Text

Forwards Draft Responses & Fire Protection Evaluation Rept Page Changes Re R Martin Request for Addl Info.Responses & Page Changes Will Be Incorporated Into Fire Protection Evaluation Rept,Rev 2 Scheduled for Submittal Jan 1983
	ML20070M138
Person / Time
Site:	Limerick
Issue date:	01/07/1983
From:	Bradley E; PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Schwencer A; Office of Nuclear Reactor Regulation
References
	NUDOCS 8301120314
	Download: ML20070M138 (103)
	v • d • e

<w 7 s, PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 C OW ARD G. B AU ER, J R.

(215)841-4000

',*::~:ll*.i".' ...

CUG ENE J. BR ADLEY

................. .... January 7, 1983 DON ALD BLANMEN CUDOLPH A. CHILLEMI

3. C. MIR M H ALL T. H. M AH ER CORMELL PAUL AUERB ACH

...s.,s.,e.....Lsou.. 6 CDW A RD J. CU LLEN, J R.

THC fA AS H. MILLER, J R.

ORENE A. Me M EN N A

..... ........ 6 Mr. A. Schwencer, Chief Docket Nos. 50-352 Licensing Branch No. 2 50-353 Division of Licensing U. S. Nuclear Rcgulatory Commission Washington, D.C. 20555

Subject:

Limerick Generating Station Units 1 and 2 Request for Addit'iona) Information (RAI) from NRC Fire Protection Section of the Chemical Engineering Branch

Reference:

Letter, A. Schwencer to E. G. Bauer, Jr.

dated July 28, 1982

Dear Mr. Schwencer:

Transmitted herewith are draft responses and Fire Protection Evaluation Report (FPER) page changes related to the subject RAIs. This material is provided in draft form at the request of Mr. Robert Martin, NRC Project Manager for Limerick, as an aid to the Chemical Engineering Branch in preparing their portion of the draft safety evaluation report.

We plan to formally incorporate these responses and page changes into FPER Revision 2 scheduled for submittal in late January, 1983.

Very truly yours b

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EUG ' J. LEY JLP/pb/Il-5 1 005 l cc: See attached service list I

l 8301120314 830107 l

PDR ADOCK 05000352 F PDR

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cc: Judge Lawrence Brenner. (w/o enclosure)

Judge Richard F. Cole (w/o enclosure)

Judge Peter A. Morris (w/o enclosure)

~ Troy B. Conner, Jr. , Esq. (w/o enclosure)

Ann P. !!odgdon (w/o enclosure)

Mr. Frank R. Romano (w/o enclosure)

Mr. Robert L. Anthony (w/o enclosure)

Mr. Marvin I. Lewis (w/o enclosure)

-Judith A. Dorsey, Esq. (w/o enclosure)

Charles W. Elliott, Esq. (w/o enclosure)

Mr. Alan J. Nogee (w/o enclosure)

Robert W. Adler, Esq. (w/o enclosure)

Mr. Thomas Gerusky (w/o enclosure)

Director, Pennsylvcnia Emergency Management Agency (w/o enclosure)

Mr. Steven P. liershey (w/o enclosure)

James M. Neill, Esq. (w/o enclosure)

Donald S. Bronstein, Esq. (w/o enclosure)

Mr. Joseph 11. White, III (w/o enclosure)

Dr. Judith 11. Johnsrud (w/o enclosure)

Walter W. Cohen, Esq. (w/o enclosure)

Robert J. Sugarman, Esq. (w/o enclosure)

Rodney D. Johnson (w/o enclosure)

Atomic Safety and Licensing Appeal Board (w/o enclosure)

Atomic Safety and Licensing Board Panel (w/o enclosure)

Docket and Service Section (w/o enclosure) m

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2 OUESTION 280.1 g

, Zhe fire protection program will be reviewed to the guidelines of 11 BTP CMEB 9.5-1 (NUREG-0800), July 1981. Provide a comparison 12 that shows conformance of the plant fire protection program to 13 these guidelines. Deviations from the guidelines should be 14 specifically identified. A technical basis should be provided 15 for each deviation. 15 RESPONSE 37 fection 3.1 of the FPER has been changed to address the July 1981 19 revision of BTP CMEB 9.5-1, rather than Appendix A to the 20 Prpvious revision of BTP ASB 9.5-1. ,20 e.

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OUESTION 280.2 27 ,

provide the qualifications of the fire protection engineer 29 responsible for the formulation and implementation of the fire 31 protection program. 31

Response

The Superintendent Generation Division - Nuclear is responsible for the formulation and implementation of the fire protection program. In- this capacity he has the services of a member of the Mechanical Engineering department as a fire protection engineer. The individual meets the requirements for membership in the Society of Fire Protection Engineers (i.e. a graduate of an engineering curriculum of accepted standing and shall have completed not less than 6 years of engineering attainment indicative of growth in engineering competency and achievement, 3 years of which shall have been in responsible charge of fire protection work, in adclIfioh fire p rdestion sen sulto=ts are, owadoble fo a ssist in design e d review tasks as reguired, D

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DUESTION 280.3 - 41 Verify that administrative controls will be developed and 43 Implemented in accordance with BTP CHEB 9.5-1 Section C.2. 44 RESPONSE 46 gection 3.1 of the FPER has been changed to address the 48 guidelines of RTP CMEB 9.5-1, including Sectic3 C.2. 49 I

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2 OUEST10N 280.4 56 Yerify that a plant fire brigade will be provided in accordance 58 gith BTP CMEB 9.5-1 Section C.3. 59 RESPONSE 61 Rection 3.1 of the FPER has been changed to address the 63 guidelines of BTP CHEB 9.5-1, including Section C.3. 64 f

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OUESTION 280.5 71 ;

Yerify that the plant fire brigade will have the minimum 73 equipment listed in BTP CHEB 9.5-1 Section C.3.c. 74 RESPONSE 76 fection 3.1 of the FPER has been changed to address the 78 guidelines of BTP CMEB 9.5-1, including Section C.3.c. 79 I

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2 OUESTION 280.6 86 yerify that a fire brigade training program will be provided in 88 accordance with BTP CHEB 9.5-1 Section C.3.d. 89 RESPONSE 91 gection 3.1 of the FPER has been changed to address the 93 guidelines of BTP CHEB 9.5-1, including Section C.3.d. 94

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Q LGS FSAR g., s. - 2 OUESTION 280.'7 101 Verify that fire brigade drills wil be performed at reghlar 103 Intervals in accordance with BTP CMEB 9.5-1 Section C.3.d(7). 104 RESPONSE 106 fection 3.1 of the FPER has been changed to address the 108 guidelines of BTP CMEB 9.5-1, including Section C.3.d(7). 109 l .

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LGS FSAR 2 OUESTION 280.8 116 Verify that all fire barriers have been tested and approved b an 119 Independent laboratory. 119 RESPONSE 121 S ection. 3.1 4 4he FPER has been. changed to add.ress 4he Ju.iy 198l revision, of sTP CMES 9.5-t, including fhe provisions of 4hs BTP 4hai con.cern 4he raling and. hsfirg of fire.

barriers. h various componen s of Wre barriers are ciscussed under lhe follOwing ifent nurnbers oi,hin., Sechien, s.1 :

a.. WucAural. feahures -

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b. Peneira : ion, sea s -

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OUESTION 280.9 129 :

Yorify that all openings in rated fire barriers will be sealed to 132 provide a fire resistance rating at least equal to that of the 133 barrier in conformance with BTP CMEB 9.5-1 Section C.5.a. 133 RESPONSE 135 gection 3.1 of the FPER has bee:. changed to address the 137 guidelines of BTP CHEB 9.5-1, including Section C.5.a. 138 l

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have been conducted to qualify the resistance of the geals in 150 acccedance with BTP CHEB 9.5-1 Section C.5.a. Verify that the 151 seals will be installed in accordance with the Eanufacturer's 151 l instructions. 151 !

, RESPONSE 153 fection 3.1 of the FPER has been changed to address the 155 ,

guidelines of BTP CMEB 9.5-1, including Section C.5.a. 2he 157 !

requested information is included in FPER Section 3.1. ,157 i i

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QUESTION 280.11 164

' Verify that door openings in fire barriers will be protected with 166 equivalently rated doors, frames,' and hardware. Epecify that a 168 l nationally recognized independent testing laboratory has tested 169 and labelled this equipment in accerdance with RTP CMEB 9.5-1 170 i Section C.5.a. 170 i RESPONSE 172 fection 3.1 of the FPER has been changed to address the 174 guidelines of RTP CMEB 9.5-1, including Section C.5.a. 175 l

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LGS FSAR 2 OUESTION 280.12 - 182 yerify that the closing of fire doors will be supervised by one 185 of the measures stated in BTP CHEB Section C.5.a. 185 RESPONSE 187 fection 3.1 of the FPER has been changed to address the 189 l guidelines of RTP CMEB 9.5-1, including Section C.5.a. 190 l J

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OUESTION 280.13 197 yerify that fire protection has been provided for safe shutdown 199 ,

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go that one train of systems necessary to achieve and maintain J1ot shutdown conditions from either the control room or emergency 201 gontrol station (s) is free of fire damage and that systems 202 necessary to achieve and maintain cold shutdown from either the 203 control room or the emergency control station (s) can be repaired 204 1 within 7I hours. 204 Provide an analysis which shows that one redundant train of 206 equipment, gystems, and cables necessary for safe shutdown can be 207 maintained free 2f fire damage by either: 208 a) Separation of cables and equipment and associated circuits of 210 redundant trains by a fire barrier having a 3-hour rating. 211 Etructural steel forming a part of or supporting such fire 212 barriers ghould be protected to provide fire resistance 213

equivalent to.that required of the barrier; 214 b) Separation of cables and equipment and associated circuits of 216 redundant trains by a horizontal distance of more than 20 217 feet with no intervening combustible or fire hazards. In 219 addition, fire detectors and an automatic fire suppressTon 219 systems should be installed in the fire area; or 220 c) Enclosure of cable and equipment and associated circuits of 222 one redundant train in a fire barrier having a 1-hour rating. 223 in a3dition, fire detectors and an automatic fire suppression 224 system ghould be installed in the fire area. 225 Identify those areas of the plant that'will not meet the 227 guidelines of Section C.5.b of BTP CMEB 9.5-1 and, thus 228 alternative shutdown will be provided. Additionally provide a 230 statement that all otEer areas of the plant will be in compliance 231 with Section C.5.b of BTP CMEB 9.5-1. 231 RESPONSE 233 Section 3.1 of the FPER has been changed to address the 23'5 including Section C.5.b. The 237 '

guidelines of BTP CHEB requested information is 9.5-1, inclu 3ed in (or referenced in) FPER 237

, Section 3.1. 237 l'

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2 OUESTION 280.14 244 yerify that redundant safety-related cable systems outside the 246 cable apreading room are protected in accordance with BTP 247 CMEB 9.5-1 Section C.5.e(2). 247 RESPONSE 249 Jection 3.1 of the FPER has been changed to address the 251 guidelines of BTP [MEB 9.5-1, including Section C.5.e(2). 252 1

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Y.J M 2 OUEST10N 280.15 259 Qn page 9.5-10 of the FSAR, it is stated that emergency ac/dc 261 lighting normally is powered from the Class IE buses and, in the 263 event of loss of the Class IE source, the emergency lighting is 264 transferred to the 125 V de non-Class IE.gtation battery source. 265 Ihe emergency lighting is provided in the following locations: 266

g. Control room ,

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b. Auxiliary equipment room 270

g. Cable spreading room 272

, d. Static inverter room 274

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e. 4-kV switchgear compartment 276 1 13-kV switchgear compartment 278 2 Drywell 280 h .' HPCI, RCIC, and RHR pump

compartments lat exit doors only) 283

1. Diese?-generator compartments 285 :

J. Spray 3.ond pump structure 288

- packs, at exit doors only)111ghts with individual battery 288

k. Stairways and access corridors. 290 It is our position that self-contained 8-hour minimum capacity, 292 Battery powered emergency lighting units be installed in 293 conformance with BTP CHEB 9.5-1 Section C.5.g. 293

RESPONSE

295 Details of the emergency lighting system are discussed in FPER 298 Eection 3.2, Item 23. The design of the emergency' lighting 299 system provides an alternate m_eans of compliance with the 300 guidelines of BTP CHEB 9.5-1 and 10CFR50, Appendix R. Because 302 the emergency lighting system utilizes the standby diesel- 303 generators as a backup source of power, it will maintain adequate 304 lighting in the designated greas on a long-term basis. The 306 existing emergency lighting system is considered to be superior 307 to a system utilizino individual 8-hour battery power supplies, 307

>forthefo11owinQsons3ofreus 308

1. The power source for the lighting is located remote from the 311 location of the lighting fixtures, thereby exposing Tess of 312 the lighting system to the effects of a'n exposure fire 313 280.15-1 Rev. 13, 11/82 257

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occurring in the location where he emergency lighting is 314 l required. '?his results in a hi er probability that the 315 9

lighting witl be available in that area when required. 316 1 Electrical cabling for the emergency lighting is routed 319 exclusively in conduit, most of which is embedded in 320 concrete. Ihis design protects the cabling from the effects 322 ,

of exposure fires. 322 l 1 Individual battery packs, if used to power the lighting 325 fixtures,-could fail during exposure to heat in a manner 326 l which would be extremely hazardous to fire brigade personnel 327 :

in the area. Ihe existing design of the emergency lighting 328 i gystem utilizes centralized power sources which would not 330 !

present this type of hazard. 330 i 1 The use of standby diesel-generators to power the emergency 333 !

lighting system ensures that the required ligh";ing levels can 334 be maintained for much longer than the 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months that is 335 available with battery packs. 33C l I

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1 OUESTION 280.16 343 yerify that fixed repeaters installed to permit use of portable 345 radio sommunication units will be protected from exposure fire 346 damage in accordance with BTP CMEB 9.5-1 Section C.5.g. 347 RESPONSE 349 gection 3.1 of the FPER has been changed to address the 351 guidelines of RTP CMEB 9.5-1, including Section C.5.g. 352 l

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OUESTION 280.17 359 yerify that a fire detection system has been provided in 361 accordance with BTP CMEB 9.5-1 Section C.6.a to protect all areas 362 of the plant which contain or present an exposure fire hazard to 363 safety relate 3 equipment and cables. 364 RESPONSE 366 fection 3.1 of the FPER has been changed to address the 368 guidelines of CMEB 9.5-1, including Section C.6.a. 369 e

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~'h J LGS FSAR h 2 OUESTION 280.18 376 gn page 2-2 of the Fire Protection Evaluation Report, it is 378 stated that five hose cart houses will be provided which can be 379 manually moved to any hydrant where they are needed. It .s our 381 position that permanent hose houses, equipped with hose, aozzles 382 and other auxiliary equipment recommended in NFPA 24, be provided 383 as needed, but at least every 1,000 feet, in accordance with BTP 384 CNEB 9.5-1 Section C.5.b(7). 384 RESPONSE -

386 fection 3.1 of the FP R has been changed to address the 388 guidelines of RTP CMEB 9.5-1, including Section C.6.b(7). ,389 i

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MS FSAR 2 OUESTION 280.19 396 .

, Verify that the minimum fire water requirements are dedicated by 398 passive means in accordance BTP CMEB 9.5-1 Section C.5.b(11). 399 RESPONSE 401 Eection 3.1 of the FPER has been changed to address the 403 guidelines of BTP GMEB 9.5-1, including Section C.6.b(11). 404 i

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LGS FSAR 2 OUESTION 200.20 . 4ij i Verify that fixed water extinguishing systems conform to the 413 requirements of NFPA 13 and NFPA 15 in accordance with BTP 414 CHEB 9.5-1 C.I.c(3). -

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RESPONSE 416 Section 3.1 of the FPER has been changed to address the 418 guidelines of BTP CMEB 9.5-1, including Section C.6.c(3). 419 1

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} 2 OUESTION 280.2i 426 it is our position that the reactor recirculation pumps be 428 equipped with an oil collection system in conformance with 429 Section C77.a of RTP CHEB 9.5-1. Provide the design description 431 of this system. 431 RESPONSE 433 gection 3.1 of the FPER has been changed to address the 435 guidelines of RTP CHEB 9.5-1, including Section C.7.a. 436 V

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t QUESTION 280.22 443 Verify that all cables in the control room meet the separation 445 criteria and fire protection criteria detailed in BTP CHEB 9.5-1 446 Section C.7.b. 446

RESPONSE

448 fection 3.1 of the FPER has been changed to address the 450 guidelines of BTP CMEB 9.5-1, including Section C.7.b. 451

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' LGS FSAR v y U 2 w-OUESTION 280.23 458 Verify that smoke detectors have been provided in all control 460 ;

room cabinets and gonsoles in accordance with BTP CMEB 9.5-1 461 1 Section C.7.b. 461 l

i RESPONSE 463 fection 3.1 of the FPER has been changed to address the 465 guidelines of BTP CMEB 9.5-1, including Section C.7.b. 466 i

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LGS FSAR 2 OUESTION 280.24 473 Qn page 9.5-12 of the FSAR, it is stated that primary f' ire 475 suppression in the cable spreading room is provided by a total 476 flooding CO, extinguishing system. It is our position that the 477 primary fire suppression in the cable spreading room _be an 478 automatic water system in conformance with BTP CMEB 9.5-1 478 Section C.7.c. 478 RESPONSE 480 fection 3.1 of the FPER has been changed to address the 482 guidelines of RTP CMEB 9.5-1, including Section C.7.c. 483 O

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2 OUESTION 280.25 490 Verify that the loss of ventilation in the safety-related battery 492

.Iooms is alarmed in accordance with BTP CMEB 9.5-1 Section C.7.g. 493 RESPONSE I 495 l 1

Eection 3.1 of the FPER has been changed to address the 497 l guidelines of RTP CMEB 9.5-1, including Section C.7.g. 498 g - --

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CHAPTER 3 COMPARISON BETWEEN LGS FIRE PROTECTION PROGRAM AND NRC GUIDELINE DOCUMENTS 3.1 NRC BRANCH TECHNICAL POSITION CMEB 9.5-1 l The purpose of this section is to compare the fire protection provisions of Limerick Generating Station-(LGST units 1 and 2 with the guidelines in Branch Technical Position CHEB 9.5-1.

