ML20071F466

Forwards Draft Responses to SER Open Items Re Draft Fire Protection Section,Per .Final Responses & Related Page Changes Will Be Submitted Subsequent to 830518 & 19 Meetings

ML20071F466
Person / Time
Site:	Limerick
Issue date:	05/13/1983
From:	Bradley E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Schwencer A Office of Nuclear Reactor Regulation
References
NUDOCS 8305180451
Download: ML20071F466 (67)

Text

{{#Wiki_filter:.e. PHILADELPHIA ELECTRIC COMPANY 2301 MARKET GTREET P.O. BOX 8699 PHILADELPHI A. PA.19101 '"*""",**[,^"'""' 12:53 e414ooo .s., CUG ENE J. BR ADLEY assoconts ennemat counsak DON ALD BLANKEN [UDOLPH A. CHILLEMS 9 E. C. KIR K H A LL T. H. M AMER CORN ELL PAUL AUERB ACH assistant sanamaL counse6 CDWARD J. CULLEN. J R. THOM AS H. MILLER. JR. 17.E N E A. Mc K EN N A ASSISTANT COWNSEL Mr. A. Schwencer, Chief Docket Nos: 50-352 50-353 Licensing Branch No. 2 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Limerick Generating Station, Units 1 and 2 Draft Fire Protection Section of the Safety Evaluation Report

REFERENCE:

Letter, A. Schwencer to E. G. Bauer, Jr. dated April 19, 1983

Dear Mr. Schwencer:

Transmitted herewith are draft responses to open items which were transmitted by the reference letter. This material is provided in draft form at the request of Mr. Eberly,-NRC staff reviewer. Final f responses and any related FPER page changes will be submitted subsequent l to the meeting scheduled for May 18 and 19, 1983 with the Fire Protection Section. l l Very truly your, Euge J. radicy JLP/ cam d/2 00' Copy to: See attached service list i i 8305180451 830513 PDR ADOCK 05000352 E PDR

..a. 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. Hodgdon (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) Thomas Y. Au, Esq. (w/o enclosure) Mr. Thomas Gerusky (w/o enclosure) Director, Pennsylvania Emergency Management Agency (w/o enclosure) Mr. Steven P. Hershey (w/o enclosure) James M. Neill, Esq. (w/o enclosure) Donald S. Bronstein, Esq. (w/o enclosure) Mr. Joseph II. White, III (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) b 6 6 l l l

'E. NRC Open Item #2: Fire Hazards Analysis Redundant trains of components that are susceptible to damage from water spray are physically separated so that manual fire suppression activities will not adversely affect the operability of components not involved in the postulated fire. However, we cannot determine if mechanisms by which fire and fire fighting systems may cause.the simultaneous failure of redundant or diverse trains have been considered in the design. We require that the applicant identify such mechanisms that were con-sidered in its fire hazards analysis and the measures taken to preclude the fire or fire suppressant induced failure of redundant or diverse safety trains. CMEB Position Firefighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems, and components. [ Excerpt from General Design Criterion 3, Appendix A to 10 CFR Part 50]. I LGS Response The Limerick design with respect to the potential for rupture or inadvertent operation of fire suppression systems is addressed in FPER Section 3.1, Item 24. As noted in Item 24, moderate-energy leakage cracks in fire suppression system piping were analyzed as discussed in FSAR Section 3.6. FSAR Section 3.6.1.2.2 summarizes the results of the moderate-energy fluid system analysis and also provides references to other FSAR sections that discuss the design bases and criteria that were used in the moderate-energy fluid system analysis. The analysis demonstrates that the occurrence of a crack in moderate-energy piping, including the fire suppression system piping, will not prevent the plant from being brought to a safe, cold shutdown. Automatic suppression systems have been designed and located so that operation of the systems, either intentional or inadvertent, will not cause damage to redundant trains of safety-related equipment that is needed for safe shutdown of the plant. To the greatest extent practical, safety-related electrical components are located outside the coverage zones of automatic suppression systems. Where necessary, components that are needed in order to achieve safe shutdown and also are located within automatic suppression system coverage zones are designed to remain functional in the event of suppression P-60(b)/3 - 2/1-

7 ~ DRAFT system actuation. Three of the areas that are provided with auto-matic water-type suppression systems are the HPCI pump compartment, the RCIC pump compartment, and the diesel-generator cells. Actua-tion of the suppression systems in the HPCI and RCIC pump compart-ments could cause damage significant enough to affect the oper-ability of the systems in those compartments. In the diesel-generator cells, baffles are provided to protect the generators and control devices from damage due to suppression system actuat-ion, but each diesel-generator will be automatically tripped if the suppression sysem in its cell is actuated. Loss of any of these three systems (HPCI, RCIC, or a single diesel-generator) due to suppression system actuation is acceptable, since redundant systems will remain available to bring the plant to a safe, cold shutdown. Automatic (water) suppression systems located in safety-related areas of the plant are of the type that have fusible heads (either pre-action or wet pipe). These systems cannot be actuated in the absence of a significant heat source in the vicinity of the sprinkler heads. Therefore, electrical anomalies in the circuits of the smoke and heat detection systems or the suppression system power supplies cannot cause inadvertent actuation of these suppression systems. Section 5.1 of the FPER describes the methodology that was used in evaluating the effects of postulated fires on the capability to achieve safe shutdown of the plant. The assumptions and design bases involved in this evaluation are identified in Section 5.1. Section 5.2.2 of the FPER provides a description of the four methods of achieving safe shutdown that were analyzed, including identifi-cation of the individual components that are utilized in each of the shutdown methods. Consideration of the need to manually posi-tion certain motor-operated valves is included in Section 5.2.2. Postulated fires are considered to be capable of rendering a com-ponent inoperable either by directly damaging the component or by damaging electrical cabling that serves the component to the extent that circuit faults occur. Possible failure modes of circuits that are damaged by fire are considered to include open circuits, hot shorts, and shorts to ground. Components and/or cables that are associated with redundant shutdown methods and are horizontally separated from each other by less than 20 feet within the same fire area are considered to be damaged simultaneously by a postulated fire, unless one of the redundant trains of components / cables is enclosed by a fire barrier having a minimum rating of 1 hour. ~~ The measures that have been taken to preclude a postulated fire from causing concurrent damage to all four of the specified shutdown methods are discussed for each individual fire area in Sections 5.3 through 5.9 of the FPER. References 1. Branch Technical Position ASB 9.5.1, Appendix A, Section A.2 and D.l(b) 2. Branch Technical Position CMEB 9.5-1, Section C.1.b. P-60(b)/3 -2/2-

l NRC Open Item #5: 3-Hour Fire Barriers In e-r./ areas the structural steel supports of floor assemblies are not provided with a fire protective covering, resulting in unrated floor assemblies. CMEB Position We will require the exposed steel structural supports to be protected to provide 3-hour fire resistance in all areas containing safe shutdown systems and in all other areas where the structural failure of the unprotected steel would affect areas containing safe shutdown systems in accordance with Section C.5.a of BTP CMEB 9.5-1. LGS Response The structural steel supports of floor assemblies at elevations 254 ft., 269 ft., 289 ft. and 304 ft of the Control Structure are provided with a fire protective coating to give a 3-hour rated assembly. All other structural steel supporting floor assem-blies in the Control Structure and Reactor Enclosure are not provided with a fire protective coating for the reasons des-cribed below. 1. The fire loading below the uncoated areas is considered to be very low. All fire areas with a fire severity of 10 mins. or less have been elininated from f urther con-sideration due to the extremely low combustible loading in these areas. Any fire area provided with a water sup-pression system has also been eliminated as the water sup-pression system is considered to provide sufficient pro-tection and cooling of the area to prevent the failure of the structural steel supports. Table A-1 of the FPER provides a tabulation of the fire areas, combustible loading and equivalent severity for all areas of the plant. After elimination of the above described areas, the following areas remain for further consideration. Combustible Equivalent Area Elevation Loading (lb/ft2) Severity (min) 44 217'-0" 3.94 22 45B 253'-0" 2.63 16 47A 283'-0" 2.28 14 47B 295'-3" 2.07 12 2. In order to adequately assess the fire resistance of the unprotected structural steel supports, an analysis was performed to determine the maximum temperatures P-70 (b )/16 -5/1-

mm D jbs h" O reached by the subject steel members at the end of the fire duration. These maximum temperatures were then compared to the temperatures at which the steel members may fail, as determined by several recognized experts in the field, to determine acceptability of the steel members. See References 1, 2 and 3. Transient combustibles have not been considered in this analysis as the amount carried and location will be ad-ministratively controlled. The fire was assumed to occur due to a faulted cable in a tray. This analysis considered the possibility of point loadings or a heavy concentration of in-situ combustible material in a localized area of the compartment. A point loading has been defined as an area which contains 6 vertically stacked horizontal cable trays with i adjacent vertical tray. The following is a list of major assumptions that was used in the analysis:

• Duration of fire is determined based on stoichiometric combustion c
• Thes.e are 2.5 air changes per hour
• Fire is extinguished at one hour
• One-fourth of total in-situ combustible is involved in the fire
• No transient combustibles are assumed The results of the analysis show that the maxinum temperature of any steel member is less than 1000*F which is much lower than the failure temp of 1600*F for full composite action as determined by Pearch and Stanzak, Ref.

3. Conservatisms in the analysis are as follows:

• All of the combustible material, one-fourth of that located in the fire area, was assumed to be involved in the fire from start to extinguishment.
• The heat of combustion of IEEE-383 approved cable was taken as 9950 BTU /lb as compared to 8,000 BTU /lb for wood.
• No heat was transmitted from the steel members into the concrete.

P-7 0 ( b)/16 -5/2-

i .e m=a Ear

• The calculation of tamperature rise of steel was based on the entire surface area of the beam except I

the top flange. In fact, in the as-built condition, one-half of the beams are embedded.

• The maximum initial temperature of 104*F in compart-ment was used as the initial steel temperature.

This corresponds to an outside air temperature of 95'F and 100*F relative humity. Based on the results of the worst case analysis and the con-servatisms delineated above, it is concluded that coating of the exposed structural is not required. References 1.

Lie, T.T.,

Fire and Buildings, Applied Science Pub-lishers Ltd., London, 1972, p. 158. 2.

