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Page 1 of 12 DSAR-9.11 Auxiliary Systems Fire Protection System Rev 2 Safety Classification: Usage Level:
Safety Information Change No.: EC 70143 Reason for Change: Align with NO-FC-10 (QATR) to remove "and equipment" from Section 9.11.8.
Preparer: N. Thompson Fort Calhoun Station
DSAR-9.11 Information Use Page 2 of 12 Fire Protection System Rev. 2 Table of Contents 9.11 Fire Protection System.................................................................................................. 4 9.11.1 Design Bases................................................................................................ 4 9.11.2 Fire Brigade Staffing ..................................................................................... 6 9.11.3 Fire Brigade Training .................................................................................... 6 9.11.4 Component and System Design and Operation............................................ 6 9.11.5 Radioactive Release ................................................................................... 10 9.11.6 Safety Evaluation ........................................................................................ 10 9.11.7 System Design Evaluation .......................................................................... 10 9.11.8 Fire Protection Program Documentation, Configuration Control, and Quality Assurance ............................................................................................................... 10 9.11.9 Tests and Inspections ................................................................................. 10 9.11.10 B.5.b Requirements .................................................................................... 11 9.11.11 General References.................................................................................... 11
DSAR-9.11 Information Use Page 3 of 12 Fire Protection System Rev. 2 List of Figures The following figures are controlled drawings and can be viewed and printed from the listed aperture card.
Figure No. Title Aperture Card 9.11-1 Fire Detection System, Ground Floor Plan .............................................. 21430 9.11-2 Fire Detection System, Basement Floor Plan, Elevation 995' -6" ............ 21431 9.11-3 Fire Detection System, Auxiliary Building and Containment, Elevation 1025' -0"................................................................................... 21432 9.11-4 Fire Detection System, Operating Floor Plan, Elevation 1036' -0" .......... 21433 9.11-5 Fire Detection System, Turbine Building, Elevation 990' -0".................... 21434 9.11-6 Fire Detection System, Turbine Building, Elevation 1011' -0".................. 21435 9.11-7 Fire Detection System, Turbine Floor, Elevation 1036'-0" ....................... 21436 9.11-8 Fire Protection System in the Technical Support Center and Intake Structure ....................................................................................... 21437 9.11-9 Containment Building, Tray and Conduit Layout, Plan Elev. 994'-0" ....... 40253 9.11-10 Containment Building, Tray and Conduit Layout, Plan Elev. 1013'-0" ..... 40251
DSAR-9.11 Information Use Page 4 of 12 Fire Protection System Rev. 2 9.11 Fire Protection System 9.11.1 Design Bases In November 2016, OPPD certified to the NRC per 10 CFR 50.82(a)(1) that fuel had been permanently removed from the reactor vessel. With this certification, 10 CFR 50.48(f) became applicable to the fire protection program. Subsequently, Amendment No. 290 to Renewed Operating License DPR-40 deleted the fire protection program as a License Condition.
The fire protection program must now be maintained in accordance with 10 CFR 50.48(f).
10 CFR 50.48(f)(1) specifies the required objectives of the fire protection program. The fire protection program for the Fort Calhoun Station consists of design features, personnel training, operating procedures, fire protection systems and firefighting equipment provided to reduce the adverse effect of fires on structures, systems, and components (SSCs), such that in the event of a fire the plant SSCs important to the prevention or mitigation of fire-induced releases of radioactive materials are protected. This is accomplished by using a defense-in-depth approach which consists of:
Prevent fires. Administrative controls and, where possible, physical features (e.g., barriers or other physical separation of combustibles from ignition sources) should be implemented to provide reasonable assurance that fires will not occur.
Rapidly detect, control, and extinguish fires that do occur and could result in a radiological hazard. Appropriate levels of fire protection, including detection systems, automatic or manual fire suppression systems, water supplies, and emergency response capability, should be provided based on the fire hazards present.
Minimize the risk to the public, environment, and plant personnel resulting from fires that could result in a release of radioactive materials. Plant SSCs important to the prevention or mitigation of fire-induced releases of radioactive materials should have an appropriate level of fire protection. Plant personnel should be adequately trained in emergency response procedures for fire events.
The fire protection program is based on NRC requirements and guidelines, Nuclear Electric Insurance Limited (NEIL) Property Loss Prevention Standards, and related industry standards.
SSCs are designed and located to minimize, consistent with other fire safety requirements, the probability and effects of fire and explosions.
