RS-02-207, Amendment 20 to Byron/Braidwood Stations Fire Protection Report, Tables 2.4-5 - 3-1
| ML030030472 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 12/31/2002 |
| From: | Jury K Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| -nr, RS-02-207 | |
| Download: ML030030472 (150) | |
Text
BYRON - FPR AMENDMENT 20 DECEMBER 2002 TABLE 2.4-5 REMOTE SHUTDOWN PANEL (RSP) INSTRUMENTATION A.
PANEL IPL04J INSTRUMENT NO.
IFI-AF011B*
IFI-AF013B*
IFI-AF015B*
1LI-501 I LI-502 1 LI-503 1 LI-504 1PI-0514B 1PI-0544B (Sheet I of 6)
DESCRIPTION Auxiliary Feedwater Pump 1A Flow to Steam Generator 1A Auxiliary Feedwater Pump 1A Flow to Steam Generator lB Auxiliary Feedwater Pump IA Flow to Steam Generator 1C Auxiliary Feedwater Pump 1A Flow to Steam Generator ID Steam Generator 1A Level Steam Generator 1 B Level Steam Generator 1C Level Steam Generator I D Level Essential Service Water Pump 1A Discharge Temperature Essential Service Water Return Header OA Temperature Steam Generator 1A Steam Pressure Steam Generator I D Steam Pressure
BYRON - FPR AMENDMENT 20 DECEMBER 2002 TABLE 2.4-5 (Cont'd)
B.
PANEL 1PL05J INSTRUMENT NO.
IFI-AF012B*
ITI-RC005A ITI-RC006A 1TI-RC007A 1ITI-RC008A ITI-RC005B 1TI-RC006B 1TI-RC007B 1TI-RC008B (Sheet 2 of 6)
DESCRIPTION Auxiliary Feedwater Pump 1 B Flow to Steam Generator IA Auxiliary Feedwater Pump 1 B Flow to Steam Generator 1B Auxiliary Feedwater Pump 1 B Flow to Steam Generator IC Auxiliary Feedwater Pump 1 B Flow to Steam Generator 1D Reactor Coolant Loop IA Hot Leg Temperature Reactor Coolant Loop 1 B Hot Leg Temperature Reactor Coolant Loop IC Hot Leg Temperature Reactor Coolant Loop 1D Hot Leg Temperature Reactor Coolant Loop IA Cold Leg Temperature Reactor Coolant Loop 1 B Cold Leg Temperature Reactor Coolant Loop IC Cold Leg Temperature Reactor Coolant Loop ID Cold Leg Temperature
BYRON - FPR AMENDMENT 20 DECEMBER 2002 TABLE 2.4-5 (Cont'd)
B.
C.
PANEL IPL06J INSTRUMENT NO.
I LI-0459B 1 LI-0460B 1 PI-0455B 1FI-0121B*
1 NI-NR002*
PANEL 1PL05J (Cont'd)
INSTRUMENT NO.
I PI-0524B 1 PI-0534B 1 FT-0110*
DESCRIPTION Pressurizer Level Pressurizer Level Pressurizer Pressure Volume Control Tank Level Charging Header Pressure Charging Header Flow Source Range Neutron (NE-31) Indicator Source Range Neutron (NE-32) Indicator (Sheet 3 of 6)
DESCRIPTION Essential Service Water Pump I B Discharge Temperature Essential Service Water Return Header OB Temperature Steam Generator 1 B Steam Pressure Steam Generator 1C Steam Pressure Emergency Boron Injection Flow
BYRON - FPR AMENDMENT 20 DECEMBER 2002 TABLE 2.4-5 (Cont'd)
D.
PANEL 2PL04J INSTRUMENT NO.
2FI-AF011 B*
2LI-501 2LI-502 2LI-503 2LI-504 2PI-0514B 2PI-0544B (Sheet 4 of 6)
DESCRIPTION Auxiliary Feedwater Pump 2A Flow to Steam Generator 2A Auxiliary Feedwater Pump 2A Flow to Steam Generator 2B Auxiliary Feedwater Pump 2A Flow to Steam Generator 2C Auxiliary Feedwater Pump 2A Flow to Steam Generator 2D Steam Generator 2A Level Steam Generator 2B Level Steam Generator 2C Level Steam Generator 2D Level Essential Service Water Pump 2A Discharge Temperature Essential Service Water Return Header OA Temperature Steam Generator 2A Steam Pressure Steam Generator 2D Steam Pressure
BYRON - FPR AMENDMENT 20 DECEMBER 2002 TABLE 2.4-5 (Cont'd)
E.
PANEL 2PL05J INSTRUMENT NO.
2TI-RC005A 2TI-RC006A 2TI-RC007A 2TI-RC008A 2TI-RC005B 2TI-RC006B 2TI-RC007B 2TI-RC008B (Sheet 5 of 6)
DESCRIPTION Auxiliary Feedwater Pump 2B Flow to Steam Generator 2A Auxiliary Feedwater Pump 2B Flow to Steam Generator 2B Auxiliary Feedwater Pump 2B Flow to Steam Generator 2C Auxiliary Feedwater Pump 2B Flow to Steam Generator 2D Reactor Coolant Loop 2A Hot Leg Temperature Reactor Coolant Loop 2B Hot Leg Temperature Reactor Coolant Loop 2C Hot Leg Temperature Reactor Coolant Loop 2D Hot Leg Temperature Reactor Coolant Loop 2A Cold Leg Temperature Reactor Coolant Loop 2B Cold Leg Temperature Reactor Coolant Loop 2C Cold Leg Temperature Reactor Coolant Loop 2D Cold Leg Temperature
BYRON - FPR AMENDMENT 20 DECEMBER 2002 TABLE 2.4-5 (Cont'd)
PANEL 2PL05J (Cont'd)
INSTRUMENT NO.
2PI-0524B 2PI-0534B 2FT-01 10*
F.
PANEL 2PL06J INSTRUMENT NO.
2LI-0459B 2LI-0460B 2PI-0455B 2FI-0121B*
DESCRIPTION Essential Service Water Pump 2B Discharge Temperature Essential Service Water Return Header OB Temperature Steam Generator 2B Steam Pressure Steam Generator 2C Steam Pressure Emergency Boron Injection Flow DESCRIPTION Pressurizer Level Pressurizer Level Pressurizer Pressure Volume Control Tank Level Charging Header Pressure Charging Header Flow Source Range Neutron (NE-31) Indicator Source Range Neutron (NE-32) Indicator
- Not identified as a safe shutdown instrument.
(Sheet 6 of 6)
E.
BYRON-FPR AMENDMENT 20 DECEMBER 2002 TABLE 2.4-6 REMOTE SHUTDOWN PANEL CONTROLS A.
PANEL 1PL04J EQUIPMENT NUMBER 1AF005A 1AF005B IAF005C IAF005D IAF013A IAF013B
'*j 1AF013C IAF013D IAF01PA 1CV01PA I CV01 PA-A OCC01P 1CC01PA IMS001A,lD DESCRIPTION AFW Regulating Valve AFW Regulating Valve AFW Regulating Valve AFW Regulating Valve AFW Steam Generator Isolation Valve AFW Steam Generator Isolation Valve AFW Steam Generator Isolation Valve AFW Steam Generator Isolation Valve AFW Pump 1A Centrifugal Charging Pump 1A CCP 1A Lube Oil Pump Component Cooling Pump 0 Component Cooling Pump 1A Main Steam Isolation Valves 1A, 1D CONTROL NUMBER 1HK-AF031B I HK-AF033B 1 HK-AF035B 1HK-AF037B IHS-AF071 IHS-AF073 1HS-AF075 IHS-AF077 IHS-AF003 1 HS-CV001 IHS-CV013 OHS-CCO01 1HS-CCO01 1HS-MS143 CONTROL FUNCTION Position controller Position controller Position controller Position controller Open-close switch Open-close switch Open-close switch Open-close switch On-off switch On-off switch On-off switch On-off switch On-off switch Open-close switch (Sheet I of 12)
BYRON -FPR AMENDMENT 20 DECEMBER 2002 TABLE 2.4-6 (Cont'd)
A.
PANEL 1 PL04J (Cont'd)
EQUIPMENT NUMBER lMS018A lMS018D 1RCOIPA iRCOIPD 1SXOIPA OSX02PA OSX03CA OSX03CB OVCOI CA OVC02CA 0VCI8Y,19Y, 20Y OVC21Y,22Y, 43Y IVP01CA IVPOICC DESCRIPTION CONTROL NUMBER Main Steam Atmospheric I PK-MS041 B Relief Valve 1A Main Steam Atmospheric 1 PK-MS044B Relief Valve ID Reactor Coolant Pump IA 1HS-RC001 Reactor Coolant Pump 1 D I HS-RC004 ESW Pump 1A 1HS-SX003 ESW Makeup Pump OA OHS-SX009 ESW Cooling Tower Fan OHS-SXOOI OA low speed ESW Cooling Tower Fan OHS-SX002 OB low speed MCR Supply Fan OA OHS-VC1 11 MCR Return Fan OA OHS-VC008 MCR Outside Air Dampers OHS-VCl 18 MCR Charcoal Filter Iso.
OHS-VC120 Dampers Reactor Cont. Fan Cooler 1 HS-VP01 I high speed Reactor Cont. Fan Cooler IHS-VP013 high speed CONTROL FUNCTION Setpoint controller Setpoint controller On-off switch On-off switch On-off switch On-off switch On-off switch On-off switch On-off switch On-off switch Open-close switch Open-close switch On-off switch On-off switch (Sheet 2 of 12)
AMENDMENT 20 DECEMBER 2002 BYRON -FPR TABLE 2.4-6 (Cont'd)
B.
PANEL IPL05J EQUIPMENT NUMBER IAF005E 1AF005F 1AF005G 1AF005H 1AF013E 1AF013F 1AF013G IAF013H 1AF01PB 1CV01PB 1 CV01 PB-A 1CV8104 OCCOIP 1CC01PB 1MS001B,C DESCRIPTION AFW Regulating Valve AFW Regulating Valve AFW Regulating Valve AFW Regulating Valve AFW Steam Generator Iso. Valve AFW Steam Generator Iso. Valve AFW Steam Generator Iso. Valve AFW Steam Generator Iso. Valve AFW Pump 1B Centrifugal Charging Pump lB CCP 1B Lube Oil Pump Emergency Boration Valve Component Cooling Pump 0 Component Cooling Pump 1B Main Steam Isolation Valves IB, IC CONTROL NUMBER 1HK-AF032B 1 HK-AF034B 1 HK-AF036B IHK-AF038B 1HS-AF072 I HS-AF074 1 HS-AF076 1 HS-AF078 1 HS-AF004 1 HS-CV002 1HS-CV014 IHS-CV005 OHS-CCO02 I HS-CCO02 1HS-MS144 CONTROL FUNCTION Position controller Position controller Position controller Position controller Open-close switch Open-close switch Open-close switch Open-close switch On-off switch On-off switch On-off switch Open-close switch On-off switch On-off switch Open-close switch (Sheet 3 of 12)
AMENDMENT 20 DECEMBER 2002 BYRON -FPR TABLE 2.4-6 (Cont'd)
B.
