ML18019A793

Rev 1 to Shearon Harris Nuclear Power Plant Crdr Final Summary Rept.

ML18019A793
Person / Time
Site:	Harris
Issue date:	04/28/1986
From:	CAROLINA POWER & LIGHT CO.
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ML18019A792	List: ML18019A791 ML18019A793
References
NUDOCS 8605020186
Download: ML18019A793 (315)

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ENCLOSURE l Revision 1 to the SHNPP Control Room Design Review Final Summary Report Bb05020i8b 8b0428 PDR ADOCK 05000400 A PDR (3705AWS/ccrc)

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1~3 INTEGRATION OF CRDR WITH OTHER ACTIVITIES Although the CRDR was specifically directed toward evaluating the Control Room (CR) (including the auxiliary shutdown panel), CPSL recognizes the interface between the CRDR and other related activities, such as the design of a Safety Parameter Display System (SPDS), implementation of REG. GUIDE 1.97 requirements, development of Emergency Operating Procedures (EOPs), operator training, and the implementation of Emergency Response Facilities (ERF). The organization of the CRDR considers the coordination of the CRDR with these related efforts. This report reflects the balanced and orderly approach CPaL followed to implement the NUREG-0737 requirements. It is not the intent of this report to describe all the detailed information related to SPDS, REG. GUIDE 1.97, and EOPs development and implementation. This report is limited to the man/machine interface requirements and the integration of these requirements as they affect plant operation.

The Lead Discipline Engineer (LDE) for the CRDR is Mr. Robert Prunty. As the Principal ISC Engineer of the Harris Plant Engineering section he was responsible for the design and engineering of all instrumentation and control systems, which includes the CR, the ACP, SPDS and 1.97 instrumentation. As the LDE for the CRDR he had the overall responsibility for ensuring .

that the review was conducted as planned and scheduled. He participated as the Leader of the HEDAT meetings, and had the ultimate responsibility and approval for any change or fix'hat resulted from HED corrective actions. He was responsible for day-to-day CRDR activities and the reporting of project status and progress to CP&L Management. The Site Project Coordinator (SPC), of the CRDR, under the direction of LDE had the responsibility of the day-to-day processing of each HED and corrective fixes. The Operations personnel on the CRDR and the System Integration Team Leader were the individuals responsible for the development of the EOPs and the development of EOP training packages.

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The integration of REG. GUIDE 1.97, SPDS and the ERF took place in conjunction with the human factors review of the MCB and the subsequent redesign.

These items are discussed below:

a. Safety Parameter Display System SPDS has been and continues to be reviewed with its companion items (EOPs and Control Board modifications) for continuity under the direction of the LDE. (See Section 6.3.3.10 for discussions on the human factors review of the SPDS.)

The SPDS consists of the six critical safety functions as defined by Westinghouse. Each of these critical safety functions is associated with a fault tree, which was developed and coordinated with the EOPs.

The SPDS was developed as a set with the EOPs. It functions as a companion to the EOPs and as an aid to the operator.

The revised MCB layout includes six colorgraphic CRTs. One of these CRTs is designated as the primary SPDS display, and a second CRT serves as the alternate SPDS display. The placement of these CRTs was considered in the redesign effort to ensure maximum readability of the displays.

The EOPs and the SPDS display formats (hard copy) -have been tested as a set for over 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> on several simulators as well as over 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> in table-top exercises.

The process CP&L followed in the SPDS development is outlined in Figure 1-1.

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b. REG. GUIDE 1 ~ 97 The REG. GUIDE 1.97 items have been discussed by CP&L and the NRC (See LAP-83-405).

The majority of the REG. GUIDE 1.97 instrumentation was added to the MCB during the MCB rearrangement. The 1.97 instrumentation was incorporated into the MCB layout using the same human factors guidelines used in the MCB redesign effort.

CP&L has ensured that no HEDs have been introduced with the addition of the instruments. These additions were coordinated by the LDE and the Human Engineering Discrepancy Assessment Team (HEDAT) . This was verified during the completion/reassessment phase within the verification and validation activities. The Post Accident Monitoring instruments have been highlighted on the MCB with yellow bezels. It should be noted that the 1.97 parameters can also be displayed on the CRTs as each paramete'r has been incorporated into the ERFIS. Attachment 1-1 contains a listing of the 1.97 parameters and their locations.

c. Emergency Operating Procedures The EOPs were written specifically to adhere to the Westinghouse (Q Emergency Response Guidelines (ERGs), REV.-l and have been tested on the same simulator on w'hich the p generic procedures were tested. The results provided evidence that any deviation taken by CP&L in making the procedures plant-specific resulted in expected responses and ensured that safe conditions were achieved. These EOPs were written and tested by the same individuals that participated in the CRDR efforts and supported the HEDAT.

The ERFIS/SPDS information has also been incorporated into the EOPs (see Figure 1-2) ~ The Critical Safety Function Status trees contained in the SPDS are tied directly into the EOPs.

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EOP revisions are made using 'the methodology specified in the EMERGENCY OPERATING PROCEDURE WRITER ' GUIDE (OMM-006) ~

Notifying the appropriate departments of these changes is also a requirement of OMM-006.

d. Operator Training The initial EOP training program was tailored to the upgraded EOPs and was written by the personnel responsible for the development of the EOPs. The Element Tables in the task analysis (see Section .6.4 of this report) also provide a top-level indication of t4e area of training for each EOP step. In addition< the Hot License training program reflects the recently updated EOPs. As the plant continues toward completion and as background/operatirig information becomes available, the training material is updated.

The training department is notified. of all Control Room and plant modifications through the distribution of Field Change Requests (PCRs) and Design Change Notices (DCNs). Plant modifications and procedure changes will be reviewed by training to determine the need for either dissemination of the information or inclusion in training.

e. Emergency Response Facilities The ERF has been coordinated with the CRDR in the areas of information and communication needs. The same integrated plant computer system (Emergency Response Facilities Information System or ERFIS) that drives the MCB CRTs also drives the CRTs in the Technical Support Center (TSC) and the Emergency Operating Facility (EOF). All CRT displays available on the MCB can be called up in the TSC or EOF without affecting the MCB displays. This information is displayed (real time) in the TSC and EOF, which ensures maximum coordination of facilities.

1-16

The communication systems between the Control Room and the ERF conform to the requirements of 10CFR50, Appendix E. The communication devices to be provided include: dedicated telephones (Hot Lines), dial-up telephones, the Emergency Notification System, company radios, sound-powered telephones, and the ERFIS.

A summary of CP&L design standards and criteria for the TSC (which was also used for the EOF) is contained in Attachment 1-2.

1.4 GLOSSARY OF TERMS Since there are differences in usages of terms, (even among practitioners within the same field), the following definitions are provided to reduce ambiguity.

CONTROL ROOM: For the purpose of this plan, the Control Room is defined as including the primary operating area of the main Control Room and the auxiliary shutdown panel.

CONTROL ROOM DESIGN REVIEW: The Control Room Design Review as required by NUREG-0660, Item I.D.l and implemented in accordance with NUREG-0700.

1 ENHANCEMENTS: Surface modifications that do not involve major physical changes, for example, demarcation, labeling changes, and painting.

FINAL

SUMMARY

REPORT: Final summary report of the results of the CRDR as required by NUREG-0660, Item I.D.l and in accordance with Generic Letter 82-33.

FUNCTION: An action performed by one or more system constituents (people, mechanisms, structures) to achieve an objective.

FUNCTIONAL ALLOCATION: The distribution of functions among the human and machine constituents of a system.

HUMAN ENGINEERING DISCREPANCY HED : A departure from some benchmark of system design suitability for the roles and capabilities of the human operator.

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HED ASSESSMENT TEAM HEDAT: Those individuals of the CRDR Team who have the responsibility for review and assessment of all HED reports.

HUMAN FACTORS ENGINEERING: The science of optimizing the performance of human beings, especially in industry; also, the science of designing equipment for efficient use by human beings.

OBJECTIVE MISSION GOAL : The end-product as a result of a coordinated set of actions taken.

LICENSED OPERATOR: Any individual currently licensed by the NRC who,manipulates a control or directs another to manipulate a control that directly affects reactivity (SRO or RO).

SUBTASK: An action performed by a person (or machine) directed toward completing a single task.

SUMMARY

'REPORT: Description and results of CRDR actions performed for SHNPP-1 and a description of CP&L's plans to complete the CRDR. Submitted to NRCi April, 1985.

SYSTEM: Components that function as a whole by virtue of the interdependence of its parts: an organization of interdependent constituents that work, together in a patterned manner to accomplish some purpose.

TASK: A specific action, performed by a single system constituent (person or equipment), that contributes to the accomplishment of a function. In NUREG-0700, only tasks allocated to people, in particular to Control Room operatorsi are addressed in detail. Moreover, in accordance with Generic Letter 83-22, only tasks associated with emergency systems have been evaluated.

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VALIDATION: The process of determining if the physical and organizational design for operations is adequate to support effective integrated performance of the functions of the Control Room operating crew.

Pp other equipment meet the specif ic requirements fd'*'f'ontrols and of the tasks performed by operators.

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1.5 ACRONYMS A number of acronyms are used in thi's report. This list is presented to facilitate the reader's use and comprehension of the report.

AC Alternating Current ACP Auxiliary Control Panel ARE Architect & Engineer

'EP Auxiliary Equipment Panel AIRD Action-Information Requirements Details AIRS Action-Information Requirements Summary Annunciator Light Box APDMS Axial Power Distribution Monitor-System CP&L Carolina Power S Light CR Control Room CRER Control Room Evacuation Requirement CRDR Control Room Design Review CRT Cathode Ray Tube CWD Control Wiring Diagram DMIMS Digital Metal Impact Monitoring System EDG Emergency Diesel Generator ERF Emergency Response Facilities ERFIS Emergency Response Facilities Information System ERG Emergency Response Guidelines (WOG)

EOP Emergency Operating Procedure FHB Fuel Handling Building FSAR Final Safety Analysis Report FW Feedwater GFFD Gross Failed Fuel Detection GFFDS Gross Failed Fuel Detector System HED Human Engineering Discrepancy HEDAT Human Engineering Discrepancy Assessment Team HERS Human Engineering Requirements Specification HF Human Factors HFS Human Factors Specialist HP High Pressure HVAC Heating Ventilation and Air Conditioning 1-20

ISAAC Instrument and Control INCORE Incore Instrumentation System LDE Lead Discipline Engineer LED Light Emitting Diode LHFS Lead Human Factors Specialist LOCA Loss of Coolant Accident MCB Main Control Board MSIV Main Steam Isolation Valve MWe Megawatts Electric NIS Nuclear Instrumentation System NOD Nuclear Operations Department NRC Nuclear Regulatory, Commission NSSS Nuclear Steam Supply System NTOL Near Term Operating License OER Operating Experience Review OPS Operations Personnel Survey OS Operations Support PAM Post-Accident Monitoring PAID Piping and Instrumentation Diagram PGP Procedure Generation Package RAB Reactor Auxiliary Building RCP Reactor Coolant Pump RCPVM Reactor Coolant Pump Vibration Monitoring RCS Reactor Coolant System RO Reactor Operator SFTA System Function Task Analysis SG Steam Generator SGTR Steam Generator Tube Rupture SHNPP-1 Shearon Harris Nuclear Power Plant, Unit 1 SI Safety Injection SITL System Integration Team Leader SMS Seismic Monitoring System SPC Site Project Coordinator SPDS Safety Parameter Display System SRO Senior Reactor Operator SRTA System Review and Task Analysis WOG Westinghouse Owners Group 1 21

FlGURE 1

'l ERFIS/SPDS EFFORT

'ETAILH)

FUNCTIONAL SPEC.

NUREG-0696 R.G. 1.97 NUREG-0654 S DEVELOPED EOPS PLNT PARAMElERS HUMAN FACTORS TECH. e CONSOLE DESIGN SPECS. ~ SAIC REVIEW DR SPDS DISPLAY EOPS DEVELOPMENT ERF EMERGENCY ACIION LOCAIIONS t,'EAL )

MONITORS FINALIZE STAIUS ONFORMAlION) lREES SAFElY ANALYSIS HlSQH FACTORS EFFORT e DISPLAY REMEN

~ TAKE TQP FAG'mR STAllC CHECK OF ERFIS SPDS SYSTEM lEST PLN FINAL ERFIS SPDS IN CONTROL ROOM 1-22

FIGURE 1 2

EOP EFFORT EOP DEVELOPMENT SPDS INTERFACE CRITERIA QNKO 073l; IINK9 III DOCSBITAlli R.G, 1.97 EAL DESIGN (NUREG 0654}

SET POINT STUDY WOG OUlUNES SPDS SPDS DISPLAY DEVELOPED PGP SUBMITTED SPDS VAUDA'ttON IN RU S SPDS DISPLAY DEVELOPMENT EALS DEVELOPMENT EALS VALIDATED EOPs ACCEPTED 1 23

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C ).1 CostelsaeaC I lee ISt 1L)S SA 0 t ~ IO1 0 to IOT IC CI Tlt h54raata shsiyrvt I ~ cstshlt el vsrthriht lly4roits ISt-1L)a LS (Certhlt ot (hy vo(vv) Irhvclvpt) lese > tall co 4vslth Drteevt ~ . arl ~ I to Coectettel lea operellai Iroa I tris ISAL Sectloa L.I~ S.

lo DLIA lo vs ~ IEOI ieslia preesvre)

C. ). ) Coal s I sar et ) Tee tl )ILOL ) t5IC le ) tlaee l)S 0 5 IC Cost IICL trotters 1)LOL iesl54 pressers S CD La I IL tar castrate ~ SIC C.).I Ceatalsval Clllvtst 2 Tes IC ZTT ))OSSA IO L DCI/cc Ia Io DCI/cc I 5 IC CI lhl ~ verlshle I ~ sctrttet4 ~ 5 aealtac ~ sote4 tat(settle(ty - Coals I ~ le III IS ~ I Icee L.).I.S. Llivl~ Coty Cvlit I t1 Cases Itch l4ealltlei lo I DCI/cc ~ I 10 DCI/cc (Irv )) Their ) loolsvt ~ lo ~ Ilovt the celeste tolala ceohlaelloh et ~ Ittsoe ptl4t lo ttltset C.) 5 C((local Tee CC ITT ))OSSA IO I DCI/cc Calo 5 DCI/cc I I 0 5 IC CI Also relet to lies C.).I.S.

~

Ls4lsscl lelty lo I~ IIIIS No'll ~ Ceres IO) IICI/cc Oslo DCI/cc (testtr ~ lloe INlchse)

O.l.l IAI 51 ~ tta tlev 1 Tte 4cec 0 co IIOC 4let Iroa IC IKL l4rL vt I ~ Iorvt los I~ ptovl4t4 hy pvap ascot OeslSa utS CII IS cvrtrsl eal valet ~ I ~ cvs 'Iht react vill tish Act ~ eet esi/or etcet4 DIIOT al ieelio llov.

O.).1 LN Neet Tschselet 1 lee 4tet Loot ce )S(y'f 4ter I) NI Iloa IC IAS NCS 54th vp lh4lcel los I ~ provl iei hy c(N Ovllet Ieaterslsre 0tS ICOI ttvprtelvr ~ ttlllaa the 'Irelivsl Neet troovel LatlS Nes\ Cschshtet ~ .

Tht teact vill asti 4441st ~ sctri Lot la

)SO O.). Ie *cvv)~ Iet 5 latest Ll-tlo,t)),tli IOC C ~ )01 Noa IC ltcu Teal 4vrl ss4 trnevr ~ erv aoalrotr4 hy Tash lovel Ll-tla, tlirt)0 valves 0 I 001 ut5 CILI IS ItrlNIIC~ I Lttsltlc~ ties ~ ivfIse s4rasl lh Tosh tr ~ esvre laltel tT tll,t)),tIS oper ~5 Ioh Sal ~ Iy Attic Is41 ~ 'Lish 'I ~ Ive

~ l t)1,)lt,t)l o yso tslc 0 - 500 tSIC Noa IL Ilt I I44lcsr Iw I ~ ~ Iovl4r4 Sleet ltle States I ~

uts Coal LILI I5 psoslvr, tvvrr rh valve ls locLe4 svl st thv Clrcvl ~ Irslrr. Tart ~ rote ao Ivrcl~ te

~

OprteIOI OII Iso I ~ ~ atlclretei THIL ~ I ~ 'lvs Ceh ht lhtvfrei rrw tat t(5 tttsevce 0 ~ 1.1 Acr wvlet et 'tee - LLVCA Clos t4 hot I 0 5 IL NE'I laster lsa reive 55055 4t Cleet4 LLI lh teel 5 Isa Otto Nol Opr 4

ter lail ~ (I) ()) ()) (IV)

(I) Sre>tt Cessor TOK Ketvlre4 Lsletla$

4a (4) (S) (4) 44<<a (Vl Sesset Vl ~ I lry Ceetlller to>teil ~ Osec ~ 'I clos CAT Cee lies t><<e'ier kee e ~ C Selselc Psst te<<c r lecettaa le ~ C res l>>os>'i>,

D.).) Sorlc Ac I4 I Tee Lc ~ t 0 to later Nos IK Nca DvrlsS tie la)set les casse ( ~ I tet rtceltt ol tberKlal ylev I IVI urS Lsi li ~s 1 ~ Iesel) ~ ltea V./ ~ 4 ~ Iw Tres>oct tet ~

Des ISO wy be wt4 te soalter Sores lo)ectleo rlov tlov Tbe 4ace <<III sect ~ ae/or e ~ c ~ C4 0 te IIVI ol Deelta ~ I<<<<

D.).l flee ls Ntl Syetea ) Teo Later 0-IIOK later NK Nes-IC NID Ntl I ~ by cisrelo$ tvef. Ibe reels <<III Decl as vrS LKIIS sett ea4/or cscec4 0 so IIVI or Oeelie Ilov.

tie<<

D.) I flw ls Ltl ) Tee Lt~ C 0 ta IIOC Later 0 NK Noa IK KAS NCS Ltl I ~ by I/>I eystee. Kc/er I ~ Itoe D.l.).

~

Systes Des/CO ylov VTS Let lt D.I ~ 4 Ke/wlla$ Voter Tee LTILI t)0 I Tot 0 I OOK 0 s IK Nct Starets Tesi Leal LTILI ttl II Sattoa Kcl>~

LTILI tt) III Key l$

LTILI/ttlIT D.).I 4sctec Coelsat ) Tee Kl 0)10 0 $ 00 0 $ 00 Aate Ne Nos IC SVCK Nta teat Scotw Cl OIAI AVL KIEI IS Kl OI ~ ) IVS CT P.).) trlwry Iyetoa ) Tse {~ ) SOIOA Claret Nat Claeo4 0 S lb Cost IarIS 4<1 vt Iaolcetloa I ~ froel44 1y Teeter ~ t<<r ~

tel lel Solely SO/OS Not Cloeei ~

Not Ofea ~ <<altar ~ 40<<a ~ ctree ol tlwet Oftr ~ tor tell ~ I relet teel\lese SOIOC S IC NCS valses {tutt),

~ t flee tbroelb (~) tlt AASA ot twwera I ~ ~ CT ll)S 4lltl tales Clare tCT illS D.),) treeeerlter Lsr ~ I I Tee LT-4)t I Tot 0 IOOC ~ VK NCS LT 440 II t~ DIST 4tloa Noa IC tNL CT D.S>i ttessottter latest Kl 04l4 Cltctrlc 0.400 NA Noa IL coat r>ts Ii>~ ter States Cetrtat Aaf utS Lsr'IS ACt D.) ~ S 0<<satb Test Teo LT/4/0 Tat NA Nos IL Coat NCS Lee el ta vrs Ltlr Ii bettea r>t D trrseerlter Tsai

tectebl ~ (I) (1) (I) (10)

(1) SNNPP bee<<or Tet krtvlre4 I ~ let lak (4) (S) (4) keda (8) Stater Vl ~ I'Iey Idlal ltltr terr ~ ble Drtclt Icos

~T cAt cee lite svsbvr kas e 4O e 5<<lear<< Da st paver toe<<clos lvcvc lvs kesv r I ~

0.).4 qvesch Ttab ) I ~ Iral Tt 411 SOef ta )SOef SD))ry f NA Nos IL Cost IICD Stsce PNT Dr<<its Pcreavre I ~ IOV pelt ~

Teart I ~ I v I a 8 ps AC (aeter Co Iceo O.l.l) Che Lvptvr ~ Ol ~ I I ~

I'al IS ~ I ~ PPIO<<la<<rely 84 IVO Pelt. To ~ I )1).8'r

~ I IVO Polk aery D.).y Cpwscb Taab 1 'lee F14)1 0 Io DIDO NA Noa It Coat NI ~ kvpcvrc Disc eec co bllw ptlar co IVV pel ~ ~

preetvre Dr o I 8 s PSIC CIF5 AC fata<<<<e I'kt IS D.c,l 5ce<<s Cease<<car Lstoac LT 4)1 I fees 'Tobe 0 1001 A 8 q II<<8 Theet Vldt reatt Creee ~ ICC<<r ~

terri LT 48) II Sbttc la (Vide teak<<) Lac IS ~ e evpplesesced by Ihc t<<toadeat Lf-ct) lll 5tptracore ACP sar<<os teett ttesalcctr ~ os ~ trh

~ cteo ktsec ~ cvr sce Iles ~ 4 I Ia oddltloa, 4lrrl~ lty I ~

pro<<Id<<4 by vec ol ececo lls<<

prtetvte asd avalll leedvscer Ilw.

D.4.1 5<<eas Ceaeratat aery 2 Tee rl-b)4.$ ,4 I Tcoa ncaa. 0 I)OV PSIC 8 5 IICS Slees llae prreevre I'eatvred

~ re ~ oete PT-484,$ .8 II ftet ~ ~ re ls (Steosllse coerced ol ac<<as Sea<<color pceetvr .

PT I'l/$ 4 lll )Vt ~ bert pressure)

ACI'(08 IS

~

Lovtoc valve ESP Setllak 0.4.) Seletylke) I ~ ( 2 T<<o PCV )OSA Closed Nat I q NA ~ AS IK8 faire peoltloao PLV )088 Nat Cia<<ed Acf

~ r Nels 5ttaa ~ CV )08C Clot<<4 4 Lkflk

~ 1av Not Orts 0.4.4 Nel ~ fetdveler ) 1st ff-cya.y 0 1)01 DS all)los Ibfhr q 5 NCS Thl ~ casa<<covet ~ 0 i)01 os ~ ach sets FI ev fl 484,) Des Its far each IVN 1st IS leedvacer Ilov llae.

FT-4) ~ .y Pl ov Liat 0.$ .1 As<<ill at Tto FT IDSOA 0 ta l001 D)44,000 Ibyhr I q IL IK8 T'll~ resae rover ~ O-l)01 oa ~ ach to<<rtescy PT-20)08 Deolts os each AID !lac Atr avclllecy coed<<et<<c clov Ila<< ~

~ ntvacer flev FT 10)OC fI ov Lkt IS 0.$ ~ 1 Cos4toeoce Startle Tash Voto<< Level I Tee LT 10IOA LT 90IOS

~ last Sp clllc D I OVS 5, I q 5 Nck Alr ESFIS Cosdestere lest Ireel vill cecvt4<<4 'by Lailb (Lospvctc)lot

!scars<<Iles bt ctts4lak D.a.'I Coo I ~ I sw s I 1 ree LT yll)A 0 IIV1 Later q NA IL kAS ESI IS Treaeelttero vill be Wc<<he<<ed Spcry flov LT II)18 Des lka co seat Ihc cea Svl4<< Ie<<vlc<<eeoc ~

Flew

terlell ~ (I) ()) (1) I~) IIO)

(1) SINIP Scarer Tel Net v I It 4 Lslotlal (5) (I) (0) ke4va (I) Scarer Nival ay

~ rvtaaler terteble Drectt t toe CAT Cw Iree Ihvlrr 40 e 40I ~ I 5eroslc Deal rover 4reI IOII Ler ~ I I oa k <<Iav D.l.) Neet 4oorel ly 1 Teo AN I pleat Sycc lr lc Oa/Ot( IL LIFIS Dlrtr~ Iay Ivr eoalteraat vectealoa Cosa ~ reseat AS kvaalak I'corldrd by vvc ot atc tea Neet Iceerel AN ) 5a ~ cve coac ~ Iaecst aeeprretvte lstlcaa ~ I~ .

Syeces AN I Sce Icca D.l.).

D.l.) Cwaolwesa 1 'Teo TC )sa) IOet C I 0 IC Cost NCN Atseeyhere TC 1)01 lo lllll Tcsperetate IDO t D.l. l Coal ~ I twr st 1 Too Tl yl))A )OF $0 )SO C I IC Coat NCI Svap UOI ~ I Tl 1I)) ~ lo Lk) IS Teeter et vr ~ 1)rPF W D.I.I Ntitap tlov la lsaeet FT III 0 IOOC Dlho cyla C C Noa-IC RAI RCDk TI le oyotra verlelle I'oa tttvlrtd Ier eel ~

I De ~ lls ties CII IS pleat elwcdvvn. Thc oyeare I'oel aed oa

~

~ losa praaecaloa ~ lloel ~ ~

405e corer ~ 0 to IIII 0.1 1 LOC4elW Fl~va 1 Isaost tT 1$ 0 0 te IIOC 0 100 CIN C C Nos IC RAI VCR Thl ~ oyecta rerlelle I ~ aac retvlred Ior eat ~

Doe(50 Flav VtS LRI IS pleat eawtceva Thc eyeaa ~ lo lsol ~ tt4 oe

~ I ~ el prottclloa ~ llllel~

lartlavs Lta iovn llov I ~ IIO Ips.

D.y,) Telwe Cosatol 1 Latest LT ISO Top to Dl001 C C Noa IC IKN Thl ~ a)etta rerlolle I ~ set tetvlrcd I ~ I eel ~

'leal Carel Iat tea Vtl LIIIS ~ lest eawadova Thc bleats lo leal ~ aoi 00

~ lear protect loa ~ Ilael ~ .

D. ~,I Caoyoseaa Cool lel I Tto TC SN AO F 0.100 I I 0 IC Nal TC ~ yt 004 IC ~ IS la4lceae ceepcret re avt at Voter Tnpeceavro TL-h)$ te Icbk Ihc LIV iver lethe*ter ~ . Iht Trsptr ~ rvrc af Ce 551 51eloe )OO t CIFIS CCV lato ahe Neet Ccchesktre I ~ ls4lcated ly TC 01) aad ll ~ 11.

0-5.1 Cooyoaeat Cool let Veter lslest FT tl ~5$ )

$1 0 Der IIa I l01 D)so(0 CFN Noa IC RAI Nal I(DR FT lll 004 IT llt INR heat area eater ~

la4lcett CCV llew to abe la4II ~ Iles <<1 IN ~ lee tlav ao 55t tlev CIF Il islet ted Itos FT-Ott 004 t'I \SO.

5yeaes D.t.l Nllh Lerel ) I@t ~ et LT lOOI Tet Noa IC Utk alt l Ieiloectlvt Lltvl~ (UO ~ tr Noldvp Teal) le Teel Level LT olOI 4tlos (FL DI ~ ls Teal) Nva IL VIR VrI

Ver I ebl ~ (I) ()) (I) (t) (IV)

(I) Srstt Seaeoc lec Seto(roc talettlll (I) (I) (4) 4ow- (4) $ eaeor Pleylay loeatrrrer vert ~ 'lie oeerrt crea car coa tree avatar 4>> e 4 e CO Selealc Near tevv r toe at taa cure\toe 4aerl ~

D.t. I Iecloect lee ) lee tl to)4 te 0- IN Nes I'l vrs vrs t. ~

Cee Nelrvt tl IO)t Oee lsa Teal trewere tl IOSI to trreevre Nea IC Vti Vty&$

n-)OS S D.IO.I torrceecy Teo Ver tow Oyea Nat C C Noa IE Vti vrs I ~

Veatll ~ cloa Closer Dyes Dearer toe ltlos Ststw Net Closer D II,II Stotw o( Stasciy Teo See Terlebleo tl ~ tec 4lov tooer l Other laerST Scale ~o Iayarcosc to Salary (electric hyrrevllc, yeeweclc)

O.ll.l S.t hV INIS SOS I 'loo CI-St)441 eaJ Sl tlast eyeclllc DSOOOV I' q IC Svlr NCS Vo1 C CI&t)4$1 tt Styli D.ll.l Oleeel 4serecor I Tea Cl 4TSSS sos ~ tlest oyoclllc 0 t000 I I q 4 IC Iver Nc,h vole tt car($

D.ll.) Oleeel Ceeeretor 1 leo Cl-itS4$ osc O tlest steel (le DISOT I q $ IC DC Coot tlelc Tell D.l I. ~ O.C. Tlelc lee Cl at)OS esc $ tlast oteclllc DSOQ ooy I I q $ Oc Cost cvrr ~ ec tal D,II.S O.C. Ceectlre tewr 1 Tee Cl STSCS eoc S tlsst eyoclllc e 10 KvAI I 0 S Coat

~ I D. 11.4 O.C tooer 1 lae CI<TSIS aac S tlaat erect(le DO NV I I q Da coat " NCS tel D.ll.l I I O.C. Correct 1 Teo Cc-at)14 aac $ tlaot erect(IC DSOO Sst q 4 tl "OC Coal D.ll.~ 4ct Cvrrest I lee cl iti)a ooc $ tloac eyeclllc e 400 Aay I I 4 IL tX: Coat N($

tel

Terrehl ~ (I) ()) (I I ('I) (Iv)

(2) Srhtt Scseor 1st ~ ctvlred Let ~ ciao (I) (I) (I) ledvs- (I) lessor Display

~ vetrrrec Tecrehl ~ Ovec ~ I Cree CAT Cev Irvo Nwacr 4e e 4>> e 'I Sel sale Deer eever 4I ~ I Coo Iocerrvs 4ver1 ~

O.ll I Sett Velta 'tee Cl Ltelh esd I Iieet epeclllc 0 )SOT 5 IL DC COst ICCI tsl O.ll.)0 NSIV Nydrovl lc 1 Teo )CIS.VISA)-I Tilt'l-l tleat ~ Peclllc IO.ISO tell I I I IC Accwvlaler heelers 2a5

)rch v)IAI I D.ll.ll tv'ydrovllc 1 lee )yv TIISAI I tlaat steel(le later I '2 q I Accwvl~ tar treeevre 2yv V)OSAI I

)W T)SSAI I l.l.l Coat ~ Cowst Ares 441 ~ ties I Teo IIJC )Stt 5A trit-)Sto Sl II CO later I I I IL Ad41rloeel ooeltec ~ vrll IN tvccheeed

)s q Nllh leo)a IIIC )Nl ASA lo I/Nl LltlS 1st vw Ie ~ Ide cost ~ reseat, Iea )Se) svelter ~

Teo IIN )St) ~ SI 41er INS ~ ce lac t0$ 1 lOCA soertecrst Cstclr reacts

~ re Tehlt 12.).i I. ooteo I ~ ySAI le)I ~

11.).t I le4let lee lryoevre 4t ~ (leolde ~ Idle or 1 1oe ICIC III-)Sty I)It ltl )SII lo-I I/Nl to I 1 NA Nos ll lll Styli INS Costly tealte 12.).t I

~ re setto la VSAI Tshlo Artcc vhrre access lo Circ Itt ))jyl )OI I/Nl retvlted ta settles IIN lll 2)IVC lll )IOO

~ tvlt Iopecrsot lo ~ IN

~ er ~ ty IIN-lll-)OOI

~ Ut III SLOI ICN III )50th IIIC Ilt )10) ICN III )tool Sea Ieaarl ICN 2ll )tot C.).I.I Ceatolaorst or 1 10 I tCI/cc Not Aptl lcehle ~ Isct e(l lvcat ~ Iechtclee tv rlt ~ I(least to Iot OCtlcc thcovlh ceases ~ lest veer.

0 I ~ l)01 Ts ~ 1 Oe ~ I la I 1ov l.).l I~ ltectar SLIeld lo I OCI/cc Not Appllcehl ~ .

~ )45 Assvlve to 10 rCllcc 0 I~ 1 )hi Vest Des lie I I ov I.).l,) ~ vtlllacy lldl 20 10 OCI/cc Not Appllcehle ~ lace err lvcat ~ Iecherteo (I eel vdlel eay Lldl) I ~ lo Cl/cc throvlh coesos pleat vest.

Coal I I el pt I so cy

~ ~ 0 to 1101 Stores Ieeer ~ ~ .I Vtat Oeolla wctu Ieo decoy ceaL) I )ov

0 terreblr(l) ()) (I) I'Pl ( IO)

T~T (I) Sfsrt )secor TOS Reevl ted tsl ~ Clat (4) (I) (~ ) 4dv- (~ ) Slaoof Droplet Idrellrcrr 4lleble Drerfl floe CAT coo Ill~ vvsbrf 4o ~ 4 ~ t Solesrc a4 pwr r col ~ l I os IIV~ l roe Sroefl ~

tIII CosdrMef T<<e tt ITT )$ )4 10 4 OCI/cc Lt<<c NA Nes-It Tvb Nosllor vill he pvrlheeed to ofrt Alr traorel Co IOS oCI/cc CSI IS lr 4 v I r r oe a c ~

Spells tlhowc 0 I ~ 1101 Trot Dsalta tlav t.).1.) coasoo ~ leal test Trs tt-IIV-)SOP SA 10 4 OP/cc I 0 CA

~r Nolt lperpeee I~ 10 OCI/cC tt)1$

teal Dlecherllst esp 0 1101 (lt shore telreero tree Deolts le Isclodedl I lov t.').l.4 'leal tres stree Tee AS-)SSI -I OCI/cc Cs lscec t I 0 S CR Ceserelar I~ tsrp ~S )St) 10) oCI/cc IAI IS

~ cllet relace or RS-)S)) (Drrotles ot Ala. DVsp telree r ~ I ~ oMo Ia ooc 4 aoe ~ st ~ coos psr salt ciao t.).1,1 All ether Idescltled I Tes tCN IIN )S44 10 A,CI/lc tater t 'I 0 CR Noalcor vll I be pvrcheetd co arel loll~ e ~ polar ~ RIN IVt ))41 to 10 OCI/cc tt) IS tetvltearal ~ .

0 to 1101 teat doelts tlev R.).1 pertlcsl ~ ceo ) Tee RUI IIT )SOT SA 10 ) rcCI/cc Ltot t T Nos-It Noallor vcll bs pvrcheeed la scot

~ ad terr ITT )IOt AA to 10 OCI/cc trtvlrrseal ~ .

Vs(stree ~ Irf lvt ))44 0 co 1101

~ trf IVT ))41 Test Deslta tlov 1.4.1 Alrbersr teedlo Tes 10 ) OCllcc I. 7 Noa It CR Other Idler lt ltd trleerc polar ~ easel ~ t et ths teleteso ood ttllS Vl~ \ ~ plOrtr ~ IOA Drl Idiot Sl ~ lt pertlcelecee 10 att.cc (portable eespllat all ~ oaelr ~ oulpel ~

l c o pe b I I I 7 1,4,1 plea\ 4 esrlr@M ) T@ ~ 10 ) t/Nr to Noa lt crct vill pvrlhoee sosltof ~ to arel 4(I ~ clos 10 R/IN, thereas

) t/Nl t ~

rrtvlfrsrsl~ .

(port ~ bl ~ IO laecrwwceclos) 10 R/IN, bol ~

~ ods 4 Iw OMrtp Prioress

re ~ tell ~ (I) ()) ( I) ($ ) ( I 0)

T~T (1) Start Sea%or Tel tctvltet tel ~ tlat (a) ($ ) (O) tcew (t) Sensor Diaster Icraalfl ~ r terletle De%crt alen cat coo I I ~ e vwscr tea e 4h 1 Se I I a Dent tow r lor ~ c Isa Iocoa tw As%lie float Co%Irene Tee Nvlt Ic4asol later 4e 4 leaC \ It T Cewo ref non Il coal vali tvnhoee ra%alters ao seel t~I~

(tertell ~ Steccreseter Set%It%scat Iee'trvoEOA'IIOE)

C.SKI Ulat Dltectloo Tee 0 aa )eO'CS' 0 Non It I,I Nil%a lal IS S.l ar lt)

Sao'e ccvrecf %IIII ~ Nl ot elena Aflectlen ef )0% vates ~ A(lac

~ tertlas oeeea ~I I)

O.to Ntt (I Ntt). Stanlst Steat ef Doselst reals 0.)$ latt osa treater trer ~ ar Aorist Sat I ~ of

~ twl I ~ O.t, Afaf 0.&. ~ . Deist

~ I ~ I ~ ac ~ I ~ e ~ Distance I' t4a or otwl c~ 111 notate.

1 seaero C.S ~ I lais( Steat ) 'les 0 ta 11 Ntt ($ 0 0-)00 NtN (llaeer)- Nos IC I.I Nl leo tttlt Nta). e 0.1 Ntf vita ~ cc ~ reef of Nl ol tlast tA (0.$ ratN) occsroct e O. ~ Ntt or lt fot oteeA Item valcaeret le I4a 1 Ntf (S Ntt) ~ tteetet Sterllnf IOI lor eteeA I ~ taree4I ~ of 0.)S

~ cease of 1 Ntt Ntt asc ~ conetaat

($ Ntv) ~ vlat ~ tl ~ tesce of

~ Iaralst tltoe4I ~ I.)II oscars.

