ML21008A418

Amendment 29 to Fire Protection Report, Chapter 3, Guidelines of BTP Cmeb 9.5-1

ML21008A418
Person / Time
Site:	Braidwood
Issue date:	12/17/2020
From:	Exelon Generation Co LLC
To:	Office of Nuclear Reactor Regulation, Office of Nuclear Material Safety and Safeguards
Shared Package
ML21008A383	List: ML21008A380 ML21008A386 ML21008A387 ML21008A388 ML21008A389 ML21008A392 ML21008A394 ML21008A397 ML21008A399 ML21008A401 ML21008A402 ML21008A403 ML21008A404 ML21008A405 ML21008A406 ML21008A408 ML21008A409 ML21008A410 ML21008A411 ML21008A413 ML21008A414 ML21008A416 ML21008A417 ML21008A418 ML21008A420 ML21008A421 ML21008A422 ML21008A426 ML21137A191 ML21137A207 ML21137A221 ML21137A238 ML21137A246 ML21137A251 ML21137A253 RS-20-153, Amendment 29 to Fire Protection Report, Chapter 3, Guidelines of BTP Cmeb 9.5-1
References
RS-20-153
Download: ML21008A418 (198)

Text

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 3.0 GUIDELINES OF BTP CMEB 9.5-1 3.1 FIRE PROTECTION PROGRAM REQUIREMENTS IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

a. Fire Protection Program A fire protection program should Comply. Refer to Section II.A of be established at each nuclear Appendix A5.7.

power plant. The program should establish the fire protection policy for the protection of structures, systems, and compo-nents important to safety at each plant and the procedures, equip-ment, and personnel required to implement the program at the plant site.

(1) The fire protection program Comply. Refer to Section II.A of should be under the direction of Appendix A5.7.

an individual who has been dele-gated authority commensurate with the responsibilities of the position and who has available staff personnel knowledgeable in both fire protection and nuclear safety.

(2) The fire protection program Comply. Refer to Section II.A of should extend the concept of Appendix A5.7.

defense-in-depth to fire protection in fire areas important to safety, with the following objectives:

to prevent fires from starting; to detect rapidly, control, and extinguish promptly those fires that do occur; to provide protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by the fire suppression activities will not prevent the safe shutdown of the plant.

3.1-1

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (3) Responsibility for the overall Administrative procedures identify the fire protection program should individual delegated the authority for be assigned to a person who has establishing the fire protection management control over all program. The Fire Marshall developed organizations involved in fire the Fire Protection Administrative protection activities. Formula- Procedure. He has nuclear plant tion and assurance of program safety expertise available as part of implementation may be delegated the operating department.

to a staff composed of personnel prepared by training and exper-ience in fire protection and personnel prepared by training and experience in nuclear plant safety to provide a balanced approach in directing the fire protection program for the nuclear power plant.

The staff should be responsible for:

(a) Fire protection program Using the prefire plans for safety-requirements, including related areas, hazards are defined, consideration of potential structures and system identified. The hazards associated with Fire Marshall (as administrator) postulated fires, with maintains the plans.

knowledge of building layout and systems design.

(b) Post-fire shutdown The Shift Manager is responsible for capability. operating safely and can order shutdown if he deems it necessary for safety per Administrative Procedures.

(c) Design, maintenance, Maintenance and surveillance are surveillance, and quality handled by the station Operating, assurance of all fire Maintenance and Engineering programs protection features (e.g., and procedures.

detection systems, suppres-sion systems, barriers, Offsite QA (Nuclear Oversight) is a dampers, doors, penetration separate organization. Onsite QA seals, and fire brigade (Nuclear Oversight) organization equipment). provides review of maintenance, and purchase activities in accordance with the corporate QA Manual.

(d) Fire prevention activities The Fire Marshall and Training (administrative controls and Department direct training per training). Administrative Procedures.

3.1-2

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (e) Fire brigade organization and The Fire Marshall administers the training. station fire protection program (see 3.1.a(2)).

(f) Prefire planning. Prefire plans are written for safety-related areas and are controlled by the Fire Marshall. Preplans were reviewed by a Fire Protection Engineer.

Comply.

1. Responsibility for the Fire Protection Program

a. Initial Design and Construction Phase The fire protection system design for the EGC plants was developed by the project consulting engineer using members of his staff who were experienced in nuclear plant design.

Exelon Generation Company is a member of Nuclear Electric Insurance Limited (NEIL) and therefore guidelines for fire protection design were provided in the NEIL Property Loss Prevention Standards for Nuclear Generating Stations.

The building design was done by the consulting engineer. All design drawings which were pertinent to fire protection were submitted to a fire protection consultant as required by NEIL for their review and comment.

The fire protection consultant was employed by NEIL and was therefore independent of EGC. The comments on design information made by the fire protection consultant were submitted to EGC for their action.

Exelon Generation Company reviewed the project consultants' design drawings 3.1-3

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE and the fire protection consultants' comments. Judgments were made on a cost-benefit basis as to whether or not the fire protection features were to be incorporated into the plant.

Consideration was given to the following plant features when evaluation of fire protection was made:

a. plant and personnel safety,

b. credibility of a fire or fire hazard,

c. loss of generation because of fire loss, and

d. protection of surrounding or adjacent equipment resulting from a fire.

A Project Engineer who reported to the Project Engineering Manager coordinated fire protection design features at Braidwood.

Likewise, a review of design and design changes was performed by a Fire Protection Engineer in the Station Support Services Department and by Independent Fire Protection Engineers working under contract to EGC.

Resumes for the reviewers are in Appendix A5.1.

Surveillance tests were performed by the Project Construction Department and by the Station. The Fire Protection Engineers were involved in pre-operational and surveillance tests.

3.1-4

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

b. Operating Phase Exelon Generation Company has a Fire Marshall and Fire Protection System Engineer at each nuclear plant. In addition, there are Fire Protection Engineers in the Corporate and/or Site design engineering departments.

1. Properties and Equipment - The Fire Protection Engineers furnish informa-tion on underwriting standards, fire insurance rating standards and other information. When necessary they arrange for procuring advice from 3.1-4a

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE outside fire prevention agencies or other outside sources. When neces-sary, arrange and set up meetings to discuss and resolve any questions on current standards or fire protection equipment.

2. Fire Inspections - Site personnel, QA (Nuclear Oversight), and NEIL perform fire protection inspections of plant facilities.

3. Fire Fighting Equipment - The Station Fire Marshall sees that adequate fire fighting equipment is provided and that such equipment is maintained in good operating condition.

4. Tests - The Project Startup Group performs preoperational testing of new fire fighting equipment and automatic fire protection systems to ensure that each is in good condition and operat-ing satisfactorily. During normal or routine inspections, one or more of the following tests may be made:

a. alarm tests,

b. drain tests,

c. churning of fire pumps,

d. inspecting of control valves,

e. physical testing of fire pumps and yard hydrants, 3.1-5

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

f. checking or testing water deluge systems,

g. checking of automatic sprinkler systems, and

h. testing of standpipes and hoses.

5. Contacts - The Station Fire Marshall maintains company contacts with local fire departments. The Station Fire Marshall and the Fire Protection Engineers maintain contact with fire prevention organizations, insurance companies, and others on matters relating to fire fighting.

6. Reporting Fires - Fire reports are issued by the station. The Fire Marshall reports fires as necessary to the insurance company.

7. Training of Personnel - The Station Training Department, Corporate Training Department, and Fire Marshall are responsible for personnel training. This is done to ensure that individuals trained become familiar with the operation and use of fire fighting equipment.

8. Rules and Standards - The Fire Protection Engineers assist and advise departments concerned with established rules and standards relative to fire prevention and protection as may be necessary.

9. Recommendations - On all recommendations initiated by insurance agencies, fire prevention organizations, and other outside activities or company departments, the Fire Protection Engineers investigate, evaluate, discuss, and review such recommendations, where necessary, before making final recommendations as to specific action to be taken.

3.1-6

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE 10.Design Change - All design changes are reviewed for impact upon the Fire Protection Program per Administrative Procedures.

3.1-6a

BRAIDWOOD AMENDMENT 27 DECEMBER 2016 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE It is our opinion that the intent of the Branch Technical Position is met by the above outlined organizational structure in design, construction and operation of the EGC nuclear plants.

(4) The organizational responsibili- Administrative procedures define the ties and lines of communication organizational responsibilities and pertaining to fire protection lines of communication for the Fire should be defined between the Protection Program.

various positions through the use of organizational charts and functional descriptions of each position's responsibilities.

The following positions/organi-zations should be designated:

(a) The upper level offsite Administrative procedures identify the management position which offsite-delegated individual has management responsibil- responsible for the nuclear plant fire ity for the formulation, protection program.

implementation, and assess-ment of the effectiveness Assessment of the program is made by:

of the nuclear plant fire protection program. a) EGC Fire Protection Engineers b) EGC QA (Nuclear Oversight)

(b) The offsite management Nuclear Oversight and EGC Fire position(s) directly Protection Engineers have these responsible for formu- responsibilities.

lating, implementing, and periodically assessing the effectiveness of the fire protection program for the licensee's nuclear power plant including fire drills and training conducted by the fire brigade and plant personnel. The results of these assessments should be reported to the upper level management position responsible for fire pro-tection with recommenda-tions for improvements or corrective actions as deemed necessary.

3.1-7

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (c) The onsite management posi- Administrative Procedures identify the tion responsible for the onsite-delegated individual overall administration of responsible for the overall the plant operations and administration of the plant operations emergency plans which and emergency plans.

include the fire protection and prevention program and which provide a single point of control and con-tact for all contingencies.

(d) The onsite position(s) which:

i. Implements periodic Administrative Procedures require the inspections to: mini- Fire Marshall to conduct periodic mize the amount of plant tours, identify unacceptable combustibles in conditions and initiate corrective safety-related areas; actions.

determine the effec-tiveness of housekeep- Administrative Procedures state the ing practices; assure Fire Marshall is responsible for the availability and implementation and administration of acceptable condition the fire protection program.

of all fire protection systems/equipment, Administrative Procedures state the emergency breathing Radiation Protection department will apparatus, emergency control and maintain emergency lighting, communica- breathing apparatus.

tion equipment, fire stops, penetration Administrative Procedures state seals, and fire Electrical Maintenance will maintain retardant coatings; emergency lighting and communications.

and assures the prompt and effective correc- Fire barriers, seals, and doors are tive actions are taken inspected per the appropriate to correct conditions operating, maintenance, and adverse to fire pro- engineering surveillance.

tection and preclude their recurrence. Administrative Procedures state the Fire Marshall will investigate fires, evaluate prevention recommendations and make recommendations when needed.

ii. Is responsible for the Fire brigade training is a responsi-fire fighting training bility of both the Fire Marshall and for operating plant the training department per personnel and the Administrative Procedures. Operating plant's fire brigade; personnel are trained periodically design and selection through the Training Department on of equipment; periodic fire fighting.

3.1-8

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Inspection and testing The Operating Manager ensures all of fire protection operating surveillances are done in systems and equipment accordance to required guides.

in accordance with established The Maintenance, Engineering, and procedures, and Operating Managers are responsible for evaluate test results station procedures performed by their and determine the department.

accept-ability of the systems under test. The Fire Marshall will review the surveillances he deems necessary.

Evaluation of tests and surveillances are specified in test, surveillance and administrative procedures.

The Fire Marshall is responsible for the purchase of fire brigade equipment.

iii. Assists in the Critique of all fire drills is a critique of all fire responsibility of the Fire Marshall drills to determine per Administrative Procedures.

how well the training objectives have been met.

iv. Reviews and evaluates The Fire Marshall will have these proposed work responsibilities.

activities to identify potential transient fire loads.

v. Implements a program Contractor's training through NGET for indoctrination of fulfills this requirement. They are all plant contractor informed of emergency procedures personnel in relative to fire protection.

appropriate administrative 3.1-9

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Procedures which implement the fire protection program, and the emergency procedures relative to fire protection.

vi. Implements a program The procedure for instruction of for instruction of personnel on the proper handling of personnel on the oil spills is identified in proper handling of Administrative Procedure for the accidental events such "Control and Cleanup of Oil Spills."

as leaks or spills of The procedure references corporate flammable materials general instruction on spill that are related to prevention and countermeasures.

fire protection.

(e) The onsite position respon- The Fire Protection Program Admini-sible for fire protection strative Procedure identifies that quality assurance. This Fire Protection Activities are treated position should be respon- as augmented quality per the QA sible for assuring the program. Site/Offsite QA (Nuclear effective implementation or Oversight) Department personnel the fire protection program conduct audits and surveillances to by planned inspections, ensure proper implementation and scheduled audits, and veri- administration of the Fire Protection fication that the results Program.

of these inspections or audits are promptly re-ported to cognizant management personnel.

(f) The positions which are part of the plant fire brigade:

i. The plant fire brigade The Fire Protection Program positions should be Administrative Procedure defines the responsible for fight- Fire Chief and Brigade responsibili-ing fires. The ties and meets the requirements for authority and respon- authority and duties.

sibility of each fire brigade position rela-tive to fire 3.1-10

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Protection should be clearly defined.

ii. The responsibilities of each fire brigade position should correspond with the actions required by the fire fighting procedures.

iii. The responsibilities Administrative Procedures state that of the fire brigade training will be scheduled through the members under normal Fire Marshall and Operating Depart-plant conditions ment. The procedure specifies per-should not conflict sonnel (non-brigade) required for with their responsi- emergency operation.

bilities during a fire emergency.

iv. The minimum number of Braidwood complies with BTP CMEB 9.5-1 trained fire brigade paragraph 3.3.b. and Appendix R III.H.

members available on- which requires a 5-member brigade.

site for each operat-ing shift should be consistent with the activities required to combat the most sig-nificant fire. The size of the fire brigade should be based upon the func-tions required to fight fires with adequate allowance for injuries.

v. The recommendations See Table 3-1 for discussion of for organization, conformance with NFPA 27.

training, and equip-ment of "Private Fire Brigades" as specified in NFPA No. 27-1975, including the applic-able NFPA publications listed in the appendix to NFPA No. 27, are considered appropriate criteria for organiza-tion, training, and 3.1-11

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE operating a plant fire brigade.

(5) Personnel Qualifications Comply.

(a) The position responsible for The position responsible for the fire formulation and implementa- protection program has the use of a tion of the fire protection Fire Protection Consultant. These program should have within Consultants meet SFPE member grade his organization or as a requirements. Exelon Generation consultant a fire protection Company also employs Fire Protection engineer who is a graduate of Engineers who meet the qualification an engineering curriculum of for member grade in SFPE. (The EGC accepted standing and shall Fire Protection Engineer's duties are have completed not less than identified in the Fire Protection 6 years of engineering Program administrative procedure.)

attainment indicative of growth in engineering com-petency and achievement, 3 years of which shall have been in responsible charge of fire protection engineering work. These requirements are the eligibility requirements as a Member in the Society of Fire Protection Engineers.

(b) The fire brigade members' The fire brigade members have an qualifications should include annual physical which shows them satisfactory completion of a capable of unrestricted activity.

physical examination for performing strenuous acti-vity, and of the fire brigade training described in Posi-tion C.3.d.

(c) The personnel responsible for The personnel responsible for the maintenance and testing maintenance and testing of the fire of the fire protection protection systems receive training systems should be qualified scheduled by the training department.

by training and experience for such work.

(d) The personnel responsible for The training of the fire brigade is the training of the fire conducted by a qualified member of the brigade should be qualified EGC Training Department. State-by training and experience certified members of the EGC Fire for such work. Marshall's staff monitor this training.

3.1-12

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (6) The following NFPA publications The administrative procedures needed should be used for guidance to for maintaining the performance of the develop the fire protection fire protection system and personnel program: were established with the guidance of the NFPA standard available at the No. 4 - "Organization for Fire time.

Services" No. 4A - "Organization of a Fire See Table 3-1 for discussion of Department" conformance with the listed NFPA No. 6 - "Industrial Fire Loss publications.

Prevention" No. 7 - "Management of Fire Emergencies" No. 8 - "Management Responsi-bilities for Effects of Fire on Operations" No. 27 - "Private Fire Brigades" (7) On sites where there is an Comply.

operating reactor and construc-tion or modification of other Administrative procedures define this units is underway, the superin- as a duty of the station manager.

tendent of the operating plant should have the lead responsi-bility for site fire protection.

b. Fire Hazards Analysis The fire hazards analysis should Comply.

demonstrate that the plant will maintain the ability to perform The overall fire protection program is safe shutdown functions and mini- based on evaluation of fire hazards so mize radioactive releases to the a safe shutdown can be accomplished.

environment in the event of a The fire protection program began with fire. the protection of specific hazards in mind, to minimize, or prevent the loss The fire hazards analysis should of property. The main emphasis is now be performed by qualified fire placed on safe plant shutdown, but the protection and reactor systems protection of ALL hazards will satisfy engineers to (1) consider both reasons. Not ALL hazards are potential in situ and transient protected or separated as indicated in fire hazards; (2) determine the other sections of the report, but the consequences of fire in any basis for the fire protection program location in the plant on the basically complies.

ability to safely shut down the reactor or on the ability to Fire hazards were considered in plant minimize and control the release design for Braidwood Units 1 and 2.

of radioactivity to the The cable separation criteria for the environment; and (3) specify plant is described in Appendix 5.2 of 3.1-13

BRAIDWOOD AMENDMENT 23 DECEMBER 2008 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE measures for fire prevention, this report. The fire protection fire detection, fire suppression, system is discussed in Appendix 5.4.

and fire containment and alterna-tive shutdown capability as Deviations from the compliance required for each fire area con- criteria of 10 CFR 50 Appendix R are taining structures, systems, and listed and justified in Appendix A5.7.

components important to safety that are in conformance with NRC guidelines and regulations.

"Worst case" fires need not be postulated to be simultaneous with nonfire-related failures in safety systems, plant accidents, or the most severe natural phenomena.

On multiple-reactor sites, Comply.

unrelated fires in two or more units need not be postulated to A fire involving more than one reactor occur simultaneously. Fires unit was not postulated except for involving facilities shared facilities shared between units.

between units and fires due to man-made site-related events that have a reasonable probability of occurring and affecting more than one reactor unit (such as an aircraft crash) should be considered.

Because fire may affect safe The criteria used to demonstrate safe shutdown systems and because the shutdown capability are consistent loss of function of systems used with these requirements.

to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents. Three levels of fire damage limits are established according to the safety function of the structure, system, or component:

3.1-14

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Safety Function Fire Damage Limits Hot Shutdown One train of equip-ment necessary to achieve hot shut-down from either the control room or emergency control station(s) must be maintained free of fire damage by a single fire, including an exposure fire.

Cold Shutdown Both trains of equipment necessary to achieve cold shutdown may be damaged by a single fire, including an exposure fire, but damage must be limited so that at least one train can be repaired or made operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> using onsite capability.

Design Basis Both trains of Accidents equipment necessary for mitigation of consequences following design basis accidents may be damaged by a single exposure fire.

The most stringent fire damage limit should apply for those systems that fall into more than one category. Redundant systems used to mitigate the consequences of other design basis accidents but not necessary for safe shut-down may be lost to a single 3.1-15

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE exposure fire. However, protec-tion shall be provided so that a fire within only one such system will not damage the redundant system.

The fire hazards analysis should Sections 2.3 and 2.4 basically provide separately identify hazards and for each fire zone in the plant the provide appropriate protection in relevant information from this list locations where safety-related applicable to each zone.

losses can occur as a result of:

(1) Concentrations of combustible contents, including transient fire loads due to combusti-bles expected to be used in normal operations such as refueling, maintenance, and modifications; (2) Continuity of combustible contents, furnishings, building materials, or combinations thereof in configurations conducive to fire spread; (3) Exposure fire, heat, smoke, or water exposure, including those that may necessitate evacuation from areas that are required to be attended for safe shutdown; (4) Fire in control rooms or other locations having critical safety-related functions; (5) Lack of adequate access or smoke removal facilities that impede fire extinguishment in safety-related areas; (6) Lack of explosion-prevention measures; (7) Loss of electric power or control circuits; 3.1-16

BRAIDWOOD AMENDMENT 24 DECEMBER 2010 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (8) Inadvertent operation of fire Inadvertent operation of fire suppression systems. suppression systems has no adverse impact on safe shutdown capability as described in EC 341981 and EC 371447.

The fire hazards analysis should verify that the NRC fire protec-tion program guidelines have been met. The analysis should list applicable elements of the pro-gram, with explanatory statements as needed to identify location, type of system, and design criteria. The analysis should identify and justify any devia-tions from the regulatory guidelines. Justification for deviations from the regulatory guidelines should show that an equivalent level of protection will be achieved. Deletion of a protective feature without com-pensating alternative protection measures will not be acceptable, unless it is clearly demonstrated that the protective measure is not needed because of the design and arrangement of the particular plant.

c. Fire Suppression System Design Basis (1) Total reliance should not be Comply.

placed on a single fire suppres-sion system. Appropriate backup Backup fire suppression equipment is fire suppression capability provided in the form of manual hose should be provided. stations and portable extinguishers at locations near where automatic fire suppression systems are installed as well as at other locations throughout the plant.

(2) A single active failure or a The primary supply of fire protection crack in a moderate-energy line water at each station is described in (pipe) in the fire suppression Appendix 5.4.

system should not impair both the primary and backup fire suppres- Cracks in the fire protection piping sion capability. For example, will not impair primary suppression neither the failure of a fire system performance or availability of 3.1-17

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE pump, its power supply or the backup hose stations. Non-safety-controls, nor a crack in a related portions of the fire protec-moderate-energy line in the fire tion system can be isolated from the suppression system, should result safety-related portions by manual in loss of function of both isolation valves. Loss of a main fire sprinkler and hose standpipe pump is considered in the design of systems in an area protected by the system. The SX system is also such primary and backup systems. available as a backup for the hose stations.

(3) As a minimum, the fire suppres- Comply.

sion system should be capable of delivering water to manual hose See Section A5.4.1. Cross-ties to the stations located within hose essential service water system are reach of areas containing equip- provided to ensure seismically ment required for safe plant qualified water supply to the Seismic shutdown following the safe Category I portions of the fire shutdown earthquake (SSE). In suppression (standpipe systems) areas of high seismic activity, located in safety-related areas.

the staff will consider on a case-by-case basis the need to design the fire detection and suppression systems to be functional following the SSE.

(4) The fire protection systems Comply.

should retain their original design capability for (a) natural Seismic design is considered in the phenomena of less severity and whole FP system; however, only the greater frequency than the most Category I portions are designated severe natural phenomena seismic. Floods have no effect. A (approximately once in 10 years) single tornado missile can do no more such as tornadoes, hurricanes, damage than as described in 3.1c2.

floods, ice storms, or small-intensity earthquakes that are characteristic of the geographic region, and (b) potential man-made site-related events such as oil barge collisions or aircraft crashes that have a reasonable probability of occurring at a specific plant site. The effects of lightning strikes should be included in the overall plant fire protection program.

(5) The consequences of inadvertent Comply.

operation of or a crack in a moderate-energy line in the fire suppression system should meet 3.1-18

BRAIDWOOD AMENDMENT 23 DECEMBER 2008 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE the guidelines specified for moderate-energy systems outside containment in SRP Section 3.6.1.

d. Alternate or Dedicated Shutdown Alternative or dedicated shutdown Comply. Refer to Section 2.4 "Safe capability should be provided Shutdown Analysis."

where the protection of systems whose functions are required for Exemptions from 10 CFR 50 Appendix R safe shutdown is not provided by Sections III.G and III.L are listed in established fire suppression Appendix A5.7.

methods or by Position C.5.6.

e. Implementation of Fire Protection Programs (1) The fire protection program Comply.

(plans, personnel, and equipment) for buildings storing new reactor Fire brigade, and specific hose reels fuel and for adjacent fire areas and fire extinguishers were functional that could affect the fuel prior to receiving fuel. Training storage area should be fully records and surveillance were being operational before fuel is conducted for receipt of fuel. Pre-received at the site. Such fire plans were in place for the fuel adjacent areas include those handling building and the adjacent whose flames, hot gases, and fire areas. The fire brigade members fire-generated toxic and corro- were trained prior to receiving fuel sive products may jeopardize on site. Fire detection was operable safety and surveillance of the in the Fuel Handling Building prior to stored fuel. receipt of fuel on site.

(2) The fire protection program for Comply.

an entire reactor unit should be fully operational prior to initial fuel loading in that reactor unit.

(3) On reactor sites where there is Comply.

an operating reactor and construction or modification of The continuing evaluation of fire other units is under way, the hazards is accomplished by periodic fire protection program should inspections as specified in BWAP 1100-provide for continuing evaluation 18 Station Housekeeping/Equipment of fire hazards. Additional fire Preservation Procedure.

barriers, fire protection capability, and administrative Administrative control to protect the controls should be provided as operating unit from construction fire necessary to protect the hazards is accomplished by adhering to 3.1-19

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE operating unit from construction administrative procedures for the fire hazards. "Breaching of Fire Barriers, Fire Penetrations, Fire Dampers, Fire Doors and Fire Floor Plugs."

3.1-20

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 3.2 ADMINISTRATIVE CONTROLS IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Administrative controls should be used Administrative controls which will be to maintain the performance of the in effect will comply with the fire protection system and personnel. requirements of this section.

These controls should establish procedures to:

a. Prohibit bulk storage of combust- Comply. Refer to Section III.K.2 of ible materials inside or adjacent Appendix A5.7.

to safety-related buildings or systems during operation or main-tenance periods. Regulatory Guide 1.39 provides guidance on house-keeping, including the disposal of combustible materials.

b. Govern the handling and limita- Comply. Refer to Section III.K.1 of tion of the use of ordinary com- Appendix A5.7.

bustible materials, combustible and flammable gases and liquids, high efficiency particulate air and charcoal filters, dry ion exchange resins, or other com-bustible supplies in safety-related areas.

c. Govern the handling of and limit Comply. Refer to Section III.K.3 of transient fire loads such as com- Appendix A5.7.

bustible and flammable liquids, wood and plastic products, or other combustible materials in buildings containing safety-related systems or equipment during all phases of operating, and especially during mainte-nance, modification, or refueling operations.

d. Designate the onsite staff member Comply. Refer to Section III.K.4 of responsible for the inplant fire Appendix A5.7.

protection review of proposed work activities to identify potential transient fire hazards and specify required additional fire protection in the work activity procedure.

3.2-1

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

e. Govern the use of ignition Comply. Refer to Section III.K.5 of sources by use of flame permit Appendix A5.7.

system to control welding, flame cutting, brazing, or soldering operations. A separate permit should be issued for each area where work is to be done. If work continues over more than one shift, the permit should be valid for not more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the plant is operating or for the duration of a particular job during plant shutdown.

f. Control the removal from the area Comply. Refer to Section III.K.6 of of all waste, debris, scrap, oil Appendix A5.7.

spills, or other combustibles resulting from the work activity immediately following completion of the activity, or at the end of each work shift, whichever comes first.

g. Govern leak testing; similar Comply. Leak testing is done with procedures such as airflow noncombustible materials.

determination should use one of the commercially available techniques. Open flames or combustion-generated smoke should not be permitted.

h. Maintain the periodic housekeep- Comply. Refer to Section III.K.7 of ing inspections to ensure con- Appendix A5.7.

tinued compliance with these administrative controls.

i. Control the use of specific Comply with exceptions. Refer to combustibles in safety-related Section III.K.8 of Appendix A5.7 for areas. All wood used in safety- details.

related areas during maintenance, modification, or refueling opera-tion (such as lay-down blocks or scaffolding) should be treated with a flame retardant. Equip-ment or supplies (such as new fuel) shipped in untreated com-bustible packing containers may be unpacked in safety-related areas if required for valid operating reasons. However, all 3.2-2

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE combustible materials should be removed from the area immediately following unpacking. Such tran-sient combustible material, unless stored in approved con-tainers, should not be left unattended during lunch breaks, shift changes, or other similar periods. Loose combustible packing materials such as wood or paper excelsior, or polyethylene sheeting should be placed in metal containers with tight-fitting self-closing metal covers.

j. Disarming of fire detection or Comply. Disarming of fire detection fire suppression systems should or fire suppression systems is be controlled by a permit system. controlled by administrative Fire watches should be estab- procedure. Compensatory measures are lished in areas where systems are established as required by the so disarmed. governing procedure.

k. Successful fire protection Comply. The scope of the job requires testing and maintenance classification for maintenance of the fire protection equipment personnel identifies job and the emergency lighting and responsibilities in the area of fire communication. A test plan that protection.

lists the individuals and their responsibilities in connection An administrative procedure for "Fire with routine tests and inspec- Protection Impairment," provides tions of the fire detection and instructions in the use of fire protection systems should be protection impairment permit cards in developed. The test plan should the event a fire protection component contain the types, frequency, and is taken out of service. The detailed procedures for testing. surveillance program (Test Plan)

Procedures should also contain contains the types, frequency, and instructions on maintaining fire detailed procedures for testing.

protection during those periods when the fire protection system is impaired or during periods of plant maintenance, e.g., fire 3.2-3

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE watches or temporary hose connections to water systems.

l. Control actions to be taken by an Comply. Refer to Section III.K.9 of individual discovering a fire, Appendix A5.7.

for example, notification of control room, attempt to extin-guish fire, and actuation of local fire suppression systems.

m. Control actions to be taken by Comply. Refer to Section III.K.10 of the control room operator to Appendix A5.7.

determine the need for brigade assistance upon report of a fire or receipt of alarm on control room annunciator panel, for example, announcing location of fire over PA system, sounding fire alarms, and notifying the shift supervisor and the fire brigade leader of the type, size, and location of the fire.

n. Control actions to be taken by Comply. Refer to Section III.K.11 of the fire brigade after notifica- Appendix A5.7.

tion by the control room operator of a fire, for example, assem-bling in a designated location, receiving directions from the fire brigade leader, and dis-charging specific fire fighting responsibilities, including selection and transportation of fire fighting equipment to fire location, selection of protective equipment, operating instructions for use of fire suppression systems, and use of preplanned strategies for fighting fires in specific areas.

o. Define the strategies for fight- Pre-fire plans have been developed for ing fires in all safety-related Braidwood which generally meet these areas and areas presenting a guidelines. Refer to Appendix A5.7, hazard to safety-related equip- Section K.12 for a detailed discussion ment. These strategies should of these plans and their conformance designate: to these requirements.

3.2-4

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (1) Fire hazards in each area covered by the specific prefire plans.

(2) Fire extinguishants best suited for controlling the fires associated with the fire hazards in that area and the nearest location of these extinguishants.

