Text

0 to Updated Final Safety Analysis Report, Chapter 9, Appendix 9A, Fire Protection Evaluation Report. (Redacted)
	ML21252A522
Person / Time
Site:	Limerick
Issue date:	04/29/2021
From:	Audrey Klett; NRC/NRR/DORL/LPL1
To:	; Office of Nuclear Reactor Regulation
	Klett A
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ML21251A560	List: ML21252A520; ML21252A522; ML21252A572; ML21252A741; ML21252A742; ML21253A055; ML21253A056;
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LGS UFSAR 9A.2.5 WATER DELUGE APPLICATION FOR CHARCOAL FILTERS Charcoal filters in the ventilation systems of the plant are provided with water deluge application systems for fire protection. The water is supplied to the filters by means of a fixed piping system.

An indicating gate valve is manually opened when a thermal sensor actuates a local alarm system and registers an alarm condition on the fire protection panels in the control room. The operation is terminated manually by shutting the gate valve.

9A.2.6 WET STANDPIPES AND HOSE STATIONS Wet standpipes are designed for Class II service in accordance with NFPA 14. All areas in the power block are within reach of at least one effective hose stream. Each hose station has nominally 100 feet of NFPA compliant fire hose. Hose stations are located outside entrances to normally unoccupied areas, and outside both entrances of the control room. Most areas of the plant have adjustable fog nozzles that can be adjusted down to a straight stream. In areas with electrical hazards, there are adjustable fog nozzles (intrinsically safe) that will not go down below a 30 degree fog pattern.

9A.2.7 FOAM EXTINGUISHING SYSTEM A foam system is provided for the protection of the fuel oil transfer structure and one outdoor fuel oil storage tank, and is designed in accordance with NFPA 11. The foam is educted from a foam solution tank by water from the main fire water header. Contacts are provided to annunciate operation of the system in the control room.

The one storage tank is provided with a fixed foam maker at the tank. Foam making is initiated manually from a local station after a high temperature condition at the tank has been alarmed locally and annunciated on the fire protection panels in the control room. Fire protection inside the fuel oil transfer structure is provided by a foam play pipe with hose rack. When the play pipe is removed from its holder, an electric switch located in the holder actuates a control valve to allow foam solution to enter the hose. A squeeze-type play pipe valve enables the operator to control the flow of foam.

9A.2.8 DELETED 9A.2.9 HALON EXTINGUISHING SYSTEMS Three independent Halon extinguishing systems are provided for the raised flooring at el 289' in the control structure. Two of the systems serve the auxiliary equipment room; one system is designed to discharge simultaneously into all floor sections on the Unit 1 side of the room, and the other system is designed to discharge simultaneously into all floor sections on the Unit 2 side of the room. The third Halon system serves the remote shutdown room.

The flooring in the auxiliary equipment room and the remote shutdown room consists of 1 foot high floor sections resting on the concrete slab at el 289'. The floor sections are of all-steel construction (except for aluminum honeycomb in the floor plates) and are used for the routing of cabling to and from the electrical equipment located in the two rooms. In the auxiliary equipment room, this equipment includes the PGCC equipment, the plant computers, the Samac panels, the river APPENDIX 9A 9A-6 REV. 19, SEPTEMBER 2018

LGS UFSAR evacuation and PA panel, a tone cabinet, and fault detection equipment. The PGCC for each unit consists of floor sections that are 8 feet wide and 20 feet long, each of which has vertical panels mounted near the center of the floor section. A termination cabinet is located at one end of each PGCC floor section. Smoke detectors are located in the floor sections and termination cabinets.

The equipment located in the remote shutdown room consists of the remote shutdown panels for Unit 1 and Unit 2. Smoke detectors are located within the floor sections in the remote shutdown room.

The Halon extinguishing systems are designed in accordance with NFPA 12A. Each Halon system is designed to achieve a concentration of 20% by volume with the raised flooring that it serves fully installed and secured. Each system includes two banks of Halon cylinders, each of which has sufficient capacity to maintain a 20% concentration for 20 minutes. In addition to having two banks of Halon cylinders, each system consists of distribution piping and nozzles, heat detectors, and a manual selector switch. The heat detectors serve to actuate the Halon system; a predischarge alarm is sounded first, followed by a time-delayed discharge of Halon. The manual selector switch is used to designate which of the two banks of Halon cylinders in each system will discharge automatically. Halon cylinders can be discharged manually at the hand switch location or at the cylinder locations. The unused bank of cylinders can be used to provide a supplemental discharge of Halon by manually actuating the release.

9A.2.10 WATER CURTAIN SYSTEMS Two types of water curtain suppression systems are provided in the plant: (a) systems that subdivide certain fire areas into two zones, and (b) systems that protect floor slab openings associated with equipment hatchways in the reactor enclosures.

Water curtain systems that serve to subdivide fire areas are provided at el 217', el 253', and el 313' in the reactor enclosures. Each water curtain system consists of an OS&Y gate valve, a deluge valve, a local pull station, piping, and open sprinkler heads. Each water curtain system is actuated manually, using the local pull station to open the deluge valve. The pull station is located inside a stairwell near the location of the water curtain. Actuation of a water curtain system is sounded throughout the plant by a coded alarm. Operation of the system is terminated manually by shutting the OS&Y gate valve, which is located near the stairwell in which the pull station is located.

Each of the water curtain systems is designed to achieve a discharge density of 0.3 gpm/ft2 at floor level. This is accomplished through the use of open sprinkler heads arranged in a linear array across the top of the water curtain location. In addition, sprinkler heads discharging horizontally inward from the sides of the water curtain are provided where necessary to achieve the design discharge density.

Water curtain systems that serve to protect the equipment hatchways in the reactor enclosures are designed similarly to the water curtain systems described above. The equipment hatchways are located in the southeast corner of the Unit 1 reactor enclosure and the southwest corner of the Unit 2 reactor enclosure. Each hatchway consists of openings in the concrete floor slabs at el 253', el 283', and el 313', with the openings arranged above one another. The opening in each slab is protected by an individual water curtain system having its distribution piping located at the underside of the slab and arranged around the perimeter of the opening. Each water curtain system is actuated manually, using a local pull station to open the deluge valve. The pull station is installed inside the stairwell near the location of the water curtain. In addition to the pull station, each water curtain system can be actuated by use of an emergency trip valve located near the system's local control panel.

APPENDIX 9A 9A-7 REV. 19, SEPTEMBER 2018

LGS UFSAR 9A.2.11 PORTABLE FIRE EXTINGUISHERS Portable fire extinguishers, using extinguishing agents compatible with the combustible material in the area in which they are located, are provided throughout the plant.

9A.2.12 FIRE AND SMOKE DETECTION SYSTEM The fire and smoke detection system is in compliance with NFPA 72A (1979). The system also complies with the requirements of NFPA 72D (1975), with the following exceptions and clarifications:

a. No device is provided for permanently recording incoming signals with the date and time of receipt. (The logging of fire events by a device for permanently recording incoming signals is not needed, because plant operating procedures will require the operator on duty in the control room to update the plant log book with the date and time of alarms from the fire detection system and of initiation of any fire suppression system.)

b. Operation and supervision of the system is not the primary function of the operators. (The control room operators are responsible for monitoring and supervision of all plant systems, including the fire detection and fire suppression systems.)

c. The locations of early warning fire and smoke detectors were established under the direction of a registered fire protection engineer. (The locations of fire and smoke detectors are in compliance with the guidance of NFPA 72E, with the clarification that ionization-type detectors in certain areas of the plant are located in accordance with subsections 4-3.1 and 4-3.1.1 of NFPA 72E. These subsections allow detector location to be determined based on engineering judgement considering ceiling shape, ceiling surfaces, ceiling height, configuration of contents, combustible characteristics, and ventilation. In areas where concrete floor slabs are supported by structural steel beams, the diffusion of ionized particles throughout the compartment volume during the incipient stage of the fire will negate the effect of beam depth and result in an appropriate level of detection capability.

d. NFPA 72D (1979) references NFPA 72E (1978) for testing of smoke detectors.

NFPA 72E (1978) requires functional testing of smoke detectors semiannually.

Functional testing of smoke detectors at Limerick will be done in accordance with the Technical Requirements Manual.

e. In fire area 2, the smoke detection system is upgraded to NFPA 72, 1996, Chapter 5 for detector location and spacing.

f. In fire area 98, the smoke detection system above the ASD System is upgraded to NFPA 72, 2010, Chapter 17 for detector location and spacing.

g. In fire area 25, the locations of in-cabinet and under floor smoke detectors accepted was by the NRC in their review of GE NEDO-10466A Power Generation Control Complex Design Criteria and Safety Evaluation.

APPENDIX 9A 9A-8 REV. 19, SEPTEMBER 2018

LGS UFSAR

h. In fire area 111, the smoke detection system above the ASD System is upgraded to NFPA 72, 2010, Chapter 17 for detector location and spacing.

Fire and smoke monitoring, detection, and alarm are accomplished by installing smoke detectors and/or heat-responsive detectors in areas where fire potential exists. Fire and smoke detection systems for annunciation are separate from fire detection systems for actuation of fire extinguishing systems, except for the 13kV Switchgear Area (Fire Area 2). The smoke detection system in the 13 kV Switchgear Area (Fire Area 2) provides early warning notification while also providing an input signal to the double interlock preaction system that provides localized protection.

Although the fire and smoke detection system is primarily a Class B system, certain portions of it are designed as Class A. The local fire detection panels in safety-related areas of the plant (control structure, reactor enclosures, and diesel generator enclosures) and in the Unit 2 turbine enclosure are Class A. All other local fire detection panels are Class B. The detector systems and local panels for the Halon system in the raised flooring of the auxiliary equipment room are Class A.

The heat detector wiring and local panel wiring for all sprinkler systems is Class B. Transmitter circuits from all local panels (both Class A and Class B) back to the fire protection alarm panel near the control room are Class B. Circuits in the fire protection alarm panel (00C926) are Class B.

Both the Class A and Class B portions of the fire and smoke detection system are electrically supervised to detect circuit breaks, ground faults, and power failure. Class A portions of the system have the capability to detect fire and smoke concurrent with a single break or single ground in the detection circuit; Class B portions of the system do not have this capability. Class A detection circuits utilize a four-wire system, whereas Class B detection circuits utilize a two-wire system with end-of-line resistor. Functional testing of the supervised circuits is done in accordance with the Technical Requirements Manual.

Annunciator circuits from the local fire suppression system panels to fire protection alarm panel 00C926 and from 00C926 to control room fire protection annunciator 0BC850 are not electrically supervised. Detection of smoke or fire is registered visually on a window of control room fire protection annunciator 0AC850 (identifying the location of the fire) and is sounded throughout the plant by a coded alarm. Trouble conditions (circuit breaks, ground faults, and power failures) in the fire and smoke detection system are registered by an audible alarm in the control room and by visual indication on the affected local fire detection panel as well as on a common window of control room fire protection annunciator 00C650. Actuation of any fire suppression system is sounded throughout the plant by a coded alarm. Trouble conditions in any fire suppression system are registered by an audible alarm in the control room and by visual indication on panel 00C926 and a common window of control room fire protection annunciator 0BC850.

APPENDIX 9A 9A-9 REV. 19, SEPTEMBER 2018

LGS UFSAR 9A.3 COMPARISON BETWEEN LGS FIRE PROTECTION PROGRAM AND NRC GUIDELINE DOCUMENTS 9A.3.1 NRC BRANCH TECHNICAL POSITION CMEB 9.5-1 The purpose of this section is to compare the fire protection provisions of LGS Units 1 and 2 with the guidelines in BTP CMEB 9.5-1.

To identify areas of potential impact and to facilitate comparison, a matrix addressing each guideline of the BTP and relating to the plant systems, equipment, and components, is included as Section 9A.3.1.1. The matrix has extracted all suggested guidelines from the BTP and given each an item number, 1 through 255. Each item has condensed a particular guideline and makes reference to the section in the BTP where that guideline can be found. The general degree of conformance to the guideline is indicated in the COMPARISON column, using codes defined as follows:

C - indicates conformance to the guideline or conformance to its intent.

Substantiating statements may be included as part of the matrix or in Section 9A.3.1.2.

AC - indicates conformance to the guidelines by alternate means or methods.

The manner of conformance is included in the matrix or discussed in Section 9A.3.1.2.

NC - indicates that the plant is not in conformance and no design changes are planned. The basis for nonconformance to the guideline is included in the matrix or discussed in Section 9A.3.1.2.

NA - indicates that the guideline is not applicable to LGS Units 1 and 2.

Substantiating statements are included as part of the matrix in Section 9A.3.1.1.

In the REMARKS column, additional information is provided to explain or expand on the degree of conformance. Alternatively, reference may be made to Section 9A.3.1.2 (or other sections in this report) for a more detailed discussion. The item numbers in Section 9A.3.1.2 correspond to those in Section 9A.3.1.1.

9A.3.1.1 Detailed Comparison to Branch Technical Position CMEB 9.5-1 Specific items in the following table identify compliance to specific National Fire Protection Association (NFPA) codes (or standards) for the design, installation, and maintenance of fire protection systems. The fire protection systems at Limerick Generating Station were originally designed and installed using the criteria found in the NFPA codes in order to comply with NRC guidance. NFPA codes provide guidance for the requirements for the performance of fire protection systems. This guidance provides reasonable assurance that the fire protection systems installed at Limerick Generating Station will provide timely warning and adequate suppression for the purpose of life safety and property protection.

APPENDIX 9A 9A-10 REV. 19, SEPTEMBER 2018

LGS UFSAR The Fire Protection Program at Limerick Generating Station is based on a defense-in-depth philosophy with numerous barriers in place to ensure adequate protection of plant structures, systems and components as well as the health and safety of the public in the event of a postulated fire occurring. It is recognized that there are situations in the plant where verbatim compliance with all aspects of the NFPA codes have not been satisfied. When the fire protection systems were initially designed and installed, the NFPA codes were considered guidance documents, not verbatim compliance documents. Through the use of qualified designers, engineers, and installation personnel, alternative plant configurations may have been employed to satisfy the intent of the NFPA requirements.

Deviations that could potentially affect system performance are documented in the design record for the plant. Minor deviations, while considered during initial design and installation, are not necessarily documented in the design record for the plant.

APPENDIX 9A 9A-11 REV. 19, SEPTEMBER 2018

LGS UFSAR CMEB 9 5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS Fire Protection Program

1. The fire protection program should be under the direction C.1.a(1) C of an individual who has been delegated 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 should extend the concept C.1.a(2) C of 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, system s, 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. Responsibility for the overall fire protection program C.1.a(3) C should be assigned to a person who has management control over all organizations involved in fire protection activities. Formulation and assurance of program implementation may be delegated to a staff composed of personnel prepared by training and ex perience 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.

4. The staff should be responsible for: C.1.a(3) C (a) Fire protection program requirements, including consideration of potential hazards associated with postulated fires, with knowledge of building layout and systems design.

(b) Post-fire shutdown capability.

(c) Design, maintenance, surveillance, and quality assurance of all fire protection features (e.g.,

detection systems, suppression systems, barriers, dampers, doors, penetration seals, and fire brigade equipment).

(d) Fire prevention activities (administrative controls and training).

(e) Fire brigade organization and training.

(f) Prefire planning.

5. The organizational responsibilities and lines of C.1.a(4) C communication pertaining to fire protection should be defined through the use of organizational charts and functional description.

APPENDIX 9A 9A-12 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS

6. Personnel qualification requirements for fire protection C.1.a(5) C See Section 3.1.2 engineer reporting to the position responsible for formulation and implementation of the fire protection program.

7. The fire brigade members qualifications should include C.1.a(5)(b) C a physical examination for performing strenuous activity, and the training described in Position C.3.d.

8. The personnel responsible for the maintenance and C.1.a(5)(c) C testing of the fire protection systems should be qualified by training and experience for such work.

9. The personnel responsible for the training of the fire C.1.a(5)(d) C brigade should be qualified by training and experience for such work.

10. The following NFPA publications should be used for C.1.a(6) C guidance to develop the fire protection program; No. 4, No. 4A, No. 6, No. 7, No. 8, No. 27.

11. On sites where there is an operating reactor and C.1.a(7) C construction of modification of other units is underway, the superintendent of the operating plant should have a lead responsibility for site fire protection.

Fire Hazards Analysis

12. The fire hazards analysis should demonstrate that the C.1.b C See Sections 9A.4 and 9A.5.

plant will maintain the ability to perform safe shutdown functions and minimize radioactive releases to the environment in the event of a fire.

13. The fire hazards analysis should be performed by fire C.1.b C protection and reactor systems engineers to (1) consider potential in situ and transient fire hazards: (2) determine the consequences of a fire in any location in the plant; and (3) specify measures for fire prevention, detection, suppression, and containment.

14. Fires involving facilities shared between units should C.1.b C Fires are postulated to occur in structures be considered. such as the control structure and the spray pond pump structure that are common to both reactor units.

15. Fires due to man-made site-related events that have a C.1.b C See Section 9A.3.1.2.

reasonable probability of occurring and affecting more than one reactor unit should be considered.

APPENDIX 9A 9A-13 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS

16. Establishment of three levels of fire damage limits C.1.b C according to safety function (hot shutdown; cold shutdown; design basis accidents.)

17. The fire hazards analysis should separately identify C.1.b C hazards and provide appropriate protection in locations where safety-related losses can occur.

Fire Suppression System Design Basis

18. Total reliance should not be placed on a single fire C.1.c(1) C All automatic fire suppression systems are suppression system. Backup fire suppression capability backed up by two methods of manual should be provided. extinguishment (hose stations and portable extinguishers).

19. A single active failure or a crack in a moderate energy C.1.c(2) C See Section 9A.3.1.2.

line in the fire suppression system should not impair both the primary and backup fire suppression capability.

20. The fire suppression system should be capable of C.1.c(3) NC See item 155.

delivering water to manual hose stations located within hose reach of areas containing equipment required for safe shutdown following an SSE.

21. The fire protection systems should retain their original C.1.c(4) C See Section 9A.3.1.2 design capability for natural phenomena of less severity and greater frequency than the most severe natural phenomena.

22. The fire protection systems should retain their original C.1.c(4) NC See Section 9A.3.1.2 design capability for potential man -made site-related events that have a reasonable probability of occurring at a specific plant site.

23. The effects of lightning strikes should be included in C.1.c(4) C Lightning protection is pr ovided per NFPA the overall plant fire protection program. No. 78

24. The consequences of inadvertent operation or of a crack C.1.c(5) C See Section 9A.3.1.2.

in a moderate energy line in the fire suppression system should meet the guidelines sp ecified for moderate energy systems outside containment in SRP section 3.6.1.

Alternative or Dedicated Shutdown

25. Alternative or dedicated shutdown capability should be C.1.d C See item 20 of Section 9A.3.2.2.

provided where the protection of systems whose functions are required for a safe shutdown is not provided by established fire suppression methods or by Position C.5.b.

APPENDIX 9A 9A-14 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS Implementation of Fire Protection Programs

26. The fire protection program for buildings storing new C.1.e(1) C The fire protection program for the new reactor fuel and for adjacent fire areas that could fuel area will be completed and fully affect the fuel storage area should be fully operational operational before fuel is received at the before fuel is received at the site. Site.

27. The fire protection program for an entire reactor unit C.1.e(2) C should be fully operational prior to initial fuel loading in that reactor unit.

28. Special considerations for the fire protection program C.1.e(3) C See Section 9A.3.1.2.

on reactor sites where there is an operating reactor and construction or modification of other units is under way.

Administrative Controls

29. Establishment of administrative controls to maintain the C.2 C performance of the fire protection system and personnel.

Fire Brigade

30. The guidance in Regulatory Guide 1.101 should be C.3.a C followed as applicable.

31. Establishment of site brigade: minimum number of fire C.3.b C brigade members on each shift; qualification of fire brigade members; competence of brigade leader.

32. The minimum equipment provided for the brigade should C.3.c C consists of turnout coats, boots, gloves, hard hats, emergency communications equipment, portable ventilation equipment, and portable extinguishers.

33. Self-contained breathing apparatus using full -face C.3.c C See Section 9A.3.1.2.

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 personnel. At least 10 masks shall be available for fire brigade personnel. Control room personnel 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.

APPENDIX 9A 9A-15 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS At least two extra air bottles should be located onsite for each 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 compressors 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.

34. Recommendations for the fire brigade training program. C.3.d AC See Section 9A.3.1.2.

Quality Assurance Program

35. Establishment of quality assurance programs for the fire C.4 AC See Section 9A.3.1.2.

protection systems for safety -related areas; identification of specific criteria for QA programs.

Building Design

36. Fire barriers with a minimum rating of 3 ho urs should C.5.a(1)(a) C Structures housing safety-related systems be provided to separate safety-related systems from any are separated from nonsafety -related potential fires in nonsafety -related areas. structures by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire walls.

37. Fire barriers with a minimum rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months should C.5.a(1)(b) AC See Section 9A.3.1.2.

be provided to separate redundant divisions of safety-related systems from each other.