PANEL IPL05J (Cont'd)
EQUIPMENT DESCRIPTION NUMBER IMS018B Main Steam Atmospheric Relief Valve I B IMS018C Main Steam Atmospheric Relief Valve IC 1RCOIPB Reactor Coolant Pump 1B 1RC01PC Reactor Coolant Pump 1C 1SXOIPB ESW Pump 1B OSX02PB ESW Makeup Pump OB OSX03CE ESF Cooling Tower Fan OE low speed OSX03CF ESF Cooling Tower Fan OF low speed 1VP01CB Reactor Containment Fan Cooler - high speed IVP01CD Reactor Containment Fan Cooler - high speed CONTROL NUMBER IPK-MS042B 1PK-MS043B I HS-RC002 IHS-RC003 IHS-SX004 OHS-SX010 OHS-SX005 OHS-SX006 1HS-VPO12 IHS-VP014 CONTROL FUNCTION Setpoint controllers Setpoint controller On-off switch On-off switch On-off switch On-off switch On-off switch On-off switch On-off switch On-off switch (Sheet 4 of 12)
BYRON -FPR AMENDMENT 20 DECEMBER 2002 TABLE 2.4-6 (Cont'd)
C.
PANEL 1PL06J EQUIPMENT DESCRIPTION NUMBER Plant Evacuation Alarm Plant-wide Fire Alarm Plant Evac. & Fire Alarm Reset 1AB03P Boric Acid Transfer Pump 1A CONTROL NUMBER 1 HS-CQ001 1 HS-CQ002 1 HS-CQ003 IHS-AB001 CONTROL FUNCTION On switch On switch Reset switch On-off switch 1CV8145 1CV8149A 1CV8149B 1CF8149C ICV02P 1 CV-LCV459 1CV-LCV460 1CV02P 1CV-FCV121 Pressurizer Auxiliary Spray Valve Letdown Orifice Isolation Valve Letdown Orifice Isolation Valve Letdown Orifice Isolation Valve Position Displacement Charging Pump Letdown Isolation Valve Letdown Isolation Valve P. D. Charging Pump Charging flow control valve I HS-CV039 1 HS-CV007 I HS-CF009 IHS-CV011 1HS-CV017 1HS-CV019 1HS-CV021 ISHC-459B 1FHC-121 Open-close switch Open-close switch Open-close switch Open-close switch On-off switch Open-close switch Open-close switch Pump speed controller Flow controller (Sheet 5 of 12)
BYRON -FPR AMENDMENT 20 DECEMBER 2002 TABLE 2.4-6 (Cont'd)
C.
PANEL I PL06J (Cont'd)
EQUIPMENT DESCRIPTION NUMBER Steam Generator IA Level Steam Generator 1B Level Steam Generator IC Level Steam Generator I D Level OPW02A Primary Water Pump OA Press. Heaters Backup Group A Breaker Press. Heaters Backup Group B Breaker Press. Heaters Backup Group A Contactor Press. Heaters Backup Group B Contactor 1VP03CA CRDM Exhaust Fan 1A IVP03CB CRDM Exhaust Fan lB IVP03CC CRDM Exhaust Fan IC IVP03CD CRDM Exhaust Fan 1D CONTROL NUMBER ILSH-FW047 1 LSH-FW048 lLSH-FW049 1 LSH-FW050 OHS-PWOI I 1HS-RY001 1HS-RY002 1HS-RY005 1HS-RY006 IHS-VPI 12 1 HS-VP1 14 IHS-VP116 1HS-VP118 CONTROL FUNCTION SG high level alarm SG high level alarm SG high level alarm SG high level alarm On-off switch On-off switch On-off switch On-off switch On-off switch On-off switch On-off switch On-off switch On-off switch (Sheet 6 of 12)
BYRON -FPR AMENDMENT 20 DECEMBER 2002 TABLE 2.4-6 (Cont'd)
"D. PANEL 2PL04J EQUIPMENT NUMBER 2AF005A 2AF005B 2AF005C 2AF005D 2AF013A 2AF013B 2AF013C 2AF013D 2AF01 PA 2CV0I PA 2CV0I PA-A OCC01P 2CC01PA 2MS001A,D DESCRIPTION AFW Regulating Valve AFW Regulating Valve AFW Regulating Valve AFW Regulating Valve AFW Steam Generator Isolation Valve AFW Steam Generator Isolation Valve AFW Steam Generator Isolation Valve AFW Steam Generator Isolation Valve AFW Pump 2A Centrifugal Charging Pump 2A CCP 2A Lube Oil Pump Component Cooling Pump 0 Component Cooling Pump 2A Main Steam Isolation Valves 2A, 2D CONTROL NUMBER 2HK-AF031B 2HK-AF033B 2HK-AF035B 2HK-AF037B 2HS-AF071 2HS-AF073 2HS-AF075 2HS-AF077 2HS-AF003 2HS-CV001 2HS-CV01 3 OHS-CCO01 2HS-CC001 2HS-MS143 CONTROL FUNCTION Position controller Position controller Position controller Position controller Open-close switch Open-close switch Open-close switch Open-close switch On-off switch On-off switch On-off switch On-off switch On-off switch Open-close switch (Sheet 7 of 12)
AMENDMENT 20 DECEMBER 2002 BYRON -FPR TABLE 2.4-6 (Cont'd)
D.
PANEL 2PL04J (Cont'd)
EQUIPMENT NUMBER 2MS018A 2MS018D 2RC01PA 2RC01PD 2SX01 PA OSX03CC OSX03CD 2VPOICA 2VP01CC DESCRIPTION Main Steam Atmospheric Relief Valve 2A Main Steam Atmospheric Relief Valve 2D Reactor Coolant Pump 2A Reactor Coolant Pump 2D ESW Pump 2A ESW Cooling Tower Fan OC low speed ESW Cooling Tower Fan OD low speed Reactor Cont. Fan Cooler high speed Reactor Cont. Fan Cooler high speed CONTROL NUMBER 2PK-MS041B 2PK-MS044B 2HS-RC001 2HS-RC004 2HS-SX003 OHS-SX003 OHS-SX004 2HS-VPOII 2HS-VP013 CONTROL FUNCTION Setpoint controller Setpoint controller On-off switch On-off switch On-off switch On-off switch On-off switch On-off switch On-off switch (Sheet 8 of 12)
BYRON -FPR TABLE 2.4-6 (Cont'd)
AMENDMENT 20 DECEMBER 2002 E.
PANEL 2PL05J EQUIPMENT NUMBER 2AF005E 2AF005F 2AF005G 2AF005H 2AF013E 2AF013F 2AF013G 2AF013H 2AF01PB 2CVOIPB 2CVOIPB-A 2CV8104 OCCOIP 2CC01PB 2MS001 B,C DESCRIPTION AFW Regulating Valve AFW Regulating Valve AFW Regulating Valve AFW Regulating Valve AFW Steam Generator Iso. Valve AFW Steam Generator Iso. Valve AFW Steam Generator Iso. Valve AFW Steam Generator Iso. Valve AFW Pump 2B Centrifugal Charging Pump 2B CCP 2B Lube Oil Pump Emergency Boration Valve Component Cooling Pump 0 Component Cooling Pump 2B Main Steam Isolation Valves 2B, 2C CONTROL NUMBER 2HK-AF032B 2HK-AF034B 2HK-AF036B 2HK-AF038B 2HS-AF072 2HS-AF074 2HS-AF076 2HS-AF078 2HS-AF004 2HS-CV002 2HS-CV014 2HS-CV005 OHS-CCO04 2HS-CCO02 2HS-MS144 CONTROL FUNCTION Position controller Position controller Position controller Position controller Open-close switch Open-close switch Open-close switch Open-close switch On-off switch On-off switch On-off switch Open-close switch On-off switch On-off switch Open-close switch (Sheet 9 of 12)
AMENDMENT 20 DECEMBER 2002 BYRON -FPR TABLE 2.4-6 (Cont'd)
E.
PANEL 2PL05J (Cont'd)
EQUIPMENT NUMBER 2MS018B 2MS018C 2RCOIPB 2RC01PC 2SXOIPB OSX03CG OSX03CH 2VPOICB 2VPOICD DESCRIPTION Main Steam Atmospheric Relief Valve 2B Main Steam Atmospheric Relief Valve 2C Reactor Coolant Pump 2B Reactor Coolant Pump 2C ESW Pump 2B ESF Cooling Tower Fan OG low speed ESF Cooling Tower Fan OH low speed Reactor Containment Fan Cooler - high speed Reactor Containment Fan Cooler - high speed CONTROL NUMBER 2PK-MS042B 2PK-MS043B 2HS-RC002 2HS-RC003 2HS-SX004 OHS-SX007 OHS-SX008 2HS-VPO12 2HS-VP014 CONTROL FUNCTION Setpoint controllers Setpoint controller On-off switch On-off switch On-off switch On-off switch On-off switch On-off switch On-off switch (Sheet 10 of 12)
BYRON -FPR AMENDMENT 20 DECEMBER 2002 TABLE 2.4-6 (Cont'd)
F.
PANEL 2PL06J EQUIPMENT DESCRIPTION NUMBER Plant Evacuation Alarm Plant-wide Fire Alarm Plant Evac. & Fire Alarm Reset 2AB03P Boric Acid Transfer Pump2A CONTROL NUMBER 2HS-CQ001 2HS-CQ002 2HS-CQ003 2HS-AB001 CONTROL FUNCTION On switch On switch Reset switch On-off switch 2CV8145 2CV8149A 2CV8149B 2CF8149C 2CV02P 2CV-LCV459 2CV-LCV460 2CV02P 2CV-FCV121 Pressurizer Auxiliary Spray Valve Letdown Orifice Isolation Valve Letdown Orifice Isolation Valve Letdown Orifice Isolation Valve Position Displacement Charging Pump Letdown Isolation Valve Letdown Isolation Valve P. D. Charging Pump Charging flow control valve 2HS-CV039 2HS-CV007 2HS-CF009 2HS-CV01 I 2HS-CV017 2HS-CV019 2HS-CV021 2SHC-459B 2FHC-121 Open-close switch Open-close switch Open-close switch Open-close switch On-off switch Open-close switch Open-close switch Pump speed controller Flow controller (Sheet 11 of 12)
BYRON -FPR AMENDMENT 20 DECEMBER 2002 TABLE 2.4-6 (Cont'd)
F.
