ML20008E649
| ML20008E649 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 02/13/1981 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20008E644 | List: |
| References | |
| NUDOCS 8103090334 | |
| Download: ML20008E649 (14) | |
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SUPPLEMENT NO. 1 TO THE JULY 27, 1979 FIRE PROTECTION SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION j
U. S. NUCLEAR REGULATORY COMMISSION PROVISIONAL OPERATING LICENSE NO. OPR-45 DAIRYLAND POWER COOPERATIVE LA CROSSE BOILING WATER REACTOR DOCKET NO. 50-409 i
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1 Date: February 13, 1981 n
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8203o90#1
1.0 Introduction and Background On July 27, 1979, the Commission issued Amendment No. 17 to Provisional Operating License No. OPR-45 for the Lacrosse Boiling Water Reactor.
The amendment added license conditions relating to the completion of facility modifications and implementation of administrative controls for fire protection.
Certain items listed in Section 3.0 of the supporting Fire Protection Safety Evaluation (FPSE) were noted as requiring additional information to assure that the design is acceotable prior to actual implementation.
This supplement provides the staff's evaluation of the modifications.
Each modification is identified by title and section number, consistent with Section 3.0 of the July 27, 1979 FPSER.
On November 19,1980 (45 FR 76e02) the Commissien puolished a revised Section 10 CFR 50.48 and a new Appendix R to 10 CFR 50 regarding fire arotection features of nuclear power plants.
The revised Section 50.48 and Accendix R recuire that Fire Protection of Safe Shutdown Capability, E e gen:y Lighting, and Oil Collection Systems for Reactor Coolant Pumps be cackfit according to Appendix R"and open items of previous staff fire protection reviews be comoleted.
Section 50.48 also addresses completion requirements. regarding modifications that have creviously been approved by the staff but have not been implemented, and :: fire protection features
- na: have not been previously accroved as satisfying the provisions of Apoendix A to Branch Technical Position STP PCS39.5-1.
2.0 Evaluation In the FPSE many modifications were approved for implementation in conjunction with the Systematic Evaluation Program (SEP). The publication of the revised Section 50.48 and Appendix R requires acceleration of the schedules given in Table 3.1 and Table 3.2 of the FPSE. We have revised Tables '.1 and 3.2 to be consistent with the new Section 50.48, Appendix R, and the status of the actual implementation of modifications at the facility.
This supplement and Enclosure 2 of its transmittal letter, which now supersede Table 3.1 and Table 3.2 of the July 27, 1979 FSER, also incorporate the results of the evaluation by the staff of the following modifications.
2-3.1.3(1).
Interior Hose Stations In the SER, it was our concern that the interior hoses may not be capable of reaching all safety related areas and, therefore, manual fire suppression capability would be inadequate.
By letter dated November 3, 1980, the licensee. indicated that a hose reach test has been performed. The hose reach test verified that all safety-related areas and areas containing major fire hazards could be effectively reached by at least one hose stream.
Based on the licensee's verification, we conclude that the interior manual hose stations are capable of reaching any location with at least one effective hose stream which meets Section E.3(d) of Appendix A to BTP APCSB 9.5-1 and, therefore, are acceptable.
3.1.3(4).
Interior Hose Stations In the SER, it was our concern that the interior fire hoses may not be adequate for fire suppression use. We recommended that the licensee provide lh-inch diameter,100f. polyester, single jacketed, lined, FM or UL listed fire hose, factory test rated at not less than 300 psig, for all hose stations which protect safety-related systems and components.
By letter dated November 3, 1980, the licensee indicated that the fire hose at stations which protect safety-related systems and components outside the Containment Building have been replaced with ih-inch diameter, 100% polyester, single jacketed, FM listed fire hose, factory tested at 300 psig. The licensee indicated that the fire hoses inside the Containment Building are not UL or FM listed.
The licensee has provided an acceptable type fire hose for the hose stations which are outside the Containment Building. For the hose stations inside the Containment Building, the hoses are non-collapsing lh-inch two braid noses.