(3) Most favorable direction from which to attack a fire in each area in view of the ventilation direction, access hallways, stairs, and doors that are most likely to be free of fire, and the best station or elevation for fighting the fire. All access and egress routes that involve locked doors should be specifically identified in the procedure with the appropriate precautions and methods for access specified.

(4) Plant systems that should be managed to reduce the damage potential during a local fire and the location of local and remote controls for such management (e.g.,

any hydraulic or electrical systems in the zone covered by the specific fire fighting procedure that could increase the hazards in the area because of overpressurization or electrical hazards).

(5) Vital heat-sensitive system components that need to be kept cool while fighting a local fire. Particularly hazardous combustibles that need cooling should be designated.

3.2-5

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (6) Organization of fire fighting brigades and the assignment of special duties according to job title so that all fire fighting func-tions are covered by any complete shift personnel complement. These duties include command control of the brigade, transporting fire suppression and support equipment to the fire scenes, applying the extin-guishant to the fire, com-munication with the control room, and coordination with outside fire departments.

(7) Potential radiological and toxic hazards in fire zones.

(8) Ventilation system operation that ensures desired plant air distribution when the ventilation flow is modified for fire containment or smoke clearing operation.

(9) Operations requiring control room and shift engineer coordination or authoriza-tion.

(10) Instructions for plant operators and general plant personnel during fire.

3.2-6

BRAIDWOOD AMENDMENT 22 DECEMBER 2006 3.3 FIRE BRIGADE IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

a. The need for good organization, The guidelines of Regulatory Guide training, and equipping of fire 1.101 are followed where applicable.

brigades at nuclear power plant Insurance industry standards in sites requires that effective existence at the time and NFPA 27 -

measures be implemented to ensure "Private Fire Brigades" - were proper discharge of these func- consulted in writing the procedures.

tions. The guidance in Regula-tory Guide 1.101, "Emergency The administrative procedure governing Planning for Nuclear Power the fire protection program outlines Plants," should be followed as the organization, training, and applicable. equipping of fire brigades.

b. A site fire brigade trained and Comply, except as noted. Refer to equipped for fire fighting should Section III.H of Appendix A5.7 for be established to ensure adequate details.

manual fire fighting capability for all areas of the plant con-taining structures, systems, or components important to safety.

The fire brigade should be at least five members on each shift.

The brigade leader and at least two brigade members should have sufficient training in or know-ledge of plant safety-related systems to understand the effects of fire and fire suppressants on safe shutdown capability. The qualification of fire brigade members should include an annual physical examination to determine their ability to perform stren-uous fire fighting activities.

The shift supervisor should not be a member of the fire brigade.

The brigade leader shall be com-petent to assess the potential safety consequences of a fire and advise control room personnel.

Such competence by the brigade leader may be evidenced by pos-session of an operator's license or equivalent knowledge of plant safety-related systems.

3.3-1

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

c. The minimum equipment provided Comply. Refer to Section III.H of for the brigade should consist of Appendix A5.7 for details.

personal protective equipment such as turnout coats, boots, gloves, hard hats, emergency communications equipment, port-able lights, portable ventilation equipment, and portable extin-guishers. Self-contained breath-ing apparatus using full-face positive-pressure masks approved by NIOSH (National Institute for Occupational Safety and Health-approval formerly given by the U.S. Bureau of Mines) should be provided for fire brigade, damage control, and control room per-sonnel. At least 10 masks shall be available for fire brigade personnel. Control room per-sonnel may be furnished breathing air by a manifold system piped from a storage reservoir if practical. Service or rated operating life shall be a minimum of one-half hour for the self-contained units.

At least two extra air bottles Comply. Refer to Section III.H of should be located onsite for each Appendix A5.7.

self-contained breathing unit.

In addition, an onsite 6-hour supply of reserve air should be provided and arranged to permit quick and complete replenishment of exhausted supply air bottles as they are returned. If com-pressors are used as a source of breathing air, only units approved for breathing air shall be used; compressors shall be operable assuming a loss of offsite power. Special care must be taken to locate the compressor in areas free of dust and contaminants.

d. The fire brigade training program The fire brigade training program shall ensure that the capability meets the requirements presented in to fight potential fires is items 1 through 9 herein. Refer to 3.3-2

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE established and maintained. The Section III.I of Appendix A5.7 for a program shall consist of an discussion of conformance with the initial classroom instruction requirements of items 1 through 8 program followed by periodic below.

classroom instruction, fire fighting practice, and fire drills.

(1) The initial classroom instruction should include:

(a) Indoctrination of the plant fire fighting plan with specific identification of each individual's responsibilities.

(b) Identification of the type and location of fire hazards and associated types of fires that could occur inplant.

(c) The toxic and corrosive characteristics of expected products of combustion.

(d) Identification of the location of fire fighting equipment for each fire area and familiarization with the layout of the plant, including access and egress routes to each area.

(e) 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 3.3-3

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE cables and cable trays, hydrogen fires, fires involving flammable and combustible liquids or hazardous process chem-icals, fires resulting from construction or modification (welding),

and record file fires.

(f) The proper use of communication, lighting, ventilation, and emergency breathing equipment.

(g) The proper method for fighting fires inside buildings and confined spaces.

(h) The direction and coordination of the fire fighting activities (fire brigade leaders only).

(i) Detailed review of fire fighting strategies and procedures.

(j) Review of the latest plant modifications and corresponding changes in fire fighting plans.

(k) Training of the plant Comply with items k and l. The local fire brigade should be fire department is included periodi-coordinated with the cally in the station fire drills, local fire department which require them coming into the so that responsibil- plant boundary. The local fire ities and duties are department has been trained in delineated in advance. operational precaution and the need This coordination for radioactive protection of per-should be part of the sonnel in fighting fires in a nuclear training course and power plant. It is clearly understood should be included in by the local fire department that they the training of the are a reserve force only and that they 3.3-4

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Local fire department will be under the direction of the staff. station Fire Marshall or Chief at the station.

(l) Local fire departments should be provided training in operational precautions when fight-ing fires on nuclear power plant sites and should be made aware of the need for radiologi-cal protection of per-sonnel and the special hazards associated with a nuclear power plant site.

Note: Items (i) and (j) may be deleted from the training of no more than two of the non-operations personnel who may be assigned to the fire brigade.

(2) The instruction should be Comply. Refer to Section III.I.1.b of provided by qualified Appendix A5.7.

individuals who are known ledgeable, experienced, and suitably trained in fighting the types of fires that could occur in the plant and in using the types of equip-ment available in the nuclear power plant.

(3) Instruction should be provided to all fire brigade members and fire brigade leaders.

(4) Regular planned meetings Comply. Refer to Section III.I.1.d of should be held at least Appendix A5.7.

every 3 months for all brigade members to review changes in the fire protec-tion program and other subjects as necessary.

3.3-5

BRAIDWOOD AMENDMENT 19 DECEMBER 2000 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (5) Periodic refresher training Comply. Refer to Section III.I.1.e of sessions shall be held to Appendix A5.7.

repeat the classroom instruction program for all brigade members over a 2-year period. These sessions may be concurrent with the regular planned meetings.

(6) Practice (a) Practice sessions Comply. Refer to Section III.I.2 of should be held for each Appendix A5.7.

shift fire brigade on the proper method of fighting the various types of fires that could occur in a nuclear power plant.

These sessions shall provide brigade members with experience in actual fire extinguish-ment and the use of emergency breathing apparatus under strenuous conditions encountered in fire fighting.

(b) These practice sessions should be provided at least once per year for each fire brigade member.

(7) Drills (a) Fire brigade drills Items 7a through 7f are accomplished should be performed in by administrative procedure. The type the plant so that the of drills and assessment of drills are fire brigade can documented on the Station Fire Drill practice as a team. record. Refer to Section III.I.3 of Appendix A5.7 for details.

(b) Drills should be performed at regular intervals not to exceed 3 months for each shift fire brigade. Each 3.3-6

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE fire brigade member should participate in each drill, but must participate in at least two drills per year.

A sufficient number of these drills, but not less than one for each shift fire brigade per year, should be unan-nounced to determine the fire fighting readiness of the plant fire brigade, brigade leader, and fire protection systems and equipment. Persons planning and authoriz-ing an unannounced drill should ensure that the responding shift fire brigade members are not aware that a drill is being planned until it is begun. Unannounced drills should not be scheduled closer than 4 weeks.

At least one drill per year should be per-formed on a "back shift" for each shift fire brigade.

(c) The drills should be preplanned to establish the training objectives of the drill and should be critiqued to deter-mine how well the training objectives have been met. Unan-nounced drills should be planned and criti-qued by members of the management staff responsible for plant 3.3-7

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE safety and fire protec-tion. Performance deficiencies of a fire brigade or of indivi-dual fire brigade mem-bers should be remedied by scheduling addi-tional training for the brigade or members.

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

(d) These drills should provide for local fire department participa-tion periodically (at least annually).

(e) At 3-year intervals, a randomly selected unan-nounced drill should be critiqued by qualified individuals independent of the licensee's staff. A copy of the written report from such individuals should be available for NRC review.

(f) Drills should as a minimum include the following:

i. Assessment of fire alarm effective-ness, time re-quired to notify and assemble fire brigade, and se-lection, place-ment, and use of equipment and fire fighting strate-gies.

3.3-8

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE ii. Assessment 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 members' conformance with established plant fire fighting procedures and use of fire fighting equipment, includ-ing self-contained emergency breath-ing apparatus, communication equipment, and ventilation equipment, to the extent practic-able.

iii. The simulated use of fire 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 pre-vious drills so that brigade mem-bers are trained in fighting fires in various plant areas. The situa-tion selected should simulate the size and arrangement of a fire that could reasonably occur 3.3-9

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE in the area selected, allowing for fire develop-ment due to the time required to respond, to obtain equipment, and organize for the fire, assuming loss of automatic suppression capability.

iv. Assessment of brigade leader's direction of the fire fighting effort as to thoroughness, accuracy, and effectiveness.

(8) Records Comply. Refer to Section III.I.4 of Appendix A5.7.

Individual records of train-ing provided to each fire brigade member, including drill critiques, should be maintained for at least 3 years to ensure that each member receives training in all parts of the training program. These records of training should be available for NRC review. Retraining or broadened training for fire fighting within build-ings should be scheduled for all those brigade members whose performance records show deficiencies.

(9) Guidance Documents NFPA 27, "Private Fire Comply. Fire training by responsible Brigade," should be followed instructors is done periodically. See in organization, training, Table 3-1 for delineation of and fire drills. This stan- conformance with NFPA 27 and NFPA 197.

dard also is applicable for 3.3-10

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE the inspection and mainte- The local fire department has been nance of fire fighting checked for fire hose thread equipment. Among the compatibility and a letter is on file standards referenced in this to document compatibility. The letter document, NFPA 197, "Train- is in Braidwood QA file No. 62.9.

ing Standard on Initial Fire Attacks," should be utilized as applicable. NFPA book-lets and pamphlets listed in NFPA 27 may be used as applicable for training references. In addition, courses in fire prevention and fire suppression that are recognized or sponsored by the fire protection industry should be utilized.

3.3-11

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 3.4 QUALITY ASSURANCE PROGRAM IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE The quality assurance (QA) programs The fire protection systems at of applicants and contractors Byron/Braidwood Stations Units 1 and 2 should ensure that the guidelines are addressed in two different manners for design, procurement, under the Quality Assurance Program.

installation, and testing and the administrative controls for the 1. Fire protection systems classed as fire protection systems for safety- safety-related are covered by the related areas are satisfied. The entire Quality Assurance Program QA program should be under the which includes the cri-teria set management control of the QA forth in Appendix B of 10 CFR 50.

organiza-tion. This control consists of (1) formulating a fire 2. Fire protection systems that are protection QA program that classed as non-safety-related and incorporates suitable requirements that are awarded after September 1, and is acceptable to the management 1978 are procured and in-stalled in responsible for fire pro-tection or accordance with the Branch Technical verifying that the program Position 9.5-1. Vendors awarded with incorporates suitable requirements supplying or installing a fire and is acceptable to the management protection system after September 1, responsible for fire protection, 1978 must have an approved QA and (2) verifying the effectiveness Program as required by the Quality of the QA program for fire Assurance Program and be on the protection through review, Approved Bidder's List.

surveillance, and audits.

Performance of other QA program However, exceptions may be func-tions for meeting the fire made for selected non-safety-protection program requirements may related systems to allow be performed by personnel outside installation without an of the QA organi-zation. The QA approved QA program. Each program for fire protection should be part of the overall plant QA installation of this type program. It should satisfy the requires a separate analysis specific criteria listed below. that includes, as a minimum, a regulatory change evaluation; a definable augmented quality class break point, such as an isolation valve; and a hydraulic evaluation for added sprinklers or fire hose stations, as applicable. The applicable fire and building codes (such as NFPA codes) will be followed and a fire protection engineer will review the change.

3.4-1

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Scheduled fire protection inspections are conducted under the direction of QA (Nuclear Oversight) with direct participation by a qualified fire protection engineer consultant.

New designs or revisions to plant fire protection systems are reviewed as outlined in the response to Section 3.1.

The Quality Assurance Program applies to procurement, design, installation, modifications and maintenance activities involving fire protection systems. As such, each specific criteria listed as "a" through "j" of Section NRC Position are covered by the Quality Assurance Program and by Department and Station Procedures. Further implementation 3.4-1a

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE relating to specific criteria, where deemed appropriate, follow:

a. Design and Procurement Document Control Measures should be established to ensure that the guidelines of the regulatory position of this guide are included in design and pro-curement documents and that devi-ations therefrom are controlled.

b. Instructions, Procedures, and b. Department and station procedures Drawings are established to cover specific instructions such as for inspec-Inspections, tests, tions, tests, administrative con-administrative controls, fire trols, fire drills and training drills, and training that govern that govern the fire protection the fire protection program program.

should be prescribed by documented instructions, pro-cedures, or drawings and should be accomplished in accordance with these documents.

c. Control of Purchased Material, c. Carbon dioxide (CO2) is controlled Equipment, and Services as a non-safety-related item per Material Engineering Group Measures should be established to Evaluation M-94-0585-00.

ensure that purchased material, equipment, and services conform to the procurement documents.

d. Inspection d. Independent inspections are performed by Quality Assurance A program for independent inspec- (Nuclear Oversight), utilizing tion of activities affecting fire fire protection consultants as protection should be established required.

and executed by or for the organ-ization performing the activity to verify conformance with docu-mented installation drawings and test procedures for accomplishing the activities.

e. Test and Test Control e. Tests of fire protection equipment and systems are A test program should be estab- included in regularly scheduled lished and implemented to ensure station operating surveillance 3.4-2

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE that testing is performed and procedures. These procedures and verified by inspection and audit test results are reviewed and to demonstrate conformance with evaluated by appropriate station design and system readiness personnel. QA (Nuclear requirements. The tests should Oversight) also audits this area.

be performed in accordance with written test procedures; test results should be properly evalu-ated and acted on.

f. Inspection, Test, and Operating Status Measures should be established to provide for the identification of items that have satisfactorily passed required tests and inspections.

g. Nonconforming Items Measures should be established to control items that do not conform to specified requirements to pre-vent inadvertent use or installa-tion.

h. Corrective Action h. Tests of fire protection equip-ment and systems are included in Measures should be established to regularly scheduled operating ensure that conditions adverse to surveillance procedures. Noncon-fire protection, such as fail- forming equipment is identified ures, malfunctions, deficiencies, as a result of their test and deviations, defective components, corrective action taken to rec-uncontrolled combustible material tify any deficiencies as provided and nonconformances, are promptly by the QA Program.

identified, reported, and corrected.

i. Records i. Documentation involving the fire protection program is retained in Records should be prepared and a central file or QA vault as maintained to furnish evidence provided by the QA Program.

that the criteria enumerated above are being met for activities affecting the fire protection program.

3.4-3

BRAIDWOOD AMENDMENT 19 DECEMBER 2000 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

j. Audits j. Scheduled audits and surveil-lances of the fire protection Audits should be conducted and activities in our plants are documented to verify compliance performed in accordance with the with the fire protection program, QA Program by the Nuclear including design and procurement Oversight Department.

documents, instructions, procedures and drawings, and SITE QUALITY ASSURANCE inspection and test activities.

The fire protection program is covered by the Quality Assurance Program.

Fire protection activities are subject to audit under the applicable portions of the approved QA program to ensure proper implementation and compliance with commitments, which is described in QA topical report (QATR) CE-1-A.

3.4-4

BRAIDWOOD AMENDMENT 18 DECEMBER 1998 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE FIRE PROTECTION AUDIT CRITERIA Quality Assurance can use, but is not limited to, the following documents as audit reference material:

1. Station Fire Protection Report

2. Station responses to the Branch Technical Position 9.5-1

3. Station SER and Supplements 3.4-4a

BRAIDWOOD AMENDMENT 19 DECEMBER 2000 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

4. Technical Specifications

5. Station Fire Protection Procedures

6. QATR

7. NFPA Codes

8. Applicable sections of 10 CFR 50 App. R

9. 29 CFR 1910.155 to 165 3.4-5

BRAIDWOOD AMENDMENT 23 DECEMBER 2008 3.5 GENERAL PLANT GUIDELINES IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

a. Building Design The fire area concept, as it relates to reactor safety, was not a require-(1) Fire barriers with a minimum ment in the initial design of Byron/

fire resistance rating of 3 Braidwood Stations Units 1 and 2. As hours should be provided to: implied in the Branch Technical Position and as stated in Section (a) Separate safety-related 4.3.4.4 of NUREG-0050, "Recommendation systems from any potential Related to Browns Ferry Fire," the fires in non-safety-related fire area concept is impractical to areas that could affect implement to any great extent to their ability to perform plants already under construction.

their safety function; The original plant design did incorporate a fire hazard separation (b) Separate redundant in accordance with insurance industry divisions or trains of standards for nuclear power plants.

safety-related systems from In areas where redundant safety-each other so that both are related systems could not be separated not subject to damage from from each other by a barrier, an a single fire; analysis was conducted to determine if both ESF divisions could be adversely (c) Separate individual units affected by a single postulated on a multiple-unit site credible fire. These areas are unless the requirements of identified in Section 2.3. Deviations General Design Criterion 5 from the Appendix R separation are met with respect to criteria are identified and justified fires. in Appendix A5.7.

(2) Appropriate fire barriers should The general separation criteria used be provided within a single for Byron/Braidwood Units 1 and 2 are safety division to separate described in Appendix 5.2 of this components that present a fire report. In general, safety-related hazard to other safety-related systems are isolated from unacceptable components or high concentra- fire hazards as discussed in Section tions of safety-related cables 2.3.

within that division.

(3) Openings through fire barriers Electrical penetration seals have been for pipe, conduit, and cable installed at all barrier penetrations; trays which separate fire areas their construction characteristics are should be sealed or closed to described in Appendix 5.2. Mechanical provide a fire resistance rating penetration seals have been installed at least equal to that required in all penetrations of rated fire of the barrier itself. Openings barriers.

inside conduit larger than 4 inches in diameter should be All openings inside conduits which sealed at the fire barrier penetrate fire barriers which separate penetration. Openings inside fire areas 3.5-1

BRAIDWOOD AMENDMENT 19 DECEMBER 2000 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE conduit 4 inches or less in are sealed in accordance with Appendix diameter should be sealed at the A5.2.2 of this report.

fire barrier unless the conduit extends at least 5 feet on each side of the fire barrier and is sealed either at both ends or at the fire barrier with noncom-bustible material to prevent the passage of smoke and hot gases.

Fire barrier penetrations that must maintain environmental isolation or pressure differ-entials should be qualified by test to maintain the barrier integrity under such conditions.

Penetration designs should For both the electrical and mechanical utilize only noncombustible penetrations, all materials used in materials and should be quali- the construction of the rated fire fied by tests. The penetration stops have a flame spread of 25 or qualification tests should use less. Penetration tests were the time-temperature exposure conducted in accordance with IEEE 634-curve specified by ASTM E-119, 78 using the time-temperature curve of "Fire Test of Building Construc- ASTM E-119. However, it should be tion and Materials." The accep- noted that six penetration seals as tance criteria for the test described in Section 2.3 are should require that: constructed of Thermo-Lag 330-1 material and have been abandoned in place. Per NRC Information Notice 92-82, this material has been determined to be combustible. In accordance with drawing 20E-0-3600, these seals are now considered nonrated seals.

(a) The fire barrier penetra- All rated fire barrier penetration tion has withstood the fire seals have 3-hour ratings.

endurance test without pas-sage of flame or ignition of cables on the unexposed side for a period of time equivalent to the fire resistance rating required of the barrier.

3.5-2

BRAIDWOOD AMENDMENT 18 DECEMBER 1998 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (b) The temperature levels The acceptance criteria is an average recorded for the unexposed of 250ºF above ambient. This is side are analyzed and considered to be equivalent to the demonstrate that the maxi- stated requirement.

mum temperature does not exceed 325ºF.

(c) The fire barrier penetra- Fire testing is normally done per tion remains intact and IEEE-634.

does not allow projection 3.5-2a

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE of water beyond the unex-posed surface during the hose stream test. The stream shall be delivered through a 1-1/2-inch nozzle set at a discharge angle of 30% with a nozzle pressure of 75 psi and a minimum discharge of 75 gpm with the tip of the nozzle a maximum of 5 ft from the exposed face; or the stream shall be delivered through a 11/2-inch nozzle set at a discharge angle of 15%

with a nozzle pressure of 75 psi and a minimum dis-charge of 75 gpm with the tip of the nozzle a maximum of 10 ft from the exposed face; or the stream shall be delivered through a 2-1/2-inch national standard playpipe equipped with 1-1/8-inch tip, nozzle pres-sure of 30 psi, located 20 ft from the exposed face.

(4) Penetration openings for Ventilation system penetrations in ventilation systems should be rated barriers are protected by fire protected by fire dampers having dampers having a rating equivalent to a rating equivalent to that that of the barrier.

required of the barrier (see NFPA-90A, "Air Conditioning and For details, see the Fire Protection Ventilating Systems"). Flexible Report Subsection 2.1.4.1b and c.

air duct coupling in ventilation and filter systems should be See Table 3-1 for delineation of noncombustible. conformance with NFPA-90A.

(5) Door openings in fire barriers Access doors in fire barriers are should be protected with equi- Label A or B fire doors or are of valently rated doors, frames, Label A or B construction (see Section and hardware that have been 2.1, page 2.1-8 for a detailed tested and approved by a discussion of doors provided for rated nationally recognized labora- fire barriers).

tory. Such doors should be self-closing or provided with See Table 3-1 for delineation of closing mechanisms and should be conformance with NFPA 80.

inspected semiannually to verify 3.5-3

BRAIDWOOD AMENDMENT 23 DECEMBER 2008 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE that automatic hold-open, release, and closing mechanisms and latches are operable. (See NFPA 80, "Fire Doors and Windows.")

One of the following measures All fire doors have automatic closers.

should be provided to ensure Options a, b, and d are used on they will protect the opening as various doors in the plant. Cable required in case of fire: spreading room interior doors alarm in the control room. The other (a) Fire doors should be kept supervised doors are monitored by closed and electrically security. Required fire doors are supervised at a contin- inspected per the appropriate uously manned location; operating surveillance.

(b) Fire doors should be locked closed and inspected weekly to verify that the doors are in the closed position; (c) Fire doors should be provided with automatic hold-open and release mechanisms and inspected daily to verify that doorways are free of obstructions; or (d) Fire doors should be kept closed and inspected daily to verify that they are in the closed position.

The fire brigade leader should The brigade chief can obtain a key to have ready access to keys for access all areas.

any locked fire doors.

Areas protected by automatic The doors to the diesel generator day total flooding gas suppression tank rooms,diesel generator systems should have electrically ventilation shafts, and the auxiliary supervised self-closing fire feedwater diesel- driven pump and day doors or should satisfy option tank rooms are not electrically (a) above. supervised, although they are boundaries for areas protected by automatic total flooding gas suppression systems. The fire doors to these rooms are surveilled to ensure they are in their proper position.

3.5-4

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (6) Personnel access routes and The stairwells at Braidwood which escape routes should be provided serve as escape routes for station for each fire area. Stairwells personnel and access routes for fire outside primary containment fighting personnel, as per the serving as escape routes, access requirements of building codes, are routes for fire fighting, or enclosed by 2-hour fire-rated masonry access routes to areas contain- walls with self-closing fire doors, ing equipment necessary for safe and are clearly marked.

shutdown should be enclosed in masonry or concrete towers with a minimum fire rating of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and self-closing Class B fire doors.

(7) Fire exit routes should be Comply, see item 6 above.

clearly marked.

(8) Each cable spreading room should The Braidwood design complies, except contain only one redundant for instances where cables from both safety division. Cable safety divisions are routed in the spreading rooms should not be same cable spreading room. Fire shared between reactors. Cable Protection Report Section 2.4.2 spreading rooms should be describes the measures taken in these separated from each other and areas to assure safe shutdown.

from other areas of the plant by barriers having a minimum fire resistance of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

(9) Interior wall and structural Minor amounts of combustibles are used components, thermal insulation as architectural finish materials.

materials, radiation shielding These existing materials do not materials, and soundproofing significantly contribute to the fire should be noncombustible. loading in the plant, and do not Interior finishes should be expose safety-related systems to undue noncombustible. risks.

Materials that are acceptable for use as interior finish without evidence of test and listing by a nationally recognized laboratory are the following:

Plaster, acoustic plaster, gypsum plasterboard (gypsum wallboard), either plain, wallpapered, or painted with oil- or water-base paint; Ceramic tile, ceramic panels; 3.5-5

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Glass, glass blocks; Brick, stone, concrete blocks, plain or painted; Steel and aluminum panels, plain, painted, or enameled; Vinyl tile, vinyl-asbestos tile, linoleum, or asphalt tile on concrete floors.

(10) Metal deck roof construction Not applicable. Metal deck roof should be noncombustible and construction is not used at Braidwood listed as "acceptable for fire" Station.

in the UL Building Materials Directory, or listed as Class I in the Factory Mutual System Approval Guide.

(11) Suspended ceilings and their Comply.

supports should be of noncombustible construction.

Concealed spaces should be devoid of combustibles except as noted in Position C.6.b.

(12) Transformers installed inside Comply. See Table 3-1 for delineation fire areas containing safety- of compliance with NFPA 70.

related systems should be of the dry type or insulated and cooled with noncombustible liquid.

Transformers filled with combustible fluid that are located indoors should be enclosed in a transformer vault (see Section 450(c) of NFPA 70, "National Electrical Code").

(13) Outdoor oil-filled transformers Does not fully comply. The Unit 1 (2) should have oil spill confine- Unit Auxiliary Transformer 141 (241) ment features or drainage away is within approximately 30 feet of the from the buildings. Such turbine building. The turbine build-transformers should be located ing wall has a 2-hour fire rating in at least 50 feet distant from this area. It also has a Label-B the building, or by ensuring door. The turbine building and 3.5-6

BRAIDWOOD AMENDMENT 18 DECEMBER 1998 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE that such building walls within equipment located inside it are non-50 feet of oil-filled trans- safety-related. All outdoor trans-formers are without openings and formers are separated from the have a fire resistance rating of safety-related auxiliary building by at least 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. approximately 48 feet. The auxiliary building wall in this area has a 3-hour fire rating. A small 1,000-kVA transformer is located approximately 35 feet from the fuel handling train shed. At this location, the train shed has insulated metal siding that does not carry a fire rating. A fire hazard analysis has been performed, and it was concluded that existing fire protection features are adequate to protect this hazard. The RWST and fuel handling building, which are withn 50 feet of this transformer, have 3-hour rated walls. In addition, a temporary transformer is located within 50 ft of the Unit 2 containment building, and a pad-mounted transformer is located within 50 feet of the Unit 2 RWST and the fuel handling building.

3.5-7

BRAIDWOOD AMENDMENT 18 DECEMBER 1998 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (14) Floor drains sized to remove Comply. See Table 3-1 for delineation expected fire fighting waterflow of compliance with NFPA Codes. NFPA without flooding safety-related 92M-1972 is no longer an NFPA Code.

equipment should be provided in Guidance for waterproofing and those areas where fixed water drainage was incorporated from other fire suppression systems are applicable NFPA Codes.

installed. Floor drains should also be provided in other areas where hand hose lines may be used if such fire fighting water could cause unacceptable damage to safety-related equipment in the area (see NFPA-92, "Water-proofing and Draining of Floors"). Where gas suppression systems are installed, the drains should be provided with adequate seals or the gas suppression system should be sized to compensate for the loss of the suppression agent through the drains. Drains in areas containing combustible liquids should have provisions for preventing the backflow of combustible liquids to safety-related areas through the interconnected drain systems.

Water drainage from areas that may contain radioactivity should be collected, sampled, and analyzed before discharge to the environment.

b. Safe Shutdown Capability (1) Fire protection features should Refer to Appendix A5.7,Section III.G be provided for structures, sys- for a discussion of fire protection tems, and components important provided for safe shutdown capability to safe shutdown. These and detailed discussion of conformance features should be capable of to the criteria listed in paragraphs limiting fire damage so that: b(1), b(2), and b(3).

3.5-7a

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (a) One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) is free of fire damage; and (b) Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station(s) 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) To meet the guidelines of Position C5.b.1, one of the following means of ensuring that one of the redundant trains is free of fire damage should be provided:

(a) Separation of cables and equipment and associated circuits of redundant trains by a fire barrier having a 3-hour rating.

Structural steel forming a part of or supporting such fire barriers should be protected to provide fire resistance equivalent to that required of the barrier; (b) Separation of cables and equipment and associated circuits of redundant trains by a horizontal distance of more than 20 feet with no interventing combustible or fire hazards. In addition, fire detectors and an automatic fire suppression system should be installed in the fire area; or 3.5-8

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (c) Enclosure of cable and equipment and associated circuits of one redundant train in a fire barrier having a 1-hour rating. In addition, fire detectors and an automatic fire suppression system should be installed in the fire area.

(3) If the guidelines of Positions C5.b.1 and C5.b.2 cannot be met, then alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room, or zone under consideration should be provided.

c. Alternative or Dedicated Shutdown Capability (1) Alternative or dedicated Comply.

shutdown capability provided for a specific fire area should be able to achieve and maintain subcritical reactivity condi-tions in the reactor, maintain reactor coolant inventory, achieve and maintain hot standby* conditions for a PWR (hot shutdown* for a BWR) and achieve cold shutdown*

conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and maintain cold shutdown conditions thereafter. During the postfire shutdown, the reactor coolant system process variables shall be maintained within those predicted for a loss of normal ac power, and the fission product boundary integrity shall not be affected; i.e., there shall be no fuel clad damage, rupture, or any

• As defined in the Technical Requirements Manual.

