ML18078A711

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Forwards Final NRC Positions Re FSAR Fire Protection Program Review.Requests Prompt Response.Confirms 790131 Meeting in Bethesda,Md
ML18078A711
Person / Time
Site: Salem 
Issue date: 01/19/1979
From: Parr O
Office of Nuclear Reactor Regulation
To: Mittl R
Public Service Enterprise Group
References
NUDOCS 7901290023
Download: ML18078A711 (22)


Text

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.. 9!I Docket No.

  • 50-311 JAN 19 1979 Mr. R. L. Mittl, General Manager Licensing and Environment Engineering and Construction Department Public Service Electric and Gas Company 80 Park Pl ace

Dear Mr. Mfttl:

Distribution Docket file NRC PDR Local PDR LWR #3 Fi'l e R. B.oyd D. Vassallo F. Wi 11 i ams

0. Parr A. Dromerick M. Rushbrook R. Mattson D. Ross J. Knight R. Tedesco R. DeYoung V. Moore R. Vollmer M. Ernst R. Denise R. Hart'field ELD IE (3)

(w/extra copies) bee:

NSIC ACRS (16)

TIC In order to maintain our review schedule, your resp6ns~ to o~r positions is required promptly.

As you know a meeting is scheduled with your representatives for January 31, 1979"1-n Bethesda, Maryland to discuss this*

matt~r. Please contact us if you desiri~ny discussion or clarifioation of the enclosed request.

Enclosure:

As stated ccs w/enclosure:

Sincerely, Original Sig!'led flY.

,Olan Parr

___.J Olan D. Parr, Chief Dight Water R~actors Branch No. 3 Division of Project Management See next page 790129000'3

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NllC FORM 318 (9*76) NRbJ 0240 U.M. GOVe:R~Ml!!NT PRINTING OFFICE: t F.170 - ZGS

  • 78~

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Mr. R. cc:

Richard Fryling, Jr., Esq.

Assistant General Counsel Public Service Electric & Gas Co~pany 80 Park Place Newark, New Jersey 07100 Mark Wetterhahn, Esq.

Cbnner, Moore & Caber 1747 Pennsylvania Avenue, N.W.

Suite l 050 Washington, D.C.

20006 Mr. Lei f J

  • Norr ho l 1n.

U. S. Nuclear Regulatory Cornnission Region I Drawer I Hancocks Bridge, New Jersey 08038

ENCLOSURE.

Auxiliary Systems Branch Fire Protection Positions

  • Salem Nuclear Generating Station, Units 1 & 2 Docket Nos. 50*272 and 50-311
1.

You state in yJur response to Question l(a) that the call-up of personnel is not necessary since off-site local fire company teams are

. available. It is our position a five-man fire brigade be available within the site. Verify that you follow the staff supplemental guidance contained in "Nuclear Plant Fire Protection Function Responsibilities, Administrative Controls, and Quality Assurance," dated June 14, 1977 for your administrative procedures, and fire brigade and te:*sting program.

2.

Your response to Question l(b) and 5(b) are unacceptable.

It is our position that portable radios be provided incorporating repeaters as necessary for the fire brigade and operations personnel required to achieve safe shutdown.

Preoperational testing should demonstrate that the frequencies used for portable radio communication will not affect the actuation of protective relays.

Fixed repeaters installed to permit use of portable radio communication units should be pro-tected from exposure fire damage.

3.

Your response to Question 2 is unacceptable.

Our positions for each part of Question 2 are as follows:

a.(l)

You respond by.saying that all doors to safety-related areas are certified by the manufacturer; however, the exact hourly rating of all these doors have not been given.

Verify that all

i.. ' fire doors used to protec't openings in walls containing safety-related equipment and/or conduit cable have a fire rating of at least 1!2 hrs.,

and that the rating is commensurate with the fire hazards analysis for the area assuming an exposure fire.

(2)

It is our position that cable and cable tray penetrations of fire barriers (both vertical and horizontal) be qualified according

  • to ASTM E-119 time-temperature curve including th~ hose stream test.

Provide the necessary fire test results to demonstrate the adequacy of your penetration seals. If documentation cannot be provided, it is our position that the seals be protected on both sides by covering it with an approved fire retardant material.

The adequacy of using such material should be demanstrated by suitable testing.

(3) It is our position that fire stops be installed between levels or in vertical cable chases.

