ML20206M415

Forwards Revs to App A5.7 of Facilities App R Fire Protection Rept.Rev Includes Braidwood Facility.Revised App Will Be Included in Future Amend to Rept

ML20206M415
Person / Time
Site:	Byron, Braidwood, 05000000
Issue date:	08/15/1986
From:	Miosi A COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
1988K, NUDOCS 8608210207
Download: ML20206M415 (35)

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) Commonwealth Edison l

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Address Reply tJ: Post Office Box 767 Chicago, Illinois 60690 0767 August 15, 1986 Mr. Harold R. Denton U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, DC. 20555

Subject:

Byron Station Units 1 & 2 Braidwood Station Units 1 & 2 Description of Appendix R Conformance as Provided by Appendix A5.7 of the B/B Fire Protection Report ,

NRC Docket Nos. 50-454. 50-455. 50-456. and 50-457

Dear Mr. Denton:

Enclosed in this report are revisions to Appendix AS.7 of the Byron /Braidwood Fire Protection Report which provides a description of conformance to Appendix R. The current version applies to Byron. This revision now includes Braidwood. Attachment 1 provides a short summary explaining the changes made to the current Appendix. Enclosure 1 provides the revised Appendix AS.7.

The revised Appendix AS.7 will be included in a future amendment to the Fire Protection Report.

Should you have any questions concering this matter please contact this office.

One signed original and fifteen copies of this letter and attachments are provided for your review.

l Very truly yours, k

A. D. iosi Nuclear Licensing Administrator

/klj cc: J. Stevens 1988i!

8608210207 860015 4 POR ADOCK 05000 r\

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ATTACIRIENT 1 DESCRIPTION OF CRANGES TO APPENDIX 5.7 Page No. Description of Change AS.7-i This is a new page which provides an introduction to the appendix. The old Appendix AS.7 was appli-cable to Byron only. The new appendix has been changed to be applicable to both Byron and Braidwood.

The new introduction explains procedure numbers for both stations and provides a brief introduction to the section. ,

AS.7-1, The page is now printed on white paper and the page A5.7-2 heading has been changed to "B/B". No other changes have been made.

AS.7-3 Page color and heading change. The first paragraph under " Byron /Braidwood conformance" has been revised to indicate that the company fire protection policy is addressed by Presidential Instruction 003 instead of the Commonwealth Edison Fire Prevention Manual.

In addition, where specific procedures are referenced, Braidwood procedure numbers have been added.

AS.7-4 Page color and heading change. Braidwood procedure numbers are added.

4 A 5.7-5 Page color and heading change. The second paragraph j under "conformance" has been revised to indicate l

that a safe shutdown analysis has now been provided

for Braidwood (Unit 1) also.

A5.7-6 Page color and heading change only.

1 4

A5.7-7 Page color and heading change. An incorrect section

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reference was corrected in the second paragraph.

Braidwood procedure numbers on description have been 1 added.

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Paga 2'of 3 '

l Page No. Description of change A5.7-8 Page color and heading change. Item "D" was moved to this page from the previous page. No other changes have been made.

A5.7-9 Page color and heading change only.

AS.7-10 Page color and heading change. Braidwood procedure numbers added. .

A5.7-11 Page color and heading change. Incorrect section references were corrected also.

A5.7-12 Page color and heading change only.

A5.7-13 Page color and heading change. Braidwood references i thru added.

A5.7-16

A5.7-17 Page color and heading change only.

I A5.7-18 Page color and heading change. An editorial correction has been made under "conformance". '

A5.7-19 Page color and heading change. Braidwood references thru added.

A5.7-22 A5.7-22a This is a new page which has descriptions which were moved from the previous page, but which were not changed otherwise.

A5.7-23 Page color and heading change. Braidwood references and added.

AS.7-24 b

- -- --- ,----,,,..- ,n ,-. -. - - - - . - , , - . . -n.-._, --,,.,,,.n_.- . - - - , , , , .--.n-. ,_ - . - , , _ . . ., , , . . . _ , . , . , _ _ , , _ - , . , - , , - - , .

Page 3 of 3 Page N_o._

Description of Change A5.7-25 Page color and heading change only, and A5.7-26 A5.7-27, Page color and heading change. Braidwood references added. In the first paragraph under "conformance",

the reference to specific Transco test reports has been changed to a general reference to contractors test reports. The last paragraph has been amended to include the surveillance interval for electrically supervised fire doors. -

A5.7-28 Page color and heading change only.

and A5.7-29

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. Enclosure 1 Page 1 of 31 B/B s

Introduction Appendix A5.7 now applies to both the Byron and Braidwood ,

stations. In many cases, specific station procedures are referenced in the description of conformance to particular .

requirements. In each case, the first procedure number is the Byron procedure (Byron procedure numbers will be preceded by a "B" only), and the second procedure number is the Braidwood A

procedure (Braidwood procedure numbers will be preceded by a ,

"BW"). In cases where the description of conformance is only r applicable to one of the stations, this is so indicated by following the description with the station name in parentheses.

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' APPENDIX R--FIRE IROTECTION PROGRAM FOR NUCLEAR

,l powstR FACILITIES 0"ERATING PRIOR TO JAN. 1,.1979

, 10 Crm 50 APPENDIX R bvRON/BRAIDWOOD CONFORMANCE RE MAR 3t S

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,.1. IEtroduction and Scope r .

This T.pg endix app *ies to licensed nuclear power Although Appendiu R to 19 CFR 50 applies Slactric generating stations that were operating strictly to plants licensed to o6erate

prior to January 1, 1979, except to*the extent prior to January 1, 1979, the NRC 1as set forth in paragraph 50.40(b) of this part. made conformance to 20 CFR 51 A m ndia R Eith respect to certain generic issues for a licensing requirement for Dyron/nrald-ruch facilities it sets forth fire protection wood. See NRC question 500.01 (June 3, fsatures required to satisfy Criterion 3 of 1981).

Appendix A to this part'.

Criterion 3 of Appendix A to this part speciftas that " Structures, systems, and components important to safety shall be designed and located to .

, cizimise, consistent with other safety require-ments, the probability and effect of fires and s" plosions.*

s when considering the effects of fire, those #

u. cystems associated with achieving and maintain-q ing safe shutdown conditions aestsee major 4

• importance to safety because damage to them can lead to core damage resulting from loss of coolant through bo11off.

The phrases "important to safety," or " safety

• related,' will be used throughout this The design basis of the Fyron/Braidwood Appendia R as applying to all safety functions. plant has f rom the beginr.ka.; been that The phrase " safe shutdown" will be used throughout Not Standby (as defined in the Technical this Appendia R as applying to both hot and cold Specifications) is a " safe shutdown" i thttdown functions. condition, since the plant can be main-tained in Hot Standby for en extended

, .ecaus. fi,e ma, af,ect .af. .hutd n .,st.as and because the loss of function of systems cyer-r- -*c*>

used to mitigate the consequences of design M trj ba21s accidente under postfire conditions does 03 D not per se impact public safety, the need to (Q O 11 Lit fire damage to systems required to achieve OH l End maintain safe shutdown conditions is greater O t

than the need to limit fire damage to those bJ U3 eystems required to mitigate the consequences O

, of design basis accidents. Three levels of O ti

! fire damage limits are established according to NO the safety functions of the structure, system, or component g l

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,s F N s/ M T M D CONP01emem DFwpK::

10 CPR "JO AF N NDTI R Saf ty Function Fire Damage Limite

.1 Not Shutdown...One tesin of equipment necessary to achieve hot shutdown from either the control

! room or emergency control station (s) must be maintained free of the damage by a single i fire, including an esposure fire.' .

