ML20138J760

Forwards Info Re Fire Protection,Discussed in 851113 & 1212 Telcons.Fsar Mods Discussed in Encl Will Be Included in FSAR Amend 14

ML20138J760
Person / Time
Site:	Hope Creek
Issue date:	12/16/1985
From:	Corbin McNeil Public Service Enterprise Group
To:	Adensam E Office of Nuclear Reactor Regulation
References
NUDOCS 8512180020
Download: ML20138J760 (9)

Text

{{#Wiki_filter:c Public Service Electric and Gas Company ' Corbin A. McNeill, Jr. Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609 339-4800 Vica President - Nuclear December 16, 1985 Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20834 Attention: Ms. Elinor Adensam, Director Project Directorate 3 Division of BWR Licensing

Dear Ms. Adensam:

FIRE PROTECTION HOPE CREEK GENERATING-STATION DOCKET NO. 50-354 Pursuant to telecons on November 13, 1985 and December 12, 1985; PSE&G hereby submits the attached information. The FSAR modifications discussed in the attached submittal will be included in FSAR Amendment 14. We trust this information will satisfactorily resolve this issue. Should you have any questions in this regard, please contact us. Sincerely, Attachment 5 2180g g5 4 F \\ 0

' Director of Nuclear 2 12-16-85 Reactor Regulation TC D.H.' Wagner USNRC Licensing Project Manager ~R.W. Borchardt 'USNRC Senior Resident Inspector D. Kubicki USNRC - DE - CMEB i .: 4

~ W ATTACHMENT 1 ~ -1. EFire System' Single Failure Criteria F FSAR' Sections ~9.5.1.1.3 and 9.5.1.6.1 address-the fire systemfconfiguration and design characteristics which-Lpreclude a, single. failure from adversely affecting primary and secondary suppression. As a supplement to

these features, the onsite complement of. fire hose, yard hydrants, and adjacent powerblock area hose' stations, and the. availability of an onsite= fire purper shared by HCGS and the ' adjacent ~ Salem Generating Stat ion provide - added assurance that an effective hose stream could be applied to any powerblock area.

A FSAR~ markup clarifying this Kitem is attached.- (Page 9.5-39 and 9.5-2) J2.. Extent of Non-IEEE-383 Oualified Cable In clarifying the' extent of non-IEEE-383 qualified cable in FSAR Section 9.5.1.1.14 (Page 9.5-9, third paragraph), PSE&G had apparently left the impression that the use~of non-qualified cable was' extensive. This'is'in actuality, not the case.- The FSAR clarification of this section consisted of adding the administration facility, non-safety'related yard structures, and "some. . communication / data cables" to the previously identified non-qualified cable. In addition, the 10 foot limit on icable'inJflexible conduit for. lighting was changed to "short segments" as some cables exceed this limit by a ~ minimal length. f DIt should be noted that the clarification.was intended to accurately identify uses and areas with non-qualified

cable, not to~ expand on the scope of non-qualified cable over'and above what had been previously accepted in the SER.

.In all cases, with specifics as follows, the K non-qualified cable is in conduit, in solely non-safety related areas, in areas.with fire suppression, or is routed in small quantities, such as 1 or 2 cables to individual. computer terminals. a.

The-' Administration Facility, which is separated f rom the remainder of the plant with three hour barriers and does not contain any safety related equipment, does not have qualified cable installed.

Similarly non-safety related yard structures, remote from safety related structures do not always utilize

m er k qualified cable. Please. note that in many cases . qualified cable was used in these areas due to onsite. availability.

6. ;Some coaxialLdata cables to office areas in the powerblock are non-qualified.

These cables are routed in small quantities to remote terminals and .are not prone to short induced faulting due to their data transmission function. c. .The non-qualified; cable in flexible conduit is that supplied with certain suspended or grid lighting fixtures-(pigtails) which is routed short distances L(approximately 10 feet) to ceiling mounted junction boxes. These cables are not' concentrated due to their function (one per light fixture), are protected by flexible conduit, and are limited in length. Summarizing, the PSE&G position has been,.and remains committed to the use of'IEEE-383 qualified cable for all uses, with clarifications and exceptions limited to-the ~ cases outlined above.- These do not constitute any increased fire risk and do not have'an adverse impact on plant safety. -A'FSAR clarification is included. (Page 9.5-9) .3. Fireproofing Program .The NRCJconcerns. raised regarding the structural steel fireproofing~ program are clarified as follows:

a.._ Clarification ofl Program FSAR Section 9A.8.0 identifies the specifics of the s

-fireproofing program. The current FSAR Section is in compliance with the flow chart included in our August 27, 1985, submittal.: As'a' point'of clarification, automatic sprinklers are relied.on only'in rooms where-the structural steel is inaccessible for fireproofing application. The backup documentation 'for each area is'available in our files. We will include a revised flow chart in the FSAR, as further clarification, as' detailed below. .b. ' Lack of.fireproofing of " Branch Technical Position" ~ fire barriers 1(vs. Safe Shutdown Separation -barriers). -W- 'wnye'v-fw-rww w v v9 wwpN9"'* T-- --v-am *wT-e

_ c73; s b r 3z-Based 1on the PSE&G andLNRC telecon on November 13, ~1985, we~will expand the fireproofing program, with a 0; . slight: modification, to. include all' fire barriers-

identified on drawings M-5101 through M-5111 as.BTP CMEB 9.5-11fireibarriers, submitted as markups under separate cover.

The change in the program is-that areas with no~ combustibles, such as the unoccupied . areas, will notibe:fireproofed. -We will, however, monitor the areas-where we have taken credit for lack of combustibles under the station ~ fire protection routine surveillances as a.means;to assure ongoing compliance. 'A_FSAR markup of Section 9.A.8.0 is i included a:s pages 9A-78,79, & 79A. Table 9A-104-(similar to' Table 9A-103) is included to document the resultsJof.our fireproofing program analysis. All areas still^under evaluation will be resolved and entered into.the table by: February 1, 1986. c. . Specific. Clarifications - The deviation requested in 9A.6.3.1.e'(9A-39) has been deleted since itris-consistent with the above referenced flow chart and

our program.

4. Smoke Stratification rRevised, FSAR wording.with.further explanation is Lincluded (page 9.5-23). Summarizing,: smoke stratification has been considered.and evaluated in the . design of the/ detection and HVAC systems at Hope Creek. (Page 9.5-23) 5. . Licensing Basis As~ discussed.in FSAR Section 1.11, HCGS has utilized the requirementsaof BTP-CMEBi9.5-1 (NUREG-0800),.with deviations as~noted in the applicable FSAR sections, and 1 - as toviewed'via the SER. 6. Smoke Detection -A revised FSAR markup-(Page 9.5-23) is attached to further-delineate the extent of mitigating measures in safety related areas which do not have smoke detection. ~ L In all cases, the areas contain two or more of the 'following features: a.. low or negligable fire 11oading

r 4 b. separation by fire barriers with detection in adjacent areas c. lack of safety related, or safe shutdown equipment / cable d. small areas with limitsd combustibles (vestibules, corridors, janitors closets, chases, etc.) e. high radiation areas f. alternate means of detection, such as pump overload or equipment trouble indication g. steam vents.and chases h. existing suppression and detection covering the significant hazard (e.g. charcoal-loaded in filters) We have a breakdown of the features of each area available in our files. 7. Ruskin Fire Dampers The Ruskin Fire Damper program has been submitted via

letter dated December 3, 1985.

It.is self explanatory and inclusive of all aspects of the program. In place L testing has also b'een delineated. Surveillance testing will be in accordance with our Technical Specifications. 8. Non-Segregated Phase Bus Duct Sealing Extrapolation of the non-segregated phase bus duct fire barrier test-for a variation in bus bar material ~has been submitted via letter dated November 21, 1985. Again, it is-self explanatory. These internal bus seals are being placed in the perimeter of the diesel-generator rooms. Deviations where the bus duct passes through other areas of the plant are identified in the appropriate FSAR sections. 9. Branch Technical Position Required Fire Barriers Public Service Electric & Gas has prepar'ed drawings which will be included as FSAR figures, addressing the BTP fire barrier scope as discussed in item 3.b above. These drawings should be used in conjunction with the current FSAR Figures 9.5.1 through 9.5.12. The barriers

t 5 delineated on the BTP scope drawings will all be included in the Technical Specification surveillances and the fireproofing program clarified in Item No. 3 above. The barriers shown are based upon separation between hazards and safety related equipment, separation of main structures, separation of turbine and radwaste from each other and safety related equipment, and other barriers required by BTP CMEB 9.5-1. 10., Miscellaneous Clarifications Section 9A.6.5.1.d and.e - Loss of redundant HVAC is clarified in the FSAR markup. As detailed, there is no immediate impact on shutdown capability. Assuming loss of this equipment, alternato, portable cooling equipment would be employed in conjunction with fixed temperature monitoring devices to attempt to maintain room anbient temperatures below equipment qualification limits (page 9A-46 and 9A-49). Section 9A.6.8.1.b and.d - The physical separation ~ distances between redundant safe shutdown divisions have 'been added to the appropriate sections (pages 9A-54 and 9A-55). All powerblock battery rooms have HVAC exhaust ductwork within 18 inches of the-ceiling. In accordance with FSAR squestion 430.23 we are testing the exhaust capabilities with helium to assure that room mixing is adequate to limit hydrogen buildup to 2%. This will alleviate any concerns regarding the potential to buildup hydrogen. The attached. FSAR markup contains minor grammatical, format, and accuracy modifications other than those referenced herein. The upcoming FSAR amendment will incorporate this markup.

11. SER/SSER Clarifications The following sections of the SER 9.5.1 do not adequately address the HCGS fire protection program.

We recommend - the intent of the following modifications be considered (new words underlined): I a. Page 9-34 2nd paragraph "All open-head sprinklers in safety related areas were changed to manual operation. These are the FRVS system charcoal filter systems, containment pre-purge cleanup charcoal filter, main control room..."

s u r n N 6 b. -Page 9-34'3rd paragraph "The automatic CO2 systems in

safety related areas cover'the' control equipment X'

mezzanine at elevation 117'-6";.."

c.. Page19-34 Section.9.5.1.3. .Our fire brigade commitment;has been, modified per_ letter dated August 27,.:1985. -d.- Page 9-35-Section 9.5.1.4. The revised wording in 'FSAR Sections.-9.5.1.1.14,'and 9.5.1.6.3 may result in changes to this SER Section. - e. .Page 9-37 Control of Combustible Materials - " Hydrogen piping. routed in safety related areas is designed to Seismic. Class I~ criteria". . f. Page.9-37 Electrical-Cable Construction, Cable Tray, .and' Penetrations - The clarification contained in item 2 of-this letter may; require-modification of the LSER in this section.. - g. Page 9-38 second paragraph "...in areas protected by total. flooding CO2 extinguishing systems... h. Page 9-39 fourth paragraph..The discussion of fire' Jprotection.' power supplies in FSAR section 9.5.1.1.6 - i:s accurate. The SER section may need clarification. 11. Pagef9-40 second paragraph. '"of the nominal'350,000 gallons of storage capacity.for each tank, 328,000 gallons is dedicated'to the fire protection water system; and the remaining amount is available"for other water uses.". (We have recently modified our fresh water supply.) j. Page 9-40-third paragraph. -Please note that the largest water demand:shown is a non-safety.related system. The largest safety related water demand is given in FSAR section 9.5.1.2.3.1. 1 - k. Page 9-40 fourth paragraph. Hydrant spacing is delineated in FSAR section 9.5.1.2.3.3. ' l...Page:9-41 Halon Suppression Systems - Halon is provided per FSAR section 9.5.1.2.10. m. Page 9-41 Primary Containment and Reactor Building Enclosure - HCGS.does not have fixed CO2 fire s suppression in the HPCI pump room. I

6 z-. - 3;. 7 n. Page 9-43 Remote Safety - Related Panels. The Remote Shutdown Panel is located at elevation 137' of the "~ auxiliary building radwaste and service area. d e if t {

0+-l PAGE 1 OF FSAR GANGE NOTIG [M4b 1. DISCIPLINE: 2. CHANGE NO. J,[. fg 3 M [ [ g. DATE: gMt/g

3. ORIGNOR;

5. THE EOLIDWING SECTIONS OF biE ST B h SED:

9. 5. I M 1A i

2

6. DESCRIPTIQ4 OF GANGE: (Note-Attach a marked up copy of all affected pages of the trinted FSAR. Mark up text to be deleted with a horizontal line. Text to be added should'be printed on the copy or on a separate page labeled as an insert.)

$W CA cicoryds & Sopmedes BexMe) FSA d C N 5 1987 ?Il40- \\ T shAf;Rfe Arr^caers:

7. JUSTIFICATION FOR CHANGE:

@Below Attached rs NR C Vevaaws cj vesitc.,1 &A ufdd 43< ~ CNwpts art refvived do PaletWew pacpo.m /. dorrect.pd le a

8. CHANGE WILL IMPACT THE EOLI4 MING PR17ECT PIOCEDURES, TEST REQUIREMENIS, MANUALS:

4

9. THIS CHANGE NOTICE SHOULD BE SENT TO GE FOR A CUNCURRENCE REVIEW.

10. CHANGE WILL IMPACT THE FOLIOWING DISCIPLINES:

(Note: Group Supervisor's initials for the iUpaCted disciplines are required) ' Civil Division bFuelSupplyDept. bNuclearDept. OControls s Electrical OLicensinsaEnvironmene oA-esc hConstruction Div./Startup ] Mechanical Division hOther: Be<[hf

11. APPRNED BY

12. APPIOVED BY

13. APPPOVED BY

14. APPROVED BY GIOUP ING R: PR17ECT LICENSING MANAGER: CHIEF ENGR /PFQ7. M3R:

DATE: yI DATE: DATE: g, 15. DISPOSITION: CInplemented dNot Inplemented Date:

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HCGS FSAR 09/85 l Consistent with other safety requirements, structures, systems, and components, including those required for safe shutdown, are designed and located to minimize the probability and effect of fires. Noncombustible and fire-resistant materials are used whenever practicable throughout the plant to minimize fire potential by lessening the duration, severity, and intensity of combustion. Redundant safety-related components are separated from each other and the rest of the plant by 3-hour fire barriers, and/or are separated by 20 feet. Deviations are identified in Appendix 9A. The fire protection system (FPS) has been designed in accordance with the NFPA standards listed in table 9.5-1. Deviations have been identified and evaluated against specific plant conditions with the design details chosen to reflect a suitable fire protection program. Significant deviations to NFPA standards are identified in Section 9.5.1.6. 9.5.1.1.2 Redundant Fire Suppression Capability i Fire protection of areas identified as containing potential fire hazards is not dependent on a single fire suppression system. Backup capability is discussed in Section 9.5.1.2. 9.5.1.1.3 Single Failure Criteria A single failure in the FPS does not impair the p)rimary and backup fire suppression capability except as noted in Section 9.5.1.6.1. A single failure in the pumping system does not impair the fire protection water system, due to the availability of redundant fire pumps; one is a motor-driven fire pump and the other is a diesel-engine-driven fire pump. A failure in a header of one of the automatic sprinkler systems does not impair the backup hose racks, which are fed from a different header of the in-plant loop, as shown on Figures 9.5-13 QQ y gik (;ye pop,per glgyed j,3 [kGs ord through 9.5-15.*In Sakm is m.4/d k. 9.5.1.1.4 Failure or Inadvertent Operation FPS components are designed so that a failure or inadvertent operation does not result in loss of function of plant structures l' 9.5-2 Amendment 12 e-r

HCGS FSAR 1/84 9.5 OTHER AUXILIARY SYSTEMS 9.5.1 FIRE PROTECTION PROGRAM ~( The fire protection program is designed to: a. Prevent fire from starting by using noncombustible and fire-resistant materials wher racticable in the - plant, and to maintain safe tdown ability by providing fixed and/or porta le fire fighting equipment b. Detect fires quickly and nnunciate in the main control -room the fire location f r fire brigade notification and personnel safety c. Suppress and extingui,h those fires that occur in the shortest possible tijne to minimize damage and to maintain safe shutd wn ability .d. Prevent the spre of fire by using fire barriers between structur s, systems, and components of safety-related systems e. Ensure that ailure or inadvertent operation of the suppression / system does not jeopardize the capability to achieve safe shutdown of the plant. 9.5.1.1 Design Bases / 9.5.1.1.1 General / The overall Hope Creek Generating Station (HCGS) fire protection [ program is baped on the evaluation of potential fire hazards throughout the plant and on the effects of postulated fires on the performance of safe shutdown functions. A detailed evaluation df the effects of postulated fires on safety-related systems reg'uired for safe shutdown of the plant is summarized in Appendix 9,A, Appendix R comparison. l l' l l / 9.5-1 Amendment 4 y y-- -.,y. ,+---e-a .,, + - -

+ A HCGS FSAR 1J 09/85 t ? In addition, water hose stations and portable fire extinguishers O-are provided for manual firefighting throughout the plant in accordance with Section 9.5.1.2.9 and 9.5.1.2.13, including those provided with automatic preaction sprinkler systems. The tray configurations comply with the separation criteria of Regulatory Guide 1.75, with exceptions stated in Section 1.8. 9ehac wO but\\ Cable and cable tray penetrations through fire barriers, both ~~ vertical and horizontal, are sealed to provide protection equivalenttothefirebarrierswithclarificationsasnotedin} Section 9.5.1.6.3. "The d::ign of fir; barrier p nctratic. :::1. m::ta thw seguit einte of ASTn E i i i.- In addition we have evaluated the effect of.a fire on cable tray penetration seal integrity with regard to the mechanical forces on the seal. It i is concluded that under the worst case scenarios, the barrier seal at the electrical cable tray penetration will maintain its fire integrity. l; W 1e lul [AN O i Medium and low voltage power an control ables, and al1 other ~ cables installed in cable trays in the lant have passed the IEEE 383 vertical flame test. Cable installed in conduits for normal and emergency lighting, -- EI= communcation/ data wiring, short segments flexible conduit for the normal and emergency lighting syst ome cables and wirings used in the administratio cility and non safety-related yard structures, (]) and cables and wirings in some components mounted in non-Class 1E cabinets are not subjected to IEEE 383 flame t.es_t tequirements. QS!&O t'2 dl*d. 0 No piping for flammable or combustible liquids or gases is routed in cable trays, or in electrical raceways and conduits used only for electrical cables. l The design considerations for cabling involve an optimized t balance of electrical, physical, and environmental characteristics. The environmental prerequisites of the jacketing materials include high flame retardance, radiation resistance, and capability to endure a postulated accident condition. These jacketing materials, when involved in a fire, give off small amounts of hydrogen chlorides, which turn into corrosive acids in the presence of a substantial amount of moisture or water. Alternative materials that satisfy the i primary design bases without releasing potentially corrosive gases are not available at this time. i Cables entering the main control room also terminate there, and are essential to its operation. 1 () 9.5-9 Amendment 12 1 ...__._-_.._,_____m__._.-_,_.