Fire stops should be installed at the midheight of the vertical run if 20 ft. or more but less than 30 ft., or at 15 ft. intervals in vertical runs of 30 ft. or more.

Indi-vidual fire stop designs should prevent the propagation of a fire for a minimum period of 30 min. when tested for the largest number of cable routin',JS and maximum cable density.

a.(4) and Question 2b.

It is our position that where ventilation

. ducts penetrate 3 hr. fire rated construction that 3 hr. fire dampers be provided and installed per the manufacturer's instructions. Verify that you will comply with this position.

.. c.

You have not responded to our concern that the equipment hatches of any room in fire areas containing safety related equipment have a 3 hr. fite rating as tested under ASTM E-11*9.

It is our position that the hatches have a 3 hr. fire rating; Comply with this pssition.

4.

Your response to Question 3 is unsatisfactory. Verify that you follow the staff supplemental guidance contained in 11 Nuclear Plant Fire Protection Function Responsibilities Administrative Controls and Quality Assurance, 11 dated June 14, 1977, to prohibit any storage of combustible material near safety-related conduit/cable or equipment at any time.

5.

Your response to Question 4 is inadequate. It is our position that the thennal and acoustical glass fiber insulation manufactured by Owens Corning and the Cellic mineral tiles manufactured by Arm-strong have:

1. *A potential heat release of 3500 Btu/lb or less when tested under ASTM D-3286 or NFPA 259, and
2.

A flamespread rating of 50 or less when tested under ASTM E-84.

Verify that these materials meet this position or replace them wi'th acceptable materials~

... 6.

Your response to Question 5a is unacceptable.

It is our position that fixed 8-hr. capacity self-contained emergency lighting of the fluorescent or sealed beam type be provided according to Section 0.5 of Appendix A t6 BTP ASB 9.5-1.

7.

Your response to question 7 is unsatisfactory. It is our position that sufffcient hose stations be provided so that all portions of the plant including the areas listed below can be protected by stations having a maximum of 100 ft. of hose.

1.

Uppe~ electrical penetration area - elevation 100 ft.

2.

Emergency diesel day tank room.

Portable fire extinguishers are of limited value due to their short duration and limited capacity.

The intent of Appendix A guidelines that 11 Hose stations should be located outside entrances to normally unoccupied areas" was for small areas *where the hose s ta ti ons ma.v be blocked by the fire. For 1 arge areas, hose stations may be 1 ocated in unoccupied areas and offer better protection, since fire barrier doors do not have to be breached to draq the fire hose throuqh and thus the door cannot be closed.

The use of an outside hydrant for backup fire suppression for the Service Water Pump House is* satisfactory provided a hose house is pro-vided over the hydrant and the l~ in. hose is preconnected to the hydrant outlet. Also sufficient hose should also be provided_to enable a second hose stream from the hydrant, in the event the one hose stream cannot reach all the areas.

  • . 8.

Your response to Question 8 is unsatisfactory. It is our pas iti on that the existing manually activated total flooding C02 systems be modified for automatic operation in the following areas:

(1) 460V switchgear room, elevation 84 ft.

(2) 4160V switchgear room, elevation 64 ft.

(3)

Electrical penetration area, elevation 78 ft.

Each of the above rooms contains redundant safety related conduit/cable within 20 ft. of each other. It is our position that the design be modified to an automatic C02 system.

It is also our position where redundant equipment as well as conduit/cable necessary for safe shutdown.

are within 20 ft. of each other, that each train be protected by a half hour fire rated barrier, and automatic sprinklers be provi~ed to protect against an exposure fire, or that an alternate method of achiev-ing safe plant shutdown be established which is independent of the equip-ment in the fire area in accordance with the attached staff positions.

9.

Your response to 10.a(l) is unacceptable.

Both RHR pumps and associated equipment are located on elevation 45 ft. in separate rooms; however, these rooms are interconnected on elevation 55 ft. by ventila-tion ducts, ladder access to the 45 ft. elevation and equipment hatches.

The rooms are not separated from each other by 3 hr. fire rated con-struction. Also a fire on the lowest elevation would be extremely difficult to reach since access is only by a ladder.

!. It is our position that a wet pipe automatic sprinkler system be pro-vided to protect the redundant trains on the 45 1 elevation.

It is also our position that for any redundant conduit/cable trains located within 20 ft. of each other on the 55 1 elevation, automatic sprinklers and a half hour fire barrier be provided.

