ML19338E481
| ML19338E481 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/19/1980 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19338E480 | List: |
| References | |
| NUDOCS 8010030010 | |
| Download: ML19338E481 (18) | |
Text
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l FIRE PROTECTION SAFETY EVALUATION BY TH:
01FICE OF NUCLEAR REACTOR REGULATION U. S. NUCLEAR REGULATORY COMMISSION IN THE MATTER OF METROPOLITAN EDIS0N COMPANY, JERSEY CENTRAL POWER AND LIGHT COMPANY, AND PENNSYLVANIA ELECTRIC COMPANY THREE MILE ISLAND NUCLEAR STATION, UNIT NO. 1 DOCKET NO. 50-289 SUPPLEMEN1AL NO. 4 Introduction By letters dated October 13, and November 1,1978, March 6 and 18, August 27, and December 28,1979, March 19 and May 30, 1980, Metropolitan Edison Company (Met Ed or the licensee), as required by the Fire Protection Safety Evalua-tion (FPSE) for Facility Operating License No. DPR.50 for the Three Mile Island Nuclear Station, Unit No.1 (Tril-1), submitted results of their studies on open items and plant modifications.
The specific items addressed in their studies are as follows:
3.1.1 Fire Detectors (4.2) 3.1.13 Reactor Coolant Pump (5.1) 3.2.3/3.1.6 Effects of Water Spray (4.3.16) 3.2.14 Fire Door Supervision (4.9.1) 3.1.11 Fire Barriers at Reactor Bldg. Emergency Cooling Valves (5.5) 3.2.1 Prctection of Emergency Feedwater Pumps (5.5) 3.2.13 Protection of Relay Room (5.1) 3.2.6/3.1.8 Unlabled Fire Doors (4.9.1) 8010 0s o
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. Met Ed also submitted by letter dated May 30, 1980, a revision to the schedule given in Table 3.1 of the FPSE for completing the modifications.
Our evaluation of these studies including the proposed revised schedule is complete and is the subject of this FPSE.
Background
On September 19, 1978, the Commission issued Amendment No. 44 to the TMI-l operating license. This amendment added a condition to the license which requires completion of the modifications and the completion of the incom-plete items identified in paragraphs 3.1.1 through 3.1.23 and paragraphs 3.2.1 through 3 .15 respectively, of the NRC's FPSE for TMI-1.
Amendment No. 44 also requires that as the items and modifications are completed or as additional information becomes available for our review, the fire pro-tection program will address those items in supplements to the Safety Evaluation.
The licensee susmitted by letters dated above, the necessary infcrmation to assure the requirements of Amendment No. 44 are met for the specific items identified above.
Evaluation 3.1.1 Fire Detectors (4.2)
FPSE Section 3.1.1 indicates that fire detectors will be installed on all levels of the reactor building, in several areas of the auxiliary building, in several areas of the intermediate building, in certain areas in the fuel handling building, and in safety-related control cabinets in the control room.
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s The licensee has submitted for review, design drawings showing the proposed location of the fire detectors throughout the reactor builidng, the auxiliary building, the intermediate building, certain areas in the fuel handling building, and i:. the area of the safety related control cabinets in the control room.
The proposed detectors will be either surface-mounted, field adjustable, dual chamber ionization type smoke detectors or dual chamber ionization type smoke detectors with air duct detector housing and sampling tube.
In addition, the proposed fire detector systems will pro-vide continuous supervision of power supply, detector and alarm signal ci rcui try.
The fire detection system design meets the recuirements in the NRC Branch Technical Position APCSB 9.5-1 Appendix "A" and NFPA 72.D.
The licensee has proposed to locate fire detectors outside the safety-related t
control cabinet because of space limitations inside the cab! net.
The licensee proposes to install icnization type detectors above each cabinet in the direct exhaust rir pathway. We agree with the licensee that the location of ionization type fire detectors 1]cated in the exhaust air pathway will give adequate detection of a fire inside the cabinet because of the highly sensi-tive nature of this type of detector. Also locating the detector in the exhaust air pathway further improves the senstivity in the detection of an incipient fire.
