATION 796'-6" (NOT TO SCALE) NOUU lEBO IEDJ-3 CP2-EPMCE8 08 CP2-EPM!'EO 07 I I 1 I

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DEVIATION 1A SERVICE WATER INTAKE STRUCTURE ELEVATION 796'-6" (NOT TO SCALE) FAN X-08 FAN X-06 FAN

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PUMP 1-02 PUMP 1-01 PUMP 2-01 PUMI' 2-02 FAN NUMBER X-02 CPX-VAFNWV-02 X-03 CPX-VAFNWV-03 X-04 CPX-VAFNWV-04 X-05 CPX-V AFNWV -05 X-06 CPX-VAFNWV-06 X-07 CPX-VAFNWV-07 LEGEND X-08 CPX-VAFNWV-08

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CPNPP/FPR Deviation 1b Location: Bldg. E&C Elev. -::::;7=78::;;:----- Room 115a F.A. AA153 Col N-S Systems Path A Safety Chilled Water E-W Systems Path B Safety Chilled Water Reference Drawings: Grinnell Fire Protection 99 M1-1927 2323-E 1-2012 2323-S-0795 2323-S-0797 2323-E1-0714-11 Deviation: Appendix R of 10CFR50 Section III.G.2.b.

== Description:== Redundant safety related chiller units and their respective circulation pumps are located in a common fire area. Justification: 1. One hour rated gypsum on steel stud partial barrier is provided between redundant equipment. Curbs are provided to contain flammable liquids.

2. General area ionization detection and automatic sprinkler coverage is provided. Sprinkler locations are positioned to provide coverage of transient and in-situ combustible hazards in accordance with NFPA.

3. The combustible loading in the room is moderate, primarily due to exposed fire barrier materials installed on electrical cables and raceways, which have conservatively been considered as combustible. Fire barriers are installed on non-essential electrical cables which span across the one hour rated partial height gysum walls separating redundant safety-related chiller units and their respective circulation pumps. These fire barriers are not installed to insure the operability of the enclosed non-essential cables, but rather to migrate the threat of flame propagation along the cables.

4. As stated above, these barriers are conservatively considered as combustible and as such could themselves provide a flame propagation path. This concern is alleviated since testing has shown that, while the material does contribute added heat in the presence of an external heat source of sufficient temperture to cause it to sublime and ignite, the material will not sustain combustion in the absence of external heat.

Therefore, the ability of the material to prevent flame propagation in its 1 OF 3 Revision 28

CPNPP/FPR Deviation 1b currently installed configuration is determined by its own flame propagation properties. In-test and post test observations revealed that the fire barrier material, as installed, protects the enclosed cables from ignition and flame propagation along the inside of the barrier. Therefore, the concern over potential flame propagation is limited to the outside surface of the enclosures, and cables routed inside the protected enclosures will not contribute fuel to a postulated fire. However, flame propagation along installed fire barrier material is futher mitigated by the following: The protected raceways crossing the walls are approximately 17 feet above the floor, thus limiting their direct flame exposure from floor based fire hazards. Raceways essential for equipment operation have been coated to within 3 feet of the equipment with a one hour rated barrier system. In-situ combustibles directly under the fire barrier installations are in metal enclosures. Other combustibles in the room are within robust metal enclosures or equipment which do not allow significant flaming to occur. Fixed combustibles (i.e. pumps, panels, chillers, etc.) Are centered in the room and do not allow direct flame or heat impingement on the fire barriers crossing the walls. General area ionization detection and automatic sprinkler coverage is provided.

5. Eight 6" diameter steel pipe drain lines with check valves have been installed in the fire barrier between fire area AA 153 and fire area EA43 to remove fire suppression water. Four drains have been installed on either side of the partial barrier separating the redundant chiller units.

6. Spray shields have been added to electrical equipment to protect against water damage from sprinkler actuation.

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CPNPP/FPR Deviation Location: Bldg. E&C Elev. 778 Room 115 b F.A. AA F.Z. AA154 Col N-S Systems Path A Safety Chilled Water E-W Systems Path B Safety Chilled Water Reference Drawings: Grinnel Fire Protection Drawing 134 M1-1927, Figure FPR-7 2323-S-0795 2323-S-0797 2323-E1-0714-11 2323-E 1-2012 Deviation: Appendix R of 10CFR50 Section III.G.2.b.

== Description:== Redundant safety related chiller units and their respective circulation pumps are located in a common fire area. This is equivalent to Unit 1 deviation 1b. Justification: 1. One hour rated gypsum on steel stud partial walls are provided between redundant components. A specially designed extension of the automatic sprinkler system installed throughout the room is provided to enable water curtain coverage at each partial wall. Fast response sprinkler heads are positioned to protect all open areas around and above the walls such that a continuous barrier, either structural or spray protection, separates redundant components.

2. Curbs are provided at each wall to contain liquid spills and cable tray fire stops are provided where exposed nonessential cables in trays pass above the walls. These features provide additional assurance that a postulated fire will not propagate beyond the barriers.

3. General area ionization detection and automatic sprinkler protection is provided throughout the room in accordance with applicable NFPA standards. The sprinkler system installed at the ceiling and beneath obstructions ensures complete coverage for all in-site combustibles and any transient combustibles which may be brought into the room.

Additional ionization detectors are provided over each partial wall separating redundant components to ensure early detection should a fire occur in the vicinity of the wall.

4. The combustible loading in Fire Zone AA 154 is low. The maximum permissible fire loading in Fire Zone AA 154 is also low.

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CPNPP/FPR Deviation 1b (2)

5. All essential raceways associated with redundant components in the room are enclosed in a one hour fire rated material up to the room penetrations or particular components as applicable.

6. 6" diameter steel pipe drain lines with check valves are installed at floor level in the fire barrier between Fire Zone AA 154 and Fire Zone EA43 to remove fire suppression water from the room. In addition, floor drains are provided in each of the areas formed by the partial walls.

7. Equipment is provided with spray shields and penetrations into the equipment are sealed to protect against water damage due to sprinkler actuation.

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CPNPP/FPR Deviation 3a Location: Bldg. Auxiliary Elev. 81 0'-6" Room 200 F.A. AC29 Col N-S KA Systems Path A E-W 2A Systems Path B Reference Drawings: 2323-S-0711 2323-S-0786 2323-S-0787 M1-1928 ATTACHMENT Exception: BTP APCSB 9.5-1 Appendix A Section D.1.j

== Description:== A removable solid concrete block wall used to seal equipment access hatches through fire rated barriers. Justification: 1. Construction of removable solid block walls is substantial in nature. Walls are 2 feet thick composed of two layers keyed into the opening. (See analysis Attachment 3a.)

2. General area ionization detection is provided in all areas. Automatic sprinkler coverage is provided in corridors. Hose stations and portable hand held extinguishers are available in Fire Zone AA21 b.

3. Fire loading is low as shown in the attached table.

4. Primary design considerations are seismic requirements, radiation shielding, and maintenance.

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CPNPP/FPR Deviation 3a Attachment 3a ANALYSIS OF FIRE RATING OF REMOVABLE SOLID CONCRETE BLOCK ACCESS HATCH SEALS The removable concrete block walls are composed of a minimum of two (2) vertical layers of blocks placed in series with staggered block joints. The block walls are a minimum of one foot to a maximum of four feet in depth as dictated by the depth of the adjoining poured concrete walls. Blocks are field constructed of concrete having a minimum density of 136 pcf using Type II Portland cement with individual block dimension tolerance of plus or minus 1/8 inch. All surfaces of each block are painted to facilitate decontamination. The configuration of the block walls would allow them to be free standing, however, exposed structural steel supports are provided to contain the block walls during a seismic event. Concrete block walls that are designated as watertight are covered with a 1/4 inch thick steel plate. The type of concrete used for the blocks is the same type used in construction of the poured reinforced concrete fire barriers throughout the plant. The type of concrete used for the blocks along with the relative thickness of the block walls gives a general correlation to listed fire rated construction. However, due to the installation of the concrete blocks (absence of mortared joints) no direct comparison to UL or other standards of approved construction can be made. A fire would not create major pressure differential loading on the concrete block walls to the extent of jeopardizing structural integrity. Steel supports would aid in maintaining the block walls integrity in the event of an explosion. Close concrete block fabrication tolerances along with staggering of block joints, including the keying of the block walls into the interfacing wall, eliminates direct hot gas propagation paths. The increased surface contact area and the heat-sink characteristics of concrete will combine to reduce the temperature of any gases which might reach the unexposed surface of the wall. A primary consideration in the evaluation of the adequacy of the block walls is fire exposure hazard on a case-by-case basis, per table 3a. 2 OF3 Revision 28

TABLE 3a DEVIATION 3a CONCRETE BLOCK WALLS FHA ROOM FIRE DESCRIPTION HAZARD MPFL PROTECTION THICKNESS WALL FIRE DESCRIPTION HAZARD MPFL PROTECTION AREA ROOM AREA 15 200 29 Centrifugal low moderate detection 2'-0" 207 21b corridor low low sprinkler/ Charging detection Pump 0

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CPNPP/FPR Deviation Location: Bldg. Auxiliary Elev. 810'-6" Room X-195 F.A. AA,AB F.Z. AA21 B, AB24 Col N-S J-A Systems Path A E-W 8-A Systems Path B Reference Drawings: M 1-1928, Figure FPR-8 2323-S-0711 2323-S-0786 2323-S-0787 Deviation: BTP APCSB 9.5-1 Appendix A Section D.1.j.

== Description:== A removable solid concrete block wall used to seal equipment access hatches through fire rated barriers between Charging Pump (2-01) Room and the Auxiliary Building 81 0'-6" corridor. This is equivalent to Unit 1 deviation 3a. Justification: 1. Construction of removable solid block walls is substantial in nature. Walls are 2 feet thick composed of two layers keyed into the opening. See analysis Attachment 3a (2).

2. General area ionization detection is provided on both sides of the block wall. Automatic sprinkler coverage is provided in the corridor. Hose stations and portable fire extinguishers are provided within travel distances recognized by applicable NFPA standards.

3. Fire loading is low as shown in the attached Table 3a (2).

4. Primary design considerations for the removable concrete block wall are seismic requirements, radiation shielding, and maintenance.

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CPNPP/FPR Deviation 3a (2) Attachment 3a (2) ANALYSIS OF FIRE RATING OF REMOVABLE SOLID CONCRETE BLOCK ACCESS HATCH SEALS The removable concrete block walls are composed of a minimum of two (2) vertical layers of blocks placed in series with staggered block joints. The block walls are a minimum of one foot to a maximum of four feet in depth as dictated by the depth of the adjoining poured concrete walls. Blocks are field constructed of concrete having a minimum density of 136 pcf using Type II Portland cement with individual block dimension tolerance of plus or minus 1/8 inch. All surfaces of each block are painted to facilitate decontamination. The configuration of the block walls would allow them to be free standing, however, exposed structural steel supports are provided to contain the block walls during a seismic event. Concrete block walls that are designated as watertight are covered with a 1/4 inch thick steel plate. The type of concrete used for the blocks is the same type used in construction of the poured reinforced concrete fire barriers throughout the plant. The type of concrete used for the blocks along with the relative thickness of the block walls gives a general correlation to listed fire rated construction. However, due to the installation of the concrete blocks (absence of mortared joints), no direct comparison to UL or other standards of approved construction can be made. A fire would not create major pressure differential loading on the concrete block walls to the extent of jeopardizing structural integrity. Steel supports would aid in maintaining the block walls integrity in the event of an explosion. Close concrete block fabrication tolerances along with staggering of block joints, including the keying of the block walls into the interfacing wall, eliminates direct hot gas propagation paths. The increased surface contact area and the heat-sink characteristics of concrete will combine to reduce the temperature of any gases which might reach the unexposed surface of the wall. A primary consideration in the evaluation of the adequacy of the block walls is fire exposure hazard on a case-by-case basis, per Table 3a (2). 2 OF3 Revision 28

TABLE 3a(2) DEVIATION 3a (2) CONCRETE BLOCK WALLS FPR FIGURE FPR-8 ROOM X-195 FIRE ZONE AB24 DESCRIPTION Centrifugal Charging Pump 2-01 HAZARD Low MPFL Low PROTECTION Detection coverage, HPK extinguisher THICKNESS 2'-0" ROOM X-207 FIRE ZONE AB21b DESCRIPTION Corridor 0

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CPNPP/FPR Deviation 3a-1

Subject:

Removable Block Walls Location: Bldg. Safeguards Elev. 831'-6" Room 88, 77 F.A. SA,SB F.Z. 142,143,144 Col N-S D-D Systems Path A E-W 7.5-S Systems Path B Reference Drawings: 2323-S-0787 2323-S-0788 M1-1922 Exception: BTP APCSB Appendix A, Section D.1.j

== Description:== Fire Zone SA142 contains cabling related to the following Systems: Residual Heat Removal, AC Distribution, Chemical and Volume Control, Safety Injection, Component Cooling, Main Steam, Sampling, Safety Chilled Water, Reactor Coolant and Heating, Ventilating and Air Conditioning. One of the redundant trains is protected in this area. Fire Zone SA 143 contains cabling associated with the following systems: Safety Injection, Chemical and Volume Control, Main Steam, Residual Heat Removal, Sampling, Auxiliary Feed, Containment Spray, AC Distribution, Heating, Ventilating and Air Conditioning, and Safety Chilled Water. One of the redundant trains is protected in this area. Fire Zone SB144 contains cabling associated with the following systems: Main Steam, Chemical and Volume Control, Containment Air Monitoring, Residual Heat Removal, AC Distribution, Heating, Ventilating and Air Conditioning, Component Cooling, Auxiliary Feed, Safety Injection, Safety Chilled Water, Nuclear Instrumentation, and N-16 Detection. One of the redundant trains is protected in this area. Fire Zone SB144 contains no redundant equipment to either Fire Zone SA142 or Fire Zone SB143. The interaction path between Fire Zone SA142 and SB143 is through the pipe chases that are contained in Fire Zone SB144. The only non-rated openings in the pipe chase in Fire Zone SB144 are 5 solid concrete block wall access hatches. These access hatches are of similar design to those access hatches already accepted. Fire Zone SB144 has already been 1 OF 4 Revision 28

CPNPP/FPR Deviation 3a-1 combined with Fire Zone SB143 in the Fire Area SB and Fire Zone SA142 will be maintained separate in Fire Area SA by a 3 hour barrier except for these 5 hatches. There is ionization detection in the fire zones of concern and automatic sprinkler coverage in Fire Zone SB144. The fire severities in Fire Zones SA 142, SB143 and SB144 are low. The maximum permissible fire loading in all Fire Zones of concern is low. For a fire to affect equipment in either Fire Zone SA142 or SB143, it must travel up one pipe chase across Fire Zone SB144 and then down the other chase into the opposite train Fire Area. Based on the fire loading in these fire zones this occurrence would be highly unlikely. Justification: 1. Construction of removable solid block walls is substantial in nature. Walls are 2 feet thick composed of two (2) layers keyed into the opening.

2. General area ionization detection is provided in Fire Zones SB143 and SB144. Automatic sprinkler coverage is provided in F.A. SB144 and partial automatic sprinkler coverage in Fire Zones SA142 and SB143.

3. The fire severities in Fire Zones SA142, SB143 and SB144 are low. The maximum permissible fire loading in all Fire Zones of concern is low.

4. Primary design considerations are seismic requirements, radiation shielding, and maintenance.

5. Rapid response is provided by early detection of fires with ionization detection throughout the area. Manual suppression response is available using hose stations and portable extinguishers.

6. A fire in Fire Area SA must travel up a pipe chase, breach the block closures, across Fire Zone SB144 which contains automatic sprinkler suppression and then travel down another pipe chase into Fire Zone SB143 before any redundant components are affected.

7. Fire testing of the removable block closures would not significantly enhance the fire safety at CPNPP.

2 OF 4 Revision 28

CPNPP/FPR Deviation 3a-1 ANALYSIS OF FIRE RATING OF REMOVABLE SOLID CONCRETE BLOCK ACCESS HATCH SEALS The removable concrete block walls are composed of a minimum of two (2) vertical layers of blocks placed in series with staggered block joints. The block walls are a minimum of one foot to a maximum of four feet in depth as dictated by the depth of the adjoining poured concrete walls. Blocks are field constructed of concrete having a minimum density of 136 pcf using Type II Portland cement with individual block dimension tolerance of plus or minus 1/8 inch. All surfaces of each block are painted to facilitate decontamination. The configuration of the block walls would allow them to be free standing; however, exposed structural steel supports are provided to contain the block walls during a seismic event. Concrete block walls that are designated as watertight are covered with a 1/4 inch thick steel plate. The type of concrete used for the blocks is the same type used in construction of the poured reinforced concrete fire barriers throughout the plant. The type of concrete used for the blocks along with the relative thickness of the block walls gives a general correlation to listed fire rated construction. However, due to the installation of the concrete blocks (absence of mortared joints) no direct comparison to UL or other standards of approved construction can be made. A fire would not create major pressure differential loading on the concrete block walls to the extent of jeopardizing structural integrity. Steel supports would aid in maintaining the block walls integrity in the event of an explosion. Close concrete block fabrication tolerances along with staggering of block joints, including the keying of the block walls into the interfacing wall, eliminates direct hot gas propagation paths. The increased surface contact area and the heat-sink characteristics of concrete will combine to reduce the temperature of any gases which might reach the unexposed surface of the wall. A primary consideration in the evaluation of the adequacy of the block walls is fire exposure hazard on a case-by-case basis, per table 3a. 30F 4 Revision 28

TABLE 3a-1 DEVIATION 3a-1 FIRE WALL F. A FHA ROOM ZONE DESCRIPTION HAZARD MPFL PROTECTION THICKNESS ROOM A.Z. DESCRIPTION HAZARD MPFL PROTECTION 3 88 SB144 Penetration Low Low Sprinkler 2'-0" Carr SA142 Pipe Chase Low Low Sprinkler Area Ionization Ionization Detection/HMP Detection 0

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CPNPP/FPR Deviation 3a-1 (2) Location: Bldg. Safeguards Elev. 831'-6" Rooms 2-088, 2-077 A F.A. 2SA, 2SB F.Z. 2SA142,2SB143,2SB144 Col N-S D-S Systems Path A E-W 9.5-S Systems Path B Reference Drawings: 2323-S-0787 2323-S-0788 M2-1922, Figure FPR-27 Exception: BTP APCSB 9.5-1 Appendix A Section D.1.j. Appendix R of 10CFR50, Section III.G.2.b.

== Description:== Fire Areas 2SA and 2SB are adjacent fire areas on the 773'- 0~, 81 0'- 6~ and 831 '-6~ elevations of the Unit 2 Safeguards Building. The 2 fire zones are separated by 3 hour fire-rated barriers except for 5 solid non-rated openings. The 5 non-rated openings are on the 831 '- 6~ elevation between rooms 2-088 (Fire Zone 2SB144) and the pipe chase in room 2-077A (Fire Zone 2SA142). There are fire safe shutdown components and cables which rely on the barrier between these two fire areas for separation of redundant components and cables. This is equivalent to Unit 1 deviation 3a-1. The 5 non-rated openings are constructed of concrete blocks each measuring 2'- 6~ x 2'- 6~ x 2'- 0~ thick (the full thickness of the wall in which they are installed). In order to mitigate the passage of heat, flame smoke and hot gases, the blocks are installed in a staggered fashion and the opening in the reinforced concrete wall is offset. The concrete block assemblies are secured by steel plates bolted to each side of the reinforced concrete wall. The combustibles for both fire zones primarily consist of exposed cables. There are no redundant fire safe shutdown components or cables in the immediate vicinity of the openings. There is complete automatic sprinkler system protection and ionization detection coverage for both fire zones. There is manual fire suppression capability by portable extinguishers and hose stations. Justification: 1. Construction of the removable solid block walls is very substantial. The walls are 2 feet thick composed of two layers keyed into the opening and held in place by steel plates bolted to the permanent wall. See Attachment 3a (2). 1 OF 4 Revision 28

CPNPP/FPR Deviation 3a-1 (2)

2. The ionization detection and automatic sprinkler protection is provided on both sides of the wall (Fire Zones 2SA142 and 2SB144) ensures rapid response to a fire. Additionally, manual fire suppression capability by portable fire extinguishers and hose stations is provided.

3. The fire severity is low for both Fire Zone 2SA142 and Fire Zone 2SB144.

The maximum permissible fire loading in both fire zones of concerns is low.

4. Primary design considerations for the removable block walls are seismic requirements, radiation shielding, and maintenance.