3.5-9

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE primary coolant boundary, or rupture of the containment boundary.

(2) The performance goals for the Comply, with following clarification.

shutdown functions should be: For some fire zones, it is necessary to take credit for making certain (a) The reactivity control repairs in order to achieve cold function should be capable shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Refer to of achieving and main- Section 2.4 for details for individual taining cold shutdown fire zones.

reactivity conditions.

(b) The reactor coolant makeup function should be capable of maintaining the reactor coolant level above the top of the core for BWRs and be within the level indication in the pressurizer for PWRs.

(c) The reactor heat removal function should be capable of achieving and main-taining decay heat removal.

(d) The process monitoring function should be capable of providing direct read-ings of the process varia-bles necessary to perform and control the above functions.

(e) The supporting functions should be capable of pro-viding the process cooling, lubrication, etc., neces-sary to permit the opera-tion of the equipment used for safe shutdown func-tions.

(3) The shutdown capability for Comply.

specific fire areas may be unique for each such area, or it 3.5-10

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE may be one unique combination of systems for all such areas. In either case, the alternative shutdown capability shall be independent of the specific fire area(s) and shall accommodate postfire conditions where offsite power is available and where offsite power 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 effect to implement this capability.

(4) If the capability to achieve and Comply.

maintain cold shutdown will not be available because of fire damage, the equipment and systems comprising the means to achieve and maintain the hot standby or hot shutdown condition shall be capable of maintaining such conditions until cold shutdown can be achieved. If such equipment and systems will not be capable of being powered by both onsite and offsite electric power systems because of fire damage, an independent onsite power system shall be provided. The number of operating shift personnel, exclusive of fire brigade members, required to operate such equipment and systems shall be onsite at all times.

(5) Equipment and systems comprising Comply. A repair procedure has been the means to achieve and main- prepared to cover any repairs tain cold shutdown conditions required. All materials and equipment should not be damaged by fire; needed to make these repairs will be or the fire damage to such maintained onsite.

equipment and systems should be limited so that the systems can be made operable and cold shut-down achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Materials for such repairs shall be readily available onsite and 3.5-11

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE procedures shall be in effect to implement such repairs. If such equipment and systems used 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 not be capable of being powered by both onsite and offsite elec-tric power systems because of fire damage, an independent onsite power system should be provided. Equipment and systems used after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be powered by offsite power only.

(6) Shutdown systems installed to Comply.

ensure postfire shutdown capability need not be designed to meet seismic Category I criteria, single failure criteria, or other design basis accident criteria, except where required for other reasons, e.g., because of interface with or impact on existing safety systems, or because of adverse valve actions due to fire damage.

(7) The safe shutdown equipment and Comply. There are no associated systems for each fire area circuits as defined in IEEE 384-1974 should be known to be isolated at B/B. Associated circuits as from associated circuits in the defined in the NRC's April 6, 1982 fire area so that hot shorts, clarification letter to Generic Letter open circuits, or shorts to 81-12 are addressed in Subsection ground in the associated cir- 2.4.1.

cuits will not prevent operation of the safe shutdown equipment.

The separation and barriers between trays and conduits containing associated circuits of one safe shutdown division and trays and conduits contain-ing associated circuits or safe shutdown cables from the redun-dant division, or the isolation of these associated circuits from the safe shutdown equip-ment, should be such that a 3.5-12

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE postulated fire involving associated circuits will not prevent safe shutdown.

d. Control of Combustibles (1) Safety-related systems should be Comply.

isolated or separated from combustible materials. When this is not possible because of the nature of the safety system or the combustible material, special protection should be provided to prevent a fire from defeating the safety system function. Such protection may involve a combination of automatic fire suppression, and construction capable of withstanding and containing a fire that consumes all combustibles present. Examples of such combustible materials that may not be separable from the remainder of its system are:

(a) Emergency diesel generator The emergency diesel generator fuel fuel oil day tanks. oil day tanks are provided with automatic fire suppression.

(b) Turbine-generator oil and The turbine-generator oil and hydraulic control fluid hydraulic control fluid system are systems. contained in the Turbine Building and thus separated from all safety-related areas.

(c) Reactor coolant pump lube Fire Protection of the reactor coolant oil system. pump lube oil system is described in A5.7 Section III.0 and 3.7.a(1)(e).

(2) Bulk gas storage (either See Table 3-1 for delineation of compressed or cryogenic), should conformance with NFPA 50A.

not be permitted inside struc-tures housing safety-related equipment. Storage of flammable gas such as hydrogen should be located outdoors or in separate 3.5-13

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE detached buildings so that a fire or explosion will not adversely affect any safety-related systems or equipment.

(Refer to NFPA 50A, "Gaseous Hydrogen Systems.")

Care should be taken to locate high-pressure gas storage containers with the long axis parallel to building walls.

This will minimize the possi-bility of wall penetration in the event of a container failure. Use of compressed gases (especially flammable and fuel gases) inside buildings should be controlled. (Refer to NFPA 6, "Industrial Fire Loss Prevention.")

(3) The use of plastic materials Comply. The use of plastic material should be minimized. In is minimized. The use of PVC and particular, halogenated plastics neoprene has been severely restricted.

such as polyvinyl chloride (PVC) and neoprene should be used only when substitute noncombustible materials are not available.

All plastic materials, including flame and fire retardant materials, will burn with an intensity and BTU production in a range similar to that of ordinary hydrocarbons. When burning, they produce heavy smoke that obscures visibility and can plug air filters, especially charcoal and HEPA.

The halogenated plastics also release free chlorine and hydrogen chloride when burning which are toxic to humans and corrosive to equipment.

(4) Storage of flammable liquids See Table 3-1 for delineation of should, as a minimum, comply conformance with NFPA 30.

with the requirements of NFPA 3.5-14

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE 30, "Flammable and Combustible Liquids Code."

(5) Hydrogen lines in safety-related Comply.

areas should be either designed to seismic Class I requirements, A 1-inch diameter hydrogen pipe is or sleeved such that the water routed from the station hydrogen pipe is directly vented to the system through the Auxiliary Building outside, or should be equipped to the Volume Control Tank. This line with excess flow valves so that provides a blanket of hydrogen above in case of a line break, the the reactor coolant in the Volume hydrogen concentration in the Control Tank to aid in oxygen control.

affected areas will not exceed 2%. Within the Auxiliary Building, the hydrogen piping is Category II, except for the sections of pipe between the Volume Control Tank and the control valve which are Category I. However, the Category II portions are seismically supported throughout this building. An excess flow check valve is also provided at the bulk storage facility. The pipe routing takes this pipe through the general areas on elevations 364'-0", 383'-0", and 401'-0", and through the Unit 1 piping penetration area on elevation 364'-0".

These areas are all large open areas.

Because of the large size of these areas, any hydrogen flow from a line break would be stopped by the excess flow check valve well before the concentration would reach 2%.

Although these areas contain safe shutdown equipment, they hydrogen piping is separated from exposed safe shutdown equipment within these areas by the maximum distance practicable.

Because of this separation and the seismic support of the piping, the hydrogen piping does not present a significant fire hazard to the safe shutdown equipment.

The Volume Control Tank Room is enclosed by shield walls. The valves used for operation of the Volume 3.5-15

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Control System are located in an adjacent valve aisle. Therefore, a fire in the Volume Control Tank Room would not disable system operation. A short loop of the hydrogen piping containing the hydrogen control valves also extends into this valve aisle.

The hydrogen pipe between the control valve and the Volume Control Tank is Category I piping. The remainder of the hydrogen pipe is Category II, but additional margin is incorporated into the design of the pipe and supports to protect against failure under seismic loads.

The Unit 2 piping is a continuation of the Unit 1 system.

e. Electrical Cable Construction, Cable Trays, and Cable Penetrations (1) Only metal should be used for Comply for all raceways containing cable trays. Only metallic electrical cables. Thin wall conduit tubing should be used for is used as a raceway in certain field-conduit. Thin-wall metallic routed systems (e.g., lighting and tubing should not be used. communication).

Flexible metallic tubing should only be used in short lengths to connect components to equipment.

Other raceways should be made of noncombustible material.

(2) Redundant safety-related cable Separation of redundant safety-related systems outside the cable cable systems by 3-hour rated barriers spreading room should be sepa- is not employed outside of the cable rated from each other and from spreading rooms. The cable separation potential fire exposure hazards criteria used at Braidwood are de-in non-safety-related areas by scribed in Appendix 5.2. Continuous fire barriers with a minimum line-type heat detectors are not used, fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. These as they are unnecessary. All fire cable trays should be provided areas containing safety-related cable with continuous line-type heat trays have ionization and thermal type detectors and should be access- fire detectors, which are effective in ible for manual fire fighting. detecting fires involving cable Cables should be designed to materials.

3.5-16

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE allow wetting down with fire Automatic water-type area suppression suppression water without is not employed on the cable tray electrical faulting. Manual system at Braidwood. Cables are not hose stations and portable hand considered to be the primary fire extinguishers should be hazard in any areas of the plant provided. except the cable spreading rooms, and therefore they do not have specific Safety-related cable trays of a fire suppression systems provided, single division that are sepa- except for the cable spreading rooms.

rated from redundant divisions However, cable trays are protected by by a fire barrier with a minimum the detection and manual suppression rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and are nor- equipment provided for areas where mally accessible for manual fire they are located.

fighting should be protected from the effects of a potential Refer to Section 2.3 for detailed exposure fire by providing discussion of each fire zone.

automatic water suppression in the area where such a fire could occur. Automatic area protection, where provided, should consider cable tray arrangements and possible transient combustibles to ensure adequate water coverage for areas that could present an exposure hazard to the cable system. Manual hose standpipe systems may be relied upon to provide the primary fire sup-pression (in lieu of automatic water suppression systems) for safety-related cable trays of a single division that are separated from redundant safety divisions by a fire barrier with a minimum rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and are normally accessible for manual fire fighting if all of the following conditions are met:

(a) The number of equivalent*

standard 24-inch-wide cable trays (both safety-related and non-safety-related) in a given fire area is six or less;

• Trays exceeding 24 inches should be counted as two trays; trays exceeding 48 inches should be counted as three trays, regardless of tray fill.

3.5-17

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (b) The cabling does not provide instrumentation, control or power to systems required to achieve and maintain hot shutdown; and (c) Smoke detectors are provided in the area of these cable routings, and continuous line-type heat detectors are provided in the cable trays.

Safety-related cable trays that are not accessible for manual fire fighting should be pro-tected by a zoned automatic water system with open-head deluge or open directional spray nozzles arranged so that ade-quate water coverage is provided for each cable tray. Such cable trays should also be protected from the effects of a potential exposure fire by providing automatic water suppression in the area where such a fire could occur.

In other areas where it may not be possible because of other overriding design features necessary for reasons of nuclear safety to separate redundant safety-related cable systems by 3-hour-rated fire barriers, cable trays should be protected by an automatic water system with open-head deluge or open directional spray nozzles arranged so that adequate water coverage is provided for each cable tray. Such cable trays should also be protected from the effects of a potential exposure fire by providing automatic water suppression in the area where such a fire could occur. The capability to 3.5-18

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE achieve and maintain safe shutdown considering the effects of a fire involving fixed and potential transient combustibles should be evaluated with and without actuation of the automatic suppression system and should be justified on a suitably defined basis.

(3) Electric cable construction All cables installed in cable trays, should, as a minimum, pass the with the exception of certain flame test in the current IEEE specialty instrumentation cables, pass Std 383. (This does not imply the IEEE 383-1974 flame test. All that cables passing this test cables that do not pass the flame test will not require fire protec- will be identified and any corrective tion.) action which is deemed necessary will be implemented.

(4) Cable raceways should be used Comply.

only for cables.

(5) Miscellaneous storage and piping Comply.

for flammable or combustible liquids or gases should not Propane storage is in a separate create a potential exposure building. Welding gases and oxygen hazard to safety-related are stored outdoors. Individual systems. bottles of flammable gases used for calibration are located in the Auxiliary Building.

f. Ventilation (1) The products of combustion and Since all fire barrier ventilation the means by which they will be openings have fire dampers which close removed from each fire area if a fire causes room temperature to should be established during the exceed a setpoint, automatic exhaust initial stages of plant design. of combustion products is not Consideration should be given to possible. However, the means and the installation of automatic methods to remove smoke from all suppression systems as a means safety-related plant areas have been of limiting smoke and end heat established and are set forth in an generation. Smoke and corrosive operating procedure.

gases should generally be discharged directly outside to an area that will not affect safety-related plant areas. The normal plant ventilation system may be used for this purpose if capable and available. To 3.5-19

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE facilitate manual firefighting, separate smoke and heat vents should be provided in specific areas such as cable spreading rooms, diesel fuel oil storage areas, switchgear rooms, and other areas where the potential exists for heavy smoke condi-tions (see NFPA 204 for addi-tional guidance on smoke control).

(2) Release of smoke and gases All smoke and gases which contain containing radioactive materials possible radioactive material is to the environment should be monitored prior to release to the monitored in accordance with environment.

emergency plans as described in the guidelines of Regulatory For details, see FSAR Subsections Guide 1.101, "Emergency Planning 3.1.2.6.1, 3.1.2.6.2, 6.4.1, 6.4.4.1, for Nuclear Power Plants." Any 6.5.1, 6.5.1.1, 9.4.1.2.b, 9.4.1.3.e, ventilation system designed to 9.4.1.3.h, 9.4.9.1.1.6-2, 9.4.9.1.2.c, exhaust potentially radioactive and 9.4.9.1.2.e.

smoke or gases should be evalu-ated to ensure that inadvertent operation or single failures will not violate the radiologi-cally controlled areas of the plant design. This requirement includes containment functions for protecting the public and maintaining habitability for operations personnel.

(3) Special protection for ventila- Power supply and controls for tion power and control cables mechanical ventilation equipment are may be required. The power not necessarily routed outside of fire supply and controls for mechan- zones served by the system. Most ical ventilation systems should ventilation equipment is located be run outside the fire area within the fire hazard area, thereby served by the system where requiring electrical cable to be practical. routed accordingly. However, such cabling is in conduit. To relocate the vent equipment outside the fire hazard area would be impractical. For details, see FSAR Subsections 4.4.4, 9.4.1.1.g, and 9.4.1.3.a.

(4) Engineered safety feature Comply. For details, see FSAR filters should be protected in Subsections 6.5.1.2.d-5 and Fire accordance with the guidelines Protection Report Subsection 2.3.3.14.

3.5-20

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE of Regulatory Guide 1.52. Any filter that includes combustible materials and is a potential exposure fire hazard that may affect safety-related components should be protected as deter-mined by the fire hazards analysis.

(5) The fresh air supply intakes to Comply. For details, see FSAR areas containing safety-related Subsection 9.4.1.1.1.e and Figure equipment or systems should be 6.4-1.

located remote from the exhaust air outlets and smoke vents of other fire areas to minimize the possibility of contaminating the intake air with the products of combustion.

(6) Stairwells should be designed to Comply, see part 6 of Subsection minimize smoke infiltration 3.5.a.

during a fire.

(7) Where total flooding gas extin- See Table 3-1 for delineation of guishing systems are used, area conformance to NFPA 12 and NFPA 12A.

intake and exhaust ventilation dampers should be controlled in For details, see Fire Protection accordance with NFPA 12, "Carbon Report Subsections 2.3.3.6, 2.3.3.7, Dioxide Systems," and NFPA 12A, 2.3.3.8, 2.3.3.9, 2.3.3.10 and 11, "Halon 1301 Systems," to main- 2.3.3.14, 2.3.3.16, 2.3.3.18, and tain the necessary gas concen- 2.3.3.20.

tration.

g. Lighting and Communication Lighting and two-way voice communication are vital to safe shutdown and emergency response in the event of fire. Suitable fixed and portable emergency lighting and communication devices should be provided as follows:

(1) Fixed self-contained lighting Comply. Fixed self-contained lighting consisting of fluorescent or will be provided in all areas where sealed-beam units with indivi- manual operation is assumed in the dual 8-hour minimum battery safe shutdown analysis in Section 2.4.

power supplies should be provided in areas that must be See FPR Section A.5.7.III.5.

3.5-21

BRAIDWOOD AMENDMENT 27 DECEMBER 2016 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE manned for safe shutdown and for access and egress routes to and from all fire areas. Safe shutdown areas include those required to be manned if the control room must be evacuated.

(2) Suitable sealed-beam battery- Comply. Portable lights are provided powered portable hand lights for emergency use by the fire brigade should be provided for emergency and other operations personnel.

use by the fire brigade and other operations personnel required to achieve safe plant shutdown.

(3) Fixed emergency communications Comply. A plant pager system is independent of the normal plant installed. Power is supplied from MCC communication system should be 033W3 and the security diesel.

installed at preselected sta-tions.

(4) A portable radio communications Comply. Four repeaters are provided system should be provided for at the Braidwood station. The use by the fire brigade and repeaters are located in the Security other operations personnel Ready Room (SRR) on elevation 451 in required to achieve safe plant the Turbine Building along column row shutdown. This system should L The repeaters connect with the not interfere with the communi- stations Distributed Antenna System cations capabilities of the (DAS) above the SRR on elevation 468 plant security force. Fixed in the Turbine Building along column repeaters installed to permit row L. A single credible fire at use of portable radio communi- either location could disable all cation units should be protected repeaters. However, the hand-held from exposure fire damage. radios would remain operable for the Preoperational and periodic fire brigade, other operations testing should demonstrate that personnel, and security to mitigate the frequencies used for the consequences of such a fire and to portable radio communication achieve safe plant shutdown. Testing will not affect the actuation of has demonstrated that coverage of the protective relays. plant by the remaining radio system components in the event of such a fire is adequate.

3.5-22

BRAIDWOOD AMENDMENT 18 DECEMBER 1998 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Separate radio talk groups for normal radio system operation and an independent frequency for abnormal operations are available for use by the fire brigade and other operations personnel required to achieve safe plant shutdown.

Security has its own talk group for normal operation and its own frequency for abnormal operations.

Preoperational testing has demonstrated that the frequencies used for portable radio communications do not affect the actuation of protective relays nor the transmitters that input to a relay that actuates a reactor trip for an engineered safety feature.

In the latter case, the area surrounding the transmitters has been labeled with appropriate warning messages. Further, portable radio transmissions are not allowed in the auxiliary electric equipment room and other designated areas. These actions have been taken in lieu of periodic testing.

3.5-23

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 3.6 FIRE DETECTION AND SUPPRESSION IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

a. Fire Detection Protection (1) Detection systems should be Comply with exceptions. See Table provided for all areas that 2.2-3.

contain or present a fire exposure to safety-related equipment.

(2) Fire detection systems should See Appendix 5.4 (to be provided).

comply with the requirements of Class A systems as defined in See Table 3-1 for delineation of NFPA 72D, "Standard for the conformance to NFPA 70 and NFPA 72D.

Installation, Maintenance, and Use of Proprietary Protective Signaling Systems," and Class 1 circuits as defined in NFPA 70, "National Electrical Code."

(3) Fire detectors should be Comply. Line-type heat detectors are selected and installed in accor- not used, in general, at B/B except in dance with NFPA 72E, "Automatic most charcoal filters and all outdoor Fire Detectors." Preoperational transformers.

and periodic testing of pulsed line-type heat detectors should See Table 3-1 for delineation of demonstrate that the frequencies conformance to NFPA 72E.

used will not affect the actu-ation of protective relays in other plant systems.

(4) Fire detection systems should The fire detection system will give give audible and visual alarm audible and visual alarm and and annunciation in the control annunciation in the control room.

room. Where zoned detection Local alarms are provided for areas systems are used in a given fire with fixed suppression systems.

area, local means should be provided to identify which de-tector zone has actuated. Local audible alarms should sound in the fire area.

(5) Fire alarms should be distinc-tive and unique so they will not be confused with any other plant system alarms.

3.6-1

BRAIDWOOD AMENDMENT 23 DECEMBER 2008 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (6) Primary and secondary power The fire detection system is powered supplies should be provided for from an ESF bus.

the fire detection system and for electrically operated See Table 3-1 for delineation of control valves for automatic conformance to NFPA 72D.

suppression systems. Such primary and secondary power supplies should satisfy provisions of Section 2220 of NFPA 72D. This can be accom-plished by using normal offsite power as the primary supply with a 4-hour battery supply as se-condary supply; and by providing capability for manual connection to the Class 1E emergency power bus within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of loss of offsite power. Such connection should follow the applicable guidelines in Regulatory Guides 1.6, 1.32, and 1.75.

b. Fire Protection Water Supply Systems (1) An underground yard fire main See Table 3-1 for delineation of loop should be installed to conformance to NFPA 24.

furnish anticipated water requirements. NFPA 24, "Stan-dard for Outside Protection" gives necessary guidance for such installation. It refe-rences other design codes and standards developed by such organizations as the American National Standards Institute (ANSI) and the American Water Works Association (AWWA). Type of pipe and water treatment should be design considerations with tuberculation as one of the parameters. Means for inspect-ing and flushing the systems should be provided.

(2) Approved visually indicating Comply, except for underground non-sectional control valves such as indicating valve OFP590 at the post-indicator valves should be gatehouse and valve 0FP983 for the provided to isolate portions of Unit 2 Containment Access Facility..

the main for maintenance or 3.6-2

BRAIDWOOD AMENDMENT 19 DECEMBER 2000 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE repair without shutting off the supply to primary and backup fire suppression systems serving areas that contain or expose safety-related equipment.

(3) Valves should be installed to Comply.

permit isolation of outside hydrants from the fire main for maintenance or repair without interrupting the water supply to automatic or manual fire sup-pression systems in any area containing or presenting a fire hazard to safety-related or safe shutdown equipment.

(4) The fire main system piping Comply, except for connections to the should be separate from service service water system, the or sanitary water system piping, demineralized water system, the except as described in Position service air compressor, and the C.5.c. (4). temporary cross-tie capability to the centrifugal charging pump oil coolers.

(5) A common yard fire main loop may Comply. Braidwood has only one loop serve multi-unit nuclear power in the Auxiliary Building which serves plant sites if cross-connected both units.

between units. Sectional con-trol valves should permit main-taining independence of the individual loop around each unit. For such installations, common water supplies may also be utilized. For multiple-reactor sites with widely separated plants (approaching 1 mile or more), separate yard fire main loops should be used.

(6) If pumps are required to meet Comply.

system pressure or flow require-ments, a sufficient number of pumps should be provided to ensure that 100% capacity will be available assuming failure of the largest pump or loss of offsite power (e.g., three 50%

pumps or two 100% pumps). This 3.6-3

BRAIDWOOD AMENDMENT 22 DECEMBER 2006 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE can be accomplished, for example, by providing either:

(a) Electric motor-driven fire pump(s) and diesel-driven fire pump(s); or (b) Two or more seismic Category I Class 1E electric motor-driven fire pumps connected to redun-dant Class 1E emergency power buses (see Regulatory Guides 1.6, 1.32, and 1.75).

Individual fire pump connections to the yard fire main loop should be separated with sectionalizing valves between connections. Each pump and its driver and controls should be located in a room separated from the remaining fire pumps by a fire wall with a minimum rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The fuel for the diesel fire pump(s) should be separated so that it does not provide a fire source exposing safety-related equipment.

Alarms indicating pump running, driver availability, failure to start, and low fire-main pressure should be provided in the control room.

The fire pump installation See Table 3-1 for delineation of should conform to NFPA 20, conformance with NFPA 20.

"Standard for the Installation of Centrifugal Fire Pumps."

(7) Outside manual hose installation Comply, as noted. See Table 3-1 for should be sufficient to provide delineation of conformance with NFPA an effective hose stream to any 24.

onsite location where fixed or transient combustibles could jeopardize safety-related equipment. Hydrants should be installed approximately every 250 ft on the yard main system.

3.6-4

BRAIDWOOD AMENDMENT 22 DECEMBER 2006 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE A hose house equipped with hose A dedicated fire brigade response and combination nozzle and other vehicle and two mobile hose carts auxiliary equipment recommended provide hose and equipment equivalent in NFPA 24, "Outside Protec- to that supplied by three hose houses.

tion," should be provided as needed, but at least every 1,000 ft. Alternatively, mobile means of providing hose and associated equipment, such as hose carts or trucks, may be used. When pro-vided, such mobile equipment should be equivalent to the equipment supplied by three hose houses.

(8) Threads compatible with those Comply.

used by local fire departments should be provided on all hydrants, hose couplings, and standpipe risers.

(9) Two separate, reliable fresh- Not applicable.

water supplies should be pro-vided. Saltwater or brackish water should not be used unless all freshwater supplies have been exhausted. If tanks are used, two 100% (minimum of 300,000 gallons each) system capacity tanks should be installed. They should be so interconnected that pumps can take suction from either or both. However, a failure in one tank or its piping should not cause both tanks to drain.

Water supply capacity should be capable of refilling either tank in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or less.

(10) Common tanks are permitted for Not applicable.

fire and sanitary or service water storage. When this is done, however, minimum fire water storage requirements should be dedicated by passive means, for example, use of a vertical standpipe for other water services. Administrative controls, including locks for 3.6-5

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE tank outlet valves, are unacceptable as the only means to ensure minimum water volume.

(11) The fire water supply should be Comply.

calculated on the basis of the largest expected flow rate for a The original calculations on the fire period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, but not less protection system were based on a line than 300,000 gallons. This flow break which creates the greatest rate should be based (conserva- friction loss in the system per NML tively) on 500 gpm for manual requirements. This has the same hose streams plus the largest effect as delivering water over the design demand of any sprinkler longest route even though the longest or deluge system as determined route was not considered in the in accordance with NFPA 13 or calculation. It would take four line NFPA 15. The fire water supply breaks to restrict the flow to only should be capable of delivering the longest route.

this design demand over the longest route of the water See Table 3-1 for delineation of supply system. conformance to NFPA 13 and NFPA 15.

(12) Freshwater lakes or ponds of Comply. At Braidwood, the cooling sufficient size may qualify as pond serves as the sole source of sole source of water for fire water for fire protection. The fire protection but require separate protection water system has two redundant suctions in one or separate suction intakes.

more intake structures. These supplies should be separated so that a failure of one supply will not result in a failure of the other supply.

(13) When a common water supply is Comply. The cooling pond is of such permitted for fire protection capacity that it meets the require-and the ultimate heat sink, the ments of the ultimate heat sink and following conditions should be fire protection. The fire protection satisfied: suction intake is not used for the heat sink.

(a) The additional fire protection water requirements are designed into the total storage capacity, and (b) Failure of the fire protection system should not degrade the function of the ultimate heat sink.

3.6-6

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (14) Other water systems that may be The Essential Service Water tie-in is used as one of the two fire manual; however, this is not designed water supplies should be to be redundant to the fire water permanently connected to the pumps.

fire main system and should be capable of automatic alignment to the fire main system. Pumps, controls, and power supplies in these systems should satisfy the requirements for the main fire pumps. The use of other water systems for fire protection should not be incompatible with their functions required for safe plant shutdown. Failure of the other system should not degrade the fire main system.

c. Water Sprinkler and Hose Standpipe Systems (1) Sprinkler systems and manual See paragraph 3.1c(2).

hose station standpipes should have connections to the plant underground water main so that a single active failure or a crack in a moderate-energy line cannot impair both the primary and backup fire suppression systems.

Alternatively, headers fed from each end are permitted inside buildings to supply both sprinkler and standpipe systems, provided steel piping and fittings meeting the require-ments of ANSI B31.1, "Power Piping," are used for the headers up to and including the first valve supplying the sprinkler systems where such headers are part of the seismically analyzed hose standpipe system. When provided, such headers are considered an extension of the yard main system. Each sprink-ler and standpipe system should be equipped with OS&Y (outside screw and yoke) gate valve or other approved shutoff valve and 3.6-7

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE waterflow alarm. Safety-related equipment that does not itself require sprinkler water fire protection but is subject to unacceptable damage if wet by sprinkler water discharge should be protected by water shields or baffles.

(2) Control and sectionalizing Electrical supervision is generally valves in the fire water systems provided for valves controlling should be electrically super- individual, fixed extinguishing vised or administratively systems. These valves alarm in the controlled. The electrical control room. Although interior and supervision signal should exterior sectional control valves are indicate in the control room. not electrically supervised, their All valves in the fire positions are administratively protection system should be controlled by station operating periodically checked to verify procedures.

position (see NFPA 26, "Supervision of Valves"). See Table 3-1 for delineation of conformance to NFPA 26.

(3) Fixed water extinguishing See Table 3-1 for delineation of systems should conform to conformance to NFPA 13 and NFPA 15.

requirements of appropriate standards such as NFPA 13, "Standards for the Installation of Sprinkler Systems," and NFPA 15, "Standard for Water Spray Fixed Systems."

(4) Interior manual hose installa- Hose stations are generally located tion should be able to reach any outside of unoccupied areas. Shutoff location that contains, or could valves are provided for all standpipes present a fire exposure hazard or sections of interior piping.

to, safety-related equipment Generally, these standpipe hose with at least one effective hose stations are located throughout the stream. To accomplish this, plant at approximately 100-foot standpipes with hose connections intervals on each floor.

equipped with a maximum of 100 feet of 1-1/2-inch woven-jacket, Hose reels in the station generally lined fire hose and suitable contain 50 feet of hose, although nozzles should be at least 4 selected reels are supplied with up to inches in diameter for multiple 200 feet of hose.

hose connections and 2-1/2 inches in diameter for single The standpipes used have a varying hose connections. These systems diameter of 2-1/2 inches to 4 inches.

should follow the requirements Portions of the Fire Protection System 3.6-8

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE of NFPA 14, "Standpipe and Hose that service safety-related equipment Systems," for sizing, spacing, or run through areas where safety-and pipe support requirements. related equipment is housed use Seismic Category I piping.

Hose stations should be located as dictated by the fire hazard See Table 3-1 for delineation of analysis to facilitate access conformance to NFPA 14.

and use for fire fighting operations. Alternative hose stations should be provided for an area if the fire hazard could block access to a single hose station serving that area.

Provisions should be made to supply water at least to stand-pipes and hose connections for manual fire fighting in areas containing equipment required for safe plant shutdown in the event of a safe shutdown earth-quake. The piping system serv-ing such hose stations should be analyzed for SSE loading and should be provided with supports to ensure system pressure inte-grity. The piping and valves for the portion of hose stand-pipe system affected by this functional requirement should, as a minimum, satisfy ANSI B31.1, "Power Piping." The water supply for this condition may be obtained by manual opera-tor actuation of valves in a connection to the hose stand-pipe header from a normal seismic Category I water system such as the essential service water system. The cross connec-tion should be (a) capable of providing flow to at least two hose stations (approximately 75 gpm per hose station), and (b) designed to the same standards as the seismic Category I water system; it should not degrade 3.6-9

BRAIDWOOD AMENDMENT 21 DECEMBER 2004 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE the performance of the seismic Category I water system.