PANEL 2PL06J (Cont'd)
EQUIPMENT NUMBER OPW02B 2VP03CA 2VP03CB 2VP03CC 2VP03CD DESCRIPTION Steam Generator 2A Level Steam Generator 2B Level Steam Generator 2C Level Steam Generator 2D Level Primary Water Pump OB Press. Heaters Backup Group A Breaker Press. Heaters Backup Group B Breaker Press. Heaters Backup Group A Contactor Press. Heaters Backup Group B Contactor CRDM Exhaust Fan 2A CRDM Exhaust Fan 2B CRDM Exhaust Fan 2C CRDM Exhaust Fan 2D CONTROL NUMBER 2LSH-FW047 2LSH-FW048 2LSH-FW049 2LSH-FW050 OHS-PWO13 2HS-RY001 2HS-RY002 2HS-RY005 2HS-RY006 2HS-VP1 12 2HS-VP114 2HS-VPI 16 2HS-VP 118 CONTROL FUNCTION SG high level alarm SG high level alarm SG high level alarm SG high level alarm On-off switch On-off switch On-off switch On-off switch On-off switch On-off switch On-off switch On-off switch On-off switch (Sheet 12 of 12)
BYRON AMENDMENT 26 DECEMBER 2602 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE SECTION NRC POSITION to provide protection for structures, systems, and components important to safety so that a fire that is not promptly extin guished by the fire suppression activities will not prevent the safe shutdown of the plant.
(3)
Responsibility for the overall fire protection program should be assigned to a person who has management control over all organizations involved In fire protection activities.
Formu lation and assurance of program implementation may be delegated to a staff composed of person nel prepared by training and experience in fire protection and personnel prepared by training and experience in nuclear plant safety to provide a balanced approach in direct ing the fire protection program for the nuclear power plant.
The staff should be responsible for:
(a)
Fire protection program requirements, including consideration of potential hazards associated with postulated fires, with knowledge of building lay out and systems design.
(b)
Post-fire shutdown capability.
Administrative procedures identify the individual delegated the authority for establishing the Fire Protection program.
He has nuclear plant safety expertise available as part of the operating department.
Using the prefire plans for safety, related areas, hazards are defined, structures and system identified.
The Fire Marshall (as administrator) maintains the plans.
The Shift Manager is responsible for operating safely and can order shutdown if he deems it necessary for safety.
3.1-2
BYRON AMENDMENT 20 DECEMBER 2062 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (c)
Design, maintenance, surveillance, and quality assurance of all fire pro tection features (e.g.,
detection systems, sup pression systems, bar riers, 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.
Maintenance and surveillance are handled by the station Operating, Maintenance and Engineering programs and procedures.
Offsite.QA is a separate organtzation.
Onsite QA organization provides review of maintenance, and purchase activities in accordance with the corporate QA Manual.
The Fire Marshall and Training Department direct training.
The Fire Marshall administers the station fire protection program (see 3.1. a(2))
Prefire plans are written for safety-related areas and are con trolled by the Fire Marshall.
Preplans were reviewed by a Fire Protection Engineer.
Comply.
- 1.
Responsibility for the Fire Protection Program
- a.
Initial Design and Construction Phase The fire protection system design for the EGC plants was developed by the project consulting engineer using members of his staff who were experienced in nuclear plant design.
Exelon Generation Company is a member of Nuclear Electric Insurance Limited (NEIL) and therefore guidelines for fire protection design were provided in the NEIL Property Loss Prevention Standards for Nuclear Generating Stations.
The building design was done by the consulting engineer.
All design 3.1-3
BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR "SECTION NRC POSITION NONCOMPLIANCE drawings which were pertinent to fire protection were submitted to a fire protection consultant as required by NEIL for their review and comment.
The fire protection consultant was employed by NEIL and was therefore independent of EGC.
The comments on design information made by the fire protection consultant were submitted to EGC for their action.
Exelon Generation Company reviewed the project consultants' design drawings and the fire protection consultants' comments.
Judgments were made on a cost-benefit basis as to whether or not the fire protection features were to be incorporated into the plant.
Consideration was given to the fol lowing plant features when eval uation of fire protection was made:
"a.
plant and personnel
- safety,
- b.
credibility of a fire or fire hazard,
- c.
loss of generation because of fire loss, and
- d.
protection of surrounding resulting from a fire.
3.1-4
BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE A Project Engineer who reported to the Project Engineering Manager coordinated fire protection design features at B/B.
Likewise, a review of design and design changes was performed by a Fire Protection Engineer in the Nuclear Services Department and by Independent Fire Protection Engineers working under contract to EGC.
Resumes for the reviewers are in Appendix AS.1.
Surveillance tests were performed by the Project Construction Department and by the Station.
The Fire Protection Engineers were involved in pre-operational and surveillance acceptance tests.
3.1-4a
BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE
- b.
Operating Phase Exelon Generation Company has a Fire Marshall and Fire Protection System Engineer at each nuclear plant.
In addition, there are Fire Protection Engineers in the Corporate and/or site design engineering departments.
- 1.
Properties and EguiDment - The Fire Protection Engineers furnish information on underwriting standards, fire insurance rating standards and other information.
When necessary, they arrange for procuring advice from outside fire prevention agencies or other outside sources.
When necessary, they arrange and set up meetings to discuss and resolve any questions on current standards or fire protection equipment.
- 2.
Fire Inspections -
Site personnel, QA (Nuclear Oversight),
and NEIL performs fire protection inspections of plant facilities.
- 3.
Fire Fighting Equipment - The Station Fire Marshall sees that adequate fire fighting equipment is provided and that such equipment is maintained in good operating condition.
- 4.
Tests - The station conducts tests of fire fighting equipment and I automatic fire protection 3.1-5
BYRON AMENDMENT 26 DECEMBER 2602 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE systems to ensure that each is in good condition and operating satisfactorily. During normal or routine inspections, one or more of the following tests may be made:
- a.
alarm tests,
- b.
drain tests,
- c.
churning of fire pumps,
- d.
inspecting of control
- valves,
- e.
physical testing of fire pumps and yard hydrants,
- f.
checking or testing water deluge systems.
- g.
checking of automatic sprinkler systems, and
- h.
testing of standpipes and hoses.
- 5.
Contacts - The Station Fire Marshall maintains company contacts with local fire departments.
The Station Fire Marshall and the Fire Protection Engineers maintain con tact with fire prevention organizations, insurance companies, and others on matters relating to fire fighting.
- 6.
Reporting Fires -
Fire reports are issued-by the station.
The Fire Marshall reports fires as necessary to the insurance company.
3.1-6
BYRON SECTION NRC POSITION
/ý AMENDMENT 2e DECEMBER 2ee2 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE
- 7.
Training of Personnel - The Station Training Department, Corporate Training Department, and Fire Marshall are responsible for personnel training.
This is done to ensure that individuals trained become familiar with the operation and use of fire fighting equipment.
(4)
The organizational respon sibilities and lines of com munication pertaining to fire protection should be defined between the various positions through the use of organi zational charts and functional descriptions of each position's responsibilities.
The follow ing positions/organizations should be designated:
- 8.
Rules and Standards - The Fi.re Protection Engineers assist and ad vise departments concerned with established rules and standards re lative to fire prevention and pro tection as may be necessary.
- 9.
Recommendations - On all recommendations initiated by insurance agencies, fire prevention organizations, and other outside activities or company departments, the Fire Protection Engineers investigate, evaluate, discuss, and review such recommendations, where' necessary, before making final re commendations as to specific action to be taken.
le.
Design Change -
All design changes are reviewed for impact upon the Fire Protection Program per administrative procedures.
It is our opinion that the intent of the Branch Technical Position is met by the above outlined organizational structure in design, construction and operation of the EGC nuclear plants.
Administrative procedures define the organizational responsibilities and lines of communication for the Fire Protection Program.
. 3.1-7 i
AMENDMENT 20 DECEMBER 2002 SECTION NRC POSITION (a)
The upper level offsite management position which has management respon sibility for the form ulation. implementation, and assessment of the effectiveness of the nuclear plant fire protection program.
(b)
The offsite management position(s) directly responsible for formu lating, implementing, and periodically assessing the effectiveness of the fire protection program for the licensee's nuclear power plant including fire drills and training con ducted by the fire brigade and plant personnel.
The results of these assess ments should be reported to the upper'level manage ment position responsible for fire protection with recommendations for im provements or corrective actions as deemed neces sary.
(c)
The onsite management position responsible for the overall administration of the plant operations and emergency plans which include the fire pro tection and prevention program and which provide a single point-of control and contact for all con tingencies.
IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE Administrative procedures identify the offsite-delegated individual responsible for the nuclear plant fire protection program.
Assessment of the program is made by EGC Fire Protection Engineers.
The Site Nuclear Oversight Manager and EGC Fire Protection Engineers have these responsibilities.
Administrative procedures identify the onsite-delegated individual responsible for the overall administration of the plant operations and emergency plans.
3.1-8 BYRON I
II
AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR.
JUSTIFICATION FOR NONCOMPLI ANCE SECTION NRC POSITION (d)
The onsite position(s) which:
- i.
Implements periodic inspections to:
minimize the amount.
of combustibles in safety-related areas; determine the effec tiveness of house keeping practices; assure the avail ability and accept able condition of all fire protection systems/equipment, emergency breathing apparatus, emergency lighting, communi cation equipment, fire stops, pene tration seals, and fire retardant coatings: and assures the prompt and effec tive corrective actions are taken to correct conditions adverse to fire pro tection and preclude their recurrence.
ii.
Is responsible for the fire fighting training for op erating plant per sonnel and the plant's fire bri gade; design and selection of equip ment; periodic in spection and testing of fire protection systems and equip ment in accordance with established procedures, and eva luate test results and determine the acceptability of the systems under test.
Administrative Procedures require the Fire Marshall to conduct periodic plant tours, identify unacceptable conditions, and initiate corrective actions.
The Fire Marshall is responsible for implementation and administration of the fire protection program.
Administrative Procedures state that Radiation Protection department will control and maintain emergency breathing apparatus.
Administrative Procedures state that Electrical Maintenance will maintain emergency lighting and communications.
Fire barriers, seals, doors, and dampers will be inspected per Station procedures and surveillance.
Administrative Procedures state that the Fire Marshall will investigate fires, evaluate prevention recom mendations and make recommendation when needed.
Fire brigade training is a re sponsibility of both the Fire Marshall and the training depart ment.
Operating personnel are trained periodically through the Training Department on fire fight ing.
The Operating Manager ensures all operating surveillance are done in accordance to required guides.
The Maintenance, Engineering and Operating Managers are responsible for station procedures performed by their department.
3.1-9 BYRON I
I
AMENDMENT 29 DECEMBER 2962 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE SECTION NRC POSITION lii. Assists in the critique of all fire drills to deter mine how well the training objectives have been met.
iv.
Reviews and evaluates proposed work activities to identify potential transient fire loads.
- v.
Implements a program for indoctrination of all plant contractor personnel in appropriate adminis trative procedures which implement the fire pro tection program. and the emergency procedures rel ative to fire protection.
vi.
Implements a program for instruction of personnel on the proper handling of accidental events such as leaks or spills of flam mable materials that are related to fire pro tection.