5. For a fire to involve redundant components, it would have to originate on the 81 0'- 6~ elevation, travel up an essentially noncombustible pipe chase, breach the solid concrete block closures, cross Fire Zone 2SB144 on the 831 '- 6~ elevation, and then propagate down another essentially noncombustible pipe chase to the 81 0'- 6~ elevation. This is extremely unlikely due to the tortuous fire path, lack of combustible materials, provision of complete detection and automatic suppression along the entire propagation path and the remote possibility that a fire would propagate down an essentially noncombustible pipe chase.

6. Provision of 3 hour fire-rated barriers at these openings would not significantly enhance the existing level of protection.

2 OF 4 Revision 28

CPNPP/FPR Deviation 3a-1 (2) Attachment 3a-1 (2) ANALYSIS OF FIRE RATING OF REMOVABLE SOLID CONCRETE BLOCK ACCESS HATCH SEALS The removable concrete block walls are composed of a minimum of two (2) vertical layers of blocks placed in series with staggered block joints. The block walls are a minimum of one foot to a maximum of four feet in depth as dictated by the depth of the adjoining poured concrete walls. Blocks are field constructed of concrete having a minimum density of 136 pcf using Type II Portland cement with individual block dimension tolerance of plus or minus 1/8 inch. All surfaces of each block are painted to facilitate decontamination. The configuration of the block walls would allow them to be free standing, however, exposed structural steel supports are provided to contain the block walls during a seismic event. Concrete block walls that are designated as watertight are covered with a 1/4 inch thick steel plate. The type of concrete used for the blocks is the same type used in construction of the poured reinforced concrete fire barriers throughout the plant. The type of concrete used for the blocks along with the relative thickness of the block walls gives a general correlation to listed fire rated construction. However, due to the installation of the concrete blocks (absence of mortared joints) no direct comparison to UL or other standards of approved construction can be made. A fire would not create major pressure differential loading on the concrete block walls to the extent of jeopardizing structural integrity. Steel supports would aid in maintaining the block walls integrity in the event of an explosion. Close concrete block fabrication tolerances along with staggering of block joints, including the keying of the block walls into the interfacing wall, eliminates direct hot gas propagation paths. The increased surface contact area and the heat-sink characteristics of concrete will combine to reduce the temperature of any gases which might reach the unexposed surface of the wall. A primary consideration in the evaluation of the adequacy of the block walls is fire exposure hazard on a case-by-case basis, per Table 3a-1 (2). 30F 4 Revision 28

TABLE 3a-1 (2) DEVIATION 3a-1 (2) CONCRETE BLOCK WALLS FPR FIGURE FPR-27 ROOM 2-088 FIRE ZONE 2SB144 DESCRIPTION Penetration Area HAZARD Low MPFL Low PROTECTION Ion. Detection, Automatic sprinkler, Hose station and HMP extinguisher coverage THICKNESS 2'-0" ROOM 2-077A FIRE ZONE 2SA142 0 DESCRIPTION Pipe Chase -u .j::>.. z 0 HAZARD Low -u "'Tl -u .j::>.. MPFL Low "'Tl

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CPNPP/FPR Deviation 3b Location: 3b-1 Bldg. See attached Table 3b Elev. See attached Table 3b Room See attached Table 3b F.A. See attached Table 3b Col N-S Systems Path A E-W Systems Path B Reference Drawings: Bunker Ramo 50021526, Sheets 1 and 2; 50020445; 50021765; 50021690; 50021914; FSE-00182; Conax-7060-1001; M1-1922; M1-1927 Exception: BTP APCSB Appendix A, Section D.1.j

== Description:== Penetrations for electrical conductors through the containment walls have not been tested as fire seals. Justification: 1. All penetration assembly non-metallic materials (excluding cables) have been classified by testing to be "non-burning" or "self-extinguishing" by test in accordance with ASTM D635.

2. Ionization, thermistor strip or UV fire detection is provided in all area on both sides of the seal (see Table 3b).

3. Penetration assemblies provide a means for continuity of power, control, and signal circuits through the containment structure pressure barrier while maintaining the integrity of the barrier.

4. Penetration assemblies are normally pressurized from outside containment with dry nitrogen at between 60 to 100 psi g.

5. Penetrations assemblies are designed to remain intact following a DBA and prevent leakage to the atmosphere.

6. See Table 3b for fire severities and maximum permissible fire loading in the fire zones of concern.

1 OF 2 Revision 28

TABLE 3b DEVIATION 3b ATTACHMENT NO. OF BUILDING ROOM FIRE ZONE HAZARD MPFL SYSTEMS PENETRATIONS Safeguard 83 SD9 Low Low Train A Switchgear Containment 154 CA 101 b Low Low I High* RCP, RHR 27 Safeguard 96 SE16 Low Low Alternate Shutdown Panel Containment 155a CA 101 d Low Low I High* Reactor Trip 19 Safeguard 103 SE18 Low Low Train B Switchgear Containment 155a CA101f Low Low I High* 28 Fuel 272 AA99e Low Low Fuel Storage Pool Containment 155a CA101f Low Low I High* Fuel Handling Area 1 0

                                                                                                                                         -u N                                                                                                                                         z 0    *The MPFL for Containment is the combustible loading during operation and high during outages.                                       -u "Tl                                                                                                                                       -u N                                                                                                                                         "Tl
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CPNPP/FPR Deviation Location: Bldg. See attached Table 3b (2) Elev. See attached Table 3b (2) Room See attached Table 3b (2) F.A. See attached Table 3b (2) F.Z. See attached Table 3b (2) Col N-S Systems Path A E-W Systems Path B Reference Drawings: Bunker Ramo 50021526, SH. 1 and 2 Bunker Ramo 50020445 Bunker Ramo 50021765 Bunker Ramo 50021690 Bunker Ramo 50021914 Conax-7060-1 001 M2-1921, Figure FPR-2 M2-1922, Figure FPR-3 M2-1923, Figure FPR-4 M1-1927, Figure FPR-7 Exception: BTP APCSB 9.5-1 Appendix A Section D.1.j.

== Description:== Penetration for electrical conductors through the containment walls have not been tested as fire seals. This is equivalent to Unit 1 deviation 3b. Justification: 1. All penetration assembly non-metallic materials (excluding cables) have been classified by testing to be "non-burning" or "self-extinguishing" by test in accordance with ASTM D635.

2. Ionization, thermistor strip or UV fire detection is provided in all areas on both sides of the penetration, see Table 3b (2).

3. Penetration assemblies provide a means for continuity of power, control, and signal circuits through the containment structure pressure barrier while maintaining the integrity of the barrier.

4. Penetration assemblies are normally pressurized from outside containment with dry nitrogen at between 60 to 100 psi g.

5. Penetration assemblies are designed to remain intact following a Design Basis Accident and prevent leakage to the atmosphere.

6. See Table 3b (2) for fire severities and maximum permissible fire loading in the fire zones of concern.

1 OF 2 Revision 28

TABLE 3b (2) DEVIATION 3b (2) ELECTRICAL CONTAINMENT PENETRATIONS NO. OF BUILDING ROOM FIRE ZONE HAZARD MPFL SYSTEMS PENETRATIONS SAFEGUARD 2-083 2SD9 Low Low Train A Switchgear CONTAINMENT 2-154A 2CA101B Low Low/High* RCP, RHR 27 SAFEGUARD 2-096 2SE16 Low Low Alternate Shutdown Panel CONTAINMENT 2-155D 2CA101D Low Low/High* Reactor Trip 13 SAFEGUARD 2-103 2SE18 Low Low** Train B Switchgear CONTAINMENT 2-163 2CA101F Low Low/High* Rod Position Indicator Room 2 SAFEGUARD 2-103 2SE18 Low Low** Train B Switchgear CONTAINMENT 2-155N 2CA101F Low Low/High* RB Cool Unit Area 18 0

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0 CONTAINMENT 2-159 2CA101E Low Low/High* lncore Instrumentation 9 FUEL X-272 AA99e Low Low Fuel Storage Pool CONTAINMENT 2-155A 2CA101F Low Low/High* Fuel Handling Area 1

      *The MPFL for Containment is the actual combustible loading during operations and High during outages.
     **Based on the combustibles in this zone having the buring characteristics of the "C" time-temperature curve.

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CPNPP/FPR Deviation 3c Location: Bldg. See attached Table 3c Elev. 810 Room 82 F.A. SB8 Col N-S Systems Path A E-W Systems Path B Reference Drawings: Overlay Drawing 08164, Sheets 1-17 2323-A 1-0540 M1-1921 Attachment Grinnel Drawing 133 Exception: BTP APCSB 9.5-1 Appendix A, Section D.1.j

== Description:== Missile Resisting Doors are installed in fire barriers but are not of a fire rated construction. Justification: 1. Door is constructed of solid 2 1/2" thick steel plate (see sketch 3c-2) and will not degrade the integrity of the fire barrier. Door latching assembly is comprised of 2 dead bolt locks (see sketch 3c-3).

2. Automatic sprinkler suppression is provided where potential for exposure of safety related systems exists. Ionization detection is provided throughout the area.

3. Primary design criteria is resistance to externally generated missiles.

4. Primary Exposure hazard is 138KV start-up transformer (see sketch 3c-1 ).

The missile resistant door is shielded from direct exposure of a transformer fire by three hour rated walls on the switchgear and safeguard building exteriors.

5. See Table 3c for fire severity and maximum permissible fire loading values.

1 OF 5 Revision 28

TABLE 3c DEVIATION 3c OTHER SIDE OF DOOR FHA ROOM DESCRIPTION ROOM NO. FIRE ZONE FIRE HAZARD MPFL DOOR# FIRE ZONE ROOM# FIRE HAZARD & DURATION 2 SFGD BLDG. 82 SB8 Moderate Low* S-27 YARD NA 810'-6" Carr.

    *The MPFL for this zone has been exceeded, but it is provided with adequate fire mitigation features. Reference section II of the FPR for a description of these features.

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CPNPP/FPR Deviation 3c-1

Subject:

Control Room Missile Door Location: Bldg. Electrical & Control Elev. 830 Room 135

              ~~---------------

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              ~~---------------

Col N-S --;;A--A-;;--------- Systems Path A E-W 5-A Systems Path B Reference Drawings: M1-1929;M1-1939; Overly 08164, sheets 6 thru 9 2323-A1-0504, July 26, 1983 Submittal item 3c Exception: BTP APCSB 9.5-1, Appendix A, Section D.1.j

== Description:== The control room missile door in the west wall is not a three hour rated fire door. This wall separates corridor room 140 and the turbine deck. The door is a single swing 4-1/2" thick solid steel structure mounted in a 6" door jamb embedded in a 30" reinforced concrete wall. The door opens to the turbine deck at the 830'-0" elevation. The fixed combustible loading in the area of the door is non-existent for a distance exceeding 100 feet. Only transient combustibles will be passing through this area. A thermal and structural evaluation of the door indicated it would experience deformation from thermal growth and potential failure of the door jamb welds, but would remain in place during postulated ASTM E-119 "E" curve fire conditions. In actuality, the fact that the turbine deck is open to the atmosphere and lacks fixed combustible loading in the area of the missile door prevents such a fire from occurring. Justification: 1. The door is installed in an exterior wall of the control room opening to the turbine deck which is void of fixed combustibles for a minimum of 100 feet and is an open air space.

2. The fixed combustibles (lubricating and control oil) on the turbine deck are contained within metal enclosures for the turbines a distance of 125 feet from the missile door.

3. A fire hose house with a 2 1/2" wet standpipe is located within 50 feet of the door. Others are located throughout the turbine deck area. Fire 1 OF 2 Revision 28

CPNPP/FPR Deviation 3c-1 extinguishers, hand-held and a 150 pound wheeled unit, are located near the door and throughout the turbine deck area.

4. Evaluations indicate that the missile door will provide adequate protection for the control room from a fire on the turbine deck for a period of time in excess of the burn time for the actual combustible loading (fixed and transient) for the area.

5. The design of the door ensures the door will remain standing in place under severe fire conditions and provides a tortuous path which a fire has to propagate.

6. The door is a 4 1/2" solid steel structure mounted in a 6" deep door jamb embedded in the outer surface of a 30" reinforced concrete wall.

7. The door seals against a steel frame that is poured into wall with reinforcement ties.

8. Transient combustibles in this area consist of small quantities of flammable materials in transit from one location to another.

9. The doorway is 24" deep and void of combustible materials and there is a negligible amount of combustible loading in the corridor of the control room (east side of the door).

10. The control room has an area wide early warning smoke detection system installed for assuring early detection and response by the plant fire brigade ensuring early fire extinguishment.

11. A loss of the control room due to a fire will not prevent a safe shutdown of the plant because the shutdown can be performed by alternate shutdown.

12. Manual suppression is available in the control room utilizing hose stations, portable extinguishers and fire hydrants.

13. Based on the thermal and structural evaluation, size and design of the door, and lack of combustibles in the vicinity of the door this door meets the intent of BTP APCSB 9.5-1, Appendix A and provides an adequate level of fire safety.

2 OF2 Revision 28

CPNPP/FPR Deviation 3d Location: Bldg. Safeguard Elev. See attached Table 3d Room See attached Table 3d F.A. See attached Table 3d Col N-S Systems Path A E-W Systems Path B Reference Drawings: Overly Drawing Q7068X2, Sheets 1 - 4 7068, Sheets 1-1 -1 05 2323-A 1-0540 M1-1921 M1-1923 M1-1924 Exception: BTP APCSB 9.5-1 Appendix A, Section D.1.j

== Description:== Watertight doors are installed in fire barriers, but are not a fire tested construction. Justification: 1. Doors are of substantial construction and will not degrade the integrity of the fire barrier. Dogs hold the doors closed on the two vertical sides of the door frame. Seals are constructed of RTV Silicone elastomer materials, similar to elastomers used in penetration seal construction.

2. Automatic water sprinkler coverage is provided in areas of high exposure hazard, and other areas per Table 3d. Hose stations and portable extinguishers are available.

3. Combustible loading for each fire zone is per Table 3d.

4. Primary design criteria is containment of internal flood water to prevent damage to redundant essential equipment and systems.

1 OF 2 Revision 28

TABLE 3d DEVIATION 3d WATER TIGHT DOORS FHA ROOM FIRE DESCRIPTION HAZARD MPFL DOOR PROTECTION FIRE ROOM DESCRIPTION HAZARD MPFL PROTECTION ZONE ZONE 2 84 SG10a Diesel Generator >High High S-28 Sprinkler/ SD9 83 Train A Low Low Cable Tray Room Train -A Detection Switchgear Sprinkler/ Electrical Detection Equipment Room 2 85 Sl12a Diesel Generator >High High S-26 Sprinkler/ SD9 83 Train A Low Low Cable Tray Room Train A & B Detection Switchgear Sprinkler/ Electrical Detection Equipment Room 4 100A SK17a Light Feedwater Low Low S-38C Sprinkler/ SE18 103 Electrical Low Low Sprinkler/ Pipe Penetration Detection Equipment Room Detection 5 110 SK17c Main Steam Low Low S-408 Sprinkler/ SF19 107 Filter Storage Low Moderate Sprinkler/ Penetration Area Detection Area Detection 0

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CPNPP/FPR Deviation Location: Bldg. Safeguards Elev. See attached Table 3d (2) Room See attached Table 3d (2) F.A. See attached Table 3d (2) F.Z. See attached Table 3d (2) Col N-S Systems Path A E-W Systems Path B Reference Drawings: Overly Drawing Q7068X2, SH. 1 - 4 Overly Drawing 07068, SH. 1 105 A2-0540 M2-1921, Figure FPR-26 M2-1923, Figure FPR-28 M2-1924, Figure FPR-29 Exception: BTP APCSB 9.5-1 Appendix A Section D.1.j.

== Description:== Watertight doors installed in fire barriers are not fire tested configurations. This is equivalent to Unit 1 deviation 3d. Justification: 1. Doors are of substantial construction and will not degrade the integrity of the fire barrier. Dogs hold the doors closed on the two vertical sides of the door frame. Seals are constructed of RTV Silicone elastomer used in penetration seal construction.

2. Automatic sprinkler coverage is provided in areas of high exposure hazard, and other areas per Table 3d (2). Hose stations and portable extinguishers are available.

3. Combustible loading for each fire zone is per Table 3d (2).

4. Primary design criteria is containment of internal flood water to prevent damage to redundant essential equipment and systems.

1 OF 5 Revision 28

TABLE 3d (2) DEVIATION 3d (2) WATER TIGHT DOORS FPR FIGURE FPR-26 FPR-26 FPR-28 FPR-28 FPR-29 FPR-29 ROOM 2-084 2-085 2-1 OOH 2-100E 2-110A 2-110D FIRE ZONE 2SG10A 2SI12A 2SK17A 2SK17A 2SK17C 2SK17C DESCRIPTION Diesel Generator Diesel Generator Light Feedwater Light Feedwater Main Steam Main Steam Room Train A Room Train B Penetration Area Penetration Area Penetration Area Penetration Area HAZARD >High >High Low Low Low Low MPFL High High Low* Low* Low* Low* PROTECTION Detection and Auto Detection and Auto Detection and Auto Detection and Auto Detection and Auto Detection and Auto Sprinkler Coverage Sprinkler Coverage Sprinkler Coverage Sprinkler Coverage Sprinkler Coverage Sprinkler Coverage DOOR S2-28 S2-26 S2-38C S2-38A S2-40B S2-40C ROOM 2-083 2-083 2-103 2-100 2-107 2-108 FIRE ZONE 2SD9 2SD9 2SE18 2SLSK100 2SF19 2SN158 0 DESCRIPTION Train A Train A Train B High Pressure Filter Stairway "'U N Switchgear Switchgear Switchgear Chemical Feed Storage Area z 0 "'U

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0 PROTECTION Detection and Manual Detection and Manual Detection and Manual Detection and Auto Detection and Auto Hose station and HMP Sprinkler Coverage Sprinkler Coverage Sprinkler Coverage Sprinkler Coverage Sprinkler Coverage extinguisher coverage

      *Limited to the actual combustible loading (Deviation 8c (2)).
     ** Based on the combustibles in this zone having the burning characteristics of hte "C" time-temperature curve.

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CPNPP/FPR Deviation 3e

Subject:

Containment Air-Locks Location: Bldg. Containment/Safeguard Elev. See attached Room See attached F.A. SB, SF, CA F.Z. See attached Col N-S Systems Path A E-W Systems Path B Reference Drawings: CB&I: 74-2427-236-4, 74-2427-11 0-4, 74-2427-200-2 CB&I Figures: E1, E3, E4, P1 M1-1922, M1-1925 E 1-2022, E 1-2024 Exception: BTP APCSB 9.5-1 Appendix A, Section D.1.j

== Description:== The personnel and emergency Air-Locks for containment are not fire rated construction. Justification: 1. Hatch construction is substantial with two steel doors on either end of the air lock assembly separated by more than 10 feet.

2. Detection is available in Fire Zones SB15 and SF20 in the Safeguards side. In containment, area wide detection is provided in Fire Zone CA 101 d, and in Fire Zone CA 101 g which is adjacent to Fire Zone CA 101 h.

3. The primary design function of the air-locks is to minimize the leakage of containment atmosphere.

4. Manual suppression is available utilizing both hose stations and portable extinguishers. Hose coverage for Fire Zone SF20 is available by utilizing station CP1-FPFESH-19, in Fire Zone SF19, and additional hose supplied by the Fire Brigade.

5. The design and construction of the hatch provide an equivalent level of protection to the requirements of BTP APCSB 9.5-1.

6. See Table 3e for fire severities and maximum permissible fire loadings.

1 OF 4 Revision 28

TABLE 3e DEVIATION 3e FHA ROOM FIRE DESCRIPTION HAZARD MPFL PROTECTION HATCH ROOM FIRE DESCRIPTION HAZARD MPFL PROTECTION ZONE ZONE 3 95 SB15 Personnel Low Low Sprinklers/ Personnel 155A CA101d Containment Cables

Thermal Air-Lock Cables/ Hose Sta/ Air-Lock Detector Access Transient HMP/Ion Elev. 832 HMP/Port Corridor Lube Oil Detection Extinguisher 6 111 SF20 Emergency Low Moderate HPK Emergency 160 CA101h Containment Rad Waste
HPK Air-Lock Transient HHP/Ion Air-Lock Compactor Access Detection Elev. 905

       *The MPFL for containment is the combustible loading during operation and high during outages.

NOTES

1. HMP- Hand held portable multi-purpose fire extinguisher 0

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CPNPP/FPR Deviation Location: Bldg. Containment/Safeguards Elev. See attached Room See attached F.A. 2SB, 2SF, 2CA F.Z. See attached Col N-S Systems Path A E-W Systems Path B Reference Drawings: CB&I: 74-2427-236-4 CB&I: 74-2427-110-4 CB&I: 74-2427-200-2 CB&I Figures: E1, E3, E4, P1 M2-1922, Figure FPR-27 M2-1925, Figure FPR-30 Exception: BTP APCSB 9.5-1 Appendix A Section D.1.j.