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s HCGS FSAR 09/85 SYSTEM FSAR SECTION l G. .s( A Diesel Generator' Room Recirculation (DRR) 9.4.6 (Shutdown HVAC fhns on CO, system actuation prior to ETL release) Radwaste Supply (RWS) 9.4.3 l Service Area Exhaust (SAE) 9.4.3 l Service Area Supply (SAS) 9.4.3 l Solid Radwaste Exhaust (SRWE) 9.4.3 l Solid Radwaste Supply (SRWS) 9.4.3 l Wing Area Exhaust (WAE) 9.4.1 l Wing Area Supply (WAS) 9.4.1 l l Administration Facility N/A l Guard house N/A l In addition to the systems that automatically shut down five systems are manually shut down based on area smoke detectors or duct high temperature alarms. These systems are: Control Room Return (CRR) Control Room Supply (CRS) MG Set Ventilation (MGV) Radwaste Exhaust (RWE) Turbine Building Compartment Exhaust (TBCE) b. Smoke Removal - The normal building ventilation systems or separate smoke removal systems are provided to-remove products of combustion. For areas where smoke i can not be removed via the permanent plant ventilation systems as described below, portable blewers for use as smoke ejectors will be provided by the' fire brigade. Refer to Section 9.4 for a complete description of the air conditioning, heating, cooling and ventilation systems. 1. Control Are.t - A separate smoke removal system is provided for the control area to remove the 1 9.5-12 Amendment 12 1. u.

HCGS FSAR 09/85 ' subcontractors provide required records of their activities. Bechtel will turn the records over to PSE&G at the appropriate time. j. Audits - Audits will be performed in accordance with written procedures as appropriate on Bechtel activities in engineering, procurement, construction, installation, and testing. Audits will be conducted by Bechtel QA and PSE&G QA departments. 9.5.1.2

System Description

9.5.1.2.1 General g 9.5-35 firewall/barri[erratings,andfiredetectionand through 9.5-12 show the plant layout, facility Figures 9.5-1 arrangement, suppression with respect to FPS equipment and components. The FPS is also shown schematically on Figures 9.5-13 through 9.5-19. g Hazardous materials are listed in Table 9.5-3. 9.5.1.2.2 Codes and Standards In general, the FPS is designed and constructed in accordance with the following codes and standards: a. Nuclear Mutual Limited (NHL) Property Loss Prevention Standards for Nuclear Generating Plants b. New Jersey Uniform Construction Code, Chapter 23, Title 5 l c. American National Standards Institute (ANSI) d. National Fire Protection Association (NFPA), as listed j in Table 9.5-1 9.5-14b Amendment 12 -,----,--r ,,,-- -. ~, ,,-,,--,n.,._,,

4 HCGS FSAR 09/85 h '. Code of Federal Regulations, 10 CFR 50, Appendix A, GDC 3 1. Occupational Safety Health Act (OSHA) j. HCGS General Plant Electrical Design Criteria, D4.0 k. Nuclear Regulatory Commission's Appendix A to BTP APCSB 9.5-1 and 10 CFR 50, including Appendix R. 1. Nuclear Regulatory Commission's BTP CMEB 9.5-1. l 9.5.1.2.3 Fire Protection Water Supply Systems and*F MrnIDB f S M- ~ 9.5.1.2.3.1 Water Source Fire protection water supply is from two, 50,000-gallon nominal capacity, fire water storage tanks located north of the plant. Of thedo,ninerhg;3d Each tank feeds the FPS and the '-- ' 350,000 gallons of storage capacity for each tank, r 328,000 gallons is dedicated to the fire protection water lsystem, and the remaining am is available for the &eesk wacei system. he water syst s fed through an external tap physically located above the fire water level of 328,000 gallons. Water is pumped by two deep-well water pumps, and the discharge piping for the pumps is cross-connected so that either pump can fill both tanks. Each pump is capable of filling the fire water portion of either fire wat pg'orage-tank within 8 hours. demgnerll2-b. r om i l The adjacent Salem Generating Station fire protection water supply is physically connected to the Hope Creek yard loop by a 10-inch connection controlled by a normally closed post-indicator valve (PIV). The dedicated fire water storage capacity of 328,000 gallons i f/FO each tank will provide water to meet the demand of M of C the largest sprinkler system (non safety-related system) plus 500 gpm for manual hose streams for 2 hours. The largest safety related sprinkler demand is 1455 gpm plus 500 gpm for hose streams. l l 9.5-15 Amendment 12

[ i HCGS FSAR 09/85 pump is from a non-Class IE bus. Offsite power is needed to run the electric-motor-driven fire pump. The diesel-engine-driven pump controller is provided with power from batteries. Offsite ac power is provided to the battery charger. Loss of ac power .does not prevent startup or operation of the diesel-driven fire pump. The diesel fire pump starts automatically on loss of ac power. Jh es 1 fuel supply tank has a capacity of 280 gallons of l C5;r - uel oil. This is sufficient to supply the necessary fuel needed for diesel-engine-driven fire pump operation in excess of 8 hours at full pump capacity. i The electric-motor-driven fire pump and controls are located in a room along with the jockey pump and controls. The diesel-driven ~ fire pump and controls are located in a separate enclosure with 3-hour fire-rated barriers. The diesel fuel o.11 day tank is located outdoors. Each fire pump room is provided with an l automatic water sprinkler system. 9.5.1.2.3.3 Yard Piping l The connections to the yard fire main loop from each of the two fire pumps are spaced approximately 75 feet apart, separated by a divisional valve with additional valves arranged to isolate either connection to maintain a 100% water supply to the main loop. The top of the piping is below the site frost line of 3 feet 6 inches below ground level. For underground piping within the power block area, bedding is of lean concrete or l granular material compacted to 90%, according to ASTM D 1577 (Method D); and for piping outside the pwer block area, bedding is of granular material compacted to 90% (ASTM D 1577, Method D) or of lean concrete or sanderete. Backfill is of granular 1 material compacted to 85% (ASTM D 1577, Method D). The outdoor, underground yard loop was designed in accordance with NFPA 24. The yard loop consists of 12-inch diameter cement mortar-lined ductile iron pipe that extends around the power block. Post-indicator valves (PIV's) are provided for sectional control. Hydrants with two 2-1/2 inch outlets, controlled by 2 individual curb box valves, are installed on the yard loop at i intervals sufficient to provide an effective hose stream to any yard location. A hose house is provided for each hydrant and equipped with 200 feet of hose, fittings, and accessories in accordance with NFPA 24. ] 9.5-16a Amendment 12 4 -........e-,. -.,y__. m. _,,.,,,,-_.,-.m_,__--.__,-_.,-....,~..--+e_.-.

HCGS FSAR 11/85 Valves are either electrically supervised, or locked and inspected monthly. Documentation recording this inspection will be maintained. Automatic and manually actuated sprinkler system design was based on area coverage of hazards. To effect this result ordinary hazard listed sidewall sprinkler heads and sprinklers with orifices below one half inch in diameter were utilized to provide full coverage and to control water density, respectively. In all ] cases, the system design was specific to the room and hazards involved. 9.5.1.2.4 Wet Pipe Sprinkler Systems i Wet pipe sprinkler systems are provided for the plant areas listed in Table 9.5-2. The density coverage and installation for the sprinkler systems are in accordance with NFPA 13. Each sprinkler system is provided with an alarm check valve or flow switch that annunciates in the main control room. OS&Y gate valves serving as shutoff valves to automatic sprinkler systems are supervised with any problems annunciated in the main control room. 1 The flow of water through an alarm check valve or flow switch energizes a local audible alarm and registers an alarm condition on the fire monitor panel in the main control room. Once initiated, the wet sprinkler system operation is terminated manually by shutting either a gate valve external to the hazard or a post-indicator valve outdoors. 9.5.1.2.5 Water Spray Systems Water spray systems are provided for the plant areas or equipment listed in Table 9.5-2. The water spray systems have directional solid cone spray nozzles 6 or perforated pipe for certain HVAC charcoal filters or closed l sprinkl heads for certain areas. The water flow is controlled l by UL 'I ted deluge valves. A system actuation -hrm and an alar ich annunciates supervised circuit tr le as well as x b out sition supervised OS&Y isolation valv J r each spray x system are provided in the main control room, my densities and installation complies with NFPA 13 and 15. 9.5-16c Amendment 13 J

... _. ~. HCGS FSAR 09/85 i The manual deluge system for the control equipment room mezzanine is divided into four zones with open sprinkler heads and the water flow for each zone is controlled by a normally closed OS&Y gate valve. The gate valves are supervised and a common trouble alarm is provided in the main control room if the valves are not l 100% closed. The system is designed in accordance with NFPA 13. Operation of the system is initiated by manually opening any of l the gate valves for each zone, allowing water to discharge l through the open sprinkler heads. Water flow alarm for the i system is annunciated locally and in the main control room. When the fire is controlled, water discharge is terminated by manually closing the gate valve. After the water is drained, the system is ready for use again. 9.5.1.2.7 Manual Preaction Water Spray Systems l l Manual preaction water spray systems protect charcoal filter beds 4 in nine HVAC units located in the Reactor Building. The specific HVAC units covered are listed in Table 9.5-2. j l The individual charcoal filter systems are supplied by a common header which in normally dry. The header is charged with supervisory air between the common deluge valve at the supply end of the header and the individual motor operated valves (normally i closed) which isolate each of the nine sub-systems. The deluge i valve isolation gslum A normally kept in the closed position. A motor operated.:.t-!a rrd'b olation valve, located on the header i g inside the butiding, is 1HkTntained normally open. 1 Linear thermistor circuits are installed in each charcoal filter 2 j unit which alarm on local annunciator panels installed at each filter unit and on the common control panel (located adjacent to the deluge valve) when the "high" and "high-high" temperature setpoints are reached. A common alarm is received in the Control Room when the "high" setpoint is reached on any linear thermistor circuit and a sub-system specific alarm is received when the J "high-high" setpoint is reached. i When the "high-high" setpoint is reached for any sub-system, the 4 header isolation valve is opened, and then the deluge valve is tripped and the sub-system MOV is opened using push bottons on the local control panel. When the fire is extinguished the system can be reset as follows: 1 i 9.5-16e Amendment 12 4 . - - ~

4 1 HCGS FSAR 09/85 a. The sub-system MOV and header isolation valves are closed and the header drained. b. The local control panel is reset and tne deluge valve is manually reset. t c. The header is re-charged with supervisory air. l 9.5.1.2.8 Preaction Sprinkler Systems Preaction sprinkler systems are provided for plant areas or equipment as listed in Table 9.5-2. 4 I Preaction sprinkler system operation is initiated by thermal or smoke detectors located in the hazard area, which actuates the UL-listed valve and charges the system with water up to the i closed, fusible link sprinkler heads. No water is di ' Ted the hazard area at this time. System specific fir _M '1-r't _; g alarms are annunciated in the main control room. igh temperature due to fire condition melts one or more of the 1 fusible link sprinkler heads and water discharges onto the hazard. When the fire is controlled, water discharge is terminated by manually closing the fire main gate valve, and the system is i drained. ' Fused sprinkler heads are replaced, the deluge valve is manually reset, and the header is pressurized with supervisory air. The preaction sprinkler system for the cable spreading room at i elevation 77 feet of the auxiliary building-control area is divided into four zones, each of which has a deluge valve. All a i sones are actuated when smoke detectors from the early warning detection system detec*. a fire. This is the only water system which is initiated by smoke detection. Details of the early warning detection system are provided in Section 9.5.1.2.15.1. 9.5.1.2.9 Wet Standpipes and Hose Stations i l Wet standpipes for fire hoses are designed to provide 65 psig at the topmost outlet of the hose standpipe system with 100 gpm l i I 9.5-16f Amendment 12 ~--,yp-cm,-w.,-.., _ mm, ,, w y n,,,, _, _, ._m_m.mn,,,,,,,,_w,,w.m.. ,,,n,--,- ,e,-, --~y---,

HCGS FSAR 09/85 flowing from the outlet in accordance with NFPA 14. -Standpipes l are installed adjacent to stairwells, exits, and other points in all-normally accessible areas in plant buildings. Four-inch standpipes are provided for three or more hose connections, and 3-inch standpipes are provided for one or two hose connections except in one instance where three hoses are connected to a 3-inch branch. These three hose stations are not on the same floor and cannot be used to fight the same fire. The standpipe hose connections are equipped with 1-1/2-inch hose valves and i badh ~preconnecte3%75 or 100 feet of 1-1/2-inch woven jacket lined hose e spray nozzles. In safety-related areas, some standpipe hose connections (fire hose stations), are provided with an additional 50 feet of hose which is not connected and is stored near the fire hose station. In the unlikely event of a fire, the additional hose will be used to-reach certain areas that a 100-foot hose will not reach. For a list of the fire hose stations that have the additional 50 feet ~ of hose and the areas that they will be used to reach, see Section 9.5.1.6.21. j The existing 75/100-foot fire hoses may not reach some areas of the nonsafety-related turbine building and auxiliary building - radweste/ service area. The fire brigade is equipped with additional lengths of hose which will be used if necessary. Installed hose length will not exceed 150 feet. l gf TD ' 1: di= charge pressure f(e g f a se whic eq tes to 65 si with 100 vem !!--i the hose sta ion out1 r FPA 1 is avai1=k_ the noz all fir hose at to which 5 ;;-U5'to 156 feet of hos 3 -The fire water supply can provide water at the required flow and pressure to supply any hydraulically designed sprinkler or deluge 4 system and all the hose streams which can be brought to bear on the same fire. See Sections 9.5.1.6.19 and 9.5.1.6.21. Standpipes are maintained in a dry condition in the reactor l building and the intake structure. Adjustable spray nozzles with shutoff capabilities, UL-listed for l Class C fires, are provided. The power block fire hose stations are also provided with adjustable pressure restricting hose angle valves. 9.5-17 Amendment 12

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HCGS FSAR 09/85 9.5.1.2.10 Halon Extinguishing Systems An automatic Halon 1301 total flooding system is provided for the OA vault in the administration facility and underneath the raised floor of room number 1 in the guardhouse. Each system is actuated by a fire detection system using cross-zoned ionization detectors. The Halon extinguishing systems are designed in accordance with NFPA 12A. Each system is designed to achieve a Halon 1301 concentration by 4 a volume of 7% within a nominal 10 seconds; with a maintained concentration of Halon 1301 of not less than 5% for a period of 10 minutes. A 100% backup supply of manifolded Halon storage containers is provided to enable a manual-electric discharge into the protected area.' A' manually actuated Halon system is provided for the main control room console and associated pit. For further discussion on this system, see Section 9.5.1.2.19. l 9.5.1.2.11 Carbon Dioxide Systems i Low pressure carbon dioxide systems, designed in accordance with NFPA 12, are provided for room total flooding, local application, local hand hose fire protection applications, and also for 1 turbine-generator purge. The carbon dioxide is stored in low pressure storage units consisting of a pressure vessel that maintains the carbon dioxide at approximately 300 psig pressure and 00F temperature, using an integral refrigeration unit. Two fire protection storage units are provided for the plants one serving the turbine building, and one serving the remainder of the plant. A third carbon dioxide storage unit located in the turbine building is used for generator purge and is not considered part of the fire protection system. 1 Each fire protection carbon dioxide storage tank serves two or more zones with a solenoid-pilot-operated master control valve. l Additionally, each total flooding hazard area is provided with a pilot-operated selector control valve in series with the master valve. A supervised annunciated alarm is provided to indicate closure o_f_ the-mamre-ly:-.__ eat valve in the selector valve pilot line70T7?r

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opefation. -Provisions ~are made for local and remote alarm, and manual operation. The ETLs provided to close fire dampers for room isolation from the ventilation system are actuated by a 9.5-18 Amendment 12

i HCGS FSAR 09/85 signal'from total flooding the carbon dioxide system control panel. 9.5.1.2.11.1 Carbon Dioxide Total Flooding Systems Carbon dioxide total flooding systems are provided for plant areas or equipment, as listed in Table 9.5-2. Low pressure carbon dioxide system operation is initiated by attainment of a fixed high temperature. A temperature sensor initiates the following automatic operation sequence for total flooding: a. A local predischarge alarm is sounded to allow ) personnel to evacuate the area. The alarm condition is registered on the fire protection status panel in the main control room. Electrothermal devices actuated by the circuit shut all fire dampers. b. After completion of a delayed action timer circuit ~ sequence, the master and selector valves open, releasing carbon dioxide to the hazard area. Upon completion of the discharge cycle, the timer closes the master and selector valves. -t: tt; elc;;ij cla==A 4 __ " The alar condition is maintained until the system rele, s reset manually. control In p nvu n rao_ns _s Control pilot valves located outside the hazar area may also be l '~' operated manually to activate th system. A upervised 1/4-inch ball valve, with a ;;.trel re_.. valve position alarg serves as a defeat valve in the pilot line and can be used to deictivate the system when personnel occupy the room. The carbon dioxide i storage capacity is adequate to permit two separate discharges within the largest single protected area. The local manual defeat valve for the CO, systems will not be routinely locked due to personnel safety considerations. However, actuation of the manual defeat mechanism alarms in the Main Control Room on the fire protection status panel, t Operations or fire brigade personnel will investigate and rectify any unanticipated CO, system defeat. I l 4 t 9.5-19 Amendment 12

HCGS FSAR 09/85 9.5.1.2.12 Mechanical Foam System A mechanical foam system is provided for the 1,000,000-gallon fuel oil storage tank located in the yard. The system consists l of a foam tank, proportioner, deluge valve, and foam maker designed in accordance with NFPA 11. The system is controlled by a deluge valve actuated by either a local manual or remote manual actuation from the main control room. A system actuation alarm and a valve position alarm is provided in the main control room. Rate-compensated thermal detectors inside the fuel tank locally and remotely alarm on the fire status panel in the main control room upon fire conditions. A 1-1/2-inch hose valve is provided to supply foam for manual firefightin. of Operation of the mechanical foam system is initiated by a~ manual switch on the local control pane in the main control room. x Actuation of the switch opens the deluge valve and charges the system piping and foam storage tank with water. Water pressure in the foam storage tank forces foam concentrate out of the tank to the proportioner where foam concentrate is metered into the water. The water and foam mixture then flows to the foam maker on the fuel storage tank which discharges foam into the storage tank. Water flow in the system initiates a local alarm and registers the system actuation condition on the fire status panel in the main control room. 3 Manual release of the deluge valve tripping device also initiates l local and remote water flow alarms. System operation is terminated by manually closing an OS&Y gate valve located at the inlet of the deluge valve. 9.5.1.2.13 Portable Fire Extinguishers Portable carbon dioxide fire extinguishers and/or dry chemical extinguishers, or Halon 1211 extinguishers are provided throughout the plant in a eas that may contain combustible material. I Portable fire extinguishers are provided in accordance with l NFPA 10, and OSHA regulations and recommendations. Multipurpose portable extinguishers for use on Class A, B, and C fires have a nominal capacity of 20 pounds, 10 pounds, and 5 pounds of dry j chemical rated and labeled by UL as 20-A, 60-B:C; 4-A, 60-B:C; and 2-A, 10-B:C; respectively. Portable extinguishers for Class B and C fires have a capacity of 20 pounds of carbon 9.5-21 Amendment 12

