ML20155G818
| ML20155G818 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood, 05000000 |
| Issue date: | 05/02/1986 |
| From: | Miosi A COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20155G821 | List: |
| References | |
| 1655K, NUDOCS 8605070146 | |
| Download: ML20155G818 (16) | |
Text
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I O ). Commonwealth Edison O1 One First National Raza. Chicago, ithno,s Address Reply to Post Othee Box 7@
- Chicago, Ilknois 60690 May 2, 1986 4
Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC.
20555
Subject:
Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 Amendment 7 to Fire Protection Report NRC Docket Nos. 50-454/455 and 50-456/457 1
References (a):
August 16, 1982 letter from T.R.
Tramm to 1-H.R. Denton (b):
February 3, 1984 letter from R.C.
Knop to C.
Reed (c):
April 27, 1984 letter from R.F. Warnick to C.
Reed (d):
July 6, 1984 letter from D.L.
Farrar to H. R. Denton (e):
March 25, 1985 letter from R.F. Warnick to C. Reed (f):
March 1, 1985 letter from T.R. Tramm j
to H.R. Denton This letter provides Amendment 7 to the Byron /Braidwood 4
Fire Protection Report (FPR) which was submitted in Reference (a).
This amendment updates the FPR to incorporate new information and analyses applicable to Byron Unit 1 and 2 and Braidwood Units 1 and 2.
These changes do not represent a decrease in the level of fire protection program which require prior NRC approval according to Condition 6 of the Byron 1 Operating License, NPP-37.
Amendment 7 includes a new section 2.4, chapter 3, and Appendix AS.8 providing the Braidwood Unit 1 safe shutdown analysis, j
the Braidwood Station BTP CMEB 9.5-1 conformance description, and L
Appendix R~(Section III G.2) deviations for Braidwood Unit 1, i
respectively.
This is new information which will allow the staff to begin its Braidwood Station fire protection reviews.
Note that an i.
NFPA code review of the Braidwood Station is currently in progress.
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8605070146 860502 7
. This review will be completed on time to document the results (i.e.
-all NFPA code deviations) in Chapter 3 of the FPR prior to fuel load of Braidwood Unit 1.
While a substantial portion of this review is already complete, a decision was made not to submit these results in an FPR amendment until the entire review is complete.
In the interim, the completed portions of the review and the status of the ongoing review is available for audit.
Amendment 7 also includes miscellaneous changes throughout the document.
These changes can generally be categorized as either editorial in nature, or as changes to reflect the latest "as-built" condition of the plants.
Attachment A to this letter provides an itemized summary and explanation of all changes included in this amendment.
This attachment is provided as an aid to the NRC Staff in identification of changes.
In some cases, the changes which reflect the "as-built" condition of the plant result in an increase in the combustible inventories for some zones, with resultant increased combustible loadings.
In these cases, an analysis of the increased combustible loadings was performed to demonstrate that the level of fire protection was not decreased.
This evaluation is provided in Attachment B to this letter.
One particular change deserves special mention.
During inspections of the Braidwood station documented in reference (b) and (c),' Region III questioned the use of wire mesh fences to separate the 125Vdc safety related batteries from their associated switchgear.
After much discussion with the NRC Staff, the applicant committed to replace the wire mesh fence with reinforced masonry walls.
This was documented in reference (d).
Reference (d) also included a commitment to update the PSAR and FPR to reflect this design change.
This item was closed by the NRC in inspection report 50-456/85-004 and 50-457/85-004 which was provided in reference (e).
Amendment 6 to the FPR, provided in reference (f), included a revision to the applicable parts of section 2.3 to describe the replacement of the wire mesh fence with the reinforced masonry wall. -However, section 2.3 was also erroneously changed to indicate that the battery room ceilings were upgraded to 3-hour rated fire barriers.
A review of the referenced documents clearly indicates that this was never intended, and design changes to accomplish this were not issued.
Amendment 7 includes revisions to section 2.3 to delete the statements regarding the fire rating of the battery room ceilings.
Inasmuch as the statements were included in the FPR by error, their deletion does not represent a decrease in the level of fire protection.
. In summary, none of the changes to the Fire Protection Report included in Amendment 7 require NRC approval at this time.