Fire Marshall will review the sur veillances he deems necessary.
Evaluation of tests and sur veillances is specified in test.
surveillance and administrative procedures.
Fire Marshall is responsible for the purchase of fire brigade equipment.
Critique of all fire drills is a
responsibility of the Fire Marshall.
The Fire Marshall will have these responsibilities.
Contractor's training through NGET fulfills this requirement.
They are informed of emergency procedures relative to fire protection.
The Administrative procedures pro vide instructions for personnel on the proper handling of oil spills.
These procedures reference corporate general instruction on spill pre vention and counter measures.
3.1-16 BYRON I
BYRON AMENDMENT 20 DECEMBER 2602 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (e)
The onsite position responsible for fire protection quality as assurance.
This position should be responsible for assuring the effective implementation of the fire protection program by planned inspections, scheduled audits.
and verification that the results of these inspections of audits are promptly reported to cognizant management personnel.
(f)
The positions which are part of the plant fire brigade:
- 1.
The plant fire brigade positions should be re sponsible for fighting fires.
The authority and responsibility of each fire brigade position relative to fire pro tection should be clearly defined.
ii. The responsibilities of each fire brigade position should correspond with the actions required by the fire fighting procedures.
iii. The responsibilities of the fire brigade members under normal plant con ditions should not con flict with their respon sibilities during a fire emergency.
The Fire Protection Program identifies that Fire Protection Activities are treated as augmented quality per the QA program.
Site/Off-Site QA (Nuclear Oversight)
Department personnel conduct audits and surveillances to ensure proper implementation and administration of the Fire Protection Program.
Administrative procedures define the Fire Chief and Brigade responsi bilities and the requirements for authority and duties.
Training will be scheduled through the Fire Marshall and Operating Department.
Administrative Proce dures specify personnel (non brigade) required for operation.
3.1-11 I
AMENDMENT 20 DECEMBER 20e2 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE SECTION NRC POSITION iv.
The minimum number of trained fire brigade members available onsite for each operating shift should be consistent with the activities required to combat the most signi ficant fire.
The size of the fire brigade should be based upon the functions required to fight fires with adequate allowance for injuries.
- v.
The recommendations for organization, training.
and equipment of "Private Fire Brigades" as specified in NFPA No.
27
- 27.
are considered appropriate criteria for organizing, training, and operating a plant fire brigade.
(5)
Personnel Qualifications.
(a)
The position responsible for formulation and imple mentation of the fire protection program should have within his organ ization 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 en gineering attainment In dicative of growth in en gineering competency and achievement, 3 years of which shall have been in responsible charge of fire protection engineering work.
These requirements are the eligibility Byron complies with BTP CMEB 9.5-1 paragraph 3.3.b and Appendix R III.H. which requires a 5 member brigade.
See Table 3-1 for discussion of conformance with NFPA 27.
Comply.
The position responsible for the fire protection program has the use of a Fire Protection Consultant.
These Consultants meet SFPE member grade requirements.
Exelon Generation Company also employs Fire Protection Engineers who meet the qualifications for member grade in SFPE.
(The Fire Protection Engineer's duties are identified in the Fire Protection Program administrative procedures.)
3.1-12 BYRON
BYRON AMENDMENT 26 DECEMBER 2662 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE SECTION NRC POSITION requirements as a Member in the Society of Fire Protection Engineers.
(b)
The fire brigade members' qualifications should include satisfactory completion of a physical examination for performing strenuous activity, and of the fire brigade training described in Position C.3.d.
(c)
The personnel responsible for the maintenance and testing of the fire protection systems should be qualified by training and experience for such work.
(d)
The personnel responsible for the training of the fire brigade should be qualified by training and experience for such work.
(6)
The following NFPA publications should be used for guidance to develop the fire protection program:
No.
4 "Organization for Fire Services" No.
4A -
"Organization of a Fire Department" No.
6 No.
7 No.
8 "Industrial Fire Loss Prevention" "Management of Fire Emergencies" "Management Re sponsibilities for Effects of Fire on Operations" The fire brigade members have an annual physical which shows them capable of unrestricted activity.
The personnel responsible for maintenance and testing of the fire protection systems receive training scheduled by the training department.
The initial training of the fire brigade was administered by State of Illinois licensed instructors.
The administrative procedures needed for maintaining the performance of the fire protection system and personnel were established with the guidance of the NFPA standard available at the time.
The organization of fire protection services and the review of their performance is one of the functions of the station administration.
See Table 3-1 for discussion of conformance with the listed NFPA publications.
3.1-13 I
BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE SECTION NRC POSITION No.
27 - "Private Fire Brigades" (7)
On sites where there is an operating reactor and construction or modification of other units is underway, the superintendent of the operating plant should have the lead responsibility for site fire protection.
- b.
Fire Hazards Analysis The fire hazards analysis should demonstrate that the plant will maintain the ability to perform safe shutdown functions and minimize radioactive releases to the environment in the event of a fire.
The fire hazards analysis should be performed by qualified fire protection and reactor systems engineers to (1) consider potential in situ and transient fire hazards; (2) determine the consequences of fire in any location in the plant on the ability to safely shut down the reactor or on the ability to minimize and control the release of radioactivity to the environment; and (3) specify measures for fire prevention, fire detection, fire suppression, and fire containment and alternative shutdown capability as required for each fire area containing structures, systems, and components important to safety that are in conformance with NRC guidelines and regulations.
"Worst case" fires need not be postulated to be simultaneous with nonfire-related failures in safety systems, plant Comply.
Position Description procedures define this as a duty of the station manager.
Comply.
The overall fire protection program is based on evaluation of fire hazards so a safe shutdown can be accomplished.
The fire protection program began with the protection of specific hazards in mind, to minimize, or prevent the loss of
- property.
The main emphasis is now placed on safe plant shutdown, but the protection of ALL hazards will satisfy both reasons.
Not ALL hazards are protected or separated as indicated in other sections of the report, but the basis for the fire protection program basically complies.
Fire hazards were considered in plant design for Byron/Braidwood Units 1 and 2.
The cable separation criteria for the plant is described in Appendix 5.2 of this report.
The fire protection system is discussed in Appendix 5.4.
Deviations from the compliance criteria of 10 CFR 50 Appendix R are listed and justified in Table A5.7-1.
3.1-14 I
BYRON AMENDMENT 2e DECEMBER 2eG2 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE
- i.
Control the use of specific combustibles in safety-related areas.
All wood used in safety-related areas during maintenance, modification, or refueling operation (such as lay-down blocks or scaffolding) should be treated with a flame retardant.
Equipment or supplies (such as new fuel) shipped in untreated combustible packing containers may be unpacked in safety related areas if required for valid operating reasons.
However, all combustible materials should be removed from the area immediately following unpacking.
Such transient combustible material, unless stored in approved containers, should not be left unattended during lunch breaks, shift changes, or other similar periods.
Loose combustible packing materials such as wood or paper excelsior, or polyethylene sheeting should be
.placed in metal containers with tight-fitting self-closing metal covers.
J.
Disarming of fire detection or fire suppression systems should be controlled by a permit system.
Fire watches should be established in areas where systems are so disarmed.
Comply with exceptions.
Refer to Section III.K.8 of Appendix A5.7 for details.
Comply.
Disarming of fire detection or fire suppression systems is controlled by administrative procedure.
A fire watch or other compensatory measures are established as required by the governing administrative procedure.
3.2-3
BYRON AMENDMENT 2e DECEMBER 2e62 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE
- k.
Successful fire protection requires testing and maintenance of the fire protection equipment and the emergency lighting and communication.
A test plan that lists the individuals and their responsibilities in connection with routine tests and inspections of the fire detection and protection systems should be developed.
The test plan should contain the types. frequency, and detailed procedures for testing.
Procedures should also contain instructions on maintaining fire protection during those periods when the fire protection system is impaired or during periods of plant maintenance, e.g., fire watches or temporary hose connections to water systems.
- 1.
Control actions to be taken by an individual discovering a fire, for example, notification of control room, attempt to extinguish fire, and actuation of local fire suppression systems.
- m.
Control actions to be taken by the control room operator to determine the need for brigade assistance upon report of a fire or receipt of alarm on control room annunciator panel, for example, announcing location of fire over PA system, sounding fire alarms, and notifying the shift supervisor and the fire brigade leader of the type, size, and location of the fire.
Comply.
The scope of the Job classification for maintenance personnel identifies job responsibilities in the area of fire protection.
Disarming of fire detection or fire suppression systems for maintenance is controlled by administrative procedure.
A fire watch or other compensatory measures are established as required by the governing administrative procedure.
The surveillance program (Test Plan) contains the types, frequency, and detailed procedures for testing.
Comply.
Refer to Section III.K.9 of Appendix A5.7.
Comply.
Refer to Section III.K.10 of Appendix A5.7.
3.2-4
AMENDMENT 28 DECEMBER 2082 3.3 FIRE BRIGADE IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE SECTION NRC POSITION
- a.
The need for good organization.
training, and equipping of fire brigades at nuclear power plant sites requires that effective measures be implemented to ensure proper discharge of these functions.
The guidance in Regulatory Guide 1.181, "Emergency Planning for Nuclear Power Plants," should be followed as applicable.
The guidelines of Regulatory Guide 1.101 are followed where applicable.
Insurance industry standards in existence at that time and NFPA 27 "Private Fire Brigades" - were consulted in writing the procedures.
Station administrative procedures governing the fire protection program outlines the organization.
training and the equipping of the fire brigades.
3.3-1 BYRON
BYRON AMENDMENT 20 DECEMBER 2e02 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE
- b.
A site fire brigade trained and equipped for fire fighting should be established to ensure adequate manual fire fighting capability for all areas of the plant containing structures, systems, or components important to safety.
The fire brigade should be at least five members on each shift.
The brigade leader and at least two brigade members should have sufficient training in or knowledge of plant safety related systems to understand the effects of fire and fire suppressants on safe shutdown capability.
The qualification of fire brigade members should include an annual physical examination to determine their ability to perform strenuous fire fighting activities.
The shift supervisor should not be a member of the fire brigade.
The brigade leader shall be competent to assess the potential safety consequences of a fire and advise control room personnel.
Such competence by the brigade leader may be evidenced by possession of an operator's license or equivalent knowledge of plant safety-related systems.
Comply, with one exception taken.
Refer to Section III.H of Appendix A5.7 for details.
3.3-1a
SECTION NRC POSITION AMENDMENT 20 DECEMBER 2902 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE (7)
Drills (a)
Fire brigade drills should be performed in the plant so that the fire brigade can practice as a team.
(b)
Drills should be performed at regular intervals not to exceed 3 months for each shift fire brigade.
Each fire brigade member should participate in each
- drill, but must parti cipate in at least two drills per year.
A sufficient number of these drills, but not less than one for each shift fire brigade per year, should be unannounced to determine the fire fighting readiness of the plant fire brigade, brigade leader, and fire protection systems and equipment.