O HCGS FSAR 11/85 dioxide or dry chemical with a minimum UL rating and label of 10-B:C and 60-B:C, respectively. Portable Halon 1211 extinguishers for Class A, B, and C fires have a nominal capacity of 17 pounds of Halon 1211 labeled by UL as 2-A, 60-B:C. Class B and C portable dry chemical extingushers are provided inthe power block and service water intake structure. Class A first aid fire fighting capability is provided by the standpipe and hose station system described in Section 9.5.1.2.9. Also portable pressurized water fire extinguishers are provided in the reactor buidling and service water intake structure for first aid fire fighting and to supplement the normally dry standpipe and i hose station system in these areas. Class A, B and C portable dry chemical extinguishers are provided in the yard buildings, excluding the service intake structure; the administration facility; and the guardhouse. 9.5.1.2.14 Mobile Dry Chemical Extinguisher A mobile dry chemical extinguishing cart consists of a nominal 300-pound dry chemical powder tank and an inert gas cylinder mounted on a mobile chassis. Each unit is equipped with 50 feet A of 1-inch hose and nozzle designed for local application of dry chemical powder. Normally, the units are stationed in the turbine building and auxiliary building diesel area ready'for'f"# immediate use. The unit is in accordance with NFPA

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l 9.5.1.2.15.1 Early Warning Fire and Smoke Detection Systems l Early warning fire and smoke detection systems are installed in all required areas in accordance with NFPA 72D and 72E. Except for the cable spreading room at elevation 77 feet of the auxiliary building control area, the early warning fire and smoke detection systems are independent of the detection systems used i i to actuate the suppression systems. For discussion of the i detection systems used to actuate the suppression systems, see Sections 9.5.1.2.5 through 9.5.1.2.8 and 9.5.1.2.10 through i i 9.5.1.2.12, 4 The selection, placement, and spacing of fire and smoke detection devices is based on the design, configuration, and use of the area, together with draft conditions due to natural or mechanical ventilation. s 9.5-22 Amendment 13

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Flame detectors respond directly to the infrared radiation emanating from a flame sustained for at least 3 seconds in areas where fire develops rapidly with a minimum or absent incipient stage. Photoelectric smoke detectors respond directly to visible smoke concentrations of not less than 0.5% per foot of light obscuration caused by smoke for at least 5 seconds, and are used in areas where fire potential might exist and areas that are exposed to a radiation dose rate greater than that recommended for ionization detectors. All fire and smoke detection devices are supervised for reliability per NFPA 72D with exceptions as noted in Section 9.5.1.6.14. Areas with combustible loading greater than 8000 Btu /fca are l provided with fire and smoke detection systems. Se e Appendix 9A, Table 9A-1 for specific safety-related areas where detectors are provided. Safety-related areas without detectors are also identified in Table 9.5-19. These areas have been evaluated for combustible loading and alternate means of determining whether an abnormal condition exists during a postulated fire. The evaluation has also considered radiation zoning (ALARA considerations), safe shutdown equipment and likely ignition sources. The evaluation has indicated that early warning detection is not justified. Th,.3 b 4 a o., A kt. NJ.M of-N 0cakCe3 cc.sk...o M .c .F A follo,. g whp ,.) f di,,, h u< u.,

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HCGS FSAR 09/85 The fire pro ection status panel utilizes the Pyrotron cs Multilarm V m Itiplex system and is provided with two micro processor-base controllers, one normally on-line an'ided on the the other is on standby. A light emitting diode (LED) is prov panel for each alarm point and a desk mounted CRT,a,nd printer is provided to annu@iate each alarm. The CRT and F inter provides a 57 character mes' age for each alarm and the date and time is also included with ach message. 4 The fire protection st tus panel receives aJarm signals from the various local fire prot ction panels and ipstruments via transmitter / receivers ( 's) located neaf the local panel and instruments. Each T/R re eives the alarm signal via Class B sensor. wires which go to t e local fire,brotection panels and instruments. The T/R send the alarm gignals to the fire protection status panel via Class A ultiplex loop (communication line). If a short or single break occu s in the Class B sensor wires, a trouble alarm, for the T/R affec e', will be annunciated on the d 4 the fire /(a single break occurs in the I6 i fire protection status panel. Class A multiplex loop, otection status panel will i stillreceivealarmsignalsfor/an T/R and a loop failure alarm i will occur on the fire protect on s tus panel. b') I AL i () d 9.5.1.2.16 Emergency Lighting I See Section 9.5.3 for a d cussion of em gency lighting. 9.5.1.2.17 Communication System See Section 9.5.2 for a discussion of the HCGS communication system. i f 9.5.1.2.18 Pri ary Containment and Reactor Bui ding Enclosure Fi e Protection There are no pr visions for permanently installed manu 1 firefighting f cilities within the primary containment. The primary conta nment is inerted during plant operation. Rermanent dry standpip hose stations and portable extinguishers are provided at trategic locations throughout the reactor bub) ding and near th drywell entrances for fire protection of the drywell \\q i 9.5-24 Amendment 12

HCGS FSAR 09/85 i The fire protection status panel utilizes the Pyrotronics Multilarm V multiplex system and is provided with two micro processor-based controllers, one normally on-line and the other is on standby. A light emitting diode (LED) is provided on the panel for each alarm point and a desk mounted CRT and printer is provided to annunciate each alarm. The CRT and printer provides a 57 character message for each alarm and the date and time is also included with each message. The fire protection status panel receives alarm signals from the various local fire protection panels and instruments via transmitter / receivers (T/R's) located near the local panel and instruments. Each T/R receives the alarm signal via Class B sensor wires which go to the local fire protection panels and instruments. The T/R sends the alarm signals to the fire protection status panel via a Class A multiplex loop (communication line). If a short or single break occurs in the Class B sensor wires, a trouble alarm, for the T/R affected, will be annunciated on the fire protection status panel. If a single break occurs in the Class A multiplex loop, the fire protection status panel will still receive alarm signals any T/R and a loop failure alarm 4 g will occur on the fire protection status panel. Qro vv-9.5.1.2.16 Emergency Lighting See Section 9.5.3 for a discussion of emergency lighting. 9.5.1.2.17 Communication System See Section 9.5.2 for a discussion of the HCGS communication system. 9.5.1.2.18 Primary Containment and Reactor Building Enclosure Fire Protection There are no provisions for permanently installed manual firefighting facilities within the primary containment. The primary containment is inerted during plant operation. Permanent dry standpipe hose stations and portable extinguishers are j provided at strategic locations throughout the reactor building i and near the drywell entrances for fire protection of the drywell 9.5-24 Amendment 12 )

HCGS FSAR 09/85 i Three-hour floors, walls with Class A fire doors, and ceiling are provided for each CSR. Penetrations are sealed to equivalent barrier rating. Two remotely separated entrances are also provided for access to each CSR. l Redundant safety-related cabling in each CSR meets the requirements of Regulatory Guide 1.75, with exceptions stated in Section 1.8. Auxiliary shutdown capability is provided by redundant systems with cabling independent of both CSR in accordance with the requirements of Appendix R to 10 CFR 50. Fire dampers are provided in the supply and return air ducts. 9.5.1.2.21 Computer Room Fire Protection The computer room walls, ceilings, and floors are 3-hour rated. The computer room is provided with an automatic smoke detection l system that alarms locally and annunciates in the main control room. t The computer room is adjacent to the control room complex and shares the manual hose facilities provided for the control room complex, in addition to the portable extinguishers installed within the computer room. l,ud m SS4P 9.5.1.2.22 Class IE Switchgear Room Fire Protection l Early warning smoke detectors are provided in all switchgear l rooms and MCC and load center areas. Manual hose station and portable extinguishers are readily available. 9.5.1.2.23 Remote Shutdown Panel Fire Protection The remote shutdown panel is located in the remote shutdown panel room at the floor elevation 137 feet. Automatic fire detectors alarm locally, and alarm and annunciate in the main control room. Also, the room is provided with portable fire extinguishers, and a manual hose station is provided in the area. 9.5-27 Amendment 12

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HCGS FSAR 09/85 9.5.1.5.2 Fire Brigade Organization, Training, and Equipment The Hope Creek Fire Brigade will be comprised of dedicated I personnel from a six man trained fire fighting team capable of responding to a fire in either Hope Creek or Salem nuclear plants. At least three of the six man team will be sufficiently knowledgeable in Hope Creek safety systems to understand the i effects of fire and fire suppressants on safe shutdown i capability. The fire brigade will be provided with personal protective clothing, emergency communication equipment, portable lights and portable ventilation equipment. Portable extinguishers will be available throughout the plant. At least ten self-contained breathing units with a minimum of 30 minute rating will be available for fire brigade personnel. Additional self-contained breathing units will be available for control room personnel. At least two extra air bottles per unit will be located on site. In addition, a six hour supply of reserve air will be provided by I means of a breathingacompressor and stored air available to Salem 4 or Hope Creek stationhgp d The fire brigade training program will ensure that the capability to fight potential fires is established and maintained. The l program will consist of verbal classroon training, fire fighting practice and fire drills. Details of the training program are included in Section 13.2.2. 4 9.5.1.5.3 Administrative Controls 1 Administrative controls will be implemented at Hope Creek for the purpose of controlling combustible and hazardous materials, controlling ignition sources, controlling fire protecticn system impairments and testing fire protection equipment and systems. Procedures will be established for governing actions to be taken ,in the event of a fire for general employees, control room personnel, fire brigade members and other required support groups. Prefire plans will be written for all safety-related areas. 4 Administrative Procedures are available for review. Procedures will be implemented for all areas where new fuel is to be stored 9.5-38 Amendment 12

HCGS FSAR 09/85 prior to receiving fuel on site. The fire protection program will be implemented in its entirety prior to fuel load. 9.5.1.6 SRP Rule Review All differences and clarifications discussed below are differences and clarifications to BTP CMEB 9.5-1, Revision 2, dated July 1981. 9.5.1.6.1 Paragraph C.1.c.(2) Paragraph C.1.e.(2) requires that a single active failure or crack in a moderate-energy line in the fire suppression system should not impair both the primary and backup fire suppression capability. 4dw.smbb., c)h t At HCGS, automatic nd manual sprinkler / spray systems headers are connected to in-pla t loops that are fed from the main underground fire p tection water piping or yard loop by two separate lines. S nce the in-plant loops are fed by two separate supplies, they are considered an extension of the main underground yard 1 op. Except for the radwaste/ service area, elevator shaft, a d machine room for elevator 11-02 in the turbine building and elevator shaft and machine room for elevator 51-01 in the control area, the automatic and manual sprinkler / spray systems and hose stations serving a single area, including safety-related areas, have takeoffs from the in-plant loop, separated by sectional control valves normally locked open. The-header arrangement is such that by manual positioning of the sectional valves, no single piping failure can impair both the primary and backup fire water protection provided for a single ci.p.M.h poo c d,N <d b h.&d!bJ ap, o rm

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,4{, pia wda 4 See pe w In addition, he automatic : j, ::pp'. h set <Redst b a % c.g sm .,p,,.$Q. e n;._. ater sprinkler /spra / foam syst and fire water hose stations or hydrants serving the circulatin water pump structure and the non safety-related 1,000,000-gallon fuel oil storage tank located in the yard are each fed from the main underground yard loop by one feed line. A single break in the feed line can impair both the primary and backup fire water protection. A single failure of the fire water piping serving the above areas and buildings will not affect safe shutdown of the plant. HCGS is designed for separation of redundant safe shutdown trains to I I 9.5-39 Amendment 12

HCGS FSAR 09/85 t meet'the requirements of Appendix R to 10CFR50 to the extent noted in Appendix 9A. 9.5.1.6.1.1 Paragraph C.4 Paragraph C.4 requires that the quality assurance program of the contractors should ensure that the guidelines for design, procurement, installation and testing of the fire protection systems for safety related areas are satisfied. For HCGS, the fuel oil tank, the fire pumps and associated controls, and the fire protection water spray systems, the carbon dioxide systems and the early warning smoke and fire detection systems in safety related areas are covered under the fire protection quality assurance program ('F' program). The 'F' program was formally implemented, effective July 1, 1978. In view of that, certain fire protection system components purchased and installed prior to July, 1, 1978, such as the fire water storage tanks, the tank heaters and associated controls and the valve pit unit heaters are excluded from the 'F' program during the construction phase. They will be maintained under the "F" program after fuel is delivered to the site. 9.5.1.6.2 Paragraph C.5.a.(1) Paragraph C.5.a.(1). requires separation of redundant divisions or trains of safety-related systems from each other and from any potential fires in nonsafety related areas. HCGS complies with the requirements of Appendix R to 10CFR50 with regards to redundant division separation with deviations as noted in Appendix 9A, Section 9A.6.0. b.4Ted Pd.6 On. L u m m F3AR Wyu 3 5,M A w [ 3.5. %. Au p6 4 f,,t kuk -Asm on 3b 1 9.5.1.6.3 Paragraph C.S.a.(3) bA % a- - \\*" "" ' " " *( ~ " C 3 9 l 9.S.G ed S S.3 o p, p %.. i A c q Paragraph C.5.a.(3) requires that openings inside conduit larger than 4 inches in diameter be sealed at the fire barrier penetration. Openings inside conduit 4 inches or less in diameter should be sealed at the fire barrier unless the conduit extends at least 5 feet on each side of the fire barrier and is sealed either at both ends or at the fire barrier with noncombustible material to prevent the passage of smoke and hot gases. 9.5-40 Amendment 12 1 __-.-..,._,,,,,.,__,._,__,-.,,m _._,,.,_,_,,--_...___.,r, _-_..__..,,.,____._.-_.,,,-,___m.__ ._.m__--. _,,

HCGS FSAR 09/85 At HCGS, all conduits with exposed ends which enter or exit a room through a fire barrier a-e sealed against fire and the passage of smoke and hot gas-t. Openings inside conduit 4 inches or less in diameter that extend less than 5 feet on either side of a fire barrier and open inside conduits exceeding 4 4 4 inches in diameter regardless of its distance from the fire barrier are sealed on one side only with at least 7 inches of silicone foam at the fire barrier, or at the first junction box lj or open end closest to the fire barrier. Openings inside conduit 4 inches or less in diameter that extend 5 feet or more from both sides of the fire barrier are sealed on both sides of the fire l barrier at the first junction box or open end with at least 4 inches of silicone foam. Conduits terminating in equipment are not sealed. l 9.5.1.6.3.1 Paragraph C.5.a.(3) l 4 Paragraph C.5.a.(3) requires that openings in fire barriers for pipe, conduit and cable trays which separate fire areas should be sealed or closed to provide a fire resistance rating at least equal to that required of the barrier itself. [Vi At HCGS, the non-segregated phase bus ducts from the station service transformers penetrate through various 2 and 3 hour fire 3 barriers in the turbine and auxiliary buildings. The penetrations are sealed with fire barrier material between the wall openings and the outside of the bus duct, but the ducts are i not sealed internally at each fire barrier penetration with fire sealaht material. For fire barriers which do not separate safe shutdown equipment, safe shutdown of the plant will not be affected, even if a fire did spread to both sides of the i barriers. See Appendix 9A for discussion of the duct penetration in fire _bar_r_iers_th_at separate safe shut wn arman. W,, 7-Feet by 74At, a.idTW H~ h/ tt-Fa:t ) /Siy j Also, at elevation 137 feet of the turbine building there are six 12-feet by 10-feet openings in the 3-hour fire rated floor between the moisture separator areas and the candenser area Mow. rne openings are provided for the turbine) combined intermediate valves (CIV's) and associated pipinf rand are also used for ventilation. Since the moisture separatdr areas and l condenser area do not contain any safe shutdown equipment, a fire j n these areas will not affect safe shutdown of the plant. mond'We 6CP rator p,pq, o.nd. o.ccess b e6f forms belo@ 9.5-41 Amendment 12 i L

HCGS FSAR 09/P5 encountered. However, the manufacturer of the diesel engine has stated that by using a suitable diesel fuel oil no problems for diesel engine starting and/or operation would occur due to the outdoor installation of a fuel oil tank which could be subjected to temperatures as low as -40F. The diesel manufacturer has stated that fuel oil number 2 or 1 or a mixture can be used without affecting normal starting or operation of the diesel fire pump. The fuel oil selected is suitable for use at temperatures less than the worst ambient temperatures expected at the HCGS site?V The fuel oil day tank installation has been approved by i"**' "}cNe*b 5$,, encyre %.pcchon, o f rue Fac\\ sue?dcllhe h- -VM by L & = ^ !^^:; as Trov wsW 'i g % ; f +/ M % cill p N reduiresNINtNhewastewaterlinefromthedieselfire pump heat exchanger discharge into a visible open waste cone. At HCGS, the diesel fire pump waste water line does not discharge to a waste cone, but it does discharge to an equipment drain in such a way that the water flow into the drain is visible. The pump test flow meter and test manifold are installed in series in the same test line. Though NFPA 20 does not contemplate installation of the test flow meter and test manifold in the same line, the installation will provide a way to accurately measure the pump discharge water flow by either device. The installation of both measuring devices in series in the same line has been approved by the insuring authority. 9.5.1.6.17.1 Paragraph C.6.b.(7) l Paragraph C.6.b.(7) states that hydrants should be installed approximately every 250 feet on the yard main system. H At HCGS, hydrants are provided on the yard main system, but in some areas, the distance between hydrants is greater than 250 {- feet. The hydrants are located to provide coverage of the outside walls of the power block, major yard buildings, and various yard areas where combustible materials may be located. l An effective hose stream can be provided to any yard location. In addition, the fire brigade has available on site a pumper i. truck which can be used to extend coverage of outside hose 4 stream. l l l m \\ 9.5-50 Amendment 12

HCGS FSAR 09/85 The sign'ificant deviation from NFPA 13 and 15 are as follows. l l l a. Sprinkle systemsOWS1,OWS5,OWS6)OWS8,OWS14,OWS16,

OWS17, WS4-5, eWS13, OPS 2, OPS 3, (PS I, 7 PS2,7PS6, IMPS 9, TPS14-16, TD8, and N 9 do not cover the entire area within their respective fire zones.

