ML20045D257
| ML20045D257 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 06/10/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20045D252 | List: |
| References | |
| 50-458-93-09, 50-458-93-9, EA-93-091, EA-93-91, NUDOCS 9306280138 | |
| Download: ML20045D257 (37) | |
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NOTICE OF VIOLATION Gulf States Utilities Docket No. 50-458 River Bend Station License No. NPF-47 EA 93-091 During an NRC inspection conducted March 29 through April 22, 1993, a violation of NRC requirements wss identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
10 CFR 50, Appendix B, Criterion XVI, states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, and nonconformances are promptly identified and corrected.
Contrary to the above, as of the date of the inspection, the measures established by the licensee did not assure that a condition adverse to quality was promptly identified and corrected.
Specifically, the licensee did not identify and correct a deficiency in the River Bend Station fire hazards analysis (FHA): the FHA did not contain information necessary to support certain assumptions that electrical control circuits required to assure a safe shutdown of the facility would not be adversely affected by certain associated circuits. This deficiency should have been promptly identified and corrected because the licensee committed in response to a related Notice of Violation issued on April 6,1990, that a final review and verification of the FHA would be performed by an independent contractor and that the contractor was to provide fully detailed documentation of the design bases and assumptions of the FHA.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Gulf States Utilities is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, cnd a copy to the NRC Resident Inspector at the River Bend Station, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a
" Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued to show cause why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
Dated at Arlington, Texas this j g 4 day of June, 1993 9306280138 930610 PDR ADOCK 05000458 G
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. ENFORCEMENT CONFERENCE ATTENDANCE
- l LICENSEE / FACILITY Gulf States Utilities / River Bend Station TIME /DATE 10 a.m. CDT, June 4, 1993 LOCATION NRC Region 4, Arlington, Texas EA NUMBER EA 93-091 l
NAME (PLEASE PRINT)
ORGANIZATION TITLE James L. Milhoan NRC Region 4 Regional Administrator Samuel J. Collins Director, Div. of Reactor Safety G. L. Constable Chief, Plant Support Section, DRS.
Amarjit Singh Reactor Inspector, PSS DRS Howard F. Bundy Reactor Inspector, PSS, DRS Michael E. Murphy Reactor Inspector, PSS, DRS
]
T. P. Gwynn Dep. Dir., Div. of Reactor Proj.
James E. Gagliardo Chief, Project Section C DRP William L. Brown Regional Counsel Gary Sanborn Regional Enforcement Officer Suzanne C. Black Nuclear Reactor Reg.
Project Directorate IV-2 Edward Baker Nuclear Reactor Reg.
Project Manager James G. Luehman**
Office of Enforcement Senior Enforcement Specialist John Ganiere Nuclear Reactor Reg.
NRR Intern l
Philip D. Graham Gulf States Utilities Vice President, River Bend Joesph D. Schippert Plant Manager i'
John R. Hamilton Manager, Engineering Michael A. Stein Director, Plant Engineering l
Joseph F. Mead Control Systems Supervisor j
Jim Booker Manager, SAQV i
John C. Maher Licensing Engineer l
Joey A. Clark Control Operating Foreman (SRO) l Joe Burton Supervisor-Nuclear Safety Eng.
Rudy Kerar Fire Protection Engineer Thomas Hoffman Supv-Civil /Struct. Design Eng.