Each hose has a rubber tube and cover, has been tested to 300 - 400 psig, has a burst pressure of 500 psig, and a working pressure of 150 psgi. The hose has been tested to pressures which meet the recommendations of NFPA 1961, " Fire H o s e'.'.
This type of hose should be adequate for use in manual fire suppression activities within the Containment Building. We find that the hoses for the interior hose stations are equivalent to those that meet our guidelines, and, therefore, acceptable.
Based on our review, we conclude that the fire hoses meet the guidelines of Section E.3(d) of Appendix A to BTP-ASB 9.5-1, and therefore are acceptable.
. 3.1.3(2).
Interior Hose Stations In the Fire Protection SER, the concern was that fire water system pressure losses might result in inadequate flow at standpipe hose nozzles.
By letter dated February 6, 1980, the licensee provided calculations to confirm that pressures at all plant hose stations will be greater than 65 psi with 100 gpm flowing at the nozzle. The calculations indicated that the supply is adequate with the diesel fire pump supplying the hose station and the 75 gpm for the crib house screen wash.
We reviewed the calculations and found them acceptable. We find that the water supply for the standpipe and hose system meet the recorr.endations of NFPA 14, Section E.3(d) of Appendix A to BTP APCSS 9.5-1 and is, therefore, acceptable.
3.1.3(3).
Interior Hose Stations In the Fire Protection SER, the concern was that access to the interior hose stations could be blocked by material storage and thus delay manual firefighting activi ties.
By letter dated February 6, 1980, the licensee indicated that the plant Administra-tion Control Procedure now requires that fire fighting equioment be maintained readily accessible, and that a weekly written inspection report includes an ev tiuation of the accessibility of manual fire fighting ecuipment. Based on these acministrative procedures, there is reasonable assurance that access to the hose stations will not be blockea and, find it acceptable.
3.1.4(1). Fixed Suooression Systems In the SER, it was our concern that a fire involving a leak in the lube oil reservoir associated piping would expose the structural steel of the turbine building.
A collapse of these supports could degrade the safe shutdown ability of the plant.
We requested that the automatic sprinkler system pro-tecting the lube oil reservoir be extended to also protect the associated piping.
By letter dated February 6, 1980, the licensee indicated that automatic sprinkler system over the turbine oil reservoir was extended to protect the associated piping. By letter dated November 3, 1980, the licensee provided design drawings and hydraulic calculations for the automatic sprinkler system protecting the turbine oil reservoir and the extension which protects the associated piping.
The drawings indicate that sprinkler system extension will provide sprinkler coverage for the associated piping.
In addition, sheet metal heat collectors are installed above sprinkler heads where there is no ceiling to trap heat.
Based on our review, we conclude that the extension of the sprinkler system will provide adequate coverage for the associated piping. Therefore, we find the sprinkler system extension is acceptable.
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3.1.4(3). Fixed Sucoression Systems In the Fire Protection SER, it was our concern that fire suppression i
capability for the "A" diesel generator room may not be adequate to suppress a fire.
By letter dated November 3, 1980, the licensee proposed to install a manually actuated sprinkler system for the 1A Diesel Generator Room.
In our evaluation, we concluded that a manually actuated sprinkler system did not meet our guidelines and, therefore, was not acceptable.
In order to meet Section F.9 of Appendix A to STP ASB 9.5-1, we recom-mended that the licensee modify the sprinkler system to provide automatic actuation.
By letter dated February 6, 1980, the licensee provided additional infor-mation and further justification for installing a manual system.
A manually actuated sprinkler system would result in a delay of the actua-i tion of the system and allow the fire to burn for a longer period of time.
i However, this time delay would not be of sufficient length to allow the i
fire to threaten the 1A Diesel Generator Room enclosure which is fire ratec for 2-hours.
Therefore, a fire should be confined to the room until the sprinkler system is actuated.
In addition, there is a redundant ciesel generator. This diesel generator is in a separate enclosure and located away from the 1A Diesel Generator Room.
Therefore, an. unmitigated fire in the "A" diesel generator room would not affect the redundant "B" diesel generator and, therefore, would not affect the ability of the plant to reach a safe shutdown condition.