(5) The proper type of hose nozzle Comply.

to be supplied to each area should be based on the fire The proper type of hose nozzle is hazard analysis. The usual supplied to each area; fog nozzles are combination spray/straight- supplied in areas where high-voltage stream nozzle should not be used hazards exist and straight-stream in areas where the straight nozzles are supplied to areas of new stream can cause unacceptable fuel storage.

mechanical damage. Fixed fog nozzles should be provided at locations where high-voltage shock hazards exist. All hose nozzles should have shutoff capability. (Guidance on safe distances for water application to live electrical equipment may be found in the "NFPA Fire Protection Handbook.")

(6) Fire hose should be hydro- Comply. Hose is tested per guidance statically tested in accordance of NFPA 1962.

with the recommendations of NFPA 1962, "Fire Hose - Care, Use, Maintenance." Hose stored in outside hose houses should be tested annually. Interior standpipe hose should be tested every 3 years.

(7) Certain fires, such as those Comply. See Table 3-1 for delineation involving flammable liquids, of conformance with NFPA 11, NFPA 11A, respond well to foam suppres- NFPA 11B, and NFPA 16.

sion. Consideration should be given to use of mechanical low-expansion foam systems, high-expansion foam generators, or aqueous film-forming foam (AFFF) systems, including the AFFF deluge system. These systems should comply with the require-ments of NFPA 11, NFPA 11A, NFPA 11B, and NFPA 16, as applicable.

3.6-10

Braidwood AMENDMENT 21 DECEMBER 2004 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

d. Halon Suppression Systems Comply, except as noted below.

Halon fire extinguishing systems See Table 3-1 for delineation of should comply with the require- conformance with NFPA 12A and NFPA ments of NFPA 12A and NFPA 12B, 12B.

"Halogenated Fire Extinguishing Agent Systems - Halon 1301 and Interlock and alarms are tested Halon 1211." Only UL-listed or initially by startup group. The halon FM-approved agents should be is purchased with a Certification of used. Provisions for locally Conformance.

disarming automatic Halon sys-tems should be key locked and The control panels will be locked with under strict administrative the keys controlled by operating.

control. Automatic Halon extin-guishing systems should not be The disarming of the system will alarm disarmed unless controls as in the control room.

described in Position C.2.c. are provided. Testing of halon cylinders will be performed semiannually, as allowed by In addition to the guidelines of NFPA 12A.

NFPA 12A and 12B, preventive maintenance and testing of the Pre-discharge alarms are provided systems, including check- locally, except for the Halon system weighing of the Halon cylinders, protecting the QA Records Vault. Pre-should be done at least discharge timers delay the discharge quarterly. to allow personnel time to leave the area. The Halon systems for the Upper Particular consideration should Cable Spreading Rooms also alarm in also be given to: the control room.

(1) Minimum required Halon Concentration testing is done by the concentration, vendor. They verify hold time and distribution, soak time, concentration. Ventilation is and ventilation control; controlled by fire damper held by electro-thermal links.

(2) Toxicity of Halon; There are only ventilation ducts and (3) Toxicity and corrosive cables in the area. Neither is likely characteristics of the to experience serious corrosive thermal decomposition damage. The rooms will be vented per products of Halon; and the smoke removal procedure.

(4) Location and selection of the activating detectors.

3.6-11

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

e. Carbon Dioxide Suppression Systems Carbon dioxide extinguishing Comply.

systems should comply with the requirements of NFPA 12, "Carbon Braidwood has an evacuation time with Dioxide Extinguishing Systems." alarm on CO2 systems. Local disarming Where automatic carbon dioxide will be electrically supervised and systems are used, they should be administratively controlled by equipped with a predischarge Operating. Disarming the system will alarm system and a discharge alarm in the control room. Valves delay to permit personnel will be verified every 31 days, per egress. Provisions for locally operating surveillance, for position.

disarming automatic carbon dioxide systems should be key See Table 3-1 for delineation of locked and under strict admini- conformance with NFPA 12.

strative control. Automatic carbon dioxide extinguishing systems should not be disarmed unless controls as described in Position C.2.c. are provided.

Particular consideration should also be given to:

(1) Minimum required CO2 Concentration and hold times are concentration, distri- verified by a test during the bution, soak time, and construction phase. Ventilation is ventilation control; controlled with electro-thermal links fire dampers. In addition to a (2) Anoxia and toxicity of CO2; predischarge alarm for personnel protection, an odorizer has been added (3) Possibility of secondary to the CO2 systems which adds a thermal shock (cooling) wintergreen odor to the CO2.

damage; (4) Conflicting requirements for venting during CO2 injection to prevent overpressurization versus sealing to prevent loss of agent; and (5) Location and selection of the activating detectors.

3.6-12

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

f. Portable Extinguishers Fire extinguishers should be Comply. See Table 3-1 for delineation provided in areas that contain, of conformance with NFPA 10.

or could present a fire exposure hazard to, safety-related equipment in accordance with guidelines of NFPA 10, "Portable Fire Extinguishers, Installa-tion, Maintenance and Use." Dry chemical extinguishers should be installed with due consideration given to possible adverse ef-fects on safety-related equip-ment installed in the area.

3.6-13

BRAIDWOOD AMENDMENT 27 DECEMBER 2016 3.7 GUIDELINES FOR SPECIFIC PLANT AREAS IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

a. Primary and Secondary Containment (1) Normal Operation - Fire Braidwood complies except as protection requirements for the identified below.

primary and secondary contain-ment areas should be provided for hazards identified by the fire hazards analysis.

Examples of such hazards include Fixed automatic suppression is not lubricating oil or hydraulic provided. Hose stations and portable fluid system for the primary extinguishers are available throughout coolant pumps, cable tray the containment. Ionization detectors arrangements and cable pene- provide local coverage over cable trations, and charcoal filters. penetrations. Heat detectors are Because of the general inaccess- provided over the reactor coolant ibility of primary containment pumps.

during normal plant operation, protection should be provided by automatic fixed systems. The effects of postulated fires within the primary containment should be evaluated to ensure that the integrity of the pri-mary coolant system and the containment is not jeopardized assuming no action is taken to fight the fire.

(a) Operation of the fire Comply. Manual hose stations are protection systems should relied upon for primary suppression not compromise the integ- inside the containment. Safety-rity of the containment or related equipment inside the other safety-related sys- containment is qualified for a post-tems. Fire protection LOCA environment, including water activities in the contain- spray. Fire fighting activities are ment areas should function thus not expected to adversely affect in conjunction with total safe shutdown components or the containment requirements containment integrity.

such as ventilation and control of contaminated liquid and gaseous release.

3.7-1

BRAIDWOOD AMENDMENT 27 DECEMBER 2016 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (b) Inside noninerted contain- Division 11 and 12 cable comes in ment one of the fire pro- close proximity. Descriptions of such tection means stated in occurrences and justification are Positions C.5.b.1 and provided in Appendix A5.7.

C.5.b.2 or the following fire protection means should be provided:

separation of cables and equipment and associated nonsafety circuits of redundant trains by a noncombustible radiant energy shield having a minimum fire rating of one-half hour.

(c) In primary containment, Fire detection systems are provided fire detection systems over reactor coolant pumps and should be provided for each electrical penetrations. A general fire hazard. The type of area fire detection system is not detection used and the employed in the containment at location of the detectors Braidwood.

should be the most suitable for the particular type of fire hazard identified by the fire hazard analysis.

A general area fire detec-tion capability should be provided in the primary containment as backup for the above described hazard detection. To accomplish this, suitable smoke or heat detectors compatible with the radiation environ-ment should be installed.

(d) Standpipe and hose stations Comply. Standpipes and hose stations should be inside PWR con- are provided inside the containment.

tainments and BWR contain- The normal fire protection system is ments that are not inerted. used. The containment penetrations Standpipe and hose stations comply with the stated requirements.

inside containment may be connected to a high quality water supply of sufficient quantity and pressure other than the fire main loop if plant-specific features prevent extending the fire 3.7-2

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE main supply inside contain-ment. For BWR drywells, standpipe and hose stations should be placed outside the drywell with adequate lengths of hose, no longer than 100 ft, to reach any location inside the drywell with an effective hose stream.

The containment penetration of the standpipe system should meet the isolation requirements of General Design Criterion 56 and should be seismic Category I and Quality Group B.

(e) The reactor coolant pumps Comply. Refer to Section III.O of should be equipped with an Appendix A5.7.

oil collection system if the containment is not inerted during normal op-eration. The oil collection system should be so designed, engineered, and installed that failure will not lead to fire during normal or design basis accident conditions and that there is reasonable assurance that the system will withstand the safe shutdown earthquake.

Such collection systems should be capable of collecting lube oil from all potential pressurized and unpressurized leakage sites in the reactor cool-ant pump lube oil systems.

Leakage should be collected and drained to a vented closed container that can hold the entire lube oil system inventory. A flame arrester is required in the 3.7-3

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE vent if the flash point characteristics of the oil present the hazard of fire flashback. Leakage points to be protected should include lift pump and pip-ing overflow lines, lube oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and lube oil reser-voirs where such features exist on the reactor cool-ant pumps. The drain line should be large enough to accommodate the largest potential oil leak.

(f) For secondary containment Braidwood does not have a secondary areas, cable fire hazards containment area.

that could affect safety should be protected as described in Position C.5.e(2). The type of de-tection system for other fire hazards identified by the fire hazards analysis should be the most suitable for the particular type of fire hazard.

(2) Refueling and Maintenance - Comply.

Refueling and maintenance operations in containment may Administrative procedures ensure introduce additional hazards adequate fire protection for transient such as contamination control fire loads.

materials, decontamination supplies, wood planking, tem-porary wiring, welding, and flame cutting (with portable compressed-gas fuel supply).

Possible fires would not necessarily be in the vicinity of fixed detection and suppres-sion systems. Management proce-dures and controls necessary to ensure adequate fire protection for transient fire loads are discussed in Position C.1.

3.7-4

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Adequate self-contained breath- Two self-contained breathing units are ing apparatus should be provided provided at each entrance to the near the containment entrances containment and at selected locations for fire fighting and damage in the containment. These air packs control personnel. These units will provide the necessary air for should be independent of any fire fighting and damage control breathing apparatus or air sup- personnel. These units are ply systems provided for general independent from the station's plant activities and should be supplied air system.

clearly marked as emergency equipment.

b. Control Room Complex The control room complex The walls, floor, and roof are 3-hour (including galleys, office fire barriers as shown in Fire spaces, etc.) should be pro- Protection Report Figures 2.3-7 and tected against disabling fire 2.3-8 Sheets 1 and 3.

damage and should be separated from other areas of the plant by Neither automatic fixed suppression floors, walls, and roof having systems nor smoke dampers are provided minimum fire resistance ratings for peripheral rooms (i.e., offices) of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Peripheral rooms in in the control room complex.

the control room complex should have automatic water suppression For details see FSAR Subsections and should be separated from the 6.4.2.3, 6.4.2.4, and Fire Protection control room by noncombustible Report Subsection 2.3.2.1.

construction with a fire resist-ance rating of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Ventila- Control room fire dampers are held by tion system openings between the thermal links not hooked to the control room and peripheral detectors.

rooms should have automatic smoke dampers that close on Portable fire extinguishers are operation of the fire detection provided in the control room. A hose or suppression system. If a station is available near the entrance halon flooding system is used to the control room.

for fire suppression, these dampers should be strong enough to support the pressure rise accompanying halon discharge and sealed tightly against infiltra-tion of halon into the control room. Carbon dioxide flooding systems are not acceptable for these areas.

Manual fire fighting capability The approximate locations of should be provided for both: extinguishers and hoses are shown on Fire Protection Report Figure 2.3-8 Sheets 1 and 3.

3.7-5

BRAIDWOOD AMENDMENT 16 DECEMBER 1994 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (1) Fire originating within a cabinet, console, or connecting cables; and (2) Exposure fires involving combustibles in the general room area.

Portable Class A and Class C fire extinguishers should be located in the control room. A hose station should be installed immediately outside the control room.

Nozzles that are compatible with Comply.

the hazards and equipment in the control room should be provided for the manual hose station.

The nozzles chosen should satisfy actual fire fighting needs, satisfy electrical safety, and minimize physical damage to electrical equipment from hose stream impingement.

Smoke detectors should be Do not comply fully. Smoke detectors provided in the control room, are installed in the exhaust vents of cabinets, and consoles. If the cabinets. Detectors are installed redundant safe shutdown equip- at the ceiling. Additional protection ment is located in the same is not provided. Fire Hazards panel control room cabinet or console, is installed for indication where additional fire protection separation was not met. Ceiling measures should be provided. detectors alarm on OPMO1J, 1PM09J, and Alarm and local indication the duct detectors alarm on OPMO2J and should be provided in the the SER. Smoke detectors are provided control room. in the control room exhaust ducts.

Additionally, fire protection features are not provided for panels containing redundant safe shutdown equipment; however, this equipment is addressed in Section 2.4.

3.7-6

BRAIDWOOD AMENDMENT 16 DECEMBER 1994 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Breathing apparatus for control Comply.

room operators should be readily available. Seven (7) S.C.B.A. with dedicated air bottles will be provided for the control room emergency personnel.

Additional bottled air supplies are maintained onsite for a total of six (6) hours of breathing air for each of the seven emergency staff personnel.

Two additional S.C.B.A. units are maintained to comply with single failure criteria for Regulatory Guide 1.95.

3.7-6a

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE For details see FSAR Subsection 6.4.1.f.

The outside air intake(s) for Comply in terms of providing the control room ventilation ionization detectors at outside air system should be provided with intakes, as well as isolating the smoke detection capability to intakes on ionization detection with alarm in the control room to provision to use alternate intakes for enable manual isolation of the makeup air. In addition, all the air control room ventilation system is passed through recirculation and thus prevent smoke from charcoal filters.

entering the control room.

The detectors alarm at OPMO2J and the SER. The manual damper controls are on OPMO2J.

For details see FSAR Subsections 9.4.1.2b and 9.4.1.1.1e, and 6.4.1h.

Venting of smoke produced by Comply.

fire in the control room by means of the normal ventilation The manual controls for air intake are system is acceptable; however, on OPMO2J.

provision should be made to permit isolation of the recircu- For details see FSAR Subsection lating portion of the normal 9.4.1.3d and Fire Protection Report ventilation system. Manually Subsection 2.3.2.1.

operated venting of the control room should be available to the operators.

All cables that enter the Comply.

control room should terminate in the control room. That is, no All cables that enter the control room cabling should be routed through terminate in the control room.

the control room from one area to another. Cables in under- The ESF Division 11 cables enter from floor and ceiling spaces should the ceiling and ESF Division 12 cables meet the separation criteria enter from the floor. Cable separa-necessary for fire protection. tion is defined in IEEE Standard 384-1974 and NRC Regulatory Guide 1.75.

Air-handling functions should be Comply, except as explained below.

ducted separately from cable runs in such spaces; i.e., if Ceiling and floor are not used as a cables are routed in underfloor plenum. Ducts are not used for cable or ceiling spaces, these spaces runs.

should not be used as air 3.7-7

BRAIDWOOD AMENDMENT 25 DECEMBER 2012 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE plenums for ventilation of the control room. Fully enclosed electrical raceways located in There are no electrical cable trays such underfloor and ceiling located under floor and ceiling spaces, if over 1 square foot in spaces. Currently, this is also true cross-sectional area, should for the raised floor in the process have automatic fire suppression computer room, which is part of the inside. Area automatic fire control room complex. There are some suppression should be provided conduits above dropped ceiling.

for underfloor and ceiling spaces if used for cable runs Upper cable spreading room has unless all cable is run in 4- automatic halon and lower cable inch or smaller steel conduit or spreading room has automatic CO2.

the cables are in fully enclosed Upper cable spreading room has manual raceways internally protected by CO2 as a backup.

automatic fire suppression.

There should be no carpeting in Carpeting in the main control room has the control room. a flame spread of 25 or less.

c. Cable Spreading Room The primary fire suppression in Comply, except as explained below:

the cable spreading room should be an automatic water system The Byron/Braidwood design includes such as closed-head sprinklers, several cable spreading rooms at open-head deluge system, or open elevation 439'-0" and 463'-4-1/2".

directional water spray system. The rooms are designed such that Deluge and open spray systems redundant safe shutdown cabling is should have provisions for routed through separate rooms (except manual operation at a remote as noted in Section 2.4.2) and station; however, there should isolated by 3-hour fire barriers. The be provisions to preclude upper cable spreading rooms are inadvertent operation. Location protected by an automatic Halon 1301 of sprinkler heads or spray system, with a manual CO2 backup nozzles should consider cable system. Manual hose stations and tray arrangements and possible portable extinguishers provide transient combustibles to ensure additional backup. The lower cable adequate water coverage for spreading areas are protected by an areas that could present automatic CO2 system. Backup is exposure hazards to the cable provided by manual hose stations and system. Cables should be portable extinguishers. Conformance designed to allow wetting down of the halon and CO2 systems as with water supplied by the fire installed at Braidwood to the suppression system without requirements of the governing codes, electrical faulting. NFPA 12 and NFPA 12A, will be evaluated.

3.7-8

BRAIDWOOD AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Open-head deluge and open Cable spreading rooms 3.3B-1 and 3.3B-directional spray system should 2 have only one access door. The BTP be zoned. position is that an automatic water suppression system should be installed The use of foam is acceptable. in the cable spreading rooms. The Braidwood system provides adequate Cable spreading rooms should fire protection in the cable spreading have: rooms without an automatic water system. Hose stations are available (1) At least two remote and for use in the cable spreading rooms separate entrances for if required.

access by fire brigade personnel; An automatic water suppression system was not installed in the cable rooms (2) An aisle separation between because of concerns about the tray stacks at least 3 feet probability and effects of inadvertent wide and 8 feet high; actuations. The thermal elements in the Fenwal rate compensated heat (3) Hose stations and portable detectors are very similar to the extinguishers installed thermal elements in the automatic immediately outside the water suppression systems. Since a room; cable fire would generate large quantities of smoke in a very early (4) Area smoke detection; and stage of a fire, the ionization detectors would be very effective in (5) Continuous line-type heat detecting small cable fires and detectors for cable trays annunciating in the control room. If inside the cable spreading the fire was of such magnitude that room. the thermal detectors sensed the fire, the automation actuation of the fire Drains to remove fire fighting suppression system would then be water should be provided. When initiated. The detector circuits are gas systems are installed, designed that if either of the drains should have adequate redundant detection zones failed, the seals or the gas extinguishing remaining detection zone could then systems should be sized to solely initiate the automatic compensate for losses through suppression system. For this the drains. application the cross-zoning of rate compensated heat detectors with A separate cable spreading room ionization detectors would not reduce should be provided for each redundant the responsiveness of a fire detection division. Cable spreading rooms system compared to a closed-head should not be shared between reactors. sprinkler system. A deluge system Each cable spreading room should be which indiscriminately sprays a large separated from the others and from area will result in a significant other areas of the plant by barriers effort to restore the cable spreading with a minimum fire room to normal conditions and could 3.7-9

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. If this is potentially cause other problems if not possible, a dedicated system water leaks into adjacent areas such should be provided. as the control room which is below the upper cable spreading room, or the ESF The ventilation system to each switchgear room which is below the cable spreading room should be lower cable spreading room.

designed to isolate the area Inadvertent actuation of a halon or upon actuation of any gas CO2 system would have no adverse extinguishing system in the effects.

area. Separate manually actuated smoke venting that is The probability of a fire in a cable operable from outside the room spreading room is quite low. The main should be provided for the cable combustible material is cable insula-spreading room. tion. The cables are covered with EPR or EPDM insulation with hypalon jac-kets. The cables have passed IEEE 383-1974 flame tests. In the event of a fire in a cable spreading room, spread of the fire would be prevented by 3-hour fire barriers. Disabling of one full cable spreading room would not prevent safe shutdown of the plant due to the redundancy and separation criteria used in design. This fire barrier construction ensures a long residence time in the event of a halon or CO2 discharge.

In the unlikely event that water is required to quench hot areas after a fire, manual application of water using the nearby hose stations will provide localized control without the effects to the general area which could result from actuation of a deluge system. As shown in the Braid-wood Fire Protection Report, hose sta-tions are located in each compartment of the upper and lower cable spreading areas. Hose stations are located adjacent to each doorway so that water availability will be guaranteed even if severe smoke conditions exist.

In summary, the Braidwood cable spreading area fire protection system design ensures that fire will not com-promise plant safety. Use of automa-tic halon or CO2 systems instead of water deluge reduces the probability 3.7-10

BRAIDWOOD AMENDMENT 26 DECEMBER 2014 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE of a plant shutdown or equipment damage in the event of a spurious actuation.

Additionally, the area is well supplied with manual hose stations and portable fire extinguishers.

d. Plant Computer Rooms Computer rooms for computers The process computer at Braidwood is performing safety-related non-safety-related and is part of the functions that are not part of the control room complex. Automatic fixed control room complex should be suppression is not provided. Fire separated from other areas of the protection features which are provided plant by barriers having a minimum are described in Subsection 2.3.4 of fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> this report.

and should be protected by automatic detection and fixed automatic suppression. Computers that are part of the control room complex but not in the control room should be separated and protected as described in Position C.7.b. Computer cabinets located in the control room should be protected as other control room equipment and cable runs therein.

Non-safety-related computers outside the control room complex should be separated from safety-related areas by fire barriers with a minimum rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and should be protected as needed to prevent fire and smoke damage to safety-related equipment.

e. Switchgear Rooms Switchgear rooms containing Comply, except as noted below:

safety-related equipment should be separated from the remainder of Alarms do not annunciate locally.

the plant by barriers with a Doors in the L-line wall on EL 426-0 minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. that separate the Switchgear Rooms and Redundant switchgear safety adjacent turbine building fire zones are divisions should be separated from non-labeled fire doors. The subject each other by barriers with a 3- doors are addressed in Generic Letter hour fire rating. Automatic fire 86-10 Evaluation EC-EVAL 392603; this detectors should alarm and evaluation determined that the doors are annunciate in the control room adequate for the fire hazards to which they are exposed and justifies the use of each non-labeled fire door. Refer to EC 391762 and EC-EVAL 392603.

3.7-11

BRAIDWOOD AMENDMENT 22 DECEMBER 2006 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE and alarm locally. Cables entering the switchgear room that do not terminate or perform a function there should be kept at a minimum to minimize the combustible loading. These rooms should not be used for any other purpose. Fire hose stations and portable fire extinguishers should be readily available outside the area.

Equipment should be located to See Table 3-1 for delineation of facilitate access for manual conformance with NFPA 92M.

fire fighting. Drains should be provided to prevent water accu-mulation from damaging safety-related equipment (see NFPA 92M, "Waterproofing and Draining of Floors"). Remote manually actuated ventilation should be provided for venting smoke when manual fire suppression effort is needed (see Position C.5.f).

f. Remote Safety-Related Panels Comply, except as noted below:

Redundant safety-related panels The remote shutdown panels can be remote from the control room electrically isolated from control complex should be separated from room equipment by transfer switches each other by barriers having a located on the panels. For control minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. room evacuation or damage, this Panels providing remote shutdown isolates the remote shutdown panels capability should be separated from the control room, but also from the control room complex by renders the control room panels barriers having a minimum fire inoperable. The redundant remote rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Panels pro- shutdown panels are not separated from viding remote shutdown capabil- each other by 3-hour-rated barriers.

ity should be electrically They are located alongside each other isolated from the control room in the same room. The automatic complex so that a fire in either detectors provided for the remote area will not affect shutdown shutdown control room do not alarm capability from the other area. locally.

The general area housing remote safety-related panels should be Alternate shutdown is provided for a provided with automatic fire fire in the remote shutdown control detectors that alarm locally and room by operating equipment from the alarm and annunciate in the switchgear rooms and locally. This is control room. Combustible covered by Braidwood Procedure 1BWOA materials should be controlled ELEC-5.

3.7-12

BRAIDWOOD AMENDMENT 26 DECEMBER 2014 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE and limited to those required for operation. Portable extinguishers and manual hose stations should be readily available in the general area.

g. Safety-Related Battery Rooms Safety-related battery rooms Comply, with exception noted below.

should be protected against fires The safety-related batteries are and explosions. Battery rooms located in the same fire zone with should be separated from each their associated battery charger, other and other areas of the inverter, and dc switchgear and plant by barriers having a distribution panels. The battery minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> itself is located in a separate room inclusive of all penetrations and within the larger miscellaneous openings. DC switchgear and electric equipment room (fire zone) inverters should not be located and has its own ventilation system, in these battery rooms. but is separated by 3-hour walls and Automatic fire detection should an unrated ceiling. Each battery and be provided to alarm and electrical equipment room is separated annunciate in the control room from its redundant counterpart and and alarm locally. Ventilation other fire zones by 3-hour-rated fire systems in the battery rooms barriers.

should be cap-able of maintaining the hydrogen concentration well Detectors do not alarm locally.

below 2 vol-%. Loss of ventilation should be alarmed in the control room. Standpipe and hose and portable extinguishers should be readily available outside the room.

h. Turbine Building The turbine building should be The Applicant complies with this separated from adjacent position with two exceptions.

structures containing safety- The complete collapse of the turbine related equipment by a fire building structure is not a design barrier with a minimum rating of basis event for the Braidwood plant.

3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The fire barriers This building, although not a Category should be designed so as to I structure, is designed for the SSE maintain structural integrity and other Category I loads. Fire even in the event of a complete protection features are adequate to collapse of the turbine prevent a fire of sufficient severity structure. Openings and to threaten the integrity of the penetrations in the fire barrier structure from developing.

should be minimized and should Additionally, four fire doors in L-not be located where the turbine line wall that separate the turbine oil system or generator hydrogen building on El3 401-0 and adjacent cooling system creates DG Rooms and four fire doors in the L-line wall that separate the turbine building on El.426-0 and Switchgear Rooms are non-labeled fire doors.

3.7-13

BRAIDWOOD AMENDMENT 26 DECEMBER 2014 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE a direct fire exposure hazard to The subject doors are addressed in the barrier. Considering the Generic Letter 86-10 Evaluation severity of the fire hazards, EC-EVAL 32603; this evaluation defense in-depth may dictate determined that the doors are adequate additional protection to ensure for the fire hazards to which they are barrier integrity. exposed and justifies the use of each non-labeled fire door. Refer to EC 391762 and EC-EVAL 392603.

i. Diesel Generator Areas Diesel generators should be Comply, except as noted below:

separated from each other and from other areas of the plant by UV detectors do not alarm locally.

fire barriers having a minimum fire resistance rating of 3 Thermal detectors do alarm locally hours. prior to CO2 discharge.

Doors in the L-line wall on EL 401-0 that separate the dg Rooms and adjacent turbine building fire zones are non-labeled fire doors. The subject doors are addressed in Generic Letter 86-10 Evaluation EC-EVAL 392603; this evaluation determined that the doors are adequate for the fire hazards to which they are exposed and justifies the use of each non-labeled fire door. Refer to EC 391762 and EC-EVAL 392603.

Automatic fire suppression should Some diesel oil piping associated with be installed to combat any diesel one ESF train is routed through generator or lubricating oil redundant train fire areas. Some fires; such systems should be diesel oil piping associated with one designed for operation when the ESF train is routed through the diesel is running without redundant train's room. Calculations affecting the diesel. Automatic (MAD 90-0079 and 3C8-0890-001) have fire detection should be provided been performed to demonstrate that to alarm and annunciate in the even if this DO piping is unprotected, control room and alarm locally. a fire in this zone does not affect Hose stations and portable the operability of the redundant extinguishers should be readily diesel generator. Therefore, a fire available outside the area. in this zone would not affect the Drainage for fire fighting water ability to shut down the plant safely.

and means for local manual However, fire wrap was added as a venting of smoke should be conservative measure on most DO lines provided. associated with the ESF train credited for safe shutdown.

3.7-14

BRAIDWOOD AMENDMENT 18 DECEMBER 1998 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Day tanks with total capacity up to 1100 gallons are permitted in the diesel generator area under the following conditions:

(1) The day tank is located in a separate enclosure with a minimum fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, includ-ing doors or penetrations.

These enclosures should be capable of containing the entire contents of the day tanks and should be pro-tected by an automatic fire suppression system, or 3.7-14a

BRAIDWOOD AMENDMENT 25 DECEMBER 2012 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (2) The day tank is located inside the diesel generator room in a diked enclosure that has sufficient capacity to hold 110% of the contents of the day tank or is drained to a safe location.

j. Diesel Fuel Oil Storage Areas Diesel fuel oil tanks with a Comply, except as noted below:

capacity greater than 1,100 gallons should not be located Diesel fuel oil tanks are located inside buildings containing within the Auxiliary Building. See safety-related equipment. If Table 3-1 for delineation of confor-above-ground tanks are used, mance with NFPA 30.

they should be located at least 50 feet from any building con- The outdoor above-ground diesel fuel taining safety-related equipment oil storage tanks (located more than or, if located within 50 feet, 100 feet away from any building they should be housed in a sepa- containing safety-related equipment) rate building with construction are not protected by an automatic fire having a minimum fire resistance suppression system. Potential fuel rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Potential oil spills are confined within a berm.

oil spills should be confined or Manual suppression capability will directed away from buildings prevent the fire from spreading from containing safety-related equip- the berm.

ment. Totally buried tanks are acceptable outside or under buildings (see NFPA 30, "Flammable and Combustible Liquids Code," for additional guidance).

Above-ground tanks should be protected by an automatic fire suppression system.

k. Safety-Related Pumps Pump houses and rooms housing Comply, except as noted below:

redundant safety-related pump trains should be separated from Most safety-related pumps are located each other and from other areas in the Auxiliary Building. Most pumps of the plant by fire barriers are located in individual rooms sepa-having at least 3-hour ratings. rated from other plant areas by walls These rooms should be protected of substantial construction, but which by automatic fire detection and generally do not carry fire ratings.

3.7-15

BRAIDWOOD AMENDMENT 23 DECEMBER 2008 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE suppression unless a fire Automatic fire detection is provided hazards analysis can demonstrate for all pumps, but automatic that a fire will not endanger suppression is in general not other safety-related equipment provided. Refer to the applicable required for safe plant shut- portions of Sections 2.3 and 2.4 of down. Fire detection should this Fire Protection Report for a alarm and annunciate in the description of individual pumps and control room and alarm locally. the fire hazards and safe shutdown Hose stations and portable analyses. Deviations from the 10 CFR extinguishers should be readily 50 Appendix R criteria are listed in accessible. Appendix A5.7.