To identify areas of potential impact and to facilitate

'gomparison, a matrix addressing each guideline of the BTP and l relating to the plant systems, equipment, and components, Ts included as Section 3.1.1. The matrix has extracted all suggested guidelines from the BTP and given each an item number, I through.255. Each item Eas condensed a particular guideline and makes reference to the section in the BTP where that guideline can be found. The general degree of conformance to the guideline is indicated in the " comparison" column, using codes defined as follows:

l C

- indicates conformance to the guideline or conformance to its intent. Substantiating statements may be included as part of the matrix or in Section 3.1.2.

AC - indicates conformance to the guidelines by alternate means or methods. The manner of conformance is included in the matrix or discussed in Section 3.1.2.

EC - indicates that design changes, means, or methods are glanned in order to conform, or conform to the intent gf the guideline. The planned design changes, means, or methods and the manner of gonformance may be discussed in the matrix or in Section 3.1.2.

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NC - indicates that the plant is not in conformance and no design changes are planned. The basis f,r non-conformance to the guideline is included in the matrix gr discussed in Section 3.1.2.

NA - indicates that the guideline is not applicable to Limerick Generating Station Units 1 and 2.

Substantiating statements are included as part of l

the matrix in Section 3.1.1. /

3-1 REV. 2, 11/82

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LGS FPER - - 1 In the " remarks" column, additional information is Erovided to explain or expand on the degree of conformance. Alternatively, reference may be made to Section 3.1.2 (or other sections in this report) for a more detailed discussion. The item numbers in Section 3.1.2 correspond to those in SectTon 3.1.1.

l 3-1 REV. 2, 11/82

LGS FPER SECTION 3.1.1

,, DETAILED COMPARISON '!D BR ANCH TECHNICAL POSITION CMEB 9.5-1 CMEB 9.5-1 1 CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON- REMARKS Fire Protection Proara,a

10 Direction of fire protection program; availability of personnel.

C.1.a (1) WC

2. Defense-in-depth concept; objective of fire C. I . a (2) WC protection program.

30 Management responsibility for overall fire pro-tection program; delegation of responsibility to staff. C.1.a (3) WC 4 The staff should be responsible for: C.1.a (3) WC (a) Fire protection program re.pairements.

(b) Post-fire shutdown capability.

(c) Design, maintenance, surveillance, and quality assurance of all fire protection features.

(d) Fire prevention activities.

(e) Fire brigade organisation and training.

(f) Prefiro planning.

5. The organisational responsibilities and' lines of C. I.a (4) communication pertaining to fire protection should be defined through the use of organizational WC h' D charts and functional descriptions. O

6. Personnel qualification requirements for fire C.1.a (5) (al WC protection engineer raporting to the position responsible for tormulation and implementation of the ftre protection program.

7. The fire brigade members' qualifications should C.1.a (5) (b) WC r-include a physical eramination for performing L strenuous activity, and the training described in _L Position C.3.d.

8. The personnel responsible for the maintenance and C.1.a (5) (c) WC testing of the fire protection systems should be qualified by training and experience for such work.

j 3-3 REV. 2, 11/82

l ISS FPER CMEB 9.5-1 ,

1 NO. OtE8 9.5-1 GUIDELINE __

ITEM NO. CO WARISON REMARKS

9. The personnel responsible for the training of the C.1.a (5) (d) WC fire brigade should be qualified by training and I

experience for such work.

10. The following WPA publications should be used for C.1.a (6) WC guidance to develop the fire protection program; No. 4, No. 4A, No. 4, No. 7, No. 6, No. 27. -

110 on sites where there is an operating reactor and C.1. a (7) WC construction or modification of other units is underway, the superintendent of the operating plant should have a lead responsibility for site fire protection.

Fire Bazards Analysis

12. The fire hasards analysis should demonstrate that C.1.b c See Chapters 4 and 5 the plant will maintain the ability to perform safe shutdown functions and minimize radioactive releases to the environment in the event of a fire.

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, 13. The fire hasards analysis should be performed by C.1. b C -

, fire protection and reactor systems engineers to C3 (1) consider potential in situ and transient fire hazards: (2) determine the consequences of a fire in any location in the plant; and (3) specify mea- N sures for fire prevention, detection, suppression, -

and containment. I

14. Fires involving facilities shared between units '

C.I.b C Fires are postulated to occur in should be considered. structures such as the control i structure and the spray pond pump ~~

L structure that are cosmon to both reactor units.

15. Fires due to man-made site-related events that Col.b c See Section 3.1.2.

have a reasonable probability of occurring and i affecting more than one reactor unit chould be .

considered.

16. Establishment of three levels of fire damage C.1. b C limits according to safety function (hot shutdown; cold shutdown; design basis accidents) .

17. The fire hasards analysis should separately iden- c.1.b C tify hazards and provide appropriate protection in iocations where safety-related losses can occur.

1

, 3-4 REV. 2, 11/82 i

LGS FPER CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COW ARISON REMARKS Fire Sucoression System Desian Basis 180 Total reliance should not be placed on a single C.1.c (1) C All automatic fire suppression fire suppression system. Backup fire suppression systems are backed up by two methods capability should be provided. of manual extinguishment (hose stations and portable extinguisheral.

l 19. A single active failure or a crack in a moderate- c.1.c (2) C See Section 3.1.2.

l energy line in the fire suppression system should not impair both the primary and backup iire suppression capability.

20. The fire suppression system should be capable C.1.c (3) NC See Item 155.

of delivering water to manual hose stations located within hose reach of areas containing equipment required for safe shutdown following an SSE.

21. The fire protection systems should retain their C.1.c (4) C See Section 3.1.2.

] original design capability for natural phenomena ' >

! of less severity and greater frequency than the most severe natural phenomena. I i .

O

22. The fire protection systems should retain their C.1.c (4) NC See Section 3.1.2.

original design capability for potential man-made site-related events that have a reasonable proba- N bility of occurring at a specific plant site.

I

23. The effects of lightning strikes should be in-cluded in the overall plant fire protection C. 1.c (4) C Lightning protection is provided per NFPA No. 78.

kr program. -

I L

24 0 The consequences of inadvertent operation or of a C.1.c (5) C See Section 3.1.2.

crack in a moderate-energy line in the fire

! suppression system should meet the guidelines specified for moderate-energy systems outside

containment in SRP Section 3.6.1.

j Alternative or Dedicated Shutdown l 25. Alternative or dedicated shutdown capability C.1.4 AC See Item 20 of Section 3.2.1.

1, should be provided where the protection of systems l whose functions are required for safe shutdown is i not provided by established fire suppression met-i hods or by Position C.S.6.

}

4 i

3-5 REV. 2, 11/82

IAS FPER CMEB 9.5-1 NO. CNES 9.5-1 GUIDELINE ITEM NO. CO W ARISON REMARKS i

Imolementation of Fire Protection Programs l

26. The fire protection program for buildings storing C.1.e (1) C The fire protection program for the l new reactor fuel and for adjacent fire areas new fuel area will be completed and .

. that could affect the fuel storage area abould fully operational before fuel is i be fully operational before fuel is received at received at the site.

3 -

the site.

27. The fire protection program for an entire reactor C.1.e (2) C unit should be fully operational prior to initial fuel loading in that reactor unit.

2 80 Special considerations for the fire protection C.1.e (3) C See Section 3.1.2.

program on reactor sites where there is an operating reactor and construction or modifica-tion of other units is under way.

Administrative Controls

< 29. Establishment of administrative controls to main- C.2 WC tain the performance of the fire protection -

system and personnel.

Fire Brigade C"7

30. The guidance in Regulatory Guide 1.101 should be C.3.a WC followed as applicable.

c:=-

i 310 Establishment of site brigades minimum number of C.3.b WC _

fire brigade members on each shift; qualification g of fire brigade members; competence of brigade 1eader.

g q g l 32. The minimum equipment provided for the brigade C.3.c WC

, should consist of turnout coats, boots, gloves, L i hard hats, emergency communications equipment, i portable ventilation equipment, and portable extinguishers.

l 33. Recommendations for breathing apparatus for fire C.3.c WC See Section 3.1.2.

brigade, damage control, and control roon j personnel. ,

)

3 40 Recommendations for the fire brigade training program.

C.3.4 WC 1

i 3-6 REv. 2, 11/s2 i

i

IAS FPER CMEB 9.5-1 1 CNEB 9.5-1 GUIDEI.INE ITEM NO. COMPARISOrt RENARES j Quality Assurance Proaram ;

35. Establishment of quality assurance programs for C.4 AC/WC See Section 3.1.2.

the fire protection systems for safety-related I areas; identification of specific criteria for QA programs. ,

g] {

Buildine Desien I '

6 I

36. Fire barriers with a minimum rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months C. 5.a (1) (a) C Structures housing safety-related should be provided to separate safety-related systems are separated from non+

{

systems from any potential fires in nonsafety- safety-related structures by 3 h gl a related areas. rated fire walls. I i 37. Fire barriers with a minimum rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months C. 5.a (1) (b) AC See Section 3.1.2. L should be provided to separate redundant divisions

of safety-related systems from each other.

! 38. Fire barriers with a minimum rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months should be provided to separate individual units C. 5.a (1) (c) C Fire barriers rated for 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months are provided to separate Unit 1 structures on a multiple-unit site. from Unit 2 structures. Those struc-tures that are common to both reactor i

units (such as the control structure :

! are separated from the adjacent struc-tures of both reactor unite by 3-hour

! fire barriers.

l 39. Fire barriers should be provided within a single C. 5.a (2) AC See section 3.1.2. M b C airol ,

i safety division to separate components or cabling por b of n e. a that present a fire hazard to other safety-related

, components. gg gg4

40. Openings through fire barriers for pipe, conduit, C. 5.a (') WC See Section 3.1.2.

and cable trays which separate fire areas should 1 be sealed or closed to provide a fire resistance .

rating equal to that required of the barrier.

41. Recommendations for internal sealing of conduits C.S.a (3) AC See Section 3.1.2.

! penetrating fire barriers.

1 l 42. Fire barrier penetrations that must maintain C.S.a (3) C Frew-reled

environmental isolation or pressure differentials reqpired 4. perform penetration tsaals other barrier thatfunctions ars also

! should be qualifled by test.

I (Sut.h as memtowing are qualWwd by test Graaltpreneurs 46e Maled differential func .

) Ens +

1 k

j 430 Penetration designs should utilize only noncombus- C. 5.a (3) WC See Section 3.1.2.

tible materials.

h fire berrier be. tion. .t au psentrah seal 3-7 5 notquird to b peder -I sieuNesteously M arv other barrice funcl.lons.

IAS FPER C3 I CMEB 9.5-1 No. CMEB 9. 5-1 GUIDELINE _ ITEM NO. Col @ARISON REMARES C:>

40. The penetration qualification tests should use the C.S.a (3) C The time-temperature exposure curve -

i time-tesperature exposure curve specified by used in qualificati m tests for pene-ASTM E-119. tration seals is as specified by ASTM E-119-73. ,

U

45. Acceptance criteria for penetration qualification C.S.a (3) NC The acceptance criteria for penetra-tests. tion qualification tests are in agree-ment with those specified in paragraphs (a) , (b), and (c) cf Position C.5.a(3),e

46. Penetration openings for ventilation systems C.5.a (4) C Ventilation ducts that penetrate should be protected by fire dampers having a fire barriers are provided with 3-hour rating equivalent to that required of the barrier. rated fire dampers.at penetrations of 3-hour rated barriers and with 1.5-hour rated fire damperslat penetrations of 1-hour rated barriers. Both classifi-cations of fire dampers are UL-listed and manufactured to comply with NFPh 90 and the Commonwealth of Pennsylvania Fire Protection Code.

47. Flexible air duct couplings in ventilation and C. 5.a .(4) C filter systems should be noncombustible. -

48. Door openings in fire barriers should be protected C.S.a (5) AC See Section 3.1.2.

with equivalently rated doors, frames, and hard-ware that have been tee +ed and approved' by a nationally recognised labores. cry.

49. Fire doors should be self-closing or provided with C.5.a (5) AC See Item 40 of Section 3.2.1.

closing mechanisms.

50. Fire doors should be inspected semiannually to C.S.a (5) AC See Item 41 of Section 3.2.l.

verify that automatic hold-open, release, and closing mechanisms and latches are operable. ,

51. Alternative means'for ensuring that fire doors C.S.a (5) C See Item 42 of.Section 3.2.1.

protect the door opening as required in case of fire. .

52. The fire brigade leader should have ready access C.S.a (5) WC to keys for any locked fire doors.

530 Areas protected by automatic total flooding gas C.S.a (5) C See Item 44 of Section 3.2.1.

suppression systems should have electrically supervised self-closing fire doors or should escept 4 hat es unanimum. aNeedeble {eniperalure en na satisfy option (a) above.

m J & is 315 *F de MM i@In %*g It 'm., accordance wiMt. One ANI ' Steer ard liceed of Ore tests of Cable and Pipe 1%ne.tre. Hen Fire Steps."

Testing of fire-rated penetraUen se-Is is performed.

3-a A ocs.h ddh, AuI guidelines.

LGS FPER ,

CMEB 9.5-1 NO. CNEB 9.5-1 GUIDELINE ITEM NO. C0094RISON REMARKS

54. P9rsonnel access routes and escape routes should C.5.a (6) C All fire areas are provided with l be provided for each fire area. personnel access routes and eagepe routes.

( )

1

55. stairwells serving as escape routes, access routes for firefighting, or access routes to areas con-C.5.a (6) C h taining equipment necessary for safe shutdown y should be enclosed in masonry or concrete towers with a minimum fire rating of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and self- g closing Class B fire doors.

}

56. Fire exit routes should be clearly marked. C.S.a (7) WC ,

57. Each cable spreading room should contain only one C.S.a (8) NC The cable spreading room for each redundant safety division. reactor unit contains all four divie-ions of safety-related cabling.

Raceways containing the different divisions of cabling are separated from each other in accordance with l Regulatory Guide 1.75. Cabling associated with the remote shutdoest

panel is not rooted through the cable spreading roon. -

1

58. Cable spreading rooms should be separated from C.5.a (8) C each ,other and from other areas of the plant by barriers having a minimum fire resistance of

, 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

i

{ 59. Interior wall and structural components, thermal C.S.a (9) AC See Section 3.1.2.

. insulation materials, radiation shielding mate-

rials, and soundproofing should be noncombustible.

! 60. Interior finishes should be noncombustible. C. S..a (9) AC Areas containing systems or equipment a

1

, , required for safe shutdown of the plant are unfinished, or are finished with materials which are either noncom-

bustible or are listed by an 4 independent testing laboratory for j flame spread, smoke generation, and

fuel contribution of 25 or less, i

i 61. Metal deck roof construction should be noncombus- C.S.a (10) AC See Section 3.1.2.

i tible and listed as " acceptable for firea in the UL Building Materials Directory, or listed as i Class I in the Factory Mutual Approval Guide.

3-9 REV. 2, 11/82 l

E_ _ __ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ . _ _ _ _ , _ _ _ _ _ _ . _ _ . - _ . _ , . _- . _

IAS FPER i CMEB 9. 5-1 A CetEB 9. 5-1 GUIDELINE _. ITEM NO. COWARISON REMAJtRS

62. suspended ceilings and their supports should be of C.5.a (11) C The suspended ceillag in the control ,

noncombustible construction. room consists of mineral fiber panels resting on a metal grid system ;

which is supported by steel wires.

t These materials are either '

noncombustible or are listed by an i independent testing laboratory for

' flame spread, smoke generation, and ,

fuel contribution of 25 or less.

t i 63 Concealed spaces should be devoid of combusti- C.S.a (11) AC See Section 3.1.2.

bles except as noted in Position C.6.b.

64.- Transformers installed inside fire areas contain- C.5.a (12) C All indoor transformers are either i

ing safety-related systems should be of the dry air cooled, dry type, or cooled by type or insulated and cooled with non-coobustible noncombustible gases.

i liquid.

l 65. outdoor oil-filled transformers should have oil C.S.a (13) C See Section 3.1.2. I spill confinement features or drainage away from

! the buildings. m} . -

1-C.S.a (f3) C i

i i

65. outdoor oil-filled transformers should be located at least 50 feet distant from the building, or building walls within 50 feet of oil-filled trans-AC See section 3.1.2.

Q l formers should be without openings and have a >

j 3-hour fire resistance rating.

?

I j

j

67. Floor drains sized to remove expected firefighting water flow without flooding safety-related equip-C.S.a (14) C kr i ment should be provided in areas where fixed water I l fire suppression systems are installed. L .

J l 68. Floor drains should be provided in areas where C. 5.a (14) AC See Section 3.1.2.

hand hose lines may be used if such fire-fighting i water could cause unacceptable damage to safety-j related equipment.

i l 69. Where gas suppression systems are installed, the C. S.a (14) C The capacity of the carbon dioside drains should be provided with adequate seals, or storage tant is sufficient to the gas suppression system should be sized to compensate'for losses through

. compensate for the loss of the suppression agent the floor drains in the cable I through the drains. spreading rooms.

I

! 70. Drains in areas containing combustible liquids C.S.a (14) C See Section 3.1.2.

shodd have provisions for preventing the back-flow of combustible liquids to gafety-related

} areas through the interconnected drain systems.

I 1

t i 3-10 REV. 2, 11/82 i

Ir.S FPER CMEB 9.5-1 ,

A OtEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS

71. Water drainage f rom areas that may contain radio- C. 5.a (14) C Potentially radioactive liquid activity should be collected, sampled, and analysed wastes are collected and moni-before discharge to the environment. tored prior to discharge. '

Safe Shutdown capability

72. Fire damage should be limited so that one train C.5.b (1) WC of systems necessary to achieve and maintain hot

~

shutdown conditions from either the control room or emergency control station is free of fire

{ damage.