38. Fire barriers with a minimum rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months should C.5.a(1)(c) C Fire barriers rated for 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months are be provided to separate individual units on a multiunit provided to separate Unit 1 structures from site. Unit 2 structures. Those structures that are common to both reactor units (such as the control structure and the central portion of the turbine enclosure) are separated form the adjacent structures of both reactor enclosures by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire barriers.

39. Fire barriers should be provided within a single safety C.5.a(2) AC See Section 9A.3.1.2.

division to separate components or cabling that present a fire hazard to other safety -related components.

40. Openings through fire barriers for pipe, conduit, and C.5.a(3) AC See Section 9A.3.1.2.

cable trays which separate fire areas should be sealed or closed to provide a fire resistance rating equal to that required of the barrier.

APPENDIX 9A 9A-16 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS

41. Recommendations for internal sealing of con duits C.5.a(3) AC See Section 9A.3.1.2 penetrating fire barriers.

42. Fire barrier penetrations that must maintain C.5.a(3) C Fire-rated penetration seals that are also environmental isolation or pressure differentials should required to perform ot her barrier functions be qualified by test. (such as maintaining a pressure differential) are qualified by test for all the intended functions. The fire barrier function of a penetration seal is not required to be performed simultaneously with other barrier functions.

43. Penetration designs should utilize only noncombustible C.5.a(3) AC See Section 9A.3.1.2.

materials.

44. The penetration qualification tests should use the C.5.a(3) C The time-temperature exposure curve used in time-temperature exposure curve specified by ASTM E-119. qualification tests for penetration seals is a specified by ASTM E -119-73.

45. Acceptance criteria for penetration qualification tests. C.5.a(3) AC See Section 9A.3.1.2.

46. Penetration openings for ventilation systems should be C.5.a(4) AC See Section 9A.3.1.2.

protected by fire dampers having a rating equivalent to that required of the barrier.

47. Flexible air duct couplings in ventilation and filter C.5.a(4) C systems should be noncombustible.

48. Door openings in fire barriers should be protected with C.5.a(5) AC See Section 9A.3.1.2.

equivalently rated doors, frames, and hardware that have been tested and approved by a nationally recognized laboratory.

49. Fire doors should be self -closing or provided with C.5.a(5) AC See Item 40 of Section 9A.3.2.2.

closing mechanisms.

50. Fire doors should be inspected semiannually to verify C.5.a(5) AC See Item 41 of Section 9A.3.2.1.

that automatic hold open, release, and closing mechanisms and latches are operable.

51. Alternative means for ensuring that fire doors protect C.5.a(5) C See Item 42 of Section 9A.3.2.2.

the door opening as required in case of fire.

52. The fire brigade leader should have ready access to keys C.5.a(5) C for any locked fire doors.

53. Areas protected by automatic total flooding gas C.5.a(5) C See Item 44 of Section 9A.3.2.1.

suppression systems should have electrically supervised self-closing fire doors or should satisfy option (a) above.

APPENDIX 9A 9A-17 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS

54. Personnel access routes and escape routes should be C.5.a(6) C All fire areas are provided with personnel provided for each fire area. access routes and escape routes.

55. Stairwells serving as escape routes, access routes for C.5.a(6) C Stairwells of the type described in the fire fighting, or access routes to areas containing guideline are each enclo sed by a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months equipment necessary for safe shutdown should be enclosed rated envelope consisting or either in masonry or concrete towers with a minimum fire rating reinforced concrete or concrete unit of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and self-closing Class B fire doors. masonry walls with a minimum thickness of 8 inches. Each door opening that is a part of this envelope is provided with a UL Class B fire door. All penetrations through the walls of the envelope are sealed using penetration seal details that are qualified for use in 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire barriers.

56. Fire exit routes should be clearly marked. C.5.a(7) C

57. Each cable spreading room should contain only one C.5.a(8) NC The cable spreading room for each reactor redundant safety division. unit contains all four divisions of safety-related cabling. Raceways containing the different divisions of cabling are separated from each other in accordance with Regulatory Guide 1.75. Cabling associated with the remote shutdown panel is not routed through the cable spreading room.

58. Cable spreading rooms should be separated from each C.5.a(8) C See Section 9A.3.1.2.

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

59. Interior wall and structural components, thermal C.5.a(9) AC See Section 9A.3.1.2.

insulation materials, radiation shielding materials, and soundproofing should be noncombustible.

60. Interior finishes should be noncombustible. C.5.a(9) AC See Section 9A.3.1.2.

61 Metal deck roof construction should be non -combustible C.5.a(10) C See Section 9A.3.1.2.

and listed as acceptable for fire in the UL Building Materials Directory, or listed as Class 1 in the Factory Mutual Approval Guide.

62. Suspended ceilings and their supports should be of C.5.a(11) C See Section 9A.3.1.2.

noncombustible construction.

63. Concealed spaces should be devoid of combustibles except C.5.a(11) AC See Section 9A.3.1.2.

as noted in Position C.6.b.

APPENDIX 9A 9A-18 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS

64. Transformers installed inside fire areas containing C.5.a(12) C All indoor transformers are either air safety-related systems should be of the dry -type or cooled, dry-type, or cooled by insulated and cooled with noncombustible liquid. noncombustible gases.

65. Outdoor oil-filled transformers should have oil spill C.5.a(13) C See Section 9A.3.1.2.

confinement features or drainage away from the buildings.

66. Outdoor oil-filled transformers should be located at C.5.a(13) AC See Section 9A.3.1.2.

least 50 feet distant from the building, or building walls within 50 feet of oil-filled transformers should be without openings and have a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire resistance rating.

67. Floor drains sized to remove expected fire fighting C.5.a(14) AC See Section 9A.3.1.2 water flow without flooding safety -related equipment should be provided in areas where fixed water fire suppression systems are installed.

68. Floor drains should be provided in areas where hand hose C.5.a(14) AC See Section 9A.3.1.2.

lines may be used if such fire fighting water could cause unacceptable damage to safety -related equipment.

69. Where gas suppression systems are installed, the drains C.5.a(14) C See Section 9A.3.1.2.

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.

70. Drains in areas containing combustible liquids should C.5.a(14) C See Section 9A.3.1.2.

have provisions for preventing the backflow of combustible liquids to safety -related areas through the interconnected drain systems.

71. Water drainage from areas that may contain C.5.a(14) C Potentially radioactive liquid wastes are radioactivity should be collected, sampled, and collected and monitored prior to discharge.

analyzed before discharge to the environment.

Safe Shutdown Capability

72. Fire damage should be limited so that one train of C.5.b(1) C systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station is free of fire damage.

73. Fire damage should be limited so that one train of C.5.b(1) C systems necessary to achieve and maintain cold shutdown conditions from either the control room or emergency control station can be repaired wi thin 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

APPENDIX 9A 9A-19 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS

74. Alternative means of ensuring that one train of systems C.5.b(2) AC See Item 18 of Section 9A.3.2.2.

necessary to achieve and maintain hot shutdown is free of fire damage.

75. Provision of alternative or dedicated shutdown C.5.b(3) C See Item 20 of Section 9A.3.2.2 capability in certain fire areas.

76. Alternative or Dedication Shutdown Capability C.5.c C See Items 25 through 36 of Section 9A.3.2.

Control of Combustibles

77. Safety-related systems should be separated from C.5.d(1) C To the maximum extent possible, significant combustible materials where possible; where not concentrations of combustible materials are possible, special protection should be provided to located outside structures containing prevent a fire from defeating safety system safety-related components. In those cases function. for which this is not possible, such as the standby diesel generator fuel oil day tanks, special fire protection consisting of automatic fire suppression systems and/or construction capable of withstanding a fire is provided.

78. Bulk gas storage (compressed or cryogenic) should not C.5.d(2) NC See Section 9A.3.1.2.

be permitted inside structures housing safety -related equipment. Flammable gases should be stored outdoors or in separate detached buildings.

79. High pressure gas storage containers should be located C.5.d(2) NC See Section 9A.3.1.2.

with the long axis parallel to building walls.

80. Use of compressed gases inside buildings should be C.5.d(2) C See Section 9A.3.1.2.

controlled.

81. The use of plastic materials should be minimized. C.5.d(3) C See Section 9A.3.1.2.

Halogenated plastics such as PVC and neoprene should be used only when substitute noncombustible materials are not available.

82. Storage of flammable liquids should comply with NFPA C.5.d(4) C Liquid fuels are stored either in

30. aboveground tanks that have been provided with suitable fire barriers or in underground tanks.

83. Hydrogen lines in safety-related areas should be either C.5.d(5) C Hydrogen lines in safety-related areas are designed to seismic Class I requirements, or sleeved, designed to seismic Class I requirements.

or equipped with excess flow valves.

APPENDIX 9A 9A-20 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS Electrical Cable Construction, Cable Trays, and Cable Penetrations

84. Only metal should be used for cable trays. C.5.e(1) C Cable trays are of all -metal construction.

85. Only metallic tubing should be used for conduit. C.5.e(1) NC See Section 9A.3.1.2.

Thin-wall metallic tubing should not be used.

86. Flexible metallic tubing should only be used in short C.5.e(1) C Flexible metallic tubing used at raceway lengths to connect components to equipment. connections to components is limited to 5 feet in length.

87. Other raceways should be made of noncombustible C.5.e(2) C Gutter-type raceways are of all-metal materials. construction.

88. Redundant safety-related cable systems outside the cable C.5.e(2) AC See Section 9A.3.1.2.

spreading room should be separated from each other and from potential fire exposure hazards in nonsafety-related areas by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire barriers.

89. These cable trays should be provided with continuous C.5.e(2) NC See Section 9A.3.1.2.

line-type heat detectors.

90. Cables should be designed to allow wetting down with C.5.e(2) C Cable insulating systems include fire suppression water without electrical faulting. proprietary jacketing materials designed for wetting.

91. Redundant safety-related cable trays outside the cable C.5.e(2) C spreading room should be accessible for manual fire fighting. Manual hose stations and portable hand extinguishers should be provided.

92. Safety-related cable trays of a single division that are C.5.e(2) AC See Section 9A.3.1.2.

separated from redundant divisions by a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire barrier and are accessible for manual fire fighting should be protected from the effects of a potential exposure fire by providing automatic water suppression.

93. Safety-related cable trays that are not accessible for C.5.e(2) NA Safety-related cable trays are not routed manual fire fighting should be protected by an automatic through areas that are inaccessible for water systems. Manual fire fighting.

94. Safety-related cable trays that are not separated fro m C.5.e(2) AC See Section 9A.3.1.2 and Item 92 above.

redundant divisions by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire barriers should be protected by automatic water suppression systems.

95. The capability to achieve safe shutdown considering the C.5.e(2) C See Section 9A.5.

effects of a fire involving fixed and transient combustibles should be evaluated with and without actuation of the automatic suppression system.

APPENDIX 9A 9A-21 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS

96. Electric cable construction should pass the flame test C.5.e(3) AC See Section 9A.3.1.2.

in IEEE 383.

97. Cable raceways should be used only for cables. C.5.e(4) C

98. Miscellaneous storage and piping for combustible liquids C.5.e(5) C See Section 9A.3.1.2.

or gases should not create a potential exposure hazard to safety-related systems.

Ventilation

99. Smoke and corrosive gases should be discha rged directly C.5.f(1) AC See Section 9A.3.1.2.

outside to an area that will not affect safety -related plant areas.

100. To facilitate manual fire fighting, separate smoke and C.5.f(1) NC See Section 9A.3.1.2.

heat vents should be provided in certain areas.

101. Release of smoke and gases containing radioactive C.5.f(2) C See Section 9A.3.1.2.

materials to the environment should be monitored.

102. Any ventilation system designed to exhaust potentially C.5.f(2) AC See Section 9A.3.1.2.

radioactive smoke or gases should be evaluated to ensure that inadvertent operation or single failures will not violate the radiologically controlled areas of the plant.

103. The power supply and controls for mechanical C.5.f(3) AC See Section 9A.3.1.2.

ventilation systems should be run outside the fire areas served by the system.

104. Engineered safety feature filters should be protected C.5.f(4) C See Section 9A.3.1.2.

in accordance with the guidelines of Regulatory Guide 1.52.

105. Air intakes for ventilation systems serving areas C.5.f(5) C Air intakes serving areas which contain containing safety-related equipment should be located safety-related equipment are remote from remote from the exhaust air outlets and smoke vents of exhaust and smoke outlets of other fire other fire areas. areas.

106. Stairwells should be designed to minimize smoke C.5.f(6) C Stair towers are provided with self-closing infiltration during a fire. doors, which will minimize smoke infiltration during a fire.

107. Where total flooding gas extinguishing systems are C.5.f(7) C See Section 9A.3.1.2.

used, ventilation dampers, should be controlled in accordance with NFPA 12 and NFPA 12A.

APPENDIX 9A 9A-22 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS Lighting and Communication 108. Fixed self-contained lighting units with individual 8 C.5.g(1) AC See Item 108 of Section 9A.3.1.2, and hour battery power supplies should be provided in areas Item 23 of Section 9A.3.2.2.

that must be manned for safe shutdown and for access and egress routes to and from all fire areas.

109. Sealed beam battery-powered portable hand lights should C.5.g(2) C Portable lights are provided be provided for emergency use.

110. Fixed emergency communications independent of the C.5.g(3) AC See Section 9A.3.1.2.

normal plant communication system should be installed at preselected stations.

111. A portable radio communications system should be C.5.g(4) AC See Section 9A.3.1.2.

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

Fire Detection 112. Detection systems should be provided for all areas that C.6.a(1) AC See Section 9A.3.1.2.

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

113. Fire detection systems should comply with the C.6.a(2) AC The fire and smoke detection system is requirements of Class A systems as defined i n NFPA 72D partially Class A and partially Class B, as and Class I circuits as defined in NFPA 70. described in Section 9A.2.12. (Class A and Class B systems are defined in the 1975 edition of NFPA 72D.)

114. Fire detectors should be sele cted and installed in C.6.a(3) C See Section 9A.2.12.

accordance with NFPA 72E.

115. Testing of pulsed line-type heat detectors should C.6.a(3) NA Pulsed line-type detectors are not used in demonstrate that the frequencies used will not affect the plant.

the actuation of protective relays in other plant systems.

116. Fire detection systems should give audible and visual C.6.a(4) C alarm and annunciation in the control room.

APPENDIX 9A 9A-23 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS 117. Where zoned detection systems are used in a given fire C.6.a(4) C A coding system has been established for area, local means should be provided to identify which all fire alarms in the plant so that the zone has actuated. location of a fire can be determined from the sound of the alarm. A list of these codes and their corresponding detection areas will be posted at each fire alarm pull station.

118. Local audible alarms should sound in the fire area. C.6.a(4) C Fire alarms are annunciated throughout the plant, as well as in the local area in which a fire detector has been actuated.

119. Fire alarms should be distinctive and unique so they C.6.a(5) C will not be confused with any other plant system alarms.

120. Primary and secondary power supplies which satisfies the C.6.a(6) AC See Section 9A.3.1.2.

provisions of section 2220 of NFPA 72D should be provided for the fire detection system and for electrically operated control valves for automatic suppression systems.

Fire Protection Water Supply Systems 121. An underground yard fire main loop should be installed C.6.b(1) C An underground yard fire main loop has been to furnish anticipated water requirements. provided and is in compliance with NFPA 24.

122. Type of pipe and water treatment should be design C.6.b(1) C The yard fire main loop utilizes consideration with tuberculation as one of the cement-lined cast iron pipe to reduce parameters. tuberculation. Water used fire protection service meets the requirements of NFPA 22 and does not require treatment.

123. Means of inspecting and flushing the systems should be C.6.b(1) C Following its installation, the yard fire provided. main loop was flushed and tested in accordance with NFPA 24 (1973), sections 98 and 99. Flushing of the loop is accomplished through the use of sectional control valves to direct the flow and yard hydrants to serve as discharge points.

124. Approved visually indicating sectional control valves C.6.b(2) C Postindicator valves provided for should be provided to isolate portions of the main for sectionalized control and isolation of maintenance or repair. portions of the yard fire main loop.

125 Valves should be installed to permit isolation of C.6.b(3) C A key-operated gate valve with a curb box outside hydrants from the fire main for maintenance or is provided in each lateral from the yard repair without interrupting the water supply to fire main loop to a fire hydrant.

automatic or manual fire suppression system.

APPENDIX 9A 9A-24 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS 126. The fire main system piping should be separate from C.6.b(4) C See Section 9A.3.1.2.

service or sanitary water system piping.

127. A common yard fire main loop may serve multiunit nuclear C.6.b(5) C The yard fire main loop is common to both power plant sites if cross -connected between units. reactor units. The loop is cross -connected Sectional control valves should permit maintaining between units and provided with sectional independence of the loop around each unit. control valves.

128. A sufficient number of pumps should be provided to C.6.b(6) C Two fire pumps (one diesel -driven and one ensure that 100% capacity will be available assuming electric motor-driven) are provided, each failure of the largest pump or a LOOP. capable of supplying 100% of the systems flow requirements.

129. Individual fire pump connections to the yard fire main C.6.b(6) C loop should be separated with sectionalizing valves between connections.

130. Each pump and its driver and controls should be C.6.b(60 C separated from the remaining fire pumps by a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire wall.

131. The fuel for the diesel fire pump should be separated C.6.b(6) C The diesel oil day tank is located in a so that it does not provide a fire source exposing curbed area within the diesel -driven fire safety-related equipment. pump compartment. This compartment is located in the circulating water pump structure, which is separated from all structures containing safety -related equipment.

132. Alarms indicating pump running, driver availability, C.6.b(6) AC Pump running, driver availability, and failure to start, and low fire main pressure should be failure to start are annunciated in the provided in the control room. control room. Fire main pressure is indicated in the control room but not annunciated.

133. The fire pump installation should conform to NFPA 20. C.6.b(6) C 134. Outside manual hose installation should be sufficient C.6.b(7) AC Hydrants are space between 250 rod and 300 to provide an effective hose stream to any onsite feet apart along the fire main loop.

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

135. Recommendations for hose houses and hose carts. C.6.b(7) AC See Section 9A.3.1.2.

136. Threads compatible with those used by local fire C.6.b(8) C departments should be provided on all hydrants, hose couplings, and standpipe risers.

APPENDIX 9A 9A-25 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS 137. Two separate, reliable freshwater supplies should be C.6.b(9) C The cooling tower basins of the Unit 1 and provided. Unit 2 circulating water systems are used as the two sources of water for the fire pumps.

138. Recommendations for tanks used to supply fire protection C.6.b(9) NA Tanks are not utilized for fire protection water. Water supply.

139. Recommendations for tanks used to supply fire protection C.6.b(10) NA Tanks are not utilized for fire protection water. water supply.

140. The fire water supply should be based on the largest C.6.b(11) C See Section 9A.3.1.2.

expected flow rate for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , but not less than 300,000 gallons.

141. The fire water supply should be capable of delivering C.6.b(11) C In the event that a portion of the yard the design demand over the longest route of the water fire main loop is valved out of service, supply system. the fire pumps are capable of delive ring the design demand over the longest route of the water supply system.

142. Recommendations for freshwater lakes or ponds used to C.6.b(12) NA Lakes or ponds are not utilized for fire supply fire protection water. protection water supply.

143. Recommendations concerning use of other water systems C.6.b(13) NA The fire protection system and the ultimate for fire protection and the ultimate heat sink. heat sink do not share a common water supply.

144. Recommendations concerning us e of other water systems C.6.b(14) AC See Section 9A.3.1.2.

as the source of fire protection water.

145. Recommendations concerning connection of sprinkler C.6.c(1) C See Item 19.

systems and manual hose station standpipes to the yard fire main loop.

146. Each sprinkler and standpipe system should be equipped C.6.c(1) AC See Section 9A.3.1.2.

with OS&Y gate valve or other approved shutoff valve and water flow alarm.

147. Safety-related equipment should be protected from C.6.c(1) AC See Section 9A.3.1.2.

sprinkler discharge if such discharge could result in unacceptable damage to the equipment.

148. Control and sectionalizing valves in the fire water C.6.c(2) C See Section 9A.3.1.2.

systems should be electrically supervised (with indication in the control room) or administratively controlled.

149. All valves in the fire protection systems should be C.6.c(2) C periodically checked to verify position.

APPENDIX 9A 9A-26 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS 150. Fixed water extinguishing systems should conform to C.6.c(3) AC See Section 9A.3.1.2.

requirements of NFPA 13 and NFPA 15.

151. Recommendations for interior manual hose installations. C.6.c(4) NC See Section 9A.3.1.2.

152. Individual standpipes should be at least 4 inches in C.6.c(4) AC See Section 9A.3.1.2.

diameter for multiple hose connections and 2.5 inches in diameter for single hose connections.

153. Standpipe and hose station installations should follow C.6.c(4) C the requirements of NFPA 14.

154. Hose stations should be located as dictated by the fire C.6.c(4) C hazards analysis to facilitate access and use for fire fighting operations.

155. Recommendations concerning seismic design of standpipes C.6.c(4) NC See Section 9A.3.1.2.

and hose connections.

156. Recommendations concerning hose nozzle selection. C.6.c(5) C 157. Fire hose should be hydrostatically tested in C.6.c(6) C accordance with NFPA 1962. Hose stored in outside hose houses should be tested annually. Interior standpipe houses should be tested every 3 years.