They represent either new information provided for NRC review or updates to reflect the "as-built" condition and editorial corrections, i.e. changes ~which do not represent a decrease in the level of fire protection.
One signed original and forty copies of this letter, the attachment and Amendment 7 are being provided for NRC review.
Please direct any questions that your or your staff may have to this office.
Very truly yours, 4
A. D.
si Nuclear Licensing Administrator
/klj att.
1655K
ATTACHMENT A IQ
SUMMARY
OF CHANGES CONTAINED IN B/B FPR AMENDMENT 7
, V PAGE NO (s )
DESCRIPTION i and ix Editorial corrections.
2.1-4 and 2.1-4a Subsection 2.1.3.1 revised to explain that fire hazards analysis was based on Byron plant orientation and that Braidwood layout is 180 out of phase from Byron.
2.1-5 and 2.1-6 Part "a" items 10, 11, 12, 13, 14, and 15 added to reflect current design information.
Part "a" item 2 changed to delete exception regarding heater bay area.
Par t " a" items 4 and 8 have editorial changes.
Part "b" item 5 revised to indicate that charcoal filter deluge systems are manual.
Part "b"
item 4 4
has editorial change.
Subsec tion 2.1. 3. 2. 3 has editorial change.
2.1-6a Revised to reflect current design information on locations of Halon bottles.
2.1-11 Statement concerning use of fire retardant s '
paint on protection racks deleted, since this type of paint was not used in this application.
2.1-12 Item f revised to include specific heat load of lube oil condi tioner.
2.1-13 and 2.1-13a subsection 2.1. 4. 6 item b revised to indicate that locations of portable extinguishers are indicated symbolically in the figures in Section 2.3.
Figures are not meant to s how actual numbers and locations.
2.2-4 Revised to add ref erence to essential cable pans for fire zone 3.2-0.
2.2-12 Revised to indicate that there are essential cable pans in fire zone 12.1-0.
2.2-15 Revised to reflect addition of 50,000 gallon outdoor f uel oil storage tank to fire zone 18.20-0 at both Byron and Braidwood.
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1 ATTACHMENT A (Cont'd)
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PAGE NO(s)
DESCRIPTION 2.2-17 Addition of reference to Note 1 for zones 1.2-1, 1.2-2, 1.3-1, and 1.3-2.
Also revised to indicate that temperature switches are in charcoal banks lA and 1B in zone 1.3-1 and banks 2A and 2B in zone 1.3-2.
Other changes are editorial.
2.2-21 Revised to indicate that Braidwood zones 7.1-1 and 7.1-2 have ionization detection, and zone 8.1-0 has ionization detection at Byron only.
Also, 1110 gallons of lube oil conditioner has been added for zones 8.3-1 and 8.3-2.
The fire loading for these two zones has been revised (see Attachment B).
2.2-22 Revised to indicate that ultraviolet detection in zones 8.5-1, 8.5-2, and 8.6-0 is at Byron only.
Also, for zone 8.6-0, table has been revised to discuss manual charcoal deluge system.
1800 lbs of charcoal have been added to the combustibles for this zone and the fire loading has been revised.
Other changes are editorial.
g-s 2.2-23 Revised to show that Braidwood zones 10.1-1, 10.1-2, 10.2-1, and 10.2-2 have only Fenwal thermal detection.
Other changes are editorial.
2.2-24 Revised to show that zone 11.3-0 has automatic sprinkler for stairway and open hatch.
2.2-25 Revised to show that 11.4-0 has automatic sprinkler for stairway and open hatch.
2.2-26 Revised to show that Braidwood zones 11.4A-1 and ll.4A-2 have only Fenwal thermal detection, and that zone 11.5-0 has automatic sprinkler for stairway, open hatch, and auxiliary building waste oil drain tank.
Other changes are editorial.
2.2-27 Revised to show that Braidwood zone 11.5A-0 has ionization detection, and that zone 11.6-0 has automatic sprinkler for stairway and open hatch.
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ATTACHMENT A (Cont'd)
PAGE NO (s)
DESCRIPTION 2.2-27a Revised to show that Braidwood zone ll. 6C-0 has ionization detection.
Also added reference to Unit 1 suppression zone 10 for fire zone 11.7-0.
2.2-28 Revised to discuss manual charcoal deluge system for zone 14. 6-0.
700 lbs of charcoal have been added to combustibles for this zone and fire loading has been revised.