Persons planning and authorizing an unannounced drill should ensure that the responding shift fire brigade members are not aware that a drill is being planned until it is begun. Unannounced drills should not be scheduled closer than 4 weeks.
At least one drill per year should be performed on a "back shift" for each shift fire brigade.
Items 7a through 7f under (7) drills are accomplished by administrative procedure that includes drill and drill assessments.
Refer to Section 111.1.3 of Appendix A5.7 for details.
3.3-7 BYRON I
AMENDMENT. 2 DECEMBER 26O2 IMPLEMENTATION OR.
JUSTIFICATION FOR NONCOMPLIANCE SECTION NRC POSITION And arrangement of a fire that could reasonably occur in the area selected, allowing for fire development due to the time required to respond, to obtain equipment, and organize for the fire, assuming loss of automatic suppression capability.
iv.
Assessment of brigade leader's direction of the fire fighting effort as to thoroughness, accuracy, and effectiveness.
(8)
Records Individual records of training provided to each fire brigade member, including drill critiques, should be maintained for at least 3 years to ensure that each member receives training in all parts of the training program.
These records of training should be available for NRC review.
Retraining or broadened training for fire fighting within buildings should be scheduled for all those brigade members whose performance records show deficiencies.
Comply.
Refer to Section 111.1.4 of Appendix A5.7.
(9)
Guidance Documents NFPA 27, "Private Fire Brigade." should be followed in organization, training, and fire drills.
This standard also is applicable for the inspection and maintenance of 3.3-18 Comply.
Fire training by responsible instructors is done periodically.
See Table 3-1 for delineation of conformance with NFPA
- 27.
NFPA 197 has been renumbered NFPA 1416, deals with public fire departments. and is not applicable at the station level.
BYRON
AMENDMENT 20 DECEMBER 2e02 3.4 QUALITY ASSURANCE PROGRAM IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE SECTION NRC POSITION The quality assurance (QA) 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 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.
It should satisfy the specific criteria listed below.
The fire protection systems at Byron Station Units 1 and 2 are addressed in two different manners under the Quality Assurance Program.
- 1.
Fire protection systems classed as safety-related are covered by the entire Quality Assurance Program which includes the criteria set forth in Appendix B of 18 CFR 50.
- 2.
Fire protection systems that are classed as non-safety related and that are awarded after September 1, 1978 are procured and installed in accordance with the Branch Technical Position 9.5-1.
Vendors awarded with supplying or installing a fire protection system after September 1, 1978 must have an approved QA Program as required by the Quality Assurance Program and be on the Approved Bidder's List.
However, exceptions may be made for selected non-safety-related systems to allow installation without an approved QA program.
Each installation of this type requires a separate analysis that 3.4-1 BYRON I
BYRON AMENDMENT 28 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE includes, as a minimum, a
regulatory change evaluation; a definable augmented quality class break point, such as an isolation valve; and a hydraulic evaluation for added sprinklers or fire hose stations, as applicable.
The applicable fire and building codes (such as NFPA codes) will be followed and a fire protection engineer will review the change.
Scheduled fire protection inspections are conducted under the direction of QA (Nuclear Oversight) and with direct participation by a qualified fire protection engineer consultant...
New designs or revisions.to plant fire protection systems are reviewed as outlined in the response to Section 3.1.
The Quality Assurance Program applies to procurement, design, installation, modifications and maintenance activities involving fire protection systems.
As such, each specific criteria listed as "a" through "j" of Section NRC Position are.covered-by the Quality Assurance 3.4-1a
AMENDMENT 26 DECEMBER 26e2 SECTION NRC POSITION
- d.
Inspection A program for independent inspection of activities affecting fire protection should be established and executed by or for the organization performing the activity to verify conformance with docu mented installation drawings and test proce dures for accomplishing the activities.
IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE
- d.
Independent inspections are performed by Quality Assurance (Nuclear Oversight), utilizing fire protection consultants, as required.
I At Byron, periodic inspections are performed on fire-rated penetration seals.
Inspection of the interface between exterior electrical conduit surfaces and the fire barrier are performed as part of the periodic fire barrier inspection.
This conduit/barrier Interface consists of an approved material specified by typical details on design drawings, which restores the barrier after the conduit has been installed in accordance with the QA Program.
At the request of the Byron NRC Resident Inspector in May 2600, one sample conduit penetration in a masonry block wall in the Unit 2 4KV Switchgear Room was examined to verify its installation conforms to the design detail.
It was confirmed that the conduit/barrier interface was installed during initial installation as specified in the design drawing.
See also Section C.4.i for a discussion of Records associated with the installation of conduit/barrier interfaces.
3.4-3 BYRON
AMENDMENT 26 DECEMBER 2002 "X~--
SECTION NRC POSITION
- e.
Test and Test Control A test program should be established and imple mented to ensure that testing is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements.
The tests should be performed in accordance with written test procedures; test results should be properly evaluated and acted on.
IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE
- e.
Tests of fire protection equipment and systems are included in regularly scheduled station operating surveillance procedures.
These procedures and test results are reviewed and evaluated by appropriate station personnel.
QA (Nuclear Oversight) also audits this area.
- f.
Inspection. Test.
and Operating Status Measures-should be established to provide for the identification of items that have satis factorily passed required tests and inspections.
- g.
Nonconforming Items Measures should be established to control Items that do not conform to specified requirements to prevent inadvertent use or Installation.
3.4-3a BYRON I
BYRON AMENDMENT 2e DECEMBER 2eG2 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE
- h.
Corrective Action Measures should be established to ensure that conditions adverse to fire protection, such as fail ures, malfunctions, de ficiencies, deviations, defective components, un controlled combustible material and nonconform ances. are promptly identified, reported, and corrected.
- i.
Records Records should be prepared and maintained to furnish evidence that the criteria enumerated above are being met for activities affect ing the fire protection program.
- h.
Tests of fire protection equipment and systems are included in regularly scheduled operating surveillance procedures.
Nonconforming equipment is identified as a result of their test and corrective action taken to rectify any deficiencies as provided by the QA Program.
- i.
Documentation involving the fire protection program is retained in a central file or QA vault as provided by the QA Program.
Records of fire-rated barriers and fire-rated penetration seals are maintained in accordance with the QA Program.
Individual installation records for each internal conduit non-combustible seal.
cable tray fire stop, mechanical penetration seal, and other fire-rated seals are maintained in accordance with the QA Program.
The sealing interface between exterior electrical conduit surfaces and a fire barrier is not considered an individual fire seal.
Installation records of this interface are a part of the fire barrier QA records.
3.4-4
BYRON AMENDMENT 20 DECEMBER 2062 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Aud.
Audits should be conducted and documented to verify compliance with the fire protection program, including design and procurement documents, instructions, procedures and drawings. and inspection and test activities.
J.
Scheduled audits and surveillances of the fire protection activities in our plants are performed in accordance with the QA Program by the Nuclear Oversight Department.
3.4-4a
BYRON AMENDMENT 20 DECEMBER 20e2 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE
- -J' SECTION NRC POSITION located 26 feet from the exposed face.
(4)
Penetration openings for ventilation systems should be protected by fire dampers having a rating equivalent to that required of the barrier (see NFPA-9gA, "Air Conditioning and Ventilating Systemsm).
Flexible air-duct coupling in ventilation and filter systems should be noncombustible.
(5)
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 labora tory.
Such doors should be self-closing or provided with closing mechanisms and should be inspected semiannually to verify that automatic hold open, release, and closing mechanisms and latches are operable.
(See NFPA 80, "Fire Doors and Windows.")
One of the following measures should be provided to ensure they will protect the opening as required in case of fire:
Ventilation system penetrations in rated barriers are protected by fire dampers having a rating equivalent to that of the barrier.
For details, see the Fire Protection Report Subsection 2.1.4.1b and c.
See Table 3-1 for delineation of conformance with NFPA-90A.
Access doors in fire barriers are Label A or B fire doors or are of Label A or B construction (see Section 2.1, page 2.1-8 for a detailed discussion of doors provided for rated fire barriers).
See Table 3-1 for delineation of conformance with NFPA 80:
All fire doors have automatic closers.
Options a, b, and d are used on various doors in the plant.
Cable spreading room interior doors alarm in the control room.
The other supervised doors are monitored by security.
3.5-4 I
I
AMENDMENT 26 DECEMBER 2662 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE SECTION NRC POSITION (a)
Fire doors should be kept closed and electrically supervised at a contin uously manned location; (b)
Fire doors should be locked closed and inspected weekly to verify that the doors are in the closed position; (c)
Fire doors should be provided with automatic hold-open and release mechanisms and inspected daily to verify that doorways are free of obstructions; or (d)
Fire doors should be kept closed and inspected daily to verify that they are in the closed position.
The fire brigade leader should have ready access to keys for any locked fire doors.
Access protected by automatic total flooding gas suppression systems should have electrically supervised self closing fire doors or should satisfy option (a) above.
Locked fire doors are inspected every 31 days, based upon historical analysis of plant specific records (document identification number DG99-800873).
Unlocked fire doors are inspected every 7 days, based upon historical analysis of plant specific records (document identification number DG99-6e6873).
The brigade chief can obtain a key to access all areas.
The diesel generator day tank rooms and the auxiliary feedwater diesel driven pump and day tank rooms are not electrically supervised, although they are protected by automatic total flooding gas suppression systems.
The fire doors to these rooms are surveilled to ensure they are in their proper positions.
3.5-5 BYRON I
BYRON SECTION NRC POSITION (6)
Personnel access routes and escape routes should be provided for each fire area.
Stairwells outside primary containment serving as escape routes, access routes for firefighting, or access routes to areas containing equipment necessary for safe shutdown should be enclosed in masonry or concrete towers with a minimum fire rating of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and self-closing Class B fire doors.
AMENDMENT 28 DECEMBER 2e62 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE The stairwells at Byron which serve as escape routes for station personnel and access routes for fire-fighting personnel, as per the requirements of building codes, are enclosed by 2-hour fire rated masonry walls with self-closing fire doors, and are clearly marked.
3.5-5a
BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (7)
Fire exit routes should be clearly marked.
(8)
Each cable spreading room should contain only one redundant safety division.
Cable spreading rooms should not be shared between reactors.
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 <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
(9)
Interior wall and structural components, thermal Insulation materials, radiation shielding materials, and soundproofing should be noncombustible.
Materials that are acceptable for use as interior finish without evidence of test and listing by a nationally recognized laboratory are the following:
Plaster, acoustic plaster, gypsum plasterboard (gypsum wallboard), either plain, wallpapered, or painted with oil-or water-base paint; Ceramic tile, ceramic panels; Glass, glass blocks; Brick, stone, concrete blocks, plain or painted; Steel and aluminum panels, plain, painted, or enameled; Vinyl tile, vinyl-asbestos tile, linoleum, or asphalt tile on concrete floors.
Comply, see item 6 above.
The Byron design complies, except for instances where cables from both safety divisions are routed in the same cable spreading room.