== Description:== Containment personnel and emergency air locks installed in fire barriers are not fire tested configurations. This is equivalent to Unit 1 deviation 3e. Justification: 1. Hatch construction is substantial with two steel doors on either end of the air lock assembly separated by a horizontal distance of more than 10 feet.

2. Detection is available in Fire Zones 2SB15 and 2SF20 on the Safeguards Building side. In Containment, area wide detection is provided in Fire zone 2CA 101 G, and in Fire Zone 2CA 101 F which is adjacent to Fire Zone 2CA 101 H.

3. The primary design function of the air locks is to minimize the leakage of containment atmosphere.

4. Manual suppression is available utilizing both hose stations and portable extinguishers. Hose coverage for Fire Zone 2SF20 is available by utilizing station CP2-FPFESH-19, in Fire Zone 2SF19, and additional hose supplied by the fire brigade.

5. The design and construction of the hatch provide an equivalent level of protection to the requirements of BTP APCSB 9.5-1.

6. See Table 3e (2) for fire severities and maximum permissible fire loadings.

1 OF 4 Revision 28

TABLE 3e (2) DEVIATION 3e (2) CONTAINMENT AIR-LOCKS FPR FIGURE FPR-27 FPR-30 ROOM 2-095 2-111 FIRE ZONE 2SB15 2SF20 DESCRIPTION Personnel Air-Lock Access Corridor Emergency Air-Lock Access HAZARD Low Low MPFL Low High PROTECTION Ion. Detection and Automatic Sprinkler, Hose station lon. Detection, Hose station and and HHA/HPKIHMP extinguisher coverage HHA/HPK extinguisher coverage HATCH Personnel Air-Lock Elev. 832'-6" Emergency Air-Lock Elev. 905'-6" ROOM 2-155D 2-160A 0 FIRE ZONE 2CA101D 2CA101 H -u N z 0 DESCRIPTION Loop 1 832' Corridor Operating Deck -u "'Tl -u .j::>.. HAZARD Low Low "'Tl

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        *The MPFL for Containment is the actual combustible loading during operations and High during outages.

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CPNPP/FPR Deviation 3e (2) 30F 4 Revision 28

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CPNPP/FPR Deviation

Subject:

Containment Mechanical Penetration Seals Location: Bldg. See attached Elev. See attached Room See attached F.A. SB, SA, SK, CA F.Z. See attached Col N-S Systems Path A E-W Systems Path B Reference Drawings: 2323-M 1-0502, 2323-M 1-0503, 2323-M 1-0503-01 2323-M1-0522, M1-1920, M1-1921, M1-1922, M1-1923, M1-1924, M1-1935 Exception: Appendix A, Section D.1.j

== Description:== The mechanical penetration seals used as retention pressure boundary seals are not three hour rated seals by ASTM-E-119 testing. Justification: 1. Mechanical penetration seals are designed for containment of the atmosphere inside the containment building following a Design Basis Accident inside this building.

2. These penetration assemblies are manufactured of welded ferrous metal alloy. One assembly contains tubing carrying a small quantity of high purity silicone oil used in a pressure sensor.

3. Ionization, thermistor strip or UV fire detection devices are provided in all fire zones on both sides of the seal.

4. The construction of these penetration assemblies exceeds the requirements for fire rating of the penetration seals and does not degrade the safety function of the containment walls or fire barriers.

5. Most of the penetrations are process pipe systems supplying containment.

Also involved are the fuel transfer tube and HVAC penetrations.

6. The containment mechanical penetration seals provide a barrier with an equivalent level of protection as required by Appendix R Section III.G.2.

7. See Table 3g for fire severities and maximum permissible fire loadings in the Fire Zones of concern.

1 OF 2 Revision 28

TABLE 3g DEVIATION 3g BUILDING ROOM FIRE ZONE HAZARD/COMBUST! BLE MPFL SYSTEMS NO. OF PENETRATIONS Safeguard 65 SB2c Low/Cables Low RHR 2 Containment 154 CA101b Low/Cables, L.O. Low/High* RCP, RHR Safeguard 63 SA1c Low/Cables Low RHR 2 Containment 154 CA101b Low/Cables, L.O. Low/High* RCP, RHR Safeguard 77 SB143 Low/Cables Low eves, ccw 22 Containment 154 CA101b Low/Cables, L.O. Low/High* RCP, RHR Safeguard 77 SA142 Low/Cables Low eves, ccw 20 Containment 154 CA101b Low/Cables, L.O. Low/High* RCP, RHR Safeguard 88 SB144 Low/Cables Low ccw 27 Containment 155A CA101d Low/Cables, L.O. Low/High* Rx Trip 0

                                                                                                                           -u N     Safeguard       100A           SK17a         Low/Cables                 Low                FW            8            z 0    Containment      155A           CA101f        Low/Cables                 Low/High*          FW                         -u

"'Tl -u N Safeguard 108 SK17b Low/Hyd Fluid Low MS 4 "'Tl

                                                                                                                           -u Containment      155a           CA101g        Low/Cables                 Low/High*                                     :::0 Fuel            272            AA99e         Low/Cables, Transients     Low                Fuel Handling 2 Containment      155A           CA101b        Low/Cables                 Low/High*          and Air Handling Auxiliary        244            AA39          Low/Charcoal Filters       Low                Air Handling  2 Containment     155A           CA101g        Low/Cables                 Low/Cables

Air Handling Auxiliary 246 AA40 Low/Charcoal Filters Low Air Handling 2 Containment 155A CA101g Low/Cables Low/High* Air Handling
The MPFL for Containment is the combustible loading during operation and high during outages.

0 CD (jj" a*

J N

(X)

CPNPP/FPR Deviation 3g (2) Location: Bldg. See attached Elev. See attached Room See attached F.A. 2SA, 2SB, 2SK, 2CA F.Z. See attached Col N-S Systems Path A E-W Systems Path B Reference Drawings: M2-0502 M2-0503 M2-0503-01 M2-0522 M2-1920, Figure FPR-1 M2-1921, Figure FPR-2 M2-1922, Figure FPR-3 M2-1923, Figure FPR-4 M2-1924, Figure FPR-5 M2-1935, Figures FPR-11, 14 , 15 Exception: BTP APCSB 9.5-1 Appendix A Section D.1.j.

== Description:== The mechanical penetration seals used as retention pressure boundary seals are not fire tested in accordance with ASTM-E-119. This is equivalent to Unit 1 deviation 3g. Justification: 1. Mechanical penetration seals are designed for containment of the atmosphere inside the Containment Building following a Design Basis Accident.

2. These penetration assemblies are manufactured of welded ferrous metal alloy. One assembly contains tubing carrying a small quantity of high purity silicone oil used in a pressure sensor.

3. Ionization, thermistor strip or UV fire detection is provided in all areas on both sides of the seal.

4. The construction of these penetration assemblies exceeds the fire rating requirements of silicone foam and elastomer fire-rated penetration seals used throughout the plant and does not degrade the safety function of the containment walls or fire barriers.

5. Most of the penetrations are process pipe systems supplying Containment. Also involved are the fuel transfer tube and HVAC penetrations.

1 OF 5 Revision 28

CPNPP/FPR Deviation 3g (2)

6. The Containment mechanical penetration seals provide a barrier with an equivalent level of protection as required by 10CFR50, Appendix R Section III.G.2.

7. See Table 3g (2) for fire severities and maximum permissible fire loading in the fire zones of concern.

2 OF 5 Revision 28

TABLE 3g (2) DEVIATION 3g (2) MECHANICAL CONTAINMENT PENETRATIONS BUILDING ROOM FIRE ZONE HAZARD DURATION SYSTEMS NO. OF PENETRATIONS SAFEGUARD 2-065 2SB2C Low Low Train A Valve Isolation Tank Room CONTAINMENT 2-154A 2CA101B Low Low/High* Loop 1 808' Corridor 2 SAFEGUARD 2-063 2SA1C Low Low Train B Valve Isolation Tank Room CONTAINMENT 2-154D 2CA101B Low Low/High* Loop 4 808' Corridor 2 0 SAFEGUARD 2-077A 2SA142 Low Low Penetration Valve Room -u (,V z 0 -u "'Tl CONTAINMENT 2-154D 2CA101B Low Low/High* Loop 4 808' Corridor 22 -u (J1 "'Tl

                                                                                                                           -u SAFEGUARD           2-077B         2SB143        Low           Low              Penetration Valve Room                 :::0 CONTAINMENT 2-154A                 2CA101B       Low           Low/High*        Loop 1 808' Corridor           20 SAFEGUARD           2-088          2SB144        Low           Low              Penetration Valve Room CONTAINMENT 2-155D                 2CA101D       Low           Low/High*        Loop 1 832' Corridor           12 SAFEGUARD           2-088          2SB144        Low           Low              Penetration Valve Room CONTAINMENT 2-155G                 2CA101D       Low           Low/High*        Loop 4 832' Corridor           15

0 CD

The MPFL for Containment is the actual combustible loading during operations and High during outages.

(jj" a* ** Limited to the actual combustible loading (Deviation 8c (2)).

J N

(X)

TABLE 3g (2) DEVIATION 3g (2) MECHANICAL CONTAINMENT PENETRATIONS BUILDING ROOM FIRE ZONE HAZARD DURATION SYSTEMS NO. OF PENETRATIONS SAFEGUARD 2-100A 2SK17A Low Low** Feedwater Isolation Valve CONTAINMENT 2-155L 2CA101F Low Low/High* Feedwater Penetration Area 2 SAFEGUARD 2-100B 2SK17A Low Low** Feedwater Isolation Valve CONTAINMENT 2-155L 2CA101F Low Low/High* Feedwater Penetration Area 2 SAFEGUARD 2-100C 2SK17A Low Low** Feedwater Isolation Valve CONTAINMENT 2-155L 2CA101F Low Low/High* Feedwater Penetration Area 2 0

-u

.j::>.. z 0 SAFEGUARD 2-100D 2SK17A Low Low** Feedwater Isolation Valve -u "'Tl -u (J1 "'Tl CONTAINMENT 2-155L 2CA101F Low Low/High* Feedwater Penetration Area 2 -u

0 SAFEGUARD 2-108A 2SK17B Low Low** Main Steam Penetration Area CONTAINMENT 2-1550 2CA101G Low Low/High* Main Steam Penetration Area 1 SAFEGUARD 2-108B 2SK17B Low Low** Main Steam Penetration Area CONTAINMENT 2-1550 2CA101G Low Low/High* Main Steam Penetration Area 1 SAFEGUARD 2-108C 2SK17B Low Low** Main Steam Penetration Area

0

The MPFL for Containment is the actual combustible loading during operations and High during outages.

CD (jj" a* ** Limited to the actual combustible loading (Deviation 8c (2)).

J N

(X)

TABLE 3g (2) DEVIATION 3g (2) MECHANICAL CONTAINMENT PENETRATIONS BUILDING ROOM FIRE ZONE HAZARD DURATION SYSTEMS NO. OF PENETRATIONS CONTAINMENT 2-1550 2CA101G Low Low/High* Main Steam Penetration Area 1 SAFEGUARD 2-108D 2SK17B Low Low** Main Steam Penetration Area CONTAINMENT 2-1550 2CA101G Low Low/High* Main Steam Penetration Area 1 FUEL X-272 AA99e Low Low Spent Fuel Pool Area CONTAINMENT 2-155P 2CA101F Low Low/High* Reactor Cavity Open Area 1 FUEL X-267 AA99b Low Low Fuel Transfer Canal 0

                                                                                                                             -u (J1 z

0 CONTAINMENT 2-158 2CA101E Low Low/High* Fuel Transfer Canal Area 1 -u "'Tl -u (J1 "'Tl AUXILIARY X-246 AA40 Low Low Upper Primary Plant Filter -u

0 Room CONTAINMENT 2-155P 2CA101F Low Low/High* Reactor Cavity Open Area 2 AUXILIARY X-244 AA39 Low Low Lower Primary Plant Filter Room CONTAINMENT 2-155P 2CA101F Low Low/High* Reactor Cavity Open Area 2

The MPFL for Containment is the actual combustible loading during operations and High during outages.

~ ** Limited to the actual combustible loading (Deviation 8c (2)). (jj" a*

J N

(X)

CPNPP/FPR Deviation 3h

Subject:

Cable Spreading Room BR-PR Door Location: Bldg. Electric & Control Elev. 810'-6" Room 133,25 F.A. EN,TB F.Z. 64, 111 Col N-S Systems Path A E-W Systems Path B Reference Drawings: M1-1928 M1-1940 Architectural Control System Incorporated Manual No. 501210-4001-1 Operations Manual Auto Release Tornado Venting Door P/N 501210-3001-4 Exception: BTP APCSB 9.5-1 Appendix A, Section D.1.j

== Description:== The Bullet Resistant-Penetration Resistant (BR-PR) door to the Unit 1 cable spread room (CSR) is located in the south wall of the EN Fire Area Boundary. It provides access to the East-West corridor in Fire Area TB. The combustible loading in the corridor consists primarily of transient combustibles. The corridor contains the Halon system cylinders for the Unit CSR. The BR-PR door is a dual function special purpose door. It is designed to provide security, and fire resistance. The door is normally locked closed. The door may be opened from inside the CSR using the panic exit latch or from the corridor using the mechanical key override. The door is a 3'-0" X 7'-0", 2 1/2" thick single swing hollow metal design constructed of 1/14" armored steel plate. The frames are constructed of C-6 channel iron anchored with Hilti Kwik bolts to a structural concrete wall and grouted in place with a non-shrink grout. The door procured in 1980 does not exhibit a UL label although it is of labeled construction similar to a subsequent UL test File R9271-3 Project 80NK 20450 dated July 15, 1981. The door was tested utilizing a mortice type lock instead of the rim latch device used at CPNPP to achieve the triple function capability. The latch utilized as described above (Sargent 12-9800 series) is a fire and panic exit device. 1 OF 2 Revision 28

CPNPP/FPR Deviation 3h Justification: 1. The door is a multi-purpose design providing protection for security, and fire criteria.

2. The door is of a construction similar to subsequent UL tests with the exception of the latching mechanism.

3. The latching mechanism is a modified UL F listed rim lock device required to meet design criteria other than Fire Protection. The modifications to the device are limited to the unlatching hardware.

4. Ionization detection is available on both sides of the door, providing early warning and rapid response by the fire brigade to any fires in this corridor.

Manual suppression is available using hose stations, manual pre-action sprinklers inside the Cable Spread Room, and portable extinguishers.

5. Automatic Halon total flooding suppression is available in the Cable Spread Room.

6. The combustible loading in the corridor, Fire Zone TB111, is low. The maximum permissible fire loading for Fire Zone TB111 is also low.

7. The corridor fire area contains no redundant essential equipment, cables, or components.

8. Alternate shutdown is available independent of a fire in the Cable Spread Room.

2 OF2 Revision 28

CPNPP/FPR Deviation 3ha (2) Location: Bldg. Electric & Control Elev. 810'-6" Room X-134, 2-038 F.A. EM, TB F.Z. EM63, TB111 Col N-S Systems Path A E-W Systems Path B Reference Drawings: M1-1928 M1-1940 Architechural Control Systems Incorporated Manual No. 501210-4001-1 Operations Manual Auto Release Tornado Venting Door P/N 501210-3001-4 Figure FPR-8 Figure FPR-19 Deviation: BTP APCSB 9.5-1 Appendix A Section D.1.j.

== Description:== The bullet resistant-penetration resistant (BR-PR) door number E-24 separates Room X-134, the Unit 2 Cable Spread Room (CSR), (Fire Zone EM63) from Room 2-308, the Unit 2 CSR Corridor (Fire Zone TB111 ). The BR-PR door is a dual function special purpose door. It is designed to provide security, and fire resistance. The door is normally locked closed. The door may be opened from inside the CSR using the panic exit latch or from the corridor using the mechanical key override. The door is a 3'-0" by 7'-0" by 2-1/2" thick single swing hollow metal design constructed of 1/4" armored steel plate. The frames are constructed of C-6 channel iron anchored in place by Hilti Kwik bolts to a structural concrete wall and grouted in place with non-shrink grout. The door procured in 1980 does not exhibit a UL label although it is of labeled construction similar to a subsequent UL test file R9271-3 Project 80NK 20580 dated July 15, 1981. The door was tested utilizing a mortise type lock instead of the rim latched device used at CPNPP. The latch utilized as described above (Sargent 12-9800 series) is a fire and panic exit device. This is equivalent to Unit 1 deviation 3h. Justification: 1. The door is a multi-purpose design providing protection for security and fire criteria. 1 OF 2 Revision 28

CPNPP/FPR Deviation 3ha (2)

2. The door is of a construction similar to subsequent UL tests with the exception on the latching mechanism.

3. The latching mechanism is a modified UL F listed rim lock device required to meet design criteria other than Fire Protection. The modifications to the device are limited to the unlatching hardware.

4. Ionization detection is available on both sides of the door, providing early warning and rapid response by the fire brigade to a fire in the area.

Manual suppression is available using hose stations, manual pre-action sprinklers inside the Cable Spread Room, and portable extinguishers.

5. Automatic Halon total flooding suppression is available in the Cable Spread Room.

6. The combustible loading in Fire Zone TB111, is low. The maximum permissible fire loading for Fire Zone TB111 is also low.

7. The corridor fire area contains no redundant essential equipment, cables, or components.

8. Alternate shutdown is available independent of a fire in the Cable Spread Room.

2 OF2 Revision 28

CPNPP/FPR Deviation 3hb (2) Location: Bldg. Electric & Control Elev. 810'-6" Room X-134, X-134B F.A. EM, EB F.Z. EM63, EB45 Col N-S Systems Path A E-W Systems Path B Reference Drawings: M1-1928 M1-1940 Architechural Control Systems Incorporated Manual No. 501210-4001-1 Operations Manual Auto Release Tornado Venting Door P/N 501210-3001-4 Figure FPR-8 Figure FPR-19 Deviation: BTP APCSB 9.5-1 Appendix A Section D.1.j.

== Description:== The bullet resistant-penetration resistant (BR-PR) door number E-23 separates Room X-134, the Unit 2 Cable Spread Room (CSR), (Fire Zone EM63) from Room 2-2-134B, the Electrical and Control Building stairwell (Fire Zone EB45). The BR-PR door is a dual function special purpose door. It is designed to provide security, and fire resistance. In the standard mode, the door is secure until a card is inserted in the reader. This initiates a time cycle causing the latches to release. In the card reader or system failure mode, the door may be opened via mechanical key override. The door is a 3'-0" by 7'-0" by 2-1/2" thick single swing hollow metal design constructed of 1/4" armored steel plate. The frames are constructed of C-6 channel iron anchored in place by Hilti Kwik bolts to a structural concrete wall and grouted in place with non-shrink grout. The door procured in 1980 does not exhibit a UL label although it is of labeled construction similar to a subsequent UL test file R9271-3 Project 80NK 20580 dated July 15, 1981. The door was tested utilizing a mortise type lock instead of the rim latched device used at CPNPP. The latch utilized as described above (Sargent 12-9800 series) is a fire and panic exit device. This is equivalent to Unit 1 deviation 3h. Justification: 1. The door is a multi-purpose design providing protection for security and fire criteria. 1 OF 2 Revision 28

CPNPP/FPR Deviation 3hb (2)

2. The door is of a construction similar to subsequent UL tests with the exception on the latching mechanism.

3. The latching mechanism is a modified UL F listed rim lock device required to meet design criteria other than Fire Protection. The modifications to the device are limited to the unlatching hardware.

4. Ionization detection is available in the CSR providing early warning, actuation of the Halon Suppression system and rapid response by the fire brigade to a fire in the area. Manual suppression is available using hose stations, manual pre-action sprinklers inside the Cable Spread Room, and portable extinguishers.

5. Automatic Halon total flooding suppression is available in the Cable Spread Room.

6. The combustible loading in Fire Zone EB45 is low. The maximum permissible fire loading for Fire Zone EB45 is moderate.