~f lees t4O 0.40 lrts (I lrtN) enf ~

tf~ tanto cewtos'I

~ ot c~ street 1 notoA C,S.) tealsetlos of areeotatrlc

) Teo 4oef w ~ tert ~

elf( tres IO t I~ IS t Noa IC I,I Nllee Ctflt teste %Its oo octvfact Nl at tlest Steitlftt ~ rlsetf aetoorolv ol o O.liter Steel ~ Teteo rer at steers.

$ 'C

( t't ~ta IO'C a

lt't) lece O.IS

$ 0 wast ace%rect

~

lnterval ~

(e 0,$ I eccvroct trt lat tool Iowa%el ~ ) or

~ aalolevo Aaf ~

Ac ~ lt~ aaaatv ~

~ aotllltt sealso\oo.

rsrlsMO(l) (3) (7) I'I) (ID)

(1) Start Sraoor Toc Setvlte4 CslstlaS (I) (5) (S) tcdva- ( ~) Scoeor Oretler fceottfler rsrloll ~ tvscrt ttoo csl coa tres Nveber 4O ~ Ss ~ 4 loafe Nest reve I lecstteo taeet toa tI a 4 A s S.i,l.l Cross AcCI ~ I ~ 1 ) loe 4ter ID Cl/al Sco Soastlo.

(1rlaorl Coolest) t~ NA Noa- IC ~ AS Net lbe tostsccldeat eeatl lac ~ fates Itl55 10 Cl/al Lsb vlf l Ie OIII III4 Ia oIdct Io 0'll ~ Ia Crab

~ carlos of trisect coolest ~ Ibe tASS vill also le olla to troeldc 4lleted

~ setlco. safer to 1$ AI Sect los t ).I for laloraet los relar4laa cbo tAIS ~

C.i,l.l Cease 51ettrvs ) Toa 4ter (Ioototlc 4 5 cls. T rll Noa Il SAO Sce ltce C.a.l.l.

(trlosrf Caolast) Ass I 7 el ~ )

S.i.l.) Scree Cosrosc 3 Tee 4cer 0 4000 5ee Seasrla. L NA Nos IC CAS Not See Itea C.l.l.'I, tl (tr Iso Ceo lest) TIN 41 41 C.i.l. ~ aforfde Toa 4tor 0 10 Soo 4aorle L T NA Noa Il SAl Not 5 e Itea C.l.l.l.

Coatest tfN 41 (trlasrl Caaltat) 5 S.I.S Ofosoleed 574rolea er total Soo 5 loe 4ter 0 1000 cc (Slt)/CS 0 5000 cc L 5 NA Noo ll CAS Set Itea C. ~ .I.I.

(ttlastl Ceolsst)

S,i.l,l Dissolved Dtrlsa (trloocf Coolest)

Tee 4ter o I ~ 10 trN 0-ttN 10 L 1 NA Noa Il'AS See ltea l. ~ .I ~ I~

C.l.l.l (trlaatf Coolest) los Later Ital) I - I) L 5 NA Noe IS OAS 5ee lies C. ~ .I,I, C. i.l.I Crass Act frit) ) Tas later I aCI/NI Sce Seaorls 5 NA Noa IC SA5 Not Tile toot Accldcat Sootlfat Srstr ~

(Seat) I~ 41 (tASS) vill br vtllltr4 IO olr ~ I ~ ~

10 ll/al stab ~ seal ~ ol coatslaacot ~ oot llvl4. Tbc tasS I ~ ~ leo tel slit ol tteel ~ laS ~ llvte4 treb ~ earl ~ O 4(or IO

~

tSAS 5ettloa 'I.).1 lar laloraetloa recst4lst tbc tASS, S. ~ .1.1 Cease llecttva I los 4tet (loototlc Soe Saasrie L V Not Scc Itra C.S.I I. ~

(Svat) Asallol ~ ) 41

eoolable(l) (3) ly) >> lt) I I 0)

T~T Sraart Sraeoc tek Rat>>area le I ~ I I ok (I) (I) (l) SeAs (0) Sea>>or Oleelay lce>>taller earlebl ~ be>>era ales cl'I c>>a 'lice amber 4>> e kao ~ Se I >>ate 0>>>>a rove r twr ~ I o>>

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ATTACHMENT 1 2 CAROLINA POWER 6 LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT TECHNICAL SUPPORT CENTER (TSC)

SUMMARY

OF DESIGN STANDARDS AND CRITERIA FOR THE TSC The design for the Technical Support Center has been based on widely recognized industry and technical standards and building codes which encompass many aspects of good human factors engineering principles.

The primary standard governing the design of the TSC is the NUREG-0696, Functional Criteria for En ineerin Res onse Facilities, which identifies various parameters for physical layout, staffing, size requirements, habitability, communications, data systems, and operational capabilities.

Structural and internal features were based on the Uniform Buildin Code and the North Carolina State Buildin Code Volumes I II and III.

AIA Architectural Gra hic Standards was used for sizes, clearances, and The features not specifically covered in codes. Seismic design considerations, safe and sufficient layout parameters, requirements for construction materials, and installation are some of the areas covered by these particular codes and standards.

Heating, air conditioning, and ventilation were designed utilizing the ASHRAE Handbook and the Industrial Ventilation Handbook. Power and En ineerin Societ standards.

Safety and equipment systems were based on National Fire Protection Asso ciation and the Occu ational Health and Safet Association standards.

Anthropometric design data has been incorporated into the display systems equipment and computers. This data deals with optimizing human, physical motion and perceptual capabilities relative to equipment control methods and sequences, motion and time manipulations, and display quality to, ensure efficient, accurate, and expedient use of essential display equipment.

In designing the TSC, the physical arrangement, interior, and environmental characteristics, communications, and protective/emergency systems specifi-cally incorporate good human factors engineering principles.

The physical layout is designed for optimum function grouping. Rooms and personnel are logically arranged according to work functions for an orderly flow and interaction of task to ensure efficient and expedient response for decision-making purposes. Adequate working area for personnel and equipment has been provided. The amount of partitioned and open plan work areas allow flexible use of space and personnel. Team functions are set up in open-plan areas with partitioned rooms having view windows where necessary for operational observation of work activities but main-taining privacy when required. Circulation patterns provide sufficient and convenient access to services and work areas.

1 39

The location of the TSC in a concrete structure provides seismic (earth-quake) protection in addition to direct radiation shielding. The interior features have been finis'hed suitable to an office environment. Finish surface colors are to be light in value,'lare free, and relatively neutral so as not to create visual contrast and confusion with surrounding display charts and equipment. Noise control has been utilized throughout to ensure proper acoustics. External noise is blocked by the dense con-crete envelope of the TSC. Built-in equipment has vibration isolation for air handling units, fans, pumps, piping systems, and ductwork to attenuate background noises. Partitions are sufficiently constructed and sealed to reduce sound transmission between. walls. Individual rooms and particularly large spaces have length, width, and height proportions that avoid long, narrow rooms with high ceilings which can cause objec-tionable reverberations (echoes). Speech, phones, movement of people, equipment printers, keyboard punching, and other internally-generated noise is dampened by continuous, absorbent acoustical ceiling system throughout the TSC.

The heating, cooling, and ventilation system is designed to provide com-plete habitability in the event of a release of airborne radioactivity from in-plant sources. A microprocessor<<based, programmable thermostat regulates constant air comfort for heating and cooling cycles. Humidity control is provided for both human comfort and optimum operation of essential computer equipment. Air within the TSC is maintained at a positive pressure to prevent any infiltration of contamination. 'uclear grade, high-efficiency particulate air (HEPA) and charcoal filter systems protect the TSC supply air from airborne radiation.

The electrical system provides a wide range of needs for the TSC. The major electrical needs are convenience outlets, mechanical systems, communications equipment, computer systems, and space lighting. Office area lighting is evenly distributed and maintains a minimum of 75 foot-candles with some work areas on a dimmer switch for light-level control.

Other light levels in the TSC are designed around IES-recommended stan-dards for each particular space use. Normal electrical system has an Emergency Back-up System in case of a loss of normal power.

Consideration was given to providing adequate communications equipment and procedures for expeditious interfacing, transfer of vital information, and problem solving. Automatic ring down (ARD) phones, for example, are provided from the control room to the TSC, from the TSC to the NRC, and offsite agencies which gives a hotline capability to key emergency response personnel for use if making prompt notifications of emergency conditions and possible recommendations for protective actions. Regular telephones are provided throughout work areas to ensure adequate numbers and location. Displays, in addition to the ERFIS/SPDS, were designed for the purpose of expediting the communication of vital information within the TSC, the plant, and the corporate office and enhancing command, control, and decision making. These large graphic displays include such examples as Time/Event Logs, Vital Equipment Out-of-Service, Organization/

Assignment Charts, Status Charts, and others. Displays took into consid-eration size, location, visibility, readability, accessibility, and need of data.

40

Protective/emergency systems have been incorporated to ensure habitability and reliability of the TSC. A smoke detection system has been incorporated to alarm in the event of smoke in the TSC. A fire sprinkler system protects the TSC in case of fire. A Halon system protects the communications equipment room. An automatic radiation detector at the air intake to the TSC will activate flow to the HEPA and charcoal filter system. The filter system has an integral fire alarm and deluge system to protect it in the event of fire. Portable radiation monitoring equipment will be maintained to determine continuous radiation dose rates and airbone radioactivity concentrations. The TSC maintains electronic card reader security system for entry and exit.

EP 0 AIR L~g c Q 0 AIR LQA CI c

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~HAPP- TSC- FURNISHINGS PLAN

((~END PG4NOARO OFFICE OEcK ANGL'E ~ESTRAL DESK SECRETARY. UNIT yV/ ISW OISPLAT WaITER ANO MOQEIII REFERENCE TA8I.E OFFICE, 5'5NIVEL CHAIR Q OFFICE, SIDE CHAIR SCDIICASE

I ILK CAIINET EIEELCASE SHELVES X)OueLE DOOR METAL STOIVGE CABINET

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~RO READER /PRINTER Q WATER COOLER COAT RACK 1-43

Four surveys have not been conducted in the assess-ment/reassessment phase because CR construction is not complete. Preliminary surveys will be conducted prior to fuel load to ensure that there are no gross inadequacies in these areas. Final surveys will be conducted prior to the first plant refueling outage.

The final surveys will provide the necessary information for an operational CR environment. The 4 surveys will be conducted per the following:

a. Ambient Noise Direct measurements of noise levels are taken and compared to individual guideline items.

b. Illumination Measurements are taken under various ambient conditions (e.g., emergency lighting) and are compared to individual guideline items.

c. Control Room Environment (HVAC) Assessments are made by direct measurement of the parameters listed below and comparison of the data to the NUREG-0700 guidelines:

Temperature Humidity Ventilation

d. Communications Communications systems are evaluated by guidelines, and speech intelligibility of communication modes is analyzed.

Survey data were collected from preconstructed task plans that contained checklists, interview forms and methods of direct measurements of CR parameters, such as noise levels, light levels, etc. The guidance for the conduct of the survey was found in NUREG-0700.

6-4 (0802NEL)

System Functions and Task Analysis (SFTA) The task analysis procedure is a descriptive process that extracts generic operator action and information requirements from systems function data, converts these requirements to a plant-specific level, and generates a data base for use as an input into the Verification of Task Performance Capabilities and the Validation of Control Room Functions.

These procedures consisted of 3 major activities, which were:

1. Converting the HP Basic Westinghouse Owners Group (WOG) System Review and Task Analysis (SRTA) into a "SHNPP-1 System Function Task Analysis." Refer to Figure 6-3 for a comparison between the SRTA and SFTA.

'he

2. Generating a list of plant-specific actions and information requirements for each task, organized by task in the form of a mechanized data base.

3. Selecting and sorting the data base so that the action requirements of a given type and the infor-mation requirements of a given type were collected together. "Type" refers to a group of actions or information requirements that have the same system, subsystem, plant components, and parameter.

6-5 (0802NEL)

Results A summary of some of the major findings from the operator interviews are listed below. Summary descriptions of the operator interview HEDs and the disposition of each HED are contained in Appendix A-17.

a. Workspace Operators reported the 'Cooling Tower Makeup Panel is inconveniently located. Because relocating the panel is cost prohibitive and an annunciator horn is available to alert the operators to the panel, no further action is required.

b. Anthropometrics Operators reported that the test pushbuttons on Light Boxes are located too high on the MCB. Because the pushbuttons are used for test purposes only, the operators will be instructed to use the ladder if they cannot reach the test'ushbuttons.

c. Emergency Equipment Operators reported that protective clothing is not available in all sizes.

All sizes will be available in the Control Room prior to fuel load.

d. Maintainability Operators reported that the ladder used for changing bulbs in Annunciator Light Boxes is inadequate. A new ladder will be provided when construction in the Control Room is complete.

Operators reported that there is no designated storage area for expendables and spare parts. A storage cabinet has been ordered and will be placed in the Control Room area when it is delivered.

6 ll (0802NEL)

e. Communications Operators reported that the communications link between the Control Room and the Radwaste Control Room is inadequate. A dedicated line between the Control Room and the Radwaste Control Room has been provided.

f. Annunciator System Operators reported that coordinated designators on the annunciator panels would aid the operators in locating annunciator tiles when going through procedures. Coordinate labels have been provided to all the annunciator light boxes.

Operators reported that there is no coding method used for annunciators to indicate which tiles will be on (illuminated) for extended periods such as equipment repair or replacement. A procedure will be put in place to code annunciators that will be on for extended periods of time.

g. Controls Operators reported that a potential for accidental activation exists for breaker controls on the startup XFMR protection panel. Guards will be provided around these controls.

6 l2 (0802NEL)

Operators reported that a potential for accidental activation exists for controls located at the lower edge of the benchboard. A guard rail has been added to the edge of the benchboard.

Operators reported that the containment spray pump test switches are seldom used and were not needed on the MCB. The controls are actual'ly the sequencer loading pump test and should be located on the MCB. The label has been changed to "Sequencer Containment Spray Test."

Operators reported that the knurled knob switches used as selector switches are inadequate. No replacement handle is available for the current modules. The knob pointer will be painted to make the switch position readily apparent. If a replacement knob becomes available, the knob will be replaced.

6 13 (0802NEL)

The 4 surveys that could not be conducted are those for:

1. Ambient Noise

2. Illumination

3. HVAC

4. Communications As stated previously, these surveys will be conducted on a preliminary basis prior to fuel load with the final surveys completed prior to the first refueling outage.

c. In order to facilitate data collection, reduction, and analysis, and to support the review documentation requirements, task plans were developed for each of the above. 14 survey areas.

Each of these task plans directed the data collection, data analysis and HED report generation based upon a mix of 4 basic data collection procedures. These are:

l. Measurements

2. Observations

3. Questionnaires/Interviews

4. Document Reviews Each of these task plans used one or more of these procedures to collect the data needed to evaluate the applicable area of CR design. Task plan organization and these procedures are explained in more detail in paragraph 6.4.2. (A sample task plan is provided in Appendix E).

6- 15 (0802NEL)

b. Bookcases, cabinets and drawer'torage areas were found to be adequate for the quantity of stock items required by the operators. Expendable supplies, spare parts, and tools are inventoried and restocked on a regular basis. Better storage facilities and additional expendables will be supplied as requirements expand.

Summary descriptions of the Maintainability Survey HEDs and the disposition of each HED are included in the operator interview HEDs, Appendix A-17.

6.3.3.6 Annunciator System Survey a0 The annunciator system survey design was compared to applicable guidelines, which addressed such items as readability of annunciator tiles, consistency of message content (such as abbrevi-ations and acronyms), and general arrangement features.

b. Viewing angles betweenfI 2 annunciator response stations and their associated tiles were found to be so acute that it was difficult to read the annunciator tiles. An additional response station has been installed. Other stations did not quite meet the 45 degree viewing angle requirement; however, tests conducted in the CR indicated that no difficulty was encountered in reading the extreme left and right tiles from these response stations.

6- 24 (0802NEL)

c. Tile messages were evaluated for multiple inputs, ambiguity, and specificity. Some problems in these areas were identified. The physical characteristics of engravings on annunciation tiles were evaluated for readability. Character heights, as a function of viewing distance and angles, did not meet the requirements. Spacing was inadequate between lines of engraving, especially for tiles containing 4 lines per message. Newly engraved tiles had letter heights too tall and stroke widths too narrow in comparison with the majority of the ALB tile engraving. These newly engraved annunciator tiles have been re-engraved to closely match the other ALB tiles.

Summary descriptions of the annunciator HEDs and the disposition of each HED are contained in Appendix A-20.

6.3.3.7

~ ~ ~ Controls Survey

a. The MCB control modules were evaluated for a number of characteristics such as knob configuration and dimensions, type of control, handle coding, and labeling.

b. The knurled style of knob used as selector switches is too short, uncomfortable and difficult to move.

The control module shaft torque is high (9 to 10 in-lbs) in relation to the maximum recommended torque of 6 in-lbs. Additionally, operators have complained about the difficulty of operating these controls. A marginally high torque reading associated with two t-handled controls was also 6- 25 (0802NEL)

c. Engraved indicator lights and bypass permissive status lights that contain more than 3 lines of text per light are difficult to read. The crowding of characters, words, and lines on these tiles cause the engraving to appear cluttered.

Investigation of the bypass permissive status lights determined that messages could not be reduced without reducing the meaning of the message.

Summary descriptions of the Display HEDs and the disposition of each HED are contained in Appendix A-22.

6.3.3.9 Labels and Location Aids Survey

a. The existing labels on the MCB were evaluated to determine if wording was appropriate, functionally correct and consistent. Criteria addressing the physical characteristics were not evaluated because of the repainting of the MCB, and the re-engraving and replacement of all board labels and demarcation.

b. Numerous discrepancies concerning labeling completeness, accuracy, and consistencies were identified. These problems are documented as HED reports. These reports, along with other operational and functional information, were used to update and correct new engraving lists. These lists, along with readability criteria, will be used to control the quality of the new labels.

6 27 (0802NEL)

Summary descriptions of the labeling HEDs and the disposition for each HED are contained in Appendix A-23.

6.3.3.10 SPDS and ERFIS Computer System Survey

a. The Computer System Task Plan, along with the applicable portions of the Anthropometrics, Controls, Displays, Labels and Location Aids, Conventions, and Maintainability Task Plans, was used in the evaluation of the SPDS and ERFIS computers. The features of the SPDS/ERFIS operator-software interface that were evaluated with the computer task plan were the physical characteristics of some display formats on the CRT.

b. Computer operating procedures and cross-referenced indexes for different methods of addressing data displays were not available I in the Control Room.

Computer procedures for use by the CR operators will be available in the Control Room prior to fuel load.

c ~ Function labels were missing for pushbuttons on the computer console. The use of abbreviations on legend light engravings was inconsistent with abbreviations used throughout the Control Room.

Labels have been provided or re-engraved as appropriate.

6- 28 (0802NEL)

d. The majority of text and graphics characters are presented in a 5 x 7 dot-matrix, rather than the recommended 7 x 9 size. This presents a discrimination problem on all trends and on some tabular data formats, as smaller symbols are used on some tabular data. Because operators view CRT screens from a position directly in front of the CRT and an optional size selection of a 10 x 14 dot-matrix for all characters is available, no further action is required.

e. As found in a number of procedures during validation, gpm units are used in places .to indicate flow that is displayed on the MCB in pph units. Units have been changed to reflect the same units as the MCB displays.

f. There is the ability for the operator to choose a function, such as "plot" from a menu of functions and plots. When the operator hits the return key the menu disappears, so the operator is expected to remember the acronym of the plot desired. The menu will be displayed until the function or plot has been selected.

g. Use of the color blue (as opposed to cyan) for trend displays was evaluated. The color blue for plotting is acceptable if another color is used for the legend or text. Blue should not be used for all items on a selected display or for text.

The use of blue will be avoided.

6- 29 (0802NEL)

Summary descriptions of the Computer Survey HEDs and the disposition of each HED are contained in Appendix A-24. The HEDs have been assessed, prioritized, and improvements verified per Section 7.0.

6.3.3.ll Conventions Survey

a. All annunciator tile engraving, panel labeling, component labeling, function labeling, and position labeling were compared to the CPSL "Dictionary of Acronyms and Abbreviations" as a means of identifying inconsistencies and incorrect usages with abbreviations.

b. The Conventions Survey also addressed shape coding and size coding for 'ontrol handles. The application of color coding in all areas of the Control Room and control directional movement with related display indicator movement was also addressed. Techniques used for the distinctive enhancement of emergency controls were verified.

c. Some inconsistencies were found in the use of abbreviations on annunciator tile and status light box engraving and component labels. 'nconsistent abbreviations on component labels and status light boxes have been corrected. Annunciator tile abbreviations were verified as being acceptable.

Summary descriptions of the Conventions Survey HEDs and the disposition of each HED are contained in Appendix A-25.

6- 30 (0802NEI)

process, selected guidelines from NUREG-0700 and criteria derived from the task analysis were used to determine the suitability of Control Room components. Such aspects of component design as the adequacy of display range, usability of displayed values, adequacy of control type, completeness and ease of understanding of component labels, and other characteristics not easily evaluated without reference to specific task sequences, were considered. Any deviations from established criteria were documented as HEDs.

6.6.4 Results 6.6.4.1 Verification of Availability

a. Using the SFTA data base that contains the action and information requirements and the Control Room inventory data base, a comparison was made to ensure the availability of all required instruments, controls, and other equipment in the Control Room.

b. RCS hot leg and cold leg Loop C temperature indicators were not on the MCB. These indicators have been installed on the MCB and are functional.

c. Main feedwater flow indication was missing from the MCB. These indicators were installed on the MCB and are now functional.

6.6.4.2 Verification of Suitability

a. Following the verification of availability, the inventory data base was compared to the range, accuracy, trend, nomenclature, and control function requirements contained in the SFTA data base.

6-41 (0802NEL)

b. The MSXVs and bypass valves, the FN isolation and bypass valves, the blowdown isolation valves, and the sample line isolation valves all have "closed" instead of "shut" on the position labels. These have been corrected.

c. The pressurizer pressure indicator, the SG Narrow Range level indicator, and the SG pressure indicators cannot be read to the degree of accuracy required. An engineering re-analysis of these values was performed to determine whether the values should be changed or the meter scales reconfigured. Appropriate procedures have been revised to reflect the changed values obtained from the re-analysis.

Summary descriptions of the Verification and Validation HEDs and the disposition for each HED are contained in Appendix A-26.

6-42 (0802NEL)

i. The analytical results were recorded in HED reports as required. These results are summarized in paragraph 6.7.3.

6.7.3 Results

a. In general, the Control Room equipment arrangement and the control panel layout were determined to be designed effectively to support the Control Room operating crew.

Discrepancies were identified concerning some missing indications and missing or inaccurate panel/component labels. These items are discussed in more detail below.

The majority of identified discrepancies, including most label-to-procedure terminology discrepancies were found to be 'procedure problems. Lack of required reference information, inconsistent terminology usage, and disagreement between panel labeling and procedure terms-were the primary problems encountered. The procedures have been corrected.

b. The instrumentation that was identified as missing was also identified during verification: RCS hot and cold leg Loop C temperatures and the main feedwater flow indicators. Also supporting the verification findings were the problems in reading the pressurizer pressure, steam generator narrow range level, and steam generator pressure indicators to the degree of accuracy stated in the procedures. As stated previously, missing instruments have been installed and the required values for the above-mentioned=parameters have been determined.

6-50 (0802NEL)

c. Arrangement difficulties were noted with the EDG instruments, with the turbine bearing and seal lube oil pump controls, and with the containment spray and Phase B isolation and reset controls. These problems have been corrected.

d. A number of minor labeling problems were identified.

These problems will be corrected prior to fuel load.=

Subsequent review of the new and revised engraving lists:

(see paragraph 6.3.3.9) indicated that these problems have been corrected on these lists.

e. During the walkthrough it became apparent that the operators were not using the ERFIS for trending and other indications. Post-walkthrough debriefings revealed a lack of emphasis for the ERFIS use in training. The local instrumentation, regardless of location, was predominately used instead of the ERFIS; the procedures also reflected this philosophy. HED reports were generated and sent to the appropriate areas of responsibility for correction.

6- 5l (0802NEL)

DCRDR DESIGN AREA NRC HEDs NRC NRC NRC PROBLEM DESCRIPTION PHOTO FINDING HED No. CP5L RESPONSE 3.0 ANNUNCIATOR WARNING SYSTEMS

3. 1 B453 "On the reactor and turbine First-out oanels. ther e is no oriorsti "ation scheme tor alarms other than red/white."

CP'~L response: Para. 6. 3. 1. 4a( ) oF 1.

0700 states that a r elatively smal 1 number oF levels (from 2 to 4) are r ecomarended. Two levels appear adeouate and also meets the CP <<L operat i no p hi 1 osophy oF minimi".ing d x f ferences between a ar ms in or der to d scour age 1

lax responses to any implied 'low pr i or i ty alarms. Additional ly, the F ir st-out alarms are physical ly separated fr om al 1 others whi ch essential ly af fords thr ee levels of prior ity: two-level color coding within the f irst-outs, and one-level of position codina between the f irst-outs and al 1 other s.

3~ 2 B458 "On al 1 panels, lar ge matrixes of annunc i ator 1 ights and status lights have no coordinate axis labels."

CPSL res onse: HED NO. 3100-2134

( Appendix A20-12) .

3. 3 B471 "On the annunciator visual alarm sub-system. cues For out-of -ser vi ce alarms are not olanned For."

CPS L response: HED NO. 3100" 2124

( Append ix A17- 0)~

3. 4 B463 "On the annunc gator resoonse subsystem, ther e is no coding of controls For easy r ccogniton."

C P,'~ L r es o ons e '-

HED NO. 3100 3421 (Appendix A21-12) .

E - 2

6 ~ 4 SYSTEM FUNCTIONS AND TASK ANALYSIS 6.4.1 Introduction The objective of the System Functions and Task Analysis (SFTA) was to determine action and information requirements and the performance criteria for the tasks that operators were required to accomplish under emergency conditions. These requirements and criteria served as benchmarks for the examination of the adequacy of Control Room instrumentation, and other equipment during the verification and validation activities.

'k 6.4.2 Method a ~ The procedure employed by CP&L in conducting the SFTA involved the development of a plant-specif ic task analysis data base from generic task analytic background information and generic emergency response guidelines.

Throughout this process, the emphasis was on identifying and analyzing operator action and information reouire-ments from the plant-specific task analysis.. It addressed those tasks performed under emergency conditions that provided emergency response capabilities with respect to maintaining critical plant safety functions (i.e.,

containment integrity, reactivity control, RCS inventory control, and heat transfer). The SFTA data is .currently being updated to include training requirements.

Figure 6-1 illustrates the general structure and organization of the SFTA process. The left blocks contain the background information and source documents used to develop the SFTA and EOPs. The central block of this figure contains a bullet item list that shows the sequence, f rom top to bottom, in which activities were conducted. The blocks on the right represent the 6-31

documents that resulted f rom the SFTA and EOP development.

The task analysis methods and procedures documented herein were based on the Westinghouse Owner's Group (WOG)

Emergency Response Guidelines (ERGs), Revision 1, and the WOG HP Basic System Review and Task Analysis (SRTA). The process as outlined in Figure 6-1 demonstrates that the starting point for the SFTA. will be the ERGs and associated background documentation.

b. The Revis'ion 1 WOG ERGs is considered a validated data base (NRC-WOG meeting of 29 Narch 1984) that defined the generic plant systems and functions, including the primary action/information requirements, and allocates f

the unctions between the human and the machine. The Revision 1 ERGs were used as the basis for the CP6L emergency response procedures development and the basis for the task analysis methods described below. The SRTA also served as a data base for the plant-specific Shearon Harris SFTA.

c. The WOG SRTA was a joint program with the ERG development program. It provided a systematic compilation of the operator tasks, instrumentation requirements (i.e.,

information requirements), and control capability requirements (i.e., action requirements) contained in the ERGs. The SRTA docum nts, which consisted of TASK/SYSTEM SEQUENCE NATRXCES and ELEHENT TABLES (see Figures 6-2 and 6-3), identified" the following:

Individual operator task requirements 2~ Sequential operator task requirements 3 ~ Individual information requirements (called instrumentation requirements in the SRTA) 6 - 32

4. Individual action reouirements (called control capability requirements in the SRTA).

d. There is a Task/System Sequence Matrix (Figure 6-2) for each ERG, and its function was to identify and inventory the tasks and subtasks associated with each ERG.

Essentially, the Task/System Sequence Matrices are tables of contents for each ERG.

e. The Element Tables (Figure 6-3) constituted the central document in the ERG SRTA program and the SHNPP-1 SFTA process.'hese tables identified the action and information requirements that must be addressed in determining the suitability and acceptability of Control Room equipment. Because of the dual application of these tables, there has been some confusion concerning the meaning of the following terms:

o Instrumentation Requirements o Information Requirements o Control Capability Requirements o Action Requirements o Task Action Requirements o Task Requirements Figure 6-3 clarif ies these terminology differences between the WOG SRTA and the SHNPP-1 SFTA. The WOG SRTA refers to information requirements as instrument requirements (i.e., those requirements which drive instrument selection) and 'refers to action requirements as control capability'equirements (i.e., those requirements which drive control selection). Additional confusion results from the SRTA Element Table header entitled "Task Action Requirements." This block of data contains the overall task requirements (i.e. the sequence 6 33

1 of activities or steps that must be accomplished for that task). The SRTA terminology is not the traditional behavioral terminology and has resulted in confusion and mis-interpretation of the SHNPP-1 SFTA process. The SHNPP-1 SFTA process used the correct behavioral terms for all SFTA-generated products. Initially, SRTA terms H

were retained on SRTA documentation with the explicit understanding of their behavioral meaning. As indicated in Figure 6-3, terminology on the SRTA (plant-specific adapted) element tables will be changed to the appropriate behavioral terms on any subsequent use of the SFTA process.

f. The first step in the SHNPP-1 SFTA process was to convert the HP Basic SRTA into a plant-specific revision. This document, called "SHNPP-1 System Function Task Analysis,"

consisted of plant-specific Task/System Sequence Matrix Tables (Figure 6-4) and Element Tables (Figure 6-5). The SHNPP-1 SFTA was based on the plant-specific emergency response guidelines, the EOP/ERG Transition Document, and related background information. Differences in tasks and task steps between the Rev. 1 ERGs to the SHNPP-1 SFTA are documented within the Transition Document.

The EOP/ERG Transition Document is contained within the Procedure Generation Package (PGP) . It tracks -the difference from the NOG ERGs to the plant-specific EOPs.

The Transition Document consists of the following sections:

1. List of differences between the ERG High Pressure reference plant and the Shearon Harris plant

2. Step deviation forms that explain any variance between an SHNPP-1 procedure step and a NOG step 6 34

t

3. Deviation for the parameter values used in the SHNPP-1 EOPs.

The SHNPP-1 Task/System Sequence Natrices (Figure 6-4) reflect task/step differences and sequence changes. The SHNPP-1 Element Tables (Figure 6-5) contain a description of the plant-specific tasks. Included in this description a re the plant-specif ic knowledge requirements, overall task requirements, task decision requirements, and the plant-specific information and action requirements. Note that Figures 6-4 and 6-5 refer to SHNPP-1'RG EPP-'5, step 15. This EPP and step is the example used throughout the remaining figures in this section. The purpose of EPP-5 step 15 is to determine if the accumulators should be isolated.

g. The next step in the SFTA process was to generate a list of plant-specific action and information requirements for each task within the SHNPP-1 SFTA. This information was tabulated on the Action-Information Requirements Details (AIRD) forms (see Figure 6-6). The AIRD forms break down each task into behavioral elements. A behavioral element is defined by the various behavioral or physical proper-ties of an action requirement or information requirement. The names of these properties appear as column headers for columns 2 through 10 of the AIRD form. Some of these properties were plant-specific and required input from plant operations/engineering personnel.

h. The development of the AIRD forms is a manual process of extracting just the operator action and operator information requirements from the element tables. The AIRD form, when filled out, (Figure 6-7) is used o~nl as an input form to a computerized function for sorting and 6 35

selecting these action and information requirements. It should be noted that at this point in the SFTA process these action and information requirements have been listed in a task-sequencing order. Related information requirements vill not be grouped together and related action requirements will not be grouped together. In the later and separate verification activities (Section 6.7),

this task-sequence listing would be difficult to compare to the control board inventory in evaluating the presence of and adequacy of the controls and displays. Hence, the next step in the SFTA process: development of the Action-Information Requirements Summary (AIRS) forms (Figure 6-8) .

The AIRS development is a computerized process that rearranges the action and information data from the AIRD forms. It does not add or delete any data, but rather re-sorts the action and information requirements from their existing task-sequencing order into a system-function-parameter order. In this way every occurrence of a given information requirement is grouped together and every occurrence of a given action requirement is grouped together. This is done for every system, sub-system, function, and parameter represented in the SHNPP-1 plant-specific ERGs. As an example, Figure 6-8 illustrates part of the requirements of EPP-S, step 15. The information requirement is to observe that RCS pressure is less than 1000 psig (Figure 6-8A). The action requirements are to close the accumulator isolation valves (Figure 6-8B).

It is at this point that the SFTA activities a~sthe contributed to the CRDR are considered complete.

6 36

As can now be seen, at no time during the development of the AIRD forms from ihe element tables to the outputting of the, AIRS listings has any control room equipment or control board component information been used. Also, neither step (AIRD or AIRS development) adds or deletes any operator action or operator information requirements.

j. Table 6-1 summarizes the relationships between the Element Tables, the AIRD forms, and the AIRS forms.

6.4.3 Products The product of the SFTA process is a data base of operator action and information requirements. This data base, along with the Control Room inventory data, base, was used as input into the verification of task performance capabilities to assess the availability and suitability of instruments and equipment used by the Control Room operators. In addition, the results of the SHNPP-1 SFTA were used to assist in the selec-tion of event sequences to be analyzed during the validation of Control Room functions.

6 37

6.5 CONTROL ROOM INVENTORY 6.5.1 Introduction

~ ~

The objective of the Control Room inventory was to develop a comprehensive listing of the instrumentation, controls and equipment contained in the Control Room. This list was used in subseouent tasks to determine the adequacy of Control Room components for supporting operator information and control requirements identified during the task analysis.

The Control 'Room inventory also aided in integrating multiple HEDs that could be associated with a particular component or type of component. This ensured a complete, integrated data file that aided in the implementation of backfits.

It should be noted that the Control Room inventory was kept up to date and reflects any component or label changes made in the Control Room. The inventory was also used to verify label, wording, and abbreviation consistency and served as the primary aid in the development of label engraving sheets.

6.5.2 Method Project personnel conducted a systematic inspection and review of the Control Room and relevant Control Room documentation (e.g., instrument lists, engraving lists, etc.) to develop the Control Room inventory.

The inventory records contain the following information for each component:

a. Component identification number (used for sorting within the date base) 6 38

b. ,Component nomenclature or description

c. Component labels

d. Component characteristics (i.e., scale ranges)

e. Panel.

6.5.3 Result The result of the Control Room inventory is a comprehensive record of the instrumentation, controls, and equipment contained in the Control Room. Tables 6 2 and 6 3 contain samples of the inventory printouts. The Control Room inventory was used in the'verification of available and suitable Control Room instrumentation.

6-39

6 ' VERIFICATION OF TASK PERFORMANCE CAPABILITIES 6.6.1 Introduction The objective of this activity was to ensure the availability and suitability of required Control Room instrumentation and controls. As recommended in NUREG-0700, this activity was conducted in two parts: verification of availability and verification of suitability. After the completion of the verification and validation activities, identified problems were documented on HED reports. The plant-specific instruments and controls from the inventory that satisfied the action and information requirements from the AIRS forms were also added to the element tables as shown in Figure 6-9. Copies of these element tables function as historical documents which 'define the baseline rationale for the selected instruments and controls.

6.6.2 Verification of Availabilit Verification of availability was accomplished by comparing the operator action and information requirements identified during the task analysis to the Control Room inventory. The compari-son was conducted on a component basis to verify the presence or absence of the required instruments and controls for each task sequence analyzed, during the SFTA. For any action or information requirement where an appropriate display, control, or other device could not be found, an HED report was generated.

6.6.3 Verification of Suitabilit Verification of suitability involved examination of the human engineering characteristics of instrumentation and controls identified during the verification of availability. For this 6-40

process, selected guidelines from NUREG-0700 and criteria derived from the task analysis were used to determine the suitability of Control Zoom components. Such aspects of component design as the adequacy of display range, usability of displayed values, adequacy of control type, completeness and ease of understanding of component labels, and other character-istics not easily evaluated without reference to specific task sequences, were considered. Any deviations from established criteria were documented as HEDs.

6.6.4 Results 6.6.4.1 Verification of Availability

a. Using the SFTA data base that contains the action and information requirements and the Control Room inventory data base, a comparison was made to ensure the availability of all required instru-ments, controls, and other equipment in the Control Room.

b. RCS hot leg and cold leg Loop C temperature indicators were not on the HCB. These indicators will be installed on the HCB and functioning prior to fuel load.

c. Hain feedwater flow indication was missing from the HCB. These indicators will be installed on the HCB and functioning prior to fuel load.

I 6.6.4.2 Verification of Suitability

a. Following the verification of availability, the inventory data base was compared to the range, accuracy, trend, nomenclature, and control function requirements contained in the SFTA data base.