] 730 Fire damage should be limited so that systems C. S.b (1) WC E necessary to achieve and maintain cold shutdown Q.l/

f rom either the control room or emergency control station can be repaired within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

5 CD

l 74. Alternative means of ensuring that one train of C.S.b (2) AC See Item 18 of Section 3.2.f..

systems necessary to achieve and maintain bot shutdown is free of fire damage. 6

, 750 Provision of alternative or dedicated shutdown C.S.b (3) AC See Item 20 of Section 3.2.1.

capability in certain fire areas.

76. Alternative or Dedicated Shutdown Capability C. S. c --

See Items 25 through 26 of E- ,

Section 3.2. Lj j Control of Combustibles

77. Safety-related systems should be separated from C.S.d (1) C To the ' maximum extent possible, combustible materials where possible; where not significant concentrations of com-i possible, special protection should be provided bustible materials are located to prevent a fire from defeating the safety outside structures containinq

! system function. safety-related com.ponents. In those cases for which this is not j possible, such as the standby i

diesel-generator fuel oil day tanks, j special fire protection consisting

of automatic fire suppression

} systems and/or construction capa-j ble of withstanding a fire is provided.

l l 78. Bulk gas storage (compressed or cryogenic) should C.S.d (2) NC See Section 3.1.2.

1 not be permitted inside structures housing l safety-related equipment. Flammable gases should be stored outdoors or in separate detached i,

buildings.

l 3-11 REY. 2, 11/82

1 LGS FPER 1 .

i i CMEB 9.5-1

! A CMEs 9. 5-1 GUIDEIJ'tE ITEM NO. COMPARISON RENARES

79. High pressure gas storage containers stiould be C.S.d (2) C High pressure gas storage cylinders j located with the long axis parallel to building are stored vertically. f walls. *

80. Use of compressed gases inside buildings should be C.5.4 (2) WC See Section 3.1.2. i l controlled.

81. The use of plastic materials should be minimized. C.5.4 (3) C See Section 3.1.2.

l Halogenated plastics such as PVC and neoprene should be used only when substitute noncombus-tible materials are not available.

1 l 82. Storage of fla==mhle liquids should comply with C.S.d (4) C Liquid fuels are stored either in - 1

NFPA,30. aboveground tanks that have been d provided with suitable fire barriers or in underground tanks.

83. Byerogen lines in safety-related areas should be C.5.4 (5) C Hydrogen lines in safety-related i either designed to seismic Class I requirements, areas are designed to seismic C>-

l or sleeved, or equipped with excess flow valves. Class I requirements. ,

I l' Electrical Cab:,e Construction. Cable Travs. and Cable Penetrat;.ons +

84. '

Only metal should be used for cable trays. C.S.e (1) C Cable trays are of all-metal L construction.

i 85. Only metallic tubing should be used for conduit. C. 5.e (1) NC See Section 3.1.2.

l Thin-wall metallic tubing should not be used.

86. Flexible metallic tubing should only be used in C.5.e (1) C Flexible metallic tubing used at i short lengths to connect components to equipment. raceway connections to ca-pa===ets is limited to 5 feet in length.

j 87. Other raceways should be made of noncombustible C.S.e (1) C Gutter-type recogniya are of all-metal

materials. construction.

l

88. Redundant safety-related cable systems outside C.S.e (2) AC See Section 3.1.2.

the cable spreading room should be separated l- from each other and from potential fire exposure hazards in nonsafety-related areas by 3-hour i fire barriers. -

l l 89. These cable trays should be provided with con- C.S.e (2) NC Continuous'line-type heat detectors tinuous line-type heat detectors. are not proyided in cable trays.

i Smoke detectors of the ionization or

! photo-electric type are located

in areas through which safety-l related cable trays are routed.

l B

3-12 REV. 2, 11/82 1_ _ __ _ __ _ _ , . __ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _

, IAS FPER CMEB 9.5*1 NO. CMIB 9.5-1 GUIDELINE ITEM NO._ COpWARISON REMARKS

90. ~

cables should be designed to allow wetting down c.5.e (2) c cable insulating systems include i with fire suppression water without electrical proprietary jacketing materials

! faulting. designed for wetting.

! 91 Redundant safety-related cable trays outside the c.5.e (2) c 1 cable spreading room should be accessible for i

manual firefighting. Manual hose stations and portable hand extinguishers should be provided.

[

92. Safety-related cable trays of a single division c.5.e (2) NC Safety-related cable trays that are 4 that are separated from redundant divisions separated from their redundant divi-

by a 3-hour fire barrierishould be protected sions by 3-hour fire barriers are not i from the effects of a* potential exposure generally provided with automa*.ic ,

fire by providing automatic water suppression.

suppression system coverage. FFire-caused damage to a single train of I

d are aMM for safety-related components will not manual firefisMin3 have an adverse offact on the ability to achieve safe shutdoest.

93. Safety related cable trays that are not acces- c.5.e (2) MA Safety-related cable trays are not sible for manual fire fighting should be pro- routed through areas that are in-

, tected by an automatic water system. accessible for manual fire fighting.

93. Safety-related cable trays that are not separated C.S.e (2) NC See Section 3.1.2.

t from redundant divisions by 3-hour fire barriers l

should be protected by automatic water suppres- 'The (reys eLrt sion systems. eccessiWs for I

i. c manual fireQleUnj.

95. The capability to achieve safe shutdown consi- c.5.e~(2) See chapter 5.

I dering the effects of a fire involving fixed j and transient combustibles should be evaluated _ _ _ .

i with and without actuation of the automatic l suppression system. , Lj

{

96. Electric cable construction should pass the flame test in IEEE Std 383.

C.S.e (3) AC See Section 3.1.2. ha' IN I

97. Cable raceways should be used only for cables. c. 5.e (4) C

c>

1 l 98. Miscellaneous storage and piping for combustible c.5.e (5) c See Section 3.1.2.

, liguids or gases should not create a potential

j. exposure hazard to safety-related systems.

ventilation b t

[ 99. Smoke and corrosive gases should be discharged c.5.f (1) Ac See Section 3.1.2.

j directly outside to an area that will not affect safety-relaced plant areas.

2 I

3-13 REV. 2, 11/82

_ _ . .-. _ _ . . _ . .m---...------.--,-._-.,..-.----.e - - - . - - . - - - _.. - - - . - - .- - - --_. _ _ _ . _ _ _ _ _ _

i LGS FPER 4

CMEB 9.5-1

[ A CNES 9.5-1 GUIDELINE ITEM NO. COWARISON, REMARKS 1000 a

l ~

To facilitate manual firefighting, separate smoke and heat vents should be provided in C.S.f (1) NC See Section 3.1.2.-

l certain areas.

l 101. Release of smoke and gases containing radioactive C.5.f (2) C See Section 3.1.2. -

l materials to the environment should be monitored.

102. i

}' Any ventilation system designed to exhaust poten-tially radioactive smoke or gases should be C.5.f (2) AC See Section 3.1.2.

i evaluated to ensure that inadvertent operation or single failures will not violate the radio-logically controlled areas of the plant.

j 103. The power supply and controls for mechanical ven- C.S.f (3) AC See Section 3.1.2.

4 tilation systems should be run outside the fire area served by the system.

1040 Engineered safety feature filters should be pro- C. 5. f (4) C See Section 3.1.2.

tected in accordance with the guidelines of Regulatory Guide 1.52. .

j 105. Air intakes for wentilation systems serving areas C.S.f (5) C Air intakes serving areas which con-i containing safety-related equipment should be tain safety-related equipment are t

! located remote from the exhaust air outlets and remote from exhaust and ==aara outlets j smoke vents of other fire areas. of other fire areas.

4 i 106. Stairwells should be designed to minimize smoke C.5.f (6) C Stair towers are provided with self-

! infiltration during a fire. closing doors, which will minimise i

smoke infiltration during a fire. , ,j' .

107. L" ' ./

l Where total flooding gas extinguishing systems are ' C. 5.f (7) C See Section 3.1.2. ,

i used, ventilation dampers should be controlled in t-y accordance with NFPA 12 and NFPA 12A. ,

Lichtine and Communication C::n-4 108. Fixed self contained lighting units with individual C.S.g (1) AC See Item 23 of Section 3.2.2..

8-hour battery power supplies should be provided in areas that must be manned for safe shutdown g ,e and for access and egress routes to and from all fire areas. ,

L f 109. Sealed-beam battery powered portable hand lights C.5.g (2) WC Portable lights will be,provided..

! should be provided for emergency use.

I j 1100 Fixed emergency communications independent of the C.S.g (3) AC See Section 3.1.2.

3 the normal plant communication system should be j installed at preselected stations.

l 3-14 REV. 2, 11/82 i

In licu sf complsis reliano m WPA 72,E, smake and firs detectcr locabas arv. established.

LGS FPER hQ guthbed Ere pro {ectiert engineer.

CMEB 9. 5-1 NO. CMEB 9. 5-1 GUIDELINE ITEM NO. COWARISON REMARES 111. A portable radio communications system should be C.S.g (4) WC See section 3.1.2.

provided for use by the fire brigade and other operations personnel required to achieve safe plant shutdown.

Fire Detection 112. Detection systems should be provided for all C.6.a (1) AC Fire detection systems have been areas that contain or present a fire exposure provided for all areas that contain to safety-related equipment. safety-related equipment, with the exception of the service water pipe tunnel (fire area 75). As discussed in Section 5.4. 24, this area contains no combustible materials and the redundant componente needed for safe shutdown are widely separated.

113. Fire detection systems should comply with the C.6.a (2) C Class A systems are defined in the requirements of Class A systents as defined in 1975 edition of NFPA 72D.

NFPA 72D and Class I circuits as defined in NFPA 70.

114. Fire detectors should be selected and installed C.6.a (3) AC in accordance with NFPA 72E.

115. Testing of pulsed line-type heat detectors C.6.a (3) NA Pulsed 2ine-type detectors are not l should demonstrate that the frequencies used will used in the plant.

not affect the actuation of protective relays in other plant systems.

l[

116. Fire detection ayatoms should give audible and C. 6.a (4) C visual alarm and annunciation in the control room.

C>-

117. Where zoned detection systems are used in a given C.6.a (4) C A coding system has been established I fire area, local means should be provided to iden- for all fire alarms in the plant so ,

tify which sone has actuated. that the location of a fire can be determined from the sound of the alarm. A list of these codes and I]

their corresponding detection areas I will be posted at each fire alarm pull station.

118. Local audible alarms should sound in the fire area. C.6.a (4) C Fire alarms are annunciated throughout the plant, as well as in the local area in which a fire detector has been actuated.

3-15 REV. 2, 11/82

, n

. t ISS FPER CMEB 9.5-1 A CMEB 9.5-1 GUIDELINE ITEM NO. COWARISON REMARKS 119. Fire alarms should be distinctive and unique so C.6.a (5) C W they will not be confused with any other plant system alarms.

.(

k C aj 120. Primary and secondary power supplies which C.6.a (6) AC See Section 3.1.2. O satisty the provisions of Section 2220 of NFPA 72D ,

should be provided for the fire detection system '

and for electrically operated control valves for automatic suppression systems. Al6

=

Fire Protection Water Supply Systems .

121. An underground yar'd fire main loop should be C. 6.b (1) C An underground yard fire main laop t --r installed to furnish anticipated water has been provided and is in compli-requirements. ance with NFPA 24. L 122. Type of pipe and water treatment'should be design C.6.b (1) C The yard fire main loop utilises considerations with tuberculation as one of the cement-lined cast iron pipe to parameters. reduce tuberculation. Water used for fire protection service meets the requirements of NFPA 22 and does act <

require treatment. '

123. Means of inspecting and flushing the systems C.6.b (1) C Following its installation the yard should be provided. fire main loop was flushed and tested in accordance with.IWPA 24 - 1973, i

Sections 98 and 99. Flushing of the loop is accomplished through the use of sectional control valves to direct the flow and yard hydrants to serve as j discharge points.

124. Approved visually indicating sectional control C.6.b (2) C Post indicator valves provided for valves should be provided to isolate portions of sectionalised control and isolatica the main for maintenance or repair. of portions of the yard fire main

loop.

125. Valves should be installed to permit isolation C.6.b (3) C A key-operated gate valve with a of outside hydrants from the fire main for main- curb box is provided in each lateral tenance or repair without interrupting the water from the yard fire main loop to a supply to automatic or manual fire suppression fire hydrant.

systems. -

126. The fire main system piping should be separate C. 6.b (4) C from service or panitary water system piping.

4 l

3=16 REV. 2, 11/82 I

i

l LGS FPER

, CMEB 9.5-1

& CMEs 9.5-1 GUIDELINE ITEM NO. COIWARISON REMARES 127. A common yard fire main loop may serve multi- C.6.b (5) C The yard fire main loop is common to unit nuclear power plant sites if cross-connecte'd both reactor units. The loop is ,

between units. Sectional control valves should cross-connected between units and .,

permit maintaining independence of the loop around provided with sectional control

each unit. valves.

128. A sufficient number of pumps should be provided C.6.b (6) C Dao fire pumps (one diesel-driven and r to ensure that 1005 capacity will be available one electric motor-driven) are pro-l~ assuming failure of the largest pump or loss of - vided, each capable of supplying 1005 offsite power. of the system flow requirements.

i 2 129. Individual fire pump connections to the yard C.6.b (6) C fire main loop should be separated with sec-tionalizing valves between connections. C I

+

I 1300 Each pump and its driver and controls should be C.6.b (6) C g- y separated from the remaining fire pumps by a 3-hour fire wall.

C> i 131. The fuel for the diesel fire pump should be C.6.b (6) C The diesel oil day tank is located separated so that it does not provide a fire , in a curbed area within the diesel- i j source exposing safety-related equipment. driven fire pump compartment. This compartment is located in the circa-p lating water pump structure, which ,

is separated from all structures con- g taining safety-related equipment.

I 132. Alarms indicating pump runnirg, driver availa- C.6.b (6) AC Pump running, driver availability, bility, failure to start, and low fire-main and failure to start are annunciated

! pressure should be provided in- the control room. in the. control room. Fire main <

l pressure is indicated in the control i

room but not annunciated..

133. The fire pump installation should conform to C. 6. b ' (6) C '

NFPA 20.

134. outside manual hoes installation should be suffi- C.6.b (7) AC Bydrants are spaced between 250 and cient to provode an effective home stream to any 300 feet apart along the fire main

, onsite location where fixed or transient combus- loop.

! tibles could jeopardize safety-related equipment.

! Hydrants should be installed approximately every l 250 feet on the yard main system.

i l 1350 Rom-ndations for hose houses and hose carts. C.6.b (7) C 'See Section 3.1.2.

} 136. Threads compatible with those used by local fire C.6.b (8) C i

departments should be provided on all hydrants, hose couplings, and standpipe risers, l 3,17 'REV. 2, 11/02 1

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~

CNEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEN NO. COWARISON RENARES 137. Two separate, reliable freshueter supplies should C.6.b (9) C The cooling teuer basins of the

, be provided. Unit 1 and Unit 2 circulating water systems are used as the two sources of water for the fire pumps. -

138.

Recommendations for tanks used to supply fire pro- C. 6.b (9) NA Tanks are not utilised for fire pro-taction water. , tection water supply.

139. Recommendations for tanks used to supply fire C.6.b (10) NA Tanks are not utilised for fire pro-protection water taction water supply.

140. The fire water supply should be based on the C.6.b (11) C See Section 3.1.2.

largest espected flow rate for a period of

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , but not less than 300,000 gallons.

141. The fire water supply should be capable of deli- C.6.b (11) C In the event that a portion of the vering the design demand over the longest route yard fire main loop is valved out of the unter supply system. of service, the fire pumps are caps-ble of delivering the design demand over the longest route of the unter

, supply system.

j 142. Recommendations for freshwater lakes or ponds C.6.b (12) NA Lakes or ponds are not utilised for l used to supply fire protection water. fire protection water supply.

j 143. Recommendations concerning use of a common water C.6.b (13) NA The fire protection system and the supply for fire protection and the ultimate heat ultimate heat sink 40 not share a

! sink. common water supply.

! 144 Recommendations concerning use of other water C.6.b (14) AC See Section 3.1.2. p! is j systems as the source of fire protection water.

(C":lPJ j unter sprinkler and nose standpipe systems g

i

~

145. Reca==andations concerning connection of sprinkler C.6.c (1) C See Item 19.

systems and manual hose station standpipes to the yard fire main loop. gg i

3 146. Each sprinkler and standpipe system should be C.6.c (1) AC See Section 3.1.2. ===g &

j equipped with OS&Y gate valve or other approved bJ ,

shutoff valve and waterflow alarm. -

l 1

! 147. Safety-related equipment should be protected from C. 6. c (1) AC See Section 3.1.2. '

i sprinkler discharge if such discharge could result "

l. in unacceptable damage to the equipment.

.i

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CMEB 9.5-1 A OtEB 9.5-1 Gt f DELINE ITEM NO. CQlfARISON REMARKS

. 148. Control and sectionalizing valves in the fire C.6.c (2) C See Section 3.1.2.

water systems should be electrically supervised ,

(with indication in the control room) or adminis- ?'

tratively controlled.

149. All valves in the fire protection system should C.6.c (2) WC be periodically checked to verify position.

150. Fixed water extinguishing systems should conform C.6.c (3) C to requirements of NFPA 13 and NFPA 15.

151. Recommendations for interior manual hose C.6.c (4) NC See Section 3.1.2. -

installations.

152. Individual standpipes should be at least 4 inches C.6.c (4) AC Wet standpipes are not less than 3 in diameter for multiple hose connections and inches in diameter for one or two

{ and 2.5 inches in diameter for single hose hose connections and 4 inches in connections, diameter for three or more hose connections.