References to Note 1 and suppression zone 58 have also been added for zone 14.6-0.
Other changes are editorial.
2.2-29 Revised to indicate that zones 18.1-1, 18.1-2, 18.2-1, and 18.2-2 do not have a charcoal deluge system.
There are no charcoal banks in these zones.
Also, for these zones changes have been made to show that supply sir ducts have ionization detection and there are no charcoal thermos tats.
2.2-30 Revised to show that there is automatic sprinkler system for store room in zone
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18.7-0.
Other change is editorial.
2.2-31 Reduced combustibles for zones 18.10A-1, 18.10A-2, 18.10B-1, and 18.10B-2 :
92,700 gallons of transformer oil reduced to 12,500 gallons (former quantity erroneously referred to pounds of transformer oil).
Fire loadings are also reduced.
Also for fire zone 18.11-0, Braidwood has both ionization and ultraviolet detection.
2.2-32 Revised to indicate that both Byron and Braidwood have ionization and ultraviolet detection in zone 18.12-0.
Also, only Byron has ionization detection in zone 18.13-0.
Table was also revised to indicate that ESW cooling towers are at Byron only.
2.2-33 For zone 18.20-0 re'/isions were made to include the new 50,000 gallon fuel oil storage tank and to indicate that zone has Fenwal rate compensating detection.
The quantity of combustibles and fire loading were also changed.
For zone 18.26-0, a discussion of the manual charcoal deluge system was added.
600 lbs of charcoal were added to the
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combustibles, and the fire loading has in cre ased.
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ATTACHENT A (Cont'd)
PAGE NO (s)
DE SCRIPTION 2.2-33a Revised to show that zone 18.36-0 has ionization detection.
Other changes are editorial.
2.3-1 Deleted sentence which stated that containment base slab, walls, and roof slab are 3-hour fire rated.
These were down-rated in FPR Amendment 6.
Down-ra ting is consistent with figures in Section 2.3.
2.3-11 Revised to state that ionization duct detectors are located in exhaust ductwork for control room panels.
2.3-13 Statement regarding portable extinguishers revised to be consistent with change on page 2.1-13.
2.3-17 Clarification of fire damper arrangement and extinguishing and detecting capabilities in zone 3.1-1.
2.3-19 Statement on safety-related equipment in zone
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3.2-0 reworded for clarification.
2.3-33a and 2.3-34 Fire barrier description reworded for clarification.
2.3-39 Statement regarding portable fire extinguishers revised to be consistent with change on page 2.1-13.
2.3-44, 2.3-45, and Fire barrier description reworded for 2.3-45a clarification and to describe differences between Byron and Braidwood.
2.3-46, 2.3-48, and Statements regarding portable fire 2.3-55 extinguishers revised to be consistent with change on page 2.1-13.
2.3-58 Fire barrier description for z irur 5.4-1 (and 5.4-2) revised to indicate that the ceiling of the battery enclosure carries no fire rating.
This is acceptable since the battery enclosure ceiling is not part of the barrier separating the zone from adjacent zones.
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ATTACHMENT A (Cont'd)
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PAGE NO (s)
DE SCRIPTION 2.3-60, 2.3-60a, and Fire barrier description revised to describe
-2.3-63 differentas between Byron and Braidwood for zones 5.3-1 and 5.5-2.
2.3-63a Fire barrier description for zone 5.6-1 (and 5.6-2) revised to indicate that the ceiling of the battery enclosure carries no fire rating.
This is acceptable since the battery enclosure ceiling is not part of the barrier separating the zone from adjacent zones.
2.3-68 Revised to indicate that Braidwood zone 7.1-1 (and 7.1-2) has ionization detection.
2.3-71 Revised to indicate that zone 8.1-0 has ionization detection at Byron only.
2.3-72 Statement regarding portazble fire extinguishers revised to be consistent with change on page 2.1-13.
2.3-73 Fire barrier description for zone 8.3-1 changed to give revised reinforced concrete O
floor thickness (values increased).
2.3-74 and 2.3-75a Combustibles and fire loading revised for zones 8.3-1 and 8.3-2 to include 1110 gallons of lube oil conditioner in each zone.
2.3-76 Fire barrier description revised to indicate that there are 3 floor drains (not 2) in zone E.4-1.