Fire Protection Report Section 2.4.2 describes the measures taken in these areas to assure safe shutdown.
Minor amounts of combustibles are used as architectural finish materials.
These existing materials do not significantly contribute to the fire loading in the plant, and do not expose safety-related systems to undue risks.
3.5-6
BYRON AMENDMENT 2e DECEMBER 2802 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE fire suppression system should be installed in the fire area.
(3)
If the guidelines of Positions C5.b.1 and C5-b.2 cannot be met, then alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room, or zone under consideration should be provided.
- c.
Alternative or Dedicated Shutdown Capability (1)
Alternative or dedicated shutdown capability provided for a specific fire area should be able to achieve and maintain subcritical reactivity conditions in the reactor, maintain reactor coolant Inventory, achieve and maintain hot standby* conditions for a PWR (hot shutdown* for a BWR) and achieve cold shutdown*
conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and maintain cold shutdown conditions thereafter.
During the postfire shutdown, the reactor coolant system process variables shall be maintained within those predicted for a loss of normal ac power, and the fission product boundary integrity shall not be affected; i.e., there shall be no fuel clad damage, rupture, or any primary coolant boundary, or rupture of the containment boundary.
- As defined in the Technical Requirements Manual 3.5-10
AMENDMENT 20 DECEMBER 2082 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE SECTION NRC POSITION and shall accommodate postfire conditions where offsite power is available and where offsite power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Procedures shall be in effect to implement this capabil1ty.Comply.
(4)
If the capability to achieve and maintain cold shutdown will not be available because of fire damage, the equipment and systems comprising the means to achieve and maintain the hot standby or hot shutdown condition shall be capable of maintaining such conditions until cold shutdown can be achieved.
If such equipment and systems will not be capable of being powered by both onsite and offsite electric power systems because of fire damage, an independent onsite power system shall be provided.
The number of operating shift personnel, exclusive of fire brigade members, required to operate such equipment and systems shall be onsite at all times.
(5)
Equipment and systems comprising the means to achieve and maintain cold shutdown conditions should not be damaged by fire; or the fire damage to such equipment and systems should be limited so that the systems can be made operable and cold shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Materials for such repairs shall be readily available onsite and procedures shall be in effect to implement such repairs.
If such equipment and systems used prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the fire will not be capable of being powered by Comply.
Comply.
Repair procedures have been I prepared to cover any repairs required.
All materials and equipment needed to make these repairs will be maintained onsite.
3.5-12 BYRON
AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE SECTION NRC POSITION both onsite and offsite electric power systems because of fire damage, an independent onsite power system should be provided.
Equipment and systems used after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be powered by offslte power only.
(6)
Shutdown systems Installed to ensure postflre shutdown capability need not be designed to meet seismic Category I criteria, single failure criteria, or other design basis accident criteria, except where required for other reasons, e.g., because of interface with or impact on existing safety systems, or because of adverse valve actions due to fire damage.
(7)
The safe shutdown equipment and systems for each fire area should be known to be isolated from associated circuits in the fire area so that hot shorts, open circuits, or shorts to ground in the associated circuits will not prevent operation of the safe shutdown equipment.
The separation and barriers between trays and conduits containing associated circuits of one safe shutdown division and trays and conduits containing associated circuits or safe shutdown cables from the redundant division, or the isolation of these associated circuits from the safe shutdown equipment. should be such that a postulated fire involving associated circuits will not prevent safe shutdown.
Comply.
Comply.
There are no associated circuits as defined in IEEE 384-1974 at B/B.
Associated circuits as defined in the NRC's April 6, 1982 clarification letter to Generic Letter 81-12 are addressed in Subsection 2.4.1.6.
3.5-13 BYRON I
AMENDMENT 20 DECEMBER 20e2 SECTION NRC POSITION portable hand extinguishers should be provided.
Safety-related cable trays of a single division that are separated from redundant divisions by a fire barrier with a minimum rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and are normally accessible for manual firefighting should be protected from the effects of a potential exposure fire by providing automatic water suppression in the area where such a fire could occur.
Automatic area protection.
where provided, should consider cable tray arrangements and possible transient combustibles to ensure adequate water coverage for areas that could present an exposure hazard to the cable system.
Manual hose standpipe systems may be relied upon to provide the primary fire suppression (in lieu of automatic water suppression systems) for safety-related cable trays of a single division that are separated from redundant safety divisions by a fire barrier with a mini mum rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and are normally accessible for manual firefighting if all of the following conditions are met:
IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE cable tray system at Byron.
Cables are not considered to be the primary fire hazard in any areas of the plant except the cable spreading rooms, and therefore they do not have specific fire suppression systems provided, except for the cable spreading rooms.
- However, cable trays are protected by the detection and/or manual suppression equipment provided for areas where they are located.
Refer to Section 2.3 for detailed discussion of each fire zone.
(a)
The number of equivalent*
standard 24-inch-wide cable trays (both safety related and nonsafety related) in a given fire area is six or less;
- Trays exceeding 24 inches should be counted as two trays; trays exceeding 48 inches should be counted as three trays, regardless of tray fill.
3.5-18 BYRON
AMENDMENT 26 DECEMBER 2002 3.6 FIRE DETECTION AND SUPPRESSION IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE SECTION NRC POSITION
- a.
Fire Detection Protection (1)
Detection systems should be provided for all areas that contain or present a fire exposure to safety-related equipment.
(2)
Fire detection systems should comply with the requirements of Class A systems as defined in NFPA 72D, "Standard for the Installation, Maintenance, and Use of Proprietary Protective Signaling Systems," and Class 1 circuits as defined in NFPA 7e, "National Electrical Code."
(3)
Fire detectors should be selected and installed in accordance with NFPA 72E, "Automatic Fire Detectors.m Preoperational and periodic testing of pulsed line-type heat detectors should demonstrate that the frequencies used will not affect the actuation of protective relays in other plant systems.
(4)
Fire detection systems should give audible and visual alarm and annunciation in the control room.
Where zoned detection systems are used in a given fire area, local means should be provided to identify which detector zone has actuated.
Local audible alarms should sound in the fire area.
(5)
Fire alarms should be distinctive and unique so they will not be confused with any other plant system alarms.
Comply with exceptions.
See Table 2.2-3.
Codply, see Appendix 5.4..
See Table 3-1 for delineation of conformance to NFPA 72D.
Comply.
Line type heat detectors are not used, in general, at B/B except in most charcoal filters and all outdoor transformers.
See Table 3-1 for delineation of conformance to NFPA 72E.
The fire detection system will give audible and visual alarm and annunciation in the control room.
Local alarms are provided for areas with fixed suppression systems.
Comply.
3.6-1 BYRON I
AMENDMENT 20 DECEMBER 2602 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE SECTION NRC POSITION from either or both.
- However, a failure in one tank or its piping should not cause both tanks to drain.
Water supply capacity should be capable of refilling either tank in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or less.
(1e)
Common tanks are permitted for fire and sanitary or service water storage.
When this is done, however, minimum fire water storage requirements should.be dedicated by passive means, for example, use of a vertical standpipe for other water services.
Administrative controls, including locks for tank outlet valves, are unacceptable as the only means to ensure minimum water volume.
(11)
The fire water supply should be calculated on the basis of the largest expected flow rate for a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, but not
-less than 386,666 gallons.
This flow rate should be based (conservatively) on 560 gpm for manual hose streams plus the largest design demand of any sprinkler or deluge system as determined in accordance with NFPA 13 or NFPA 15.
The fire water supply should be capable of delivering this design demand over the longest route of the water supply system.
(12) Freshwater lakes or ponds of sufficient.size may qualify as sole source of water for fire protection but require separate redundant suctions in one or more intake structures.
These supplies should be separated so that a failure of one supply will not result in a failure of the other supply.
Not applicable.
Comply.
The original calculations on the fire protection system were based on a line break that creates the greatest friction loss in the system per NEIL requirements.
This has the same effect as delivering water over the longest route even though the longest route was not considered in the calculation.
It would take four line breaks to restrict the flow to only the longest route.
See Table 3-1 for delineation of conformance to NFPA 13 and NFPA 15.
Comply.
At Byron, the natural draft cooling tower basin serves as the sole source of water for fire protection.
As described in a January 6, 1983 letter from T. R.
Tramm to H. R. Denton responding to a CMEB request, the required volume of fire protection water will always be available from this source.
3.6-6 BYRON
AMENDMENT 2e DECEMBER 20e2 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE SECTION NRC POSITION Particular consideration should also be given to:
(1)
Minimum required C02 concentration, distribution, soak time, and ventilation control; (2)
Anoxia and toxicity of C02; (3)
Possibility of secondary thermal shock (cooling) damage; (4)
Conflicting requirements for venting during C02 injection to prevent overpressurization versus sealing to prevent loss of agent; and (5)
Location and selection of the activating detectors.
- f.
Portable Extinguishers Fire extinguishers should be provided in areas that contain, or could present a fire exposure hazard to, safety related equipment in accordance with guidelines of NFPA 10, "Portable Fire Extinguishers, Installation, Maintenance and Use."
Dry chemical extinguishers should be installed with due consideration given to possible adverse effects on safety related equipment installed in the area.
Concentration and hold times are verified by a vendor test during the construction phase.
Ventilation is controlled by fire dampers with electrothermal links.
In addition to a pre-discharge alarm for personnel protection, an odorizer has been added to the C02 systems, which adds a wintergreen odor to the C02.
See Table 3-1 for delineation of conformance with NFPA 18.
3.6-13 BYRON
BYRON AMENDMENT 20 DECEMBER 2e82 3.7 GUIDELINES FOR SPECIFIC PLANT AREAS IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE SECTION NRC POSITION
- a.
Primary and Secondary Containment (1)
Normal Operation - Fire protection requirements for the primary and secondary containment areas should be provided for hazards identified by the fire hazards analysis.
Examples of such hazards include lubricating oil or hydraulic fluid system for the primary coolant pumps, cable tray arrangements and cable penetrations, and charcoal filters.
Because of the general inaccessibility of primary containment during normal plant operation, protection should be provided by automatic fixed systems.
The effects of postulated fires within the primary containment should be evaluated to ensure that the integrity of the primary coolant system and the containment is not jeopardized assuming no action is taken to fight the fire.
(a)
Operation of the fire protection systems should not compromise the integ rity of the containment or other safety-related systems.
Fire protection activities in the contain ment areas should function in conjunction with total containment requirements such as ventilation and control of contaminated liquid and gaseous release.
Byron complies except as identified below.
Fixed automatic suppression is not provided.
Hose stations and portable extinguishers are available throughout the containment.
Ionization detectors provide local coverage over cable penetrations.
Heat detectors are provided over the reactor coolant pumps.
The charcoal filter units within containment are provided with manual deluge systems.
Temperature switches provide detection alarms to the control room for the charcoal units.
Comply.
Manual hose stations are relied upon for primary suppression inside the containment.