DSAR-9.11 Information Use Page 5 of 12 Fire Protection System Rev. 2 The plant design has been reviewed to assess potential for fire-induced radiological hazards involving spent fuel, contamination, or radioactive waste.
Combustibles have been identified and minimized as much as practical.
Additionally, provisions have been made for early detection of possible fires, as well as for suppression systems where combustible materials warrant.
NFPA codes were used as guidelines in the design of passive fire protection features (e.g., fire doors, dampers, and walls), active fire protection systems (e.g., fire suppression and detection systems), and in the development of administrative controls of fire hazards. Unique situations and configurations arise in nuclear power plants that are not specifically addressed in NFPA codes. These require departures from strict adherence to NFPA code requirements based on sound engineering principles.
The fire extinguishing system designs are based on the assumption that outside help will not be immediately available to assist in fighting fires; therefore, the systems are independent of aids external to the plant. The water supply is drawn from the Missouri River. One of the fire pumps is diesel engine driven and is therefore independent of on and off-site power.
Fire barrier walls enclosing separate fire areas utilize fire resistive construction. Penetrations in fire barrier walls are protected by doors, dampers, and penetration seals with fire resistance ratings commensurate with the hazards in the area. Fire rated barrier systems equate to, or are bounded by, configurations that have been tested according to the ASTM E-119, Standard Time Temperature Curve. Exceptions in the ratings of protective systems for openings in fire barrier walls have been identified, analyzed and determined to be acceptable. Reference 9.11.11.3, EA97-001, Updated Fire Hazards Analysis 9.11.1.1 Fire-Induced Radiological Hazard Considerations The primary fire protection concern for permanently shutdown plants is protecting the integrity of the spent fuel and preventing or minimizing the release of radioactive materials resulting from fires involving contaminated plant SSCs or radioactive wastes. The radiation dose limits specified in 10 CFR Part 20, "Standards for Protection Against Radiation," apply to plant personnel and members of the public for fire incidents at permanently shutdown nuclear power plants. Measures are established to maintain exposures to radiation resulting from a fire as low as reasonably achievable by maintaining fire protection for the following areas and SSCs.
- a. Spent Fuel Pool Area, including spent fuel pool and adjacent areas.
- b. Radioactive Waste Storage and Accumulation Areas, including temporary structures and transportation containers.
DSAR-9.11 Information Use Page 6 of 12 Fire Protection System Rev. 2
- c. SSCs that are necessary to provide protection of the spent fuel and mitigate radiological release that may exceed 10 CFR 20 requirements, including building ventilation, spent fuel pool cooling and makeup, instrumentation and controls, and electrical power.
Onsite fire brigades and offsite responders should be adequately trained and drilled on the pre-plans and general fire attack strategy.
9.11.1.2 Codes of Record The codes, standards and guidelines used for the design and installation of plant fire protection systems are documented in Reference 9.11.11.4, EA95-022, NFPA Code Compliance.
9.11.2 Fire Brigade Staffing A Shift Manager, one Non-Certified Operator (qualified Incipient Responder),
and one person qualified in radiological procedures are to be maintained on site at all times (except unexpected absences) as specified in Reference 9.11.11.8, SO-G-28, Station Fire Plan. The Blair Volunteer Fire Department (BFVD) will be notified if a fire exists. A support agreement has been established with BVFD. The agreement requires BVFD to respond to emergency calls with a fully-equipped force of no less than five (5) firefighters, including one officer.
9.11.3 Fire Brigade Training A training program for the fire brigade is maintained under the Manager-Training which meets or exceeds the requirements of NFPA 600, Standard on Facility Fire Brigades, applicable to fire brigades that perform incipient-stage firefighting. This program also includes requirements associated with the implementation of B.5.b. Reference 9.11.11.1, FCS License Condition 3.G and Reference 9.11.11.2, NRC-17-018, Rescission of Interim Compensatory Measure B.1.A from EA-02-026. A support agreement with BVFD has been established. The agreement addresses involvement of BVFD personnel in FCS training and drills.