158. Consideration of foam suppression systems for flammable C.6.c(7) C See Section 9A.3.1.2.

liquid fires.

Halon Suppression Systems 159. Halon fire extinguishing systems should comply with C.6.d C Design and installation of the Halon 1301 NFPA 12A ad NFPA 12B. Only UL -Listed or FM-approved system is in accordance with NFPA 12A.

agents should be used.

160. Provisions for locally disarming automatic Halon C.6.d NC Administrative controls do not exist systems should be key -locked and under administrative permitting disarming of the Halon system.

control. Automatic Halon systems should not be disarmed unless controls as described in Position C.2.j are provided.

161. Preventive maintenance and testing of the systems, C.6.d C including check-weighing of the Halon cylinders, should be done at least quarterly.

APPENDIX 9A 9A-27 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS 162. Considerations for design of Halon suppression systems. C.6.d C See Section 9A.3.1.2.

Carbon Dioxide Suppression Systems 163. Carbon dioxide extinguishing systems should comply C.6.e NA the requirements of NFPA 12.

164. Carbon dioxide extinguishing systems should comply with C.6.e NA with a predischarge alarm system and a discharge delay to permit personnel egress.

165. Provisions for locally disarming automatic carbon C.6.e NA dioxide systems should be key-locked and under administrative control. The systems should not be disarmed unless controls as described in Position C.2.c are provided.

166. Considerations for design of carbon dioxide suppression C.6.e NA systems.

167. Fire extinguishers should be provided in areas that C.6.f C See Section 9A.3.1.2 contain, or could present a fire exposure hazard to, safety-related equipment in accordance with NFPA 10.

168. Dry chemical extinguishers should be installed with due C.6.f C consideration given to possible adverse effects on safety-related equipment.

Primary and Secondary Containment 169. Fire protection for the primary and secondary C.7.a(1) C Fire hazards have been identified, as containment areas should be provided for hazards discussed in Section 9A.4, and fire identified by the fire hazards analysis. suppression system have been provided CMEB 9.5-1 APPENDIX 9A 9A-28 REV. 20, SEPTEMBER 2020

LGS UFSAR NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS accordingly. The types and locations of suppression systems are identified in Table 9A.1 and Figures 9A -4 through 9A -12.

170. Because of the general inaccessibility of primary C.7.a(1) NC See Section 9A.3.1.2.

containment during normal plant operation, protection should be provided by automatic fixed systems.

171. Operation of the fire protection systems should not C.7.a(1)(a) C The fire protection systems does not compromise the integrity of the containment or other penetrate the primary containment boundary.

safety-related systems. Also see Item 24.

172. Recommendations for protection of safety -related cables C.7.a(1)(b) NA The primary containment is inerted with and equipment inside noninerted containments. nitrogen during reactor operation.

173. Recommendations concerning fire detection inside the C.7.a(1)(c) NC See Section 9A.3.1.2.

primary containment.

174. For BWR drywells, standpipe and hose stations should be C.7.a(1)(d) C The hose reels located nearest the drywell placed outside the dry well with adequate lengths of entrances are equipped with a 100 foot hose, no longer than 100 feet, to reach any location length of fire hose. To supplement this inside the drywell with an effective hose stream. hose length, a hose station equipped with enough hose to reach any location within the drywell is located near each drywell entrance.

175. Recommendations for reactor coolant pump oil collection C.7.a(1)(e) NA The primary containment is inerted with system in noninerted containments. nitrogen during normal reactor operation.

176. For secondary containment areas, cable fire hazards C.7.a(1)(f) -- See Items 88 through 95.

that could affect safety should be protected as described in Position C.5.e(2).

177. Self-contained breathing apparatus should be provided C.7.a(2) C See Item 33.

near the containment entrances for fire fighting and damage control personnel. These units should be independent of any breathing apparatus provided for general plant activities.

Control Room Complex 178. The control room complex should be separated from other C.7.b C The control room is separated from other areas of the plant by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire barriers. parts of the control structure by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated floor slabs at el 269 and el 289.

Three hour rated walls at the north, south, east, and west sides of the control room separate it from the reactor enclosures and turbine enclosures.

APPENDIX 9A 9A-29 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS 179. Recommendations concerning peripheral rooms in the C.7.b NC See Section 9A.3.1.2.

control room complex.

180. Recommendations concerning the use of Halon and carbon C.7.b NA The peripheral rooms adjacent to the dioxide flooding systems in the peripheral rooms. control room are not provided with Halon or carbon dioxide flooding systems.

181. Recommendations concerning manual fire fighting C.7.b C See Section 9A.3.1.2.

capability in the control room.

182. Recommendations concerning fire detection in the C.7.b AC See Section 9A.3.1.2.

control room.

183. Breathing apparatus for control room operators should C.7.b C See Item 33.

be readily available.

184. Recommendations concerning control room ventilat ion. C.7.b C See Section 9A.3.1.2.

185. All cables that enter the control room should terminate C.7.b C in the control room.

186. Cables in under-floor and ceiling spaces should meet C.7.b C See Section 9A.3.1.2.

the separation criteria necessary for fire protection.

187. Air handling functions should be ducted separately from C.7.b C The space above the suspended ceiling in cable runs in such spaces. the control room is not used as an air plenum for ventilation of the control room.

Ventilation air is deducted through the space above the suspended ceiling.

188. Fully enclosed electrical raceways located in under - C.7.b C None of the fully enclosed raceways in the floor and ceiling spaces, if over 1 square foot in space above the suspended ceiling in the cross-sectional area, should have automatic fire control room has a cross -sectional area suppression inside. exceeding 1 square foot. The raceways in the raised flooring of the auxiliary equipment room are provided with an automatic Halon suppression system, as described in Section 9A.2.9.

189. Recommendations concerning automatic fire suppression C.7.b AC See Section 9A.3.1.2.

in under-floor and ceiling spaces.

190. There should be no carpetin g in the control room. C.7.b NC See Section 9A.3.1.2.

Cable Spreading Room 191. Recommendations concerning automatic fire suppression C.7.c C See Section 9A.3.1.2.

in the cable spreading room.

APPENDIX 9A 9A-30 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS 192. Open-head deluge and open directional spray systems C.7.c NA Open-head water suppression systems are not should be zoned. used in the cable spreading room.

193. Cable spreading rooms should have at least two remote C.7.c(1) C and separate entrances for access by fire brigade personnel.

194. Cable spreading rooms should have an aisle separation C.7.c(2) NC Cable trays in the cable spreading rooms between tray stacks at least 3 feet wide and 8 feet are arranged to provide aisleways with a high. minimum headroom approximately 6.5 feet high and and a minimum width between tray stacks of approximately 3 feet. A t certain locations, structural supports for the cable trays reduce the aisle width to a minimum of 17 inches. All points in the cable spreading rooms can be reached by an effective hose stream.

195. Cable spreading rooms should have hose stations and C.7.c(3) C The locations of hose stations in the portable extinguishers installed immediately outside the vicinity of the cable spreading rooms are room. shown in Figure 9A.7.

196. Cable spreading rooms should have area smoke detection. C.7.c(4) C The fire and smoke detection system is described in Section 9A.2.12. The number of detectors located in each fire area is listed in Table 9A.1.

197. Cable spreading rooms should have continuous line -type C.7.c(5) NC Continuous line-type heat detectors are not heat detectors for cable trays inside the cable used in cable trays. Smoke detectors are spreading room. provided in the cable spreading room (as specified in Table 9A-1) and will provide early warning for cable tray fires occurring in the cable spreading room.

See Item 89 for further discussion.

198. Drains to remove fire-fighting water should be provided. C.7.c C 199. When gas systems are installed, drains should have C.7.c NA adequate seals or the gas extinguishing system should be sized to compensate for losses through the drains.

200. A separate cable spreading room should be provided for C.7.c NC See Item 57.

each redundant division.

201. Cable spreading rooms should not be shared between C.7.c C Each reactor unit is provided with its own reactors. separate cable spreading room.

202. Each cable spreading room should be separated from the C.7.c C See Item 58 of Section 9A.3.1.2.

others and from other areas of the plant by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire barriers.

APPENDIX 9A 9A-31 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS 203. The ventilation system for the cable spreading room C.7.c NA should be designed to isolate the area upon actuat ion of the gas extinguishing system.

204. Separate manually actuated smoke venting that is C.7.c C Portable smoke ejectors are used to clear operable from outside the room should be provided for smoke and toxic gases from the cable the cable spreading room. spreading rooms.

Plant Computer Rooms 205. Recommendations concerning fire protection for computers C.7.d NA The plant computer is not safety -related.

performing safety-related functions.

206. Nonsafety-related computers outside the control room C.7.d AC The plant computer is nonsafety -related and should be separated from safety -related areas by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months is located in the auxiliary equipment room.

fire barriers and should be protected as needed to The auxiliary equipment room is separated prevent damage to safety -related equipment. from other areas of the plant by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire barriers, but the computer is not separated (other than by distance) from safety-related panels in the auxiliary equipment room. Automatic fire suppression for the raised flooring in the auxiliary equipment room is discussed in Section 9A.2.9.

Switchgear Rooms 207. Switchgear rooms containing safety -related equipment C.7.e AC The safety-related switchgear rooms at el should be separated from the remainder of the plant by 239 in the control structure are separated 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire barriers. Redundant switchgear safety from each other and from the remaining divisions should be separated from each other by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months areas of the plant by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire fire barriers. walls. The concrete slab above these rooms is a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated barrier, and the slab below the room is capable of a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire rating with the exception of exposed structural steel members supporting the slabs.

208. Automatic fire detectors should alarm and annunciate in C.7.e C Each safety-related switchgear room is the control room and alarm locally. provided with smoke and heat detectors that annunciate in the control room and alarm locally.

APPENDIX 9A 9A-32 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS 209. Fire hose stations and portable fire extinguishers C.7.e C should be readily available outside the switchgear rooms.

210. Drains should be provided to prevent water accumulation C.7.e AC See Section 9A.3.1.2.

from damaging safety-related equipment.

211. Remote manually actuated ventilation should be provided C.7.e NC Ventilation features separate from the for venting smoke when manual fire suppression effort normal ventilation system are not provided is needed. for the switchgear rooms. Smoke removal can be accomplished using portable exhaust fans, if necessary.

Remote Safety-Related Panels 212. Recommendations concerning separation and electrical C.7.f AC See Section 9A.3.1.2.

isolation of remote safety -related panels.

213. The general area housing remote safety -related panels C.7.f C should be provided with automatic fire detectors that alarm locally and alarm and annunciate in the control room. Combustible materials should be controlled and limited to those required for operation. Portable extinguishers and manual hose stations sh ould be readily available in the general area.

Safety-Related Battery Rooms 214. Safety-related battery rooms should be separated from C.7.g AC The safety-related battery room are each other and other areas of the plant by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated located in the control structure. These fire barriers. rooms are separated from each other and from the remaining areas of the plant by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire walls. The floor slabs above and below the battery rooms are capable of 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire ratings with the exception of exposed structural steel members supporting the concrete slabs.

215. DC switchgear and inverters should not be located in C.7.g AC See section 3.1.2.

safety-related battery rooms.

216. Automatic fire detecti on should be provided to C.7.g C Each safety-related battery room is annunciate in the control room and alarm locally. provided with smoke and heat detectors that annunciate in the control room and alarm locally.

APPENDIX 9A 9A-33 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS 217. Ventilation system in the battery rooms should be C.7.g C See Section 9A.3.1.2.

capable of maintaining the hydrogen concentration below 2%.

218. Loss of ventilation should be alarmed in the control C.7.g C See Section 9A.3.1.2.

room.

219. Portable extinguishers and manual hose stations should C.7.g C be readily available outside the battery rooms.

Turbine Building 220. The turbine building should be separated from adjacent C.7.h C The turbine enclosure is separated from the structures containing safety -related equipment by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months reactor enclosure and control structure by fire barriers. 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire walls.

221. The fire barriers should be designed so as to maintain C.7.h C See Section 9A.3.1.2.

structural integrity in the event of collapse of the turbine structure.

222. Openings and penetration in the fire barrier should be C.7.h C See Section 9A.3.1.2.

minimized and should not be located where the turbine oil system or generator hydrogen cooling system creates a fire exposure hazard to the barrier.

Diesel Generator Areas 223. Diesel generators should be separated from each othe r C.7.i C The individual diesel generator cells, each and from other areas of the plant by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire of which encloses a single diesel barriers. generator, are separated from adjacent fire areas by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated barriers consisting of 24 inch thick reinforced concrete walls and 18 inch thick reinforced concrete slabs. Each door opening in the 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated walls is provided with a UL Class A fire door. All penetration through the 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated walls and floor slabs are sealed using penetration seal details that are qualified for use in 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire barriers.

APPENDIX 9A 9A-34 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS 224. Automatic fire suppression should be installed to combat C.7.i AC See Section 9A.3.1.2.

diesel generator or lubricating oil fires. Such systems should be designed for operation when the diesel is running without affecting the diesel.

225. Automatic fire detection should be provided to C.7.i C annunciate in the control room and alarm locally.

226. Portable extinguishers and manual hose stations should C.7.i C Portable extinguishers are available be readily available outside the area. outside the diesel generator cells. Fire hydrants located in the yard can reach any area of the diesel generator cells.

227. Drainage for fire fighting water and means for local C.7.i AC See Section 9A.3.1.2.

manual venting of smoke should be provided.

228. Day tanks with total capacity up to 1100 gallons are C.7.i C The day tank for each diesel generator has permitted in the diesel generator area under specified a capacity of 850 gallons.

conditions.

229. The day tank should be located in a separated enclosures C.7.i C The day tank for each diesel generator is with a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire rating. located in a vault that is separated from the remainder of the diesel generator cell by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire walls.

230. The day tank enclosures should be capable of containi ng C.7.i C the entire contents of the tank.

231. The day tank enclosure should be protected by an C.7.i C The preaction sprinkler system provided in automatic fire suppression system. each diesel generator cell includes coverage of the day tank vault.

Diesel Fuel Oil Storage Areas 232. Recommendations concerning diesel fuel oil tanks. C.7.j C Each diesel generator is provided with a diesel fuel oil storage tank that has a capacity of 41,500 gallons. All eight tanks are located adjacent to each other and are buried underground.

233. Above-ground tanks should be protected by an automatic C.7.j NA See Item 232.

fire suppression system.

APPENDIX 9A 9A-35 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS Safety Related Pumps 234. Pump houses and rooms housing redundant safety -related C.7.k C The safety-related pump compartments pump trains should be separated from each other and from located at el 177 in the reactor enclosure other areas of the plant by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire barriers. are separated from each other and from other areas of the plant by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire walls. The spray pond pump structure is located remote from other plant structures, and the two divisions of pu mps within the structure are separated by a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire wall.

235. These rooms should be protected by automatic fire C.7.k C The HPCI compartment and the RCIC pump suppression unless a fire hazards analysis can compartment are protecte d by automatic demonstrate that a fire will not endanger equipment preaction sprinkler systems. Fires required for safe shutdown. originating in other safety -related pump compartments would not endanger other safety-related equipment required for safe shutdown, as discussed in Section 9A.5.

236. These rooms should be provided with automatic fire C.7.k C detection to annunciate in the control room and alarm locally.

237. Portable extinguishers and manual hose stations should C.7.k NC Portable extinguishers are provided for use be readily accessible. in all areas housing safety-related pumps.

Manual hose stations are provided for use in all areas housing safety-related pumps, except for the spray pond pump structure.

In consideration of the low combustible loading in the spray pond pump structure, portable extinguishers are deemed adequate to control and extinguish a fire at any pump.

238. Floor drains should be provided to prevent water C.7.k C accumulation from damaging safety-related equipment.

239. Provisions should be made for manual control of the C.7.k C The ventilation systems in areas housing ventilation systems to facilitate smoke removal. safety-related pumps are provided with controls that are sufficient to permit manual control of the ventilation as necessary to facilitate smoke removal.

240. Recommendations for fire protection of the new fuel C.7.l NA/AC The normal storage area for new fuel is the area. spent fuel pool. Prior to plant operation and during the initial phases of plant operation, new fuel may be stored in a temporary outdoor storage area. Fire protection for this temporary new fuel storage area will be provided in accordance with guidelines established by ANI.

APPENDIX 9A 9A-36 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS Spent Fuel Pool Area 241. Protection for the spent fuel pool area should be C.7.m C Hose stations and portable extinguishers provided by hose stations and portable extinguishers. are located near the spent fuel pool.

242. Automatic fire detection should be provided to C.7.m NC See Section 9A.3.1.2, item 112.j.

annunciate in the control room and to a larm locally.

Radwaste and Decontamination Areas 243. Fire barriers, automatic fire suppression and detection, C.7.n C See Section 9A.3.1.2.

and ventilation controls should be provided.

Safety-Related Water Tanks 244. Fire protection provisions f or safety-related water C.7.o NA The plant has no safety -related water tanks. tanks.

Records Storage Areas 245. Records storage areas should be so located and protected C.7.p C that a fire in these areas does not expose safety-related systems or equipment.

Cooling Towers 246. Cooling towers should be of noncombustible construction C.7.q C The cooling towers are of noncombustible or so located and protected that a fire will not construction except for the fill material, adversely affect any safety-related systems or which is polyvinyl chloride. No equipment. safety-related structures or systems are located near the cooling towers such that they could be affected by a fire in the cooling towers.

247. Cooling towers should be of noncombustible construction C.7.q AC See Section 9A.3.1.2.

when the basins are used for the ultimate heat sink or for the fire protection water supply.

Miscellaneous Areas 248. Location and protection of miscellaneous areas. C.7.r C See Section 9A.3.1.2.

APPENDIX 9A 9A-37 REV. 20, SEPTEMBER 2020

LGS UFSAR CMEB 9.5-1 NO. CMEB 9.5-1 GUIDELINE ITEM NO. COMPARISON REMARKS Storage of Acetylene/Oxygen Fuel Gases 249. Gas cylinder storage locations should not be in areas C.8.a C Compressed gas storage cylinders for that contain or expose safety-related equipment or the welding are located outdoors, away from fire protection systems that serve those safety -related safety-related components.

areas.

250. A permit system should be required to use this equipment C.8.a C in safety-related areas of the plant.

Storage Areas for Ion Exchange Resins 251. Unused ion exchange resin s should not be stored in areas C.8.b AC Storage areas for dry ion exchange resins that contain or expose safety-related equipment. in safety-related equipment areas utilize approved metal storage containers.

Hazardous Chemicals 252. Hazardous chemicals should not be stored in areas that C.8.c AC Procedural controls exist to ensure contain or expose safety -related equipment. hazardous chemical storage in safety -

related areas do not pose a fire risk.

Materials Containing Radioactivity 253. Materials that collect and contain radioactivity should C.8.d C be stored in closed metal tanks or containers that are located in areas free from ignition sources or combustibles.

254. These materials should be protected from expos ure to C.8.d C fires in adjacent areas.

255. Consideration should be given to requirements for C.8.d C Provisions for accommodating decay heat are removal of decay heat from entrained radioactive considered when selecting containers.

Materials.

APPENDIX 9A 9A-38 REV. 20, SEPTEMBER 2020

LGS UFSAR 9A.3.1.2 Explanatory Notes for Comparison to Branch Technical Position CMEB 9.5-1 Item 6 BTP Guideline The position responsible for formulation and implementation of the fire protection program should have within his organization or as a consultant a fire protection engineer who is a graduate of an engineering curriculum of accepted standing and shall have completed not less than 6 years of engineering attainment indicative of growth in engineering competency 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.

LGS Design The Vice President, LGS, is responsible for the formulation and implementation of the fire protection program. In this capacity, he has access to the services of corporate support personnel, other Exelon sites, or vendors as necessary in the capacity of a fire protection engineer. The individual meets the requirements for membership in the Society of Fire Protection Engineers (i.e.,

a graduate of an engineering curriculum of accepted standing and shall have completed not less than 6 years of engineering attainment indicative of growth in engineering competency and achievement, 3 years of which shall have been in responsible charge of fire protection work).

In addition, fire protection consultants are available to assist in design and review tasks as required.

Item 15 BTP Guideline Fires involving facilities shared 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.

LGS Design The control structure, the spray pond pump structure, and the radwaste enclosure are common to the two reactor units. Fires are postulated to occur in these structures just as in other structures, and appropriate provisions are made for fire prevention, fire detection, and fire suppression.

For a discussion of fires due to man-made site-related events, refer to Item 22.

Item 19 BTP Guideline A single active failure or a crack in a moderate energy line (pipe) in the fire suppression system should not impair both the primary and backup fire suppression capability. For example, neither the failure of a fire pump, its power supply or controls, nor a crack in a moderate energy line in the fire suppression system, should result in loss of function of both sprinkler and hose standpipe systems in an area protected by such primary and backup systems.

APPENDIX 9A 9A-39 REV. 20, SEPTEMBER 2020

LGS UFSAR LGS Design As described in Section 9A.2.1.2, fire water is supplied by two redundant pumps, each of which is capable of providing the design fire protection system flow rate at the design pressure. Power for the motor-driven fire pump is provided from either of two independent offsite power sources. The controls for the diesel engine-driven fire pump are dc-operated and are powered from batteries which supply only the engine-driven fire pump. Therefore, no single failure of the power supplies or controls can affect both fire pumps.