This is acceptable as these systems were designed to protect specific hazards such as oil piping, strectural steel above high cable concentrations, and oily weste sumps. In addition certain systems did not extend to areas above water sensitive electrical equipment. Sprink1)erisers and or local panels for system kPS1, b. l -tPS2, US3, OPS 3, OWS10, OWS11, OWS14 are located within the fire hazard areas. This is acceptable as each system is either in a non safety-related area, a remote facility (fire pump house, circulating water pump structure, or service water intake structure) or a limited coverage system in a larger fire zone. In addition, remote shutoff val es are provided. .i 9.5.1.6.21 Paragraph C.6.c.(4) Paragraph C.6.c.(4) requires individual standpipes be at least 4 inches in diameter for multiple hose connections and 2 1/2 inches in diameter for single hose connections. ? At HCGS, all standpipe connections to the in-plant loop are 4 ~ inch diameter for standpipes feeding multiple hose connections. s x., See Figures 9.5_13 through 9.5-18. But branches off the standpipes, that feed two or less hose connections, are 3 inches c, _ 3 in diameter except in one instance where three hoses are s/ connected to a 3 inch branch. These three hose stations are'not all on the same floor and could not all be used to fight the same fire. This 3 inch branch has been evaluated and found acceptable to meet NFPA 14 pressure and flow requirements. As stated in Section 9.5.1.6.19, the fire water supply can provide water at the required flow and pressure to supply any sprinkler or deluge system and all the hoses which can be used to fight the same fire. Paragraph C.6.c.(4) requires that the interior manual fire water hose installation should be able to reach any location that contains or could present a fire exposure hazard to safety-related equipment with at least one effective hose stream. To l 9.5-54 Amendment 12

HCGS FSAR 09/85 i s accomplish this, hose connections should be equipped with a s . maximum of 100 feet of fire hose. At HCGS,'certain fire hose stations are provided with an additional 50 feet of hose which is not connected and is stor.ed near the fire hose station. In the unlikely event of a fire, the additional hose will be used to reach certain areas where a 100-foot hose will not reach. Ee.7e of tt.ese eceos oci required for esfe chutie.. fvlivwing a. fire. The hose stations which are provided with-the additional hose are IEHR400 and 1HHR400 at elevations 54 feet and 77 feet of the auxiliary building-control i area, respectively; 1RHR200, IVHR200, 10HR20G, and.1AHR202 at i elevations 132 feet, 162 feet, and 178 feet-6 inches of the reactor building, espectivelyWand 1AHR500 and 1BHR500 at elevation 100 f t.of the intake structure. The additional hose would be used o reach the back part of RPS motor-generator set room an ch unoccupied spaces 5124 and 5234 where nonsafety-r cable trays are located at elevations 54 and 77 feet of e auxiliary building-control area. Also, the,sdditional hose would be used to reach the area behind the FRVS recirculating units at elevations 132 feet, 162 feet, and.17S feet-6-inches of the reactor building; to reach the back part of the containment pre-purge clean-up room at elevation 162 feet of the reactor Ci buildin and to reach the traveling screen motor area at elevatio 114 feet of the intake structure. See Figures 9.5-1, 9.5-2, .5-4, 9.5-6, 9.5-7, and 9.5-11 for hose station-f. o'ch % h 17A of S w.% %v 5 rad O A Sv " "% j ro r w% blot-ty.pe.4-bd A<cq. 34AI Even with the additional lengths of hose, there is adequate pressure to provide a water flow equal to or greater than what is required in NFPA 14 and stated in Table 9.5-18. l 9.5.1.6.22 Paragraph C.6.c.(4) Paragraph C.6.c.(4) requires that provisions be made to supply water at least to standpipes and hose connections for manual firefighting in areas containing equipment required for safe plant shutdown in the event of a safe shutdown earthquake (SSE). The firewater piping serving such hose stations should be analyzed for SSE loading, and should be provided with supports to ensure system pressure integrity. AT HCGS, the hose station standpipes and the firewater piping feeding the standpipes inside the plant buildings meet the requirements of ANSI B31.1, but the piping is not analyzed for O SSE loadings, and therefore, is not Seismic Category I. No 9.5-55 Amendment 12 =.

HCGS FSAR 4/84 for diesel generator operation. In this case, the affected diesel generator would be taken out of service. If no fire has occured, the diesel generator can be brought back into service after the carbon dioxide has been removed from the room and the carbon dioxide system and fire dampers have been reset. The diesel generator rooms are separated from each other and other parts of the plant by 3-hour fire barriers. For the diesel area, HCGS meets the requirements of Appendix R to 10CFR50 to the extent noted in Appendix 9A. Any discharge of the carbon dioxide system due to a fire or an inadvertent operation, will not prevent safe shutdown of the plant because the other three diesel generators will be available. 9.5.1.6.31 Paragraph C.7.j Paragraph C.7.j requires that diesel fuel oil tanks with capacity greater than 1,100 gallons should not be located inside buildings containing safety-related equipment. At HCGS, two 26,500 gallon diesel fuel oil storage tanks are located in each of the four fuel oil storage tank rooms at floor elevation 54 feet of the diesel area. Each room is enclosed by 3-hour fire barriers and the diesel area is separated from the control area by a 3-hour fire wall. The diesel generators are located two floors above the diesel fuel oil storage tank rooms. Separating floors and main structural members have a fire resistance rating of 3-hour. Drains are provided to remove possible oil spills and water discharged during deluge system operation. Each room is diked such that it can hold fuel oil spilled from one entire tank plus thirty minutes of water flow from the manual deluge sprinkler system. An automatic CO, total flooding system is provided in each diesel fuel oil storage tank room. Manual deluge system and water hose stations are provided as a backup fire suppression system. Fire and smoke detectors are also provided in each room. 2. Although the combustible loading in the diesel fuel oil storage tank rooms is 7,100,000 Btu /ft of floor area, oxygen depletion can restrict the fully developed period of any fire event to approximately 5 minutes. 9.5-61 Amendment 5 i I

=-. I l HCGS FSAR 4/84 7 for specific creas. Although detection has been provided in the access corridors to the gaseous and liquid radwaste areas below floor elevation 87 feet, no detection or automatic fire suppression has been provfded for the individual tank, filtration, separator, pipaway and pump areas. Provisions for detection and automatic fire suppression systems throughout these area o ld not sufficiently increase the level of fire safety to be sti ied due to the restricted access and lack of fixed and tr sei t combustibles, as indicated in the fire hazard i ana See Appendix 9A for HCGS's fire hazard analysis. 2( 9.5.2 COMMUNICATIONS SYSTEMS 9.5.2.1 Desian Bases The communication systems have no safety-related functions. Various communication systems are provided in the plant to ensure reliable communication. These systems and their design bases are: a. An intraplant, five-channel, page-party, public-address (:.;.. intercom system to provide onsite communication between various plant locations b. An automatic telephone system from the plant to the telephone company switching facilities to permit plant-to-offsite communication on a continuous basis c. A two-way radio communication system to provide communications between onsite and offsite locations d. A two-way radio communication system for inplant personnel with the capability for communication during a fire. 9.5.2.2

System Description

9.5.2.2.1 Public Address System The intraplant public address (PA) system is a five-channel, f' independent, page-party communication system, consisting of ( telephone handsets, amplifiers, and loudspeakers located at 9.5-63 Amendment 5

HCGS FSAR TABLE 9.5-1 Page 1 of 2 NATIONAL FIRE PROTECTION ASSOCIATION STANDARDS Number Title 10 Installation of Portable Fire Extinguishers A Maintenance and Use of Portable Fire Extinguishers aut Cebane<L A ent Systed. Il Low 65 pen.nsto n Fo.m ~$~ '2 Carbon Dioxide Extinguishing Systems 12A Halon 1301 Fire Extinguishing Systems 13 Installation of Sprinkler Systems 13A Maintenance of Sprinkler Systems 13E Fire Department Operations in Properties Protected by ~ Sprinkler and Standpipe Systems 14 Standpipe and Hose Systems 15 Water Spray Fixed Systems 23 _ Centrifu al Fire Pumps

• 22.

Wic( o.nks For Petyst.ie Fire Protedto A-24 Outside Protection ~ 27 Private Fire Brigades 30 Flammable and Combustible Liquids Code 37 Combustion Engines and Gas Turbines 50A Gaseous Hydrogen Systems ['70 Mo.fie%l GledocM Cod 6 71 Central Station Signaling ~ Systems 72A Local Protective Signaling Systems 72D Proprietary Protective Signaling Systems 72E Automatic Fire Detectors 75 Electronic Computer Data Processing Equipment 78 Lightning Protection Code 80 Fire Doors and Windows 4 .r,.. _~--.-,,._,._v,,,--7, m.

HCGS FSAR TABLE 9.5-1 (cont) Page 2 of 2 Number Title 90A Air Conditioning and Ventilation Systems 91 Blower and Exhaust Systems 92M Waterproofing and Draining Floors 204 Smoke and Heat Venting Guide 321 Classification of Flammable Liquids 0' 5 "#rl:;; re-c. Pl:nte b t w

HCGS FSAR 09/85 l TABLE 9.5-2 (cont) Page 2 of 5 System Used Area or Equipment Covered Automatic wet pipe Fire pump house sprinkler systems, All areas l ordinary hazard occupancy pipe Guardhouse schedule, except Lobbies and corridors as noted Waiting and screening area offices Conference rooms Security administration rooms Storage rooms Health physics room and office Lunch room Mechanical rooms Whole body counting room 1 Automatic preaction Turbine building sprinkler systems, Equipment unloading area, elevation ll ordinary hazard 102 feet occupancy pipe schedule, except Exposed turbine-generator lube oil as noted piping above operating floor (hydraulically designed) Auxiliary building Elevator numbers 51-01 and 51-02 (control and diesel areas) Truck bay area Solid radwaste drum storage area Cable spreading room (safety-related, l hydraulically designed) Corridors 5207 and 5237 (safety-related, hydraulically designed) Electrical accesses 3204, 3425, 5339, and 5401 (safety-related, hydrauli-ll cally designed) Cable chases 5531, 5532, 5533, and 5534 including vertic. rtions of ll chases (safety '-rersted, hy e ally H&V chase 55(3 Ecty-rebAt ) designed) _ydraulically designed) Reactor building Motor control center area 4201 (safety-related, hydraulically designed) Corridor 4301 (safety-related, hydraulically designed) Amendment 12 l

p HCGS FSAR 09/85 l TABLE 9.5-2 (cont) Page 3 of 5 -System Used Area or Equipment Covered Circulating water pump structure Circulating water pump rooms Intake structure l Service water pump room (safety-related) 1 Automatic water spray Turbine building . systems, hydraulically Motor generator units designed Hydrogen seal oil unit Lube oil receiving storage tank Tu gina M--in; nd 5 ~i-i nn E__ / Turbine lube oil reservoir and purifier Yard Main transformers Station service transformers Circulating water pump structure transformers Auxiliary building. TSC emergency supply charcoal filters l Radwaste tank vent. charcoal filters l -Manual water spray Aux'iliary building Control room emergency supply charcoal l systems, hydraulically designed filters (safety-related) l Manual preaction Reactor building FRVS charcoal filters (safety-aterspray sys~ hydrAvhcAlly desg, nM related) FRVS vent unit charcoal filters (safety-related) Drywell prepurge cleanup charcoal filters I Wet standpipe and hose Entire plant stations Near stairwells, exits, and other points accessible to personnel Wet standpipe and Reactor building hose stations Near stairwells, exits, and other maintained in a dry points accessible to personnel condition Amendment 12 l . _ _ _ ~ _, _.

.~ HCGS FSAR 09/85 l TABLE 9.5-2 (cont) Page 4 of 5 System Used Area or Equipment Covered Intake structure Near stairwells, exits,.and other points accessible to personnel Manual deluge-systems, Auxiliary building hydraulically designed Diesel fuel tank rooms (safety-related) Control equipment room mezzanine (safety-related) Manual mechanical 1,000,000 gallon - fuel oil storage tank foam system outdoors (stores fuel oil No. 2) Carbon dioxide systems Auxiliary building (automatic total Diesel generator fuel oil tank flooding with time delay rooms (safety-related) and manual override) Diesel generator rooms (safety-related) Control equipment room mezzanine (safety-related). Carbon dioxide system Turbine Building (automatic local Oil piping inside generator application) exciter-housing. Manual Halon Auxiliary Building '(local application) Main Contro1 Room Control ~ Conaare pit' x ( kd Automatic Halon 1301 Guardhouse k total flooding systems Under raised floor of room number 1 l Administration facility QA vault l Carbon dioxide hand Turbine building hoses Switchgear rooms Around main turbine-generator Near motor control centers Amendment 12 l i ,n -...

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. - - = / HCGS FSAR 09/85 l TABLE 9.5-2 (cont) Page 5 of 5 i System Used Area or Equipment Covered Auxiliary building Auxiliary building wing areas Control panel and instrument racks area near. gaseous radwaste (ele-vation 54 feet) Cable tray area (elevation 87 feet above radwaste) Near motor' control centers Electrical chase areas with safe egress (safety-related) -Portable fire Entire plant site (excluding adminis-extinguishers 0) tration facility and guardhouse) y Con types All normally accessible areas where there are small Class B & C hazards Dry chemical type . (,. All normally accessible areas where l there are large Class B & C hazards, such as large motors, batteries, and ] combustible liquids l Halon 1211 type Control room (safety-related) Computer room Remote shutdown panel room (safety-l related) Solid radwaste control room Pressurized water type (Chss A ba.wds) Reactor building and intake structure.i. r--- =h r-th::d" -' art =Ctass-A.'._z fr ? / Administration facility and guardhouse Multipurpose dry chemical type All normally accessible areas (1) Portable fire extinguishers are not provided for Class A fire hazards except as noted. Fire water hose stations will be used for Class A fire hazards. Amendment 12 l

HCGS FSAR 09/8 5 l TABLE 9.5-3 (cont) Page 5 of 5 l Approximate i BatmIlal Descristipo Quentity Plant Location Condition of Use Time of Use sodium bisulfite Dne 250 gal. Yard - circ water Solution 15 by wt continuous tank at 11 pump house soln store approx 10-50 lb bags dry ruel cil no. 2 2-26,500 gal. Diesel generator Atmospheric During emergency l tacks in each building elevation 54' diesel generator l room room nos. 5107, 5108 operation i 5109, 5110 l ruel oil no. 2 550 gal day Diesel generator Atmospheric During emergency l tank building diesei generator l 4 elevation 102' operation i room nos. 530~, 5305 l 5306, 5307 l Fuel oil no. 2 1,000,000 gal Yard-adjacent to Atmospheric During auxiliary l I Delaware River boiler operation l j -{ Fuel cil no. 2 18,000 gal Yard-ad jacent Atmospheric During auxiliary l tank auxiliary boiler boiler operation l building i I Fuel cil no. 1 280 gal tank Yard-adjacent to Atmospheric During diesel l cr no. 2 fire pump house driven fire pump l operation l Halon 1301 120 pounds Guardhouse' - electrical 360 poi During fire l equipment room emergency l Halon 1301 160 pounds Administration facility 360 psi During fire l technical document emergency l room vault l g gggkg %s 268 poMS gpf,gog pound 4[7(_rt^r pj{ Auxiliary building - (i-s-.F jghp f3sg Durir.g fire l ] Halon 1301 c-r 2:: f, control area - control emergency I room complex (peripheral l { room) l 1 (a3 Air receiver tanks at less than 125 psig pressure are not listed. l j Amendment 12 l i

HCGS FSAR 09/85 TABLE 9.5-19 page 1 of 7 SAFETY RELATED AREAS WITHOUT DETECTION ELEV. FT-IN. ROOM DESCRIPTION Auxiliary Buildino - R/W Service Wino Area 054-0 3110-1 Sample station 137-0 3507 Janitor's room 145-0 Emergency vent stack Reactor Buildino 054-0 4101 Torus water cleanup pump room 054-0 4102 Torus compartment (cable trays with safety related cable have linear thermister detection.) -M i10 F - C0'.*, ^,L e ...y....a su;,

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054-0 4115 CRW/DRW pumps and sump room 077-0 4204 Vestibule 077-0 4206 Vestibule Amendment 12

,. m I .e-AJA d rwing m - s ola, ru o to P6AE as Fi$vre 45-35 h 4 -M ~ 4 eeen. + 4 w., w=~- b

e IICGS FS%R 11/H5 l TABLE 1.11-1 (cort) Page 21 ot 30 l Summary FSAP Section (s) SRP Specific SRP Descriptior, of Where Section Acc;ggggggg_ Criteria D i f f er er.ces Discussed 9.5.1 II.2 e. 5.1. 6 (Pev 3) All criteria paragraphs listed hereunder relate to BTP CMEB 9.5-1, Rev 2, 7/81. C. t.c (2) requires that single HCGS complies with this requireme-t ac-ive failure or crack in fire except for the auxiliary buildino - protection piping should not radwaste/ service area, elevator shaf ts, impair both the primary ar.d ar.d machine rooms for elevators 11-02 backup fire suppression capattiity and 51-01 in the turbine and auxiliary buildings, circulating water pump structure, ard the 1,000,000-gallon fuel oil storage tank in the yard area. C.4 requires that the quality HCGS complies with this requiremeat assurance program of the Con-for the fuel oil tank, the fire pumps tractors should easure the ard associate 1 cortrols, the fire guidelines for design, pro-protection water spray systems, the curement, installation, and carbor dioxide systems, ard the early testing of the fire protection warnirg smoke and detection systems systems for safety related areas in safety related areas. However are satisfied, the quality assurance program ('F' prog ram) was formally implemen-ted ef f ective July 1, 1978. Ir view of that certain fire system comparents purchased ard installed prior to July 1, 1978 such as the fire water storage tanks, the tank heaters and associated coctrols, and the valve pit heaters are excluded from the 'F' programr U(I dhg CCO M rdIiOA h 56. C. 5.a (1) requires separation of See FSAR Appendix 9A for ) D OM h e. 'F"O will bc OS(.gcr redundant divisions or trains description of differer.ces of safety-related systems from this requirement. ppm g cr pqgg ,g dehvered to ne s i+c Amendment 13 l

e HCGS FSAR 11/85 l T ABLE 1.11-1 (coS.t) Page 22 of 30 l Summary FSAP SectioS (s) SRP Specific SRP Desc*iption of Where _StC11on_ Acceptance Criteria Differences Discussed C.5.a.(3) requires openings for Some oper ings in fire barriers are not piping, conduit ard cable trays in seal ed, i.e., inside non-segregated 1 fire barriers be sealed phase bus ducts and openirgs ir turbine operating deck for turbire CIVs. Also see FSAR %pperdix 9A for additional dif ferences f rom this requirement. C. 5.a. (4) requires that penetration Some penetration openings for openings for ventilation systems ventilation systems are not in fire barriers be provided with provided with fire dampers. fire dampers. Also see PS4R Apperdix 9A for addit ional dif f erences f rom this requirement. C. 5.a (5) requires door openings HCGS complies with this requiremert in fire barriers be protected ari provides Urderwriters' a with equivalently rated doors, Laborator ies (UL) or Factory Mutual frame and hardware (FM) labeled doors for all openings except for those operir.gs that exceed the matimum available UL or FM label doors size. UL Certificate of Inspection is provided for oversize fire doors. C. S.a (8) allows orly ore Both safety divisions are redundant safety division in one cable spreading room, per cable spreading room. C. S.a (13) requires outdoor The transformers are less oil-filled transformers to thac 50 feet from buildiaq j be located at least 50 feet walls. All wsils facing from building walls, or if t ransformers have fire withir 50 feet, adjacent resistarce rating of 2 hours building walls shall have and are r ot entirely f ree no openings and have a fire of opeairqs. rating of at least I hours. C.S.b. requires one safe shutdown See FSAR Apper dix 9 A f or trair be free of fire damage description of differences by separation of redur dant from this requirement. shutdowr trains by 3-hour fire s' barrier or other alterr.ates. b 11645/1 /1 - 2: Amendment 13 l

[ In s Cri (k bY s mwa r v T> esceirhow 'a pecipis S R f' o c m,PFerences j hCc&phis-nC6 Cr t$CfIL C. s. c ree ou ees one See F sAR G.ppen be qA use h v+Aown + be gree oP Gsrc $ m Sor A escrop-hon crf d u Vferexa myc pron. ns rm u u rem u+.