6-41

b. The 51SIVs and bypass valves, the FW isolation and bypass valves, the blowdown isolation valves, and the sample line isolation valves all have "closed" instead of "shut" on the position labels. These will be corrected prior to fuel load.

c. The pressurizer pressure indicator, the SG Narrow Range level indicator, and the SG pressure indicators cannot be read to the degree of accuracy required. An engineering re-analysis of these values is currently in progress to deter-mine whether the values will be changed or the meter scales reconfigured. Whichever is required will be accomplished prior to fuel load, except for the case where obtaining the actual value is dependent upon actual system operations to obtain stable and final performance measures.

Summary descriptions of the Verification and Valida-tion HEDs and the disposition for each HED are contained in Appendix A-26.

6 42

6.7 VALIDATION OF CONTROL ROOl1 FUNCTIONS 6.7.1 Introduction

a. The objective of this activity was to determine if the functions allocated to the Control Room operating crew during emergencies could be accomplished effectively within: 1) the structure of defined emergency procedures, and 2) the design of the Control Room as it exists. As with verification of task performance capabilities, validation of Control Room functions is an extension of the SFTA. In this case, emphasis was placed on determining the adequacy of the Control Room design for supporting operator task sequences.

b. A set of emergency-related scenarios were prepared from the SFTA data base, and walkthroughs/talkthroughs were performed with control room personnel and trained observers. HEDAT members were included in both categories of personnel. Walkthroughs and talkthroughs consisted of simulating event sequences in the control room and analyzing event sequences in table-top exercises. Development of the 'vent sequences and the methodology used followed the guidance of NUREG-0700, Section 3.8. The sequence of validation activities were as follows:

1. Scenarios were defined and established.

2. SHNPP-1 emergency procedures were obtained.

3. Walkthrough/talkthrough,procedures were developed and validation personnel were instructed.

4. Walkthrough/talkthroughs were conducted.

6-43

5. Recorded data were analyzed and results documented.

6.7.2 Method 6.7.2.1 Selected Events

a. Events were selected to include the items suggested in NUREG-0700, paragraph 3.8.2, and to address events listed in Section 15 of REG. GUIDE 1.70 with regard to exercising all emergency-re-lated Control Room workstations, and to include all unique sequences of tasks within the EOP structure. These events covered all systems in the EOPs and all instruments and controls used in the EOPs.

b. The events selected were the following:

1. Reactor Trip

2. Loss of AC Power with SI Required

3. Reactor Trip with Void in the Reactor Vessel

4. Reactor Trip with Faulted Steam Generator

5. Reactor Trip with Loss of Secondary Heat Sink

6. Anticipated Transient without Scram and Recovery

7. Response to Steam Generator High Level 6-44

1 pr,

8. Loss of Normal Steam Release Capability

9. Response.to Steam Generator Low Level

10. Response to Inadequate Core Cooling ll. Loss of Core Shutdown

12. Steam Generator Overpressure

13. Response" to Imminent Pressurized Thermal Shock Conditions

14. Response to Containment High Pressure.

15. Loss of Emergency Coolant Recirculation

16. SGTR (As a followup to faulted Steam Generator Analysis)

a. Post-SGTR Cooldown Using Backfill

b. Post-SGTR Cooldown Using Blowdown

c. Post-SGTR Cooldown Using Steam Dump

d. SGTR With Loss Of Reactor Coolant:

Subcooled Recovery

e. SGTR With Loss Of Reactor Coolant:

Saturated Recovery

f. SGTR Without Pressurizer Pressure Control 6-45

17. Uncontrolled Depressurization Of All Steam Generators

18. Transfer To Hot/Cold Leg Recirculation

19. Post LOCA Cooldown And Depressurization

20. LOCA Outside Containment

21. SGTR Isolation

22. Response To Containment Flooding

23. Response To High Pressurizer Level

24. Response To Nuclear Power Generation/ATWS

25. Response To High Containment Radiation Level

26. Response To Loss Of Secondary Heat Sink 6.7.2.2. Emergency Operating Procedures (EOPs)

The SHNPP-1 EOPs were used to direct all operator actions during the walkthrough/talkthroughs. The procedures used included all Emergency Plant Procedures (EPPs) and all Functional Restoration Procedures (FRPs) needed to exercise the emergency-related instruments and controls.

6 46

6.7.2.3. Walkthrough/Talkthrough Procedures

a. The event scenarios were separated into two groups which were:

1. Those events which emphasized operator interactions, traffic patterns, .and general workstation use. These events were also selected to include at least 80% of all emergency-related instruments and controls (actual percentage was 87%). This group included those events numbered 1 through 14 in paragraph 6.7.2.1.

2. Those events that exercised the remaining 13% of the instruments and controls. This group included those events numbered 15 through 26 in paragraph 6.7.2.1.

b. The first group of events was scheduled for control room walkthroughs and talkthroughs. The second group of events was scheduled for table-top walkthroughs and talkthroughs.

c. All participants in the validation process were briefed on the objectives and instructed on the procedures.

Participants were divided into two primary groups; those performing operator functions and those observing the walkthroughs and talkthroughs.

d. Operator participants were instructed to describe all actions performed during the scenarios. This included the following:

6-47

1. cues by which they initiate a task

2. sources of information (displays, procedures, knowledge, etc.)

3. application of information, including any mental conversions or uncertainties

4. controls selected and expected system response

5. methods for verifying system response and selection of alternative actions if response is not obtained

6. indications that sequence is proceeding as expected

7. indication that sequence is complete

8. other comments, as appropriate.

e. Observers were instructed to record the following:

l. Operator interactions

2. Operator movements (traffic patterns)

3. General flow of task sequences

4. Operator workload and time stresses

5. Any observed problems concerning component location and identification 6 48

6. Any observed problems concerning component usage (e.g. difficult to determine appropriate control action or cannot read value specified in procedures) .

7. The 'impact on operator performance of any previously identif ied HEDs or any additional HEDs identified during the walkthrough/talkthrough

f. Walkthrough/talkthroughs in the control room consisted of first reviewing the scenario to be conducted, including assumptions concerning plant status and the initiating event for that scenario, and then performing the specificed precedural activities. During the walkthroughs, the observers were allowed to halt the activities to obtain clarification or additional information.

g. Table-top walkthrough/talkthroughs were conducted using a complete, updated set of control panel drawings, a control room layout drawing, and the appropriate EPPs and FRPs. Performance of these activities were similar to that described in f., above.

h. All recorded data were analyzed to identify any concerns with operator performance in terms of:

l. Operator difficulty in responding to an event

2. Impact of previously identified HEDs

3. Identification and impact of any new HEDs 6 49

i. The analytical results were recorded in HED reports as required. These results are summarized in paragraph 6.7.3.

6.7.3 Results

a. In general, the Control Room equipment arrangement and the control panel layout were determined to be designed effectively to support the Control Room operating crew.

Discrepancies were identified concerning some missing

.indications and missing or inaccurate panel/component labels. These items are discussed in more detail below.

The majority of identified discrepancies, including most label-to-procedure terminology discrepancies were found to be procedure problems. Lack of required reference information, inconsistent terminology usage, and disagreement between panel labeling and procedure terms were the primary problems encountered. The procedures are currently being corrected.

b. The instrumentation that was identified as missing was also identified during verification: RCS hot and cold leg Loop C temperatures and the main feedwater flow indica-tors. Also supporting the verification findings were the problems in reading the pressurizer pressure, steam generator narrow range level, and steam generator pressure indicators to the degree of accuracy stated in the procedures. As stated previously, missing instruments will be installed prior to fuel load, and the required values for the above-mentioned parameters will be resolved either by fuel load or, in the case of design necessity, as soon as operational system data is available.

6 50

c. Arrangement difficulties were noted with the EDDG instru-ments, with the turbine bearing and seal lube oil pump controls, and with the containment spray and Phase B isolation and reset controls. These 'problems will be corrected prior to fuel load.

d. A number of minor labeling problems were identified.

These problems will be corrected prior to fuel load.

Subsequent review of the new and revised engraving lists (see paragraph 6.3.3.9) indicated that these problems have been corrected on these lists.

e. During the walkthroughs it became apparent that the operators were not using the ERFIS for trending and other indications. 'ost-walkthrough debriefings revealed a lack of emphasis for the ERFIS use in training. The local instrumentation, regardless of location, was predominately used instead of the ERFIS; the procedures also reflected this philosophy. HED reports were generated and sent to the 'appropriate areas of responsibility for correction.

6 51

RE 6-1 SYSTEM FUNCTION AND TASK ANALYSIS (SFTA) PROCESS

%)Q EMERGENCY

RESPONSE

CUIDKUNXH IDENTIFY SYSTEMS EhERGENCY RKK I OPERATING PRO CEDUREB 0 DEFINE FUNCTIONS

%)G BACKGROUND DOCUlGM'P 0 DEFINE FUNCTIONAL VERSION ALLOCATIONS ADMIONAL PROCEDURES 0 DEVELOP TASKS: DRVHQP1OKI'CTIVI SHNPP FEAR task desoription RES and other SHNPP doo's as re@'d lcno~ge requirements SHNPP-1 sldlls requlraInents PLANT-SPECIFIC K)G SYSTEM aotion reAIuirements REVIEW AND information raquirements TASK ANALYSIS 0 DEVRXOP YRITER'S GUIDE SFI'A OUTPUT 0 D&'EMP ZZZh9XT TABLES EOP/ERG TRANSITION DOCUBEST REFEI6ZCE PLANT-SPECIFIC generate generio tables DOCUMEFIS ENGINEER1NG ANAL'fSIS from ERGs ocnvart to plant speoi5o (set point study) 0 DEYEIDP AIRD FORMS 1BXhAEBT TABLES RG 1.97 k NUIKGs eztraot aotion and 0700, 07S7, 0801 information requirements from element tabies ADD1110NAL CRDR SIGhLRON HARIGB 0 DEVZMP AIRS FORMS ACTION-QQQRMATION ACTIVITY

SUMMARY

HEQUIRI5GQVS DETAES 41TRsgO INBAEo REPORT (MARCH, 1986) ~uhemeuhs by paraawter auk eErasee I&0?TGLUccl reAIsIEtoellts by paaameter

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FIGURE 6-3 AN EXPLANATION OF THE CONFUSING DATA HEADERS USED ON ELEMENT TABLES P- SPTA P~nnot on

-'ask-f This section defines the task information requirements as contained in the WOG SRTA. To eliminate confusion, the term "Instrument" is being changed to the term "Information" on later versions of this form.

ask Dec s on r ter a R u e nts This section lists the owl eu mns total task activities as sk defined in the WOG ERGs.

To eliminate confusion, the term "Action" is being deleted from the Inst te r header and the block of as ument C a u me s information is being moved in front of the Task Decision Requi rements block.

as Ac i n r t u m s This section defines the task information ask ontrol Ca ab lt C r a R u ements requirements as contained in the WOG SRTA. To eliminate conf us ion, the terms "Control Capability" are being nse uenc s of Task 8 o ission changed to the term "Action" on later versions of this form.

6 54

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FIGURE 6-5 EXAMPLE OF ELEMENT TABLE FOR EPP-5 STEP 15 EBRSI1RB - NOnitOr/Regulate RCS Pressure and Tespcrature TR85 - check If sl Accunulators should Be Isolated TlaLSRimtlxt o To deternine if appropriate plant conditions exist for NOTE isolating SI accunulators I

Refer to Figure 6-3 for o To deteraine if RCS pressure is less than the rcguircd value to perait sl sccunulators to be isolated {RCs pressure less the Clarification of than 1000 psigl various header terminology o Rcquirencnts for isolating SI accunultors o Beans to isolate SI sccunulators o Nide range RCs pressure Indication>

o Accuaul stot isolation valves position Indicationi o Accunulator isolation valve pover supply Indication>

o Accunulator vent valve position Indicationt 15 Check If SI Accunulators Should Be Isolated>

RCS pressure - LESS TRAN 1000 PSIC Continue vlth step 16. ~ RCS prcssure is less than 1000 PSICr TSQ Perforn stePs 15bc c, and d Close SI Accunulator isolation valve breakers'

~ Close SI Accunulator isolation valvesr 8808A 88088 8808C vent any unisolated accunulators vhil~

continuing vith this procedure Open SI Accusulator isolation valve breakers o Accuaulator isolation valve svltchcs>

o Accusulator isolation valve breaker controlss o Accuaulator vent valves svitchcs>

o Task error/onission vill result in presature lockout of the SI Syaten uhen RCS Preaaure I ~ gfe ~ ter then 1000 Paigr presaturely defeating St systen operation.

o Task error/onission nay result in failure to lock out SI systen vhen RCS pressure ls less than 1000 psigi potentially resulting in delivery of accunulator contents into the RCS and cosplicating plant recovery. If SI pusps ~ re not locked out vhen RBR systen I ~ in operation, inadvertent SI pusp actuation

~ ay result in RCS cold overpressurisation.

6-60

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FIGURE 6-8 EXAMPLES OF AN INFORMATION AIRS AND AN ACTION AIRS FIGURE 6-8A INFORHATION AIR& (VERB, COL 4 IS OBSERVE)

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TABLE 6-1 ~

A CONPARISON OF THE ELENENT TABLES. THE AIRD FORNS. AND THE AIRS FORNS El ENENT TABLES AIRD FORNS AIRS FORNS LINEE

~ CONTAINS A LISTING ~ CONTAINS A LISTING ~ CONTAINS A LISTING OF ACTION (CONTROL) OF ACTION (CONTROL) OF ACTION (CONTROL)

AND INFORMS T ION AND INFORMATION REQUIREMENTS BY REQUIREMENTS SORTED REQUIREMENTS SORTED PARAMETER AND A LIST BY BEHAVIORAL TASK SY PROCEDURE GUIDE- ING OF INFORMATION REQUIREMENTS BY PARAM TER 0 ALSO CONTAINS THE 0 CONTAINS PARAMETRIC 0 CONTAINS THE REQUIRED TASK DESCRIPTIONS lNFORMATION (I eEe i. RANGE OF VALUESi LONG KNOWLEDGE REQUIRE- PARAMETER t VALUEi OBSERVATION TIMES (IF fKNTSi AND SKILL DIRECTION OF VALUE APPLICABLE)r AND THE REQUIREMENTS N)VEMENTi ETCe ) REQUIRED PRECISION FOR ALL NOTED VALUES i ACTS AS AN HISTOR-lCAL DOCLNENT AND t 1S AN INTERMEDIATE STEP IN EXTRACTING 0 PRIMARY DATA SOURCE .

USED DURING CRDR VERIFI-A CENTRAL LOCATION THE ACTION AND IN- CATION TO EVALUATE THE FOR TASK PERFORMANCE FORMATION REQUIRE- CR INVENTORY FOR PRESENCE INFORMATION s AFTER IKNTS THAT THE CR OFi AND ADEQUACY OF ALL CRDR VER IF I EQUIPMENT MUST MEETe CONTROLS AND DISPLAYS CATION'ELATED CONTROLS AND INSTRUMENTATION ARE ADDED 6 66

TABLE 6-2 Page 02-19-1986 SHEARON HARRIS CONTROL ROON INDICATIOHS PAHEL ID LBL 4 EXT NRNE ~

. UNITS A2 2201? 143 LP LTDN TENP 50-200 DEB F R2 22031 Pl 8910 PjlPS DISCH PRESS 0-150 PSIB A2 22040 Tl 463 PORV LINE TENP 50-400 DE6 F A2 23005 PCV 444C PRESSURIZER SPRAY/LOOP A/VLV PCV-IIIC POSITION A2 23006 PCV 444D PRESSURIZER SPRAY/LOOP 8/VLV PCV-444D POS IT IOH A2 22051 Tl 453. 1 PRZ LIQUID TENP 10-70 DE6 F I 10 A2 22041 Pl 445. 1 PRZ PRESS 170-250 PSI6 X 10 A2 22039 Pl 444 PRZ PRiSS 170-250 PS16 X 10 A2 22048 TI 454.1 PRZ VAPOR TENP 10-70 DEB F I 10 A2 22036 Pl 156A1 RCP R SEAL D/P 0-400 PSID A2 22033 Fl 130A RCP A SEAL, MATER FLOM 0-20 6PN A2 22037 PI 155AI RCP B SEAL D/P 0-400 PSID A2 22034 Fl 127A RCP B SEAL MATER FLOM 0-20 6PN R2 22038 Pl 154A1 RCP C SEAL D/P 0-400 PSID A2 22035 Fl 124A RCP C SERL MATER FLOM 0-20 6PN A2 27001 RCS BOPON A2 22059 Pl 402A RCS NARROM RANGE PRESS 0-700 PS16 A2 22026 Tl 123 RE6EN HX CHARB OUT TENP 100-600 DE6 F A2 22013 Tl 140.1 REBEN HX LETDH 100-600 DE6 F R2 22015 Tl 111 RELF LINE TENP 50-350 DE6 F A2 22065 Tl 171.1 RELIEF TANK TENP 50-350 DE6 F R2 22063 LI 470.1 RELIEF TK LEVEL 0-100 PERCENT h? 22064 Pl 172.1 RELIEF TK PRESS 0-120 PSIB IA2 220I2 Tl 165 SFTY LINE TEMP 50-400 DE6 F h? 22044 TI 167 BFTY LINE TENP 50-100 DEB F A2 22046 Tl 169 SFTY LINE TENP 50-400 DE6 F R? 22032 LI e9018 SB STORA6E TK LEVEL 0-100 PERCEHT A2 22030 LI 8901R SA STORA6E TK LEVEL 0-100 PERCENT A2 22052 TI 150.1 SUR6E LIIIE TEllP 10-70 DE6 F X 10 A2 22017 LI 115.1 VCT LEVEL 0-100 PERCENT 12 22019 Tl 116.1 VCT OUT TENP 50-300 DE6 F A2 22018 Pl 117.1 VCT PRESS-VACUUN 0-100 PSI6-INCHES Hg A2 22055 PI 102. 1 SA MIDE RAHBE PRESS 0-300 PSIB I 10 A2 22053 Pl 403.1 SB MIDE RAHBE PRESS 0-300 PSIB X 10 A2 22062 Pl 141 MIDE RANGE PRESS 0-3000 PS16 A2 220I9 Pl 140 MIDE RAHGE PRESS 0-3000 PS16 AA 22013 Ll '922 ACCUNULATOR TK A LEVEL 0-100 PERCENT AA 22011 LI 920 ACCUNULATOR TK A LEVEL 0-100 PERCENT RA 22012 Pl 921 ACCUNULATOR TK A PRESS 0-800 PS16 AA 22014 PI 923 ACCUNULATOR TK A PRESS 0-800 PS16 AA 22015 LI 924 ACCUNULATOR TK B LEVEL 0-100 PERCENT RA 22017 Ll 926 RCCUNULRTOR TK 8 LEVEL 0-100 PERCEHT AA 22018 Pl 927 ACCUllULATOR TK 8 PRESS 0-800 PSI6 AA 22016 Pl 925 ACCUNULATOR TK B PRESS 0-800 PSI6 AA 22019 Ll 928 ACCUNULATOR TK C LEVEL 0-100 PERCEHT AA 22021 LI 930 ACCUNULATOR TK C LEVEL 0-100 PERCENT AA 22020 PI 929 ACCUNULRTOR TK C PRESS 0-800 PSI6 AR 2202? Pj 931 ACCUNULRTOR TK C PRESS 0-800 PS16 RA 23005 ISI 246 SA ACCUNULATORS A/DISCHAR6E VLV/161-246 SA POSITION 6-67

TABLE 6-3 h 0

Page 5 02-19-1986 SHEAROK HARRIS CONTROL ROD)i CONTROLS PAHEL ID NRklE POSIT IOHS A2 32059 REACTOR tlRKE UP/MATER PU)IP/8 STOP/AUTO/START {J)

R2 32011 REACTOR TRIP TRIP (J)

A2 32075 RN RRB HEADER ISOL/IPtl-60 SHUT/OPEN {T)

R2 32077 RklM TO NPB,CNklT, 6/BORON RECYCLE SYS/IPN-30 SHUT/OPEN (I)

A2 32060 Rt(M TO/BORIC ACID BLEHDER/FCV-114B SHUT/AUTO/OPEN (T)

A2 32087 RN TO/PPT/1RC-161 SHUT/OPEN (T)

A2 32068 RtlM TG/PRT/IRC-167 SHUT/OPEN (T)

A2 32062 Rtlii/CONTROL STOP/START (J)

A2 32058 Rt{M/t{ODE/SELECTOR OFF/AUTO/HAH BOR DIL ALT DIL {K)

A2 31012 RN!(U/FLOik/ICS-151 t(RN/OUTPUT I 6ETPOIKT/AUTO A2 32042 SUCTION FROkl RHR/HEAT EXCHAN6ER A-SA/IRH-25 SA SHUT/OPEK (T)

A2 32048 SUCTION FRON RHR/HEAT EXCHAN6ER 8-SB/IRH-&3 SB SHUT/OPEN (I)

A2 32031 SUCTION FROk{/RNST/LCV-1158 SHUT/OPEH (T)

A2 32036 SUCTION FRON/RNST/LCV-1158 SHUT/OPEN (I)

A2 32037 SUCTION HERDER/CROSS CONHECT/ICS-168 SB SHUT/OPEH (I)

A2 32043 SUCTION HEADER/CRDSS COHHECT/ICS-1&9 SA SHUT/OPEN {T)

A2 32032 SUCTION HEADER/CROSS CONNECT/ICS-170 SA SHUT/OPEN (T)

R2 32049 SUCTION HEADER/CROSS COHHECT/ICS-171 SB SHUT/OPEH (T) h2 31009 VCT/LEVEL/LCV-115A NAK/OUTPUT/SETPOINT/AUTO A2 32023 VCT/OUTLET/LCV-115C SHUT/OPEN {T)

A2 32024 VCT/OUTLET/LCV-115E SHUT/OPEK (T)

A2 32025 VCT/VEHI/ICS-131 SHUT/OPEN (T) hh 32019 hCCU)(ULATOR A/CHECK VALVE TEST/1SI-255 SHUT/OPEN (T) hh 32031 ACCUt{ULATOR A/DISCHAR6E/ISI-246 SA SHUT/OPEK (T) hA 32023 ACCUtlULATOR 1/FILL/151-186 SHUT/OPEK (T)

AA 32033 ACCUHULATOR A/K2 SUPPLY 6 VENT/IS1-295 SHUT/OPEN (T) hA 32025 hCCUNULATOR B/CHECK VALVE TEST/ISI-257 SHUT/OPEN (T) hA 32034 ACCUklULATOR B/DISCHAR6E/ISI-247 SB SHUT/OPEN (T) hA 32024 ACCU((ULATOR 8/F ILL/IS I-187 SHUT/OPEN (I)

AA 32035 hCCm{ULATOR BIH2 SUPPLY 4 VENT/151-296 SHUT/OPEN (T) hA 32029 ACCU)lULATOR C/CHECK VALVE TEST/1SI-259 SHUT/OPEK (T)

AA 32028 ACCUtlULA70R C/FILL/IS I-188 SHUT/OPEN {T)

AA 32021 ACCU){ULATOR CHECK/VALVES TEST RETURK/ISI-263 SHUT/OPEK (T)

AA 32022 RCCUk(ULRTOR CHECK/VALVES TEST RETURN/161-264 SHUT/OPEN {T)

AA 32027 ACCUNULATOR FILL/FRON RNST/1SI-17'9 SHUT/OPEH {T)

AA 32032 ACCUNULATORS  % PRZ/PORV H2 SUPPLY/161-287 SHUT/QPEH (T)

AA 32009 CHt(T ISOL PHASE B/TRAIN A/RESET RESET (J)

RA 32013 CHklT ISOL PHASE 8/TRAIN B/RESET ,RESET (J)

AA 32012 CN!(T SPRAY CHEtllCAL/ADDIT IOH/1CT-'l l SB SHUT/OPEN {T!

AA 32005 CKtlT SPRAY CHEt{ICAL/RDDITIOH/1C7-12 SA SHUT/OPEN (T)

AA 32004 CHkll SPRAY PUNP A-SA/DISCHAR6E/1CT-50 SA SHUT/AUTO/OPEH (T)

AA 32008 CNtlT SPRAY PUHP A-SA/RECIRC/1CT-47 SA SHUT/OPEK {T)

AA 32016 CKNT SPRRY PUNP B-SB/DISCHARGE/1CT-88 SB SHUT/AUTO/OPEH (T)

AA 32018 CHNT SPRAY PUMP B-SB/RECIRC/ICT-95 SB SHUT/OPEN {I)

RA 32010 COHTRINk(EKT SPRRY/EDUCTOR TEST/1CT-24 SA SHUT/OPEN (T)

AA 32011 CONTAINI{EHT SPRAY/EDUCIOR TES7/ICT-25 SB SHUT/OPEN (T)

RA 32003 CONTAIHNFHT SPRAY/PUHP/A-SA STOP/AUTO/START {J)

RA 32015 CONTRIHk{EHT SPRAY/PUk{P/8-SB STOP/AUTO/START {J) 3200) COKTRINklEHT SPRAY/TRAIN A/RESET RESET (J!

6 6S

FIGURE 6-9 LEN NT TABL TASK P- /15 HNPP REV I I N

~unu t n - pont ter/Regulate RCS p/ ennure and Tenperatura Iaak - Check If SI Accumulators Should Be Isolated ask Ob ec ive

.o To determine if appropriate plant conditions exist for isolating S I accumulators a k Decision Cr teria) Re u r ment o To determine to permit if RCS SI accumulators pressure to is less than the required value be isolated (RCS pressure less than 1000 ps ig )

ask n w ed e Re u r men o Requirements fdr isolating SI accuaultors o Means to isolate SI accumulators n r men ) ur me RCSI5 o Wide r ange RCS pressure indications ARCS PRESSURE)

WIDE RANGE PRESS PI 403. I SB CRCS PRESSURE)

WIDE RANGE PRESS PI 402 ~ 1 SA CRCS PRESSURE3 MIDE RANGE PRESS PI 440 CRCS PRESSURE3 WIDE RANGE PRESS PI 441 (RCS TENP/PRESS3 PR 402 6 69

FIGURE 6-9 continued NT E ~K~P-5/15 HNPP R V ION SII8 o Accumulator isolation valves position indication:

L'DISCHARGE ISOLATION)

ACCUMUL4TOR A DISCHARGE ISI-246 SA (8808A)

(DISCHARGE ISOLATION)

ACCUMUL4TORS 4 DISCHARGE VLV ISI-246 SA POSITION (8808A)

CDISCHARGE ISOLATION)

ACCUMULATOR B DISCHARGE ISI-247 SB (8808B)

CDISCHARGE ISOLATION)

ACCUMULATORS B DISCHARGE VLV 1SI-247 SB POSITION (8808B)

CD ISCHARGE ISOLATION)

ACCUMULATOR C DISCHARGE ISI-248 SA (8808C)

(DISCHARGE ISOLATION)

ACCUMUL4TORS C DISCHARGE VLV ISI-248 SA POSITION (8808C)

SII9 o 4ccumulator isol'ation valve power supply indication(

CDISCHARGE ISOLATION)

ACCUMULATORS A DISCHARGE VLV ISI-246 S4 POSITION (8808A)

ID ISCHARGE ISOLATION'CCUMULATORS B DISCHARGE VLV 181-247 SB POSITION (8808B)

ID ISCHARGE ISOLATION)

ACCUMULATORS C DISCHARGE VLV ISI-2IB 54 POSITION (8808C)

SII10 o Accumulator vent valve position indicationr ACCUMULATOR A N2 SUPPLY (c VENT 1SI-295 (88754)

ACCUMULATOR B N2 SUPPLY 5 VENT ISI-296 (88758)

ACCUMULATOR C N2 SUPPLY (c VENT 1SI-297 (8875C)

Ta k n ( r r a) u rem

15. Checl'f SI Accumulators Should Be Isolated i

a. RCS pressure - LESS THAN 1000 PSIG 6 70

FXGURE 6-9 continued Jf5h~(~/1 HNPP EV N 1 Continue wi th step 16. ~WH N RCS pr essure is less than 1000 PSIG, THEN perform steps 15b, c, and d

b. Close SI Accumulator isolation valve breakers c~ Close SI Accumulator isolation valves>

8808A 8808B 8808C Vent any un i so lated accumulators while continuing with this procedure d ~ Open SI Accumulator isolation valve breakers b

SIC5 o Accumulator isolation valve switchest IDISCHARGE ISOLATION)

ACCUHULATOR A" DISCHARGE ISI-246 SA (8808A)

KDISCHARGE ISOLATION)

ACCUNULATOR B DISCHARGE 181-247 SB (88088)

CD ISCHARGE ISOLATIONI ACCU((ULATOR C DISCHARGE IS 1-248 SA (8808C)

SIC6 o Accumulator isolation valve breaker controls:'OCAL SI C7 o Accumulator vent valves svitchesi ACCUMULATOR A N2 SUPPLY I VENT 1SI-295 (8875A).

ACCUHULATOR B N2 SUPPLY h VENT 1SI-296 (8875B)

ACCUMULATOR C N2 SUPPLY 5 VENT 1SI-297 (8875C) 6 7l

0' FIGURE 6-9 continued JfiSK~PP~/15 HNPP R VISION o uen sk r or/ ~I i o Task error/omission wi ll result in premature lockout of the SI system when RCS pressure is greater than 1000 psig, prematurely defeating SI system operation.

o Task error/omission may result in failur e to lock out SI system when RCS pressure is less than 1000 psi g, potentially resulting in delivery of accumulator contents into the RCS and complicating plant recovery. If SI pumps are not locked out when RHR system is in operation, inadvertent SI pump actuation may result in RCS cold overpressurixation.

6 72

SECTION 7.0 ASSESSMENT AND DESIGN SOLUTIONS

7.1 BACKGROUND

The HED process, as outlined in Figure 7-1, consists of the following major elements:

a ~ HED is generated and then reviewed/assessed by the HEDAT

b. Corrective actions are developed c~ Corrective actions are initiated and performed under FCR/DCNs

d. HED is closed This process is described in more detail in the following sections and was followed for each HED. Each HED was fully documented and tracked through the system by the Site Project Coordinator.

7 1

7.1.1 Method used for recordin HEDs HEDs are recorded on Human Engineering Discrepancy Report forms, which are included in each Task Plan as Appendix B9 (see Figure 7-2). A discrepancy/deviation from the guidelines is recorded on the HED form with the items/components involved. The form also contains a place for recording the data collection method (e.g.

Observation, Operator Interview, etc.) and a place for listing potential human errors that may exist because of the discrepancy.

The second page of the HED form contains a place for the suggested backfit and the disposition of the HED.

A summary sheet, called the "HED Prioritization" form (see Table 7-1), is attached to each HED. This form contains a record of the final disposition of the HED. The Category Number, Final Corrective Action, and Implementation rating/schedule are recorded on these forms.

7.1.2 Assessment of HEDs for Cumulative effects HEDs were easily assessed for cumulative effects with the HED numbering scheme developed by CP&L. The numbering scheme (described in Figure 7-3) identifies the component type within the HED number. This allowed for easy tracking and grouping of HEDs that addressed the same components or design feature, such as labeling, annunciator< workspace, etc.

The process used to assess HEDs for:cumulative effects consisted of:

a. Grouping HEDs that addressed the same problems.

b. Grouping HEDs that addressed the same components.

7-2

c. Reassessment of HEDs for probability of error and the consequence of error occurrence (this process is described in Section 7.3).

When HEDs addressed the same components the HEDAT would re-assess the HEDs for cumulative effects to determine if the component required modification due to the number of HEDs against that component. Grouping HEDs that addressed the same problems allowed the HEDAT to assess the scope for potential fixes. For example, the HEDs that addressed individual problems with the meter scales, were determined to be so numerous that the HEDAT concluded that the majority of the meter scales should be replaced. These HEDs were resolved by replacement of the meter scales.

HEDs were also verified for consistencies across panels. For example, an HED addressing a particular type of rotary control on the MCB was grouped with any HEDs for the same type of component that was on the ACP or AEP. These HEDs were assessed together and the same resolution was assigned to each HED.

Cg 7 2a

7 ' ASSESSMENT PROCESS As stated in NUREG-1038, Supplement 1 (SER for SHNPP-l), it was CPGL's policy to correct every HED by designing it out of the system, with the objective of achieving an HED-free board.

NUREG-1038, Sup'plement 1 also states that for instances in which an HED with safety significance cannot be designed out of the system, and a decision is made not to correct the HED or to only partially correct I

it, CP&L will provide justification for the action taken. Even though the NRC found this approach acceptable, CP&L decided to adopt a prioritization/

categorization scheme in order to document HED justifications adequately.

The objective of the assessment process was for the HED Assessment Team (HEDAT) to evaluate the relative significance of the HEDs produced during each phase of the CRDR. The HEDAT separated those HEDs that were unlikely to degrade performance from those that might degrade performance.

The approach employed by CP&L in assessing HEDs consisted of the following:

a. Assessment of HEDs

b. Selection of Design Improvements

c. Verification of Control Room Design Improvements.

7.3 ASSESSMENT OF HEDs The process used in the assessment of HEDs consisted of the following:

a. assessment of probability of error occurrence

b. assessment of consequence of error occurrence

c. prioritization of HEDs.

7 3

r I 7.3.1 Assessment of Error Occurrence Factors considered in the assessment of probability of error occurrence consisted of component design factors, task factors, and human factors. These factors are defined as follows:

a. Component design factors In assessing the component design factors the HEDAT would assess the HED in terms of its deviation from the guidelines (e.g., How much over the criteria stated in the guidelines is the torque on a rotary switch') .

Also considered was whether the guideline conformed to plant design conventions (e.g., unlabeled switch position on spring-return-to-center switches. SHNPP-1 has an established convention that the center position on these switches will not be engraved. Only detented switch positions are engraved.)

b. Task factors The assessment of task factors involved the assessment of the tasks that required using the component(s) identified in the HED. Factors such as difficulty, frequency of use, and time demands were considered. These factors were defined in terms of the following:

1. Difficulty The HED was assessed in terms of the difficulty that may be imposed on the operator to perform his/her task because of the discrepancy.

4

2. Frequency The HED was assessed in terms of the frequency of use. The number of tasks using the component(s) and the number of times the tasks were performed were considered.

3. Time Demands The HED was assessed in terms of the time demands that may be imposed on the operator in performing the task using the component(s) specified in the HED.

c. Human Factors In assessing human factors the HEDAT assessed the HED in terms of human performance factors. The factors'were assessed in terms of the following:

1. Physical Performance - Factors such as fatigue, operator discomfort, potential for injury, and suitability of the component(s) for the required usage were considered.

2. Sensory and Perceptual Performance Factors such as visibility, readability, noise, and audibility were considered.

7.3.2'riteria used for the Assessment of the Conse uences of Error Once the potential for error had been established, the HEDAT assessed the HED for error consequences. Criteria used in the assessment of error consequences was based on the following:

a. The potential impact on plant safety considering the system/functions affected by the error.

b. An error involving a system/function identified as safety-related that could lead to the unavailability of the system.

c. An error that could result in a violation of a technical specification or unsafe operation.

7 5

'I 7.3.3 Prioritization of HEDs Based on the results of the assessment for probability of error occurrence and error consequence, the HEDs were assigned category numbers (see Figure 7-4). The category numbers allowed for further assessment of HEDs in'erms of significance and prioritization. The category numbers were defined as follows:

a. Category I Those HEDs that were assessed to have a high probability of error and a high consequence of error or a low probability of error and a high

.consequence of error. These HEDs included errors that might have safety consequences or result in a violation of a technical specification.

b. Category II Those HEDs that were assessed to have a high probability of error and a low consequence of error.

c. Category III Those HEDs that were assessed to have a low probability of error and a low consequence of f

error.

d. Category IV Those HEDs that were assessed to have a non-significant probability of error. These HEDs were determined to have no impact on operator performance.

7-6

t 7 ' SELECTION OF DESIGN IMPROVEMENTS

a. The procedure used in the selection and specification of corrective actions for HEDs that were to be, corrected, involved an analysis for correction by enhancement, an analysis for correction by design alternatives, and the assessment of the extent of the correction.

b. The process followed by the HEDAT, as outlined in Figure 7-5, consisted of, first, a determination of whether the HED could be corrected by an enhancement. An enhancement was defined as a fix that consisted of labeling, demarcation, operator aids, etc.

c. Where correction by enhancement was not possible, the discrepancy was analyzed for a design alternative correction.

The HEDAT would first develop design alternatives as suggested backfits for the HED. These alternatives were then reviewed to determine the most appropriate alternative. Criteria used in the assessment of this review consisted of:

l) Integration with other NUREG-0737, Supplement l programs

2) Safety consequences

3) The extent of the suggested correction in terms of cost restrictions

4) Any other constraints (e.g., availability of replacement equipment).

d. The HEDAT would then select a design alternative and assess it to determine if the HED would be corrected. It was also the responsibility of the HF Specialists and the Site Project Coordinator to verify that the design alternative did not create any new HEDs or invalidate other HEDs. This was done by verifying that the correction was in compliance with NUREG-0700 guidelines.

7-7

e. If new HEDs were created or other corrected HEDs were invalidated, the HEDAT would reevaluate the design alternative and select another alternative. The process of assessing the alternative and verifying the design alternative would be repeated for the second alternative.

7.4.1 Im lementation Priorities and Schedules The implementation ratings associated with a given category were intended to aid in prioritizing HED corrective actions. Category I HEDs were given first priority, Category II HEDs second priority, Category III HEDs third priority, and Category IV the lowest priority.