10.

Your response to question 10.a(2) is unacceptable.

a.

The three charging pumps are separated by a concrete wall; however, a corridor is common to all three pumps.

An expo?ure f1re can still damage redundant conduit/cable and equipment in the area.

Although you state you will install a 3 hr. wall separating each.

pump, a flammable liquid spill fire can still damage redundant equip-ment. It is our position that curbs should be provided to prevent such an occurrence from happening.

In addition a half hour fire barrier should be installed to separate the equipment from its counterparts including conduit and cable.

In addition, since the pumps are in a common room, automatic sprinklers should be installed over the pumps.

b.

The two motor driven auxiliary feedwater pumps are separated from the steam driven feedwater pump by a noncombustible barrier; however, a common corridor provides communication between the steam and electric pumps.

An exposure fire can still damage redundatn pieces of equipment.

.. It is our position that you pro~ide a half hour fire barrier to separate each piece of equipment from its counterpart including conduit and cablr:::, as well as provide automatic sprinklers for the area.

c.

The component cooling pumps haye a conman passageway connecting them.

It is our position that automatic sprinklers be provided* for this area for protection against an exposure fire.

11.a.

If redundant equipment located in the upper electrical penetration area are needed for safe shutdown on the plant and/or*the habitability of the control room complex, automatic sprinklers should be installed in addition to half hour rated fire barriers between the redundant pieces of equipment that are within 20 ft. of each other.

Redundant conduit and/or cable withih this distance in this area should alsd be protected in the same manner as above.

12.

Your respons~ to Question lla is inadequate. Steel floor plates between the control and control equipment rooms, and the relay room.

below are protected with silicone foam.

It is our position that an approved fire rated barrier separate the control room from the relay room below.

13.

Your response to Question llb is unsatisfactory. It is our position that all peripheral rooms within the control room complex (within the 3 hr. fi"re rated walls) be provided with automatic smoke detectors, as well as the walls and doors of these rooms be fire rated for l hr. (the walls should extend to the underside of'the floor above).

.. This applies to all rooms in which the operator does not have visual inside surveillance from the main console.

14.

Your response to 4uestion llc is uns?tisfactory. Since an exposure*fire can involve bcith redundant divisions in the control equip-ment rooms, it is our position that automatic Halon system be provided to. totally flood the room.

15.

Your response to Question 12a. is inadequate. Verify that any fire water used iii the relay room will not flood the relay room, and will be directed to flow to the floor drains in.the 250 yolt battery room or to the stairway at the east end of *the. corridor and down to the floor drains in the 4160V switchgear room.

l6r You~ response to Question 12f is inadequate.

Provide an automatic gas system in the relay room.

State that this system wi 11 be ins ta 11 ed prior to the first refueling of Unit 2.

17.

Your responses to questions 12g and 15b are unsatisfactory. It

  • is our position that 3-hr. automatic fire door/dampers be provided in all ventilat*ion d.ucts that penetrate the floors, walls and ceiling of the control room, relay room and switchgear rooms.

The fire area surrounding these rooms are required to have a 3~hr. fire rating to protect all openings, including ventilation openings.

The fire hazard analysis for these rooms did not consider that the fire may be on the other side of the wall which exposes the safety-related equipment and conduit/cable within the room itself.

.. 18.

Your response in Question 13 that with 150 ft. of hose you can reach both battery rooms is unsatisfactory. It is our position that

  • an additional hose station whereby 100.fi. of hose can reach any of the battery rooms.be provided.

The hoses should be equipped with appropriate nozzles to combat an electrical fire.

19.

Your response to Question 14 is unsatisfactory. It is our posi-tion as stated in Question 3 that fire damp~r/doors be provided in the ventilation penetrations in the 460 volt switchgear room.

20.

Your response to question 16a is unsatisfactory.

You only addressed an exposure fire in the laundry pump area of the auxiliary building.

You have not addressed the problem of all three power divi-sions of the emergency diesel generators penetrating the west wall of the 4160V switchgear room, elevation 64 ft.

An exposure fire may damage all three redundant divisions of the emergency diesel. It is our position that 3-hr. fire barriers be installed between the divisions.

21.

Your response to Question 16c is unsatisfactory. It is our position that a ~ hour fire barrier as well as an automatic sprinkler protection be provided for redundant conduit/catle in the vicinity of the remote shutdown panels.