We have reviewed the licensee's fire detector systen design and find that it meets the intent of the modifications to improve the fire protection programs in Amendment No. 44, Section 3.1.1 titled " Fire Detectors". We therefore find the proposed action taken by the licensee regarding the selection of the fire detectors and establishing their locations throughout the plant is acceptable.
. Curbs in Reactor Building / Reactor Coolant Pump Lubricating 3.1.6/3.1.13 011 Collection System _
FPSE Section 3.1.6 indicates that curbs will be installed inside the secondary shield at elevation 281 feet of the reactor building to reduce the possible spread of oil from the reactor coolant pump motor lubrication systems and FPSE Section 3.1.13 indicates that the existing lube oil splash guard on the reactor coolant pumps will be modified to enclose the pump motor and to drain the collected oil in a drain tank located inside the secondary shield.
By letter dated August 27, 1979, the licensee submitted drawings and several photographs of the proposed lubricating oil collection system for the staff's review and requested deletion of the requirement of FPSE Section 3.1.6 (curbs in reactor building). The licensee's response transmitted by letter dated March 19, 1980 that the proposed system pro-vides a complete enclosure for all potential leakage points with exception It is of the oil level sight gauge on each reactor coolant pump motor.
necessary to leave the sight gauge visible in order to monitor oil level during pump operation. However, to reduce the possibility of damage to the sight gauge, the licensee informed us that a metal case is installed around the glass serving as a guard. The metal case is designed to protect the glass from external impacts and the location of the sight gauge assembly is away from frequently traveled routes.
During normal plant operation the sight gauges are in a restricted area, limiting personnel access that could result in the accidental damage of the sight gauge.
We agree with the licensee that adequate protection against accidental damage of the sight gauge that would result in oil spillage does exist and therefore we find this condition acceptable.
Strainers have not been provided for the drain piping.
Clogging of the drain piping may be a possibility in a new plant construction atmosphere but is less j
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. likely during current plant operation or refueling.
Part of the pump reintenanc s program the technician by procedure is cequired to check the drain pipes for clogging.
Additionally, clogging would be evident when the oil reservoirs are d ained for periodic inspection and subsequently corrected. The drain piping con-sists of three 2 inch diameter pipes and the possibility of all three pipes clog-ging simultaneously has been judged as unlikely. We agree with the licensee that strainers are not require f.
A stream of leaking oil would not hit the ventilation louvers on the outer splash shields since it would be deflected and drained by an inter-nal metal plate which totally encloses the upper oil reservoir. Any oil that might escape would be of reduced velocity and as a result of the angle of the ventilation louvers, would run down the side of the outer splash shield to the oil collection gutter and drained to the tanks. A clarifi-cation sketch of this system shows the potential' direction of the oil stream, the locations of ventilation louvers and the outer splash shield.
Based on the above, we agree with the licensee that curbs inside the secondary shields at elevation 281 feet of the reactor building (FPSE Seciton 3.1.6) are not needed since the proposed lubricating oil collection system is designed to be leak tight and any oil spillage will divert to the oil drain tanks. Therefore, the requirements of FPSE Section 3.1.6 need not be met and Section 3.1.6 should be deleted from Amendment No. 44.
Furthermore, as a result of our review of the licensee's proposed design of the reactor coolant pumps lubricating oil collection system, we find that this proposed system meets the requirements of the modification to improve the fire pro-tection program in Amendment No. 44, Section 3.1.13 titled " Reactor Coolant Pump Lubricating Oil Collection System". We find this item of the program acceptable.
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3.2.3 Effects of Water Spray (4.3.1.6)
FPSE Section 3.2.3 indicates that the licensee will analyze the effect of water spray to ensure that both divisions of safety-related equipment will not be incapacitated by rupture or inadvertent operation of the fire water system, or the application of fire hoses. Additional modification (s) will be provided as necessary.
The licensee, by letter dated December 28, 1978, reported the results of his analysis that indicated, all plant areas containing safety-related equipment necessary to bring the plant to a safe shutdown condition in the event of a fire had been reviewed. This review showed that water spray from fire protection sources will not simultanously incapacitate both divisions of safety-related equipment with the exception of tvo areas.
These two arecs ccatain safety-related electrical equipment cabinets which will be modified by installing drip shields to protect these cabinets from the effects of water spray. The licensee has agreed to these modifications.