Safety related equipment inside the containment is qualified for a post LOCA environment, including water spray.
Firefighting activities are thus not expected to adversely affect safe shutdown components or the containment integrity.
3.7-1
AMENDMENT 20 DECEMBER 2002 SECTION NRC POSITION All cables that enter the control room should terminate in the control room.
That is, no cabling should be routed through the control room from one area to another.
Cables in underfloor and ceiling spaces should meet the separation criteria necessary for fire protection.
Air-handling functions should be ducted separately from cable runs in such spaces; i.e., if cables are routed in underfloor or ceiling spaces, these spaces should not be used as air plenums for ventilation of the control room.
Fully enclosed electrical raceways located in such underfloor and ceiling spaces, if over 1 square foot in cross-sectional area, should have automatic fire suppression inside.
Area automatic fire suppression should be provided for underfloor and ceiling spaces if used for cable runs unless all cable is run in 4 inch or smaller steel conduit or the cables are in fully enclosed raceways internally protected by automatic fire suppression.
There should be no carpeting in the control room.
- c.
Cable Soreading Room The primary fire suppression in the cable spreading room should be an automatic water system such as closed-head sprinklers, open-head deluge system, or open directional water spray system.
Deluge and open spray systems should have provisions for manual operation at a IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE Comply.
All cables that enter the control room terminate in the control room.
The ESF Division 11 cables enter from the ceiling and ESF Division 12 cables enter from the floor.
Cable separation is defined-in IEEE Standard 384-1974 and NRC Regulatory Guide 1.75.
Comply, except as explained below.
Ceiling and floor are not used as a plenum.
Ducts are not used for cable runs.'
There are no electrical cable trays located under floor and ceiling spaces.
This is-currently also true for the raised floor.-n the Byron computer room, which is part of the control room complex..
There are some conduits above the dropped ceiling.
Upper cable spreading room has automatic halon and lower cable spreading room has automatic C02.
Upper cable spreading room has a manual C02 system as a backup.
Carpeting in the main control room has a Class 1 rating.
Comply, except as explained below:
The Byron design includes several cable spreading rooms at elevation 439'-0" and 463'-4-1/2".
The rooms are designed such that redundant safe shutdown cabling is routed through separate rooms (except as noted in Section 2.4.2) and isolated by 3-hour fire barriers.
The upper cable spreading rooms are protected 3.7-8 BYRON I
BYRON AMENDMENT 2e DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE remote station; however, there should be provisions to preclude inadvertent operation.
Location of sprinkler heads or spray nozzles should consider cable tray arrangements and possible transient combustibles to ensure adequate water coverage for areas that could present exposure hazards to the cable system.
Cables should be designed to allow wetting down with water supplied by the fire suppression system without electrical faulting.
Open-head deluge and open directional spray system should be zoned.
The use of foam is acceptable.
Cable spreading rooms should have:
(1)
At least two remote and separate entrances for access by fire brigade personnel; (2)
An aisle separation between tray stacks at least 3 feet wide and 8 feet high; (3)
Hose stations and portable extinguishers installed Immediately outside the room; (4)
Area smoke detection; and (5)
Continuous line-type heat detectors for cable trays inside the cable spreading room.
Drains to remove firefighting water should be provided.
When gas systems are Installed, by an automatic Halon 1301 system with a manual C02 backup system.
Manual hose stations and portable extinguishers provide additional backup.
The lower cable spreading areas are protected by an automatic C02 System. Backup is provided by manual hose stations and portable extinguishers.
The Halon and C02 systems as installed at Byron meet the requirements of the governing NFPA codes 12 and 12A.
Cable spreading rooms 3.3B-1 and 3.3B-2 have only one access door.
The BTP position is that an automatic water suppression system should be installed in the cable spreading rooms.
The Byron system provides adequate fire protection in the cable spreading rooms without an automatic water system.
Hose stations are available for use in the cable spreading rooms if required.
An automatic water suppression system was not Installed in the cable rooms because of concerns about the probability and effects of inadvertent actuations.
The thermal elements in the Fenwall rate compensated heat detectors are very similar to the thermal elements in the automatic water suppression systems.
Since a cable fire would generate large quantities of smoke in a very early. stage of a fire, the ionization detectors would be very effective in detecting small cable fires and annunciating in the Control Room.
If the fire was of such magnitude that the thermal detectors sensed the fire, the actuation of the fire suppression system would then be initiated.
The 3.7-9 I
AMENDMENT 20 DECEMBER 2602 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE SECTION NRC POSITION
- d.
Plant Computer Rooms Computer rooms for computers performing safety-related functions that are not part of the control room complex should be separated from other areas of the plant by barriers having a minimum fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and should be protected by automatic detection and fixed automatic suppression.
Computers that are part of the control room complex but not in the control room should be separated and protected as described in Posit.ion C.7.b.
Computer cabinets located in the control room should be protected as other control room equipment and cable runs therein.
Non safety-related computers outside the control room complex should be separated provide localized control without the effects to the general area which could result from actuation of a deluge system.
As shown in the*
Byron'Fire Protection Report, hose stations are located in each compartment of the upper and lower cable spreading areas.
Hose stations are located adjacent to each doorway so that applicati6n of water is available.
In summary, the Byron cable spreading area fire protection system design ensures that fire will not compromise plant safety.
Use of automatic halon or COz systems instead of water deluge reduces the probability of a plant shutdown or equipment damage in the event of a spurious actuation.
Additionally, the area is well supplied with manual hose stations and portable hand extinguishers.
The process computer at Byron is non-safety-related and is part of the control room complex.
Automatic fixed suppression is not provided.
Fire protection features which are provided are described in Subsection 2.3.4 of this report.
3.7-11 BYRON I L
BYRON SECTION NRC POSITION and alarm locally.
Ventilation systems in the battery rooms should be capable of maintaining the hydrogen concentration well below 2 vol Loss of ventilation should be alarmed-in the control room.
Standpipe and hose and portable extinguishers should be readily available outside the room.
AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE counterpart and other fire zones by 3-hour rated-fire barriers.
Detectors do not alarm locally.
- h.
Turbine Building The turbine building should be separated from adjacent structures containing safety related equipment by a fire barrier with a minimum rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
The fire barriers should be designed so as to maintain structural integrity even in the event of a complete collapse of the turbine structure.
Openings and penetrations In the fire barrier should be minimized and should not be located where the turbine oil system or generator hydrogen cooling system creates a direct fire exposure hazard to the barrier.
Considering the severity of the fire hazards, defense in depth may dictate additional protection to ensure barrier integrity.
I.
Diesel Generator Areas Diesel generators should be separated from each other and from other areas of the plant by fire barriers having a minimum fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
The Applicant complies with this position with one exception.
The complete collapse of the turbine building structure is not a design basis event for the Byron plant.
This building, although not a Category I structure, is designed for the SSE and other Category I loads.
Fire protection features are.
adequate to prevent a fire of sufficient severity to threaten the integrity of the structure from developing.
Comply, except as noted below:
UV detectors do not alarm locally.
Thermal detectors do not alarm locally prior to C02 discharge.
3.7-14 I
BYRON AMENDMENT 26 DECEMBER 26e2 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE
- j.
Diesel Fuel Oil Storage Areas Diesel fuel oil tanks with a capacity greater than 1,160 gallons should not be located inside buildings containing safety-related equipment.
If above-ground tanks are used, they should be located at least 56 feet from any building containing safety-related equipment or, if located within 56 feet, they should be housed in a separate building with construction having a minimum fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
Potential oil spills should be confined or directed away from buildings containing safety-related equipment.
Totally buried tanks are acceptable outside or under buildings (see NFPA 3e, "Flammable and Combustible Liquids Code," for additional guidance).
Above-ground tanks should be protected by an automatic fire suppression system.
- k.
Safety-Related PUmDS Pump houses and rooms housing redundant safety-related pump trains should be separated from each other and from other areas of the plant by fire barriers having at least 3-hour ratings.
These rooms should be protected by automatic fire detection and suppression unless a fire hazards analysis can demonstrate that a fire will not endanger other safety related equipment required for safe plant shutdown.
Fire detection should alarm and annunciate in the control room and alarm locally.
Hose Comply, except as noted below:
Diesel fuel oil-tanks are located within the auxiliary building.
See Table 3-1 for delineation of conformance with NFPA 30.
The outdoor above-ground diesel fuel oil storage tanks (located more than 5e feet away from any building containing safety-related equipment) are not protected by an automatic fire suppression system.
Potential fuel oil spills are confined within a berm.
Manual suppression capability from nearby hydrants will prevent the fire from spreading-from the berm.
Comply, except as noted below:
Most safety-related pumps are located in the auxiliary building.
Most pumps are located in individual rooms separated from other plant areas by.walls of substantial construction, but which generally do not carry fire ratings.
Automatic fire detection is provided for all pumps, but automatic suppression Is in general not provided.
Refer to the applicable portions of Sections 2.3 and 2.4 of this Fire Protection Report for a description of individual pumps and the fire hazards and safe shutdown analyses.
3.7-16
(i BYRON-1 TABLE 3-1 NFPA CODE DEVIATION REPORT RECONMENDATION
/NUMER NFPA 10. 1981 EdItion - Portabse ExtInguishers (Cont'd Extinguishers shall be inspected monthly.
Extinguishers are inspected quarterly, except for fire extinguishers located Inside
'the containment building during at-power conditions.
Performance based historical reviews of previously performed monthly inspections have demonstrated few inspection failures.
sufficient to justify extending the inspections to a quarterly basis.
This evaluation was conducted in accordance with the approved administrative procedure for "Performance Based Evaluation for Fire Protection'.
During at-power conditions, access to "the containment building is controlled administratively to prevent unauthorized entry.
There is very small risk that fire extinguishers located within the containment will be tampered with or removed during at-power conditions.
An Inspection of fire
,extinguishers will be performed at the beginning of each plant refueling outage.
3-4a AMENOMEMI 20 DECEMBER 2002 1-1 2 (S)*
1-1981-4-3.1 FluIREOE
(
TABLE 3-1 NFPA CODE DEVIATION REPORT RECOMMENDATION NUMBER RESOLUTION NFPA 12. 1981 Edition - Portable Extinguishers (Cont'd-Extinguishers shall be subjected to maintenance not more than I year apart.
Comply, except for extinguishers located inside the containment building during at-power conditions.
During at-power conditions, access to the containment building is controlled adminstratively to prevent unauthorized entry.
There is very small risk that fire extinguishers located within containment will be tampered with during at-power conditions.
Maintenance or replacement of fire extinguishers inside the containment building will be performed at the beginning of each plant refueling outage.
3-4b
(
AMENDMENT 20 DECEMBER 2092 BYRON-1 FIE RZONES 1-1. 2 (S),
16-1981-4-4.1
(
BYRON-1 TABLE 3-1 NFPA CODE DEVIATION REPORT RECOMMENDATION HU"BER REERENC$
NFPA 16. 1981 Edition - Portable Extinguishers (Cont'd) 1-1.