22.

You state in your response to Question 16e that only one train from *each unit will be affected by an exposure fire in the corridor on elevation of 84 or 100 ft.

Each and every safety related train should have some means of protection. Provide a wet pipe automatic sprinkler system* for those areas of high cable concentration (six cable trays or more) to protect against an. exposure fire as required in Appendix A, Section 0.3.(c).

23.

In response to question 16f you state that the hydrogen supply lines to the volume control tank will be rerouted away from safety related equipment, conduit or cable to the maximum extent possible.

It is our position that the hydrogen lines be totally rerouted.

Provide an implementation schedule for this modification.

24.

Your response to Question 16g is unsatisfactory.

During the site visit,we noted that transient combustible material was exposing safety-related cable of both trains at the west end of the auxiliary equipment area, elevation 122 ft. It is our position that you provide automatic sprinklers for th.is area to protect the safety related systems and a 1/2 hr. fire rated barrier be provided around the safety related cable trays in the area where an exposure fire could involve more than one channel.

As stated in Appendix A, Section O.l(j), it is our position that 3 hr. fir~ door/dampers be provided for the ventilation ducts that penetrate the fire boundary of this are~ or provide an alternate method of shutdown that is independent of this area.

25.

Your response to question 18a is unsatisfactory. It is our position that rated fire door/dampers be provided in the ventilation penetrations

- for the-fo 11 owing areas:

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1.

Inlet air from the COz equipment room.

2.

Fuel oil transfer pump ro.om exhaust duct.

3.

Exhaust duct to outdoors.

26.

Your response to question 18d is unsatisfactory.

Total reliance is being placed on the automatic actuated flooding COz system to

. properly extinguish a flammable liquid fire. If the primary suppression system fails, the 3 hr. fire barriers will' be void since there are no fire door/dampers at the ventilation penetrations of this room.

Small hose lines are of limited value for a fire of this nature due to the limited quantity of water that they deliver. It is our position that rated fire door/dampers and one of the following be provided.

1.

An automatic open head deluge or open head spray nozzle system.

2.

An automatic closed head sprinkler.

3.

An automatic AFFF, the foam delivered by a sprinkler system or spray system.

27.

Your response to Que::tion 19a is unsatisfactory. If the boron injection tank is not kept at operating conditions, then this equip-ment may not be available when needed to bring the plant to a safe cold shutdown.

Since the controls for the heat tracing equipment for the boron injection and chemical and volume control systems are both located on the mezzanine l~vel of the radioactive waste storage area (drumming and bailing area), elevation 102 ft., it is our position as stated in Appendix A, Section D.l(a) (1), that a half hour fire barrier

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). as well as area automatic sprinklers be provided, or establish proce-dures to provide an alternate source of boron injection independent of this area.

28.

The response to Question 19b is unacceptable.

You state that as a result of the fire hazards analysis, the potential fire duration is negligible and you state tha~ Section 7, Chapter 4 of the NFPA Fire Prntection Handbook does not require fire dampers for barriers rated 1 hr. or less.

Fi re barriers for these areas are requi r.ed to be 3 hr. fire rated construction and are needed to properly protect the ventilation pene-trations. It is our position that automatic 3 hr. fire door/dampers be provided for all ventilation ducts that penetrate the fire rated barriers of the radwaste area (designated Drul1illing and Bailing Area) to separate that area from other safety related areas as recommended in Appendix A, Section F-14.

29.

You have not addressed the overhead cabling problem in your response to Question 21..

You have stated you will install a 3-hr.

fire rated barrier to separate redundant motor control centers. It is our position that a half hour.fire barrier be installed between redundant equipment as well as conduit and cable trays that are within 20 ft. of each other, and provide automatic sprinklers for the area as

' recommended in Appendix A, Section D.l(a) (1) and (2).

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30.

In Question 23 you state that two ionization detectors will be added in the piping penetration area, elevation 78 ft. It appears

  • from the scaled drawing that two detectors will not be enough.

Verify that the area covered per detector is within the listed spacing requirement bf the detector or install additional.detectors.

31.

The response to Question 25 is unsatisfactory. It is our posi-tion that automatic detection which alarms ar~ annunciates in the control room be provided throughout the new fuel area as well as.the spent fuel pool area.

32.

The response to Question 27 is unsatisfactory.