Cs12 Shutdown...Both trains cr equipment necessary to achieve cold shutdown. spay be (amaged by a single fire, including an ex-i posure fire, but damage must be limited s2 thal 4t least one train can be repaired or made opereta within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> using onsite c:pability.

De21gn Basis Accidents...Both trains of equis;-

l ment necessary for mitigation of consequences following design basis accidents may be damaged by a single exposure fire.

Th3 most stringent fire damsge limit sna11 rpply for those systems that fall into more 8 3 than one category. Redundant systems used to i- citigate the consequences of other design basis

,7 accidents but not necessary for safe shutdown may be lost to a single exposure fire. How.

!' ** evIr, protection shall be provided so that a firs within only one such system will not damage the redundant system.

I II. Genital Requirements

! A. Fire Protection Program The applicant's fire protection program complies with these requirements as described below.

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A fire protection program shall be estab- Commonwealth Edison Presidential Instruction 003 l 11shed at each nuclear power plant. The outlines company-wide policy for fire prevention. I l program shall establish the fire protection The Fire Protection Report Section 2.2, " Fire nazards policy for the protection of structures, Analysis' and Section 2.3, " Safe Shutdown Analysis

• systems, and components important to establish the components for safe shutdown. Prefire

, safety at each plant and the procedures, plans establish the components needed and the equipment, and personnel required"to imple- protection for the area.

ment the program at the plant site.

BAP 1100-1 Section C1-5/3WAP 1100-1 detines the l responsibilities, procedures, and personnet for the Fire Protection Program.

4 The fire protection program shall be under BAP 1100-1 Section C.E.a/9WAP 1100-1 identifies the the direction of an individual who has been Station Manager for establishing the fire protection l delegated authority comumensurate with the program.

responsibilities of the position and who has available staff personnel knowledgeable SAP 1100 T1/BWAP 1100-1A1 shows the flow charts of In both fire protection and nuclear safety. responsibility with the Station Manager. ' Staff l available to him includes Pire Marshall, Technical Staff, Caco Pire Protection Coordinator, CBCo Pire Protection Engineer, and operating staff.

7 The flee protection program shall estond Comply. The F/B fire protession progree includes I O'

y the concept of defense-in-depth to fire these general objectives withine it.

w protection in fire areas important to safety, with the following objectives BAP 550-9 Section C3/DWAP 550-0 outlines inspection l '

i e to prevent fires freus starting requirements for spill preventlojn. +

SAP 000-9 Section C r6 quires a weekly inspection of l i service building store's combustible materials - f l )

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' (Byron only - covered elsewhere for staidwood). y D3 BAP 1100-7 Sectio.4 C5-13/3WAP 1100-11 controls lu-her I@

plus other combustibles in the plant including O safety-related areas.

gg MAP 1100-9 Section P/BWAP 1100-10 controls l C combustibles and flammable liquids.

SAP 1110-15/aWAP 1100-10 addresses plant housekeeping and requires periodic instructions for fire hasards. l BMP 3300-6/8WAP 1100-15 outlines fire prevention when welding and cutting. l m

f. , v 10 CFR % APFTirDTX R MRON/BRATW NNM NM o to detect rapidly, control, and eu. .The detection system alarms in the main control tinguish promptly those fires that do room. The proper method of reporting fires is occurs identified in BAP 100 Fire and Emergency Notification and Evacuation Plan /BWAP 1100-1. g BAP 1100-10, -11. -12/BWAP 1100-2, -3, -4 are the implementing procedures for the Fire Marshall, Chief  !

l' and brigade respectively to respond during a fire.

.r BAP 1100-16/BWAP 1100-13 provides for a Fire Watch in areas where detection or suppression systems are inoperable. l BAP 11CO-17/BWAP 1100-6 is the implementation of the g prefire plans for the station.

Fire estinguishing is described in BAP 1100-13 BAP-1100-11. In addition, agreements have been made with the local fire department for assistance g (Byron).

DNAP 1100-2, -3, and -4 address the implementation of the Fire Marshall, Fire Chief and Fire Brigade, respectively, in a fire situation. BWAP 1100-5 addresses Fire Dep rtment response, notification, ,

mutual aid agreements and espected chain of events s during a fire (Braidwood).

• O to provide protection for structures, BOP-FF013/BWOP FP-13 outlines the use of hand held l tystems, and components important to foam hose for fire fighting.

refety so that a fire that is not promptly extinguished by the fire BOP FF015/BWOP FP-20 outilnes tLa manual initiation l suppression activities will not prevent of CO2 with loss of power, the safe shutdown of the plant.

BOP FP-19/BWOP FP-19 outilnes manual initiation of  !

the charcual filter deluge.

e BOP FP022 (to be written at Braidwood) outlines T EU manual initiation of Halon. These apply to areas 08 3 where fire protection may fall to respond and allow d3 O for a longer duration. H 1he Fire Hazards Analysis 2.3 and Safe Shutdown fn O Analysis 2.4 address components, structures, and safe O shutdown capability. g Prefire plans address protection of equipment. g, Fd Fd

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i Pf 3DR'sMTWOOD Cop 01MM RM E le CPP 9 APPEfMT 3 D. Fire Rasards Analysis A Fire Basards Analysis was performed for the Byron /

l Fraldwood stations and was included with the Fire j' A fire hasard analysis shall be performed Protection Report, filed with the NBC on October 31.

by qualified fire protection and reactor 3977, This report documented conformance with BTP j systems engineers to (1) consider poten. APCSS 9.5-1, Append!n A, but did not specifically a taal in situ and transtant fire hasards: address safe shutdown capability, the subject of (2) determine the conseguences of fire in Appendia R.

any location in the plant on the ability to ,

safety shut down the reactor or on the The Applicant has performed Safe Shutdown Analyses ability to minimize and control the release for the syron and Braidwood units which demonstrate of radioactivity to the environdbnts and the ability to safely shut down the units following a (3) spee!!y measures for fire prevention, fire in any sone. The analyses are included in fire detection, fire suppression, and fire Section 2.4 of the Fire Protection Report.

containment and alternative shutdown capability as reqeired for each fire area The fire hasards analysis and the safe shutdown containing structures, systems, and com- analysis were performed primarily by the architect /

Ponents important to safety in accordance engineer for this plant. Engineering personnel from

! with NRC quidelines and regulations

• the AE's mechanical, electrical and structural i disciplines participated in these efforts. They are

thoroughly familiar with the overall plant design and with the design of the many systems and components within the plant, including the reactor and related systems. Significant participation was also obtained f rom the applicant's engineering staf f and the

, station personnel (fire marshall and operating u.

start). A p alified fire protection engineer

• participatM in the preparation of the fire hasards

• 4 analysis, and reviewed the final results. The participation by engineers from all of the relevant disciplines, and personnel esperienced in operation as well as design ensures that the requirements set forth here have been met.

Also see FPR Section 3.1.b. ,

i C. Fire Prevention Features Comply. The fire prevention program and plant features meet these requirements.

Fire Protection features shall meet the following general requirements for all fire M3 EU areas that contain or present a fire hasard UU to structures, systems, or components in-Portant to safety. jj ,

1. In situ fire hasards shall be identified Fire hasards were considered in the plant design as Ch and suitable protection provided. shown in the Fire Protection Report Section 2.3. In g

situ combustible materials have been identified for gg a!! fire sones in the plant and they are listed in pg g i Table 2.2-1 of the Fire Protection Report. Suitable protection has been provided for all plant areas. og ps Table 2.2-3 also lists a!! detection and suppre9sion ps available in each fire zone.