Stanzak, W.W.,

"The Calculation of the Fire Resistance of Steel Constructions," National Research Council of Canada, Technical Translation 1425, 1971, p.8, 3. Pearch, N.S. and Stanzak, W.W., " Load and Fire Test Data on Steel-Supported Labor Assemblies", Symposium on Fire Test Methods, Restraint and Smoke,~1966, ASTM STP 422, Am. Soc. Testing Mats., 1967, p. 5-20. 4. Branch Technical Position ASB 9.5-1, Appendix A, Sections B.4 and B.S. 5. Branch Technical Position CMEB 9.5-1, Section C.3 P-70(b)/16 -5/3-

DRAFT NRC Open Item #6: Penetration Seals The applicant will provide penetration seals for all penetrations of fire rated walls or floor / ceiling assemblies. The penetration seals have been subjected to qualification tests using the time-temperature curve specified by ASTM Standard E-119, " Fire Test of Building Construction and Materials". The test acceptance criteria used by the applicant would permit temperatures up to 325'F above ambient on the unexposed side of the seal. Our guidelines recommend that a maximum temperature of 325'F be used as the acceptable level. The applicant's higher acceptance criteria of 325'F above ambient could permit the acceptance of penetration seals that would cause fire damage to unexposed cables in a shorter time period than would penetration seals meeting our guidelines. CMEB Position We require the applicant to verify that none of the penetra-tion seals used will permit a temperature in excess of 325'F on the unexposed side as recommended by BTP CMEB 9.5-1, Section C.5.a(3), or to justify the deviation from our guidelines. LGS Response l Each type of penetration seal design that is planned to be used in fire-rated barriers at Limerick has been qualified for the intended used by fire testing of prototype penetration seals. The test results show that, for each type of penetration seal, the maximum temperature on the unexposed side does not exceed 325'F. This is in compliance with Section C.S.a(3)(b) of BTP CMEB 9.5-1. References 1. Branch Technical Position ASB 9.5-1, Appendix A, Section D.l(j) 2. Branch Technical Position CMEB 9.5-1, Section C.5.a(3) 1 l P-60(b)/3 -6/1-

i DE l i E D NRC Open Item #7: Fire Doors u i The doors between the turbine building and areas of the plant con-taining safe shutdown systems are not labeled fire doors. Although these steamtight doors are certified by the manuf acturer to be con-structed in the same manner as the labeled doors, their method of installation as a steamtight door generally precludes the necessary gaps for expansion and distortion for a labeled fire door assembly and would probably not provide the necessary fire resistance. CMEB Position We will require that either labeled 3 hr. fire door assemblies be provided at all such openings or replicate assemblies of the steam-tight doors be tested by a nationally recognized testing laboratory to show that they provide equivalent fire protection when subjected to the ASTM E-119 time temperature curve for 3 hours. LGS Response All single-leaf steamtight doors that are located in 3-hour fire walls are rated as Class A UL-labeled doors. Seven double steam-tight doors in the walls between the control structure and the turbine enclosure are designated as fire rated but are not provided with UL labels. These double doors are similar to the UL-labeled doors with the exception of the following design differences from UL tested and approved assemblies: a. Door size - the size tested by UL is 6'-0" by 7'-2" where-as the maximum size of the Limerick doors is 10'-0"x11'-0". b. Door thickness - the maximum thickness tested by UL is 2-3/4" whereas the maximum thickness of the Limerick doors is 9". c. Limerick doors contain a removable mullion that is not present in the UL tested assemblies. d. Minor hardware dif ferences as follows: 1. Customized hinges 2. Locksets by Sonicbar Door Systems 3. Additional security hardware e. Limerick doors are equipped with elastomeric gaskets to assure steam tightness. These double steamtight doors are certified by the manufacturer to be constructed as closely as possible to the Underwriters Laboratories procedure for 3-hour rated, Class A, special purpose door units (file No. R7643, Vol. 1). References 1. Branch Technical Position ASB 9.5-1, Appendix A, Section D.l(j) 2. Branch Technical Position CMEB 9.5-1, Section C.5.a(5) l l P-60(b)/3 -7/1-

O DR297 NRC Open Item #8: Metal Deck Roof Construction Metal roof deck construction is a UL listed Class A assembly. The Class A rating indicates that the roof assembly is effective against severe external fire exposures. This does not meet our guidelines in Section C.5.a(10) of BTP CMEB 9.5-1, as the roof assembly has not been tested for performance under internal fire exposures. CMEB Position We will require the applicant to provide metal roof deck construction that is classed " acceptable for fire" in the UL Building Materials directory or which meets the criteria for Class 1 roof deck systems in the FM system approval guide. LGS Response Metal deck roof construction is used only for the turbine enclosure, which is'a nonsafety-related structure. The roof is constructed of metal decking and non-reinforced concrete covered by "Gacoflex N-3S", which is a single-ply membrane supplied by Gates Engineering Company. "Gacoflex N-3S" is listed as Class A in the UL Puilding Materials Directory. The entire turbine enclosure roof assembly meets the requirements for a Class 1 system in the Factory Mutual System Approval Guide. References 1. Branch Technical Position ASB 9.5-1, Appendix A, Section D.l(e) 2. Branch Technical Position CMEB 9.5-1, Section C.5.a(10) P-60(b)/3 -8/1-

Ne%=f77 t: NRC Open Item #9: Floor Drains Some areas of the plant are not equipped with floor drains. The applicant states that collected fire fighting water could be drained rooms. This is not consistent through the doorways to the adjacent with our guidelines in Section C.5.a(14) of BTP CMEB 9.5-1. It is our concern that redundant trains of safety-related equipment in unaffected areas could be flooded by excess fire fighting water. CMEB Position We require that the applicant provide suitable floor drains or a system of drains and curbs to prevent flooding of safety related equipment. LGS Response The only fire areas that are not provided with floor drains and which contain safety-related equipment that is needed for safe shutdown are the 4-kV switchgear compartments (fire areas 12 through 19) and the static inverter compartments (fire areas 20 and 21). The use of hand-held fire hoses in any of these fire areas will not result in flooding that causes unacceptable damage to safety-related equipment. A fire hose can be used in the 4-kV switchgear compartments only by bringing the hose in through a doorway from adjacent fire areas. For fire areas 12, 14, 16, and 18, the fire hose would be brought in from the generator equipment area (fire zone 113B) along the north side of the control structure. Water discharged from a hose in one of these 4-kV switchgear compartments would flow through the open doorway to fire zone ll3B and drain into the floor drains in that area. For fire areas 13, 15, 17, and 19, the fire hose would be brought in from the equipment hatch corridor (fire areas 97 for Unit 1 and 110 for Unit 2) via the control structure corridor (fire area 7). Water discharged from a hose in one of these 4-kV switchgear compartments would flow through the open doorway to fire area 7 and then through the doorway to the equipment hatch corridor. The equipment hatch corridor is provided with floor drains to dispose of the fire fighting water. For either case of the two water discharge paths described above, I I water discharge from a fire hose in one of the 4-kV switchgear compartments has been determined to result in a maximum water level lower than the water level that would cause damage to the safe shutdown components in the compartment. Therefore, I additional floor drains are not needed to ensure that safe shutdown capability is retained. A fire hose can be used in the Unit I static inverter compartment (fire area 20) only by bringing the hose in from the Unit I cable spreading room through an open doorway. The Unit 2 static P-60(b)/3 -9 /1-

r O Dhei"P; D'P inverter compartment (fire area 21) contains a manual hose station, so that a hose would not have to be brought in from outside the compartment in order to initiate manual fire fighting.

However, the fire brigade would gain access to the Unit 2 static inverter ccmpartment through a doorway from either the Unit 2 cable spread-ing room or the generator equipment area (fire zone 113B).

The doorway that is used for access will remain open during fire fight-ing activities within the compartment. Water discharged from a hose in the Unit 1 static inverter compartment would flow through the open doorway to the Unit I cable speading room, whereas water dis-charged from a hose in the Unit 2 static inverter compartment would flow to either the Unit 2 cable spreading room or the generator equipment area. The cable spreading rooms and the generator equip-ment area are each provided with floor drains to dispose of the fire fighting water. For either of these water flow paths, water discharge from a fire hose in one of the static inverter compart-ments has been determined to result in a maximum water level lower than the water level that would cause damage to the safe shutdown components in the compartment. Furthermore, loss of the safe shutdown components in a static inverter compartment would not prevent safe shutdown from being achieved, since the redundant safe shutdown components would remain operable. Therefore, additional floor drains are not needed to ensure that safe shut-down capability is retained. The provisions discussed above for drainage of fire fighting water out of the 4-kV switchgear compartments and the static inverter compartments are in full compliance with Section C.S.a(14) of BTP CMEB 9.5-1. References 1. Branch Technical Position ASB 9.5-1, Appendix A, Section D.l(i) 2. Branch Technical Position CMEB 9.5-1, Section C.5.a(14) P-60(b)/3 -9/2-

DRAFT NRC Open Item #10: Stairwell Enclosures The applicant has not provided a description of the 2-hour rated fire barriers for the plant enclosed stairwells for us to independently verify compliance with our guidelines. CMEB Position We require the applicant to provide details showing compliance with Section C.S.c of BTP CMEB 9.5-1. LGS Response All stairwells that serve as escape routes, access routes for fire fighting, or access routes to areas containing equipment necessary for safe shutdown are enclosed by a 2-hr fire rated envelope consisting of reinforced concrete unit masonry walls with a minimum thickness of 8 inches. 'Each door opening which is a part of the above fire barrier has a fire rating of 1 1/2 hr. and is provided with Underwriters Laboratories "B" label doors which qualify for use in a 2-hr barrier. All penetrations in the above barrier are sealed using penetration seal details that have been qualified for use in 3-hr rated fire barriers. Based on the above, it is concluded that Limerick complies with the BTP CMEB 9.5-1 guidelines concerning fire protection for stairwells. References 1. Branch Technical Position ASB 9.5-1, Appendix A, Section D.4(f) 2. Branch Technical Position CMEB 9.5-1, Section C.S.a(6) P-60(b)/4 -10/1-

.. ] ^ DRAFT DetR Ouen Iter: l'32 "We have evaluated the fire protection provided for the remote shatdown panel and conclude that it is not physically separatto from the control room in accordance with our gaidelines in Section C.S.c of BTP CMED 9.5-1. The remote shatdown panel is located in the Auxiliary Equipnent Room (Fire Area 25) along with PGCC cabinets and therefore, this area containc systems fer both the normal shutdown system and the alternative shutdown capability for both units. The applicant has orally indicated that additienal information will be sabmitted on this item." BTP CMEB 9.5-1, Section C.S.c C.5.c. Alternative or Dedicated shutdown capability l (1 ) Alternative or dedicated shutdown capability previded for a l specific fire area shoald be able to achieve and maintain I saberitical reactivity conditions in the reactor, maintain l reactor coolant inventory, achieve and maintain het standby conditions for a PWR (hot shotdown for a BWR) and achieve cold l shatdown conditions within 72 hoars and maintain cold shatdown conditions thercafter. Daring the postfire shutdown, the reactor coolant system pr'ocera variables shall be maintained with those predicted for a loss of normal ac power, and the fission prodact boandary integrity shall not be affected; i.e., there shall be no fuel clad damage, raptare, or any primary coolant boundary, or rapture of the containment boundary. (2) The performance goals for the shutdown functions shoald be: (a) The reactivity control function shoald be capabic of achieving and maintaining cold shutdown teactivity conditions. (b) The reactor coolant makeup function should be capable of maintaining the reactor coolant level above the top of the core for BWRs and be within the level indication in the rtessurizer for PWRs. (c) The reactor heat removal function should be capable cf achieving and maintaining decay heat removal. (d) The process monitoring function shoald be capable of providing direct readings of the process variables necessary to perform and control the above fonctions. (e) The supporting functions shoald be capable of providing the process cooling, lubrication, etc., necessary to permit the operations of the equipment used for safe shatdown fanctions. e

4 j U2 0 nu d (3) The shatdown capability for specific fire areas may be ar 1qac for each sach area, or it may be one aniq;e combinatien ci systems for all soch areas. In.either case, the alternative shutdown capability shall be independent of the specific fire area (s) and shall accommodato postfire conditions where offsite power is avai3able and where offsite power is not available for 72 hours. Procedares shall be in effect to implement this capTbility. (4) If the capability to achieve and maintain cold shutdown will not be available becaase of fire damage, the equipment and systems comprising the means to achieve and maintcin the het standby or hot shatdown condition shall be capable of maintaining sach conditions until cold shatdown can be achieved. If sach equipment and systems will nct be capnble of being powered by both ensite and offsite electric pcwer systems because of fire damage, an independent entite power system shall be provided. The number of operating shif t personnel, exclusive of fire brigade members, reqaired to operate sach egaipment and systems shall be onsite at all times. (5) Equipment and systems comprising the means to achieve and maintain cold shutdown conditions shoald not he danaged by fires or the fire damage to such eqaipnent and systcns shcald be limited so that the systems can be made operable and cold shutdown achieved within 72 hoars. Materials fer sach repairs shall be readily available onsite and procedares shall be in effect to implement such repairs. If such equipment and systems ased prier to 72 hours after the fire,will net be capable of being powered by both onsite and offsite electric power systems because of fire damage, an independent onsite power system shoald be provided. Equipment and cyt.tems ased after 72 hoars may be powered by offsite power only. (6) Shutdown systems installed to ensare postfire shatdewn capability need not be designed to meet seismic Category I criteria, single failure criteria, or other design baris accident critoria, except where reqaired for other reasons, e.g., because of interface with or impact on existing safety systems, or becaase of adverse valve actions due to fire damage. (7) The safe shutdown egaipment and systems for each fire area should be known to be isolated from associated circuits in the fire area so that hot shorts, open circaits, or shorts to groand in the associated circuits will not prevent cperation of the safe shutdown eqaipment. The separation and barriers between trays and condaits containing associated circuits cf one safe shutdown division and trays and cor its containing associated circuits or safe shatdcwn cables from the redandant division, or the isolation of these associated circaits frem the safe shutdown eqaipment, should be sach that a pestalated i l l l