Based on our evaluation, we concluce that to modify the manually actuated sprinkler system so that it will be automatically actuated would not provide substantial additional fire orotection and, therefore, the manually. actuated sprinkler system is acceotable.
3.1.4(4).
Fixea Suopression Systems In the SER, it was our concern that an unmitigated fire in the penetration room could damage many~ cables, thereby causing the loss of essential bus lA, and possibly affecting the long-term cooling capability of the plant. We requested that a fixed dry pipe sprinkler system capable of quick connection to a manual hose be provided at the exterior side of the cable penetration of containment.
By letter dated February 6,1980, the licensee committed to install a fixed dry pipe sprinkler system, capable.of quick connection to a manual hose station, in the penetration area.
In our evaluation, we concluded that based on the licensee's commitment the suppression capability for this area was adequate.
By_ letter dated November 3,1980, the licensee provided the design drawings and hydraulic calculations for the sprinkler system for the electrical pene-tration area.
. The sprinklers in the penetration area are designed to deliver a density of 0.2 gpm/sq. ft. over the entire area. This is an adequate density for the i
hazard.
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Based on our review, we find that the system should provide adequate suppression.apability for the area. Therefore, we conclude that the system is still acceptable.
3.1.4(S). Fixed Suopression Systems In the SER it was our concern that a fire involving the transformers outside the west end of the turbine building could affect the safe shutdown capability of the plant. We requested that an automatic water suppression system be pro-vided for the transformers.
By letter dated February 6,1980, the licensee committed to install an automatic water suppression system to protect against a fire.in the outside transformers.
By letter dated November 3, 1980, the licensee provided the design drawings and hydraulic calculations for the sprinkler system.
2 The system is designed to deliver a density of 0.25 gpm/ft over the surface area of the transformers. This design density meets the recommendations of l
NFPA 15, " Water Spray Fixed Systems". The licensee indicated that the system l
will be manually actuated instead.of automatic.. A. manually actuated suppression system may not be adequate to prevent a fire involving the transformers from affecting the turbine building before the system becomes effective.
Based on our evaluation, we conclude that a manually actuated sprinkler system may allow a transformer fire to develop to an unnecessary level before beinn suppressed and, therefore, is not acceptable. The licensee has committed to provide an automatically initiated suppression system by November 1, 1981, and,we, therefore, find this system acceptable.
3.1.6.
Breathing Air In the Fire Protection SER, the concern was that the cascade charging system for the self-contained breathing unit air bottles would not provide sufficient reserve air for fire brigade use.
By letter dated February 6,1980, the licensee indicated that 17 breathing air units and 12 spare air bottles are available on-site, and that the cascade recharging system has adequate capacity to provide the required air reserve.
Based on this information, we conclude that the licensee's spare air bottle supply and cascade charging system meet the guidelinesof Section 0.4(h) of Appendix A to BTP APCSB 9.5-1 and are, therefore, acceptable.
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, 3.1.13.
Protection of Service Water Pioing In the Fire Protection SER, the concern was that a fire in the oil storage room could damage the service water pipes in this area.
By letter dated February 6, 1980, the licensee indicated that the high pressure service water and low pressure service water piping and hangers in the oil storage room have been insulated with a 2-inch layer of pipe insulation and covered with metal. The licensee has estimated that this insulation would provide a fire resistive rating of at least four hours based on a comparison with similar materials. We basically agree that an adequate fire barrier has been provided.
The area is protected by an automatic sprinkler system and a smoke detection system.
We conclude that the level of fire protection provided for the service water piping and supports in the oil storage room is now adequate, and is, therefore, acceptable.
3.1.14.
Neutron Shields In the SER, it was our concern that the polyethylene neutron shield blocks around the control red' drive system below the reactor were combustible and represented an unnecessary fire hazard.
By letter dated Novemcer 3, 1980, the licensee proposed to replace the poly-ethylene neutron shield blocks with a noncombustible neutron shielding material.
The neutron shielding material which the licensee has proposed to use has an ASTM E-84 surface flame spread rating of less than 50 which meets our guide-lines for ncncombustible material.