During the implementation phase it was determined by the Harris Engineering Group that any HEDs that are to be corrected will be done prior to fuel load. Corrections for HEDs were incorporated into the construction phase process (see Figure 7-1).

For all HEDs outlined in Appendix A of the Final Summary Report that were approved for correction, it was stated that they are to be corrected prior to fuel load, with the exception of one HED.

This HED addresses carpeting on the floor of the Control Room.

When the Final Summary Report was written the schedule for laying carpeting had not been determined. The dates still have not been determined, but it is intended to be in place prior to Commercial Operations.

7-8

P 0

7.4.2 Coordination of HED Corrections Any Control Room changes/HED corrections require an FCR or a DCN.

The FCR/DCN formally documents the change into the Construction Phase process and allows for a detailed tracking of any changes.

By procedure, FCRs and DCNs are distributed to the various groups and departments, including Operations and Training. Members of the Operations and Training staff review the FCR/DCN to determine the need for either dissemination of the information or its inclusion in training.

7-9

7~5 VERIFICATION OF CONTROL ROOM DESIGN IMPROVEMENTS Verification that design improvements provide the necessary correction without creating new HEDs is inherent in CP&L's CRDR program. The HEDAT, collectively, determined the backfit for each HED. In assessing the backfit the HEDAT verified the following:

No HEDs were created by the backfit.

Other corrections were not invalidated by the backfit.

The correction is in compliance with NUREG-0700/human engineering guidelines.

7.5.1 Schedulin of Correcti ns HEDAT-approved solutions to HEDs were incorporated into the Construction Phase Control Room Change process (see Figure 7-6). Within this process a human factors review of the final design change package is conducted.

7.5.2 HF Review of Future Control Room Desi n Im rovements When the Control Room construction is complete CP&L will have a Human Factors Design Specification incorporated into the Plant Modification Procedure (MOD-200). This modification process is outlined in Figure 7-7. Control Room design improvements will follow the guidelines specified in the design specification.

It will be the responsibility of the designer to ensure that the guidelines are met. A draft copy of the design specification is currently available in the project files.

7 10

FIGURE 7-1 CONSTRUCTION PHASE HED REVIEWjIMPLEMENTATIDN i

HED GENERA KD HEDAT REVIEItltS AND CATEGORIZES HED BED DISPOKlOHED AND APPROVEO BY HEDAT CORRECIIVE ACIlON?

FCR/DCN GENERATED TO DOCuuENXD/

INlllATE CHANGE FILED FCR/OCH MAKES DISIRIBIION AP IX-02 VfORK PERFORMED UNDER WORK PACKAGE WORK VERIRED BY Cl/QA WORK PACKAGE CLOSED

FIGURE 7-2 ANNUNCIATOR SYSTEM APPENDIX B9 HUMAN ENGINEERING DISCREPANCY (HED) REPORT PLANT/UNIT ORIGINATOR: HED NO. s VALIDATED BY: DATE:

a) HED TITLEs b) ITEMS INVOLVED:

c) PROBLEM DESCRIPTION AND 0700 PARA. NUMBERs

6) DATA COLLECTION DESCRIPTION AND CODE NUMBERs e) SPECIFIC HUMAN ERROR(s) s 7 - 12

ANNUNCIATOR SYSTEM APPENDIX B9 HED REPORT (CONTINUED)

HED NO.

S) SUGGESTED BACKFIT:

REVIEW AND DISPOSITION:

7 - 13

FIGURE 7-3 HED NUMBERING SCHEME HED numbers are composed of an eight (8) digit number divided

'finto two (2) groups of four (4) digits by a hyphen (done for ease reading) . The number.

first digit contains the plant identification The second digit is the unit number at the plant. The third and fourth digits contain the physical location (panel identification) of the component. The fifth and sixth digits contain the component type or design feature (e.g., a rotary control or a component label). The seventh and eight digits are sequence numbers for the fifth and sixth digits.

The sequence numbers allow for 99 separate HEDs for any given two-digit component or design feature identifier. The unique identity of an HED is. only dependent upon the first two digits and the last four. This was done to keep a specific four-digit HED unique within a given power plant unit.

Below is an example of an HED number which describes the eighth (8) HED against a discrete rotary control HED written against the C Section of the main control board for unit 1 at Shearon Harris Nuclear Power Plant.

Plant Unit 1 Physical Location Component Type o Design Feature Sequence Number 7 14

TABLE 7-1 HED NO ~ .

HED PRIORI TI ZATION CATEGORY Category Z Safety Consequences/Tech. Spec. Violation/

documented error Category ZZ Potential for error/Valid concern Category ZZZ Low probability for error Category ZV No potential for error CORRECTI E ACTION Correction by enhancement Correction by design alternatives Alternative Solution

==

Description:==

MP EME TATION TI C E Earliest Opportunity Mandatory Earliest Opportunity High Priority/Prior to Fuel Load When Convenient Low Priority/Prior to Fuel Load Optional Not Mandatory No Action Reguired

==

Description:==

7 15

FIGURE 7 4 HED ASSESSMENT PROCESS PR08ABILITY HIGH OF NOT ERROR SIGNIFICANT LOW IG LOW LOW h

7 - 16

FIGURE 7 5 SELECTION OF DESIGN IMPROVEMENT PROCESS CORRECTABLE BY HED ENHANCEMENT CORRECTED NO DFVELOP DESIGN ALTERNATIVES RE-EVALUATE'LTERNATI VES SELECT DESIGN ALTERNATIVES INCORRECTED ASPECTS NO HED ANAUZED AND CORRECTED 4J STlR CATION DOCUMENTED NO NEW HED CREATED dc OTHER HED NOT INVAUDATED HEDs SCHEDULED FOR CORRECTION 7 -'17

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0

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'h e II II II

Dl I '0 I'l I

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NRC QUESTION: 280.1 Your fire protection program vill be reviewed to the guidelines of BTP CHEB 9.5-1 (NUREG-0800),

July 1981. Provide a comparison that shoes conformance of the plant fire protection program to these guidelines. Deviations from the guidelines should be specifically identified. A technical basis should be provided for each deviation.

CAROLINA POWER 6 LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1 POINT BY POINT COMPARISON OF SHEARON HARRIS NUCLEAR POWER PLANT FIRE PROTECTION WITH NUREG-0800 (FORMERLY NUREG-75/087), BRANCH TECHNICAL POSITION CMEB 9.5-1 (FORMERLY BTP ASP 9.5-1) GUIDELINES FOR FIRE PROTECTION FOR NUCLEAR POWER PLANTS

BRANCH TECHNICAL POSITION CMEB 9. 5-1 (FORMERLY BTP ASB 9.5-1)

GUIDELINES FOR FIRE PROTECTION FOR NUCLEAR POWER PLANTS

I1 ~

TABLE OF CONTENTS Page A. INTRODUCTION........ ~ . o. ~ ~ ~ ~..... o... ~ ~ o ~ ~ ~ ~ . o so ~ ~ ~ ~

B. D IS CUSS ION i ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ t~~~~~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o ~ 0 ~ ~

l. Defense-in-Depth.................. ~ .- ~ - ~ - ~ ~ -~- ~ ~ ~ - ~ ~ ~ ~ 4

2. Use of Water on Electrical Cable Fires............. ~ ~ ~ 7

3. Establishment and Use of Fire Areas................ ~ ~ ~ 8

4. Definitions..................................-..... ~ ~ 0 9 C. PO SIT IONo ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 14

1. Fire Protection Program Requirements...............

a0 Fire Protection Program........................ ~ ~ ~ 14

b. Fire Hazards Analysis.......................... ~ ~ 4 20 C ~ Fire Suppression System Design Basis........... ~ ~ ~ 25

d. Alternative or Ded i ca t ed Shutdown.............. ~ ~ ~ 27

e. Implementation of Fire Protection Programs... ~ ~ ~ ~ ~ 27 E

2. Administrative Controls............. . ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 1 ~ 28

3. F ire Brigade.................................. ~ ~ ~ ~ ~ ~ ~ ~ 31 4, Quality Assurance Program..................... ~ ~ ~ ~ ~ ~ ~ 36 a@ Design and Procurement Document Control. ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 36

b. Instructions, Procedures, and Drawings.. ~ ~ ~ ~ ~ ~ ~ ~ ~ 4 36

.C ~ Control of Purchased Material, Equipment and Services.............................. ~ ~ ~ 36

d. Inspection.............................. ~ ~ ~ 37

e. Test and Test Control................... ~ ~ ~ 37

f. Inspection, Test, and Operating Status.. ~ ~ ~ 37 go Nonconforming Items..................... ~ ~ ~ 37

h. Corrective Action....................... ~ ~ ~ 37

i. R ecords................................. ~ ~ 37

] Audits..................................

~ ~ ~ ~ 37

5. General Plant Guidelines........................... 38 a~ Building Design............... ~ ~ ~ 38

b. Safe Shutdown Capability...... ~ ~ ~ ~ ~ ~ t~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ t ~ 47 C ~ Alternative or Dedicated Shutd own Capabili 'ty o ~ ~ ~ ~ ~ 49 Control of Combustibles....... ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 51

e. Electrical Cable Construction, Cable Trays and Cable Penetrations.......... ~ ~ 0 55

f. Ventilation................... ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 59 g ~ Lighting and Communication.... ~ ~ ~ 62

6. Fire Detection and Suppression..................... ~ ~ ~

a. Fire Detection............................ ~ ~ ~ 63

b. Fire Protection Water Supply Systems...... ~ ~ ~ ~ ~ ~ ~ ~ 65 iv

W 1 ~

TABLE OF CONTENTS (Cont'd)

Page C ~ Water Sprinkler and Hose Standpipe Syst ems ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o 71

d. Ha ion Suppr essi on Sys t ems.............. ~ ~ ~ ~ 75

e. Carbon Dioxide Suppression Systems..... 76

f. Portable Extinguishers................. ~ ~ ~ ~ 77

7. Guidelines for Specific Plant Area....... ~........... .. ~ ~ 77 a~ Primary and Secondary Containment. ~ ~ ~ ~ 77

b. Control Room Complex....o...o..... ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 81 C ~ Cable Spreading Room.............. ~ ~ ~ ~ 85

d. Plant Computer Rooms.............. ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 87

e. Switchgear Rooms.................. ~ ~ ~ ~ 87

f. Remote Safety-Related Panels...... ~ ~ ~ ~ 88 g ~ Safety-Related Battery Rooms...... ~ ~ ~ ~ 89

h. Turbine Building.................. ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 90 Diesel Generator Areas............ ~ ~ ~ ~ 90 Diesel Fuel Oil Storage Areas..... ~ ~ ~ ~ 92

k. Saf ety-Related Pumps.............. ~ ~ ~ ~ 93

1. New Fuel Area..................... ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 94

m. Spent Fuel Pool Area.............. ~ ~ ~ ~ 94

n. Radwaste and Decontamination Areas ~ ~ ~ ~ 95 Oo Safety-Related Water Tanks........ ~ ~ ~ o 95 po Records Storage Areas............. ~ ~ ~ ~ 96 Cooling Towers.............. ~ ~ ~ ~ 96 r ~ Miscellaneous Areas............... ~ ~ ~ ~ 97

8. Special Protection Guidelines............................ 97 ao Storage of AcetyleneWxygen Fuel Gase S ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 97

b. Storage Areas for Ton Exchange Resins ~ ~ ~ ~ 98 C ~ Hazardous Chemicals.................. ~ ~ ~ ~ 98

d. Materials Containing Radioactivity... ~ ~ ~ ~ 98

NRC GUIDELINES: A. INTRODUCTION General Design Criterion 3, "Fire Protection" of Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, "Licensing of Production and Utilization Facilities," requires that structures, systems, and components important to safety be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. Noncombustible and heat-resistant materials are required to be used wherever practical throughout the unit, particularly in locations such as the containment and control room.

Criterion 3 also requires that fire detection and suppression systems of appropriate capacity and capability be provided and designed to minimize the adverse effect of fires on structures, systems, and components important to safety and that firefighting systems be designed to ensure that their failure, rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems, and components.

This Branch Technical Position (BTP) presents guidelines acceptable to the NRC staff for implementing this criterion in the development of a fire protection program for nuclear power plants. These revised guidelines include the acceptance criteria listed in a number of documents, including Appendix R to 10 CFR Part 50 and 10 CFR Part 50.48.

The purpose of the fire protection program is to ensure the capability t'o shut down the"reactor and maintain it in a safe shutdown condition and to minimize rad'""" ":" releases to the, environment in the event of a fire.

It implements tne pnilosophy of def ense-in-depth protection against the hazards of fi v cl 1ll its associated effects on safety-.related equipment.

If designs or methods different from the guidelines recommended herein are used, they must provide equivalent fire protection. Suitable bases and justification should be provided for alternative approaches to establish acceptable implementation of General Design Criterion 3.

This BTP addresses fire protection programs for safety-related systems and equipment and for other plant areas containing fire hazards that could adversely affect safety-related systems. It does not give guidance for protecting the life or safety of the site personnel or for protection against economic or property loss. This document supplements Regulatory Guide 1.75, "Physical Independence of Electrical Systems," in determining the fire protection for redundant cable systems.

PRO JECT CONFORMANCE: A. INTRODUCTION General Design Criterion 3, "Fire Protection" of Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, "Licensing of Production and Utilization Facilities," was followed in the design of SHARP. Safety and non-safety-related structures, systems, and components were designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions.

Noncombustible and heat-resistant materials were used wherever practical throughout the units, particularly in locations such as the containment and control room. Fire detection and suppression systems of appropriate capacity and capability were provided and designed to minimize the

adverse effect of fires on structures, systems, and components important to safety. Firefighting systems were designed to ensure that their failure, rupture or inadvertent operation will not impair the safety capability of these structures, systems, and components.

The purpose of the fire protection program is to ensure the capability to shut down the reactor and maintain it in a safe shutdown condition and to minimize radioactive releases to the environment in the event of a fire.

Defense-in-depth protection against the hazards of fire and its associated effects on safety-related equipment was implemented in the SHNPP fire protection design philosophy. Whenever designs or methods different from the guidelines recommended herein were used, they are intended to provide equivalent fire protection. Suitable bases and justification were provided for alternative approaches to establish acceptable implementation of General Design Criterion 3.

This BTP was followed in the design of fire protection program for safety-related systems and equipment and for other plant areas containing fire hazards that could adversely affect safety-related systems. It is understood that it does not give guidance for protecting the life or safety of the site personnel or for protection against economic or property loss. Regulatory Guide 1.75, "Physical Independence of Electrical Systems," in determining the fire protection for redundant cable systems was followed in the plant design. Redundant safety-related systems required for safe shutdown were separated in accordance with requirement of Section III.G.2 of Appendix R to 10CFR50 or an exemption was requested as detailed in Section 9.5B.3 of Safe Shutdown Analysis in Case of Fire.

NRC GUIDELINES: B. DISCUSSION There have been numerous fires in'perating U.S. nuclear power plants through December 1975 of which 32 were important enough to report. Of these, the fire on, March 22, 1975 at Browns Ferry nuclear plant was the most severe. With approximately 250 operating reactor years of experience, one may infer a frequency on the order of one fire per 10 reactor years. Thus, on the average, a nuclear power plant may experience one or more fires of varying severity during its operating life. Although WASH-1400, "Reactor Safety Study An assessment of Accident Risks in U.S. Commercial Nuclear Power Plants," dated October 1975, concluded that the Browns Ferry fire did not affect the validity of the overall risk assessment, the staff concluded that cost-effective fire protection measures should be instituted to significantly decrease the frequency and severity of fires and consequently initiated the development of this BTP. In this development, the staff made use of many national standards and other publications related to fire protection.

The documents discussed below were particularly useful.

A document entitled "The International Guidelines for the Fire Protection of Nuclear Power Plants" (IGL), 1974 Edition, Second Reprint, published on behalf of the National Nuclear Risks Insurance Pools and Association, provides a step-by-step approach to assessing the fire risk in a nuclear power plant and describes protective measures to be taken as a part of the fire protection of these plants. It provides useful guidance in this

important area. The Nuclear Energy Liability and Property Insurance Association (NELPIA) and the Mutual Atomic Energy Reinsurance Pool (MAERP) have prepared a document titled "Specifications for Fire Protection of New Plants," which gives general conditions and valuable criteria. A special review group organized by NRC under Dr Stephen H Hanauer, Technical Advisor to the Executive Director for Operations, to study the Browns Ferry fire, issued a report, NUREG-0050, "Recommendations Related to Browns Ferry Fire," in February 1976, which contains recommendations applicable to all nuclear'ower plants. This BTP uses the applicable information contained in these documents.

The fire protection program for a nuclear power plant presented 1n this BTP consists of design features, personnel, equipment, and procedures that provide the defense-in-depth protection of the public health and safety. The purpose of the program is to prevent significant fires, to ensure the capability to shut down'the reactor and maintain it in a safe shutdown condition, and to minimize radioactive releases to the environment in the event of a signif1cant fire. To meet these objectives, it is essential that management participation in the program begin with early design concepts and plant layout work and continue through plant operation and that a qualified staff be responsible for engineering and design of fire protection features that provide f1re detection annunciation, confinement, and suppression for the plant. The staff should also be responsible for fire prevention activities, maintenance of fire protection systems, training, and manual firefighting activities. It is the combination of all these that provides the needed defense-in-depth protection of the public health and safety.

PROJECT CONFOR."RNCE: B. DISCUSSION It is understood that on the average, a nuclear power plant may experience one or more fires of varying severity dur1ng its operating life. Cost-effective fire protection measures were instituted to significantly decrease the potential of frequent and severe fires.

National standards and other publications related to fire protection were used in developing the SHNPP Fire Protection Program.

The Shearon Harris Fire Protection Program considered the information found in "The International Guidelines for the Fire Protection of Nuclear Power Plants" (IGL), 1974 Edition, Second Reprint, published on behalf of the National Nuclear Risks Insurance Pools and Association, which provides step-by-step approach to assessing the fire risk in a nuclear power plant and describes protective measures to be taken as a part of the fire protection of these plants, the Nuclear Energy Liability and Property Insurance Association (NELPIA) and the Mutual Atomic Energy Reinsurance Pool (MAERP) "Specifications for Fire Protection of New

'Plants," and NUREG-0050, "Recommendations Related to Browns Ferry Fire,"

in February 1976.

The fire protection program for Shearon Harris Nuclear Power Plant consists of design features, personnel, equipment, and procedures that provide the defense-in-depth protection of the public health and safety.

The purpose of the program was to prevent significant fires, to ensure the capability to shut down the reactor and maintain it in a safe

shutdown condition, and to minimize radioactive releases to the environment in the event of a significant fire. To meet these objectives, management participation in the program began with early design concepts and plant layout work and will continue through plant operation. A qualified staff was responsible for engineering and design of fire protection features that provide fire detection annunciation, confinement, and suppression for the plant. The staff was also responsible for fire prevention activities, maintenance of fire protection systems, training, and manual firefighting activities. The combination of all these provide the needed defense-in-depth protection of the public health and safety.

NRC GUIDELINES: B. DISCUSSION (Cont'd)

Some of the major conclusions that emerged from the Browns Ferry fire investigations warrant emphasis and are discussed below.

B.l. Def ense-in-Depth Nuclear power plants use the concept of defense"in-depth to achieve the required high degree of safety by using echelons of safety systems. This concept is also applicable to fire safety in nuclear power plants. With respect to the fire protection program, the defense-in-depth principle is aimed at achieving an adequate balance in:

a. Preventing fires from starting;

b. Detecting fires quickly, suppressing those fires that occur, putting them out quickly, and limiting their damage; and C ~ Designing plant safety systems so that a fire that starts in spite of the fire prevention program and burns for a considerable time in spite of fire protection activities will not prevent essential plant safety functions from being perrormed.

No one of these echelons can be perfect or complete by itself. Each echelon should meet certain minimum requirements; however, strengthening any one can compensate in some measure for weaknesses, known or unknown, in the others.

PROJECT CONFORMANCE: B. DISCUSSION (Cont'd)

Major conclusions that emerged from the Browns Ferry fire investigations and warrant emphasis as applicable for Shearon Harris are discussed below.

B.l. Defense-in-Depth Shearon Harris Nuclear Power Plants considered the concept of defense-in-depth to achieve the required high degree of safety by using echelons of safety systems, applicable to fire safety. With respect to the fire protection program, the defense-in-depth principle was aimed at achieving an adequate balance in:

I ~ ~

a. Preventing fires from starting',

b. Detecting fires quickly, suppressing those fires that occur, putting them out quickly, and limiting their damage, and C ~ Designing plant safety systems so that a fire that starts in spite of the fire prevention program and burns for a considerable time in spite of fire protection activities will not prevent essential plant safety functions from being performed.

NRC GUIDELINES: B. DISCUSSION (Cont'd)

The primary objective of the fire protection program is to minimize both the probability and consequences of postulated fires. In spite of steps taken to reduce the probability of fire, fires are expected to occur.

Therefore, means are needed to detect and suppress fires with particular emphasis on providing passive and active fire protection of appropriate capability and adequate capacity for the systems necessary to achieve and maintain safe plant shutdown with or without offsite power. For other safety-related systems, the fire protection should ensure that a fire will not cause the loss of function of such systems, even though loss of redundancy within a system may occur as a result of the fire. Generally, in plant areas where the potential fire damage may jeopardize safe plant shutdown, the primary means of'fire protection should consist of fire barriers and fixed automatic fire detection and suppression systems.

Also, a backup manual firefighting capability should be provided throughout the plant to limit the extent of fire damage. Portable equipment consisting of hoses, nozzles, portable extinguishers, complete personnel protective equipment, and air breathing equipment should be provided for use by properly trained firefighting personnel. Access for effective manual application of fire extinguishing agents to combustibles should be provided. The adequacy of fire protection for any particular plant safety system or area should be determined by analysis of the effects of the postulated fire relative to maintaining the ability to safely shutdown the plant and minimize radioactive releases to the environment in the event of a fire.

PROJECT CONFORMANCE: B. DISCUSSION (Cont'd)

The primary objective of the fire protection program was to minimize both the probability and consequences of postulated fires. In spite of steps taken to reduce the probability of fire, fires may occur. Therefore, means to detect and suppress fires were provided, with particular emphasis on providing passive and active fire protection of appropriate capability and adequate capacity for the systems necessary to achieve and maintain safe plant shutdown with or without offsite power. For other safety-related systems, the fire protection was aimed to ensure that a fire will not cause the loss of function of such systems, even though loss of redundancy within a system might occur as a result of the fire.

Generally, in plant areas where the potential fire damage might jeopardize safe plant shutdown, the primary means of fire protection consisted of fire barriers and fixed automatic fire detection and suppression systems, or combination thereof. Also, a backup manual firefighting capability was provided throughout the plant to limit the

extent of f ire damage. Portable equipment consisting of hoses, nozzles, portable extinguishers, complete personnel protective equipment, and air breathing equipment were provided for use by properly trained firefighting personnel. Access for effective manual application of fire extinguishing agents to combustibles were provided to the extent practicable. 'Ihe adequacy of fire protection for any particular plant safety system or area was determined by analysis of the effects of the postulated fire relative to maintaining the ability to safely shutdown the plant and minimize radioactive releases to the environment in the event of a fire.

NRC GUIDELINES: B. DISCUSSION (Cont'd)

Fire protection starts with design and must be carried through all phases

,of construction and operation. A quality assurance (QA) program is needed to identify and rectify errors in design, construction, and operation and is an essential part of defense-in-depth.

PROJECT CONFORY~CE: B. DISCUSSION (Cont'd)

Fire protection started with design and was carried through all phases of construct'n and operation. A quality assurance (QA) program to identify and rectify errors in design, construction, and operation was developed for fire protection and constitutes an essential part of defense"in-depth.

'i'he Design Construction QA Program is described in the FSAR and was approved by the NRC staff. The Engineering and Construction fire protection quality assurance program was approved by the NRC during the construction permit review. The fire protection QA program, which is under the management control of the QA organizati.on, has assured the satisfaction of QA guidelines during the design, procurement, installation, and acceptance testing of fire protection equipment and systems provided for the plant and will assure their continued inspection, testing, maintenance, and administrative control after the plant becomes operational. As part of management control, the QA organization has:

(1) Developed a fire protection QA program, incorporating suitable requirements necessary for the provision of an effective Fire Protection System.

(2) Verified the acceptability of the fire protection QA.program to the management responsible for fire protection, and (3) Verified through, audit and surveillance the effectiveness of the QA program for fire protection.

For components of the fire protection program designed, specified, procured, manufactured, fabricated, and installed prior to institution of the formal fire protection Quality Assurance Program (February 18, 1977),

sufficient control was exercised and followed to the extent practical and the activities performed evaluated during subsequent audit, surveillance, and design review activities.

The operational Quality Assurance Program is described in Section l7.2 of the FSAR.

NRC GUIDELINES: B. DISCUSSION (Cont'd)

B.2. Use of Water on Electr'cal Cable Fires Experience with major electrical cable fires shows that water will promptly extinguish such fires. Since prompt extinguishing of the fire is vital to reactor safety, fire and water damage to safety systems is reduced by the more efficient application of water from fixed systems spraying directly on the fire rather than by manual application with fire hoses. Appropriate firefighting procedures and fire training should provide the techniques, equipment, and skills for the use of water in fighting electrical cable fires in nuclear plants, particularly in areas containing a high concentration of electric cables with plastic insulation.

This is not to say that fixed water systems should be installed everywhere. Equipment that may be damaged by water should be shielded or relocated away from the fire hazard and the water. Drains should be provided to remove any water used for fire suppression and extinguishment to ensure that water accumulation does not incapacitate safety-related equi.pment.

PROJECT CONED.""'..".C": B. DISCUSSION (Cont'd)

B.2. Use of ~ai~a on Electrical Cable Fires Fixed automatic water systems discharging water on potential electrical cable fires were selected in most instances versus manual application of water with fire hoses. Experience with major electrical cable fires shows that ~ater promptly extinguished such fires, and prompt extinguishing oi a fire is vital to reactor safety. More efficient application of water from fixed systems delivering water directly on the fire, can potentially reduce fire and water damage to safety systems.

Appropriate firefighting procedures and fire training will provide the techniques, equipment, and skills for the use of water in fighting electrical cable fires, particularly in areas containing a high concentration of electric cables. Use of cables with plastic insulation was minimized, and the places and amount used are detailed in the fire hazards analysis.

Automatic fixed water suppression systems were installed selectively.

Equipment that might be damaged by water was protected from the fire hazard and/or the water. Drains were provided to remove water used for fire suppression and extinguishment to ensure that water accumulation will not incapacitate safety-related equipment. (Refer to project Conformance C.l.g for description of fire suppression systems.)

NRC GUIDELINES: B. DISCUSSION (Cont 'd)

B.3. Establishment and Use of Fire Areas Separate fire areas for each division of safety-related systems will reduce the possibility of fire-related damage to redundant safety-related equipment. Fire areas should be established to separate redundant safety divisions and isolate safety-related systems from fire hazards in non-safety-related areas. Particular design attention to the use of separate isolated fire areas for redundant cables will help to avoid loss of redundant safety-related cables. Separate fire areas should also be employed to limit the spread of fires between components that are maj or fire hazards within a safety division. Where redundant systems cannot be separated by fire barriers, as in containment and the control room, it is necessary to employ other measures to prevent a fire from causing the loss of function of safety-related systems.

Within fire areas containing components of a safety-related system, special attention should be given to detecting and suppressing fires that may adversely affect the system. Measures that may be taken to reduce the effects of a postulated fire in a given fire area include limiting the amount of combustible materials, installing fire-resistant construction, providing fire rated barriers for cable trays, installing fire detection systems and fixed fire suppression systems, or providing other pratection suitable to the installation. The fire hazard analysis will be the mechanism to determine the fire areas have been properly selected.

Suitable design of the ventilation systems can limit the consequences of a fire by preventing the spread of the products of combustion to other fire areas. It is important that means be provided to ventilate, exhaust, or isolate the fire area as required and that consideration be given to the consequences of failure of ventilation systems due to fire causing loss of control for ventilating, exhausting, or isolating a given fire area. The capability to ventilate, exhaust, or isolate is particularly important to ensure the habitability of rooms or spaces that must be attended in an emergency. In the design, provision should be made for personnel access to and escape routes from each fire area.

PROJECT CONFORMANCE: B. DISCUSSION (Cont'd)

B.3. Establishment and Use of Fire Areas As stated in the FSAR on page 9.5.1-1, separate fire areas, which reduce the possibility of fire-related damage to redundant safety-related trains, were established to separate redundant safety divisions and to isolate safety-related systems from hazards in non-safety-related areas to the extent possible since the plant was designed prior to issuance of NUREG-0800 (see first paragraph on FSAR page 9.5.1-1). Where fire barriers could not be installed to separate redundant systems, alternate means, as permitted by Appendix A 'to Branch Technical Position APCSB 9.5-1 Rev 0 Guidelines for Fire Protection for Power Plants Docketed

Prior to July 1, 1976, such as limitation of the amount of combustible materials through administrative procedures, utilization of fire resistive construction, installation of automatic fire detection systems, automatic fire suppression systems or combination thereof.

The fire hazards analysis, FSAR Subsection 9.5.1.3, Appendix 9.5A and Safe Shutdown Analysis in Case of Fire (SSA) were used to demonstrate the adequacy of the fire prevention and protection measures utilized. As a result of SSA, additional fire prevention and protection measures were prescribed, as detailed in the Safe Shutdown Analysis in Case of Fire.

Spread of the products of combustion to other fire areas was limited by provision of adequate means to ventilate, exhaust, or isolate the fire area as required. Consideration was given to the consequences of failure of ventilation systems due to fire causing loss of control for ventilating, exhausting, or isolating a given fire area. Provisions were made for personnel access to and escape routes from each fire area.

NRC GUIDELINES: DISCUSSION (Cont'd)

B.4. Definitions

/

For the user's convenience, some of the terms related to fire protection are presented below with their definitions as used in this BTP.

Aooroved tested and accepted for a specific purpose or application by a nationally recognized testing laboratory.

Automatic self-acting, operating by its own mechanism when actuat'ed by some impersonal influence such as change in current, pressure, temperature, or mechanical configuration.

Combustible Material - material that does not meet the definition of n one omous t ibl e.

Control Room Complex the zone served by the control room emergency ventilation system (see SRP Section 6.4, "Habitability Systems" ).

either in situ or transient combustibles and is external to any structures, systems, or components located in or adjacent to that same area. The effects of such fire (e.g., smoke, heat, or ignit'ion) can adversely effect those structures, systems, or components important to safety. Thus, a fire involving one train of safe shutdown equipment may constitute an exposure fire for the redundant train located in the same area, and a fire involving combustibles other than either redundant train may constitute an exposure fire to both redundant trains located in the same area.

Fire Area that portion of a building or plant that is separated from other areas by boundary fire barriers.

Fire Barrier those components of construction (walls, floors, and their supports), including beams, joists, columns, penetration seals or closures, fire doors, and fire dampers that are rated by approving laboratories in hours of resistance to fire and are used to prevent the spread of fire.

~pire Sto a feature of construction that prevents fire propagation along the length of cables or prevents spreading of fire to nearby combustibles within a given fire area or fire zone.

who are equipped for and trained in the fighting of fires.

Fire Detectors a device designed to automatically detect the presence of fire and initiate an alarm system and other appropriate action (see NFPA 72E, "Automatic Fire Detectors" ). Some typical fire detectors are classified as follows:

Heat Detector a device that detects a predetermined (fixed) temperature or rate of temperature rise.

e Smoke Detector a device that detects the visible or invisible products of combustion.

Flame Detector a device that detects the infrared, ultraviolet, or visible radiation produced by a fire.

Line-Tv e Detector a device in which detection is continuous along a path, e.g., fixed-temperature, heat"sensitive cable and rate-of-rise pneumatic tubing detectors.

Fire Protection Pro ram the integrated eff ort involving components, procedures, and -personnel utilized in carrying out all activities of fire protection. It includes system and facility design, fire prevention, fi're detection, annunciation, conf inement, suppression, administrative controls, fire brigade organization, inspection and maintenance, training, quality assurance, and testing.

Fire Resistance Rating The time that materials, or assemblies have withstood a fire exposure as established in accordance with the test procedures of "Standard Methods of Fire Tests or Building Construction and Materials" (NFPA 251).

Fire Suppression control and extinguishing of fires (firefighting).

Manual fire suppression is the use of hoses, portable extinguishers, or manually-actuated fixed systems by plant personnel. Automatic fire suppression is the use of automatically actuated fixed systems such as water, Halon, or carbon dioxide systems.

Fire Zones - the subdivision of Eire areas in which the fire suppression systems are designed to combat particular types of fires.'0

Noncombustible Material

a. A material whic'n in the form in which it is used and under the conditions anticipated, will not ignite, burn, support combustion, or release flammable vapors when subjected to fire or heat.

b. Material having a structural base of noncombustible material, as defined in a., above, with a surfacing not over 1/8-inch thick that has a flame spread rating not higher than 50 when measured using ASTM E-84 Test "Surface Burning Characteristics of Building Materials."

Rateuav - refer to Regulatory Gufde 1.75.

Restricted Area any area to which access is controlled by the licensee for purposes of protecting individuals from exposure to radiation and radioactive materials.

Safety-Related Systems and Components - systems and components required to shutdown the reactor, mitigate the consequences of postulated accidents, or maintain the reactor in a safe shutdown condition.

Secondary Containment a structure that completely encloses primary containment, used for controlling containment leakage.

S rinkler System a network of piping connected to a reliable water supply that will distribute the water throughout the area protected and will discharge the water through sprinklers in sufficient quantity either to extinguish the fire entirely or to prevent its spread. The system, usually activated by heat, includes a controlling valve and a device for actuating an alarm when the system is in operation. The following categories of sprinkler systems are defined in NFPA 13, "Standard for the Installation of Sprinkler Systems."

Wet Pipe System Dry-Pipe System Preaction System Deluge System Combined Dry-Pipe and Preaction System OnWff System Stand ioe and Hose S stems a fixed piping system with hose outlets, hose, and nozzles connected to a reliable water supply to provide effective fire hose streams to specific areas inside the building.

Water Spray System a network of piping similar to a sprinkler system except that it utilizes open-head spray nozzles. NFPA 15, "Water Spray Fixed Systems," provides guidance on these systems.

11

PROJECT CONFORMANCE: DISCUSSION (Cont'd)

B.4. Definitions For the user's convenience, some of the terms related to fire protection are presented below with their definitions as used in the Shearon Harris Nuclear Power Plant.

~A roved tested and accepted for a specific purpose or application by a nationally recognized testing laboratory.

Automatic self-acting, operating by its own mechanism when actuated by some impersonal influence such as change in current, pressure, temperature, or mechanical configuration.

Combustible Material material that does not meet the definition of noncombustible.

Control Room Com lex Fire Area - the fire area located west of the Control Room Fire Area, outside of the control room emergency ventilation system, and including the following fire zones: Non-Safety Computer Room, Rod Control Cabinets Room, Auxiliary Relay Panels Room, Process Instruments and Control Racks and Communications Room.

Control Room Fire Area the fire area served by the control room emergency ventilation system (see SRP Section 6.4, "Habitability Systems" ).

either in situ or transient combustibles and is external to any structures, systems, or components located in or adjacent to that same area. The effects of such fire (e.g., smoke, heat, or ignition) can adversely effect those structures, systems, or components important to safety. Thus, a fire involving one train of safe shutdown equipment may constitute an exposure fire for the redundant train located in the same area, and a fire involving combustibles other than either redundant train may constitute an exposure fire to both redundant trains located in the same area. (Note: the exposure fires were considered part of SSA.)

Fire Area that portion of a building or plant that is separated from other areas by boundary fire barriers, or 50 ft of open space to the atmosphere without any combustibles.

Fire Breaks a feature of construction designed to prevent the propagation of a fire along the length of a loaded cable /

tray.

Fire Barrier those components of construction (walls, floors, and their closures, fire doors, and fire dampers that are rated by approving 12 (3276PPC/ccc )

I '

laboratories or certified by their manufacturers to be of rated construction in hours of resistance to fire and are used to prevent the spread of fire.

who are equipped for and trained in the fighting of fires.

Fire Detectors a device designed to automatically detect the presence of fire and initiate an alarm system and other appropriate action (in accordance with NFPA 72E, "Automatic Fire Detectors" ). Some typical fire detectors are classified as follows:

Heat Detector a device that detects a predetermined (fixed) temperature or rate of temperature rise.

Smoke Detector - a device that detects the visible or invisible products ot combustion.

Flame Detector a device that detects the infrared, ultraviolet, or visible radiation produced by a fire.

Line-Tyne Detector -' device in which detection is continuous along a path, e.g., fixed-temperature, heat-sensitive cable and.

rate-of-rise pneumatic tubing detectors.

Fire Protect'".. P"""ram the integrated effort involving components, procedures, ana personnel utilized in carrying out all activities of fire protection. "eludes system and facility design, fire prevention, fire detection, annunciation, confinement, suppression, administrative controls, fire brigade organization, inspection'nd maintenance, training, qual.ity assurance, and testing.

Fire Resistance Rating - The time that materials or assemblies have withstood a fire exposure as established in accordance with the test procedures of "Standard Methods of Fire Tests or Building Construction and Materials" (Bi'PA 251).

Fire SuDDression control and extinguishing of fires (firefighting).

Manual fire suppression is the use of hoses, portable extinguishers, or manually-actuated fixed systems by plant personnel. Automatic fire suppression is the use of automatically actuated fixed systems such as water, Halon, or carbon dioxide systems.