-DRAFT fire involving arsociated circuits will not preves.t r,afe shatdown. Las Response: The Remote Shatdown Pancis (10C201 and 20C201) will be encicsed by walls which will separate these panels from the rest of the Auxiliary Equipment Room. These walls will have a three hear fire rating. All cabling going to the homote Shatdown Panels which pass throagh the Aaxiliary Eqaipment Room will be encapsulated by a three hear fire barrier. Access to the new remote shatdown room will be provided se that operating personnel will not be reqaired to pars throagh tl.c Aaxiliary Eqaipment Room to gain access to the Remote Shatdcur. Fanels. These mensores will assare that the anits can be broaght to a safe cold shutdown condition daring a fire in the Auxiliary Eqaipment Recm. The addition of the walls around the Renote Shatdown Pcnols creates a new fire area (Area 26, Remote Shatdown Room). For a fire within this room, safe shatdown can be achicved from the Control Room asing either shatdown methods B or D. Under this scenario, however, control of the following safe shatdown components will be lost in the Contre,) Ecom: HV51-F009 RIIR Shatdown Cooling Suction Valve 152-11602 Div II 4160V Das Breaker 152-11607 Div II 490V Load Center Breaker 152-11609 Div TI 4160V Bas Breaker The three circuit breakers will be controlled directly at the Division II switchgear. Valve HV51-F009 will be operated manaally by torning the valve hand wheel. The above provisions assare that alternate shatdown capability exists for fires in the Control Room, Aaxiliary Eqaipment Room, Hemote Shutdown Room and Cable Spreading Room. The requirements of the above cited section of RTP CMED 9.5-1 are therefore satisfied. Limerick will comply with the reqairements cf BTP CMEB 9.5-1, Section C.5.c, in Fire Area 25 and 26.

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DRAFT NRC Open Item #13: Control of Combustible Gases Safety-related systems have been isolated or separated from combustible materials as much as possible. The storage of flammable liquids complies with NFPA 30. Compressed gases are stored either outdoors or in nonsafety-related structures whenever possible. However, compressed gas cylinders associated with the primary containment instrument gas system and con-tainment combustible gas monitoring system are located in the reactor enclosure. This does not meet our guidelines in Section C.S.d of BTP CMEB 9.5-1. CMEB Position We require that either the cylinders be moved to nonsafety-related areas or a combination of the conditions of storage plus fire protection provided be demonstrated to achieve an equivalent level of safety. LGS Response The compressed gas cylinders associated with the primary contain-ment instrument gas system are filled with nitrogen. The cylin-ders are located inside secondary containment, with their longi-tudinal axes parallel to the reactor enclosure wall. This gas is noncombustible, and therefore does not constitute a hazard with respect to fire protection. Similarly, the oxygen cylinders associated with the containment combustible gas monitoring system have been located in the reactor enclosure, in accordance with NFPA 51 guidelines. In contrast to primary containment, the oxygen concentration inside the secondary containment is not maintained at reduced levels during plant operation. Since the volume of compressed oxygen is negligible in comparison to the volume of oxygen in the atmosphere within the oxygen cylinder storage area, the oxygen cylinders do not cons-titute a hazard with respect to fire protection. In accordance with the guidelines of Section C.S.d of BTP CMEB 9.5-1, the hydrogen cylinders associated with the containment combustible gas monitoring system are being located outside of safety-related structures. These cylinders will be stored with their longitudinal axes parallel to the reactor enclosure walls. References 1. Branch Technical Position ASB 9.5-1, Appendix A, Section D.2(b) 2. Branch Technical Position CMEB 9.5-1, Section C.5.d(2) P-60(b)/4 -13/1-

n,~, 7=r n;-as open Item #14: Line Type Heat Detectors and Suppression Safety related cable trays outside the cable spreading room are not provided with continuous line type heat detectors, and in many areas automatic water suppression systems are not provided. The applicant states that smoke detectors are provided in the vicinity of cable trays, and separation of one hour barriers are provided in lieu of automatic sprinklers. This does not meet our guidelines in Section C.S.e(2) of BTP CMEB 9. 5-1. CMEB Position Line type heat detectors will detect overheating in cable trays prior to combustion. Automatic sprinklers permit a means of promptly suppressing incipient fires. To meet our guidelines, we require that the applicant provide line-type heat detectors and automatic sprinklers. LGS Response Limerick has provided smoke and fire detectors (ionization or photo-electric type) at ceiling level in areas through which safety-related cable trays are routed. The detectors are located throughout the plant as discussed in FPER section 2.11 and as listed in FPER Table A-1. This type of smoke and fire detection provides a means to detect an incipient cable tray fire, whereas thermally actuated line-type heat detectors will not initiate an alarm until the fire has passed beyond the incipient stage. Auto-matic sprinklers do not provide a means to promptly suppress incipient fires since they must be thermally actuated. Adequate manual fire fighting means are provided in areas through which safety-related cable trays are routed, as described in the response to open Item #21, and all of these areas are easily accessible. In general, the cable trays are not provided with auto-matic suppression system coverage because all, raceways that are needed for safe shutdown are separated as described in the response to open Item #11, thus assuring that a fire occurring in any fire area will not result in loss of safe shutdown capability. Testing has shown that electrical cable tray fires involving cables of the type used at Limerick (IEEE 383 qualified) will not propa-gate to adjacent trays that are separated in accordance with Regu-latory Guide 1.75. Raceway separation at Limerick is in confor-mance with Regulatory Guide 1.75. Therefore, the Limerick design can accommodate any cable tray fire due to either an electrical failure or an exposure fire, and the use of line-type heat detectors and automatic suppression systems for the cable trays would not provide any enhancement of safe shutdown capability. The Limerick design for fire detection systems and fire suppression capability in areas through which safety-related cable trays are routed is adequate to ensure that fires involving cable trays will not prevent safe shutdown of the plant f rom being achieved. References 1. Branch Technical Position ASB 9.5-1, Appendix A, Section D.3(c) 2. Branch Technical Position CMEB 9.5-1, Section C.5.e(2) P-60(b)/4 -14/1_

DRM7 NRC Open Item #15: Power Supplies for Ventilation The power supply and controls for the ventilation systems for the control structure f an rooms are not run outside the fire area served by the system. The applicant has not provided suf ficient details for us to independently verify compliance with our guidelines in Section C.5.f of BTP CMEB 9.5-1. CMEB Position We require the applicant to demonstrate that a single fire will not disable both trains of ventilation needed for safety-related areas in the control structure. LGS Response In accordance with the guidelines of BTP CMEB 9.5-1,.Section C.S.f(3), the routing of the power supply and control cables for mechanical ventilation systems was studied. Considering the plant's configuration and equipment location, it was determined to be impractical to run the power supply and controls for the ventilation systems for the control structure fan room outside the fire area served by the system. This is because ventilation for the control structure fan room is provided by one of the fan systems located in the fan room. Portable smoke ejectors will be provided to assist in removal of the products of combustion from the f an room if the normal ventilation system becomes unavailable due to fire damage to both divisions of the ventilation control / power cables. As discussed in FPER Section 5.3.26, Revision 3, neither of the trains of the ventilation system are needed for safety-related areas in the control structure either during or after fire. If a fire should cause the loss of redundant trains of the venti-lation system, the room (s) affected will gradually increase in temperature. Appropriate countermeasures such as opening of doors and use of portable f ans will be implemented to re-establish air flow and limit the temperature rise in the affected rooms. References 1. Branch Technical Position ASB 9.5-1, Appendix A, Section D.4(c) 2. Branch Technical Position CMEB 9.5-1, Section C.5.f(3) P-60(b)/4 -15/1-t

~ r-L .. l. ,g rux:=2 I"4 B l ~ r DSER open Iten #36 I "This does not meet oar gcidelines in Section C.S.g of BTP C::E3 l 9.5-1 because upon loss of offsite power only one hear of energency l lighting capability is provided. We require the applicant to provide 8-hour self-contained battery powered lighting units in all areas needed for operation of safe shutdown eqJipment and in access and egress roates thereto." BTP CMER 9.5-1, Section C.S.q: C.S.g. Lighting and Commanication i Lighting and two-way voice commanication are vital to safe shatdown and emergency response in the event of fire. Saitable fixed and portable emergency lighting and commanication devices shoald be provided as follows: (1) rixed self-contsined lighting consisting of ficorescent or i sealed-beam units with individual 8-hocr miniman battery power sapplies shoald be provided in areas that mast be manned for I safe shatdown and for access and egress roates to and frem all fire areas. Safe shatdown areas include those required to be l manned if the controi room must be evacuated. l (2) Saitable sealed-beam battery-powered portabic hand lights should be provided for emergency use by the fire brigade and other operatiot.s personnel required to achieve safe plant shutdown. (3) Fixed emergency communications independent of the nornal plant commanication system shoald be installed at presclected l stations. (4) A portable radio commanications system should be provided for r l use by the fire brigado and other operations personnel required to achieve safe plant shutdown. This system should l not interfere with the commanications capabilities of the plant secarity force. rixed repeaters installed to permit use of portable radio commanication units shoald be protected fron exposure fire damage. Preoperational and periodic testing L shoald demonstrate that the frequencies used for portable radio communication will not affect the actuation of protective relays. s t i ..-- e - ---.-,__-._-_,__,..,..-_m.,,..,-,-,r.v--_.-,

_n_ r f DR w@Yt r. I4S Response All areas needed for the operation of safe shutdown equiprent and the access and egress paths thereto are provided with two diverse energency licating systemr., an AC system and an AC/DC system. The AC system is fed from the four diesel generator bast,es. The DC fee 1 to the b AC/DC systera is from the BCP battery. The chargers for this battery are fed from a diesel generator bas, therefore, DC emergency lighting will y be provided indefinetly daring loss of of f site power. The AC and DC energency lighting levels are nhown in FSAR Table 9.5-12 for all safety related areas. Table 9.5-13 will be revised to show the arens needed for operation of safe shatdown equipment ard the lighting levels provided. Where the DC emergency lighting systen does not provide at least b foot cand3c in these areas, self-contained 8-hoar battery powered lighting anits will be provided. This design assares that emergency lighting is available in all areas. The Limerick emergency lighting design is egaivalent to the energency lighting reqairements of the above cited BTP section.