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- by telephone l
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GULF STATES UTILITIES COMPANY PRESENTATION L
ENFORCEMENT CONFERENCE NRC INSPECTION REPORT 93-09
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i JUNE 4,1993
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ENFORCEMENT CONFERENCE AGENDA JUNE 4,1993 OPENING REMARKS PHIL GRAHAM MANAGEMENT. OVERVIEW JOHN HAMILTON FIRE HAZARDS ANALYSIS MIKE STEIN q
HISTORY AND CORRECTIVE' ACTIONS COMMON ENCLOSURE ANALYSIS JOE MEAD ASSESSMENT OF SAFE PLANT OPERATIONS JOE SCHIPPERT FIRE PROTECTION PROGRAM CORRECTIVE ACTION
SUMMARY
JOHN HAMILTON
. CONCLUSIONS
_ PIHL GRAHAM f
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IS5IJES FROM IR 93-09" LACK OF A DOCUMENTED COMMON ENCLOSURE ASSOCIATED CIRCUIT ANALYSIS LACK OF FULLY DETAILED DOCUMENTATION OF THE DESIGN BASES AND ASSUMPTIONS SUPPORTING CONCLUSIONS IN THE FIRE HAZARDS ANALYSIS LACK OF ENGINEERING ORGANIZATIONAL DEPTH TO EFFECTIVELY RESOLVE FIRE PROTECTION ISSUES LACK OF DOCUMENTED EVALUATION OF THE SPURIOUS SIGNAL ASSOCIATED CIRCUIT CONCERN POTENTIAL FOR INEFFECTIVE PROCEDURAL GUIDANCE A.OP-31 CONCERNS LSV COMPRESSOR JUMPERING VERIFICATION TIMING HIGH PRESSURE VESSEL WATER LEVEL UNTIMELY CORRECTION OF DEFICIENT FIRE SEALS t
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i LESSONS LEARNED
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i MANAGEMENT ATTENTION AND SUPPORT i
,5 PROMPT CORRECTIVE ACTION MULTI-DISCIPLINE TEAM INVOLVEMENT I
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g-g RESPONSE TO LESSONS LEARNED i
l INTENSIVE MANAGEMENT OVERSIGHT i
MONTHLY PROGRESS AND TECHNICAL REVIEW AUDITS AT CONTRACTOR FACILITY PROMPT COMMUNICATION
'OF P.ROBLEMS ENCOUNTERED TO NRC MULTI-DISCIPLINE TEAM FIRE PROTECTION ENGINEER SENIOR REACTOR: OPERATOR-1 SYSTEM ENGINEER ELECTRICAL DESIGN ENGINEER-
-NUCLEAR SAFETY ENGINEER.
CIVIL STRUCTURAL' ENGINEER MAINTENANCE FIRE PROTECTION ~
COORDINATOR' NO DELAY IN OVERALL COMPLETION-4
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I' FIRE HAZARD ANALYSIS HISTORY j
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9 ORIGINAL DESIGN WITH DEFENSE IN DEPTH I
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POST FIRE SAFE SHUT DOWN ANALYSIS IN ACCORDANCE WITH BTP APCSB 9.5-1 AND l
APPENDIX A.
t CONCLUSION:
SAFE SHUTDOWN METHODOLOGY DETERMINED. ACCEPTABLE IN-1985.
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FIRE HAZARD ANALYSIS HISTORY
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OCTOBER 1989:
GSU IDENTIFIED DISCREPANCY-.
BETWEEN POST FIRE SAFE SHUTDOWN ANALYSIS (SSA) AND PLANT PROCEDURES.
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9 JANUARY 1990: ATTAINED COMPLIANCE WITH SSA.
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'f CONCLUSION:
IN JANUARY 1990, GSU. WAS CONFIDENT OF HAVING AN ACCEPTABLE POST FIRE SAFE SHUTDOWN ANALYSIS...
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FIRE HAZARD ANALYSIS HISTORY l
9 MARCH 1990: GSU COMMITMENTS IN RESPONSE TO IR 90-02 (ENERGIZED MOVs).
REVIEW OF SSA BY INDEPENDENT CONTRACTOR.
VERIFICATION OF Ct YSISTENCY BETWEEN SSA AND PLANT PROCEDURES BY INDEPENDENT CONTRACTOR.
INDEPENDENT CONTRACTOR TO PROVIDE FUL LY DETAILED DOCUMENTATION OF THE DESIGN-BASES AND ASSUMPTIONS OF THE SSA.
SSFI TO BE PERFORMED BY QA IN THE SSA AREA.
REVISE MODIFICATION PROCEDURE FOR DEPTH OF DESIGN BASES EVALUATION 'AND DOCUMENTA90N.
REVIEW MODIFICATIONS PRIOR TO JANUARY 20, 1987~FOR POTENTIAL IMPACT ON SSA.