As a result of our review of the licensee's December 28, 1978 submittal, we requested design drawings of typical drip shields for our review and requested additional information on the criterion used by the engineer in the study concerned with the effects of water spray on safety related equipment.
By letter dated March 19, 1980, the licensee responded to our concerns.
We reviewed the licensee's submittal regarding the design of the drip shields and found them acceptable in that water spray will be diverted from safety related electrical equipment during a fire fighting period.
i The criterion used by the engineer in this study consisted of the following:
. 1.
Adequate wall barriers separating safety related equipment:;do exist.
2.
Identified all equipment not susceptable to water damage, heat excahnger, valves, pipes, etc.
3.
Assure that adequate protection offered by cabinets-housing electrical equipment (i.e.,motorstarters, relays,etc.).
4.
Assure that adequate protection exists for electrical motors located throughout the plant such as those used for valve operators, motor operators, total enclosed fan coolers, etc.
5.
Assure that adequate concrete pedestals exist for raising engineered safeguard equipment off the floor.
6.
Assure that fire hoses that would be used for electrical fires are equipped with UL list fog nozzles eliminating straight stream capabilities.
Based on the above, we have concluded that the licensee had adequately analyzed to ensure that one division of safety-related equipment will be operable to i
bring the plant to a safe shutdown condition if the fire water system is ruptured or is operated or if fire hoses are applied.
We, therefore, find i
that the modifications and the analysis performed by the licensee for the effects of water sp~ ray are acceptable.
3.2.14 Fire Door Supervision (4.9.1)
FPSE Section 3.2.3 indicated that the licensee will provide to the staff his proposal with regard to (1) fire doors which are electrically locked and alarmed, (2) fire doors which are mechanically locked closed when not in use,
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and (3) fire doors which are neither locked nor alarmed but which are kept d
closed when not in use. We will address the acceptability of the licensee's proposal upon completion of our review of his submittal.
By letter dated November 1,1978, the licensee identified those doors that will be electrically locked and alarmed, mechanically locked closed and doors that will be neither locked nor alarmed. Our criterion for achieving adequate protection used in our review consisted of:
(1) maintaining fire i
doors closed when not in use, (2) the fire doors are electrically locked and alarmed or (3) the doors are mechanically locked closed.
On this basis, we requested the licensee to justify the decision not to supervise those fire doors that are neither locked nor alarmed.
By letter dated March 19, 1980, the licensee submitted additional justification for those fire doors that are neither locked nor alarmed. Additional justi-fication for exceptions to locking or electrical supervision are as follows:
)
1.
Three doors in the north wall of the Control Room will be neither locked or supervised since the Control Room, is constantly manned.
Because of extensive traffic, locking these fire doors will not only be an inconvenience during normal plant operation but could jeopardize safety during emergencies.
2.
The overhead door between the Fuel Handling Building and Reactor Building Personnel Access Area when replaced (commitment per SER Item 3.1.8) will be provided with automatic UL listed hold open and release mechanisms.
3.
All fire doors in the plant are provided with automatic closing mechanisms so when the door is not used, it automatically closes.
. 4.
Additional administrative controls have been established requiring:
that all fire doors protecting safety related areas that are locked closed will be inspected weekly to verify that the doors are locked closed are free of obstructions; that doors held open and provided with automatic release mechanisms will be inspected daily to verify that the doorway is free of osbtructions; and that fire doors neither locked or supervised will be kept closed (signs have been installed on all fire doors stating this rer;uirement) and are inspected daily to verify that they are in a closed position.
Based on our review of the licensee's submittal on his proposal for fire door supervision (SER 3.2.14) we find that adequate measures have been taken to assure that fire doors will be kept closed when not in use and therefore, measures taken by the licensee are acceptable.
3.1.11 Fire Barriers at Reactor Bldg. Emergency Cooling Valve (5.5)
FPSE Section 3.1.11 indicates.that the licensee will provide additional fire barriers to reduce the possibility of loss of function of the reactor building emergency cooling valves in the event of a fire in the valve gallery and penetration room i' 1e intermediate building.
