ML19270E878

Forwards Responses to NRC Position PF-40 Thru PF-49 Re Fire Protection Review in Response to NRC 780814 Ltr

ML19270E878
Person / Time
Site:	Point Beach
Issue date:	12/29/1978
From:	Burstein S WISCONSIN ELECTRIC POWER CO.
To:	Harold Denton, Schwencer A Office of Nuclear Reactor Regulation
References
NUDOCS 7901030070
Download: ML19270E878 (73)

Text

we WISCONSIN Elecinc mia comur 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE, WI 53201 December 29, 1978 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. flUCLEAR REGULATORY COMiIISSI0ft Washington, D. C. 20555

's Attention: Mr. A. Schwencer, Chief Operating Reactors Branch #1 Gentlemen:

DOCKET NOS. 50-266 A;;D 50-301 P0lflT DEACH NUCLEAR PLAf4T UillTS 1 Af10 2 FIRE PROTECT 10:1 REVIEW With this letter we are submitting our completed response to itRC Staff positions PF-40 through PF-49 which we received with your letter dated August 14, 1978. This submittal fulfills the co:Jaitment stated in our September 22, 1978 letter to submit this information by December 31, 1978.

Twenty copies are enclosed for your review purposes.

Very truly yours, o o ag ~

Sol Burstein Exe utive Vice President Enclosures 790103(D70

t s

POINT BEACH NUCLEAR PLANT FIRE PROTECTION REVIEW APPENDIX B RESPONSE TO POSITIONS SUBMITTAL NO. 4 PF-40 Two-Hour Fire Rated Cable Penetration Seais PF-41 Smoke Detection System Tests PF-42 Cable Spreading Room: Fire Protection PF-43 Safe Shutdown Capability PF-44 Portable Smoke Venting Capability PF-45 Reactor Coolant Pump 011 Collection System PF-46 Circulating Water Pumphouse Fire Protection PF-47 Control Room Shutdown Requirements PF-48 Fire Brigade Practice Sessions PF-49 Fire Brigade Size

s STAFF POSITION POINT BEACH NUCLEAR PLANT PF-40 Two-Hour Fire Rated Cable Penetration Seals Staff Concern:

Cable tray penetrations at Point Beach are sealed or will be sealed with various sealing configurations that are purported by the licensee to have two and three hour fire ratings. By staff position PF-32, the licensee was requested to provide test results to verify these ratings. In a letter dated March 15, 1978, the licensee agreed to provide test data verifying the ratings for the three-hove seals. Verification testing for existing and future two-hour seal configurations has not been addressed by the licensee.

Staff Position:

The licensee should provide test results verifying the rating for those seals that are in place or that will be installed for which the licensee is crediting a two-hour fire resistance.

RESPONSE

The Licensee's March 15, 1978 response to staff position PF-32 described four potential methods to upgrade fire barrier penetration seals. A fire barrier penetration seal survey has been performed and penetration accessibility and configurations have been evaluated. We have concluded that silicone foam penetration seals will be the most practical installation. We have further determined that there is no advantage to install both approved two-hour and three-hour rated seals. Therefore all safety related fire barrier cable pene-tration seals at Point Beach Nuclear Plant will be upgraded to a three-hour rating. Tested and approved seal designs will be used for which appropriate test results can be furnished. Because of differing penetration configurations, the applicable seal designs will be determined at the time of installation.

Penetration seal designs and accompanying test results will be available when installation is completed.

PF40-1

STAFF POSITION POINT BEACH NUCLEAR PLANT PF-41 Smoke Detection System Tests Staff Concern:

The type and location of ionization smoke detectors may not provide prompt detection of fires in areas where they are used. Ventilation air flow patterns or detector sensitivity may prevent effective fire detection.

Staff Position:

In situ tests should be conducted with a suitable smoke generation device to verify that the products of combustion from a fire would be promptly detected by installed or proposed smoke detectors and that ventilation air flcw patterns in the area do not significantly reduce or prevent detection response. Bench tests should be conducted to verify that smoke detectors will provide prompt response and have adequate sensitivity to the prcducts of combustion for the combustibles in the area where smoke detectors are installed. If any fire detection systems are found to be inadequate, appropriate modifications should be made to provide adequate detection system performance.

RESPONSE

The Licensee will provide a fire detection system using Underwriters' Laboratories approved fire detectors. Bench tests of detectors are performed as part of manufacturers' quality assurance programs in order to obtain this approval.

Where total room detector coverage is required, fire detectors will be installed with spacing equal to or less than NFPA 720 recommendations.

The air handling requirements of the Point Beach ventilation systems are sufficient to assere turbulent air flow thereby enhancing the dispersion of products of combustion. It will be specified that fire detectors not be mounted in the direct flow path of supply air outlets.

Operability of fire detectors and the detection system will be verified in accord-ance with the Licensce's quality assurance program at the time of installation.

This verification will include functional testing using demonstrated approved techniques.

The Licensee does not propose to conduct in situ tests for the following reasons.

1. Fire detectors which will be installed to monitor locations of vital safety related equipment, will be installed near the equipment to i be protected and their location would not be determined by in situ  !

testing. '

i.

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2. Fire detectors which are installed to provide total room monitoring will be spaced equal to or closer than NFPA 720 recommendations.

in situ testing could only duplicate a portion of the experience which NFPA used to develop this accepted standard.

3. A fire in an area of high combustible loading will enit a heavy concentration of products of combustion. In situ testing could not simulate such an emission and would be useless.

4. In areas of light combustible loading, the exact location of a potential fire cannot be specified. If the products of combustion emission could be duplicated by insitu testing, a large number of tests would be required. Total area smoke ficoding is impractical in an operating plant and probably would not duplicate the emission density of a realistic potential fire. In situ testing would be inconclusive.

5. The capability of smoke generating devices to accurately reproduce the characteristics of smoke generated by open flame has not been demonstrated. Open flame smoke generation is not permitted at Point Beach Nuclear Plant. Should a smoke generating device which accurately reproduces the characteristics of flame generated smoke be tested and approved by NFPA, we will consider its use.

PF41-2

STAFF POSITI0t1 P0ItiT BEACH tiUCLEAR PLAT 1T PF-42 Cable Spreading Room: Fire Protection Staff Concern:

The Point Beach cable spreading room contains redundant safety-related cable trays and motor control centers for both reactor units. The control cables for redundant safe hot and cold shutdown equipment are routed through the cable spreading room; however, the control of safe hot shutdown equipment can be transferred to remote shutdown panels located outside the room. Although the control of safe cold shutdown equipment cannot be decoupled from the cable spreading room, the licensee has stated that these systems would be placed in service manually in the event of fire damage to redundant control cables. The only power cables in the room for shutdown equipment are those short sections of cable in conduit which penetrate the floor of the room and enter the bottom of the motor control centers. It can be inferred from the discussion in the licensee's fire hazard analysis that the power cables and motor control centers are required for both safe hot shutdown and safe cold shutdown.

The cable trays and their supports in the cable spreading room are of total steel construction. All cable trays are solid bottom trays with screwed-on covers.

The cables are covered with a full-width 1/2-inch thick layer of Kaowool blanket.

Where nonsafety-related cables run between redundant safety-related channels, fire stops are (or will be) provided by coating the interposing cable with a fire retardant coating.

The licensee proposes the following modifications to the cable spreading room:

1. A manually-actuated spray system for the trays above the safety-related motor control centers will be added.

2. Spray shields will be installed above the MCC's and curbing installed around them to protect against water damage.

3. The two adjacent hose reel stations will be provided with' low velocity fog nozzles with extension pieces to facilitate manual suppression of cable fires.

4. All cable tray covers will be removed.

5. A smoke purge fan will be added to the cable spreading room ventilation exhaust system.

The staff is concerned that the proposed cable spreading room fire protection system does not assure that manual actions can be taken to suppress a fire before damage is incurred to redundant cables and motor control centers required for safe hot and cold shutdown. The specific concerns with the proposed fire protection system are as follows: -

PF42-1

1. An exposure fire may damage redundant motor control centers required for safe hot and cold shutdown prior to manual actuation of the proposed manual spioy system.

2. Shielding of the motor control centers against the effects of the water spray to ensure operability of required components not involved in a fire may be difficult to achieve in practice.

3. Removal of the cable tray covers may actually degrade the fire protection for the cable trays. The covered trays utilizing Kaowool blankets have an inherent fire retardancy which may be adequate to cause self-extinguishment of a cable tray fire. However, the screwed-on covers and tight tray spacing increase the difficulty of manually suppressing a cable fire which does not self-extinguish.

4. An exposure fire in the cable spreading room could damage redundant safety-relhted cables especially if such cables are in the lower trays of adjacent stacks.

5. Details of the smoke exhaust path and proposed smoke purge fan have not been provided.

Staff Positions:

A. The licensee should reevaluate the proposal to remove the cable tray covers in the cable spreading room and demonstrate that removal of the covers improves the overall fire protection for the cable spreading room. If this cannot be demonstrated, the licensee should not remove the covers. Test data should be provided to support whichever arrangement the licensee decides to accept (i.e., to remove the covers or leave them on).

B. If the use of covered trays is continued, provide test data which demonstrates that cable fires completely self-extinguish or provide quick release fasteners for the covers to facilitate manual suppression of cable fires.

Note: if the present 1/2 inch thick Kaowool blanket does not provide sufficient retardancy for self-extinguishment of cable fires, the licensee should consider filling the entire void space above the cables with Kaowool, particularly in vertical cable tray runs.

C. For vertical cable tray runs, means should be provided to assure that the Kaowool will remain in place during a fire to protect tha cables.

D. Test data should be provided which demonstrates the effectiveness of spray shields to ensure operability of the motor control centers.

E. The licensee should demonstrate that the proposed fire protection system, as modified by the positions stated above, resolves the staff concerns regarding the overall capability of the system. The licensee should demonstrate that manual action can be taken to suppress any exposure fire in the cable spreading room in time to prevent damage to redundant safe hot and cold shutdown cable and equipment such that safe hot shutdown can be achieved immediately and cold shutdown can be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The availability of offsite power may be assured. for cold shutdown operations.

PF42-2

F. If safe shutdown, as described in E above, cannot be assured with the pro-posed fire protection system, additional fire protection measures should be proposed to provide such assurance. Alternatively, equipment should be provided outside the cable spreading room to perform the shutdown functions which could be disabled by a cabic spreading room fire.

G. The proposed smoke exhaust system should exhaust products of combustion outside the building so as not to inadvertently actuate fire detectors in other plant areas or expose other safety-related areas to smoke damage.

The exhaust fan motor cabling and control should be located outside the cable spreading room.

RESPONSE

4_2- A, The Licensee has reevaluated the proposal to remove the cable tray covers in the cable spreading room. Fire safety objectives include fire prevention and fire management by containment and suppression. The retention of covered cable trays will provide improved fire prevention by eliminating the potential accumulation of foreign combustibles and cable exposure to potential ignition sources. The retention of covers on the solid bottom cable trays will provide additional containment of a potential fire within a single tray. This conclusion is supported by SAND 78-1456 "A Preliminary Repc*t on Fire Protection Research Program Fire Barriers and Fire Retardant Coatings Tests'. A two tray test, No. 40, conducted on cabling and tray construction similar to the Point Beach installation demon-strated that a cable tray fire would not propagate to the tray above. Forcible entry tools will be available within the cable spreading room to facilitate cable tray fire suppression. On this basir , we have determined that the best overall fire protection for the cable spreading room is enhanced by retaining the cable tray covers.

42-B In SAND 78-1456, the report for a two tray test, No. 40, which was conducted using solid bottom trays with vented covers and without wool blanket demonstrated that a cable fire would self extinguish. Two tray test No. 34, which was conducted using solid bottom trays without covers and without wool blanket, also demonstrated that a cable fire would self extinguish. A comparison of these tests indicates that tray covers appear to retard fire propagation within the tray. This characteristic and the availability of forcible entry tools in the cable spreading room will facilitate manual response and suppression capability. Two tray test No. 28, which was conducted using ladder trays with 1" ceramic wool blanket and no covers, also demonstrated that a cable fire would self extinguish.

However, 75-80% of the cable within the tray was damaged. On this basis, we believe that, while the wool blanket may have insulating benefit and retard fire propagation within tne tray, increasing the blanket thickness would not add significant assurance that a cable fire will self extinguish. All of the referenced tests were conducted on trays containing PVC cable similar to the Point Beach Nuclear Plant installation.

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PF42-3

42-C The Licensee has removed the covers from three vertical cable trays and inspected the Kaowool blanket position. The blanket was found to be in its installed position in all three trays. On this basis, we believe that the friction fit of the blanket within the trays and the stabilizing support of the tray covers are adequate to keep it in its installed position.

42-D The Licensee has inspected the 480V switchgear cabinets. We have found that these cabinets do not have a continuous watertight top surface. The cabinets are also provided with ventilation openings in the front and rear panels. Spray shields will be installed on top of the switchgear cabinets. These shields will have to be custom fitted to the cabinets in order to accommodate operating and maintenance requi rements. Spray deflectors will be provided on the front and rear panel openings in accordance with the switchgear manufacturer's recommendations. We do not consider it to be feasible to provide test data for the following reasons.

1. The actual spray shield configuration will be determined at the time it is fitted to and installed on the cabinets.

2. The sprinkler pattern will be independently designed by the sprinkler installer.

3. We do not have specific manufacturer's guidance which defines the moisture tightness requirements for the switchgear cabinets.

4. It is not practical to conduct an actual sprinkler test in an operating power plant.

42-E, F Cable tray tests reported in SAND 78-1456 have demonstrated that a cable fire in a totally enclosed tray, similar to those installed in the Point Beach cable spreadinq room, will self extinguish and will not propagate outside of the involved tray. Therefore, a potential cable fire would be restricted to a single safety-related cable tra) Therefore, redundant cabling will not be damaged. In response to staff position PF-49, an analysis is provided which demonstrates that the Point Beach Nuclear Plant fire brigade is capable of accomplishing all functions necessary in the event of a fire in the cable spreading room. This analysis also demonstrates that redundant safe shutdown cabling will not be affected by an exposure fire.

The electrical loads necessary for hot shutdown may have their control cabling totally decoupled from the cable spreading room by shif ting control to one of the remote shutdown panels. The power cabling for these loads does not traverse the cable spreading room, making instead a short penetration through the bottom of the load center. The power cables are enclosed in conduit. The power cabling for the loads necessary for cold shutdown is routed in an identical manner. The control cabling, however, cannot be totally decoupled from the cable spreading room. Reviewing the routing of these control cables indicates that in no case is redundant cabling routed in trays which are cross-connected by nonsafety-related cabling. Considering the absence of potential combustible pathways between these PF42-4

trays and the referenced SAND 78-1456 cable tray test results, a postulated fire would not be expectcJ to affect redundant control cabling for cold shutdown loads.

Existing fire suppression capabilities will be upgraded to further limit the potential consequences of a postulated fire. Additional fire detectors will be installed in the cable spreading room to provide early fire detection and to serve as an input into a pre-action sprinkler system. The pre-action sprinkler system will be extended to cover all open floor areas in order to provide maximum fire exposure protection for each safeguards load center (IB03, 1804, 2003, 2B04).

As proposed in the Fire Protection Review, an additional cable spreading room entrance door will be installed (Section 6.1.8). A smoke venting system will be installed (Section 6.1.1). Two 1-1/2 inch hose stations fitted with low velocity fog nozzles will be installed (Section 6.1.3). In addition, two 1-inch hose stations fitted with ball shutoff variable tog nozzles will be installed. These measures will significantly enhance manual fire suppression capability.