PROVIDE TRAINING TO ENGINEERS, OPERATIONS
~ STAFF AND THE FACILITY REVIEW COMMITTEE IN THE SSA AREA.
9 ACTION ITEMS EXPECTED TO BE COMPLETED BY-LATE 1990.
CONCLUSIONS:
GSU HAD EXPECTATION OF FEW DISCREPANCIES OR PROBLEMS.
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O FIRE HAZARD ANALYSIS HISTORY STATUS OF CORRECTIVE ACTIONS i
G REVIEW OF SSA BY INDEPENDENT CONTRACTOR.
REVIEW COMPLETED IN JANUARY 1991.
iO V'.EW VERIFIED ADEQUACY OF SAFE SHUTDOWN MI:THODOLOGY.
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106 DISCREPANCIES IDENTIFIED.
(6 REPORTED BY LER 91-008 SUPPLEMENT 1).
9-CONSISTENCY VERIFIED BETWEEN PLANT PROCEDURES AND SSA.
F AOP-0052, " FIRE OUTSIDE THE MAIN CONTROL ROOM", DEVELOPED AND ISSUED.
CONCLUSION:
SAFE SHUTDOWN METHOD IS ACCEIrrABLE. ITEMS ~AFFECTING OPERATIONS RESOLVED AND PLANT PROCEDURES REVISED.
NUMBER OF DISCREPANCIES MUCH LARGER.THAN ANTICIPATED.
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FIRE HAZARD ANALYSIS HISTORY STATUS OF CORRECTIVE ACTIONS O
CONTRACTOR TO PROVIDE FULLY. DETAILED DOCUMENTATION OF DESIGN BASES AND ASSUMPTIONS.
DETAILED INFORMATION'IN ATTACHMENTS TO LETTERS.
CONTRACT TERMINATED IN OCTOBER 1992.
1 REVISION OF SSA AND CONSOLIDATION OF DESIGN BASES INFORMATION. TO BE-COMPLETED BY GSU.
a CONCLUSION:
IN OCTOBER 1992, GSU
-INCORRECTLY BELIEVED THAT ALL NECESSARY DESIGN DOCUMENTATION WAS READILY AVAILABLE-ALTHOUGH NOT IN OPTIMAL FORM.
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FIRE HAZARD ANALYSIS HISTORY STATUS OF CORRECTIVE ACTIONS 9
SSFI COMPLETED IN FEBRUARY 1993.
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REVISE MODIFICATION PROCEDU'RE FOR DEPTH OF DESIGN BASES EVALUATION AND DOCUMENTATION:
ADDED DESIGN REQUIREMENTS AND OBJECTIVES
SUMMARY
O REVIEW OF MRs COMPLETED AND ONGOING FOR FUTURE MRs.
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FIRE HAZARD ANALYSIS HISTORY STATUS OF CORRECTIVE ACTIONS S
PROVIDE TRAINING ENGINEERS: CONTINUING TRAINING GENERAL AWARENESS TRAINING COMPLETED NOVEMBER 1992.
OPERATIONS: TRAINING MODULES UPDATED JANUARY 1993.
FRC: TRAINING COMPLETED NOV:1992.
DETAILED TRAINING MANUAL DEVELOPED FOR USE BY FUTURE INDIVIDUALS INVOLVED WITH SSA.
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STATUS OF CORRECTIVE ACTIONS i
CONCLUSION GSU FAILED TO MEET T11E INTENT OF ONE CORRECTIVE ACTION. SIX CORRECTIVE ACTIONS WERE COMPLETED AS COMMnTED UNDER T11E i
EXPANDED C/A PROGRAM.
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- Describe Common Enclosure Associated Circuit Requirements Present Immediate Actions Taken In Response To NRC Concern l
- Discuss Our Approach To Completing The Analysis
- Discuss A-Needed Correction In NRC Inspection Rsport j
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Common Enclosure Associated Circuits Are Circuits That:
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- Have Physical Separation Less Than That Required.By Section III.G.2 Of Appendix R, AND
- Share A Common Enclosure (Raceway, Panel, Junction Box, etc.) With Redundant Or Alternate Shutdown-Cables, i
AND.