By letters dated August P7,1979 and March and March 19, 1980, the licensee requested that since additional fire barriers are not necessary, this item should be deleted. This position is based on the results of a review con-ducted by the licensee that revealed the following:
1.
The combustible loading within this area is extremely low.
As noted in the Fire Hazard Analys'is Section 4.3.1.2, the fire loading consists i
. 2 of 8,500 BTU's/f t of cable insulation qualified by IEEE-383 as fire retardant. This material is extremely difficult to ignite (referenced in raronite barrier test results under SER Item 3.2.2) and also re-presents a poor ignition source to other combustibles in the area as a result of the qualifications of the cable and circuit design. Admin-2 istrative procedure AP 1035 limits transient combustibles to 8480 BTU's/ft 2
for an absolute max # aum fire loading of 16,980 BTU's/ft.
Based on NFPA criteria, this represents a fire loading that is considered a 13-minute fire zone.
2.
Two ionization type smoke detectors have been installed within this area (SER commitment 3.1.1).
This will provide early warning detection in the highly unlikely occurrence of a fire. These detectors are shown on drawing E-313-506 submitted with our letter GQL 0343 dated March 6, 1979.
3.
As noted in the Fire Hazard Analysis Section 4.3.1.2, fire protection for this zone consists of presently installed water and carbon dioxide fire extinguishers and fire hoses. The detection and suppression systems combined with the extremely low fire loading give excellent accessibility to the fire brigade and are therefore more than adequate to detect and extinguish the unlikely occurring fire. The actual fire loading in the area of the valves is much lower than that for the general fire area for which'the loading was calculated when considered as a local zone of influence fire.
Accessibility is considered as excellent because of
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access points from two elevations and near ambient temperatures for the general area under fire conditions based on the type of combustibles available, their distribution, likelihood of involvement, and the fire T
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loading. The rooin is cut-off from the remainder of the building by partial barriers with openings in these barriers not consnunicating to any significantly loaded area. The licensee submitted photographs of the area which we reviewed substaniating the above.
4.
In the improvable occurrence of a fire rendering the motor operator unusable, manual hand wheel control, independent of the motor, is available to open the valves.
5.
There is no possibility of. radiological releases occurring as a result of a fire in this area.
Based on the above, we agree with the licensee that an additional fire barrier at the reactor building emergency cooling valves are not necessary and adequate fire protection does exist in the area.
Therefore, Section 3.1.11 titled " Fire Barriers at the Reactor Bldg. Emergency Cooling Valve" may be deleted from Amendment No. 44, 3.2.1 Protection of Emergency Feedwater Pumps (5.5)
FPSE Section 3.2.1 indicates that the licensee will analyze the fire hazards in the emergnecy feedwater pump area and propose additional modification as necessary to preserve the safe shutdown capability.
By letter dated December 28, 1978, the licensee submitted the results of an evaluation of fire protection i
for the emergency feed pump area.
The design of this area incorporates par-i l
tial barrier walls and spatial separation of more than 35 feet between the i
motor-driven and turbine-driven pumps.
Combustible loading in the areas is low J
2 (i.e., loading for turbine driven pump area is 14,400 Btu /ft and the motor driven emergency feedwater 7,100 Btu /ft ).
Considering these conditions and the existing fire protection in the area which includes a detection system, the licensee concluded that adequate protection exists in the area and i,_..._.-.,....
. additional modification necessary to preserve the safe shutdown capability is not necessary. We conclude based on the licensee's initial submittal that positive evidence to justify such a position was not adequate. We requested that the licensee provide an analysis of fire hazards (i.e., lube oil of the turbine dirve pump and transient combustible) in the emergency feedwater ramp areas to support such a position.
By letter dated Maich 19, 1980, the licensee submitted a copy of the analysis prepared by Gilbert / Commonwealth Associates GAI/TM-lCS 2336 dated December 15, 1978. This analysis showed that if largest permissible quantity of lube oil 2
were spilled in one minute with all drains blocked, a burning area of l60 ft could be achieved which would be approximately 14.5 ft in diameter. Since a safe separating distance for such an oil fire is 7 feet and all equipment in this area is separated by at least 10 to 25 feet and partial barriers, it reasonable to assume that a single fir in the area will not damage more than one emergency feedwater pump.