References:

1. LGS FSAR Section 9.5.3 2. LGS FSAR Table 9.5-12 3. LCS FSAR Qaestions 430.65 throagh 430.69 Drawings: None 6 A E

C 4 DRAFT NRC Open Item #17: Fire Detection We cannot verify, from the applicant's fire protection report, H that detection is provided for adjacent areas which present a hazard to safety related equipment (e.g., the refueling floor area of the reactor enclosure and the decontamination areas.) We will require the applicant to verify that detection is provided for all areas that present a hazard to safety related equipment in accordance with our guidelines in Section C.6.a of BTP CMEB 9.5-1. The fire and smoke detection system is in compliance with NFPA 72A. The system does not comply with the requirements of NFPA 72D in the following areas: i 1. No device is providad for permanently recording incoming signals with the date and time of receipt. 2. Operation and supervision of the system is not the primary function of the operators. 3. In lieu of complete reliance on NFPA 72E, smoke and fire detector locations are established by a qualified fire protection engineer. This does not meet our guidelines in Section C.6.a of BTP CMEB 9.5-1. We will require the applicant to provide a system which complies with NFPA 72D for a Class A system, with detectors installed in accordance with NFPA 72.E. CMEB Position 1) Detection systems should be provided for all areas that contain or present a fire exposure to safety-related equipment. 2) Fire detection systems should comply with the requirements of Class A systems as defined in NFPA 72D, " Standard for the Installation, Maintenance, and Use of Proprietary Protective Signaling Systems," and Class 1 circuits as defined in NFPA 70, " National Electrical Code." 3) Fire detectors should be selected and installed in accordance with NFPA 72E, " Automatic Fire Detectors." LGS Response Fire detection capability is provided for all areas containing combustible materials that present a hazard to equipment or P-70(b)/13 -17/1- ,,ey

l s =0 f. o"* p, [TTU que 4 s l cabling that is needed for achieving and maintaining safe shutdown. Fire detection is not provided for the refueling floor area (fire zone 78A) or the shower and dressing areas (fire zones 78B and 78C) since the combustible loading in these areas is zero and none of the areas contain safe shutdown equipment or cabling. Further discussion of fire area 78 is provided in Section 5.4.27 of the FPER. The fire and smoke detection system is designed in con-formance with NFPA 72D except for the three items noted in Section 2.11 of the FPER. These three exceptions are justi-fied by the following considerations: 1. The logging of fire events by a device for permanently recording incoming signals is not required as the standard operating procedures will require the operator on duty in the main Control Room to enter the date and time of the receipt of an alarm from the fire detection system or initiation of any fire suppression system in the plant log book. 2. The plant operator's duties include monitoring and super-vision of the fire protection system. 3. The location of early warning fire and smoke detectors was determined and performed under the direction of a registered fire protection engineer. The location of fire and smoke detectors complies with NFPA 72E except for the location of ionization detectors in high-bay Ionization datectors are not located in each bay areas. formed by the deep beams. At locations in areas where composite construction is used, the dif fusion of ionized particles throughout the compart-ment volume produced during the incipient stage of the fire will negate the effect of beam depth and result in accept-able levels of detection coverage. Detector location conforms to NFPA 72E is met because the deep beams do not interfere with the circulation of ionized particles to the detector. References 1. Branch Technical Position ASB 9.5-1, Appendix A, Section F.13 & F.15. 2. Branch Technical Position CMEB 9.5-1, Section C.6.A. P-70(b)/13 -17/2-

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~ - O n y,4 m NRC Open Item #18: System Piping Connections Pressure for the fire protection water system is provided by a 2 in. connection to the service water system. This does not meet our guidelines in Section C.6.b(4) of BTP CMEB 9.5-1. We require the applicant to provide a separate jockey pump to maintain pressure. CMEB Position The fire main system piping should be separate from service or sanitary water system piping, except as described in Position C.5.c(4). LGS Response The fire protection water system does not include any piping that also functions as part of the service water or sanitary water systems. The 2-inch line that provides pressure maintenance for the fire protection water system is part of that system only 3' and has no function in the operation of the service water system. This design is in conformance with Section C.6.b(4) of STP CMEB 9.5-1. The pressure-maintenance feature of Limerick's fire protection water system is designed in accordance with NFPA 20, in that the 2-inch connection from the service water system meets the requirements and function of a supply from a pressure-main-tenance pump having the required rated capacity not less than the normal leakage rate and having a discharge pressure sufficient to maintain the desired fire protection system pressure. The water source for the service water system is the cooling tower basin, which is the same water source that the fire pumps utilize. The service water system serves as a highly reliable source of pressure, in that (a) connections are provided between the fire protection system and both the Unit 1 and Unit 2 service water systems, and (b) each service water system inlcudes three 50% capacity service water pumps. This design results in a more reliable pressure source than would be provided by a jockey pump. J i P-60(b)/3 -18/1-

3

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s =ca u+9 /t m '%3 ,l s ~ The use of a 2-inch line from the service water system to maintain pressure in the fire protection water system is appropriate because it is in confonnance with NFPA 20 as well as with Section C.6.b(4) of BTP CMEB 9.5-1. References ( l. Branch Technical Position ASB 9.5-1, Appendix A, Section E.2(c) 2. Branch Technical Position CMEB 9.5-1, Section C.6.b l P-60(b)/3 -18/2-w _e n m. -..,

,.V r DRAFT NRC Open Item 419: Valve Supervision Supervision has not been provided for all valves in the fire protection water supply in accordance with NFPA 26. CMEB Position To meet our guidelines, in Section C.6.c of BTP CMEB 9.5-1 the type of valve supervised and the frequency at which its position is verified should be as listed below. Frequency of Type of Inspection with Type of Valve Supervision Written Record Post-indicator valves every 7 days Sectional control valves every 7 days Valves in the suction and every 7 days discharge piping of the fire pumps Valves controlling water every 30 days supply to aqueous fire suppression or manual hose station standpipe systems

• Sealing valves so that the valve cannot be operated without breaking seals.

Seals should be of a character to prevent injury in handling and prevent reassembly when broken.

• Electrically in accordance with NFPA 26 with electrical supervisory signals annunciated in the control area.

LGS Response Control and sectional valves in the fire protection water system are either electrically supervised or administratively controlled. The features that provide the electrical super-vision or administrative control, and also the inspection program that will be implemented for the two categories of valves, are described below. The valves that will be electrically supervised are those valves that control the water supply to fixed (water) sup-pression systems and the valves that control the water supply to standpipe systems and to groups of manual hose stations. These valves are shown in FPER Figure B-2. The electrically supervised valves are provided with normally P-70(b)/13 -19/1-

D, RAFT h open contacts that close in the event of valve movement. The L electrical supervision signal is indicated at fire protection i alarm panel 00C926, located near the entrance to the control room, and is annunciated inside the control room. Each of ~ the electrically supervised valves is inspected monthly, with written record, in order to verify the position of the valve. l The valves that will be administratively controlled are the { valves in the suction and discharge of the fire pumps, plus the post indicator valves in the yard area that provide for sectional control of the fire main loop and control of the fire water headers branching into the various structures. These valves are padlocked in the open position so that they cannot be operated without breaking the padlocks. Padlocks are of a frangible design. Each of the administratively controlled valves is inspected weekly, with written record, in order to verify the position of the valve. Thus LGS design provides appropriate supervision of the fire protection system control and sectionalizing valves. References 1. Branch Technical Position ASB 9.5-1, Appendix A, Section E.2. 2. Branch Technical Position CMEB 9.5-1, Section C.6.c. P-70(b)/13 -19/2-E C T [I$ E " 3 5 @ 7 " E 7 D f ? * " 7 " "

DR WT NRC Open Item #20: Branch Connections for Standpipes The sprinkler systems and manual hose station standpipe con-nections to the looped interior fire protection headers are arranged and valved such that in many cases, branch con-nections to the headers are provided with approved shutoff valves so that groups of sprinkler systems and/or manual isolated without interrupting the hose stations can be supply to other sprinkler systems and manual hose connected to the same header. of BTP This does not meet our guidelines in Section C.6.c(1) CMEB 9.5-1 because a single break in the water supply piping could impair both the primary and backup fire suppression systems. CMEB Position We will require the applicant to modify the design to prevent a single break or malfunction from incapacitating multiple automatic protection systems and standpipes hose systems. LGS Response The standpipes supplying the sprinkler system and the manual hose station were designed to NFPA piping requirements, where the materials and construction are the same as for Power Piping Code, ANSI B31.1. The standpipes were seismically analyzed for safe shutdown earthquake (SSE) loads to ensure l piping integrity, and are considered an extension of the l-yard main system. Each sprinkler and manual hose station supplied from the main standpipe are equipped with an approved shutoff valve and waterflow alarm. Safety related in the vicinity of the sprinkler water fire pro-equipment tection is either protected or will not be damaged by sprinkler water discharge. References l. Branch Technical Position ASB, Appendix A, 9.5-1, Section E.2.b & E.3 Branch Technical Position CMEB 9.5-1, Section C.6.c.1 2. -20/1-P-70(b)/14

.]qw ;.. ri=::ar,z g ,f j i NRC Open Item #21: Hose Station Coverage Manual hose stations are not located throughout the plant in accordance with NFP 14. CMEB Position We will require the applicant to provide sufficient hose stations to enable the fire brigade to reach any location that culd present a fire exposure hazard to safety related equipment with at least one effective hose stream. LGS Response Clarification on the provisions for hose stations in the areas of concern is provided below: 1. Reactor Enclosure Elevation 177ft:- No manual hose stations are provided a. at this elevation for fire zones 31 thru 40.

However, g

I in the event hose coverage is required, the hose I stations at elevation 201 feet can be used for this purpose. Additional lengths of 1-1/2 inch hose are stored in the vicinity of the hose stations at elev-ation 201 ft. for extension down to elevation 177 ft. b. Elevation 313 ft; Fira Zones 49 and 72:- Hose stations lHR-207 in Unit 1 and 2HR-207 in Unit 2 are capable

(

of providing coverage of fire zones 49 and 72. An additional 50-foot length of hose is stored in the i vicinity of each of the above hose stations to provide the necessary hose reach. c. Elevation 331 ft. - Manual hose stations wil?. be pro-vided on El. 331 ft. in fire zones 50A and 73A. 2. Radwaste Building Elevation 195 f t; Fire zones 139A through H:- Table A-1 of the FPER indicates that no suppression capability is available for these areas. This is incorrect. The hoses from manual hose stations OHR-303 and OHR-304 (located in fire zone ll8B) can be used for fire sup-pression in fire zone 119. Table A-1 will be revised to show manual suppression for this area. 3. Service Water Pipe Tunnel Elevation 198ft; Fire zone 75: - Table A-1 of the FPER indicates that manual hose stations are available for P-70(b)/15 -21/1-K 4

i DRAFT use in this area. The hoses from lHR-240 and 2HR-240 (located in fire zones 42 and 65) can be used for fire suppression in fire zone 75. An additional 50 foot length of hose is stored in the vicinity of each of the above hose stations to provide the necessary hose reach. Thus adequate manual suppression is provided as there are no in-situ combustibles in this tunnel. 4. Turbine Building a) Elevation 200 ft; Fire zone 88A:- The condenser and feedwater areas are protected by a wet pipe sprinkler system and do not present a fire exposure hazard to safety-related equipment. Therefore manual hose cove rage is not required for fire zone 88A. b) Elevation 217 ft. Fire zone 91:- The air ejector and steam packing exhauster compartment does not present a fire exposure hazard to safety-related equipment. 3 Therefore, manual hose coverage is not required for fire zone 91. c) Elevation 200 ft; Fire zone 101A:- Same response as given in 4.b above. d. Elevation 217 ft: Fire zone 104A:- Same response as given in 4.b above. 5. Diesel Generator Enclosure (' Fire zones 79 through 86:- The diesel generator cells The fire are protected by pre-action sprinkler systems. hose required is met by the fire hydrants Nos. 8 and 9, with two hoses available from each hydrant. References 1. Branch Technical Position ASB 9.5-1, Appendix A, Sections E.2.g & E.3 l 2. Branch Technical Position CMEB 9.5-1, Section C.6.c.4 l U P-70(b)/15 -21/2-