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10 CFR 50 APPENDIX R N fire sard analysis tw 1 des an all m we

2. Transient fire hasards associated with I" "'*"'I'"" **IDI'* " "D' ' ""IDI*

normal operation, maintenance, repair, I"""" Y I" *** III' "" " I'

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or modification activities shall be ssient m ismaterials a m tro11M ucess area." W ific tran-identified and eliminated where possible, which could be present are not Those transient fire hasards that can m i en !!! rather, a transient hasard g ivalent be eliminated shall be contro1}ed pad in Stu content to one or more S5-gallon drums suitable proteetion,prootde4J of lubricating oil is assumed and the Stu content is added to that of the identifled in situ combus-tiblee in calculating the fire sones fire load.

Administrative controle reisting to the control of transtent combustibles are estabitehed as discussed in FPR Section 3.2.a through 3.2.c.

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s 10 CFR 50 APPENDIX R BYRON /BRAIDWOOD CCNFORMANCE PEMARKS 1

3. Fire detection systems, portable Byron /Braidwood Stations comply as documented in the

. entinguishers. and standpipe and hose FPR Section 3.6.

I stations shall be installed.

Bedundant safe shutdown components and systees are 4 Fire barriers or automatic suppression not always separated by fire barriers and/or i

systems or both shall be installed protected by automatic suppression systems. All as necessary to protect redundant deviations from this requirement are identified and

, systems or components necessary for justified in Appendix AS.S.

j safe shutdown.

I i The site fire brigade is established as described in l S. A site fire brigade shall be established. BAP 1100-13/BWAP 1100-4. Defer to section III.H and l trained, and equipped and shall be on Igg.1 of this Appendix.

site at all times.

6. Fire detection and suppression systems Byron /Braidwood Stations fire protection and shall be designed, installed, maintainede suppression systems are designed and constructed as and tested by personnel properly described in FPR Section 3.1 of Paragraph 1.a.',

qualified by experience and training Beasonsibility for Fire Protection Program, Design in fire protection systems. Phase and 1.b, Construction and Operating Phase.

The following procedures are applicable to the i

maintenance and testing of fire detection and suppression systems: Das 3.3.7.1-1, Bus 3.3.7.1-3,  !

BNS 3.3.7.1-4, sus 3.3.7.1-5, sus 3.3.7.1-6, and BRS Rm 3.3.2.1-2. (Byron)

Various procedures included in the Electrical

{ Maintenance Department SWHS 4002 and 400g series are applicable to the maintenance and testing of fire l detection and suppression systems (Braidwood).

See also FPR Sections 3.1.a(3) and 3.1.a(5) .

7 surveillance procedures shall be The following survelliance procedures have been q g {f established to ensure that fire barriers established to ensure that fire barriers are in place are in place and that fire suppression and fire suppression systems are operable Det 4200-11 Bar 4200-12, Bar 4200-13, BNP 4200-22. BNP g) g systems and components are operable. g g, 4200-24, O BOS FP-4,BMP 3200-10, SMS BOS 7.11.2.a-1, 7.11.2-1, and BMS 7.10.5.a-1').

DOS 7.11.2.b-1 (Byron on gy C

l Many surveillance procedures as dictated by 0N applicable codes and regulations have beem Ph G

. established to ensure that fire barriers are in place l and that fire suppression systems and components are $h p

operable (scaldwood).

See also FPR Section 3.2.j.

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10 CFR 50 APPENDIX R BYRON /BRAIDWOCD CONFORMANCE REMARKS D. Alternative or Dedicated Shutdown capability Byron /Braidwood compiles with this requirement.

Specific plant areas for which alternate shutdown in areas where the fire protection features components or systems have been installed include the cennot ensure safe shutdown capability in control room and the ausiliary electrical equipment the event of a fire in that area, alter

• room. Specific details for each room are described f native or dedicated safe shutdown capability in Section 2.4 of the Fire Protection Repor t.

thall be provided. ,,

III. Specific Requirements A. Water supplies for Fire Suppression Systems The B/8 design complies with these requirements in Part A as described in Section 3.6.b and Appendia Two separate water supplies shall be 5.4, Subsection A5.4.1 of the FPR.

provided to furnish necessary water volume and pressure to the fire main loop.

Each supply shall consist of a storage tank, pump, piping, and appropriate iso-lation and control valves. Two separate redundant suctions in one or more intake structures from a large body of water (river, lake, etc.) will satisfy the r uirement

5 for two separated water storage Akas . or These supplies shall be separated so that e a f ailure of one supply will not result in D

• a failure of the other supply.

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Rach supply of the fire water distribution cystem shall be capable of providing for a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> the manie n expected i -

water demands as determined by the fire hazards analysis for safety-related areas or ether areas that present a fire espqsure ~

hazard to safety-related areas.

when storage tanks are used for combined service-water / fire-water uses the minimum volume for fire uses shall be ensured by means of dedicated tanks or by some physical means such as vertical standpipe for other water service. A&sinistrative controls, including locks for tank outlet valves, are unacceptable as the only means ,

to ensure minimum water volume.

Cther water systems used as one of the two

fire water supplies shall be permanently

' connected to the fire main system and shall

$ be capable of automatic alignment to the *

fire main system. P eps, controls, and e I e power supplies in these systems shall

• catisfy the requirements for the main fire pumps. The use of other water systems for fire protection shall not be incompatible with their functions required for safe plant shutdown. Failure of the other system rhall not degrade the fire main system.

D. Sectional Isolation valves Sectional isolation valves such as post The S/5 design complies with this requirement indicator valves or key operated valves as described in Section 3.6.b(2) and Appendiz shall be installed in the fire main loop 5.4, Subsection 5.4.1 of the FPR.

to permit isolation of portions of the main yg fire main loop for maintenance or repair gg without interrupting the entire water gg cupply, gg O

gg C. Cydrant Isolation valves OC Valves shall be installed to permit isolation The 3/3 design complies with this requirement t1 cf outside hydrants from the fire main for as descr ibed in Section 3.6.b(3) and Appendis Om maintenance or repair without interruptin9 5.4, Subsection 5.4.1 of the FPR. M p

the water supply to automatic or manual fire (,a ruppression systems in any area containing H-or presenting a fire hazard to safety-related or safe shutdown equipment. _

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10 CIR 50 APPENDIX R BYRON /BRAIDWOOD CCelFORMANCE REgg s D. Manual Fire Suppression Sttndpipe and hose systems shall be installed B/B complies. See FPR Section 3.6.c(4) and Appendis so that at least one ef fective hose. etream 5.4, Subsection A5.4.7.

will be able to reach any location that contains or presents an exposure fire h2sard to structures, systems, or components important to safety.

Access to permit effective functioning of 8/5 complies. Access routes for fire fighting are listed in the Pre-Fire Plans, tha fire brigade shall be provided to all ars:as that contain or present an exposure ftre hazard to structures, systems, or components important to safety.

Standpipe and hose stations, shall be s/s complies. See FPR Sections 2.3.1, 3.7.a.

inaide PwR containments and BWR containments and Appendia 5.4, Subsection A5.4.7.

3 that are not inerted. Standpipe and hose stations inside containment may be connected to a high quality water supply of sufficient quantity and pressure other than the fire main loop it plant-specific features e l'

prsvent extending the fire main supply inside w containment. For BWR dyrwells, standpipe end hose stations shall be placed outside the dry well with adequate lengths of home to reach any location inside the dry well with an effective hose stream.

E. Eydrostatic Hose Tests Fire hose shall be hydrostatically tested Comply. . Refer to BMP 3200-0/0ewoS 7.10.5.C.2-1 and at a pressure of 150 psi or 50 psi above anP 3200-9/0ewoS FP-A2. See also FPR Section maximum fire main operating pressure, 3. 6.c (6) .

whichever is greater. Hose stored in outside DM NU hose houses shall be tested annually.