Furthermore, the turbine driven emergency feedwater pump (which contains most of combustible lube oil) and the motor driven emergency feedwater pumps are separated by two parital barriers and a distance of more than 35 feet.
Based on the limited amount of combustible material in this area, the partial separation and the partial barriers between redundant safe shutdown equipment and the existing fire protection equipment we agree with the licensee that adequate fire protection exists in the area and additional protection to pre-serve the function of at least one emergency feedwater pump is not necessary.
Therefore, based on the above, the licensee has met the requirement of FPSE Section 3.2.1 of Amendment No. 44 and this matter is considered complete.
. 3.2.13 Protection of Relay Room (5.1)
FPSE Section 3.2.13 indicates that the licensee will identify those areas in the Relay Room where he proposes to provide a manually operated fixed water suppression system or will coat the electrical cables with an appropriate flame retardant coating.
The licensee has coninitted to an alternate shutdown capability which allows the safe shut-down of the plant independent of and concurrent with a complete loss of the relay room. This includes associated circuits that pass through the relay room which in themselves are not safe-shutdown related but are important to safety. e.g., fire pump, remote start circuits. The licensee has installed the following in meeting the NRC guideline, for fire protection in this area:
1.
A CO2 flooding system with reserve capacity actuated by heat detectors.
2.
Fire' hose station capable of supprest g any cable fire within the room.
3.
Fire extinguishers throughout the ror. and surrounding a mas.
4.
Cables qualified to IEEE-383 as fire retardant.
The preparation of strategies for fire fighting by the fire, rigade for this and all other safety related areas, administrative controls over trar sient combus-tibles and no smoking regulation is considered by the licensee as additional defense in depth in meeting the fire protection program guidelin s.
. Based on the above, the licensee has concluded that the fire protectior, program guidelines have been met and no additional fire protection mod-ifications for this area are required, We have evaluated the licensee's fire protection program for the relay room and we agree with the licensee's positicii in that no additional modifications are necessary.
The actions taken by the licensee are acceptable in that the intent FPSE for Section 3.2.13 of Amendment No. 44 have been met.
3.2.6/3.1.8 Unlabled Fire Doors / Fire Door (4.9.1)
FPSE Section 3.2.6 indicates that the licensee is to study the feasibility of establishing the adequacy of the fire resistance of unlabeled fire door and frame assemblies.
If the adequacy of the fire resistance of such assemblies cannot be established, they will be replaced by properly rated fire door assemblies.
FPSE Section 3.1.8 indicates that the Class A labeled fire doors will be installed, and existing unlabeled doors in various areas of the plant will be verified to have the correct rating or will be replaced with labeled doors.
By letters dated December 1,1978 and June 7,1979 and March 19,1980, the licensee submitted the results of a study establishina the adequacy of the fire resistance of all the TMI-1 fire doors including doors previously addressed as being completed. This study resulted in replacing several doors and frames with Class A labeled doors and frames.
In other areas having oversized doore, only the frames will be replaced.
However, the licensee proposed to retain some unlabeled fire doors on the basis that they are either oversized or it.ntical in construction to a Class A or B labeled fire door. The oversized doors which the licensee proposed to retain were
. fabricated in accordance with a label requirement but because of the sizes could not be subjected to the standard fire test as required for label attachment.
Furthemore, the licensee in support of the adequacy of the unlabled fire doors furnished a copy of a Certified Letter from the A/E (who is responsible for the engineering, procurement and the installation of the fire doors) certifying that all doors supplied were of similar construction whether labeled or unlabeled. The licensee has proposed to leave 11 unlabled fire doors in place since they are considered. adequate as fire protection barriers.
Five of the fire doors were purchased as Underwriters Laboratory Class B doors which are considered adequate for these locations and do meet the requirements of the Fire Protection Handbook (14th Edition, Section 6, Chapter
- 8) published by the National Fire Protection Association.
The total fire loadings were considered with the protection offered for the area and the fire loading is 1/2 hour less than the rating of the surrounding barriers for the fire areas.
Based on the licensee's submittal, the adequacy of the fire resistance of each door assembly has been established.