You state that the cable at the end as well as throughout the tunnel area, is arranged such that separation between redundant safety related chann1!lS and Units l and 2 cables exceed IEEE-384 separation requirements.

It is our position that if redundant trains are within 20 ft. of each other, you provide 1/2 hour fire barriers and an automatic sprinkler s,vstem.

33.

Your response to Question 29 is unacceptable. It is our position

-~hat for the back-draft type dampers installed between fire areas; that fire door/dampers need not be installed provided that the back-draft

~ype damper has a fire rating equivalent to the fire barrier.

34.

You state in your Fire Hazards Analysis how various safety-related

,.cable trays, conduit and equipment are separated by distance from its

  • redundant counterpart, and the criteria that were used to estab 1 i sh l

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barriers between these redundant trains.

In order to provide a defense-in-depth design, so that a fire will not prevent thP rPrfnrm~nr.P nf necessary safe plant shutdown functions, a detailed fire hazards analysis should ~e conducted for each plant area.

It is essential that the analysis include the effects of postulated fire involving pennanent and/

or transient combustibles (exposure fires) on systems, circuit cable trays or equipment required for safe plant cold shutdown.

The fire hazards analysis should ide:-:tify all the redundant mechanical and electrical systems and components necessary for safe cold shutdown which are separated only by distance (no fire barriers and with redun-dant trains 20 ft~ or less from each other).

Redundant trains within 20 ft. of each other, as a minimum, will be required to be protected by a half hour fire rated barrier as well as area automatic sprinklers.

This does not mean that in some instances, such as cable spreading room and relay room, 460V and 4160V switchgear room, redundant trains separated by more than 20 ft. will not require additional protection.

The fire hazards analysis need to demonstrate that, assuming failure of the primary suppression system, a fire on installed or transient combustibles will not result in the loss of capability to achieve safe cold shut-down.

Where this cannot be demonstrated, an alternate'means of assuming safe plant shutdown (cold shutdown) should be provided.

Demonstrate that:

.,."' 1.

Safe shutdown from the main control room where a fire disables any safe shutdown equipment including conduit/cable trays controlled from remote locations.

2.

Saf~ shutdown from remote locations when the main control room is uninhabitable due to a fire or when fire disables safe shut-down equipment of. the re 1 ay room or 460V switchgear room or 4 l 60V swi.tchgea r rorJm.

Remote location need only be provided for the essential instrumentation, controls and equipment necessary to bring the plant to a hot standby condition.

Fire damage to systems necessary to achieve and maintain cold shutdown should be limited so that repairs can be made and cold shutdown condition achieved within 72 hrs.

A detailed breakdown of staff requirements (enclosure 2) is enclosed for:

l. Minimum safe shutdown systems when one division of all safety systems is not available.
2.

Minimum fire protection when dedicated or alternate shutdown systems are provided.

35.

Safe S.hutdown Capability: Supplement Item 34**above as follows:

(1) It is assumed that the motive and/or control power to systems and components required for achieving hot and cold shutdown would be lost as

- a result of a postulated fire. Thus, for each fire hazards analysis to be performed for a plant area, describe the design provisions and/or

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the procedures to be implemented that will assure that motive and control power supplies affected by the fire are restored to those systems and components that are essential for achieving hot and colr shutdown.

(2)

Consistent with our position documented in Sectic11 8.3.2(3) of the Power Systems Supplem,:intal Safety Evaluation Report Number 3 regarding the interconnections between redundant divisions in the 125 volt direct current e!mergency power system and in the 28 volt direct current vital.

system, we require that the applicant examine each intercon~ection within and between these systems and either demonstrate the capability or the design to withstand a fire event without the loss of capability to achieve hot and cold shutdm-m, or modify the design accordingly.

(3) Consistent with our position documented in Section 8.3.2(4) of the Power Systems Supple~mental Safety Evaluation Report Number 3 regarding the interconnection of the 125 volt di re ct current emergency sys terns between units, we require that the applicant either demonstrate the capability of the interconnection design to withstand a fire event with-out the 1 oss of capability to a chi eve hot and cold shutdown in each unit, er modify the design accordingly.

(4)

For each fire hazards analysis to be perfonned of a plant area, identify.those valves which are necessary for hot and cold shutdown and are not required to be acted upon because it has been assumed that these valves will remain in the same position as they are following a fire event. It is our concern that the fire event may cause the sµurious operation of these valves to a* position which is different from that required to accomplish hot or cold shutdown.