7. The stairwell fire area contains no redundant essential equipment, cables, or components.

8. Alternate shutdown is available independent of a fire in the Cable Spread Room.

2 OF2 Revision 28

CPNPP/FPR Deviation 4a Slides View Location: 4b-1 Looking North Bldg. Containment 4b-2 Looking Northeast Elev. 905 Room 161A F.A. CA101h Col N-S Systems Path A PCV-445A, HV-1-8000A, 801 OA E-W Systems Path B PCV-456, HV-1-80008, 80108 Reference Drawings: M1-1924 Alison Controls- 521 05D (Sheet 10 of 13) Deviation: Appendix R to 10CFR50 Section III.G.2.d

== Description:== Redundant essential relief and isolation valves for pressurizer control are located within the same compartment and within 20 feet inside the containment building. Justification: 1. A negligible amount of combustible material exists in the room.

2. Administrative controls will be implemented to ensure that transient combustibles are removed from this particular location prior to power operations.

3. Due to the nature of the pressurizer compartment its location within the containment, and restricted access, control of combustibles is considered feasible as protection of the equipment from a damaging fire.

1 OF 1 Revision 28

CPNPP/FPR Deviation Location: Bldg. Unit 2 Containment Elev. 905 Room 2-161E F.A 2CA F.Z 2CA101H Col N-S Systems Path A 2-PCV-0455A E-W Systems Path B 2-PCV-0456 Reference Drawings: M2-1925-01, Figure FPR-30 Alison Controls- 521 05D2 (Sheet 10 of 13) Deviation: Appendix R to 10CFR50 Section III.G.2.d

== Description:== Redundant essential relief and isolation valves for pressurizer control are located within the same compartment and within 20 feet inside the containment building. This is equivalent to Unit 1 deviation 4a. Justification: 1. A negligible amount of combustibles exist in the room where the relief valves are located.

2. Administrative controls will be implemented to control transient combustibles by designation of the room as a "No Storage" area.

3. Thermistor detection is installed in room 2-161 C beneath the open grating which is the floor of room 2-161 D. Standpipe and extinguisher protection are provided for the room.

4. Due to the nature of the pressurizer compartment, it's location within the containment, restricted access into the room, control of combustibles and fire protection features described above, the components and cables located in the room are adequately protected from the damaging effects of a postulated fire.

1 OF 1 Revision 28

CPNPP/FPR Deviation 4a-1 Location: Bldg. Containment Elev. 812'-0" Room 154 RCS Loops 1&4 Steam Generator Compartment F.A. CA101c Col N-S Systems Path A E-W Systems Path B Reference Drawings: M1-1921 Deviation: Appendix R to 10CFR50 Section III.G.2.d

== Description:== Residual Heat Removal Loops 1 and 2 are located on the 808'-0" elevation, in the Containment Building. Inlet isolation motor operated valves 1-8701A, 1-8702A, and 1-8702B are control valves essential to safe shutdown. Valves 1-8702A and 1-8702B are located in the steam generator 1 and 4 compartment Fire Zone 101 C while valves 1-8701 A & 1-8701 B are located in the corridor outside of the steam generator compartments in Fire Zone 101 b. Valves 1-8701A and 1-8701 Bare separated by more than 20 feet with intervening combustibles. Three cable trays constitute the intervening combustibles; however, none of the trays transcend the space between the valves. A partial barrier is located between redundant essential inlet isolation motor operated valves (1-8702A and 1-8702B) for residual heat removal loops 1 & 2. The valves are located approximately five feet above the floor and are spatially separated seven feet apart center to center. The partial barrier does not provide physical separation between the redundant valve bodies. The control circuits for the motorized valve operating mechanisms, as well as the motorized valve operating mechanisms themselves, are located above the valves, and are separated by a three foot thick barrier which extends from the top of the valves at approximately the 819' elevation to the 832' elevation, separating the operating mechanisms and redundant circuits. Justification: 1. Configuration- Valves 1-8701A and 1-8701 Bare located well in excess of 20 feet apart. The distance separating the valves eliminates the hazard of a fire under either valves impinging on the other valve. The partial barrier separating valves 1-8702A and 1-8702B is a three foot thick reinforced concrete wall. The barrier separates redundant components so that radiant energy from a fire involving the motorized valve operating mechanisms and control circuits of one train would not degrade or ignite components of the other train. The barrier also directs 1 OF 5 Revision 28

CPNPP/FPR Deviation 4a-1 the convective energy from the fire away from the surviving train of components. The floor in the compartment is slightly sloped toward the doorways mitigating the accumulation of fluids beneath the valves.

2. Combustibles- Between valves 1-8701A and 1-8701 B there are 3 cable trays. One cable tray is full and extends from the vicinity of 1-8701A to a point 12 feet short of 1-8701 B. Another cable tray is approximately 10%

full and spans from the vicinity of 1-8701 A to a point 12 feet short of 1-8701 B. The last tray is located between the valves and does not extend to either of them (see attached diagram). Since no tray is closer than 12 feet to the train B valve, a fire in the area disabling both valves is highly unlikely. The combustible loading for fire area CA is 35,800 BTU/Sq. Ft. This is approximately equal to a 27 minute fire duration. However, this is not a realistic representation of the possible fire that could occur in containment. There are no in-situ combustibles in the room housing valves 1-8702A and 1-8702B with the exception of lubricating oil in the reactor coolant pumps and a negligible amount of exposed cable. The reactor coolant pumps are located at opposite ends of the compartment near the doorways more than 20' from the valves. A reactor coolant pump oil collection system is installed per the requirements of regulatory guide 1.29 paragraph C.2. The reactor coolant pump oil collection system provides control for a postulated reactor coolant pump oil spill. Both sets of valves are located in a high radiation area where transient combustibles are administratively controlled consistent with utility policies for minimizing radioactive waste materials.

3. Ignition Sources - Fixed ignition sources in Fire Zones CA 101 b, CA 101 c are limited to electrical faults.

Transient ignition sources are minimized by administrative controls.

4. Protection - Fire Zone CA 101 b and CA 101 care provided with area wide thermistor strip detection which alerts the control room for prompt emergency response.

Summary: Based on the above justifications redundant component's operability will not be affected by a fire in the area. 2 OF 5 Revision 28

CPNPP/FPR Deviation 4a-1 CONDUlT Tl3QPC1C2~ RH~ LOOP 1 - - - - ! 1 I E - - - - RHR LOCP 2

                                                 . - - - - . - - - NONE:SSENiiAL ESSENilAI... ----...---it_..,

t A CONTA!NHENT F' A CA !Ole ELEVATION 812'-o* SKETCH 4A-1 SHT. 1 NOT TO SCALE 30F 5 Revision 28

CPNPP/FPR Deviation 4a-1 SECTION A-A CONDUFS - - , - - - CDNDU!TS1l 1-8702A I 1-8702B NONESSENTIAL _ __; F'LOOR ELEV. 812'-0* l 71 CONTAINMENT F'.A. CA lOlc ELEVATION 812'-0' SKETCH 4c. -1 SHT. 2 NOT TO SCALE 40F 5 Revision 28

CPNPP/FPR Deviation 4a-1 SECTION B- B

                     ~----    T12DRBK05                                     l 4'-6' B.D.C.
          ~---,--------rr--r--1-r
                  ~v      r           T13QRCl02 - - - - '

I.H9'0' L T!3QRCJ02

                                                                     ~12'-0' u

l 8

              '-0'IITYP). T13QRCI04
                                                                  !{           i1 t

l-8701A l-8701B 9'-0'

                                                             ~*-
                                                    <42'-0' FLOOR E:LEV. 808'-0' CDNTAlNMENT FA. CA 101 ELEVATION 808'-0' SKETCH 4Q-l SHT. 3 NOT TO SCALE 50F 5                                       Revision 28

CPNPP/FPR Deviation 4a-1 (2) Location: Bldg. Unit 2 Containment Elev. 812'-0" Room 2-1541 & 2-154L F.A. 2CA F.Z. 2CA101C Col N-S Systems Path A E-W Systems Path B Reference Drawings: M2-1921, Figure FPR-26 Deviation: Appendix R to 10CFR50 Section III.G.2.d

== Description:== Residual Heat Removal Loops 1 and 2 are located on the 808'-0" elevation, in the Unit 2 Containment Building. Inlet isolation motor operated valves 2-8701A, 2-8701 B, 2-8702A, and 2-8702B are control valves essential to safe shutdown. Valves 2-8702A and 2-8702B are located in the steam generator 1 and 4 compartment in Fire Zone 2CA 101 C while valves 2-8701 A & 2-8701 B are located in the corridor outside of the steam generator compartments in Fire Zone 2CA 101 B. This is equivalent to Unit 1 deviation 4a-1. Valves 2-8701A and 2-8701 Bare separated by more than 20 feet with intervening combustibles. Three cable trays constitute the intervening combustibles; however, none of the trays transcend the space between the valves. A partial barrier is located between redundant essential inlet isolation motor operated valves 2-8702A and 2-8702B) for residual heat removal loops 1 & 2. The valves are located approximately five feet above the floor and are spatially separated six and one half feet apart center to center. The partial barrier does not provide physical separation between the redundant valve bodies. The control circuits for the motorized valve operating mechanisms, as well as the motorized valve operating mechanisms themselves, are located above the valves, and are separated by a three foot thick barrier which extends from the top of the valves at approximately the 819' elevation to the 832' elevation, separating the operating mechanisms and redundant circuits. Justification: 1. Configuration- Valves 2-8701A and 2-8701 Bare located well in excess of 20 feet apart. The distance separating the valves eliminates the hazard of a fire under either valve impinging on the other valve. The partial barrier separating valves 2-8702A and 2-8702B is a three foot thick reinforced concrete wall. The barrier separates redundant components so that radiant energy from a fire involving the motorized valve operating mechanisms and control circuits of one train would not degrade or ignite components of the other train. The barrier also directs 1 OF 5 Revision 28

CPNPP/FPR Deviation 4a-1 (2) the convective energy from the fire away from the surviving train of components. The floor in the compartment is slightly sloped toward the doorways mitigating the accumulation of fluids beneath the valves.

2. Combustibles- Between valves 2-8701A and 2-8701 B there are 3 cable trays. One cable tray is full and extends from the vicinity of 2-8701A to a point 12 feet short of 2-8701 B. Another cable tray is approximately 10%

full and spans from the vicinity of 2-8701A to a point 9 feet short of 2-8701 B. The last tray is located between the valves and does not extend either of them (see attached diagram). Since no tray is closer than 9 feet to the train B valve, a fire in the area disabling both valves is highly unlikely. The combustible loading for Fire Area 2CA is less than 40,000 BTU/Sq. Ft. This is equal to a fire duration of less than 30 minutes. However, this is not a realistic representation of the possible fire that could occur in containment. There are no in-situ combustibles in the room housing valves 2-8702A and 2-8702B with the exception of lubricating oil in the reactor coolant pumps and a negligible amount of exposed cable. The reactor coolant pumps are located at opposite ends of the compartment near the doorways more than 20' from the valves. A reactor coolant pump oil collection system is installed per the requirements of regulatory guide 1.29 paragraph C.2. The reactor coolant pump oil collection system provides control for a postulated reactor coolant pump oil spill. Both sets of valves are located in a high radiation area where transient combustibles are administratively controlled consistent with utility policies for minimizing radioactive waste materials.

3. Ignition Sources - Fixed ignition sources in Fire Zones 2CA 101 B and 2CA 101 C are limited to electrical faults.

Transient ignition sources are minimized by administrative controls.

4. Protection - Fire Zones 2CA 101 B and 2CA 101 Care provided with general area thermistor strip detection which alerts the control room for prompt emergency response.

Summary: Based on the above justifications redundant component operability will not be affected by a fire in the area. 2 OF 5 Revision 28

CPNPP/FPR Deviation 4a-1 (2) PLAN VIEW CONTAINMENT EXTERIOR W AU I I 12' 16' 1 , T:::3GRCL02

                                ~I r----o-"-+-- "r-'tO RClOl 1

STEAM GENERATOR COMPARTMENT WALL ESSENTIAL A REAcrOR WAll. FIRE ZONE 2CA101C SKETCH 4a-l (2) ELEVATION 812'-Q .. SHEET 1 OF 3 DEVIATION 4a-1 (2) NOT TO SCALE 30F 5 Revision 28

CPNPP/FPR Deviation 4a-1 (2) SECTION A-A CONDLTIS CONDUITS 2-8702B 2-8702A I

                              ' l J

1 CONDUIT NONESSENTIAL FLOOR EI..EV. 812'..{)" FIRE ZONE 2CA101C SKETCH 4a-1(2) ELEVATION 812'..{)" SHEET 2 OF 3 DEVIATION *-1(2) NOTTOSCALE 40F 5 Revision 28

CPNPP/FPR Deviation 4a-1 (2) SECTIONB-B

         \
                '---------------------------:~:;~;o:ot~:::l--~3~.~~-r=o~~~

1 moRBitOt 1 4*~*

                                           'I'23GRCLQ2 ~       f I

__...\ . I I (TY'P.) I

                                                                 ~11'-il"~ * ~*

I l 16'...()* I

+-

j D 2-S70l.B I 1 1 l FLOOR l!J..EV. 808'...0" FIRE ZONE 2CAI01C ELEVATION 808'0" SKETCH 4a-1{2) DEVIATION *-1(2) SHEET 3 OF 3 NOT TO SCALE 50F 5 Revision 28

CPNPP/FPR Deviation 5a Slides View Location: Bldg. E&C Elev. 830, 807 Room 133, 135, 147 F.A EN64, E065, E069 Col N-S Systems Path A E-W Systems Path B Reference Drawings: E-81388-3 E-81388-5 Deviation: BTP APCSB 9.5-1, Appendix A, Section D.3.f

== Description:== Non-IEEE 383 cable is installed in the ERF and Data Acquisition Computer Systems. Other isolated and limited instances were non-1 EEE-383 cabling has been utilized are described and technically justified in FSAR Section 9.5.1.6.2. Justification: 1. The fire hazard impact is of a minor nature with 10 cable runs totalling 450 feet of cable installed in the Control Room (CR), cable spread room (CSR), and computer room to link the ERF computer. In addition, 3 cable runs totalling 195 feet of cable are installed in the CR/CSR to link the DATA Acquisition System (DAS) Computer.

2. ERF cables are constructed of 6 each 22 gauge conductors insulated with

                     .010 inches of polypropylene and jacketed by .045 inches of PVC.

DAS cables are constructed of 24 each 26 gauge conductors insulated with .014 inches of PVC and jacketed by .035 inches of PVC.

3. The rooms through which Non IEEE 383 cables travel are Control Room (Fire Zone 65) with hand held Halon and water extinguishers, Cable Spreading Room (Fire Zone 64) with fixed automatic Halon System and Fixed Water Suppression System, and Computer Room (Fire Zone 69) with fixed manually actuated Halon System.

4. A low impedence cable is required to meet NRC data transfer rates. No IEEE 383 cable construction providing the impedence values required was available.

5. If cable spread room and control room are affected by a fire, alternate shutdown is achievable from the Alternate Shutdown Panel.

1 OF 1 Revision 28

CPNPP/FPR Deviation 8b

Subject:

20 feet Separation Criteria Location: Bldg. Auxiliary Elev. 852' Room 241 F.A. AA F.Z. 21f Col N-S Systems Path A E-W Systems Path B Reference Drawings: M1-1928, 1929, 1930, Figures FPR-8, 9 and 10 Grinnell Drawings 101, 103, 106, 150 2323-E 1-0703 2323-E 1-071 0-12 2323-E 1-0711-11 2323-E 1-0702 2323-A 1-0509 2323-A 1-0510 Deviation: Appendix R of 10CFR50 Section III.G.2.b.

== Description:== Redundant motor control centers for the UPS ventilation system are located in the same fire area, AA21f, on the 852' elevation in the Auxiliary Building. This deviation is applicable to both Unit 1 and 2. Separation of the Train A MCCs from Train B redundant MCCs and raceways on elevation 852 ft. and from the remainder of the hazards associated within Fire Area AA is achieved by the elimination of intervening combustibles and the protection of redundant raceways. The intervening combustibles are comprised of exposed IEEE 383 cables transversing the corridor on elevation 852ft. The only contributing fire propagation paths are openings provided as equipment hatches and tornado vents. Justification: 1. Suppression is installed in the corridors below the MCC's at 81 0' elevation and 832' elevation as well as above the MCC's in the 852' elevation.

2. Redundant essential raceways in the areas requiring separation meet the necessary requirements stated in FOR Ill 4.3.

3. The intervening combustibles between the redundant MCC's are composed primarily of cable trays containing non-essential cables and raceways containing essential cables that are protected with fire barrier materials, which have been conservatively considered as a combustible material that could provide a flame propagation path. The north and south 1 OF 2 Revision 28

CPNPP/FPR Deviation 8b boundaries separating Train A and B components are special separation areas called "buffer zone". These are 20 feet wide areas with no intervening combustibles with the exception of the two noted above running north-south. Cable trays which contain non-essential cables and transverse the north and south boundaries of the buffer zones are fire stopped to prevent potential fire propagation paths across the buffer zones. Raceways containing essential cables are protected with fire barrier materials up to the boundary of their respective buffer zone with one exception. One protected cable tray extends through the north buffer zone and through the north boundary of the south buffer zone at which point the cable tray terminates and the essential cables transition to two 4 inch conduits and one 12 inch wide tray. These commodities which are also protected with fire barrier materials then extend south out of the buffer zone. Fire propagation along the fire barrier material installed on the associated cable trays and conduits which transverse both buffer zones is not credible because testing has shown that, while the material does contribute added heat in the presence of a sufficient external heat source causing it to ignite, the material will not sustain combustion in the absence of this heat source. There is lack of other combustibles to fuel such a fire and there is area wide suppression and detection coverage provided.

4. The combustibles at lower elevations do not present a significant hazard to the MCC's above these cables because rising hot gases will be cooled by the volume of air available and automatic sprinkler suppression is installed at all three elevations. In addition, fire dampers are installed in the 852' elevation floor (corridor 241) adjacent to and between the redundant MCCs.

5. The MCC's are protected from water suppression actuation by the sealing of all conduits.

6. Area wide early warning ionization smoke detectors are provided to ensure immediate fire brigade response and quick suppression activities.

7. The elimination of intervening combustibles, that present a hazard to the MCC's and the provision of automatic and manual suppression systems provides an equivalent level of protection to that of the requirements of Appendix R.III.G.2.

2 OF2 Revision 28

CPNPP/FPR Deviation 8c Location: Bldg. Safeguards Elev. 873'-6" Room 108 F.A. SK17b Col N-S Systems Path A E-W Systems Path B Reference Drawings: M1-1924 Deviation: Appendix R of 10CFR50 Section III.G.2.b.

== Description:== The main steam isolation valves 1-HV2333A, 1-HV2334A, 1H-2335A and 1-HV2336A are located in separate compartments on the 873'-6" elevation in Fire Zone 17B which extends up to the 880'-6" elevation in Fire Zone 17C in the Safeguards Building. On the 880'-6" elevation, a common walkway provides access into all four cubicles. The cubicles are separated by part-width concrete barriers which extend out to the open walkway. The MSIV's are separated by a minimum horizontal distance 15ft. via the open walkway around the partial barriers. The MSIV's are equipped with stored energy actuators, held open by hydraulic pressure, and fail closed on loss of hydraulic fluid. Hydraulic pressure is released to close the valves by energizing any one of two redundant solenoid valves associated with each MSIV. The redundant solenoid valves for each MSIV are located within each MSIV's compartment. The solenoid valves within each compartment are separated by a distance of approximately 18". In the event of loss of offsite power, all four MSIV's must be operable; as such, at least one of the two redundant solenoid valves for each MSIV must be operable with offsite power available. (TechSpec and FSAR plant operational limits apply). A fire in this are a does not generate a requirement for these valves to be closed, except for the simultaneous condition of a coincidental loss of offsite power. Justification 1. The MSIV's, all of which must be operable upon loss of offsite power, are separated by a minimum of 15ft. However, the actual fire propagation path is greater than 20ft. The fixed combustible loading is made up of the hydraulic fluid for the MSIV's which yields a one minute fire in the area. All cable except a negligible amount of metal clad cable in the area is routed in conduit.

2. Area wide automatic detection and suppression systems are provided in the area of the MSIV's and solenoid operated valves. Transient combustibles are controlled by designating the area as no storage. This 1 OF 3 Revision 28

CPNPP/FPR Deviation 8c assures that during maintenance, transient combustibles will not be left unattended.

3. Raceways supplying power consists of 4" conduit with individual conduits branching off and supplying the valves (see attached sketch). The solenoids which are located less than 2 ft. apart and the flexible conduits leading up to the solenoids are qualified to withstand conditions more extreme than conditions existing during a postulated one minute ASTM E-119 fire.

4. The only combustibles in the area are FYRQUEL Hydraulic Fluid and Thermo-Lag Fire Barriers. The fluid is contained inside a substantial steel reservoir and steel piping. The probability of FYRQUEL leaking from the system is extremely low and physical damage to the system is very unlikely. The reservoir is at atmospheric pressure. Leakage of fluid from the reservoir should not atomize which further limits the potential for fire in this situation.