Ionization detectors are provided which annunciate and alarm in the control room.

Detectors do not alarm locally.

Floor drains should be provided to prevent water accumulation from damaging safety-related equipment (see Position C.5.a.(14)).

Provisions should be made for manual control of the ventila-tion system to facilitate smoke removal if required for manual fire fighting operation (see Position C.5.f).

l. New Fuel Area Hand portable extinguishers Comply, except as noted below:

should be located within this area. Also, hose stations Ionization and ultraviolet detectors should be located outside but are provided which annunciate and within hose reach of this area. alarm in the control room.

Automatic fire detection should alarm and annunciate in the Detectors do not alarm locally.

control room and alarm locally.

Combustibles should be limited to a minimum in the new fuel area. The storage area should be provided with a drainage system to preclude accumulation of water.

3.7-16

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE The storage configuration of new fuel should always be so main-tained as to preclude critical-ity for any water density that might occur during fire water application.

m. Spent Fuel Pool Area Protection for the spent fuel Comply, except as noted below:

pool area should be provided by local hose stations and portable Ionization and ultraviolet detectors extinguishers. Automatic fire are provided which annunciate and detection should be provided to alarm in the control room.

alarm and annunciate in the control room and to alarm Detectors do not alarm locally.

locally.

n. Radwaste and Decontamination Areas Fire barriers, automatic fire Comply, except as noted below:

suppression and detection, and ventilation controls should be Radwaste areas within the Auxiliary provided. Building are separated from other Auxiliary Building areas by non-fire-rated walls. The radwaste areas with-in the service building are provided with 3-hour-rated barriers between the adjacent turbine building and between other service building areas. Most radwaste areas are not provided with automatic fire suppression systems.

Automatic suppression with only par-tial coverage is provided for radwaste areas within the service building.

Refer to Subsection 2.3.14 for detailed description of the various radwaste areas of the plant. Decon-tamination areas are not treated as separate fire areas, and hence do not have fire barriers or automatic sup-pression systems. Four such areas are identified on plant drawings. A decontamination skid is shown on the ground floor of the service building.

It is part of fire zone 14.6-0. A decontamination station is shown in the radwaste tunnel on Elevation 383 feet 0 inch near column-row 26/N. It 3.7-17

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE is part of fire zone 14.1-0. In the fuel handling building, a decontami-nation area is shown on Elevation 401 feet 0 inch near column-row 17/Z. It is a pit for washing down spent fuel casks and has neither rated fire bar-riers nor automatic suppression. It is part of fire zone 12.1-0 (refer to Subsection 2.3.12). Finally, a decon-tamination/change area and a decon-tamination pad are shown on Elevation 426 feet 0 inch in the general area of the Auxiliary Building between column-rows 15-21/U-V. These rooms are sepa-rated from the rest of the Auxiliary Building by non-fire-rated walls, and they do not have automatic suppres-sion. Refer to Subsection 2.3.11 for a detailed description of these areas.

o. Safety-Related Water Tanks Storage tanks that supply water Comply.

for safe shutdown should be protected from the effects of an exposure fire. Combustible materials should not be stored next to outdoor tanks.

p. Records Storage Areas Records storage areas should be Comply. The record storage areas are so located and protected that a located such that there is no exposure fire in these areas does not to safety-related systems. The main expose safety-related systems or record storage facility is located in equipment (see Regulatory Guide the service building. For compliance 1.88, "Collection, Storage, and with Regulatory Guide 1.88, see B/B-Maintenance of Nuclear Power FSAR Page A1.88-1.

Quality Assurance Records").

q. Cooling Towers Cooling towers should be of NA noncombustible construction or so located and protected that a fire will not adversely affect any safety-related systems or equipment. Cooling towers should be of noncombustible construction when the basins are 3.7-18

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE used for the ultimate heat sink or for the fire protection water supply.

r. Miscellaneous Areas Miscellaneous areas such as Comply.

shops, warehouses, auxiliary boiler rooms, fuel oil tanks, and flammable and combustible liquid storage tanks should be so located and protected that a fire or effects of a fire, including smoke, will not adversely affect any safety-related systems or equipment.

3.7-19

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE 3.8 SPECIAL PROTECTION GUIDELINES

a. Storage of Acetylene-Oxygen Fuel Gases Gas cylinder storage location Comply.

should not be in areas that contain or expose safety-related A fire prevention procedure for equipment or the fire protection welding and cutting covers the permit systems that serve those safety- needed to use acetylene-oxygen fuel related areas. A permit system gases.

should be required to use this equipment in safety-related areas of the plant (also see Position C.2).

b. Storage Areas for Ion Exchange Resins Unused ion exchange resins Comply.

should not be stored in areas that contain or expose safety-related equipment.

c. Hazardous Chemicals Hazardous chemicals should not Hazardous chemicals such as caustic be stored in areas that contain soda, sulphuric acid, etc., are kept or expose safety-related in proper containers in accordance equipment. with fire protection recommendations.

Ventilation and flood protection are provided. Storage areas have curbs, good drainage, and sump capability.

d. Materials Containing Radioactivity Materials that collect and Comply.

contain radioactivity such as spent ion exchange resins, charcoal filters, and HEPA filters should be stored in closed metal tanks or containers that are located in areas free from ignition sources or combustibles. These materials should be protected from exposure to fires in adjacent areas as well. Consideration should be given to requirements 3.8-1

BRAIDWOOD AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE for removal of decay heat from entrained radioactive materials.

3.8-2

BRAIDWOOD-1 AMENDMENT 28 DECEMBER 2018 BRAIDWOOD STATION NFPA Code Deviations For Unit 1 and Common Areas 3.9-1

BRAIDWOOD-1 AMENDMENT 28 DECEMBER 2018 INTRODUCTION The National Fire Protection Association (NFPA) code review conducted for Braidwood Station includes Unit 1 and common areas. On a case-by-case basis, the applicable NFPA codes (as referenced in the Branch Technical Position CMEB 9.5-1) were utilized to perform a detailed analysis and evaluation of the fire protection program at Braidwood Station.

The fire protection program review included the fire protection design, installation, acceptance testing, periodic surveillance and maintenance in addition to administrative responsibility. Results of the ongoing code review were forwarded to Commonwealth Edison via itemized deficiency reports. Each item was then evaluated in detail and resolved per NFPA requirements or listed in this finalized deviation report. The review included safety and non-safety-related areas of the plant.

Inspection, testing and maintenance surveillance/predefine activities for the fire protection systems are controlled by the Companys Predefine Program, as described by administrative procedure. This program utilizes an electronic predefine database designed to prompt the scheduling and performance of all predefine activities entered into the system.

A 25% extension of the frequency interval specified for the surveillance/predefine activity is permitted to facilitate scheduling of the activity and to provide consideration for unit operating conditions that may not be suitable for conducting the surveillance/predefine activity (e.g. transient conditions or other ongoing surveillance maintenance activities). This 25% extension does not significantly degrade the reliability that results from performing the surveillance/predefine activity at its specified frequency. This is based on the recognition that the most probable result of any particular surveillance/predefine activity being performed is the verification of conformance with the requirements for the surveillance/predefine activity.

The 25% surveillance/predefine activity frequency interval extension is not intended to be used repeatedly merely as an operational convenience to extend surveillance/predefine activity frequency intervals.

In conclusion, significant progress has been made to identify and resolve noted deficiencies and to assure that the Braidwood fire protection design, installation, and testing program satisfies the guidance of NFPA.

3.9-2

BRAIDWOOD-1 AMENDMENT 28 DECEMBER 2018 The following NFPA codes were utilized in the Braidwood Station review:

NFPA 4 - 1977 (Organization of Fire Services) and NFPA 4A - 1969 (Fire Department Organization) previously dealt with public or municipal organizations but were withdrawn as NFPA codes and are no longer applicable at the station level.

NFPA 6 - 1974 (Industrial Fire Loss Prevention), NFPA 7 - 1974 (Fire Emergencies Management), and NFPA 8 - 1974 (Management Responsibilities for Effects of Fire on Operations) are no longer NFPA codes but contained useful information on loss prevention organization and responsibility. Guidance from NFPA as well as BTP CMEB 9.5-1 and 10 CFR 50, Appendix R was incorporated into station procedures which clearly define the organization and responsibility of the Braidwood fire protection program.

NFPA 10 - 1984 (Portable Fire Extinguishers)

NFPA 11 - 1983 (Low Expansion Foam and Combined Agent Systems)

NFPA 11A - 1983 (Medium & High Expansion Foam Systems) is not applicable as there are none of these systems at the station.

NFPA 11B (Synthetic Foam & Combined Agent Systems) is no longer a NFPA code and is not applicable as there are none of these systems at the station.

NFPA 12 - 1985 (Carbon Dioxide Extinguishing Systems)

NFPA 12A - 1985 (Halon 1301 Fire Extinguishing Systems)

NFPA 12B - 1985 (Halon 1211 Fire Extinguishing Systems) is not applicable as there are none of these systems at the station.

NFPA 13 - 1985 (Installation of Sprinkler Systems)

NFPA 13A - 1981 (Inspection, Testing and Maintenance of Sprinkler Systems)

NFPA 14 - 1983 (Standpipe and Hose Systems)

NFPA 15 - 1985 (Water Spray Fixed Systems)

NFPA 16 - 1980 (Deluge Foam-Water Sprinkler Systems)

NFPA 20 - 1983 (Centrifugal Fire Pumps) 3.9-3

BRAIDWOOD-1 AMENDMENT 28 DECEMBER 2018 NFPA 24 - 1984 (Private Fire Service Mains and Their Appurtenances)

NFPA 26 - 1983 (Supervision of Valves Controlling Water Supplies)

NFPA 27 - 1981 (Private Fire Brigades)

NFPA 30 - 1984 (Flammable and Combustible Liquids)

NFPA 37 - 1984 (Stationary Combustion Engines and Gas Turbines)

NFPA 50A - 1984 (Gaseous Hydrogen Systems)

NFPA 51B - 1984 (Fire Prevention in Cutting & Welding Processes)

NFPA 69 - 1978 (Explosion Prevention Systems) is not applicable as there are no explosion suppression systems at the station. Guidance for protecting the over pressurization of vessels containing flammable liquids and compressed gases is covered in the NFPA 30, NFPA 37 and NFPA 50A code reviews.

NFPA 70 - 1984 (National Electrical Code) specifically excludes electric utility generation facilities. However, specific references from the BTP CMEB 9.5-1 regarding indoor transformers and proprietary signaling systems were reviewed. There are no combustible fluid transformers located indoors. The proprietary signaling system is covered in the NFPA 72D review.

NFPA 72D - 1979 (Proprietary Signaling Systems)

NFPA 72E - 1984 (Automatic Fire Detectors)

NFPA 80 - 1983 (Fire Doors and Windows)

NFPA 90A - 1985 (Air Conditioning and Ventilating Systems)

NFPA 92M - 1972 (Waterproofing and Draining of Floors) is no longer a NFPA code.

Guidance for waterproofing and drainage was incorporated from applicable NFPA codes.

NFPA 197 - 1966 (Training Standard on Initial Fire Attack) has been renumbered NFPA 1410 and deals with public fire departments and pumper companies and is not applicable at the station level.

NFPA 204M - 1985 (Smoke & Heat Venting)

NFPA 220 - 1985 (Types of Building Construction) is incorporated into the Byron/Braidwood Fire Protection Report building descriptions.

3.9-4

BRAIDWOOD-1 AMENDMENT 28 DECEMBER 2018 NFPA 231C - 1980 (Rack Storage of Materials)

NFPA 232 - 1980 (Protection of Records)

NFPA 232AM - 1980 (Fire Protection for Archives and Record Centers)

NFPA 251 - 1985 (Fire Tests of Building Construction and Materials) is incorporated into the Byron/Braidwood Fire Protection Report description of materials.

NFPA 259 - 1982 (Test Method for Potential Heat of Building Materials) is included in the Byron/Braidwood Fire Protection Report combustible loadings and heat release values.

NFPA 1962 - 1979 (Care, Use and Maintenance of Fire Hose)

NFPA 802 - 1983 (Fire Protection for Nuclear Research Reactors) does not apply to commercial facilities. Guidance for fire protection was incorporated from NRC regulations and NFPA.

3.9-5

BRAIDWOOD-1 AMENDMENT 20 DECEMBER 2002 Table 3-1 NFPA CODE DEVIATION REPORT NFPA 10 - 1984, "Standard for Portable Fire Extinguishers" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 10, para. 4-4.3, Each extinguisher Permanently mounted fire extinguishers Completed surveillance procedure records that shall have a tag or label securely attached located in the Containment Building do contain this information are maintained. This that indicates the month and year the not have tags or labels securely practice is considered equivalent. Paper tags maintenance was performed and shall attached. are not provided in the Containment Building identify the person performing the service. due to sump blockage concerns.

2 NFPA 10, para. 4.3.1, Fire extinguishers Portable handheld extinguishers are Historical review indicates a failure rate of <1%.

shall be inspected when initially placed in inspected at approximately a 90-day Administrative procedure allows extension of service and thereafter at approximately 30- frequency based on historical review of interval for inspection if failure rate is <1%.

day intervals. failure rate.

Hand portable extinguishers inside During at power conditions, access to containment during at power conditions containment is controlled administratively to are inspected during planned refuel prevent unauthorized Entry. The risk that fire outages. extinguishers located in containment will be tampered with is very small. Inspections and maintenance or replacement of fire extinguishers in containment is performed during planned refuel outages.

3 NFPA 10, para. 4.4.1, Extinguishers shall be Compliance will be met for all hand During at power conditions, access to subjected to maintenance not more than a portable extinguishers except for those containment is controlled administratively to year apart located inside containment during at prevent unauthorized Entry. The risk that fire power conditions. These extinguishers extinguishers located in containment will be are subjected to maintenance during tampered with is very small. Maintenance or planned refuel outages. replacement of fire extinguishers in containment is performed during planned refuel outages.

3.9-6

BRAIDWOOD-1 AMENDMENT 20 DECEMBER 2002 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 10 - 1984, "Standard for Portable Fire Extinguishers" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 4 NFPA 10, para. 4-3.1, Extinguishers shall Wheeled portable extinguishers are Historical review indicates a failure rate of < 1%.

be inspected monthly, or at more frequent inspected at quarterly frequency based Administrative procedure allows extension of intervals when circumstances require. on historical review of failure rate. frequency interval for inspection if the failure rate is < 1%.

5 NFPA 10, para. 4-3.1, Extinguishers shall CO2 portable extinguishers are Historical review indicates a failure rate of < 1%.

be inspected monthly, or at more frequent inspected at annual frequency based on Administrative procedure allows extension of intervals when circumstances require. historical review of failure rate. frequency interval for inspection if the failure rate is < 1%.

6 NFPA 10, para. 4-3.1, Extinguishers shall AFFF Wheeled portable extinguishers Historical review indicates a failure rate of < 1%.

be inspected monthly, or at more frequent are inspected at annual frequency Administrative procedure allows extension of intervals when circumstances require. based on historical review of failure rate. frequency interval for inspection if the failure rate is < 1%.

3.9-7

BRAIDWOOD-1 AMENDMENT 25 DECEMBER 2012 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 11 - 1983, "Standard for Low Expansion Foam and Combined Agent Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 11, para. 5-4, Operating and Data will be maintained on file only All pertinent data is maintained on permanent maintenance instructions shall be posted at file. Therefore, it is not necessary to post all the control equipment with a second copy information at the equipment.

maintained on file.

3.9-8

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 12 - 1985, "Standard on Carbon Dioxide Extinguishing Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 12, para. 1-8.3.8, The source of fuel The fuel supply to the diesel generators The continued operation of this equipment may shall be automatically shut off. and auxiliary diesel feedwater pump do be necessary for operating safety-related not shut off automatically upon system equipment. No action necessary.

actuation.

2 NFPA 12, para. 1-11.2, At least annually, all The systems are surveilled on a 3 year System demonstration procedure was reviewed; carbon dioxide systems shall be thoroughly frequency with the exception of the SEE EC 394429 for justification.

inspected and tested for proper operation by upper cable spreading Room CO2 competent personnel. System which is still at 18 months.

3 NPFA 12, para. 2-4.1, after the design The Upper Cable Spreading room System is administratively operated to perform concentration is reached, the concentration manual systems are not designed to an additional manual actuation after 10 minutes, shall be maintained for a substantial period maintain a single actuation, 20 minute to provide a hold time equal to 20 minutes.

of time, but not less than 20 minutes. hold time. (M)MPC Letter dated Oct. 3, 1984).

3.9-9

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 12 - 1985, "Standard on Carbon Dioxide Extinguishing Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 4 NFPA 12, para. 1-6.1.1, Appropriate Signage in areas that are protected by Braidwood Station is in compliance with the warning signs shall be affixed outside of carbon dioxide gas are in accordance intent of para. 1-6.1.1 of the 1985 Edition of those spaces where concentrations of with the 2005 edition of NFPA 12, para. NFPA 12. Para. 4.3.2 of the 2005 Edition of carbon dioxide gas can accumulate, not 4.3.2. NFPA 12 further enhances the wording in signs only in protected spaced but in the adjacent used, as well as incorporates universal safety areas where the carbon dioxide could symbols to further improve personnel safety.

migrate. Typical signs are shown below:

Typical sign in protected space:

WARNING CARBON DIOXIDE GAS WHEN ALARM OPERATES VACATE IMMEDIATELY Typical sign at entrance to protected space:

WARNING CARBON DIOXIDE GAS WHEN ALARM OPERATES DO NOT ENTER UNTIL VENTED Typical sign in nearby space:

CAUTION CARBON DIOXIDE DISCHARGE INTO A NEARBY SPACE MAY COLLECT HERE WHEN ALARM OPERATES VACATE IMMEDIATELY 3.9-10

BRAIDWOOD-1 AMENDMENT 28 DECEMBER 2018 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 12A - 1985 "Standard on Halon 1301 Fire Extinguishing Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 12A, Section 1-9.4.5, Container Test. Halon cylinder testing is performed per This deviation identified that halon cylinder Section 4-2 of the 1997 Edition of NFPA testing is performed per a more recent edition of 12A, and not per the 1985 Edition of this the code. Testing does not deviate from the standard. requirements of Section 4-2 of NFPA 12A, 1997 Edition.

2 NFPA 12A, para. 1-11.1.1, at least annually, The halon systems for the upper cable Performance-based review of system testing, in all systems shall be thoroughly inspected spreading rooms and QA Vault are accordance with Station-Approved procedures, and tested for proper operation by functionally tested every 3 years. supports this frequency. (Reference EC#

competent personnel. 358660 and 394429) 3 NFPA 12A, PARA. 1-8.2.2, detecting SEE NFPA 72E for deviations. EC 394429 Provides justification equipment shall be installed, tested and maintained in accordance with NFPA 72E, Standards on Automatic Fire Detectors.

4 NFPA 12A, Para. 1-11.1.6, at least UCSR Halon cylinders weight and Performance Base Review of system testing, in semiannually, the agent quantity and pressure check are performed annually. accordance with station approved procedures, pressure of refillable containers shall be supports this frequency. (Reference checked. EC#403823) 3.9-11

BRAIDWOOD-1 AMENDMENT 23 DECEMBER 2008 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 13 - 1985, "Standard for the Installation of Sprinkler Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 13, para. 2-9.2.2, Installed gauges have a limit of 300 psi. Gauges are adequate for expected working The pressure gauges shall have a maximum pressures of 180 psi and are considered limit not less than twice the normal working acceptable.

pressure at the point where installed.

2 NFPA 13, para. 3-14.1.1 The Powell, Anchor- Darling, ITT The valves are designed to ANSI Standards and and 3-14.2, All valves shall be listed. Grinnell and Rockwell-Edwards valves working pressure of 285 psi. Therefore, the are not listed. valves are considered acceptable.

3 NFPA 13, para. 3-15.1.2, Hanger Hanger assemblies in safety-related In the Auxiliary Building, all sprinkler system assemblies shall be listed. areas are not listed. supports are seismically designed by Sargent &

Lundy to ANSI B31.1 and are acceptable.

4 NFPA 13, para. 2-7.1, A fire department A fire department pumper connection is The only source of water is the cooling lake, connection shall be provided. not provided. therefore, a pumper connection would be of no value without a municipal supply.

5 NFPA 13, Chapter 4. Spacing, locations and Deviating locations and positions of Field changes made to eliminate obstructions position of sprinklers shall be made in sprinklers were identified. where practical. Other partial obstructions are accordance with NFPA. protected by adjacent sprinklers which provide overlapping coverage for the area. Obstructions to the foam sprinkler heads located in the Diesel Fuel Oil Storage Tank Rooms have been evaluated under GL 86-10 evaluation, EC#

391656 and found to be acceptable.

3.9-12

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 13 - 1985, "Standard for the Installation of Sprinkler Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 6 NFPA 13, para. 7-1.2, The installer shall Signs or placards are not provided for The placards have been provided for the identify a hydraulically designed system by hydraulically designed systems. hydraulically designed systems.

an attached placard.

7 NFPA 13, para. 3-11.2.5, Each interior Drains are not provided at each Drainage provisions are made throughout the sectional valve shall be provided with a sectional valve. piping system at locations other than at each sectional drain valve. sectional valve. This arrangement is adequate to drain all portions of the system(s).

8 NFPA 13, para. 3-10.3.4, Some portions of the piping pass Sargent & Lundy has designed anchor points on Clearance shall be provided around all through walls and floors without the fire protection piping, therefore, clearances piping extending through walls and floors. clearance. are not provided as it would affect the structural design.

9 NFPA 13A, para. 4-4.1, Gauges are checked quarterly and With periodic alarm tests, inspector's test, drain Gauges should be checked monthly on semi-annually. test, valve position surveillance, system sprinkler systems and weekly on deluge operability will be monitored. Quarterly gauge systems. checks are considered more than adequate.

10 NFPA 13A, para. 4-4.2, No procedure for 5-year check. Gauges will be observed quarterly on drain Gauges should be checked with an tests. Any unusual conditions will be resolved, inspector's gauge every 5 years. including gauge off scale. This will satisfy a separate gauge check every 5 years and is considered acceptable.

3.9-13

BRAIDWOOD-1 AMENDMENT 28 DECEMBER 2018 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 13 - 1985, "Standard for the Installation of Sprinkler Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 11 NFPA 13-2002 Edition, para. 7.3.2.3.1, pre- The Containment Access Facility (CAF) This deviation is considered acceptable based action sprinkler piping shall be automatically pre-action sprinkler piping is not upon the justification provided in EC 355868.

supervised where there are more than 20 automatically supervised and has more sprinklers on the system. than 20 sprinklers.

12 NFPA 13, para. 4-4.8.2.3 Shall be placed 6 AUX Building stairwell sprinklers near This deviation is considered acceptable based to 12 in. from the draft stop on the side P/18 has sprinklers located closer than upon the justification provided in EC 399104.

away from the opening to form a water 6 inches.

curtain.

13 N/A The deluge systems piping for Main The deluge systems piping for Main Power Power Transformers 1E and 1W are Transformers 1E and 1W are redesigned designed in accordance with applicable (Reference EC 379761). It is acceptable to sections of NFPA 13-2013. design the new systems to the code year (2013) that was current at the time of design.

3.9-14

BRAIDWOOD-1 AMENDMENT 22 DECEMBER 2006 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 13A - 1981, Inspection, Testing and Maintenance of Sprinkler Systems ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 13A, para. 2-7.1.4, All control valves The sprinkler system alarm shutoff Historical review indicates a failure rate of < 1%.

of the sprinkler system should be inspected valves position verification is performed Administrative procedure allows extension of at regular intervals at quarterly frequency based on frequency interval for inspection if the failure Sealed valves -weekly historical review of failure rate. rate is < 1%.

Locked valves and valves with tamper switches - monthly 2 NFPA 13A, para. 2-7.1.4, All control valves The automatic deluge system trim Historical review indicates a failure rate of < 1%.

of the sprinkler system should be inspected valves position verification is performed Administrative procedure allows extension of at regular intervals at quarterly frequency based on frequency interval for inspection if the failure Sealed valves -weekly historical review of failure rate. rate is < 1%.

Locked valves and valves with tamper switches - monthly 3 NFPA 13A, para. 4-7.1, Test alarms The automatic deluge (Turbine Bearing) Historical review indicates a failure rate of < 1%.

quarterly by opening the inspectors test system alarm test is performed at Administrative procedure allows extension of connections. semiannual frequency based on frequency interval for inspection if the failure historical review of failure rate. rate is < 1%.

4 NFPA 13A, para. 4-5.3, Water flow alarm The automatic deluge (Turbine Bearing) Historical review indicates a failure rate of < 1%.

devices should be tested at least quarterly, system alarm test is performed at Administrative procedure allows extension of weather permitting. semiannual frequency based on frequency interval for inspection if the failure historical review of failure rate. rate is < 1%.

3.9-15

BRAIDWOOD-1 AMENDMENT 22 DECEMBER 2006 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 13A - 1981, Inspection, Testing and Maintenance of Sprinkler Systems ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 5 NFPA 13A, para. 2-6.1, Main drain valves Main drain valve water flow tests are not See EC 357163 for justification.

water flow tests should be made quarterly performed.

from water supply test pipes.

6 NFPA 13A, para. 2.5-1, Private hydrants Private hydrants are inspected annually. Private hydrants are inspected annually to should be inspected monthly to verify that NFPA 25 inspection, test, and maintenance they are visible and readily accessible with requirements.

caps in place.

3.9-16

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 14 - 1983, "Standard for the Installation of Standpipe and Hose Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 14, para. 3-2.2, All portions of the steam tunnel do not The present arrangement and proposed All portions of each story of a building shall meet this requirement. resolution is acceptable per NRR site audit of 8-be within 30 ft of a nozzle when attached to 18-86.

not more than 100 ft of hose.

2 NFPA 14, para. 4-2.1 & 4-4.2, Valves at the Anchor-Darling, Conval, Anderson The valves are designed per ANSI Standards main riser, including hose valves, shall be Greenwood, Powell and ITT Grinnell and a working pressure of 285 psi. Therefore, approved. valves are not listed. the valves are considered acceptable.

3 NFPA 14, para. 4-7.1, Where pressure at Pressure reducing devices are not Fire brigade members have been trained for any hose outlet exceeds 100 psi, an installed for hose stations. hose pressure in excess of 150 psi. This will approved device shall be installed to reduce satisfy the omission of pressure reducing the pressure to 100 psi. devices.

4 NFPA 14, para. 5-2.3 A water supply is not available at the The hose stations at the River Screenhouse At least one water supply shall be automatic River Screenhouse. have been removed. The water supply from the and capable of supplying the streams first Circulating Water Make-up Pumps is insufficient operated until secondary sources can be to support the proper operation of the hose brought into action. stations. The local fire department provides water suppression capability. This is considered acceptable.

5 NFPA 14, para. 3-3.1 Standpipes are located throughout the In order to provide adequate distribution of hose Standpipes shall be located in fire rated stair plant. stations throughout the facility, it is not possible enclosures. to enclose the entire standpipe system.

Sectionalizing valves are provided to isolate a minimum number of hose stations if necessary.

This design is considered acceptable.

3.9-17

BRAIDWOOD-1 AMENDMENT 23 DECEMBER 2008 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 14 - 1983, "Standard for the Installation of Standpipe and Hose Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 6 NFPA 14, para. 7-6.1.1, Pipe hangers in safety-related areas are In containment, Auxiliary Building and Fuel Pipe hangers shall be approved. not listed. Handling the piping supports are seismically designed by Sargent & Lundy in accordance with ANSI B31.1. Therefore, the hanger design is considered acceptable.

7 NFPA 14-1983, para. 4-4.3.1, Listed fire Hard rubber hose is used for the cable Hard rubber hose is used on these hose hose shall be used. spreading room area and electric cable stations for maneuverability in the cable areas.

tunnels. The hose may not be listed by The hose is hydrostatically tested and surveilled UL or approved by Factory Mutual (FM). to the same standards regardless of listing or The listing or approval is dependent on approval status.

availability of listing or approval from the applicable authority at the time of procurement.

8 NFPA 14-1983, para. 4-4.3.2 & 4.3.3, Each U.L. listed replacement hose reels are Fire hose is used by trained fire brigade station provided with a 1.5-inch hose shall no longer available. These reels will be personnel only. Non-listed hose reels do not be equipped with a listed rack and affixed replaced with similar non-listed hose affect the firefighting performance of the hose with a label, "Fire hose for use by reels, as needed. station. Other than red color-coded piping, no occupants." other labels are required.

3.9-18

BRAIDWOOD-1 AMENDMENT 27 DECEMBER 2016 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 15 - 1985, "Standard for Water Spray Fixed Systems for Fire Protection" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 15, para. 2-6, Hangers are not listed in safety-related Hanger supports in Containment, Auxiliary Hangers shall be approved. areas. Building and Fuel Handling Building are seismically designed by Sargent & Lundy to ANSI B31.1 and are considered acceptable.

2 NFPA 15, para 2-7, The Anchor-Darling, Target Rock The valves are designed to ANSI Standards and All valves shall be approved. solenoid, Rockwell Edwards, and ITT a working pressure of 285 psi and are Grinnell valves on the charcoal filters considered acceptable.

units are not listed.

3 NFPA 15, para. 2-1.2, The Namco Controls and Micro Switch The Namco switch is manufactured for nuclear Only listed devices shall be employed. Co. valve position limit switches on the environments and the Micro switch device has a charcoal filters are not listed. U.L. electrical listing. The switches are utilized for special applications and will be tested periodically and are acceptable as is.

4 NFPA 15, para. 2-1.2, The Spraying Systems Co. nozzles on The unique configuration of each charcoal filter Only listed devices shall be employed. the charcoal filters are not listed. requires a specialized nozzle for adequate water spray application. There are no listed nozzles available for this purpose. The existing equipment is acceptable.

3.9-19

BRAIDWOOD-1 AMENDMENT 27 DECEMBER 2016 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 15 - 1985, "Standard for Water Spray Fixed Systems for Fire Protection" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 5 NFPA 15, para. 2-8.4, Automatic detection The following charcoal filters utilize The United Electric devices are U.L. listed for equipment shall be listed. United Electric or Conax heat detection hazardous atmospheres and the Conax RTD devices that are not specifically listed for thermocouples are industrial grade heat sensing fire protection service: Braidwood devices. The detectors are an acceptable charcoal filters 1VP05FA & FB have design for alarm purposes since the water spray been removed per EC 401148 and systems are actuated manually.