2.3-77, 2.3-78, and Discussion of manual fire suppression 2.3-78a equipment for zone 8.4-1 revised to be consistent with change on page 2.1-13.
- Also, revised description of fire barrier for zone 8.5-1.
Fire barrier rating is not changed.
2.3-79 and 2.3-79a Extinguishing and detecting capabilities for zone 8.5-1 revised to indicate that only "yron has ultraviolet detectors over the mezzanine floor.
Also discussion for zone 8.5-2 revised to clarify differences between zone 8.5-1 and 8.5-2.
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ATTACHENT A (Cont d )
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PAGE NO(s)
DE SCRIPTION 2.3-80 and 2.3-81 Discussion for zone 8.6-0 revised to include manual deluge system for off-gas filter unit and to add 1800 lbs of charcoal to the combustibles.
The fire loading has been revised.
Also, a revision has been made to indicate that only Byron has ultraviolet detection in this zone.
2.3-86 Editorial correction.
2.3-93 Discussion for zone 10.1-1 revised to indicate that Byron has ionization detectors and Braidwood has Fenwal heat detectors.
2.3 Z
2.3-}0a, Minor revisions made to fire barrier descriptions for zones 10.1-2, 11.3-0, 11.3-1, 2.3-117, and 2.3-127 11.3B-1, ll.3C-1, and ll.4A-1.
Fire barrier ratings have not changed.
2.3-128a Revised to indicate that zone ll.4A-1 has ionization detection at Byron only.
(Both Byron and Braidwood have Fenwal thermal detection.)
2.3-129a Statement regarding portable extingelshers revised to be consistent with change on page 2.1-13.
2.3-133 Minor revision to fire barrier description for zone ll.4C-1.
Fire barrier rating has not changed.
2.3-139a Revised to indicate that zone ll.5A-0 has ionization detection at Braidwood only.
2.3-141b and 2.3-147 Minor revisions to fire barrier descriptions for zones 11.6-0 and ll.6A-1.
Fire barrier ratings have not changed.
2.3-147a Statement regarding portable fire extinguishers in zone 11.6A-1 revised to be consistent with change on page 2.1-13.
2.3-147d Discussion for zone 11.6C-0 revised to indicate that Braidwood has ionization detection.
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4 ATTACHMENT A (Cont ' d)
PAGE NO (s)
DESCRIPTION 2.3-148 Revised to indicate that zone 11.7-0 has ionization detection except on elevation 475 feet 0 inch.
2.3-150 Revised to indicate that 11.7-1 has ionization detection except on elevation 467 feet 0 inch.
2.3-152 Minor revision of fire barrier description for zone 12.1-0.
Fire barrier-rating has not changed.
2.3-1 53 Editorial correction.
2.3-154 Fire barrier description for zone 12.1-0 revised to indicate that fire dampers are provided in wall separating this zone f rom the auxiliary building.
Also, deleted statements under protection criteria and measures which indicated that'there are no safety-related cable trays in this zone.
2.3-155 Revised to indicate that zone 12.1-0 has 4
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manual hose stations on Elevation 426 feet 0 inch (previously stated that there were 2).
\\-s Also, s tatement regarding portable extinguishers revised to be consistent with change on page 2.1-13.
2.3-158 Discussion for zone 13.0 revised to indicate that Halon system can be manually initiated by a toggle switch rather than a pushbutton.
2.3-159 Revised to indicate that zone 14.1-0 has seven floor drains at Byron and six at Braidwood.
2.3-167 Discussion for zone 14.6-0 revised to include manual deluge system for the charcoal filter units.
Combustibles revised to add 700 lbs of charcoal.
Also fire loading was revised.
2.3-178, 2.3-178a, 2.3-179, 2.3-180, Fire barrier descriptions for zonec 18.4-1, 18.4-2,18.5-1, and 18.5-2 revised to indicate 2.3-180a, and 2.3-181 dif f erences between Byron and Braidwood.
Barrier ratings have not changed.
2.3-184 Statement regarding portable fire extinguishers for zone 18.6-0 revised to be consistent wi th change on page 2.1-13.
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ATTACHMENT A (Cont ' d) i j
PAGE NO (s)
DESCRIPTION 2.3-185 Revised to indicate that storeroom in zone 18.7-0 is protected by automatic sprinklers.