- ' Are Not Electrically Protected By. Circuit-Breakers, Fuses -
Or Similar Devices,.
- Will Allow Propagation Of The Fire Into The Common Enclosure.
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Safe Shutdown Cable O
Fire Area "X" i
Associated Circuit Cable O
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Safe Shutdown Cable for fire in area "X" Common Enclosure l
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O Safe Shutdown Cable 4
Fire Wrapped Raceway Fire Area 'Y' 3
-Non-Safe Shutdown Cable O
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.i Immediate Actions Taken
- Initiated Condition Report 93-0174 j
- Firewatch Adequate Compensation i
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- All Safety Related Areas Of The Plant Fire Watched Except:
- Main Steam Tunnel
- Drywell
- No Appendix "R" Cables In The Drywell Or Steam Tunnel Requiring j
Wrapping; Therefore, Fire Propagation Into A Common Enclosure l
Within Either Of These Areas Is Not A Possible Situation
- All Steam Tunnel And Drywell Control Cables Analyzed For A'ssociated Circuit Common Enclosure Concern Due To Potentially' Inadequate Circuit Protection.
- Cable Sizing Methodology At 480 Volts And Above Assures That Cables Are Protected From Fault Current Damage
- No Common Enclosure Concerns Exist for a Fire In These Areas l
Conclusion l
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- 1With The Firewatches 'Already In Place And The Satisfactory Results Of The Analysis Of All Cables In The Steam Tunnel And Drywell, River!
Bend Station Is Adequately Protected From-A Common Enclosure 1
Hazard l
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Analysis Details
- All But Six (6) Cables Adequately Protected By Either A Fuse Or A Circuit Breaker
- Cable Failure Modes Analyzed - Not Common Enclosure Hazard.
- Circuits Supplied From Ungrounded Battery; Therefore, A Single Short To Ground Has No Effect On The Circuit.
- Multiple Shorts To Ground Will Not Produce " FAULT" Current
- Conductor-to-Conductor Shorts Will Not Produce " FAULT" Current
- Shorts To Other Control Circuits Will Not Produce " FAULT" Current is
Drywell Boundry A[+
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Actuating Control Contacts l
Components
[ switches, contacts,- etc.)
125 vde r
D Actuated Control TC l
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Components (rel'ays, coils, etc.)
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Approach
- All Safe Shutdown Cables Are Either In One Safety Related Electrical Raceway System Or Another.
- Non-Safety Related Cables Do Not Share Common Enclosures (Raceways)
With Safety Related Cables; Therefore, Non-Safety Related Cables Do Not Pose An Associated Circuit Common Enclosure Concern.
- All Safety Related Control Circuits will Be Analyzed For Common Enclosure Concerns 480 Volt And 4160 Volt Circuits Will Be Sampled To Re-verify Adequacy Of Electrical Protective Devices Circuits Determined Not To Be Adequately Protected By A Fuse Or Circuit Breaker Will Be Analyzed For Failure Modes And Effects 20
A, A,
Schedule
- July 19,1993 - Completion Of Initial Review And Identification Of Cables Requiring Detailed Analysis.
September 9,1993 - NUS Complete Detailed Analysis And Issue Draft Analysis To GSU September 23,1993 - GSU Comments Back To NUS September 30,1993 - NUS Deliver Final Report
- October 29, 1993 - GSU Issue Final Report 2.1
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Summary q
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- OUR RESOLUTION OF THE l
ASSOCIATED CIRCUIT COMMON ENCLOSURE CONCERN WILL BE BOTH THOROUGH AND TIMELY, i
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CABLE SSSD REQD NON-CABLE CABLE ELECTRICAL ENCLOSURE
.CKTS IN-ESSENTIAL FUNCTION SIZE PROTECTION ID ENCLOSURE CIRCUIT ID.
'& TYPE e.
1TX0010 YES 1CSHAOX800 INST.
16AWG 35 AMP FUSE 2 CONDUCTOR-ICSHBOX800 -
INST.
16AWG 35 AMP FUSE 2 CONDUCTOR 1CSHCOX800
' INST.