Further, we accept the licensee's proposed position that unlabeled fire doors are adequate to resist the postulated fire loading and therefore need not be replaced.
. IMPLEMENTATION OF MODIFICATION TABLE 3.1
Background
By letter dated May 30, 1980 (TLL 243) Met Ed responded to our request to revise Table 3.1 entitled " Implementation Date for Modifications".
Table 3.1 in the FPSE shows the implementation dates tied to the end of refueling outage in 1980. Because of the extended shutdown state of TMI-1, a calendar date for t..e refueling outage in 1980 will not occur and therefore we requested that Met Ed commit to calendar date for the remaining open item.
Evaluation The proposed revised Table 3.1 shows that the licensee committed to completing all remaining modifications (except for the alternate shutdown capbility, Item 3.1.21) by hovember 1,1980. The If;ensee committed to complete Item 3.1.21 the alternate shutdown capability by May 30, 1981. This commitment date is not consistent with the proposed rule change to 10 CFR 50, Appendix R which would require that this item be completed by April 1,1981.
This matter was brought to the attention of the licensee in the transmittal letter of Supplenent No. 3, dated July 21, 1980.
Since this issue has not been resolved with the licensee, the proposed revised Table 3.1 has been changed to show this as an open item.
This position was discussed with and agreed upon with the licensee.
In the proposed revised Table 3.1, Item 3.1.4 " Auto Sprinkler Systems or Coating of Electrical Cable" and Item 3.1.8 " Fire Doors" are shown having the revised completion dates extended from October 1,1980 to November 1,1980.
Since the licensee has not given any justification for this change, we have not modified these dates.
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' Item 3.1.5 "Halon Extinguishing System in Computer Room", Item 3.1.10 " Thermal Insulation and Valves" and Item 3.1.11 " Fire Barriers at Reactor Building Emergency Cooling Valves" are shown in tre proposed revised Table 3,1 as not required. We agree with this position en these items and the basis is givel in this supplement (as noted above) for Items 3.1,6 and 3.1.11 and Supplement No. 3 issued by letter dated July 21, 1980 gives the basis for Item 3.1,10.
Ne, therefore, find the position taken by the licensee acceptable in showing these items as not being required in Table 3,1.
We have reviewed the status of all remaining items that the licensee has comitted to a completion date of November 1,1980 and conclude that this date is acceptable.
Furthermore, this completi.on date is in agreement with the proposed completion date givea in the proposed rule of 10 CFR Part 50, Appendix R.
On this basis, we find the November 1, 1980 an acceptable completion date and should be reflected in Table 3.1 of Amendment No. 44.
Accordingly, the attached Table 3.1 supersedes Table 3.1 of the FPSE dated April 14, 1979.
Dated:
September 19, 1980 TABLE 3.1 Attachment to FPSE IMPLEMENTATION DATE FOR MODIFICATIONS 3.1.1 Fire Detectors 11/1/80 3.1. 2 Manual Hose Stations 11/1/80 3.1. 3 Automatic Water Spray Systems 11/1/80 3.1. 4 Automatic Sprinkler Systems or Coating of Electrical 10/1/80 Cables 3.1. 5 Halon Extinguishing System in Computer Room 11/1/80 3.1. 6 Curbs in Reactor Building Not Required 3.1. 7 Fire Dampers 11/1/80 3.1. 8 Fire Doors 10/1/80 3.1.9 Fire Barrier Penetrations Completed 3.1.10 Thermal Insulation on Valves Not Required 3.1.11 Fire Barriers at Reactor Building Emergency Cooling Not Required Valves 3.1.12 Fire Water Valve Seals Completed 3.1.13 Reactor Coolant Pump Lube Oil Collection System Completed 3.1.14 Separation of Computer Room from Control Room Completed 3.1.15 Electrical Cable Penetration Seals Completed 3.1.16 Battery Room Ventilation Air Flow Monitor Completed 3.1.17 Fire Fighting Plans Completed 3.1.18 Smoking Completed 3.1.19 Control of Combustibles Completed 3.1.20 Backup Manual Hose Coverage 11/1/80 3.1.21 Alternate Shutdown capability 0 PEN 3.1.22 Brigade Training Completed 3.1.23 Comunication Cable Penetrations Completed
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