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HCGS FSAP 11/HS -l F%BLE 1.11-1 (cor t) Page 23 ot 30 l Summary FSAP Sect ion (s) SRP Specific SRP Description of Where . M 1_on. MCestance Critegia Differences Discussed C. 5.e (2) requires redundar.t See FSAP Apperdix 9A aafety-related cable system outside for description of dif ferences the cable spreading room to be from this requirement. separated from each other and from potential fire exposure hazards by 3-hour fire barrier or provided automatic water systems. C.5.e (2) requires that continuous line-type heat reiundert safety-related detectors are : ot provided. cable trays outside the Instead, photoelectric and spreading rooms to be pro-ionizatior. detectors are vided with continuous installed in areas where line-type heat detectors. safety-related cable trays are located. C. S.e (2) also requires that fety elated cable trayu safety-related cable trays are rovided with a shall be protected from water suppression system. potential exposure to fire by an automatic water suppression system where a fire could occur. Paragraph C.5.f (1) requires Im s generally uses normal smoke and corrosive gases to vestilation system to remove be discharged directly outside smoke and gases. A separate and separate smoke and heat smoke system is provided vents be provided for certain for control area. areas. C. 5.g. (3) states that a HCGS has no specific fixed emergency communica-emergency communication tion system independent of system irtended solely the normal plant communica-for emergency situations. tion system be installed at pre-selected stations. l L er t [ Amendment 1J l

o NCGS FSAR 11/85 l TABLE 1.11-1 (cont) Page 24 of 30 l Summary FSAR Sectior (s) SRP Specific SRP Description of Where Section. Accentance Criteria Differences Discussed C. 6.a (2) requires that fire Areas required for initial hot detection systems comply shutdown outside the reactor building with NFPA 72D, Class A and most areas of the reactor building, systems. except the new fuel storage area, spent fuel pool, ard above the cask loading pit, are provided with a class A fire detection system. All other class B fire detection s ystems. In addition, the operatior and supervision of the fire protection system is not the sole function of the plant operator. C.6.a (3) requires that Location of early warning the fire detectors be ir. stalled fire and smote detectors was in accordance with NFPA 72E deteraired bV Ib dccffg SvMg I urder the direction of Ig o p) a._,..... fire rotect or ergineer. g g (g C.6.a (6) requires that Secordary power is provided secondary power supplies for for motor operated valve, electrically operated control which is iscorrecte durin httdto/\\ Sgie gao 1/Ac power, valves be provided p9r NFPA 72D. a IDCA. \\SO jrg fgg afw p bb is suePhe w N Upt C. 6.b (6) requires that Fire pump installation conforms fire pump installatior cor. form to NFPA 20 except the diesel to MFPA 20 fire pump fuel oil day tark is located outside and is subject to f reez ing, and the waste water lire f rom the diesel fire pump heat exchanger is r.ot provided with a open waste cone. Also, the pump test flow meter ard test marifold are irstalled in series in the same test line. C. 6.b. (7) requires that hydrants Hydrants are provided on the be irstalled approximately every yard mair, but in some areas 250 feet on the yard main system the distance between hydrants is greater thar 250 feet. Amendmer t 13 l

Sed .Ln scY 6 V4 Ifl / S ec#re gRf' Summary bescrigh p Accephncs Critenp 4 Di #6erences C. /,. 6. (C pq ui ecs At A (emk n +he &c i &du rc m o ne bc mfer evme sucha pipe sh>r%e ta wk or its. g r ei ng and e t&er Owr water sho o \\1 n ot cause bo+h-s-vre c -sak. autol %ks to drath ca.usc loss cewefte. %m botlr k&.nkik 7,.. g.G 7:. C. (o. c GD rca vires At M FPA dev hvc i bc) water exhng uisLg been d en b Cica m.nd. eyecms coyn ply w in &c evalunted. Sgn,91eut m.p e ro p rtotPc W PPA Shndard devichons are idenhAd in F.s A R. .kw 4 -. gy ' / ~ -- w w -p&& sip - +an .+eer eh eM- -=- o we. g iw.--o, w-m

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8 4 HCGS FSAR 11/p5 l TABLE 1.11-1 (cont) Page 25 ot 30 l Summary FSAF Rect ior (s} SRP Specific SRP Descriptien of Where Sect h ACCSEMBCe Criteria Differences Discussed C.6.c. (2) requires that al! Administrative 1y controlled, locked valves in the fire protection valves are irspected mo-thly and water system be periodically electrically supervised valves are checked to verify position rot periodically checked because they in accordance with NFPA 26. are constantly monitored. C.6.c. (4) requires that interior At HCGS, certain hose stations are fire water hose installations be provided with an additional 50 able to reach any locatior that feet of bose that is not connected contains or could present a fire ar.d is stored rear the fire hose exposure hazard to safety-related statior, which will be used to reach equipment with at least ore certain areas where 100-foot hoses ef fective hose stream using a will rot reach. maximum of 100 feet of hose. C.6.c. equires individual HCGS provides 4-irch in standpipes should be at least diameter stardpipes feeding 4-inches in diameter for multiple hose connection, multiple hose connections. but branches off standpipes feeding two or one hose conr.ections are 3-inch ir diameter. C.6.C. (4) states that Firewater piping to hose provisions should be made stations and standpipes are to supply water to at least not analyzed for SSE load-standpipes and hose con-ings.and no cross-connectio" nections for manual fire - to a normal Seismic Category I fighting in areas cortaining water system is provided. equipment required for safe plant shutdown in the ever.t of an SSE. Piping serving such hose stations should be analysed for SSE loadings. c.7.a. (1). (C) requires that No fire protection systems the primary containment are provided in the contain-should be provided with fire ment drywell. I detection systems including backup, general area, fire detection capability. d Amendment 13 l

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% mwary hseophon kccc0anieCrthveL o& h&G erences x C. 4. b. (u) req v i res &c 1046 9. 6-18 .ht h te We 9we wAcer supply m1n t wou ad odud sko A A be c.alc.vided o n. hosc stren m Alows basts e& the 6veest availoJole I2or all eypeyek C\\ow 9<an sennkJer kycnv 6 cally. c essnck spy plu s sooggm 4or sprin k ler sp.s&m.j _ p ~ hose strea m.s ... Q ..,. a 9 .-.i... pm (* $1,',;- 9 -.,m .,m.

O e e e HCGS FSAP 11/85 l TABLE 1.11-1 (cor.t) Page 26 of 30 l Summary FSAR Section (s) SRP Specific SRP Description of Where .Sectigg_ 4_- Critegia Differences Discussed a' C.7.b requires that venti-HCGS has fire dampers in the lation openings between return air ducts of the peri-control room and peripheral pheral rooms, rooms shall be provided with automatic smoke dampers. C.7.b also requires peri-No automatic water suppressior pheral rooms in the control is provided ir peripheral room complex to be provided rooms of the main control with automatic water room complex. suppression. C.7.b also requires that Smoke detectors are only smoke detectors be provided provided in cor. trol room ir. the control room cabinets cabirets and consoles that ard consoles. irclude redurdant safe shut-down equipeert. C.7.c requires primary HCGS provides an automatic fire suppressic,n in cable carbon dioulde ir the spreading room be an control equipmert mezzanine automatic water system, room (cable spreadir.1 room) at floor elevatioa 1M feet h (Y) ant)A,l QJCLkCl* C, UK -6 Laches of control area. C.7.c (2) requires aisle Main access aisles are M' I6 N I bg gjp. separatios between tray stacks l es s tha* 3 feet wide and i Er cable spreading room te a feet high in some areas \\ at least 3 feet wide and of cable spreading rooms. 8 feet high. C. 7.c (5) requires continuous contiruous line-type heat line-type heat detectors for detectors are not provided, cable trays l'iside the cable Irstead, photoelectric and spreading room. ionization detectors are 7 irstalled in areas where saf ety-related cable trays are located. C.7.f requires redundant safety-See Apnendix 9A for description related panels remote from the of differences from this requirement. control room complex t'e separated from each other by a 3-hour fire barrier. = Amendment 13 l ^

e 1-HCGS FSAR 09/35 l Responses Not applicable. The HCGS drywell is inerted. Therefore, there are no standpipes or hose stations inside the drywell. III.D.4. For BWR drywells, standpipe and hose stations shall be placed outside the drywell with adequate lengths of hose to reach any location inside the drywell with an effective hose stream.

Response

Comply. Standpipe with hose stations have been provided. See FSAR Section 9.5.1.2.18. III.E. Hydrostatic Hose Tests Fire hose shall be hydrostatically tested at a pressure of 150 psi or 50 psi above maximum fire main operating pressure, whichever is greater. Hose stored in outside hose houses shall be tested annually. Interior standpipe hose shall be tested every three years.

Response

Comply. Details of procedures w described in FSAR Chapter 16, Technical Specifica ns. III.F. Automatic Fire Detection 1 Automatic fire detection systems shall be installed in all arear 1 of the plant that contain or present an exposure fire hazard to safe shutdown safety-related systems or components. These fire detection systems shall be capable of operating with or without offsite power.

Response

Comply. All plant areas with a combustible loading greater than 8000 Btu /fta that present an exposure fire hazard to safe 9A-8 Amendment 12 l (

HCGS FSAR 09/85 l

Response

Comply. HCGS will comply with the fire brigade organization training and equipment requirements of BTP CMEB 9.5-1, Revision 2, and Appendix R to 10 CFR 50. The_ detail discussion of fire brigade organization and equipment 511 bc de> eloped ;dl'} provided in FSAR Section 9.5.1.5.2 15 III.I. Fire Bricade Training Requirements for training of fire brigade members.

Response

Comply. The training program will be deve provided in FSAR Section 9.5.1.5.2 III.J. Emeroency Lichtina Emergency lighting units with at least an 8-hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment, and in access and egress routes thereto.

Response

Comply. Eight-hour battery-powered lighting is provided for safe shutdown operating areas and access and egress routes. III".K. Administrative Controls Establishment of administrative controls to minimize fire hazards.

Response

Comply. HCGS will comply with the administrative controls requirements of Branch Technical Position (BTP) CMEB 9.5-1, Revision 2, and Appendix R to 10 CFR 50. The administrative 9A-11 Amendment 12 l 1

HCGS FSAR 09/85 l W controlsprocedurewi-i-1 lid;; clepe {_3.ffprovidedinFSAR 3 Section 9.5.1.5.3 i III.L. Alternative and Dedicated Shutdown Capability i 1 III.L.la. The alternative or dedicated shutdown capability provided for a specific fire area shall be able to achieve and maintain subcritical reactivity conditions in the reactor, maintain reactor coolant inventory, achieve and maintain hot shutdown conditions, achieve cold shutdown conditions within 72 hours, and maintain cold shutdown conditions thereafter.

Response

Comply. The areas for which alternative shutdown capability is provided are listed in Table 1 of the attached responses to NRC Generic Letter 81-12. The reactor shutdown is the same as a normal shutdown from the main control room, but will use controls and instrumentation located at the remote shutdown facility, the diesel. generator control panels, and at equipment operating areas. III.L.lb. During the postfire shutdown, the reactor coolant system process variables shall be maintained within those predicted for a loss of normal ac power, and the fission product boundary integrity shall not be affected.

Response

Comply. Process variables for a reactor shutdown from the remote shutdown facility and equipment operating areas will be maintainedgthe same as during a shutdown from the main control room. ,III.L.2. Performance goals for the shutdown functions. III.L.2.a. The reactivity control function shall be capable of achieving and maintaining cold shutdown reactivity conditions 9A-12 Amendment 12 l 4

HCGS FSAR 09/85 l limited so that the systems can be made operable and cold shutdown can be achieved within 72 hours. Material for such repairs shall be readily available onsite and procedures shall be in effect to implement such repairs. If the equipment and systems comprising the means to achieve and maintain cold shutdown conditions (and which are used prior to 72 hours after the fire) will not be capable of being powered by both offsite and onsite power systems because of fire damage, an independent onsite power system shall be provided. pM o l#nyb i. A6

Response

1. ftug Not applicable.

The cold shutdown equipment and systems comply - with Section III.G.2 separation or III.G.3. Therefore, one train of equipment will remain free of fire damage, and no repairs are postulated. III.L.6. Shutdown systems installed to ensure post fire shutdown ? capability need not be designed to meet Seismic Category I criteria, single failure criteria, or other design basis accident criteria, except where required for other reasons.

Response

Comply. The safe shutdown systems are designed commensurate with their importance to safety and other safety requirements. III.L.7. Isolation of safe shutdown equipment and systems from associated non-safety circuits. l (

Response

Comply. The response to this guideline is given in Item 2, Associated Circuits of Concern (a through c) of the NRC Generic Letter 81-12 which follows these Appendix R responses. i i 1 9A-16 Amendment 12 l {

/ HCGS FSAR 09/85 l t 9A.4.1.5 The possibility of fire spreading from one area to-another is analyzed. If the walls, floor, ceiling, doors or penetrations are rated less than three hour barriers, then the O fire's influence is assumed to extend into the adjacent area. Cable and equipment within this adjacent zone of influence is analyzed for spuric a operation and the effects on safe shutdown. The results of this analysis is presented in Section 9A.6,0. l 9A.4.1.f.; A well, 0 iling er fl:Or is coa.eidered reted when the e:11 :: ;1;b met; riel, soppert: Ord p-aetraticae =ra ret-d by/', ud y UL :: : fis. L ccles. Dvese nd "stch r, which==y ca=pri : partien f :nd/v6 effect une oves.ll fir; reting, are liel.J end -{r# diera= ed e ;rr;tely. All ncated welle end oi.^. v cy Icom 12 j o t: 15" inch:: thick reinforced cencrete and .6. cepeble er being reted ;; e 3 Lvur fim. L...-i;t. i 9A.4.1.6 The effects on safe shutdown for a fire area are arrived at by reviewing the effects of fire or safe shutdown equipment and cable in that fire area. The shutdown method used in the analysis for each fire area is stated in Section 9A.6. If any deviations from the stated method, fixes or manual actions are assumed for cold shutdown they are stated there. The effects of fire on safe shutdown and combustible loading in each fire area are written up in the Fire Hazard Analysis Tabulation and Summary Tables starting at Table 9A-6. For fire areas made up of more than one room, the analysis assumed the equipment and cable O for all rooms were affected by the fire, i.e., the walls within the fire area boundry were considered not to exist. Fire Hazard Analysis Tabulations are provided for each room within the fire area. The parameters listed in 9A.4.2 are included on these sheets. 9A.4.1.7 The Fire Hazard Analysis summary Table 9.A-1 lists by room, the description of the room, the safe shutdown equipment and cable. In addition, the amount of combustibles, fire load in i Btu /fta, fire detection and suppression features, are listed. i 9A.4.2 FIRE HAZARD ANALYSIS TABULATION SHEET PARAMETERS The Fire Hazard Analysis tabulation sheets contain the following information: 1 9A.4.2.a. Fire area number, room number, room name, building and l floor elevation. i

O 9A-27 Amendment i2 i

a Y fssevh/ 9 /1. 4. f. S / A cvs //, C e r l<ng, hu-llow c v, s a de v e c) is So ve & ala) i f i / i.s de s yn sc) h m.< < n kir i/s 5 - --- ' - in ley vily when e spnec) ha o s hnela-J $< v e. ks#. [ach e lem e n + b m, es-i.o eIvd.s3 c) ou <s, p e n e /~ ha,.s, o[- er cmc) ha/c4es 7A 7-p e n e h o/e. /4 e_ 4 m --, e c< s w e.1I as sh c Mu / e /enie erh ' s pp a.-h->g 9 varli $ed h ", eel M, e-0-e. )l, a<e V e sishmee. u hay a f th er An e<,ev d y S k n cla <cl S. <e ) e.s /s c< s id an 4 kec) /n d& C"Es '/-S'- / y ASTM E4\\Sr and ASTM E-814, o,3 uppe,pn (t, hk., an,ac,R6 in Sub.3 3.s 1 aJ 9A.6.o s e-O d i

e HCGS FSAR 09/85 l a. The boundary walls between the fire area RB2 and this fire area varies from unrated, I hour and 2 hour ratings. - These walls do not separate redundant safe shutdown equipment. L. DAM Th N:11 : parett res ABI st elevat4 M 37 fcc,e LF 'tpis fire area in n ad - A l b c$ Exterior walls or ceiling are not rated. d i -_ _,_ b rec _ M,. 4,.. i _ma O <---l'"' ~ G J E "' e G T u e-W E T.._ H w 6 M iyM