153. Standpipe and hose station installations should, C. 6.c (4) C 4 follow the requirements of NFPA 14.~

! 154. Hose stations should be located as dictated by the C.6.c (4) C fire hazard analysis to facilitate access and use (

l for fire fighting operations.

C7 155. Recommendations concerning seismic design of C.6.c (4) NC See Section 3.1.2.

standpipes and hose connections.

i 156. Recommendations concerning hose noasle selection. C.6.c (5) WC

. )b i e 1

157. Fire home should be hydrostatically tested in accordance with NFPA 1962. Hose stored in out-C. 6.c , (6) WC 1

y ,a I side hose houses should be tested annually.

l Interior standpipe hose'should be tested every y 3 years.

B l 158. Consideration of foam suppression systems for C.6.c (7) C See Section 3.1.2.

i flammable liquid fires.

Halon Suppression Systems l 159. Halon fire extinguishing systems should comply C.6.d C ' Design and installation of the Halon with NFPA 12A and NFPA 128. Only UL-listed or 1301 system is in accordance with FM-approved agents should be used. NFPA 12A.

1 i

3-19 REV. 2, 11/82 1

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It.S FPER CMEB 9.5-1

, A CMEB 9.5-1 GUIDELINE ITEM NO._ COMPARISON RENARKS 140. Provisions for locally disarming automatic Halon C.6.4 WC systems should be key locked and under administra-tive control. Automatic Halon systems should not be disarmed unless controls as described in Position C.2.c are provided.

161. Preventive maintenance and testing of the systems, C.6.4 C including check-weighing of the Halon cylinders, t should be done at least quarterly.

1620 Considerations for design of Halon suppression C.6.4 C See Section 3.1.2.

systems.

. Carbon Dioxide Superefssion Svetens i 163. Carbon dioxide extinguishing systems should comply C.6.e C with the requirements of NFPA 12.

I 1640 Automatic carbon dioxide systems should be C.6.e C equipped with a predischarge alarm system and .

a discharge delay to permit personnel egress. ,

165. Provisions for locally disarming automatic carbon C.6.e WC .

1 dioxide systems should be key locked and under administrative control. The systems should not I be disarmed unless controls as described in Position C.2.c are provided.

")

1660 Considerations for design of carbon dioxide C. 4. e C See Section 3.1.2.

suppression systems. yg i Portable Extinguishers IW 1670 Fire extinguishers should be provided in areas C.6.f* C 1 that contain, or could present a fire exposure I hazard to, safety-related equipment in accor-I dance with NFPA 10. ,m-t 168. Dry chemical extinguishers should be installed C. 6. f C 1 -

k I~ with due consideration given to possible adverse effects on safetywrelated equipment.

I k

i 1.

3-20 REV. 2, 11/82

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l CMEB 9.5-1 A CNEB 9.$-1 GUIDELINE ITEM NO. COMPARISON REnMtRS -

Primary and Secondary Containment 169. Fire protection for the primary and secondary C.7.a (1) C Fire hasards have been identified, z containment areas should be provided for hazards as Giscussed in Chapter 4, and fire identified by the fire hasards analysis.

suppression systems have been pro-vided accordingly. The types and locations of suppression systems are )

identified in Table A-1 and Figures B-4 through B-13 170. Because of the general inaccessibility of primary C.7.a (1) NC See Section 3.1.2.

containment during normal plant operation, protec-tion should be provided by automatic fimod systems.

171. operation of the fire protection systems should C.7.a (1) (a) C Ttw fire protectica system does not not compromise the integrity of the containment penetrate the' primary containment or other safety-related systems. boundary. Also see item 24. g 172. The primary containment is inerted IM Recommendations for protection of safety-related C. 7.a (1) (b) NA cables and equipment inside noninerted with nitrogen during reactor >

containments. ,

operation.

173. Ren=mdations concerning fire detect; ion inside C. 7.a (1) (c) NC See Section 3.1.2.

the primary containment.

_1

I l 174. For BWR dryuells, standpipe and hose stations C.7.a (1) (d)

WC The hose reels located nearest.the y should be placed outside the drywell with ade- drywell entrances are equipped with quate lengths of hose, no longer than 100 feet, a 100-foot length of fire hose. To to reach any location inside the drywell with supplement this hoes length, a home an offective hose stream. cart equipped with enough hose to reach any location within the drywell will be located near each drywell entrance.

175. Recommendations for reactor coolant pump oil C. 7.a (1) (e) NA The primary containment is inerted collection systems in noninerted containments. with nitrogen during normal reactor operation. l 176. For secondary containment areas, cable fire C. 7.a (1) - See Items 88 through 95.

hazards that could affect safety should be protected as described in Position C.S.e(2) .

177. Self-contained breathing apparatus should be pro- C.7.a (2) WC See Iten 33.

vided near the containment entrances for firefight-ing and damage control personnel. These units should be independent of any breathing apparatus provided for general plant activities.

3-21 REV. 2, 11/82 I

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CMEB 9.5-1 NO. CMEB 9.5-4 GUIDELINE ITEM NO. COWARISON REMARKS Cgntrol Room complex 178. The control room complex should be separated C.7.b c from other areas of the plant by 3-bour rated fire barriers. J 179. RF - edations concerning peripheral rooms in the C.7.b NC See Section 3.1.:2.

control room complex.

180. Recn==agdations concerning the use of Halon and C.7.b NA The peripheral roces adjacent to the carbon dioxide flooding systems in the peripheral control room are mot provided with g rooms. Halon or carbon dioxide flooding systems.

181. Recommendations concerning manual fire fighting C.7.b C See Section 3.1.2.

capability in the control room.

182 Recommendations concerning fire detection in the C. 7. b AC See section 3.1.2. , i control room. ,

183. Breething apparatus for control room operators C.7.b WC See Item 33. %

should be readily available.

184. Recommendations concerning control room C.7.b c See Section 3.1.2.

ventilation.

185. All cablas that enter tpne control room 'should C.7.b c terminate in the control room.

186. Cables in underfloor and ceiling spaces should C.7.b C See.Section 3.1.2.

meet the separation criteria necessary for fire protection.

187. Air-handling functions should be ducted separate- C. 7.b ' C The space above the suspended ceiling ly from cable runs in such spaces. in the control room is not used as an air plenum for ventilation of the con-trol room. Ventilation air is ducted through the space above the suspended ceiling.

188. Fully enclosed electrical raceways located in C.7.b C None of the fully enclosed raceways underfloor and ceiling spaces, if over 1 square in the space above the suspended foot in cross-sectional area, should have auto- ceiling in the control room has a matic fire suppression inside. ' cross-sectional area exceeding 1 square foot. The raceways in the raised flooring of the auxiliary equipment room are provided with an automatic Halon suppression system, as described in Section 2.9.

3-22 REV. 2, 11/82

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CMEtt 9.5-1 -

l No. OtEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARRS 189. Recommendations concerning automatic fire suppres-sion in underfloor and ceiling spaces.

C.7.b NC See Section 3.1.2. ho

-W ,

190. There should be no carpeting in the control room. C.7.b c >

Cable Spreadino Doom 4 ,

191. Recommendations concerning automatic fire suppres- C.7.c AC See Section 3.1.2.

sion in the cable spreading room.

192.

Open-head deluge and open directional spray sys- C.7.c NA Open-head water suppressirwt systems '

tems should be zoned. are not used in the cable spreading room. .

193. Cable spreading rooms should have at least two re- C.7.c (1) C Each cable spreading row is provided * ,

note and separate entrances for access by fire with at least three entzences at brigade personnel. widely separated locations.

194. Cable spreading rooms should have an aisle , C. 7. c (2) MC' Cable treys in,4he cable spreadin separation between tray stacks at least 3 feet errengeal te peeride elsleways w%garooms delsman, een wide and 8 feet high. head a emmdely & 5 feet h h end a. .

.4ai=um s bebe.= tesy dec of appremmed*ly 3 feet. 4 certain locabens', stendural 195. Cable spreading rooms should have hose stations C.7.c (3) C sepperU for Es table tray 6 redeCe Et and portable extinguishers installed immediately sists as. s ta e, s h ,( ly gehog, outside the room.

196. Cable spreading rooms should have area smoke C.7.c (4) C

. detection.

197. Cable spreading rooms should have continuous C.7.c (5) MC Continuous line-type heat detectors line-type heat detectors for cable trays inside are not used in cable trays. Smoke the cable spreading room, detectors are provided in the cable spreading. room (as specified in Table A-1) and will provide early warning for cable tray fires occur-

'- ring in the cable spreading room.

I 198. Drains to remove firefighting water should be C. 7.c C provided.

i 199. When gas systems are installed, drains should have C.7.c C The capacity of the carbon dioxide adequate seals or the gas extinguishing systems storage tank is sufficient to com-should be sized to compensate for losses through 'pensate for losses through the the drains. , floor drains in the cable spreading

. rooms.

200. A separate cable spreading room should be pro- C.7.c' NC See Item 57.

vided for each redundant division.

3-23 REV. 2, 11/82

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i CMEB 9.5-1 I

! A CMES 9.5-1 GUIDELINE ITEM No. COMPARISON REMARKS t- y r 1

i 2010 Cable spreading rooms should not be shared between C.7.c C Each reactor unit is provided with ,

l reactors. its own separate cable spreading c::=-

i room.

I c

l l

2020 Each cable spreading room should be separated from the others and from other areas of the plant by 3-C.7.c Qp .

j hour fire barriers. , ;

i L' 203.

1 The ventilation system for the cable spreading C.7.c C In the event of actuation of the car-i room should be designed to isolate the area upon bon dioxide system in the cable j actuation of the gas extinguishing system. spreading room, ventilation ducts penetrating the boundaries of the ,

room are automatically isolated by .

steam isolation dappers. The dampers

are actuated by pressure switches I connected to the carbon dioxide dis-tribution piping.

204. Separate manually actuated smoke ironting that is C.7.c NC The normal ventilation system is used I

operable from outside the room should be provided to exhaust smoke from the cable i for the cable spreading room. spreading rooms. The awhaust from the I

cable spreading rooms is discharged i

to the generator equipment area of j the turbine enclosure.

i Plan $ Computer pocas l 205. Recommendations concerning fire protection for C.7.4 NA The plant computer is not safety-i computers performing safety-related functions. related.

l l 206. Nonsafety-related computers outside the control C.7.4 AC The plant computer is nonsafety-

} room should be separated from safety-related related and is located in the areas by 3-hour fire barriers and should be pro- auxiliary equipment room. The

! tected as needed to prevent damage to safety- acxiliary, equipment room is separated

! related equipment. from other areas of the plant by

}

3-hour fire barriers, but the compu-4 ter is not separated (other than by I

distance) from safety-related panels j -in the auxiliary equipment room. l Automatic fire suppression for the raised flooring in the auxiliary equipment room is discussed in

! Section 2.9.

1 i

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3-24 REV. 2, 11/82

4

. 6 ItaS FPER ,

l l CMEB 9.5-1 NO, OtEB 9.5-1 GUIDELINE ITEM NO. COf@ARISON

REMARKS l Switcheear Roome 207. Switchgear rooms containing safety-related equip- C.7.e AC The safety-related switchgear rooms i ment should be separated from the remainder of at elev. 239 *eet in the control t I the plant by 3-hour fire barriers. Redundant structure are separated from each switchgear safety divisions should be separated other and f rom the remaining areas l from each other by 3-hour fire barriers. of the plant by 3-hour rated fire

! walls. The concrete slab above these i rooms is a 3-hour rated barrier, and f the slab below the room is capable l of a 3-hour fire rating with the I

exception of exposed structural steel members supporting the slabs. .

, 208. Automatic fire detectors should alarm and annun- C.7.e C Each safety-related switchgear room

] ciate in the control room and alarm locally. is provided with smoke and heat i detectors that annunciate in the

] control room and alarm locally.

I 209. Fire hose stations and portable fire extinguishers C.7.e C

should be readily available outside the switch-gear rooms.

e

] .

l 2100 Drains should be provided to prevent water accu- C.7.e NC See Section 3.1.2.

mulation from damaging safety-related equipment.

! 211o Remote manually actuated ventilation should be C.7.e NC Ventilation features separate from

! provided for venting smoke when manual fire the normal ventilation system are i suppression effart is needed. not provided for the switchgear rooms. Smoke removal can be accomplished using portable exhaust fans, if necessary.

Remote Safety-Related Panels 1.

sCy 212. Recommendations concerning separation and electri- C.7.f AC See Section 3.1.2.

cal isolation of remote safety-related panels.

213. The general area housing remote safety-related C.7.f C =

]l panels should be provided with automatic fire I

i detectors that alarm locally and alarm and -

I

. annunciate in the control room. Combustible materials should be controlled and limited to L j those required for operation. Portable ex- L tinguishers and manual hose stations should be readily available in the general area.

I I

J l

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REV. 2, 11/82

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I IES FPER CMEB 9.5-1

_ggg,_ CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS %l Safety-Related Battery Rooms y 214. Safety-related battery rooms should be separated C.7.g AC The safety-related battery rooms are from each other and other areas of the plant by located in the control structure. -

3-hour rated fire barriers. These rooms are separated from each

! other and from the remaining areas l of the plant by 3-hour rated fire [ y 1 walls. The ficor slabs above and

! below the battery rooms are capable of 3-hour fire ratings with the l exception of exposed structural i steel members supporting the concrete

! slabs.

t

215. DC switchgear and inverters should not be located C.7.g AC j in safety-related battery rooms.

4 4 216. Automatic fire detection should be provided to C.7.g C Each safety-related battery room is

! annunciate in the control room and alarm locally. provided with smoke and heat detec-s tors that annunciate in the control j room and alarm locally.

217. Ventilation systems in the battery rooms should C.7.g C See Section 3.1.2.

4 be capable of maintaining the hydrogen concen-

tration below 25.

l 218. Ioss of ventilation should be alarmed in the C.7.g C See Section 3.1.2.

! control room.

b 2190 Portable extinguishers and manual hoes stations C. 7. g C i should be readily available outside the battery rooms.

'nsrbine Buildine 220. The turbine building should be separated from C.7.h C The turbine enclosure is separated l adjacent structures containing safety-related from the reactor enclosure and con-I equipment by 3-hour fire barriers. trol structure by 3-hour rated fire walls.

2210 The fire barriers should be designed so as to C.7.h C See Section 3.1.2.

maintain structural integrity in the event of collapse of the turbine structure.

j 222. Openings and penetrations in the fire barrier C.7.h C- See Section 3.1.2.

should be minimized and should not be located where the turbine oil system or generator B 9 hydrogen cooling system creates a fire expo- c,hargers and dc, fues leauss are located h N, safek Ny* ,

i sure hazard to the barrier. '7 NS dee$ Wk b WIGS lhal k Serve.

j . o&er de poner sysjem, cec-+r ds (such as inverters and I

3 26 de P***r DOM *W PemIS) are IMd *dside k bette*y rooms.

i,

1 LGS FPER I CMEB 9.5-1 O NO. CMEB 9. 5-1 GUIDELINE ITEM NO. C00@ARISON REMARES Diesel Generator Areas >

223. Diesel generators should be separated from each C.7.1 C I ,

other and from other areas of the plant by ,

3-hour rated fire barriers. L I

224. Automatic fire suppression should be installed to C.7 4 AC See Section 3.1.2. In -

combat diesel generator or lubricating oil fires.

Such systems should be designed for operation when the diesel is running without affecting the diesel.

225. Automatic fire detection should be provided to C.7.1 C annunciate in the control room and alare locally.

226. Portable extinguishers and manual hose stations C. 7 1 C Portable extinguishers are available should be readily available outside the area. outside the diesel-generator cells.

Fire hydrants located in the yard can reach any area of the diesel-generator cells.

[ 227. Drainage for'firefighting water and means for C.7.1 AC See Section 3.1.2.

local manual venting of smoke should be provided.

228. Day tanks with total capacity up to 1100 gallons C.7.1 C The day tank for each diesel-are permitted in the diesel generator area under generator has a capacity of 800 7

specified conditions. gallons.

t i

229. The day tank should be located in a separated on- C.7.i C Me day tank for each~ diesel generator closure with a 3-hour fire rating. is located in a vault that is separa-1 ted f rom the remainder of the diesel-generator cell by 3-hour rated fire j walls.

l 230. The day tank enclosure should be capable of con- C. 7. i ' C j taining the entire contents of the tank. -

231. The day tank enclosure should be protected by an C.7.i' C he pre-action sprinkler system pro-automatic fire suppression system. vided in each diesel-generator cell includes coverage of the day tank vault.

Diesel Fuel Oil Storace Areas i 232. Recommendations concerning diesel f uel oil tanks. C.7.j C Each diesel-generator is provided j with a diesel fuel oil storage tank

that has a capacity of 41,500 gallons.

l All eight tanks are located adjacent j to each other and are buried

underground.

3-27 REY. 2, 11/82 1

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CMEB 9.5-1 i NO. CMEB 9.5-1 GUIDELINE ITEM No. COWARISON REMMtKS l

2330 Above-ground tanks should be protected by an C.7.j NA See Item 232.

automatic fire suppression system.

Safety-Related Pumps "

234. Pump houses and rooms housing redundant safety- C.7.k C The safety-related pump compartments related pump trains should be separated from each located at elevation 177 feet in the other and from other areas of the plant by 3-hour reactor enclosure are separated from rated fire barriers. each other and from other areas of

the plant by 3-hour rated fire walls.

The spray pond pump structure is located remote from other plant structures, and the two divisions of pumps within the structure are separa-4 ted by a 3-hour rated fire wall.

235. These rooms should be protected by automatic C.7.k C The BPCI pump compartment and the

'. fire suppression unless a fire hazards analysis RCIC pump compartment are protected can demonstrate that a fire will not endanger by automatic pre-action sprinkler

equipment required for safe shutdown.

- systems. Fires originating in other 3

safety-related pump compartments

' would not endanger other safety- J related equipment required for safe C l shutdown, as discussed in Chapter 5.