Thermo-Lag is used to protect conduits and Juction Boxes in this area. They are installed at the ceiling level or high on the compartment walls in the main steam relief valve area. Thermo-Lag contributes a negligible amount of combustibles to this area, requires a high amount of heat for ignition and is self-extinguishing. These limit its potential for fire in this area.

5. The actuator manifolds and inner cylinder are high pressure systems.

Should fire result due to atomization as a result of leakage under pressure, it would not impact on the ability of the valve to close. Leakage of the high pressure fluid will fail the valve closed, which is the desired position upon loss of offsite power. In addition, a pressure switch installed in the high pressure system should provide indication of low system pressure in the Control Room. This capability would provide early warning in the event of high pressure system leakage.

6. The reservoir is at atmospheric pressure. Leakage of fluid would not atomize, limiting the potential for fire in this situation.

In addition, a level switch is installed in the reservoir. This level switch should provide early warning in the event of loss of hydraulic fluid from the reservoir. 2 OF3 Revision 28

CPNPP/FPR Deviation 8c FIRE AREA

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832' &:Ia' 30F3 Revision 28

CPNPP/FPR Deviation Location: Bldg. Safeguards Elev. 873'-6" Room 108E-H/11 OA-D F.A. 2SK F.Z. 2SK17B Col N-S Systems Path A E-W Systems Path B Reference Drawings: M2-1924, Figure FPR-29 Deviation: Appendix R of 10CFR50 Section III.G.2.b.

== Description:== The main steam isolation valves 2-HV-2333A, 2-HV-2334A, 2-HV-2335A and 2-HV-2336A are located in separate compartments on the 873'-6" elevation in Fire Zone 2SK17B which extends up to the 880'-6" elevation in Fire Zone 2SK17C in the Safeguards Building. On the 880'-6" elevation, a common walkway provides access into all four cubicles. The cubicles are separated by part-width concrete barriers which extend out to the open walkway. The MSIV's are separated by a minimum horizontal distance of 15ft. via the open walkway around the partial barriers. This is equivalent to Unit 1 deviation 8c. The MSIV's are equipped with stored energy actuators, held open by hydraulic pressure, and fail closed on loss of hydraulic fluid. Hydraulic pressure is released to close the valves by energizing any one of two redundant solenoid valves associated with each MSIV. The redundant solenoid valves for each MSIV are located within each MSIV's compartment. The solenoid valves within each compartment are separated by a distance of approximately 18". In the event of loss of offsite power, all four MSIV's must be operable; as such, at least one of the two redundant solenoid valves for each MSIV must be operable with offsite power available. (Tech Spec and FSAR plant operational limits apply). A fire in this area does not generate a requirement for these valves to be closed, except for the simultaneous condition of a coincidental loss of offsite power. Justification: 1. The MSIV's all of which must be operable upon loss of offsite power, are separated by a minimum of 15ft. However, the actual fire propagation path is greater than 20ft. The fixed combustible loading is made up of the hydraulic fluid for the MSIV's which yields a one minute fire in the area. All cable except a negligible amount of metal clad cable in the area is routed in conduit.

2. Area wide automatic detection and suppression systems are provided in the area of the MSIV's and solenoid operated valves. Transient 1 OF 3 Revision 28

CPNPP/FPR Deviation 8c (2) combustibles are controlled by designation as a "No Storage" area. This assures that during maintenance, transient combustibles will not be unattended.

3. Raceways supplying power consists of 4" conduit with individual conduits branching off and supplying the valves (see attached sketch). The solenoids which are located less than 2 ft. apart and the flexible conduits leading up to the solenoids are qualified to withstand conditions more extreme than conditions existing during a postulated one minute ASTM E-119 fire.

4. The only combustible in the area is FYRQUEL Hydraulic Fluid and Thermo-Lag Fire Barriers. The fluid is contained inside a substantial steel reservoir and steel piping. The probability of FYRQUEL leaking from the system is extremely low and physical damage to the system is very unlikely. The reservoir is at atmospheric pressure; leakage of fluid from the reservoir should not atomize which further limits the potential for fire in this situation.

Thermo-Lag is used to protect conduits and Juction Boxes in this area. They are installed at the ceiling level or high on the compartment walls in the main steam relief valve area. Thermo-Lag contributes a negligible amount of combustibles to this area, requires a high amount of heat for ignition and is self-extingushing. These limit its potential for fire in this area.

5. The actuator manifolds and inner cylinder are high pressure systems.

Should fire result due to atomization as a result of leakage under pressure, it would not affect on the ability of the valve to close. Leakage of the high pressure fluid will fail the valve closed, which is the desired position upon loss of offsite power. In addition, a pressure switch installed in the high pressure system should provide indication of low system pressure in the Control Room. This capability would provide early warning in the event of high pressure system leakage.

6. The reservoir is at atmospheric pressure. Leakage of fluid would not atomize, limiting the potential for fire in this situation.

In addition, a level switch is installed in the reservoir. This level switch should provide early warning in the event of loss of hydraulic fluid from the reservoir. 2 OF3 Revision 28

CPNPP/FPR 30F3 Revision 28

CPNPP/FPR Deviation 10

Subject:

Control Room Lighting Location: Bldg. Electrical & Control Elev. 830'-0" Room 135 F.A. EO F.Z. 65 Col N-S Systems Path A E-W Systems Path B Reference Drawings: M1-1929, Figures FPR-9,18 and 33 Deviation: Appendix R to 10CFR50, Section III.J

== Description:== The control room does not contain 8 hour battery pack powered emergency lighting. This deviation is applicable to both Unit 1 and Unit 2. Justification: 1. DC Emergency Lighting in the Control Room is provided by remote 8 hour dedicated batteries located in the Unit 1 and Unit 2 battery room enclosures on the Turbine Building Operating Floor adjacent to the Control Building. Power from the batteries is fed directly into the DC Emergency lighting panels located in the Control Room.

2. The DC Emergency Lighting is normally deenergized and is activated upon the loss of power to the AC Lighting Systems. The remote battery power supply to the Control Room lighting provides lighting availability equivalent to that of 8 hour battery pack lighting except in the case of a Control Room fire where DC Lighting panels may be inoperable. In this case, lighting for the Control Room is necessary for evacuation purposes and for hot shutdown activities performed prior to evacuation. Eight (8) hour battery pack lighting units and battery powered portable hand lights are provided in the Control Room for these purpose.

3. DC Emergency Lighting equivalent to the requirements of Appendix A to BTP APCSB 9.5-1, D.5 and Appendix R, III.J is provided for the Control Room.

1 OF 1 Revision 28

CPNPP/FPR Deviation 14

Subject:

Two Hour Rated Penetration Seals Location: Various Bldg. Various Elev. Various Room Various F.A. Various Col N-S Systems Path A E-W Systems Path B Reference Drawings: Penetration Seal Schedule M1-1900, M1-1901, SHT 3, Detail31 Sisco Fire Test 748-98 dated 5/18/83 Exception: BTP APCSB 9.5-1, Appendix A Section D.1.j

== Description:== Spare conduits were tested in accordance with ANI acceptance criteria and not ASTM E-119. The seals tested performed through a three hour endurance test and hose stream, but the temperature limits of ASTM E-119. were exceeded after two hours into the test. Justification: 1. The spare conduit seal detail performed for two hours within acceptance criteria for temperature rise and also passed the hose stream test.

2. The combustible loading on either side of the penetration seals in safe shutdown related areas is controlled by the maximum permissible fire loading combustible control program.

1 OF 1 Revision 28

CPNPPIFPR Deviation 2015-1 Location: Bldg. Auxiliary I EC Elev. 792'-0" Rooms X-119&X-121 F.A. EC& EH F.Z. EC51 & EH53 Col N-S Systems Path A E-W Systems Path B Reference Drawings: FHA Drawing M1-1927-01A Figure FPR-7 Deviation: Appendix R of 10CFR50 Section III.G.2.

== Description:== Battery chargers at CPNPP are redundant for each of the station battery banks (i.e., there are two battery chargers per train). Plant operational methodology alternates the use of each battery charger to ensure each charger has equal run time. Thus, for specific fire scenarios, it is necessary to ensure that the proper battery charger is aligned in order to support the operation of the connected electrical distribution systems prior to the depletion of the associated station battery. This is accomplished through an OMA that validates either that the proper battery charger is already aligned or, if necessary, manually aligns the proper battery charger. Justification: 1. The proposed change to allow the Operator Manual Action does not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. All Fire Areas I Fire Zones of concern are physically separated by rated fire barriers and the equipment and components discussed herein remain free of fire damage. The Operator Manual Action is to ensure proper alignment of the battery charger, not to effect any repairs on a protected train component.

2. The proposed Operator Manual Actions are feasible. The operator performing the manual action does not have to travel to or through an area subjected to fire in order to perform the action. Additionally, the operator has a four (4) hour window to perform the manual action.

3. The proposed Operator Manual Actions are reliable. Once performed, the battery charger alignment remains intact.

4. All components identified in the fire safe shutdown analysis that require protection or separation remain protected and separated. The proposed Operator Manual Action does not replace any existing cable or raceway fire barriers.

1 OF 2 Revision 30

CPNPP/FPR Deviation 2015-1

5. All defense-in-depth aspects of the CPNPP Fire Protection Program remain intact.

6. Reference Generic Letter 86-10 evaluation EV-CR-2014-000847-1 for the complete analysis and bases for this deviation.

2 OF2 Revision 30

CPNPPIFPR Deviation 2015-1 (2) Location: Bldg. Auxiliary I EC Elev. 792'-0" Rooms X-120 F.A. EH F.Z. EH52 Col N-S ----- Systems Path A E-W Systems Path B Reference Drawings: FHA Drawing M1-1927-01A Figure FPR-7 Deviation: Appendix R of 10CFR50 Section III.G.2.

== Description:== Battery chargers at CPNPP are redundant for each of the station battery banks (i.e., there are two battery chargers per train). Plant operational methodology alternates the use of each battery charger to ensure each charger has equal run time. Thus, for specific fire scenarios, it is necessary to ensure that the proper battery charger is aligned in order to support the operation of the connected electrical distribution systems prior to the depletion of the associated station battery. This is accomplished through an OMA that validates either that the proper battery charger is already aligned or, if necessary, manually aligns the proper battery charger. Justification: 1. The proposed change to allow the Operator Manual Action does not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. All Fire Areas I Fire Zones of concern are physically separated by rated fire barriers and the equipment and components discussed herein remain free of fire damage. The Operator Manual Action is to ensure proper alignment of the battery charger, not to effect any repairs on a protected train component.

2. The proposed Operator Manual Actions are feasible. The operator performing the manual action does not have to travel to or through an area subjected to fire in order to perform the action. Additionally, the operator has a four (4) hour window to perform the manual action.

3. The proposed Operator Manual Actions are reliable. Once performed, the battery charger alignment remains intact.

4. All components identified in the fire safe shutdown analysis that require protection or separation remain protected and separated. The proposed Operator Manual Action does not replace any existing cable or raceway fire barriers.

1 OF 2 Revision 30

CPNPP/FPR Deviation 2015-1 (2)

5. All defense-in-depth aspects of the CPNPP Fire Protection Program remain intact.

6. Reference Generic Letter 86-10 evaluation EV-CR-2014-000847-1 for the complete analysis and bases for this deviation.

2 OF2 Revision 30

CPNPP/FPR Deviation 2015-2 Location: Bldg. Auxiliary Elev. 81 0'-6" Rooms X-203 &X-207 F.A. AA F.Z. AA21B Col N-S ----- Systems Path A E-W Systems Path B Reference Drawings: FHA Drawing M1-1928 Figure FPR-8 Deviation: Appendix R of 10CFR50 Section III.G.2.b.

== Description:== Redundant motor operated valves (MOVs) 1-LCV-01128 and 1-LCV-0112C (Room X-203) and redundant MOVs 1-LCV-0112D and 1-LCV-0112E (Room X-207) are located in the same fire area and are not separated by a fire barrier having a 3-hour rating; are not separated by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards; and neither valve or motor operator are enclosed in a fire barrier having a 1-hour rating. Justification: 1. Automatic sprinkler coverage is provided in both Rooms X-203 and X-207 in accordance with the NFPA 13 code of record (1985), as well as the remaining portions of Fire Zone AA21 b. In Room X-203, directional spray nozzle coverage is provided for both of the vertical cable tray runs, plus a sprinkler head is located in the vicinity of the redundant MOVs. Two (2) sprinkler heads are positioned near 1-LCV-0112E that provide unobstructed floor area coverage. To ensure rapid automatic sprinkler system response capability and effective floor area spray coverage for MOV 1-LCV-0112D, an additional sprinkler head is installed near the entrance to the X-203.

2. Automatic fire detection is provided in Room X-203. Ceiling level ionization detection provides early warning in the event of a fire. An ionization type fire detector is installed at the ceiling level in Room X-203; due to the small floor area, a single fire detector meets the requirements of the NFPA 72E code of record (1978).

Automatic fire detection is provided throughout the Room X-207 and the remaining portions of Fire Zone AA21 b. Ionization type fire detectors are installed at the ceiling level and under large obstructions. The fire 1 OF 2 Revision 30

CPNPP/FPR Deviation 2015-2 detection system meets the requirements of the NFPA 72E code of record (1978).

3. The power and control cables associated with the credited MOVs in Rooms X-203 and X-207 are enclosed in Thermo-lag fire-rated materials up to the component, as applicable. The Thermo-Lag 330 ERFBS configuration is in accordance with a design qualified by Luminant; the continuity, thickness, methods of attachment, raceway support protection, and end use I application of the Thermo-Lag 330 ERFBS is consistent with comparable tested configurations.

4. Manual fire suppression equipment in the form of standpipe and hose and portable fire extinguisher coverage is provided and readily available for use. This equipment is located within the travel path that fire brigade personnel would use to access both Rooms X-203 and X-207.

5. The Fire Loading (Combustible Loading) in Room X-203 is low. There are very few combustibles in this room, with no combustible materials located on the floor. Transient hazards are controlled by MPFL, and Room X-203 is designated as a "No Storage" area, which ensures that transient combustibles will not be left unattended without appropriate compensatory measures.

The Fire Loading (Combustible Loading) in Room X-207 is low. The primary in-situ combustible materials consists of exposed electrical cabling in cable trays, anti-contamination clothing, Thermo-Lag 330 ERFBS materials, and miscellaneous Radiation Protection equipment (e.g., frisker stations, rope, signs, etc.).

6. Room X-203 is separated from the remainder of the plant by reinforced concrete construction having a minimum 1-hour fire resistance rating.

7. Reference Generic Letter 86-1 0 evaluation EV-CR-2014-00084 7-2 for the complete analysis and bases for this deviation.

2 OF2 Revision 30

CPNPP/FPR Deviation 2015-2 (2) Location: Bldg. Auxiliary Elev. 81 0'-6" Rooms X-202 &X-207 F.A. AA F.Z. AA21B Col N-S ----- Systems Path A E-W Systems Path B Reference Drawings: FHA Drawing M1-1928 Figure FPR-8 Deviation: Appendix R of 10CFR50 Section III.G.2.b.

== Description:== Redundant motor operated valves (MOVs) 2-LCV-01128 and 2-LCV-0112C (Room X-202) and redundant MOVs 2-LCV-0112D and 2-LCV-0112E (Room X-207) are located in the same fire area and are not separated by a fire barrier having a 3-hour rating; are not separated by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards; and neither valve or motor operator are enclosed in a fire barrier having a 1-hour rating. Justification: 1. Automatic sprinkler coverage is provided in both Rooms X-202 and X-207 in accordance with the NFPA 13 code of record (1985), as well as the remaining portions of Fire Zone AA21 b. In Room X-202, directional spray nozzle coverage is provided for both of the vertical cable tray runs, plus a sprinkler head is located in the vicinity of the redundant MOVs. In Room X-207 two (2) sprinkler heads are positioned near 2-LCV-0112E that provide unobstructed floor area coverage.

2. Automatic fire detection is provided in Room X-202. Ceiling level ionization detection provides early warning in the event of a fire. An ionization type fire detector is installed at the ceiling level in Room X-202; due to the small floor area, a single fire detector meets the requirements of the NFPA 72E code of record (1978).

Automatic fire detection is provided throughout the Room X-207 and the remaining portions of Fire Zone AA21 b. Ionization type fire detectors are installed at the ceiling level and under large obstructions. The fire detection system meets the requirements of the NFPA 72E code of record (1978). 1 OF 2 Revision 30

CPNPP/FPR Deviation 2015-2 (2)

3. The power and control cables associated with the credited MOVs in Rooms X-202 and X-207 are protected with Thermo-lag fire-rated materials up to the component, as applicable. The Thermo-Lag 330 ERFBS configuration is in accordance with a design qualified by Luminant; the continuity, thickness, methods of attachment, raceway support protection, and end use I application of the Thermo-Lag 330 ERFBS is consistent with comparable tested configurations.

4. Manual fire suppression equipment in the form of standpipe and hose and portable fire extinguisher coverage is provided and readily available for use. This equipment is located within the travel path that fire brigade personnel would use to access both Rooms X-202 and X-207.

5. The Fire Loading (Combustible Loading) in Room X-202 is low. There are very few combustibles in this room, with no combustible materials located on the floor. Transient hazards are controlled by MPFL, and Room X-202 is designated as a "No Storage" area, which ensures that transient combustibles will not be left unattended without appropriate compensatory measures.

The Fire Loading (Combustible Loading) in Room X-207 is low. The primary in-situ combustible materials consists of exposed electrical cabling in cable trays, anti-contamination clothing, Thermo-Lag 330 ERFBS materials, and miscellaneous Radiation Protection equipment (e.g., frisker stations, rope, signs, etc.).

6. Room X-202 is separated from the remainder of the plant by reinforced concrete construction having a minimum 1-hour fire resistance rating.

7. Reference Generic Letter 86-1 0 evaluation EV-CR-2014-00084 7-2 for the complete analysis and bases for this deviation.

2 OF2 Revision 30

CPNPPIFPR Deviation 2015-3 Location: Bldg. Various Elev. Various Rooms Various F.A. Various F.Z. Various Col N-S Systems Path A E-W Systems Path B Reference Drawings: EV-C R-2014-00084 7-4 Deviation: Appendix R of 10CFR50 Section III.G.2.

== Description:== CPNPP utilizes a shorting switch design for mitigating certain fire-induced circuit failures. This deviates from the NRC approved mitigation methods in Appendix R, III.G.2. The electrical viability and fire protection acceptability is provided in evaluation EV-CR-2014-000847-4 and is based on CPNPP design modification bases and information presented by the Nuclear Energy Institute (NEI) to NRC as a proposed Appendix I to NEI 00-01 for shorting switch design and application. The components protected by the shorting switch application are: Group 4 OMAs: 1(2)-8351A- Seal Injection Line Isolation Valve 1(2)-8351 B- Seal Injection Line Isolation Valve 1(2)-8351 C- Seal Injection Line Isolation Valve 1(2)-8351 D- Seal Injection Line Isolation Valve Group 8 OMAs: 1(2)-HV-2491 B- Auxiliary Feedwater I Steam Generator Isolation Valve 1(2)-HV-24928- Auxiliary Feedwater I Steam Generator Isolation Valve Group 10 OMAs: 1(2)-HV-8220- Centrifugal Charging Pump Suction Line Vent Valve Group 8 MSOs: 1(2)-8154- Excess Letdown Line Isolation Valve Group 32 MSOs: 1(2)-HV-4395- Station Service Water I Auxiliary Feedwater Crosstie Isolation Valves 1(2)-HV-4396- Station Service Water I Auxiliary Feedwater Crosstie Isolation Valves 1 OF 2 Revision 30

CPNPP/FPR Deviation 2015-3 Justification: 1. Both NRC and NEI provide a definition for the phrase "free offire damage." Both of these definitions provide for the flexibility to evaluate the required post-fire safe shutdown function. In those cases where a shorting switch would be employed to prevent a spurious change of state of an sse, the required fire safe shutdown function of the sse would be to not change state (not energize the relay, solenoid valve, or contactor). The objective of having the sse be "free of fire damage" is achieved by preventing spurious operation. In the case of the shorting switch, this is accomplished through modification and/or analysis in which the circuit is redesigned so that it is not susceptible to spurious operation.