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. x,. x_..._._ 9A.6.2.1 Exemption Recuests ct. DeleN ' An exemption from Appendix R Section III.G.2 i equested for the two safe shutdown division which are s arated by a 2 hour fire barrier. Eleva on 124, roo 3442, 3444, and 3414 contains Div on II safe shut n instrument distibution panel able for SACS, Diesel nerators, 120 Vac, 125 Vdc 50 Vde, etc. Fire area 1, room 5501, contain ivision I safe l i shutdown ca for the redundan systems. These two areas are sepa ted by the un ed east wall'of 5501 and a two hour f a rated c ing above elevation 124 of the radwaste bu ing. he radwaste building fire area is partially cov e by an automatic sprinkler system. Elevation 137 the radwaste fire area contains an automati wet rinkler throughout most of. that elevation and overs th area adjacent to the unrated 3 foot.t ek wall sepa ing these fire areas. Refer to Figur 9.5-4 and 9.5-5. The cable at elevation 12 is in conduit. i Based o the two hour fire barrier, cover e by wet L sprin ers adjacent to the boundary, and ph cal dis nce between safe shutdown divisions, the isting se aration provides an equivalent level of safety in cess of the technical requirements of III.G.2. b. This fire area contains both divisions of cable in 3 conduit. Channel C at elevation 153 and channel B & D at elevation 124. -Mace these i.wu eress are t= f40ers--- lL::u,1Le 5klo of elevs%n iT3ll5V SeptroNy +]^wn 4t"'o o t'^L *\\ $*A' *& lL hev reded. The SIsb &T t.devatty 137 is s2 = Win [.1 rasvor<c f f*Ws it~are o as earl m m1 + *b Y g I g 4 **dO+t IX slb7 o 73/gn'-1. An a. des prht?' GA S n * $ N a:4 v fsn 13 7. god no eemp, n rep,g(.( %,e fe,e we M A cMF6*"4 dth - gr.G. 2.c

HCGS FSAR 11/85 l 2 ,. apart there are 4 hours nf @ valent fire barri b ~ be Nar the= Therefore, no avamptior ic regsc;ted. A g i ;> c. The rated floor slab supporting room 5619 is not supported by fireproofed beams due to inaccessibility and interferences. Safe shutdown cable from the Division I main control room HVAC system penetrates through this slab to the Division I fire area AB1 below (room 5501.). Since this slab does not separate redundant safe shutdown cabling no exemption is requested. 9A.6.2.2 Shutdown Method ~ Shutdown Method II can be used for a fire at elevation 153. Shutdown Method I can be used for a fire at elevation 124. Either Shutdown Method I or II can be used at any other elevation. 9A.6.3 ELECTRICAL ACCESS AREA DIVISION II, FIRE AREA AB2 n Several corridors between the auxiliary building and reactor building are used as cable access. The corridors carrying the Division II electrical cable are lumped into fire area AB2. This -fire area is made up of the following architectural rooms covering several floors. Refer to Figures 9.5-1, 2, 3, 4, and 5. Elevation 54; 3110, 3110-1, and 5106 Elevation 77; 3204 and 5207 Elevation 102; 3301, 3302, 3303, 3304, 3314, 3342, and 5301 l Elevation-1:24; 3425 and 5401 Elevation 130; 5423 Partial coverage by automatic suppression systems are provided in this area over cable concentrations in 3204, 5207, 3425, and 5401. This area is defined by fire barriers except as follows: 9A-36 Amendment 13 l

HCGS FSAR 11/85 l separate redundant safe shutdown divisions since the same channel of cable exists on both sides of the wall. Therefore no exemption is requested. d. This fire area contains partial coverage by automatic water suppression systems in areas of high cable concentrations. Since this area does not utilize Appendix R, Section III.G.2.b, c or III.G.3 to justify safe shutdown, no exemption for partial coverage is requested. e. (t4d~ /. An exempt " = ^p-ftdix R, Cti- .2 is r tet r the la k f fi to fing o a teel suppor in the 3-h ur i e arrie et een ms 01 and 542 thi s fi ae an ropm 33 in te D v sion I fi aret bel B lh hogoelectr c a e TEatic nd ectior, an 41 automa su pres ion / s s em arl allec i roMm 5339 rec y bel w fthe sp rt s e ~guto tic wa sp Qer

stem, ith c1 ea s seY at 0F il pr t ect t steel ve e tin.

he e i al e t fi e : e verit 33 ininute a uming I cab e t a' s are fi L1.ed t gpac) T There re[th aut uticau p msi prov{ des al equ v leht leve i prote ic i om-at specifie ecti n ~ Append 9A.6.3.2 Shutdown Method Shutdown Method I will be used for a fire in fire area AB2. Since shutdown cooling valves BC-HV-F008 (suction) and BC-HV-F015A (return) are in this fire area, the alternate shutdown method can be used or the affected valves can be opened manually to establish shutdown cooling 9A.6.4 ELECTRICAL ACCESS AREA DIVISION I, FIRE AREA AB! The following architecture rooms combine to form one fire area covering several floors. Refer to Figures 9.5.-2, 3, 4 and 5. Elevation 77, electrical access 5227 9A-39 Amendment 13 l t

i HCGS FSAR 09/85 l h. The structural steel above room 5339 and below 5401 and 5423 is a 3-hour fire barrier but the structural steel j is not fireproofed. 1. The structural steel above 5501 and below 5619 (fire area AB3) is not fireproofed. j. The ceiling above 5501 is unrated. Most of it is an t exterior ceiling except the east end which separates 5501 from 5619 (fire area AB3) and is rated 2 hours. 2 9A.6.4.1 Exemption Requests a. An exemption from Appendix R, Section III.G.2 has been requested in 9A.6.3.1.b for the two electrical bus ducts penetrating the 3-hour fire barrier between zones i 5339 and 5301. i i b. This fire area contains partial coverage by automatic water suppression systems in areas of high cable concentrations. Since Appendix R, Section III.G.2.b, c or III.G.3 are not used to justify safe shutdown in this fire area, no exemption for partial coverage is requested. cleded-s An exemptTon~from Appendix R, Section III.G.2 was c. i requested in 9A.6.2.1.a for the unrated east boundary (of 550,1 which separates redundant divisions. ele / ten d. ni emp on mA endigs, Spution giI.G 2 ha been ) r cJue ted 1A. 3 1. for ha 3 our f re' ba ir ]( wi hou str jura tee ir rbofi g abo e zon 33 D2lc4 ~~ e. b . ve z 5 oes separ red at { wn a s s c sed .6 .I Th ex on e est o ack stru tural s f eproof ng'was kequest i f. The east end of 5501 separates this fire area from fire area AB3, room 5619. This portion of the ceiling is a two hour fire barrier, however, since it does not separate redundant shutdown divisions, fireproofing has 9A-41 Amendment 12 l i -,,,,.__.--,y_.m -.c-,,_y-,_,, ,,-__ _.~,-,, m_,_._m_,.,____,-,__._..,_m. __,m.,,., _ m _,,

HCGS FSAR 09/85 l not been provided on the support beams. Since this does not separate redundant shutdowa-dLv4sions it is -not required to be rate (p:: App;;di: Fand no exemption is requested. N 9A.6.4.2 Shutdown Method l Shutdown Method II can be used for shutdown following a fire in this fire area. If RHR shutdown cooling valve BC-HV-F009 is affected, then the alternate shutdown path can be used. ll 9A.6.5 AUXILIARY BUILDING, CONTROL AND DIESEL FIRE AREAS, FIRE AREAS CD1 THROUGH CD85 Table 9A-5 lists the rooms or group of rooms which make up each fire area in the control and diesel area. This table also lists the shutdown method used in each fire area. Each fire area is defined by rated barriers as defined in NRC Generic Letter 83-33 except for corridors, and barriers which border the building exterior. All stairwells and elevator shafts are fire areas from top to bottom. s 9A.6.5.1 Exemption Reauests a. An exemption from Appendix R, Section III.G.3 requirement for a fixed fire suppresion system is requested for the control equipment room (CER), fire area CD26, room 5302. Auxiliary building control equipment room 5302 contains both divisions of control panels and cable. Figure 9A-19 shows the equipment layout of this room. Alternative shutdown capability via the rerote shutdown panel is provided for a fire in this area. The RSP controls can achieve and maintain hot and subsequent cold ~ shutdown independently from the fire or effects of the fire in 5302. l Fire area CD26 could contain a maximum of 31,368 lbs of cable insulation for a total burning time of 21 minutes. There are no power cables in this fire area. The cables are fire retardant qualified per IEEE-383. Area 5302 in combination with the corridor 5303 define 9A-42 Amendment 12 l

. _ = - _ - _ J HCGS FSAR 09/85 l a fire occurs in the control console pit area beneath the control console which can not be handled by portable extinguishers and/or water hose, a fixed pipe, manually actuated, halon suppression system is installed. The bottles are stored adjacent to the MCR and are brought in for use. The HVAC is manually turned off during halon use. The alternate shutdown capability provides assurance that one train of equipment necessary to achieve hot and subsequent cold shutdown is free of fire damage. This is not a large quanitity of combustibles and the area is continually staffed. Therefore, the addition of a fixed fire suppression system required by III.G.3 will not enchance fire protection safety above that provided by the existing configuration. 1 l c. An exemption from the requirements of Appendix R, i Section III.G.3 for a fixed suppression is requested for the IE panel room, fire area CD61. This fire area is at elevation 163 ft-6 in. of the aux 1 ary building diesel area and encompasses room 560 (en_y.- hS50b i i Fire Area CD61 contains logic cabinets for the main control room > Figure 9A-20 shows the equipment layout O d,gp of this room. Both divisions of redundant logic and A>Mek";9,4, fsn instrumentation are in panels therein. The panels have 5#4" less than 20 feet of separation between redundant divisio All cable are bottom entry. There are no Tlie in sit transient combustibles in this area g th c[ & W f Transient combustibles are administrative 1y controlled. f m l WCPT ~ - Alternate shutdown capabilities are provided in the RSP. The RSP contrcls can achieve and maintain hot and subsequent cold shutdown independently from a postulated fire or effects of a fire in fire area 5605. This fire area is defined by 3-hour fire barrier walls, floor and ceiling, and an unrated exterior wall. Both I ionization and photo-electric type detection cover this area. Suppression can be handled by portable extinguishers and/or water hose. Addition of a fixed suppression system covering the panels can be detrimental to the solid state logic and may compound a safe shutdown from the main control room (requiring use l of the RSP) and therefore result in a decrease in plant I safety. 9A-44 Amendment 12 l r

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HCGS FSAR 09/85 l If loss of both air handling units is assumed due to a transient fire in this area, it will not have an immediate effect on safe shutdown logic or instrumentation in the IE panel room. If the IE panel logic is eventually affected by high ambient temperatures, the unaffected instrumentation and/or controls on the RSP can be utilized. Tepperature indication is provided in the IE panel room in order to i monitor room ambient temperature. p,nm fans will be used i en w &Yt k mzinMn roen a,nM-wymiurgkgq (mis. The RSP provides assurance that one train of equipment necessary to achieve hot and subsequent cold shutdown is free of fire damage. There are very few combustibles in this area. Therefore, separation of the equipment or addition of a fixed fire suppression system will not enchance fire protection safety above that provided by the existing configuration. l e. An exemption from the requirements of Appendix R, i Section III.G.2 for separation plus suppression and Section III.G.3 for fixed suppression is requested for i the diesel area HVAC equipment room, fire area CD84, elevation 178 ft-0 in. This fire area encompasses rooms 5703 and 5704. This fire area is defined by a 3-hour fire barrier wall, floor and ceiling and unrated exterior walls. Refer to Figure 9.5-7. i The Air Handling Units AVH407 and BVH407 are enclosed in metal casing, are connected by both HVAC supply and return duct, and are physically separated by 6 ft. Loss of these VH407 units would cause a loss of air conditioning to the Control Room HVAC rooms 5602 and 1 5630, electrical access area 5501, control equipment j mezz. 5403, control equipment room 5302, cable spread room 5202, battery and equipment rooms 5105, 5128, 5102, 5103, 5104, 5126, and corridors 5525, 5404, 5303. ] The Diesel Generator HVAC panels provide control and i instrumentation for the D-G air handling units at elevation 77 ft of the diesel area and the switchgear room coolers. There are 20 ft of separation between the divisionalized DG HVAC panels B&DC483 and A&CC483 and their associated conduit with negligable intervening combustibles. In addition, a partial height wall of 1-hour fire barrier construction is installed with a wing section. This barrier is t 9A-46 Amendment 12 l I

HCGS FSAR 09/85 l A transient fire which affects D-G HVAC Division I panels will eventually affect operation of Division I i diesel generators. The same fire is not postulated to ~ affect the Division II panels and subsequently Division II diesel generators since the panels and associated cable are grea';er than 20 feet apart and a i barrier is installed with the height at least I foot higher than the panel, between the panels. 1 If a fire affected both air handling units and both chillers, the effect would be no different than loss of both chillers as described above. i If the fire were to affect the A&C Diesel Generator HVAC panels and both chiller units, che effect would be i. the same as loss of both chillers, as described above, except that loss of the RSP HVAC (on the A diesel) is also postulated. 4 Loss of both air ~ handling units and the Division II D-G 1 HVAC panels would only be a concern on high ambient temperature days. This concern would be for the long-term heat up of the Ccntrol Equipment room at elevation 102 and the possible effect on the solid state electronics therein.s Major Division I equipment can be ( controlled from the switchgear room for use in long-f term shutdown outside the main control room if this scenarlp were to come =hau& p s u <J n &ff*k&M h

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a fire in this area would be of limited severity and duration and the dual detection system provides an i early warning system. The probability is very low that an exposure fire of sufficient magnitude to damage redundant safe shutdown divisions could occur prior to response of the fire brigade. The installation of a fixed fire suppression system will not significantly enhance the safe shutdown capability. l l f. An exemption from Appendix R, Section III.G.2.a for the bus duct penetrations in fire areas CD28, CD29, CD30 and CD31, the diesel generator rooms. The seal inside the bus duct 3-hour fire barrier qualification report i shows the cold side temperature exceeds 3250F by 2*F. } J I 9A-49 Amendment 12 l i 1

HCGS FSAR 09/85 l v. The upper boundary (ceiling) between elevation 102 and fire area RB5 is not a fire rated barrier. 9A.6.8.1 Exemption Request a. An exemption from Appendix R, Section III.G.2 is requested for the non-UL rated pressure tight doors which bound this fire area. These doors are between rooms: 4111 and 4110, 4118 and 4101, 4209 and 4207, 4218 and 4217, 4309 and 4307, 4301 and 3314, 4328 and 4323, 4331 and 4316, 4328 and 4329, and 4328 and 4327. Refer to the exemption requested in 9A.6.3.1.a for a discusion of the type of doors used for pressure tightness on HCGS. The equivalent fire loading for rooms adjacent to the doors are given in Table 9A-1. The equivalent fire load is less than 30 minutes in most rooms adjacent to the doors. b. An exemption from Appendix R, Section III.G.2 requirements is requested for the equipment access panel between safety auxiliary cooling system rooms, 4307 and fire area RB2, room 4309. This panel is a pressure tight panel and is not qualified as a 3-hour i fire barrier by UL. The panel is fabricated out of heavy gage steel. The outline of the panel is shown on Figure 9A-17. Adjacent to the panel, on both sides, are areas of greater than 20 feet of clear space without combustibles. The panel is 10" x 22, and does not extend up to the ceiling. The 6 feet between the top of the panel and the ceiling is a reinforced concrete 3-hour-rated fire barrier. This 6-foot section is a hot gas barrier and retards the effects of the fire from affecitng the redundant division. Fire loading on either side of the barrier is low; 16 minutes and 8 minutes in 4309 and 4307, respectively. The pressure tight (leak tight) panel is required for overriding safety censiderations of flood protection. Ionization type detectors, wate Q ose and_ portable e ggyighers covegbotLareasAk i<pA Mm bel.., .m, q,m u m.a, a,9 a. y.g m.a. ponenb The combinatibn ofIoar spac_e, gas trap, low f loading, detection and fire brigade action assures that one train of equipment necessary to achieve hot shutdown will be free from damage. Any additional modifications to upgrade the access panel would not enhance fire protection safety above that provided by the existing configuration. 9A-54 Amendment 12 l

HCGS FSAR 09/85 l c. An exemption from Appendix R, Section III.G.2 is requested for the unrated equipment access panel and for the HVAC duct without fire damper in the 3-hour fire barrier between the SACS room,.4309, and the equipment airlock, fire area RB2, room 4323. Refer to l fire drawing Figure 9.5-3. The redundant safe shutdown cable are approximately 70 feet apart through two walls and a normally empty equipment airlock. The equivalent fire loading is low, less than 17 min. in each room. The equipment airlock is used mostly during shutdown; however, a small amount of combustibles may pass through this room during routine maintenance. Ionization detection is provided over both rooms. Water hose and portable extinguishers are available for suppression. Because of the wide separation, both rated and unrated wall, low in situ fire loading, clear space and early fire detection system, there is low probability that an exposure fire can damage redundant safe shutdown equipment prior to response to the fire brigade. The existing fire protection provided for this area provides a level of safety equivalent to the technical requirements of Section III.G.2. i d. An exemption from Appendia R, Section III.G.2 is . requested for the HVAC duct without fire damper in the 3-hour fire barrier between rooms 4326 and 4323, the equipment airlock. This exemption is identical with 9A.6.8.1.c. This is the same duct which penetrates from 4309 to 4323 then from 4323 to 4326. This duct is a supply duct from the reactor building ventilation system and is not required for safe shutdown. The equivalent fire loading is less than 23 minutes in 4326. Ionization detection is provided over both p Water hose and portable extinguishers are areas. pgr available for suppression. T* O e. An exemption from Appendix R, Section III.G.2, is requested for the HVAC supply and return duct to the pipeways (part of fire area RB3N) rooms 4327 and 4329, which do not contain UL rated fire dampers. The HVAC duct is made from 12 and 14 inch diameter steel pipe with two series valves serving as redundant pressure tight isolation dampers. The-isolation dampers are controlled by redundant pipe break detection 9A-55 Amendment 12 l I

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HCGS FSAR 09/85 l redundant divisions. The physical configuration of distance between divisions, clear space and heat trap (low ceiling in 4315) creates a fire barrier between redundant divisions. This, in combination with the low fire loading of in situ and transient combustibles plus fire retardant cable per IEEE-383 and detection, provides an effective alternative to Appendix R, Section III.G requirements. The equipment necessary to achieve hot and cold shutdown from the main control room will be free of fire damage. Additional modifications would not enhance fire protection safety above that provided by the existing condition. a ]g.lde). g. An exemption from Appe n III G.2.a, is s requested for the lack of fireproofing of structural steel supporting 3-hour fire barrier slabs in the I regtorbuilding. An analysis of beas' temperatures due to a (ire involving in situ and trans'it combustibles / i has bee performed for each room of the reactor building. The calculations were performed by Professiona Loss Control, Inc.f(PLC), using a methodology,geqmputer program and acceptance criteria reviewed and acqpted by the JfRC staff on the Limerick Generating Statiog docket. Ahe results of PLC's analysis for HCGS for thos( beams required to support the 3 hour fire barr'i ere7 sed-tA entify the id '@) 1 extent of fireproofi able tray covers onadditional suppression systems n .1 Ocy -to protect-tWsupport steel from overheatin. i The extent of this' fire area wh ch falls into the above category ares (Refer to Figures 5-1,2,63)