236. These rooms should be provided with automatic C.7.k C

{ fire detection to annunciate in the control room and alarm locally. '

237. Portable extinguishers and manual hose stations C.7.k NC Portable extinguishers are provided i~ should be readily accessible. for use in all areas housing safety- I l

related pumps. Manual hose stations are provided for use in all areas housing safety-related pumps, except 3

for the spray pond pump structure. 6 In consideration of the low combus-

. tible loading in the spray pond pump

) structure, portable extinguishers are j deemed adequate to control and extin-i guish a fire at any pump.

1

( 238. Floor drains should be provided to prevent water C.7.k C

accumulation from damaging safety-related equipment.

l I

4 l

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CMEB 9.5-1 NO, CMEB 9.5-1 GUIDELINE ITEM NO. COWARISON REMARKS h{ C7 W 2390 Provisions should he made for manual control of C.7.k C The ventilation systems in areas >-

the ventilation system to f acilitate smoke ~

housing safety-related pumps are removal. Provided with controls that are sufficient to permit manual control of the ventilation as necessary to facilitate smoke I

removal. g

.e. ruei nr l

l 240. Recommendations for fire protection of the new C.7.1 NA/AC :

fuel area.

I

Spent Fuel Pool Area l 241. Protection for the spent fuel pool area should be C.7.m C Hose stations and portable eatinguis-

} provided by hose stations and portable hers are located near the spent fusi j extinguishers. Pool.

j 242. Automatic fire detection should be provided to C.7.m NC See Section S.I.f..

annunciate in the control room and to alarm

, locally.

Radwaste and Decontamination Areas 243. Fire barriers, automatic fire suppression and C.7.n C l and detection, and ventilation controls should See Section 3.1.2.

l be provided.

l Safety-Related Water Tanks 244. Fire protection provisions for safety-related C.7.o NA The plant has no safety-related water

! water tanks. tanks.

i

Records Storaeo Areas l

t 245. Records storage areas should be so located and C.7.p WC protected that a fire in these areas does not expose safety-related systems or equipment.

5 The normal storage aretfer new bl is k spent fuel pool.

j

' Prior la plant operalion, and. during he. InNial phases of plant operation, new fuel may be stored. in a. taaporary oddaer stwase area. % pndec.tsn for Als tenporary na, f l. storeg.

area. W be provided in accordonce toAS Suidelines established ,

l by American. Nuclear Insurere.

3-29 REv. 2, 11/82

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MS MR s CMEB 9.5-1 l

A CMEB 9.5-1 GUIDELINE ITEM No. _CgllPMtISON REMARKS

Cooline Towers l 2 6. Cooling towers should be of noncombustible con- C.7.q C The cooling towers are of noncombus-

struction or so located and protected that a tible construction except for the !

! fire will not adversely affect any safety-related fill material, which is polyvinyl -

systems or equipment. chloride. No safety-related struc= C:::-)

j tures or systems are located near ;

the cooling towers such that they

could be affacted by a fire in the C3 l cooling towers.

247. Cooling towers should be of noem=8==tible con- C.7.q AC See Section 3.1.2. b struction tshen the basins are used for the . --

ultimate heat sink or for the fire protection I water supply.

Qr Miscellaneous Areas I

248. Incation and protection of miscellaneous areas.

L C.7.r C See SecHan 3.1.2.

Storace of Acetylene-Oxween Fuel Gases j 2 *.9. Gas cylinder storage locations should not be in C. 8.a WC Compressed gas storage cylinders for

areas that contain or expose safety-related welding are located outdoors, away j equipment or the fire protection systems that from safety-related components.

j serve those safety-related areas.

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! 250. ' A permit system should be required to use this C.8.a WC l equipment in safety-related areas of the plant.

i l Storage Areas for Ion Exchange Resins '

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251. Unused ion exchange resins should not be stored C. 8. b WC Storage areas for dry ion exchange in areas that contain or expose safety-related resins will be remote from safety-equipment. related @ pment.

l Hazardous Chemicals

! 252. Hazardous chemicals should not be stored in areas C.8.c WC Bazardous chemicals are stored in I that contain or expose safety-related equipment. areas remote from safety-related, equipment.

I Materials Containine Radioactivity 1

253. Materials that collect and contain radioactivity C. 8. 4 NC l! should be stored in closed metal tanks or con-tainers that are located in areas free from j ignition sources or combustibles.

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, CMEB 9.5-1 CMEB 9.5-1 GUIDELINE NO. ITEM NO. COMPARISON REMARKS

250. These materials should be protected from exposure C.8.4 WC to fires in adjacent areas.

255. Consideration should be given to requirements for C.8.4 C Provisions for accommodating decay removal of decay heat from entrained radioactive heat are considered when selecting materials. containers.

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LGS FPER 3.1.2 EXPLANATORY NOTES FOR COMPARISON TO BRANCH TECHNICAL POSITION CMEB 9.5-1 Item 15 BTP Guideline Fires involving facilities shared between units and fires due to man-made site-related events that have a reasonable probability of occurring and affecting more than one reactor unit (such as an aircraft crash) should be considered. -

LGS Desian The control structure, the spray pond pump structure, and the ,

radwaste enclosure are common to the two reactor units. Fires are postulated to occur in these structures just as in other structures, and appropriate provisions are made for fire prevention, fire detection, and fire suppression.

For a discussion of fires due to man-made site-related events, refer to Item 22.

Item 19 BTP Guideline A single active failure or a crack in a moderate-energy line (pipe) in the fire suppression system should not impair both^the primary and backup fire suppression capability. For example, neither the failure of a fire pump, its power supply or controls, nor a crack in a moderate-energy line in the fire suppression systen, should result in loss of function of both sprinkler and hose standpipe systems in an area protected by such primary and, backup systems.

LGS Desian .

As described in Section 2.1.2, fire water is supplied by two redundant pumps, each of which is capable of providing the design fire protection system flow rate at the design pressure. Power for the motor-driven fire pump is provided from either of two independent offsite power sources. The controls for the diesel engine-driven fire pump are de-operated and are powered from -

batteries which supply only the engine-driven fire pump.

Therefore, no single failure of the power supplies or controls can affect both fire pumps.

If a crack should occur in the yard fire main loop, sectional isolation valves can be used to isolate the damaged portion of 1

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the loop without affecting the majority of the loop. There is no single active failure that could affect the operability of both the sprinkler systems and manual hose stations for a given area.

In certain cases, the occurrence of a crack in a header that I

supplies water to sprinklers and manual hose stations could affect the ability to achieve design flow rates for the i sprinklers and hose stations in a given fire area. The provision i of portable extinguishers for manual fire fighting precludes the {

possibility of a pipe crack'from disabling all.means of fire !

suppression for a given area. l t

Item 21 BTP Guideline l The fire protection systems should retain their original design !

capability for natural phenomena of less severity and greater ,

frequency than the most severe r atural phenomena (approximately ,

. once in 10 years) such as tornadoes, hurricanes, floods, ice !

storms, or small-intensity earthquakes that are characteristic of (

the geographic region. !

. LGS Desian r I

The fire pumps, the yard fire main loop, distribution piping I within structures, manual hose stations, and fixed suppression !

systems are conservatively designed so as to retain their !

operability following the occurrence of natural phenomena with !

severities corresponding to a recurrence interval of once in 10 i years.

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Item 22 j 1

BTP Guideline The fire protection systems should retain their original design ;

capability for potential man-made site-related events such as oil i barge collisions or aircraft crashes that have a reasonable :

probability of occurring at a specific plant site. l l l' LGS Desian Transportation activities taking place near the plant site, and !

the potential for accidents affecting the plant, are discussed in l Section 2.2 of the FSAR. As indicated in Section 2.2.2.4 of the l FSAR, there is no commercial traffic on the Schuylkill River in l the vicinity of the site. As discussed in Section 2.2.3 of the l FSAR, the potential effects of an explosion occurring on nearby l highways are exceeded in serverity by the potential effects of a j railway explosion. Structures housing safety-related systems and !

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components are designed to withstand impact from missiles generated by a railway explosion. Portions of fire protection systems that are located outside the safety-related structures could potentially be damaged by missiles generated by a railway explosion. However, such damage will not jeopardize safe -

l shutdown capability since the syttems and components needed for i safe shutdown are protected from damage due to missile impact and

are isolated from the effects of fires occurring outside the j safety-related structures.

Hazards to the plant resulting from aircraft operating in the vicinity of the Limerick site are discussed in Section 3.5.1.6 of

the FSAR. The control structure, reactor enclosure, and spray l pond pump structure are designed to withstand the. impact of the design aircraft (a Learjet) without loss of structural integrity.

Portions of fire protection systems that are located outside these structures could potentially be damaged by aircraft impact. ,

However, such damage will not jeopardize safe shutdown capability l since the systems and components needed for safe shutdown are

. protected from damage due to aircraft impact and are isolated from the effects of fires occurring outside the control structure, reacto_r enclosure, and spray pond pump structure.

Item 24' I

BTP Guideline The consequences of inadvertent operation of or a crack in a l

moderate energy line in the fire suppression system should meet

.the guidelines specified for moderate-energy systems outside containment in SRP Section 3.6.1.

! LGS Desian Moderate-energy leakage cracks in fire suppression system piping

'. are analyzed as discussed in Section 3.6 of the FSAR.

Inadvertent operation of a fire suppression system could, in certain cases, affect the operability of safety-related systems or components. However, such inadvertent operation would not prevent safe shutdown from being achieved through the use of redundant safety-related systems.

Item 28 BTP Guideline On reactor sites where there is an operating reactor und construction or modification of other units is under way, the fire protection program should provide for continuing evaluation of fire hazards. Additional fire barriers, fire protection j

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capability, and administrative controls should be provided as necessary to protect the operating unit from construction fire hazards.

l LGS Desian Administrative procedures will be prepared to protect the operating Unit 1 from fire hazards associated with construction of Unit 2. Special pr/ecautions will be taken to prevent and l control fire hazards Use of open flames and welding or cutting l' equipment will be pro,perly supervised.

2 Construction of both the underground yard fire main and the fire l water distribution piping inside both units of the plant will be !

completed prior to Unit 1 operation so that manual hose station coverage will be available in Unit 2 as well as Unit 1. Portable fire extinguishers will al.so be available in the Unit 2 port

ions

, of the plant during its construction. The construction site will be kept clean and orderly and contractors' sheds will be kept i outside the confines of new construction.

l l l Item 33 l BTP Guideline l

Self-contained breathing apparatus using full-face positive- ,

4 pressure masks approved by NIOSH (National Institute for l Occupational Safety and Health--approval formerly given by the !

U.S. Bureau of Mines) should be provided for fire brigade, damage j control, and control room personnel. At least 10 masks shall be ;

available for fire brigade personnel. Control room personnel may l be furnished breathing air by a manifold system piped from a i storage reservoir if practical. Service or rated operating life shall be a minimum of one-half hour for the self-contained units.

At least two extra air bottles should be located onsite for each l self-contained breathing unit. In addition, an onsite 6-hour j supply of reserve air should be provided and arranged to permit i quick and complete replenishment of exhausted supply air bottles l i

as they are returned. If compressors are used as a source of !

breathing air, only units approved for breathing air shall be i used; compressors shall be operable assuming a loss of offsite l power. Special care must be taken to locate the compressor in I areas free of dust and contaminants. !

1 LGS Desian l Self-contained breathing apparatus will be available for use by 1 control room personnel and fire brigade members. The breathing !

apparatus will have a minimum operating life of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for control room personnel and 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for fire brigade members.

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LGS FPER An onsite reserve' air supply of six hours for at least five .

persons will be provided in stored air bottles. Compressors, if ,

used, will be units approved for breathing air, l l

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Ifent 35 BTP Guideline The quality assurance (QA) programs of applicants and contractors should ensure.

that the guidelines for design, procurement, installation, and testing and the administrative controls for the fire protection systeas for safety-related areas-are satisfied. The QA program should be under the management control of the QA organization. This control consists of (1) formulating a fire protection QA program that incorporates suitable requirements and is acceptable to the management responsible for fire protection or verifying that the program incor-potates suitable requirements and is acceptable to the management responsible for fire protection, and (2) verifying the effectiveness of the QA program for fire protection through review, surveillance, and audits. Performance of other QA program functions for meeting the fire protection program requirements may be performed by personnel outside of the QA organization. The fire protection should be part of the overall plant QA program.QA It should prograa for satisfy the specific criteria listed below.

LGS Desion -

The OA program described below will be under the management control of 4he PECo Ongineci-ing :. ",;;;;ai. Lepatsmeu6 C;. MP . ev W4 ,

organizationsduring the construction phase.

1. Desion Control and Procurement Document Control The design review performed to compare the Limerick design to the BTP guidelines provides assurance that necessary design features are included in appropriata design and procurement documents.

Deviations from the design and procurement documents will be controlled by mechanisms specified in the 10 CFR 50, Appendix B OA program for this project.

2. Instructions, Procedures, and Drawinos These requirements will be met during the construction phase l through the use of a documented, final installation inspection and through implementation of a written pre-operational test.

3. Control of Purchased Material, Equipment, and Services Based upon the status of procurements and the identification of significant design or manufacturing features, certain fire protection equipment may be subject to shop inspection during manufacture. '

Receipt inspection at the construction site shall be performed.

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4. Inspection )

9 These requirements will be met through the use of a documented, final installation inspection and through implementation of a written preoperaticaal test.

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5. Test and Test Control Documented preoperational test procedures including evaluation of results and followup action, if indicated, shall be employed to_ meet these requirements relative to the construction phase of.the plant.

6. Inspection, Test, and Operatinc Status -

Installation inspections, as described in Item 4 above, shall be documented in such a manner as to indicate the acceptability of the item / activity inspected. Deficiencies shall be identified and corrected in accordance with mechanisms specified in the 10 CFR 50, Appendix B QA program for this project.

Satisfactory completion of the preoperational test and release for operation shall be accomplished and documented in accordance with mechanisms specified in the 10 CFR 50, 1 Appendix B QA program for this project.

7. Nonconformino Items Nonconforming items shall be identified, controlled, and corrected in accordance with the mechanisms specified in the 10 CFR 50, Appendix B QA program for this project.

8. Corrective Action Conditions adverse to fire protection (such as failures, malfunctions, deficiencies, deviations, defective components, and nonconformances) during the construction phase shall be reported and corrected in accordance with mechanisms specified in the 10 CFR 50, Appendix B QA program for this project.

9. Records Records shall be prepared and maintained to furnish evidence that the criteria described in Items 1 through 10 are being met for activities affecting the fire protection program.

10. Audits

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The activities described above are subject to audit. In j addition, implementation of receipt inspections, final

! installation inspections, and pre-operational tests shall be l subject to audit to conform with documented instructions, procedures, and drawings.

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-5 Item 37 BTP Guideline Fire barriers with a minimum rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months should be provided

. to separate redundant divisions of safety-related systems from '

each other. -

LGS Desian -

Redunda'nt divisions of safety-related systems will be separated from each other so as to achieve the three levels of fire damage limits established in Position C.I.b. The provision of fire

. barriers between redundant divisions of safety-related systems that do not have safe shutdown functions is not required. Fire barriers will be provided between redundant divisions of safe shutdown systems as necessary to ensure that one train of equipment necessary to achieve safe shutdown is maintained free of fire damage to the degree specified in Position C.1.b.

The reactor enclosures, turbine enclosures, diesel-generator enclosures, radwaste enclosure, and administration building are separated from each other by 3-hour rated fire walls. Walls internal to these structures (and also the spray pond pump i structure) which serve as boundaries between different fire areas are provided with fire ratings or construction details consistent with the fire hazard existing in each area. The locations of -

fire-rated walls are shown on Figures B-4 through B-12, and the walls surrounding each fire area are further described in the fire area discussions contained in Sections 5.3 through 5.9.

The structural steel beams supporting the floor slabs at four elevations in'the control structure (254, 269, 289 and 304 feet) have been fireproofed to provide a 3-hour rating for the completc i floor assembly. The structural steel beams supporting floor l

slabs in other areas have not been fireproofed. The fire ratings of floor slabs above and below each fire area are listed in the fire area discussions contained in Sections 5.3 through 5.9.

Those slabs.which are shown as "3 hr*" are capable of being rated as 3-hour fire barriers, except for the lack of fireproofing on l the structural steel beams supporting the slab.

Reinforced concrete walls without penetrations are considered to qualify for a 3-hour fire rating, provided that the wall has a thickness of at least 6 inches. Concrete block walls designated as fire walls are constructed in accordance with UL Design No.

3-35 REV. 2, 11/82

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Sopero.ficn. b cnsura indepe.ndenc3 bebeen Clnss IE and nort-Cbss IE circuMs and bducan. rsdunddnt cHvis' ions of closa IE circuib is discuesed A FSAR Snciicn. 8.1. (e. l 14. ;

LGS FPER U904, as a minimum. Fire walls incorporating metal studs with lath and plaster are constructed in accordance with UL Design No.

U409. Fireproofing material is applied to structural steel beams in accordance with UL Design No. N706 or N712.

Item 39 BTP Guideline Appropriate fire barriers should be provided within a single safety division to separate components that present a fire hazard to other safety-related components or high concentrations of safety-related cables within that divisior,.

LGS Design i The diesel-generator day tanks constitute the most'significant fire hazard posed by components within safety-related systems.

As stated in Item 229, the day tank for each diesel-generator is located in a vault that is separated from the remainder of the diesel-generator cell by 3-hour rated fire walls. The HPCI, t

RCIC, RHR, and LPCI systems contain lesser fire hazards in the form of lubricating oil associated with th'e pumps and drivers in these systems. These pumps are located at elevation 177 feet in the reactor enclosure, which is compartmentalized to separate the pumps from each other and from other safety-related systems.

Fire barriers are not provided solely for the purpose of ,

separating safety-related cables from other safety-related cables l in the same division. Separation by distance or by fire barriers l between redundant divisions is provided as necessary to ensure !

safe shutdown capability in the event of a fire.

Item 40 BTP Guideline Openings through fire barriers for pipe, conduit, and cable trays I which separate fire areas should be sealed or closed to provide a fire resistance rating at least equal to that required of the i barrier itself. .