42-G The proposed smoke exhaust system will be designed and installed to exhaust prodacts of combustion outside of the turbine building in a location remote from ventilation system intakes. The exhaust fan motor cabling and control will be located outside of the cable spreading room.

PF42-5

STAFF POSITION POINT BEACH NUCLEAR PLANT PF-43 Safe Shutdown Capability Staff Concern:

The licensee has proposed to cover or coat exposed cables in the containment buildings with a fire retardant material. The licensee has also proposed to cover cables in open ladder trays with Kaowool in the auxiliary building, pipeways, auxiliary feedwater pump room, switchgear room and containment facades. Cables and equipment required for safe hot shutdown are located in the auxiliary feed-water pump room, switchgear room, containment and sections of the auxiliary building. Safety-related cables are located in all of these areas. In response to staff position PF-21, the licensee agreed to provide test data to verify the effectiveness of Kaowool to retard the propagation of fire from tray to tray and to limit fire damage within an affected tray.

The licensee has also proposed the use of Marinite board as a fire barrier between redundant divisions of safe hot shutdown cable on the 8 feet elevation of the auxiliary building and in the auxiliary feedwater pump area. liarinite barriers have also been proposed to protect redundant safe hot shutdown cables from the effects of a fire at the safety injection pumps. However, no data has been presented to verify the capability of such a barrier to prevent loss of redundant cables from a cable or exposure fire. The licensee's evaluations to-date have primarily dealt with the cables and equipment required for safe hot shutdown.

Although liarinite barriers will only be used between redundant safe hot shutdown cables, Kaowool will be used on all safety-related and some nonsafety-related trays in the areas discussed above. The use of Kaowool on exposed cable: will provide some protection for any redundant safe cold shutdown cables in these areas.

However, the ability to reach cold shutdown after a fire in certain areas of the plant has not been verified.

Staff Position:

A. The licensee should demonstrate that the use of Kaowool, cable coatings (if used) and Marinite board barriers will retard the spread of cable fires and provide protection against exposure fires such that a fire in the auxiliary building, containments, switchgear rooms and auxiliary feedwater pump area can be detected and manuelly suppressed before redundant divisions of cables required for safe hot shutdown are damaged.

B. The licensee should verify that safe cold shutdown can be attained within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of a fire in the auxiliary building, containments, containment facades, pipeways, auxiliary feedwater pump area and switchgear room independent of cable damage from fire in these creas. The availability of offsite power may be assumed for this analysis. As an alternate, demonstrate that a fire could be detected and manually suppressed before redundant safe cold shutdown cables and equipment in these areas are damaged.

PF43-1

RESPONSE

43-A Results of full scale two tray tests reported in SAND 78-1456 demonstrate that ceramic wool blankets, cable coatings or marinite barriers will prevent propa-gation of a fire outside of the involved tray. Redundant divisions of cables required for safe hot shutdown will not be damaged by a fire which is confined to a single tray. Test number 28 was conducted using open ladder trays, PVC This tray configuration and cables and covered with a ceramic wool blanket.The test showed no fire propagation cable material is installed at Point Beach.

outside of the involved tray and a cable involvement rate of 2.4 inches per minute. Test number 48 was conducted using open ladder trays, PVC cables, and a 1-inch solid barrier between trays. The test showed no fire propagation outside of the involved tray and a cable involvement rate of 3.2 inches per minute. This test demonstrated that, while barrier extension 6 inches beyond the side of the tray was sufficient to prohibit propagation, less than full Therefore ,

length separation could allow cable damage in the tray above.

barriers between crossing cable trays will be installed with a 6-inch minimum extension beyond the sides of both trays. Comparison of the burning rates of these two tests indicates that a ceramic wool blanket will retard the burning rate approximately 25 percent. This will enhance manual response time and extinguishment capability.

_4 3- B_

1.0 Introduction 1.1 Each unit at Point Beach has incorporated in its basic design the cold shut-down equipment listed in Table 43-1. For simplicity, only Unit i equipment is listed. Unit 2 cold shutdown equipment list would be identical except for the source of power.

1.2 In this discussion, Unit 1 is treated as the affected unit and Unit 2 as the unaffected unit. There would be no difference if the roles were reversed, and all conclusions reached would be applicable tt either unit.

1.3 It is assumed that a fire emergency has forced Unit 1 offline and the unit is being maintained in a hot shutdown condition. The fire is either out or under control and Unit 1 is to be placed in a cold shutdown condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of initial shutdown. The availability of off-site AC power is assumed prior to cooling down. The Technicali.e.,

Specifications definition of a shutdown margin of at cold shutdown is referenced and employed, least 1% AK/K and a reactor coolant temperature <200"F.

1.4 With the fire extinguished and the unit in a safe hot shutdown condition,Suspect the extent of damage to cold shutdown equipment can be evaluated.

power cabling to key pumps (residual heat removal, component cooling water) can be continuity and ground tested. Local cable repairs or the laying Power breakers can be repaired or of new power cable can be accomplished.

replaced as a unit. Pumps can then be load tested before their actual use or designation as standby equipment. Instrumentation channels can be s

PF43-2

checked against other instruments that measure the same parameter.

Functional tests can be run on key cold shutdown instrumentation. A list can be compiled of functional local and remote instrumentation. Portable readout instrumentation can be connected locally to aid or serve in lieu of normal instrumentation. Motor and air-operated valves in cold shutdown systems can be cycled for an operability check. Inoperable motor-operated valves can be handwheel operated. Inoperable air-operated valves can be either handwheel operated, placed in a failed position, or gagged in any position and flow controlled with a local manual valve. With the above information available, a realistic manpower requirement can be made.

Additional operations personnel can be scheduled for local valve manipula-tion, parameter readout and local control of cold shutdown equipment.

Electrical group personnel can be scheduled for local power breaker control as required.

2.0 Cooldown Operations 2.1 The first phase of the cooldown employs the hot shutdown equipment until the reactor coolant temperature is approximately 325 F. Of this group, the steam driven and electric motor driven auxiliary feedwater pumps, atmospheric steam dump and the charging and letdown system have local and remote operating stations. Sufficient local or remote operating controls will be available in a fire emergency.

2.1.1 If the reactor coolant system has not previously been borated to a cold shutdown concentration, it should bc accomplished prior to the commencement of cooldown as additional personnel are available. Local controls are provided for the charging pumps, letdown orifices, and two groups of pressurizer backup heaters.

Local controls are also provided for the boric acid transfer pumps. It is mechanically possible to line up any one of the three boric acid storage tanks to any of the four (two par unit) boric acid transfer pumps and to the charging pump suction header of either unit. In addition, the boric acid tank recirculation pumps have sufficient discharge head and volume to serve in lieu of a boric acid transfer pump if required. As shown in Tables 43-1 and 43-2, sufficient diversity of power supply exists among the boric acid pumps to assure at least one operable pump for any credible fire event. The boric acid to blender isolation valve is a fail open air operated valve and the blender itself may be manually bypassed to the charging pump suction. Local boric acid tank level indication could be provided by instrumentation personnel.

2.1.2 A charging pump is required for the above path of boric acid injection. Two of the three charging pumps per unit are powered from the same 480 volt safeguards load center. The power cabling for these two pumps is routed in the same cable tray up to the pump cubicle. However, the remaining pump is powered from a redundant 480 volt safeguards load center and its power cabling is run in a separate cable tray per the separation criteria as defined in Appendix "A" of the Point Beach Nuclear Plant Fire Protection Review.

Thus, at least one charging pump will be available in local or remote control for boric acid injection and primary makeup during the cooldown.

PF43-3

2.1.3 Three separate injection paths from the charging pumps to the reactor coolant system are available. All three piping systems exit the auxiliary building via the No.1 pipeway. The normal charging line has an air-operated (fail open) flow control valve with manual bypass at the entrance to the No. I pipeway. No other motor or air-operated valves for the charging system are located in the No. 1 pipeway. Thus a pipeway fire would not be expected to affect any of the 2500 psi design paths.

2.1.4 The containment side of the above injection paths contains a normally open motor-operated valve in the normal charging line, a normally closed (fail close) air-operated valve in the auxiliary charging line, and no remote operated valves in the seal injection lines. It is expected that the motor operated valve in the normal charging line would fail as is, i.e. , valve open. This valve can also be handwheel operated. The auxiliary charging line air operated valve has no local valve operated features but could be pryed and blocked open if required.

2.1.5 An alternate means of high pressure boric acid injection and primary system makeup is available by aligning one of two 4160 volt high head safety injection pumps to take suction on either a boric acid storage tank or a refueling water storage tank and injecting directly into a reactor coolant loop. All motor-operated valves in this system that would .m.c t he aligned to establish a flow path are also capable of being har.dwheel operated.

2.2 The second phase of cooldown involves the residual heat removal, component cooling water, and service water systems to cool down the primary system from approximately 325 F to <200 F. The core decay heat load is significantly reduced with time and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after shutdown is approximately 10% of the initial decay heat load.

2.2.1 The shared service water system is in continuous service and utilizes a supply ring header concept within the plant safety-related areas. Six service water pumps powered from four 480 volt safeguards load centers are provided. Two pumps are normally in service and a total of three pumps are required to remove the decay heat in one unit and the operating heat load in the other unit.

Normally open motor-operated sectionalizing valves are provided on the supply ring header. They would be expected to fail as is and in any case, they can be handwheel operated. Local and remote pump operating stations are provided. Thus it is highly unlikely that any single fire emergency can reduce the service water system heat removal capability below that required to remove core decay heat.

2.2.2 The component cooling system is a closed loop chromated water cooling system utilizing a heat exchanger and two pumps per unit.

One of the two pumps is a standby pump. A third head exchanger is provided and is shared by the separate component cooling water system of each unit. Figure 43-1 shows the relationship of the PF43-4

residual heat removal system of one unit and both component cooling water systems. All valving of service water and component cooling water at the component cooling heat exchangers is accomplished with manual valves. Component cooling water is the cooling medium for the redundant residual heat removal system heat exchangers and is supplied through normally closed motor-operated valves. These valves also have handwheel operators.

2.2.3 The ccmponent cooling water pumps for each unit can be manually cross connected at the pumps to provide service for the opposite unit. In an emergency any one of the four component cooling water pumps can be lined up to provide services for either unit or both units. Each pump is powered from a separate safeguards load center and has an automatic start feature actuated by low system pressure.

Each pump can be started from the control room via a control switch or manually at the load center.

2.2.4 Component cooling water is supplied to each residual heat removal heat exchanger by opening a motor-operated valve from the control room. These valves can be handwheel operated.

2.2.5 The residual heat removal system suction piping is the only portion of the system that is conmon to both trains of residual heat removal system. The system is normally split into two separate trains when lined u) as the low head safety injection system. A manual valve lineup is required to align the system to a cooldown mode of operation.

2.2.6 All motor-operated valves are capable of handwheel operation. The loop suction and discharge valves are located in the containment and are accessible. The air-operated flow control valves in each train are fail open type and flow control can be accomplished with a manual valve. The heat exchanger bypass air-operated valve is a fail closed type.

2.2.7 Either residual heat removal pump can be lined up to the redundant train for cooldown purposes as shown in Figure 43-1. Each pump is powered from a separate safeguards load center and power cabling separation is maintained by caole tray and rigid conduit layout in accordance with the separation criteria of Appendix "A" in the Point Beach fluclear Plant Fire Protection Review. Each pump and motor is housed in a separate concrete structure. Each pump is normally controlled from the control room. Local manual breaker closure is possible at the load center.

2.3 The following equipment may be utilized in the sequence of cooldown operations described above.

1. One steam driven turbine and two electric motor driven auxiliary feed-water pumps are located on elevation 8'-0" of the control building.

The electric motors are provided with redundant safeguards power supplies. One pump is adequate to achieve safe hot shutdown.

PF43-5

2. Two air-operated atmospheric steam dump valves are located on elevation 85'-0" of the containment facade. The;e valves can be handwheel operated.

3. The letdown system includes the regenerative heat exchanger, piping and motor operated and air operated valves in the containment and the non-regenerative heat exchanger, demineralizers, piping and air operated valves in the auxiliary building.

4. Three boric acid storage tanks are located on elevation 46'-0" of the auxiliary building, One tank is adequate for cooldown.

5. Four boric acid transfer pumps and two boric acid recirculation pumps are located on elevation 26'- 0" of the auxiliary building. Pump motors are powered from five separate power supplies. One pump is adequate for cooldown.

6. Three charging pumps are located in separate rooms on elevation 8'-0" of the auxiliary building. Two pumps are powered from one safeguards power supply. The third pump is powered from a redundant safeguards power supply. One pump is adequate for unit cooldown.

7 Three separate boric acid injection paths including piping and motor operated and air operated valves are located in pipeway 1 and the containment. One path is adequate for cooldown.

8. Service water supply piping with normally open motor operated sectional-izing valves is located in the control building and the auxiliary building. Six service water pumps are located in the circulating water pumphouse. The service water pumps are provided with redundant power supplies. Three pumps are used during cooldown.

9. Three component cooling heat exchangers are located on elevation 46'-0" of the auxiliary building. All valves at these heat exchangers are manually operated. One heat exchanger is adequate for cooldown.

10. Four component cooling water pumps are located on elevation 8'-0" of the auxiliary building. Each pump is provided with a separate safe-guard power suppiy. One pump is adequate for cooldown.

11. Two residual heat removal heat exchangers are located in separate rooms on elevation 5'-0" of the auxiliary building. Valves at these heat exchangers are normally closed motor operated. These valves are also provided with handwheels for manual operation. One heat exchanger is adequate for cooldown.

12. The residual heat removal piping contains motor operated valves located in the containment. These valves are also provided witn handwheel operators and are accessible for manual operation. An air operated flow control valve is installed in each train. This valve can be failed open and flow control can be accomplished with a manual valve.

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IO. Two residual heat removal pumps are located in separate rooms on elevation 19'-3" of the auxiliary building. The pump motors are pro-vided with redundant safeguard power supplies. One pump is adequate for cooldown.

3.0 Auxiliary Building Fire

1. An auxiliary building fire could affect the turbine driven auxiliary feedwater pump steam supply valves. However, these valves are provided with handwheel operators for mar ual operation. The power supply for the motor driven pumps does not enter the auxiliary building and these pumps would be unaffected.

2. An auxiliary building fire could interrupt power to the solenoid operated air supply valve for the atmospheric steam dump valves. The dump valves located outside the auxiliary building are provided with handwheels for manual operation and would not be affected.

3. An auxiliary building fire would not affect letdown system components within the building or system operation.

4. An auxiliary building fire would not affect all three boric acid stor-age tanks. Sufficient redundancy exists to assure a continued boric acid supply.

5. An auxiliary building fire would not be expected to affect all six boric acid pumps. A single cable tray fire would not affect all five power supplies. Sufficient redundancy and separation exists to assure continued boric acid transfer.

6. An auxiliary building fire would not affect all three charging pumps.

A single cable tray fire would not affect the redundant power supplies.

Sufficient redundancy and separation exists to assure continued charging pump operation.

7. An auxiliary building fire would not affect enree boric acid injection flow paths. Sufficient redundancy and manual valve operability exists to assure continuity of at least one flow path.

8. An auxiliary building fire could affect the motor operated sectionalizing valves in the service water header. These valves are normally open and are provided with handwheels for manual operation. The service water pumps and power supplies are located outside of the auxiliary building and would not be affected. A continued supply of service water is assured.