2.3-136 Minor revision to fire barrier description for zone 18.8-0.
Barrier rating has not changed.
2.3-189 and 2.3-190 Revised to indicate that main power transformers in zones 18.10A-1, 18.10A-2, 18.108-1, and 18.10B-2 contain only 12,500 (not 92,700) gallons of transformer oil.
Fire loadings are also reduced.
2.3-194 and 2.3-197 Revised to indicate that zones 18.11-0 and 18.12-0 have ultraviolet detectors at Braidwood in addition to ionization detectors.
2.3-198 Revised to indicate that zone 18.13-0 has ionization detectors at Byron only.
2.3.-202 Revised to indicate that zone 18.15-0 has twelve (not 1) manual hose station.
2.3-2C5 Revised to include discussion of new 50,000
(~')
gallon f uel oil storage tank in zone
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18.20-0.
Also revised to indicate that foam system activated by a Fenwal rate compensating detector.
2.3-211 and 2.3-211a Revised to include discussion of manual deluge system for TSC HVAC charcoal filter unit.
Also added 600 lbs. charcoal to combus tibles and revised fire loading.
2.3-219 Minor revision to fire barrier description for zone 18.35-0.
Barrier rating has not changed.
I 2.3-220 Edi torial correction.
2.3-221 Revised to indicate that ionization detection is provided in zone 18.36-0.
2.4-1 (Byron)
Editorial correction.
2.4-49 (Byron)
Corrected to indicate that Uni t 1 RWST is located in zone 16.1-1.
2.4-1 through provided new B raidwood-l Section 2. 4 which 2.4-215 (Braidwood) includes Braidwood-l saf e shutdown and high-
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low pressure interf ace analysis.
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ATTACHMEffr A (Cont ' d)
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PAGE NO (s)
DESCRIPTI ON 3.1-1, 3.1-2, 3.1-3, 3.1-4, 3.1-5, 3.1-6, Editorial corrections, corrected position 3.1-7, 3.1-8, 3.1-9, ti tles, and miscellaneous changes to 3.1-11, 3.1-12, and description of fire protection program 3.1-13 (Byron) responsibilities at Byron.
3.2-2 (Byron)
Editorial: " cords" changed to "permi t cards".
3.3-6 (Byron)
Editorial change.
3.4-1, 3.4-2, and Editorial corrections and also revised 3.4-3 (Byron) discussion of responsibilities for fire protection QA inspections and ref et ence material used in audits.
3.5-1, 3.5-3, 3.5-4 Editorial corrections.
(Byron) 3.5-5 (Byron)
Editorial correction and revised discussion to state that door in turbine wall adjacent to Unit 1 unit auxiliary transformer has 1 1/2-
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hour or Class B rating.
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3.5-9, 3.5-11, 3.5-12, Miscellaneous edi torial corrections and 3.5-13, 3.5-14, and clarifications.
On page 3. 5-9, for items (2) 3.5-15 (Byron) and (4), the statement " comply" was deleted, leaving ref erence to Table 3-1 for delineation of compliance to NFPA code.
3.6-1, 3.6-2, 3.6-3, Miscellaneous edi torial corrections and 3.6-4, 3.6-5, 3.6-6, clarifications.
Exception has been taken to
{gYf6-7 )and 3.6-8 items (2) and (4) on page 3.6-2.
For items 4
- a. 6 and b.1 on page 3. 6-1, item (7) on page 3.6-3, items (6) and (7) on page 5. 6-6, and item f on page 3.6-8, the statement "Com pl y" has been deleted, leaving ref erence to Table 3-1 for delineation of conformance to NFPA code.
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ATTACHMENT A (Cont ' d )
PAGE NO (s)
DESCRIPTION 3.7-1 through 3.7-11 Miscellaneous editorial corrections and (Byron) clarifications.
Some changes made to be consistent with text in other parts of FPR.
On page 3.7-4 discussion of compliance with requirement f or isolating the control room HVAC system expanded to state that outside air intakes can be isolated on ionization detection, however HVAC system remains in ope r ation.
3.8-1 (Byron)
- Corrected procedure number.