Interior standpipe hose shall be tested ev2ry three years. O H [A F. Automatic Fire Detection gg t1 Automatic fire detection systems shall be B/B complies. See FPR Section 3.6.a and Appendis O (D installed in all areas of the plant that 5.4, Subsection A5.4.8. m contain or present an exposure ftre hazard g i to safe shutdown or safety-related systems u or components. These fire detection systems H shall be capable of operating with or w i t h..u t ofenste yww.ar . ,

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10 CFR 50 APPENDIE R 3YRON/ BRA!! WOOD COMORMANCE PEMARKS 4

6. Fire Protection of Safe Shutdown capability

1. Fire protection features shall be Byron /Braidwood complies with this requirement.

provided for structures, systems, and Certain plant configurations esist, each of which is components important to safe shutdow't. described and justifa'ed below under the discussion These features shall be capable of for Section III.G.2 and Appendis A5.8, where g limiting fire damage so thsto separation of redundant safe shutdown components or systems is not as specified in Section 111.C.2.

a. One train of systems necessary to Tating credit for the alternative separation and j

achieve and maintain hot shutdown protection features identified in these deviations

, conditions from either the control room from the reqettements of Section III.C.2, one train i

or emergency control station (s) is of systems necessary to achieve and maintain hot free of fire damages and shutdown w!!! remain free of fire damage, and systems required to achieve and maintain cold shutdown will

b. Systems necessary to achieve and maintain either remain free of fire damage or will be cold shutdown from either the control repatrable so that cold shutdown can be ac'ileved room or emergency control station (s) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, for each fire area in the plant.

j can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

> 2. Except as provided for paragraph G.3 Deviations from the requirements of Section It!.C.2 I are described in Appendis AS.S. In each case, a ,

7 of this section, where cables or equip-detailed description of the deviations is included, s W

y ment, including associated non-safety circuits that could prevent operation or modifications !!f any) implemented as a result of the j **

deviation are described, and a justification for the cause meloperation due to hot shorts, open circuits, or shorts to ground, or deviation is provided.

l redundant trains of systems necessary

' to achieve and maintain hot shutdown con-ditions are located within the same fire area outside of primary containment, one of the following means of ensuring

! that one of the redundant trains is free j of fire damage shall be provided:

a. Separation of cables and equipment and i associated non-safety circuits of redundant trains by a fire barrier having a 3-hour rating. Structural i

steel forming a part of or supporting gg I such fire barriers shall be provided gg to provide ftre resistance equivalent O to that required of the barriers pm hJ C

, b. Separation of cables and equipment and q I associated non-safety circuits t>f OG redundant trains by a horizontal dis- m tance of more than 20 feet with no p i

intervening combustible or fire hazards. L,3 In addition, fire detectons and an H automatic fire suppression system shall be installed in the fare areas or - .

g y pyg 10 G R 50 A M NDIE R BYRON /SRAIDWOOD CCsdTORMANCE

e. Enclosure of cable and equipment and associated non-safety circuits of one redundant train in a fire barrier having s 1-hour rating. In addition. fire '

detectors and an automatic fire suppreeston system shall be installed

• r in the fire areas Inside nominerted containments one of the fire protection means specified above or one of the following fire protection means shall be provideos

d. Separation of cables and equipment and associated non-safety circuits of redundant traine by a horisontal .

distance of more than 20 feet with no intervening combustibles or ftre hasards:

e. Installation of fire detectors and an automatic fire suppression system in

• the fire areas or Separation of cables and equipment and &

2. f. w

• • associated non-safety circuits of redundant trains by a shetible radiant energy shield.

3. Alternative or dedicated shutdown capa- Taking credit for the alternative separation and bility and its associated circuits, protection features described above for those independent of cables, systems or plant areas which deviate f rom the requirementa components in the area, room or sone of section III.C.2, Syron/Bralduced compiles with under consideration, shall be provided: this requirement.

a. Where the protection of systems whose function is required for hot shutdown 'O M does not satisfy the requirement of DJ D paragraph G.2 of this sections or (O O where redundant trains of systems OH

b. O required for hot shutdown located in P U) the same fire area may be subject to WC dameqe from fire suppression acttwities or f rcus the rupture or inadvertent operation of fare suppression systems. D H

In addition. fire detection and a flued fire suppression system shall be installed in the area, room, or zone ~

unde

• consideratlon. .

k $.

e 10 CFR 50 AFPEND1E R BVRON/BRAIDWOOD CC WFORMANCE E MARES e

W. Fire Brigade g syron and traidwood comply with one exception noted g A site brigade trained and equipped for below. The fire brigade wi!! seet the requirements fire fighting shall be established to stated herein, escept that exception is taken to the ensure adegaate manual fire fightintg'capa- performance standards required by the annual physical t;ility for all areas of the plant containing esamination. The wording "abt!!ty to perform structures, systems, or components important strenuous fire-fighting activities" is lacking in to safety. The fire brigade shall be at specific detail and is open to wide interpretation.

least five members on each shift. Th* The annual physical will demonstrate that fire brigade leader and at least two brigade brigade members are capable of performing members shall have sufficient training in unrestricted physical activity.

or knowledge of plant safety-related systems l ta understand the effects of fire and fire Bay 113e-1/gukP 1100-1 Fire Protection Program sets suppressants on safe shutdown capability. forth the qualifications for the members of the fire The qualification of fire brigade members brigsde. These requirements set forth the training shall include an annual physical esamination and physical condition of the members of the to determine their ability to perform brigade. All brigade members complete the training Etrenuous fire fighting activittee. The course set forth by the C - raith Edison shift supervisor shall not be a member of production Training Department Technical Training or the fire brigade. The brigade leader Section

• Training Standard for Initial Training of y shall be competent to aseees the potential Inselear Station Fire Brigade Members." The Fire safety consequences of a fire and advise Brigade 1.eader who is designated Shift Foreman holde control room personnel. Such competence an operator's license or has squlwalent knowledge.

by the brigade leader may be evidenced by Refer also to SAP 1194-13/SMAP 1190-4.

Possession of an operator's license or - ~

equivalent knowledge of plant safety-related systems.

The minimum equipment provided for the brigade Comply. SAP 1100-1 (OeWOS FP-1) Fire Protection shall consist of personal protective equip- Program provides the regetroment of the Fire Brigade ment such as turnout coats, boots, gloves, inventory to be performed and SAP 1100-T12 (Syron hard hats, emergency consomnicatione equip- only) lists the eqelpment to be inventorted.

ment, portable lights, portable ventilation equipment, and portable estinguishers.

Self-contained breathing apparatus using is11-face positive-pressure masks approved gg by uloss tuational Institute for occupational gg S&fety and Health-approval formerly given g by the U. S. Sureau of Mineal shall be gg provided for fire brigade, damsge control, ag and control room personnel. At least.10 g assks shall be available for fire brigad* Om personnel. Control room personnel may be m g Isrnished breathing air by a manifold system p GJ piped from a storage reservoir if practical.

Service or rated coerating life shall be . H a minimum of one-half hour for the self-contained unita. - .

t >

10 CFR 50 APFENDIX R BYROM/BRAIDidOOD Ct siFORMANCE pgMAgg s Comply. The estra air bottles are included in SAP l At least two extra air bottles shall be 1100-T12/m " S FP-1 inventory form for the fire located onsite for each self-contained . brigade equipment. The 6-hour supply of reserve air p breathing unit. In addition, an onsite 4 6-hour supply of reserve air shall be is supplied by a bank of cylinders and bottles which is under the control of the mad-Chem department.

provided and arranged to permit qujqk and Compressors are not used to supply breathing air for complete replenishment of eshausted'aupply the fire brigade, cir bottles as they are returned. If compressors are used as a source of breathing air, only units approved for breathing air shall be useds compressors shall be operable assmaing a loss of of fsite power. Special ccre must be taken to locate the compressor la areas free of dust and containinants.