9. An auxiliary building fire would not affect all three component cooling heat exchangers. Sufficient redundancy exists to assure continued heat exchange capability.

10. An auxiliary building fire would not affect all four component cooling water pumps. A single cable tray fire would not affect four power supplies. Sufficient redundancy and separaticn exists to assure component cooling water pump operation.

PF43-7

11. An auxiliary building fire would not affect both residual heat removal heat exchangers or manual valve operability. Sufficient redundancy exists to assure heat exchanger operability.

12. An auxiliary building fire would not affect the residual heat removal piping system. Sufficient manually operated valves are provided to enable continued system operation.

13. An auxiliary building fire would not affect both residual heat removal pumps. A single cable tray fire would not affect the redundant power supplies. Sufficient redundancy and separation exists to assure continued residual heat removal pump operation.

An auxiliary building fire as designated above could occur in a location where onn or more of the listed components could be affected. A single auxil ia ry building would not affect ell of the listed equipment.

Should the normal letdown system be unavailable, the excess letdown system could be used. Relief valves provide further backup protection.

Should a portion of the normal boric acid injection equipment be unavailable, boric acid injection can be accomplished by using the refueling water storage tank located in the containment facade and the safety injection pumps located on elevation 8'-0" of the auxiliary building.

Should any other item of cooldown equipment, power supply or desired instrumentation be affected by a fire, the unit would be maintained in the safe hot shutdown condition until the desired equipment was restored to service. Following a fire and allowing adequate time for accomplishing unit cooldown, sufficient time would be available within a 72-hour period to accomplish the necessary activities as described in paragraph 1.4.

Therefore, cold shutdown can be attained within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following a fire in the auxiliary building.

4.0 Containment Fire

1. All heat removal equipment and power supplies used to accomplish unit cooldown are located outside of the containment and would not be affected by a containment fire.

2. A containment fire could affect motor operated valves in the letdown system. These valves are provided with handwheels for manual operation.

The excess letdown system provides an alternate means to accomplish required letdown.

3. A containment fire could affect the motor operated valve in the normal charging line. This valve is provided with a handwheel for manual operation. The air operated valve in the auxiliary charging line could also be affected. However, with three flow paths available, sufficient redundant exists to assure continued charging capability.

PF43-8

4. A containment fire could affect residual heat removal loop suction and discharge motor operated valves. These valves are provided with handwheels for manual operation. Two discharge piping trains are provided and sufficient redundancy exists to assure continued residual heat removal system flow capability.

A containment fire as designated above could occur in a location where one or more of the listed components could be affected. A single containment fire would not affect all of the listed equipment.

Therefore, cold shutdown can be attained within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following a fire in the containment.

5.0 Containment Facade Fire

1. All heat removal equipment and power supplies used to accomplish unit cooldown are not located in the containment facade and would not be affected by a fire in this area.

2. A containment facade fire could affect access to the atmospheric steam dump valves due to smoke accumulation. These air operated valves would not be expected to be affected by a fire. The valves are provided with handwheels for manual operation. The facade is provided with wall screen openings and roof ventilators. Sufficient time is available within the 72-hour period for the facade atmosphere to purge itself by natural circulation.

Therefore, cold shutdown can be attained within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following a fire in the containment facade.

6.0 Pipeway Fire

1. Most equipment, power supplies, and instrumentation used to accomplish unit cooldown are located outside of the pipeways and would not be affected by a pipeway fire.

2. A pipeway 1 fire could affect one of three normally open power operated valves. Sufficient redundancy exists to maintain letdown control.

3. A pipeway 1 fire could affect the power supply to a motor operated valve which is required to initiate residual heat removal cooling.

This valve is provided with a handwheel for manual operation.

4. A pipeway 2 fire could affect the power supply to the normally open motor operated letdown isolation valve. The excess letdown system provides an alternate path to accomplish required letdown.

5. A pipeway 2 fire could affect the power supply to a motor operated valve which is required to initiate residual heat removal cooling.

This valve is provided with a handwheel for manual operation.

Should any other desired power supplies or instrumentation be affected by a pipeway fire, the unit would be maintained in the safe hot shut-down condition until the desired equipment was restored to service.

PF43-9

Sufficient time would be available within a 72-hour period to accomplish the necessary activities as described in paragraph 1.4.

Therefore, cold shutdown can be attained within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following a pipeway fire.

7.0 Auxiliary Feedwater Pump Area Fire

1. Most equipment used to accomplish unit cooldown is located outside of the auxiliary feedwater pump (AFP) room and would not be affected by a fire in this area.

2. An AFP room fire could affect one AFP. These pumps are separated by 1-foot thick reinforced concrete walls. A single cable tray fire would not affect the safeguard power supply to both motor driven pumps. Sufficient redundancy and separation exists to assure AFP availability.

3. An AFP room fire would not be expected to affect cables routed through the area because of the area's low combustible content, controlled access and because the cable trays are located 12 feet above the floor. Power supplies for charging pumps, component cooling water pumps and residual heat removal pumps are routed through this area.

This cabling is safeguard train separated per the separation criteria as defined in Appendix "A" of the Fire Protection Review. A single cable fire would not be expected to affect redundant power supplies.

In order to further assure that a single cable tray fire would not propagate, the licensee has committed to add a fire retardant material to trays in this area. Results of test number 28 reported in SAND 78-1456, which was a tro tray test using open ladder trays filled with PVC cable and covered with a ceramic wool blanket, demonstrate that a fire will not propagate outside of the involved tray. This measure provides further assurance that redundant power supplies would not be affected by a single cable tray fire.

4. An AFP room fire could affect one of the redundant remote shutdown panels. Sufficient redundancy and separation exists to assure shutdown capability.

An AFP room fire as designated above could occur in a location where one or more of the listed components could be affected. A single AFP room fire would not affect all of the listed equipment.

Should any cabling or instrumentation desired for unit cooldown be affected by an AFP area fire, the unit would be maintained in the hot shutdown condition until the required equipment was restored to service. Sufficient time would exist within the 72-hour period following a fire to accomplish the necessary activities as described in paragraph 1.4.

Therefore, cold shutdown can be attained within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following a fire in the auxiliary feedwater pump area.

PF43-10

8.0 Switchgear Room Fire

1. All equipment, associated cabling and instrumentation used to accomplish unit tooldown is located outside of the switchgear room and would not be affected by a fire in this area.

2. A switchgear room fire would not be expected to affect cable trays routed through the room because of the room's low combustible content, controlled access and the height of the cable trays above the floor.

Considering circuit protective features a fire in a switchgear cabinet would be expected to remain localized. Incoming power cabling and power cabling to switchgear associated with equipment used for unit cooldown is routed through this room. Separate offsite power cables enter the room from Units 1 and 2 sides. The Unit 1 and Unit 2 buses could be interconnected if one of these power sources were unavailable.

Redundant power cables enter the room from the diesel generators.

Redundant power cabling is routed from the room to switchgear associated with equipment used for unit cooldown. The redundant cabling is safe-guard train separated per the separation criteria as defined in Appendix "A" of the Fire Protection Review. A single cable tray fire would not be expected to affect redundant cable trays.

To further assure that a single cable tray fire would not propagate outside of the involved tray, the licensee has committed to add a fire retardant material to cable trays in this room. Marinite barriers are or will be installed where appropriate to further assure fire containment.

Cable tray test results reported in SAND 78-1456, which are referenced in response to staff position PF-43A, demonstrate the effectiveness of these materials in controlling fire propagation.

Sufficient time exist within the 72-hour period following a fire to repair or install new power cable which may be desired to accomplish a unit cooldown.

Therefore, safe shutdown can be attained within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following a fire in the switchgear room.

PF43-ll

TABLE 43-1 COLD SHUTDOWN EQUIPMENT PER UNIT Equipment Equipment Equipment Power Equipment Number Description Location Source Status Residual Heat Removal (RHR)

P-10A RHR Pump -19' PAB* 1803 Off P-10B RHR Pump -19' PAB 1804 Off HX-ll A RHR Heat Exch. - 5' PAB Off HX-llB RHR Heat Exch. - 5' PAB Off Component Cooling Water (CCW)

P-llA CCW Pump 8' PAB 1803 On P-llB CCW Pump 8' PAB 1804 Standby HX-12A CCW Heat Exch. 46' PAB On HX-12B CCW Heat Exch. 46' PAB Standby Boric Acid (BA)

T-6A 12% BA Tank 46' PAB On T-6B 12% BA Tank 46' PAB Standby P-4A BA Transfer Pump 26' PAB B-33 Standby P-ll6 BAT Recirc. Pump 26' PAB P-4B Standby P-ll6 BAT Recirc. Pump 26' PAB 1B-41 On T-13 RWST (2000 ppm) 8' Facade Standby P-2A Charging Pump B' PAB 1B03 On P-2B Charging Pump 8' PAB 1803 On P-2C Charging Pump 8' PAB 1804 Standby

• Primary Auxiliary Building

TABLE 43-2 AVAILABLE COLD SHUTDOWN EQUIPMENT - UNAFFECTED UNIT Equipment Equipment Equipment Power Equipment Number Description Location Source S' tus Residual Heat Removal (RHR)

None Component Cooling Water (CCW)

P-llA CCW Pump 8' PAB* 2B03 On P-llB CCW Pump 8' PAB 2B04 Standby HX-12C CCW Heat Exch. 45' PAB On Boric Acid (BA)

T-6C 12% BA Tank 46' PAB On P-4A BA Transfer Pump 26' PAB 18-31 Standby P-4B BA Transfer Pump 26' PAB B-33 Standby P-ll6 BAT Recirc. Pump 26' PAB 2B-41 On

• Primary Auxiliary Building.

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STAFF POSITION POINT BEACH NUCLEAR PLANT PF-44 Portable Smoke Venting Capability Staff Concern:

Portable smoke venting equipment is currently available on-site at Point Beach and will be used for those areas of the plant where the installed ventilation systems may be incapable of smoke venting in the event of a fire. In a letter dated January 13, 1978, the licensee proposed to provide additional portable smoke venting equipment for the auxiliary building. The capacity of the existing and proposed equipment has not been addressed.

Staff Position:

The onsite portable smoke ejection capacity should be 17,500 cfm divided into a minimum of three smoke ejector units with an approximate sizing of one unit at 9500 cfm and two units at 4000 cfm each.

RESPONSE

In response to staff position PF-10, the Licensee committed to provide portable smoke venting capability. Based upon recommendations made by the NRC fire fighting consultant during the September 1977 site inspection, we have purchased one 5500 cfm gasoline engine driven and one 5200 cfm electric motor driven portabic smoke exhausters. Eight existing 960 cfm portable fan units can also be used for smoke control purposes. We believe that the combination of existing smoke venting equipment provides a flexible approach to potential smoke control problems.

PF44-1

STAFF POSITION P0 INT BEACH NUCLEAR PLANT PF-45 Reactor Coolant Pump Oil Collection System Staff Concern:

Each of the two reactor coolant pumps has a lube oil inventory of 175 gallons.

The reactor coolant pumps are provided with oil deflector plates that divert oil leakage away from the hot pump body. Oil leakage would drop off the deflector The licensee proposas plates and accumulate at the containment 10 feet elevation.

to add a curb below the reactor coolant pumps that would restrict the oil spread at the 10 feet elevation to 230 square feet. With this restriction the burning rate of 175 gallons of lube oil would be reduced. The licensee states that at this reduced burning rate, the containment air temperature can be maintained below the design limit (286F) by operation of two of the four containment air cool ers.

In response to staff position PF-29, the licensee identified several cablesThe in containment for equipment and instrumentation required for safe shutdown.

staff is concerned that an uncontrolled reactor coolant pump lube oil fire could damage these cables. There is not reasonable assurance that the effects of an open pool fire in containment can be accurately predicted. Local temperatures could be significantly above the average temperature calculated by the licensee.

Staff Position:

The present oil diverting system should be modified to provide the capability to collect lube oil from all potential pressurized and unpressurized leakage sites in the reactor coolant pumps' lube oil systems and to drain the oil to an enclosed container. Leakage points to be protected should include lift pump and piping, overflow lines, lube oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines and lube oil reservoirs where such features exist on the reactor coolant pumps at Point Beach Units 1 and 2.

RESPONSE

The Licensee's response to staff position PF-29 identified equipment, instrumen-tation and systems normally used to achieve safe hot shutdown. The same response also identified alternatives, redundancies and spatial separations which exist in the containment so that a single f. ire would not impair safe hot shutdown capability. In order to further reduce the effect of a poteatial reactor coolant pump oil leakage fire, the existing oil deflector cones will be fitted with curbs and drain piping installed in a manner which will allow oil leakage to be collected in four 55 gallon capacity drums located on Elevation 10'-0" of the containment. The drum containers will be connected in parallel, will have closed tops and will be provided with vents. This proposed arrangement is shown on attached figure 45-1. During periods of normal operation, internal oil circulators maintain oil flow. The proposed installation provides suitable The external high pressure lift oil collection capability for this condition.

pump is utilized for a short time during reactor coolant pump startup.

PF45-1

Reactor coolant pumps are running and checked for oil leakage and proper opera-tion before a Unit criticality is achieved. Extensive modification to provide suitable oil collection capability during these infrequent periods of high oil system pressure would impair reactor coolant pump ventilation, inspection and maintenance.

PF45-2

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STAFF POSITION POINT BEACil NUCLEAR PLANT PF-46 Circulating Water Pumphouse Fire Protection Staff Concern:

The six safety-related service water pumps are located in an enclosure within the circulating water pumphouse along with the electric motor-driven fire pump, the diesel-driven fire pump and the screen wash pumps. All of these pumps are in close proximity with no intervening barriers between the pumps. At least three service water pumps are required to operate to shutdown the two reactor units. Cables for the service water pumps and fire pumps are embedded in the floor slab and would not be damaged by a fire in this area.

The licensee has proposed to erect a 12 foot high wall around three sides of the diesel fire pump to protect the service water pumps and the other fire pump from a fire involving leakage of fuel oil at the diesel. A curo will be added around the diesel fire pump to contain any lube or fuel oil leakage from the diesel fire pump within the area bounded by the proposed wall. The ce~ ling height in this area is 18 feet.

Additional fire protection was reconmended for the circulating water pumphouse by staff position PF-8. The staff recommended that the service water pumps and fire pumps be provided with sprinkler protection. The staff also recommended that the storage of marine engines and vehicles within the pumphouse be discontinued.

In a letter dated January 13, 1978, the licensee stated that an analysis had been performed to show that the proposed wall would limit the heat flux from a diesel oil fire sufficiently to assure operability of three service water pumps.

The potential for damage to service water pumps from a service pump lube oil fire was not addressed. In subsequent conversations with the licensee, the licensee stated that a metal wall would be erected to replace the chain link fence which encloses the pump area. This metal wall would reach to the ceiling.

The licensee stated that this wall would protect the pumps from a fire involving the fuel in marine engines and vehicles stored in the pumphocse.

The staff's concerns are as follows:

1. There is not reasonable assurance that the effects of a diesel fuel fire in the pump enclosure can be accurately predicted. Ambient temperatures in the enclosure could increase sufficiently to affect the service water pump motors.

2. A fire involving the lube oil in a service watcr pump or screen wash pump could incapacitate redundant service water pumps.

3. The capability of the proposed metal wall around the pump area to protect the pumps from an exposure fire has not'been demonstrated.

PF46-1

Staff Position:

A. The licensee should provide an automatically-actuated sprinkler system to suppress a fire in the area of the diesel fire pump.