Fire Zones - the subdivision of fire areas in which the fire suppression systems are designed to combat particular types of fires.

Noncombustible Material

a. A material which in the form in which it is used and under the conditions anticipated, will not ignite, burn, support combustion, or release flammable vapors when subjected to fire or heat.

13

0

b. Material having a structural base of noncombustible material, as defined in a., above, with a surfacing not over 1/8-inch thick that has a flame spread rating not higher than 50 when measured using ASTM E-84 Test "Surface Burning Characteristics of BuiLding Materials."

~Racewa refer to Regulatory Guide 1.75.

Restricted Area Any area to which access is controlled by the licensee for purposes of protecting individuals from exposure to radiation and radioactive materials.

Safet -Related S stems and Com onents systems and components required to shutdown the reactor, mitigate the consequences of postulated accidents, or maintain the reactor in a safe shutdown condition.

Essential S stems and Com onents safety and non-safety-related systems required to shutdown the reactor and maintain it in a safe shutdown condition in case of a fire.

Secondar Containment not applicabLe.

S rinkler S stem a network of piping connected to a reliable water supply that will distribute the water throughout the area protected and will discharge the water through sprinklers in sufficient quantity either to extinguish the Eire entirely or to prevent its spread. The system usually activated by heat, includes a controlling valve and a device for actuating an alarm when the system is in operation or water does not flow through the preaction or multi-cycle valve. The following categories of sprinkler systems as defined in NFPA 13, "Standard for the Installation of Sprinkler Systems" and FSAR Subsection 9.5.1.2.3 are used:

~ Deluge Pipe System

~ Pre-Action System

~ Multi-Cycle (On-Off System)

Stand i e and Hose S stems a fixed piping system with hose outlets, hose, and nozzles connected to a reliable water supply to provide effective fire hose streams to specific areas inside the building.

Water S ra S stem a network of piping similar to a sprinkler system except that it utilizes open-head spray nozzles. NFPA 15, "Water Spray Fixed Systems," was followed for these systems.

NRC GUIDELINES: C. POSITION C. 1. Fire Protection Pro ram Re uirements C.l.a. Fire Protection Program A Eire protection program should be established at each nuclear power plant. The program should establish the fire protection poLicy for the 14 (3276PPC/ljs)

protection of structures, systems, and components important to safety at each plant and the procedures, equipment, and personnel required to implement the program at the plant site.

(1) The fire protection program should be under the direction of an individual who has been delegated authority commensurate with the responsibilities of the position and who has available staff personnel knowledgeable in both fire protection and nuclear safety.

PROJECT CONFORMANCE: C. POSITION C.l.a(1) SHNPP has a fire protection program which establishes the policy for protection of structures, components, and systems important to safety. Procedures have been prepared to implement the plan and the plant is staffed to implement the procedures. The Plant General Manager directs the staff who is knowledgeable in fire protection and nuclear safety.

NRC GUIDELINES: C. POSITION (Cont'd)

C.l.a(2) The fire protection program should extend the concept of a 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 safe shutdown of the plant.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.l.a(2) The fire protection program utilizes the concept of defense-in-depth 'for fire protection in areas containing safety related systems and equipment and other plant areas containing fire hazards that could adversely affect safety related systems by:

Preventing fires from starting.

Rapid detection, control and extinguishing of those fires that do occur.

Providing protection for structures, systems and components important to safety so that a fire which is not promptly extinguished by fire suppression activities will not prevent safe shutdown of the pLant.

(3276PPC/Ljs)

NRC GUIDELINES: C. POSITION (Cont'd)

C.l.a(3) Responsibility for the overall fire protection program should be assigned to a person who has management control over all organizations involved in fire protection activities.

Formulation and assurance of program implementation may be delegated to a staff composed of personnel prepared by training and experience in fire protection and personnel prepared by training and experience in nuclear plant safety to provide a balanced approach in directing the fire protection program for the nuclear power plant.

The staff should be responsible for:

a. Fire protection program requirements, including consideration of potential hazards associated with postulated fires, with knowledge of building layout and systems design.

b. Post-fire s'nutdown capability.

c. Design, maintenance, surveillance, and quality assurance of all fire protection features (e.g., detection systems, suppression systems, barriers, dampers, doors, penetration seals, and fire brigade equipment).

d. Fire prevention activities (administrative controls and training).

e. Fire brigade organization and training.'.

Prefire planning.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.l.a(3) SHNPP has provided a balanced approach to the nuclear fire protection situation by providing personnel who are qualified in fire protection as well as the usual nuclear safety trained p ers onnel.

The staff is responsible for all areas of fire protection from planning to pose-fire capability.

NRC GUIDELINES: C. POSITION (Cont'd)

C.l.a(4) The organizational responsibilities and lines of communication pertaining to fire protection should be defined between the various positions through the use of organizational charts and functional descriptions of each position's responsibilities.

The f ollowing positions/organizations should be designated:

16

a. The upper level offsite management pos1tion which has management responsibility for the formulation, implementation, and assessment of the effectiveness of the nuclear plant fire protection program.

b. The offsite management position(s) directly responsible for f ormulating,,implementing, and periodically assessing the effect1veness of the fire protection program for the licensee's nuclear power plant including fire drills and training conducted by the fire brigade and plant personnel.

The results of these assessments should be reported to the upper level management position responsible for fire protection with recommendations for improvements or corrective actions as deemed necessary.

c. The onsite management position responsible for the overall administration of the plant operations and emergency plans which include the fire protection and prevention program and which provide a single point of control and contact for all i

c onting enc es.

d. The onsite position(s) which:

Implements periodic inspections to: minimize the amount of combustibles in safety-related areas; determine the effectiveness of housekeep1ng practices; assure the availability and acceptable condition of all fire protection systems/equipment, emergency breathing apparatus, emergency lighting, communication equipment, fire stops, penetration seals, and fire retardant coatings; and assures the prompt and effective corrective actions are taken to correct conditions adverse to fire protection and preclude their recurrence.

Is respons1ble for the firefighting training for operating plant personnel and the plant's fire brigade',

design and selection of equipment; periodic inspection and testing of fire protection systems and equipment in accordance with established procedures, and evaluate test results and determine the acceptability of the systems under test.

iii. Assists in the critique of all fire drills to determine how well the training objectives have been met.

iv. Reviews and evaluates proposed work activities to identify potential transient fire loads.

vo Implements a program for 1ndoctrination of all plant contractor personnel in appropriate administrative procedures which implement the fire protection program, and the emergency procedures relative to fire protection.

17

vi. Implements a program for instruction of personnel on the proper handling of accidental events such as leaks or spills of flammable materials that are related to fire protection.

e. The onsite position responsible for fire protection quality assurance. This position should be responsible for assuring the effective implementation of the fire protection program by planned inspections, scheduled audits, and. verification that the results of these inspections of audits are promptly reported to cognizant management personnel.

f. The positions which are part of the plant fire brigade.

i. The plant fire brigade positions should be responsible for fig/ting fires. The authority and responsibility of

'ach fire brigade position relative to fire protection should be clearly defined.

ii. The responsibilities of each fire brigade position should correspond with the actions required by the f iref ighting procedures.

iii. The responsibilities of the fire brigade members under normal plant conditions should not conflict with their responsibilities during a fire emergency.

iv. The minimum number of trained fire brigade members available onsite for each operating shift should be consistent with the activities required to combat the most significant fire. The size of the fire brigade should be based upon the functions required to fight fires with adequate allowance for injuries.

v. 'Ihe recommendations f or organization, training, and equipment of "Private Fire Brigades" as specified in NFPA No. 27-1975, including the applicable NFPA publications listed in the appendix to NFPA No. 27, are considered appropriate criteria for organizing, training and operating a plant fire brigade.

PROJECT CONFORKVlCE: C. POSITION (Cont 'd)

C.l.a(4) The organizational responsibilities are defined in the fire protection program. Both the onsite and offsite positions are included and responsibilities are assigned for the complete defense-in-depth approach.

NRC GUIDELINES: C. POSITION (Cont'd)

C.l.a(5) Personnel Qualifications

a. The position responsible for formulation and implementation of the fire protection program should have within his 18

organization or as a consultant a fire protection engineer who is a graduate of an engineering curriculum of accepted standing and shall have completed not less than 6 years of engineering attainment indicative of growth in engineering competency and achievement, 3 years of which shall have been in responsible charge of fire protection engineering work.

These requirements are the eligibility requirements as a Member in the Society of Fire Protection Engineers.

b. The fire brigade members'ualifications should include satisfactory completion of a physical examination for performing strenuous activity, and of the fire brigade training described in Position C.3.d.

c. The personnel responsible for the maintenance and testing of the fire protection systems should be qualified by training and experience for such work.

d. The personnel responsible for the training of the fire brigade should be qualified by training and experience for such work.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.l.a(5) a. CP&L will comply.

b. A trained fire brigade meeting technical specification requirements is provided.

c. & d. Personnel utilized for inspection, maintenance, and training are qualified for such duties by training and experience.

NRC GUIDELINES: C. POSITION (Cont'd)

C.l.a(6) The following NFPA publications should be used for guidance to develop the fire protection program.'o.

1201-1977 "Organization for Fire Services" No. 1202-1976 "Organization of a Fire Department" No. 27 -1975 "Private Fire Brigades" PROJECT CONFORMANCE: C. POSITION (Cont'd)

CP&L will comply.

NRC GUIDELINES: C. POSITION (Cont'd)

C.l.a(7) On site where there is an operating reactor and construction or modification of other units is underway, the superintendent of the operating plant should have the lead responsibility for site fire protection.

19.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C. l.a(7) Not applicable.

NRC GUIDELINES: C. POSITION (Cont'd)

C.l.b. Fire Hazards Analysis The fire hazards analysis should demonstrate that the plant will maintain the ability to perform safe shutdown functions and minimize radioactive releases to the environment in the event of a fire.

The fire'hazards analysis should be performed by qualified fire protection and reactor systems engineers to (1) consider potential in situ and transient fire hazards; (2) determine the consequences of fire in any location in the plant on the ability to safely shutdown the reactor or on the ability to minimize and control the release of radioactivity to the environment; and (3) specify measures for fire prevention, fire detection, fire suppression, and fire containment and alternative shutdown capability as required for each fire area containing structures, systems, and components important to safety that are in conformance with NRC guidelines and regulations.

"Worst case" fires need not be postulated to be simultaneous with nonfire-related failures in safety systems, plant accidents, or the most severe natural phenomena.

On multiple-reactor sites, unrelated fires in two or more units need not be postulated to occur simultaneously. Fires involving facilities shared between units and fires due to manmade site-related events that have a reasonable probability of occurring and affecting more than one reactor unit (such as an aircraft crash) should be considered.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.l.b. Fire Hazards Anal sis The fire hazards analysis demonstrates that the plant will maintain the ability to perform safe shutdown functions and minimize radioactive releases to the environment in the event of a fire.

The fire hazards analysis was performed by qualified fire protection engineers and other engineers knowledgeable of nuclear power plant design. It considered potential in situ and transient fire hazards', it determined the consequences of a fire in any location in the plant on the ability to safely shutdown the reactor or on the ability to minimize and control the release of radioactivity to the environment; and it specified measures for fire prevention, fire detection, fire suppression, and fire containment and alternative shutdown capability as required for each fire area containing structures, systems, and components needed to achieve and maintain cold shutdown following NRC guidelines and regulations, showing 20

conformance with the guidelines or demonstrating the equivalency of alternative approaches.

"Worst case" fires were not postulated to be simultaneous with nonfire-related failures in safety systems, plant accidents, or the most severe natural phenomena.

NRC GUIDELINES: C. POSITION (Cont'd)

C.l.b. Fire Hazards Analysis (Cont'd)

Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under postfire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents. Three levels of fire damage limits are established according to the safety function of the structure, system, or component.

Sa f etv Function Fire Dama e Limits Hot shutdown One train of equipment necessary to achieve hot shutdown from either the control room or emergency control station(s) must be maintained free of fire damage by a single fire, including an exposure fire.

Cold shutdown Both trains of equipment necessary to achieve cold shutdown may be damaged by a single fire, including an exposure fire, but damage must be limited so that at least one train can be repaired or made operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> using onsite capability.

Design basis Both trains of equipment necessary for accident mitigation of consequences following design basis accidents may be damaged by a single exposure fire.

The most stringent fire damage limit should apply for those systems that fall into more than one category. Redundant systems used to mitigate the consequences of other design basis accidents but not necessary for safe shutdown may be lost to a single exposure fire. However, protection shall be provided so that a fire within only one such system will not damage the redundant system.

PROJECT CONFORHANCE: C. POSITION (Cont'd)

C.l.b. Fire Hazards Anal sis Three levels of fire damage limits were established according to the safety function of the 'structure, system, or component.

21

1' Safety Function Fire Damage Limits Hot standby One train of equipment necessary to achieve hot standby from either the control room or emergency control station(s) is maintained free of fire damage by a single fire, including an exposure fire.

Cold shutdown Both trains of equipment necessary to achieve cold shutdown may be damaged by a single fire, including an exposure fire, but damage is limited so that at least one train can be repaired or made operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> using onsite capability.

Design basis Both trains of equipment necessary for accident mitigation of consequences following design basis accidents may be damaged by a single exposure fire.

The most stringent fire damage limit was applied for those systems that faX'nto more than one category. Redundant systems used to mitigate the consequences of other design basis accidents but not necessary for safe shutdown were not protected from a single exposure fire. However,

'protection was provided so that a fire within only one such system will not damage the redundant system.

NRC GUIDELINES: C. POSITION (Cont'd)

C.l.b. Fire Hazards Analysis (Cont'd)

The fire hazards analysis should separately identify hazards and provide appropriate protection in locations where safety-related losses can occur as a result of:

(I) Concentrations of combustible contents, including transient fire load due to combustibles expected to be used in normal operations such as refueling, maintenance, and modifications; (2) Continuity of combustible contents, furnishings, building materials, or combinations thereof in configurations conducive to fire spread; (3) Exposure fire, heat, smoke, or water exposure, including those that may necessitate evacuation from areas that are required to be attended for safe shutdown; (4) Fire in control rooms or other locations having critical saf ety"related functions; (5) Lack of adequate access or smoke removal facilities that impede fire extinguishment in safety-related areas; 22

(6) Lack of explosion-prevention measures; (7) Loss of electric power or control circuits; (8) Inadvertent operation of fire suppression systems.

The fire hazards analysis should verify that the NRC fire protection program guidelines have been met. The analysis should list applicable elements of the program, with explanatory statements as needed to identify location, type of system, and design criteria. The analysis should identify and justify any deviations from the regulatory guidelines. Justification for deviations from the regulatory guidelines should show that an equivalent level of protection will be achieved.

Deletion of a protective feature without compensating alternative protection measures will not be acceptable, unless it is clearly demonstrated that the protective measure is not needed because of the design and arrangement of the particular plant.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.l.b. Fire Hazards Analysis (Cont'd)

The fire hazard analysi,s separately identifies hazards and appropriate protection in locations where safety-related losses can result from:

(1) Concentrations of combustible contents, including transient fire load due to combustibles expected to be used in normal operation of the plant. During refueling, maintenance, and modifications of the plant transient f ire loading is controlled through Fire Protection Procedure 001.

(2) Continuity of combustible contents, furnishings, building materials, or combinations thereof in configurations conducive to fire spread; (3) Exposure fire, heat, smoke, or water exposure, including those that may necessitate evacuation from areas that are required to be attended for safe shutdown; (4) Fire in control room or other locations having critical saf ety-related functions; (5) Lack of adequate access or smoke removal facilities that impede fire extinguishment in safety-related areas; (6) Lack of explosion"prevention measures; (7) Loss of electric power or control circuits; (8) Inadvertent operation of fire suppression systems.,

As stated in FSAR Subsections 9.5.1.1.5 and 9.5.1.2.3 the evaluation of the consequences of inadvertent operation of the fire suppression 23

system is addressed in the description of each system used in safety-related areas. These systems require two steps for the release of water, thus preventing any potential misoperation, mechanical damage, or premature discharge of water. Further, as detailed in each fire hazard analysis Item 8, Fire Suppression System, equipment which could be adversely impacted by automatic water suppression system was provided with water resistant enclosures and/or installed on pedestals or racks. Water seals will be provided inside conduit entering power centers and motor control centers where required to prevent water entry.

The fire hazards analysis was performed to meet the intent of Appendix A to BTP-APCSB 9.5-1 and identifies the location, type of system and design criteria. It describes the fire hazards for each fire area and the justifications for the protection provided.

Alternate protection measures are provided where plant design and arrangement indicate the alternate offers, at a minimum, equivalent protection.

As described in the Safe Shutdown Analysis in Case of Fire, Section 1, Chronology of Fire Protection Submittals the Shearon Harris fire protection program was based on the guidelines of Appendix A to USNRC Branch Technical Position (BTP) APCSB 9.5-1 dated August 23, 1976 for plants docketed prior to July 1, 1976, and the PSAR Fire Hazards Analysis (FHA) was performed in accordance with NRC Letter of September 30, 1976 on the basis of the above listed criteria.

On June 26, 1980 CP&L submitted the SHNPP FSAR to the NRC, at which time the FHA was expanded following RG 1.70 Revision 3 - November 1978, Subsection 9.5.1.3 Safety Evaluation (Fire Hazards Analysis) however, the design criteria and design basis were the same as established in the PSAR Amendment 54.

The guidelines of an NRC BTP may be followed, or acceptable alternative may be provided by a Utility. Appendix A to BTP-APCSB 9.5"1 was not complied with as written by NRC. Alternatives to it were included in the SHNPP design and accepted by the NRC at the time when the Plant Construction Permit was issued.

The FHA presently filed with the NRC, FSAR Section 9.5-1 Appendix 9.5A did not address Appendix R or NUREG-0800 Criteria, because Appendix R was issued on November 19, 1980, becoming effective on February 17, 1981 and NUREG-0800 was issued on July 1, 1981. Both these documents were issued after the FSAR Submittal.

SHNPP Safe Shutdown Analysis in Case of Fire was performed in response to NRC Questions 280.13 and 280.14 and was submitted to the NRC. In this analysis either conformance to 10CFR50 Appendix R Section III.G was indicated or a deviation request was made for which justification is contained in the Safe Shutdown Analysis in Case of Fire.

24 (3276PPC)

NUREG-0800 BTP 6KB 9.5-1 was addressed in response to NRC Question 280.1 and submitted to the NRC. This comparison identifies and justifies deviations from these guidelines.

NRC GUIDELINES: C. POSITION (Cont'd)

C.l.c. Fire Suppression S stem Desizn Basis (1) Total reliance should not be placed on a single fire suppression system. Appropriate backup fire suppression capability should be provided. (Contend PROJECT CONFORMANCE: C. POSITION C.l.c. Fire Suppression S stem Design Basis (1) Tote'"ance was not placed on a single fire suppression system. Appropriate backup fire suppression capability was provided. A full complement of appropriate hand fire extinguishers are installed throughout the plant to provide either initial firefighting capability or backup to any automatic or manual suppression systems. As a backup to hand fire extinguishers and/or automatic suppression systems, a system of 1-1/2 inch small hose connections are installed throughout so that all areas within each building will be reached with 100 feet of this hose, attached to a standpipe co"..-.'- '.-;.. As a final backup to all of the protection outlined abovo. ~>>t side hydrants and hose houses are also provided.

NRC GUIDELINES: POSITION (Cont'd)

C.l.c. Fire Suppression Desi n Basis (Cont'd)

(2) A sin~'~ active failure or a crack in a moderate-energy line (pipe) in'he fire suppression system should not impair both the pri .. ~ad backup fire su p pr es si on capability. For example, neither the failure of a fire pump, its power supply or controls nor a crack in a moderate-energy line in the fire suppression system, should result in loss of function of both sprinkler and hose standpipe systems in an area protected by such primary backup systems.

PROJECT CONFO~~~<<E: POSITION (Cont'd)

C.l.c(2) A single active failure or a crack in a moderate-energy line (pipe) in the fire suppression system will not impair both the primary and backup fire suppression capability. For example, neither the failure of a fire pump, its power supply or controls nor a crack in a moderate-energy line in the fire suppression sys .-:.,: 11 not result in loss of function of both sprinkler and hose standpipe systems in an area protected by such primary backup sys t ems.

Where feasible, fire protection, detection and suppression system control circuitry are routed through areas not served by the systems and thus not exposed to failure by the fire incident.

NRC GUIDELINES: C. POSITION (Cont'd)

C.l.c(3) As a minimum, the fire suppression system should be capable of delivering water to manual hose stations located within hose reach of areas containing equipment required for safe plant shutdown following the safe shutdown earthquake (SSE). In areas of high seismic activity, the staff will consider on a case-by-case basis the need to design the fire detection and suppression systems to be functional following the SSE.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.l.c(3) The fire suppression system is capable of delivering water to manual hose stations located within reach of areas containing equipment required for safe plant shutdown following the safe shutdown earthquake (SSE) with the exception of the Diesel Generator Building, Diesel Fuel Oil Storage Building and the Emergency Service Water Intake Structures.

NRC GUIDELINES: C. POSITION (Cont'd)

C.l.c(4) The fire protection systems should retain their original design capability for (a) natural phenomena of less severity and greater frequency than the most severe natural phenomena (approximately once in 10 years) such as tornadoes, hurricanes, floods, ice storms, or small-intensity earthquakes that are characteristic of the geographic region, and (b) potential man-made site-related events such as oil barge collisions or aircraft crashes that have a reasonable probability of occurring at a specific plant site. The effects of lightning strikes should be included in the overall plant fire protection.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.l.c(4) The fire protection systems were designed to retain their original design capability for (a) natural phenomena of less severity and greater frequency than the most severe natural phenomena (approximately once in 10 years) such as tornadoes, hurricanes, floods, ice storms, or small-intensity earthquakes that are characteristic of the geographic region and (b) for potential man-made site-related events refer to FSAR Subsection 2.2.3. Lightning protection is provided for the plant.

NRC GUIDELINES: C. POSITION (Cont'd)

C.l.c(S) The consequences of inadvertent operation of or a crack in a moderate energy line in the fire suppression system should meet the guidelines specified for moderate-energy systems outside containment in SRP Section 3.6.1.

26 (3276PPC/1 js )

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.l.c(5) The consequences of a crack in a moderate-energy line in the fire suppression system has been evaluated and meets the guidelines specified in SRP 3.6.1 as stated in FSAR Subsection 3.6.1 and 3.6.2. Inadvertent operation of an automatic suppression system is discussed in Project Conformance Item C.l.b.

NRC GUIDELINES: C. POSITION (Cont'd)

C.l.d. Alternative or Dedicated Shutdown Alternative or dedicated shutdown capability should be provided where the protection of systems whose functions are required for safe shutdown is not provided by established fire suppression methods or by Position C.5.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.l.d. Alternative shutdown systems have been provided for the control room, process and instrumentation room and HVAC room located on elevation 305'f the Reactor Auxiliary Building. A dedicated HVAC System has been provided for the PIC room located on elevation 286'f the Reactor Auxiliary Building.

NRC GUIDELINES: C. POSITION (Cont'd)

C.l.e.

~ ~ ~ Im lementation of Fire Protection Pro rams (1) The fire P rotection

~

P ro g ram ( P lans ~ P ersonnel and equipment) for buildings storing new reactor fuel and for adjacent fire areas that could affect the fuel storage area should be fully operational before fuel is received at the site. Such adjacent areas include those whose flames, hot gases, and fire"generated toxic and corrosive products may jeopardize safety and surveillance of the stored fuel.

(2) The fire protection program for an entire reactor unit should be fully operational prior to initial fuel loading in that reactor unit.

(3) On reactor sites where there is an operating reactor and construction or modification of other units is under way, the fire protection program should provide for continuing evaluation of fire hazards. Additional fire barriers, fire protection capability, and administrative controls should be provided as necessary to protect the operating unit from construction fire hazards.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.l.e. (1) The fire protection program (plan, personnel, and equipment) for the Shearon Harris Nuclear Power Plant New Fuel Area shall comply with the fire protection provisions of the Special Material Handling License.

27 (3276PPC)

(2) CP&L wi11 comply.

(3) Not applicable.

0 NRC GUIDELINES: C. POSITION {Cont'd)

C.2. Administrative Controls Administrative controls should be used to maintain the perf ormance of the fire protection system and personnel. These controls should establish procedures to:

a~ prohibit bulk storage of combustible materials inside or adjacent to safety-related buildings or systems during operation or maintenance periods. Regulatory Guide 1.39 provides guidance on housekeeping, including the disposal of combustible materials.

b. Govern the handling and limitation of the use of ordinary combustible materials, combustible and flammable gases and liquids, high efficiency particulate air and charcoal filters, dry ion exchange resins, or other combustible supplies in safety"related areas.

C ~ Govern the handling of and limit transient fire loads such as combustible and flammable liquids, wood and plastic products, or other combustible materials in bui1dings containing safety-related systems or equipment during all phase of operating, and especially during maintenance, modification, or refueling operations.

d. Designate the onsite staff member responsible for the inplant fire protection review of proposed work activities to identify potential transient fire hazards and specify xequired additional fire protection work activity procedure.

e. Govern the use of ignition sources by use of a flame permit system control welding, flame cutting, brazing, or soldering operations. A separate permit should be issued for each area where work is to be done. If work continues over more than one shift, the permit should be valid for not more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the plant is operating or for the duration of a particular job during plant shutdown.

Control the removal from the area of all waste, debris, scrap, oil spills, or other combustibles resulting from the work activity immediately following completion of the activity, or at the end of each work shift, whichever comes first.

g~ Govern leak testing; similar procedures such as airflow determination should use one of the commercially available techniques. Open flames or combustion-generated smoke should not be p ermi t t ed.

h. Maintain the periodic housekeeping inspections to ensure with these administrative controls.

continued'ompliance 28

Control the use of specific combustibles in safety-related areas.

All wood used in safety-related areas during maintenance, modification, or refueling operation (such as lay-down blocks or scaffolding) should be treated with a flame retardant. Equipment or supplies (such as new fuel) shipped in untreated combustible packing containers may be unpacked in safety-related areas if required for valid operating reasons. However, all combustible materials should be removed from the area immediately following unpacking. Suc'n transient combustible material, unless stored in approved containers, should not be left unattended during lunch breaks, shift changes, or other similar periods. Loose combustible packing material such as wood or paper excelsior, or polyethylene sheeting should be placed in metal containers with tight-fitting self-closing metal covers.

Disarming fire detection or fire suppression systems should be controlled by a permit system. Fire watches should be established in areas where systems are so disarmed.

Successful fire protection requires testing and maintenance of the fire protection equipment and the emergency lighting and communication. A tes" plan that lists the individuals and their responsibilities in connection with routine tests and inspections of the fire detection and protection systems should be developed. The test plan should contain the types, frequency, and detailed procedures for testing. Procedures should also contain instructions on maintaining fire protection during those periods when the fire protection system is impaired or during periods of plant maintenance, e.g., fire watches or temporary hose connections to water systems.

Control actions to be taken by an individual discovering a fire, for example, notification of control room, attempt to extinguish fire, and actuation of local fire suppression systems.

Control actions to be taken by the control room operation to determine the need for brigade assistance upon report of a fire or receipt of alarm on control room annunciator panel, for example, announcing location of fire over PA system, sounding fire alarms, and notifying the shift supervisor and the fire brigade leader of the type, size, and location of the fire.

Control actions to be taken by the fire brigade after notification by the control room operator of a fire, for example, assembling in a designated location, receiving directions from the fire brigade leader, and discharging specific firefighting responsibilities, including selection and transportation of firefighting equipment to f ire location, selection of protective equipment, operating instructions for use of fire suppression systems, and use of preplanned strategies for fighting fires in specfic areas.

29

V'

o. Define the strategies for fighting fires in all safety-related areas and areas presenting a hazard to safety-related equipment. These strategies should designate:

(l) Fire hazards in each area covered by the specific prefire plans.

(2) Fire extinguishants best suited for controlling the fires associated with the fire hazards in that area and the nearest location of these extinguishants.

(3) Most favorable direction from which to attack a fire in each area in view of the ventilation direction, access hallways, stairs, and doors that are most likely to be free of fire, and the best station or elevation for fighting the fire. All access and egress routes that involve locked doors should be specifically identified in the procedure with the appropriate precautions and methods for access specified.

(4) Plant systems that should be managed to reduce the damage potential during a local fire and the location of local and remote controls for such management (e.g., any hydraulic or electrical systems in the zone covered by the specific firefighting procedure that could increase the hazards in the area because of overpressurization or electrical hazards). 4 (5) Vital heat-sensitive system components that need to be kept cool while fighting a local fire. Particularly hazardous combustibles that need cooling should be designated.

(6) Organization of firefighting, brigades and the assignment of special duties according to job title so that all firefighting functions are covered by any complete shift personnel complement. These duties include command control of the brigade, transporting fire suppression and support equipment to the fire scenes, applying the extinguishant to the fire, communication with the control room, and coordination with outside fire departments.

(7) Potential radiological and toxic hazards in fire zones.

(8) Ventilation system operation that ensures desired plant air distribution when the ventilation flow is modified for fire containment or smoke clearing operation.

(9) Operations requiring control room and shift engineer coordination or authorization.

(10) instructions for plant operators and general plant personnel during fire.

30

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.2. Administrative Controls Procedures are established to: control the use and storage of combustibles and flammables, control ignition sources through the use of a permit system, prohibit open flames or combustion-generated smoke for leak testing, provide for inspection programs to verify adherence to procedures, provide for periodic surveillance of fire protection systems, provide controls for disabling fire protection systems, posting of watches when systems andlor barriers are degraded, provide for pre-fire plans, control storage of combustibles, hazardous chemicals, and resins. The procedures comply with Sections 2.a through 2.o.

NRC GUIDELINES: C. POSITION (Cont'd)

I, a ~ The need for good organization, training, and equipping of fire brigades at nuclear power plant sites requires that effective measures be implemented to ensure proper discharge of these functions. The guidance in Regulatory Guide 1.101, "Emergency Planning for Nuclear Power Plants," should be followed as applicable.

A site fire brigade trained and equipped for firefighting should be established to ensure adequate manual firefighting capability for all areas of the plant containing structures, systems, or components important to safety. The fire brigade should be at least five members on each shift. The brigade leader and at least two brigade members should have sufficient training in or knowledge of plant safety-related systems to understand the effects of fire and fire suppressants on safe shutdown capability. The qualification of fire brigade members should include an annual physical examination to determine their ability to perform strenuous firefighting activities. The shift supervisor should not be a member of the fire brigade. The brigade leader shall be competent to assess the potential safety consequences of a fire and advise control room personnel. Such competence by the brigade leader may be evidenced by possession of an operator's license or equivalent knowledge of plant safety-related systems.

C ~ The minimum equipment provided for the brigade should consist of personal protective equipment such as turnout coats, boots, gloves, hard hats, emergency communications equipment, portable lights,,

portable ventilation equipment, and portable extinguishers. Self-contained breathing apparatus using full-face positive-pressure masks approved by NIOSH (National Institute for Occupational Safety and Health approval formerly given by the U.S. Bureau of Mines) should be provided for fire brigade, damage control, and control room personnel. At least 10 masks shall be available for fire brigade personnel. Control room personnel may be furnished 31 (3276PPC)

breathing air by a manifold system piped from a storage reservoir if practical. Service or rated operating life shall be a minimum of one-half hour for the self-contained units.

At least two extra air bottles should be located onsite for each self-contained breathing unit. In addition, an onsite 6-hour supply of reserve air should be provided and arranged to permit quick and complete replenishment of exhausted supply air bottles as they are returned. If compressors are used as a source of breathing air, only units approved for breathing air shall be used; compressors shall be operable assuming a loss of offsite power. Special care must be taken to locate the compressor in areas free of dust and contaminants.

d. The fire brigade training program shall ensure that the capability to fight potential fires is established and maintained. The program shall consist of an initial classroom instruction program followed by periodic classroom instruction, firefighting practice, and fire drills.

(1) The initial classroom instruction should

~ include.'

a) Indoctrination of the plant firef igh ting i plan wi th sp ecif c identification of each individual's responsibilities.

(b) Identification of the type and location of fire hazards and associated types of fires that could occur in the plant.

(c) The toxic and corrosive characteristics of expected products of combustion.

(d) Identification of the location of firefighting equipment for each fire area and familiarization with the layout of the plant, including access and egress routes to each area.

(e) The proper use of available firefighting equipment and the corrective method of fighting each type of fire. The types of fires covered should include fires in energized electrical equipment, fires in cables and cable trays, hydrogen fires, fires involving flammable and combustible liquids or hazardous process chemicals, fires resulting from construction or modification (welding), and record file fires.

(f) The proper use of communication, lighting, ventilation, and emergency breathing equipment.

(g) The proper method for fighting fires inside buildings and confined spaces.

(h) The direction and coordination of the firefighting activities (fire brigade leaders only).

32

(i) Detailed review of firefighting strategies and procedures.

(j) Review of the latest plant modifications and corresponding changes in firefighting plans.

(k) Training of the plant fire brigade should be coordinated with the local fire department so that responsibilities and duties are delineated in advance. This coordination should be part. of the training course and should be included in the training of the local fire department staff.

(1) Local fire departments should be provided training in operational precautions when fighting fires on nuclear po~er plant sites and should be made aware of the need for radiological protection of personnel and the special hazards associated with a nuclear power plant site.

Note: Items (i) and (j) may be deleted from the training of no more than two of the nonoperations personnel who may be assigned to the fire brigade.

(2) The instruction should be provided by qualified individuals who are knowledgeable, experienced, and suitably trained in fighting the types of fires that could occur in the plant and in using the types of equipment available in the nuclear power plant.

(3) Instruction should be provided to all fire brigade members and fire brigade leaders.

(4) Regular planned meetings should be held at least every 3 months for all brigade members to review changes in the Eire protection program and other subjects as necessary.

(5) Periodic refresher training sessions shall be held to repeat the classroom instruction program for all brigade members over a 2-year period..These sessions may be concurrent with the regular planned meetings.

(6) Practice (a) Practice sessions should be held for each shift fire brigade on the proper method of fighting the various types of fires that could occur in a nuclear power plant. These sessions shall provide brigade members with experience in actual fire extinguishment and the use of emergency breathing apparatus under strenuous conditions encountered in firefighting.

(b) These practice sessions should be provided at least once per year for each fire brigade member.

33

(7) Drills (a) Fire brigade drills should be performed 1n the plant so that the fire brigade can practice as a team.

(b) Drills should be performed at regular 1ntervals not to exceed 3 months for each shift fire brigade. Each fire brigade memoer should participate in each drill, but must participate in at least two drills per year.

A sufficient number of these drills, but not less than one for each shift fire brigade per year, should be unannounced to determine the firefighting readiness of the plant fire brigade, brigade leader, and fire protect1on systems and equipment. Persons planning and authorizing an unannounced drill should ensure that the responding shift fire brigade members are not aware that a drill is being planned until it is begun. Unannounced drills should not be scheduled closer than 4 weeks.

At least one drill per year should be perf ormed on a "back shift" for each shift fire brigade.

(c) The drills should be preplanned to establish the training objectives of the drill and should be critiqued to determine how well the training objectives have been met. Unannounced drills should be planned and critiqued by members of the management staff responsible for plant safety and fire protection. Performance deficiencies of a fire brigade or of individual fire brigade members should be remedied by scheduling additional training for the brigade or members.

Unsatisfactory drill perf ormance should be followed by a repeat drill within 30 days.

(d) These drills should provide for local fire department participation periodically (at least annually).

(e) At 3-year intervals, a randomly selected unannounced drill should be critiqued by qualified 1ndividuals independent of the licensee's staff. A copy of the written report from such individuals should be available for NRC review.

(f) Drills should as a min1mum include the following:

1. Assessment of fire alarm effectiveness, time required to notify and assemble fire brigade, and selection, placement, and use of equipment and firefighting strategies.

ii. Assessment of each brigade member's knowledge of his or her role in the firefighting strategy for the area assumed to contain the Assessment of the brigade members'onf ormance with 'ire.

34

established plant firefighting procedures and use of fire-fighting equipment, including self-contained emergency breathing apparatus, communication equipment, and ventilation equipment, to the extent practicable.

iii. The simulated use of firefighting equipment required to cope fire selected for the drill.

with the situation and type of The area and type of fire chosen for the drill should differ from those used in the previous drills so that brigade members are trained in fighting fires in various plant areas. The situation selected should simulate the size and arrangement of a fire that could reasonably occur in the area selected, allowing for fire development due to the time required to respond, to obtain equipment, and organize for the fire, assuming loss of automatic suppression capability.

iv. Assessment of brigade leaders direction of the firefighting efforting as to thoroughness, accuracy, and effectiveness.

(8) Rec ord s Individual records of training provided to each fire br'gade member, including drill critiques, should be maintained for at least 3 years to ensure that each member receives training in all parts of the training program. These records of training should be available for NRC review.

Retraining or broadened training for firefighting within buildings should be scheduled for all those brigade members whose performance records show d ef icienci es.