I. Fire Brigade Training The fire brigade training program shall The fire brigade training program meets the ensure that the capability to fight poten- requirements presented herein. This is addressed in tial fires is established and maintained. BAP 1100-13/StenP 1100-4. l The program shall consist of an initial

• classroom instruction program followed by The fire brigade training program is administered periodic classroom instruction, fire through a Training Standard for teuclear Station rire

• a

, fighting practice, and fire drills. stigade stenbers developed by the Braidwood Production *

• Training Center.

1. Instruction Byron and Braidwood ly with Parts a through e.

a. The initial classroom instruction l shall anclude: see SAP 1100-13/st8AP 1100-4.

(1) Indoctrination of the plant fire fire fighting plan with specific identification of each indivi-dual's responsibilities.

(2) Identification of the type and gg location of fire hasards and pp associated types of fires that Qa could occur in the plant. GH O

6 39 The toxic and corrosive character- H (A istics of expected products of U1 C combustion. Pt OG ten Identification of the location of Hi ,

fire fighting equipment for each H fare area and familiarization W with the layout of the 3,lant, H ancludang acca n ard e.oreas routes to c.ecti .e rca . .

s 10 Cyt 50 APPEND 11 R BYRON /8RAIDWOOD CtNFORMANCE REMARMS (5) The proper use of available fire fighting equipment and the correct method of fighting each type of fire. The types of fires covered .

should include fires in energized electrical equipment, fires in cables and cable trays. hydro-gen fires, fires involving flasmmable and combustible liquids or hasardous process chemicals, firee resulting from construction or modifications (welding), and record file fires.

(5) The proper mee of c-alestion, lighting, ventilation, and ,

emergency breathing equipment.

(7) The proper method for fighting firee inside buildings and y confined spaces.

w m e (8) The direction and coordination of All brigade members get the 1e.dership course (Byron *

,' the fire fighting activitteg only).

• (fire brigade leaders only).

(9) Detailed review of fire f agSting Training of fire-fighting strategies and procedures strategies and procedures. is included in the initial and continued training.

(10) moview of the latest plant modi- preplanned meetings are held (Syron). This subject

• **

• e ding is covered during fire brigade training (Braidwood). l

, , g plane.

NOTE: Items (9) and (10) may be deleted from the training of no more than two of the non-operations per- y tij sonnel who may be assigned to the g; y fire brigade, 4O

b. Licensed qualified instructors from the local fire (D H The instruction shall be provided by O qualified individuals who are knowledge. department have provided the initial training of the H 0) able, esperienced, and suitably trained fire brigade (Byron).

OC in fighting the types of fires that r1 could occur in the plant and in using The training of the fire brigade is conducted by a O (D the types of equipment available in quallfled member of the Ceco training department. Ph the nuclear power plant. The Fire Marshall and state-certified memberg of the H Crco Fire Marshall's Staff supervise this training OJ

c. Instruction shall be provided to all 18taldwood). H ftre brigade members and ftre brigade leaders. -

1 p

1 i

gypog/BRAIDWOOD CCriFORMANCE RCMApgs 10 CFR 50 APPENDIE R i

l I

d. Regular planned meetinge shall be held Comply. SAP 1100-1/suhP 1100-1 Fire Protection Program sets forth the requirements to hold planned l

at least every 3 months for all brigade members to review changes in the fire meetings quarterly for all brigade members to review protection program and other,sybjects changes in the fire protection program, etc.

as necessary.

Comply. Periodic refresher training is included in i O. Periodic refresher training seselone the Training Standard for Nuclear Station Fire

shall be held to repeat the class- riede Members,

! room instruction program for all brigade meeers over a two-year period. These sessions may be con- =

current with the regular planned meetinge.

Byron and Sta14 wood comply. Practice sessions in l

2. Practice actuel fire extinguishment and use of emergency f breathing apparatus under strenuous conditions is l Practice messions shall be held for accomplished through the annual fire eatinguisher l each shift fire brigade on the proper training on live fires and annual smokehouse / live er

'a method of fighting the various types of fires that could occur in a nuclear fire training. )

power plant. These seselone shall

/,. Practice sessions are also addressed in SAP i

• provide brigade members with emperinece 1100-1/ SNAP 1100-1. l j in actual fire eatinguishment and the l use of emergency breathing apparatus

! under straneous conditions encountered in fire fighting. These practice seestone shall be provided at least once per year for each fire brigade member.

Items 3a through 3e are accomplished by SAP 1100-6/ ,

3. Drills guAP 1100-7 " Fire Dr!!!s." The type of drills and assessment of the drl!!s are documented on SAP

, a. Fire brigade drille shall be performed 1104-T3/BMAP 1100-7A1,

• Fire Dritt Critique in the plant so that the fire brigade pecord." Syron and traidwood comply with parts a y trj can practice as a team. through e, except as noted. D3 D Drills shall be performed at regular Comply encept as noted belows 40

b. mp intervals not to exceed 3 months for O each shift fire brigade. Each fire Byron /Braidwood Stations will perform fire brigade 4 a ta brigade member should participate in dt!!! training such that the fire brigade drills once

%J C each drill, but must participate in per quarter, so that each fire brigade member et at least two drille per year. participates in at least two fire brigade drills per OQ j

year. The brigade performs during the drill as a l'%

j team. The members may not always be the same H i

personnel. Las l H 4

(,

1 a

l 10 CFR 50 APPENDIX R BVRON/BRAIDWOOD C( s4FORMANCE REMARF5 A suf ficient number of these drills, but not less than one for each shift fire brigade per year, shall be on-announced to determine the fire fighting

• readiness of the plant fire brigade.

brigade leader, and fire protection systems and equipment. Persons planning and authorizing an ud '

announced drill shall ensure that I the responding shift fire brigade mesters are not aware that a drill is being planned until it is begun. On-announced drille shall not be scheduled closer than four weeks.

At least one drill per year shall be

, performed on a

• beck-shift

• for each shift fire brigade.

c. The drille shall be peoplanned to establish the training objectives of "

i y the drill and shall be critiqued to

• determine how well the training objec- "

l '4 tives have been met. Unannounced l ,'. drills shall be planned and critiqued

-a by members of the management staff responsible for plant safety and fire protection. Performance deficiencies

, of a fire brigade or of individual

! fire brigade members shall be remedied 1 by scheduling additional training for the brigade or members.

Unsatisfactory drill performance shall be followed by a repeat drill within 30 days.

d. At 3-year intervals, a randomly 'O trj selected unannounced drill shall be D# D critiqued by qualified individuals LQ O independent of the licensee's staff. OH A copy of the written report from such O individuals shall be available for H (A NgtC review. CO C

' P1 O. Drille shall as a minimuis include the OO following: 4 (1) Assessment of fire alarm effective- La H

ness, time required to notify and

) assemble fire brigade, and selec-tion, placement and use of equip- .

ment, and fire fighting strategies.

I l

BYRON /SPAIDWOOD CONFORMANCE PEMARES 10 CFR 50 APPEND 12 R (2) Aseeeement of each brigade member's

knowledge of his or her role in the fire fighting strategy for the area assumed to contain the

• fire. Assessment of the brigade member's conformance with established plant fire fighting procedures and use of fire fighting eqdivment, including self-contained emergency breathing apparatue, communication

, equipment, and ventilation equip-ment to the entent practicable.