If a crack should occur in the yard fire main loop, sectional isolation valves can be used to isolate the damaged portion of the loop without affecting the majority of the loop. There is no single active failure that could affect the operability of both the sprinkler systems and manual hose stations for a given area. The standpipes supplying water to the sprinklers and manual hose stations have been designed to minimize the probability of a moderate energy crack occurring in these portions of piping. The standpipes were designed in accordance with NFPA requirements, for which the materials and standards of construction are the same as for ANSI B31.1, "Power Piping." The standpipes were seismically analyzed for safe shutdown earthquake loads in order to verify piping integrity under such loads. In the unlikely event that a crack does occur in a standpipe that supplies water to sprinklers and hose stations serving the same area, such that the ability to achieve design flow rates for the sprinklers and hose stations is affected, an effective hose stream could be provided to the area from a hose station attached to the closest unaffected standpipe.

Item 21 BTP Guideline The fire protection systems should retain their original design capability for natural phenomena of less severity and greater frequency than the most severe natural phenomena (approximately once in 10 years) such as tornadoes, hurricanes, floods, ice storms, or small intensity earthquakes that are characteristic of the geographic region.

LGS Design The fire pumps, the yard fire main loop, distribution piping within structures, manual hose stations, and fixed suppression systems are conservatively designed so as to retain their operability following the occurrence of natural phenomena with severities corresponding to a recurrence interval of once in 10 years.

Item 22 BTP Guideline The fire protection systems should retain their original design capability for 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.

LGS Design Transportation activities taking place near LGS, and the potential for accidents affecting the plant, are discussed in Section 2.2. As indicated in Section 2.2.2.4, there is no commercial traffic on the Schuylkill River in the vicinity of the site. As discussed in Section 2.2.3, the potential effects of an explosion occurring on nearby highways are exceeded in severity by the potential effects of a APPENDIX 9A 9A-40 REV. 20, SEPTEMBER 2020

LGS UFSAR railway explosion. Structures housing safety-related systems and components are designed to withstand impact from missiles generated by a railway explosion. Portions of fire protection systems that are located outside the safety-related structures could potentially be damaged by missiles generated by a railway explosion. However, such damage will not jeopardize safe shutdown capability since the systems and components, excluding offsite power, needed for safe shutdown are protected from damage due to missile impact and are isolated from the effects of fires occurring outside the safety-related structures.

Hazards to the plant resulting from aircraft operating in the vicinity of the site are discussed in Section 3.5.1.6. The control structure, reactor enclosure, and spray pond pump structure are designed to withstand the impact of the design aircraft (a Learjet) without loss of structural integrity.

Portions of fire protection systems that are located outside these structures could potentially be damaged by aircraft impact. However, such damage will not jeopardize safe shutdown capability since the systems and components, excluding offsite power, needed for safe shutdown are protected from damage due to aircraft impact and are isolated from the effects of fires occurring outside the control structure, reactor enclosure, and spray pond pump structure.

Item 24 BTP Guideline The consequences of inadvertent operation of or a crack in a moderate energy line in the fire suppression system should meet the guidelines specified for moderate energy systems outside containment in SRP section 3.6.1.

LGS Design Moderate energy leakage cracks in fire suppression system piping are analyzed as discussed in Section 3.6. Section 3.6.1.2.2 summarizes the results of the moderate energy fluid system analysis and also provides references to other UFSAR sections that discuss the design bases and criteria that were used in the moderate energy fluid system analysis. The analysis demonstrates that the occurrence of a crack in moderate energy piping, including the fire suppression system piping, will not prevent the plant from being brought to a safe, cold shutdown.

Automatic suppression systems have been designed and located so that operation of the systems, either intentional or inadvertent, will not cause damage to redundant trains of safety-related equipment that is needed for safe shutdown of the plant. To the greatest extent practical, safety-related electrical components are located outside the coverage zones of automatic suppression systems. Where necessary, components that are needed in order to achieve safe shutdown and also are located within automatic suppression system coverage zones are designed to remain functional in the event of suppression system actuation. Four of the areas that are provided with automatic water-type suppression systems are the HPCI pump compartment, the RCIC pump compartment, the diesel generator cells, and the 13.2 kV switchgear room. Actuation of the suppression systems in the HPCI and RCIC pump compartments could cause damage significant enough to affect the operability of the systems in those compartments. In the diesel generator cells, baffles are provided to protect the generators and control devices from damage due to suppression system actuation. In the 13.2 kV switchgear room, the design features of the system mitigate the effects due to spurious actuation or MELB. This system is supervised with instrument air and incorporates a double interlock deluge valve that is maintained normally closed.

Sprinkler flow is initiated only when two seperate inputs are received; one from a pneumatic actuator, due to the melting of the sprinkler fusible link(s) allowing the supervised air to be APPENDIX 9A 9A-41 REV. 20, SEPTEMBER 2020

LGS UFSAR released; and the other from the fire detection system that sends a signal to an electric solenoid valve. Loss of any of these four systems (HPCI, RCIC, or a single diesel generator and 13.2 kV switchgear room) due to suppression system actuation is acceptable, since redundant systems will remain available to bring the plant to a safe, cold shutdown.

There are no cases in which safe shutdown components have electrical interconnections with fire detection or fire suppression systems. Therefore, safe shutdown components cannot be inadvertently actuated or shut down due to either normal or abnormal signals in the control and power circuits of the fire detection and fire suppression systems.

The HPCI and RCIC pump compartments and the diesel generator cells are the only safety-related areas of the plant that are provided with automatic suppression systems and also are potentially subject to steam flooding as a result of high energy pipe breaks. Elevated compartment temperatures due to steam flooding could result in suppression system actuation if the temperatures are high enough to cause the deluge valve to open and the fusible links on the sealed sprinkler heads to open. However, loss of the HPCI system, RCIC system, or a single diesel generator due to suppression system actuation is acceptable, since redundant systems will remain available to bring the plant to a safe, cold shutdown.

Automatic (water) suppression systems located in safety-related areas of the plant are of the type that have fusible heads (either preaction or wet pipe). These systems cannot be actuated in the absence of a significant heat source in the vicinity of the sprinkler heads. Therefore, electrical anomalies in the circuits of the smoke and heat detection systems or the suppression system power supplies cannot cause inadvertent actuation of these suppression systems.

Item 28 BTP Guideline On reactor sites where there is an operating reactor and construction or modification of other units is under way, the fire protection program should provide for continuing evaluation of fire hazards.

Additional fire barriers, fire protection capability, and administrative controls should be provided as necessary to protect the operating unit from construction fire hazards.

LGS Design Administrative procedures will be prepared to protect the operating Unit 1 from fire hazards associated with construction of Unit 2. Special precautions will be taken to prevent and control fire hazards. Use of open flames and welding or cutting equipment will be properly supervised.

Construction of both the underground yard fire main and the fire water distribution piping inside both units of the plant will be completed prior to Unit 1 operation so that manual hose station coverage will be available in Unit 2 as well as Unit 1. Portable fire extinguishers will also be available in the Unit 2 portions of the plant during its construction. The construction site will be kept clean and orderly and contractors' sheds will be kept outside the confines of new construction.

Item 33 BTP Guideline APPENDIX 9A 9A-42 REV. 20, SEPTEMBER 2020

LGS UFSAR Self-contained breathing apparatus using full face positive- pressure masks approved by the 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 personnel. At least 10 masks shall be available for fire brigade personnel. Control room personnel 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 should be located onsite for each self-contained breathing unit. In addition, an onsite 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 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 compressors are used as a source of breathing air, only units approved for breathing air shall be used; compressors shall be operable assuming a LOOP. Special care must be taken to locate the compressor in areas free of dust and contaminants.

LGS Design Self-contained breathing apparatus will be available for use by control room personnel and fire brigade members. The breathing apparatus will have a minimum operating life of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for control room personnel and 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for fire brigade members.

An onsite reserve air supply of six hours for at least five persons will be provided in stored air bottles. Compressors, if used, will be units approved for breathing air.

Item 34 BTP Guideline Recommendations for the fire brigade training program.

LGS Design Fire Protection program objectives for training fire brigade members is accomplished by using a combination of in plant areas and an off-site training facility that simulates plant physical conditions.

Drills are conducted in conformance with plant fire drill procedures.

An off-site facility enables drills to include the use of live fire conditions. These elements plus the use of breathing apparatus and full protective clothing create actual conditions that would be encountered during a real plant fire emergency. Additional drills, including backshift unannounced drills are conducted in plant areas throughout the year. Unannounced drills are scheduled on a "per shift basis" in accordance with the corporate fire protection procedures.

Local fire departments are offered annual training associated with the responsibilities and duties of the plant fire brigade and offsite responders, operational precautions when fighting fires on nuclear power plant sites including awareness of the need for radiological protection of personnel and the special hazards associated with a nuclear power plant site.

Item 35 BTP Guideline The quality assurance programs of applicants and contractors should ensure that the guidelines for design, procurement, installation, and testing and the administrative controls for the fire protection systems for safety-related areas are satisfied. The QA program should be under the management APPENDIX 9A 9A-43 REV. 20, SEPTEMBER 2020

LGS UFSAR control of the QA organization. This control consists of (1) formulating a fire protection QA program that incorporates suitable requirements and is acceptable to the management responsible for fire protection or verifying that the program incorporates suitable requirements and is acceptable to the management responsible for fire protection, and (2) verifying the effectiveness of the QA program for fire protection through review, surveillance, and audits. Performance of other QA program functions for meeting the fire protection program requirements may be performed by personnel outside of the QA organization. The QA program for fire protection should be part of the overall plant QA program.

LGS Design The QA program described below will be under the management control of the licensee and their agent's organizations during the construction and operation phases.

a. Design and Procurement Document Control The design review performed to compare the LGS design to the BTP guidelines provides assurance that necessary design features are included in appropriate design and procurement documents.

Deviations from the design and procurement documents will be controlled by mechanisms specified in the 10CFR50, Appendix B, QA program for this project.

b. Instructions, Procedures, and Drawings These requirements will be met through the use of a documented, final installation inspection and through implementation of a written preoperational test.

c. Control of Purchased Material, Equipment, and Services Based upon the status of procurement and the identification of significant design or manufacturing features, certain fire protection equipment may be subject to shop inspection during manufacture.

Receipt inspection at the site shall be performed.

d. Inspection These requirements will be met through the use of a documented, final installation inspection and through implementation of a written preoperational test.

e. Test and Test Control Documented preoperational test procedures including evaluation of results and follow-up action, if indicated, shall be employed to meet these requirements.

f. Inspection, Test, and Operating Status Installation inspections, as described in Item 4 above, shall be documented in such a manner as to indicate the acceptability of the item/activity inspected. Deficiencies APPENDIX 9A 9A-44 REV. 20, SEPTEMBER 2020

LGS UFSAR shall be identified and corrected in accordance with mechanisms specified in the 10CFR50, Appendix B, QA program for this project.

Satisfactory completion of the preoperational test and release for operation shall be accomplished and documented in accordance with mechanisms specified in the 10CFR50, Appendix B, QA program for this project.

g. Nonconforming Items Nonconforming items shall be identified, controlled, and corrected in accordance with the mechanisms specified in the 10CFR50, Appendix B, QA program for this project.

h. Corrective Action Conditions adverse to fire protection (such as failures, malfunctions, deficiencies, deviations, defective components, and nonconformances) during the construction phase shall be reported and corrected in accordance with mechanisms specified in the 10CFR50, Appendix B, QA program for this project.

i. Records Records shall be prepared and maintained to furnish evidence that the criteria described in Items 1 through 10 are being met for activities affecting the fire protection program.

j. Audits The activities described above are subject to audit. In addition, implementation of receipt inspections, final installation inspections, and preoperational tests shall be subject to audit to conform with documented instructions, procedures, and drawings.

Item 37 BTP Guideline Fire barriers with a minimum rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months should be provided to separate redundant divisions of safety-related systems from each other.

LGS Design Redundant divisions of safety-related systems will be separated from each other so as to achieve the three levels of fire damage limits established in Position C.1.b. The provision of fire barriers between redundant divisions of safety-related systems that do not have safe shutdown functions is not required. Fire barriers will be provided between redundant divisions of safe shutdown systems as necessary to ensure that one train of equipment necessary to achieve safe shutdown is maintained free of fire damage to the degree specified in Position C.1.b unless specified otherwise in Section 9A.5.

APPENDIX 9A 9A-45 REV. 20, SEPTEMBER 2020

LGS UFSAR The reactor enclosures, turbine enclosures, diesel generator enclosures, radwaste enclosure, and administration building are separated from each other by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire walls. Walls internal to these structures (and also the spray pond pump structure) which serve as boundaries between different fire areas are provided with fire ratings or construction details consistent with the fire hazard existing in each area. The locations of fire-rated walls are shown on Figures 9A-4 through 9A-12, and the walls surrounding each fire area are further described in the fire area discussions contained in Sections 9A.5.3 through 9A.5.9.

The structural steel beams supporting the floor slabs at el 254', el 269', el 289' and el 304' in the control structure were fireproofed to provide a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rating for the complete floor assembly during initial construction. Subsequently, Ref. 9A.7.5 approved an analytical method that demonstrated certain structural steel members did not require fire roofing. The structural steel beams supporting floor slabs in other areas have not been fireproofed. The fire ratings of floor slabs above and below each fire area are listed in the fire area discussions contained in Sections 9A.5.3 through 9A.5.9. Those slabs which are shown as "3 hr*" are capable of being rated as 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire barriers, except for the lack of fireproofing on the structural steel beams supporting the slab.

Reinforced concrete walls without penetrations are considered to qualify for a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire rating, provided that the wall has a thickness of at least 6 inches. Concrete block walls designated as fire walls are constructed in accordance with UL Design No. U904, as a minimum. Fire walls incorporating metal studs with lath and plaster are constructed in accordance with UL Design No.

U409. Fireproofing material is applied to structural steel beams in accordance with UL Design No.

N706, N712, N742, or N760. Concrete block walls which are designated with a "^" have perpendicular steel beam penetrations that are evaluated as adequate for the hazards present in the fire areas under a deviation (see 9A.6.6).

Item 39 BTP Guideline Appropriate fire barriers should be provided within a single safety division to separate components that present a fire hazard to other safety-related components or high concentrations of safety-related cables within that division.

LGS Design The diesel generator day tanks constitute the most significant fire hazard posed by components within safety-related systems. As stated in Item 229, the day tank for each diesel generator is located in a vault that is separated from the remainder of the diesel generator cell by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire walls. The HPCI, RCIC, RHR, and LPCI systems contain lesser fire hazards in the form of lubricating oil associated with the pumps and drivers in these systems. These pumps are located at el 177' in the reactor enclosure, which is compartmentalized to separate the pumps from each other and from other safety-related systems.

Fire barriers are not provided solely for the purpose of separating safety-related cables from other safety-related cables in the same division. Separation by distance or by fire barriers between redundant divisions is provided as necessary to ensure safe shutdown capability in the event of a fire. Separation to ensure independence between Class 1E and non-Class 1E circuits and between redundant divisions of Class 1E circuits is discussed in Section 8.1.6.1.14.

APPENDIX 9A 9A-46 REV. 20, SEPTEMBER 2020

LGS UFSAR Item 40 BTP Guideline Openings through fire barriers for pipe, conduit, and cable trays which separate fire areas should be sealed or closed to provide a fire resistance rating at least equal to that required of the barrier itself.

LGS Design Pipe, conduit, and cable tray penetrations through fire-rated barriers will be sealed to provide a fire resistance rating that is consistent with that of the overall barrier. Such seals in fire barrier penetrations will be installed in accordance with the manufacturer's tested configurations where possible. Individual penetration seals that include configurations or features that constitute deviations from the manufacturer's tested configuration are reviewed and accepted by LGS's authorized insuring agency for use as fire-rated seals.

Item 41 BTP Guideline Openings inside conduit larger than 4 inches in diameter should be sealed at the fire barrier penetration. Openings inside conduit 4 inches or less in diameter should be sealed at the fire barrier unless the conduit extends at least 5 feet on each side of the fire barrier and is sealed either at both ends or at the fire barrier with noncombustible material to prevent the passage of smoke and hot gases.

LGS Design In areas of the plant that contain safety-related equipment, conduits that penetrate fire barriers will be sealed internally to prevent the passage of smoke and hot gases. For each penetrating conduit that extends 5 feet or more on both sides of the fire barrier, noncombustible seals will be provided on both sides of the fire barrier at the access point (junction box, termination at a cable tray, or equipment connection) that is closest to the fire barrier. For each penetrating conduit that extends less than 5 feet on either side of the fire barrier, a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire rated seal will be provided either at the fire barrier or on one side of the barrier at the access point that is closest to the barrier. For the cases in which access to the interior of a conduit has been provided at the fire barrier via a junction box or condulet, the 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months seal is located at the barrier. Where no access has been provided at the barrier, the 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months seal is located at the access point that is closest to the barrier. For the cases in which the penetrating conduit is larger than 4 inches in diameter and the 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months seal is not located at the barrier, the conduit forms part of the fire barrier in combination with the seal.

Conduits in this category are schedule 40 rigid steel and will maintain their integrity while exposed to a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire.

Any installation which deviates from the above criteria for internal conduit seals is documented in a technical evaluation in the form of a fire hazards and safe shutdown analysis that is performed and reviewed by personnel responsible for fire protection and safe shutdown analyses for the plant.

Each technical evaluation documents the as-built configuration and presents the rationale for concluding that the affected seal does not degrade the effectiveness of the fire barrier in preventing the spread of a postulated fire and in limiting the migration of smoke and hot gases. Each technical evaluation performed is retained as part of the permanent plant records.

APPENDIX 9A 9A-47 REV. 20, SEPTEMBER 2020

LGS UFSAR For conduits that enter the bottom of floor-mounted components that are mounted on fire-rated floor slabs, 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated seals are normally installed inside each conduit at the point where it enters the component. In some cases, however, the congestion of cables in a conduit prevents the fire sealant material from being installed to the minimum thickness necessary to qualify as a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated seal. In each such situation, a second seal is installed inside the conduit at the access point nearest to the component, with the thickness of the sealant material in the second seal being selected so that the combined thickness of the first and second seals is not less than the thickness required for a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated seal.

For fire barriers that separate safety-related areas from nonsafety-related areas of the plant, conduit penetrations will be provided with internal seals in the same manner as discussed above for safety-related areas.

In areas of the plant not containing safety-related equipment, internal seals will be provided for conduits penetrating fire barriers that are adjacent to fire areas with high combustible loadings.

The locations of the conduit seals with respect to the fire barrier being penetrated will be the same as discussed above for safety-related areas.

Item 43 BTP Guideline Penetration designs should utilize only noncombustible materials.

LGS Design All materials used in fire-rated penetration seals are either noncombustible or are listed by an independent testing laboratory for flame spread, smoke generation, and fuel contribution of 25 or less, as determined by testing in accordance with ASTM E-84. Alternatively, the fire retardation of caulking and adhesive materials that are used in small quantities as part of penetration seal assemblies may be demonstrated by successful completion of the fire test specified in section 3.B of the "ANI/MAERP Standard Method of Fire Tests of Cable and Pipe Penetration Fire Stops,"

issued in February of 1976. The following different types of seals will be used in fire-rated applications:

a. Cement-type grout.

b. Foamed silicone polymer. This is a self-vulcanizing material that results from the mixture of two liquid components.

c. Solid silicone polymer. The polymer is impregnated with a powdered high density filler.

d. Flexible boot with ceramic fiber. The boot material is silicone rubber with woven glass fiber reinforcing. Ceramic fiber is installed inside the boot, in the space between the penetrating object and the edge of the penetration. Stainless steel compression straps and silicone adhesives are used in attaching the boot.

APPENDIX 9A 9A-48 REV. 20, SEPTEMBER 2020

LGS UFSAR

e. Flexible boot with gel. The boot material is silicone rubber with woven glass fiber reinforcing. The boot is filled with a high density silicone dielectric gel. Stainless steel compression straps and silicone adhesives are used in attaching the boot.

Item 45 BTP Guideline The acceptance criteria for the test should require that:

a. The fire barrier penetration has withstood the fire endurance test without passage 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.

b. The temperature levels recorded for the unexposed side are analyzed and demonstrate that the maximum temperature does not exceed 325oF.

c. The fire barrier penetration remains intact and does not allow projection of water beyond the unexposed surface during the hose stream test. The stream shall be delivered through a 11/2 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 discharge 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 21/2 inch national standard play pipe equipped with 11/8 inch tip, nozzle pressure of 30 psi, located 20 ft from the exposed face.

LGS Design In accordance with American Nuclear Insurer's NEL-PIA/MAERP, Standard Test method for penetration fire stops, a maximum allowable temperature of 325F above ambient is applicable to temperature measurements taken at the seal surface on the unexposed side at locations not involving interfaces with objects that penetrate the seal. In accordance with IEEE 634 (1978), a maximum allowable temperature of 700F is applicable to temperature measurements taken on the unexposed side at interfaces between the seal material and objects that penetrate the seal.