1. The ceilin above the torus compar.ent, room 4102 g

and below 4315, 4326, 4322, 4330, 41 I and 4332;

2. The sla above 4201 and below 4301;

,/

3. The elab above 4209 and below 4307;

4. The slab above 4108 and 4110 and below 4209 and 4210.

/ 9A-57 Amendment 12 l

HCGS FSAR 09/85 l -m of these, the area below item 2 is partially covered by automatic water suppression system. The fina esults indicate that some the beams f supporting t lab between rooms 9 and 4307 require protection in the'ac a above t stack of four cable trays. These beams ar r' oofed directly above and i four feet to each side o ay stack to the maximum extent practical. I dition, somo f the beams i supporting the s between rooms 4108 4209 require protection. se beams are fireproofed 1 e maximum extent pr cal. In all other areas, the beam temper ce either fell below 11000F or the beams we not utred to support the 3-hour fire bartie V N h. An exemption from Appendix R, Section III.G.2 is requested for the HVAC ducts without fire dampers and unrated door in the fire barrier between rooms 4218 and 4201. Elevation 77 of the reactor building, room 4218, is part of fire area RBI and contains Division I safe shutdown cable. Room 4201 contains Division II safe shutdown cable. These rooms are separated by a 12-inch I thick reinforced concrete wall with pipe, conduit and cable tray penetrations sealed for 3-hour fire barriers. The penetrations include a hollow metal core door and two HVAC duct which do not provide a 3-hour fire barrier. There are greater than 30 feet of horizontal distance without intervening combustibles or fire hazards in room 4201. The Division II IE cable, located at the south end of 4301, is covered by an automatic water suppression system because of a cable concentration. There are greater than 120 feet horizontal distance plus the wall between the redundant 1E divisions. There are 13,506 lbs (34 minutes) of combustibles in 4201, and 10,251 lbs (20 minutes) of combustibles in 4218. Both rooms contain ionization detection and, in addition to the auto suppression, water hose and portable extinguishers are available for suppression. The wall penetrations are sealed, therefore, the wall acts like a heat trap. Since the fire loading is low, partial auto suppression is provided, and the distance between IE cable is great, the existing wall, door and HVAC duct will provide an adequate fire stop. The wall 9A-58 Amendment 12 l

HCGS FSAR 09/85 l b. The exemption from Appendix R, Section III.G.2, has been requested in 9A.6.8.1.b. for the equipment access panel between SACS rooms 4307 and 4309. c. An exemption from Appendix R, Section III.G.2, has been requested in 9A.6.8.1.c for the unrated equipment access panel and for the HVAC duct without fire damper in the 3-hour fire barrier between SACS room, 4309, and the equipment airlock 4323. d. An exemption from Appendix R, Section III.G.2, has been requested in 9A.6.8.1.d for the HVAC duct without fire damper in the 3-hour fire barrier between rooms 4326 and 4323, the equipment airlock. e. An exemption from Appendix R, Section III.G.2, is requested for the HVAC supply duct to the pipeways, rooms 4319 and 4321, which do not contain UL rated fire dampers. These two supply pipes are identical with those discussed in 9A.6.8.1.e and 9A.6.8.1.j. The duct is 14 inch diameter steel pipe with two series valves serving as redundant pressure tight isolation dampers. The pipe and valve configuration, temperature control, elevations, detection and suppression are the same as discussed in 9A.6.8.1.e. The equivalent fire load is less than 12 minutes in 4320 and 17 minutes in 4322. There is no fire load in the pipeways. This configuration provides a level of fire stop equivalent to the technical requirements of Appendix R. f. An exemption from Appendix R, Section II.G.2, has been requested in 9A.6.8.1.f for the corridor 4315 which separates redundant division cable, and fire areas, ithout a fire barrier wall. ~' kQld&d-) / +g. An exemption from Appendix R, Se,ct'lon III.G.2.a, has been requested i 9A.6.8.1.g.,for the lack of fire proofing of struc ural stee,14'upporting 3-hour fire barrier slabs in t e reactor building. In addition to the areas listed in 9A.6'.8.1.g. as 2, 3, and 4, the following areas in. is fire area fall into this category: The ceilin above the torus compartment, room 4102 and below 4315, A317, 4318, 4320, 4322, 4323, and 4324. An exemption frba Appendix R, Section III.G.2.a, is requested for the la'ck of fireproofing of structural / \\ ~ _ N 9A-64 Amendment 12 l

HCGS FSAR 09/85 l / [ q h steel in the areas isted aboye. The analysis described in 9A.6.8.1.g cover this area. The results indicate at beam temperature either fell below 11000F or th'e be s were not required to suppo(t the 3-hour fir [ barrier. f h. An ex~e_mption from Appendix R, Section III.G.2, has been requested in 9A.6.8.1.h. for the HVAC duct without fire dampers and unrated door in the fire barrier between rooms 4201 and 4218. i. An exemption from Appendix R, Section III.G.2, has been requested in 9A.6.8.1.1 for the two ducts without fire dampers which penetrate the fire barrier between rooms 4207 and 4209. j. An exemption from Appendix R, Section III.G.2, is requested for the non-UL rated isolation dampers for the HVAC duct penetrating the fire barrier between corridor 4201, part of fire area RB2, and fire area RB35, room 4102. This reactor building ventilation system supply duct is steel pipe with redundant pressure tight isolation valves of the same configuration discussed in 9A.6.8.1.e. The 26 inch pipe penetrates at elevation 95 feet. An automatic water suppression system covers the cable concentration and this duct and dampers (pipe and valves). Ionisation detection provides early detection and in addition to the auto suppression, water hose and portable extinguishers are available. This pipe ducting, redundant pressure tight isolation dampers (valves), redundant actuation temperature elements and auto suppression, provide a level of fire stop equivalent to the technical requirements of Appendix R. k. An exemption from Appendix R, Section III.G.2, is requested for the pressure relieving blowout panels between the RHR room 4109, the RCIC pump room 4110 and fire area R335, room 4102. Rooms 4109 and 4110 are part of this fire area. The barrier between these rooms is otherwise rated as 3-hour ftre barrier. These panels are required for overriding safety reasons to protect the RHR and RCIC rooms from overpressure due 9A-65 Amendment 12 l

HCGS FSAR 09/85 l b. An exemption from Appendix R, Section III.G.2, was requested for the non-UL rated pressure tight doors which bound this fire area below elevation 132. An exemption was requested for the door between 4204 and 4205 in Section 9A.6.9.1.a. An exemption was requested for the doors between 4217 and 4218, 4319 and 4320, and 4321 and 4322 in Section 9A.6.8.1.a. The remainder of the doors are pressure tight type in non-UL rated walls between rooms 4402 and 4401, 4409 and 4408 and between 4505 and 4504. Refer to Figures 9.5-4 and 9.5-5. The justification for these doors being treated as fire barriers is given in Section 9A.6.3.1.a. l c. An exemption from Appendix R, Section III.G.2, was requested for the reactor building ventilation ducts with non-UL rated dampers. These ducts are pressure tight pipe with dual isolation valves for dampers. The exemptions are requested in Section 9A.6.8.1.e, 9A.6.8.1.j, 9A.6.9.1.e, and 9A.6.9.1.j. Additional HVAC duct of the same type penetrate the barrier into the pipeways 4402 and 4505. l d. An exemption from Appendix R, Section III.G.2, was requested for the non-UL rated fire barrier between the H' steam vent and fire area RB2, in Section 9A.6.9.1.m. l f ~ e. An exemption from Ap ndix [, Section III.G.2, w_as p j requested for the lac o fireproofing of structural steel above the torus etment in Sections 4 A<6181 Q and 9A.6.9yV.g f. An exemption from Appendix R, Section III.G.2, is requested for the unrated walls and penetrations separating this fire area pipe way from fire area RSS at elevation 132 and above. The walls involved surrounded rooms 4402, at elevation 132, and 4505, at elevation 145. These walls are minimum 24 inch thick reinforced concrete. The HVAC is piping with isolation valves the same as in Section 9A.6.8.1.e. The doors are pressure tight doors, the same as in Section 9A.6.8.1.a and 9A.6.3.1.a. All penetrations are sealed to maintain the pressure boundary of the torus compartment. The walls do not directly separate safe shutdown equipment or cable since there are no safe shutdown equipment or cable at elevation 132 and 145. However, indirectly, through the unrated slab at 132, both divisions of shutdown cable could be reached. 9A-69 Amendment 12 l

HCGS FSAR 09/85 l A fire in the area closest to the core spray suction valves should not affect both divisions of core spray since they are separated by 40 feet. However, if both core spray loops were assumed to be affected, both divisions of RHR, HPCI and RCIC are greater than 120 feet away and can be used for safe shutdown. Appendix R, Section III.G.2, accepts an automatic suppression system with greater than 20 feet of separation without intervening combustibles plus detection for this situation. HCGS has heat actuated detectors in the horizontal 1E trays to detect a challeng to the Class 1E cable. Water hose stations are pro for suppression in the torus compartment. The high ceilings and physical horizontal separation limit propagation of heat damage to one channel of one division. Therefore, at least one train of equipment necessary to achieve cold shutdown will be free from damage. The level of safety provided in the torus compartment is equivalent to the technical requirements of Section III.G. Additional modifications required to meet III.G.2 will not enhance fire protection safety above that provided by the existing configuration. 9A.6.10.2 Shutdown Method l The torus room and its adjoining rooms in this fire area do not have one shutdown method for a fire anywhere in this fire area. However, there is more than sufficient separation to rely on different shutdown equipment depending on the portion of the fire area a postulated fire occurs. For a fire in the northern rooms, defined in 9A.6.10, Shutdown Method II utilizing Division II Core Spray, RHR, and SRVs can be used. For a fire in the southern rooms, Shutdown Method I utilising Division I Core Spray, RHR and the Division II SRVs (Channel D) can be used. 9A.6.11 REACTOR BUILDING MAIN STEAM TUNNEL, FIRE AREA R34 l The main steam tunnel fire area R34, consists of the steam tunnel room 4316 up to the ventilation barrier at the boundary of the reactor building. The remainder of the steam tunnel and vent stacks are part of the turbine building fire area T51. The steam tunnel is designed for pressure tightness. The emergency vent stack contains blowout panels to the outside and provides 9A-72 Amendment 12 l

HCGS FSAR 09/85 l overpressure protection of the main steam tunnel in the case of a high pressure line break. There are no combustibles in this area and because of high radiation, detectors are not qualified for this area. Therefore, only the redundant pipe break detection temperature elements are used to annunciate abnormalities in this area. Refer to Figures 9.5-3 and 9.5-9. This fire area is defined by 3-hour fire barriers except as noted below. There are no combustibles in this fire area. a. The steam tunnel fire barrier support steel is not fireproofed. b. The doors at elevation 102 and at 132 are not UL rated fire doors. c. The ventilation barrier between the reactor building and turbine building portions of the steam tunnel is a pressure relieving panel and is not a rated fire barrier. d. The south wall adjacent to the outside is not a ated fire barrier. 9A.6.11.1 Exemption Requests /-g~Q[ M L- -x . ' a.' ? m.,Ue, f ' Appendis-Seetion-III.G,2 M-7 requested-f,or-t -ieeproo#1ng ef fire-area-R54 s steel. Ap analyst for am capability durJng a fire wa( performed on t$ s el in thi area. / efer to R Sectig 9A.6.8.1.g i No fthes were identifi,, discussion of a more comp e thejrhalysis. since all beam temperatur'es were'belbgr 1100*F or,tfie b me were not required to support the 3-hour fire barrier. b. An wxemption from Appendix R, Section III.G.2, is requested for the pressure tight door at elevation 102. Refer to Section 9A.6.8.1.a. An exemption from Appendix R, Section III.G.2, is requested for the pressure tight door at elevation 132. Refer to the exemption r guested in 9A.6.3.1.a for a complete discussion of the door type and justification. 9A-73 Amendment 12 l

HCGS FSAR 09/85 l both divisions of service water pumps to deliver the required cooling water flow. Therefore the existing fire protection program for this area provides a level of safety equivalent to the technical requirements of Section III.G. 9A.6.16.2 Shutdown Method l Shutdown Method I or II can be used following a fire in this area. 9A.6.17 MISCELLANEOUS AREAS, NO FIRE AREA DESIGNATION l The remaining intake struc'ture fire area is an unoccupied area. This area does not contain any safe shutdown equipment or cable. The other miscellaneous buildings throughout the site each form their own fire area, except the fire water pump house. The fire water pump house is separated into two fire areas. There are no safe shutdown equipment or cables in these areas. 9A.7.0 WALKDOWN VERIFICATION l A.walkdown will be performed by personnel knowledgeable in ftre protection and nuclear safety after a significant portion of the MCGS plant features and equipment have been completed. The purpose of this ws1kdown will be to verify compliance to Appendia R commitments and make necessary enhancements. We expect this walkdown to take place in the year preceding initial fuel loading. 9A.S.0 E1REERQQEIEs_ERQGRAM l supp.4%; 8rt' 9.s*I f*,,e k olc a 9A.S.1 Steel Senaretine-RedundantrTrains l ($1 p q.s -I r e ywe d Structuralsteelformingapartoforsupportingffirebarriers whet >gepeesto: equipment =or=essociated stremite ofaredundant -4pe6es are reviewed to determine the requirement for ftreproofing. An analysis of beam temperatures due to a ftre involving in situ combustiblesis performed for each to these fire sones. The calculations are performed by Professional Loss Control Inc., (PLC) using a methodology, computer program and Ofuiule.q by C 9A-7 ' Amendment 12 l

HCGS FSAR 09/85 l Shutdown Method I can be used for safe shutdown for a fire 6 this area. 9A.6.16 TRAVEI,IN SCREEN MOTOR ROOM, FIRE AREA IS3 l Fire area IS3 is made up of the intake structure t)ravsling screen l motor room. This area is defined by exterior wal)s and unrated wall between this fire rea and adjacent fire ar as IS1, I 2 and unoccupied area fire are. See Figures 9.5-11 nd 9.5-12 elevation 114 ft. 9A.6.16.1 Exemption Reauest b a. An exemption from A pendia R, ection III.G.2, is requested for fire a ea IS3. This area, elevation 114, contains all four se vice w er pump intake traveling screen motors (5501) nd b h supply fans (V558) for the traveling screen tor areas. This area also separates the Division I quipment in fire area ISI from the Division II eq pment in fire area 152 without a rated fire barrier. for to Figures 9.5-11, 9.5-12, 1.2-14 (Section A-A), n 1.2-40. Failure of this equ poent oes not have an immediate impact on the serylce wate pump's ability to supply cooling water. instrumentation a$11 the cab e for power, nd control re routed in conduit and thereareneglfableotherc bustibles in this area. The floor grat; ng will not c stain a liquid (flammable or otherwise)/ nd the motors,ce 5 hp. Access is by ladder, which tends to preclu use of the area for storage. S6ppression is by po table extinguishers. Both lonisstion and photoelect c detection is provided./ Becau of the greater than 25 fe t of separation betw n redundant traveling water creen motors, seco in tu fire loading, and an early fire detection s es, there is a low probability that an esposure { f e can damage redundant safe shut own equipment prior response of the fire brigade. E en if all the raveling water screen motors falle there is an additional low probability that, bec use of the intake structure location, high debris load ill be present to sufficiently plug the screens and aff t the ability of ~ 9A-77 Amendment 12 l l f k

HCGS FSAR 09/85 l acceptance criteria reviewed and accepted on the Limerick Generating Station docket. d M L ""'i u +4 geh chuk as ab'kJ onossur"to-J car 3 Au u k en n.ah dosto ye breg,cdL7O Cdo bML toala b<<4 Fo g ardMi del ch"e2Ne3s b i'0'00 F ahe IssidedYea7r/Io D oa,;ajh "t+% N$p Et sfe f*w i $ Based on this assumption the structural capability of the fire barrier is determined assuming support by the remaining support steel, if any, and a room temperature as determined by the PLC analysis. The,results of this analysis will determine those Q structural stee1% required to be protected in order to support the N ftre barrier. No credit is taken for manual firefighting in reducing fire temperatures or duration. Beams thus identfied are fireproofed or if fireproofing is not possible, an automatic,, suppression system is relied on. #c f,

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==.- etr :g.P.- ::t _ :::::leted W eeMe, ' -_._ t::in:, the fire brigade action is assumed to reduce both the duration and temperature of a postulated firo. In addition, the ftre is assumed to affect equipment or circuits on the floor above the fire hic (tryr<el0yis;^r-4.pdcJ M k re ua, w ha. s<a rab on s q %L'!L-. /'. e ' A M _ h t" 4 e.....p...a< a 9A.8.3 /,/-Shc @- s ns.or ns s y.rpsa. Table 9A - 103 liste rooms with exposed ceiling 4 structural steel supporting fire barriers which separate redundant trains. The table categorizes the fireproofing in each of these room as follows: Room contains beams not fireproofed or partially a. fireproofed because of a PLC analysis, b. Room contains beams not fireproofed because of a civil / structural analysis, c. Room contains beams not fireproofed because of inaccessibility and an automatic suppression system is relied on. d. Room with beams fireproofed (complies with BTP). l All other rooms not listed do not require fireproofing. l 9A-79 Amendment 12 l

HCGS FSAR 09/85 l Comparison of HCGS to NRC Generic Letter 81-12 With Clarifications Dated March 25, 1982 '\\ Request for additional i formation concerning/ design modifica to meet the requirements f Section III. of Appendix "R". 1. Identify those areas the plant,that will not meet the requirements of Section III .2 of Appendix R and either alternative shutdown or an .emption/from the requirements of Section III.G.2 of Appendix will 6e provided. provide a statement that all ther/ Additionally, areas of the plant are or will be in compliance with Section .II.G.2 of Appendix R.