3.1-1 through 3. 8-1 (Braidwood)
Provided new Braidwood Sections 3.1,
- 3. 2, 3.3, I
- 3. 4,
- 3. 5,
- 3. 6, 3. 7, and 3. 8 discussing compliance to BTP CMEB 9. 5-1 for B raidwood.
l 3-1, 3-2, and 3-3 (Byron)
Revised introduction to Byron NFPA code r e vi ew.
3-1 and 3-2 (Braidwood)
Provided new introduction-for Braidwood NFPA code review.
O AS.1-2, AS.1-3, AS.1-5 Deleted resume for T. Gray and added resumes through A5.1-14 for R. Adcock, J. Biggins, S. Chingo, N. Malicki, J.
Robinson and R. Smith AS.4-2 Deleted sentence stating that the ties to each hydrant f rom the yard main are controlled by post indicator valves.
Also, revised sentence in second to last paragraph to state that there are five connections between the yard main and the interior loops.
A5.4-3 Revised discussion on control room annunciators for motor-and diesel-driven fire pumps.
A5.4-6 Revised to include discussion of automatic foam system for the new 50,000 gallon outdoor fuel oil storage tank.
AS.4-10 and AS.4-ll Minor revisions to description of CO2 system and edi tor ial corrections.
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ATTACHMENT A (Cont'd)
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PAGE NO (s)
DESCRIPTION AS.4-14 Revised to indicate that the electrical cable tunnels have two Class B fire detection ci rcui ts.
A5.4-15 through These tables have been revised primarily to be AS. 4-22 and A5. 4-26 consistent with other parts of FPR text.
through A5.4-32 Other changes were made to be consistent with current design information.
For Tables AS.4-6 and AS.4-7, separate Byron and Braidwood pages have been generated since certain data (e.g.
quantity of detectors and actual IIalon concentr ation) for Braidwood may be different from Byron.
Editorial corrections have also been made.
AS. 8. 3-1, A5. 8. 4-1, A5.8.5-1, AS.8.6-1, Changes made to Byrc.i-1 Appendix R deviations A5. 8. 7-1, A5. 8.10-1, to indicate completion of certain commi tments AS.8.ll-1, A5.8.12-l,'
(.e.g. ins tallation of sprinkler sys tems).
AS. 8.13-1, AS. 8.15-1, Also, editorial corrections were made.
AS.8.18-1 and AS. 8. 32-1 (Byron)
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Appendix A5.8 Added new section providing Braidwood-l (Braidwood)
Appendix R delvations.
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ATTACHMENT B EVALUATION OF CHANGES TO COMBUSTIBIE INVENTORIE S FIRE OLD FIRE NEW FIRE ZONE LOADING LOADING EVALUATION 8.3-1 62,200 66,400 The increase in the fire loading 8.3-2 58,000 61,700 is due to the addition of 1100 gallons of lube oil conditioner in each of these zones.
The increase is not significant and does not decrease the level of fire protection.
8.6-0 4,200 4,500 The increase in the fire loading is due to the inclusion of 1800 lbs. of charcoal for the off-gas filter units.
The increase is not significant and does not decrease the level of fire protection.
A manual deluge system is provided for these filter banks.
14.6-0 21,900 22,800 The increase in fire loading is due to the inclusion of 700 lbs of charcoal for the charcoal filter units.
The increase is O
not significant and does not decrease the level of fire protection.
A manual deluge system is provided for these filter banks.
18.10A-1 8,670,000 1,170,000 The fire loading has been reduced 18.10A-2 8,670,000 1,170,000 due to correction of error in 18.10B-1 8,670,000 1,170,000 previous amendment.
There are 18.10B-2 8,670,000 1,170,000 12,500 gallons of transformer oil in each zone (not 92,700 gallons).
Quantity of transformer oil given previously corresponded to " pounds" rather than " gallons".
18.20-0 14,800,000 2,640,000 The fire loading has been reduced.
Although 50,000 gallons of diesel fuel was added to the combustibles, the berm area increased.
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p, 5
ATTACHMENT B (Cont ' d )
1 FIRE OLD FIRE NEW FIRE j ~
ZONE LOADING LOADING EVALUATION r
t 18.26-0 12,200 14,000 The increase in the fire loading 2
is due to the inclusion of 600 lbs charcoal for the charcoal filter units.
The increase is i
not significant and does not decrease the level of fire protection.
A manual deluge system is provided for these l
filter banks.
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1 f
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