2. The application of the shorting switch does not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

3. Reference EV-CR-2014-000847-4 for the complete discussion of the shorting switch design and application.

2 OF2 Revision 30

CPNPP/FPR Technical Justification: I

Subject:

Radiant Energy Shields Location: Bldg. Containment Elev. Various Room 154, 155A F.A. CA F.Z. 101b, 101d Reference Documents:

1. Specification 2323-MS-38H

2. Procedure CMP-CV-1005

3. Engineering Report ER-ME-128

4. Drawing Series M 1/M2-1702

5. C.N.-ASC0-6-1-1982 (CTP-1026; Fire Qualification Test of HEMYC Cable Wrap System- One Hour; June 1, 1982; Central Nuclear de ASCO, Tarragona, Spain)

Deviation: Appendix R to 10CFR50, Section III.G.2.f

== Description:== Radiant energy shields installed at CPNPP are comprised of the HEMYC system, as manufactured by PCI/Promatec, Inc., and marinite board. HEMYC is an insulating blanket design, constructed of nominal 1-1/2" thick alumina silica refactory wool blanket encapsulated by Siltemp 84 cloth (fire exposure side) and Klevers 600/6 cloth (raceway side) and stitched together using Astroquartz sewing thread (Siltemp and Klevers cloths are no longer available; current HEMYC composition may utilize other flexible refractory silica fabrics such as Refrasil or Alpha-Sil 600 as the outer fabric). The HEMYC blanket is directly wrapped around and banded to the components being protected. Typical installation details were derived from vendor supplied documents. The single application of marinate board is placed flush over an embedded junction box. A fire endurance rating has not been established for the HEMYC system. Of the test data available, vendor supplied testing does not meet the requirements of Generic Letter 86-10, Supplement 1 or ASTM E-119, and the HEMYC configurations in the NRC sponsored fire tests did not successfully achieve the 1-hour objective. However, through fire hazard analysis evaluation along with the data from the NRC sponsored fire tests, it is demonstrated that 1-1/2" thick HEMYC system is qualified as a radiant energy shield. Installed as a direct wrap on electrical cables, raceways, and components, the HEMYC system provides an appropriate level of fire safety protection against the effects of radiant energy from an exposure fire. The installed HEMYC system at CPNPP satisfies the requirements of Appendix R to 10CFR50 Section III.G.2.f for areas inside the Containment Building (Reference 3). 1 OF 1 Revision 28

CPNPP/FPR APPENDIX D CPNPP FIRE PROTECTION PROGRAM FPR FIGURES

CPNPP/FPR TABLE OF CONTENTS FPR NO. REV DESCRIPTION FPR-1 2 Containment/Safeguards Building, Unit 1, Plans at EL. 773'-0" and 790'-6" FPR-2 2 Containment/Safeguards Building, Unit 1, Plans at EL. 808'-0" and 81 0'-6" FPR-3 2 Containment/Safeguards Building, Unit 1, Plans at EL. 831 '-6" and 832'-6" FPR-4 2 Containment/Safeguards Building, Unit 1, Plans at EL. 852'-6" and 860'-0" FPR-5 2 Containment/Safeguards Building, Unit 1, Plans at EL. 873'-6" and 880'-6" FPR-6 2 Containment/Safeguards Building, Unit 1, Plans at EL. 896'-4" and 905'-9" FPR-7 3 Auxiliary/Electrical Control Building, Common, Plans at EL. 778'-0" and 790'-6" FPR-8 2 Auxiliary/Electrical Control Building, Common, Plans at EL. 807'-0" and 810'-6" FPR-9 2 Auxiliary/Electrical Control Building, Common, Plans at EL. 830'-0" and 831 '-6" FPR-10 2 Auxiliary/Electrical Control Building, Common, Plans at EL. 852'-6" and 854'-4" FPR-11 2 Auxiliary/Electrical Control Building, Common, Plans at EL. 873'-6" and 886'-6" FPR-12 2 Auxiliary/Electrical Control Building, Common, Plan at EL. 840'-6" FPR-13 2 Fuel Handling Building, Common, Plan at EL. 810'-6" FPR-14 2 Fuel Handling Building, Common, Plans at EL. 838'-9" and 841 '-0" FPR-15 2 Fuel Handling Building, Common, Plans at EL. 860'-0" and 899'-6" FPR-16 2 Turbine Building, Unit 1, Plan at EL. 778'-0" FPR-17 2 Turbine Building, Unit 1, Plans at EL. 803'-0" and 81 0'-6" FPR-18 2 Turbine Building, Unit 1, Plan at EL. 830'-0" FPR-19 3 Turbine Building, Unit 1, Plans at EL. 81 0'-6" and 833'-1 0" FPR-20 2 Turbine Building, Unit 1, Plans at EL. 803'-0" and 81 0'-6" FPR-21 2 Turbine Building, Unit 1, Plans at EL. 755'-4" and 758'-3" FPR-22 2 Turbine Building, Unit 1, Plan at EL. 81 0'-6" FPR-23 2 Turbine Building, Unit 1, Plan at EL. 821 '-8" FPR-24 2 Service Water Intake Structure Building, FP Pump House, Common FPR-25 Sh. 1 1 Containment/Safeguards Building, Unit 2, Plans at EL. 773'-0" and 790'-6" FPR-25 Sh. 2 1 Containment/Safeguards Building, Unit 2, Plans at EL. 773'-0" and 790'-6" FPR-26 Sh. 1 2 Containment/Safeguards Building, Unit 2, Plans at EL. 808'-0" and 81 0'-6" FPR-26 Sh. 2 2 Containment/Safeguards Building, Unit 2, Plans at EL. 808'-0" and 81 0'-6" FPR-27 Sh. 1 1 Containment/Safeguards Building, Unit 2, Plans at EL. 831 '-6" and 832'-6" FPR-27 Sh. 2 1 Containment/Safeguards Building, Unit 2, Plans at EL. 831 '-6" and 832'-6" FPR-28 1 Containment/Safeguards Building, Unit 2, Plans at EL. 852'-6" and 860'-0" FPR-29 Sh. 1 1 Containment/Safeguards Building, Unit 2, Plans at EL. 873'-6" and 880'-6" FPR-29 Sh. 2 1 Containment/Safeguards Building, Unit 2, Plans at EL. 873'-6" and 880'-6" FPR-30 Sh. 1 1 Containment/Safeguards Building, Unit 2, Plans at EL. 896'-4" and 905'-9" FPR-30 Sh. 2 1 Containment/Safeguards Building, Unit 2, Plans at EL. 896'-4" and 905'-9" FPR-31 1 Turbine Building, Unit 2, Plan at EL. 778'-0" FPR-32 1 Turbine Building, Unit 2, Plans at EL. 803'-0 and 81 0'-6" FPR-33 1 Turbine Building, Unit 2, Plan at EL. 830'-0" FPR-34 Sh. 1 2 Turbine Building, Unit 2, Plans at EL. 81 0'-6" and 833'-1 0" FPR-34 Sh. 2 1 Turbine Building, Unit 2, Plans at EL. 81 0'-6" and 833'-1 0" FPR-35 1 Turbine Building, Unit 2, Plans at EL. 755'-4" and 758'-3" VD-1 Revision 30

Fire Protection Report- Description of Changes Revision 25 LDCR-FP-2006-001 (CPSES-200600208) (JCH): These editorial changes are administrative and contain no technical changes. The electronic files have been converted from Microsoft Word to Adobe Framemaker and published in Adobe Portable Document Format (PDF). The type of changes include changes such as

      -Correction of spelling errors
      -Correction of inadvertent word processing errors from previous changes
      -Style guide changes (e.g., changing from a numbered bullet list to an alphabetized bullet list and vice versa, change numbering of footnote naming scheme)

The entire Fire Protection Report will be reissued as Revision 25. For the text and tables there will be no change bars in the page margins for editorial changes. The list of effective pages is being replaced with a list of effective section, tables, and figures. The NRC Staff guidance applicable to the CPSES Fire Protection Program is primarily provided by BTP APCSB 9.5-1 Appendix A The proposed changes to the Fire Protection Report, do not affect the installation, operation, or maintenance of plant fire protection features. The proposed changes do not change the method of operation or control of safe shutdown functions or safe shutdown related fire protection equipment, nor do the changes alter the plant's defense-in-depth approach to fire protection. This being the case, these changes to the Fire Protection Report do not affect the plant's compliance with BTP APCSB 9.5-1, Appendix A Based on the results of this review, the proposed changes to the CPSES Fire Protection Report (FPR) are acceptable and a Fire Hazard Analysis (FHA) evaluation, as defined in FSAR Section 9.5.1.2.1, is not required. Sections Revised: All Tables Revised: All (except as noted above) Figures Revised: All (except as noted above) Revision 26 LDCR-FP-2005-004 (EVAL-2005-000197-02) (JCH): Added "and its assemblies such as louvers, glazing, etc.," after "fire door. Under Section II of the FPR, Fire Hazards Analysis Report, there is a discussion on fire doors and their fire ratings. This change clarifies that fire doors includes all parts of the door, including louvers and glazing. A FHA is not required for this change. CPNPP/FP DOC-1 Revision 30

Fire Protection Report- Description of Changes Revision 26 (continued) LDCR-FP-2006-002 (EVAL-2005-003093-02) (JCH): Update Fire Area EM for fire protection features for fire safe shutdown:

      "Redundant components and raceways necessary to satisfy the fire safe shutdown functions are located within Fire Area EN. The redundant components, equipment and raceways cannot be separated using the criteria of Section 11-4.5 Item 2, therefore, CPSES has provided Alternate Shutdown Capability in accordance with Section 11-4.5 Item 3 for a fire in this area.

A total flooding automatic halon suppression system is provided for the area. The halon system is actuated by an area wide smoke detection system. A manual pre-action sprinkler system provides partial coverage to the area as back up to the halon system. In addition, hose stations which are normally dry and controlled outside the fire area and portable fire extinguishers are available within the fire area for use by the fire brigade in manual fire fighting activities." This change clarifies the fire safe shutdown features in Fire Area EM, the Unit 2 Cable Spreading Room, and makes the description consistent with Fire Area EN, the Unit 1 Cable Spreading Room. A Fire Hazards Analysis Evaluation is not required for this change. Revision 27 LDCR-FP-2007-001 (EVAL-2007-000255-01) (JCH): Section 111-5.0, Update to properly reflect FSSA equipment and associated FZ locations: Page 111 Add MCC CP1-EPMCEB-04, 480 VAC Motor Control Center 1EB4-1 to FZ21A. Page 111 Add CP2-EPTRNT-12, 480/120 VAC Transformer T2C3 to FZ54. Page 111 Add CP1-EPTRNT-12 480/120 VAC Transformer T1C3 to FZ57. Page Ill Add CP1-VAHEUH-02, Train B Battery Room 1-2 Unit Heater 1-02 to FZ49. Page Ill Delete CP1-VAHUEH-02 from FZ56 (it is moved to FZ49 above, title as listed in FZ56 is misspelled also) Page 111 Change CP1-EPTRET-03, TransformerT1EB3 to CP1-EPTRET-02, Transformer T1 EB2. Delete 1EB4-1 from FZ18. 1EB4-1 is located in FZ21A as noted above. Page 111 Delete 1-PV-4252 and 1-PV-4253 from FZ104B. Page 111 Change CP1-CTATRW-02 to CP2-CTATRW-01 in Fire Area YARD. CPNPP/FP DOC-2 Revision 30

Fire Protection Report- Description of Changes Revision 27 (continued) LDCR-FP-2007 -001 (EVAL-2007 -000255-01) (JCH) (continued): Justification: The changes to the FSSA equipment list bring the FPR into agreement with the FSSA GENESIS database and reflect the current configuration of the CPNPP Fire Safe Shutdown Analysis. Section 111-6.0, Page 111-67, Update to reflect that Reference (4) has been incorporated into Reference (3) and Reference (3) now applies to both Units. Justification: The change to the Reference section reflects that the CPNPP analysis is now documented in a single calculation that encompasses both Units rather than separate calculations for each Unit. The change is made to simplify maintenance of the analysis going forward. LDCR-FP-2007 -002 (EVAL-2005-001555-03) (JCH): Revised discussion of Radiant Energy Shields in Section II, Paragraph 6.2.2-Fire Rated Barriers. Paragraph 6.2.2, Fire Rated Barriers, describes the composition of the HEMYC fire barrier system. Technical Justification 1 is referenced as a basis for not using one of the HEMYC components. This change revises the description of the HEMYC system to exclude the metal framework component. NRC has deemed the fire endurance qualification test referenced in Technical Justification 1 was inadequate. Consequently, the methodology employed for qualifying HEMYC as radiant energy shielding at CPNPP is now based on NRC sponsored testing and fire hazard analysis. Revised Technical Justification I in FPR Section V, Appendix C. Technical Justification 1 discusses the radiant energy shield materials in use at CPNPP to comply with 10CFR50, Appendix R, Section II.G.2 for areas inside the containment buildings. This Technical Justification provides discussion of the evaluation of vendor supplied testing used to validate the HEMYC design and installation at CPNPP. This change revises several aspects of the Technical Justification:

      - Referenced documents: this change ensures that the correct and current documents are listed.
      - HEMYC blanket composition: this change updates the materials now used by the vendor for the construction of the HEMYC blankets.
      - Radiant energy shield acceptability: this change provides updated information related to the fire endurance capability of HEMYC and the methodology used by CPNPP to justify its use as a radiant energy shield material.

CPNPP/FP DOC-3 Revision 30

Fire Protection Report- Description of Changes Revision 28 LDCR-FP-2008-1 (EV-CR-2008-000254-2) (JCH):

Description:

Revise Section I, Paragraph 1.2.11 (1) and (3) to enhance the definitions of Short Circuit and Hot Short to reflect inter-and intra- cable interactions by adding the following: 1.2.11 (1) Add "or another" in front of the word cable on the second line. 1.2.11 (3) Add "the same or in front of the work another in the second line. Justification: This clarification to the definitions of Short Circuit and Hot Short more clearly reflect the definitions found in industry and regulatory documents. The changes affected by this LDCR are consistent with, and support the current FSSA methodology. There are no new methodologies introduced, or changes to the existing methodologies.

Description:

Revise Section Ill, Paragraph 3.1.2.1 [c] to reflect the FSSA circuit analysis process for hot shorts by deleting the following words- "located in the same enclosure (e.g., raceways)". Justification: This change clarifies the process followed for analyzing hot shorts. Deleting the words "located in the same enclosure (e.g., raceways)" removes a limiting condition for hot short analysis and reflects intra- and inter- cable hot shorts. The changes affected by this LDCR are consistent with, and support the current FSSA methodology. There are no new methodologies introduced, or changes to the existing methodologies.

Description:

Revise Section Ill, Paragraph 4.3.2.1 item (2) of "As a PRE-FIRE strategy, the following are examples of precluding spurious actuations" by adding "If spurious actuation has already occurred prior to control transfer, the transfer will mitigate the effects either upon transfer or upon restoration of 480 VAC power depending on the component." Justification: The added text provides clarification that, should a spurious actuation occur prior to the transfer of circuits to the Hot Shutdown Panel, those spurious signals will clear either upon transfer, or upon restoration of 480 VAC, depending on the affected component. The changes affected by this LDCR are consistent with, and support the current FSSA methodology. There are no new methodologies introduced, or changes to the existing methodologies.

Description:

Revise Section II, Paragraph 5.0, FSSA Equipment List, to correct error in equipment description. See EV-CR-2008-000254-002 for the changes. Affects the following pages: 111-25, 30, 35, 36, 38, 40, 43, 44, 46, 48, 49, 55, 57, 58, 61, 62, 63, 64, 65, and 66. CPNPP/FP DOC-4 Revision 30

Fire Protection Report- Description of Changes Revision 28 (continued) LDCR-FP-2008-1 (EV-CR-2008-000254-2) (continued) (JCH): Justification: The changes to the FSSA equipment list in Section Ill, Paragraph 5.0, are typographical corrections. There are no additions or deletions of equipment or components credited for safe shutdown. LDCR-FP-201 0-1 (EV-CR-2005-001539-01-4) (JCH):

Description:

Section 5.8.1.5 Yard Area Fire Load Classification, Page 11-98 Add the Fire Zone YC232 to include the Chemical Feed Building into the Yard Area. Update drawing FPR-32 to show the fire zone YC232. Justification: The Yard is the exterior area within fifty feet of Unit 1, Unit 2 and Common Buildings containing fire safe shutdown equipment. The Chemical Feed Building is approximately 15ft west of the Turbine Building. The Turbine Building contains fire safe shutdown equipment per Section 111-5.0 of the Fire Protection Report revision 27. Therefore meets the requirement to be included in the Yard Area.

Description:

FPR-32, Unit 2 Turbine Building Add Chemical Feed Building, YC232 Justification: The Yard is the exterior area within fifty feet of Unit 1, Unit 2 and Common Buildings containing fire safe shutdown equipment. The Chemical Feed Building is approximately 15ft west of the Turbine Building. The Turbine Building contains fire safe shutdown equipment per Section 111-5.0 of the Fire Protection Report revision 27. Therefore meets the requirement to be included in the Yard Area. LDCR-FP-2009-2 (EV-CR-2009-001265-07 (JCH): Description of Change: Added the new RP Building Zone information to section 11-5.8.1, Yard Fire Area CPNPP/FP DOC-5 Revision 30

Fire Protection Report- Description of Changes Revision 28 (continued) LDCR-FP-2009-2 (EV-CR-2009-001265-07) (JCH) (continued): Technical Justification: Similar to the Fire Protection Pump house, the RP Building is considered in the Fire Hazard Analysis as a Yard structure as designed and implemented by SMF-2009-001265 and respective FDAs. The respective FHA drawing M1-1934, Sht. 001 B was created in the RP Building FDA revisions as sketch SK-0050-09-001265-01-01. Accordingly, this new FHA zone 201 RP requires addition to the FPR licensing basis document so it is consistent with the implemented new design and yard structure. Description of Change: Added the new RP Building Zone information to Figure 13 of the FPR. Technical Justification: Similar to the Fire Protection Pump house, the RP Building is considered in the Fire Hazard Analysis as a Yard structure as designed and implemented by SMF-2009-001265 and respective FDAs. The respective FHA drawing M1-1934, Sht. 001 B was created in the RP Building FDA revisions as sketch SK-0050-09-001265 01. Accordingly, this new FHA zone 201 RP requires addition to the FPR licensing basis document so it is consistent with the implemented new design and yard structure and is shown on FPR-13, Fuel Handling Building. LDCR-FP-201 0-4 (EV-CR-201 0-011385-1) (JCH):

Description:

Change Comanche Peak Steam Electric Station and CPSES to Comanche Peak Nuclear Power Plant and CPNPP throughout the FPR. Justification: This is an administrative change only. Amendment 150 to the OLand TS changed CPSES to CPNPP. LDCR-FP-201 0-3 (EV-CR-201 0-006565-1 (JCH): Section V, Appendix C, Deviation 1b

Description:

Page 2 of 3, Add the following sentence to the end of the first bullet, "Raceways essential for equipment operation have been coated to within 3 feet of the equipment with a one hour rated barrier system." CPNPP/FP DOC-6 Revision 30

Fire Protection Report- Description of Changes Revision 28 (continued) LDCR-FP-201 0-3 (EV-CR-201 0-006565-1) (JCH) (continued): Justification: Deviation 1b in Section V Appendix C of the Fire Protection Report had a sentence inadvertently deleted when LDCR FP-97-009 was incorporated into Revision 13 of the Fire Protection Report on March 2, 1998. The following sentence was deleted from item 4 of Deviation b: "Raceways essential for equipment operation have been coated to within 3 feet of the equipment with a one hour rated barrier system." Discussions with the originator confirmed that there was no intention to delete this sentence from the deviation. This sentence is still applicable for the Unit 1 Safety Chillers. LDCR-FP-2009-1 (EV-CR-2009-000513-3) (JCH):

Description:

Change Fire Area 2SK from "Diesel Day Tank Room" to "Main Steam and Feedwater Penetration Area". Justification: Editorial change to correct description of Fire Area 2SK.