Based on our review, we conclude that the proposed neutron shielding material meets Section 0.1(d) of Appendix A to BTP ASB 9.5-1 and, therefore, is acceptable.
3.1.22(2). Protection for the Electrical Equipment and the Control Rooms In the SER, it was our concern that the fire suppression capability for the electrical equipment room may not be adequate.
By letter dated November 3, 1980, the licensee proposed to protect the electrical equipment room with a total flooding Halon 1301 system. The licensee provided the flow calculations, preliminary drawings of the system layout, and an evaluation of the system. The report lists the following modifications to be necessary:
. (1) a backup, a single reserve supply of Halon of similar size to the primary cylinder should be provided; (2) if the abort switch is to be provided, it should be removed from the pro-posed system; (3) all accessible openings witin the room area should be provided with automatic closing mechanisms which operate on system actuation.
All such openings should be fully weatherstripped to assist in achieving the required Sr. concentration; and (4) details of the installation should conform with the recommendations of FM Data Sheet 4-8N, and all applicable equipment used should be FM approved We concur with recommendations; however, the licensee has not indicated whether these recommendations will be provided.
The licensee should comit to the recommended modifications.
Based on our review, we conclude that the proposed Halon system for the electrical equipment room' does not meet Section E.4 of Appendix A to BTP APCSB 9.5-1 and, therefore, is not acceptable.
The licensee should modify the system to meet the above recommendations.
3.1.24 Fire Hazard in the Waste Handling Building In the Fire Protection SER, the concern was that a fire in the Waste Disposal Building could cause the release of radioactive materials. We recommended that the licensee install an automatic sprinkler system in the Waste Disposal Building.
By letter dated November 3,1980, the licensee indicated that an automatic sprinkler system in the Waste Disposal Building was inappropriate for the folicsing reasons:
(1) The resins are non-flammable.
(2)
The resins are stored in an almost completely enclosed spent resin tank.
(3)
There is a limited amount of combustible material in tne Waste Disposal Euilding.
The 'r.aste Disposal Building is of non-cou.oustible construction with concrete on steel roof and masonry walls.
Ionization-type smoke detectors are installed to provide alarm in the control room. An interior hose station, an outside fire hydrant and portable extinguishers are available for manual fire fighting.
These fire protection features meet Section F.14 of Appendix A to BTP ASB 9.5-1 as an acceptable alternative to an automatic sprinkler system.
Eased on our review, we conclude that the fire protection provided for the Waste Disposal Building meets Section F.14 of Appendix A to BTP ASB 9.5-1 and, tnerefore, is acceptable.
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Gas Suppression System In the Fire Protection SER, the concern was that a fire in the "B" diesel generator room would damage the onsite backup power supply for the gas suppression system in this area, and that the emergency manual control of the suppression system was not in conformance with the requirements of NFPA 12.
By letter dated February 6,1980, the licensee indicated that the activation power circuit for the carton dioxide system will be modified by rewiring the actuation power for the 19 diesel generator room CO2 system to the 1A diesel generator, and that the emergency manual release for the carbon dioxide system in the 13 diesel generator room will be modified by adding two remote manual releases in the adjacent electrical equipment room.
We conclude that with the licensee's proposed modifications, the fire protection level in this area meets the guidelines of Section E.5 of Appendix A to BTP APCSB 9.5-1 and are, therefore, acceptable.
3.1.28.
Cable Penetration Seal In the SER, it was our concern that the existing electrical cable penetration seals may not provide adequate fire resistance. We recommended that the licensee modify these seal designs to a specific seal design which was tested to an ASTM E-119 fire exposure for 3-hours.
By letter dated November 3,1980, the licensee indicated that all electrical cable penetration seals were being modified to the recommended penetration seal design.
Based on the licensee's commitment to modify the electrical cable penetration seals to a design which has been tested and qualified as a 3-hour fire rated seal, we conclude that the electrical penetration seals meet Section D.1.(j) of Appendix A to BTP ASB 9.5-1 and, therefore, are acceptable.
3.1.29(3). Sianalina System In the SER, it was our concern that a bypass switch installed in the circuit of each detector zone may allow a fire detection zone to be bypassed indefinitely since the bypass indicating lights are not readily visible.