( 9) Guidance Documents NFPA 27, "Private Fire Brigade," should be followed in organization, training, and fire drills. This standard also is applicable for the inspection and maintenance of firefighting equipment. Among the standards referenced in this document NFPA 197, "Training Standard on Initial Fire Attacks," should be utilized as applicable. NFPA booklets and pamphlets listed in NFPA 27 may be used as applicable for training references. In addition, courses in fire prevention and fire suppression that are recognized or sponsored by the fire protection industry should be utilized.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C. 3. Fir e brigad e The fire brigade consists of five persons, three of which are knowledgeable in the effects of fire on plant operation and safe shutdown capability. The brigade leader possesses an operator's license or has demonstrated equivalent knowledge of saf ety-related systems.

35

Full'protection clothing is provided for the brigade including 10 SCBAs.

Spare cylinders for one hour are supplied onsite for each SCBA. An addition six-hour supply is located onsite for replenishment.

The team leader will have access to the key locker to gain access to locked fire doors. Pire doors will be monitored in accordance with technical specifications and/or one of the choices in C.5(a)(5).

See response to question 630.8 as transmitted on July 20, 1983 NRC GUIDELINES: C. POSITION (Cont'd)

C.4. Qualit Assurance Pro ram The quality assurance (QA) programs of applicants and contractors should ensure that the guidelines for design, procurement, installation, and testing and the administrative controls for the fire protection systems for safety-related areas are satisfied. The QA program should be under the management control of the QA organization. This control consists of (1) formulating a fire protect'n QA program that incorporates suitable requirements and is acceptable to the management responsible for fire protection or verifying that the program incorporates suitable requirements and is acceptable to the management responsible for fire protection, and (2) verifying the effectiveness of the QA program for fire protection through review, surveillance, and audits. Perf ormance of other QA program functions for meeting the fire protection program requirements may be performed by personnel outside of the QA organization. The QA pxogram for fire protection should be part of the overall plant QA program. It should satisfy the specific criteria listed below.

a. Desi n and Procurement Document Control Measures should be established to ensure that the guidelines of the regulatory position of this guide are included in design and procurement documents and that deviations therefrom are controlled.

b. Instructions, Procedures and Drawines Inspecting, tests, administrative controls, fire drills, and training that govern the fire protection program should be prescribed by documented instructions, procedures, or drawings and should be accomplished in accordance with these documents.

c. Control of Purchased Material, E uioment and Services Measures should be established to ensure that purchased material, equipment, and services conform to the procurement documents.

36

d. Insoection A program for independent inspection of activities affecting fire protection should be established and executed by or for the organization perf orming,the activity to verify conf ormance with documented installation drawings and test procedures for accomplishing the activities.

e. Test and Test Control A test program should be established and implemented to ensure that testing is performed and verified by inspection and audit to demonstrate conformance witn design ~and system readiness requirements. The tests should be performed in accordance with written test procedures; test results should be properly evaluated and acted on.

f. Inspection, Test, and 0 eratina Status Measures should be established to provide for the identification of items that have satisfactorily passed required tests and inspections.

g. None onr ormine Items Measures should be established to control items that do not conform to specified requirements to prevent inadvertent use or installation.

h. Corrective Action Measures should be established to ensure that conditions adverse to fire protection, such as failures, malfunctions, dericiencies, deviations, defective components, uncontrolled combustible material and nonconformances, are promptly identified, reported, and corrected.

Records Records should be prepared and maintained to furnish evidence that the criteria enumerated above are being met for activities affecting the fire protection program.

Audits should be conducted to verify compliance with the fire protection program, including design and procurement documents, instructions, procedures and drawings, and inspection and test activities.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.4. Quality Assurance Program The Design Construction QA Program is described in the FSAR and was approved by the NRC staff. The Engineering and Construction fire 37

protection quality assurance program was approved by the NRC during the construction permit review. The fire protection QA program, which is under the management control of the QA organization, has assured the satisfaction of QA guidelines during the design procurement installation, and acceptance testing of fire protection equipment and will assure their continued systems provided for the plant and inspection, testing, maintenance, and administrative control after the plant becomes operational. As part of management control, the QA organization has:

(1) Developed a fire protection QA program, incorporating suitable requirements necessary for the provision of an effective Fire Protection System.

(2) Verified the acceptability of the fire protection QA program to the management responsible for fire protection, and (3) Verified through audit and surveillance, the effectiveness of the QA program for fire protection.

For components of the fire protection program designed, specified, procured, manufactured, fabricated, and installed prior to institution of the formal fire protection Quality Assurance Program (February 18, 1977),

sufficient control was exercised and followed to the extent practical a an a d thee activities performed evaluated during subsequent audit, surveillance, and design review activities.

The operational Quality Assurance Program is described in Section 17.2 of the FSAR.

NRC GUIDELINES: C. POSITION (Cont'd)

I C.5. General Plant Guidelines C. 5.a. Buildin Design (1) Fire barriers with a minimum fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> should be provided to:

(a) Separate safety-related systems from any potential fires in non-safety-related areas that could affect their ability to perf orm their safety function; (b) Separat e redundant divisions or trains of saf ety-related systems from each other so that both are not subject to damage from a single fire,'c)

Separate individual units on a multiple-unit site unless the requirements of General Design Criterion 5 are met with respect to fires.

38

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5. General Plant Guidelines C.5.a. Buildin Desi n (1) Fire barriers with a minimum fire resistance rating of 3 hours are provided to satisfy that:

(a) Safety-related systems are separated from non-safety areas that could affect their ability to perform their safety functions. Turbine Building and Waste Processing Building are separated by three-hour rated fire barriers from building housing safety-related equipment and systems.

(b) Redundant divisions or trains of safety-related systems are separated from each other so that both are not subject to damage from a single fire to the extent practical. However, a single train of ductwork provides air between redundant air handling units AH-15A and AH-15B and the Control Room. The same is true between the Electrical Equipment Protection Rooms and redundant air handling units AH-16A and AH-16B. Redundant safety-related systems required for safe shutdown are separated in accordance with the requirements of Section III.G.2 of Appendix R to 10CFR50, or a deviation was requested, as detailed in the Safe Shutdown Analysis in Case of Fire. For redundant safety-related systems not required for Safe Shutdown, Regulatory Guide 1.75 separation criteria were followed, as described in the FSAR Section 8.3. In most cases the equipment was separated by distance in excess of that prescribed by R.G. 1.75, structural barriers, provision of automatic suppression and detection, or combination thereof.

(c) Not applicable.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.a(2) Appropriate fire barriers should be provided within a single safety division to separate components that present a fire hazard to other safety-related components or high concentrations of safety-related cables within that division.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.a(2) Fire barriers are provided as required within a single safety division to separate components that present a fire hazard to other safety-related components or high concentrations of safety-related cables within that division.

39 (3276PPC)

/

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.a(3)

~ ~ Openings through fire barri ers for pipe, conduit, and cable trays which separate fare areas should be sealed or closed to provide a fire resistance rating at least equal to that required of the barrier itself. Openings inside conduit larger than 4 inches in diameter should be sealed at the fire barrier penetration. Openings inside conduit 4 inches or less in diameter should be sealed at the fire barrier unless the conduit extends at least 5 feet on each site of the fire barrier and is sealed either at both ends or at the fire barrier with noncombustible material to prevent the passage of smoke and hot gases. Fire barrier penetrations that must maintain environmental isolation or pressure differentials should be qualified by test to maintain the barrier integrity under such conditions.

Penetration designs will utilize only noncombustible materials and should be qualified by tests. The penetrations qualification tests should use the time-temperature exposure curve specified by ASMT E-119, "Fire Test of Building Construction and Materials." The acceptance criteria for the test should require that:

(a) The fire barrier penetration has withstood the fire endurance test without passage of'lame or ignition of cables on the unexposed side for a period of time equivalent to the fire resistance rating required of the barrier.

(b) The temperature levels recorded for the unexposed side are analyzed and demonstrate that the maximum temperature does not exceed 325'F (c) The fire barrier penetration remains intact and does not allow projection of water beyond the unexposed surface during the hose stream test. The stream shall be delivered through a 1< inch nozzle set at a discharge angle of 30 degrees with a nozzle pressure of 75 psi and a minimum discharge of 75 gpm with the tip of the nozzle a maximum of 6 ft from the exposed face; or the stream shall be delivered through a 1< inch nozzle set at a discharge angle of 15 degrees with a nozzle pressure of 75 psi and a minimum discharge of 75 gpm with the tip of the nozzle a maximum of 10 ft from the exposed face; or the stream shall be delivered through a 2< inch national standard playpipe equipped with a 1< inch tip, nozzle pressure of 30 psi, located 20 ft from the exposed face.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.a(3)

~ ~ Openings through fire barriers for pipe, conduit, and cable trays which separate fire areas will be sealed or closed to 40 (3276PPC)

,it ~

V provide a fire resistance rating at least equal to that required of the barrier itself. Openings inside conduit larger than 4 inches in diameter will be sealed at the fire barrier penetration. Openings inside conduit 4 inches or less in diameter will be sealed with a tested fire seal unless the conduit'xtends at least 5 feet on each side of the fire barrier and will be sealed either at both ends at the first available access, or at the fire barrier with noncombustible material to prevent the passage of smoke and hot gases. Fire barrier penetrations that must maintain environmental isolation or pressure differentials will be qualified by test to maintain the barrier integrity under such conditions'enetrations designs will utilize only noncombustible materials and will be qualified by tests. The penetrations qualification tests will use the time-temperature exposure curve specified by ASTM E-119, "Fire Test of Building Construction and Materials."

The acceptance criteria for the test will require that:

(a) The fire barrier penetration has withstood the fire endurance test without passage of flame or ignition of cables on the unexposed side for a period of time equivalent to the fire resistance rating required of the barrier.

(b) The temperature levels recorded for the unexposed side are analyzed and demonstrate that the maximum temperature does not exceed an average of more than 250'F above its initial temperature; if any temperature readings on the unexposed surface exceed 250'F rise by greater than 30'F, the reason shall be investigated and documented in the test report.

(c) The fire barrier penetration remains intact and does not allow projection of water beyond the unexposed surface during the hose stream test. The stream will be delivered through a 1-1/2 inch nozzle set at a discharge angle of 30 degrees with a nozzle pressure of 75 psi and a minimum discharge of 75 gpm with the tip of the nozzle a maximum of 6 ft from the exposed face', or the stream will be delivered through a l-l/2 inch nozzle set at a discharge angle of 15 degrees with a nozzle pressure of 75 psi and a minimum discharge of 75 gpm with the tip of the nozzle a maximum of 10 ft from the exposed face', or the stream will be delivered through a 2-1/2 inch national standard playpipe equipped with 1-1/2 inch tip, nozzle pressure of 30 psi, located 20 ft from the exposed face; or the stream will be in accordance with Nuclear Mutual Limited Appendix A-14, which follows a modified IEEE 634.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.a(4) Penetration openings for ventilation systems should be protected by fire dampers having a rating equivalent to that required of 41 (3276PPC)

the barrier (see NFPA-90A, "Air Conditioning and Ventilating Systems" ). Flexible air duct coupling in ventilation and filter systems should be noncombustible.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.a(4) Penetration openings for ventilation systems will be protected by fire dampers having a rating equivalent to that required of the barrier per NFPA-90A, "Air Conditioning and Ventilating Systems" with the following exceptions i) Exhaust and intakes at exterior walls, stacks and roofs.

Because these walls are not contiguous with fire areas was not necessary to provide fire dampers.

it ii) Transfer air from RAB, HVAC equipment room to the tank area Elevation 286 because the tank area has negligible combustibles.

HVAC ductwork penetrating floors in RAB which are designated fire analysis boundaries within fire areas 1-A-BAL and 12-A-BAL. See the Safe Shutdown Analysis in Case of Fire for justification of these deviations.

Flexible air duct coupling is utilized in ventilation and filter systems for isolation of vibration due to equipment and for stress relief due to seismic and thermal loading considerations. The material used for flexible air duct coupling at SHNPP is "Fairpierce NN-0003 or DX-0002" manufactured by DuPont, or equal. These components are neoprene and EPDM materials which are combustible. However, it is conservatively estimated that this material constitutes less than 1.5 percent of the total ductwork footage used at SHNPP; and due to the application, there is no large concentration of the material in any area which could create a combustible problem.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.a(5) Door openings in fire barriers should be protected with equivalently rated doors, frames, and hardware that have been tested and approved by a nationally recognized laboratory. Such doors should be self-closing or provided with closing mechanisms and should be inspected semiannually to verify that automatic hold-open, release, and closing mechanisms and latches are operable. (See NFPA 80, "Fire Doors and Windows.")

One of the following measures should be provided to ensure they will protect the opening as required in case of fire'.

(a) Fire doors should be kept closed and electronically supervised at a continuously manned location; (b) Fire doors should be locked closed and inspected weekly to verify that the doors are in the closed position; (c) Fire doors should be provided with automatic hold-open and release mechanisms and inspected daily to verify that doorways are free of obstructions; or (d) Fire doors should be kept closed and inspected daily to verify that they are in the closed position.

42 (%97 SPP C'1

The fire brigade leader should have ready access to keys for any locked fire doors.

Areas protected by automatic total flooding gas suppression systems should have electrically supervised self-closing fire doors or should satisfy option (a) above.

PROJECT CONFOR.MICE. C, POSITION (Cont ')

C.S.a(5) Door openings in fire barriers have fire resistant ratings equivalent to that of the fire barrier and are certified and guaranteed by the manufacturer to have fire resistant construction. Such doors will be self-closing or provided with closing mechanisms and will be inspected semiannually to verify that automatic hold-open, release, and closing mechanisms and latches are operable, or normally secured closed.

One of the following measures will be provided to ensure they will protect the opening as required in case of fire:

(a) Fire doors will be kept closed and electronically supervised at a continuously manned location; (b) Fire doors will be locked closed and inspected weekly to verify that the doors are in the closed position,'c) r~<<uoors will be provided with automatic hold-open and mechanisms and inspected daily to verify that doorways are free of obstructions; or (d) Fire doors will be kept closed and inspected daily to verify that they are in the closed position.

The lie origade leader will have ready access to keys for any locked fire doors.

Areas protected by automatic total flooding gas suppression systems will have electrically supervised self-closing fire doors or will satisfy option (a) above.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.a(6) Per~~,i <<I access routes and escape routes should be provided for each fire area. Stairwells outside primary containment serving as escape routes, access routes for firefighting, or access routes to areas containing equipment necessary for safe shutdown should be enclosed in masonry or concrete towers with a minimum fire rating of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and self-closing Class B fire doors.

PROJECT CONFORM:~.i~E: C. POSITION (Cont'd)

C.5.a(6) Personnel access routes and escape routes are provided for each fire area. In most cases, more than one means of access or egress are provided, as detailed in the fire hazards analysis, for each fire area. Stairways outside the primary containment 43

serving as escape routes, access routes for firefighting, or acc'ess routes to areas containing equipment necessary for safe shutdown are enclosed in masonry or concrete with a minimum fire resistive rating of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and provided with self-closing Class B type fire doors.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.a(7) Fire exit routes should be clearly marked.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.a(7) Fire exit routes are clearly marked.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.a(8) Each cable spreading room should contain onLy one redundant safety division. CabLe spreading rooms should not be shared between reactors. Cable spreading rooms should be separated from each other and from other areas of the pLant by barriers having a minimum fire resistance of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />'ROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.a(8) Each cable spreading room is designed to contain only one redundant safety division; however, in some cases redundant safety divisions do pass thru the areas. In those cases they are either enclosed in one hour fire resistance rated enclosure due to sprinkler system already existing in this area or analyzed to determine the effects of a fire in the area. Cable spreading rooms are separated from each other and from other areas of the plant by barriers having a minimum fire resistance of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.a(9) Interior wall and structural components, thermal insulation materials, radiation shielding materials, and soundproofing should be noncombustible. Interior finishes should be noncombustible.

Materials that are acceptable for use as interior finish without evidence of test and listing by a nationally recognized

'Laboratory are the following:

~ Plaster, acoustic plaster, gypsum pLasterboard (gypsum wallboard), either plain, waLLpaperedy or painted with oil-or water-base paint;

~ Ceramic tile, ceramic panels',

~ Glass, glass blocks; 44 (3276PPC/Ljs)

Brick, stone, concrete blocks, plain or painted; Steel and aluminum panels, plain, painted, or enameled; Vinyl tile, vinyl-asbestos tile, linoleum, or asphalt tile on concrete floors.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.a(9) Interior wall and structural components, thermal insulation materials, radiation shielding materials, and soundproofing are noncombustible. Interior finishes including thermal insulation radiation shielding and soundproofing have a flame spread, smoke and fuel contribution of 50 or less as defined in ASTM E-84, "Surface Burning Characteristics of Building Materials."

Materials used as interior finish without evidence of test and listing by a nationally recognized laboratory are the following:

Plaster, gypsum plasterboard (gypsum wallboard), or painted with oil- or water-base paint; Ceramic tile, ceramic panels; Glass; Concrete blocks, plain or painted; Steel panels, painted; Vinyl tile, vinyl-asbestos tile.

NRC GUIDELINES: C. POSITION (Cont 'd)

C.5.a(10) Metal deck roof construction should be noncombustible and listed as "acceptable for fire" in the UL Building Materials Directory, or listed as Class I in the Factor Mutual System Approval Guide.

PROJECT CONFOR fANCE: C. POSITION (Cont'd)

C.5.a(10) Metal deck roof construction is not used on safety-related buildings.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.a(11) Suspended ceiling and their supports should be of noncombustible construction. Concealed spaces should be devoid of combustibles except as noted in Position C.7.b.

45

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.a(ll) Suspended ceilings and their supports are of noncombustible construction. Electrical wiring to lighting fixtures and HVAC systems in these spaces is in conduits to reduce the combustible loading.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.a(12) Transformers installed inside fire areas containing safety-,related systems should be of the dry type or insulated and cooled with noncombustible liquid. Transformers filled with combustible fluid that are located indoors should be enclosed in a transformer vault (see Section 450(c) of NFPA 70, "National Electrical Code" ).

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.a(12) Transformers installed inside the buildings containing safety-related systems are dry type only. Transformers filled with combustible fluid are not located indoors.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.a(13) Outdoor oil-filled transformers should have oil spill confinement features or drainage away from the buildings. Such transformers should be located at least 50 feet distant from the building, or by ensuring that such building walls within 50 feet of oil-filled transformers are without openings and have a fire resistance rating of at least 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

PROJECT CONFORKQlCE: C. POSITION (Cont'd)

CPS.a(13) Outdoor oil-filled transformers are located more than 50 feet from safety-related buildings and separated from the Turbine Building by two-hour fire rated walls. Each transformer is installed over a gravel filled pit designed for oil spill.

confinement plus 30 minutes of flow from the fixed water spray.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.a(14) Floor drains sized to remove expected firefighting waterflow without flooding safety-related equipment should be provided in those areas where fixed water fire suppression systems are installed. Floor drains should also be provided in other areas where hand hose lines may be used if such firefighting water could cause unacceptable damage to safety-related equipment in the area (see NFPA-92, "Waterproofing and Draining of Floors" ). Where gas suppression systems are installed, the 46

drains should be provided with adequate seals or the gas suppression system should be sized to compensate for the loss of the suppression agent through the drains. Drains in areas containing combustible liquids should have provisions for preventing the backflow of combustible liquids to safety-related areas through the interconnected drain systems.

Water drainage from areas that may contain radioactivity should be collected, sampled, and analyzed before discharge to the environment.

PROJECT CONFOR'LANCE: C. POSITION (Cont'd)

C.5.a(14) Floor drains are provided in areas in which fixed water suppression systems and hoses are installed except for areas having natural drainage. Drainage requirements and impact on safety-related equipment will be considered before extending or adding water suppression systems. See Subsection 9.3.3 of the FSAR for a description of the drainage systems. Equipment containing quantities of oil which may be of concern regarding backflow, such as the reactor coolant pumps, RHR pumps, chillers, the diesel generator, DG day tank and fuel oil

~

storage, storage tank pumps, and Security Building are remote from each other and are serviced by drainage systems designed to control a possible spill and contain such a spill in a predetermined area. Water drained from areas having a

~ potential for'adioactive contamination is collected, sampled and analyzed before discharge to the environment. Areas with equipment controlling significant amounts of combustible "liquids will have containment curbing to control inadvertent oil flows to surrounding areas and the drainage system.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.b. Safe Shutdown Capability (1) Pire protection features should be provided for structures, systems and components important to safe shutdown. These features should be capable of limiting fire damage so that:

(a) One train of systems necessary to achieve and maintain hot shutdown 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 standby from either the control room or emergency control station(s) can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

47

0 PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.b.

~ ~ ~ Safe Shutdown Ca abilit C.5.b(1) Fire protection features are provided for structures, systems, and components important to safe shutdown. These features are capable of limiting fire damage so that:

(a) One train 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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

For details, refer to the Safe Shutdown Analysis in Case of Fire.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.b(2) To meet the guidelines of Position C.5.b(1), one of the following means of ensuring that one of the redundant trains is free of fire damage should be provided:

(a) Separation of cables and equipment and associated circuits of redundant trains by a fire barrier having a 3-hour rating. Structural steel forming a part of or supporting such fire barriers should be protected to provide fire resistance equivalent to that. required of the barrier; (b) Separation of cables and equipment and associated circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustible or fire hazards. In addition, fire detectors and an automatic fire suppression system should be installed in the fire area', or (c) Enclosure of cable and equipment and associated circuits of one redundant train in a fire barrier having a 1-hour rating. In addition, fire detectors and an automatic fire suppression system should be installed in the fire area.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.b(2) To meet the guidelines of Position C.5.b(1), where cables or equipment including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or short to ground, of redundant trains of systems necessary to achieve and maintain hot standby conditions are located within the same fire area outside of primary containment, one of the following means of ensuring that one of the redundant trains is free of fire damage is provided; 48 (3276PPC )

(a) Separation of cables and equipment and associated circuits of redundant trains by a fire barrier having a 3-hour rating. Structural steel forming a part of or supporting such fire barriers will be protected to provide fire resistance equivalent to that required of the barrier',

(b) Separation of cables and equipment and associated circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustible or fire hazards. In addition, fire detectors and an automatic fire suppression system will be installed in the fire area; or (c) Enclosure of cable and equipment and associated circuits of one redundant train in a fire barrier having a 1-hour rating. In addition, fire detectors and an automatic fire suppression system should be installed in the fire area; One'f the fire protection means specified above or one of the following fire protection means are provided for inside the containment:

(a) Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards',

(b) Installation of fire detectors and an automatic fire suppression system in the fire area', or (c) Separation of cables and equipment and associated non-safety circuits of redundant trains by a noncombustible radiant energy shield.

NRC GUIDELINES: POSITION (Cont'd)

C.5.b(3) If the guidelines of Positions C5.b.l and CS.b.2 cannot be met, then alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room, or zone under consideration should be provided.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.b(3) Alternative shutdown systems have been provided for the'control room, process and instrumentation room, and HVAC room located on elevation 305'f the Reactor Auxiliary Building. A dedicated HVAC System has been provided for'he PIC room located on elevation 286'f the Reactor Auxiliary Building.

NRC GUIDELINES:~ POSITION (Cont'd)

C.5.c.

~ ~ ~ Alternative or Dedicated

~ ~

Shutdown Ca abilit (1) Alternative or dedicated shutdown capability provided for a specific fire area should be able to achieve and maintain 49 (3276PPC)

subcritical reactivity conditions in the reactor, maintain reactor coolant inventory, achieve and maintain hot standby*

conditions for a PWR (hot shutdown* for a BWR) and achieve cold shutdown* conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and maintain cold shutdown conditions thereafter. During the post-fire shutdown, the reactor coolant system process variables shall be maintained within those predicted for a loss of normal ac power, and the fission product boundary integrity shall not be affected; i.e., there shall be no fuel clad damage, rupture, or any primary coolant boundary, or rupture of the containment boundary.

(2) The performance goals for the shutdown functions should be:

(a) The reactivity control function should be capable of achieving and maintaining cold shutdown reactivity conditions.

(b) The reactor coolant makeup function should be capable of maintaining the reactor coolant level above the top of the core for BWRs and be within the level indication in the pressuri"er for PWRs.

(c) The reactor heat removal function should be capable of achieving and maintaining decay heat removal.

(d) ine. process monitoring function should be capable of

~.~.lding direct readings of the process variables necessary to perzorm and control the above functions.

(e) The supporting functions should be capable of providing the process cooling, lubrication, etc., necessary to permit the operation of the equipment used for safe shutdown functions.

The shutdown capability for specific fire areas may be unxque for each such area, or it combination of systems for all such areas.

may be one unique In either case, the alternative shutdown capability shall be independent of the specific fire area(s) and shall accommodate post-fire conditions where offsite power is available and where offsite power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Procedures shall be in effect to implement this capability.

(4) If the capability to achieve and maintain cold shutdown will not be available because of fire damage, the equipment and systems comprising the means to achieve and maintain the hot standby or hot shutdown conditions shall be capable of maintaining such conditions until cold shutdown can be achieved. If such equipment and systems will not be capable "As defined in the Standard Technical Specifications.

50

of being powered by both onsite and offsite electric power systems because of fire damage, an independent onsite power system shall be provided. The number of operating shift personnel, exclusive of fire brigade members, required to operate such equipment and systems shall be onsite at all times'5)

Equipment and systems comprising the means to achieve and maintain cold shutdown conditions should not be damaged by fire; or the fire damage to such equipment and systems should be limited so that the systems can be made operable and cold shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Materials for such repairs shall be readily available onsite and procedures shall be in effect to implement such repairs. If such equipment and systems used prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the fire will not be capable of being powered by both onsite and offsite electric power systems because of fire damage, an independent onsite power system should be provided. Equipment and systems used after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be powered by offsite power only.

(6) Shutdown systems installed to ensure post-fire shutdown capability need not be designed to meet seismic Category I criteria, single failure criteria, or other design basis accident criteria, except where required for other reasons, e.g., because of interface with or impact on existing safety systems, or because of adverse valve actions due to fire damage.

(7) The safe shutdown equipment and systems for each fire area should be known to be isolated from associated circuits in the fire area so that hot shorts, open circuits, or shorts to ground in the associated circuits will not prevent operation of the safe shutdown equipment. The separation and barriers between trays and conduits containing associated circuits of one safe shutdown division and trays and conduits containing associated circuits or safe shutdown cables from the redundant division, or the 'isolation of these associated circuits from the safe shutdown equipment, should be such that a postulated fire involving associated circuits will not prevent safe shutdown.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5oc. Safe Shutdown Ca abilit Alternative shutdown systems have been provided for the control room, process and instrumentation room, and HVAC room located on elevation 305'f the Reactor Auxiliary Building. A dedicated HVAC System has been provided for the PIC room located on elevation 286'f the Reactor Auxiliary Building.

NRC GUIDELINES: C. POSITION (Cont'd)

Safety-related systems should be isolated or separated from combustible materials. When this is not possible because of 51 (3276PPC)

Cp t the nature of the safety system or the combustible material, special protection should be provided to prevent a fire from defeating the safety system function. Such protection may involve a combination of automatic fire suppression, and construction capable of withstanding and containing a fire that consumes all combustibles present. Examples of such combustible materials that may not be separable from the remainder of its system are:

(a) Emergency diesel generator fuel oil day tanks.

(b) Turbine-generator oil and hydraulic control fluid systems.

(c) Reactor coolant pump lube oil system.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.d. Control of Combustibles Safety-related equipment and systems are isolated or protected against exposure from ignition sources or high combustible loading. This separation and protection consists of physical separation, fire rated barriers, fire suppression, fire control or damage limitation systems or any combination of these which provides the degree of protection required by the fire hersrd analysis.

Examples of typical combustible materials that may not be separable from the remainder of its system and the isolation or protection provided, are:

(a) Each emergency diesel fuel oil day tank is located within a concrete vault, which is separated from other plant areas by three-hour fire barriers. An automatic, multi-cycle sprinkler system actuated by thermal detection is provided for each area, with hose station and yard hoseline equipment and portable extinguishers as backup.

(b) The turbine-generator lubricating oil system is located within the turbine building, away from all safety-related equipment. This area is provided with an automatic preaction sprinkler system actuated by thermaL detection for equipment and property protection. A fi.re in this area will not pose any hazard to safety-related equipment.

(c) The reactor coolant pump lube oil system is located within containment near the reactor coolant pumps and 52 (3276PPC/ccc )

will be equipped with an oil collection system. The oil collection system will be designed, engineered and installed so that failure will not lead to fire during design basis accident conditions and that there will be reasonable assurance that the system will withstand the safe shutdown earthquake. A thermal automatic detection system is provided around each reactor coolant pump.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.d(2) Bulk gas storage (either compressed or cryogenic), should not be permitted inside structures housing safety-related equipment. Storage of flammable gas such as hydrogen should be located outdoors or in separate detached buildings so that a fire or explosion will not adversely affect any safety-related systems or equipment. (Refer to NFPA 50A, "Gaseous Hydrogen Systems.")

Care should be taken to locate high pressure gas storage containers with the long axis parallel to building walls. This will minimize the possibility of wall penetration in the event of a container failure. Use of compressed gases (especially flammable and fuel gases) inside buildings should be controlled. (Refer to NFPA 6, "Industrial Fire Loss Prevention.")

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.d(2) Bulk storage of compressed or cryogenic gases is not permitted within structures housing safety-related equipment. Flammable gases such as hydrogen are stored outdoors and will not adversely affect safety-related equipment, systems or structures.

Care will be taken to locate high pressure gas storage containers with the long axis parallel to building walls, to minimize the possibility of wall penetration in the event of a container failure. Use of compressed gases (especially flammable and fuel gases) inside buildings will be controlled.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.d(3) The use of plastic materials should be minimized. In particular, halogenated plastics such as polyvinyl chloride (PVC) and neoprene should be used only when substitute noncombustible materials are not available. All plastic materials, including flame and fire retardant materials, will burn with an intensity and BTU production in a range similar to that of ordinary hydrocarbons. When burning, they produce

heavy smoke that obscures visibility and can plug air filters, especially charcoal and HEPA. The halogenated plastics also release free chlorine and hydrogen chloride when burning which are toxic to humans and corrosive to equipment.

PROJECT CONFORMANCE: C. POSITION (Cont'd) c.5.a(3) The use of plastic materials is minimized. Plastics are used only where required as essential equipment and to the minimum extent possible, as detailed in the fire hazards analysis' small quantity of vinyl is used within motor control centers, and for trimming of cable tray edges for cable exits from those trays. Standard Products Quickedge Minitrim Part No. 75000341, which is a vinyl, was selected for this application. It's use is limited. The "Quickedge" vinyl is self-extinguishing passing Federal Specification FSS-302. PVC is used for raceways embedded in concrete or underground applications and in the Water Treatment Building. HVAC ductwork is gasketed using Neoprene or Tremco 440 duct tape. For discussion of ductwork flexible connectors see Section C.5.a(4).

NRC GUIDELINES: C. POSITION (Cont'd) c.5.a(4) Storage of flammable liquids should, as a minimum, comply with the requirements of NFPA 30, "Flammable and Combustible Liquids Code."

PROJECT CONFORMANCE: C. POSITION (Cont'd) c.5.a(4) Storage and use of flammable and combustible liquids follows the intent and basic criteria of NFPA 30, "Flammable and Combustible Liquid Code" except that the requirements of NFPA-37 "Installation and Use of Stationary Combustion Engines and Gas Turbines" apply to the installation of the Diesel Generator Day Tank.

NRC GUIDELINES: C. POSITION (Cont'd) c.5.a(5) Hydrogen lines in safety-related areas should be either designed to seismic Class I requirements, or sleeve such that the water pipe is directly vented to the outside, or should be equipped with excess flow valves so that in case of a line break, the hydrogen concentration in the affected areas will not exceed 2Z.

PROJECT CONFORMANCE: C. POSITION (Cont'd) c.5.a(5) Hydrogen lines in safety-related areas are seismically supported and/or equipped with excess flow valve(s) so that in (3276PPC)

case of a line break, the hydrogen concentration in the affected areas will not exceed 2X.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.e Electrical Cable Construction Cable Tra s and Cable Pehetrations (1) Only, metal should be used for cable trays. Only metallic tubing should be used for conduit. Thin-wall metallic tubing should not be used. Flexible metallic tubing should only be used in short lengths to connect components to equipment. Other raceways should be made of noncombustible material.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.e Electrical Cable Construction Cable Tra s Cable Penetrations (1) Cable trays and other raceways are constructed of noncombustible material. Metallic tubing is used for conduit and thin wall tubing is only used for spare sleeve embedded in qualified fire assemblies. Short lengths of flexible metallic tubing are used to connect components to equipment. A small quantity of vinyl is used for cable trays as described in Position C.5.d(3). PVC is used only for raceways embedded in concrete or underground applications.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.e(2) Redundant safety-related cable systems outside the cable spreading room should be separated from each other and from potential fire exposure hazards in non-safety-related areas by fire barriers with a minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. These cable trays should be provided with continuous line-type heat detectors and should be accessible for manual firefighti,ng.

Cables should be designed to allow wetting down with fire suppression water without electrical faulting. Manual hose stations and portable hand extinguishers should be provided.

Safety-related cable trays of a single division that are separated from redundant divisions by a fire barrier with a minimum rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and are normally accessible for manual firefighting should be protected from the effects of a potential exposure fire by providing automatic water suppression in the area where such a fire could occur.

Automatic area protection, where provided, should consider cable tray arrangements and possible transient combustibles to ensure adequate water coverage for areas that could present an exposure hazard to the cable system. Manual hose standpipe systems may be relied upon to provide the primary fire 55 (3276PPC)

suppression (in lieu of automatic water suppression systems) for safety-related cable trays of a single division that are separated from redundant safety division by a fire barrier with a minimum rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and are normally accessible for manual firefighting if all of the following conditions are met:

(a) The number of equivalent* standard 24-inch"wide cable trays (both safety-related and non-safety-related) in a given fire area is six or less; (b) The cabling does not provide instrumentation, control or power to systems required to achieve and maintain hot shutdown; and (c) Smoke detectors are provided in the area of these cable routings, and continuous line-type heat detectors are provided in the cable trays.

Safety-related cable trays that are not accessible for manual firefighting should be protected by a zoned automatic water system with open-head deluge or open directional spray nozzles arranged so that adequate water coverage is provided for each cable tray. Such cable trays should also be protected from the effects of a potential exposure fire by providing automatic water suppression in the area where such a fire could occur.

ln tne other areas where it may not be possible because of oiu~a overriding design features necessary for reasons of nuclear safety to separate redundant safety-related cable systems by 3-hour rated fire barriers, cable trays should be protected by an automatic water system with open-head deluge or open directional spray nozzles arranged so that adequate water coverage is provided for each cable tray. Such cable trays should also be protected from the effects of a potential exposure fire by providing automatic water suppression in the area where such a fire could occur. The capability to achieve and maintain safe shutdown considering the effects of a fire involving fixed and potential transient combustibles should be evaluated with and without actuation of the automatic suppression system and should be )ustified on a suitably defined basis.

• Trays exceeding 24 inches should be counted as two trays; trays exceeding 48 inches should be counted as three trays, regardless of tray fill.

56

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.e(2)

~ ~ Redundant safety-related cable s ystems outside the cable spreading room are separated from potential fire exposure hazards in non-safety-related areas by fire barriers having a minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Redundant safety-related cable systems outside the cable spreading room are separated from each other and from potential fire exposure hazards by separation criteria given in Regulatory Guide 1.75 plus automatic smoke detection and/or area coverage preaction or multi-cycle sprinkler systems actuated by thermal detection. Redundant cable systems required for safe shutdown in case of fire were separated in accordance with Section C.5.b(2), as detailed in the Safe Shutdown Analysis in Case of Fire, with noted exceptions. Spot type ionization smoke detectors and thermal detectors located above the cable trays are provided instead of line-type thermal detection. These detectors are sensitive to products of combustion and provide early warning in the first stages of a fire. Cables are designed to allow wetting down with fire suppression water without electrical faulting. Manual hose stations and portable hand extinguishers are provided.

Safety-related cable trays separated by fire barriers with a minimum rating of three hours and accessible for .manual firefighting are protected by automatic suppression systems from the effects of an exposure fire. Where provided, automatic area protection considers cable tray arrangements and transient combustibles to assure adequate protection against exposure fires. Manual hose stations are not relied upon for primary fire suppression for redundant safety cables in lieu of automatic water suppression.

Locations of safety-related cable trays are accessible for manual firefighting, except for the Cable Spreading Area 1A-SA where SB cable trays are enclosed in three-hour fire resistive barriers along the outside wall of the area north from column line 41B to 43B and west from 43B to 43E. In other areas where it may not be possible because of other overriding design features necessary for reasons of nuclear safety to separate safety-related cables systems by 3-hour rated fire barriers, cable trays are protected by either preaction or multi-cycle sprinkler systems equipped with closed sprinkler heads. For further description see FHA and SSA. Since the two step operation of closed sprinkler head systems requires activation of the sprinkler flow control valve by automatic detectors .or manual fire alarm stations and fusing of the sprinkler heads by heat from the fire before water is discharged, unnecessary water damage resulting from premature discharge or inadvertent operation is avoided. Water is discharged only from sprinkler 57 (3276PPC )

heads in the immediate area of the fire. The capability to achieve and maintain safe shutdown in case of fire is evaluated in the Safe Shutdown Analysis.