B. The licensee should justify the lack of sprinkler protection for the service water pumps or barriers between the pumps to prevent loss of redundant service water pumps in the event of a service water or screen wash pump lube oil fire.

C. The licensee should verify the capability of the proposed metal wall around the pump area to prevent damage to the service water and fire pumps in the event of a fire involving combustibles stored in the pumphouse.

RESPONSE

46-A The Licensee will install a sprinkler system to suppress a fire in the area of the diesel fire pump. We have evaluated the diesel fire pump installation and have determined that suitable deflectors can be installed to contain spilled oil a minimum distance of 7 feet from any service water pump. We have also determined that curbing to contain 250 gal. of fuel oil and a 10 minute discharge of fire suppression water would cause access difficulties and be impractical to install. Therefore, we propose to install a small curbed area and a floor drain routed to the circulating water pump pit area. This area having a floor elevation of -11'-9" is separated from the safety-related pump area by 2-foot thick reinforced concrete walls. Therefore, the severity of a potential oil fire in the safety-related pump area would be significantly reduced. The service water pumps would be shielded from this fire by the diesel engine and its foundation.

The pumphouse arrangement is shown on Figure 46-1. The previously proposed barrier wall would provide no added functional shielding and will not be installed.

46-B The Licensee will install sprinkler protection for the service water pumps.

46-C The storage of combustibles within the pumphouse is minimized. Fuel required for the outboard motor and the vehicle, which are stored within the pumphouse, is contained within the boat and the vehicle. These combustibles are separat ed from the service water and fire pumps by distance of 50 feet and the metal security wall which is a physical barrier. While the security wall is not constructed to qualify for an approved fire rating, a rating of at least 30 minutes can be expected without testing. For a postulated fire contained at the boat or the vehicle, the security wall and distance separation are considered adequate to prevent damage to the service water or fire pumps. The boat and vehicle locations within the pumphouse are such that the missile barrier walls adjacent to the circulating water pumps would protect the service water and fire pumps from a postulated fuel tank rupture or explosion. If it were PF46-2

postulated that the entire content of the vehicle fuel tank would spread across the pumphouse floor without evapordtion or leakage through floor penetrations prior to ignition, the maximum fuel depth would be .001 in, without co the security wall.

security wall would effectively shield the service water and fire pumps from radiant heat flux.

PF46-3

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STAFF POSITION POINT BEACH NUCLEAR PLANT PF-47 Control Room Shutdown Requirements Staff Concern:

In response to staff position PF-1, the licensee verified that both reactors could be brought tc safe hot shutdown independent of cable damage in the control room. In the event of damage to redundant hot shutdown cables in the control room, hot shutdown could be controlled from remote shutdown panels. The ability to achieve and maintain cold shutdown was not addressed.

Staff Position:

The licensee should demonstrate that any fire in the control room could be manually extinguished before damage would occur to redundant cables and equip-ment needed for safe cold shutdown. Alternatively, the licensee should verify that cold shutdown can be achieved and maintained, with offsite power available, independent of cable and equipment damage in the control room.

RESPONSE

In the event that the control room were the scene of a fire emergency, the control room would continue to be the connand post and any functioning instru-ments and controls would be employed during the cooldown. Communication with the control room would be via any existing communications circuit or with portable hand held communications equipment as a backup. The following analysis is presented to verify that cold shutdown can be attained following a fire in the control room.

1. All equipment and associated power cable used to accomplish unit cooldown is located outside of the control room and would not be affected by a control room fire. A control room fire could affect instrumentation and control associated with this equipment.

2. A control room fire could impair normal control of the auxiliary feedwater pumps. Control of these pumps can be decoupled from the control room and the pumps can be operated from the remote shutdown panel.

3. A control room fire could impair normal control of the atmospheric steam dump valves. These valves are provided with handwheels for local manual operation. Backup protection is provided by the main steam safety valves.

4. A control room fire could impair normal control of the letdown orifices.

Local controls are provided for manual operation. Backup protection is provided by the excess letdown system. Relief valves located in the containment provide further backup protection.

PF47-1

5. A control room fire could impair normal control of the charging pumps.

Local controls are provided for charging pump operation.

6. A control room fire could impair normal control of the boric acid injection system. The flow control valve station is provided with bypass piping and valves to allow manual control. Three separation injection paths are provided. The boric acid pumps can be decoupled from the control room and the pumps can be controlled locally.

7. A control room fire could impair normal control of the service water pumps.

Control of these pumps can be decoupled from the control room and the pumps can be operated from the remote shutdown panei.

8. A control room fire could impair normal control of the component cooling water pumps. These pumps can be started manually at the load center.

9. A control room fire could impair normal control of the residual heat removal system. Motor operated valves in this system are provided with handwheels for manual operation. Sufficient manually The normal operated valves are provided for system line up procedure for system line up and flow control.

cooldown operation is a manual activity.

10. A control room fire could impair normal control of the residual heat removal pumps. These pumps can be started manually at the load center.

A control room fire as designated above could occur in a location where one or more of the listed components could be affected. Any single control room fire would not affect controls for all listed cooldown equipment.

Should other controls or instrumentation which may be affected by a control room fire be desired for unit cooldown, the unit would be maintained in the safe hot shutdown condition until the equipment was restored to service.

Following a control room fire, the activities which may be necessary to restore equipment to service could be orderly evaluated and accomplished.

Therefore, cold shutdown can be attained following a fire in the control room.

PF47-2

STAFF POSITION P_0 INT BEACH NUCLEAR PLANT PF-48 Fire Brigade Practice Sessions Staff Concern:

The licensee has proposed to conduct practice sessions for members of the fire brigade once every two years. The proposed frequency for fire brigade practice sessions does not provide adequate training to assure personnel understanding and familiarization with the operation of the fire fighting equipment provided.

Staff Position:

Practice sessions should be provided at least annually for each member of the plant fire brigade.

RESPONSE

In response to staff position PF-37, the licensee proposed to conduct practice sessions on a two-year cycle. The bases for this proposed cycle are:

1. The fire brigade training program is repeated on a two year cycle. The inclusion of one practice session for each area of training would appear to be a logical component of this program.

2. The operator licensing and retraining program is repeated on a two year cycle. Licensed operators must demonstrate an intelligence and ability to safely operate the plant in a manner which will protect the public safety as well as the owners investment. Safe operation includes fire awareness and prevention. We believe that a cycle for fire extinguishment training equivalent to operator training is appropriate.

3. Four of the seven operating shift personnel are licensed operators. The three remaining auxiliary operators were hired on the premise that their intelligence and attitude would enable them after a period of plant familiarization to qualify for a reactor operator's license. Therefore ,

the operating shif t fire brigade members either are or aspire to be licensed operators. The maintenance fire brigade is composed of four supervisory and ten senior maintenance personnel. These people, in the performance of their plant duties, are also responsible for the protection of public safety and the owners investment. A two-year practice session cycle for the Point Beach fire brigade members who have demonstrated inteilectual, menery and responsibility characteristics is more effective than annual practice sessions would be for unproven personnel.

4. Point Beach fire brigade members perform all fire protection system tests and maintenance. Brigade members thereby become very familiar with the operation of all fire protection equipment.

PF48-1

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5. In an actual fire event, fire fighting activities are directed by either the fire brigade chief or his assistant. Both of these men have attended the Af4SUL fire training school. This further assures that proper fire fighting techniques and proper handling of fire fighting equipment are implemented.

6. Practice sessions are:

a. A burden upon personnel scheduling. This is also disruptive to plant activities including those associated with fire protection.

b. Environmentally disturbing. Practice sessions cause unjustified pollution of the atmosphere. The acquisition of required burn permits is dependent upon the policy of local authorities.

c. Expensive. Practice session scheduling may require overtime pay for members. Practice sessions require the unproductive use of fuels and impose unnecessary wear on fire protection equipment.

We are unaware of any basis for required annual practice sessions. We believe that our proposed two-year practice cycle is appropriate and justified.

PF48-2

STAFF POSITION POINT BEACH NUCLEAR PLANT PF-49 Fire Brigade Size Staff Concern:

By letters dated Cecember 12, 1977 and July 3, 1978, the licensee proposed to maintain a trained fire brigade of four fire fighters, and provided his justi-fication therefore.

The licensee's bases for a four man fire brigade are as follows: (1) during day shift of the week days of normal operations, and maintenance outages, the onsite brigade could be supported by as many as 22 trained fire brigade members; (2) the potential for fires is significantly reduced because during back, holiday, and weekend shifts, only activities associated with the direct operation of the plant are conducted; (3) should a fire occur, assistance would be requested from the offsite volunteer fire department, and from the off duty fire brigade members; and (4) the licensee expects that the fire brigade to either extinguish the fire or to confine it to a single fire area for the 15 minutes required to bring the offsite assistance into action.

The staff and its consultants have evaluated the licensee's bases and have found that the plant specific justifications are not sufficient to support the proposal.

Although the potential for fires may be reduced durin, back, holiday, and weekend shifts as a result of limited work activities; the potential for fire will not be eliminated. The onsite fire brigade must have the capability to promptly extinguish fires, whenever they occur. Point Beach contains many fire zones which are not bounded by fire barriers, it is essential that the fire brigade be capable of extinguishing fire in such zones promptly; simply containing a fire in a single bounded fire area, and allowing it to continue unsuppressed until offsite assistance can be brought into action may result in damage to systems or equipment required for a safe shutdown of the reactors.

Staff Position:

1. Provide a plant specific analysis which demonstrates that the proposed four man fire brigade will be self sufficient in suppressing fires. The analysis should use the plant's prefire strategies for the cable spreading room, switchgear room, component cooling pump room, circulating water pumphouse, auxiliary feed pump areas, and the turbine lube oil storage room to demonstrate the capability of the four man fire brigade to accomplish all functions necessary in the event of a fire in each of these areas:

1. transport support equipment to the scene of the fire,

2. assess fire conditions; command, and direct the fire fighting activities,

3. communicate with the control room or remote shut'down panels,

4. lay and maneuver fire hose,

5. locate fire and apply the extinguishant to the fire, PF49-1

6. set up and operate portable ventilation equipment,

7. charge and replace respirator air bottles,

8. direct and coordinate offsite fire department personnel,

9. set up and operate emergency lights,

10. set up and operate emergency communications equipment,

11. rescue injured personnel,

12. maintain fire fighting activities if supporting personnel are delayed.

The postulated fire scenarios should include: the obscure fire that requires a significant time to locate, and the well-developed fire that will require a sustained effort to extinguish; fires in areas where the automatic suppression system has failed to operate; injury and rescue of at least one brigade member; and rotation of the men handling the hose and other fire fighters exposed to heat and/or products of combustion.

2. Provide a summary of the related qualifications for those individuals respon-

_"le for developing the aforementioned prefire strategies and fire fighting scinarios which demonstrate their knowledge and experience in fire fighting and fire protection.

RESPONSE

The Point Beach Nuclear Plant minimum shift crew is comprised of:

Shift Title Fire Brigade Status 1 Shift Supervisor (SRO Licensed) Chief 1 Operations S2pervisor (SRO or R0 Licensed) Assistant Chief 2 Control Operators (R0 Licensed) Member 3 Auxiliary Operators Member 8 Security Guards Non-Member The seven operations personnel are fully trained members of the Point Beach fire brigade. The Shift Supervisor and the three Auxiliary Operators are the basic four-man fire brigade attack team. The Operations Supervisor is a backup to the brigade chief. The two Control Operators are backup to the brigade attack members.

The Point Beach Nuclear Plant Technical Specifications allow the Operations Super-visor and one control operator to leave the control room. Present plant practice requires one supervisor to remain in the control room unless an emergency situation develops which requires his presence elsewhere in the plant. Therefore, one of the three operating personnel who normally remain in the control room could become part of the attack team in an injury emergency.

The three auxiliary operators are assigned specific plant areas for regular fire surveillance and alarm response. The assigned fire areas are generally identical to the auxiliary operator's assigned watch station areas. Additional fire areas may be assigned during abnormal conditions such as monitoring a transient fire hazard in a normally unmanned area.

PF49- 2

Should a fire occur, the Shif t Supervisor and the auxiliary operator assigned to the af fected area proceed ininediately to the fire area. The other two auxiliary operators proceed to the fire brigade ready station, man the FM radio and await specific instructions from the fire brigade chief. The Operations Supervisor and the two coritrol operators will normally remain in the control room to handle consnunications with the fire attack team, the Duty and Call Superintendent, outside organizations and conduct plant operations necessitated by the event in progress.

After the fire brigade chief has evaluated the fire situation, he may order an emergency call-out of Point Beach off-site of f-duty fire brigade personnel and a call-out of the Two Creeks Volunteer Fire Department. The Two Creeks Volunteer Fire Department has demonstrated by drill that they can have a pumper truck and five members at the plant within ten minutes following receipt of the call. This is verified by the attached critique of the August 31, 1978 drill. O f f-duty fire brigade members will arrive at the plant gate within 20 minutes following notification by the Duty and Call Superintendent. The call in of off duty personnel continues until at least five fire brigade muibers confirm their availability.

Security guards, while performing their assigned surveillance duties, provide a personnel network for the early detection and reporting of fires. Security guards may also be assigned fire watch duty. Security guards are trained to provide emergency medical assistance to injured personnel. Therefore, guard personnel will be relied upon to provide emergency medical assistance and trans-portation, if required, for injured personnel during a fire event. Security guards are not required to have fire fighting training. Their familiarity tith equipment location and function is well below what is required for a beginning auxiliary operator. While security guards will be relied upon to perform valua91e support duties, they cannot be expected to perfonn effectively as fire attack versonnel.

Therefore, security guards are not included in the fire brigade.

Fire scenarios for the cable spreading room, 4160 volt vital switchgear room, component cooling pump area, circulating water pumphouse, auxiliary feed pump area and the turbine lube oil storage t nk room are included in this response.

Each scenario address specifically the 12 point analysis outlined in the staff position.

The postulated fire scenarios have been prepared on the following basis.

1. All presently proposed fira protection equipment conunitted to in the fire hazard analysis and subsequent responses to the NRC staff positions PF-1 through PF-49 is available to the fire brigade.

2. Because a definition for a well developed fire has not been provided, we define this fire for analysis purposes as: one 2 1/2 gallon container of flannable solvent stored in a combustible container, the container and contents are ignited in some manner. The container ruptures and a spill fire results.

3. Because a definition for an obscure fire bas not been provided, we define this fire for analysis purposes as: a single cable tray ignited in some manner creating dense smoke, which obscures the fire source.

PF49-3

4. The automatic suppression system (if provided) has failed to apply extin-guishing agent. This assumes the worst case situation for each area to be analyzed.

5. The fire occurs during a holiday, weekend, or backshif t when the facility staff is at minimum allowea by Technical Specifications (seven operations and eight security personnel). For all other periods of plant operations, 10-20 additional fire brigade members will be on site and available.

6. Fire brigade response to all fire situations will be per the following established General Fire Plan.

General Fire Plan 1.0 Fire Detection 1.1 Local (fire / heat / smoke) detector senses fire and transmits a signal to the control room alarm or the fire is observed by a member of the plant staff and the word is passed to the control room by GAI-TRONICS phone system.

1.2 An automatic fire protection system has actuated and transmitted this signal to the control room. While it is assumed that the installed fire suppression system fails to perform its function for this analysis, the potential to alarm is not precluded.