9.11.4 Component and System Design and Operation 9.11.4.1 General Description The overall fire protection system provides means for detecting, alarming, isolating and suppressing plant fires. The system is divided into the following subsystems
- The Fire Detection and Alarm System; this is an instrumentation system which alerts operators of a fire and indicates its location
DSAR-9.11 Information Use Page 7 of 12 Fire Protection System Rev. 2
- The Fire Suppression System; this includes firefighting equipment such as automatic sprinklers, deluge systems, portable fire extinguishers, automatic Halon fire extinguishing systems, standpipe hose systems, and outside fire hydrants
- The features of plant design and construction which contribute to the separation of fire hazards into zones and fire areas Reference 9.11.11.3, EA97-001, Updated Fire Hazards Analysis 9.11.4.2 Facilities, Systems and Equipment That Could Result in a Radiological Hazard Requirements of 10 CFR 50.48(f)(3) apply to fire protection for facilities, systems and equipment that could result in a radiological hazard, taking into account the decommissioning plant conditions and activities.
9.11.4.3 Fire Protection Systems and Features 9.11.4.3.1 Fire Detection and Alarm System The Fort Calhoun Station fire detection system consists of extensive fire detectors, strategically located manual fire alarm pull stations, and numerous local annunciator panels located throughout the plant and general site buildings.
Various types of detectors are used in the plant.
Fire detectors in the general plant area are arranged to sound an alarm on the fire alarm annunciator panel in the control room. This panel also has indicating lights to show the specific fire detection zone/room involved.
The fire detection system within the containment building includes specific coverage for fires in the reactor coolant pump compartments. If a fire is detected inside the containment, it will be extinguished using portable firefighting equipment.
Location of detectors at strategic positions is shown in Figures 9.11-1 through 9.11-10.
9.11.4.3.2 Fire Suppression System The Fire Suppression System consists of several sub-systems as described in Reference 9.11.11.3, EA97-001, Updated Fire Hazards Analysis.
DSAR-9.11 Information Use Page 8 of 12 Fire Protection System Rev. 2 The fire protection water supply system (see P&ID 11405-M-266) has two vertical turbine type fire pumps, one electric motor driven and one diesel engine driven, each rated for 2000 gpm at 125 psig. Pressurization of supply piping is provided by means of a jockey pump. If pressure drops below predetermined setpoints, the fire pumps automatically start. The fire pumps can also be started manually from the control room or locally. The electric fire pump starts automatically whenever a transformer spray thermostat calls for the deluge valve to open. The diesel driven fire pump starts automatically if the electric pump fails to start after a time delay. The electric pump can be secured remotely or locally however the diesel engine can only be secured locally. Both pumps deliver screened and strained Missouri River water to the plant's underground water distribution system, which in turn supplies the plant's automatic water fire suppression systems, interior hose stations, and fire hydrants in the yard.
Dedicated manual operator action may be used for maintaining fire pump functionality when the automatic actuation logic is disabled. The difference in response time between manual operator action starting a fire pump based on a valid demand and the fire pump starting automatically on low system pressure will have an insignificant effect on fire suppression system performance.
An independent underground looped yard main system capable of delivering sprinkler flow plus adequate hose flow to support manual fire fighting for a single fire is provided for the fire protection system. Freezing of the fire water distribution system is prevented by burying the piping below the frost line and by routing indoor piping through heated areas. The system is provided with various types of sectionalizing valves to facilitate the isolation of portions of the system for maintenance or repairs, without interrupting the supply to the remaining system.
Automatic sprinkler and water spray protection is provided in several areas. Wet pipe, dry pipe, deluge, preaction and water curtain systems are utilized where appropriate and applicable to the hazard.
DSAR-9.11 Information Use Page 9 of 12 Fire Protection System Rev. 2 Several plant areas are provided with automatic Halon extinguishing systems. Guidelines established in NFPA 12A were generally followed in the system design and installation. The Halon Systems extinguishing agent is a gas. The gas is a clean extinguishing agent as it leaves no residue and the Halon vapor has a low level of toxicity.
Based on Underwriters Laboratories tests, the agent is classified as Group 6, which is the least toxic classification of life hazard for concentrations up to 20%.
Hose stations are located throughout the Facility. The hose stations are located such that adjacent areas can be reached in case of fire.
Fire hydrants are located around the perimeter of the plant.
The hydrants are fed by the yard loop. Inside of the Protected Area outdoor fire hydrants are equipped with hose houses which contain the hose, nozzles, and tools.
Firefighting equipment located in hydrant hose houses is readily available. Additional fire hydrants are located outside of the Protected Area. These hydrants are outside of the Security Fence and are not equipped with hose houses.
Portable fire extinguishers are provided (generally in accordance with NFPA 10 - Standard for Portable Fire Extinguishers) throughout the Facility. Extinguisher type has been matched to the hazard in the area.