2VP05FA & FB have been removed per EC 401150, 0VF05FA & FB, 0VC06FA

& FB, OVF04F, 1VQ09F, 2VQ09F, 00G04F & 5F, 0VW012F/18F, and 0VV21F & 22F. The United Electric devices are U.L. listed for hazardous atmospheres and the Conax RTD thermocouples are industrial grade heat sensing devices. The detectors are an acceptable design for alarm purposes since the water spray systems are actuated manually.

6 NFPA 15, para. 4-6.2, Adequate provisions Charcoal filter drains not sized for Administrative procedures have been written to shall be made to promptly and effectively largest possible water flow. address potential overflow. This is acceptable.

dispose of all liquids from the fire area during operation of all systems in the fire area.

7 NFPA 15, para. 6-2.7, Main Drain flow tests Main drain valve water flow tests are not See EC-EVAL 357163 for justification.

shall be made after valves are reopened performed.

(See NFPA 13A, Recommended Practice for the Inspection, Testing and maintenance of Sprinkler System.)

3.9-20

BRAIDWOOD-1 AMENDMENT 23 DECEMBER 2008 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 16 - 1980, "Standard for the Installation of Deluge Foam-Water Sprinkler Systems and Foam-Water Spray Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 16, para. 2-1, The ASCO "Redhat" solenoid valve and A listed solenoid valve is not available for this All component parts shall be listed. Rockwood model A-20 pneumatic installation. Upon testing completion, the actuator are not listed. equipment should be acceptable.

3.9-21

BRAIDWOOD-1 AMENDMENT 13 DECEMBER 1990 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 20 - 1983, "Standard for the Installation of Centrifugal Fire Pumps" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 20, paras. 2-7.6 and 8 3.1, The floor The diesel fire pump room floor is The entire room is designated as a curbed area shall be pitched for adequate drainage of pitched towards a floor drain that inside the Lake Screen House. This is escaping water or fuel away from the pump, contains a sleeved pipe with an opening considered adequate.

driver, controller, fuel tank, etc. The pump 4" above the floor.

room shall be provided with a floor drain.

2 NFPA 20, para. 2-10.5, Listed valves shall Powell gate valves are not listed. The Powell valves are designed to ANSI be installed on the system side of the check Standards and working pressure of 285 psi and valve. are considered acceptable.

3 NFPA 20, para. 2-13.3.1, Vogt gate valves are not listed (test The Vogt test header valves are designed to Hose valves shall be listed. header). ANSI Standards and working pressure of 740 psi and are considered acceptable.

4 NFPA 20, para. 2-13.3,1, A 10" pipe is installed. The 10" test header pipe provides adequate Test header pipe shall be 12". flow as recorded on all previous fire pump tests.

Therefore, the 10" line is acceptable.

5 NFPA 20, para. 6-3.1.1, Some conductors are not in concrete All conductors are in heavy steel conduit that Fire pump feeder conductors inside (elec. pump). will provide fire resistance and the cable routing buildings shall be enclosed by 2" of is acceptable.

concrete or equivalent 1-hour fire resistance.

6 NFPA 20, para. 7-1.1.1, All controllers shall Electric motor controller is not listed. Justification is provided in T. R. Tramm's letter be listed for electric motor driven fire pump of 12 14 83 to H. R. Denton.

service.

3.9-22

BRAIDWOOD-1 AMENDMENT 28 DECEMBER 2018 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 20 - 1983, "Standard for the Installation of Centrifugal Fire Pumps" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 7 NFPA 20, paras. 7-1.1.3, 7 3.7.1, 7-3.8 & 7 All electrical information is not attached Complete electrical information including 3.9, Wiring diagrams, marking of each motor to the controller on the electric motor- diagrams, ratings, and vendor manuals are control device, and instructions shall be driven fire pump. permanently on file at the station. The data are mounted on the controller. retrievable via equipment identification number.

Therefore, all pertinent data are available when required.

8 NFPA 20, para. 7-4.3, Over current device is not located within Over current protection is provided from 4160-V An over current protective device shall be the fire pump controller. switchgear bus 144, cubicle 000 and considered located within the fire pump controller. acceptable.

9 NFPA 20, para. 7-4.6 Line power is monitored on the feeder Loss of power on the 4160-V bus which feeds Alarms shall be provided for (b) loss of line source and there is no phase reversal the fire pump motor is annunciated on control power, and (c) phase reversal. alarm. room panel 1PM07J. Phase reversal is highly improbable and therefore is not alarmed.

10 NFPA 20, para. 7-6.2, An ammeter is attached to the electric For testing, provisions are made to measure An ammeter and voltmeter shall be provided pump controller, but not a voltmeter. volts and amps. This is acceptable for testing on the controller. and surveillance purposes.

11 NFPA 20, para. 8-6.1, Diesel engines are started every 31 The diesel engine fire pump will be started from Engines shall be started no less that once a days. ambient conditions and operated 30 minutes or week and run for no less than 30 minutes to more every 31 days.

attain normal running temperatures.

12 NFPA 20, para. 8-6.2 Oil shall be changed Oil is changed in accordance with the Manufacturers recommendation allows for in accordance with the manufacturers manufacturers recommendations but alternate methods to determine oil change recommendations but not less than exceeds the, not less frequently than intervals established through use of oil analysis.

annually. annually, requirement. Oil analysis performed under PMID 39101-07.

3.9-23

BRAIDWOOD-1 AMENDMENT 23 DECEMBER 2008 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 20 - 1983, "Standard for the Installation of Centrifugal Fire Pumps" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 13 NFPA 20, para. 8-2.7.2, The solenoid valve is not listed. A listed valve is not available in the required The automatic electric solenoid valve in the pressure rating for the diesel engine pump. The cooling water line for the heat exchanger existing valve has tested satisfactory and is shall be listed for fire protection service. considered acceptable.

14 NFPA 20, para. 9-4.2.2, The off and manual positions on the Control rooms alarm response procedure An alarm shall be provided indicating that diesel engine pump are combined with BWAR-O-38-C7 addresses trouble conditions the controller switch has been turned to the other trouble condition alarms. including controller position "off." Since all off or manual position (separate signal). trouble conditions are investigated, a separate signal is not necessary.

15 NFPA 20, para. 2-4, Pumps shall be Nameplate data on electric motor-driven Accurate brake horsepower data are provided provided with an accurate nameplate. pump indicates BHP-3202 on vendor drawings and manual is on file at the station.

16 NFPA 20, para. 11-4.5, When units are to Fire pumps are tested every 31 days. The water- and diesel-driven fire pumps are be tested weekly by manual means, at least operated every 31 days.

one start shall be accomplished by reducing the water pressure.

17 NFPA 20, Para 11-3.1, An annual A functional test is performed at least The testing is performed per BwAP 1110-1, Fire Test of the fire pump assembly (pump, once per 18 months to demonstrate fire Protection Program System Requirements.

driver and controller) shall be performed to pumps ability at minimum, rated and determine its ability to continue to attain peak load conditions.

satisfactory performance at peak loads.

3.9-24

BRAIDWOOD-1 AMENDMENT 23 DECEMBER 2008 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 24 - 1984, "Standard for the Installation of Private Service Mains and Their Appurtenances" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 24, para. 3-1.1, Essential service water valves 0SX172 The SX valves are ASME section III and provide All control valves shall be listed. and 0SX174, and the Powell and a cross-tie to ensure a seismically qualified Anchor-Darling valves are not listed. backup water supply to portions of Category I standpipes in safety-related areas. The Powell and Anchor-Darling valves are designated to ANSI Standards and working pressure of 285 psi. These valves are considered acceptable.

2 NFPA 24, para. 3-2.2, Check valves are not installed at the The valved connections are normally closed A check valve shall be installed in each connections to essential service water with procedures written to monitor potential connection. (SX), makeup demineralized water, and leakage. This is considered acceptable.

the station air compressors.

3 NFPA 24, para. 3-3.1 & 3-1.1, Valve 0FP590 for the Gate House hose Procedures are written to surveil the valve, and Every connection from the fire main to a stations is a non-indicating underground T wrenches are available to operating building shall be provided with a listed valve with roadway box. personnel. This is considered acceptable.

indicating valve, unless a non-indicating Valve 0FP983 for the Unit 2 underground gate valve with roadway box Containment Access Facility is a non-and T-wrench is accepted by the authority indicating underground valve with having jurisdiction. roadway box.

4 NFPA 24, para. 3-3.2, The following valves are less than the The vales are located along blank walls and are Post indicator valves shall be located not 40 ft distance: 0FP579, 0FP591, accessible. This is considered adequate.

less than 40 ft from buildings. 0FP580, 0FP592, 0FP581, 0FP593, 0FP582, 0FP602, 0FP588.

3.9-25

BRAIDWOOD-1 AMENDMENT 23 DECEMBER 2008 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 24 - 1984, "Standard for the Installation of Private Service Mains and Their Appurtenances" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 5 NFPA 24, para. 4-2.3, The following hydrants are less than the The hydrants are located along blank walls and Hydrants shall be at least 40 ft from 40 ft distance: 0FP05S, 0FP23S, can be isolated from the fire main. This is buildings. 0FP070, 0PF24S, 0FP21S. considered acceptable.

6 NFPA 24, para. 8-6.2.10, Insufficient documentation to determine A Technical Staff Surveillance will monitor any Thrust blocks or other suitable means of thrust restraint locations on flanged unusual system leakage. Thrust blocks have restraint shall be provided at fittings for each hydrant connections. been provided as necessary during routine change in direction of a pipeline and at tees, maintenance and hydrant repositioning. The plugs, caps, and bends. present anchoring is considered adequate.

7 NFPA 24, para. 7-2, All ferrous metal pipe Pipe is not lined. Periodic flow tests will monitor the interior shall be lined. condition of the pipe. Hydraulic calculations will also utilize a conservative C factor of 100 to account for extended age. This is adequate in lieu of lining pipe.

8 NFPA 24, para. 4-3.6, To ensure proper Hydrants are tested annually. Hydrants are tested at least once per 12 months functioning, dry barrel hydrants shall be to ensure proper functioning.

tested semiannually.

9 NFPA 24, para. 4-1.1, Hydrants shall have Wall hydrant 1FP01S in the Unit 1 Calculation BRW-05-0099-M has demonstrated not less than a 6 connection with the Containment Access Facility has a 3 that there is sufficient flow to provide two mains. supply connection from the main. effective hose streams from hydrant 1FP01S.

3.9-26

BRAIDWOOD-1 AMENDMENT 25 DECEMBER 2012 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 26 - 1983, "Supervision of Valves Controlling Water Supplies for Fire Protection" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 26, para. 3-1, The locked open valves Locked open valves are inspected every Locked open valves are inspected every 92 should be inspected monthly. 92 days. days to verify the valve is in the correct position.

2 NFPA 26, para. 3-1, A systematic weekly The sprinkler system alarm shutoff Historical review indicates a failure rate of < 1%.

inspection (or monthly in the case of locked valves position verification is performed Administrative procedure allows extension of

- open valves) of each valve should be at quarterly frequency based on frequency interval for inspection if the failure made. historical review of failure rate. rate is < 1%.

3 NFPA 26, para. 3-1, A systematic weekly The automatic deluge system trim Historical review indicates a failure rate of < 1%.

inspection (or monthly in the case of locked valves position verification is performed Administrative procedure allows extension of

- open valves) of each valve should be at quarterly frequency based on frequency interval for inspection if the failure made. historical review of failure rate. rate is < 1%.

3.9-27

BRAIDWOOD-1 AMENDMENT 23 DECEMBER 2008 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 27 - 1981, "Recommendations for Organization, Training and Equipment of Private Fire Brigades" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 27, para. 4-2.1, Classroom training is conducted by The classroom instructors are qualified for the Training should be conducted and training department instructors. subject areas presented. In addition, two state supervised, where possible, by a State certified Fire Service Instructors are involved in Certified Fire Service Instructor. all live fire training and some classroom instruction. The training program is considered acceptable.

2 NFPA 27, para. 4-3, Training sessions are conducted Training sessions conducted quarterly result in Training sessions should be held at least quarterly. a total of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of training per year for each monthly for one hour or more per shift brigade member. This level of training is considered as satisfying NFPA.

3.9-28

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 30 - 1984, "Flammable and Combustible Liquids Code" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 30, para. 2-7.1, All tanks shall be Provide testing documentation for: Tanks were fabricated and tested to industry tested as evidence of an ASME Code 0D003T, 0D012T, 1T001T, 0T001T and standards (API 650, AWWAD100 and Stamp or U.L. label. Tanks not marked 0T002T. Westinghouse Standards). Tanks not labeled.

shall be tested with good engineering N stamp not required.

principles.

2 NFPA 30, para. 2-7.2, When the vertical Provide hydro. test documentation for: Per M&MPC letter dated January 29, 1987, length of fill or vent pipes is such that when 0D003T, 00D01TA, OT001T, 0T002T M&MPC have reviewed the ANSI B31.1 filled with liquid the static head imposed on and OD005T. pneumatic and/or leak rate test data on this the bottom of the tank exceeds 10 psi, the equipment and find the results satisfactory. The tank and piping shall be hydrostatically tanks were tested per Design Specification tested equal to the static head. requirements. The in-service testing has been done by virtue of being in service since 1989.

There have been no leaks identified.

3 NFPA 30, para. 3-7.1, Provide piping hydro. test Per M&MPC letter dated January 29, 1987, NFPA 37, para. 5-7-1, documentation for: 0D003T, 0D012T, M&MPC have reviewed the ANSI B31.1 Unless tested in accordance with ANSI B31, 00D01TA, 1T001T, 1DO11T, 0T001T, pneumatic and/or leak rate test data on this all piping shall be hydrostatically tested to 0T002T, 1D001TA, TC, TB & TD, equipment and find the results satisfactory. The 150% of the maximum system pressure or 1D002TA & TB, 0D006T, 1D010T and in-service testing has been done by virtue of 110% pneumatically, but not less than 5 OD005T. being in service since 1989. There have been psig at the highest point for 10 minutes. no leaks identified.

3.9-29

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 30 - 1984, "Flammable and Combustible Liquids Code" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 4 NFPA 30, para. 2-2.5.4, and NFPA 37, para. Demonstrate the venting capacity is 0D003T and 0D012T are outdoor diesel fuel oil 5-6.1, The total capacity of venting device(s) provided via: storage tanks that are not required for safe shall be in accordance with Table 2-8 (i.e., 6" breather vent on 0D003T, 6" breather shutdown and no safe shutdown components 699, 380 cubic ft per hour (CFH) for vent on 0D012T, 2" breather vent on are located by these tanks. The area is diked.

0D003T, 563,600 CFH for 0D012T, 38,400 00D01TA. This is considered acceptable. The vent line on CFH for 00D01TA). 00D01TA is sized for maximum flow via 2" fill line. In addition, a high level alarm is provided.

This is considered adequate.

3.9-30

BRAIDWOOD-1 AMENDMENT 13 DECEMBER 1990 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 37 - 1984 "Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 37, para. 5-4.2, The following tanks do not have a high An automatic shutoff will not be provided on the Tanks shall be provided with high level level automatic shutoff: safety-related tanks as they may be required for automatic shutoff. 1D002TA & TB and 1D010T. operation.

2 NFPA 37, para. 5-3.7.1, At least 15 inch The following tanks have less than 15 The clearance is sufficient for maintenance and clearance shall be left around the tank. inch clear space: inspection activities.

1D002TA, 1D002TB and 1D010T.

3 NFPA 37, para. 5-5.3 and NFPA 30, para. Overflow lines 1D066AA4, AB4, AC4, In tank rooms 1D001TA, TC, TB, & TD, the 2-4.4.8, Tanks shall be equipped with a and AD4 terminate inside tank rooms: overflow lines terminate to a floor drain which is device or other suitable means to prevent 1D00TA, TC, TB & TD. piped to a fire and oil sump. This is considered overflow into the building. acceptable.

Tank 0D005T has no overflow line.

Tank 0D005T utilizes a sight tube and gauge to Tank 0D006T overflow line terminates observe oil level. This is adequate for filling inside the building. operations.

The overflow line on 0D006T terminates in a sump which can be manually pumped out. This is considered acceptable.

3.9-31

BRAIDWOOD-1 AMENDMENT 23 DECEMBER 2008 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 50A - 1984, "Standard for Gaseous Hydrogen Systems at Consumer Sites" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 50A, para. 4-1.3, The Nelson Electric enclosure at top Per manufacturer, the Class 654 enclosure was Electrical equipment within 15' shall be in rear of the hydrogen control cabinet is not U.L. listed at the time it was purchased and accordance with Article 501 of the National Class I, Division 2, Group B but not U.L. installed. However, the 654 enclosure is now Electric Code for Class I, Division 2 labeled. listed and identical to the installed device.

locations. Therefore, the equipment is acceptable.

3.9-32

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 51B - 1984, "Standard for Fire Prevention In Use of Cutting and Welding Processes ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 51B, para. 3-2.3: Where practicable, In instance where the scope of work and Braidwood is in compliance with NFPA 51B -

all combustibles shall be relocated at least tools used to conduct hot work results in 1984. NFPA generated changes to 51B which 35 ft. (11 mm) horizontally from the work possible slag, sparks, spatter, or similar were incorporated into the 2009 edition of the site. Where relocation is impracticable, mobile sources of ignition further than Standard for Fire Prevention in Use of Cutting combustibles shall be protected with 35 ft., the distance shall be extended to and Welding Processes. NFPA 51B - 2009 flameproofed covers or otherwise shielded encompass the area. The required paragraphs 5.4.2(14) and 5.4.2(15) allow the with metal or fire-resistant guards or distance or area shall be specified and Permit Authorizing Individual(PAI) to extend or curtains. approved on the hot work permit. retract the 35 ft. area surrounding hot work based upon the potential travel distance of In instances where the scope of work mobile ignition sources. Revision 11 or OP-AA-and tools (e.g. shielded metal arc 201-004, Fire Prevention for Hot Work, welding or gas metal arc welding) used incorporates paragraphs 5.4.2(14) and 5.4.2(15) to conduct hot work are known to be of NFPA 51B, 2009 edition at Braidwood Station incapable of generating slag, sparks, spatter, or similar mobile sources of ignition capable of leaving the immediate area of hot work, then the 35 ft. may be reduced to an area that encompasses the sources of ignition and typically not less than 10 ft. The required distance or area shall be specified and approved on the hot work permit.

3.9-33

BRAIDWOOD-1 AMENDMENT 23 DECEMBER 2008 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 72D - 1979, "Standard for the Installation, Maintenance and Use of Proprietary Protective Signaling Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 72D, para. 2-2.2.1(c), Equipment Equipment is designed for a 70% The environment is controlled by the HVAC shall be so designed that it shall be capable relative humidity (fire protection panels). system that contains a humidity controller which of performing its intended function at a maintains a setting of 40% RH + 5% RH and relative humidity of 85 + 5% and an ambient heating controls which maintain a temperature temperature of 90 °F+ 4 °F for a duration of setting of 75 °F + 2 °F. This design is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. considered acceptable for the fire protection panel environment.

2 NFPA 72D, para. 2-4.3(b), The automatic deluge system alarm Historical review indicates a failure rate of < 1%.

Every two months or more frequently, test tests are performed at semiannual Administrative procedure allows extension of shall be performed for all circuit interfaces frequency based on historical review of frequency interval for inspection if the failure and water flow actuated devices. failure rate. rate is < 1%.

3 NFPA 72D, para. 2-4.3(c), Gate valve supervisory switches are Supervised valves are also surveilled monthly.

Gate valve supervisory switches shall be tested annually. Therefore, annual alarm tests should be tested semiannually. acceptable.

4 NFPA 72D, para. 2.6.2.3, The secondary power supply is provided Bus 134/234 is normally fed from Bus 144/244 The secondary (standby) supply shall be from Bus 134/234 in lieu of storage which is supplied from the system auxiliary provided and shall consist of storage batteries or generator. transformer, and it also has a diesel generator batteries with a 24-hour supply, engine backup in case of a loss-of-offsite power. This driven generators or a combination of supply is as reliable as was intended by the engine driven generators and batteries. NFPA code, and is considered to be acceptable.

3.9-34

BRAIDWOOD-1 AMENDMENT 23 DECEMBER 2008 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 72D-1979, "Standard for the Installation, Maintenance and Use of Proprietary Protective Signaling Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 5 NFPA 72D, para. 2-6.2.4, A separate power Trouble signals are fed from the primary Bus 132/232 (ESF Bus) is the primary power supply, independent of the main power source. supply to the proprietary alarm systems. Due to supply shall be provided for the operation of the high reliability of the primary power supply, trouble signals. this is considered to be acceptable.

6 NFPA 72D, para. 3-6.2.2, Signals Common trouble alarm indications are Upon receipt of a trouble alarm, an operator is transmitted shall indicate distinctively the provided. dispatched to the area and fire watch may be particular function (such as valve position, initiated until the trouble is cleared. This is pressure, etc.) of the automatic sprinkler considered acceptable.

system which is abnormal and its restoration to a normal condition.

7 NFPA 72D, para. 4-4.1, Distinctive audible alarm and trouble The Unit 1 and 2 fire alarm panels are not Provide separate, distinctive, audible trouble indications are not provided between adjacent to one another in the Control Room. It and alarm signals at the Control Room Unit 1 & 2 panels. will be obvious to an operator responding to a panels 1PM09J/2PM09J. fire alarm which unit is affected. This is considered acceptable.

8 NFPA 72D, para. 3-5.1.2, Automatic fire Ionization detection systems do not Upon receipt of a trouble alarm, an operator is detectors which have integral trouble have this trouble feature. dispatched to the area and a fire watch may be contacts shall be wired on the initiating initiated until trouble is cleared. This is device circuit so that a trouble condition on considered acceptable.

one detector will not impair the alarm operation from other initiating devices.

3.9-35

BRAIDWOOD-1 AMENDMENT 27 DECEMBER 2016 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 72E - 1984, "Standard on Automatic Fire Detectors" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 72E, para. 2-5.1.1, The following charcoal filters utilize The United Electric devices are U.L. listed for All fire detection devices shall be listed. United Electric or Conax heat detection hazardous atmospheres and the Conax RTD devices that are not specifically listed for thermocouples are industrial grade heat sensing fire protection service: devices. These devices are an acceptable design for alarm purposes since the water spray Braidwood charcoal filters 1VP05FA & systems are actuated manually.

FB have been removed per EC 401148 and 2VP05FA & FB have been removed per EC 401150, 0VC05FA & FB, 0VC06FA & FB, 0VF04F, 1VQ09F, 2VQ09F, 00G04F/5F, 0VV21F & 22F and 0VW12F/18F.

2 NFPA 72E, para. 8-3.2.2, All rate compensation heat detectors SEE EC 394429 for justification.

Test one or more heat detectors are tested every 3 years. Containment semiannually. Test all in five years. Building Detectors are tested every 18 months. EDG Air Duct Detectors are tested every 4 years.

3 NFPA 72E, para. 8-3.3.1, All smoke detectors are tested every 3 SEE EC 394429 for justification.

All smoke detectors shall be tested at least years. Containment Building Detectors semiannually. are tested every 18 months. EDG Air Duct Detectors are tested every 4 years.

4 NFPA 72E, para. 4-3.7.3, If beams exceed Not all bays located at the South end of Detectors are not required in these bays as 18 inches in depth and are more than 8 feet detection zone 2D-75 that meet this determined in EC 353989.

on centers, each bay shall require at least criterion have a detector.

one spot type detector.

3.9-36

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 72E - 1984, "Standard on Automatic Fire Detectors" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 5 NFPA 72E, para. 8-3.3.1, Sensitivity Testing Detector Sensitivity Testing is done SEE EC 394429 for justification shall be performed within 1 year after every 5 years.

installation and every alternate year thereafter.

6 NFPA 72E, para. 8-3.4, All Flame Detectors, UV Detector are tested every 3 years SEE EC 394429 for justification Fire-Gas Detectors and other Fire Detectors shall be tested at least semiannually.

3.9-37

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 80 - 1983, "Standard for Fire Doors and Windows" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 80, para. 1-6.1, The labels for several doors are either A certificate of conformance from the Only labeled or listed doors shall be used. missing, damaged, or illegible. manufacturer is on file stating that the Piano-type hinges are installed the referenced doors were manufactured and length of some doors and the labeling delivered as listed fire doors.

could not be verified.

2 NFPA 80, para. 1-6.1, Several security doors are either The justification for the use of non-labeled doors Only labeled or listed doors shall be used. oversized or provided with a modified of "A construction" is contained on pages 2.1-8 two-point latch and electric strike. The through 2.1-9b of NOTE: Amendment 25 of the doors are not labeled. B/B FPR does not have a page 2.1-9b.

Two doors at EL. 401-0 in the L line (Multiple occurrences) wall are reinforced with steel plates for HELB pressure loading in conjunction The subject doors are addressed in Generic with seismic loading under HELB design Letter 86-10 Evaluation EC-EVAL 393561; this basis analysis. One door also has evaluation determined that the modified doors horizontal stiffeners. The doors are not are adequate for the fire hazards to which they labeled. are exposed and justifies the use of each non-Several doors at EL. 401-0 AND el. labeled door. Refer to EC 392850 and EC 426-0 in the L-line wall are reinforced EVAL 393561 or EC 391762 and EC-EVAL with steel plates for HELB pressure 392603.

loading in conjunction with seismic loading under HELB design basis analysis. The doors are not labeled.

3 NFPA 80, para. 1-6.3, Several oversized doors are not labeled. The justification for the use of non-labeled doors Authorities having jurisdiction shall be of "A construction" is contained on pages 2.1-8 consulted as to the size of oversized doors through 2.1-9b of the Braidwood Fire Protection which may be deemed acceptable in a given Report location.

3.9-38

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 80 - 1983, "Standard for Fire Doors and Windows" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 4 NFPA 80, para. 2-5.1, Labels for several door frames are A certificate of conformance from the Only labeled door frames shall be used. either missing or illegible. manufacturer is on file stating that the referenced frames were manufactured and The doors installed in some frames are delivered as listed frames.

provided with piano-type hinges which run the length of the frame and labeling could not be verified.

5 NFPA 80, para. 2-5.1, Several security doors have been The justification for the use of these frames is Only labeled door frames shall be used. modified with security hardware. provided on pages 2.1-8 through 2.1-9b of the Braidwood Fire Protection Report.

The frames for two doors at EL.401-0 in the L-line wall area reinforced for The subject door frames are addressed in HELB pressure loading in conjunction Generic Letter 86 10 Evaluation EC-EVAL with seismic loading under HELB design 393561; this evaluation determined that the basis analysis. The door frames are not modified doors are adequate for the fire hazards labeled. to which they are exposed and justifies the use of each non-labeled door and frame. Refer to EC 392850 and EC-EVAL 393561 or EC 391762 and EC-EVAL 392603.

6 NFPA 80, para. 2-5.4, The clearance between doors and The clearances may be increased as stated and The clearance between doors and frames frames and the clearance between the justified in EC- EVAL#339805. Clearances that and the clearance between the meeting meeting edges of doors swinging in satisfy the criteria specified in the EC-EVAL edges of doors swinging in pairs shall not pairs may exceed 1/8 inch. represent an acceptable minor deviation from exceed 1/8 inch. NFPA 80 and may be considered operable without additional evaluation or corrective action.

3.9-39

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 80 - 1983, "Standard for Fire Doors and Windows" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 7 NFPA 80, para. 2-5.4, The clearance between the bottom of a The clearances may be increased as stated and The clearance between the bottom of a door door and sill may exceed 3/8 inch. justified in EC-EVAL#339805. Clearances that and sill shall not exceed 3/8 inch. Where Where there is no sill, clearance may satisfy the criteria specified in the EC-EVAL there is no sill, clearance shall not exceed exceed 3/4 inch. represent an acceptable minor deviation from 3/4 inch. NFPA 80 and may be considered operable without additional evaluation or corrective action.

8 NFPA 80, para. 2-8.1.3, Hinges shall be The hinges for two doors at EL. 401-0 Attachment of the subject door hinges is secured to frames with steel screws. Types in the L-line wall area replaced to addressed in Generic Letter 86-10 Evaluation of screws will vary depending on material support steel plates added to reinforce EC EVAL 393561; this evaluative determined used for the manufacture of labeled door the doors for HELB pressure loading in that the modified doors are adequate for the fire frames. Refer to labeled door frame conjunction with seismic loading under hazards to which they are exposed and justifies manufacturers instructions and published HELB design basis analysis. The the use of each non-labeled door and hinge listings for specific screw requirements. replacement hinges are not attached to configuration. Refer to EC 392850 and EC-the door frame; they are welded to a EVAL 393561 or EC 391762 and EC-EVAL short hollow steel section, which is 392603.

welded to a plate that is attached to the concrete wall and/or structural steel.

Attachments to the wall are made with 3/4 concrete expansion anchors. The other hinge leaf is attached to the door with through bolts.

9 NFPA 80, para. 2-8.2.1, Several doors are provided with security The justification for non-labeled hardware for Only labeled locks and latches shall be hardware. security doors is contained on pages 2.1 8 used. through 2.1 9b of the Braidwood Fire Protection Report.

3.9-40

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 80 - 1983, "Standard for Fire Doors and Windows" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 10 NFPA 80, para. 2-8.4.1, These doors are not provided with a The coordinating devices have been installed on Where there is an astragal or projecting coordinating device: SD 172 and SD Doors SD-172 and SD-174 (WO 1382059 & WO latch bolt that prevents the inactive door leaf 174. 1382061).

from closing and latching before the active door closes, a coordinating device shall be used.

11 NFPA 80, para. 2-9, Several doors are provided with Gasketing is installed to assist the HVAC air Gasketing on fire doors or frames shall be gasketing around the frame. flow/pressurization within the plant. The furnished only in accordance with the gasketing does not affect the operability of the published listing of the door frame or door and is considered acceptable.

gasketing material manufacturer.

Exception: Where acceptable to the authority having jurisdiction, gasketing of non-combustible or limited combustible material may be applied to the frame providing closing and latching of the door is not thereby inhibited.

12 NFPA 80, Para 14-2.1.1 Hardware shall be The inspection frequency is extended Performance based review of system testing, in examined frequently, and any parts found to on fire rated doors. accordance with station approved procedures, be inoperative shall be replaced supports frequency extension (EC 403823).

immediately.

3.9-41

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 90A - 1985, "Standard for the Installation of Air Conditioning and Ventilating Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 90A, para. 4-3 Not all duct detectors stop the fan(s). Sargent & Lundy's NFPA 90A compliance (a)&(b), In systems over 2,000 cfm, listed checklist dated 10/9/1986, Rev 1 (HVAC smoke detectors shall be installed and Systems Review in compliance with NFPA 90A) automatically stop the fan(s). identifies detector functions and list specific deviations from the NFPA code including justifications. M&MPC has performed review of the checklist as documented in their letters dated 4/16/1987 and 4/5/1988. The Smoke Removal Plan BwOP FP-27 was revised based on the formal review of the plan per M&MPC letter dated 1/22/1988. The BwOP FP-27 includes related information regarding fan trip with respect to the duct detector and direct fan shutdown to ensure closure of the fire dampers.