2.0 Fire Alarm Announcement 2.1 Control roorn personnel acknowledge the alarm (by local detection or verbal report). They actuate the plant fire alarm for ten seconds, start the electric fire pump and announce the location of the fire alarm over the plant P. A. (GAI-TRONICS) system. The alarm and announcement are repeated a second time.

2.2 Response to Alarmi 2.2.1 The fire brigade chief (FBC - shift supervisor) proceeds directly to the fire scene with an FM radio.

2.2.2 The auxiliary operator assigned to the announced fire area proceeds directly to the fire scene.

2.2.3 The two auxiliary operators not assigned to the announced fire area proceed directly to the fire brigade ready station and man the FM radio. These men stand by until instructions have been received from the FBC.

2.2.4 The security force will stand by to provide the fire brigade medical assistance and site evacuation of any f ajured personnel. The Central Alarm Station (CAS) will mon' tor the Operations FM radio channel and respond to FBC orders.

PF49-4

3.0 Fire Evaluation and Brigade Actions The FBC or the assigned auxiliary operator r..ay be the first to arrive at the scene. (Their immediate responses and responsibilities differ and are discussed separately recognizing that they may occur simultaneously.)

3.1 Auxiliary operator assigned to fire scene area.

a. Makes check for injured.

b. Evaluates if the fire area is safe to enter for rescue or if the fire can be attacked and extinguished by himself with the manual fire fighting equipment immediately available at the fire scene.

c. If in his judgement he feels it is safe, he attempts to rescue and/or attacks the fire. If not, he stands by until the FCC arrives. Note, if the FBC is apparently delayed, he notifies the control room of all conditions observed and also that the FBC has not arrived at the scene.

d. In all cases, he remaias near the fire scene until the FBC or his backup arrives and directs him otherwise.

3.2 Fire Brigade Chief

a. The FBC evaluates the fire scene immediately upon arrival using the following basic criteria:

1. Establish if personnel injury has occurred and if immediate rescue is possible. Will outside emergency medical assistance be required?

2. Can the type and magnitude of the fire be innediately determined or is it obscured by smoke?

3. Can the fire be extinguished by a single fire fighter with extinguish-ment equipment immediate? available?

4. Can the fire be extinguishe i by the auxiliary operator and himself with the equipment immediately available?

5. Will fire extinguishment require a fully protected two-man or four-man attack team, and equipment not immediately available at the fire scene?

6. Is 'f.ie fire or can the fire, if not immediately extinguished, (rfect safety-related equipment or continued plant operation?

7. Is Two Creeks Volunteer Fire Department and Point Beach Nuclear

~

Plant backup fire brigade call-in required?

8. Is the fire or can the fire, if not immediately extinguished, cause a release of radioactive material?

9. Will ventilation system alterations be required to control smoke and heat generation? .

PF49-5

b. The FBC establishes FM radio contact with the control room; the (2) fire brigade members at the ready station and security force at CAS.

He directs their response to the fire situation based upon his evaluation. Backup communications are available to him via the GAI-TR0filCS two channel phone system. Based upon his judgement, the FBC will direct the control room to take the following action when and if required:

1. Place calls for help to Twc reeks Volunteer Fire Department, Duty and Call Superintendent and other agencies.

2. Order immediate plant (s) shutdown.

3. Alter ventilation lineups.

4. Have all locked doors placed in " access" position.

Based on his judgement, the FBC will direct the security force to take the following actions when and if required:

1. Provide medical assistance to injured.

2. Provide site evacuation for the injured.

3. Assist into plant and escort Two Creeks Volunteer Fire Department to the fire scene.

4. Other support activities.

c. The following options will be used by the FBC in accomplishing personnel rescue and fire extinguishment. Since each fire incident will have some unpredictability, combinations of the options may be required. These options are preplanning alternatives for training ano practice sessions.

1. Personnel rescue and/or fire extinguishment by a single individual (FBC or A0) first arriving using equipment immediately available.

2. Personnel rescue and/or fire extinguishment by (FBC and AD) first arriving using equipment immediately available.

3. Personnel rescue and/or fire extinguishment by two man fully protected (A0's) attack team backed up by first arriving A0 and FBC using equipment immediately available.

4. Personnel rescue and/or fire extinguishment by four man fully protected attack team, 3 A0's and "BC using all fire equipment available in the plant.

5. Personnel rescue and/or fire extinguishment by four man fully protected attack team as in (4) above, backed up by outside help from Two Creeks Volunteer Fire Department and off-duty brigade members.

PF49-6

4.0 Plant Operations During Fire Event 4.1 Operations Supervisor (1)

a. Monitors plant parameters very closely for any degradation of normal conditions, and takes necessary action, including plant shutdown.

b. Responds to all orders from the duty shift supervisor (FBC).

c. Coordinates all orders and requests to outside plant support agencies and groups.

d. Backs up FBC and/or /^ -- fire brigade.

4.2 Control Operators (2)

a. Each unit's operator monitors plant parameters closely for any degrada-tion of normal conditions, reports to the operations supervisor all changing conditions. Takes necessary required action including plant shutdown.

b. Responds to all orders from duty shift supervisor.

c. Backs up A0 on fire brigade.

Cable Spreading Room 1.0 Protection Design Summary Detection: Ionization, photoelectric and heat detectors, sprinkler system actuation, roving o?erations personnel .

Suppression: Automatic dry pipe sprinkler system, two 1-inch hard rubber hose stations specially equipped with ball shut off valves and fog-only nozzles, two 1-1/2" standard industrial hard rubber hose stations with industrial fog straight stream nozzle, two 100-lb. CO2 wheeled units, one 150-lb. ABC dry chemical wheeled unit, several hand portable CO2 dry chemical and water extinguishers. Other equipment located in the plant available as required.

Ventilation: Normal supply and exhaust system, special heat and smoke system, two portable smoke and heat ejectors.

Other Features: Controlled personnel access at all times, controlled main-tenance activities, cot.' rolled ignition source area, posted no smoking area, storage not allowed, area totally protected by three hour rated fire barriers, all cable trays closed top and bottom with steel, fire blanket inside cable trays.

All electrical :abinets water spray shield protected. Floor-tray minimum clearance approximately 7 feet average approximately 10 feet. All electrical cabinets elevated approximately 6 inches on concrete curbs.

PF49-7

2.0 Fire Scenarios 2.1 A 2-1/2 gallon plastic jug containing flammable solvent was left undetected in this room and was ignited by some means. The resulting fire destroys the container causing a spill fire on the floor.

2.2 A single cable tray assembly is burning, emitting large quantities of smoke making positive location of the burning tray difficult (obscuring).

3.0 12 Point PF-49 Analysis NRC-1 Transport support equipment to the scene of the fire.

Transportation of support equipment will be accomplished by the two A0's on orders from the FBC. All equipment is mounted on four wheel hand carts (smoke ejectors and duct, self contained breathing apparatus (SCBA), hand tools, additional hose, foam equipment, emergency lights, etc.). These carts are located near the fire brigade ready station and other designated locations.

Additionally, guard force personnel can be mobilized to bring large wheeled equipment ;nd carts to the scene.

NRC-2 Assess fire conditions; command, end direct the fire fighting activities.

The FBC performs these functions, or delegates this responsibility to the Assistant FBC (operation supervisor).

NRC-3 Communicate with the control room or remote shutdown panels.

The FBC will Establish FM radio communications and direct all emergency activities.

FM radio communications will be established during fire emergency.

A two channel system is utilized, (1) channel for security and (1) channel for operations and plant emergencies. The security CAS monitors both channels as does the plant control room. The A0s reporting to the fire brigade ready station wil! man the FM radio provided. Operators reporting to remote shutdown panels will also use FM radio communication as required.

The GAI-TRONICS two channel phone system provides backup to the FM radios.

NRC-4 Lay and maneuver fire hose.

Thc cable sprc ading room can be reached with two 1-1/2" fire hose, fror the fire arotection standpipe system.

Two 1" light we'ght, maneuverable booster hose reels have been installed to cover the cable spreading room. The 1" hose system is specially designed to provide quick water application and naximum personnel protection for individyal fire fighters.

PF49-8

If a greater water quantity is required, the 1-1/2" hose system is available and can be handled easily by two men.

Depending on the situation, one, two or all four brigade members will handle and maneuver fire hoses.

When outside plant assistance arrives, additional hose lines can be layed from the hydrant connections to the cable spreading room area.

In this case, the cable spreading room can be reached easily from the pumphouse hydrant connection.

NRC-5 Locate fire and apply the extinguishment agent to the fire.

Well developed fire (flammable liquid spill fire)

Location of a well developed fire will be accomplished by the first fire brigade member to arrive at the fire scene (A0 or FBC).

Extinguishment methods 2, 3, and 4 described in the general plan would be applicable. Dry chemical hand or wheeled portable extin-gu:2hers would be used in the first attempt to extinguish the fire.

If this failed, the 1" hose line(s) would be used to cool and extinguish the fire. If the fire was still not under control, the fully protected A0's would advance a 1-1/2" water fog line or a 1-1/2" foam line. Agent application will be determined by the amount of heat, smoke, open flame, and equipment involved in the fire.

Obscure Fire (cable tray)

For the smoky cable tray fire, full protection will be required by all involved fire brigade members prior to location and extinguishment.

The special smoke and heat control ventilation system will be used to aid in location of the burning cables. Water fog will be used to help disperse the smoke and to control heat generation. When the general fire area has been located, water fog will be used to attempt extinguishment by indirect application by cooling to below ignition temperature. The cooling and heat control will help prevent the fire from migrating to adjacent trays. When smoke conditions allow, the affected tray wi.ll be forcibly entered and direct water fog will be applied to any cables still burning.

NRC-6 Set up and operate portable ventilation equipment.

The cable spreading room will have an installed heat and smoke removal ventilation system controlled locally from outside the room. The normal ventilation system can also be manipulated to also remove heat and suoke from the room and is controlled from the control room. Portable smoke ejector equipment will be transported to the scene by the A0's and utilized as required and as directed by the FBC. Smoke ejection may require coordinated effort by the four man team and the control room personnel in the case of the obscure fire scenario. .

PF49-9

NRC-7 Charge and replace respirator air bottles.

Ten Bio Pak 60p SCBA are available exclusively for fire brigade use. These units have a sixty minute duration. Before these ten units can be expended, additional PBNP fire brigade members will be on site and available to provide refill if needed. The plant will have a cascade 02 bank that will provide more than 100 sixty-minute refills. Refill of the small 02 cylinders can be accomplished by one man in less than ten minutes per cylinder.

Some units are wall mounted at the fire brigade ready station for fast donning by the fire brigade and some units are cart mountad for easy transportation to the fire scene.

This SCBA unit was selected to eliminate the compressed air-bottle system burden placed on fire fighters. The equipment literature provides details of this recently NIOSH approved SCBA unit.

NRC-8 Direct and coordinate offsite department personnel.

Coordinated prefire planning and annual drills with the Two Creeks Volunteer Fire Department have been established. Security personnel clear the Two Creeks Volunteer Fire Departr..ent rapidly for entry and escort the department to an area designated by the FBC. All fire fighting activities are directed by the FBC.

Extinguishment may be directed by the Two Creeks Volunteer Fire Department leader under orders from the FBC.

NRC-9 Set up and operate emergency lights.

Portable emergency lights (carpenter lanterns) are located at several locations throughout the plant and at the fire brigade ready station.

The lights would be brought to the fire scene as required. The four man team would use these emergency lights only if normal lighting had failed or was inadequate.

NRC-10 Set up and operate emergency communications equipment.

See response to NRC-3 for the in-plant emergency communications set up for a fire emergency.

Communications available in the control rocm includes:

1. Telephone communications, three outside lines.

2. Two-way radio connunication, County Sheriffs Department, checked daily.

3. Dedicated telephone line to the Wisconsin Electric System Control Center in Milwaukee (red phone).

4. Dedicated telephone line to all Wisconsin Electric Power Company plants. Plant trouble line (beige ch'Te).

PF49-10

5. Two-way radio communications with the Wisconsin Electric dispatcher in Appleton, Wisconsin.

6. Two channel FM radio console monitor and transmitter.

7. Two channel GAI-TRONICS telephone system.

NRC-ll Rescue injured personnel.

The Fire Brigade will rescue all injured personnel. This rescue may be accomplished by the first man arriving at the scene or a cocrdinated effort by the entire four man attack team. The injured man will be relocated to a safe area where security personnel can administer first aid and/or evacuate the injured man.

If a fire brigade member is the injured person and the fire condi-tions dictate, the FBC will order a control operator to replace this brigade member until outside assistance arrives.

NRC-12 Maintain fire fighting activities if supporting personnel are delayed.

PBNP's seven shif t operations personnel are all fully trained fire brigade members. The FBC would direct the control room personnel to prepare to relieve the four man attack team as may be required regardless of any expected or unexpected delays to supporting personnel.

If extended fire fighting activities are required (more than 20 minutes), the two control operators and the operations supervisor would be rotated, one at a time, to relieve the other fire brigade members.

Since each emergency call-in fire brigade member will be arriving in a private automobile, and some of the Two Creeks Volunteer Fire Department personnel will arrive by private automobiles, the likelihood of all supporting personnel being delayed is very remote.

Component Cooling Pump Area 1.0 Protection Design Summary Detection Ionization and photoelectric detectors, sprinkler system actuation, roving operation personnel.

Suppression Automatic wet pipe sprinkler system, four 1-1/2" standard industrial hard rubber hose stations with industrial fog nozzle, one 100 lb. CO2 wheeled unit, one 150 lb. ABC Dry Chemical wheeled unit, several hand portable CO2, dry chemical and water extinguishers. Other equipment located in the plant available as required.

PF49-11

Ventilation Primary Auxiliary Building normal supply and exhaust systems, two portable smoke and heat ejectors.

Other Features Controlled personnel access at all times, controlled main-tenance activities, controlled ignition source area, storage not allowed, area partially protected by three-hour rated fire barriers, all cable trays in the area are protected with fire retardant blankets, pump power cabling is in separate conduits, motors water spray shielded, pump and motors mounted on 6" pedestals, and floor cable tray minimum clearance approximately seven feet.

2.0 Fire Scenarios 2.1 A 2-1/2 gallon plastic jug containing flammable solvent is left undetected in this room and was ignited by some means. The resulting fire destroys the container causing a spill fire on the floor.

2.2 A single cable tray assembly is burning, emitting large quantities of smoke making positive location of the burning tray difficult (obscuring).

3.0 12 Point PF-49 Analysis NRC-1 Transport support equipment to the scene of the fire.

Transportation of support equipment will be accomplished by the two A0's on orders from the FBC. All equipment is mounted on four wheel hand carts (smoke ejectors and duct, SCBA, hand tools, additional hose, foam equipment, emergency lights, etc.). These carts are located near the fire brigade ready station and other designated locations. Additionally, guard force pertinnel can be mobilized to bring large wheeled equipment and carts to the scene.

NRC-2 Assess fire conditions; command, and direct the fire fighting activities.

The FBC performs these functions, or delegates this responsibility to the Assistant FBC (operation supervisor).

NRC-3 Communicate with the control room or remote snutdown panels.

The FBC will establish FM radio communications and direct all emergency activities.

FM radio communications will be established during fire emergency.

A two channel system is utilized, (1) channel for security and (1) chaanel for operations and plant emergencies.

The security CAS monitors both channels as does the plant control room. The A0's reporting to the fire brigade ready station will man the FM radio provided. Operators reporting to remote shutdown panels will also use FM radio communication as required.

The GAI-TRONICS two channel phone system provide backup to the FM radios.