The acceptance criteria for penetration qualification tests are in agreement with those specified in paragraphs (a) and (c) above. The maximum unexposed side temperature criteria used by the ANI test standard was 325F above ambient. Annular pipe anchors are used in the type of penetration involving a single pipe routed through a steel penetration sleeve that is embedded in a concrete wall. The pipe anchor consists of a steel plate spanning the annular space between the pipe and the penetration sleeve, and which is welded to both the pipe and the penetration sleeve over its entire circumference. Fire resistance for this type of penetration assembly is provided by installing mineral wool in the annular space to a minimum depth of 12 inches. This configuration has been tested for a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire rating at the National Gypsum Company Research Center in cooperation with Factory Mutual Research. The assembly withstood the fire test and hose stream test with a maximum temperature of 425F on the unexposed side of the annular anchor, measured at a location 1 inch from the surface of the pipe. This temperature is attributable to heat conduction APPENDIX 9A 9A-49 REV. 20, SEPTEMBER 2020

LGS UFSAR through the steel pipe. This seal configuration is acceptable because no cables are associated with the penetration.

Item 46 BTP Guideline Penetration openings for ventilation systems should be protected by fire dampers having a rating equivalent to that required of the barrier.

LGS Design Except for Fire Areas 3, 4, 5, and 6, ventilation ducts that penetrate fire barriers are provided with 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire dampers at penetrations of 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated barriers and with 1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months rated dampers at penetrations of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months fire barriers. Both classifications of fire dampers are UL-listed and manufactured to comply with NFPA 90 and the Commonwealth of Pennsylvania Fire Protection Code.

Fire Areas 3, 4, 5, and 6 ventilation duct penetrations, which communicate with Fire Area 2, have fire damper assemblies which have been evaluated per an Engineering Evaluation, dated 03/26/98 (Reference NCR-ECR LG 98-00470) and are commensurate with the postulated fire in these areas.

Item 48 BTP Guideline Door openings in fire barriers should be protected with equivalently rated doors, frames, and hardware that have been tested and approved by a nationally recognized laboratory.

LGS Design Door openings in fire barriers are protected with equivalently rated doors, frames, and hardware that have been rated as follows:

a. Hollow metal doors are listed by UL and classified as Class A (3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months ) for use in 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire barriers, Class B (1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months ) for use in 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months rated fire barriers, or Class C (3/4 hour) for use in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months rated fire barriers.

b. Roll-up doors less than 120 ft2 in size are labeled with classification markings as described above for hollow metal doors. Roll-up doors larger than 120 ft2 are not provided with UL classification labels but are certified by their manufacturer to be manufactured in compliance (except for size) with the requirements for doors of this class and type that are normally labeled as Class A.

c. Watertight doors are not provided with UL classification labels but are certified by the manufacturer to be equivalent to the requirements of the UL classification for special purpose type fire door and frame assemblies that are rated as Class A.

d. Missile-resistant doors are certified by the manufacturer to be designed so that the doors provide a degree of fire resistance equivalent to a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire rating based on APPENDIX 9A 9A-50 REV. 20, SEPTEMBER 2020

LGS UFSAR exposure to temperatures as defined by the NFPA standard time-temperature curve. Because the missile-resistant doors are custom designed for each specific application, they are not provided with UL classification labels. Only three missile-resistant doors are specified for use in fire barriers, two of which are 3'-0" by 7'-0" single-leaf doors and one of which is a 7'-0" by 10'-0" double-leaf door. The manufacturer has verified by calculation that the deformation of these doors resulting from exposure to a standard 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire will remain within the values specified in the acceptance criteria of ASTM E-152-81.

e. Steamtight, airlock, and bullet-resistant doors are labeled as described above for hollow metal doors, except for doors with conditions that do not exactly match the physical units tested and approved by UL. Doors that are not labeled are certified by the door manufacturers to be fabricated in the same manner as the labeled units, except for variances due to special functions required for the doors. These variances include the following:

1. Door size - the size of double-leaf door tested by UL is 6'-0" by 7'-2" whereas the maximum size of the LGS doors is 9'-0" by 10'-0".

2. Door thickness - the maximum thickness tested by UL is 23/4" whereas the maximum thickness of the LGS doors is 41/4".

3. LGS' double-leaf steamtight and airlock doors contain a removable mullion that is not present in the UL-tested assemblies.

4. Minor hardware differences as follows:

(a) Customized hinges (b) Locksets by Sonicbar Door Systems (c) Additional security hardware (d) Surface-mounted hardware

5. LGS' bullet-resistant doors have additional structural features for greater strength that were not included in the tested doors.

The fire loadings on either side of the subject doors are low. The maximum equivalent severity in adjacent compartments is 35 minutes. In none of the cases are the in situ combustibles located immediately adjacent to the doors.

f. Door/frame assemblies not installed in tested configurations that have been evaluated to withstand for three hours the maximum fire expected in the Fire Area.

Doors that are specified for use in fire barriers but are not listed by UL are identified in the fire area discussions contained in Sections 9A.5.3 through 9A.5.9 by a double asterisk (**) following the indicated fire rating.

APPENDIX 9A 9A-51 REV. 20, SEPTEMBER 2020

LGS UFSAR Item 58 BTP Guideline Cable spreading rooms should be separated from each other and from other areas of the plant by barriers having a minimum fire resistance of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

LGS Design The cable spreading rooms are separated from each other and from adjacent fire areas by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire barriers consisting of either reinforced concrete or concrete unit masonry walls with a minimum thickness of 12 inches, and reinforced concrete slabs with a minimum thickness of 12 inches. Exposed structural steel supporting the floor slabs above and below the cable spreading rooms are coated with fireproofing material in order to achieve a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire rating. Each door opening in the 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire walls is provided with a UL Class A fire door. All penetrations through the 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated walls and slabs are sealed using penetration seal details that are qualified for use in 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire barriers. HVAC duct penetrations through the 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated walls are equipped with 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire dampers.

Item 59 BTP Guideline Interior wall and structural components, thermal insulation materials, radiation shielding materials, and soundproofing should be noncombustible.

LGS Design Most interior walls are constructed of either reinforced concrete, or concrete masonry units.

Limited use is made of walls constructed of metal studs with either gypsum wallboard or gypsum plaster on expanded metal lath. Structural components consist of structural steel or reinforced concrete. Soundproofing materials, if required, will be noncombustible. Radiation shielding consists of concrete, concrete masonry unit, or steel plates, or other noncombustible materials.

Thermal insulation materials are noncombustible, with the following exceptions:

a. Insulation for domestic cold water piping (in the administration building only) is a closed-cell foamed elastomer with an ASTM E-84 flame spread rating of 25 or less.

b. Insulation for the offgas refrigeration equipment (located only in the offgas enclosure) has an ASTM E-84 flame spread rating of 25 or less.

c. Insulation for duct-work and plenums of the ventilation systems has an ASTM E-84 flame spread rating of 25 or less and a smoke generation rating of 50 or less.

Item 60 BTP Guideline Interior finishes should be noncombustible.

APPENDIX 9A 9A-52 REV. 20, SEPTEMBER 2020

LGS UFSAR LGS Design Areas containing systems or equipment required for safe shutdown of the plant are unfinished, or are finished with materials that are either noncombustible or (except for floor coverings and vinyl cove base) are rated by an independent testing laboratory for flame spread and smoke generation of 25 or less.

Floor coverings in areas containing systems or equipment required for safe shutdown of the plant are Class I material as defined in NFPA 101. In order to qualify for this classification, the floor covering material must have a minimum critical radiant flux of 0.45 watts per square centimeter as determined by NFPA 253 ("Standard Method of Test for Critical Radiant Flux of Floor Covering Systems Using a Radiant Heat Energy Source").

Vinyl cove base is considered trim and incidental finish and may be Class III material as defined in NFPA 101. As such, it is rated for flame spread of 200 or less and smoke generation of 450 or less. Trim and incidental finish shall not exceed 10% of the aggregate wall and ceiling area of a room.

Item 61 BTP Guideline Metal deck roof construction should be noncombustible and listed as "acceptable for fire" in the UL Building Materials Directory, or listed as Class 1 in the Factory Mutual System Approval Guide.

LGS Design Metal deck roof construction is used only for the turbine enclosure, which is a nonsafety-related structure. The roof is constructed to meet the requirements of a Class 1 roofing system in accordance with the Factory Mutual System Approval Guide.

Item 62 BTP Guideline Suspended ceilings and their supports should be of noncombustible construction.

LGS Design Two different design details are used for the suspended ceiling in the control room. One detail includes mineral fiber panels resting on a metal grid system which is supported by steel wires. A second detail, used above the peripheral rooms adjacent to the control room, includes gypsum board panels supported from galvanized steel studs. The materials used in both of these details are either noncombustible or are listed by an independent testing laboratory for flame spread, smoke generation, and fuel contribution of 25 or less.

Item 63 BTP Guideline Concealed spaces should be devoid of combustibles except as noted in Position C.6.b.

APPENDIX 9A 9A-53 REV. 20, SEPTEMBER 2020

LGS UFSAR LGS Design There are no combustible materials in the space above the suspended ceiling in the control room, other than electrical cables. These cables (associated primarily with control room annunciators and control room lighting) are routed in conduits, fully enclosed gutters, and cable trays. The cable trays are fully enclosed through the use of solid (steel) top and bottom covers. The only exposed cables in the space above the suspended ceiling are the control room annunciator cables that extend through the bottom covers on the cable trays. Since the annunciators are located immediately adjacent to the cable trays, the exposed length of cable is very short. The cable dropout openings in the tray bottoms will be sealed with ceramic fiber and a flame-retardant mastic coating to ensure that any fire originating within the cable trays is contained within the trays. Eleven smoke detectors are located above the suspended ceiling to provide early warning of fires occurring within the area.

Table 9A-3 lists the insulation and jacketing materials used for electrical cabling. As noted in the table, cable insulation and jacketing materials are specified to meet the IEEE 383 flame test requirements except for lighting, communications, and grounding cables. Lighting cables and communication cables are routed exclusively in conduit, and grounding cables are not routed through the space above the suspended ceiling in the control room.

Electrical cables are routed through the raised floor sections in the auxiliary equipment room.

Access to the cables for manual fire fighting efforts is obtained by the removal of floor plates covering the floor sections. The floor plates are constructed of aluminum honeycomb bonded between sheet metal, and are easily removable using two quick-disconnect fasteners on each plate. Automatic fire detection systems and automatic Halon suppression systems are provided in the floor sections. Additional discussion of the auxiliary equipment room raised flooring and the Halon suppression system is provided in Sections 9A.2.9 and 9A.5.3.25.

Item 65 BTP Guideline Outdoor oil-filled transformers should have oil spill confinement features or drainage away from the buildings.

LGS Design The main transformers, the safeguard transformers, and the auxiliary transformers are each surrounded by a curb approximately 2 feet high. A floor drain is provided within each curbed area to drain liquids to the normal waste drainage system.

The fire walls that are located on three sides of each plant services transformer would prevent spilled oil from flowing toward the circulating water pump structure. The pavement in the vicinity of each transformer is sloped to provide drainage to nearby catch basins.

APPENDIX 9A 9A-54 REV. 20, SEPTEMBER 2020

LGS UFSAR Item 66 BTP Guideline Outdoor oil-filled transformers should be located at least 50 feet distant from the building, or by ensuring that such building walls within 50 feet of oil-filled transformers are without openings and have a fire resistance rating of at least 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

LGS Design The main transformers are located more than 50 feet from any building. The plant services transformers are located adjacent to the circulating water pump structure, but are separated from it by free-standing 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire walls. The safeguard transformers and auxiliary transformers are located approximately 14 feet from the north side of the turbine enclosure. As described in Section 9A.2.4, the latter transformers are provided with automatically actuated deluge systems to suppress fires involving the transformers. This automatic suppression will prevent the turbine enclosure from being damaged as a result of a transformer fire. In addition, the turbine enclosure is nonsafety-related and does not contain any components that are needed in order to achieve safe shutdown of the plant.

Item 67 BTP Guideline Floor drains sized to remove expected fire fighting water without flooding safety-related equipment should be provided in areas where fixed water fire suppression systems are installed.

LGS Design Two water suppression systems are located in areas with no floor drains. A wet pipe system is located in the elevation 239 corridor (fire area 7) and localized preaction system in the 13.2 kV switchgear room, elevation 217 (fire area 2).

Although no floor drains are located in fire area 7, equipment in adjacent areas are provided with curbs, installed on 4 raised pads or the floor was sloped away from the equipment. Floor drains are also available in the adjacent battery rooms. No safety-related equipment (other than cabling) is located in fire area 7 which is also maintained as a combustible free zone, with the primary combustible loading from cables and cable tray encapsulating material. Although the UFSAR (Section 9A.5.3.7.c) states that ignition of electrical cabling in tray is extremely unlikely in the absence of a fire source, a smoke detector system provides early warning of the slow developing incipient fire that would be typical for the types of combustibles in the area. The early activation of the smoke detection system provides an audible/visual annunciation in the control room whereby operator actions are expected to mitigate the consequences of the fire before it could develop sufficiently to cause the system to actuate. If the system were to actuate due to a fire event, a flow switch provides an additional alarm to the control room requiring immediate operator actions. As discussed in response to Item 68 below, credit was taken for the opening of doors due to fire brigade response, which would allow water from hand hoses to drain into adjacent nonsafety-related areas containing floor drains.

Although no floor drains are located in fire area 2, the design feature of the installed partial preaction system minimizes the impact to equipment. This system is supervised with instrument APPENDIX 9A 9A-55 REV. 20, SEPTEMBER 2020

LGS UFSAR air and incorporates a double interlock deluge valve that is maintained normally closed. Sprinkler flow is initiated only when two separate inputs are received; one from a pneumatic actuator, due to the melting of the sprinkler fusible link(s) allowing the supervised air to be released; and the other from the fire detection system that sends a signal to an electric solenoid valve. This system is installed to protect redundant cable trays encapsulated with a 1-hour fire rated material. Although the UFSAR (Section 9A.5.3.2.c) states that ignition of electrical cabling in tray is extremely unlikely in the absence of a fire source, a smoke detector system provides early warning of a fire throughout the entire area. The early activation of the smoke detection system provides an audible/visual annunciation in the control room whereby operator actions are expected to mitigate the consequence of the fire before it could develop sufficiently to cause the system to actuate.

However, should the system actuate due to a fire, the impact to safe shutdown is mitigated by the location of redundant components outside of this area. This is further supported by MELB evaluations performed in accordance with UFSAR Section 3.6 (Reference; Item 24 of Section 9A.3.1.1, Detailed Comparison to Branch Technical Position CMEB 9.5-1, of Appendix 9A of the LGS UFSAR) that indicated that equipment was waterspray proof, or judged as not being required to ensure safe shutdown, containment integrity, or containment activity release to 10CFR50.67 limits. In addition, in accordance with Item 210 below, since floor drains were not provided in the safety-related switchgear rooms to prevent water accumulation, credit was taken for the opening of doors to drain water into areas not containing safety-related components.

Item 68 BTP Guideline 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.

LGS Design All plant areas that are provided with drainage facilities have adequately sized drains to remove all the water discharged from a hand hose line. The only fire areas that are not provided with floor drains and which contain safety-related equipment that is needed for safe shutdown are the 4 kV switchgear compartments (fire areas 12 through 19), the static inverter compartments (fire areas 20 and 21), auxiliary equipment room (fire area 25), and remote shutdown room (fire area 26).

The use of hand-held fire hoses in any of these fire areas will not result in flooding that causes unacceptable damage to safety-related equipment.

A fire hose can be used in the 4 kV switchgear compartments only by bringing the hose in through a doorway from adjacent fire areas. For fire areas 12, 14, 16, and 18, the fire hose would be brought in from the generator equipment area (fire zone 113B) along the north side of the control structure. Water discharged from a hose in one of these 4 kV switchgear compartments would flow through the open doorway to fire zone 113B and drain into the floor drains in that area. For fire areas 13, 15, 17, and 19, the fire hose would be brought in from the equipment hatch corridor (fire areas 97 for Unit 1 and 110 for Unit 2) via the control structure corridor (fire area 7). Water discharged from a hose in one of these 4 kV switchgear compartments would flow through the open doorway to fire area 7 and then through the doorway to the equipment hatch corridor. The equipment hatch corridor is provided with floor drains to dispose of the fire fighting water. Since the control structure corridor does not contain any safe shutdown components, the drainage of fire fighting water through the corridor will not have an adverse effect on safe shutdown capability.

APPENDIX 9A 9A-56 REV. 20, SEPTEMBER 2020

LGS UFSAR A fire hose can be used in the Unit 1 static inverter compartment (fire area 20) only by bringing the hose in from the Unit 1 cable spreading room through an open doorway. Although the Unit 2 static inverter compartment (fire area 21) contains a manual hose station, the fire brigade would fight a fire in this compartment using a hose brought in from the generator equipment area (fire zone 113B) through an open doorway. For both the Unit 1 and Unit 2 static inverter compartments, the doorway that is used for access will remain open during fire fighting activities within the compartment. Water discharged from a hose in the Unit 1 static inverter compartment would flow through the open doorway to the Unit 1 cable spreading room, whereas water discharged from a hose in the Unit 2 static inverter compartment would flow to the generator equipment area. The cable spreading rooms and the generator equipment area are each provided with floor drains to dispose of the fire fighting water. Since the cable spreading room does not contain any safe shutdown components, the drainage of fire fighting water into the spreading room from the static inverter compartment will not have an adverse effect on safe shutdown capability.

A fire hose can be used in the remote shutdown room (fire area 26) only by bringing the hose in from the control structure stairwell through an open doorway. This stairwell hose reel is the only hose reel available to fight a fire in this area so the door will remain open during fire fighting activities within the room. Water discharged from the hose in the remote shutdown room would flow through the open doorway into the stairwell, which does not contain any safe shutdown components.

A fire hose can be used in the auxiliary equipment room (fire area 25) only by bringing the hose in from the control structure stairwell through an open doorway. This stairwell hose reel is the only hose reel available to fight a fire in this area from the primary attack route so the door will remain open during fire fighting activities within the room. Water discharged from the hose in the auxiliary equipment room would flow through the open doorway into the stairwell, which does not contain any safe shutdown components. The secondary attack route for this area is from fire area 111 through an open door on the east wall of the auxiliary equipment room. Water discharged from the hose in the auxiliary equipment room would flow through the open doorway into the fire area 111, which does not contain any safe shutdown components.

Nonsafety-related areas of the plant that adjoin safety-related areas are provided with floor drains.

As a result, fire fighting water that is discharged into the nonsafety-related areas will be disposed of through the floor drains, so that water will not accumulate on the floor and create a potential for inadvertent flooding of the adjoining safety-related areas.

Item 69 BTP Guideline 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.

LGS Design Gas suppression systems are provided for the remote shutdown room (Halon 1301), and the raised flooring in the auxiliary equipment room (Halon 1301). Loss of Halon 1301 through floor drains is not possible, since the auxiliary equipment and remote shutdown rooms do not have floor drains.

APPENDIX 9A 9A-57 REV. 20, SEPTEMBER 2020

LGS UFSAR Item 70 BTP Guideline 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.

LGS Design For the safety-related pump compartments at el 177' of the reactor enclosure, floor drains leading to the reactor enclosure floor drain sump are each provided with backflow prevention devices. The only other safety-related areas of the plant that contain significant quantities of combustible liquids are the diesel generator cells. The drains from the diesel generator cells are not interconnected with drains from other safety-related areas of the plant. The drains from each diesel generator cell are provided with traps upstream of their connection to an oil separator receiver.

The turbine enclosure contains several oil storage tanks, but the floor drains from the turbine enclosure are not interconnected with drains from safety-related areas of the plant.

Item 78 BTP Guideline Bulk gas storage (either compressed or cryogenic), should not be permitted inside structures housing safety-related equipment. Storage of flammable gas such as hydrogen should be located outdoors or in separate detached buildings so that a fire or explosion will not adversely affect any safety-related systems or equipment.

LGS Design Compressed gases are stored either outdoors or in nonsafety-related structures whenever possible. Compressed gas cylinders used for welding are stored in the construction shop (during periods of usage only) and the machine shop. Hydrogen used in cooling of the main generators is provided from the HWC system tube trailer facility located outside the protected area.

Compressed gas cylinders are stored in safety-related areas of the plant for use with three different systems: PCIG, containment combustible gas monitoring, and offgas hydrogen monitoring. The PCIG system includes compressed gas cylinders located at el 217' in the reactor enclosure. These cylinders contain nitrogen only, and therefore do not constitute a hazard with respect to fire protection. The containment combustible gas monitoring system includes compressed gas cylinders located at el 253' and el 283' in the reactor enclosure. These cylinders contain oxygen and oxygen/nitrogen mixtures, which also do not constitute a hazard with respect to fire protection, since oxygen is not a fuel gas.

The span and reagent gas bottles for the containment combustible gas monitoring systems are located outside the south wall of the Reactor Enclosures. These bottles of high purity oxygen, high purity hydrogen, 7% oxygen and 7% hydrogen are considered transportable, not bulk. The bottles are oriented with the long axis parallel to the Reactor Enclosure walls, minimizing the impact of a bottle failure when combined with the robust design of the Reactor Enclosure.