^' DRAFT NRC Open Item #22: 3" Diameter Standpipes 3-inch piping is used to serve up to two hose stations and does not meet NRC guidelines in Section C.6.c(4 ) of BTP CMEB 9.5-1. CMEB Position We will require the applicant to either provide 4" diameter piping or verify by calculation that the fire protection system can provide the flow and pressures required in NFPA 14 for these standpipe locations, considering the operation of two hose stations simultaneously with the largest water demand flowing from any automatic suppression systems in the vicinity of the hose stations. l LGS Response l Standpipes serving hose stations and sprinkler systems are capable of delivering 250 gpm of which 100 gpm is supplied to the hose stations at not less than 65 psig at the highest hose stations while the sprinkler system is operating. The largest single sprinkler demand in the Reactor Building is 140 gpm. The design and installation of the fire protection standpipes and hose stations is in accordance with NFPA-14. References 1. Branch Technical Position ASB 9.5-1, Appendix A, Section E.3.d 2. Branch Technical Position CMEB 9.5-1, Section C.6.c.4 i P-70(b)/14 -22/1-I

DRAFT NRC Open Item #23: Seismic Support of Standpipes Standpipe system piping supply hose stations protecting safe shutdown equipment are not seismically supported or designed. This does not meet our guidelines in Section C.6.c(4) of BTP CMEB 9.5-1. CMEB Position f We require the applicant to provide seismically supported piping. LGS Response The standpipe system piping supply to hose stations protecting safe shutdown equipment has been evaluated to verify piping integrity under seismic loading and was found to be acceptable. This meets the guidelines of Section C.6.c(4) of BTP CMEB 9.5-1. References b .? 1. Branch Technical Position CMEB 9.5-1, Appendix A, Section E.3(d) 2. Branch Technical Position ASB 9.5-1, Section C.6.c(4) 4 i I

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P-60(b)/ll -23/1-

l DRMT l NRC Open Item #24: PGCC Fire Protection Specifications The applicant has not provided sufficient information to verify compliance with the fire protection specifications contained in the NEDO-10466 Report, Revision 2, dated March 1978, which was previously approved by us, and is the basis for our acceptance of the PGCC system. We will require the applicant to verify that the fire protection for the PGCC meets these specifications. LGS Response The following table provides a comparison of NEDO-10466-A (or Revision 2) commitments versus the actual plant design. It will be seen that either the NEDO-10466 commitments or an equivalent design of at least the same integrity is incorporated. References g 1. Branch Technical Position ASB 9.5-1, Appendix A, Section E.4 2. Branch Technical Position CMEB 9.5-1, Section C.6.d 3. GE Report NEDO-10466, Revision 2 4. Bechtel Specification 8031-M-49 5. GE Drawings 262A6019, 262A6020, & lH707182 6. Bech tel Vendor Prints 8031-M-1-H12-U7 87-C-2-2,-C-3-2,-C-5-2. W P-60(b)/5 -24/1-

DRAFT 1' i NRC OPEN ITEM # 24: COMPARISON TABLE (is A. ts ) g i' NEDO 10446-A FIRE PROTECTION /*/ 4 e * ** m Ay k REOUIREMENTS y f SkCTIO Ih: SCRIP yn f/w c*" ~J spUIVALENT ) DhTAILS OFl @MPLIANCEl [ 3.3.2.3 f. The floor plates are covered at site Yes Floor tile material will by a customer selected vinyl-asbestos be Armstrong Excelon f floor tile designed for commercial Imperial ModernV# 51856 g' (V/47 use. Of utmost importance is the pe r SS-T-312 { fire retardent properties of the 1 _///c J material. The tile must meet the t j following requirements as a minimum: l 1 i Flame spread index (max) 2.0 y'es p., u4 532 t<d / 11 Complies with HUD/ FHA UM69 N,4 Ap/,c.4/,

1. l iii Conforms to FED Spec.

T-312 TE3 /*r i SS i 3.3.2.4 Fire Detect ion Equipment Detection is accomplished through two Yes Vendor drawings provide a thermal detectors... details 1 l b and one product of combustion detector... Yes -ditto-c ... mounted in each of the floor section Yes -ditto-longi tudinal raceways (Fig. 3 9.). d The thermal detector is 5 inches in Equivalent 4 5/8" diamter by 2" deep j diameter and 1 inch deep... l e ...and the product of combustion Equivalent 6 5/8" diameter by 2 3/4" I detector is 6 inches in diameter and deep s j 3 inches deep. i f Both are mounted on 4-inch octagonal Yes GE drawing provides detail boxes. agreement i P-62(a)/4 r jj - \\ b NRC OPEN ITEM # 24: COMPARISON TABLE NEDO 10446-A FIRE PROTECTION /***Y REQUIREMENTS (COMpCIANCE ON LIMERICK) _ g / w ce2* 3 OR h u u ener W ShCTION) DCSCRIPTION) UIVALENT l QETAILS OF/dOMPLIANCE) l E 3.3.2.4. g Products of combustion detectors respond Yes ($fa.tector isYEdwards. De to 0.006 grams of product per cubic nufacturedJG) Response is t foot of air. standard in the trade. i The thermal detectors respond to a tempe-Yes 140*F temperature setting rature rate of rise of 15'F per minute is used. (minimum) or ambient temperature of 140*F (minimum). j Therefore the POCs (product of combustion Yes Statement is correct detectors) are usually used as pre-ala rms... k ...and the thermal detectors for suppres-Yes -ditto-sant initiation. 1 There are terminal boards on the rear Yes GE drawings confirm use of each of the detectors... m ...and the operational functions are Yes -ditto-wired out with 18 gauge insulated _ wire... n ...inside flexible steel conduit to Yes -ditto-o ... contact points in the terminal cabinet Equivalent Floor section U750 0751 & 3 (Figure 3.9). U786 have nok terminal d cabinets but do not have s terminal box in the floor section. p These contact points in the termination Equivalent -ditto-cabinet are the electrical interface with the customed/AE wiring, gg Yi P-62(a)/4 DRAFT 1 NRC OPEN ITEM # 24: COMPARISON TABLE [ -< M NEDO 10446-A FIRE PROTECTION hre j g REQUIREMENTS S, COMPLIANCE ON LIMERIC glower case q OR M caf_e_;L S(ECTION ) I$_SCRIPTIOND I[5 TAILS OF M_PLIA M l E UIVALENT 3.3.2.4. It is a requirement on the customer / Yes GE arrangement drawings AE to connect the detectors in a give zoned area require- " zoned" configuration by floor section. ments guidance for final design 3.3.2.5 a The fire suppression equipment is also Equivaglent All floor sections are y illustrated in Figure 3.9. along with covered by halon injection ( the dection in the floor section. b This equipment consists of four nozzles Yes Field walkdown confirms attached to manifold... the NEDO commitment c ... located at the termination cabinet Yes -ditto-end of the floor section. d Each nozzle is designed to flood each Yes -ditto-longitudinal raceway e The suppresant has a low toxicityjis Yes Halon 1301 will be used electrically non-conductive, leaves no 10 compliance with NFPA residue ar,J does not react with g2A @vrequirements. materials in the control room. f The Halon suppressant and its accessory Yes Field walkdown confirms equipment... connects at the piping the NEDO commitment interf ace. s g If fire stops create isolated longitudi-Yes Field review confirms nal raceway sections provisions will the NEDO commitment S j made so that suppresant material will reach these areas. P-62(a)/4 DRAFT L NRC OPEN ITEM # 24: COMPARISON TABLE t l NEDO 10446-A FIRE PROTECTION l REQUIREMENTS Y S, COMPLIANCE ON LIMERICK fomer e ne q og h mer e*w 1 CTION D)SCRIPTION3 UIVALEN DSTAILS OF[CT)MPLIANCE) Fire Stops 3.3.2.6. a Semi-permanent fire stops are located Yes Installation is incom-at the ends of each longitudinal plete. Fire stops will raceway... be installed per NEDO l 10446 requirements. b ...at the ends of the eight lateral Yes -ditto-raceways for panel-to-panel cabling (4 raceways at each end of floor section)... i c ... a nd in those lateral raceways Yes -ditto-carrying cable... d ...and are located directly under the Yes -ditto-structural I beams that support the panels. e The fire stops consist of a refractory Equivalent G.E. is in the process of material (such as sand)... specifying otherp than sand, etc. oc. gs of f ... poured over the cables to fill the Equivalent G.E4 i in e interslices... sp of y er than

shnd, tc. - t// o -

g ...then covered by a low visccstisite Equivalent G.A. s nt pr es f 5 (approximately 16 poise) fire retardant @'c 1 t n silicone rubber... san e tc. - dr //a h ...such as GE RTV 6428 two component Equivalent G. E'. /i s nt pro ss f liquid compound. spe' i i th tW tc. _ g;ffy s a P-62(a)/4 -

DRAET ~ ~ NRC OPEN ITEM # 24: COMPARISON TABLE D NEDO 10446-A FIRE PROTECTION REQUIREMENTS Yk COMPLIANCE ON LIMERICK -_. rfope, case Q l OR l*" ** '2 - SkCTIOi~P Fj?UIVALENT l ETAILS OF h MPLIANCE) M ~, 3.3.2.6 i This combination of materials provides Yes fire stops and a seal for limiting a air flow. Figure 3.9 a Manifold and nozzle arrangement and Equivalent see section 3.2.2.5. a, location response b product at combustion detector Equivalent See section 3.3.2.4. asb A quantity and location response 5 c rate of rise temperature sensors Equivalent See sectio 3.3.2.4 asb j quantity and location responser Se is ovi ed 2 [n cabinets containing more than Equivalent p$ par ti 4.2.1.6 a f la __u d 5 one division of a critical system (i.e., RPS, ESP), the divisionjare f/e[- - M - fee 4 2 I.(7 separated by a 3/18A inch thick O d a [ y,- reep-Ah* steel fire barrier ,. N b Conduit and junction boxes are used Yes S ati is rov' d within the termination eqbinets for R gu o i 1.7 s additional separation (p'.e., RPS rod A//o - group power and neutral conductors). P-62(b)/4