16AWG 35 AMP FUSE 2 CONDUCTOR ITC044B YES' 1ENBBBC950-CONTROL 16AWG 35 AMP FUSE 125VDC
'8 CONDUCTOR '
IENSBBC950 CONTROL
'16AWG 35 AMP FUSE:
125 VDC 8 CONDUCTOR k
1RHSBBC950 CONTROL 16AWG
'35 AMP FUSE 125 VDC
'4 CONDUCTOR.
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3.
35A Air (Controll u
125 Volt DC Source Brea er,, /
(Circuit j g
75/5 C
60vercurrent3 (Current 3
F T
CT Meter l
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y Relay j
(Transducerj
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- Cables in Question Load l
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35A A[+
Actuating Control Components
[ switches, contacts, etc.)
125 vde l Relay I
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35A Cables in Question Optical Computer U
lsolator input s
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ASSESSMENT OF SAFE PLANT OPERATIONS i
o NRC Inspection Report 93-09 noted areas of weakness o
- Overall, River Bend maintains a fire protection program characterized by defense in depth o
Elements:
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Prevents fires from starting or spreading f
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Can effectively detect and suppress fires
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Insures performance of essential plant functions in spite of a fire that might burn for a considerable period o
The River Bend fire protection program assures the health and safety of the public
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A v
w FIRE PROTECTION ATTRIBUTES SUPPORTING NUCLEAR SAFETY o
Physical separation of redundant equipme'nt o
Materials of construction o
Fire walls, doors, dampers o
Fire seals and barriers o
Flame retardant cables o
Control of transient combustibles o
Hot Work Permit program o
Automatic water deluge systems o
Automatic CO and Halon systems 2
o Fire detection systems o
Hose stations and hand extinguishers o
Smoke removal equipment o
System Reliability Program o
System Engineer and Fire Protection Coordinator-Support o
Fire Watch Fire Brigape o
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-St. Francisville Volunteer Fire Department
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FIRE BRIGADE RESPONIE o
Pre-Fire strategies and plans provide pertinent data for combating fires in defined plant areas
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Room layout, access, lighting and receptacles
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Fire suppression / detection features
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Room ventilation
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Fire / smoke propagation control
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Communications
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Normal combustibles
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Guidelines for fire attack -
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Evaluation of fire and shutdown capability
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Procedures are located in the Control
- Room, fire protection lockers, van, and onsite emergency response facilities o
Fire Brigade Leader is a licensed operator, and the brigade is.
manned by 2 qua!ified operators and 2 security officers
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Member training includes annual classroom and mockup qualification on flammable liquid, cable tray, transformer, and interior structural fires -
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Site-specific initial and requal training are provided
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Twice yearly drills are required
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Leader training includes additional qualifications 29
Y OPE $TIONS FIRE RESbNSE
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Control Room crews are proficient in symptom based Emergency Operating Procedures and event based Abnormal Operating Procedures
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Control Room crews are trained to interface with fire brigade activities
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Emergency Plan contingencies are available o
Abnormal Operating-Procedure (AOP) -0031, Shutdown from Outside Main Control Room, provides effective guidance to operators
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Mismatch between design basis assumptions and Emergency Procedure. Guidelines was recognized, and procedural guidance was strengthened
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Procedure and hardware was enhanced to facilitate safety related compressor availability
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Procedure was corrected for required time span for verification of diesel ventilation-
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Procedural caution was added to address spurious injection concern
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Adequate lighting at the Remote Shutdown Panel was confirmed
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Additional comparison of AOP-0031 and Safe Shutdown Analysis (SSA) indicate consistency l
AOP-0052, Fire Outside the Main Control Room, provides o
concise SSA information to operators 1
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CONCLUSION 1
o Multiple an'd robust barriers protect River. Bend from fire initiation and propagation o
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O Potential fires would be-rapidly detected and extinguished, minimizing damage l
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Reliable procedures, trained personnel and protected equipment l
insure safe _ operation and. shutdown capability 1
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o identified weaknesses will be promptly fixed 1
o The fire protection program will be continuously tested.for improvement and upgraded as warranted
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l Scope-of FHA Improvements Task Status Review & Verification of FHA Complete Resolution of' discrepancies Scheduled O
Additions to Design & Licensing Base l
Breaker - Fuse Coordination Study 4W80/92*-
coneteTe Multiple High Impedance Fault procedure RF4 coseLeTe Documentation Improvements Revision of FHA IW30/92-DELAYED Safe Shutdown Data Base IW30/92 osLayao I
j-Procedure Changes
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constaTs
-Update of prefire strategies AOP. for fire outside Main Control Room -
-RF coneLeTe Review of Modification Requests
-06/86SS-
-COMPLETE
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l Implement FHA Training Program
.09/30/92 L -COMPLETE-v-
I oCompletion of action items resulting from the study may be scheduled later.