Describe in each ca.:;e the design provisions and procedures to be implemented that will assure that the spurious movement of these valves would ~ot result in the loss of capability to achieve hot or cold shu~down.

36.

Communication Systems:

Identify the sources of electric pmver for each. type of coITTTiunication system and confirm that a single electrical failure would not result in the loss of all communication systems.

37.

Fire Detection and Suppression Systems:

Identify the electrical power sources to the fire detection systems and fire ~uppression systems and explain why.the consequences of losing the fire detection systems or the fire suppression systems as* a result of a single failure are acceptable. Also, identify the criteria governing the design of the power interfaces between the Class lE emergency buses and the fire detection and suppression systems. Moreover, your response to request for infonnation 6 did not incl~de the infonnation verifying that the fire alann system meets the requirements of Class A systems as defined in NFPA 72D and Class I circuits as stated in the National.Electrical Code.

38.

Diesel Driven Fire Pump Control Power:

Identify the sources of alternating and direct current control power for each diesel driven fire pump and confinn that a single electrical failure in the control

_ power sources or circuits would not result in the loss of capability to start at least.one.diesel driven fire pump.

39.

Safety-Related

Enclosures:

Identify those enclosures (other than rooms) that contain safety-related cables from two or more divisions.

It is our position that these cabinets or consoles which contain redundant safety-related circuits should be orovided with smoke detectors.

As an alternate, such cabinets may be vented with louvers*

or other openings venting directly to ceiling detectors which are located directly above the cabinets.

If this alternate is used, tests should be conducted to assure that such an arrangement will orovide timely detector response similar to such response if the detectors were located in the cabinets.

Indicate which oos1tion you intend to

_implement.

Access for rapid application of manual extinguishers should be provided.

40" Reactor Coolant Pressure Boundary Integrity: *a is our concern that sourious valve operation caused by fire may affect the integrity of the reactor coolant pressure boundary.

We require that the anoli-cant examine each interface at the reactor coolant pressure boundary and either demonstrate the caoabilit,v of the desi~n to withstand spurious valve operation caused by fire without the loss of reactor coolant pressure boundary integrity or modify the design to assure that integr~ty.

41.

Flame Testing of Cable Splice Covers:

Office of Inspection and Enforcement Inspection Report Number 50-311/78-15, dated June 21, 1978, indicates that insufficient data was available to confirm the acceptabil-

- ity of the flame testing of splice covers.

Provide this add1tional infonnation.

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Staff Reauire::ients 1.0 Minimum safe shutdown systems when one division of all safety systems is not available.

1.1 Following any fire, the plant can be brought to hot shutdown.

. _conditions using equipment and systems thatare free of fire dama;e.

1.2 The plant.should be capable of maintaining hot s~utdown conditions for an extended time period significantly longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

1.3 Fire damage to systems necessary to achieve and maintain cold shutdown conditions should be limited so that repairs can.

be made and cold shutdown conditions achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

1.4 Repair pro~edures for cold s~utdown systems should be prepared riow and material needed for srrch repairs should be on the site.

1.5 The hot shutdown condition must be achievable with power from the offsite power system, and upon its loss, with power from the onsite power system.

A dedicated power suppJy may be substituted for the onsite power system.'

1.6 The power needed to achieve the cold shutdown condition* may be obtained from any one of the offsite power, onsite powe*r, and dedicated power system.

  • 1.7 When these minimum systems are provided their adequacy shall be verified by a thorough evaluation of:

2.0

a.

Systems required for hot shutdown;

b.

Systems* required for cold shutdown;

c.

Fi re* damage to power. di stri bu ti on systems; and

d.

Interactions caused by fire damage to power and water supply systems and to supporting systems, i.e., component cooling water supply.

Minimum fire protection when de*dicated or alternate shutdown systems are provided.

2.1 The fire protection systems in areas (such as cable spreading rooms) that contain cables for a large number of systems should consist of:

a.

Fi re detection sys ten;

b.

Hose stations; and

c.

Fixed manual suppression system (gas or water)

NOTE:

Consideration to preventing fire propagation via covered trays, fire retardant coating, barriers or blankets on a case-by-case basis.

. J..-.

.. - 2.2 Where access.is difficult or impossible automatic systems should be provided.

2.3 Where modifications will not be implemented for an extended period, interim protection measures should be required to compensate for the lack of protection.

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