1 LGS Design l Pipe, conduit, and cable tray penetrations through fire-rated barriers will be sealed to provide a fire resistance rating that is consistent with that of the overall barrier. Such seals in fire barriers will be installed in accordance with the manufacturer's instructions and with the applicable requirements established by American Nuclear Insurers. Tests will be

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Fcr Aire barrises 4 hot sepcrsfc cafsty-nalaJed creoo from noncofety-ratchd areas of 4he plant, condu%

pxdedinns idill be prwided win, inkrnal ceala In. O3

same, manner as discussed above for safety-relahd areas.

conducted to qualify each type of penetration seal for its intended fire rating.

Item 41 BTP Guideline Openings inside conduit larger than 4 inches in diameter should be sealed at the fire barrier penetration. Openings inside conduit 4 inches or less in diameter should be sealed at the fire barrier unless the conduit extends at least,5 feet on each side of the fire barrier and is sealed either at both ends or at the fire barrier with noncombustible material to prevent the passage of smoke and hot gases.

LGS Desion In areas of the plant that contain safety-related equipment, conduits that penetrate fire barriers will be sealed internally to prevent the passage of smoke and hot gases.. For each penetrating conduit, seals will be provided on both sides of the fire barrier at the access point (junction box, termination at a cable tray, or equipment connection) that is closest to the fire barrier. For those cases in which a conduit extends less than 5 feet on either side of the fire barrier, a 3-hour fire rated seal will be provided on one side of the barrier at the access point that is closest to the barrier.

In reas of the plant not! containing safety-related equipment, internal seals will be provided for conduMs penetruung fire barriers that are adjacent to fire areas with high combustible loadings. The locations of the conduit seals with respect to the fire' barrier being penetrated will be the same as discussed above for safety-related areas.

.Th*m desian, is accePt able since all exposed '

conduit, is sdeel and cable InsulaNm Qnd Item 43 jothchn3 si flame retardant. No combuslible BTP Guideline .Pahay exis+s 4hrough ibe conduit.

l Penetration designs should utilize only noncombustible materials.

LGS Desion All materials used in fire-rated penetration seals are either noncombustible or are listed by an independent testing laboratory for flame spread, smoke generation, and fuel contribution of 25 or less. The following different types of seals will be used in l fire-rated applications:

(1) Cement-type grout. J g

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'(2) Foamed silicone polymer. This is a self-vulcanizing material that results from the mixture'of two liquid components. !

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(3) Solid silicone polymer. The polymer is impregnated with a powdered high-density filler. -

l (4) Flexible boot with ceramic fiber. The boot material is silicone rubber with woven glass fiber reinforcing. Ceramic j fiber.is installed inside the boot, in the space between the :

penetrating object and the edge of the penetration. !

Stainless steel compression straps and silicone adhesives are i used in attaching the boot. l (5) Flexible boot with gel. The boot material is silicone rubb'er !

with woven glass fiber reinforcing. The boot is filled with j a high-density silicone dielectric gel. Stainless steel compression straps and silicone adhesives are used in attaching the boot.

Item 48 !

i BTP Guideline Door openings in fire barriers should be protected with l equivalently rated doors, frames, and hardware that have been ;

tested and approved by a nationally recognized laboratory.

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Door openings in rated fire barriers are provided with fire doors i having ratings consistent with the barrier itself. Except as l discussed below, access openings in 3-hour barriers are provided l with Class A (3-hour) UL-labeled doors and access openings in 1 2-hour barriers are provided with Class B (1-1/2 hour) UL-labeled l doors. Although not provided with UL labels, oversized ,

steamtight doors which are also designated as fire rated are ' [

certified by the manufacturer to conform to standards established :

for UL-labeled fire-rated doors. American Nuclear Insurers has !

I reviewed the design differences between the steamtight doors i involved in this exception and UL-labeled doors of similar i design, and has accepted their use in fire-rated barriers. These f steamtight doors are identified in the fire area discussions i contained in Sections 5.3 through 5.9 by a double asterisk (**) :

following the indicated fire rating. ;

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Item 59 BTP Guideline Interior wall and structural components, thermal insulation materials, radiation shielding materials, and soundproofing should be' noncombustible. -

LGS Desion Most interior walls are constructed of either reinforced concrete, or concrete masonry units. Limited use is made of walls constructed of metal studs with either gypsum wa11 board or gypsum plaster on expanded metal lath. Structural components consist of structural steel or reinforced concrete.

Soundproofing materials, if required, will be noncombustible.

Radiation shielding consists of concrete, concrete masonry unit, or steel plates.

Thermal insulation materials are noncombustible, with the following exceptions:

(1) Insulation for domestic cold water piping (in the administration building only)is a closed-cell foamed elastomer with an ASTM E-84 flame spread rating of 25 or less.

(2) Insulation for the offgas refrigeration equipment (located only in the offgas enclosure) has an ASTM E-84 flame spread rating of 25 or less.

t (3) Insulation for ductwork and plenums of the ventilation systems has an ASTM E-84 flame spread rating of 25 or less, and ct smoks gene, ration raMn3 of 50 or less. ,

Item 61 BTP Guideline Metal deck roof construction should be noncombustible and listed as " acceptable for fire" in the UL Building Materials Directory, :

l or listed as Class I in the Factory Mutual System Approval Guide. I LGS Desion Metal roof deckings consist of manufactured fluted panels with t

rigid insulation and builtup roofing membrane with gravel. This is a Class A UL fire-resistive rated builtup roofing system.

3-39 REV. 2, 11/82

%are Crs no c.cm.lous4,4le, matav 5212 in 4he 1. pace abm 4hs cucpended ceilire in %e confed ro:m, o4her nan. ;

cbdrical cwes.

LGS FPER 7

B D g $L .J Item 63 U J - -

BTP Guideline ,

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Concealed spaces should be devoid of combustibles except as noted in Position C.6.b.

l LGS Desion

- These cables (associated primarily with control room i annunciators and control room lighting) are routed in cable tray, fully-enclosed gutters, and conduit above the suspended ceiling.

r Fire detectors will be located above the i suspended ceiling to provide early warning of fires occurring ;

within the area. 1 Electrical cables are routed through the raised floor sections in the auxiliary equipment room. Access to the cables for manual !

fire fighting efforts is obtained by the removal of floor plates '

covering the floor sections. The floor plates are constructed of aluminum honeycomb bonded between sheet steel, and are easily removable using two quick-disconnect fasteners on each plate.

Automatic fire detection systems and automatic Halon suppression ,

systems are provided in the floor sections. Additional :

discussion of the auxiliary equipment room raised flooring and the Halon suppression system is provided in Sections 2.9 and - ,

5.3.25. ,

Item 65 i BTP Guideline ,

Outdoor oil-filled transformers should have oil spill confinement l features or drainage away from the buildings. i LGS Desian j The main transformers, the safeguard transformers, and the auxiliary transformers are each surrounded by a curb i approximately 2 feet high. A floor drair, is provided within each ;

curbed area to drain liquids to the normal waste drainage system.

ll The fire walls that are located on three sides of each plant !

services transformer would prevent spilled oil from flowing !

toward the circulating water pump structure. The pavement in the !

vicinity of each transformer is sloped to provide drainage to .

nearby catch basins. ;

Table A,-3 lids 4he insulation. and jacketin3 mderials used for e.lectrica.l !

cablin3 As noted in, h table, cable insulation, and facketing materials j l are specified to meet the IEEE sta 383 flame test rapiremenis, except for lighting and commun'icadiens cables, which are rouhd ev.cluskely in, condu'it.

I LGS FPER D g _

Item 66 i

BTP Guideline -~

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. l Outdoor oil-filled transformers should be located at least 50 i feet distant from the building, or by ensuring that such building :

walls within 50 feet of oil-filled transformers are without !

openings and have a fire resistance rating of at least 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . ,

LGS Desian The main transformers are located more than 50 feet from any !

building. The plant services transformers are located adjacent !

to the circulating water pump structure, but are separated from ;

it by free-standing 3-hour rated fire walls. The safeguard ;

transformers and auxiliary transformers are located approximately ,

14 feet from the north side of the' turbine enclosure. As i dcacribed in Section 2.4, the latter transformers are providdd I with automatically-actuated deluge systems to suppress fires l involving the transformers. This automatic suppression will l prevent the turbine enclosure from being damaged as a result of a i transformer fire. In addition, the turbine enclosure is i nonsafety-related and does not contain any components that are ;

needed in order to achieve safe shutdown of the plant. i Item 68 i i

BTP Guideline Floor drains should also be provided in other areas where hand j hose lines may be used if such fire-fighting water could cause i unacceptable damage to safety-related equipment in the area. l LGS Desian l Most plant areas are provided with drainage facilities adequately l sized to remove all the water discharged from a 1-1/2 inch hand I hose line. Some areas which contain primarily electrical and l electronic equipment are not provided with floor drains. For l these latter areas, the doors which would be open to provide j access for hand hose usage would also provide a flow path for j fire protection water to drain to areas not containing safety- - t related components.

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Item 69 BTP. Guideline Where gas suppression systems are installed, the drains should be

. provided with adequate seals, or the gas suppression system should be sized to compensate for the loss of the suppression

. agent through the drains.

LGS Desian Gas suppression systems are provided for the cable spreading rooms (carbon dioxide) and the raised flooring in the auxiliary equipment room (Halon 1301). The carbon dioxide suppression system is sized to compensate for the loss of carbon dioxide through floor drains. Loss of Halon 1301 through floor drains is not possible, since the auxilairy equipment room does not have floor drains.

Item 70 BTP Guideline Drains in areas containing combustible liquids should have provisions for preventing the backflow of combustible liquids to safety-related areas through the interconnected drain systems.

LGS Desian The floor drains in the safety-related pump compertments at elevation 177 feet of the reactor enclosure are each provided with backflow-prevention devices. The only other safety-related areas of the plant that contain significant quantities of combustible liquids are the diesel-generator cells. The drains from the diesel-generator cells are not interconnected with drains from other safety-related areas of the plant. The drains from each diesel-generator cell are provided with traps upstream of their connection to an oil separator receiver.

The turbine enclosure contains several oil storage tanks, but the floor drains from the turbine enclosure are not interconnected

. with drains from safety-related areas of the plant.

Item 78 BTP Guideline I

j Bulk gas storage (either compressed or cryogenic), should not be permitted inside structures housing safety-related equipment.

l Storage of flammable gas such as hydrogen should be located 3-42 REV. 2, 11/82

~75 ,)

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J- U LGS FPER outdoors or in separate detached buildings so that a fire or -

explosion will not adversely affect any safety-related systems or equipment. ,

LGS Desian Compressed gases are stored either outdoors or in nonsafety-related structures whenever possible. However, compressed gases with safety-related uses must be stored in safety-related structures. For this reason, compressed gas cylinders associated with the primary containment instrument gas system and .

containment combustible gas monitoring system are located in the !

reactor enclosure. Compressed gas cylinders used for welding are j stored in the construction shop (during periods of usage only) [

and the machine shop. Hydrogen used in cooling of the main- !

generators is provided from hydrogen cylinders stored at an !

outuvut location that is separated from all structures. The !

compressed propane gas used for ignition of the auxiliary boilers is also stored outdoors. The supply line penetrates only the

! auxiliary boiler enclosure.

l Item 80 BTP Guideline l t

Use of compressed gases (especially flammable and fuel gases) l inside buildings should be controlled. .

LGS Desion l l

The usage of compressed gases for cutting and welding is limited j to those activities authorized as to be outlined in the !

administrative procedures.

l

[

The usage of compressed fuel gases for laboratory and shop use is l limited to a low pressure supply system for Bunsen burners in the i i radioactive chemistry laboratory in the radwaste enclosure and {

the instrument repair shop on the 269-foot level of the control '

structure. Compressed fuel gas cylinders and gas pressure-l reducing stations are installed outside of the building at a 1 l location that does not expose nuclear safety-related structures, I I

systems, and equipment to potential damage from fire at the storage location.

i I

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Item 81 l'

BTP Guideline ,

The use of plastic materials should be minimized. In particular, halogenated plastics such as polyvinyl chloride (PVC) and neoprene should be used only when substitute noncombustible ,

materials are n,ot available. '

i LGS Desian -

The use of plastic materials within the plant has been minimized to the greatest extent practicable. However, alternatives to plastic or elastomeric materials for electrical cable insulating systems, with an optimum balance of electrical, physical, and' environmental characteristics, are not available. Cable insulation and jacketing materials are chosen for their fire-retardant and self-extinguishing properties, such that fuel contribution to a cable fire is minimized and propagation of a fire along cables is self-limiting in the absence of an external fir hazard. The types of electrical cable insulation and ja ing used in the plant are listed in Table A-3.

Electrical components located throughout the plant, such as control panels, relay panels, motor control centers, and power distribution panels, contain relatively small amounts of plastic in the form of terminal blocks, relay cases, circuit breaker cases, and other small items. The use of plastic in these applications is necessary because of its electrically insulating properties.

Plastic materials are also used for electrical conduit, but only when embedded within poured concrete walls and floor slabs.

Item 85 BTP Guideline Only metallic tubing should be used for conduit. Thin-wall metallic tubing should not be used.

LGS Desian !

Exposed conduit used for the routing of safety-related cables is rigid steel conduit. Conduit embedded in poured concrete walls and slabs may be either rigid steel or PVC. Conduits used for I the routing ofo nonsafety-related cables may be either rigid steel or EMT.

exposed 3-44 REV. 2, 11/82

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Item 88 BTP Guidelir.e -

Redundant safety-related cable system outside the cable spreading 2

room should be separated from-each other and from poetential fire exposure hazards in nonsafety-related areas by fire barriers with

! a minimum fire rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

LGS Desian O

Fire exposure hazards in nonsafety-related areas are separated from safety-related areas by 3-hour rated fire barriers. '

Separation by distance or by fire barriers between redundant -

divisions of electrical cabling is provided as necessary to ensure safe shutdown capability in the event of a fire.

Item 94 BTP Guideline In other areas where it may not be possible because of other overriding design features necessary for reasons of nuclear safety to separate redundant safety-related cable systems by 3-hour-rated fire barriers, cable trays should be protected by an automatic water system with open-head deluge or open directional spray nozzles arranged so that adequate water coverage is provided for each cable tray. Such cable trays should also be protected from the effects of a potential exposure fire by providing automatic water suppression in the area where such a

' fire could occur.

LGS Desian In areas that contain redundant divisions of safety-related cable -

trays that are not separated by 3-hour fire barriers, those specific trays that contain' cables needed for safe shutdown are provided with separation by means of distance or by lesser-rated fire barriers (minimum 1-hour rating). and, rmided eth ohh. adu sure.esst en.

% is deemed sufficient to ensure safe shutdown capability in the event of fire, due to leu combudible leading h fhe area ademahc wder WPression to protect he cable trays Is nut provided,.

Where sepeatiott alone 47

. 3-45 REV. 2, 11/82

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. l tyTP C,uide,line.

l E\edric cable conshuchn. should, as a minirnam, poss'the Ame test in 4he curren.t IEEE Std 383 LGS Desion

. With the exception of cables associated with the lighting and communication systems, electrical cable insulation and jacketing systems pass the IEEE Std 383 flame test. Cables associated with the lighting and communication systems are routed exclusively in conduit and are not routed together ;

with cables associated with other plant systems.

Item 98 BTP Guideline Miscellaneous storage and piping for flammable or combustible liquids or gases should not create a potential exposure hazard to safety-related systems.

LGS Desian Piping for combustible liquids or gases is not routed through creas containing safety-related systems unless this is unavoidable due to the fact that the combustible liquids or gases are used by a safety-related component. The situations where i l this exception arises involve the fuel oil supply piping to the !

diesel-generators and the reagent gas (hydrogen) tubing to the combustible gas analyzer packages. ;

._ . ... - . I 4

_ 3-45a

l 7 'wm The standby diesel generalors are locded in. ind vidual' cells wi4hin, 4he diesel Senerdor- enclosure. % fuel oil supply piping is roded. so 4 hat 4he piping exposed, in, any given. diesel generaler cell serves only 4he one diesel Senerator in, 4 hat cell. Therefere, a. \eak.

occurring of any loca4 ion, in, 4he fuel oil supply piping can. oHect only one diesel 3ene.rafer.

The, combustible, gas analyz.er packages are loca"ed in, 4be reacher enclosure. h reageni sas tubin3 to 4hese analyz.er- packages is desi3nated seismic Category I and. is des @ned and constructed. in, accordance oilh.

+he ASFIE B $ PV Code 3 Section. Jll, Class 2..

As a. resul.t of the high. gttalify standards applied. to 4his tubin3, it is edremely unlikel y that any desbh, lxtsis e.veni could cause a. leak.

in, the tubin3 W w 1

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Item 99 BTP Guideline Smoke and corrosive gases should generally be discharged directly outside to an area that will not affect' safety-related plant areas. The normal plant ventilation system may be used for this purpose if capable and available.

LGS Desian The products of combustion from a fire in any area of the plant will be removed by the normal plant ventilation systems and extausted through the ventilation stacks above the reactor -

enclosure roof. A portion of the air exhausted from the control room, auxiliary equipment room, and control structure fan room is normally recirculated back to those rooms. Controls are available to permit switchover to the purge mode, in which 100%

of the exhaust air from these rooms is discharged to the atmosphere.

Item 100 BTP Guideline .

To facilitate manual firefighting, separate smoke and heat vents

, should be provided in specific areas such as cable spreading i rooms, diesel fuel oil storage areas, switchgear rooms, and other areas where the potential exists for heavy smoke conditions.

LGS Desian As discussed in Item 99, the smoke resulting from a fire will be removed by the normal plant ventilation systems. Ventilation air from the cable spreading room is exhausted to the turbine enclosure. Fuel oil for the standby diesel-generators is stored in underground tanks rather than inside any structure. Smoke I

removal from the switchgear rooms can be accomplished using portable exhaust fans, if necessary.