~ DRAFT ~ NRC OPE'N ITEM # 24: COMPARISON TABLE ~ NEDO 10446-A FIRE PROTECTION REQUIREMENTS ES, COMPLIANCE ON LIMERICK OR louer caer 2 18k, TION) D):SCRI PTION'( PdUIVALENTJ IETAILS OF1CNMPLI ANCE) c Although there may be more than one Equivalent Separation is provided per 4t, g,f,4 division in cabinet, there is never Regula tory Guide 1.7 5, fee I more than one division in any one bay. 4.2. M. d. werse * & - d In the floor sections, separation is Yes Field walkdown confirms the achieved by four longitudinal metal-NEDO commitment. cove red raceways (see Figure 4-1) e Each pair of parallel raceways is separated by a steel fire barrier Yes -ditto-f Conduit is also used within the race-Yes -ditto-ways for additional cable separation where necessary (i.e., RPS contactor conductors to ESS logic cabinets) g Metal barrier separation practices Equivalent Flexible conduit is sometiC are used for the crossing of a raceway used. of one division over a raceway of another division. [-ELgyP h In the crossover raceway locations Yes Field walkdown confirms the 1 within the floor section, fire is NEDO commitment prevented from occuring by sealing both ends of the lateral raceway where the cable runs from a longitudinal t to a lateral and where it enters the bottom of the panel. This enclosed area limits the oxygen and eliminates air flow, thus preventing a fire from starting. P-62(a)/4 LU ^ NRC OPEN ITEM # 24: COMPARISON TABLE 4 NEDO 10446-A FIRE PROTECTION -- COMPLIANCE ON LIMERICK REQUIREMENTS Y S, f OR /* * *" 7 S$CTION) /ooerc*M %. DESCRIPTION) UIVALENT MTAILS OF 5([)MPLTNNCE) l I =- ~ s4.2./.6 i As mentioned in the above paragraph, Yes Field walkdown confinns the lateral raceways are blocked-off the NEDO commitment or sealed at specific locations to control fire propagation and air flow. j longitudinal raceways are also blocked-Yes -ditto-off at the ends for the same reason. These fire stops are easy to install, maintain and repair. k The interslices between the cables Equivalent See section 3.2.2.6.e f s g y and the air space above the cables to responses the bottom of the crossover raceway are filled with a refractory material. e/, //o 1 A two-part silicone rubber RTV Yes See 500ti^= ?_2.2.6.0 fi; c compound is poured over the refractory material to form a cap and a seal. Y $h%/k@y o On each of the critical systems panels Yes (i.e., RPS, ESS and NSSS) a steel fire I barrier, or equivalent,/s installed 5 from the bottom of the floor section I (center area) to the bottom of the ends of each control panel. p To ensure that sneak common mode Yes Final design will comply with 5 failures do not occur, the raceway NEDO requirement. openings at the bottom of the panels are sealed with a semi permanent firestop consisting of a layer of refractory material (such as sand) over the cables and a cap of silicone rubber. P-62(a)/4 A h * *' k ( DR JT i NRC OPEN ITEM # 24: COMPARISON TABLE %s ?k

• ~'

f NEDO 10446-A FIRE PROTECTION "g REQUIREMENTS S, COMPLIANCE ON' LIMERICK OR lower UJ'*7 _ i I$:SCRIPTION) UIVALENT_ I$ TAILS OF(hMPLIANCE ) I S$CTIONJ i 4.2.2 Fire Protection Design I a Since the floor section is simply a Yes Field walkdown confirms { steel structure containing control the NEDO commitment room cables the assessment of com-I bustible materials can be easily made and controlled and therefore can De concluded that the combustible material is minimized and limited 4 to cable insulation. i j b The floor sections are designed to Yes -ditto-limit the flow of air and exhaust i gases by the sealing of all penetra-l tions with semi-permanent fire stops. I c Thermal and smoke defectors are Yes Vendor drawings provide located in each longitudinal duct. the details. 1 d The alarm is zoned to indicate the Yes See response to 3.3.2.4. y ] floor section requiring attention e And finally, accessibility to the Yes Field walkdown confirms potential fire area is easily the NEDO commitment provided for manual suppression. { f Tefzel insulated cables are an Equivalent Limerick uses Raychem additional defense-in-depth factor Firetrol and Rockbestos s along with the fixed detection, Firewall III fixed manual suppression and portable ext inguishers to locally suppress fires. l J P-62(a)/4 DRAFT ^ a. NRC OPEN ITEM # 24: CDMPARISON TABLE g,o rn m / NEDO 10446-A FIRE PicmLTION REQUIREMEfRS CDMPLIANCE ON LIMERICK ' Yes, No or Section Description Equivalent Details of Cortpliance 8 g[ Under " Fire Prevention", one of the objectives is Yes 4.2.2 " Control Ignition Energy" (lieut Source). In the PGCC floor sections, the only c&stible material in the design is the cable insulation and the only ignition source is an electrical overload. i f )(' Another objective in preventing ignition is " Control Equivalent See response to 4.2.2.f. / Thermal Energy Transfer". The cable insulation is TEFZEL which is a high tenperature jacket material. ][ Under " Manage the Fire", consideration is given to " Control by Construction". The support menbers as g well as all duct covers and floor plates are made of steel. l s.J[ Steel barriers between redundant Class IE systems Yes Darriers between panels are are a minimum thickness of 3/16 inch steel. 3/16 inch steel.

P-62(a)/4

( DRAFT ~ IRC OPEN ITEM # 24: (DMPARISON TARIE l NEDO 10446-A FIRE PROTECTION REQUIREMENTS COMPLIANCE ON LIPERICK Yes, No or Section Description Equivalent Details of Conpliance [g Penetrations, passages or openings between panels Equivalent See responses to 3.2.2.6 / 4.2.2 (cont'd) and PGCC under-floor areas are sealed closed with a d f e through 'h*. A semi-permanent fire stop consisting of a base mound of sand covered by an approximate 1/2 inch layer of silicone zubter, thus not only limiting fire prcpogation but also providing a limited anount of oxygen. gl 'Ihe second factor is " Control Canbusion". 'Ihe floor Yes Field walkdown confirms 4 sections are designed to eliminate the inflow of air the NEDo comnitment. in the normal configuration. In this case, any fire is difficult to start and is suppressed innediately. Exhaust of conbustion gases is as limited as inflow and sustained burning in the ficar section is prevented. )t'M " Suppress the Fire" is acconplished by detecting the Yes Installation is inconplete. fire with thermal and smoke detectors in each longi-Halon injection will be tudinal duct and suppressing the fire with a fixed, autanatic. manual llalon 1301 suppression system backed up by customer supplied portable extinguishers. 71 H. In " Managing the Exposed", one objective is to " Limit Yes Field walkdown confirms the 6 the Exposed". 'Ihe redundant Class lE systems are NElb ccmnitment, rcuted in separate chets and are usually 3 feet apart. o pf Control equipment power is also routed in conduit to Yes Field walkdown confirms the further control overload conditions. NEDo comiitment. s [ In addition to limiting the fire to one division the Yes Field walkdown confirms size of the ducts also limit the exposed since only a the FEDO ccmnitment. maximum of fifty to sixty, 19 conductor cables are rcuted in the ducts. P-62(a)/4

DRAFi MIC OPEN ITEM # 24: CDMPARISON TABLE l NEDO 10446-A FIRE PRGIECTION RBOUIREMENTS CDMPLIANCE ON LIMERICK Yes, No or Section Description Equivalent Details of Conpliance h "onpletely enclosed and thus there is no concern for Defend in Place" is achieved since each duct is Yes Floor section longitudinal 4.2.2 c and lateral ducts are (cont'd) those ducts not involved in the original fire, cmpletely enclosed. t[ ne lack of conbustible materials, the limited inflow Yes Statement is correct noting of oxygen, the flame retardent prcperties of TEFZEL, that TEFZEL is not used on the use of fire stops, the use of zoned detectors and Limerick but ph equivalent, g the accessibility to exposed areas utilizing portable d-extinguishers formulates a sound design basis for fire protection. See response to 4.2.2.[m 5[ As a result of NRC requirements for fire protection Yes We features a fixed manually actuated suppression system is also included. 4.2.4.2 4.2.4 Regulatory Guide 1.75 Design Cappliance 4.2.4.2 %e raectrical systems mounted on PGCC are Yes Separation is in accordance designed using the philosophy of " associated circuits" with Regulatory Guide 1.75 and the PGCC cables also adhere to this requirement. as discussed in FSAR section % e cables that contain associated circuits meet the 8.1.6.1.14. same cable derating, enviromental qualification, flame retardance, splicing restrictions and raceway fill as Class lE cables te_rially they are the same cables. /MD 4.2.5.6 a 4.2.5 IEEE 384-1974 Design Canpliance s 4.2.5.6 %e termination cabinets are simular in Yes Field walkdown confirms the construction to control roan panels. They do not NEDO ccanitment. contain any of the electronic equipnent found in the panels and only include termination devices and cables. %ese materials are flame retardant. P-62(a)/4

PRC OPEN ITEM # 24: COMPARISON TARIE i l NEDO 10446-A FIRE PROITJCTION REQUIREMENTS CDMPLIANCE ON LIFERICK Yes, No or Section Description Equivalent Details of Conpliance 4.2.5.6 b 'Ihe actual separation in the cabinets is much more Equivalent See respciise to 4.2.4.2. (cont'd) than the 6 inches allowed in Section 4.1.5.6. c Redundant Class lE systans are routed in separate Equivalent See respcaise to 4.2.4.2. bays of a cabinet. Redundant Class IE systems do not appear in the same bay. d The barrier separating the bays is a 3/16 inch Yes Field walkdown confirms the steel plate. NEDO comnitment, e In addition to the steel barrier the routing of the Yes Field walkdown confirms the wiring inside the cabinet is also done to maximize NEDO caenitment. the distance between redundant Class lE sysems. h An air space of approximately 1 inch exists between Equivalent Separation is justified by the wiring and the barrier in this case to prevent test. See FSAR Section barrier surface contact. 8.1.6.1.14. i i 4.2.6.1 4.2.6 Regulatory Guide 1.120 Design Ccynpliance The only exception to the guidelines has to do with Yes Field walkdown confirms the fire stop spacing. A minimum of 27 feet instead of NEDO cmmitment. 20 feet is used to close up with the ends of the longitudinal wireway. 4.2.6.2 a 4.2.6.2 '1he only work within PGCC equipment involving No Stud welding is performed for j ignition sources is the task of welding the termination mounting separation cans. l cabinets and floor sections to the enbedded structural Grinding is also performed. j s members in the building floor. Precautionary warnings l 6 are noted in the GE installation instructions for Yes Review of G.E. Specification f PGCC (See reference 23). 22A4185 confirms NEDO comnit-ment. b'C f Fire Ei s during this operation.f blankets are required to be placed over Yes Field confirms the the c NEDO cmunitment. - P-62(a)/4

cbRAFT (q 1 a ~ NRC OPEN ITEM # 24: CDMPARISON TABIE NEDO 10446-A FIRE PIUTECTION REQUIRENENTS (DMPLIANCE ON LIPERICK l Yes, No or Section Description Equivalent Details of Conpliance 4.2.6.3 4.2.6.3 h e cable insulation materials used in the Yes All wiring has been tested PGCC performed well in both the IEEE 383 (Reference and passed IEEE 383 require-

5) and PGCC Fire Barrier Tests (Appendix F).

h is is ments. the only application of plastic materials except for the terminal boards in the cabinets. A suitable non-conbustible terminal board is not available. 4.2.6.4 a 4.2.6.4 As stated previously, all cable raceways Yes Field walkdown confirms the are metal and form an integral part cf the steel NEDO ccmnitment. floor section. thh b %e flexible conduit is only used for prcwiding Yes Flex conduit is used for d a a ground path and not for fire barrier separation. electrical separation. c ne flexible conduit is only routed within a raceway Yes which in itself is a rigid, steel conduit. 4.2.6.5 a 4.2.6.5 he fire stops located in the floor Yes GE will carry out a walkdown sections are rated for more than 30 minutes. to verify ecmpliance after s all cables are pulled, b It is noted that each fire stop includes at least Yes GE will carry out a walkdown 3 inches of refractory material. to verify conpliance after all cables are pulled. P-62(a)/4

U -m' ~ N PRC CPEN ITEM # 24: ODMPARISON TABE g 1 NEDO 10446-A FIRE PROTECTION REQUIREMENTS COMPLIANCE ON LIPEHICK Yes, No i or i Section Description Equivalent Details of Capliance A spacing of 27 feet for longitudinal raceway fire Yes GE will carry out a walkdown 4.2.6.5 c i (cont'd) stops is more than adequate for the POCC design. to verify compliance after - all cables are pulled. 4.2.6.6 a 4.2.6.6 Since the cables are routed in the floor Yes Field walkdown confirms the sections with the connectors located in the panels NEDO cmunitment. and termination cabinets, the connectors would not be exposed to fire suppression water. b 'Ihe cable jacket insulation is either Tefzel, Equivalent Limerick also uses Raychem Raychem Flamtrol or GE Geoprene, which are Firetrol K. Rockbestos Firewall III. waterproof materials. Wetting down with fire suppression water, therefore, Yes Field walkdown confirms the c will not cause an electrical fault. NEDO comitment. 4.2.6.8 a 4.2.6.8 'Ihe fire detection system meets the Yes The in-floor detector cir-requirenents of a Class A system defined in NFPA72D cuitry is electrically (Reference 15) and Class 1 circuits defined in NFPA70 supervised. (Reference 21). b 'Ihe selection and installation also conplies with Yes NFPA72E. k P-62(a)/4