PF49-12

NRC-4 Lay and maneuver fire hose.

The component cooling pump area can be reached from four (4) different hose reels in the PAB giving the fire brigade great flexibility. Depending on the situation, heat and smoke, obstacles, etc. , one, two or all four brigade members will handle and maneuver fire hose.

Additionally, one 1-1/2" or one 1" hard rubber hose could be brought from the Unit #2 Turbine llall via the eight foot elevation emergency access between the PAB and Turbine llall.

When outside plant assistance arrives, additional hose lines could be layed from the loop hydrant connections to the CCP area. In this case, the CCP area can be reached with 200 feet of hose from the pump house hydrant connection via the eight foot elevation Unit #2 Turbine Hall-PAB emergency access door.

NRC-5 Locate fire and apply the extinguishment to the fire.

Well developed fire (flaninable liquid spill fire) location of a well developed fire will be accomplished by the first fire brigade member to arrive at the fire scene (A0 or FBC).

Extinguishment methods 2, 3 and 4 described in the general plan would be applicable. Dry chemical hand or wheeled portable extin-guishers would be used in the first attempt to extinguish the flannable liquid fire. If this effort failed, the 1-1/2" hose line(s) would be used to cool and extinguish the fire. If the fire was still not under control, the fully protected AO's would advance one or two 1-1/2" hose lines water fog and/or foam application.

Agent application will be determined by the amount of heat, smoke, open flame and type of equipment involved in the fire.

Obscure Fire (cable tray)

For the smoky cable tray fire, full protection will be required by all involved fire brigade members prior to location and extinguishment.

The FBC w'll have the PAB ventilation system adjusted to aid in smoke and heat cemoval, and set up the portable smoke ejectors to help locate the burning cable tray. Water fog will be used to help disperse the smoke and control heat generation. When the general area of the fire has been located and if smoke conditions allow, extinguishment may be tried using a wheeled CO2 or dry chemical unit. If conditions do not allow, or CO2 and dry chemicals are not successful, water fog application will be used to extinguish the cabic fire.

NRC-6 Set up and operate portable ventilation equipment.

The PAB supply and exhaust ventilation system will be adjusted to aid smoke and heat removal from the area. This system is controlled from the control room. Orders from the' FBC will be given as to what must be adjusted. Portable smoke ejector equipment, two units, will be transported to the area by the A0's. Set up will be PF49-13

accomplished by the four man team. Depending on conditions, one man may be required to continuously adjust these units to gain good access to the fire. In the case of the obscure fire, close coordination between the ver,tilation man and the hose team may be required.

NRC-7 Charge and replace respirator air bottles.

Ten Bio Pak 60p SCBA are available exclusively for fire brigade use. Before these ten units can be expended, additional fire brigade members will be on site and available to provide refill if needed. The plant will have a cascade 02 bank that will provide more than 100 sixty-minute refills. Refill of the small 02 cylinders can be accomplished by one man in less than ten minutes per cylinder.

Some units are wall mounted at the fire brigade ready station for fast donning by the fire brigade and some units are cart mounted for easy transportation to the fire scene.

This SCBA unit was selected to eliminate the compressed air-bottle system burden placed on fire fighters. The equipment literature details this recently NIOSH approved SCBA unit.

NRC-8 Direct and coordinate offsite department personnel.

Coordinated prefire planning and annual drills with the Two Creeks Volunteer Fire Department have been established. Security personnel clear the Two Creeks Volunteer Fire Department rapidly for entry and escort the department to an area designated by the FBC. All fire fighting activities are directed by the FBC. Extinguishment may be directed by the Two Creeks Volunteer Fire Department leader under orders from the FBC.

NRC-9 Set up and operate emergency lights.

Portable emergency lights (carpenter lanterns) are located at several locations throughout the plant and at the fire brigade ready station.

The lights would be brought to the fire scene as required. The four man team would use these emergency lights only if normal lighting had failed or was inadequate. .

NRC-10 Set up and operate emergency communications equipment.

See response to NRC-3 for the in-plant emergency communications set up for a fire emergency.

Communications available in the control room includes:

1. Telephone communications, three outside lines.

2. Two-way radio communication, County Sheriffs Department, checked daily. .

PF49-14

3. Dedicated telephone line to the Wisconsin Electric System Control Center in Milwaukee (red phone).

4. Dedicated telephone line to all Wisconsin Electric Power Company plants. Plant trouble line (beige phone).

5. Two-way radio communications with the Wisconsin Electric dispatcher in Appleton, Wisconsin.

6. Two channel FM radio console monitor and transmitter.

7. Two channel GAI-TRONICS telephone system.

NRC-ll Rescue inured personnel.

The Fire Brigade will rescue all injured personnel. This rescue may be accomplished by the first man arriving at the scene or a coordinated effort by the entire four man attack team. The injured man will be relocated to a safe are'. where security personnel 'can administer first aid and/or evacuate the injured man.

If a fire brigade member is the injured person and the fire conditions dictate, the FBC will order a control operator to replace this brigade member until outside assistance arrives.

NRC-12 Maintain fire fighting activities if supporting personnel are deleyed.

PBNP's seven shift operations personnal are all fully trained fire brigade members. The FBC would direct the control room personnel to prepare to relieve the four man attack team as may be required regardless of any expected or unexpected delays to supporting personnel.

If extended fire fighting activities are required (more than 20 minutes), the two control operators and the operations supervisor would be rotated, one at a time, to relieve the other fire brigade members.

Since each emergency call-in fire brigade member will be arriving in a private autotobile, and some of the Two Creeks Volunteer Fire Department personnel will arrive by private automobiles, the likelihood of all supporting personnel being delayed is very remote.

Auxiliary Feed Pump Area 1.0 Protection Design Sunmarv Detection Ionization and photoelectric detectors, roving operations personnel.

Suppression Two 1" hard rubber hose stations specially equipped with ball shut off valve and adjustable fog nozzle, two 1-1/2" standard industrial hard rubber hose stations with industrial fog straight stream nozzle, one 100 lb. CO2 wheelec unit, two 150 lb. ABC dry chemical wheeled units, several hand portable CO2, dry chemical and water extinguishers, other equipment located in the plant available as required.

PF49-15

Ventilation The AFP area has two recirculation ventilation units, fresh air suppy is accomplished via fire dampered openings from the Turbine Hall. Exhaust is accomplished via the 4160 volt vital switchgear room through the battery room's exhaust fans.

Other Features Controlled personnel access at all times, controlled main-tenance activities, controlled ignition source area, limited hose storage allowed in spare cubicles, all cable trays in the area are protected with fire retardant blankets, pumps separated by concrete walls, pumps mounted on pedestals, floor cable tray minimt a clearance approximately ten feet, three hour rated personnel access tunnel partially separates pump area from remote safe shutdown panels.

2.0 Fire Scenarios 2.1 A 2-1/2 gallon plastic jug containing flammable solvent is left undetected in this room and is ignited by some means. The resulting fire destroys tha container causing a spill fire on the floor.

2.2 A single cable tray assembly is burning, emitting large quantities of smoke making positive lccation of the burning tray diffic;1t (obscuring).

3.0 12 Point PF-49 Analysis NRC-1 Transport support equipment to the scene of the fire.

Transportation of support equipment will be accomplished by the two A0's on orders from the FBC. All equipment is mounted on four wheel hand carts (smoke ejectors and duct, SCBA, hand tools, additional hose, foam equipment, emergency lights, etc.). These carts are located near the fire brigade ready station and other designated locations. Additionally, guard force personnel can be mobilized to bring large wheeled equipment and carts to the scene.

NRC-2 Assess fire conditions; command, and direct the fire fighting activities.

The FBC performs these functions, or delegates this responsibility to the Assistant FBC (operation supervisor).

NRC-3 Communicate with the control room or remote shutdown panels.

The FBC will establish FM radio communications and direct all emer-gency activities.

FM radio connunications will be established during fire emergency.

A two channel system is utilized, (1) channel for security and (1) channel for operations and plant emergencies.

PF49 16

The security CAS monitors both channels as does the plant control room. The A0's reporting to the fire brigade ready station will man the FM radio provided. Operators reporting to remote shutdown panels will also use FM radio coninunication as required.

Two GAI-TRONICS two channel phone system provide backup to the FM radios.

NRC-4 Lay and maneuver fire hose.

The AFP area can be reached with two 1-1/2" fire hoses from the fire protection standpipe system. Two 1" light weight, maneuverable booster hose reels have been installed to cover the Auxiliary Feed pump area. The 1" hose system is specially designed to provide quick water application and maximum personnel protection for individual fire fighters.

If a greater water quantity is required, the 1-1/2" hose system is available and can be handled easily by two men.

Depending on the situation, one, two or all four brigade members will handle and maneuver fire hoses.

When outside plant assistance arrives, additional hose lines can be layed from the hydrant connections to Auxiliary Feed Pump area.

In this case, the Auxiliary Feed Pump area can be reached easily from the pumphouse hydrant connection.

NRC-5 Locate fire and apply the extinguishment to the fire.

Well developed fire (flammable liquid spill fire)

Location of a well developed fire will be accomplished by the first fire brigade member to arrive at the fire scene (A0 or FBC).

Extinguishment methods 2, 3, and 4 described in the teneral plan would be applicable. Dry chemical hand or wheeled portable extinguishers would be used in the first attempt to extinguish the fire. If this failed, the 1" hose line(s) would be used to cool and extinguish the fire. If the fire was still not under control, the fully protected, A0's would advance a 1-1/2" water fog line or a 1-1/2" foam line.

I, gent application will be determined by the amount of heat, smoke, open flame and equipment involved in the fire.

Obscure Fire For the smoky cable tray fire, full protection will be required by all involved fire brigade members prior to location and extinguisnment.

The FCC will ventilate the AFP room to the turbine building using the two portable heat and smoke ejectors. Additional turbine building exhaust fans will be started to aid in removing the smoke. These smoke ejectors will be maneuvered to aid location of the burning cables. When the general area of the fire has been located and if PF49-17

smoke conditions allow, extinguishment will be tried using wheeled CO2 or dry chemical extinguishers. If this approach fails, the 1" hose (s) will be used to extinguish the fire. If greater quantities of water or additional range is needed, the 1-1/2" hose in the fog potition will be used to extinguish the fire.

NRC-6 Set up and operate portable ventilation equipment.

The AFP area normal ventilation system would be exhausting heat and smoke via the battery rooms exhaust fans to the turbine building.

These fans would be temporarily secured to prevent drawing large quantities of smoke into the 4160 volt vital switchgear room.

The portable heat and smoke ejectors (2) would be set up by the A0's to ventilation the AFP area directly to the turbine building. Doors located at opposite ends of the compartment would be propped open and the ejector units set up, both as fresh air supply, exhaust or some combination. Smoke control in this area requires portable ejector equipment.

NRC-7 Charge and replace respirator air bottles.

Ten Bio Pak 60p SCBA are available exclusively for fire brigade use.

These units have a sixty minute duration. Before these ten units can be expended, additional PBflP fire brigade members will be on site and available to provide refill if needed. The plant will have a cascade Op bank that will provide more than 100 sixty-minute refills.

Refill of the small 02 cylinders can be accomplished by one man in less than ten minutes per cylinder.

Some units are wall mounted at the fire brigade ready station for fast donning by the fire brigade and some units are cart mounted for easy transportation to the fire scene.

This SCBA unit was selected to eliminate the compressed air-bottle system burden placed on fire fighters. The equipment literature details this recently NIOSH approved SCBA unit.

NRC-8 Direct and coordinate offsite department personnel .

Coordinated prefire planning and annual drills with the Two Creeks Volunteer Fire Department have been established. PBNP security personnel clear the Two Creeks Volunteer Fire Department rapidly for entry and escort the department to an area designated by the FBC. All fire fighting activities are directed by the FSC.

Extinguishment may be directed by the Two Creeks Volunteer Fire Department leader under orders from the FBC.

NRC-9 Set up and operate emergency lights.

Portable emergency lights (carpenter lanterns) are located at several locations throughout the plant and at the fire brigade ready station.

The lights would be brought to the fire scene as required. The four man tcam would use these emergency light's only if normal lighting had failed or was inadequate.

PF49-18

NRC-10 Set up and operate emergency communications equipment.

See response to NRC-3 for the in-plant emergency communications set up' for a fire emergency.

Communications available in the control room includes:

1. Telephone communications, three outside lines.

2. Two-way radio communcation, County Sheriffs Department, checked daily.

3. Dedicated telephone line to the Wisconsin Electric System Control Center in Milwaukee (red phone).

4. Dedicated telephone lines to all Wisconsin Electric Power Company plants. Plant trouble line (beige phone).

5. Two-way radio communications with the Wisconsin Electric dispatcher in Appleton, Wisconsin.

6. Two channel FM radio console monitor and transmitter.

7. Two channel GAI-TRONICS telephone system.

NRC-11 Rescue injured personnel.

The Fire Brigade will rescue all injured personnel. This rescue may be accomplished by the first man arriving at the scene or a coordinated effort by the entire four man attack team. The injured man will be relocated to a safe area where security personnei can administer first aid and/or evacuate the injured man.

If a fire brigade member is the injured person and the fire conditions dictate, the FBC will order a control operator to replace this brigade member until outside assistance arrives.

NRC-12 Maintain fire fighting activities if supporting personnel are delayed.

PBNP's seven shift operations personnel are all fully trained fire brigade members. The FBC would direct the control room personnel to prepare to relieve the four man attack team as may be required regardless of any expected or ur- pected delays to supporting personnel .

If extended fire fighting activities are required (more than 20 minutes (, the two control operators and the operations supervisor would be rotated, one at a tim e, to relieve the otner fire brigade members.

Since each emergency call-in fire brigade member will be arriving in a private automobile, and some of the Two Creeks Volunteer Fire Department personnel will arrive by private automobiles, the likelihood of all supporting personnel being delayed is very remote.

PF49-19

4160 Volt Vital Switchgear Room 1.0 Protection Design Summary Detection Ioni71 tion and photoelectric detectors, roving operations personnel.

Suppression Two 1" hard rubber hose stations specially equipped with ball shutoff valve and adjustable fog nozzle, two 1-1/2" standard industrial hard rubber hose stations with industrial fog straight stream nozzle, one 100 lb. CO2 wheeled unit, two 150 lb. ABC dry chemical wheeled units, several hand portable CO2, dry chemical and water extinguishers.

Other equipment located in the piant available as required.

Ventilation Supply air from AFP room via fire damper opening, exhaust vic battery rooms exhaust fans, two portable smoke and heat ej ectors.

Other Features Controlled personnel access at all times, controlled main-tenance activities, controlled ignition source area, storage not allowed, room fully protected by three hour fire rated construction, all cable trays in the room are protected with fire retardant blankets.

2.0 Fire Scenarios 2.1 A 2-1/2 gallen plastic jug containing flammable solvent is left undetected in this room and is ignited by some means. The resulting fire destroys the container causing a spill fire on the floor.

2.2 A single cable tray assembly is burning, emitting large quantities of smoke making positive location of the burning tray difficult (obscuring).

3.0 12 Point PF-49 Analysis NRC-1 Transport support equipment to the scene of the fire.

Transportation of support equipment will be accomplished by the two A0's on orders from the FBC. All equipment is mounted on four wheel hand carts (smoke ejectors and duct, SCBA, hand tools, additional hose, foam equipment, emergency lights, etc.). These carts are located near the fire brigade ready station. Addi tionally, guard force personnel can be mobilized to bring large wheeled equipment and carts to the scene.