~

! (3) The e1mulated use of ftre fighting equipment required to cope with the situation and type of fire selected for the drill. The area

• and type of fire chosen for the drill should differ from those used in the previous drill so that brigade members are trained

, p in fighting itres in various a y plant areas. The situation g e selected should simulate the else i ,'. and arrangement of a fire that d

a could reasonably occur in the area selected, allowing for fire development due to the time d

required to respond, to obtain i equipment and organtee for the fire assuming lose of automatic suppression capability.

(4) Aaseeement of brigade leader's direction of the fire fighting effort as to thoroughness, accuracy, and effectivenese.

TM 1 4. Secords 07 D J

Individual recorde of training provided comply. Individual recorde of training for each 4O brigade member are retained by the training OH to each fire brigade h r, including g O

drill critiques, shall be maintained department and will be available for review. The HM for at least 3 years to ensure that each dritt critique is retained in central file and will *C member receives training in all parte be available for review. M of the training program. These recorde OG of training shall be available for MRC M review. Betraining or broadened training H for fire fighting within buildings W j

ehall be scheduled for all those brigade members whose performance recorde show -

deticiencies.

\

i 10 CFR 50 APPENDIX R BYRON /BRAIDWOOD CCNFORMANCE REMARM S J. Emergency Lighting S/B complies. Eight-hour, battery-powered emergency lights are provided for plant areas that need to be Emergency lighting units with at least an manned for safe shutdown and in access and egress

! S-hour battery power supply shall be routes thereto. Testing will demonstrate the S-hour

! provided in all areas needed for operation rating of these unit's.

of safe shutdown equipment and in access and egress routes thereto. ,,

! K. Administrative Controls

! Administrative controls shall be established Byron and Braidwood ceaply. Administrative controls I to minimise fire hasards in areas containing w!!! be in effect which will comply with the structures, systems, and components import- requirements of this section.

ant to safety.

These controle shall establish procedures to

1. Govern the handling and limitation of Comply. BAP 1100-7/9WAP 1100-11

• Fire Prevention For I the use of ordinary combustible Use of Lumber and Other Combustibles

• governs the materials, combustible and f1===ahle handling and limitation of ordinary combustible n.

3 gases and liquida, high efficiency esterials. SAP 1100-9/BWAP 1100-10

• Control of I g 4

particulate air and charcoal filters, riammoble and Combustible Liquids

• governs the y dry ton exchange resins, or other com- handling and limitation of flammable gases and g bustible supplies in safety-related liquids. SWAP !!00-19 governs the handling and usage l areas. of combustible / flammable gas cylinders.

2. Prohibit the storage of combustibles Comply. Routine fire prevention surveillance is in safety-related areas or establish performed o's each shif t by the Equipment Operator or designated storage areas with appro- Equipment Attendant. Special weetly fire inspections

priate fire protection. are conducted in the storage areas laside or adjacent j to safety-related structares or systems to identify j any buildup of combustible material or other fire i hazards.

Special weekly fire inspections as identified in BAP 1100-15/BWAP 1100-18

• Station Housekeeping / Equipment l Preservation Procedure" which prohibits bulk storage eg p3 of combustible materials inside or adjacent to DJ p

.l safety-related buildings or systems during operation Qo or maintenance periods. OP O

M to oc M

OO Ni H

1 taa H

I

? , ,

k ~ >1 WTIDW/BERIDMo0p ansosomerT mmants to ogsJe w a Govern the handling of and limit Comply. Byron /Braidwood will incorporate into

3. adminletrattee procedures proviolone to control transient fire loedo such as coubestible transient combustibles. The procedures will state and flammable liquide, wood and pleetic that transient combustibles in safety-related areas, products, or other combuetable materlate which are not in approved containers, shall not be in buildinge containing safety-related left unattended, systems or equipment during all phases of operating and especially during Some procedures se in item 1 above govern.

meintenance, modification, or refueling operations. .

4. Designate the onsite etetf member Comply. The station Fire statehall is the designated responethle for the implant fir.e protec- staff member as set forth in BAP 1100-1/9WAP 1100-1. I tion review of proposed work activities to identify potential transient fire hasards and specify required additional fire protection in the work activity procedure.

$ e

.Y e a

m tn WD 4O OH O

PJ (A HC P1 OO m

H LJ H

e i

i grMAngs 10 CFR 50 APPEBCII R SYaoss/BRAIDWOOD CCssFORMANCE

5. Govern the noe of Agattion scarcos lay Comply. The welding and flame cutting work is done use of a flame permit system to control at each station with a special permit, welding, flame cutting, branlag, or g soldering operations. A separate permit MIP 3300-944/ElekP 1198-15 *Pire Protection When shall be tossed for each area where Welding and Cutting,' covers preparation and work is to be done. It work continues inspection for fire prevention when welding and over more them one shift, tWe~ permit cutting is performed. It also covers (111&ng out shall be ve11d for not more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> cutting and welding permits and precautions during i, cutting and/or welding. Also BAP 1100-3/BMAP 1100-0 l when the plant is operating or for the " Fire Protection Impairment" shall be fo11 owed when duration of a particular job during 1

t plant shutdown. esote or fire detectors are taken out of service.

6. Control the removal front the area of all Comply. Procedure SAP 1100-15/3 MAP 1100-18, " Station I waste, debris, scrap, oil spills, or Bousekeeping Equipment Preservation Proced4re,"

other combustibles resulting from the 8pecifies that combustible material can not be left unattended in safety-related areas.

work activity, immediately following complettne of the activity, or at the end of each work shift, whichever comes

first.

\

p 7 Maintain the periodic housekeeping Comply. Procedure SAP 1100-15/BMAP 1190-18 assures i e y inspections to emeure continued com- that good housekeeping inspections are met, g

., pliance with these administrative 4

controls.

8. Control the noe of specific ccumbuettbles Comply, with esceptions below:

in a safety-related arose. All wood i used in safety-ralated areas during The reactor facility at Syron/Sta!4 mood see designed maintenance, modificat'on, or refueling to ensure that the probability of events such as operatione (such as lay-down blocks - fires and emploelons and other potential consequences or scaffolding) shall be treated with of such events will not result in endue riot to the

a flame retardnat. Equipment or supplies health and safety of the public. Noncombustible and f leuch as now fuel) shipped in un- fire reelstant materials were used throughout the treated combustible pecting containere facility wherever necessary to preclude such risks, related particularly in areas containing critical pertions of may arenebe 12unpected required in safetyid for vat coerating the f acility such as containment, control room, and yg reasons. Wr, all comennettble campa= ants of engineered safety features. pg materiale shall be removed from the cn gg area isumediately following the un- Combuet!ble materiale are not used when substitutes packing. Such tremetent estible are available. When combustible meterials are used, ym o

material, antees stored in approved they are treated with fire retardant material or they containers, shall not be lef t en- are controlled as to their fire hasard. y g;

attended dering lunch breaks, n shift changes, or other stellar The control and use of speelfic combustibles in oo periods. teose combustible packing safety-related areas is assured by SAP 1100-7/ g m material such as wood or paper BuAP 1100-11 " Fire Protect ion for Use of Lumber and g-e excelsior, or polyethylene sheeting Other Combustibles.* L.3 shall be placed in metal containers H l with tight-fitting self-closing metal Exception is taken in regards to new fuel which is i covere. stored wrapped in polyethetene bags for cleanliness r eqssi remen t s. .

= .

10 CFR 50 APPENDIE a sm/BRAIDuoOD ConMMANCE prMARKS a

I

9. Control actione to be taken by an -

Comply. SAP 100-4

• Fire and toergency motification individual discovering a fire. and Evacuation Plan

• etates actions to be taken by an For example, notification of control Individual discoverlag a fire. Also refer to SEP room, attempt to entiaguish fire, and 320-1 (Byron). l j actuation of local fire suppreselon systems. Comply. SuhF 1100-1

• Fire Protectica Progree*,

states actions to be taken by an ladtvidual j

discovering a fire. Also refer to su2P 300-7

• r (araiducod).