Response

Section 9A 6.0 identifies all fire areas for which a deviation from Appendix R, Sect other areas of the p)a$cn III.G.2 o III.G.3 are requested. All nt are or wil be in compliance with Section III.G.2 of ppendix R. Section 9A.6.0 a so provides a fire ha ard analysis justifying l the alternati fire protection config ation. l l (k i a l l l l 9A-80 Amendment 12 l

l v.. 8 f 9A.8.3 Fireproofino Flow Chart Tha fireproofing flow chart presented below reiterates the pr gram presented in 9A.8.1 and 9A.8.2. BTP barrier per,M-5101 through M-5111- > No --- + Yos Arcas with no combustible loading. (see note 1) - > Yes" No Fire-proofing !!o Required PLC-type analysis: Beams > 1100*F? > No Yos Civil Analysis: Sheel Required to Support Slab? > No - Yos Aro beams acceitsib;,e for fireproofing Yes-> Fireproof Steel llo Add or rely upon sprinkler system NOTE 1: This step is not applicable to Safe Shutdown Divisional Separation Harriers 9A-79A

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~ _ - _ _ - HCGS FSAR 09/85 l L control of what components and instrumentation). Describe the 4 system (s) or portions thereof used to provide the alternative shutdown capability for the fire area and provide a table that lists the equipment and components of the alternative shutdown system for the fire area. 2

Response

Equipment and components, including circuits of the normal 'l shutdown systems for which alternative shutdown capability is provided, are listed on the fire hazard analysis tabulation sheets. The equipment is limited to control and instrumentation panels and control cables. There is no communication either mechanical or electrical between systems controlled from the RSF and any of the fire zones for which alternative shutdown capability is provided. 1.b.1 For each alternative system, identify the function of the new circuits being provided. Identify the location (fire zone) } of the alternative shutdown equipment and/or circuits that bypass the fire area, and verify that the alternative shutdown ecluipment t and/or circuits are separated from the fire area in accordance with Section III.G.2. 1. i j

Response

ggy i The RSF provides isolation for safe shutdown control circuits from the areas requiring alternate shutdown. No new circuits are provided. The control cable routing from th fire areas for which alternative shutdown is provided is to the RSF panel i (transfer switches) hen to the hot an cold shutdown ~ equipment. The fir for the RSF is-Once the transfer switches on the RSF pa 10C399 are moved to the emergency position, the circuits terminate at the panel and are no longer i connected to the fire seers for which alternative shutdown is f i provided. The circuits fnom the remote shutdown panel to the hot j and cold shutdown equipment h we III.G.2 separation from the fire ~ area. cuau i i 1.c. Provide drawings of the alternative shutdown system (s) j which highlight any connections to the normal shutdown systems (P& ids for piping and components, elementary wiring diagrams of t electrical cabling). Show the electrical location of all j breakers for power cables, and isolation devices for control and i l t L ) 9A-83 Amendment 12 l l F l - - -. - -.,. - - _ ~., -,,. - - _ _ _,.. - ~,.... _,--,,,..--,.-..--.-,~~.,.-.e.

HCGS FSAR 09/85 l FIRE AREA APPROACH For each fire area where an alternative or dedicated shutdown method, in accordance with Section III.G.3 of Appendix R is provided, the following information is required to demonstrate that associated circuits will not prevent operation or cause maloperation of the alternative or dedicated shutdown method: la. Provide a table that lists all the power cables in the fire area that connect to the same power supply of the alternative or dedicated shutdown method and the function of each power cable listed (i.e., power for RHR pump).

Response

There are no safe shutdown power cables in the fire areas for which alternative shutdown is provided. The cables in these areas are either control or instrumentation. Therefore, a table is not included. Ib. Provide a table that lists all the cables in the fire area that were considered for possible spurious operation which would i adversely affect shutdown and the function of each cable listed.

Response

HCGS maintains Appendix R separation between the two shutdown trains. If a fire occurs in the first train, safe shutdown Division I, the second train, safe shutdown Division II, is fully capable of cold shutdown, independent and unaffected by any damage, maloperation or spurious operations in the first train. Similarly, if a fire occurs in the second train, the first train is fully capable of cold shutdown. The only common juncture between the two shutdown trains are the control areas listed in Item 1 of these responses. If a fire occurs in these areas, transfer switches located at the RSF will isolate the second shutdown train from any damage upstream of these switches; therefore, maintaining independence of the second shutdown division. The only cables which were identified to possibly affect safe shutdown using Division II is a lineup of the Division I HPCI which transfers suppression pool water through the test return line to the Condensate Storage Tank,agoncurrent three valves with-HPCI-steam-available wou1~d h-opening of,Therefore valve BJ-HV-F008, the CST return valve, will required. e ~4 wJ raw O_ s[ a s,_ -9A, Amendment 12 l w

4 HCGS FSAR 09/85 l 3 x have it: M ed er ep;r.cd t prevent operice: valve eperatier..* There are no Division II spurious. operations which were found to affect Division I safe shutdown. Ic. Provide a table that lists all the cables in the fire area that share a common enclosure with circuits of the alternative or dedicated shutdown systems and the function of each cable listed.

Response

There are no circuits in the fire areas for which alternate shutdown is provided that share a common enclosure with circuits of the alternative shutdown system. The circuits of the alternative shutdown system can be isolated from the fire area by transfer switches located at the RSF. Id. Show that fire-induced failures (hot shorts, open circuits or shorts to ground) of each of the cables listed in a, b, and c will not prevent operation or cause maloperation of the alternative or dedicated shutdown method.

Response

Transfer switches are provided in the RSF to isolate circuits in the fire areas for which alternative shutdown has been provided. Therefore, since the circuits required to shut down the plant are isolated through transfer switches, a fire in the areas for which alternative shutdown is provided will not prevent operation or cause maloperation of the alternate shutdown method. In addition, coordinated protective devices are provided on all associated circuits within the fire areas. l 1e. For each cable listed in a, b, and c where new electrical l isolation has been provided, or modification to existing electrical isolation has been made, provide detailed electrical schematic drawings that show how each cable is isolated from the fire area. l l l l 9A-93 Amendment 12 l l

HCGS FSAR 9/85 l TABLE 9A-1 (cont) Page 13 of 51 l Elev Roca Description and Hazard Fire Load l f;@g Eggg Safe Shutdown Equip and Cable Material Quant ity Btu /fta Detection Suppression [ ^ 102-0 3366 Cryst bottoms tank room None None None Phot o-el Auto-wet l~ sprinkler i sys l Ha0 hose l. Port eut l 102-0 3367 Cryst recire pump room Cable insul 492 lb 11,700 shoto-el 7.uto-wet l sprinkler l sys l Ha0 hose l Port ext l 111-0 3368 Drum mezzanine 'None None None None Auto-wet l sprinkler l sys. l Han hose l Port ext l 112-0 3369 Pump mezzanine Nons None Mone Photo-el Auto-wet l sprinkler l sys l Ha0 hose l Port ext l 124-0 3401 Vestibule Nome None None None Ha0 hose l Port ext l 124-0 3402, Uncontrolled outage trade None None None Ionizat H,0 hose .l 3405 lator locker area & Port ext l Corridor l 124-0 3403 Clean issue room None None None None Hao hose Port ext 124-0 3404 Electrical tray room Cabla 2069 lb 58,400 Ionizat H 0 hose l insul Port ext l 124-0 3406, Uncontrolled toilet, Showers None None None None Ha0 hose l

3407, 8 Drying area Port ext l

3408 l D i 124-0 3410,

Showers, area None None None None Ha0 hose l

3411, 6 Uncontr toilet Port ext l

3412 Channel BSD l 124-0 3413, Unce ntrolled maint locker None None None Ionizat Ha0 hose l 3409 area & Corridor Port ext l Channel B6D l Amendment 12 l

HCGS FSAR 9/85 l TABLE 9A-1 (cont) Page 23 ot 51 l Elev Poom Description and Hazard Fire Load it-1Ds Egge Jafe gbutdown gggio and Cable Material Quant it y Btu /fta Detection suporession 155-3 3606 Radwaste exh system None None Nor.e Ionizat H O hose 1 2 h CRGWerfB)k 155-3 3609 HDV Equip'are: Cable 850 lb 640 Ionizat Ha0 hose j insul Phot o-el Port ext l 153-0 3613 iSC Nechanical room chszcual 1450 lb 25,000 Ionizet autn water i Heat spray in { actuated filter unit l in filter Ha0 hose l urit Port ext l 172-6 3703 Vent stack enclosure None None None None None l Reactor.Dulldire l 054-0 4101 Torus water cleanup None None Mone None Ha0 hose l pump rm Port ext 1 054-0 4102 Torus compartment Cable insul 9548 lb 4000 Contin-Ha0 hose l Div I valves - HPCI, RHR, CS uous line l Div I cable type heat l Div II valves - RCIC, RHR, CS heat de-l Div II cable tectors l 054-0 4103 Vestibule None None None _ Ionizat Hr0 hose l Port ext l 054-0 4104 core spray pump ra Cable insul 7522 lb 47,400 Ionizat Ha0 hose l Div II cable Lube oil 15 gal. Port ext l Transient 15 gal. l lube oil l 054-0 4105 Core spray pump ra Cable insul 2879 lb 22,200 Ionizat Ha0 hose l Div II cable Lube oil 15 gal. Port ext l Transient 15 gal. l lube oil l 054-0 4106 CRW/DRW pumps and sump rm Cable insul 1275 lb 11,100 - Nm y Ha0 hose l Charcoal 99 lb gic,3Af~ Port ext l filter l Amendment 12 l

(N [ N (v/- (L,) \\N HCGS FSAR 9/85 l TABLE 9A (cont) Page 47 of 51 l Elev Room Description and Hazard Fire Load it-1D. Jggg Safe Shutdown Equip and Cable Material Quantity Btu /fta Detection Suppression 146-0 5544 Battery charger ra Cable insul 2553 lb 32,500 Ionizat Ha0 hose l Fuse trans sw box 1AD412 Photo-el Port ext l Battery chargers 1AD413 l 1AD414 l Battery monitors 1 AD 415 l Division I cable l 146-0 5545 Battery rm Batt case 325 lb 21,100 Ionizat Ha0 hose l Battery racks 1AD411 Port ext l Division I cable l 150-0 5546 Corridor None None None Ionizat H O hose l 2 Phot o-el Port ext l 155-3 5601 Vestibule Noie Nor.e Nore None Ha0 hose l Port ext l 155-3 5602 HVic equip ra Cable insul 7658 lb 10,800 Ionizat Ha0 hose l Control rm wtr chiller 1Ak400 Photo-el Port ext l Control rm chilled wtr pump Heat act auto-water l 1AP400 in spray in l Control rm A/C unit 1AVH403 1AVH400 1AVH400 l CO hose i 2 163-6 5604, corridors Cable insul 12,240 lb 32,800 Ionizat Ha0 hose l 5611 Div I 6 II cable Photo-el Port ext l Sct jul60 163-6 Ccntrol equip rm Cable insul-9SSE lb 2844-Ionizat Ha0 hose l Sg 3, Division I and II ccermke f /#^) th Photo-el Port ext l Class 1E logic cabinets gy gg l 1AC655 l 1CC655 l 1BC655 l srests l EMS c.,e3 163-6 5606 HVA p rm - Div II None None None Ionizat H 0 hose l Switchgear rm cooler Photo-el Port ext l 1BVH401 l 1DVH401 l Diesel battery rm exh fan l 1Bv406 l 1cv406 l i Amendment 12 l

S FINAL SAFETY ANALYSIS REPORT HCGS FSAR TABLE 9A-9 FIRE HAZARD ANALYSIS TABULATION Sheet 6 of 27 ROOM: CRW/DRW Pumps and Sump Room Fire Areas RB2, Reactor Building Division II ROOM NO. 4106 BLDG. Reactor ELEV. 54 FIRE DETECTION TYPE: FIRE SUPPRESSION TYPE: MECH aannr H O hose IAHR200 & IDHR200 2 [ Jeq@p SHUTDOWN SAFE SHUTDOWN EQUIPMENT AND CABLE: DIVISION I ertable ext. None EMERG. LIGHTS: Yes CONSTRUCTION: FIRE RATING: Walls: North 3 hour Ea st Unrated South Unrated West Unrated EFFECTS OF FIRE ON SAFE SHUTDOWN AND/OR RADIOACTIVE RELEASE: Floor: Unrated (basemat) Ceiling: Unrated None Doors and Hatches Unrated Reference Drawings: Elec. Drawings - E-1561-1 Fire Drawings - Fig. 9.5-1 and 9.5-9 COMBUSTIBLES: EQUIV. FIRE MATERIAL: OUANTITY SEVERITY (MIN.) a. Cable insulation 1,275 lbs 6.9 b. Lube oil O c. Other (charcoal filter) 99 lbs 1.4 DEVIATION REQUEST: None d. Transient 0 AREA = 690 f t2 TOTAL 8 min. www

HCGS FSAR FINAL SAFETY ANALYSIS REPORT FIRE HAZARD ANALYSIS TABULATION TABLE 9A-76 09/85 ,100M Control Equipment Room Fire Areat CD61 560[JI3/ BLDG. Auxiliary / Diesel ELEV. 163'-6" FIRE DETECTION TYPE: FIRE SUPPRESSION TYPE: ROOM NO. H O hose IPHR401, 1XHR400 MECH 2 SHUTDOWN SAFE SHUTDOWN EQUIPMENT AND CABLE: Ionization DIVISION Portable extinguishers I AC680 A and B )lE elec aux, cabinets channel A ) Contains Photoelectric AC680 C and D ) ) offsite CC680 A and B )lE elec aux. cabinets channel C )~ power EMERG. LIGHTS: CC680 C and D ) ) relays AC655 ) lE Analog logic cabinets for channel A & C Yes CC655 ) MCR Instrumentation 10C601 Redundant Reactivity Control System Channel A and C CONSTRUCTION: FIRE RATING: II BC680 A and B ) lE elec aux, cabinets channel B and D Walls: BC680 C and D ) as above DC680 A and B ) North 3 hour DC680 C and D ) BC655 ) lE Analog logic cabinets for channel B and D Ea s t 2 hourf3 nour DC655 ) MCR Instrumentation 10C602 Redundant Reactivity Control System Channel B and D South Unrated (outside) Other Non IE cabinets West 3 hour Non-lE conduit NM5 Ch+wp.dEk Floor 3 hour EFFECTS OF FIRE ON SAFE SHUTDOWN AND/OR RADIOACTIVE RELEASE: Ceiling: 3 hour None. Panels are bottom entry. Very low fire loading. Loss of Doors and Hatches: 3 hour one or more of the C680 cabinets may cause of f-site breaker to open, redundant offsite breaker should transfer automatically. If both offsite sources are lost, the diesel generator will auto-matically start and energize the bus. SDG is not af f ected by fire in 5605. Therefore all C680 cabinets can be lost without affecting safe shutdown. Fire in C655 cabinets could cause erro-Reference Drawings neous instrument readings in the MCR. It is not likely that a fire could go from panel to panel and if it could, instruments and Elec. Drawings - E-1677-1 controls in the RSP would not be affected and could be used for E-1687-1 backup readings. Solid state logic generated by above instrument readings will also be affected. Controls and instruments at the Fire Drawings - Fig. 9.5-6 and 9.5-10 RSP can be used, independent of a fire in this area, for safe shutdown. COMBUSTIBLES: EOUIV. FIRE MATERIAL: QUARTITY SEVERITE iMIN.) 2cD~ 0. a. Cable insulatio_n +r395 lbs b. --uk l000 b$ hY 0.We

c. -e %er fof*sf

_gy DEVIATION REQUEST: Fixed Suppression System d. Transient 0 AREA = 7643 ft2 TOTAL 2 min. 3/1-2o Amendment 12 rnai

HCGS FSAR 09/05 TABLE 9A-103 Fuee racrinW ROOMS WITH A FIRE BARRI RATES REDUNDANT DIVISIONS PLC (a) CIVIL (b) SUPPRESSION M (d) ROOM ANALYSIS ANALYSIS SYSTEM (c) """"----" E COMW.ENTS hreyoFid 41 X 4110 X cale 11 D 4201 X GL mels 4i 4209 X LC calc 22 5104 X 5105 X 5106 X west of O PLC ::1; 00

• 5128 X

M 5129 X 5'130 X 5202 X 5215 X South of 26.7 5302 X 5303 X 5315 x [ 5336 X 5339 X Between O & PLC ;;1c 63 5401 M X Between R & M PLC ::10 5?

• 5403 X

5404 X 5411 X 5413 X 5415 X 5417 X 5510 X 5515 X 5531 X 5532 X 5533 X 5534 X 5535 X 5605 X 5606 X 5607 X 5609 X 5610 X 5612 X 5613 X 5614 X 5615 X 5616 X 5629 x (a) Beams not fireproofed or partial fireproofing per PLC analysis (b) Beams not fireproofed based on Civil / Structural analysis (c) Beams not fireproofed, relying on suppression system due to interferences (d) Beams fireproofed FHAT 6/3-1 Amendment 12

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09/83 HCGS FSAR / d5-TABLES 9A hrough 9A-2 52 have been dele ted. Ame ndme nt 12

HCGS FSAR 10/83 OUESTION 280.3 (SECTION 9.5) Verify that door openings in fire barriers will be protected with equivalently rated doors, frames, and hardware. Specify that a nationally recognized independent testing laboratory has tested and labelled this equipment in accordance with BTP CMEB 9.5-1 Section C.5.a.

RESPONSE

openings in fire barriers are protected with equiv ntly rate es, frames and hardware. Such doors and f s are labeled b nderwriters Laboratroies, and utili L listed hardware, wit he exception of oversize an assure doors which cannot be labele. The oversized doors being provided with a f UL cer h cate'of in tion which a es that, except for being oversize, the door comp 1 with other requirements for design, materials, and const ion. Pressure tight doors heavy rei reed-steel doors designed to withstand high lev of water and at pressures. From the standpoint of m erial and fabrication, doors are superior to h'- a normal UL eled fire door. However, du to their locking device a modifications necessary to satisfy akage criteria, they not labeled by UL and therefore are not sidered fire do f +:- p &f n '/, 5 l I Y h firt cek ^ ~ mw: M fa spu9h >,ms 6 a n ~ 4;;c rh den J,k G,, e n. .n O 280.3-1 Amendment 2

p HCGS FSAR 1/84 ( OUESTION 280.5 (SECTION 9.5) GDC 3 requires that fire fighting systems be designed to ensure that rupture or inadvertent operation does not significantly impair the safety capability of' structures, systems, and components important to safety, Verify that components required for hot shutdown are designed so that rupture or inadvertent operation of fire suppression systems will not adversely affect the operability of these components. Identify the mechanisms that were considered in the fire hazards analysis and the measures taken to preclude the fire or fire suppressant-induced failure of redundant or diverse safety trains.

RESPONSE

Fire fighting systems for HCGS are designed to ensure that any single rupture or inadvertent operation will not affect redundant shutdown trains and thus prevent safe shutdown of the plant. The mechanisms that were considered in the fire hazards analysis and the measures taken to preclude the fire or fire suppressant-induced failure of redundant or diver safety trains are discussed in revised Section 9A.4.1.2 3& -1) 3. I. 2. 4 9 5 l i i

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280.5-1 Amendment 4 ,.}}