APPENDIX 9A 9A-58 REV. 20, SEPTEMBER 2020

LGS UFSAR The offgas hydrogen monitoring system includes two compressed gas cylinders located at el 200' in the control structure. One of these cylinders contains nitrogen and the other contains a nitrogen/hydrogen mixture with a hydrogen content of 7%. An inadvertent release of the nitrogen/hydrogen mixture into the control structure air volume would result in immediate dilution of the hydrogen concentration to less than 4%. Since a hydrogen concentration of less than 4% in air is not combustible, the nitrogen/hydrogen mixture does not constitute a hazard with respect to fire protection.

Item 79 BTP Guideline High pressure gas storage containers should be located with the long axis parallel to building walls.

LGS Design High pressure gas storage cylinders are stored vertically with their long axis parallel to turbine enclosure walls.

Item 80 BTP Guideline Use of compressed gases (especially flammable and fuel gases) inside buildings should be controlled.

LGS Design The usage of compressed gases for cutting and welding is limited to those activities authorized as to be outlined in the administrative procedures.

The usage of compressed fuel gases for laboratory and shop use is limited to a low pressure supply system for Bunsen burners in the radioactive chemistry laboratory in the radwaste enclosure and the instrument repair shop on the 269 foot level of the control structure.

Compressed fuel gas cylinders and gas pressure- reducing stations are installed outside of the building at a location that does not expose nuclear safety-related structures, systems, and equipment to potential damage from fire at the storage location.

Item 81 BTP Guideline The use of plastic materials should be minimized. In particular, halogenated plastics such as PVC and neoprene should be used only when substitute noncombustible materials are not available.

LGS Design The use of plastic materials within the plant has been minimized to the greatest extent practicable.

However, alternatives to plastic or elastomeric materials for electrical cable insulating systems, with an optimum balance of electrical, physical, and environmental characteristics, are not available.

Cable insulation and jacketing materials are chosen for their fire-retardant and self-extinguishing APPENDIX 9A 9A-59 REV. 20, SEPTEMBER 2020

LGS UFSAR APPENDIX R NO. APPENDIX R GUIDELINE ITEM NO. COMPARISON REMARKS Water Supplies for Fire Suppression Systems

1. Two separate water supplies shall be provided to furnish A C necessary water volume and pressure to the fire main loop.

2. Each supply shall consist of a storage tank, pump, A AC In lieu of storage tanks, the cooling tower piping, and appropriate isolation and control valves. basins of the Unit 1 and Unit 2 circulating water systems are used as the two sources of water for the fire main loop .

3. These supplies shall be separated so that a failure of A C See Section 9A.3.2.2.

one supply will not result in a failure of the other supply.

4. Each supply of the fire water distribution system shall A C The storage capacity of each cooling tower be capable of providing the maximum expected water is 7,200,000 gallons, which is well in demands for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . excess of the 387,000 gallon volume required for two hour operation of the largest sprinkler system c oncurrent with hose stream operation at 500 gpm.

5. Requirements for ensuring minimum water volume when A NA See Section 9A.3.2.2.

storage tanks are used for combined service water/fire water uses.

6. Requirements for other water systems used as sources of A AC See Section 9A.3.2.2 fire protection water.

Sectional Isolation Valves

7. Sectional isolation valves such as postindicator valves B C or key operated valves shall be installed in the fire main loop to permit isolation of porti ons of the main fire main loop for maintenance or repair without interrupting the entire water supply.

APPENDIX 9A 9A-91 REV. 20, SEPTEMBER 2020

LGS UFSAR APPENDIX R NO. APPENDIX R GUIDELINE ITEM NO. COMPARISON REMARKS Hydrant Isolation Valves

8. Valves shall be installed to permit isolation of outside C C hydrants from the fire main for maintenance or repair without interrupting the water supply to automatic or manual fire suppression systems.

Manual Fire Suppression

9. Standpipe and hose systems shall be installed so that at D AC See Section 9A.3.2.2 least one effective hose stream will be able to reach any location that contains or presents an exposure fire hazard to structures, systems, or components important to safety.

10. Access to permit effective functioning of the fire D C brigade shall be provided to all areas that contain or present an exposure fire hazard to structures, systems, or components important to safety.

11. Standpipe and hose stations shall be inside PWR D NA The primary containment is inerted with containments and BWR containments that are not inerted. nitrogen during reactor operation.

12. For BWR drywells, standpipe and hose stations shall be D C The hose reels located nearest the drywell placed outside the drywell with adequate lengths of hose entrances are equipped with a 100 foot to reach any location inside the drywell with an length of fire hose. To supplement this effective hose stream. hose length, a hose station equipped with enough hose to reach any location within the drywell is located near each drywell entrance.

APPENDIX 9A 9A-92 REV. 20, SEPTEMBER 2020

LGS UFSAR APPENDIX R NO. APPENDIX R GUIDELINE ITEM NO. COMPARISON REMARKS Hydrostatic Hose Tests

13. Fire hose shall be hydrostatically tested at a pressure E C of 150 psi or 50 psi above maximum fire main operating pressure, whichever is greater. Hose stored in outside hose houses shall be tested annually. Interior standpipe hose shall be tested every three years .

Automatic Fire Detection

14. Automatic fire detection systems shall be installed in F AC See Item 112 of Section 9A.3.1.2 all areas of the plant that contain or present an exposure fire hazard to safe shutdown or safety -related systems or components. These fire detection systems shall be capable of operating with or without offsite power.

Fire Protection of Safe Shutdown Capability

15. Fire damage shall be limited so that one train of G.1.a C systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station is free of fire damage.

16. Fire damage shall be limited so that systems necessary G.1.b C to achieve and maintain cold shutdown from either the control room or emergency control station can be repaired within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

17. Consideration of associated nonsafety circuits as G.2 (part C See Section 9A.6.1 requiring protection to ensure freedom from fire damage. of first paragraph)

18. Alternative means of ensuring that one train of systems G.2.a AC See Section 9A.3.2.2 necessary to achieve and maintain hot shutdown is free G.2.b of fire damage (where cables or equipment of redundant G.2.c trains are located in the same fire area).

APPENDIX 9A 9A-93 REV. 20, SEPTEMBER 2020

LGS UFSAR APPENDIX R NO. APPENDIX R GUIDELINE ITEM NO. COMPARISON REMARKS

19. Alternative means of providing fire protection inside G.2.d NA The primary containment is inerted with noninerted containments. G.2.e nitrogen during reactor operation.

G.2.f

20. Provision of alternative or dedicated shutdown G.3 NC See Section 9A.3.2.2 capability in certain fire areas.

Fire Brigade

21. Requirements for the onsite fire brigade. H C Fire Brigade Training

22. Requirements for training of fire brigade members. I AC See Section 9A.3.2.2.

Emergency Lighting

23. Emergency lighting units with at least an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months battery J C See Section 9A.3.2.2.

power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.

Administrative Controls

24. Establishment of administrative controls to minimize K C fire hazards.

Alternative and Dedicated Shutdown Capability

25. The shutdown capabilit y provided for a specific fire L.1 C area shall be able to achieve and maintain subcritical reactivity conditions in the reactor, maintain reactor coolant inventory, achieve and maintain hot shutdown conditions, achieve cold shutdown conditions wit hin 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and maintain cold shutdown conditions thereafter.

APPENDIX 9A 9A-94 REV. 20, SEPTEMBER 2020

LGS UFSAR APPENDIX R NO. APPENDIX R GUIDELINE ITEM NO. COMPARISON REMARKS

26. During the postfire shutdown, the reactor coolant system L.1 C 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.

27. performance goals for the shutdown functions. L.2 C The systems and components relied on for hot shutdown and cold shutdown in the event of a fire have been selected so as to ensure that the listed goals are achieved.

28. The alternative shutdown capability shall be independent L.3 C of the specific fire areas.

29. The shutdown capability shall accommodate postfire L.3 C All systems and components relied on for conditions where offsite power is available and where hot shutdown and cold shutdown in the event offsite power is not available for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . of a fire are capable of being powered from the onsite power supplies, i.e., the station batteries and standby diesel generators.

30. If the capability to achieve and maintain cold shutdown L.4 C will not be available because of fire damage, the equipment and systems comprising the means to achieve and maintain the hot shutdown condition shall be capable of maintaining such conditions until cold shutdown can be achieved.

31. If the equipment and systems comprising the means to L.4 NA See Section 9A.3.2.2 achieve and maintain hot shutdown conditions 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.

APPENDIX 9A 9A-95 REV. 20, SEPTEMBER 2020

LGS UFSAR APPENDIX R NO. APPENDIX R GUIDELINE ITEM NO. COMPARISON REMARKS

32. Equipment and systems comprising the means to achieve L.5 C and maintain cold shutdown conditions shall not be damaged by fire; or the fire damage to such equipment and systems shall be limited so that the systems can be made operable and cold shutdown can be achieved within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

33. Materials for such repairs shall be readily available L.5 C See Section 9A.3.2.2.

onsite and procedures shall be in effect to implement such repairs.

34. If the equipment and systems comprising the means to L.5 NA See Section 9A.3.2.2.

achieve and maintain cold shutdown conditions (and which are used prior to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after the fire) will not be capable of being powered by both off site and onsite power systems because of fire damage, and independent onsite power system shall be provided.

35. Shutdown systems installed to ensure positive shutdown L.6 C 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.

36. Isolation of safe shutdown equipment and systems from L.7 C See Section 9A.6.1 associated nonsafety circuits.

Fire Barrier Cable Penetration Seal Qualification

37. Requirement Deleted M N/A The non-combustibility requirement for fire barrier penetration seals was deleted from 10 CFR 50 Appendix R as documented in the Federal Register, volume 65, No. 119, Tuesday June 2 0, 2000 (Doc. 00-15544).

38. Penetration seal designs shall be qualified by tests M C See Section 9A.3.2.2 that are comparable to tests used to rate fire barriers.

APPENDIX 9A 9A-96 REV. 20, SEPTEMBER 2020

LGS UFSAR APPENDIX R NO. APPENDIX R GUIDELINE ITEM NO. COMPARISON REMARKS Fire Doors

39. Acceptance criteria for tests of penetration seal M.1 C The listed criteria are included in designs. M.2 documents discussed under item 38.

M.3

40. Fire doors shall be self -closing or provided with N AC See Section 9A.3.2.2 closing mechanisms.

41. Fire doors shall be inspected semiannually to verify N AC Fire doors that are not electrically that automatic hold open, release, and closing supervised will be inspected semiannually.

mechanisms and latches are operable. For doors that are electrically supervised, this supervision provides continual verification that the doors are in the closed position.

42. Alternative means for ensuring that fire doors protect N.1 C See Section 9A.3.2.2 the door opening as required in case of fire. N.2 N.3 N.4

43. The fire brigade Leader shall have ready access to keys N C for any locked fire doors.

44. Areas protected by automatic total flooding gas N C The only automatic total flooding gas suppression systems shall have electrically supervised suppression systems are the halon systems self-closing fire doors or shall satisfy option 1 above. in the areas under the raised floor of the auxiliary equipment room and the remot e shutdown room. There are no fire doors into these areas.

Oil Collection System for Reactor Coolant Pump

45. The reactor coolant pump shall be equipped with an oil 0 NA The primary containment is inerted with collection system if the containment is not inerted nitrogen during normal reactor operation.

during normal operation.

APPENDIX 9A 9A-97 REV. 20, SEPTEMBER 2020

LGS UFSAR 9A.3.2.2 Explanatory Notes for Appendix R Comparison Item 3 Appendix R Guideline These supplies shall be separated so that a failure of one supply will not result in a failure of the other supply.

LGS Design The Unit 1 and Unit 2 circulating water systems are completely separate, so that any failures occurring in one system will not affect the other system. The two fire pumps are located in separate compartments within the circulating water pump structure. The connections of the fire pump discharge lines to the fire main loop are located underground to minimize the potential for damage to the piping.

Item 5 Appendix R Guideline When storage tanks are used for combined service water/fire water uses, the minimum volume for fire uses shall be ensured by means of dedicated tanks or by some physical means such as a vertical standpipe for other water service. Administrative controls, including locks for tank outlet valves, are unacceptable as the only means to ensure minimum water volume.

LGS Design Storage tanks are not used as the sources of fire protection water. As noted in items 2 and 4 of Section 9A.3.2.1, fire protection water is obtained from the cooling tower basins of the Unit 1 and Unit 2 circulating water systems, each of which has a storage capacity of 7,200,000 gallons.

Although the cooling tower basins also serve as the water sources for the service water systems, the storage capacity of the cooling tower basins is sufficient to ensure an adequate water supply for both systems (service water and fire protection water) without dedicating a certain volume of water to either system.

One of the two cooling tower basins will become unavailable as a source of fire protection water if the basin is drained to allow maintenance of it, or if the stop logs are inserted in the 96 inch circulating water lines from the cooling tower to allow work on some portion of the circulating water system. In this situation, the fire pump suction valves from the affected circulating water line will be closed in order to avoid jeopardizing the operability of the fire pumps. The unaffected circulating water lines and cooling tower will remain available to provide fire protection water to both the fire pumps.

Item 6 Appendix R Guideline Other water systems used as one of the two fire water supplies shall be permanently connected to the fire main system and shall be capable of automatic alignment to the fire main system. Pumps, controls, and power supplies in these systems shall satisfy the requirements for the main fire APPENDIX 9A 9A-98 REV. 20, SEPTEMBER 2020

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

LGS Design The suction piping of the fire pumps is permanently connected to the 96 inch circulating water lines that supply water from the cooling towers to the main condensers. Since there are no pumps or valves located in the circulating water lines between the cooling tower basins and the connection points of the fire pump suction lines, no realignments are necessary to make the circulating water system available to provide water to the fire pumps. Therefore, there are no active failures of the circulating water system that could degrade the fire main system, and no special requirements are needed for the circulating water pumps or their associated power supplies and controls.

Item 9 Appendix R Guideline Standpipe and hose systems shall be installed so that at least one effective hose stream will be able to reach any location that contains or presents an exposure fire hazard to structures, systems, or components important to safety.

LGS Design Hose reels are located throughout the plant in areas that either contain systems and components important to safety or present an exposure fire hazard to such areas, with the exception of the spray pond pump structure. Fire suppression capability for the spray pond pump structure is provided by portable fire extinguishers.

As shown in Table 9A-1, the combustible loading in the various compartments of the spray pond pump structure is low enough that portable fire extinguishers are sufficient to extinguish any postulated fire. Those compartments that contain combustible materials are provided with fire detectors that annunciate in the control room. In addition, the spray pond pump structure is divided into two separate fire areas by a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire wall along the centerline of the structure. A postulated fire in either fire area will leave at least one method available to safely shut the plant down.

Item 18 Appendix R Guideline Except as provided for in paragraph G.3 of this section, where cables or equipment, including associated nonsafety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one of the following means of ensuring that one of the redundant trains is free of fire damage shall be provided:

a. Separation of cables and equipment and associated nonsafety circuits of redundant trains by a fire barrier having a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rating. Structural steel forming a part of or APPENDIX 9A 9A-99 REV. 20, SEPTEMBER 2020

LGS UFSAR supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier;

b. Separation of cables and equipment and associated nonsafety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustible or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area; or

c. Enclosure of cable and equipment and associated nonsafety circuits of one redundant train in a fire barrier having a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months rating. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.

LGS Design To the greatest extent practical, redundant trains of systems necessary to achieve and maintain hot shutdown are located in different fire areas, so that the redundant trains are separated by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire barriers. In fire areas where this is not possible due to restrictions on equipment location and electrical cable routing, the capability to achieve hot shutdown is maintained by one of the following alternate means:

a. Enclosing the equipment and cabling of one redundant train in a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire barrier.

b. Enclosing the equipment and cabling of one redundant train in a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months rated fire barrier, and providing fire detection and automatic fire suppression in the fire area.

c. Dividing a fire area into two portions so that a fire is postulated to occur in only one portion at a time. Division of a fire area is accomplished by establishing a 20 foot wide zone that is free of combustible materials, and providing a water curtain suppression system within the combustible free zone. Components and equipment of redundant trains of systems that are necessary to achieve hot shutdown are located on opposite sides of the combustible free zone. Cables that are needed for operation of one redundant train and are routed through the portion of the fire area that contains equipment of the other redundant train are enclosed in a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire barrier. Fire detection capability is provided on both sides of the combustible free zone.

d. Methods alternative to the foregoing are utilized in certain fire areas; these individual fire areas are discussed in Sections 9A.5.3, 9A.5.4, and 9A.5.5.

Item 20 Appendix R Guideline Alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room or zone under consideration, shall be provided:

a. Where the protection of systems whose function is required for hot shutdown does not satisfy the requirement of paragraph G.2 of this section; or APPENDIX 9A 9A-100 REV. 20, SEPTEMBER 2020

LGS UFSAR

b. Where redundant trains of systems required for hot shutdown located in the same fire area may be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems.

In addition, fire detection and a fixed fire suppression system shall be installed in the area, room, or zone under consideration.

LGS Design Systems whose function is required for hot shutdown are provided with protection against fire-caused damage in order to ensure that at least one of the redundant trains of these systems remains available in the event of a postulated fire and/or operation of a fire suppression system in any fire area or an alternative shutdown capability is provided to ensure that hot shutdown can be achieved. Alternative methods of shutdown are identified for fires which may occur in the control complex as discussed in Section 9A.5.3.

Components required for hot shutdown are designed so that rupture or inadvertent operation of fire suppression systems will not adversely affect the operability of these components. Where necessary, appropriate protection is provided to prevent impingement of water spray on components required for hot shutdown.

Alternative shutdown capability has been identified for fires that may occur in the control complex.

However, a fixed fire suppression system may not be provided in the area, room, or zone under consideration. Compliance with Position C.5.c of BTP CMEB 9.5-1 is discussed in Section 9A.3.1.1, Item 76.

Item 22 Appendix R Guideline Requirements for training of fire brigade members.

LGS Design Fire Protection program objectives for training fire brigade members is accomplished by using a combination of in plant areas and an off-site training facility that simulates plant physical conditions.

Drills are conducted in conformance with plant fire drill procedures.

An off-site facility enables drills to include the use of live fire conditions. These elements plus the use of breathing apparatus and full protective clothing create actual conditions that would be encountered during a real plant fire emergency. Additional drills, including backshift unannounced drills are conducted in plant areas throughout the year.

Item 23 Appendix R Guideline Emergency lighting units with at least an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.

APPENDIX 9A 9A-101 REV. 20, SEPTEMBER 2020

LGS UFSAR LGS Design Fixed self-contained lighting units with individual 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months battery power supplies are provided in all areas to which access may be needed for manual actuation of safe shutdown of equipment, and in access and egress routes thereto. The locations where remote actions are required for achieving safe shutdown in the event of a postulated fire are listed in Table 9A-14. Self-contained battery powered lighting units will maintain a lighting level of at least nominal 0.5 footcandle in the listed areas and in access and egress paths thereto.

In addition to the self-contained individual battery powered lighting units, there is an emergency lighting system consisting of an ac subsystem and an ac/dc subsystem. The emergency ac lighting is powered from Class IE buses which automatically transfer to the standby diesel generators upon loss of the normal power source. Emergency ac lighting is provided throughout the plant to maintain minimum lighting levels necessary for access to and operation of equipment for a period greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The general location of the emergency ac lighting and the associated lighting levels are shown on Table 9.5-12.

The emergency ac/dc lighting is normally powered from the Class IE buses. In the event of loss of the Class IE ac source, an automatic transfer switch immediately transfers this lighting to the 125 V dc non-Class IE station battery source. This power source will sustain the ac/dc lighting load on battery power for some period of time and could sustain the lights indefinitely if the diesel generator feeding the battery charger is available. All emergency ac/dc lighting fixtures are of the incandescent type. Emergency ac/dc lighting is provided throughout the plant to maintain minimum lighting levels necessary for access to and operation of equipment. The general location of the ac/dc lighting and the associated lighting levels are shown on Table 9.5-12.

The cables for both emergency lighting subsystems are routed exclusively in conduit, most of which is embedded in concrete. The locations of the power distribution buses and the cable routing for the two emergency lighting subsystems are separated to the extent practical such that a fire in any given area is not likely to cause the loss of both lighting subsystems in areas to which access is needed for the operation of safe shutdown equipment.

Item 31 Appendix R Guideline If the equipment and systems comprising the means to achieve and maintain hot shutdown conditions 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.

LGS Design There is no postulated fire in any given fire area that could cause the simultaneous loss of both the offsite and onsite power supplies. Therefore, an additional redundant onsite power supply is not needed to ensure that safe shutdown can be achieved.

APPENDIX 9A 9A-102 REV. 20, SEPTEMBER 2020

LGS UFSAR Item 33 Appendix R Guideline Materials for such repairs shall be readily available onsite and procedures shall be in effect to implement such repairs.