Control acticas to be taken by the com-Comply. SAP 100-4 *Ftre and Emergency motification 10.

trol room operator to determine the and Ovecuation Plan */Bu1P 300-7 states the actions to e be taken by the control room operator on the report need for brigade assistance upon of a fire. Also ufer to SIP 320-1.

report of a fire or receipt of alarm on control room ammametator penet, for 8547 1100-1 and SuhP 1100-5 also describe the example, anmoeacing location of fire seguence of events to take place in the event of a mg b o n ftre at the Braldwood Stattoa. SWOP PF-19 addresses nd a 1 Plant ulde Fire Alara Actuattoa.*

and the fire brigade 1eeder of the type, else, and locettom of the fire.

, Y l **

. 11. Control actions to be taken by the Comply. The actione to be taken by the fire brigade fire brigade after notification by the after motification ty the control room operator of a 1, itre le identified la BAP 1100-13/DuhP 1100-4 I control room operator of a fire, for l

eaample.aosembling te a desigasteg

• Implementing Pr d ere For Fires (Fl u Brigade),* l location, receiving directione from and SAP 1100-11/guhr 1100-3 *1mplementing Procedere i

the fire brigade leader, and dischargtag for Fires (Fire Chief).*

opecific. fire fighting r==pa==1b111 ties including eelection and transportation of fire fighting egeipment to fire

location, selection of protective

' eqelpment, operettas instructions for 1 use of fire sopprooetom systems, and use of preplanned strategies for fighting fires in specific areas.

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4 10 CF3 50 APPEND 1X R BYRON / BRA!! MOOD CC sIFORMANCE DEMARKS

e. noot favorable direction from which to The pre-fire plans identify available access routes Particularly for large rooms and general ar eag, attack a fire in each area la vlee of for each some. The most favorable direction or the number of possible ftre locations are ton the went11ation direction, access location to fight specific fires from are not numerous to attempt to develop specific hallways, stairs, and doors that are most identified. The fire brigade can best determine strategies beforehand.

likely to be free of fire, and the best this upon reaching the, scene of an actual fire.

station or elevattom for fighting the fire. All access and egrese routes that involve locked doore should but ,

specifically identified la the procedere with the appropriate precautions and methode for accese specified.

C. Plant eyetems that should be managed to Important plant systems and components and poten-redmee the damage potential during tielly hasardous electrical components are iderti-a local fire and the location of local fled la the pre-fire plans.

and remote controle for each management fe.g., any hydrastic or electrical ~

systeme in the some covered by the opecific fire fighting procedure that could incrosse the hasarde in the area beconoe of overpreeenrisation or

> electrical hasardel.

I o. Vital heat-eenottive system componente comply. Vital compnnents have been defined in pre-fire plans. m Y that need to be kept cool while fighting e

U a local fire. Particularly hazardose combestiblee that need cooling should be designated.

f. Organisattom of fire fightien brigades Byron and Braldwood comply. See procedores SAP [

and the assigsument of spect.s duties 1100-1 and SAP 1100-13/ses4P 1188-4. All fire brigade l according to job title so that att members receive all of the specialised training fire fighting fenettons are covered by mentioned here.

any complete shift peroommel complement.

These dettee include W control of the brigade, trameperting fire suppreesten and support equipment to the oceses, applytag the extingulohant to the fire, - =1cetion with the gg control room.mnd coordination with gg outside fire departments. gg

g. Poteattal radiological and tosic Comply. Potential radiological and tonic hazards harords in fire somes. are identified la the pre-fire plans. yg tJ1 C

h. Ventilation system operettom that Comply. Vent!!ation system operation for smoke q ensures desired plant air distribution removal is addressed. venttiation system design Om when the weattistion flow is modified is such that fires in specific rooms will af f ect eg for fire containment or smoke clearing only the wentllatton for that room or diviserwi, p operatings. La

~H

1. Operettoms requiring control rooms and Fire fighting operations per se are not espected shaft engineer coordination or author 1= to rets a s e enne to t tone or shif4 ene e nser cnned i n- .

satson. a'**m-

la CTR SO APPCa311 R BYace/BRAIDWOOD C(WFORptANCE PTPuRE S

• * ' Y* " * ' "

j. Instructions for P aatl cP*retors and the pre-fire plans. sefer also to enhP 1100-1. I general plant personnel during fire.

L. Alternative and Dedicated Shutdown Capability ,

1. Alternettwo or dedicated ehetoown Syron and Staidwood comply. Alternate ehetdown capability provided for a specific fire ca-paaente or systems are provided for att plant area shall he able to achieve and mein- areas where the separation requiremente of section tain suberitical reactivity conditions III.C cannot be met. The requiremente stated herein in the reactor, maintata reactor coolant are met as described la sectaon 2.4 of the Fire toweator Protectica seport. .

3 standby'y,conditione achieve and formetatain hot a rua (hot obstdown' for a sum) and achieve cold ehetdown' eamattions within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and meistain cold ehetdous conditione thereafter. During the postfirs shut- .

dows, the reactor coolant system procese variables shall be meintataed 1 within those predicted for a toes of I normal a.c. peuer and the fleeton product

> ha==aaer integrity shall not be affecteds s i

• • 1.e., there shall be no feel clad *

. damage, rupture or any primary coolant

/. boundary, or rgtere of the contain-

• meat w ary.

2. The perfor= goele for the shutdown Byron /Brala-aaa camp 11ee with this requirement The performance goate !! stent h as ducribed la section 2.4 of the Fire protection "

functione shall be Seport.

implementedinconductingthesa$e Shutdown Analysis.

a. The reactivity control fonction shall be capable of achieving and emin-i taistag cold ehetdows reacttwity coa-i dations.

1

b. The remetor coolast makeup fonetton shall be capable of maintaining the reactor coolant level above the top *U t'2

} cf the core for suas and be within the 08 D level indicatica in the presseriter 5Q O for Pune. O >-*

O

c. The reactor heat removal function shall NM be capable of achieving and maintaining *C decay heat removal. M

, OQ

d. The process monitoring function shall D be capable of providing direct readings of the process variables necessary to i perform and control the above functions. -

10 CFR 50 APPgNDIX R BYRON /BRAIDWCOD CONTORMANCE DWM5

o. The espporting functione shall be capable of providing the process cooling, lubri.

cation, etc., necessary to permit the operation of the quipment used for safe shutdown functions.

3. The shutdown capability for specific syron/Braidsood complies with this requirement.

fire areas may be unique for each such Ref er to Section 2.4 of the Fire protection Report area, or it may be one enigos combi. for a description of safe shutdown capab!!!ty nation of systems for all such areas. for each fire zone. -

In either case, the alternattwo shut-

^

down capability shall be 1 '_, -- -at

• of the specific fire area (s) and shall accommodate poetfire conditions where offsite power is eve 11able and where offsite pouer is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Procedures shall be in offeet g to implement this capability, e y 4. If the capability to ethieve and m S/S complies. Refer to Safe Shutdown Analysis, e,

• malatain cold ehetdown will not be (Section 2.4 of FPR).

available because of fire damage, the equipment and systems comprising the means to achtowe and metatain the hot standby or hot shutdoun condition shall be capable of maintaining each conditions until cold shutdown can be achieved. If such equipment and sys-teme will not be capable of being powered by both emette and offsite electric power eyetame because of fire damage, en 1 " , " t onette power 5 trj system aball be provided. The number of operating shitt personnel, esclue1we P l3 of fire brigade members, required to 70

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operate such equipment and systeme O shall be on site et all times. . J 03 MC P1 O CD m

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%5 10 CTR SO APPENDIX R BYRON /3RAIDt8000 CCNFORMANCE RIMAPR5

5. squipment and systems comprising the Byron /sralamood compiles utth thle requirement scene to achieve amo maintain cold proolded credit is taken for alternative separation shutdows conditione shall not tg and protection features for certain plant areas damaged by fires or the fire demsee to described above under Section 311.4.2.

such e%1pment and systems shall tre.