2 NFPA 90A, para. 4-5.1, The duct detectors alarm in the main The common fire/trouble alarm in the main 4-5.2, and 4-5.3, control room HVAC panel as common control room also records a printed message Detectors shall be installed in accordance fire or trouble alarms and are not which indicates the local HVAC panel. The local with NFPA 72E and shall sound an alarm in installed on the fire alarm system per HVAC panel indicates separate fire and trouble a normally occupied area or through the NFPA 72E or 72D. alarms. Operating procedures address these building fire alarm system. alarm conditions. This is acceptable for the duct detector alarm system.

3 NFPA 90A, para. 2-4.1, Air filters shall have Effective May 1, 2012 Underwriters Filters are to be Class 1 or 2. After May 1, 2012, a U.L. Class 1 or 2 rating. Laboratory (UL) will no longer classify filters shall comply with NFPA 90A-2012, air filters as Class 1 or Class 2 under Section 4.2.2.2 and comply with ANSI/UL 900 Standard UL 900 Standard for air filters.

3.9-42

BRAIDWOOD-1 AMENDMENT 13 DECEMBER 1990 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 90A - 1985, "Standard for the Installation of Air Conditioning and Ventilating Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 4 NFPA 90A para. 3-3.7.1.6, Fusible links Some fusible links have a temperature The fusible link temperature rating is shall have a temperature rating rating greater than 50°F above the significantly below typical fire temperatures. A approximately 50°F above the maximum normally encountered maximum room Certificate of Conformance was provided by SR temperature that normally is encountered temperature due to abnormal accident Products for the non-UL listed ETLs stating that when the system is in operation or shut conditions associated with a HELB. the ETLs are designed and manufactured with down, but not less than 160°F. the same parts and standards as their UL listed devices. Refer to EC 388397, EC 388398 or EC 392191.

3.9-43

BRAIDWOOD-1 AMENDMENT 13 DECEMBER 1990 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 232 - 1980, "Standard for the Protection of Records" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 232, paras. 2-4 & 2-14.1, The QA vault is approximately 8,450 cu. The QA vault is protected by an automatic A vault shall not exceed 5,000 cu. ft. An ft. and is not equipped with automatic Halon 1301 fire suppression system with a oversize vault not over 25,000 cu. ft may be sprinklers. connected reserve. This is adequate protection used and equipped with automatic sprinkler in lieu of sprinklers.

protection.

2 NFPA 232, para. 2-14.2, Automatic sprinklers are not provided in Smoke detectors associated with the Halon Where mobile shelving is used, smoke the Q.A. vault. 1301 suppression system are provided. This is detectors shall be provided in addition to acceptable.

automatic sprinklers.

3 NFPA 232, para. 2-10.4, A heat or smoke actuated device does The door is normally locked closed and is Doors shall be equipped with an automatic not close the door (QA vault). equipped with an automatic door closure. A closing device and a heat actuated or heat or smoke interlocking device is not smoke actuated release to close them. necessary for this reason.

4 NFPA 232, para. 2-9.2 HVAC supply and exhaust ducts HVAC openings are protected by a series of two Roofs of vaults shall not be pierced for any penetrate roof (QA vault). 1-1/2-hr fire treated dampers that will purpose. automatically close upon fire or actuation of the halon system. This provides a fire barrier for the roof and is acceptable.

5 NFPA 232, para. 2-10.1, A 3-hr U.L. labeled door is installed (QA Based on external fire exposure, the 3-hr door The vault shall be provided with a listed 4-hr vault). provides adequate protection.

door.

3.9-44

BRAIDWOOD-1 AMENDMENT 13 DECEMBER 1990 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 232 - 1980, "Standard for the Protection of Records" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 6 NFPA 232, para. 2-11.2, The lighting switch is inside the vault in Electrics have been installed per the National Lighting shall be vapor proof or explosion addition to a telephone, thermostat, exit Electrical Code and present no inherent hazard.

proof controlled by a switch outside the sign, and a temp/humidity recorded (QA In addition, U.L. listed Class P gasketed light vault. No other electrical devices shall be vault). fixtures are installed with thermal ballast permitted within the vault protection. This is acceptable.

3.9-45

BRAIDWOOD-2 AMENDMENT 13 DECEMBER 1990 Table 3-2 is a listing of NFPA deviations identified for safety-related areas on Braidwood Unit 2. This list indicates deviations which were not identified on the Unit 1 NFPA deviation list.

3.9-46

BRAIDWOOD-2 AMENDMENT 13 DECEMBER 1990 Table 3-2 NFPA CODE DEVIATION REPORT NFPA 12 - 1985, "Standard on Carbon Dioxide Extinguishing Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 12A, para. 2-6.2.2, The agent (halon) Due to the extra quantity of halon added The time to reach initial concentration is not discharge shall be substantially complete in to the original design to maintain the affected and, therefore, a longer discharge a nominal 10 seconds. soaking period, the nominal 10 second period has no impact on the halon suppression discharge is exceeded. capability.

3.9-47

BRAIDWOOD-2 AMENDMENT 26 DECEMBER 2014 Table 3-2 (Contd)

NFPA CODE DEVIATION REPORT NFPA 13 - 1985, "Standard for the Installation of Sprinkler Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 13, para. 3-8.4, Return bends shall Return bends are not provided for The sprinkler systems have been adequately be used when pendent sprinklers are pendent sprinklers. flushed and the plant fire protection water is supplied from a raw water source. strained through a screen prior to its introduction into the system.

2 NFPA 13, para. 4-4.8.2.3, Where sprinklers Cross baffles are not provided on the Each of the sprinklers for these systems is installed to protect floor openings are systems protecting the center stairwell provided with a 5 inch baffle plate, which along located closer than 6 feet apart, cross of the Auxiliary Building. with some minor obstructions from equipment baffles shall be provided. between sprinklers, will adequately prevent prewetting of the sprinklers.

3 NFPA 13-2007 Edition, para. 7.3.2.4.1, pre- The Containment Access Facility (CAF) This deviation is considered acceptable based action sprinkler piping shall be automatically pre-action sprinkler piping is not upon the justification provided in EC 366860.

supervised where there are more than 20 automatically supervised and has more sprinklers on the system. than 20 sprinklers.

4 NFPA 13, Chapter 4. Spacing, locations During the walkdown of the systems, Obstructions to the foam sprinkler heads and position of sprinklers shall be made in deviating locations and positions of located in the Diesel Fuel Oil Storage Tank accordance with NFPA. sprinklers where identified Rooms have been evaluated under GL 86-10 evaluation, EC 380157 and found to be acceptable.

3.9-48

BRAIDWOOD-2 AMENDMENT 18 DECEMBER 1998 Table 3-2 (Contd)

NFPA CODE DEVIATION REPORT NFPA 14 - 1983, "Standard for the Installation of Standpipe and Hose Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 14-1983, para. 4-4.3.1, Listed fire Hard rubber hose is used for the cable Hard rubber hose is utilized on these hose hose shall be used. spreading room areas and electric cable stations for maneuverability in the cable areas.

tunnels. The hose may or may not be The hose is hydrostatically tested and surveilled listed by UL or approved by Factory to the same standards regardless of listing or Mutual (FM). The listing or approval is approval status.

dependent on availability of the listing or approval from the applicable authority at the time of procurement.

3.9-49

BRAIDWOOD-2 AMENDMENT 13 DECEMBER 1990 Table 3-2 (Contd)

NFPA CODE DEVIATION REPORT NFPA 24 - 1984, "Standard for the Installation of Private Service Mains and Their Appurtenances" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 24, para. 8-3.1, Pipe shall not be run The Receiving Building Warehouse and Sargent & Lundy letter of January 26, 1988 (R.

under buildings. Gate House extension were built over Salsbury to J. Robinson) references review the underground fire main. indicating loading to piping from buildings to negligible.

3.9-50

BRAIDWOOD-2 AMENDMENT 13 DECEMBER 1990 Table 3-2 (Contd)

NFPA CODE DEVIATION REPORT NFPA 30 - 1984, "Flammable and Combustible Liquids Code" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 30, para. 2-7.1, All tanks shall be Tank 2T001T is not marked with an The main turbine oil reservoir was designed and tested as evidence of an ASME Code ASME Code Stamp or U.L. label. The constructed to Westinghouse Standards. The Stamp or U.L. label. Tanks not marked tank was not designed to any specific tank and associated piping was leak tested at shall be tested with good engineering code such as API 650 or ASME section normal operating pressure per ANSI Standards.

principles. VIII.

2 NFPA 30, para. 2-7.2, When the vertical The flame arrestor vent lines on the The tanks are provided with overflow lines length of fill or vent pipes is such that when following tanks have large vertical which could prevent a static head increase filled with liquid the static head imposed on lengths and could impose a 10 psi static above 10 psi. Therefore, the tanks are not the bottom of the tank exceeds 10 psi, the head: 2D01TA/TB, 2D002TA/TB, tested to this criteria.

tank and piping shall be hydrostatically 2D010T & 2D011T tested equal to the static head.

3 NFPA 30, para. 3-7, Unless tested in Piping is tested to ANSI Standards Per S&L spec. L-2739, code case N-240 accordance with ANSI B31, all piping shall except open ended piping (e.g., alleviates testing all open ended piping.

be hydrostatically tested to 150% of the overflow, vent lines, etc.) which is not maximum system pressure or 110% tested from the point of the last control pneumatically, but not less than 5 psig at valve to the open end of the pipe.

the highest point for 10 minutes.

4 NFPA 30, para. 2-2.5.4, The total capacity Long lengths of vent piping are S&L has calculated that no additional venting is of normal and emergency venting shall be in prevalent on all tanks. Total venting required due to the lack of heat generated by a accordance with Table 2-8 of NFPA 30 capacity may be hindered by pipe fire in the tank storage areas. (S&L letter of and/or the listed venting requirements. lengths and height. 11/1/84, Leutloff to Smith).

5 NFPA 30, para. 2-2.7.4, The fill pipe The fill lines for tanks OVR11TA/TB During system operation, liquid level will be entering the top of a tank shall terminate terminate approximately 1.5 foot from maintained above the 1.5 foot level, utilizing the within 6 in. of the bottom of the tank. the tank's bottom. low liquid level alarm and administrative controls.

3.9-51

BRAIDWOOD-2 AMENDMENT 13 DECEMBER 1990 Table 3-2 (Contd)

NFPA CODE DEVIATION REPORT NFPA 30 - 1984, "Flammable and Combustible Liquids Code" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 6 NFPA 30-1984, para. 4-4.1.3, Maximum The floor area of the paint and oil room NFPA 30 does not provide requirements for floor area of an inside storage room should is 830 square feet. inside storage rooms with a 3-hour fire be limited to 500 square feet for a 2-hour resistance rating. This room has a 3-hour fire fire resistance rated storage room with an resistance rating and is fully sprinkled.

installed fire protection system.

7 NFPA 30-1984, para. 4-4.1.6, Exhaust and Various exhaust and makeup ventilation NFPA 91, "Standard for the Installation of makeup ventilation inlets shall be located inlets are located in excess of 12 inches Blower and Exhaust Systems for Dust, Stock within 12 inches of the floor from the floor. and Vapor Removal or Conveying," para. 3-2.1, allows for ventilation through a system of suction ducts. This is considered to be acceptable, as the requirements of NFPA 91 are referenced as being applicable.

8 NFPA 30-1984, para. 4-4.1.6, NFPA 91 Fire doors are not provided. UL listed, 3-hour rated fire dampers OVJ11Y 1983 para. 2-7.8, When ducts pass through and OVJ12Y are provided in the wall openings.

a fire wall, they shall be provided with fire These dampers are centered within the doors on both sides of the wall. opening.

9 NFPA 30-1984, para. 4-4.1.6, The No means is provided to indicate failure The dispensing of flammable liquids is mechanical ventilation system for of the ventilation system. administratively controlled and includes dispensing areas shall be equipped with an verification that the ventilation system is airflow switch or other equally reliable operating methods which is interlocked to sound an audible alarm upon failure of the ventilation system 3.9-52

BRAIDWOOD-2 AMENDMENT 13 DECEMBER 1990 Table 3-2 (Contd)

NFPA CODE DEVIATION REPORT NFPA 37 - 1984 "Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 37, para. 5-7.1, Unless tested in Piping is tested to ANSI Standards Per S&L spec. L-2739, code case N-240 accordance with ANSI B31, all piping shall except open ended piping (e.g., alleviates testing all open ended piping be hydrostatically tested to 150% of the overflow, vent lines, etc.) which is not maximum system pressure or 110% tested from the point of the last control pneumatically, but not less than 5 psig at valve to the open end of the pipe.

the highest point for 10 minutes.

2 NFPA 37, para. 5-6.1, The total capacity of Long lengths of vent piping are S&L has calculated that no additional venting is normal and emergency venting shall be in prevalent on all tanks. Total venting required due to the lack of heat generated by a accordance with Table 2-8 of NFPA 30 capacity may be hindered by pipe fire in the tank storage areas. (S&L letter of and/or the listed venting requirements. lengths and height. 11/1/84, Leutloff to smith) 3.9-53

BRAIDWOOD-1 AMENDMENT 28 DECEMBER 2018 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 90A - 1985, "Standard for the Installation of Air Conditioning and Ventilating Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 90A para. 3-3.7.1.6, Fusible links Some fusible links have a temperature The fusible link temperature rating is shall have a temperature rating rating greater than 50°F above the significantly below typical fire temperatures and approximately 50°F above the maximum normally encountered maximum room below ignition temperature of the material on temperature that normally is encountered temperature due to abnormal accident either side of the wall.

when the system is in operation or shut conditions associated with HELB. A Certificate of Conformance was provided by down, but no less than 160°F SR Products for non-UL listed ETLs stating that the ETLs are designed and manufactured with the same parts and standards as their UL listed devices. Refer to EC 388947, 388948, or 392192.

3.9-54

BRAIDWOOD-1 AMENDMENT 28 DECEMBER 2018 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 15 - 1985, "Standard for Water Spray Fixed Systems for Fire Protection" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 5 NFPA 15, para. 2-8.4, Automatic detection The following charcoal filters utilize The United Electric devices are U.L. listed for equipment shall be listed. United Electric or Conax heat detection hazardous atmospheres and the Conax RTD devices that are not specifically listed for thermocouples are industrial grade heat sensing fire protection service: Braidwood devices. The detectors are an acceptable charcoal filters 1VP05FA & FB have design for alarm purposes since the water spray been removed per EC 401148 and systems are actuated manually.

2VP05FA & FB have been removed per EC 401150, 0VF05FA & FB, 0VC06FA

& FB, OVF04F, 1VQ09F, 2VQ09F, 00G04F & 5F, 0VW012F/18F, and 0VV21F & 22F. The United Electric devices are U.L. listed for hazardous atmospheres and the Conax RTD thermocouples are industrial grade heat sensing devices. The detectors are an acceptable design for alarm purposes since the water spray systems are actuated manually.

6 NFPA 15, para. 4-6.2, Adequate provisions Charcoal filter drains not sized for Administrative procedures have been written to shall be made to promptly and effectively largest possible water flow. address potential overflow. This is acceptable.

dispose of all liquids from the fire area during operation of all systems in the fire area.

3.9-55

BRAIDWOOD-1 AMENDMENT 28 DECEMBER 2018 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 15 - 1985, "Standard for Water Spray Fixed Systems for Fire Protection" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 7 NFPA 15, para. 6-2.7, Main Drain flow tests Main drain valve water flow tests are not See EC-EVAL 357163 for justification.

shall be made after valves are reopened performed.

(See NFPA 13A, Recommended Practice for the Inspection, Testing and maintenance of Sprinkler System.)

8 N/A The deluge systems piping for Main The deluge systems piping for Main Power Power transformers 1E and 1W are Transformers 1E and 1W are redesigned designed in accordance with applicable (Reference EC #379761). It is acceptable to sections of NFPA 15-2012. design the new systems to the code year (2012) that was current at the time of design.

3.9-56

BRAIDWOOD-1 AMENDMENT 23 DECEMBER 2008 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 16 - 1980, "Standard for the Installation of Deluge Foam-Water Sprinkler Systems and Foam-Water Spray Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 16, para. 2-1, The ASCO "Redhat" solenoid valve and A listed solenoid valve is not available for this All component parts shall be listed. Rockwood model A-20 pneumatic installation. Upon testing completion, the actuator are not listed. equipment should be acceptable.

3.9-57

BRAIDWOOD-1 AMENDMENT 13 DECEMBER 1990 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 20 - 1983, "Standard for the Installation of Centrifugal Fire Pumps" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 20, paras. 2-7.6 and 8 3.1, The floor The diesel fire pump room floor is The entire room is designated as a curbed area shall be pitched for adequate drainage of pitched towards a floor drain that inside the Lake Screen House. This is escaping water or fuel away from the pump, contains a sleeved pipe with an opening considered adequate.

driver, controller, fuel tank, etc. The pump 4" above the floor.

room shall be provided with a floor drain.

2 NFPA 20, para. 2-10.5, Listed valves shall Powell gate valves are not listed. The Powell valves are designed to ANSI be installed on the system side of the check Standards and working pressure of 285 psi and valve. are considered acceptable.

3 NFPA 20, para. 2-13.3.1, Vogt gate valves are not listed (test The Vogt test header valves are designed to Hose valves shall be listed. header). ANSI Standards and working pressure of 740 psi and are considered acceptable.

4 NFPA 20, para. 2-13.3,1, A 10" pipe is installed. The 10" test header pipe provides adequate Test header pipe shall be 12". flow as recorded on all previous fire pump tests.

Therefore, the 10" line is acceptable.

5 NFPA 20, para. 6-3.1.1, Some conductors are not in concrete All conductors are in heavy steel conduit that Fire pump feeder conductors inside (elec. pump). will provide fire resistance and the cable routing buildings shall be enclosed by 2" of is acceptable.

concrete or equivalent 1-hour fire resistance.

6 NFPA 20, para. 7-1.1.1, All controllers shall Electric motor controller is not listed. Justification is provided in T. R. Tramm's letter be listed for electric motor driven fire pump of 12 14 83 to H. R. Denton.

service.

3.9-58

BRAIDWOOD-1 AMENDMENT 28 DECEMBER 2018 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 20 - 1983, "Standard for the Installation of Centrifugal Fire Pumps" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 7 NFPA 20, paras. 7-1.1.3, 7 3.7.1, 7-3.8 & 7 All electrical information is not attached Complete electrical information including 3.9, Wiring diagrams, marking of each motor to the controller on the electric motor- diagrams, ratings, and vendor manuals are control device, and instructions shall be driven fire pump. permanently on file at the station. The data are mounted on the controller. retrievable via equipment identification number.

Therefore, all pertinent data are available when required.

8 NFPA 20, para. 7-4.3, Over current device is not located within Over current protection is provided from 4160-V An over current protective device shall be the fire pump controller. switchgear bus 144, cubicle 000 and considered located within the fire pump controller. acceptable.

9 NFPA 20, para. 7-4.6 Line power is monitored on the feeder Loss of power on the 4160-V bus which feeds Alarms shall be provided for (b) loss of line source and there is no phase reversal the fire pump motor is annunciated on control power, and (c) phase reversal. alarm. room panel 1PM07J. Phase reversal is highly improbable and therefore is not alarmed.

10 NFPA 20, para. 7-6.2, An ammeter is attached to the electric For testing, provisions are made to measure An ammeter and voltmeter shall be provided pump controller, but not a voltmeter. volts and amps. This is acceptable for testing on the controller. and surveillance purposes.

10a NFPA 20. Para. 8-6.1, Engines shall be Diesel engines are started every 31 The diesel engine fire pump will be started from started no less than once a week and run days. ambient conditions and operated 30 minutes or for no less than 30 minutes to attain normal more every 31 days.

running temperatures.

3.9-59

BRAIDWOOD-1 AMENDMENT 28 DECEMBER 2018 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT 10b NFPA 20, para. 8-6.2, Engine Maintenance. Oil is changed in accordance with the Manufacturer recommendation allows for an Engines shall be kept clean, dry, and well manufacturers recommendations but alternate method to determine oil change lubricated. The proper oil level shall be exceed the, not less frequently than intervals established through the use of maintained in the crankcase. Oil shall be annually, requirement. Lubrication Oil Analysis. Oil Analysis is changed in accordance with the performed under PMID 39101-07 for the diesel manufacturers recommendations, but not engine fire pump.

less frequently than annually.

11 NFPA 20, para. 8-6.1, Diesel engines are started every 31 The diesel engine fire pump will be started from Engines shall be started no less that once a days. ambient conditions and operated 30 minutes or week and run for no less than 30 minutes to more every 31 days.

attain normal running temperatures.

3.9-60

BRAIDWOOD-1 AMENDMENT 23 DECEMBER 2008 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 20 - 1983, "Standard for the Installation of Centrifugal Fire Pumps" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 12 NFPA 20, para. 8-2.7.2, The solenoid valve is not listed. A listed valve is not available in the required The automatic electric solenoid valve in the pressure rating for the diesel engine pump. The cooling water line for the heat exchanger existing valve has tested satisfactory and is shall be listed for fire protection service. considered acceptable.

13 NFPA 20, para. 9-4.2.2, The off and manual positions on the Control rooms alarm response procedure An alarm shall be provided indicating that diesel engine pump are combined with BWAR-O-38-C7 addresses trouble conditions the controller switch has been turned to the other trouble condition alarms. including controller position "off." Since all off or manual position (separate signal). trouble conditions are investigated, a separate signal is not necessary.

14 NFPA 20, para. 2-4, Pumps shall be Nameplate data on electric motor-driven Accurate brake horsepower data are provided provided with an accurate nameplate. pump indicates BHP-3202 on vendor drawings and manual is on file at the station.

15 NFPA 20, para. 11-4.5, When units are to Fire pumps are tested every 31 days. The water- and diesel-driven fire pumps are be tested weekly by manual means, at least operated every 31 days.

one start shall be accomplished by reducing the water pressure.

16 NFPA 20, Para 11-3.1, An annual A functional test is performed at least The testing is performed per BwAP 1110-1, Fire Test of the fire pump assembly (pump, once per 18 months to demonstrate fire Protection Program System Requirements.

driver and controller) shall be performed to pumps ability at minimum, rated and determine its ability to continue to attain peak load conditions.

satisfactory performance at peak loads.

3.9-61

BRAIDWOOD-1 AMENDMENT 23 DECEMBER 2008 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 24 - 1984, "Standard for the Installation of Private Service Mains and Their Appurtenances" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 24, para. 3-1.1, Essential service water valves 0SX172 The SX valves are ASME section III and provide All control valves shall be listed. and 0SX174, and the Powell and a cross-tie to ensure a seismically qualified Anchor-Darling valves are not listed. backup water supply to portions of Category I standpipes in safety-related areas. The Powell and Anchor-Darling valves are designated to ANSI Standards and working pressure of 285 psi. These valves are considered acceptable.

2 NFPA 24, para. 3-2.2, Check valves are not installed at the The valved connections are normally closed A check valve shall be installed in each connections to essential service water with procedures written to monitor potential connection. (SX), makeup demineralized water, and leakage. This is considered acceptable.

the station air compressors.

3 NFPA 24, para. 3-3.1 & 3-1.1, Valve 0FP590 for the Gate House hose Procedures are written to surveil the valve, and Every connection from the fire main to a stations is a non-indicating underground T wrenches are available to operating building shall be provided with a listed valve with roadway box. personnel. This is considered acceptable.

indicating valve, unless a non-indicating Valve 0FP983 for the Unit 2 underground gate valve with roadway box Containment Access Facility is a non-and T-wrench is accepted by the authority indicating underground valve with having jurisdiction. roadway box.

4 NFPA 24, para. 3-3.2, The following valves are less than the The vales are located along blank walls and are Post indicator valves shall be located not 40 ft distance: 0FP579, 0FP591, accessible. This is considered adequate.

less than 40 ft from buildings. 0FP580, 0FP592, 0FP581, 0FP593, 0FP582, 0FP602, 0FP588.

3.9-62

BRAIDWOOD-1 AMENDMENT 23 DECEMBER 2008 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 24 - 1984, "Standard for the Installation of Private Service Mains and Their Appurtenances" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 5 NFPA 24, para. 4-2.3, The following hydrants are less than the The hydrants are located along blank walls and Hydrants shall be at least 40 ft from 40 ft distance: 0FP05S, 0FP23S, can be isolated from the fire main. This is buildings. 0FP070, 0PF24S, 0FP21S. considered acceptable.

6 NFPA 24, para. 8-6.2.10, Insufficient documentation to determine A Technical Staff Surveillance will monitor any Thrust blocks or other suitable means of thrust restraint locations on flanged unusual system leakage. Thrust blocks have restraint shall be provided at fittings for each hydrant connections. been provided as necessary during routine change in direction of a pipeline and at tees, maintenance and hydrant repositioning. The plugs, caps, and bends. present anchoring is considered adequate.

7 NFPA 24, para. 7-2, All ferrous metal pipe Pipe is not lined. Periodic flow tests will monitor the interior shall be lined. condition of the pipe. Hydraulic calculations will also utilize a conservative C factor of 100 to account for extended age. This is adequate in lieu of lining pipe.

8 NFPA 24, para. 4-3.6, To ensure proper Hydrants are tested annually. Hydrants are tested at least once per 12 months functioning, dry barrel hydrants shall be to ensure proper functioning.

tested semiannually.

9 NFPA 24, para. 4-1.1, Hydrants shall have Wall hydrant 1FP01S in the Unit 1 Calculation BRW-05-0099-M has demonstrated not less than a 6 connection with the Containment Access Facility has a 3 that there is sufficient flow to provide two mains. supply connection from the main. effective hose streams from hydrant 1FP01S.

3.9-63

BRAIDWOOD-1 AMENDMENT 25 DECEMBER 2012 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 26 - 1983, "Supervision of Valves Controlling Water Supplies for Fire Protection" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 26, para. 3-1, The locked open valves Locked open valves are inspected every Locked open valves are inspected every 92 should be inspected monthly. 92 days. days to verify the valve is in the correct position.

2 NFPA 26, para. 3-1, A systematic weekly The sprinkler system alarm shutoff Historical review indicates a failure rate of < 1%.

inspection (or monthly in the case of locked valves position verification is performed Administrative procedure allows extension of

- open valves) of each valve should be at quarterly frequency based on frequency interval for inspection if the failure made. historical review of failure rate. rate is < 1%.

3 NFPA 26, para. 3-1, A systematic weekly The automatic deluge system trim Historical review indicates a failure rate of < 1%.

inspection (or monthly in the case of locked valves position verification is performed Administrative procedure allows extension of

- open valves) of each valve should be at quarterly frequency based on frequency interval for inspection if the failure made. historical review of failure rate. rate is < 1%.

3.9-64

BRAIDWOOD-1 AMENDMENT 23 DECEMBER 2008 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 27 - 1981, "Recommendations for Organization, Training and Equipment of Private Fire Brigades" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 27, para. 4-2.1, Classroom training is conducted by The classroom instructors are qualified for the Training should be conducted and training department instructors. subject areas presented. In addition, two state supervised, where possible, by a State certified Fire Service Instructors are involved in Certified Fire Service Instructor. all live fire training and some classroom instruction. The training program is considered acceptable.

2 NFPA 27, para. 4-3, Training sessions are conducted Training sessions conducted quarterly result in Training sessions should be held at least quarterly. a total of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of training per year for each monthly for one hour or more per shift brigade member. This level of training is considered as satisfying NFPA.

3.9-65

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 30 - 1984, "Flammable and Combustible Liquids Code" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 30, para. 2-7.1, All tanks shall be Provide testing documentation for: Tanks were fabricated and tested to industry tested as evidence of an ASME Code 0D003T, 0D012T, 1T001T, 0T001T and standards (API 650, AWWAD100 and Stamp or U.L. label. Tanks not marked 0T002T. Westinghouse Standards). Tanks not labeled.

shall be tested with good engineering N stamp not required.

principles.

2 NFPA 30, para. 2-7.2, When the vertical Provide hydro. test documentation for: Per M&MPC letter dated January 29, 1987, length of fill or vent pipes is such that when 0D003T, 00D01TA, OT001T, 0T002T M&MPC have reviewed the ANSI B31.1 filled with liquid the static head imposed on and OD005T. pneumatic and/or leak rate test data on this the bottom of the tank exceeds 10 psi, the equipment and find the results satisfactory. The tank and piping shall be hydrostatically tanks were tested per Design Specification tested equal to the static head. requirements. The in-service testing has been done by virtue of being in service since 1989.

There have been no leaks identified.

3 NFPA 30, para. 3-7.1, Provide piping hydro. test Per M&MPC letter dated January 29, 1987, NFPA 37, para. 5-7-1, documentation for: 0D003T, 0D012T, M&MPC have reviewed the ANSI B31.1 Unless tested in accordance with ANSI B31, 00D01TA, 1T001T, 1DO11T, 0T001T, pneumatic and/or leak rate test data on this all piping shall be hydrostatically tested to 0T002T, 1D001TA, TC, TB & TD, equipment and find the results satisfactory. The 150% of the maximum system pressure or 1D002TA & TB, 0D006T, 1D010T and in-service testing has been done by virtue of 110% pneumatically, but not less than 5 OD005T. being in service since 1989. There have been psig at the highest point for 10 minutes. no leaks identified.

3.9-66

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 30 - 1984, "Flammable and Combustible Liquids Code" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 4 NFPA 30, para. 2-2.5.4, and NFPA 37, para. Demonstrate the venting capacity is 0D003T and 0D012T are outdoor diesel fuel oil 5-6.1, The total capacity of venting device(s) provided via: storage tanks that are not required for safe shall be in accordance with Table 2-8 (i.e., 6" breather vent on 0D003T, 6" breather shutdown and no safe shutdown components 699, 380 cubic ft per hour (CFH) for vent on 0D012T, 2" breather vent on are located by these tanks. The area is diked.

0D003T, 563,600 CFH for 0D012T, 38,400 00D01TA. This is considered acceptable. The vent line on CFH for 00D01TA). 00D01TA is sized for maximum flow via 2" fill line. In addition, a high level alarm is provided.

This is considered adequate.

3.9-67

BRAIDWOOD-1 AMENDMENT 13 DECEMBER 1990 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 37 - 1984 "Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 37, para. 5-4.2, The following tanks do not have a high An automatic shutoff will not be provided on the Tanks shall be provided with high level level automatic shutoff: safety-related tanks as they may be required for automatic shutoff. 1D002TA & TB and 1D010T. operation.