~

NRC-2 Assess fire conditions; command, and direct the fire fighting activities.

The FBC performs these functions, or delegates this responsibility to the Assistant FCC (operation supervisor).

PF49-20

NRC-3 Communicate with the control room or remote shutdown panels.

The FBC will establish FM radio communications and direct all emergency activities.

FM radio communications will be established during fire emergency.

A two channel system is utilized, (1) channel for security and (1) channel for operations and plant emergencies.

The security CAS monitors both channels as does the plant control room. The A0's reporting to the fire brigade ready station will man the FN radio provided. Operators reporting to remote shutdowa panels will also use FM radio comnunication as required.

The GAI-TROMICS two channel phone system provide backup to the FM radios.

NRC-4 Lay and maneuver fire hose.

The 4160 volt vital switchgear room can be reached with one 1-1/2" fire hose from the fire protection standpipe system.

One 1" light-weight, maneuverable booster hose reel has been installed to cover the 4160 Vital Switchgear Room. The 1" hose system is specially designed to provide quick water application and maximum personnel protection for individual fire fighters.

If a greater water quantity is required, the 1-1/2" hose system is available and can he handled easily by two men.

Depending on the situation, one, two or all four brigade members will handle and maneuver fire hoses.

When outside plant assistance arrives, additional hose lines can be layed from the hydrant connections to the in-plant fire area. In this case, the 4160 Vital Switchgear Room can be reached easily from the pumphouse hydrant connection.

NRC-5 Locate fire and apply the extinguishment to the fire.

Well developed fire (flammable liquid spill fire) location of a well developed fire will be accomplished by the first fire brigade member to arrive at the fire scene (A0 or FBC).

Extinguishment methods 2, 3, and 4 describcd in the general plan would be applicable. Dry chemical hand or wheeled portable extin-guishers would be used in the first attempt to extinguish the fire.

If this failed, the 1" nose line would be used to cool and extinguish the fire. If the fire was still not under control, the fully protected, A0's would advance a 1-1/2" water fog line or a 1-1/2" foam line. Agent application will be determined by the amount of heat, smoke, open flame, and equipment involved in the fire.

FF49-21

Obscure Fire For the smoky cable tray fire, full protection will be required by all involved fire brigade members prior to location and extinguishment.

The FBC will ventilate the 4160 Vital Switchgear Room to the turbine Additional building using the two portable heat and smoke ejectors.

turbine building exhaust fans will be started to aid in removing the smoke. These smoke ejectors will be maneuvered to aid location of the burning cables. When the general area of the fire has been located and if smoke conditions allow, extinguishmentIf thiswill be tried approach using wheeled CO2 or dry chemical extinguishers. If greater fails, the 1" hose will be used to extinguish the fire.

quantities of water or additional range is needed, the 1-1/2" hose in the fog position will be used to extinguish the fire.

NRC-6 Set up and operate portable ventilation equipment.

The 4160 volt switchgear room normal venti'.ation system would be exhausting heat and smoke via the battery rooms exhaust fan to the turbine building. Portable heat and smoke ejectors (2) would be set up by the AO's to increase the total capacity. Doors at the opposite ends of the room will be propped open and the portable units set up as both fresh air supply to the room, or exhaust to the turbine building or some combination, whichever is the most effective. Smoke control in this room will require the use of portable ejector equipment.

NRC-7 Charge and replace respirator air bottles.

Ten Bio Pak 60p SCBA are available exclusively for fire brigade use.

These units have a sixty minute duration. Before these ten units can be expended, additional PBNP fire brigade .nembers will be on site and available to provide refill if needed. The plant will have a cascade 02 bank that will provide more than 100 sixty-minute refills.

Refill of the small 02 cylinders can be accomplished by one man in less than ten minutes per cylinder.

Some units are wall mounted at the fire brigade ready station for fast donning by the fire brigade and some units are cart mounted for easy transportation to the fire scene.

This SCBA unit was selected to eliminate the compressed air-bottle system burden placed on fire fighters. The equipment literature details this recently U10SH approved SCBA unit.

NRC-8 Direct and coordinate of fsite department personnel .

Coordinated prefire planning and annual drills with Security the Two personnel Creeks Volunteer Fire Department have been established.

clear the Two Creeks Volunteer Fire Department rapidly for entry All and escort the department to an area designated by the FBC.

Extinguishment fire fighting activities are directed by the FBC.

may be directed by the Two Creeks Volunteer Fire Department leader under orders from the FBC.

PF49-22

NRC-9 Set up and operate emergency lights.

Portable emergency lights (carpenter lanterns) are located at several locations throughout the plant and at the fire brigade ready station. The lights would be brought to the fire scene as required. The four man team would use these emergency lights only if nonnal lighting had failed or was inadequate.

NRC-10 Set up and operate emergency connunication. equipment.

See response to NRC-3 for the in-plant emergency communications set up for a fire emergency.

Communications available in the control room includes:

1. Telephone communications, three outside lines.

2. Two-way radio communication, County Sheriffs Department, checked daily.

3. Dedicated telephone line to the Wisconsin Electric System Control Center in Milwaukee (red phone).

4. Dedicated telephone line to all Wisconsin Electric Power Company plants. Plant trcuble line (beige phone).

5. Two-way radio communications with the Wisconsin Electric dispatcher in Appleton, Wisconsin.

6. Two channel FM radio console monitor and transmitter.

7 Two channel GAI-TRONICS telephone system.

NRC-ll Rescue injured personnel.

The Fire Brigade will rescue all injured personnel. This rescue may be accomplished by the first man arriving at the scene or a coordinated effort by the entire four man attack team. The injuied man will be relocated to a safe area where security personnel can administer first aid and/or evacuate the injured man.

If a fire brigade member is the injured person and the fire conditions dictate, the FBC will order a control operator to replace this brigade member until outside assistance arrives.

NRC-12 Maintain fire fighting activities if supporting personnel are delayed.

PBNP's seven shift operations personnel are all fully trained fire brigade members. The FBC would direct the control room personnel to prepare to relieve the four man attack team, as may be required, regardless of any expected or unexpected delays to supporting personnel.

If extended fire fighting activities are required (more than 20 minutes), the two control operators and the Operations Supervisor would be rotated, one at a time, to relieve the other fire brigade members.

PF49-23

E Since each emergency call-in fire brigade member will be arriving in a private automobile, and some of the Two Creeks Volunteer Fire Department personnel will arrive by private automobiles, the likelihood of all supporting personnel being delayed is very remote.

Turbine Lube Oil Storage Room 1.0 Protection Design Summary Detection Photoelectric and ionization detectors, sprinkler system actuation, roving operations personnel.

Suppression Wet pipe automatic sprinkler system, two 1-1/2" standard industrial hard rubber hose stations with industrial fog straight stream nozzle, two 150 lb. dry chemical units and several hand held dry chemical extinguishers, other equipment located in the plant available as required.

Ventilation The room has a separate ventilation system from the turbine building. Fresh air is through a gravity vent that is fire dampered, the exhaust fan discharges outside to atmosphere.

Other Features Controlled maintenance activities, controlled ignition source area, approved storage only, no smoking area, room is fully protected by three hour fire rated construction, mai, storage tank is diked to hold full tank capacity and ten minutes of sprinkler operation, remote from any safety-related equipment, no exposed cabling in this room.

2.0 Fire Scenarios 2.1 A 2-1/2 gallon platic jug containing flamnable solvent is lef t undetected in this room and is ignited by some means. The resulting fire destroys the container causing a spill fire on the floor.

2.2 Obscure cable tray fire is not applicable for this room.

3.0 12 Point PF-49 Analysis NRC-1 Transport support equipment to the scene of the fire.

Transportation of support equipment will be accomplished by the two A0's on orders from the FBC. All equipment is mounted on four wheel hand carts (smoke ejectors and duct, SCBA, hand tools, additional hose, foam equipment, emergency lights, etc.). These carts are locatcJ near the fire brigade ready station. Additionally, guard force personnel can be mobilized to bring large wheeled equipment and carts to the scene.

NRC-2 Assess fire conditions; command, and direct the fire fighting activities.

The FBC perfonns these functions, or delegates this responsibility to the Assistant FBC (operation supervisor).

PF49-24

NRC-3 Communicate with the control room or remote shutdown panels.

The FBC will establish FM radio communications and direct all emer-gency activities.

FM radio communications will be established during fire emergency.

A two channel system is utilized, (1) channel for security and (1) channel for Operations and plant emergencies.

The security CAS monitors both channels as does the plant control room. The AO's reporting to the fire brigade ready station will man the FM radio provided. Operators reporting to remote shutdown panels will also use FM radio communication as required.

NRC-4 Lay and maneuver fire hose.

The turbine lube oil storage room is protected by two installed 1-1/2" hard rubber hose reels. Additional hose lines could be layed from the hydrant connections at the pumphouse or from the preconnected northeast hydrant.

These lines would be layed and maneuvered by the A0's as required and directed by the FBC.

NRC-5 Locate fire and apply the extinguishment to the fire.

Well developed fire (flammable liquid spill fire)

Locatien of a well developed fire will be accomplished by the first fire brigade member to arrive at the fire scene (A0 or FBC).

Extinguishmcnt methods 2, 3, and 4 described in the general plan would be applicable. Dry chemical' hand or wheeled portable extin-guishers would be used in the first attempt to extinguish the fire.

If this failed, 1-1/2" hose lines would be used to extinguish the fi re. If the fire was still not under control, the fully protected A0's would advance a 1-1/2" water fog or 1-1/2" foam line. Agent application will be determined by the amount of heat, smoke, open flame, and additional combustibles involved in this fire.

NRC-6 Set up and operate portable ventilation equipment.

The nonnal ventilation system would be exhausting heat and smoke to the outside.

Portable heat and smoke ejectors (2) would be set up by the A0's to increase the total capacity. Doors at the opposite ends of the room will be propped open and the portable units set up as both fresh air supply to the room or exhaust to the turbine building or some combination, whichever is the most effective. Smoke control in this room inay require the use of portable ejector equipment.

NRC-7 Charge and replace respirator air bottles.

Ten Bio Pak 60p SCBA are available exclusively for fire brigade use.

These units have a sixty minute duration. Before these ten units can be expended, additional PBNP fire brigade members will be on PF49-25

site and available to provide refill if needed. The plant will have a cascade 02 bank that will provide more than 100 sixty-minute refills.

Refill of the small 02 cylinders can be accomplished by one man in less than ten minutes per cylinder.

Some units are wall mounted at the fire brigade ready station for fast donning by the fire brigade and some units are cart mounted for easy transportation to the fire scene.

This SCBA unit was selected to eliminate the compressed air-bottle system burden placed on fire fighters. The equipment literature details this recently NIOSH approved SCBA unit.

NRC-8 Direct and coordinate offsite department personnel.

Coordinated prefire planning and annual drills with the Two Creeks Volunteer Fire Department have been established. Security personnel clear the Two Creeks Volunteer Fire Department rapidly for entry and escort the department to an area designated by the FCC. All fire fighting activities are directed by the Fl:C. Extinguishment may be directed by the Two Creeks Volunteer Fire Department leader under orders from the FBC.

NRC-9 Set up and operate emergency lights.

Portable emergency lights (carpenter lanterns) are located at several locations throughout the plant and at the fire brigade ready station.

The lights would be brought to the fire scene as required. The four man team would use these emergency lights only if nonnal lighting had failed or was inadequate.

NRC-10 Set up and operate emergency communications equipment.

See response to NRC-3 for the in-plant emergency communications set up for a fire emergency.

Communications available in the control room includes:

1. Telephone communications, three outside lines.

2. Two-way radio communication, County Sheriff Department, checked daily.

3. Dedicated telephone line to the Wisconsin Electric System Control Center in Milwaukee (red phone).

4. Dedicated telephone line to all Wisconsin Electric Power Company plants. Plant trouble line (beige phone).

PF49-26

5. Two-way radio communications with the Wisconsin Electric dispatcher in Appleton, Visconsin.

6. Two channel FM radio console monitor and transmitter.

7. Two channel GAI-TRONICS telephone P. A. system.

NRC-Il Rescue injured personnel.

The Fire Brigade will rescue all injured personnel. This rescue may be accomplished by the first man arriving at the scene or a coordinated effort by the entire four man attack team. The injured man will be relocated to a safe area where security personnel can administer first aid and/or evacuate the injured man.

If a fire brigade member is the injured person and the fire conditions dictate, the FBC will order a control operator to replace this brigade member until outside assistance arrives.

NRC-12 Maintain fire fighting activities if suppor;ing personnel are delayed.

PBNP's seven shift operations personnel are all fully trained fire brigade members. The FBC would direct the control room personnel to prepare to relieve the four man attack team, as may be required, regardless of any expected or unexpected delays to supporting personnel.

If extended fire fighting activities are required (more than 20 minutes), the two control operators and the Operations Supervisor would be rotated, one at a time, to relieve the other fire brigade members. Since each emergency call-in fire brigade member will be arriving in a private automobile, and some of the Two Creeks Volunteer Fire Department personnel will arrive by private automobiles, the likelihood of all supporting personnel being delayed is very remote.

Circulating Water Pump House 1.0 Protection Design Summary Detection Ionization and photoelectric detectors, sprinkler system actuation, roving operations personnel.

Suppression Wet pipe sprinkler system protecting the service water pumps and the fire water pumps, two 1-1/2" standard industrial hard rubber hose stations with industrial fog straight stream nozzle, several hand portable CO2 and dry chemical extinguishers.

Other equipment located in the plant available as required.

Ventilation Normal ventilation is accomplished with roof exhaust fans and louvered make up supply vents, two large roll-up doors on opposite ends of the building for gravity venting, two fixed air movers supplying makeup to service water pump area and two portable heat and smoke ejectors.

PF49-27

Other Features ,

Controlled personnel access at all times into the safety-related areas of the pump house, controlled maintenance activities, controlled ignition source area, combustible storage not allowed, pump power cables in separate conduits, emergency diesel fire pump diked and drained to prevent fuel oil spill spread, plant vehicle parking allowed near ends of building.

2.0 Fire Scenarios 2.1 A 2-1/2 gallon plastic jug containing flammable solvent is lef t undetected in this roors and is ignited by some means. The resulting fire destroys the container causing a spill fire on the floor.

2.2 A single cable tray assembly is burning, emitting large quantities of smoke making positive location of the burning tray difficult (obscuring).

3.0 12 Point PF-49 Analysis NRC-1 Transport support equipment to the scene of the fire.

Transportation of support equipment will be accomplished by the two A0's on orders from the FBC. All equipment is mounted on four wheel hand carts (smoke ejectors and duct, SCBA, hand tools, additional hose, foam equipment, emergency lights, etc.). These carts are located near the fire brigade ready station. Additionally, guard force personnel can be mobilized to bring large wheeled equipment and carts to the scene.

NRC-2 Assess fire conditions; command, and direct the fire fighting activities.

The FBC performs these functions, or delegates this responsibility to the Assistant FBC (operation supervisor).

NRC-3 Communicate with the control room or remote shutdown panels.

The FBC will establish FM radio communications and direct all emer-gency activities.

FM radio communications will be established during fire emergency.

A two channel system is utilized, (1) channel for security and (1) channel for operations and plant emergencies.

The security CAS monitors both channels as does the plant control room. The AO's reporting to the fire brigade ready station will man the FM radio provided. Operators reporting to remote shutdown panels will also use FM radio conmunication as required.

The GAI-TRONICS two channel phone and system provide backup to the FM radios.

PF49-28

HRC-4 Lay and maneuver fire hose.