Description:

Figure 28, Unit 2 Containment/Safeguards Building Plans at EL 852'-6" and 860' Does not correctly depict the area boundary (3-hour rated wall) between Fire Area 2SLSK1 00 (Room 2-1 00) and 2SK17a (Room 2-1 OOe). Additionally, the Area Boundary Door (fire door) between these fire areas is not depicted on the figure. Justification: Correct Figure 28 to as-built configuration in the plant. Revision 29 LDCR-FP-2011-3 (EV-CR-2011-001682-00-01) (JCH):

Description:

Correct Table 1, Fire Detection Instrumentation, in Section IV of the FPR to put back information that was inadvertently deleted in Revision 28 on Page 18 of Table 1 (page IV-33) Justification: Editorial change to correct Table 1. LDCR-FP-201 0-2 (EV-CR-2008-000324-00-9) (JCH): Section 5.1.4.4 on page 11-22 Section 5.1.4: Fire Area SO- Electrical Equipment Room/Train A Switchgear Changed "partial" area suppression coverage to "complete" in Section 5.1.4.4 Justification: Design modification FDA-2008-000324-01 has upgraded the suppression system in Room 1-083, Unit 1 Train A Switchgear Section 5.1.5.4 on page 11-24 CPNPP/FP DOC-7 Revision 30

Fire Protection Report- Description of Changes Revision 29 (continued) LDCR-FP-201 0-2 (EV-CR-2008-000324-00-9) (JCH) (continued): Section 5.1.5: Fire Area SE - Remote Safety Related Panels/Train A Switchgear Changed "partial" area suppression coverage to "complete" in Section 5.1.5.4 Justification: Design modifications FDA-2008-000324-02/03 have upgraded the suppression system in Rooms 1-096 and 1-103 Section 6.8.1 NFPA 13 Installation of Sprinkler System on page 11-146 Delete Section 4-3.1.1 for NFPA 13 Installation of Sprinkler System because suppression system in SG1 Room 1-06 no longer requires a code deviation. Justification: Design modification FDA-2008-000324-02 has upgraded the suppression system in Room 1-096. LDCR-FP-2011-1 (EV-CR-2011-001316-1) (JCH): Referenced Section: IV-2.1.b.5.a.2 on Page IV-7 Description of Change: Revise Section IV-2.1.b.5.a.2 of the FPR to reflect the 24 month visual inspection interval for fire rated dampers and associated hardware. The inspection interval is correctly stated in Section IV-2.1.c.1.b .. Technical Justification: ER-ME-1 08, Rev. 1, "Assessment of Fire Protection/Test Measures", made recommendations for changes to inspection frequencies. Specifically, the visual inspection frequency for fire dampers were recommended to be extended from 18 months to 24 months based on guidance in NFPA 90A-1999 (see ER-ME-108, rev. 1, section 4.1 0). The CPNPP FPR Section IV-2.1.c.1.b was revised to reflect this recommendation. However, Section IV-2.1.b.5.a.2 was not revised to reflect the recommended 24 month interval, and still states an 18 month interval. STA-723 was revised to visually inspect all fire dampers on a 24 month interval. This change will correct this oversight. Revision 30 LDCR-FP-2014-1 (EV-CR-2013-01 0091-2) (JCH): Description of Change:

1. Change Section II, Page 11-3, Table of Contents, 5.2.2, to read: FIRE AREA AB CENTRIFUGAL CHARGING PUMP

2. Change Section II, Page 11-47, 5.2.2, to read: FIRE AREA AB- CENTRIFUGAL CHARGING PUMP CPNPP/FP DOC-8 Revision 30

Fire Protection Report- Description of Changes Revision 30 (continued) LDCR-FP-2014-1 (EV-CR-2013-01 0091-2) (JCH) (continued): Technical Justification: PURPOSE CR-2013-01 0091 was written to identify discrepancies related to the description for Fire Area AB in Section II of the CPNPP Fire Protection Report (FPR). Specifically, on Pages 11-3 and 11-47, the description for 5.2.2 Fire Area AB states CCW Pump. 5.2.3 Fire Area AC states Centrifugal Charging Pump; 5.2.5 Fire Area AE and 5.2.6 Fire Area AF both state CCW Pump. LDCR-FP-2014-2 (EV-CR-2013-008361-1) (JCH): Description of Change: Update the Table of Contents for the correct revision of the FPR Figures in Appendix D, CPNPP Fire Protection Program FPR Figures. Technical Justification: This change is strictly to correct a typographical description error on page VD-1, Table of Contents. This change does not add, revise or delete any technical information. LDCR-FP-2015-1 (EV-CR-2014-01 0354-1) (JCH): Description of Change: This OMA on the protected train, as it relates to the proper alignment of the station Battery Chargers to supply the battery backed DC and AC power systems, is a deviation from the requirements of 10CFR50, Appendix R, Section III.G.2.

1. Add NEW Deviation 2015-001 (Unit 1) to Section V, Appendix C.

2. Add NEW Deviation 2015-001 (2) (Unit 2) to Section V, Appendix C.

Technical Justification: The complete Technical Justification for new deviations 2015-001 and 2015-001(2) is provided in evaluation EV-CR-2014-000847-1. PURPOSE: Battery chargers at CPNPP are redundant for each of the station battery banks (i.e., there are two battery chargers per train). Plant operational methodology alternates the use of each battery charger to ensure each charger has equal run time. Thus, for specific fire scenarios, it is necessary to ensure that the proper battery charger is aligned in order to support the operation of the connected electrical distribution systems prior to the depletion of the associated station battery. This is accomplished through an OMA that validates either that the proper battery charger is already aligned or, if necessary, manually aligns the proper battery charger. This OMA on the protected train, as it relates to the proper alignment of the station Battery Chargers to supply the battery backed DC and AC power systems, is a deviation from the requirements of 10CFR50, Appendix R, Section III.G.2. CPNPP/FP DOC-9 Revision 30

Fire Protection Report- Description of Changes Revision 30 (continued) LDCR-FP-2015-2 (EV-CR-2014-01 0354-2) (JCH): DESCRIPTION: Evaluation EV-CR-2014-000847-2 documents a deviation from the requirements of 10CFR50, Appendix R, Section Ill. G.2 for lack of separation between two (2) sets of redundant MOVs, MOVs 1(2)-LCV-01128/C and MOVs 1(2)-LCV-0112D/E at CPNPP.

1. Add NEW Deviation 2015-2 (Unit 1) to Section V, Appendix C.

2. Add NEW Deviation 2015-2(2) (Unit 2) to Section V, Appendix C.

JUSTIFICATION: These MOVs are located in areas of the plant with low in-situ hazards, detection capability, suppression capability, and proper protection of the cables associated with this deviation. The proposed change to allow the physical design of MOVs 1(2)-LCV-01128/C/D/E does not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. The fire protection features, along with the limited quantity and type of combustibles near the MOVs, provide adequate confidence that these FSSA components will remain free of fire damage and function as designed. LDCR-FP-2015-3 (EV-CR-2014-01 0354-3) (JCH): Description of Change:

1. Add NEW Deviation 2015-3 to Section V, Appendix C, Table of Contents.

2. Add NEW Deviation 2015-3 Page(s) to Section V, Appendix C.

Technical Justification: The complete Technical Justification for new deviation 2015-3 is provided in evaluation EV-CR-2014-000847-4. Below is a brief synopsis of EV-CR-2014-000847-4: PURPOSE: The MSO Resolution Process has identified a number of scenarios where the prevention of spurious operation is either the only available option, or the most appropriate option. This is due to the challenges that exist with many of the more traditionally used approaches for resolving fire safe shutdown separation issues. The overall purpose of this evaluation is to document that CPNPP utilizes a shorting switch design for mitigating certain fire-induced circuit failures. This deviates from the NRC approved mitigation methods in Appendix R, III.G.2. This evaluation will determine if the shorting switch design, used in lieu of NRC approved methods, adversely affects the ability to achieve and maintain safe shutdown; and determine if the shorting switch design, which is a deviation (change) to the approved fire protection program, can be implemented without prior NRC approval. CPNPP/FP DOC-10 Revision 30

Fire Protection Report- Description of Changes Revision 30 (continued) LDCR-FP-2015-3 (EV-CR-2014-01 0354-3) (JCH) (continued): CPNPP is implementing design modifications to perform circuit changes in the form of shorting switches for OMA Groups 4, 8, and 10, and for MSO Groups 8 and 32. The use of shorting switches is a deviation from the requirements of 10CFR50, Appendix R, Section III.G.2 [Note: the design is based on a justification that a specific open circuit failure is "incredible," based on industry testing, the physical configuration of CPNPP, and the location of the specific cables.]. LDCR-FP-2015-4 (EV-CR-2014-01 0354-22) (JCH): Description of Change:

1. Add the following NEW text to the end of the existing text in Definition 1.2.30, "High/

Low Pressure Interface Components", in FPR Section I, Page 1-10: For CPNPP, the High/Low Pressure Interface components are residual heat removal (RHR) suction valves, pressurizer power-operated relief valves, and excess letdown isolation valves.

2. Add the following NEW text to Paragraph 4.2.4, "HIGH/LOW PRESSURE INTERFACE ANALYSIS", in FPR Section Ill, Page 111-17.

For CPNPP, the High/Low pressure interfaces are residual heat removal (RHR) suction valves, pressurizer power-operated relief valves (PORVs), and excess letdown isolation valves. Technical Justification: The complete Technical Justification for this FPR change is provided in evaluations EV-CR-2014-01 0354-5, EV-CR-2014-01 0354-6, and EV-CR-2014-01 0354-7. Below is a brief synopsis these evaluations. PURPOSE: The overall purpose of this evaluation is to document in the CPNPP Fire Protection Report, which valve components are considered High/Low Pressure Interfaces. CPNPP has redefined which valve components are considered High/Low Pressure Interfaces as related to the Fire Safe Shutdown Analysis (Ref. EV- CR-2014-01 0354-5, EV-CR-2014-01 0354-6, and EV-CR-2014-01 0354-7). The re-classification of certain valve components as non-High/Low Pressure Interfaces is considered a change to the NRC approved CPNPP Fire Protection Program. Prior to this change, the specific High/Low Pressure Interface components were identified only in DBD-ME-020, "Fire Safe Shutdown Analysis," based on the NRC specified components in supplement 12 of NUREG-0797 (SSER 12). This evaluation will document the acceptability of the change and determine if this change can be implemented without prior NRC approval. CPNPP/FP DOC-11 Revision 30

Fire Protection Report- Description of Changes Revision 30 (continued) LDCR-FP-2015-7 (EV-CR-2015-003172-5) (JCH): Description of Change: Fix typo. Change year for NFPA 70-1986 to NFPA 70-1987. Technical Justification: NFPA did not publish a 1986 edition of National Electric Code in 1986. The correct edition is 1987. LDCR-FP-2015-9 (EV-CR-2014-01 0354-19) (JCH):

Description:

Section II- 5.2.1 Fire Area AA-Miscellaneous Areas: In section 5.2.1.4, a paragraph is added to describe how redundant MOVs LCV-01128 and 1- LCV-0112C in Room X-203 and redundant MOVs 1-LCV-0112D and 1-LCV-0112E in Room X-207 do not meet separation requirements but do not adversely affect the ability to achieve and maintain safe shutdown. Also in section 5.2.1.4, a paragraph is added to describe how redundant MOVs 2-LCV-01128 and 2-LCV-0112C in Room X-202 and redundant MOVs 2-LCV-0112D and 2-LCV-0112E in Room X-207 do not meet separation requirements but do not adversely affect the ability to achieve and maintain safe shutdown. Justification: For section 5.2.1.4, deviation 2015-2 and 2015-2 (2) describes how the combination of low insitu hazards, automatic detection, enhanced automatic suppression and 1 hour cable protection, will keep the valves free from fire damage and not adversely affect the ability to achieve and maintain safe shutdown, in the event of a fire.

Description:

Section II- 5.3.3 Fire Area EC-8attery Rooms: In section 5.3.3.4, a paragraph is added to describe how it is necessary to ensure that the proper battery charger is aligned in order to support the connected electrical distribution systems prior to the depletion of the associated station battery, by using a feasible and reliable OMA. Justification: For section 5.3.3.4, deviation 2015-1 describes why the OMA is feasible, reliable and does not adversely affect the ability to achieve and maintain safe shutdown, in the event of a fire.

Description:

Section II- 5.3.4 Fire Area EH-8attery Rooms: In section 5.3.4.4, a paragraph is added to describe how it is necessary to ensure that the proper battery charger is aligned in order to support the connected electrical distribution systems prior to the depletion of the associated station battery, by using a feasible and reliable OMA. Justification: For section 5.3.4.4, deviation 2015-1 describes why the OMA is feasible, reliable and does not adversely affect the ability to achieve and maintain safe shutdown, in the event of a fire. CPNPP/FP DOC-12 Revision 30

PLANT

KEY PLAN LEGEND AREA

                                             -BOUNDARY
                                             ~AREA BOUNDARY
                                             ........... AREA BOUNDARY DOOR c:::z::[]  R0 0 M DESIGNATION ISB15I     AREA/ZONE DESIGNATION COMANCHE PEAK           SCALE:      NTS FIRE PROTECTION REPORT       JOB    NO. 0210-063 CONTAINMENT I  SAFEGUARDS BUILDING      FIGURE NO.        REV UNIT 1 PLANS AT EL. 773'-0" AND 790'-6"        FPR-1            2 LUMINANT                SHEET     _1_   OF_1_

FPR010001

PLANT

KEY PLAN LEGEND AREA BOUNDARY AREA

                                             ~       BOUNDARY AREA BOUNDARY DOOR

[2[] ROOM DESIGNATION

                                              ~      AREA/ZONE DESIGNATION COMANCHE PEAK            SCALE: NTS FIRE PROTECTION REPORT       JOB NO. 0210-063 CONTAINMENT I  SAFEGUARDS BUILDING    FIGURE NO.      REV UNIT 1 PLANS AT EL 808'-0" AND 810'-6"       FPR-2          2 LUMINANT                 SHEET _1_   OF_1_

FPR020001

c PLANT KEY PLAN LEGEND AREA

                                             -          BOUNDARY
                                             ~AREA BOUNDARY
                                             ----AREA BOUNDARY DOOR cz::[J   ROOM DESIGNATION
                                               ~        AREA/ZONE DESIGNATION COMANCHE PEAK           SCALE=    NTS FIRE PROTECTION REPORT      JOB    NO. 0210-063 CONTAINMENT I SAFEGUARDS BUILDING     FIGURE NO.        REV UNIT 1 PLANS AT EL. 831'-6" AND 832'-6"         FPR-3           2 LUMINANT                 SHEET _1_     OF_1_

FPR030001

c PLANT KEY PLAN LEGEND AREA BOUNDARY AREA

                                             ~       BOUNDARY AREA BOUNDARY DOOR

[2[] ROOM DESIGNATION

                                              ~      AREA/ZONE DESIGNATION COMANCHE PEAK            SCALE:  NTS FIRE PROTECTION REPORT       JOB  NO. 0210-063 CONTAINMENT I  SAFEGUARDS BUILDING    FIGURE NO.      REV UNIT 1 PLANS AT EL. 852'-6" AND 860'-0"      FPR-4          2 LUMINANT                SHEET _1_    OF_1_

FPR040001

c PLANT KEY PLAN LEGEND AREA BOUNDARY AREA

                                             ~       BOUNDARY AREA BOUNDARY DOOR

[2[] ROOM DESIGNATION

                                              ~      AREA/ZONE DESIGNATION COMANCHE PEAK            SCALE: NTS FIRE PROTECTION REPORT       JOB  NO. 0210-063 CONTAINMENT I  SAFEGUARDS BUILDING    FIGURE NO.      REV UNIT 1 PLANS AT EL. 87.3'-6" AND 880'-6"     FPR-5          2 LUMINANT                 SHEET _1_   OF_1_

FPR050001

PLANT

KEY PLAN LEGEND AREA BOUNDARY AREA BOUNDARY AREA BOUNDARY DOOR C1:[J ROOM DESIGNATION

                                              ~      AREA/ZONE DESIGNATION COMANCHE PEAK           SCALE:   NTS FIRE PROTECTION REPORT      JOB NO. 0210-063 CONTAINMENT I SAFEGUARDS BUILDING     FIGURE NO.      REV UNIT 1 PLANS AT EL. 896'-4" AND 905'-9"      FPR-6          2 LUMINANT                SHEET _1_   OF_1_

FPR060001

PLANT KEY PLAN LEGEND AREA

                                                   -BOUNDARY AREA
                                                   ~        BOUNDARY AREA BOUNDARY DOOR
                                                   -----    AREA BOUNDARY DOOR ABANDONED IN PLACE AND HARDENED

[1[] ROOM DESIGNATION ISB15I AREA/ZONE DESIGNATION COMANCHE PEAK SCALE: NTS FIRE PROTECTION REPORT JOB NO. 0210-063 AUXILIARY I ELECTRICAL CONTROL BUILDING FIGURE NO. REV COMMON PLANS AT EL. 778'-0" AND 790'-6" FPR-7 3 LUMINANT SHEET _1_ OF_1_ FPR070001

c PLANT KEY PLAN LEGEND AREA

                                                  -BOUNDARY AREA BOUNDARY
                                                  ----AREA BOUNDARY DOOR c:z:[J  ROOM DESIGNATION
                                                   ~       AREA/ZONE DESIGNATION COMANCHE PEAK             SCALE:   NTS FIRE PROTECTION REPORT        JOB NO. 0210-063 AUXILIARY I ELECTRICAL CONTROL BUILDING     FIGURE NO.      REV COMMON PLANS AT EL. 807'-0" AND 810'-6"         FPR-8          2 LUMINANT                 SHEET _1_     OF_1_

FPR080001

c PLANT KEY PLAN LEGEND AREA

                                                   -           BOUNDARY AREA BOUNDARY
                                                   ----AREA BOUNDARY DOOR c::z::[]  R0 0 M DESIGNATION SB15I     AREA/ZONE DESIGNATION COMANCHE PEAK             SCALE:      NTS FIRE PROTECTION REPORT         JOB NO.      0210-063 AUXILIARY I  ELECTRICAL CONTROL BUILDING      FIGURE NO.        REV COMMON PLANS AT EL. 830'-0" AND 831'-6"           FPR-9            2 LUMINANT                  SHEET _1_       OF_1_

FPR090001

c PLANT KEY PLAN LEGEND AREA BOUNDARY AREA

                                                   ~        BOUNDARY
                                                   -----    AREA BOUNDARY DOOR

[2[] ROOM DESIGNATION ISB15I AREA/ZONE DESIGNATION COMANCHE PEAK SCALE: NTS FIRE PROTECTION REPORT JOB NO. 0210-063 AUXILIARY I ELECTRICAL CONTROL BUILDING FIGURE NO. REV COMMON PLANS AT EL. 852'-6" AND 854'-4" FPR-10 2 LUMINANT SHEET _1_ OF_1_ FPR100001

c PLANT

~~

I I I I KEY PLAN e--_j I I I FOR CONT. SEE FPR-15 8------ MECHANICAL EQUIPMENT ROOM 12441 M39l LEGEND

         ~-~~~~~~~~~~~~~                                                                                                                                                   AREA BOUNDARY 8----                                                                                                                                                             AREA
                                                                                                                                                                   ~
                                                                                                   ~~                                                 ~~
               ----+l*                                                                                                                                                     BOUNDARY AREA I I                                                       I 8----

BOUNDARY MECHANICAL EQUIPMENT ROOM DOOR e--_j

               ----+l*

[}[] I ROOM I DESIGNATION

         ~---~

8------ MECHANICAL EQUIPMENT ROOM

                                                                                                                                                                    ~      AREA/ZONE DESIGNATION pLAN AT EL. 8 7 3   I - 6 II
                      ~~                                            ~~

PARTIAL PLAN AT EL. 886'-6" I I I I e---1 I I I DDDDD~DDDDD DDDD§ODDD COMANCHE PEAK SCALE: NTS FIRE PROTECTION REPORT JOB NO. 0210-063 NOTES: AUXILIARY I ELECTRICAL CONTROL BUILDING FIGURE NO. REV PARTIAL PLAN AT EL. 842'-0" COMMON AA99a - EQUIPMENT HATCH PLANS AT EL. 873'-6" AND 886'-6" FPR-11 2 LUMINANT SHEET _1_ OF_1_ FPR110001

c PLANT KEY PLAN LEGEND AREA BOUNDARY AREA

                                                                                                          ~        BOUNDARY
                                                                                                          -----   AREA BOUNDARY DOOR

[1[] ROOM DESIGNATION

                                                                                                           ~       AREA/ZONE DESIGNATION
                                                                                       ----8

____,__ STAIRWELL

                                                                                        ----8 NOTES:

PLAN AT EL. 840'-6" EA75, EA161- VENT. CHASE

                        <OBSERVATION LEVELl COMANCHE PEAK             SCALE: NTS FIRE PROTECTION REPORT         JOB NO. 0210-063 AUXILIARY I  ELECTRICAL CONTROL BUILDING    FIGURE NO. REV COMMON PLAN AT EL. 840'-6"             FPR-12          2 LUMINANT                 SHEET _1_    OF_1_