2 NFPA 37, para. 5-3.7.1, At least 15 inch The following tanks have less than 15 The clearance is sufficient for maintenance and clearance shall be left around the tank. inch clear space: inspection activities.

1D002TA, 1D002TB and 1D010T.

3 NFPA 37, para. 5-5.3 and NFPA 30, para. Overflow lines 1D066AA4, AB4, AC4, In tank rooms 1D001TA, TC, TB, & TD, the 2-4.4.8, Tanks shall be equipped with a and AD4 terminate inside tank rooms: overflow lines terminate to a floor drain which is device or other suitable means to prevent 1D00TA, TC, TB & TD. piped to a fire and oil sump. This is considered overflow into the building. acceptable.

Tank 0D005T has no overflow line.

Tank 0D005T utilizes a sight tube and gauge to Tank 0D006T overflow line terminates observe oil level. This is adequate for filling inside the building. operations.

The overflow line on 0D006T terminates in a sump which can be manually pumped out. This is considered acceptable.

3.9-68

BRAIDWOOD-1 AMENDMENT 23 DECEMBER 2008 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 50A - 1984, "Standard for Gaseous Hydrogen Systems at Consumer Sites" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 50A, para. 4-1.3, The Nelson Electric enclosure at top Per manufacturer, the Class 654 enclosure was Electrical equipment within 15' shall be in rear of the hydrogen control cabinet is not U.L. listed at the time it was purchased and accordance with Article 501 of the National Class I, Division 2, Group B but not U.L. installed. However, the 654 enclosure is now Electric Code for Class I, Division 2 labeled. listed and identical to the installed device.

locations. Therefore, the equipment is acceptable.

3.9-69

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 51B - 1984, "Standard for Fire Prevention In Use of Cutting and Welding Processes ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 51B, para. 3-2.3: Where practicable, In instance where the scope of work and Braidwood is in compliance with NFPA 51B -

all combustibles shall be relocated at least tools used to conduct hot work results in 1984. NFPA generated changes to 51B which 35 ft. (11 mm) horizontally from the work possible slag, sparks, spatter, or similar were incorporated into the 2009 edition of the site. Where relocation is impracticable, mobile sources of ignition further than Standard for Fire Prevention in Use of Cutting combustibles shall be protected with 35 ft., the distance shall be extended to and Welding Processes. NFPA 51B - 2009 flameproofed covers or otherwise shielded encompass the area. The required paragraphs 5.4.2(14) and 5.4.2(15) allow the with metal or fire-resistant guards or distance or area shall be specified and Permit Authorizing Individual(PAI) to extend or curtains. approved on the hot work permit. retract the 35 ft. area surrounding hot work based upon the potential travel distance of In instances where the scope of work mobile ignition sources. Revision 11 or OP-AA-and tools (e.g. shielded metal arc 201-004, Fire Prevention for Hot Work, welding or gas metal arc welding) used incorporates paragraphs 5.4.2(14) and 5.4.2(15) to conduct hot work are known to be of NFPA 51B, 2009 edition at Braidwood Station incapable of generating slag, sparks, spatter, or similar mobile sources of ignition capable of leaving the immediate area of hot work, then the 35 ft. may be reduced to an area that encompasses the sources of ignition and typically not less than 10 ft. The required distance or area shall be specified and approved on the hot work permit.

3.9-70

BRAIDWOOD-1 AMENDMENT 23 DECEMBER 2008 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 72D - 1979, "Standard for the Installation, Maintenance and Use of Proprietary Protective Signaling Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 72D, para. 2-2.2.1(c), Equipment Equipment is designed for a 70% The environment is controlled by the HVAC shall be so designed that it shall be capable relative humidity (fire protection panels). system that contains a humidity controller which of performing its intended function at a maintains a setting of 40% RH + 5% RH and relative humidity of 85 + 5% and an ambient heating controls which maintain a temperature temperature of 90 °F+ 4 °F for a duration of setting of 75 °F + 2 °F. This design is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. considered acceptable for the fire protection panel environment.

2 NFPA 72D, para. 2-4.3(b), The automatic deluge system alarm Historical review indicates a failure rate of < 1%.

Every two months or more frequently, test tests are performed at semiannual Administrative procedure allows extension of shall be performed for all circuit interfaces frequency based on historical review of frequency interval for inspection if the failure and water flow actuated devices. failure rate. rate is < 1%.

3 NFPA 72D, para. 2-4.3(c), Gate valve supervisory switches are Supervised valves are also surveilled monthly.

Gate valve supervisory switches shall be tested annually. Therefore, annual alarm tests should be tested semiannually. acceptable.

4 NFPA 72D, para. 2.6.2.3, The secondary power supply is provided Bus 134/234 is normally fed from Bus 144/244 The secondary (standby) supply shall be from Bus 134/234 in lieu of storage which is supplied from the system auxiliary provided and shall consist of storage batteries or generator. transformer, and it also has a diesel generator batteries with a 24-hour supply, engine backup in case of a loss-of-offsite power. This driven generators or a combination of supply is as reliable as was intended by the engine driven generators and batteries. NFPA code, and is considered to be acceptable.

3.9-71

BRAIDWOOD-1 AMENDMENT 23 DECEMBER 2008 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 72D-1979, "Standard for the Installation, Maintenance and Use of Proprietary Protective Signaling Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 5 NFPA 72D, para. 2-6.2.4, A separate power Trouble signals are fed from the primary Bus 132/232 (ESF Bus) is the primary power supply, independent of the main power source. supply to the proprietary alarm systems. Due to supply shall be provided for the operation of the high reliability of the primary power supply, trouble signals. this is considered to be acceptable.

6 NFPA 72D, para. 3-6.2.2, Signals Common trouble alarm indications are Upon receipt of a trouble alarm, an operator is transmitted shall indicate distinctively the provided. dispatched to the area and fire watch may be particular function (such as valve position, initiated until the trouble is cleared. This is pressure, etc.) of the automatic sprinkler considered acceptable.

system which is abnormal and its restoration to a normal condition.

7 NFPA 72D, para. 4-4.1, Distinctive audible alarm and trouble The Unit 1 and 2 fire alarm panels are not Provide separate, distinctive, audible trouble indications are not provided between adjacent to one another in the Control Room. It and alarm signals at the Control Room Unit 1 & 2 panels. will be obvious to an operator responding to a panels 1PM09J/2PM09J. fire alarm which unit is affected. This is considered acceptable.

8 NFPA 72D, para. 3-5.1.2, Automatic fire Ionization detection systems do not Upon receipt of a trouble alarm, an operator is detectors which have integral trouble have this trouble feature. dispatched to the area and a fire watch may be contacts shall be wired on the initiating initiated until trouble is cleared. This is device circuit so that a trouble condition on considered acceptable.

one detector will not impair the alarm operation from other initiating devices.

3.9-72

BRAIDWOOD-1 AMENDMENT 27 DECEMBER 2016 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 72E - 1984, "Standard on Automatic Fire Detectors" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 72E, para. 2-5.1.1, The following charcoal filters utilize The United Electric devices are U.L. listed for All fire detection devices shall be listed. United Electric or Conax heat detection hazardous atmospheres and the Conax RTD devices that are not specifically listed for thermocouples are industrial grade heat sensing fire protection service: devices. These devices are an acceptable design for alarm purposes since the water spray Braidwood charcoal filters 1VP05FA & systems are actuated manually.

FB have been removed per EC 401148 and 2VP05FA & FB have been removed per EC 401150, 0VC05FA & FB, 0VC06FA & FB, 0VF04F, 1VQ09F, 2VQ09F, 00G04F/5F, 0VV21F & 22F and 0VW12F/18F.

2 NFPA 72E, para. 8-3.2.2, All rate compensation heat detectors SEE EC 394429 for justification.

Test one or more heat detectors are tested every 3 years. Containment semiannually. Test all in five years. Building Detectors are tested every 18 months. EDG Air Duct Detectors are tested every 4 years.

3 NFPA 72E, para. 8-3.3.1, All smoke detectors are tested every 3 SEE EC 394429 for justification.

All smoke detectors shall be tested at least years. Containment Building Detectors semiannually. are tested every 18 months. EDG Air Duct Detectors are tested every 4 years.

4 NFPA 72E, para. 4-3.7.3, If beams exceed Not all bays located at the South end of Detectors are not required in these bays as 18 inches in depth and are more than 8 feet detection zone 2D-75 that meet this determined in EC 353989.

on centers, each bay shall require at least criterion have a detector.

one spot type detector.

3.9-73

BRAIDWOOD-1 AMENDMENT 28 DECEMBER 2018 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 72E - 1984, "Standard on Automatic Fire Detectors" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 5 NFPA 72E, para. 8-3.3.1, Sensitivity Testing Detector Sensitivity Testing is done SEE EC 394429 for justification shall be performed within 1 year after every 5 years.

installation and every alternate year thereafter.

6 NFPA 72E, para. 8-3.4, All Flame Detectors, UV Detector are tested every 3 years SEE EC 394429 for justification Fire-Gas Detectors and other Fire Detectors shall be tested at least semiannually.

7 N/A The thermistor wire detection for Main The thermistor wire detection for Main Power Power Transformers 1E and 1W is Transformers 1E and 1W is redesigned designed in accordance with applicable (Reference EC #379761). It is acceptable to sections of NFPA 72-2013. design the new detection to the code year (2013) that was current at the time of design.

3.9-74

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 80 - 1983, "Standard for Fire Doors and Windows" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 80, para. 1-6.1, The labels for several doors are either A certificate of conformance from the Only labeled or listed doors shall be used. missing, damaged, or illegible. manufacturer is on file stating that the Piano-type hinges are installed the referenced doors were manufactured and length of some doors and the labeling delivered as listed fire doors.

could not be verified.

2 NFPA 80, para. 1-6.1, Several security doors are either The justification for the use of non-labeled doors Only labeled or listed doors shall be used. oversized or provided with a modified of "A construction" is contained on pages 2.1-8 two-point latch and electric strike. The through 2.1-9b of NOTE: Amendment 25 of the doors are not labeled. B/B FPR does not have a page 2.1-9b.

Two doors at EL. 401-0 in the L line (Multiple occurrences) wall are reinforced with steel plates for HELB pressure loading in conjunction The subject doors are addressed in Generic with seismic loading under HELB design Letter 86-10 Evaluation EC-EVAL 393561; this basis analysis. One door also has evaluation determined that the modified doors horizontal stiffeners. The doors are not are adequate for the fire hazards to which they labeled. are exposed and justifies the use of each non-Several doors at EL. 401-0 AND el. labeled door. Refer to EC 392850 and EC 426-0 in the L-line wall are reinforced EVAL 393561 or EC 391762 and EC-EVAL with steel plates for HELB pressure 392603.

loading in conjunction with seismic loading under HELB design basis analysis. The doors are not labeled.

3 NFPA 80, para. 1-6.3, Several oversized doors are not labeled. The justification for the use of non-labeled doors Authorities having jurisdiction shall be of "A construction" is contained on pages 2.1-8 consulted as to the size of oversized doors through 2.1-9b of the Braidwood Fire Protection which may be deemed acceptable in a given Report location.

3.9-75

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 80 - 1983, "Standard for Fire Doors and Windows" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 4 NFPA 80, para. 2-5.1, Labels for several door frames are A certificate of conformance from the Only labeled door frames shall be used. either missing or illegible. manufacturer is on file stating that the referenced frames were manufactured and The doors installed in some frames are delivered as listed frames.

provided with piano-type hinges which run the length of the frame and labeling could not be verified.

5 NFPA 80, para. 2-5.1, Several security doors have been The justification for the use of these frames is Only labeled door frames shall be used. modified with security hardware. provided on pages 2.1-8 through 2.1-9b of the Braidwood Fire Protection Report.

The frames for two doors at EL.401-0 in the L-line wall area reinforced for The subject door frames are addressed in HELB pressure loading in conjunction Generic Letter 86 10 Evaluation EC-EVAL with seismic loading under HELB design 393561; this evaluation determined that the basis analysis. The door frames are not modified doors are adequate for the fire hazards labeled. to which they are exposed and justifies the use of each non-labeled door and frame. Refer to EC 392850 and EC-EVAL 393561 or EC 391762 and EC-EVAL 392603.

6 NFPA 80, para. 2-5.4, The clearance between doors and The clearances may be increased as stated and The clearance between doors and frames frames and the clearance between the justified in EC- EVAL#339805. Clearances that and the clearance between the meeting meeting edges of doors swinging in satisfy the criteria specified in the EC-EVAL edges of doors swinging in pairs shall not pairs may exceed 1/8 inch. represent an acceptable minor deviation from exceed 1/8 inch. NFPA 80 and may be considered operable without additional evaluation or corrective action.

3.9-76

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 80 - 1983, "Standard for Fire Doors and Windows" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 7 NFPA 80, para. 2-5.4, The clearance between the bottom of a The clearances may be increased as stated and The clearance between the bottom of a door door and sill may exceed 3/8 inch. justified in EC-EVAL#339805. Clearances that and sill shall not exceed 3/8 inch. Where Where there is no sill, clearance may satisfy the criteria specified in the EC-EVAL there is no sill, clearance shall not exceed exceed 3/4 inch. represent an acceptable minor deviation from 3/4 inch. NFPA 80 and may be considered operable without additional evaluation or corrective action.

8 NFPA 80, para. 2-8.1.3, Hinges shall be The hinges for two doors at EL. 401-0 Attachment of the subject door hinges is secured to frames with steel screws. Types in the L-line wall area replaced to addressed in Generic Letter 86-10 Evaluation of screws will vary depending on material support steel plates added to reinforce EC EVAL 393561; this evaluative determined used for the manufacture of labeled door the doors for HELB pressure loading in that the modified doors are adequate for the fire frames. Refer to labeled door frame conjunction with seismic loading under hazards to which they are exposed and justifies manufacturers instructions and published HELB design basis analysis. The the use of each non-labeled door and hinge listings for specific screw requirements. replacement hinges are not attached to configuration. Refer to EC 392850 and EC-the door frame; they are welded to a EVAL 393561 or EC 391762 and EC-EVAL short hollow steel section, which is 392603.

welded to a plate that is attached to the concrete wall and/or structural steel.

Attachments to the wall are made with 3/4 concrete expansion anchors. The other hinge leaf is attached to the door with through bolts.

9 NFPA 80, para. 2-8.2.1, Several doors are provided with security The justification for non-labeled hardware for Only labeled locks and latches shall be hardware. security doors is contained on pages 2.1 8 used. through 2.1 9b of the Braidwood Fire Protection Report.

3.9-77

BRAIDWOOD-1 AMENDMENT 28 DECEMBER 2018 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 80 - 1983, "Standard for Fire Doors and Windows" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 10 NFPA 80, para. 2-8.4.1, These doors are not provided with a The coordinating devices have been installed on Where there is an astragal or projecting coordinating device: SD 172 and SD Doors SD-172 and SD-174 (WO 1382059 & WO latch bolt that prevents the inactive door leaf 174. 1382061).

from closing and latching before the active door closes, a coordinating device shall be used.

11 NFPA 80, para. 2-9, Several doors are provided with Gasketing is installed to assist the HVAC air Gasketing on fire doors or frames shall be gasketing around the frame. flow/pressurization within the plant. The furnished only in accordance with the gasketing does not affect the operability of the published listing of the door frame or door and is considered acceptable.

gasketing material manufacturer.

Exception: Where acceptable to the authority having jurisdiction, gasketing of non-combustible or limited combustible material may be applied to the frame providing closing and latching of the door is not thereby inhibited.

12 NFPA 80, Para. 14-2.1.1, hardware shall be Braidwood is extending the time Performance Based Review of system testing, examined frequently and any parts found to between inspection on multiple fire rated in accordance with station approved be inoperative shall be replaced doors. procedures, supports this frequency (Reference immediately. EC# 403823).

3.9-78

BRAIDWOOD-1 AMENDMENT 26 DECEMBER 2014 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 90A - 1985, "Standard for the Installation of Air Conditioning and Ventilating Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 90A, para. 4-3 Not all duct detectors stop the fan(s). Sargent & Lundy's NFPA 90A compliance (a)&(b), In systems over 2,000 cfm, listed checklist dated 10/9/1986, Rev 1 (HVAC smoke detectors shall be installed and Systems Review in compliance with NFPA 90A) automatically stop the fan(s). identifies detector functions and list specific deviations from the NFPA code including justifications. M&MPC has performed review of the checklist as documented in their letters dated 4/16/1987 and 4/5/1988. The Smoke Removal Plan BwOP FP-27 was revised based on the formal review of the plan per M&MPC letter dated 1/22/1988. The BwOP FP-27 includes related information regarding fan trip with respect to the duct detector and direct fan shutdown to ensure closure of the fire dampers.

2 NFPA 90A, para. 4-5.1, The duct detectors alarm in the main The common fire/trouble alarm in the main 4-5.2, and 4-5.3, control room HVAC panel as common control room also records a printed message Detectors shall be installed in accordance fire or trouble alarms and are not which indicates the local HVAC panel. The local with NFPA 72E and shall sound an alarm in installed on the fire alarm system per HVAC panel indicates separate fire and trouble a normally occupied area or through the NFPA 72E or 72D. alarms. Operating procedures address these building fire alarm system. alarm conditions. This is acceptable for the duct detector alarm system.

3 NFPA 90A, para. 2-4.1, Air filters shall have Effective May 1, 2012 Underwriters Filters are to be Class 1 or 2. After May 1, 2012, a U.L. Class 1 or 2 rating. Laboratory (UL) will no longer classify filters shall comply with NFPA 90A-2012, air filters as Class 1 or Class 2 under Section 4.2.2.2 and comply with ANSI/UL 900 Standard UL 900 Standard for air filters.

3.9-79

BRAIDWOOD-1 AMENDMENT 13 DECEMBER 1990 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 90A - 1985, "Standard for the Installation of Air Conditioning and Ventilating Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 4 NFPA 90A para. 3-3.7.1.6, Fusible links Some fusible links have a temperature The fusible link temperature rating is shall have a temperature rating rating greater than 50°F above the significantly below typical fire temperatures. A approximately 50°F above the maximum normally encountered maximum room Certificate of Conformance was provided by SR temperature that normally is encountered temperature due to abnormal accident Products for the non-UL listed ETLs stating that when the system is in operation or shut conditions associated with a HELB. the ETLs are designed and manufactured with down, but not less than 160°F. the same parts and standards as their UL listed devices. Refer to EC 388397, EC 388398 or EC 392191.

3.9-80

BRAIDWOOD-1 AMENDMENT 13 DECEMBER 1990 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 232 - 1980, "Standard for the Protection of Records" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 232, paras. 2-4 & 2-14.1, The QA vault is approximately 8,450 cu. The QA vault is protected by an automatic A vault shall not exceed 5,000 cu. ft. An ft. and is not equipped with automatic Halon 1301 fire suppression system with a oversize vault not over 25,000 cu. ft may be sprinklers. connected reserve. This is adequate protection used and equipped with automatic sprinkler in lieu of sprinklers.

protection.

2 NFPA 232, para. 2-14.2, Automatic sprinklers are not provided in Smoke detectors associated with the Halon Where mobile shelving is used, smoke the Q.A. vault. 1301 suppression system are provided. This is detectors shall be provided in addition to acceptable.

automatic sprinklers.

3 NFPA 232, para. 2-10.4, A heat or smoke actuated device does The door is normally locked closed and is Doors shall be equipped with an automatic not close the door (QA vault). equipped with an automatic door closure. A closing device and a heat actuated or heat or smoke interlocking device is not smoke actuated release to close them. necessary for this reason.

4 NFPA 232, para. 2-9.2 HVAC supply and exhaust ducts HVAC openings are protected by a series of two Roofs of vaults shall not be pierced for any penetrate roof (QA vault). 1-1/2-hr fire treated dampers that will purpose. automatically close upon fire or actuation of the halon system. This provides a fire barrier for the roof and is acceptable.

5 NFPA 232, para. 2-10.1, A 3-hr U.L. labeled door is installed (QA Based on external fire exposure, the 3-hr door The vault shall be provided with a listed 4-hr vault). provides adequate protection.

door.

3.9-81

BRAIDWOOD-1 AMENDMENT 13 DECEMBER 1990 Table 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 232 - 1980, "Standard for the Protection of Records" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 6 NFPA 232, para. 2-11.2, The lighting switch is inside the vault in Electrics have been installed per the National Lighting shall be vapor proof or explosion addition to a telephone, thermostat, exit Electrical Code and present no inherent hazard.

proof controlled by a switch outside the sign, and a temp/humidity recorded (QA In addition, U.L. listed Class P gasketed light vault. No other electrical devices shall be vault). fixtures are installed with thermal ballast permitted within the vault protection. This is acceptable.

3.9-82

BRAIDWOOD-2 AMENDMENT 28 DECEMBER 2018 Table 3-2 is a listing of NFPA deviations identified for safety-related areas on Braidwood Unit 2. This list indicates deviations which were not identified on the Unit 1 NFPA deviation list.

3.9-83

BRAIDWOOD-2 AMENDMENT 13 DECEMBER 1990 Table 3-2 NFPA CODE DEVIATION REPORT NFPA 12 - 1985, "Standard on Carbon Dioxide Extinguishing Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 12A, para. 2-6.2.2, The agent (halon) Due to the extra quantity of halon added The time to reach initial concentration is not discharge shall be substantially complete in to the original design to maintain the affected and, therefore, a longer discharge a nominal 10 seconds. soaking period, the nominal 10 second period has no impact on the halon suppression discharge is exceeded. capability.

3.9-84

BRAIDWOOD-2 AMENDMENT 26 DECEMBER 2014 Table 3-2 (Contd)

NFPA CODE DEVIATION REPORT NFPA 13 - 1985, "Standard for the Installation of Sprinkler Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 13, para. 3-8.4, Return bends shall Return bends are not provided for The sprinkler systems have been adequately be used when pendent sprinklers are pendent sprinklers. flushed and the plant fire protection water is supplied from a raw water source. strained through a screen prior to its introduction into the system.

2 NFPA 13, para. 4-4.8.2.3, Where sprinklers Cross baffles are not provided on the Each of the sprinklers for these systems is installed to protect floor openings are systems protecting the center stairwell provided with a 5 inch baffle plate, which along located closer than 6 feet apart, cross of the Auxiliary Building. with some minor obstructions from equipment baffles shall be provided. between sprinklers, will adequately prevent prewetting of the sprinklers.

3 NFPA 13-2007 Edition, para. 7.3.2.4.1, pre- The Containment Access Facility (CAF) This deviation is considered acceptable based action sprinkler piping shall be automatically pre-action sprinkler piping is not upon the justification provided in EC 366860.

supervised where there are more than 20 automatically supervised and has more sprinklers on the system. than 20 sprinklers.

4 NFPA 13, Chapter 4. Spacing, locations During the walkdown of the systems, Obstructions to the foam sprinkler heads and position of sprinklers shall be made in deviating locations and positions of located in the Diesel Fuel Oil Storage Tank accordance with NFPA. sprinklers where identified Rooms have been evaluated under GL 86-10 evaluation, EC 380157 and found to be acceptable.

3.9-85

BRAIDWOOD-2 AMENDMENT 18 DECEMBER 1998 Table 3-2 (Contd)

NFPA CODE DEVIATION REPORT NFPA 14 - 1983, "Standard for the Installation of Standpipe and Hose Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 14-1983, para. 4-4.3.1, Listed fire Hard rubber hose is used for the cable Hard rubber hose is utilized on these hose hose shall be used. spreading room areas and electric cable stations for maneuverability in the cable areas.

tunnels. The hose may or may not be The hose is hydrostatically tested and surveilled listed by UL or approved by Factory to the same standards regardless of listing or Mutual (FM). The listing or approval is approval status.

dependent on availability of the listing or approval from the applicable authority at the time of procurement.

3.9-86

BRAIDWOOD-2 AMENDMENT 13 DECEMBER 1990 Table 3-2 (Contd)

NFPA CODE DEVIATION REPORT NFPA 24 - 1984, "Standard for the Installation of Private Service Mains and Their Appurtenances" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 24, para. 8-3.1, Pipe shall not be run The Receiving Building Warehouse and Sargent & Lundy letter of January 26, 1988 (R.

under buildings. Gate House extension were built over Salsbury to J. Robinson) references review the underground fire main. indicating loading to piping from buildings to negligible.

3.9-87

BRAIDWOOD-2 AMENDMENT 13 DECEMBER 1990 Table 3-2 (Contd)

NFPA CODE DEVIATION REPORT NFPA 30 - 1984, "Flammable and Combustible Liquids Code" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 30, para. 2-7.1, All tanks shall be Tank 2T001T is not marked with an The main turbine oil reservoir was designed and tested as evidence of an ASME Code ASME Code Stamp or U.L. label. The constructed to Westinghouse Standards. The Stamp or U.L. label. Tanks not marked tank was not designed to any specific tank and associated piping was leak tested at shall be tested with good engineering code such as API 650 or ASME section normal operating pressure per ANSI Standards.

principles. VIII.

2 NFPA 30, para. 2-7.2, When the vertical The flame arrestor vent lines on the The tanks are provided with overflow lines length of fill or vent pipes is such that when following tanks have large vertical which could prevent a static head increase filled with liquid the static head imposed on lengths and could impose a 10 psi static above 10 psi. Therefore, the tanks are not the bottom of the tank exceeds 10 psi, the head: 2D01TA/TB, 2D002TA/TB, tested to this criteria.

tank and piping shall be hydrostatically 2D010T & 2D011T tested equal to the static head.

3 NFPA 30, para. 3-7, Unless tested in Piping is tested to ANSI Standards Per S&L spec. L-2739, code case N-240 accordance with ANSI B31, all piping shall except open ended piping (e.g., alleviates testing all open ended piping.

be hydrostatically tested to 150% of the overflow, vent lines, etc.) which is not maximum system pressure or 110% tested from the point of the last control pneumatically, but not less than 5 psig at valve to the open end of the pipe.

the highest point for 10 minutes.

4 NFPA 30, para. 2-2.5.4, The total capacity Long lengths of vent piping are S&L has calculated that no additional venting is of normal and emergency venting shall be in prevalent on all tanks. Total venting required due to the lack of heat generated by a accordance with Table 2-8 of NFPA 30 capacity may be hindered by pipe fire in the tank storage areas. (S&L letter of and/or the listed venting requirements. lengths and height. 11/1/84, Leutloff to Smith).

5 NFPA 30, para. 2-2.7.4, The fill pipe The fill lines for tanks OVR11TA/TB During system operation, liquid level will be entering the top of a tank shall terminate terminate approximately 1.5 foot from maintained above the 1.5 foot level, utilizing the within 6 in. of the bottom of the tank. the tank's bottom. low liquid level alarm and administrative controls.

3.9-88

BRAIDWOOD-2 AMENDMENT 13 DECEMBER 1990 Table 3-2 (Contd)

NFPA CODE DEVIATION REPORT NFPA 30 - 1984, "Flammable and Combustible Liquids Code" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 6 NFPA 30-1984, para. 4-4.1.3, Maximum The floor area of the paint and oil room NFPA 30 does not provide requirements for floor area of an inside storage room should is 830 square feet. inside storage rooms with a 3-hour fire be limited to 500 square feet for a 2-hour resistance rating. This room has a 3-hour fire fire resistance rated storage room with an resistance rating and is fully sprinkled.

installed fire protection system.

7 NFPA 30-1984, para. 4-4.1.6, Exhaust and Various exhaust and makeup ventilation NFPA 91, "Standard for the Installation of makeup ventilation inlets shall be located inlets are located in excess of 12 inches Blower and Exhaust Systems for Dust, Stock within 12 inches of the floor from the floor. and Vapor Removal or Conveying," para. 3-2.1, allows for ventilation through a system of suction ducts. This is considered to be acceptable, as the requirements of NFPA 91 are referenced as being applicable.

8 NFPA 30-1984, para. 4-4.1.6, NFPA 91 Fire doors are not provided. UL listed, 3-hour rated fire dampers OVJ11Y 1983 para. 2-7.8, When ducts pass through and OVJ12Y are provided in the wall openings.

a fire wall, they shall be provided with fire These dampers are centered within the doors on both sides of the wall. opening.

9 NFPA 30-1984, para. 4-4.1.6, The No means is provided to indicate failure The dispensing of flammable liquids is mechanical ventilation system for of the ventilation system. administratively controlled and includes dispensing areas shall be equipped with an verification that the ventilation system is airflow switch or other equally reliable operating methods which is interlocked to sound an audible alarm upon failure of the ventilation system 3.9-89

BRAIDWOOD-2 AMENDMENT 13 DECEMBER 1990 Table 3-2 (Contd)

NFPA CODE DEVIATION REPORT NFPA 37 - 1984 "Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 37, para. 5-7.1, Unless tested in Piping is tested to ANSI Standards Per S&L spec. L-2739, code case N-240 accordance with ANSI B31, all piping shall except open ended piping (e.g., alleviates testing all open ended piping be hydrostatically tested to 150% of the overflow, vent lines, etc.) which is not maximum system pressure or 110% tested from the point of the last control pneumatically, but not less than 5 psig at valve to the open end of the pipe.

the highest point for 10 minutes.

2 NFPA 37, para. 5-6.1, The total capacity of Long lengths of vent piping are S&L has calculated that no additional venting is normal and emergency venting shall be in prevalent on all tanks. Total venting required due to the lack of heat generated by a accordance with Table 2-8 of NFPA 30 capacity may be hindered by pipe fire in the tank storage areas. (S&L letter of and/or the listed venting requirements. lengths and height. 11/1/84, Leutloff to smith) 3.9-90

BRAIDWOOD-2 AMENDMENT 26 DECEMBER 2014 Table 3-2 (Contd)

NFPA CODE DEVIATION REPORT NFPA 90A - 1985, "Standard for the Installation of Air Conditioning and Ventilating Systems" ITEM NFPA REFERENCE DEVIATION COMMENTS / RESOLUTION 1 NFPA 90A para. 3-3.7.1.6, Fusible links Some fusible links have a temperature The fusible link temperature rating is shall have a temperature rating rating greater than 50°F above the significantly below typical fire temperatures and approximately 50°F above the maximum normally encountered maximum room below ignition temperature of the material on temperature that normally is encountered temperature due to abnormal accident either side of the wall.

when the system is in operation or shut conditions associated with HELB. A Certificate of Conformance was provided by down, but no less than 160°F SR Products for non-UL listed ETLs stating that the ETLs are designed and manufactured with the same parts and standards as their UL listed devices. Refer to EC 388947, 388948, or 392192.

3.9-91