By letters dated February 6, 1980 and November 1, 1980, the licensee. proposed to provide a timer for.each bypass switch. The time swtich will provide an i
audible alarm in the event the detector zone is bypassed for a predetermined time.
. Mechanical stops limit the maximum time a detector zone can be bypassed
..o This would permit a fire detector zone to be non-functional for two hours.
two hours which is longer than our Standard Technical Specification would allow when the allowed number of non-operable detectors are reached, that a fire watch patrol should be established for that area within one hour.
Based on our review, we conclude that timers which permit a detector zone to be inoperable for as long as 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> are not acceptable. To be in accordance with our Standard Technit'l Specifications for detectors, the maximum time a detectors zone may be bypassed should be limited to one hour.
3.1.27.
Combined Water System 3.2.2.
In the Fire Protection SER, the concern was that the High Pressure Service 3.2.8.
Water System may not be adequate to supply the combined water demand for fire fighting and for safety-related functions under fire emergency conditions, including f ailure of a pump or a section of the fire water piping system.
By letter dated March 11, 1980, the if censee provided the results of a study entitled " Fire Protection System Combined Water Oemand Analysis." This analysis concludes that:
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The worse case fire would be expected to occur in the turbine lube oil tank area.
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The existing high pressure service water system is capable of meeting the combined fire protection and safety-related water demands even if caly one of the diesel engine-driven fire pumps is available.
The licensee has proposed to install a barrier between the diesel engine-driven fire pumps to prevent the loss of both pumps as a result of a single fire in the crib house.
The licensee's analysis underestimates the water demand for the sprinkler system at the turbine lube oil tank area as follows: shutdown condenser, 69 gpm; sprinklers,161 gpm; hose streams, 472 gpm; for a totai jemand of 702 gpm.
The design demand for this sprinkler system is 503 gpm at 66.2 psi at the connection to the 6-inch high pressure service water main, according to a February 15, 1978 letter from Factory Mutual Engineering to the licensee. The letter also indicates that additional 500 gpm must be allowed for hose streams.
The licensee's analysis postulates that the installation of an oil impingement barrier will preserve the operacility of the reduncant diesel engine-driven fire pumps, but does not provide an technical casis for this assumption.
In addition, the licensee's analysis has not addressed the adequacy of the water house. There supply for safety systems in event of a major fire in the crib is a possibility that a fire there, which is large enougn to involve both fire The motor-driven pumps, would also involve both low pressure service water pumps.
high pressure service water pump in the turbine building takes suction from the low pressure service water system. The licensee has not discussed the ability of this pump to supply water to safety systems in event of loss of the Ic.
l pressure service water pumps.
Our re-evaluation of the existing water system indicates that the approximate quantities.cf water available to the major components of the system would be:
shutdown condenser, 62 gpm; sprinklers, 230 gpm; hose streams, 450 gpm; for a total demand of 792 gpm.
This indicates that there is insufficient supply of fire water for the turbine lube oil tank sprinkler systems with other concurrent demands. This deficiency may be worse when the additional sprinkler systems which the licensee will install are considered. The water supply requirement for these larger systems may exceed that of tne turbine oil tank room supply.
We conclude that the present combined oter supply represented by the High Pressure Service Water System is inadequate to meet the guidelines of Section E.2 of Appendix A to BTP APCSB 9.5-1 and 's, therefore, not acceptable.
The. licensee should install an additional fire pump of sufficient capacity to provide the required fire water supply concurrent with any safety system water demand. This pump shculd be installed in a room or building separated from the existing fire pumps by a 3-hour fire rated barrier, and should be designed and installed to comply with the requirements of.NFPA 20, including controller requirements. The pump and controller should have a UL or FM listing. A separate connection to the underground fire water system loop should be provided with t9fficient valves installed so th&i. a single break in the. piping will not impair fire pump capacity below that required as indicsted acove.
3.2.3.
Fire Pump Performance
'In the SER, it was our concern that the fire pumps may not be adequate since the fire pump test data did not cover the entire range of pump discharge from 0 to 150% of rated capacity.