11 mated so that the eyetens can be " s made operable and cold shutdog .chiewd . _

within 73 hours8.449074e-4 days <br />0.0203 hours <br />1.207011e-4 weeks <br />2.77765e-5 months <br />. Materials for such repelre shall be readily eve 11able on s site and precedures shall be in ef fect to implement such repairs. If such L equipment and systems we+5 prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the fire will mot be capable of being powered by both easite and offsite electrical power systeme because of fire damage an ~ ~ .

inder= Mt onette power system shall be provided. Boutpment and systems used after 72 heurs may ta pouered -

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by offette power only. ,

s

> Byron / Bra 1&sood complice with thte rege.trement.

• 7 6. Shutdown systems installed to ensure The only equipment which has been installert to ,

y poetfire eheteown capability need not essere posttire safe shutdown capability le thee s a be designed to meet seismic Category I criteria, single fa11ere criteria, Fire Resares Fanel which includes certain instro-maata uhtch would otherutee be unavailable following or other design beets accident criteria, a fire in either the control roam or the ausiliary except where required for other reasons, electrical equipment room. This penet le described e.g., because of interface with or impact on esisting safety systems, or in Subsection 2.4.2.16 of the Fire Protection popor t . Its design complice with the requiremente because of adverse valve actione due to fire damage. stated here.

7. The safe shutdous equipment and systems There are no associated circuite as defined in for each fire area shall be known to IBM 344-1974 at s/s. Associated circuits as be toolated from associated non-safety defined in umC's April 6, 1982, clarification circutta in the fire area so that hot letters to Generic Letter 81-12 are addressed shorte, open circuits, or shorts to in Subsection 2.4.1.5 of the Fire Protection Deport.

ground in the associated circuite yg will not prevent operation of the safe pg shutdown equipment. The separation gg and barriers between trays and gg conduits containing associated circuits o of one safe shutdome division and trays N 03 and conduits containing associated CD C circuits or safe shutdown division cables N from the redundant division, or the O (D leolation of these associated circuits 4 from the safe shutdown equipment, shall H be such that a postulated fire involving tJ associated circuits will not prevent ~

H safe shutdown.

[

REMAppS 10 CFR 50 APPE18 DIE R BYRON /BRAIDWOOD CCNFORMANCE

h. Fire Barrier Cable Penetration seal Qualification 3/B esapties. See Fra Section 3.5(al(3)(a) through (c) and Appendia 5.2, subsection AS.2.2. Cable Penetration seal designe shall utilise only penetration seals are, inspected by BVS 7.11.1-1/

noncombustible materials and shall be BIfV3 F.11.1.a-1. See contractors test reports for quellfled by tests that are comparable to details on the acceptability of seals.

teste used to rate fire barriers The receptance criteria for the test s$all include:

1. The cable fire barrier penetration seal has withstood the fire endurance test without passage of flame or ignition of cablee on the uneaposed side for a period of time egelvalent to the fire resistance rating required of the .

barriers

2. The temperature levels recorded for the unexposed eide are analysed and y demonstrate that the maximme temper.

y sture is entficiently below the cable i w insulation ignition temperature

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i 3. The fire barrier penetration seal remains intact and does not allow projection of water beyond the un-esposed surface during the home stream test.

E. Fire Doors l

Fire doors shall be self-closing or provided Byron /Braidwood complies. See FPR Section 3.5.al5).

trith closing mechanisme and shall be inspected semianraally to verify that tutomatic hold-open, relen s, and closing mechanisha and latches are operable.

tM i Cne of the following measures shall te g y g3 ()

Provid M to ensure they will pr tect <p p l

I the opening as required in case of fires o

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1. Fire doors shall be kept closed.end

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'All-fire dWrs..**c automatic closcies. Cable I

ec

• 1 spreading rooms have electrically supervised doors y

electrically super"Ised at a con- v 0 (D alarming in ede control room.

tinuously manned loca;aons -

... . ~. 4 Security will walk down fire daors, wb9ch ere pf _

2. . Fire doore shall be locked and inspected (4 unlocked or non-elect rically si.pervisett orice per L weekly to verify that the doors are day. Locked doors will be curveilled once per week . . ._

a'

_H in the closed positions '

by the operating department? Electrically supervised l

' fire doors will be surve611ed wrthly.

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10 CFR 50 APPEND!h R BYRON /BRAIDCOD COTFORMANCE 3 RE MARE S #

3.  :..ided with Fire doorshold-open automatic shall be pand release s mechanisme aaJ inspected ditiy to _

verify that %orwayn sto ltee of -

obstructional or .

4. Fire doors shall be kept closed'and inspected delly to verify that they are in the closed position..

The fire brigade leader shall have ready access to keys for any locked fira dess.

Areas protectei by autounatic total flooding gas suppression syst ems shall .

h&ee electrically supervised self-closing fire doors or shall satisfy option 1 above.

, O. 011 Collection System for Reactor Coolant Pump S/S complies.

m

. w w The reactor coolant pump shall be equipped A drlo pan system which meets the guidelines of 4 with an oil collection system if the con- Appendle R to 10 CFR $0 has been designed for

'

• tairmient is not inerted during normal the reacint coolant pump (RCF) motors for the operation. The oil collection system syron/aratoM stations. These pans are being

! thall be so designed, engineered, and fabricated and will be installed prior to fuel installed that fatture will not lead to load, fire during normal or design basis accident

conditions and that there is reasonable Five drip pans will be installed on each pump.

1 resurance that the system will withstand These five pans will cc11ect oil drips from all the Safe shutdown Barthquake.' potential leakage points and route this 011 to a safe collection point. The following five pans Such collection systems shall be capable are installed on each pumps af collecting lube oil from all potential

'j pressurised and unpressurised leakage a. A drip pan inside the motor housing below sites in the reactor coolant pump lube the lower motor bearing.

cil systems. I.eakage shall be collected gg tnd drained to a vente<1 closed container b. A drip pan under the bottom of the oil cooler. g l that can hold the entire tube oil system gg inventory. A flame arrester is required c. A deip gen around the oil cooler under the g in the vent if the fissh point characterts- upper fl ange. gg tice of the oil present the hasard of fire oy flashback. 1,eakage points to be protected d. A drip pan which encloses the oil lif t puso. g i shall include lift pump and piping, overflow Om i

lines, lube oil cooler, oil fill and drain e. A drip pan under the oli level alarm and eight m

lines and plugs, flanged connections on gauge. p

. oil lines, and lube oil reservoirs where such W l features esist on the reactor coolant pumps. H

The drain line shall be larae enough to Eccosemodate the largest, potential oil beak.

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i ,

i 10 CFR 50 APPENDIX R BYRON /8RAIDWOOD CONFORMANCE RF.MAPd5 The pone are designed such that all esternal piping connections are above the pena. A piping system collects all the all drips and seepage and routes i

the oil to closed containers in the containment which are elsed to collget the amount of oil espected to be collected ba****n outages. In the event

. of e mejor leak, an overflow 11tse stoa the me-tainers will transfer the oil directly into the containment all m llection vault. In the im!!kely event the vault is overtilled, the ott would back up into the containment (toor drain sump. Under no conditions would the oil drain into an area which is not closed.

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