3-46 REV. 2, 11/82

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Item 101 BTP Guideline Release of smoke and gases containing radioactive materials to l the environment should be monitored in accordance with emergency i plans as described in the guidelines of Regulatory Guide 1.101, ;

" Emergency Planning for Nuclear Power Plants." i LGS Desian Radiation monitors are provided in the ventilation exhaust stacks to determine if the radioactive release to the environment is within the permissible limits of the plant Technical Specifications.

Exhaust from the control room is discharged directly to the atmosphere by alignment of dampers. Exhaust from potentially contaminated areas of the turbine enclosure and the control structure is discharged through deep bed charcoal filters prior to release to the atmosphere, with a means provided to bypass the filters for direct discharge. Independent systems provide filtered exhaust from the radwaste enclosure and the reactor enclosure with discharge through ventilation exhaust stacks above the reactor enclosure roof.

Item 102 BTP Guideline Any ventilation system designed to exhaust potentially radioactive smoke or gases should be evaluated to ensure that inadvertent operation or single failures will not violate the radiologically controlled areas of the plant design. This requirement includes containment functions for protecting the public and maintaining habitability for operations personnel.

LGS Desian .

No portion of the ventilation system is specifically dedicated to smoke removal except for the purge mode of the control room ventilation system (see Item 99.) The basic design of the overall plant ventilation system considers the effects of inadvertent operation and single failure. The fire dampers provided within the ventilation system affect only those portions isolated by the dampers with no adverse effects on the balance of the systems.

3-47 REV. 2, 11/82

7 ~"I j LGS FPER 1

Item 103 l BTP Guideline ~~

l The power supply and controls for mechanical ventilation systems shotad be run outside the fire area served by the system'where practical.

LGS Desian Vilh. 4he. excepien of fire. area 17, 4he. posser and.

eswl.rol cabling associa.4ed. wMh. ventilation. sys4 ems

' for so.fe.+y-r ided areas is routed aufside, 4he area. ;

served by 4he sysfem. Fire area 2.7 is 4%e control i struchure fan room., locafec, al eleva4 ion, so4 fees in, +%e control structure.. Veniilation., for 4u.

cord.rol struc.ture fan, roent. is provided by the.

au.v.iliary equipuni room. supply a'ir fans (oAvu4 and oavit4) and rekurn air fana CoAvito and osvito ) .

Be4h. of 4hese seis of fans, plus 46r associa:v.d.

conk.rel panels, are locobed in, fire, area. 2.7.

l Fire, barriers, separation by cksta.n.ce, and an.,

auhoma-ic, suppress'ien, syrem, all be, provided.

in, attordance. idr h, 4he guide. lines of Section, .EI.G.2.

of Appendix R io 10 CFR Part 50; in, order to e,nsure, fhat a. posfuIahed fire 64hin fire area 2.7

. does not disable. bo+h fans in. each pair of fans discussect above..

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i Item 104 BTP Guideline Engineered safety feature filters should be protected in accordance with the guidelines of Regulatory Guide 1.52. Any filter that includes combustible materials and is a potential exposure fire hazard that may affect safety-related components should be protected as determined by the fire hazards analysis.

LGS Desian Manually-actuated sprinkler systems with water spray nozzles are provided as an integral component of the charcoal filters in the standby gas treatment system, the control room emergency ventilation system, the reactor enclosure equipment compartment exhaust system, and the reacter enclosure recirculation system.

i Heat detectors monitor charcoal filter temperature and alarm in

the control room on high temperature. .

The four filtration systems listed above also contain prefilters and HEPA filters that are constructed of fire retardant materials. Because of the low fire potential of these filter elements, and the fact that they are contained within all-metal l plenums, they do not constitute a significant exposure fire hazard to other safety-related systems.

3-48 REV. 2, 11/82

_ _ _ _ ._ _ _ _ . - _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ - _ . ~ . _ . . _ . _ . _ . _ . . . _ _ _

~ _

Talephens aru also incteticd of praccl2ded locodims '

4hrough.d N phnt, providins b-m y Mroplant emmeicab, n, and access to +he FA pa3a chann21. A portable radio ummwnicaAion, system. uMIMm3 a dMrbted anhone systen proviks a backup to both -}he, PA and PABX sysfems.

Item 107 BTP Guideline Where total flooding gas extinguishing systems are used, area intake and exhaust ventilation dampers should be controlled in accordance with NFPA 12, " Carbon Dioxide Systems," and NFPA 12A, "Halon 1301 Systems," to maintain the necessary gas concentration.

LGS Desian Dampers in the supply and exhaust ductwork for the cable spreading room are controlled so as to minimize the loss of gas during actuation of the carbon dioxide total flooding system for

. the cable spreading room. Carbon dioxide discharge actuates pressure switches that initiate closure of the steam isolation dampers in the ducts penetrating the cable spreading room walls.

The Halon suppression systems for the auxiliary equipment room discharge only within the raised flooring. Therefore, automatic termination of ventilation for the general area of the auxiliary equipment room is unnecessary. ,

Item 110 BTP Guideline i

Fixed emergency communications independent of the normal plant communication system should be installed.at preselected stations.

LGS Desian .

The fixed communication systems to be used during emergencies are the same as those provided for normal plant communications. Both public address and private automatic branch exchange (PABX telephone)

, systems ar.e provided. The PA system has two-way communication facilities for speech input at handset stations. Each station is capable of originating and receiving communication through the use of a page channel and five non-interfering party-line channels. Handset stations are installed at preselected locations.

Item 111 i

BTP Guideline A portable radio communications system should be provided for use l by the fire brigade and other operations personnel required to I

achieve safe plant shutdown. This system should not interfere

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LGS FPER J_ _ ,

i with the communications capabilities of the plant security force.

Fixed repeaters installed to permit use of portable radio

. communication units should be protected from exposure fire ,

damage. Preoperational and periodic testing should-demonstrate I i

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

i LGS Desian A portable radio communications system will be provided for use i by the fire brigade and other operations personnel. The system i will utilize a distributed antenna network with base station repeaters. The distributed antenna modules will be located throughout the plant. Although the antenna modules are not designed to withstand an exposure fire, the system is designed l such that the failure of one module will not result in failure of the entire antenna system. The antenna modules will be located so as to minimize their proximity to combustible materials. In the event of failure of a local antenna module, plant personnel will also have access to the plant PA and PABX communication j systems.

Item 120 BTP Guideline ,

Primary and secondary power supplies should be provided for the fire detection system and for electrically operated control valves for automatic suppression systems. Such primary and secondary power supplies should satisfy provisions of Section 2220 of NFPA 72D. This can be accomplished by using normal offsite power as the primary supply with a 4-hour battery supply as secondary supply; and by providing capability for manual connections to the Class 1E emergency power bus within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of loss of offsite power. Such connection should follow the applicable guidelines in Regulatory Guides 1.6, 1.32, and 1.75.

LGS Desian Power for the early warning fire and smoke detection systems is rovided from a Class IE ac motor control center. In the event f loss of offsite power, the motor control center is powered rom the standby diesel-generators.

non-Class IE The detection and actuation sy ems fo the Halon system, the total flooding carbon dioxide system, an the deluge and pre-action sprinkler systems ar connected to de power supply. The charger associated with the batteries is powered from a Class IE ac motor control center + hat is powered from the standby diesel-generators in the event of loss of offsite power. In the event of loss of charging power to the 3-50 REV. 2, 11/82

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batteries, the de power system can supply its rated load for ;

approximately 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . l The above-described power supplies.are in compliance with applicable portions of Regulatory Guides 1.6, 1.32, and 1.75.

They are also in compliance with Section 2220 of NFPA 72D-1975, except for the rating period of the de power supplies (3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rather than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ).

Item 135 BTP Guideline f t

A hose house equipped with hose and combination nozzle and other f auxiliary equipment recommended in NFPA 24, "Outside Proteci. ion, " ;

should be provided as nee.ded, but at least every 1,000 ft. ;

Alternatively, mobile means of providing hose and associated j equipment, such as hose carts or trucks, may be used. When !

provided, such mobile equipment should be equivalent to the !

equipment supplied by three hose houses. ;

LGS Desian As indicated in NFPA 24-1981, Section 5-2.2, portable hose carts i stored in permanent hose cart house:s are acceptable alternatives i to permanent hose houses. Hose cart houses are provided at 5 selected hydrants in the yard area at intervals of approximately f 650 feet. Each hose cart will be equipped with the following ;

fire fighting equipment. ,

(1) 600 feet of 2-1/2" rubber lined hose (2) 400 feet of 1-1/2" rubber lined hose !

(3) One 30" playpipe (4) Two 1-1/2" adjustable spray nozzles I

. (5) Two 1-1/2" ball shutoff j (6) One 2-1/2" adjustable fog nozzle j (7) One 2-1/2" ball shutoff f

(8) One siamese connection (gated wye) l (9) Two 2-1/2" to 1-1/2" spanner wrenches (10) One hydrant wrench '

(11) One fire axe '

(12.) One I '/z" Rockwood Fog Nez.z.le wMh 6-foot applicator 3-51 REV. 2, 11/82

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The above listing of equipment is in compliance with NFPA 24-1981 except for the quantities of spt~ay nozzles and spanner wrenches.

A single spray nozzle is sufficient for use with the 2-1/2" hose.

The 2-1/2" hose is intended to be used as a leader line for the

' gated wye. It is not expected that the plant fire brigade will need to use the 2-1/2" hose for direct fire fighting.

Hose coupling gaskets and an additional spanner wrench will be provided on the hose carts. Two spanner wrenches per hose cart house is sufficient to ensure their availability..

Item 140 BTP Guideline The fire water supply should be calculated on the basis of the largest expected flow rate for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , but not less than 300,000 gallons. This flow rate should be based (conservatively) on 500 gpm for manual hose streams plus the largest design demand of any sprinkler or deluge system as determined in accordance with NFPA 13 or NFPA 15.

LGS Desion, Fire protection water is supplied from the basins of the two cooling towers in the Unit 1 and Unit 2 circulating water systems. The total capacity of each cooling tower basin is 7,000,000 gallons. Each fire water pump takes suction from both cooling tower basins through connections to the 96-inch circulating water lines.

I The cooling tower basin storage capacity exceeds the 311,000 gallon capacity required for two-hour operation of the turbine condenser compartment sprinkler system at 2090 gpm plus 500 gpm for hose streams.

Item 144 BTP Guideline Other water systems that may be used as one of the two fire water supplies should be permanently connected to the fire main system and should be capable of automatic alignment to the fire main system. Pumps, controls, and power supplies in these systems should satisfy the requirements for the main fire pumps. The use of other water systems for fire protection should not be incompatible with their functions required for safe plant shutdown. Failure of the other system should not degrade the l fire main system.

3-52 REV. 2, 11/82

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_;s _, u a LGS Desian The suction piping of the fire pumps is permanently connected to the 96-inch circulating water lines that supply water from the cooling towers to the main condensers. Since there are no pumps or valves located in the circulating water lines between the cooling tower basins and the connection points of the fire pump suction lines, no re-alignments are necessary to make the circulating water system available to provide water to the fire pumps. Therefore, there are no active failures of the circulating water system that could degrade the fire main system, and no special requirements are needed for the circulating water pumps or their associated power supplies and controls.

Item 146 BTP Guideline Each sprinkler and standpipe system should be equipped with OS&Y (outside screw and yoke) gate valve or other approved shutoff valve and waterflow alarm. ,

LGS Desian Each sprinkler and deluge system is provided with an OS&Y gate valve adjacent to the system's automatic control or alarm valve.

Each sprinkler system is provided with local water flow alarms and control room annunciation. In the deluge and pre-action systems, the actuation of the heat responsive device initiates an alarm locally and in the control room.

Water flow in the standpipe systems due to manual hose station usage is indicated by pump running annunciation with the absence of automatic system actuation annunciation. Individual standpipe flow alarms are not provided.

Each connection of a fire water header to the yard fire main is provided with a post indicator valve to permit isolation of the header. In many cases, branch connections to the headers are provided with approved shutoff valves so that groups of sprinkler systems and/or manual hose stations can be isolated without interrupting the supply to other sprinkler systems and manual hose stations connected to the same header.

3-53 REV. 2, 11/82

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Item 147 BTP Guideline Safety-related equipment that does not itself require sprinkler water fire protection but is subject to unacceptable damage if wet by sprinkler water discharge should be protected by water shields or baffles.

LGS Desian Safety-related equipment not requiring sprinkler protection is provided with water shields and/or protected from unacceptable water damage by zoned discharge or directional spray nozzles.

Item 148 BTP Guideline Control and sectionalizing valves in the fire water systems should be electrically supervised or administrative 1y controlled.

The electrical supervision signal should indicate in the control room.

LGS Desian Other than the non-indicating gate valves with curb boxes controlling laterals to the fire hydrants, all valves in the yard fire loop and headers into the buildings are post indicator valves. The valves are locked in the open position using padlock-type locking devices. These valves are not equipped with supervisory switches.

All of the fire protection OS&Y valves directly controlling each wet pipe sprinkler system, pre-action sprinkler system, and deluge system are provided with electrically actuated supervisory switches with annunciation in the control room.

Item 151 BTP Guideline Interior manual hose installation should be able to reach any location'that contains, or could present a fire exposure hazard to, safety-related equipment with at least one effective hose stream. To accomplish this, standpipes with hose connections equipped with a maximum of 100 feet of 1-1/2-inch woven-jacket, lined fire hose and suitable nozzles should be provided in all buildings on all floors.

3-54 REV. 2, 11/82

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LGS Desian Readily accessible hose reels or cabinet-mounted racks are located throughout the plant in areas that either contain systems and components important to safety or present an exposure fire j hazard to such areas. The hose stations are provided with a ;

maximum of 100 feet of 1-1/2 inch woven-jacket lined fire hose '

equipped with adjustable fog and straight stream nozzles.

Fire suppression capability for the spray pond pump structure is provided by portable fire extinguishers rather than hose stations. As shown in Table A-1, the combustible loading in the various compartments of the spray pond pump structure is low enough that portable fire extinguishers are sufficient to extinguish any postulated fire. Those compartments that contain combustible materials are provided with fire detectors that annunciate in the control room. In addition, the spray pond pump structure is divided into two separate fire areas by a 3-hour rated fire wall along the centerline of the structure.

Components needed for shutdown methods A and C are located on the west side of this wall and components needed for shutdown methods B and D are located on the east side of the wall, so that a postulated fire in either fire area will leave at least one method available to safely shut the plant down.

Item 155 BTP Guideline Provisions should be made to supply water at least to standpipes and hose connections for manual firefighting in areas containing equipment required for safe plant shutdown in the event of a safe .

shutdown earthquake. The piping system serving such hose stations should be analyzed for SSE loading and should be provided with supports to ensure system pressure integrity. The piping and valves for the portion of hose standpipe system affected by this functional requirement should, as a minimum, satisfy ANSI B31.1, " Power Piping." The water supply for this condition may be obtained by manual operator actuation of valves l in a connection to the hose standpipe header from a normal i seismic Category I water system such as the essential service )

water system. The cross connection should be (a) capable of i providing flow to at least two hose stations (approximately 75 gpm per hose station), and (b) designed to the same standards as the seismic Category I water system; it should not degrade the performance of the seismic Category I water system.

3-55 REV. 2, 11/82

l LGS FPER u

g. g W U-LGS Desian As discussed in Section 2.5 of the FSAR, the region surrounding

the Limerick plant site has a low to moderate potential for seismic activity. The fire water system, including standpipes ;

and manual hose stations, is designed as seismic Category II (except for portions of the system located in the control ,

structure, reactor enclosure, and diesel-generator enclosure, l which are designed as seismic Category IIA) and is not designed to remain functional in the event of a safe shutdown earthquake.

All systems and components that are needed to ensure safe shutdown of the plant are designed as seismic Category I and are located in seismic Category I structures. These safe shutdown systems will therefore remain fur.ctional in the event of an SSE.

In the event that one train of systems needed for safe shutdown is impaired due to fire following an SSE, the combination of separation and fire barriers that is provided between redundant trains of safe shutdown systems will ensure that at least one means of achieving safe shutdown remains available. The fire l

water system is designed in accordance with the National Fire Protection Code rather than ANSI B31.1.

Item 1'58 BTP Guideline Certain fires, such as those involving flammable liquids, respond well to foam suppression. Consideration should be given to use of mechanical low-expansion foam systems, high-expansion foam generators, or aqueous film-forming foam (AFFF) systems, including the AFFF deluge system. These systems should comply with the requirements of NFPA 11, NFPA 11A, NFPA 11B, and NFPA 16, as applicable.

LGS Desian Foam suppression systems have been provided for the protection of the fuel oil transfer structure and the two outdoor storage tanks i containing No. 2 and No. 6 fuel oil for the auxiliary boilers.

These systems are designed in accordance with NFPA 11. NFPA 11A, NFPA 11B, and NFPA 16 are not applicable to the type of foam systems being used. The design of the foam suppression systems is discussed in Section 2.7.

3-56 REV. 2, 11/82

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Item 162 BTP Guideline Particular consideration should also be given to (1) Minimum required Halon concentration, distribution, soak time, and ventilation control; (2) Toxicity of Halon; (3) Toxicity and corrosive characteristics of the thermal decomposition products of Halon; and (4) Location and selection of the activating detectors.

LGS Desian The following comments apply to the Halon 1301 system that is provided for the raised flooring in the auxiliary equipment room.

(1) The design concentration for the Halon 1301 system is 20%

with a 20 minute soak time. A system of distribution piping and nozzles is provided within the raised flooring so that the Halon is distributed evenly. Since the Halon is not discharged into the general air space of the auxiliary equipment room, isolation of the ventilation system is not necessary to prevent the loss of Halon.

(2) The Halon 1301 system is provided only under the raised floor of the auxiliary equipment room, rather than in the entire room. Emergency procedures will require personnel to use self-contained breathing apparatus when entering the auxiliary equipment room following the discharge of Halon.