The CWPH has two installed 1-1/2" hard rubber hose reels located such that either hose can cover the safety-related area of the pump house. The northeast and southeast hydrant hose houses have 2-1/2" hose with a 2-1/2" to 1-1/2" gated Y pre-connected for fast hose laying. Either hose house can be utilized for pumphouse protection.

Depending on the situation, heat and smoke, obstacles, etc., one, two or all four brigade members will handle and maneuver fire hose.

When outside plant assistance arrives, additional lines can be layed from the hydrant connections.

URC-5 Locate fire and apply the extinguithment to the fire.

Well developed fire (flammable liquid spill fire)

Location of the well developed fire will be accomplished by the first fire brigade member to arrive at the fire scene (A0 or FBC).

Extinguishment methods 2, 3, and 4 described in the general plan would be applicable. The first attempt to extinguish this fire would be with hand held dry chemical or wheeled dry chemical extinguishers brought from the turbine building elevation 8'-0". If this effort failed, the 1-1/2" installed hose line(s) would be used to extinguish the fire. If the fire is still not under control, fully protected AO's would advance 1-1/2" hose line(s). (Uater fog or foam application.) These lines could be either the installed 1-1/2" line or lines from the northeast or southeast hydrants.

Obscure Fire Only two lightly loaded exposed cable trays exist in the pumphouse.

Therefore, the smoky cable tray fire does not apply. Additionally, the roll up doors allow for free venting of any fire that might occur in the pumphouse thus making an obscure fire scenario even less likely.

NRC-6 Set up and operate portable ventilation equipment.

The normal ventilation system would be very effective in removing heat and smoke. The large roll up door located at each end of the pumphouse would allow free venting for any fire that might occur, therefore, allowing gcod access to the fire. If portable ventilation equipment were required, the A0 would set it up and operate per the FBC instructions.

NRC-7 Charge and replace respirator air bottles.

Ten Bio Pak 60p SCCA are available exclusively for fire brigade use.

These units have a sixty minute duration. Before these ten units can be expended, additional PBUP fire brigade members will be on site and available to provide refill if needed. The plant will have a PF49-29

cascade 02 bank that will provica more than 100 sixty-minute refills.

Refill of the small 02 cylinders can be accomplished by one man in less than ten minutes per cylinder.

Some units are wall mounted at the fire brigade ready station for fast donning by the fire brigade and some units are cart mounted for easy transportation to the fire scene.

This SCBA unit was selected to eliminate the compressed air-bottle system burden placed on fire fighters. The equipment literature details this recently NIOSH approved SCBA unit.

NRC-8 Direct and coordinate offsite department personnel.

Coordinated prefire planning and annual drills with the Two Creeks Volunteer Fire Department have been established. Security personnel clear the Two Creeks Volunteer Fire Department rapidly for entry and escort the department to an area designated by the FCC. All fire fighting activities are directed by the FBC. Extinguishment may be directed by the Two Creeks Volunteer Fire Department leader under orders from the FBC.

NRC-9 Set up and operate emergency lights.

Portable emergency lights (carpenter lanterns) are located at several locations throughout the plant and at the fire brigade ready station. The lights would be brought to the fire scene as required. The four man team would use these cmergency lights only if normal lighting had failed or was inadequate.

HRC-10 Set up and operate emergency communications equipment.

See response to NRC-3 for the in-plant emergency communications set up for a fire emergency.

Connunications available in the control room includes:

1. Telephone communications, three outside lines.

2. Two-way radio communication, County Sheriffs Department, checked daily.

3. Dedicated telephone line to the Wisconsin Electric System Control Center in 11ilwaukee (red phone).

4. Dedicated telephone line to all Wisconsin Electric Power Company plants. Plant trouble line (beige phone).

5. Two-way radio communications with the Wisconsin Electric dispatcher in Appleton, Wisconsin.

PF49-30

6. Two channel FM radio console monitor and transmitter.

7. Two channel GAI-TRONICS telephone P.A. system.

NRC-ll Rescue injured personnel.

The Fire Brigade will rescue all injured personnel. This rescue may be accoa.plished by the first man arriving at the scene or a coordinated effort by the entire four man attack team. The injured man will be relocated to a safe area where security personnel can administer first aid and/or evacuate the injured man.

If a fire brigade member is the injured person and the fire conditions dictate, the FBC will order a control operator to replace this brigade member until outside assistance arrives.

NRC-12 Maintain fire fighting activities if supporting personnel are ( layed.

PBNP's seven shift operations personnel are all fully trained fire brigade members. The FBC would direct the control room personnel to prepare to relieve the four man attack team as may be required regardless of any expected or unexpected delays to supporting personnel.

If extended fire fighting activities are required (more than 20 minutes), the two control operators and the Operations Supervisor would be rotated, one at a time, to relieve the other fire brigade members.

Since cach emergency call-in fire brigade member will be arriving in a private automobile, and some of the Two Creeks Volunteer Fire Department personnel will arrive by private automobiles, the likeli-hood of all supporting personnel being delayed is very remote.

Conclusion Following fire detection and notification, fire extinguishment is dependent upon the following conditions:

1. Response time.

2. Building familiarity.

3. Extinguishing capability.

4. Injury and facigue.

1. Response Time Following notification, a municipal fire department is faced with a longer response time than on site personnel. This interlude allows for further development and spread of a fire. The trained on site PBNP fire brigade has a much shorter response time which enhances their capability to contain and extinguish a fire.

PF49-31

2. Building Familiarity A municipal . fire department usually possesses limited knowledge of building configuration and content which requires a significant effort to locate a fire and implement fire fighting plans. The PBi1P fire brigade is compc ed of operating personnel who are intimately familiar with the plant configura-tion, equipment location, equipment function, hazard size and hazard locations. They are also trained in prefire fighting plans for all plant areas. Therefore, the on site fire brigade can more readily accomplish the implementation of fire fighting activities.

3. Extinguishing Capability A municipal fire department is faced with laying hose from an external source to the fire location. Limited numbers of portable extinguishers must also PBf1P is provided with be carried frcm the truck to the fire location.

inter:or hose stations and many portable extinguishers which are readily available adjacent to anticipated fire areas. The manpower requirenent to transport extinguishing agents to the fire is thereby significantly reduced.

4. Injury and Fatigue _

In the event of injury, a municipal (five man) fire department attack team must remain self sufficient (four or fewer men) until backup personnel, who are also faced with a longer response time, arrive at the fire scene. In reality, a maximum four man municipal fire fighting team faced with unknown hazards in unfamiliar surroundings is expected to function adequately for At PBilP, a period of 20 to 30 minutes following notification of the fire.

one man may leave the control am in emergency situations to replace an injured fire fighter. Based upon the results of the August 31, 1978 drill, backup fire fighters will be on the scene 10 to 15 minutes following notification of a fire. Therefore, the PBftP fire brigade provides a four man fire fighting team, faced with know, hazards in very familiar surroundings, which is required to function adequately for a period of only 10 to 15 minutes.

Because of the demonstrated short response time for backup personnel and because PBilP fire brigade members are required to pass physical examinations as described in response to staff position PF-35, fatigue is not considered to be a major problem during the short period of unsupported fire fighting activi ty.

A municipal fire department receives traffic control support from the police department. In a municipality, these duties require the full attention of the assigned police. PBilP is designed and constructed for controlled acc!ss.

Part of the security duty shift is assigned to traffic control. Other on-duty security personnel are stationed within the plant or assigned patrol duties. Security personnel are trained to respond to emergency situations.

Therefore, part of the security duty shift would be available to support the fire brigade in a fire emergency. Security personnel receive fire extinguisher training only and would not be expected to participate in attacking a major fire. Security personnel are trained to provide emergency medical assistance and would be relied upon to treat and transport injured personnel in a fire emergency. They could also aid in transporting equipment to the fire scene and could aio in laying hose under the direction of a trained fire brigade member. The PBilP fire attack team can therefore rely upon the availability of three security personnel for support activities.

PF49-32

Attachment A to the flRC document "fianpower Requirements for Operating Reactors" references career fire service five man attack team as a basis for a five man fire brigade. On this basis, we consider the above comparison to be valid. The above comparison demonstrates that the PBNP trained fire brigade can provide a fire fighting team of equal or better effectiveness than that of a municipal fire department. With security personnel support, PBilP can provide a minimum of seven personnel to perform the duties of a municipal five man initial fire attack team. The in-depth analyses conclusively demonstrates that the PBNP four man fire brigade can suitably accomplish all functions necessary in the event of the postulated fire in any plant area. Therefore, the PBNP four man fire brigade is adequate and justified.

49-2 The current PBNP fire protection organization and administration program has been developed to meet the requirement of many controlling organizations. PBNP's organization and program reflects the fire protection requirements of state, local and Federal authorities and of fire insurance carriers.

The original PBNP fire protection organization and program has undergone many revisions during the ten-year operating history of the plant. The original PBNP fire brigade organization and administrative programs were developed by the plant operations group utilizing NFPA codes and fJ1L Fire Insurance Standard for Nuclear Power Plants. Mill approved this program following a detailed review by their fire protection consultant. Upgrading and improvements in the PBNP organization and administrative program resulted from these reviews and audits. The overall growth of the plant fire brigade fire protection and prevention knowledge through years of training has also contributed to improvements.

Since the Brown's Ferry fire, there has been an on-going effort to upgrade PBNP program to meet the new requirements as they are issued or developed. The participation by the Nuclear Projects Office, the System Fire Protection Officer and the PBNP operation staff in the development of the fire hazard analysis of PBNP, the review and implementation of recent NRC guides such as BTP 9.5.1,

.. 9.5.1 Appendix A, Proposed Regulatory Guide 1.120 and the NRC Nuclear Plant Fire Protection Functional Responsibilities, Administrative Control and Quality Assurance documents have increased the Licensee's fire prevention and protcction knowledge.

The PBNP fire protection organization and administrative program is typical of all plant operational programs currently in use. A balanced approach between plant originality and practicality and control organization requirements has been used historically at PBNP with proven successful results. A large portion of the credit for this successful performance record must be given to the PBNP Shift Supervisors (Fire Brigade Chiefs). These individuals have demonstrated consistently their ability to perform to the high standards set by the Nuclear Industry.

The basic fire protection plans developed by the Shift Supervisors are reviewed by the Wisconsin Electric System Fire Protection Officer, Nuclear Projects Office and the PBNP llanager's Supervisory staff for compliance with existing regulatory requi rements. When all groups, individuals and organizations are satisfied that the plans or procedures are in compliance and workable at the plant level, they are approved and implemented.

PF49-33

flRC staff approval or rejection of the general prefire plan and scenarios (PF-49 position 1) should te based totally on the merit of these plans and scenarios and not on the credentials of a particular individual. The plan and scenarios have evolved from years of accumulated operational experience, training, and drills as well as guidance from flRC,flFPA and insurance carrier documents.

The following table is a brief summary of Fire Protection experience of some of the individuals involved in the basic development of the PBilP fire protection prog ram.

The training programs conducted or completed by PBilP FBC's are briefly described to complement the table.

flavy Fire and Damage Control Training All PBilP FBC's completed basic and advanced flavy Fire Training. This training included fire protection basics, fire hose training, use of water fog and foam systems, fighting fire in windowless structures, smoke and heat control using installed and portable ventilation techniques and personnel rescue operations i.. obscured visibility conditions.

PBilP Original f!!il Approved Two-Year Training Program The program was administered by the individual FCC for each crew. Basic training in fire chemistry,1-1/2" and 2-1/2" fire hose, all types of fire extinguisher operation, fire pump and installed automatic protection system operation, emergency breathing equipuent operation and prefire strategy. Practice sessions on spill fires and Class A fires were conducted and supervised by a local fire protecticn equipment supplier.

n

_A_nsul Fire School All FBC's and Assistant FBC's have attended the Ansul Three-Day Industrial Fire School. The school broadened the backgrounds of the FBC's in the fire attack methods using dry chemicals supported with water fog and foam application on gasoline, fuel oil, and propane fires. These attack methods were supported by practice sessions that included paint locker, dip tank, trench, open spill, large pit, obstacle, and pressure fires.

PBi1P Current Revised Two-Year Training Progran The current two-year fire brigade training program has been expanded to include the new guidance as defined by the llRC administrative guidance document.

To upgrade the program initially, Lakeshore Technical Institute conducted a 16-hour program. This program was presented in 4 four-hour sessions. Each session included classroom presentations and ficid practice. The principal instructors for this program were the Fire Chief of Sheboygan, llisconsin, and the Milwaukee Fire Depart-ment Training Division Chief. These professional fire fighters were assisted by the PBttP FBC in field exercises and practice sessions. The following program schedule was followed.

PF49-34

Session 1 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />s: Classes of fires, chemistry of fires, hose handling.

Practice session on hose handling.

Session 2 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />s: Use of water on hazards associated with electrical fires.

Hose handling and use of fog nozzles on electric fires.

Practice using the 1" hose line with fixed fog applicator.

Session 3 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />s: Classroom and practice using fog and foam on Class B fires.

Practice included extinguishment of large pit fires.

Session 4 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />s: Classroom and practice in the use of smoke ejectors, fighting fires in windowless structures and the use of emergency breathing apparatus. Practice sessions were conducted also in personnel rescue.

PF49-35

FIRE PROTECTIO'l EXPERIEllCE TABLE PF-49 STAFF POSITI0fl 2 t

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Fire Brigade Chiefs Other Qualifications Crew A X X X X X Crew B _

X X ,

X X X X ,,,j I C.tgy G X X X X Crew D  ! Member VFD for seven years X X X  ! X i X

-j j 1 Orig. startup & testing of 511 Crew E X X X ,

X X I, PBitP fire p,rotection equipment l

Crew

. - = - X.- - .

X X

X ,

X X

Operations i ._Overa h 1 plant f, ire protecti.on Superintendent _ , X X X  ! X X d responsibility

__v Plant Training i  !

Supervisor X X X

,'._,.a X

Operations Tech- l nical Assistant ,

X X System Fire Administrated the PBitP Fire Protection Officei X X '

X X X Protection program for 5 years' lluclear Projects Office Engineer **

• The System Fire Protection Officer has attended the following fire protection programs:

1. Fire Protection for liuclear Power Plants presented by flational Loss Control Service Corporation and Professional Loss Control Inc.

2. liighly Protective Risk Training Program presented by Marsh & McLennan Protection Consultants.

3. Building Fire Safety Evaluation presented by Rexford Wilson Firepro Inc. and Robert Fitzgerald at the University of Wisconsin.

PF49-36

M The System Fire Protection Officer is a member of the Edison Electric Institute Fire Prevention and Protection Task Force and the NFPA. As administrator of the PBNP Fire Protection Organization for five years, he became thoroughly familiar with insurance and other control organization fire protection requirements. In the past three years, he has participated in all training, investigations, inspections, regulation evaluations, and engineering analysis associated with fire protection for PBNP.

• • The Nuclear Projects Office engineer provides design and technical support to the Point Beach fire protection program. He participated in the design and specification of the Point Beach fire protection system. He is familiar with code, insurance company and other control organizations fire protection requirements. He has participated in inspections, performed engineering evaluations and coordinated fire protection design and analysis work for Point Beach Nuclear Plant. He has attended the Building Fire Safety Evaluation presented by Rexford Wilson, Firepro Inc. and Robert Fitzgerald at the University of Wisconsin. He is a registered Professional Engineer in the State of Wisconsin and is a member of the American Society of Mechanical Engineers.

PF49-37