By letter dated November 3,1980, the licensee provided the results of fire pump flow tests which were conducted on May 15, 1979.
The fire pumps were not tested to shutoff pressure.
We need the information regarding the fire water system demand which will indicate the water demand.the pumps must be capable of providing, before we can complete our review. The fire pump performance test will be reviewed in conjunction with the fire water demand for which the needed information is not available yet.
3.2.4.
Exoosed Structural Steel in the Turbine Building In the SER, it was our concern that a fire involving the tube lube oil reservoir could affect the exposed structural steel in the Turbine Building and impair the safe shutdown capability of the plant.
By letter dated November 3,1980, the licensee indicated that the exposed structural steel in.the Turbine Building is protected by the automatic sprinklers which cover the turbine lube oil reservoir and associated piping.
The licensee also indicated that additional protection is provided by the manual fire suppression capability."
. An oil fire could result in the failure of exposed structural steel before the actuation of fixed water spray systems or manual fire fighting efforts become effective due to its rate of combustion, high heat release rate and close proximity to structural steel members. Therefore, we find that the fire protection for the structural steel members is not adequate to assure the structural integrity of the steel in the event of a fire.
Based on our review, we find that the protection of the :tructural steel in the Turbine Building does not meet Section III, Paragraph G.2(a) of Appendix R to 10 CFR Part 50 and, therefore, is not acceptable.
The licensee should protect the structural steel forming a part of or supporting fire barriers to provide fire resistance equivalent to that required of the barriers or propose an alternate solution for this issue.
3.2.5.
Security Modification on Fire Doors In the Fire Protection SER, the concern was that the fire door assemblies which were modified for security purposes would not retain their UL listing and thus, would not prevent a fire in one area from spreading to adjacent areas.
By latter dated January 31, 1979, the licensee provided documentation that the installed electric door strikes are Underwriters' Laboratories listed for fire and burglary services.
Based on this information, we conclude that the fire doors which were modified for security purposes meet the guidelines of Section D.l(j) of Appendix A to BT9 APCSB 9.5-1 and are, therefore, acceptable.
3.2.6.
Smoke Detection System Tests In the SER, we indicated our concern that the smoke detectors might not respond to the products of combustion for the types of expected combustibles in the area.
We were also concerned that ventilation air flow patterns in the area might reduce or prevent detector response. As a result, we recocinended that the licensee perform an in-situ smoke detector test.
By letter dated January 31, 1979, the licensee provided a description and accept-ance criteria for an in-situ rest for fire detectors.
s The required methodology for an in-situ smoke detector test is beyond the current state-of-the-art and, therefore, an in-situ test cannot be performed at this time.
We find that with acceptable bench testing of smoke detectors, and considering that the smoke detection systems meet appropriate NFPA codes and are designed by experienced personnel, the smoke detectors are acceptable.
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1 3.0 Summary and' Conclusions 1
i This concludes our review of plant modifications to improve the fire protection capability at the Lacrosse Boiling Water Reactor in accordance 7
j-with Appendix A to BTP 9.5-1.
This Supplement reflects the approval of the design details of the proposed modifications and provide the required l
j implementation schedule.
1 The open items -identified in ' Enclosure 2 to the transmittal letter for 1
this supplement will be resolved by the licensee in conformance with the requirements of Appendix R on the schedule specified in 10 CFR 50.48(c).
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ENCLOSURE 2 UNRESOLVED FIRE PROTECTION ITEMS LACROSSE BOILING WATER REACTOR DOCKET NO. 50-409 3.1.4(2)
Fixed Suppression Systems 3.1.5 Heat Detector Circuit Supervision 3.1.20 Unrated Barrier 3.1.22(2)
Protection For The Electrical Equipment Room 3.1.27 Combined Water Demand 3.1.29(3)
Signaling System 3.2.1 Safe Shutdown Analysis 3.2.2 Fire Water System 3.2.3 Fire Pump Performance 3.2.4 Exposed Structural Steel in Turbine Building 3.2.7 Circuit Interaction Study 3.2.8 Fire Water Supply Reliability 1
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