For the Safe Shutdown Analysis in Case of Fire, wherever 3-hour rated fire barriers could not be provided for those systems needed to achieve and maintain cold shutdown in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> one of the separation criteria of Section C.5.b(2) were provided or a deviation request and the technical basis for it identified, as detailed in the Safe Shutdown Analysis in Case of Fire. The capability to achieve and maintain safe shutdown considering the effects of a fire involved fixed and potential transient combustibles were evaluated with and without actuation of the automatic system, as detailed in the Safe Shutdown Analysis, in Case of Fire, with noted exceptions. Exposure fires were considered only for Safety-Related Systems designated as required for Safe Shutdown Analysis in Case of Fire.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.e(3) Electric cable construction should, as a minimum, pass the flame test in the current IEEE Std 383. (This does not imply that cables passing this test will not require fire protection.)

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.e(3)

~ ~ The electric cable construction conforms to IEEE Std 383 except communication and lighting cables which run in conduit or underground.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.e(4) Cable raceways should be used only for cables.

PROJECT CONFORMANCE: C POSITION (Cont'd)

C.5.e(4) Cable raceways are only used for cables.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.e(5) Miscellaneous storage and piping for flammable or combustible liquids or gases should not create a potential exposure hazard to safety-related systems.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.e(5) Miscellaneous storage and piping for flammable or combustible liquids or gases will not create a potential exposure hazard to safety"related systems. See Project Conformance C.5.d(5) for 58 (3276PPC)

0 hydrogen lines in safety-related areas. FSAR Table 9.5.1-2 lists hazardous materials storage areas. Storage areas are either in the yard or in designated spaces separated from safety-related equipment.

NRC GUIDELINES: C. POSITION (Cont'd)

Ventilation The products of combustion and the means by which they will be removed from each fire area should be established during the initial stages of plant design. Consideration should be given to the installation of automatic suppression systems as a means of limiting smoke and end heat generation. Smoke and corrosive gases should generally be discharged directly outside to an area that will not affect safety-related plant areas. The normal plant ventilation system may be used for this purpose if capable and available. To facilitate manual firefighting, separate smoke and heat vents should be provided in specific areas such as cable spreading rooms, and other areas where the potential exists for heavy smoke conditions (see NFPA 204 for additional guidance on smoke control).

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.f(1) Ventilation

~ ~

Methods of removing the products of combustion from each fire area are specifically delineated in FSAR Appendix 9.5A. Smoke from the Containment, Reactor Auxiliary, Fuel Handling, Waste Processing, and Turbine Buildings will be discharged through plant stacks whose discharge points are well removed from safety-related plant areas. The Diesel Generator Building, Diesel Fuel Oil Tank Building, and Emergency Service Water Intake Structure are remote from the main plant area and smoke discharged from these structures will not affect other .safety-related plant areas. The outside air intakes were located in consideration of the possibility of short circuiting of exhaust air and in turn any smoke discharge from reentering the building. See Subsection 9.4.0 of FSAR for discussion and location of plant HVAC effluent release points. As indicated in Appendix 9.5A, the normal plant ventilation systems will be used for smoke venting. The Control Room and Electric Equipment Protection Rooms are provided with specially designed smoke purge systems. For the Cable Spreading Rooms and Switchgear Rooms specially designed smoke purge systems will be available for smoke venting in lieu of separate smoke and heat vents; architectural limitations precluded the utilization of smoke and heat vents.

59 (3276PPC)

0 NRC GUIDELINES: C. POSITION (Cont'd)

C.5.f(2) Release of smoke and gases containing radioactive materials to the environment should be monitored in accordance with emergency plans as described in the guidleines of Regulatory Guide 1.101, "Emergency Planning for Nuclear Power Plants." Any ventilation system designed to exhaust potentially radioactive smoke or gases should be evaluated to ensure that inadvertent operation or single failures will not violate the radiologically controlled areas of the plant design. This requirement includes containment functions for protecting the public and maintaining habitability for operations personnel.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.f(2) The release of smoke that can potentially carry radioactive material is monitored at the stack discharge points. In addition, area radiation monitors are provided in areas containing radioactive material. See Subsection 9.5.1.2.2 of FSAR for further discussion of this subject. Normal ventilation systems are used to exhaust smoke and products of combustion for most of the plant areas. FSAR Subsection 9.5.1.2.2 and Section 9.4 describes these systems operations.

NRC GUIDELINES: C. POSITION (Cont'd)

C.S.f(3) Special protection for ventilation power and control cables may be required. The power supply and controls for mechanical ventilation systems should be run outside the fire area served by t he sys tern where prac t ical.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C~ 5. f (3) Special protection was provided for cables and ventilation systems which were designated as being required for the safe shutdown of the plant in case of a fire. The separation criteria as described in 10CFR50 Appendix R Part III.G was used for ventilation and control cables required for safe shutdown.

Refer to the Safe Shutdown Analysis in Case of Fire for details and/or exemptions requested. For the balance of the plant, the power supply and controls for mechanical ventilation systems were run outside the fire areas served by the system to the extent practical.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5. f(4) Engineered safety feature filters should be protected in accordance with the guidelines of Regulatory Guide 1.52. Any filter that includes combustible materials and is a potential exposure fire hazard that may affect safety-related components should be protected as determined by the fire hazards analysis.

60

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.f(4) Engineered safety feature filters are protected in accordance with the guidelines of Regulatory Guide 1.52. Any filter than includes combustible materials and is a potential exposure fire hazard that may affect safety-related components was protected as determined by the fire hazards analysis, for details see SHNPP FSAR Section 9.5A.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.f(5) The fresh air supply intakes to areas containing safety-related equipment or systems should be located remote from the exhaust air outlets and smoke vents of other fire areas to minimize the possibility of contaminating the intake air with the products of combustion.

PROJECT CONFORMANCE: C. POSITION (Cont'd) c.5.f(5) The fresh air supply intakes to areas containing safety-related equipment or systems were located remote from the exhaust air outlets and smoke vents of other fire areas to minimize the possibility of contaminating the intake air with the products of combustion, to the extent 'practical. See response to Item C.5.f(1) above for discussion on this subject.

NRC GUIDELINES: C.~ POSITION (Cont'd)

C.5.f(6) Stairwells should

~ ~ be designed to minimize smoke infiltration during a fire.

~

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.f(6) As described in FSAR Subsection 9.5.1.2 stairwells are designed to minimize smoke infiltration during a fire.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.f(7) Where total flooding gas extinguishing systems are used, area intake and exhaust ventilation dampers should be controlled in accordance with NFPA 12, "Carbon Dioxide Systems," and NFPA 12A, "Halon 1301 Systems," to maintain the necessary gas concentration.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.f(7) Where total Halon gas extinguishing systems are used, air intake and exhaust ventilation dampers will be controlled in accordance with NFPA 12A in order to maintain the necessary gas concentration. The record storage facility, located in the Administration Building, is provided with a Halon 1301 extinguishing system. The system is designed to provide 5X to 61 (3276PPC/ccc )

8X concentration of Halon within 10 seconds. An automatic ionization detection system is installed for early warning of a smoke condition and automatic closure of dampers and fire doors.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.g. Li htin and Communication Lighting and two-way voice communication are vital to safe shutdown and emergency response in the event of fire. Suitable fixed and portable emergency lighting and communication devices should be provided as follows:

(1) Fixed self-contained lighting consisting of fluorescent or sealed-beam units with individual 8-hour minimum battery power supplies should be provided in areas that must be manned for safe shutdown and for access and egress routes to and from all fire areas. Safe shutdown areas include those required to be manned if the control room must be evacuated.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.g. Li htin and Communication (1) Suitable fixed and portable emergency lighting and communication devices are provided as follows.'xcept for control, auxiliary control, computer rooms, and containment, fixed self-contained seal beam units with individual 8-hour minimum battery power supplies will be provided in areas that must be manned for safe shutdown and for access and egress routes to and from all fire areas. The DC Emergency Lighting System using the plant 125V battery provides emergency lighting for the control room, auxiliary control room, and computer room. See FSAR Subsection 9.5.3.2. The cable routing for the DC Emergency Lighting will be included in the Safe Shutdown Analysis in Case of Fire and separated or protected in accordance with Section C.5.b(2). Portable emergency lighting is provided for containment as clarified in C.5.g(2) below.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.g(2) Suitable sealed-beam battery-powered portable hand lights should be provided for emergency use by the fire brigade and other.

operations personnel required to achieve safe plant shutdown.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.g(2) Suitable sealed-beam battery-powered portable hand lights will be provided for emergency use by the fire brigade and other operations personnel required to achieve safe plant shutdown.

62 (3276PPC)

NRC GUIDELINES: C.~ POSITION (Cont'd)

C.5.g(3)

~ ~ Fixed emergency communications independent of the normal plant communication system should be installed at preselected

~ ~

stations.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.g(3) The sound powered telephone system for SHNPP is an independent, five-channel system consisting of master panels, remote jack stations, and sound-powered headsets and wiring. The jack stations are located at control panels, relay cabinet, instrument racks, switchgear, motor control centers, and other locations having critical system components. The sound-powered telephone system requires no external power source. At SHNPP, this system may be utilized for normal or emergency communications.

NRC GUIDELINES: C. POSITION (Cont'd)

C.5.g(4) A portable radio communications system should be provided for use by the fire brigade and other operations personnel required to achieve safe plant shutdown. This system should not interfere with the communications capabilities of the plant security force. Fixed repeaters installed to permit use of portable radio communication units should be protected from exposure fire damage. Preoperational and periodic testing should demonstrate that the frequencies used for portable radio communication will not affect the actuation of protective relays.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.5.g(a) A dedicated radio system for plant operation and maintenance is provided. The system consists of a base station, an interior antenna system for inside building coverage, and battery-powered, hand-held portable radios. Power for the plant operations/ maintenance radio system is from the non-Class 1E uninterruptible power supply. This system is totally independent from the plant security radio system with the exception of the antenna system in the plant where the 0&M and security radios utilize the same antenna system operating at different frequencies and will not interfere with each other.

Either a pre-operational test or an engineering evaluation .will be performed to ensure that the frequencies used for portable radio communications will not affect the actuation of protective relays.

The dedicated radio system and the sound-powered phone system described in C.5.g(3) are independent of other communication systems at SHNPP (e.g., the Private Automatic Branch Exchange System [PABX], the Site Paging System [PA], and the off-site microwave system).

63 (3276PPC)

NRC GUIDELINES: C. POSITION (Cont'd)

C.6. Fire Detection and Su ression C.6.a. Fire Detection (1) Detection systems should be provided for all areas that contain or present a fire exposure to safety-related equipment.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6 Fire Detection and Su ression C.6.a Fire Detection (1) Manual release capability and/or automatic detection systems will be provided for all areas that contain or present a fire exposure to safety-related equipment, with exceptions detailed in the Safe Shutdown Analysis in Case of Fire.

63-a (3276PPC)

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.a(2) Fire detection systems should comply with the requirements of Class A systems as defined in NFPA 72D, "Standard for the Installation, Maintenance, and Use of Proprietary Protective Signaling Systems," and Class I circuits as defined in NFPA 70, "National Electrical Code."

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6.a(2) For details on the Fire Detection System refer to FSAR Subsection 9.5.1. As stated in Subsection 9.5.1.2.3 of the FSAR the fire detection systems will be Class A systems in accordance with NFPA 72D "Standard for the Installation, Maintenance, and Use of Proprietary Protective Signaling Systems," and have Class 1 circuits as defined in NFPA 70, "National Electric Code."

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.a(3) Fire detectors should be selected and installed in accordance with NFPA 72E, "Automatic Fire Detectors." Preoperational and periodic testing of pulsed line-type heat detectors should demonstrate that the frequencies used will not affect the actuation of protective relays in other plant systems.

PROJECT CONFORMANCE: C.~ POSITION (Cont'd)

C.6.a(3)

~ ~ Fire detectors are selected and installed in accordance with"

~

NFPA 72E, "Automatic Fire Detectors." Ionization detectors installed on an area basis for early warning and rate compensated/fixed temperature thermal detectors are used.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.a(4) Fire detection systems should give audible and visual alarm and annunciation in the control room. Where zoned detection systems are used in a given fire area, local means should be provided to identify which detector zone has actuated. Local audible alarms should sound in the fire area.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6.a(4) Fire detection systems give audible and visual alarm and annunciation in the control room. Where zoned detection systems are used in a given fire area, local means are provided to identify which detector zone has actuated. Local audible alarms sound in the fire area.

9 '.1.2 '. For details refer to FSAR Subsection 64 (3276PPC)

NRC GUIDELINES: C.~ POSITION (Cont'd)

C.6.a(5)

~ ~ Fire alarms should be distinctive and unique

~

so they will not be confused with any other plant system alarms.

~

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6.a(5) Fire alarms are distinctive and unique so they will not be confused with any other plant system alarms.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.a(6) Primary and secondary power supplies should be provided for the fire detection system and for electrically operated control valves for automatic suppression systems. Such primary and secondary power supplies should satisfy provisions of Section 2220 of NFPA 72D. This can be accomplished by using normal offsite power as the primary supply with a 4-hour battery supply as secondary supply', and by providing capability for manual connection to the Class 1E emergency power bus within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of loss of offsite power. Such connection should follow the applicable guidelines in Regulatory Guides 1.6, 1.32, and 1.75.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6.a(6) Power for operation of fire detection systems and for actuation of fire suppression system is supplied from the balance of plant static uninterruptible power supply. The fire detection alarm panels are supplied from Uninterruptible Po~er Supply (UPS) Bus 81, which is supplied from the 60 kVA static UPS system. The UPS system in turn is supplied from non-Class lE motor control centers (MCC). In the event of loss of offsite power, the station 250 volt DC battery is capable of supplying the 60 kVA status UPS system. Bus DP-1-250 is also connectable via battery chargers to the Class 1E emergency diesel generator in the manual load block. FSAR Figure 8.1.3-3 shows this configuration.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.b. Fire Protection Water Su 1 S stems An underground yard fire main loop should be installed to furnish anticipated water requirements. NFPA 24, "Standard for Outside Protection," gives necessary guidance for such installation. It references other design codes and standards developed by such organizations as the American National Standards Institute (ANSI) and the American Water Works Association (AWWA). Type of pipe and water treatment should be design considerations with tuberculation as one of the parameters. Means for inspecting and flushing the systems should be provided.

65 (3276PPC )

PROJECT CONFOR<~CE: C. POSITION (Cont ')

C.6.b(1) An underground yard fire main loop is installed to furnish anticipated water requirements. NFPA 24, "Standard for Outside Protection," was followed for this installation. Fresh water and ductile iron cement, and bitumastic lined pipe was used to prevent tuberculation. Means for inspecting and flushing the systems are provided.

NRC GUIDELINES: C. POSITION (Cont'd)

C~ 6~ b(2) App roved visually indicating sectional control valves such as post indicator valves should be provided to isolated portions o the main for maintenance or repair without shutting off the supply to primary and backup fire suppression systems serving areas that contain or expose safety-related equipment.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6.b(2) Post indicator valves are provided in the distribution system for adequate sectionalization of loops and isolation of branch lines to facilitate system maintenance. Isolation valves are located in branch lines connecting fire suppression systems in t'e buildings to avoid closing sectional valves in the main loop. Sectional isolation. valves are provided in the yard loop piping to minimize the impairment of fire protection water supply if maintenance ori the loop or yard hydrants becomes necessary .

NRC GUIDELINES'. POSITION (Cont'd)

C.6.b(3) Valves should be installed to permit isolation of outside hydrants from the fire main for. maintenance or repair without interrupting the water supply to automatic or manual fire suppression systems in any area containing or presenting a fire hazard to safety-related or safe shutdown equipment.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6.b(3) Valves were installed to permit isolation of outside hydrants from the fire main for maintenance or repair without interrupting the water supply to automatic or manual fire suppression systems in any area containing or presenting a fire hazard to safety-related or safe shutdown equipment. Refer to FSAR Figure 9.5.1-1.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.b(4) The fire main system piping should be separate from service or sanitary water system piping, except as described in Position C.6.c.(4),

66

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6.b(4) The fire main system piping is separated from service or sanitary water system piping, except as described in Position C.6.c.(4),

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.b(5) A common yard fire main loop may serve multiunit nuclear power plant sites if cross-connected between units. Sectional control valves should permit maintaining independence of the individual loop around each unit. For such installations, common water supplies may also be utilized. For multiple-reactor sites with widely separated plants (approaching one mile or more).

Separate yard fire main loops should be used.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6.b(5) Not applicable.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.b(6) If pumps are required to meet system pressure or flow requirements. A suf icient number of pumps should be provided to ensure that 100% capacity will be available assuming failure of the largest pump or loss of offsite power (e.g., three 50%

pumps or two 100% pumps). This can be accomplished, for example, it by p roviding e her:

(a) Electric motor-driven fire pump(s) and diesel-driven fire pump(s); or (b) Two or more seismic Category I Class 1E electric motor-driven fire pumps connected to redundant Class lE emergency power buses (see Regulatory Guides 1.6, 1.32, and

1. 75) .

Individual fire pump connections to the yard fire main loop should be separated with sectionalizing valves between connections. Each pump and its driver'nd controls should be located in a room separated from the remaining fire pumps by a fire wall with a minimum rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The fuel for the diesel fire pump(s) should be separated so that it does not provide a fire source exposing safety-related equipment. Alarms indicating pump running, driver availability, failure to start, and low fire~ain pressure should be provided in the control room.

The fire pump installation should conform to NFPA 20'Standard for the Installation of Centrifugal Fire Pumps."

67

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6.b(6) As shown in FSAR Figure 9.5.1-1 two 100% capacity fire pumps, one electric driven and one diesel driven, installed in accordance with NFPA 20, are provided. The electric driven fire pump is UL listed and the diesel driven fire pump is FM approved. Individual fire pump connections to the yard fire main are separated by sectional valves between connections. The pumps are installed at opposite ends of the emergency service water intake structure which provides spatial separation in lieu of a fire wali'he diesel fire pump fuel supply is located about 12 feet away from the emergency service water intake screen structure within one foot high curbs which direct the oil to the sump within the curbs. Alarms indicating pump running, driver availability and failure to start are provided at the MFDIC. A common annunciation "Fire Pump System Trouble" is provided in the Main Control Room for the Motor and Diesel Driven Fire Pump. A low fire-main pressure alarm is not provided since a jockey pump maintains system pressure at about 100 psig. If system pressure is not maintained by the jockey pump the electric driven pump will start when the system pressure drops to about 90 psig. The cause of the startup of the electric driven pump will be investigated by the operator.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.b(7) Outside manual hose installation should be sufficient to provide an effective hose stream to any onsite location where fixed to transient combustibles could jeopardize safety-related equipment. Hydrants should be installed approximately every 250 ft on the yard main system. A hose house equipped with hose and combination nozzle and other auxiliary equipment recommended in NFPA 24, "Outside Protection," should be provided as needed, but at least every 1,000 ft. Alternatively, mobile means of providing hose and associated equipment, such as hose carts or trucks, may be used. When provided, such mobile equipment should be equivalent to the equipment supplied by three hose houses.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6.b(7) As stated in FSAR Subsection 9.5.1, hydrants are installed approximately every 250 feet on the yard fire main loop. Each hydrant is furnished with hose, combination nozzle and other auxiliary equipment as recommended by NFPA-24, "Outside Protection."

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.b(8) Threads compatible with those used by local fire departments should be provided on all hydrants, hose couplings, and standpipe risers.

68 (5276PPC)

0 PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6.6(8) Threads for fire hose and equipment are American National Fire Hose Connection Screw Thread (NST) in accordance with NFPA 1963. Each hose house is equipped with two adapters tagged "Raleigh Fire Department Adapter" and "Sanford Fire Department Adapter" which fit local fire department threads.

NRC GUIDELINES: C~ POSITION (Cont ')

C.6.b(9) Two separate, reliable freshwater supplies should be provided.

Saltwater or brackish water should not be used unless all freshwater supplies have been exhausted. If tanks are used, two 100% (minimum of 300,000 gallons each) system capacity tanks should be installed. They should be so interconnected that pumps can take suction from either or both. However, a failure in one tank or its piping should not cause both tanks either to drain.

Water supply capacity should be capable of refilling tank in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or less.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6.b(9) The fresh water supply is taken from the Auxiliary Reservoir which serves as the plant ultimate heat sink and fire protection supply with sufficient capacity for both functions. Tanks are not used to store fire protection water supply.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.b(10) Common tanks are permitted for fire and sanitary or service water storage. When this is done, however, minimum fire water storage requirements should be dedicated by passive means, for example, use of a vertical standpipe for other water services.

Administrative controls, including locks for tank outlet valves, are unacceptable as the only means to ensure minimum water volume.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6.b(10) Common tanks permitted for fire and sanitary or service water storage are not applicable to Shearon Harris.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.b(11) The fire water supply should be calculated on the basis of the largest expected flow rate for a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, but not less than 300,000 gallons. This flow rate should be based (conservatively) on 500 gpm for manual hose streams plus the largest design demand of any sprinkler or deluge system as determined in accordance with NFPA 13 or NFPA 15. The fire water supply should be capable of delivering this design demand over the longest route of the water supply system.

69

PROJECT CONFOR!Q2/CE: C. POSITION (Cont'd)

C.6.b(ll) The fire water supply, 360,000 gallons, is calculated on the basis of the greatest system demand, 2,000 gpm for the Turbine Building, plus a maximum hose stream demand of 1,000 gpm for a duration of two hours. The fire pumps are sized in accordance with NFPA-20 and are rated at 2,500 gpm at 125 psig. Each pump is capable of delivering 150% of rated capacity at not less than 65% of rated head. Each is capable of delivering the design demand over the longest route of the water supply system.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.b(12) Freshwater lakes or ponds of sufficient size may qualify as sole source of water for fire protection but require separate redundant suctions in one or more intake structures. These supplies should be separated so that a failure of one supply will not result in a failure of the other supply.

PROJECT CONFORKQlCE: C. POSITION (Cont'd)

C.6.b(12) The Auxiliary Reservoir supplies fresh water to the yard fire main. The electric and diesel vertical fire pumps are well separated from each other by being installed at opposite ends of the emergency service water screening structure. Each pump takes suction from a separate wet pit and has independent discharge connections, about 40 feet apart, to the main fire protection loop. No single failure or event in the emergency service water intake system will result in the failure of the o t he r supply.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.b(13) When a common water supply is permitted for fire protection and the ultimate heat sink, the following conditions should also be satisfied:

(a) The additional fire protection water requirements are designed into the total s to rage capacity, and (b) Failure of the fire protection system should not degrade the function of the ultimate heat sink.

PROJECT CONFOR"fANCE: C. POSITION (Cont'd)

C.6.b(13) The water supply for fire protection and the ultimate. heat sink satisfies'the following conditions:

(a) The additional fire protection water requirements are designed into the total storage capacity and 70

(b) Failure of the fire protection system will not degrade the function of the ultimate heat sink (see Subsection

9. 2. 5)

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.b(14) Other water systems that may be used as one of the two fire water supplies should be permanently connected to the fire main system and should be capable of automatic alignment to the fire main system. Pumps, controls, and power supplies in these systems should satisfy the requirements for the main fire pumps. The use of other water systems for fire protection should not be incompatible with their functions required for safe plant shutdown. Failure of the other system should not degrade the fire main system.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6.b(14) Not applicable.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.c. Water Sprinkler and Hose Standpipe S stems (1) Sprinkler systems and manual hose station standpipes should have connections to the plant underground water main so that a single active failure or a crack in a moderate-energy line cannot impair both the primary and backup fire suppression systems.

Alternatively, headers fed from each end are permitted inside buildings to supply both sprinkler and standpipe systems, provided steel piping and fittings meeting the requirements of ANSI B31.1, "Power Piping," are used for the headers up to and including the first valve supplying the sprinkler systems where such headers are part of the seismically analyzed hose standpipe system. When provided, such headers are considered an extension of the yard main system. Each sprinkler and standpipe system should be equipped with OS&Y (outside screw and yoke) gate valve or other approved shutoff valve and waterf low alarm.

Safety-related equipment that does not itself require sprinkler water fire protection but is subject to unacceptable damage if wet by sprinkler water discharge should be protected by water shields or baffles.

PROJECT CONFORKQlCE: C. POSITION (Cont'd)

C.b.c. Water Sprinkler and Hose Standoi e Systems (1) Sprinkler systems and manual hose station standpipes have connections to the plant underground ~ater main so that a single active failure or a crack in a moderate-energy line cannot impair both the primary and backup fire suppression systems.

Headers fed from each end are used inside buildings to supply 71

4 both sprinkler and standpipe systems in the Waste and Fuel Handling Buildings, the Turbine and Reactor Auxiliary Buildings and are fabricated of carbon steel piping and fittings meeting the requirements of ANSI B31.1 "Power Piping." Each sprinkler and standpipe system is equipped with an OS&Y gate valve and water flow alarm except that in the RAB where the header supplying the hose standpipes is arranged so that the OS&Y gate valves in the header on each side of a standpipe must be closed to isolate the standpipe. Since this header is fed from both ends the water supply to other standpipes served by this header is not interrupted. The Fire Hazards analysis describes the methods used to protect safety-related equipment in each fire area from water damage.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.c(2) Control and sectionalizing valves in the fire water systems should be electrically supervised or administratively controlled. The electrical supervision signal should indicate in the control room. All valves in the fire protection system should be periodically checked to verify position (see NFPA 26, "Supervision of Valves" ).

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6.c(2) Control and sectionalizing valves in the fire water systems are electrically supervised. The electrical supervision signal indicates on the Local Fire Detection and Control Panels and at the Main Fire Detection Information Center located in the communication room. A common trouble annunciation will be given in the control room if any valve is out of position.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.c(3) Fixed water extinguishing systems should conform to requirements of appropriate standards such as NFPA 13, "Standard for the Installation of Sprinkler Systems," and NFPA 15, "Standard for Water Spray Fixed Systems."

PROJECT CONFOR LANCE: C. POSITION (Cont'd)

C.6.c(3) Fixed water extinguishing systems conform to requirements of appropriate standards: NFPA 13, "Standard for the Installation of Sprinkler System," and NFPA 15, "Standard for Water Spray Fixed Systems."

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.c(4) Interior manual hose installation should be able to reach any location that contains, or could present a fire exposure hazard to, safety-related equipment with at least one effective hose stream. To accomplish this, standpipes with hose connections 72

equipped with a maximum of 100 feet of 1-1/2 inch woven-jacket lined fire hose and suitable nozzles should be provided in all buildings on all floors. Individual standpipes should be at least 4 inches in diameter for multiple hose connections. These systems should follow the requirements of NFPA 14, "Standpipe and Hose Systems," for sizing, spacing, and pipe support requirements.

Hose stations should be located as dictated by the fire hazard analysis to facilitate access and use for firefighting operations. Alternative hose stations should be provided for an area if the fire hazard could block access to a single hose station serving that area.

Provisions should be made to supply water at least to standpipes and hose connections for,manual firefighting in areas containing equipment required for safe plant shutdown in the event of a safe shutdown, earthquake. The piping system serving such hose stations should be analyzed for SSE loading and should be provided with supports to ensure system pressure integrity. The piping and valves for the portion of hose standpipe system affected by this functional requirement should, as a minimum, satisfy ANSI B31.1, "Power Piping." The water supply for this condition may be obtained by manual operator actuation of valves in a connection to the hose standpipe header from a normal seismic Category I water system such as the essential service water system. The cross connection should be (a) capable of providing flow to at least two hose stations (approximately 75 gpm per hose station), and (b) designed to the same standards as the seismic Category I water system', it should not degrade the performance of the seismic Category I water system.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.e.c(4) Interior manual hose stations are provided in each plant area so that all portions of the plant are protected with at least'one effective hose stream, except the tank area', Diesel Fuel Oil Storage Tank and Transfer Pumps area and ESW intake and screen structure, which are protected by yard hydrants. Each interior hose station is provided with 100 feet of 1-1/2 inches Angus "Red Chief" rubber-l.ined, rubber coated hose and adjustable nozzles suitable for use on electrical equipment. Individual standpipes are 4 inches in diameter for multiple hose stations and 2-1/2 inches for single hose stations. These systems follow the requirements of NFPA 14 "Standpipe and Hose Systems" Class II, for sizing, spaces, and pipe support requirements.

Hose stations are located as dictated by the fire hazard analysis to facilitate access and use for firefighting operations. Alternative hose stations are provided for an area if the fire hazard could block access to a single hose station serving that area.

73 (3276PPC/ccc)

Provisions were made to supply water at least to standpipes and hose connections for manual firefighting in areas containing equipment required for safe plant shutdown in the event of a safe shutdown earthquake, except for the Emergency Diesel Generator and Diesel Fuel Oil Buildings, where the redundant counterparts are well separated. The piping system serving such hose stations were analyzed for SSE loading and provided with supports to ensure system pressure integrity. The piping and valves for the portion of hose standpipe system affected by this functional requirement, as a minimum, satisfy ANSI B31.1, "Power Piping." Following an SSE, the water supply is obtained by local manual actuation of valves to connect to the Seismic Category I Emergency Service Water System.

The system cross connections are capable of supplying two, 75 gpm hose stations. Piping between these valves and the emergency service water system are designed as ASME Safety Class 3. They will not degrade the performance of the Seismic Category I Sater System.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.c(5) The proper type of hose nozzle to be supplied to each area should be based on the fire hazard analysis. The usual combination spray/straight-stream nozzle should not be used in areas where the straight-stream can cause unacceptable mechanical damage. Fixed fog nozzles should be provided at locations where high-voltage shock hazards exist. All hose nozzles should have shutoff capability.

(Guidance on safe distances for water application to live electrical equipment may be found in the "NFPA Fire Protection Handbook.")

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6.c(5) The proper type of hose nozzle supplied to each area is based on the fire hazard analysis. The usual combination spray/ straight-stream nozzle are not used in areas where the straight stream can cause unacceptable mechanical damage. Adjustable spray nozzles, approved for use on energized electrical equipment, are provided on standpipe hoselines available for discharge on electrical equipment and cabling.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.c(6) Fire hose should be hydrostatically tested in accordance with the recommendations of NFPA 1962, "Fire Hose Care, Use, Maintenance." Hose stored in outside hose houses should be tested annually. Interior standpipe hose should be tested every 3 years.

74 (3276PPC )

PROJECT CONFOR~XCE: C. POSITION (Cont'd)

C.6.c(6) Fire hose will be hydrostatically tested in accordance with the recommendations of NFPA 1962, "Fire Hose Care, Use, Maintenance." Hose stored in outside hose houses will be tested annually. Interior standpipe hose will be tested every 3 years.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.c(7) Certain fires, such as those involving flammable liquids, respond well to foam suppression. Consideration should be given to use of mechanical low-expansion foam systems, high-expansion foam generators, or aqueous film-forming foam (AFFF) systems, including the AFFF deluge system. These systems should comply with the requirements of NFPA ll, NFPA llA, NFPA 11B, and NFPA 16, as applicable.

PROJECT CONFOR~CE: C. POSITION (Cont'd)

C.6.c(7) Foam suppression is not used to protect safety-related systems.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.d. Halon Suonression Systems Halon fire extinguishing systems should comply with the requirements of NFPA 12A and NFPA 12B, "Halogenated Fire Extinguishing Agent Systems-Halon 1301 and Halon 1211." Only UL-listed or FM-approved agents should be used. Provisions for locally disarming automatic Halon systems should be key locked and under stric- administrative control. Automatic extinguishing systems should not be disarmed unless controls as described in Position C.2.j are provided.

In addition to the guidelines of NFPA 12A and 12B, preventive maintenance and testing of the systems, including check-weighing of the Halon cylinders, should be done at least quarterly.

Particular consideration should also be given to:

(1) Minimum required Halon consideration, distribution, soak time, and ventilation control; (2) Toxicity of Halon; (3) Toxicity and corrosive characteristics of the thermal decomposition products of Halon; and (4) Location and selection of the activating detectors.

PROJECT CONFOR~CE: C. POSITION (Cont'd)

C.6.d Halon Suppression Systems The Halon fire extinguishing systems used at SHNPP will comply with the 75

requirements of NFPA 12A and 12B. Only UL-listed or FM-approved agents will be used. Provisions for locally disarming automatic Halon Systems will be under administrative control and key locked. Halon discharge can be delayed locally by Halon abort pushbutton. Disarming of automatic extinguishing systems will be controlled by a permit system. Fire watches will be established in areas where the system is disarmed.

Preventive maintenance and testing will be performed semiannually in accordance with NFPA-12A.

These considerations are incorporated, as applicable, into the design of the systems:

(1) Minimum required Halon consideration, distribution, soak time, and ventilation control; (2) Toxicity of Halon; Toxicity and corrosive characteristics of the thermal decomposition products of Halon; and (4) Location and selection of the activating detectors.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.e. Carbon Dioxide Su ression S stems Carbon dioxide extinguishing systems should comply with the requirements of NFPA 1'2, "Carbon Dioxide Extinguishing Systems." Where automatic carbon dioxide systems are used, they should be equipped with a predischarge alarm system and a discharge delay to permit personnel egress. Provisions for locally disarming automatic carbon dioxide systems should be key locked and under strict administrative control.

Automatic carbon dioxide extinguishing systems should not be disarmed unless controls as described in Position C.2.c are provided.

Particular consideration should also be given to:

Minimum required CO2 concentration, distribution, soak time, and ventilation control; (2) Anoxia and toxicity of CO2, Possibility of secondary thermal shock (cooling) damage; (4) Conflicting requirements for venting during CO2 injection to prevent overpressurization versus sealing to prevent loss of agent; and Location and selection of the activating detectors.

76

Halon suppression system is used in the Records Storage areas located in the Administration Building.

Preventive maintenance and testing will be performed semiannually in accordance with NFPA-12A.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6.e. Carbon Dioxide Sup ression Systems Carbon dioxide systems are not used.

NRC GUIDELINES: C. POSITION (Cont'd)

C.6.f. Portable Extin uishers Fire extinguishers should be provided in areas that contain, or could present a fire exposure hazard to, safety-related equipment in accordance with guidelines of NFPA 10, "Portable Fire Extinguishers, Installation, Maintenance and Use." Dry chemical extinguishers should be installed with due consideration given to possible adverse effects on safety-related equipment installed in the area.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.6.f. Portable Extinguishers Fire extinghishers are provided in areas that contain, or could present a fire exposure hazard to, safety-related equipment in accordance with guidelines of NFPA 10, "Portable Fire Extinguishers, Installation, Maintenance and Use." Dry chemical extinguishers are installed with due consideration as stated in FSAR Subsection 9.5.1 for possible adverse effects on safety-related equipment installed in the area.

NRC GUIDELINES: C. POSITION (Cont'd)

C.j. Guidelines for S ecific Plant Area C.7.a Primary and Seconda Containment (1) Normal Operation - Fire protection requirements for the primary and secondary containment areas should be provided for hazards identified by the fire hazards analysis.

Examples of such hazards include lubricating oil or hydraulic fluid system for the primary coolant pumps, cable tray arrangements and cable penetrations, and charcoal filters.

Because of the general inaccessibility of primary containment during normal plant operation, protection should be provided by automatic fixed systems. The effects of postulated fires within the primary containment should be evaluated to ensure that the integrity of the primary coolant system and the containment is not jeopardized assuming no action is taken to fight the fire.

77

Operation of the fire protection systems should not

.compromise the integrity of the containment or other safety-related systems. Fire protection activities in the containment areas should function in conjunction with total containment requirements such as ventilation and control of contaminated liquid and gaseous release.

C 7.a(l)(b) Inside noninerted containment one of the fire protections means stated in Positions C.5.b.l and C.5.b.2 or the following fire protection means should be provided:

separation of cables and equipment and associated non-safety circuits of redundant trains by a noncombustible radiant energy shield having a minimum fire rating of one-half hour, C.7.a(l)(c) In primary containment, fire detection systems should be provided for each fire hazard. The type of detection used and the location of the detectors should be the most suitable for the particular type of fire hazard identified by the fire hazard analysis.

A general area fire detection capab'ity should be provided in the primary containment as backup for the above described hazard detection. To accomplish'his, suitable smoke or heat detectors compatible with the radiation environment should be installed.

C.7.a(l)(d) Standpipe and hose stations should be inside PWR containments and BUR containments that are not inerted.

Standpipe and hose stations inside containment may be connected to a high quality water supply of sufficient quantity and pressure other than the fire main loop if plant-specific features prevent extending the fire main supply inside containment. For BVR drywells, standpipe and hose stations should be placed outside the drywell with adequate lengths of hose, no longer than 100 ft, to reach any location inside the drywell with an effective hose stream.

The containment penetration of the standpipe system should meet the isolation requirements of General Design Criterion 56 and should be seismic Category I and Quality Group B.

'I The reactor coolant pumps should be equipped with an oil collection system if the containment is not inerted during normal operation. The oil collection system should be so designed, engineered, and installed that failure will not lead to fire during normal or design basis accident conditions and that there is reasonable assurance that the system will withstand the safe shutdown earthquake.

78

Such collection systems should be capable of collecting lube oil from all potential pressurized and unpressurized Leakage sites in the reactor coolant pump lube oil systems. Leakage should be collected and drained to a vented closed container that can hold the entire Lube oil system inventory. A flame arrester is required in the vent if the flash point characteristics of the oil present the hazard of Eire flashback. Leakage points to be protected should include Lift pump and piping overflow lines, lube oil cooler, oil fill and drain lines and plugs, Elanged connections on oil lines, and lube oil reservoirs where such features exist on the reactor coolant pumps. The drain Line should be large enough to accommodate the largest potential oil Leak.