LGS Design A total of six different types of repair actions may be needed in order to compensate for the effects of fire-caused damage to equipment and systems involved in achieving and maintaining cold shutdown conditions. The six types of repair actions are described below.

a. It may be necessary to install a temporary cable in order to provide power to the ADS valves or the MSRVs and monitoring instruments at the Remote Shutdown Panel. The repair action is intended to ensure continued availability of electrical power to the ADS valves or MSRVs so that the valves can be opened by operators at the Control Room, PGCC, or Remote Shutdown Panel as necessary. In the case of power for the operation of the MSRVs from the Remote Shutdown Panel, power is also provided for the continued operation of Reactor Vessel and Suppression Pool instrumentation at the RSP. This repair action is only needed in the event of a loss of the ac power supplies to the battery chargers associated with the normal dc battery power supply. The temporary cable will be used to supply power from the Division 2 dc distribution panel to either the Division 1 or Division 3 circuit that provides power to the ADS valves or the MSRVs/RSP instruments.

b. The design of the ESW system includes intertie lines with both the Unit 1 service water system and the Unit 2 service water system. The intertie lines that allow water in the ESW piping to return to the service water system are each provided with two redundant air-operated isolation valves in series. When a given loop of the ESW system is placed in operation, the intertie lines associated with that particular loop need to be isolated in order to prevent long-term diversion of water from the ESW system to the service water system. It may be necessary to remove the air supply tubing for individual isolation valves to ensure that at least one valve in each intertie line closes and remains closed. This action is needed only if both isolation valves in a given intertie line remain open and cannot be reclosed during the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of ESW system operation. The isolation valves affected are HV-011-043, HV-011-048, HV-011-121, HV-011-124, HV-011-125, HV-011-221, and HV-011-225.

c. A source of compressed gas may be required to support ADS valve or MSRV operation. The gas is required to allow opening of the valves as required for depressurization and shutdown. An air jumper will be used to connect the tank of a diesel generator air start system to the primary containment instrument gas system. Another air jumper will be connected to open valve HV-059-1(2)29B and leads to valve SV-059-1(2)52A or B may be cut to open it and allow the compressed gas system to function. This repair is only required if the primary containment instrument gas system does not operate.

d. If the Control Room or Auxiliary Equipment Room HVAC system becomes unavailable due to fire damage, it may be necessary to provide a temporary means APPENDIX 9A 9A-103 REV. 20, SEPTEMBER 2020

LGS UFSAR of ventilating the affected rooms. Ventilation for the control room will need to be re-established no earlier than nine hours after the loss of HVAC. Ventilation of the auxiliary equipment room and remote shutdown panel room will need to be re-established no earlier than seven hours after the loss of HVAC. Ventilation of the 4 kV switchgear rooms and static inverter rooms via natural convection will need to be re-established no earlier than four hours after the loss of HVAC. If necessary, a temporary ventilation capability will be established for the main control room, auxiliary equipment room and remote shutdown panel area by setting up portable fans and flexible duct-work and by opening doors to create an air flow pathway.

The portable fans will be powered from either an onsite power source or a mobile diesel generator. A diesel generator that is dedicated to this service is stored onsite in a readily accessible location. Operability of the diesel generator will be ensured by a surveillance and maintenance program. This repair is only required if the normal HVAC fails as a result of the fire.

e. If the Spray Pond Pump Structure HVAC becomes unavailable due to fire damage, it may be necessary to provide a temporary means of ventilating the structure.

Ventilation of the structure needs to be re-established no earlier than four and a half hours after the loss of HVAC. If necessary, a repair will be performed to establish a flow path for natural convection through the structure. In addition to opening doors in the spray pond pump structure, it will be necessary to partially disassemble a damper mechanism in order to permit the damper to be opened manually. This repair is only required if the normal HVAC fails as a result of the fire.

f. It may be necessary to utilize existing station procedures for "Loss of Shutdown Cooling" to establish a flow path for RHR shutdown cooling. Permissives to open the shutdown cooling suction line inboard and outboard isolation valves and the shutdown cooling return line outboard isolation valves are not included in the FSSD model and may not be available post-fire. Existing station procedures provide direction to Operations to establish the shutdown cooling flow path. Repair actions will operate the valves at the MCC via the use of jumpers.

For all six types of repairs described above, the tools and materials needed to perform the repairs are stored in readily accessible locations on site. Procedures governing the implementation of the repairs are in effect.

Item 34 Appendix R Guideline If the equipment and systems comprising the means to achieve and maintain cold shutdown conditions (and which are used prior to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after the fire) will not be capable of being powered by both onsite and offsite power systems because of fire damage, an independent onsite power system shall be provided.

LGS Design There is no postulated fire in any given fire area that could cause the simultaneous loss of both the offsite and onsite power supplies. Therefore, an additional redundant onsite power supply is not needed for permanent plant equipment to ensure that safe shutdown can be achieved. A mobile APPENDIX 9A 9A-104 REV. 20, SEPTEMBER 2020

LGS UFSAR diesel generator is stored onsite for use in providing power to temporary fans that may be needed to provide ventilation for the control room, auxiliary equipment room, and remote shutdown room.

Item 38 Appendix R Guideline Penetration seal designs shall be qualified by tests that are comparable to tests used to rate fire barriers.

LGS Design The designs of penetration seals in fire-rated barriers are tested to verify that the penetration seals are adequate to provide a specific degree of protection against the propagation of fire through the barriers. These tests are performed in accordance with the guidelines provided in the following documents:

a. Institute of Electrical and Electronics Engineers, IEEE 634 (1978), "IEEE Standard Cable Penetration Fire Stop Qualification Test".

b. NRC, Draft Regulatory Guide, "Qualification Test for Cable Penetration Fire Stops for Use in Nuclear Power Plants", (July 1979).

c. NEL-PIA/MAERP, "Standard Method of Fire Tests of Cable and Pipe Penetration Fire Stops", (February 1976).

d. American Nuclear Insurers, "ANI Position on Fire Stop Test Standards",

(September 1979).

Item 40 Appendix R Guideline Fire doors shall be self-closing or provided with closing mechanisms.

LGS Design With the exception of watertight doors, all fire doors are provided with one of the following two features:

a. A self-closer to ensure that a normally closed door returns to the closed position after someone passes through it.

b. An automatic closing mechanism to ensure that a normally open door will close if there is a fire in the vicinity of the door.

Watertight doors that also serve as fire doors cannot be provided with self-closers or automatic closing mechanisms, due to the inherent restrictions of their design and function. These watertight doors are electrically supervised or inspected daily.

APPENDIX 9A 9A-105 REV. 20, SEPTEMBER 2020

LGS UFSAR Item 42 Appendix R Guideline One of the following measures shall be provided to ensure they will protect the opening as required in case of fire:

a. Fire doors shall be kept closed and electrically supervised at a continuously manned location;

b. Fire doors shall be locked and inspected weekly to verify that the doors are in the closed position;

c. Fire doors shall be provided with automatic hold open and release mechanisms and inspected daily to verify that doorways are free of obstructions; or

d. Fire doors shall be kept closed and inspected daily to verify that they are in the closed position.

LGS Design Appropriate steps are taken to ensure that safe shutdown fire doors either are closed or will close when required in the event of a fire. One of the four measures listed above is followed for each safe shutdown fire door .

APPENDIX 9A 9A-106 REV. 20, SEPTEMBER 2020

LGS UFSAR 9A.4 EVALUATION OF POTENTIAL FIRE HAZARDS 9A.4.1 SCOPE OF EVALUATION This chapter provides an evaluation of the potential for occurrence of fires within the plant and a summary of the capabilities of the existing fire protection program. This evaluation was performed for all structures that contain safety-related equipment or could affect safety-related structures by virtue of the fire hazards present.

A review of the plant was made to identify the combustible materials present, quantify the fire hazard in terms of combustible loading, and relate the potential hazard to the capabilities of the existing fire barriers and fire suppression systems. This information is presented in Table 9A-1 which lists the type of combustible materials present in each fire zone, the corresponding combustible loading, and the availability of detection and suppression equipment. Figures 9A-4 through 9A-12 show the locations of the fire zones, fire barriers, and fire suppression coverage.

9A.4.2 PROCEDURE The evaluation of fire hazards was performed using a procedure that is summarized by the following steps:

a. For identification purposes, the various structures of the plant were divided into specific fire areas. A fire area is defined as that portion of a structure that is separated from other areas by boundaries (walls, floors, and ceilings) which are of a type of construction which is sufficient to prevent the spread of fire across the boundary, considering the combustible loading in the area. Many fire areas were further subdivided into fire zones to permit more precise identification of the locations of combustible materials, fire detection and suppression systems, and components associated with safety-related systems. The breakdown into fire zones was based on the locations of interior walls and slabs within each fire area. Fire areas are identified by a unique number, and fire zones within the same fire area are identified by a subletter. The fire area and fire zone designations are listed in Table 9A-1 "AREA-ZONE".

b. Each fire zone was surveyed to determine the type, quantity, and distribution of combustible materials present.

c. The combustible loading for each fire zone is determined based on the quantity of combustible materials present and the heat of combustion of each type of combustible material. The heat of combustion values used in this analysis are listed in Table 9A-2. The quantity of each type of combustible material (UNIT) is multiplied by the appropriate heat of combustion (BTU/UNIT) to determine the heat release (BTU) of each type of combustible material. The total heat release of all combustibles in the fire zone was then calculated by adding the heat release of each combustible material. To obtain the combustible loading (in BTU/ft2) for each fire zone, the total heat release (in BTU) was divided by floor area of the fire zone.

d. The methodology for calculating fire severity (hours) is based on information presented in the 17th edition of the NFPA Handbook. The methodology uses the relationship between the calculated fire load in an area and an exposure to a fire severity which is equivalent to the standard time-temperature curve which is used APPENDIX 9A 9A-107 REV. 14, SEPTEMBER 2008

LGS UFSAR as the exposure fire in the fire resistance rating tests (ASTM E-119). The steps involved in calculating fire severity are as follows:

1. Calculate the fire load (BTU/ft2) for an area as stated within the methodology.

2. Divide the calculated fire load by 80,000 BTU/ft 2hr to obtain fire severity:

Fire Load BTU / ft2 Fire Severity =

80,000 BTU / ft2 hr

e. The clarification of the fire loading in a zone is based on the results of fire loading studies performed by the British (contained in the 17 h edition of the Fire Protection Handbook). The results of the study show that the loading in an occupancy can be classified as low, moderate, or high, defined by the fire loading (BTU/ft2) of the occupancy. The classifications are defined as follows:

Low - The fire load of a zone is classified as low if it does not exceed an average of 60,000 BTU/ft2 of floor area. This loading corresponds to a fire severity of 45 minutes using the standard time temperature curve (ASTM E-119). Classification of fire load in a fire zone or area as low identifies the zone as having a fire severity below that which could be expected to be contained within a 1-hr fire rated enclosure.

Moderate - The fire load of a zone is classified as moderate if it exceeds an average of 60,000 BTU/ft2 but does not exceed an average of 140,000 BTU/ft2 of floor area. This loading corresponds to a fire severity of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , 45 minutes using the standard time temperature curve. Classification of fire load in fire zone or area as moderate identifies the zone as having a fire severity below that which could be expected to be contained within a 2-hr fire rated enclosure.

High - The fire load of a zone is classified as high if it exceeds an average of 140,000 BTU/ft2 of floor area. This loading corresponds to a fire severity in excess of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , 45 minutes using the standard time temperature curve. Classification of fire zone or area as high identifies the zone as having a fire severity which could be expected to be contained within a 3-hour fire rated enclosure provided the defense in depth concept has been provided for high hazard concentrations of combustibles.

No Combustibles Allowed - Item 112 of Section 9A.3.1.2, Explanatory Notes for Comparison to Branch Technical Position CMEB 9.5-1 address a deviation from the installation of automatic fire detection in certain fire zones based on the lack of combustible material located in these APPENDIX 9A 9A-108 REV. 14, SEPTEMBER 2008

LGS UFSAR areas. Therefore, in order to comply with the commitments identified in item 112 no combustible materials are allowed.

Control of Combustibles - The NRC granted a deviation on separation requirements based on fire protection defense-in-depth features and low combustible loading. In order to maintain the basis for the deviation from separation requirements, the combustible loading in these areas shall be controlled. Any increase in combustible loading shall be reviewed and approved by the licensee's fire protection engineer.

APPENDIX 9A 9A-109 REV. 14, SEPTEMBER 2008

LGS UFSAR 9A.5 ANALYSIS OF CAPABILITY TO ACHIEVE SAFE SHUTDOWN 9A.5.1 METHODOLOGY This chapter provides an evaluation of the effects of postulated fires in each fire area on the ability of the operator to achieve a safe shutdown of the plant. Of the numerous possible combinations of equipment that could be used to effect a safe shutdown, four specific combinations were selected for detailed study for the purposes of this evaluation. These four shutdown methods are described in Section 9A.5.2.

In performing the safe shutdown analysis, the four shutdown methods were examined to determine the minimum equipment, control, and power requirements for operability of each method. The locations of the equipment itself and the cabling associated with the required equipment were identified with respect to the various fire areas.

Each fire area was then examined to determine which components associated with the shutdown methods, if any, would be rendered inoperable by the occurrence of a fire within the fire area. The results of the safe shutdown analysis are summarized in Sections 9A.5.3 through 9A.5.9 for each fire area.

The following assumptions were used in performing the safe shutdown analysis:

a. No credit is taken for manual fire fighting efforts or the operation of automatic fire suppression systems. The fire is assumed to disable all equipment and electrical cabling located in the fire area, unless the fire hazard analysis demonstrates otherwise. An electrical cable tray fire is assumed not to propagate from one tray to another, since separation is provided in accordance with Regulatory Guide 1.75.

b. Plant accidents and severe natural phenomena are not considered to occur concurrently with the postulated fire.

c. A single active component failure is not assumed to occur concurrently with the fire.

d. Credit is taken for reactor trip. Any fire affecting the RPS or the CRD circuitry will not prevent the reactor from being tripped. A reactor trip can be performed manually (in the control room), automatically (by the RPS logic), or by tripping the RPS power supplies (in the auxiliary equipment room).

e. No credit is taken for proper operation or proper positioning of equipment which is not separated or protected in accordance with the guidelines of 10CFR50, Appendix R, unless the safe shutdown analyses presented in Sections 9A.5.3 and 9A.5.4 demonstrate the adequacy of the existing design. For such equipment, loss of operability or spurious operation is assumed, whichever is more conservative.

This assumption provides a worst case analysis regarding spurious signals associated with cabling failures in a fire area.

f. For Alternative or Dedicated Shutdown Capability as defined in Chemical Mechanical Engineering Branch Technical Position (CMEBTP) 9.5-1, "Fire Protection Program", and 10CFR50, Appendix R, III, L, offsite power is assumed to be unavailable during the first 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after the onset of the fire. However, no APPENDIX 9A 9A-110 REV. 20, SEPTEMBER 2020

LGS UFSAR credit is taken for loss of offsite power in situations for which a loss of offsite power would be advantageous.

g. For Safe Shutdown, as defined in Chemical Mechanical Engineering Branch Technical Position 9.5-1, (CMEBTP) "Fire Protection Program", and 10CFR50, Appendix R, III, offsite power is assumed to be available: except if the fire would cause a loss of offsite power.

One single spurious operation of a non-high/low pressure interface FSSD component is postulated to occur for a fire event. Any number of hot shorts, open circuits, or shorts to ground may occur, but they will result in only one single spurious actuation. Three phase hot shorts of the proper voltage and phase sequence capable of spuriously operating a device are not postulated.

In the discussions of individual fire areas contained in Sections 9A.5.3 through 9A.5.9, paragraph (c) addresses the nature of the fire that is postulated to occur in each fire area. Paragraph (c) relates to potential fires involving in situ combustible materials, and does not preclude the postulation of fires involving transient combustibles. In all cases, the safe shutdown analysis and the resulting fire protection features for each fire area are based on the potential for an exposure fire to affect all components and cables within the fire area.

Those floor slabs identified by an asterisk following the indicated fire rating in the fire area discussions contained in Sections 9A.5.3 through 9A.5.9 are discussed in Item 37 of Section 9A.3.1. Those fire doors identified in Sections 9A.5.3 through 9A.5.9 by a double asterisk (**)

following the indicated fire rating are discussed in Item 48 of Section 9A.3.1.

9A.

5.2 DESCRIPTION

OF REACTOR SHUTDOWN METHODS The following sections provide descriptions of methods that can be used for reactor shutdown and cooldown. Each of these methods includes a system by which makeup water can be added to the reactor vessel, a system by which energy can be removed from the reactor vessel, and any support systems needed to accommodate energy removal to an ultimate heat sink or to return water to its supply source.

Although the safe shutdown analysis for the various fire areas places primary emphasis on achievement of reactor shutdown using the methods described below, many alternative shutdown methods would be available. Use of safety-related and nonsafety-related systems not addressed in the safe shutdown analysis, plus manual operation of certain equipment and controls, would provide numerous combinations of systems with adequate capability to safely shut the plant down.

9A.5.2.1 Reactor Shutdown With Balance of Plant Cooling Systems Available After the turbine-generator has been tripped and all control rods inserted into the reactor core during the course of a normal shutdown and cooldown, reactor decay heat and sensible heat is removed by bypassing main steam to the condenser. Heat is removed from the condenser by the circulating water system and rejected to the atmosphere by the cooling tower. Makeup water is supplied to the reactor vessel by the condensate and feedwater system, taking suction on the condenser hotwell. When the reactor has been depressurized below a nominal 75 psig, the RHR system is initiated in the shutdown cooling mode of operation. In this mode, reactor water is circulated through the RHR heat exchangers, where it is cooled by the RHRSW system. Heat is rejected from the RHRSW system to the atmosphere by using either the cooling tower or the spray pond. The reactor vent valves are opened when reactor pressure reaches atmospheric.

APPENDIX 9A 9A-111 REV. 20, SEPTEMBER 2020

LGS UFSAR 9A.5.2.2 Reactor Shutdown Without Balance of Plant Cooling Systems Available Four specific methods of achieving cold shutdown and maintaining the plant in that condition have been defined for use in analyzing the capability to safely shut the plant down in the event of a fire.

Three of the specific shutdown methods (designated as methods A, B and C) are directed from the Main Control Room and may be supplemented by local operator actions, including actions at the Remote Shutdown Panel (RSP). The fourth shutdown method (designated as method R) is directed from the RSP and may be supplemented by local operator actions. Shutdown methods A, B, C and R each include systems and components necessary to accomplish the major functions of (a) providing makeup water to the reactor vessel, (b) depressurizing the reactor vessel, and (c) removing decay heat and sensible heat from the primary containment. The systems in each shutdown method that are directly relied on for accomplishing these functions are as follows:

Shutdow Pressure Inventory Decay Heat Removal Decay Heat Removal n Method Control Control (Vessel) (Pool)

A ADS RCIC RHR in Shutdown RHR in the Suppression or Cooling Mode Pool Cooling Mode MSRV or Alternate Shutdown Cooling Mode B ADS HPCI RHR in Shutdown RHR in the Suppression or Cooling Mode Pool Cooling Mode MSRV or Alternate Shutdown Cooling Mode C ADS RHR in the RHR in Shutdown RHR in the Suppression or LPCI Mode Cooling Mode Pool Cooling Mode MSRV or Alternate Shutdown Cooling Mode R MSRV RCIC RHR (Loop A) in RHR (Loop A) in the Shutdown Cooling Mode Suppression Pool Cooling Mode The main safe shutdown components that may be relied upon to achieve safe shutdown using these methods are listed in Table 9A-4.

Method A After closure of the Main Steam Isolation Valves (MSIVs), the RCIC system is used to supply makeup water to the reactor vessel from the suppression chamber. The operation of the RCIC system also removes energy from the reactor in the form of steam to drive the RCIC turbine.

During the period in which steam is generated at a rate greater than the consumption of the RCIC system, steam is relieved to the suppression pool by automatic actuation of the Main Steam Relief Valves (MSRVs), which open when reactor pressure reaches the valve setpoint.

Heat is removed from the suppression pool by operating a loop of the RHR system in the suppression pool cooling mode. In this mode, water from the suppression pool is circulated through the RHR heat exchanger and then returned to the suppression pool. In order to initiate APPENDIX 9A 9A-112 REV. 20, SEPTEMBER 2020

LGS UFSAR operation of the shutdown cooling mode of the RHR system, it is necessary to depressurize the reactor below a nominal pressure of 75 psig. This is accomplished by using the ADS valves or MSRVs to discharge steam to the suppression pool. When the reactor has been depressurized below 75 psig, operation of the RCIC system is terminated and the RHR system is switched from the suppression pool cooling mode to the shutdown cooling mode. An alternate shutdown cooling mode has been defined and may be used with Method A instead of the standard shutdown cooling mode. This involves using the RHR pump to circulate water from the suppression pool through the RHR heat exchanger and discharge it into the reactor vessel through the LPCI injection line or through the shutdown cooling return line to the reactor recirculation loop. Water from the reactor vessel is returned to the suppression pool by opening one or more of the ADS valves or MSRVs. The water level in the reactor vessel rises to the main steam line nozzles , allowing water to partially fill the main steam lines and then flow through the open relief valve and down the MSRV discharge line to the suppression pool.