(3) The Halon 1301 system is designed to achieve a concentration of 6% within the first 10 seconds after discharge begins.

This concentration is sufficient to extinguish the flames, which will largely end the production of toxic gases as a result of the thermal decomposition of Halon. Thus, rapid extinguishment of the flames will prevent the production of a significant quantity of toxic gases.

(4) Heat detectors are used to provide the actuation signal for the Halon 1301 system. Eight heat detectors are located in each of the PGCC floor sections, and additional heat detectors are located in the raised flooring that surrounds the PGCC floor sections.

3-57 REV. 2, 11/82 l -

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gg . L Item 166 BTP Guideline Particular consideration should also be gi,ven to (1) Minimum required CO, concentration, distribution, soak time, and ventilation control; (2) Anoxia and toxicity of CO,;

(3) Possibility of secondary thermal shock (cooling) damage; (4) Conflicting requirements for venting during CO, injection to prevent overpressurization versus sealing to prevent loss of agent; and

-(5) Location and selection of the activating detectors.

LGS Desian The following comments apply to the total flooding carbon dioxide system that is provided for the cable spreading rooms.

(1) The design concentration for the carbon dioxide system is 50%

achieved within 7 minutes. The carbon dioxide storage tank has sufficient capacity to maintain a 50% concentration in both the Unit 1 and Unit 2 cable spreading rooms simultaneously for a period of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Loss of carbon

. dioxide through the ventilation system is prevented by the automatic closure of steam isolation dampers in the ventilation ducts that penetrate the cable spreading room walls.

(2) The protected space is normally unoccupied. The emergency procedures will require personnel to use breathing apparatus when entering the space fol, lowing carbon dioxide discharge.

(3) Carbon dioxide discharge will be directed so as not to

, impinge directly on any cables.

(4) Provisions to prevent loss of carbon dioxide through the ventilation system are discussed in Item (1) above. Leakage

, around the doors leading into the cable spreading rooms will prevent overpressurization of the rooms due to the carbon dioxide discharge.

(5) Heat detectors are used to provide the actuation signal for the carbon dioxide system. The heat detectors are located at ceiling level in the cable spreading rooms.

i 3-58 REV. 2, 11/82

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Item 170 4

BTP Guideline l Because of the general inaccessibility of primary containment j during normal plant operation, protection should be provided by automatic fixed systems. I i

LGS Desion t t

i The primary containment is inerted with nitrogen during reactor !

1 operation, so that the oxygen concentration is maintained below l

4% by volume. This inert atmosphere will prevent fires from i occurring in the primary containment. For this reason, fixed ,

suppression systems are not needed within the primary containment and are not provided.

l l

Fire suppression coverage for the primary containment is provided !

by manual hose stations and portable fire extinguishers located l outside the two entrances to the suppression chamber at elevation t 217 feet and the two entrances to the drywell at elevation 253 i feet. , , l t

Item 173 ;

i BTP Guideline {

In primary containment, fire detection systems shoul.d be provided for each fire hazard. The type of detection used and the !

location of the detectors should be the most suitable for the !

particular type of fire hazard identified by tthe fire hazard j analysis. -

, A general area fire detection capability should be provided in i the primary containment as backup for the above described hazard [

detection. To accomplish this, suitable smoke or heat detectors ;

compatible with the radiation environment should be installed. l l

LGS Desion f Fire detectors are not provided inside the primary containment. !

During reactor operation, the primary containment is inerted with !

nitrogen, and the oxygen concentration is maintained below 4% by !

volume. This inert atmosphere will prevent fires from occurring l l in the primary containment. Administrative procedures provide i for fire watches when necessary during maintenance operations l when the drywell has been de-inerted. >

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__; u Item 179 BTP Guideline Peripheral rooms in the control room complex should have automatic water suppression and should be separated from the control room by noncombusitble construction with a fire resistance rating of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Ventilation system openings between

, the control room and peripheral rooms should have automatic smoke dampers that close on operation of the fire detection or suppression system.

LGS Desian The walls and ceilings separating the control room proper from its support facilities (such as office, shop, toilet, utility room, and instrument laboratory) are rated as 1-hour fire barriers. Ventilation ducts serving these peripheral rooms are provided with 1-hour rated fire dampers that are actuated closed by fusible links. The entrances to the individual rooms are provided with C-label (3/4 hour) doors.

Automatic suppression systems are not provided in the peripheral rooms. Manual fire fighting capability is provided for as discussed in Item 181.

Item 181 BTP Guideline Manual firefighting capability should be provided for both:

(1) Fire originating within a cabinet, console, or connecting cables; and (2) Exposure fires involving combustibles in the general room area.

Portable Class A and Class C fire extinguishers should be located in the control room. A hose station should be installed i immediately outside the control room. l Nozzles that are compatible with the hazards and equipment in the control room should be provided for the manual hose station. The nozzles chosen should satisfy actual firefighting needs, satisfy electrical safety, and minimize physical damage to electrical

equipment from hose stream impingement.

l 3-60 REV. 2, 11/82

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& c LGS Desian Portable carbon dioxide fire extinguishers are located in the control room. In addition, manual. hose stations of both the carbon dioxide and water types are located outside both entrances to the control room. The water hoses are equipped with All Fog neutes enrowd by underwebes Laeratories Inc.

Item 182 BTP Guideline Smoke detectors should be provided in the control room, cabinets, and consoles. Alarm and local indication should be providad in the control room.

LGS Desian Fire detectors are not located inside the individual cabinets and consoles in the control room. The control room panels are not gasketed and therefore are not airtight. Any smoke generated i

within the cabinets will leak out and be detected by the fire detectors in the control room. Twenty-three detectors are distributed throughout the control room to provide rapid detection of smoke originating in any panel. Actuation of any of these detectors is annunciated on the fire protection panels in the control room. The indicator light on the detector itself will then identify the specific detector originating the alarm.

Item 184 BTP Guideline The outside air intake (s) for the control room ventilation system should be provided with smoke detection capability to alarm in the control room to enable manual isolation of the control room ventilation system and thus prevent smoke from entering the control room.

LGS Desian The control room ventilation intake is provided with smoke detection capability to automatically detect and alarm the presence of smoke. Upon receipt of the alarm, the control room ventilation system can be manually placed in the recirculation mode in order to isolate the control room from the outside.

l For purge operation of the control room ventilation system, the outside supply air and exhaust air dampers are fully opened and the return air damper to the control room is closed. The control 3-61 REV. 2, 11/82

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LGS FPER room purge system can be operated from both inside and outside the control room.

Item 186 BTP Guideline Cables in underfloor and ceiling spaces should meet the separation criteria necessary for fire protection.

LGS Desian The features of the raised flooring in the auxiliary equipment room that provided separation between redundant divisions of electr} cal cabling are described in Section 5.3.25. In summary, each raceway within the raised flooring is totally enclosed and is used for only one division of cabling,' unless additional kreie rs are provideal.

Cables routed. 4hrough 4he space above 4he. suspended ceiling in. 4he codrol room. consist of low-voltage cordral and ins 4rumen.4alion, cables , plus lightinj ca.b\es 4 hat serve 4he control room. %e.cen:frol and instrumenia.fieN cables are specified to meet 4he IEEE. Md 383 flame lesi rejuirernents, and have flame retardan", facketing tha.1 hhlt not support flarne propa3x: ion.. Lighting <dles are routed exclusivel y in, conduits that are dedicahed to hbhting cabic service eny. %ese design. b iures, foc3e+her wWh. +he. lack of other-cornbusWble maherials above 4he suspencled ceiling ,

preciades the possibihty of a. fire that coulc: .

affect redundant divisions of sa.e f shutdoum.

cablin3 wihbin, fnis space.

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I Item 189 BTP Guideline .

Area automatic fire suppression should be provided for underfloor and ceiling spaces if used for cable runs unless all cable is run in 4-inch or smaller steel conduit or the cables are in fully enclosed raceways internally protected by automatic fire suppression.

LGS Desion The raised flooring in the auxiliary equipment room is provided with an automatic Halon suppression system as described in l Section 2.7.

Automatic suppression systems are not provided for the electrical cabling routed through the space above the suspended ceiling in the control room. Portable fire extinguishers located in the control room and hose stations located outside the control room -

provide the capability to manually extinguish any fire involving the cables above the suspended ceiling. Individual panels in the 3-62 REV. 2, 11/82 1

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suspended ceiling are easily removable to provide access to this area. -

Item 191 BTP Guideline The primary fire suppression in the cable spreading room should be an automatic water system such as closed-head sprinklers, open-head deluge system, or open directional water spray system.

Deluge and open spray systems should have provisions for manual operation at a remote station; however, there should be provisions to preclude inadvertent operation. Location of sprinkler heads or spray nozzles should consider tray arrangements and possible transient combustibles to ensure adequate water coverage for areas that could present exposure hazards to the cable system. Cables should be designed to allow wetting down with water supplied by the fire suppression system without electrical faulting.

LGS Desian I The primary fire suppression system in the cable spreading room is a total flooding carbon dioxide system. The design of this system is discussed in Section 2.8.

Backup suppression capability for the cable spreading room is provided by a wet pipe sprinkler system with fusible-type sprinkler heads.

Electrical cabling is designed to allow wetting down without electrical faulting.

Item 210 BTP Guideline Drains should be provided to prevent water accumulation from damaging safety-related equipment.

LGS Desian -

Floor drains are not provided in the safety-related switchgear rooms. In the event that hand hose lines are used for fire suppression in the switchgear rooms, the doors that would be open to provide access would provide a flow path for fire protection water to drain to areas not containing safety-related components.

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( 3-63 REV. 2, 11/82

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Item 212 BTP Guideline Redundant safety-related panels remote from the control room

! complex should be separated from each other by barriers having a minimum fire rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . Panels providing remote shutdown j

, capability should be separated from the control room complex by barriers having a minimum fire rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . Panels providing remote shutdown capability should be electrically isolated from the control room complex so that a fire in either area will not affect shutdown capability from the other area.

LGS Desian Most safety-related panels are located in either the control room or the auxiliary equipment room. These two rooms are separated from each other by a 3-hour rated floor slab. Some of the safety-related panels outside the control room and auxiliary equipment room are located within the same fire area as their redundant counterparts, with no intervening fire barriers. The panels that are located in this manner and are needed to achieve safe shutdown of the plant are separated by at least 20 feet horizontally, as required by Section III.G of 10 CFR Part 50, Appendix R.

4 The remote shutdown panels are located in the auxiliary equipment room, which is separated from the control room by a 3-hour rated floor slab. Transfer switches are provided on the remote shutdown panels to allow the operators to isolate the remote shutdown panels from control room circuits.

1 Item 217 BTP Guideline Ventilation systems in the battery rooms should be capable of maintaining the hydrogen concentration well below 2 volume percent.

LGS Desian i Ventilation air for the safety-related battery rooms is supplied by the safety-related 0AV118 and OBV118 fan cabinets, and is exhausted by the nonsafety-related OAV124 and OBV124 fan cabinets. Both sets of fans are 100% redundant and are l controlled such that the standby fan will start running l l automatically if the lead fan fails. In the event of loss of l flow through the battery room exhaust ducts, due either to fan stoppage or isolation damper closure, the battery room exhaust will automatically be recirculated to the suction of the OAV118 3-64 REV. 2, 11/82

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and OBV118 fan cabinets. The ventilation flow rate through the battery rooms provides 12 air changes per hour, which maintains hydrogen concentration far below 2% by volume. ,

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Item 218 BTP Guideline Loss of ventilation should be alarmed in the control room.

LGS Desian The OAV118 and OBV118 fan cabinets, which supply ventilation air to the safety-related battery rooms, are rovided with flow ,

switches at the discharge of each fan. .aw flow through an '

operating fan will be detected by the flow switches and annunciated at the control structure HVAC panels (OAC101 and OBC 101). Alarms on these panels are relayed to the control room as a common trouble alarm.

Item 221 BTP Guideline The fire barriers should be designed so as to maintain structural integrity even in the event of a complete collapse of the turbine structure.

LGS Desian The turbine enclosure is structurally separate from the reactor enclosure and control structure. The structural integrity of the fire barrier walls of the reactor enclosure and control structure will not be impaired by a collapse of the turbine enclosure.

Item 222 BTP Guideline Openings and penetrations in the fire barrier should be minimized and should not be located where the turbine oil system or generator hydrogen cooling system creates a direct fire exposure hazard to the barrier.

3-65 REV. 2, 11/82

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R LGS FPER j O- m LGS Desian Penetrations in the walls that separate the turbine enclosure from the reactor enclosure and the-control structure are provided with 3-hour rated penetration seals, and doorways in these walls are provi6ed with 3-hour rated fire doors.

The main turbine-lube oil storage tanks and lube oil reservoir are located in compartments that are separated from the remainder of the turbine enclosure by 3-hour fire walls. Therefore, a fire occurring in any of these compartments would not affect the boundary wall separating the turbine enclosure from the reactor enclosure and control structure. The generator hydrogen seal oil unit is separated from the reactor enclosure boundary wall by a 3-hour rated fire wall, and is located more than 70 feet away from the nearest control structure wall.

Item 224 BTP Guideline Automatic fire suppression should be installed to combat any diesel generator or lubricating oil fires; such systems should be designed for operation when the diesel is running without affecting the diesel.

LGS Desian Each diesel-generator cell is provided with a pre-action suppression system that is activated by heat detectors. Flow switches located in the supply piping to each pre-action system will trip the diesel-generator in that cell if the suppression system is actuated. Baffles are provided to protect the generators and control devices from damage due to suppression system water discharge.

Item 227 _

BTP Guideline Drainage for firefighting water and means for local manual venting of smoke should be provided. .

LGS Desian Each diesel-generator cell is provided with trapped and vented floor drains with adequate drainage capacity to cope with the

maximum sprinkler water flow in each room.

3-66 REV. 2, 11/82

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Each diesel-generator cell is provided with two exiiaust fans, each capable of 40 air changes per hour for cooling and/or smoke removal. The ventilation system is controlled manually from a local control panel and is also started automatically by either t

high air temperature or a diesel engine start signal.

F Item. 2.42.

BTP C,uldeline ku.domo.41c fire. pro}ecYion. Should he pftVided. ko alorrn ond.

ann.unciqfe, (n, the. condrol room and.Yo alarm. locally.

L CS bes~i,gn.

Ee. dete. dors are not provided. within, the refuelin3 area.

(elev. $52. fed. in.4e reactor enclosure). h e. flaer a t.-ceiling hew ht of this area k greater than. s7 feet, which. greatly ,

h'mGs the usefulness of photoelec4ric, er ionhfion.-f pe y ddec4 ors I maarded at ce'dir3 level. %e use of beam-t pe y detecfors as an alterna4ive loecause movement of fhe, reae.+or enclosure. crane. and i tsloads would inierfere is not practicctl, W4h proper operahon, of 4he defectors. %e lack of fire ddeders in. 4%is area is acceptable for 4he follewb reasons:

a) Equipment and cablina needed for safe shutdown, in. 4he, event of a firm. is not locafed in. 4his area., as noted im Sedien, s.4.2.7.

i (2.) There is no shnificard guanfify of combustible materials located with n. & area. l 3-66a.

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Item 243 j BTP Guideline !

Fire barriers, automatic fire suppression and detection, and ventilation controls should be provided.

LGS Desian The radwaste enclosure, including the offgas enclosu're, is l

separated from other portions of the plant by 3-hour rated fire walls. Automatic fire detection is provided in limited areas of the radwaste enclosure, as shown in Table A-1. In consideration of the low combustible loading in the remaining areas of the radwaste enclosure, detection by personnel in the vicinity is '

t deemed sufficient.

An automatic wet pipe sprinkler system is provided for the waste drum storage area at elevation 217 feet in the radwaste enclosure. Hose stations and portable fire extinguishers are provided for fire suppression coverage of the remainder of the radwaste enclosure.

Ventilation systems for the radwaste enclosure are manually controllable from control panels located in easily accessible areas of the radwaste enclosure.

Item 247 BTP Guideline Cooling towers should be of noncombustible construction when the basins are used for the ultimate heat sink or for the fire protection water supply.

LGS Desian The cooling tower basins serve as a source of water for the fire protection system but not for any safety-related systems. The cooling towers are constructed entirely of non-combustible material except for the splash bars and drift eliminators, which are polyvinyl chloride, and the splash bar support grids, which are fire retardant polyester and fiberglass. The fill material is contained in a ring-shaped area around the periphery of each 3-67 REV. 2, 11/82

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LGS FPER tower. The ring is separated into six cells by fire walls located at 600 intervals. A fire occurring in any one cell would have no effect on safety-related structures or systems, since such a fire would not affect ~ the structural integrity of the cooling tower and the towers are located away from safety-related structures. This arrangement has been accepted by ANI for design I of cooling towers with PVC and polyester fill material and !

l without fire protection sprinklers, Item 248 BTP Guideline Miscellaneous areas such as shops, warehouses, auxiliary boiler rooms, fuel oil tanks, and flammable and combustible liquid )

storage tanks should be so located and protected that a fire or 1 effects of a fire, including smoke, will not adversely affect any ,

safety-related systems or equipment.

I LGS Desian The machine shop, construction shop, warehouse, administration building, and auxiliary boiler enclosure are located adjacent to the Unit 2 reactor enclosure and turbine enclosure, but are separated from these structures by 3-hour rated fire walls so that fires occurring in any ci the miscellaneous areas will not adversely affect any safety-related systems. The machine shop, construction shop, warehouse, administration building, and auxiliary boiler enclosure each are provided with wet pipe sprinkler systems at strategic Iccations. Hose stations and portable fire extinguishers are also provided to support manual fire fighting efforts. The two outdoor storage tanks containing No. 2 and No. 6 fuel oil for the auxiliary boilers are separated from the nearest portion of the power block (the Unit 2 diesel-generator enclosure) by more than 120 feet. Both of these tanks are provided with foam extinguishing systems, as described in Section 2.7.

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ML20070M138

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ML20070M138

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