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Fire Protection Action Plan 7
Fire' Protection-Analysis Test Modify-Complete 4
Action Items Required (1)
Ampacity Yes Industry
-No
+7/92-Evaluation Practice
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COMPLETE (as installed) 4 i
Ampacity Yes Industry Yes TBD f
Evaluation Practice I
NUMARC/
(as modified)
EPRI 7
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Fire' Hazards Complete Yes" 01/94 Evaluation Respond to.NRC Complete
-94/2W-92
- l Inspection
. COMPLETE Report 3
Penetration Yes Perhaps Yes
-01/94:
- {
seals
.j Structural Yes Industry No 01/94-Steel.
Practice (1) RF-5 begins'3/15/94 j
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FIRE PROTECTION ACTION PLAN FIRE PROTECTION ANALYSIS TEST PLANT DOC TRAINING NRC FINAL ACTION ITEMS MOD CHANGE REVIEW COMPLETION SAFE SHUTDOWN 10/11/93 NOT 11/11/93 1/94 1/94 ANALYSIS INCLUDING EXPECTED (ENGR)
SPURIOUS SIGNAL COMMON ENCLOSURE 9/30/93 POTENTIAL 10/29/93 1/94 1/94 g ANALYSIS RF5' (ENGR)
EVALUATE EMERGENCY 11/05/93 11/05/93 POTENTIAL 11/05/93 LIGHTING VS SSA RF55 SSA PROJECT DATA TURNOVER 1/94 1/94 BASES 11/29/93 (ENGR)
PENETRATION SEALS YES YES YES YES COMPLETE 1/94 (MAINT)
STRUCTURAL FIRE-10/31/93 NO NOT 12/31/93 1/94 PERHAPS 1/94 PROOFING EXPECTED (MAINT,QC)
AOP/EOP REVIEW FOR 9/21/93 11/11/93 AS REQD 11/11/93 FIRE SCENARIOS IN-DEPTH TRAINING 7/15/93 FOR FIRE PROTECTION TEAM LICENSING BASES 7/15/93 DOCUMENT FIRE PRA (GL 88-20, 12/31/93 NOT PERHAPS YES YES 6/27/942 l SUPPLEMENT 4)
EXPECTED g
- 3RFS, IF MODIFICATIONS ARE REQUIRED, BEGINS 3/12/94 W
2GL 88-20, SUPPLEMENT 4 SUBMITTAL DATE l
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MITIGATING FACTORS i
i INITIAL FIRE HA.ZARDS ANALYSIS PROBLEMS WERE i
SELF IDENTIFIED c
CORRECTIVE ACTIONS ARE THOROUGH AND EXTENSIVE -- MOST COMPLETED REMAINING COMPLIANCE ISSUES ARE BEING ADDRESSED -- NO SIGNIFICANT SAFETY ISSUES q
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NO DELAY IN OVERALL COMPLETION BEYOND THE DATES DISCUSSED 4/20/92 NRC WILL BE INFORMED OF ANY ADDITIONAL l
PROBLEMS AS THEY ARE IDENTIFIED-1 34
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I RIVER BEND FIRE PROTECTION PROGRAM l
1 BASED ON TECH NIC AL S PE CIFIC ATION.
j COMPENSATORY
- ACTIONS, RIVER BEND-IS. IN COMPLIANCE WITH LICENSING BASES FOR FIRE
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-PROTECTION i
DEFENSE IN DEPTH FIRE PROTECTION IS MAINTAINED 1
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