FPR120001

c PLANT KEY PLAN LEGEND AREA BOUNDARY AREA

                                 ~         BOUNDARY AREA
                                 --------  BOUNDARY DOOR

[2[] ROOM DESIGNATION

                                  ~        AREA/ZONE DESIGNATION COMANCHE PEAK      SCALE:    NTS FIRE PROTECTION REPORT JOB   NO. 0210-063 FUEL HANDLING BUILDING     FIGURE NO.       REV COMMON PLAN AT EL. 810'-6"      FPR-13           2 LUMINANT           SHEET _1_     OF_1_

FPR130001

c PLANT KEY PLAN LEGEND AREA

                                           -        BOUNDARY
                                           ~AREA BOUNDARY
                                           ------ AREA BOUNDARY DOOR c:l[]  ROOM DESIGNATION
                                             ~      AREA/ZONE DESIGNATION COMANCHE PEAK           SCALE:   NTS FIRE PROTECTION REPORT      JOB NO. 0210-063 FUEL HANDLING BUILDING          FIGURE NO.      REV COMMON PLANS AT EL. 838'-9" AND 841'-0"     FPR-14          2 LUMINANT                SHEET _1_   OF_1_

FPR140001

c PLANT KEY PLAN LEGEND

                                           -AREA BOUNDARY AREA
                                           ~       BOUNDARY AREA BOUNDARY DOOR

[2[] ROOM DESIGNATION

                                            ~      AREA/ZONE DESIGNATION COMANCHE PEAK           SCALE: NTS FIRE PROTECTION REPORT      JOB NO. 0210-063 FUEL HANDLING BUILDING         FIGURE NO.      REV COMMON PLANS AT EL. 860'-0" AND 899'-6"    FPR-15          2 LUMINANT                SHEET_1_    OF_1_

FPR150001

PLANT KEY PLAN FINISH FLOOR 8--- EL. 810'-6" TOP OF ( LEGEND CONCRETE J AREA EL. 796'-8"

                                                                                                -          BOUNDARY

[1] ~AREA r l l1TB1071 ~BOUNDARY 8---- l LUBE OIL

                                                                                                ----AREA BOUNDARY DOOR STORAGE TANK c:z::[J  ROOM 8---

DESIGNATION SECTION D-D ISB15I AREA/ZONE (FPR-16) DESIGNATION 8---- 8---- TOP OF OPERATING FLOOR FINISH FLOOR EL. 755'-4" EL. 830'-0" 8---- MEZZANINE LEVEL FINISH FLOOR EL. 803'-0" 8---- SECTION B-B CFPR-17) e--- BASEMENT FLOOR PLAN COMANCHE PEAK SCALE: NTS FIRE PROTECTION REPORT JOB NO. 0210-063 TURBINE BUILDING FIGURE NO. REV UNIT 1 PLAN AT EL. 778'-0" FPR-16 2 LUMINANT SHEET _1_ OF_1_ FPR160001

PLANT 0 KEY PLAN

                  -.----           -y-8-----*

I ["f8166l rr=~~hr~==~~- ~ Il'::::====--=====::!JII u ' I 11 LEGEND

                                                                                                                 ~~OIJIOLJ                                                                                        AREA 8------*                                                                                                            ~§]: ~                                                                   -           BOUNDARY t
                                                                                                                                                                                                      ~AREA BOUNDARY FINISH FLOOR EL. 810'-6-'--#--
                                                                                                                                                                                                      ----AREA 8--- ----~------..----,,

STAIRWELL I~ BOUNDARY

                                    ,+~1~kl                                                                              ~~~--~-4-,..-111r-ri4_3.,..AI*

DOOR f-.- --'jl- c:z::[J ROOM 8-----* DESIGNATION

                                                                                                                                                                                                        ~         AREA/ZONE DESIGNATION 8------*

FINISH FLOOR EL. 803'-0" l 8------* B----* m = ;::== STAIRWELL ill[] l1oAI TB113 ITB1091

                                                                                                                                             ""L           I
         ~---~----------------------------------~~--~--~~                                                   ~

J; l I I I 8 8 G

t_____TRANSFORMER f(C1281 PIT _j L TRANSFORMER PIT COMANCHE PEAK SCALE: NTS FIRE PROTECTION REPORT JOB NO. 0210-063 TURBINE BUILDING FIGURE NO. REV UNIT 1 PLANS AT EL. 803'-0" AND 810'-6" FPR-17 2 LUMINANT SHEET 1 OF 1 FPR170001

PLANT 0 KEY PLAN LEGEND AREA BOUNDARY AREA

                                                         ~       BOUNDARY AREA BOUNDARY DOOR

[2[] ROOM DESIGNATION

                                                          ~      AREA/ZONE DESIGNATION I

G8 I OPERATING FLOOR PLAN COMANCHE PEAK SCALE= NTS FIRE PROTECTION REPORT JOB NO. 0210-063 TURBINE BUILDING FIGURE NO. REV UNIT 1 PLAN AT EL. 830'-0" FPR-18 2 LUMINANT SHEET_1_ OF_1_ fPR180001

PLANT 0 KEY PLAN

                                    ~ I I                                    C?                       LEGEND
                                                                                                      -         AREA BOUNDARY
                                        -------8                                      --8             ----

AREA

                                                                                                      ~         BOUNDARY AREA BOUNDARY DOOR

[TI] ROOM DESIGNATION ISB15I AREA/ZONE DESIGNATION PATRIAL PLAN OF OPERATING FLOOR AT EL. 833'-10" PARTIAL PLAN OF MEZZANINE FLOOR AT EL. 810'-6" COMANCHE PEAK SCALE: NTS FIRE PROTECTION REPORT JOB NO. 0210-063 TURBINE BUILDING FIGURE NO. REV UNIT 1 PLANS AT EL. 810'-6" AND 833'-10" FPR-19 3 LUMINANT SHEET_1_ OF_1_ fsOOOOOu.d n

PLANT 8

                                               --e                                                                   KEY PLAN
                                               --e                                                             -

LEGEND AREA BOUNDARY AREA

                                                                                                               ~        BOUNDARY MATCHLINE A                              AREA BOUNDARY DOOR

[1[] ROOM PARTIAL PLAN AT EL. 810'-6" ~ ~ DESIGNATION

                                                                                  ----8 ISB15I  AREA/ZONE DESIGNATION
                                                                                  ----8 UNIT 2 UNIT 1 FOR CONT.SEE FPR-22

[)) ITB105el PARTIAL PLAN OF MEZZANINE CEL. 803'-0" AND 810'-6") COMANCHE PEAK SCALE: NTS FIRE PROTECTION REPORT JOB NO. 0210-063 TURBINE BUILDING FIGURE NO. REV UNIT 1 PLANS AT EL. 803'-0" AND 810'-6" FPR-20 2 LUMINANT SHEET _1_ OF_1_ FPR200001

PLANT 0 KEY PLAN LEGEND AREA

                                                                                           -          BOUNDARY
                                                                                           ~AREA BOUNDARY
                                                                                           ........ AREA BOUNDARY DOOR c:z::[J  RO 0 M DESIGNATION J

ISB15I AREA/ZONE DESIGNATION [ b ----8 ITJ ( [ ITB105al e-- -tt-L Q {_, I

                                                                        ----8 C-T PARTIAL PLAN AT EL. 755'-4" PLAN AT EL. 758'-3"                              COMANCHE PEAK          SCALE:     NTS FIRE PROTECTION REPORT      JOB NO.      0210-063 TURBINE BUILDING             FIGURE NO.       REV UNIT 1 PLANS AT EL. 755'-4" AND 758'-3"      FPR-21            2 LUMINANT                 SHEET _1_      OF_1_

FPR210001

PLANT 0 KEY PLAN 8---- LEGEND

                        @]                                                                           AREA
                     ~r
                                                                                           -         BOUNDARY AREA
                                                                                           ~         BOUNDARY AREA
                            @]                                                                       BOUNDARY DOOR e--         ~

I43AI [2[] ROOM DESIGNATION ISB15I AREA/ZONE DESIGNATION [J]

                                                             ----8 e--               0§]
                                                             ----8 8-------1-1 I   I
                                 ~

l_V 6

                                      ~  PLAN AT EL. 810'-6" COMANCHE PEAK     SCALE:    NTS FIRE PROTECTION REPORT JOB    NO. 0210-063 TURBINE BUILDING        FIGURE NO. REV UNIT 1 PLAN AT EL. 810'-6"      FPR-22           2 LUMINANT          SHEET _1_     OF_1_

FPR220001

PLANT KEY PLAN

         & ---- F======;!]JI=:::!j"====lb!J~======;!=~===i!:::J~
                                  ~                              -,-

8----- LEGEND

                                                                                             -BOUNDARY AREA
                                                                                             ~AREA BOUNDARY
                                                                                             - - - AREA BOUNDARY DOOR c:l[]   ROOM DESIGNATION
                                                                                              ~       AREA/ZONE UNIT 2                                                                             DESIGNATION o~===-

UNIT 1 e---- o---r I43BI ttB105fl

                                        .r.::;L
                                                   =        _.r=

Jl I I ~ I" I I I 8 I 0 0 I 8 8 COMANCHE PEAK SCALE: NTS PLAN AT EL. 821'-8" FIRE PROTECTION REPORT JOB NO. 0210-063 TURBINE BUILDING FIGURE NO. REV UNIT 1 PLAN AT EL. 821'-8" FPR-23 2 LUMINANT SHEET_1_ OF_1_ FPR230001

PLANT 0 KEY PLAN IWA 1031 I ~~ LEGEND

                                          ~ ~ ~                                                         ;!-(A   t;             [22§]

IWH U4~ AREA BOUNDARY

                            ~                 12751 IWB104~

AREA BOUNDARY r-

                                                                                                                                                        ----AREA BOUNDARY DOOR EL. 796'-0" c:I[J    ROOM DESIGNATION PLAN  AT  EL. 796'-0"                                                                                                 ISB15I   AREA/ZONE PLAN  AT     EL. 810'-6"                                           DESIGNATION f277l I WB104ti---           12751                          12781 WB104tl I~(J" ~

FIN. FLOOR EL. 810'-6" c:u= m I I FIN. FLOOR EL. 796'-0" L..J IWB104d 12761 fWA103 [2tJ IWB104d PLAN AT EL. 755'-0" SECTION K-K CFPR-24) COMANCHE PEAK SCALE: NTS PUMP HOUSE PLAN AT EL 810'-6" FIRE PROTECTION REPORT JOB NO. 0210-063 SERVICE WATER INTAKE STRUCTURE BUILDING FIGURE NO. REV FIRE PROTECTION PUMPHOUSE COMMON FPR-24 2 LUMINANT SHEET _1_ OF_1_ FPR240001

COMANCHE PEAK FIRE PROTECTION REPORT UNIT2 CONT AlNMENT I SAFEGUARDS BUILDING PLANS AT EL 773'-0" AND 790'-6" SH.NO REV. FIGURE FPR-25 1 OF 2 1

COMANCHE PEAK FIRE PROTECTION REPORT UNIT2 CONTAINMENT I SAFEGUARDS BUILDING PLANS AT EL 773'-0" AND 790'-6" FIGURE FPR-25 SH.NO REV. l 20F 2 DSFPR2520.DGN

COMANCHE PEAK FIRE PROTECTION REPORT UNIT2 CONTAINMENT I SAFEGUARDS BUILDING PLANS AT EL 808'-0" AND 810'-6" SH.NO REV FIGURE FPR-26 1 OF 2 2 DSFPR26ll.DGN

COMANCHE PEAK FIRE PROTECTION REPORT UNIT2 CONTAINMENT I SAFEGUARDS BUILDING PLANS AT EL 808'-0" AND 810'-6" SH.NO REV FIGURE FPR-26 20F 2 2 DSFPR2621.DGN

COMANCHE PEAK FIRE PROTECTION REPORT UNIT2 CONTAINMENT I SAFEGUARDS BUILDING PLANS AT EL 831'-6" AND 832'-6" SH.NO REV. FIGURE FPR-27 1 OF 2 1 DSFPR2710.DGN

PARTIAL PLAN AT EL 849'-0" (CONTAINMENT BUILDING ONLY) PARTIAL PLAN AT EL 842'-0" (CONTAINMENT BUILDING ONLY) LEGEND AREA BOUNDRY

                              ~~s) lw ~2~s)
                                                                                                                                  *ll.---~ll*    AREABOUNDRY DOOR ROOM I 2-097 2-o1s I                                                                                             DESIGNATION I

I 2SB2g li 8 AREA/ZONE 2SB1 DESIGNATION I 2-o9s I I 2SB15 0 I 2-099 I SCALE: L;y I 2SI12a I 2SB2h NTS I I Q2SG10a) KEY PLAN PARTIAL PLAN AT EL 841'-6" COMANCHE PEAK (SAFEGUARDS BUILDING ONLY) FIRE PROTECTION REPORT SECTIONE-E UNIT2 (FPR-26, 27) CONTAINMENT I SAFEGUARDS BUILDING PLANS AT EL 831'-6" AND 832'-6" SH.NO REV. FIGURE FPR-27 20F 2 1 DSFPR2720.DGN

COMANCHE PEAK FIRE PROTECTION REPORT UNIT2 CONTAINMENT I SAFEGUARDS BUILDING PLANS AT EL 852' -6" AND 860' -0" SH.NO REV FIGURE FPR-28 1 OF 1 DSFPR2810.DGN

COMANCHE PEAK FIRE PROTECTION REPORT UNIT2 CONTAINMENT I SAFEGUARDS BUILDING PLANS AT EL 873'-6" AND 880'-6" SH.NO REV. FIGURE FPR-29 1 OF 2 1 DSFPR2910.DGN

COMANCHE PEAK FIRE PROTECTION REPORT UNIT2 CONTAINMENT I SAFEGUARDS BUILDING PLANS AT EL 873'-6" AND 880'-6" FIGURE FPR-29 REV I DSFPR2920.DGN

COMANCHE PEAK FIRE PROTECTION REPORT UNIT2 CONTAINMENT I SAFEGUARDS BUILDING PLANS AT EL 896' -4" AND 905' -9" FIGURE FPR-30 REV I DSFPR3010.DGN

COMANCHE PEAK FIRE PROTECTION REPORT UNIT2 CONTAINMENT I SAFEGUARDS BUILDING PLANS AT EL 896' -4" AND 905' -9" FIGURE FPR-30 REV I DSFPR3020.DGN

ELEVATOR TOP OF 47 !

                                                                                       ==+J'?

CONCRETE EL 796'-8" LUB EOIL STORAGE TANK ~

                                                                          ~
                                                                  ~
                                                                         ~

I SECTIONU-U (FPR-31)

                                                             ~            ~                                       -

LEGEND AREABOUNDRY TOP OF OPERATING FLOOR EL 830'-0" ~ AREABOUNDRY AREABOUNDRY DOOR ROOM

                                                                   ~                                               I TQZO   DESIGNATION
                                                                  ~                MEZZANINE LEVEL FINISH FLOOR                             AREA/ZONE EL 803'-0"                       ~       DESIGNATION I  :
                                                                                                                 ~

SECTION T-T (FPR-32) SCALE NTS COMANCHE PEAK FIRE PROTECTION REPORT 8 8 e8 8 BASEMENT FLOOR PLAN 8 8 FIGURE UNIT2 TURBINE BUILDING PLAN AT EL 778' -0" FPR-3I REV I DSFPR3110.DGN

STAIRWELL I2-288B I I TB213 I OPEN AREA 2-035 1-037 FINFLR I 2-032 I 2-043 I EL 810'-6" n 2-034 1-036 I TB111 I n 2

ID D n D n _l~1 CL ______ + ( ,-l--1/TD (r______ I I x:ru TRANSFORMER PIT II J( ll IJ_-- - - - -t- ~-rr--v t I 2-283 I I TB205e I LEGEND FIN FLR EL 803 '-0" AREA BOUNDRY T G ------- - - -

                                                                                           ~
                                      ~~L_f-"+-------_j____[_~~~

v ?===== ~~~ o=o m m **--------1** AREA BOUNDRY DOOR

                                             =                                                =
                      ~p,                                                                                                                                                                    I 2-075 ROOM TRANSFORMER PIT                                                                                         I~     ~       ~        ~       ~
                                                                                                                                                ~            ~=l                                            DESIGNATION AREA/ZONE 11=11]                                                                          I 2SB1 00 D DESIGNATION STAIRWELL I2-285A I

_j J JI J I l Ill L SCALE:

                                                                                                                                                        ~ ~                                 NTS I TB208 I                                                                                                        KEY PLAN
                                                                                                                                                             ,[

CHEMICAL FEED COMANCHE PEAK BUILDING FIRE PROTECTION REPORT I YC232 UNIT2 TURBINE BUILDING PLANS AT EL 803'-0" AND 810'-6" SH.NO REV. FIGURE FPR-32 1 OF 1 1 DSFPR3210.DGN

             §*************************

0

                                        ~TAIRWELL
                                         " I 2-29o I I TB213   I  //

00 00

' \

LEGEND AREA BOUNDRY

                                                                                                                                            **--------1**    AREA BOUNDRY DOOR ROOM 2-o1s DESIGNATION I

AREA/ZONE I 2SB1 DESIGNATION FIN FLR EL 830' -0" I TB205g I STAIRWELL I 2-29o I SCALE: I TB208 I NTS KEY PLAN COMANCHE PEAK C BUILDING FIRE PROTECTION REPORT GRATING UNIT2

                                                               . GRATING           .

(11-T) TURBINE BUILDING

                                                   ~2-v                        ~;-T)                                              PLAN AT EL 830' -0" SH.NO OPERATING FLOOR PLAN                                          FIGURE  FPR-33                  1 OF 1 REV.

1 DSFPR3310.DGN

I 2-042A

                                /------------
                              /
                           /
                        /
                      /
                    /                                                                                                                            LEGEND
                 /
               /
             /
          /                                                                                                                                                     AREA BOUNDRY
         <-,_                                                                                                         2-039
              "- -,                                                                                                                              W///~          AREA BOUNDRY
                " -,                                                                              I 2-267 I

I TBllO I AREA BOUNDRY YC227 D----------0

                              -,-,                                                             //////
                         -,_,    I DOOR
                                   -,-,_                      / T-;T-;-'--;r-TT--T-rr-r-7--"/ SWITCHGEAR ROOM NO 1 FINISH FLOOR EL 810'-6"                                           AREA BOUNDRY
                                        "- -,                                                                                                    D-----*----0   DOOR ABANDONED
                                          " -,                                                                                                                  IN PLACE AND
                                               -,_                                                                                                              HARDENED
                                                    "       /

2-o1s ROOM

"-/

I DESIGNATION AREA/ZONE 2SB1 DESIGNATION

PARTIAL PLAN OF MEZZANINE FLOORATEL 810'-6" SCALE: NTS KEY PLAN COMANCHE PEAK FIRE PROTECTION REPORT UNIT2 TURBINE BUILDING PLANS AT EL 810'-6" AND 833'-10" SH.NO REV. FIGURE FPR-34 1 OF 2 2 DSFPR3410.DGN

TOP OF ROOF SLAB EL 833'-10" LEGEND AREA BOUNDRY

                                                              *ll.---~ll*     AREABOUNDRY DOOR ROOM 2-o1s DESIGNATION I

AREA/ZONE I 2SB1 DESIGNATION PARTIAL PLAN OF OPERATING FLOOR AT EL 833'-10" SCALE: NTS KEY PLAN COMANCHE PEAK FIRE PROTECTION REPORT UNIT2 TURBINE BUILDING PLANS AT EL 810'-6" AND 833'-10" SH.NO REV. FIGURE FPR-34 20F 2 1 DSFPR3420.DGN

PIPE TRENCH

             .......~vH I TB205b I FL EL 758'-3" D

I 2-oo4 I I 2-oo2 I I TB205b I I TB205b I D

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I 2-oor I I ~><I I TB205a I I rrnww 768'-0" LJ LEGEND PLATEEL L AREA BOUNDRY 763'-8"

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AREA BOUNDRY I DOOR D D D D D D ROOM 2-o1s DESIGNATION I AREA/ZONE I 2SB1 DESIGNATION

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PLAN AT EL 758'-3" PARTIAL PLAN AT EL 755'-4" SCALE: NTS KEY PLAN COMANCHE PEAK FIRE PROTECTION REPORT UNIT2 TURBINE BUILDING PLANS AT EL 755'-4" AND 758'-3" SH.NO REV. FIGURE FPR-35 1 OF 1 1 DSFPR3510.DGN}}

ML16180A429

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1.0 INTRODUCTION

1.0 INTRODUCTION

SUMMARY

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8.0 REFERENCES

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6.1 INTRODUCTION

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6.0 REFERENCES

1.0 INTRODUCTION

6.0 REFERENCES

1.0 INTRODUCTION

1.0 INTRODUCTION

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