In the suppression pool cooling mode and the shutdown cooling modes, heat is removed from the RHR heat exchanger by the RHRSW system, which in turn dissipates heat at the spray pond. The shutdown cooling or alternate shutdown cooling mode of RHR will maintain the reactor in a cold shutdown condition.

Depending on the location of a fire within the plant, certain operations that are used in this shutdown method may need to be performed manually from outside the control room. The specific operations are identified in Table 9A-14.

Method B After closure of the Main Steam Isolation Valves (MSIVs), the HPCI system is used to supply makeup water to the reactor vessel from the suppression chamber. The operation of the HPCI system also removes energy from the reactor in the form of steam to drive the HPCI turbine.

During the period in which steam is generated at a rate greater than the consumption of the HPCI system, steam is relieved to the suppression pool by automatic actuation of the Main Steam Relief Valves (MSRVs), which open when reactor pressure reaches the valve setpoint.

Heat is removed from the suppression pool by operating a loop of the RHR system in the suppression pool cooling mode. In this mode, water from the suppression pool is circulated through the RHR heat exchanger and then returned to the suppression pool. In order to initiate operation of the shutdown cooling mode of the RHR system, it is necessary to depressurize the reactor below a nominal pressure of 75 psig. This is accomplished by using the ADS valves or MSRVs to discharge steam to the suppression pool. When the reactor has been depressurized below 75 psig, operation of the HPCI system is terminated and the RHR system is switched from the suppression pool cooling mode to the shutdown cooling mode. An alternate shutdown cooling mode has been defined and may be used with Method B instead of the standard shutdown cooling mode. This involves using the RHR pump to circulate water from the suppression pool through the RHR heat exchanger and discharge it into the reactor vessel through the LPCI injection line or through the shutdown cooling return line to the reactor recirculation loop. Water from the reactor vessel is returned to the suppression pool by opening one or more of the ADS valves or MSRVs. The water level in the reactor vessel rises to the main steam line nozzles , allowing water to partially fill the main steam lines and then flow through the open relief valve and down the MSRV discharge line to the suppression pool.

In the suppression pool cooling mode and the shutdown cooling modes, heat is removed from the RHR heat exchanger by the RHRSW system, which in turn dissipates heat at the spray APPENDIX 9A 9A-113 REV. 20, SEPTEMBER 2020

LGS UFSAR pond. The shutdown cooling or alternate shutdown cooling mode of RHR will maintain the reactor in a cold shutdown condition.

Depending on the location of a fire within the plant, certain operations that are used in this shutdown method may need to be performed manually from outside the control room. The specific operations are identified in Table 9A-14.

Method C After closure of the MSIVs, the reactor is depressurized by manually controlling the valves of the ADS or three or more MSRVs. The opening of these valves allows reactor steam to be discharged to the suppression pool. Makeup water is supplied to the reactor vessel from the suppression pool by operating a loop of the RHR system in the LPCI mode after reactor pressure has decreased to a nominal 295 psig. When the reactor has been depressurized below 75 psig, the RHR system is switched from the suppression pool cooling mode to the shutdown cooling mode. An alternate shutdown cooling mode has been defined and may be used with method C instead of the standard shutdown cooling mode. This involves using the RHR pump to circulate water from the suppression pool through the RHR heat exchanger and discharge it into the reactor vessel through the LPCI injection line or through the shutdown cooling return line to the reactor recirculation loop. Water from the reactor vessel is returned to the suppression pool by opening one or more of the ADS valves or MSRVs. The water level in the reactor vessel rises to the main steam line nozzles , allowing water to partially fill the main steam lines and then flow through the open relief valve and down the MSRV discharge line to the suppression pool.

In the suppression pool cooling mode and the shutdown cooling modes, heat is removed from the RHR heat exchanger by the RHRSW system, which in turn dissipates heat at the spray pond. The shutdown cooling or alternate shutdown cooling mode of RHR will maintain the reactor in a cold shutdown condition.

Depending on the location of a fire within the plant, certain operations that are used in this shutdown method may need to be performed manually from outside the control room. The specific operations are identified in Table 9A-14.

Method R - Reactor Shutdown from Outside the Control Room In the unlikely event that a fire disables or requires evacuation of the Control Room, an alternative shutdown capability is provided compliant with Position C.5.c of BTP CMEB 9.5-1.

The capability is designated as shutdown method R and is used to effect a plant shutdown directed from the Remote Shutdown Panel (RSP).

The shutdown sequence is similar to Shutdown Method A except that the methodology is centered around equipment that may be controlled from the RSP. After closure of the Main Steam Isolation Valves (MSIVs), the RCIC system is used to supply makeup water to the reactor vessel from the suppression chamber. The operation of the RCIC system also removes energy from the reactor in the form of steam to drive the RCIC turbine. During the period in which steam is generated at a rate greater than the consumption of the RCIC system, steam is relieved to the suppression pool by automatic actuation of the Main Steam Relief Valves (MSRVs), which open when reactor pressure reaches the valve setpoint. Heat is removed from the suppression pool by operating the A loop of the RHR system in the suppression pool cooling mode. In this mode, water from the suppression pool is circulated through the RHR heat APPENDIX 9A 9A-114 REV. 20, SEPTEMBER 2020

LGS UFSAR 9A.6 SPECIAL TOPICS 9A.6.1 ANALYSIS OF ASSOCIATED CIRCUITS Generic Letter 81-12, issued by the NRC on February 20, 1981, discussed the types of information that the NRC considers necessary for the completion of their reviews of safe shutdown capability in the event of a fire. One of the enclosures to Generic Letter 81-12 addressed the subject of associated circuits and the possibility that fire-induced damage to associated circuits could prevent operation or cause maloperation of the shutdown methods designated to be used in the event of a fire in the plant. Generic Letter 81-12 defines associated circuits to be those circuits (either safety-related or nonsafety-related) that have a separation from the equipment and cables of the redundant safe shutdown methods that is less than that required by section III.G.2 of Appendix R to 10CFR50 and also have any of the following:

a. A common power source with the safe shutdown equipment, and the power source is not electrically protected from the circuit by coordinated circuit breakers, fuses, or similar devices.

b. A connection to circuits of equipment whose spurious operation could adversely affect the shutdown capability.

c. A common enclosure or raceway with safe shutdown cables, and are not electrically protected by circuit breakers, fuses, or similar devices.

In accordance with guidance contained in Generic Letter 81-12, an analysis has been performed for LGS to verify that fire-induced damage to associated circuits will not jeopardize the plant's safe shutdown capability. This analysis utilizes a systems approach, wherein the features of circuit design, such as overcurrent protection, are evaluated together with cable routing and separation criteria in order to confirm the adequacy of the electrical system design to prevent fire-induced damage to nonsafe shutdown circuits from jeopardizing safe shutdown capability. The methodology and results of the analysis are summarized in the following sections.

9A.6.1.1 Associated Circuits Involving Common Power Sources All systems and components that are relied on for achieving safe shutdown receive power from the Class 1E ac distribution system or Class 1E dc power system. Offsite power may be credited as the source for the Class 1E ac distribution system for fire areas which do not require Alternative Shutdown and for which the offsite source(s) to the 4kV switchgear is not affected by fire damage. The Emergency Seal Oil Pump (ESOP) that services the main generator and the Emergency Bearing Oil Pump (EBOP) that services the main turbine are powered exclusively by a dedicated non-Class 1E battery and do not involve a common power source with other plant equipment or systems. The main feed from the battery and the battery charger to both motors are protected by coordinated fault actuated protective devices. All other circuits, both Class 1E and non-Class 1E, are individually protected by coordinated fault actuated protective devices. Proper coordination among these protective devices is demonstrated by the time-current coordination curves shown in Figures 9A-13 through 9A-15 for the 4 kV and 440 V ac system, Figure 9A-16 for the 120 V ac system, and Figures 9A-17 through 9A-20 for the 125/250 V dc system. These curves are typical for each type of protective device and application that is represented. The time-current coordination curves show that for each voltage level, the individual circuit breakers or fuses will clear a fault prior to the operation of the source breaker or fuse protecting the source bus. Consequently, the fault-actuated protective devices will act to isolate any APPENDIX 9A 9A-307 REV. 20, SEPTEMBER 2020

LGS UFSAR faulted circuit without jeopardizing the availability of other circuits connected to the same power source.

Because of the use of fault-actuated protective devices in power circuits as described above, LGS does not have associated circuits involving common power sources, as defined by Generic Letter 81-12.

9A.6.1.2 Associated Circuits Involving Spurious Operation Components whose spurious operation could adversely affect the shutdown capability are considered to be essential for safe shutdown of the plant. These components and the circuits that serve them are therefore treated as part of the safe shutdown systems and are included in the review of separation between the different shutdown methods. Item 18 of Section 9A.3.2.2 describes the physical separation, fire barriers, and suppression systems that are provided to ensure that at least one shutdown method remains available to shut the plant down in the event of a fire.

Because of the design and analysis approach described above, LGS does not have associated circuits involving spurious operation, as defined by Generic Letter 81-12.

9A.6.1.3 Associated Circuits Involving Common Enclosures and Raceways Separation between the different divisions of Class 1E circuits and between Class 1E and non-Class 1E circuits is discussed in Sections 7.1.2.2.3.2 and 8.1.6.1.14.b. Cabling for Class 1E circuits is routed only in raceways designated for Class 1E use. Cabling for non-Class 1E circuits is routed only in raceways designated for non-Class 1E use, except for selected non-Class 1E loads fed from Class 1E buses, which are identified and treated as Class 1E and are routed in dedicated Class 1E raceways. Non-Class 1E cables identified and treated as Class 1E do not become associated with other Class 1E divisions.

The potential for propagation of an electrical fire in enclosures (either raceways or panels) is minimized by the selection of appropriate cable construction systems and by the provision of physical separation. Insulation and jacketing materials used in both Class 1E and non-Class 1E cables are flame retardant, as discussed in Table 9A-3.

As discussed in Section 9A.6.1.1, circuits are individually protected by coordinated fault-actuated protective devices. This protection ensures that faulted circuits in common enclosures will be isolated.

Because of the provisions described above for preventing fire propagation and isolating circuit faults in common enclosures, LGS does not have associated circuits involving common enclosures, as defined by Generic Letter 81-12.

9A.6.1.4 Summary For the reasons discussed in the preceding sections, LGS does not have associated circuits in any of the three categories established by Generic Letter 81-12. Therefore, fire-induced damage to circuits that are not designated as necessary for safe shutdown will not affect the operability of any of the four safe shutdown methods described in Section 9A.5.2.2.

9A.6.2 ANALYSIS OF HIGH/LOW PRESSURE INTERFACES APPENDIX 9A 9A-308 REV. 20, SEPTEMBER 2020

LGS UFSAR Generic Letter 81-12, issued by the NRC on February 20, 1981, discussed the types of information that the NRC considers necessary for the completion of their reviews of safe shutdown capability in the event of a fire. One of the enclosures to Generic Letter 81-12 addressed the subject of interfaces between high pressure and low pressure systems. The NRC's concern involves the valves that serve to isolate low pressure systems from the high pressure reactor coolant system. If the isolation valves at a given interface point consist of two electrically controlled valves in series, and a single fire could damage the cabling associated with both valves, both valves could be caused to open. This consequence could result in a fire-induced LOCA through the high/low pressure system interface.

Information Notice 87-50, issued by the NRC on October 9, 1987, expressed a concern that spurious opening of high/low pressure interface isolation valves would overpressurize the low pressure systems connected to the reactor coolant system, thereby creating the potential for a LOCA that cannot be isolated. The information notice specifically addressed the case of a bypass line around a check valve in the discharge lines of the RHR system for certain plants. This information notice states that "Because of this bypass line around the check valve, credit for the check valve in preventing a LOCA at the high and low pressure interface can no longer be given."

A review of the LGS design has been performed to verify that a high/low pressure interface LOCA cannot be caused by a single fire. Each system that contains interfaces between the RCPB and low pressure portions of the system was reviewed to identify the valves that provide isolation at the interface point, and also to assess the susceptibility of the valves to simultaneous opening due to fire-caused damage. Table 9A-12 identifies each such high/low pressure interface and lists the valves at the interface point.

9A.6.3 FIRE BARRIER PENETRATION ASSEMBLIES FOR 4 KV BUS DUCTS At el 239' in the control structure, 4 kV nonsegregated phase bus ducts penetrate some of the walls that separate the 4 kV switchgear compartments (fire areas 12 through 19) from each other and from adjacent compartments. The bus ducts are either 15.4 by 36 inches or 19.4 by 36 inches in size, and are constructed of steel plate having a thickness of 0.119 inch. Inside these steel ducts, copper bus bars are supported by porcelain insulators. At each wall penetration, a smoke and hot gas barrier is provided internal to the duct. The bus duct penetrations have been evaluated as being adequate for the hazards present. See reference 9A.7.12.

9A.6.4 ANALYSIS OF EFFECTS OF MULTIPLE HIGH-IMPEDANCE FAULTS ON THE SAFE SHUTDOWN CAPABILITY OF THE PLANT The NRC response to question No. 5.3.8 of "Appendix R Questions and Answers", an enclosure to Generic Letter 86-10 (issued by the NRC on April 24, 1986) states that in order to meet the separation criteria of sections III.G.2 and III.G.3 of Appendix R, multiple high impedance faults should be considered for all associated (nonsafe shutdown) circuits located in the fire area of concern.

In accordance with the guidelines contained in Generic Letter 86-10, a calculation has been performed for LGS to verify that postulated high impedance faults resulting from fire-induced damage to safe shutdown cables and associated (nonsafe shutdown) cables supplied from the same bus will not jeopardize the plant's safe shutdown capability. The calculation involved a review of protective device coordination with consideration given to multiple high impedance faults for power cables at the 13.2 kV, 4.16 kV, 480 V, and 120/208 V levels of the ac power distribution APPENDIX 9A 9A-309 REV. 20, SEPTEMBER 2020

LGS UFSAR system and at the 125 V and 250 V levels of the dc power distribution system. The methodology used in the calculation is based on the intention of implementing restorative actions for manually clearing the effects of multiple high impedance faults if the effects were determined to be detrimental to safe shutdown capability. The methodology used and the results of this study are summarized in the following sections.

9A.6.4.1 Methodology and Assumptions To determine if restorative actions were required for a particular circuit, a phase analysis approach was utilized as described below.

Phase 1 analysis is a gross screening of the power sources that support safe shutdown loads to evaluate the effects of a High Impedance Fault (HIF) load on the power source circuit breaker or fuse. All circuits from a safe shutdown bus are considered as experiencing simultaneous HIFs regardless of fire area influence. The combined load and HIF current is assumed just below the trip setpoint of the associated branch breaker and to continue indefinitely. The sum of all HIF and load currents on bus is determined and compared with the trip characteristics of the power supply protective device. The high impedance fault current contribution for each load was taken to be equal to the 1000 second current rating of the load's protective device. This value was chosen since it is the maximum current the protective device can pass for an indefinite time without a trip.

The high impedance fault currents were summed and compared to the 60 second rating of the feeder breaker. If the sum was less than this rating, no restorative actions were considered to be necessary.

The basis for this approach is a flame test that was performed by the licensee for the PBAPS and which showed that 54 seconds was the maximum duration of an high impedance fault. As before, if the high impedance fault current applied to the feeder breaker did not exceed its 60 second rating, no restorative actions were deemed necessary.

Phase 2 of the analysis is applied to those panels that fail the Phase 1 analysis. This analysis is performed in more detail using the actual circuit routing on a per fire area basis, with only those cables routed through the fire area of concern experiencing a simultaneous HIF. Phase 3 of the analysis is applied to those panels that fail the Phase 2 analysis and review normally de-energized loads while considering the routing of both power and control cables when evaluating specific fire areas. Phase 4 of the analysis is applied to those panels that fail the Phase 3 analysis. This Phase determines if the failed panels are required for safe shutdown in the subject fire area and whether restorative procedures are technically feasible to maintain panel operability in the event of a fire.

9A.6.4.2 Results The results and conclusions derived in this calculation were input into the LGS Fire Area Analysis Calculations which sufficiently demonstrate that the LGS post-fire safe shutdown capability for both units will not be jeopardized due to fire-induced multiple high impedance faults.

9A.6.5 MINIMUM EFFECTIVE DESIGN DENSITY (MEDD)

This Section will discuss the use of the Minimum Effective Design Density (MEDD) concept for determining the operability of water based suppression systems at the Limerick Generating Station Units 1 and 2 (LGS).

APPENDIX 9A 9A-310 REV. 20, SEPTEMBER 2020

LGS UFSAR In general, the design basis of the Limerick Generating Station sprinkler systems is to provide a density of 0.30 gpm/ft2 over the hydraulically most remote 3000 ft2 (unless specified otherwise).

Limerick Technical Specifications (now Technical Requirements Manual) define OPERABILITY as...

A system, subsystem, train, component, or device shall be operable or have operability when it is capable of performing its specified function(s).

In the referenced paragraph above, the words capable of performing its specific function(s) as applied to suppression systems, means their ability to control a fire. A literature review of fire test information on cable and oil fires was performed to determine the minimum effective design density. The focus of this review was to determine how low the design density could be and still extinguish a fire. The literature review was intended to determine the minimum effective design density that will control a fire.

EPRI Research, Sandia National Laboratories and Factory Mutual test reports were reviewed to determine the minimum effective density necessary to extinguish a cable tray fire or oil spill fire.

These two fire scenarios were selected because they present the greatest challenge to the plant sprinkler systems and these were the fires postulated in the FPER for the plant areas protected by the majority of the Technical Requirements Manual sprinkler systems.

A variety of tests and studies performed by Factory Mutual Research Corporation and Sandia National Laboratories were reviewed to determine the minimum effective density for automatic water based suppression systems at LGS. The purpose of the tests and studies performed was to determine the required automatic sprinkler design density necessary to extinguish a developing fire in grouped cable tray installations and oil spill fires.

9A.6.5.1 Cable Tray Fires Literature reviewed indicated that a delivered water application rate of 0.16 gpm/ft2 would control the most severe fire investigated.

Water application rate is generally quantified in terms of discharge density. The discharge density is the average rate of water reaching a unit floor area in unit time and is expressed in units of gpm/ft2 of floor area. In the tests reviewed, the water application rates are referenced as delivered densities. Specifically, delivered density means the density (gpm/ft2) which was delivered at the (top) surface of the burning test array. The delivered density should not be confused with the design density commonly used in sprinkler installation standards which is the density available from the sprinkler system in the absence of a fire. (Note: The LGS Specification for fire sprinkler system (M-49) is based on the design density concept) In a fire situation, the actual water reaching the burning fuel is usually less than the design density due to phenomena such as evaporation, or entrainment of droplets in the hot gas rising from a fire. A delivered density of 0.16 gpm/ft2 is expected to be equivalent to a design density of 0.25 gpm/ft2 because test indicates that the overall penetration of water is approximately 65% when 1/2 orifice standard sprinklers are used. Therefore, a design density of 0.25 gpm/ft2 is required to provide the minimum effective density for extinguishment of grouped cable tray fires.

9A.6.5.2 Oil Spill Fires Factory Mutual Research Corporation has conducted a series of fire tests with the purpose of determining whether automatic sprinklers will protect against lubricating oil spill fires. In all the tests, the floor based fires were quickly controlled and the test building was satisfactorily protected APPENDIX 9A 9A-311 REV. 20, SEPTEMBER 2020

LGS UFSAR 9A.7 REFERENCES 9A.7.1 Appendix A to BTP APCSP 9.5-1 Guidelines for Fire Protection for Nuclear Power Plants docketed prior to July 1, 1976 9A.7.2 BTP CMEB 9.5-1 Guidelines for Fire Protection for Nuclear Power Plants", Rev.

2, dated July ,1981 9A.7.3 Appendix R to 10 CFR 50 Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979 9A.7.4 NUREG-0991, LGS SER, August 30, 1983.

9A.7.5 NUREG-0991, Supplement 2, October 1984.

9A.7.6 NUREG-0991, Supplement 8, June 1989.

9A.7.7 NUREG-0991, Supplement 9, August 1989.

9A.7.8 Letter from Eugene J. Bradley (PECO) to Dr. Thomas E. Murley (USNRC) dated April 5, 1988 (Revision 10 to FPER).

9A.7.9 Engineering Analysis LEAF-0001 Smoke Detector Engr Analysis For Fire Areas 1, 2 & 7.

9A.7.10 Engineering Analysis LEAF-0002 Suppression System Evaluation.

9A.7.11 Engineering Analysis LEAF-0009 Galvanized Steel Cable Tray Covers In CFZ-5.

9A.7.12 Engineering Analysis LEAF-0010, Switchgear Room Bus Duct Penetrations.

9A.7.13 Letter from Darrell G. Eisenhut (NRC) to G. Bauer, Jr. (PECO) dated October 15, 1981,

Subject:

Appendix R of 10 CFR Part 50 - Fire Protection Rule (Limerick Generating Station, Units 1 and 2).

9A.7.14 Generic Letter 86-10 Evaluation EC 627453 Refined Fire Barrier Inspection Criteria for Area 8 239' Beam - Wall Penetrations.

APPENDIX 9A 9A-313 REV. 20, SEPTEMBER 2020

ML21252A522

Text

5.2 DESCRIPTION

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