DN ~. m MIC CPEN I'ITM # 24: COMPARISON BBLE NEDO 10446-A FIRE PICITLTION REQUIREMENTS ODMPLIANCE ON LIPERICK Yes, No or Section Description Ekluivalent Details of Cmpliance %e detectors are wired to a contact in the termi-Equivalent See section 3.3.2.4.o 4.2.6.8 c (cont'd) nation cabinet associated with each floor section. response. d De custcmer/AE continues the circuit to a fire Yes Panel # wiring indicates connection require-protection panel which is wired up to give audible l and visual alarms that are zoned to the individual ments are l floor sections. Primary and secondary power is supplied to the Equivalent %e fire detection systen e detection system. D e primary system is 120VAC and power backup is fran the the secondary system is 24VDC. diesel generators. 4.2.6.9 a 4.2.6.9 De primary system is a fixed manual Halon Yes Halon will flood all floor 1301 suppression system which is designed to flood sections simultaneously. each individual floor section. b 2e backup system is portable extirguishers (or other Equivalent Located in adjacent areas. similar means selected by the custmer) located in the control roon. Persom trained in fire lighting can reach the fire Yes Field walkdown confirms the c area by quickly removing the floor plates and applying NEDO conmitment. the extinguishant. d Since these are two ccmpletely independent methods, Yes Field walkdown con *irms the a failure in the primary system will not affect the NEDO cemitment. operation of the backup system. s e %e PGCC Halon 1301 Fire Suppression System has been Yes Design is inconplete at this time but will conform to the designed for total flooding of the protected volume in accordance with NFPA Standard 12A(1973). NEDO comitment. 4.2.6.10 a 4.2.6.10 All PGCC cables that enter the control rocm Yes Field walkdown confirms the NEDO commitment. terminate in the control roan panels. P-62(a)/4

d .$N @ j_ .] DRAFT tRC OPEN ITEM # 24: CDMPARISCN TABM NEDO 10446-A FIRE PIUTECTICN REQUIREMENTS (DMPLIANCE ON LIPERICK Yes, No or Section Description Equivalent Details of Coupliance' l 4.2.6.10 b 'Ihe floor section ducts provide a network of steel Yes Field walkdown confirms the (cont'd) conduit for Class IE cables. NEDO comitment. A piping manifold and nozzles for a fixed manual Yes Field walkdown confirms the c Halon 1301 fire suppression system (as required by NEDO counitment. the NRC for the PGCC floor sections) is provided for suppressant injection. a . [ ables routed in the floor section should be Tefzel 5.1.8 Equivalent Limerick uses Raychem Firetrol or equivalent insulated to minimize smoke production... and Rockbestos Firewall III. ...J[ ables aided to the PGCC by the customer /AE must be b Equivalent Limerick uses Raychem Firetrol Tefzel or an equivalent. and Rockbestos Firewall III. 5.1.9 a 'Ihermal and snoke detector circuits for each panel Equivalent See section 3.3.2.4.o response module are wired in conduit to contact points in the termination cabinet. ../iththerequirementtoconnectthedetectorsina b Yes " zoned" configuration for each floor section. See section 3.3.2.4.q response 'Ihe wiring to a central alarm in the control ruan... Yes See section 3.3.2.4.q response e 6.2.1.1 a 'Ihermal and smoke detectors are located in the floor Yes Vendor drawings confirm section as shown in Figure 3.9... equivalency. See response to C 3.3.2.4.a,b and c. b Additional smoke detectors are located in the termination cabinet in Bays A and D. See response to NRC Open Item s

1. 28.

Detector contacts are available for the custaner/AE Yes Field walkdown confirms the c to use as an alarm or suppressant initiation. NEDO comitment. i P-62(a)/4 i

l DRAFT -,______.y-_-.. ~ PRC (PEN ITEM # 24: CDMPARISON TABLE 4 NEDO 10446-A FIRE PROTOCTION REQUIREMEffrS CDMPLIANCE ON LIPERICK Yes, No or Section Description Equivalent Details of Cmpliance 6.2.2.1 The suppression equipment in this plant consist of Yes Field walkdown confirm the piping and nozzles in the floor section which allows NEDO cannitent. the suppressant to be supplied at the piping interface. 4 'Ihis is the sane as BWR16 Figure 3-9. Errata and Addenda No. 1 of June 1978 3.3.1 c 'Ihe T/C encimures are made of 3/16 inch thick steel Yes Field walkdown confirms the plate welded to 3/8 inch steel corner angles. NEDO ccmnitment. d Each T/C is divided into four bays. Yes Field walkdown confirms the NEDO ca mitment. I e Swing barriers are used between Days A and B and Yes When required for separation, between Bays C and D to prwide better access for wiring. k Products of ccabustion detectors are located at the No See response to IRC Open top of each termination cabinet which contain Item #28. redundant safety cable divisions to sense snoke generated in any bay. 1 'Ihese detectors prcuide an alarm signal for locating No See response to MtC Open a fire within the termination cabinet. Item #28. m 'Ihe alarm signal...is to be connected to the main Yes Design is incmplete at this control roan fire protection annunciator panel... time but will conform to C l NEDO ccmnitment. l @nned) l ...)dnless the cabinets are located in a "maeredfarea" N/A Not applicable. 4 n ...where local alarm is sufficient. i P-62(a)/4 l I i

@C (PEN ITEM f 24: CDMPARISON TABIE NEDO lO446-A FIRE PROTECTION RBOUIREMENTS COMPLIANCE m LIPERICK Yes, No or Section Description Equivalent Details of Capliance 5.1.9 d These detector alarm circuits may also provide Yes hermal detectors will initiation for fire suppression as necessary, initiate halon release. ...Tefzel insu. lated cable based plant 5 h fire N/A Not gplicable. MA-e j suppression system shall be manually initiated. f... kn-Tefzel insulated cable based plant 5 M Yes eAx f fire suppression system shall be automatically initiated. 5.2.3 h %e suppresr; ion piping interface is a 3/4 tube - 3/4 Yes Field walkdown confirms the pipe female connector. h is fitting is located in NEDO capitment. the bottom of the floor section near the termination i cabinet. i ne flow rate for the gas shall be enough to achieve Yes Flow & volume requirements y a 20% concentration... will ensure the NEDO cavnit-nents are mt. sj ...and a 20 minute holding time in the floor sections. Yes Flow & volune requirepents will ensure the NEDO cmenit-ments are met, k Installation and testing of the suppression system Yes NFPA Standard 12A requirements shall be in accordance with NFPA Standard 12A. will be followed. -IO-P-62(a)/4

4I f-M l

.3 DRAFT M C OPEN ITEM # 24

CDMPARISON TABIE NEDO 10446-A FIRE PICIECTION REQUIREMEfRS (DMPLIANCE ON LIERICK Yes, No or Section Description Equivalent Details of Cortpliance 5.2.5 a ... installation procedures are defined in the PGCC Yes Review of CE Specification its talla tion ins truct ions... includes... f i re stop 22A4185 indicates rucwheres installation and checkout (Reference 23). are provided. b These instructions will also require that doors on Yes Terminal cabinets are not termination cabinets remain unlocked for quick provided with locks. access in case of fire. i P-62(a)/4 bRAVY NRC Open Item #25: Separation of Safety Related Components in Secondary Containment The separation of redundant cables does not meet our guidelines in Section C.7.a(1)(f) of BTP CMEB 9.5-1. This was previously discussed in Section C.5.e(2). CMEB Position We require the applicant to provide protection of cable trays in accordance with Section C.7.a.l(f) of BTP CMEB 9.5-1. LGS Response Refer to the response to open Item #14 for a discussion of compliance with Section C.7.a(1)(f) of BTP CMEB 9.5-1 concerning line-type heat detection. In addition, as required by Section C.5.e(2) of BTP CMEB 9.5-1, S all areas are accessible for manual firefighting. References 1. Branch Technical Position CMEB 9.5-1, Appendix A, Section D.3. 2. Branch Technical Position CMEB 9.5-1, Section C.5.e(2) ,s. P-60(b)/8 -25/1-

~ paAi#T NRC Open Item 426: Control Room Complex The applicant states that the control room complex is separated from all other areas of the plant by 3-hour-rated assemblies. Peripheral rooms in the control room complex consist of offices. Each room is separated from the control room by 1-hour-fire-rated barriers. Smoke detectors that alarm and annunciate in the control room panel are provided in each room. However, the applicant has not provided sufficient details of the control room complex for us to independently verify com-pliance with our guidelines. CMEB Position We require the applicant to provide details showing compliance with Section C.7.b of BTP CMEB 9.5-1 of our guidelines. LGS Response Elevation 269'-0" of the control structure consists of the main control room and peripheral rooms, all contained within a 3-hr fire rated envelope, separating this portion of the structure from the rest of the plant. All interior partitions are 1-hr fire rated, with exception of the shif t supervisor's of fice, which has a glazed opening to enable observation of control room activities. All finishes and components in the area have flame spread, fuel contribution, and smoke developed ratings of 25 or less as determined in accordance with ASTM E-84. References 1. Branch Technical Position CMEB 9.5-1, Appendix A, Section F.2 2. Branch Technical Position CMEB 9.5.1, Section C.7.b P-60(b)/10 -26/1-

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+o DRAFT NRC Open Item #27: Suppression in Control Room Ceiling Automatic suppression systems are not provided for the electrical cabling routed through the space above the suspended ceiling in the control room. CMEB Position We will require the applicant to provide an automatic fire { suppression system above the control room ceiling to meet Section C.7.b of BTP CMEB 9.L-1. LGS Response Automatic suppression systems are not provided for the electri-cal cabling routed through the space above the suspended ceil-ing in the control room for the following reasons: 1. The fire loading above the suspended ceiling is very lightNo and gives an equivalent severity of only seven minutes. q transient combustibles are considered credible above the suspended ceiling since the only available access to this area is through use of a ladder. Catwalks or storage areas above the ceiling are not provided. 2. No power cables are routed through the space above the suspended ceiling. Only control and instrumentation cables are present, therefore the probability of a fire generated by an overload and f aulted cable is considered to be extremely low because this scenario would require i, the simultaneous failure of two overcurrent protective devices. All cables routed in the trays have 600V insulation and contain 125VDC or 120VAC circuits. The 277V lighting circuits are all routed in conduit and are the highest voltage circuits routed above the suspended ceiling. 3. No safety related cables are routed in the cable trays above the suspended ceiling. All safety related cables are routed in fully enclosed gutter or conduit. Since Limerick uses IEEE-383 qualified cable and completely i 4. meets the requirements of Regulatory Guide 1.75 concerning cable tray separation, any fire that does occur in a tray above the suspended ceiling will be limited to the tray in which the fire starts. This is based on the fire tests h conducted by Sandia as described in Ref. 3. Ten smoke detectors are located above the suspended ceiling 5. to provide prompt indication of a fire. P-70(b)/12 -27/1-l