9.11.4.4 Plant Design and Construction Features The plant has been divided into fire areas. Walls enclosing separate fire areas utilize fire resistive construction (OPPD Drawing D-4098). Most configurations are listed in the UL "Fire Resistance Directory." Openings in plant fire barriers are protected as practical, by rated fire doors, fire dampers, and fire barrier penetration seals.
Reference 9.11.11.3, EA97-001, Updated Fire Hazards Analysis
DSAR-9.11 Information Use Page 10 of 12 Fire Protection System Rev. 2 9.11.5 Radioactive Release Reference 9.11.11.7, EA17-002, Fire Protection Radiological Consequences Analysis and the Reference 9.11.11.3, EA97-001, Updated Fire Hazards Analysis evaluate the Fort Calhoun fire areas and determine the areas that have the potential to result in a fire induced radiological hazard in the event of a fire in the area.
9.11.6 Safety Evaluation The Reference 9.11.11.3, EA97-001, Updated Fire Hazards Analysis contains the following:
- Description of the location and construction of the fire area.
- Identification of significant combustible loads in the fire area.
- Description of fire protection features in the fire area.
- Summary of the Radioactive Release compliance strategies.
9.11.7 System Design Evaluation A systematic approach was utilized for the review of the fire hazards. The type and quantity of combustible materials, the resulting combustible loading in the area, and the fire protection features for the area were identified. The effects of postulated fires and the minimization of radioactive releases to the environment were evaluated based on available documentation.
9.11.8 Fire Protection Program Documentation, Configuration Control, and Quality Assurance Procedure CC-FC-211, Fire Protection Program, defines the management policy and program direction and defines the responsibilities of those individuals responsible for the plans implementation.
Fire protection Quality Assurance requirements are documented in NO-FC-10, Quality Assurance Topical Report (QATR).
9.11.9 Tests and Inspections Specific measures are established for independent inspection of activities affecting fire protection. This program is executed by, or for, the organization performing the activity to verify conformance with documented modification drawings and test procedures for accomplishing the activities.
DSAR-9.11 Information Use Page 11 of 12 Fire Protection System Rev. 2 The Quality Assurance Program assures that testing is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. The tests are performed in accordance with written test procedures. The test results are properly evaluated and appropriate actions taken if required.
Periodic testing and inspection requirements as well as required actions for non-functional equipment are presented in Reference 9.11.11.9, SO-G-103, Fire Protection Functionality and Surveillance Requirements. Administrative controls implement the required actions and the test and inspection requirements presented in SO-G-103.
9.11.10 B.5.b Requirements Applicable sections of B.5.b, February 25, 2002, Interim Compensatory Measures Order (EA-02-026) contains requirements to maintain or restore spent fuel cooling capabilities using existing or readily available resources (equipment and personnel) that could be effectively implemented under the circumstances associated with the loss of large areas of the plant due to explosions or fire. Reference 9.11.11.1, FCS License Condition 3.G and Reference 9.11.11.2, NRC-17-018, Rescission of Interim Compensatory Measure B.1.A from EA-02-026.
As a result of the Order, the interface between plant safety and security operations has been strengthened to include fire-fighting response strategies and training, plant operations to mitigate fuel damage, and actions to minimize releases. Actions to minimize releases include consideration of water spray scrubbing using offsite firefighting equipment. Strategies for containing runoff due to spray scrubbing are contained in Fort Calhoun Station guidance documents.
9.11.11 General References 9.11.11.1 FCS License Condition 3.G 9.11.11.2 NRC-17-018 Rescission of Interim Compensatory Measure B.1.a from EA-02-026 ORDER FOR INTERIM SAFEGUARDS AND SECURITY COMPENSATORY MEASURES 9.11.11.3 EA97-001 - Updated Fire Hazards Analysis (UFHA) 9.11.11.4 EA95-022 - NFPA Code Compliance 9.11.11.5 EA10-043 - Radioactive Release Review
DSAR-9.11 Information Use Page 12 of 12 Fire Protection System Rev. 2 9.11.11.6 EA17-001 - Spent Fuel Pool Cooling Fire Impact Analysis 9.11.11.7 EA17-002 - Fire Protection Radiological Consequence Analysis 9.11.11.8 SO-G Station Fire Plan 9.11.11.9 SO-G-103 - Fire Protection Functionality and Surveillance Requirements