For secondary~ containment area, cable fire hazards that could affect safety should be protected as described in Position C.5.e(2). The type of detection system for other fire hazards identified by the fire hazards analysis should be the most suitable Eor the particular type of Eire hazard.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7. Guidelines for S ecific Plant Areas C.7.a. Primar Containment (1) Normal 0 eration - Fire protection systems and equipment are provided in the containment areas as required for most effective Eire controL recognizing the different types of operations in the area, accessibility and available personnel usage.

The following hazards have been identified and protection is installed in the containment as follows:

Cable trays and external surfaces of charcoal filter equipment are protected by an automatic multi-cycle sprinkler system, actuated by thermaL rate compensated detectors.

System will automaticalLy shut off upon drop in temperature (i.e., fire extinguished) to reduce quantity of unborated water introduced into the containments. Closed sprinkler heads and supervisory air pressure provide adequate safeguards against inadvertent actuation. Valving and electrical equipment associated with the system are Located outside the containment building for accessibility. A Lube oil collection system is provided for the reactor cooLant pumps as detailed in Section C.5.d and C.7.a(1)(e), and is capabLe of collecting lube oil from all potential pressurized and unpressurized leakage sites in the reactor coolant pump Lube oiL systems.

The effects of postulated fires within the primary containment are discussed in the Fire Hazards Analysis, Section 9.5A, of the FSAR.

79 (3276PPC/Ljs)

C. 7. a(1) (a) Operation of the fire protection systems do not compromise the integrity of the containment or other safety-related systems. Fire protection activities in the containment areas function in conjunction with total containment requirements such as ventilation and control of contaminated liquid and gaseous release, as detailed in FSAR Subsection 9.5.1.2.4 and Appendix 9.5A-l.

C.7.a(l)(b) Within the containment, separation of cables and equipment of redundant trains is achieved by spatial separation and/or structural barriers, or by provision of automatic multi-cycle sprinkler system actuated by thermal detection.

C.7.a(1)(c) In primary containment, fire detection systems were provided for each fire hazard. The type of detection used and the location of the detectors are the most suitable for the particular type of fire hazard identified by the fire hazard analysis, Appendix 9.5A.l.

SHNPP has no ionization detectors in the containment for general area detection.

C.7.a(1)(d) Standpipe and hose stations are provided inside the containment and are supplied from the yard fire main during normal operations. After a SSE, the standpipes are supplied

<<~~ the Emergency Service Water System. See the response to rusiiion (6.c(4) above ~

The containment penetration of the standpipe system meet the isolation requirements of General Design Criterion 56 and are seismic Category I and Quality Group B.

C. 7. a(1) (e) The reactor coolant pumps will be equipped with an oil collection system. The oil collection system will be so designed, engineered, and installed that failure will not lead to fire during normal or design basis accident conditions and that there will be reasonable assurance that the system will withstand the safe shutdown earthquake.

The collection systems will be capable of collecting lube oil from all potential pressurized and unpressurized leakage sites in the reactor coolant pump lube oil systems. Leakage

~111 be collected and drained to a vented closed container that can hold the entire lube oil system inventory. A flame arrester will be provided in the vent if the flash point characteristics of the oil present the hazard of fire flashback. Leakage points to be protected will include lift pump and piping overflow lines, lube oil cooler, oil filland drain lines and plugs, flanged connections on oil lines, and lube oil reservoirs where such features exist on the reactor coolant pumps. The drain line will be large enough to accommodate the largest potential oil leak.

80

C.7.a(l)(f)

~ ~ Not applicable.

NRC GUIDELINES: C. POSITION (Cont'd)

C.7.a(2) Refuelin and Maintenance Refueling and maintenance operations in containment may introduce additional hazards such as contamination control materials, decontamination supplies, wood planking, temporary wiring, welding, and flame cutting (with portable compressed-gas fuel supply). Possible fires would not necessarily be in the vicinity of fixed detection and suppression systems.

Management procedures and control necessary to ensure adequate fire protection for transient fire loads are discussed in Position C.2.

Adequate self-contained breathing apparatus should be provided near the containment entrances for firefighting and damage control personnel. These units should be independent of any breathing apparatus or air supply systems provided for general plant activities and should be clearly marked as emergency equipment.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7.a(2) Refuelin and Maintenance Management procedures and controls necessary to ensure adequate fire protection for transient fire loads during refueling and maintenance operations in containment are discussed in Project Conformance, Position C.2.

Adequate self-contained breathing apparatus will be provided for fire brigade use. These units will be independent of any breathing apparatus or air supply systems provided for general plant activities and will be clearly marked as emergency equipment. Fire fighting apparatus including SCBA are maintained at a central location in the Turbine Building 261'levation. Fire Brigade members will assemble. at this location to collect equipment and procedures prior to proceeding to the fire scene.

NRC GUIDELINES: C. POSITION (Cont'd)

C.7.b Control Room Com lex The control room complex (including galleys, office spaces, etc.) should be protected against disabling fire damage and should be separated from other areas of the plant by floors, walls, and roof having minimum fire resistance ratings of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Peripheral rooms in the control room complex should have automatic water suppression and should be separated from the control room by noncombustible construction with a fire resistance rating of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

Ventilation system openings between the control room and peripheral rooms should have automatic smoke dampers that close on operation of the fire detection or suppression system. If a Halon flooding system is used for fire suppression, these dampers should be strong enough to support the pressure rise accompanying Halon discharge and seal tightly against infiltration of Halon into the control room. Carbon dioxide flooding systems are not acceptable for these areas.

81

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7.b.

~ ~ ~ Control Room Fire Area The Control Room Fire Area as shown on FSAR Figure 9.5A-10 is separated from other areas of the plant by walls, floors, doors and ceiling having minimum fire resistance ratings of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The Terminal Cabinet Room and Living Quarters are part of the Control Room Fire Area. A deviat'ion for not providing automatic suppression throughout the fire area was requested and granted. A kitchen, office and the component cooling water tank are located within the Terminal Cabinet Room. Combustibles in the kitchen consists of limited amounts of ordinary Class A combustibles such as paper towels and napkins. A sprinkler will be provided in the kitchen area. The combustibles in the Terminal Cabinet Room are limited to cables within the panels which are considered negligible. A fire hose station and portable extinguisher are located in this room. The Control Room Fire Area is served by AH-15 (lA-SA) backed up by AH-15 (1B-SB).

NRC GUIDELINES: C. POSITION (Cont'd)

C.7.b. Control Room Com lex Manual firefighting capability should be provided for both:

(1) Fire originating within a cabinet, console, or connecting cables, and (2> Exposure fires involving combustibles in the general room area.

@ Portable Class control room.

A and A hose Class C fire extinguishers should station should be be located in the installed immediately outside the control room.

Nozzles that are compatible with the hazards and equipment in the control room should be provided for the manual hose station. The nozzles chosen should satisfy actual firefighting needs, satisfy electrical safety, and minimize physical damage to electrical equipment from hose stream impingement.

Smoke detectors should be provided in the control room, cabinets, and consoles. If redundant safe shutdown equipment is located in the same control room cabinet or console, additional fire protection measures should be provided. Alarm and local indication should be provided in the control room.

82

Breathing apparatus for control room operators should be readily available.

The outside air intake(s) for the control room ventilation system should be provided with smoke detection capability to alarm in the control room to enable manual isolation of the control room ventilation system and thus prevent smoke from entering the control room.

Venting of smoke produced by fire in the control room by means of the normal ventilation system is acceptable', however, provision should be made to permit isolation of the recirculating portion of the normal ventilation system. Manually operated venting of the control room should be available to the operators.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7.b. Control Room Fire Area (Cont'd)

Manual firefighting capability is provided for fires (1) within cabinets, consoles or connecting cables and (2) exposure fires involving combustibles in the general room area by means of Class A and Class C fire extinguishers inside the control room and a hose located just outside the control room.

Adjustable nozzles, approved for use on electrical fires, are provided for the hose station. The nozzle selected will also minimize physical damage to electrical equipment from hose stream impingement.

Ionization detectors will be provided in the control and peripheral rooms at the ceiling level. The Control. Room cabinets, panels and consoles are of the self ventilating type permitting smoke to quickly migrate to the ceiling of the room. Rapid migration of combustion by-products facilitates quick response by highly sensitive smoke detectors. Ionization detectors are provided in the Main control Board. Alarm and local indication will be provided in the Control Room.

Self-contained breathing apparatus are available for use by the operators until the room ventilation system can evacuate smoke.

A smoke detector is provided at the outside air makeup inlet so that smoke induction into the Control Room can be minimized by automatic isolation of the outside air intake. The supply side of normal ventilation is used in conjunction with smoke purge fans during smoke purge. The return side of normal ventilation is isolated.

83 (3276PPC)

NRC GVIDELINES: C. POSITION (Cont'd)

C.7.b. Control Room Com lex (Cont'd)

All cables that enter the control room should terminate in the control room.

That is, no cabling should be routed through the control room from one area to another. Cables in underfloor and ceiling spaces should meet the separation criteria necessary for fire protection.

Air-handling functions should be ducted separately from cable runs in such spaces; i.e., if cables are routed in underfloor or ceiling spaces, these spaces should not be used as ai r plenums for ventilation of the control room. Fully enclosed electrical raceways located in such underfloor and ceiling spaces, if over 1 square foot in cross-sectional area, should have automatic fire suppression inside. Area automatic fire suppression should be provided for underfloor and ceiling spaces if used for cable runs unless all cable is run in 4-inch or smaller steel conduit or the cables are in fully enclosed raceways internally protected by automatic fire suppression.

There should be no carpeting in the control room.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7.b. Control Room Fire Area (Cont'd)

As stated in FSAR Subsection 9.5.1.2.4 all cables entering the control room terminate there. No cables are routed through the control room from one area to another. Due to Human Factors consideration, a raised floor will be created. This raised floor section is located in front of the Main Control Panels and will have two (2) computer CRT's mounted on the raised section.

Cabling consisting of seven (7) low-voltage signal cables and one (1) 120V AC power cable will be located under the raised section to support the computer CRT's. Ionization detection will be provided under the raised floor. There is a trench under the HVAC Control Board which is about 11 feet long x 2 feet wide x 8 inches deep which contains only Train B safety cable and non-safety cable. The fire loading is low, less than 2000 BTU/sq. ft. No suppression system is provided. There are redundant safety-related radiation monitoring cables, installed in conduits and in accordance with Regulatory guide 1.75, located above the suspended ceiling. As stated in the Fire Hazards Analysis, Section 9.5A of the FSAR, the combustible loading in the Control Room is considered negligible. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> occupancy of the Control Room combined with the availability .of fire extinguishers and hose stations mitigate the effects of an exposure fire.

The Control Room suspended ceiling is aluminum luminous louver type, egg crate construction having negligible impact on air distribution. A perforated duct located above the suspended ceiling introduces air into the control room. The space above the suspended ceiling does not contain any cable tray, only conduits.

84 (3276PPC )

Conduits 4-inch and smaller in diameter run through this space. Smoke detectors will be provided on the south side of the Control Room reinforced concrete ceiling, as well as below the suspended ceiling. The conduit will be sealed in accordance with NUREG-0800 criteria. Automatic suppression will not be provided, as there is no fire loading in the space between the suspended ceiling and the concrete ceiling. Control Room carpet will be installed for Human Factors considerations and will meet the guidance of Section C.5.a(9).

84a (3276PPC)

NRC GUIDELINES:, C. POSITION (Cont'd)

C.7.c. Cable Spreading Room The primary fire suppression in the cable spreading room should be an automatic water system such as closed-head sprinklers, open-head deluge system, or open directional water spray system. Deluge and open spray systems should have provisions for manual operation at a remote station; however, there should be provisions to preclude inadvertent operation.

Location of sprinkler heads or spray nozzles should consider cable tray arrangments and possible transient combustibles to ensure adequate water coverage for areas that could present exposure hazards to the cable system. Cables should be designed to allow wetting down with water supplied by the fire suppression system without electrical faulting.

Open-head deluge and open directional spray systems should be zoned.

The use of foam is acceptable.

Cable spreading rooms should have:

(l) At least two remote and separate entrances for access by fire brigade personnel; (2) An aisle separation between tray stacks at least 3 feet wide and 8 feet high; (3) Hose stations and portable extinguishers installed immediately outside the room; (4) Area smoke detection; and (5) Continuous line-type heat detectors for cable trays inside the cable spreading room.

Drains to remove firefighting water should be provided. When gas systems are installed, drains should have adequate seals or the gas extinguishing systems should be sized to compensate for losses through the drains.

A separate cable spreading room should be provided for each redundant division. Cable spreading rooms should not be shared between reactors.

Each cable spreading room should be separated from the others and from other areas of the plant by barriers with a minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. If this is not possible, a dedicated system should be provided.

The ventilation system to each cable spreading room should be designed to isolate the area upon actuation of any gas extinguishing system in the area. Separate manually actuated smoke venting that is operable from outside the room should be provided for the cable spreading room.

85

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7.c. Cable S readin Room The primary fire suppression system in the cable spreading rooms are automatic preaction sprinkler systems actuated by thermal detection systems employing closed sprinkler heads, installed at the ceiling level. Cable tray arrangements were considered in the location of sprinkler heads to insure adequate water coverage. Since there are only cables in this room, the Fire Hazards Analysis postulates that transients such as oil, grease, rags or solvents normally associated with equipment maintenance or repair will not be brought into the area. The preaction valve can be tripped mechanically at the valve or operated by pull stations located inside or outside the room located at elevation 286'. Inadvertent operation is precluded by the two step discharge cycle of the preaction system which requires both the operation of the preaction valve and fusing of the sprinkler head. Cables are designed to allow wetting down by water from the fire protection system. Ionization type smoke detection is provided for early warning oE a Eire condition and a visual display of the detectors Location, as well as "first actuated" detector is provided at the local graphics panel located outside the Cable Spread Room.

Foam is not used.

The cable spreading rooms have:

(1) More than two remote and separate entrances;

(~) Aisles to facilitate access in the cable spreading rooms have been provided, however, due to redesign to provide redundant cable spreading rooms, the aisles have been reduced in dimensions. Depending upon their location, they vary from 3 feet wide by 8 feet high to a minimum of L-L/2 to 2 feet wide by 5 Eeet high. A number of access doors exist. A trained firefighter can access the area with his equipment, provided that he is familiar with the layout through training.

A visual display of smoke detectors is provided at the local graphics panel. The firefighter will be cognizant of the location of the fire and will use the proper aisle to facilitate fire attack strategy.

(3) Portable extinguishers located inside and outside the room and hoses located immediately outside each room; (4) Area smoke detection; and (5) Ionization detectors are used to provide early warning of incipient fires and permit early attack by manual means. Thermal detectors Located at the ceiling actuate the automatic suppression system. The dual detection system provides a sufficient means of fire detection in lieu of depending upon Line-type temperature detection.

86 (3276PPC)

Floor drains are provided to accommodate anticipated sprinkler and hose rack discharges. There is no gas system in the cable spreading rooms.

Each cable spreading room is designed to contain only one redundant safety division,'owever, in some cases redundant safety divisions do pass through the areas. In those cases, they are either enclosed in one-hour fire resistance rated enclosure due to sprinkler system already existing in this area or analyzed to determine the effects of a fire in the area. Cable spreading rooms are separated from each other and from other areas of the plant by barriers having a minimum fire resistance of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, except as explained above.

There is no gas extinguishing system for the cable spreading rooms, therefore, ventilation system isolation is not required. Smoke venting is accomplished manually through a smoke purge operation via control room operator as described in FSAR Subsection 9.4.5.

NRC GUIDELINES: C. POSITION (Cont'd)

C.7.d. Plant Com uter Rooms Computer rooms for computers performing safety-related functions that are not part of the control room complex should be separated from other areas of the plant by barriers having a minimum fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and should be protected by automatic detection and fixed automatic suppression.

Computers that are part of the control room complex but not in the control room should be separated and protected as described in Position C.7.b.

Computer cabinets located in the control room should be protected as other control room equipment and cable runs therein. Non-safety-related computers outside the control room complex should be separated from safety-related areas by fire barriers with a minimum rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and should be protected as needed to prevent fire and smoke damage to safety-related equipment.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7.d. Plant Com uter Rooms The SHNPP computer serving Unit 1 is non-safety-related and does not perform any safety function. The non-safety computer and radiation monitoring computer are located outside the Control Room and is provided with 3-hour fire resistance rated barriers on all sides except those separating it from the Auxiliary Relay Panels Room, and the Process Instruments and Control Racks Room. Automatic ionization type smoke detectors are provided in the room at the ceiling level, portable extinguisher and a hose station adjacent to the room is available. Due to a computer redesign an underfloor area was created. Ionization detectors are provided under the Room raised floor with a corresponding graphics display panel located in the Computer Room. The radiation monitoring computer located in the control room is protected as other control room equipment.

87 (3276PPC)

NRC GUIDELINES: C. POSITION (Cont'd)

C.7.e. Switch ear Rooms Switchgear rooms containing safety-related equipment should be separated from the remainder of the plant by barriers with a minimum fire raging of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Redundant switchgear safety divisions should be separated from each other by barriers with a 3-hour fire rating. Automatic fire detectors should alarm and annunciate in the control room and alarm locally. Cables entering the switchgear room that do not terminate or perform a function there should be kept at a minimum to minimize the combustible loading. These rooms should not be used for any other purpose. Fire hose stations and portable fire extinguishers should be readily available outside the area.

Equipment should be located to facilitate access for manual firefighting.

Drains should be provided to prevent water accumulation from damaging safety-related equipment (see NFPA 92M, "Waterproofing and Draining of Floors" ).

Remote manually actuated ventilation should be provided for venting smoke when manual fire suppression effort is needed (see Position C.S.f).

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7.e. Switch ear Rooms Redundant switchgear rooms containing safety-related equipment are separated from each other and other plant areas by walls having, as a minimum, a fire resistance rating of three hours. Automatic ionization type smoke detectors, provided in each room, alarm locally and in the controL room. Cables passing through the switchgear rooms are held to a minimum. The rooms are used mainly for switchgear and battery chargers which cannot be located in battery rooms for safety reasons. Carbon dioxide portable extinguishers are located in and adjacent to the rooms. Hose stations are adjacent to the rooms.

Equipment is arranged to facilitate access by fire fighters. In the event of a fire requiring the use of a manual hose station, accumulated water can migrate to adjacent areas equipped with floor drains. Drainage into the adjacent areas will not damage safety-related equipment. Curbing is installed to prevent excess fire fighting water from flooding the redundant switchgear room. Curbing height was selected based on two 75 gpm hose streams for one hour [see C.6.C(4)] in the smallest switchgear room with no allowance for leakage into the adjacent areas discussed above. Smoke is removed by the normal ventilation system for this area which is switched remote-manually to once through purge operation as described in FSAR Subsection 9.4.5. The system used is AH-12 and 13 for supply and Butterfly Valve roof vents for exhaust. Refer to FSAR Appendix 9.5A.84 and 9.5A.90 in the FSAR for additional information.

NRC GUIDELINES: C. POSITION (Cont'd)

C.7.f. Remote Safet -Related Panels Redundant safety"related panels remote from the control room complex should be separated from each other by barriers having a minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Panels providing remote shutdown capability should be separated from 88 (3276PPC )

the control room complex by barriers having a minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Panels providing remote shutdown capability should be electrically isolated from the control room complex so that a fire in either area will not affect shutdown capability from the other area. The general area housing remote safety-related panels should be provided with automatic fire detectors that alarm locally and alarm and annunciate in the control room. Combustible materials should be controlled and limited to those required for operation.

Portable extinguishers and manual hose stations should be readily available in the general area.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7.f. Remote Safet -Related Panels Areas remote from the control room, containing safety-related panels, are provided with detectors which alarm locally and alarm and annunciate in the Control Room. Panels providing remote shutdown capability are remote from the Control Room and separated from other plant areas by barriers having a fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Panels providing remote shutdown and those in the Control Room are electrically isolated and are connected to panels each of which are located in separate fire areas. Ionization redundant'ransfer detectors alarm locally and alarm and annunciate in the Control Room.

Portable extinguishers and manual hose stations are available in the area.

Redundant safety-related panels required for Safe Shutdown are separated as described in the Safe Shutdown Analysis in Case of Fire.

NRC GUIDELINES: C. POSITION (Cont'd)

C.7.g. Safet -Related Batter Rooms Safety-related battery rooms should be protected against fires and explosions. Battery rooms should be separated from each other and other areas of the plant by barriers having a minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> inclusive of all penetrations and openings. DC switchgear and inverters should not be located in these battery rooms. Automatic fire detection should be provided to alarm and annunciate in the control room and alarm locally. Ventilation systems in the battery rooms should be capable of maintaining the hydrogen concentration well below 2 vol-X. Loss of ventilation should be alarmed in the control room. Standpipe and hose and portable extinguishers should be readily available outside the room.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7.g. Safet -Related Batter Rooms The battery rooms are separated from each other and other plant areas by barriers having a minimum fire resistance rating of three hours including all penetrations and openings. DC switchgear and inverters are not located in the battery rooms. They are located in the switchgear rooms. Automatic ionization type smoke detection is provided inside battery 89 (3276PPC)

rooms, alarming locally and alarming and annunciating in the Control Room via Communications Room. The rooms are provided with adequate ventilation (See FSAR Subsection 9.4.5.2.2) to maintain the concentration of hydrogen gas released into any room air below the specified limits. Air flow switches are provided for the battery rooms with alarm and annunciation in the Control Room, as shown in FSAR Figure 7.3.1-21, Sheets-l, 2, 9 and 10 of ll. Standpipe, hose stations 'and portable extinguishers are readily available outside the rooms.

NRC GUIDELINES: C. POSITION (Cont'd)

C.7.h. Turbine Buildin The turbine building should be separated from adjacent structures containing safety-related equipment by a fire barrier with a minimum rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The fire barriers should be designed so as to maintain structural integrity even in the event of a complete collapse of the turbine structure. Openings and penetrations in the fire barrier should be minimized and should not be located where the turbine oil system or generator hydrogen cooling system creates a direct fire exposure hazard to the barrier. Considering the severity of the fire hazards, defense in depth may dictate additional protection to ensure barrier integrity.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7.h. Turbine Buildin The turbine building is separated from adjacent structures containing safety-related equipment by a fire barrier with a minimum rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The turbine building design precludes the collapse of the building towards adjacent structures containing safety related equipment thereby, maintaining the fire barrier. Openings and penetrations in the fire barriers are minimized and are not located where the turbine oil system or generator hydrogen cooling system creates a direct fire exposure hazard to the barrier. Automatic water spray systems actuated by thermal detection are provided over open oil hazards such as the Waste Oil Sumps, Turbine Oil Reservoir, etc., and hydrogen seal oil units.

Preaction sprinkler systems actuated by thermal detector are installed under the operating and mezzanine floors. Early warning ionization type smoke detection is installed over major cable tray runs and in electrical equipment room. See FSAR Section 9.5A for additional information.

NRC GUIDELINES: C. POSITION (Cont'd)

C.7.i. Diesel Generator Areas Diesel generators should be separated from each other and from other areas of the plant by fire barriers having a minimum fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

90 (3276PPC)

Automatic fire suppression should be installed to combat any diesel generator or lubricating oil fires, such system should be designed for operation when the diesel is running without affecting the diesel.

Automatic fire detection should be provided to alarm and annunciate in the control room and alarm locally. Hose stations and portable extinguishers should be readily available outside the area. Drainage for firefighting water and means for l.ocal manual venting of smoke should be provided.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7.i. Diesel Generator Areas The diesel generators are located within the diesel generator building separated from each other and from other plant structures and components by barriers having a minimum fire resistance rating of three hours. The East wall has an opening for the air intake which is considered equivalent to 3-hour fire resistance rating, based on physical separation from other structures.

Automatic multi-cycle suppression systems are installed in the diesel generator rooms to protect against diesel generator or lubricating oil fires. These systems will not affect the diesel when it is running since combustion air intake is located outside the room. Automatic detection is provided to alarm locally and annunciate in the control room. Hose stations are provided in the corridor outside the diesel rooms portable extinguishers are available inside the rooms'rainage for firefighting water is provided. Use of the normal ventilation exhaust system provides smoke purging. The electrical equipment room employs a recirculating system which upon activation of smoke detectors in the the space can be switched to a once through purge system. The systems used for these functions are described in FSAR Subsection 9.4.5.

NRC GUIDELINES: C. PQSITION (Cont'd)

C.7.i Diesel Generator Areas (Cont'd)

Day tanks with total capacity up to 1,000 gallons are permitted in the diesel generator area under the following conditions.'1)

The day tank is located in a separate enclosure with a minimum fire resistance tubing of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, including doors or penetrations.

These enclosures should be capable of containing the entire contents of the day tanks and should be protected by an automatic fire suppression system, or (2) The day tank is located inside the diesel generator room in a diked enclosure that has sufficient capacity to hold 110X of the contents of the day tank or is drained to a safe location.

91

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7.i. Diesel Generator Areas (Cont'd)

The day tank, capacity 3,000 gallons, for each diesel generator is contained within its individual enclosure having a minimum fire resistance rating of three hours. All penetration barriers and the door have the same fire resistance rating. There is a three foot high dike in the doorway which is able to contain 110X of the tank contents. The tank is also equipped with an automatic fill shutoff. The floor drain is equipped with a normally closed valve located outside the room which when opened drains to the diesel generator sump. The installation of the day tank is in accordance with NFPA 37- "Installation and Use of Stationary Combustion Engines and Gas Turbines." The tank and associated piping are designed to safety Class 3 and seismic Category I requirements minimizing the chance of oil spills and fires in the room.

The areas is also provided with an automatic multi-cycle water suppression system actuated by thermal detectors, backed up by hoses and portable extinguishers outside the room.

NRC GUIDELINES: C. POSITION (Cont'd)

C-7.j. Diesel Fuel Oil Stora e Areas Diesel fuel oil tanks with a capacity greater than 1,100 gallons should not be loc- ~ '.beside buildings containing safety-related equipment. If above-grou"..". ."".'.s are used, they should be located at least 50 feet from any building containing safety-related equipment or, if located within 50 feet, they should be housed in a separate building with construction having a minimum fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Potential oil spills should be confined or directed away from buildings containing safety-related equipment. Totally buried tanks are acceptable outside or under buildiiis~ (see NFPA 30, "Flammable and Combustible Liquids Code,"

for additional guidance).

Above-ground tanks should be protected by an automatic fire suppression system.

PROJECT CONFORMANCE: C. POSITION (Cont'd),

C.7.j. Diesel Fuel Oil Storage Areas The diesel fuel oil storage tanks are buried outside at a distance of about 150 feet from principal plant buildings. Redundant fuel oil transfer pumps are protected by automatic multi-cycle suppression systems and separated by barriers having a fire resistance rating of at least three hours. Carbon dioxide and dry chemical extinguishers as well as yard fire hydrants are available .

92

NRC GUIDELINES: C. POSITION (Cont'd)

C.7.k. Safety-Related Pumps Pump houses and rooms housing redundant safety-related pump trains should be separated from each other and from other areas of the plant by fire barriers having at least 3-hour rat1ngs. These rooms should be protected by automatic fire detection and suppression unless a fire hazards analysis can demonstrate that a f1re will not endanger other safety-related equipment requ1red for safe plant shutdown. Fire detection should alarm and annunciate in the control room and alarm locally. Hose stations and portable extinguishers should be readily accessible.

Floor drains should be provided to prevent water accumulation from damaging safety-related equipment (see Position C.5.a(14)).

Provisions should be made for manual control of the ventilation system to facilitate smoke removal if required for manual firefighting operation (see Position C.5.f).

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7.k. Safety-Related Pumps Safety-related pumps are generally located within areas provided with automatic detection and suppression systems. Separation between redundant pumps is achieved by three-hour rated barriers partial height barriers, spac1al distance or a comb1nation of these elements. Portable fire extinguishers and hoses are also available. Refer to FSAR Section 9.5A and Safe Shutdown Analysis in Case of Fire for details on safety-related pumps.

Floor drains are designed to accommodate any water discharged from fire suppression equipment, and prevent damage to safety-related equipment.

Smoke removal is assured by continuous operation of the once through normal ventilation system for the safety-related pump areas. The ventilation system used for this function are described in FSAR Section F 4 (Cont'd)

'RC GUIDELINES: C. POSITION C.7.1. New Fuel Area Hand portable extinguishers should be located within this area. Also, hose stations should be located outside but within hose reach of this area. Automatic fire detection should alarm and annunciate in the control room and alarm locally. Combustibles should be limited to a minimum in the new fuel area. The storage area should be provided with a drainage system to preclude accumulation of water.

93

The storage configuration of new fuel should always be so maintained as to preclude criticality for any water density that might occur during fire water application.

PROJECT CONFORKCNCE: C. POSITION (Cont'd)

C.7.1. New Fuel Area New fuel unloading, new fuel storage", and spent fuel pool areas are located in the Fuel Handling Building. This building is separated from other structures by three-hour fire barriers.

Combustible loading is minimal. Hand portable extinguishers and standpipe hose stations are installed throughout the building.

I.ocation of the hose stations in the new fuel storage area and wetting by fire protection water is considered acceptable, because the new fuel storage racks are designed to retain the subcriticality of the storage array even when flooded by unborated water (for details refer to FSAR Subsection 9.1.1). Due to the absence of combustible materials and the large room volume and excessive ceiling height, automatic fire detectors are not provided in general areas. However, in confined areas where safety-related equipment is present, detectors are provided. For example, in the- HVAC areas (FHB Elevation 261), which contains the Emergency Exhaust System, thermal detectors are provided over the charcoal filters, for actuation of the multi-cycle sprinkler system, and ionization type smoke detectors are provided inside the MCC room. Manual fire alarm stations are located throughout the Fuel Handling Building near hose stations with local alarm and annunciation in the Control Room.

NRC GUIDELINES: C. POSITION (Cont'd)

C.7.m. Spent Fuel Pool Area Protection for the spent fuel pool area should be provided by local hose stations and portable extinguishers. Automatic fire detection should be provided to alarm and annunciate in the control room and to alarm locally.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7.m. Spent Fuel Pool Area Portable fire extinguishers and hose stations are provided for this area. Due to minimal combustible loading in this zone and excessive ceiling height, fire detectors were not provided in general areas.

However, in confined areas where safety-related equipment is present, such as spent fuel pool cooling pumps and heat exchangers, thermal, rate compensated detectors are provided for the actuation of the multi-cycle sprinkler system installed in the room. Manual fire alarm stations are provided in strategic locations throughout the Fuel Handling Building, usually near a hose station. They will alarm and annunciate in the Control Room.

94

NRC GUIDELINES: CD POSITION (Cont'd)

C.7.n. Radwaste and Decontamination Areas Fire barriers, automatic fire suppression and detection,'nd ventilation controls should be provided.

PROJECT CONFOR.'fANCE: C. POSITION (Cont'd)

C.7.n. Radwaste and Decontamination Areas Radioactive waste is processed in the Waste Processing Building which is separated by three-hour fire barriers from other plant areas.

Administrative offices, locker rooms, and laundries are separated from other areas in the Waste Processing Building. The ventilation system within this building is independent of any other plant ventilation system. Portable extinguishers, standpipe connections for 1-1/2 in.

hose, and manual fire alarm stations are provided throughout the building. Ionization type smoke detectors are provided over major cable tray runs.

The decontamination areas in the Plant are located in the Waste Processing Building at Elevation 211 and in Reactor Auxiliary Buildings at Elevations 236 ft and 261 ft. They are not used for storage of combustible liquids or combustible materials.

Decontamination areas in the Reactor Auxiliary Buildings are protected by multi-cycle sprinkler systems actuated by rate compensated thermal detectors alarming locally and alarming and annunciating to the Control Room via Communi,cations Room. Backup protection is provided from standpipe hoselines and portable extinguishers.

Decontamination areas in the Waste Processing Building are equipped with automatic smoke detectors and are protected by standpipe hoselines and portable fire extinguishers. Manual fire alarm stations are provided at strategic locations throughout the building, in the vicinity of hose stations. They alarm locally and annunciate in the Control Room via Communications Room.

NRC GUIDELINES: C. POSITION (Cont'd)

C.7.o. Safety-Related Water Tanks Storage tanks that supply water for safe shutdown should be protected from the effects of an exposure fire. Combustible materials should not be stored next to outdoor tanks.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7.o. Safety-Related Water Tanks The Refueling Water Storage Tank, Reactor Makeup Water Storage Tank, and the Condensate Storage Tank are located in the Tank Building. Yard hose 95

lines and portable extinguishers are provided. Combustibles will not be I

stored next to these tanks.

NRC GUIDELINES: C. POSITION (Cont'd)

C.7.p. Records Storage Areas Records storage areas should be so located and protected that a fire in these areas does not expose safety-related systems or equipment (see Regulatory Guide 1.88, "Collection, Storage, and Maintenance of Nuclear Power Quality Assurance Records" ).

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7.p. Records Stora e Areas The record storage facility is enclosed within 2-hour fire rated barriers constructed in accordance with ANSI N45.2.9 as referenced by Regulatory Guide 1.88. It is located in the Administration Building, separate from main plant structures and does not present a fire exposure to any safety-related equipment. Fire protection for the record storage facility is in accordance with NFPA Standard 12A and consists of an automatic Halon 1301 system, providing a 5X to 8% concentration within 10 seconds from the discharge. A thermal detection system is installed for the automatic release of the agent. An automatic ionization detection system is installed for early warning of a smoke condition and automatic closure of dampers and fire doors.

NRC GUIDELINES: C. POSITION (Cont'd)

C.7.q. Cooliru, Towers Cooling towers should be of noncombustible construction or so located and protected that a fire will not adversely affect any safety-related systems or equipment. Cooling towers should be of noncombustible construction when the basins are used for the ultimate heat sink or for the fire protection water supply.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7.q. Cooling Towers The hyperbolic cooling tower is of noncombustible construction. The basin is not required'-for decay heat removal or fire protection water supplies. Yard hydrants and hoselines are provided in the immediate vicinity of the cooling towers at strategic locations. A fire at the cooling tower will not adversely affect any safety-related system or component.

96

NRC GUIDELINES: C. POSITION (Cont'd)

C.7. r. Miscellaneous Areas Miscellaneous areas such as shops, warehouses, auxiliary boiler rooms, fuel oil tanks, and flammable and combustible liquid storage tanks should be so located and protected that a fire or effects of a fire, including smoke, will not adversely affect any safety-related systems or equipment.

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.7. r. Miscellaneous Areas Miscellaneous areas such as plant administrative offices, shops, warehouses, and auxiliary boilers are located so that a fire or effects of a fire, including smoke, do not adversely affect any safety-related systems or equipment, since most will be located in separate, detached buildings. Fire protection consisting of sprinklers, standpipe and hose stations and portable extinguishers are provided, as dictated by the fire loadings present in these areas. Fire protection for the Administration Building consists of a sprinkler system, portable extinguishers, and standpipe hoselines.

The fuel oil tanks for auxiliary boiler are above ground surrounded by dikes sized to contain the entire tank content of oil and are equipped with a semi-fixed manual foam system.

NRC GUIDELINES: C. POSITION (Cont'd)

C.8. Special Protection Guidelines C.8.a. Storage of AcetvleneWxygen Fuel Gases Gas cylinder stotage locations should not be in areas that contain or expose safety-related equipment or the fire protection systems that serve those safety-related areas. A permit system should be required to use this equipment in safety-related areas of the plant (also see Position C.2).

PROJECT CONFORMANCE: C. POSITION (Cont'd)

C.8. Special Protection Guidelines C.8.a. Storage of Acetylene-Oxv en Fuel Gases Shearon Harris Nuclear Power Plant has a procedure which governs the storage and use of fuel gases and oxygen. A permit system for welding and burning will be used in the plant. For details see Project Position C.2.

97

NRC GUIDELINES: C. POSITION (Cont'd)

C.8.b. Storage Areas for Ion Exchan e Resins Unused ion exchange resins should not be stored in areas that contain or expose safety-related equipment.

PROJECT CONFORMANCE: C, POSITION (Cont 'd)

C.8. b. S torage Areas for Ion Exchan e Resins Bulk resins storage is maintained in an area that does not house or expose areas containing safety-related systems. Portable extinguishers and standpipe hoselines are provided for these areas. For location of storage areas see FSAR Figure 1.2.2-1.

Selected storage areas are adequately drained, and curbed as necessary.

NRC GUIDELINES: C. POSITION (Cont'd)

C.8.c. Hazardous Chemicals Hazardous chemicals should not be stored in areas that contain or expose safety-related equipment.

PROJECT CONFOR fANCE: C. POSITION (Cont'd)

C.8.c. H>>~~~ ~ ~ Chemicals Bulk hazardous chemical storage is maintained in an area that does not house or expose areas containing safety-related sysrems.

Portable fire extinguishers are provided. Hoselines are provided for those chemi-a' --hich will not react with water.

NRC GUIDEL .'ZZ: C. POSITION (Cont'd)

C.8,d. Materials Containing Radioactivity Materials that collect and contain radioactivity such as spent ion exchange resins, charcoal filters, and HEPA filters should be stored in closed metal tanks or containers that are located in areas free from ignition sources or combusti,bles. These materials should be protected from exposure to fires in adjacent areas as well. Consideration should be given to requirements for removal of decay heat from entrained radioactive materials.

PROJECT CONFOR.1ANCE: C. POSITION (Cont ')

C.8.d. M=t-r's Containing Radioactivity Materials that collect and contain radioactivity such as spent ion exchange resins, charcoal filters, etc., will be stored in metal containers located in areas which do not expose safety-related systems or equipment. See FSAR Figure 1.2.2-2, t 98

I

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