• I DRAFT e

6. Two portable ladders will be located immediately outside the control room access doors to provide access to the area above the suspended ceiling for manual fire fighting. 7. The individual panels of the suspended ceiling are easily removable to provide access. 8. Portable fire extinguishers are located in the control ( room and CO2 hose reels are located immediately outside the control room access doors to provide a manual fire fighting capability. 9. The control room is continuously manned, therefore prompt response to any alarm indicating a fire above the suspended ceiling is assured. Based on the above, it is concluded that manual suppression provides an acceptable alternative to the installation of an automatic fire suppression system. ~ References 1. Branch Technical Position ASB 9.5-1, Appendix A, Section F.2 2. Branch Technical Position CMEB 9.5-1, Section C.7.b ' 3. NUREG/CR-2931 Burn Mode Analysis of Horizontal Cable Tray Fires. p by O P-70(b)/12 -27/2-t

D 93 AFT _nrn Open 7tems #?6 n "Tonization smoke detectors have been inFtalled in the Cr nt r0 } room, hat not inside the individaal cabinets and conscles withir. the control room. This does not meet our gaidelines in Section C.7 b of BTP CMEB 9.5-1. We regaire the applicant to provide cabinet detectors in accordance with Section C.7.b of BTP CMES 9.5-1." BTP CMEB 9.5-1, Section C.7.b: C.7.b. Control Room Complex Smoke detectors shoald be provided in the control room, cabinets, and consoles. If redandant safe shatdown egaipment is located in the same centrol room cabinet or console, additional fire protection neasares shoald be provided. Alarm and local :ndication shoald be provided in the control room. I45 Response: ~ The provision of smoke detoctors in the Control Room cabinets is h not needed to provide adequate protection of redandant systens from the / effects of internal panel firet, for the following reasons: 1. Because the panels are closed except when personnel are performing interior panel maintenance, an andetected expcsare fire originating in the panel is not a credible event. 2. The design basis fire for control room panels is an electrical failure-indaced ignition of panel internal wiring. The effects of electrical failures of control panel wiring and components was thoroughly investigated by PECO daring oar .gr separation test program. It was shown by test that the pft separation criteria used in the LGS panels will prevent the .1 effects of any electrical failure from propagating to a redondant division of wiring. This was proven by demonstrating and analyzing worst case effects of electrical l failures on the types of wires used in the control panels. ( All wire types are goalified to the IEEE 383 flame test reqairements. It is our position that through the use of the panel internal wiring separation criteria, an electrical fire in any control panel will not result in the loss of safe shatdown capability as only one division of one system would be affected. l 3. The PECO test program demonstrated that prior to the ignition of any wire, copicas quantities of smoke were first generated. This smoke has an acrid odor. A single six foot condactor l generated enoagh smoke to completely fill a 19 x 10b ft. aus From the test program it is evident that this failure lr room. l; mode will generate enoagh smoke to be detected by the ceiling ionization detectors in the room as well as an odor that will i be detected by the operator. We therefore believe that no further enhancement of plant safety or safe shutdewn capability will be achieved by adding smoke detectors in the control cabinets.

References:

PECO Test Report #48503, dated September 1,1982. l Drawings: None l .. m

I DRA! T NRC Open Item #29: Cable Spreading Room The cable spreading room is separated from the balance of the plant by 3-hour-fire-rated walls and floor / ceiling assemblies. All penetrations through fire-rated barriers are fitted with 3-hour-fire-rated dampers and/or 3-hour-fire-rated penetration seals. However, the applicant has not provided sufficient information for us to independently verify compliance with our guidelines. We will require the applicant to provide details showing compliance with the guidelines in BTP CMEB 9.5-1 Section C.7.c. CMEB Position Section C.7.c 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 Deluge and open spray systems should have provisions sytem. however, there should for manual operation at a remote station; Location be provisions to preclude inadvertent operation. of sprinkler heads or spray nozzles should consider cable tray arrangements and possible transient combustibles to ensure adequate water coverage for areas that could present exposure Cables should be designed to hazards to the cable system. allow wetting down with water supplied by the fi're suppression system without electrical faulting. ( Open-head deluge and open directional spray systems should be zoned. j. The use of foam is acceptable. Cable spreading rooms should have: least two remote and separate entrances for access by (1) At fire brigade personnel; (2) An aisle separation between tray stacks at least 3 feet wide and 8 feet high; (3) Hose stations and portable extinguishers installed immediately outside the room; ) -29/1-P-60(b)/3

? c (4) Area smoke detection; and (5) Continuous line-type heat detectors for cable trays inside the cable spreading room. Drains to remove firefighting water should be provided. When gas systems are installed, drains should have adequate seals or the gas extinguishing systems should be sized to compensate for losses through the drains. l A separate cable spreading room should be provided for each redundant division. Cable spreading rooms should not be shared between reactors. Each cable spreading room should be separated from the others and from other areas of the plant by barriers with a minimum fire rating of 3 hours. If this is not possible, a dedicated system should be provided. The ventilation system to each cable spreading room should be designed to isolate the area upon actuation of any gas extin-guishing system in the area. Separate manually actuated smoke 1 venting that is operable from outside the room should be provided for the cable spreading room. LGS Response Automatic fire suppression in the cable spreading room consists of a total flooding carbon dioxide system and a wet pipe sprinkler system. The wet pipe sprinkler systems installed at ceiling level, with directional sprinkler heads laid out to provide coverage for all cable trays and any possible transient combustibles that could present exposure hazards to the cable 9 system. b The cable spreading room has the following: s (1) Two separate entrances, each rated as a Class A opening with a 3-hour rated fire door in the east and west wall respectively. Walls are constructed of concrete masonry or reinforced concrete a minimum of 12-in. thick. Ceiling and floor are a minimum of 1-ft. thick reinforced concrete supported by fireproofed steel. (2) Cable trays in the cable spreading room are arranged to provide aisleways with a minimum head room approxi-mately 5 feet high and a mininum width between tray stacks of approximately three feet. At certain locations, structural supports for the cable trays reduce the aisle b width to a minimum of 17 inches; however, all points may be reached by an effective hose stream. P-60(b)/3 -29/2-

.r* DRAFT (3) Hose stations and portable extinguishers are located just outside the entrance to each cable spreading room. For the Unit 1 cable spreading room, the hose station and extinguishers are located in the control structure stair-well. For the Unit 2 cable spreading room, the hose station and extinguishers are located in the Unit 2 static inverter compartment. ./ (4) Smoke detectors are provided at the ceiling of the cable y spreading room to alarm during the incipient stage of a N fire. (5) For the LGS position on line-type heat detectors, see the response to Open Item #14. References 1. Branch Technical Position ASB 9.5-1, Appendix A, Section F.3. h 2. Branch Technical Position CMEB 9.5-1, Section C.7.c e V s r P-60(b)/3 -29/3-

DRAFT NRC Open Item #30: Switchgear Rooms - Drains and Exposed Structural Steel The Division I and Division II switchgear rooms are not separated from each other and from other plant areas by 3-hour-fire-rated walls and floor / ceiling assemblies. Structural steel supporting the floors is not protected by fire rated barriers as discussed [ in Section 9.5.a of this SER. We require the applicant to protect the exposed structural steel supporting the floor assembly in 3 accordance with Section C.S.a of BTP CMEB 9.5-1. Automatic lire detection is provided by ionization smoke detec-Manual protection is provided by standpipe hose stations tors. and portable extinguishers. Floor drains have not been provided in the switchgear rooms. We require the applicant to provide floor drains or a system of drains and curbs in accordance with our guidelines in Section C.7.e of BTP CMEB 9.5-1. LGS Response See the response to open Item 45 for the exposed structural steel and Open Item #9 for floor drains. f, P-60(b)/6 -30/1-

DRAFT prrn open Iton: #31 "The auxiliary eqaipment room (Fire Area 25) is located directly above the control room and contains the PGCC panels fer both anits and the remote shutdown panels for both onits. A fire in this aroc could prevent the safe shatdown of both units. The separation of redandant components in this area does not meet oar gaidelines in Section C.7.f of BTP CMEB 9.5-1. We require the appliennt to provido separation of safety related equipment in accordance with g oar guidelines." ETP CMEB 9.5-1 Section C.7.f: C.7.F. Remete Safety-Related Panels Redandant safety-related panels remote from the control rocn compicx shoald be separated from each other by barriers having a minimam fire rating of 3 hoars. Panels providing remete shatdown capability shoald be separated from the control room complex by p barriers having a minimum fire rating of 3 hoars. Panels providing remote shotdown capability should be electrically isolated fren the control room complex so that a fire in either area will not affect shatdown capability from the other area. The general area hoasing remote safety-related panels shoald be provided with aatematic fire detectors that alarm locally and clarm and annanciate in the control room. Combastible materials shoald be controlled and limited to those reqaired for operation. Portable extingaishers and manual hose stations should be readily availabic in the genern3 area. i" LGS Respense: The Limerick FPER will be revised to indicate that the Auxiliary 6 Equipment Room (Fire Area 25) now complies with t ~ v above cited secticn of BTP CMEB 9.5-1 as discussed in the response to DSER Open Item 912. The separation of the Remote Shatdown Pancis and cables from the Auxiliary Equipment Room panels and cables by three hour barriers assares that safe shutdown can be achieved in the event of a fire in Fire Area 25.

References:

Response to DSER Open Item #12 { Drawings: None l l l u i

DRAFT NRC Open Item #32: Battery Room',- Exposed Structural Steel The battery rooms are not separated from each other and from the balance of the plant by 3-hour-fire-rated barriers, because their floor slabs are supported by exposed structural steel. We require the applicant to protect the exposed structural steel in accordance with our guidelines in Section C.S.a of ( BTP CMEB 9.5-1. LGS Response See the response to open Item #5 for a discussion of exposed structural steel. k s. 4 P-60(b)/7 -32/1-

e DRAF"T NRC Open Item 433: Diesel Generator Separation The applicant states that each diesel generator and its day tank are enclosed by 3-hour-fire-rated barriers.

However, the applicant has not provided sufficient information for us to independently verify compliance with our guidelines.

.k CMEB Position We will require the applicant to provide details showing compliance with our guidelines in Section C.7.i of BTP CMEB f 9.5-1. LGS Response Each Diesel Generator Day Tank is enclosed by a 3-hr fire rated envelope consisting of the following: Walls - poured in place 24" thick reinforced concrete. a. b. Roof - poured in place 24" thick reinforced concrete. Floor - concrete slab on grade. c. d. Doors - UL labeled Class " A" (__ Penetrations hr rated e. Each Diesel Generator is separated from any adjacent redundant safety related equipment by a 3-hr rated barrier consisting of a 24" thick reinforced concrete wall. '[2-This complies with the guidelines of Section C.7.i of BTP CMEB 9.5-1. .w. References 1. Branch Technical Position ASB 9.5-1, Appendix A, Section F.9. Branch Technical Position CMEB 9.5-1, Section C.7.i. 2. l P-70(b)/ll -33/1-

DR4FT Item 34: Cooling Towers The cooling towers are constructed using combustible PVC material. This does not meet the guidelines of BTP CMEB 9.5-1, Section C.7. The sole source of fire suppression water is provided from the cooling tower basins. CMEB Position 1 We require that automatic suppression system be provided in accordance with the guidelines of NFPA 214-1977 and Section C.7.g of BTP CMEB 9.5-1. r LGS Response FPER Section 3.1.2, Item 247, describes the construction of each cooling tower. The American Nuclear Insurers (ANI) accepted the cooling tower design without a sprinkler system after a successful large scale burn test was conducted by b' Marley in July 1978 and witnessed by ANI. Based on the test conducted by Marley, the cooling tower design is acceptable. 1 References 1. Branch Technical Position ASB 9.5-1, Appendix A, Section F.17 2. Branch Technical Position CMEB 9.5-1, Section C.7.g M 1,9 l i P-60(b)/9 -34/1-1 l -}}