2 (S)*
10-1981-4-4.3 Extinguishers shall have a tag or label securely attached.
Comply, except for fire extinguishers located inside the containment building.
Fire extinguishers located inside the containment building will not have an attached inspection/maintenance tag.
Tags capable of being routinely signed and dated are not compatible with the plant requirement to prohibit potential debris that may clog the Containment recirculation sump.
The extinguisher Inspection and maintenance data sheets from plant procedures provide retrievable records of the required inspections and maintenance and satisfy the intent of the code for the fire extinguishers located within the containment building.
3-4c
(
AMENDMENT 20 DECEMBER 2002 FIE RZONE I
(
(
BYRON-1
^nrnunCmn zu DECEMBER 2e82 TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE ZONES NFPA REFERENCE*
NUMBER RECM RNAO COMMETrS RESOLUTION NFPA 11. 1983 Edition - Foam Systems 1B.2e-O(NS)
(Previous NFPA 11 review recommendations are deleted because the foam system previously protecting the outdoor fuel oil storage tank has been abandoned and is no longer used.)
THIS PAGE IS INTENTIONALLY BLANK I
3-5
(
BYRON-1 AMENDMENT 28 DECEMBER 2882 TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE ZONES HFPA REFERENCE*
NUMBER NFPA 11.
1983 Edition - Foam Systems (Cont'd)
COMMENTS THIS PAGE IS INTENTIONALLY BLANK 3-6 RESOLUTION I
(
BYRON-1 TABLE 3-1 (Cont'd)
FIRE ZONES NFPA 12. 198e Edition - Carbon Dioxide All CO: Systems (S&NS)
All C02 Systems 8.3-1 18.11-8 9.1-1. 9.2-1.
9.3-1. 9.4-1.
11.4 A-I(S)
RECOMMENDATION NUMBER RECOMMENDATITON COMMENTS RESOLUTION 12-1980-1-1.3.2 12-1986-1-11.2 12-1988-1-9.6.1 12-1988-1-8.3.8 Provide the hydrostatic test pressure used on the valves controlling the low pressure COi systems.
2 Verify that all carbon dioxide systems will be thoroughly in spected and tested at least annually.
5 Verify that the CO storage tanks (18 ton and 2 ton) were tested and marked in accor dance with specifications of ASHE for unfired pressure vessels.
7 Fuel supply should be automatically shut off to the diesel generators and diesel driven auxiliary feedwater pump in case of fIre in those areas.
M&MPC will obtain and approve the required Information prior to 5%
power.
System demonstration procedure was reviewed; will be 18 month sur veillance.
This fre quency is considered to be satisfactory.
Station will obtain vendor information.
M&MPC will revie by 5%
power to verify the tanks meet the applicable ASME requirements.
Diesel engine is required for safe shut down and fuel will not be interlocked to shut off.
The room is protected by automatic COz in the event of a fire.
3-7 C
AMENDMENT 20 DECEMBER 2602 I
I
AMENDMENT 20 DECEMBER 2662 TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE-ZONES NFPA REFERENCE NUMBER NFPA 12. 1980 Edition - Carbon Dioxide (Cont'd)
RECOMMENDATION THIS PAGE IS INTENTIONALLY BLANK 3-8 C
BYRON-1 COMMENTS RESOLUTION I
(
BYRON-1 AMENDMENT 28 DECEMBER 2092 TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE ZONES nFPA REFERENCE NUMBER t
ffFPA 12A.
1980 Edittton - Halon 1391l Fire ExtinguishtngSystems NFPA 12A-198e 1-7.4 NFPA 12A-1980 6
The completed system shall be tested to meet the approval of the authority having jurisdiction.
a Plans and specifications shall include all pertinent Items necessary for the proper design.
To assure that the freon substitute test gas provided a meaningful test. list the weight(s) of the freon for the 1/28/81 test.
The Viking 1/28/81 test report refers to 1-109 lb reserve halon cylinder; however, there is no reserve backup for this system.
Station will obtain weight of freon test gas from Viking by 5% power.
Investigate why Viking referred to a 1oe lb reserve cylinder and then revise test report accordingly by S% power.
3-9 13.6(NS) 13.8(Ns)
I I
(.
BYRON-1
(
AMENDMENT 28 DECEMIBER 2882 TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION NFPA 12A.
1980 Edition - Halon 1381 Fire Extinhuishin! Systems (Cont'd)
RESOLUTION THIS PAGE IS INTENTIONALLY BLANK 3-1e
(
I
BYRON-1 AMENDMENT 29 DECEMBER 2e92 TABLE 3-1 (Cont'd)
RECOMMENDATION NUMBER EPA REFERE1BE COMMENTS NFPA 13 - Sprinkler Systems All zones sprinklered 13-1983 2-9.2.2 All System Stairwell sprinklers In 3 fire (S) zones Aux. Bldg. P-18 13-1983 1-8.1.1 13-1989 4-4.18 13-1983 3-8.4 1
Gauges on system risers shall have a maximum limit not less than twice the normal working pressure.
2 Only approved devices should be installed on sprinkler systems (shutoff valve).
3.1 Baffles shall be installed whenever sprinklers are less than 6 ft. apart to prevent the sprinkler opening first from wetting adjoining sprinklers.
For sprinklers Installed in pendant position below ceiling, return bend shall be used when the water supply is from a raw water source.
When water supply Is potable.
return bends are not required.
Gauges on riser are 386 psi.
"N' stamped and approved (UL) may not be available.
The valve fits the description in NFPA 13 other than it closes much faster than the required S seconds.
Spacing criteria is not met on certain hatchway sprinklers.
Ref. Drawings M-603. Sht. S.
M-18. M-31, and M-35.
Pendant style sprinklers for Unit 2 startup bldg. are locking return bends.
Gauges with pressure of 36e psi are considered more than adequate on the systems In the plant.
Present valve arrange ment does not compromise system integrity.
U.L.
listed valves will not be installed in lieu of "N" stamp valves.
Sidewall sprinklers are shielded by structural steel from the upright sprinkler discharge.
Resolved to the fact that the system Is adequately flushed, main drain tests are performed quarterly (further flushing the system piping) and the water supply is strained through a screen prior to its introduction into the system.
3-11 8.3-2(NS) 8.5-2(NS) 8.6-0 I
I
AMENDMENT 20 DECEMBER 2e02 TABLE 3-1 (Cont'd)
NFPA REFERENCE RECOMMENDATION NUMBER NFPA 13 - Sorinkler-Systems All zones(S) sprinklered All zones with sprinkers 13-1983 3-13.1.3 13-1983 3-14.1.2 Sprinkler system fittings should be examined to determine if they are of the heavy pattern type due to pressure on systems exceeding 17S psi.
Drain valves and test valves shall be listed type of 175 psi cold water pressure rating.
Some drain valves and test valves'are not UL listed.
The design of the pipe and fittings has been verified to be adequate for the maximum operating pressure of the system.
The original valves were supplied with a rating of 2001b per specification F-2817.
piping design table 98389.
Alternative valves have been installed In accordance with table 0838B with a pressure rating of 400 psi water, oil. gas.
This pressure rating is adequate for the maximum operating pressure of the FP system.
Note:
Some areas could not be visually Inspected due to obstructions and measurements could not be obtained.
These areas were reviewed against as-built drawings indicating piping dimensions and no deviations were observed In the sprinkler systems.
3-11a
(
(
BYRON-1 I
(i TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE ZONES NFPA REFERENCE NUMBER NFPA 13 - Sorinkler Systems (Cont'd)
RECOMMENDATION T11 PAGE IS INTE NALLY BLANK 3-12
(
AMENDMENT 29 DECEMBER 2002 BYRON-1
-RESOLUTION I
(
TAILE 3-1 (Cont'd)
FIRE ONES FP EFLERENEE NFPA 13 -Sri~rnkler-Systems (Cont'd)
RECOMMENDATION NUMBER-THIS PAOR 15 INTENTIONALL-Y BLANK 3-13 BYRON-i1 COMMENTS RESOLUTION AMENDMENT 28 DECEMBER 2e9Z RECOMM HDATION I
(
BYRON-1 AMENDMENT 20 DECEMBER 2082 TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE ZES RE E E
HUMER RECOMMENDATION NFPA 13A.
1981 Edition - Insoection. Testing. and Malntenance of Sorinkler System All Sprinklered Zones 13A-1981-3-5.1.1 (SANS)
All Exterior Zones (S&NS)
All Exterior Zones 13A-1981-2-7.3.1 13A-1981-2-1.21 I
A stock of 24 sprinklers should be maintained at all times including all temperature types that are utilized in the plant.
4 Quarterly each post indicator valve Should be given a
- spring" or torsion test.
NFPA 13A specifies a monthly Inspection to veritfy that hydrants are not obstructed and that they are accessible.
visible, and with caps In place.
Will be done by S5 power.
Sprinklers have been ordered.
Monthly the station will veritfy that lock is on and annually will open and close valve.
This is considered adequate.
Yard hydrants are Inspected annually to NFPA 25 inspection.
test. and maintenance requirements.
3-14 I
UE*A
- 1S lAeS J,&*..
(i AMIENDMENT 29 DECEMBER 2002 TABLE 3-1 (Cont'd)
RECOMMENDATION NUMBER rLr_.qW U-l Uslu M
sumUSuS 14-1983-4-43.3 14-1983-4-2.1 14-1983-7-5.1.3 14-1983-4-7.1 Each hose reel or hose rack throughout the station should be provided with a label affixed to Include *Fire Hose for Use by Occupants' and operating Instructions.
3 Verification should be made to assure that all existing angle valves on the standpipe systems are U.L. listed or F.M. approved.
Could not find listing on Anderson Greenwood Co. Valves.
Other valves have no Mfg. NA.
or Model No.
5
' Verification should be made to assure that fittings used on the standpipe systems are "extra-heavy" where pressures exceed 175 psi.
a The flowing pressures at hose outlets exceed 109 psi each.
Outlet shall be provided with an approved device to reduce to reduce the pressure with required flow at the outlet to 190 psi.
Fire hose will be utilized by trained fire brigade personnel only.
Other than red color coded piping, no further instructions will be provided.
Existing valves do not compromise system in tegrity.
Section III valves are required and will remain In place, as these valves are considered of equal quality to a listed valve.
The design of the pipe and fittings has been verified to~be adequate for the maximum operating pressure of the system.*
Fire brigade members are being trained for working pressures In excess of 150 psi.
Brigade training is being documented.
3-15
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FIRE ZONES BYRON-1 All
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AMENDMENT 20 DECEMBER 2002 TABLE 3-1 (Cont'd)
RECOMMENDATION NUMBER MesA 9A 9aOO CA4@4.4,
- Standoioe and Hose (Cont'd) 14-1983-7-7.1 14-1983-4.1.1 and 4-3.1 and 4-4.1 14-1983-4-4.3.4 14-1983-4-4.3.4 14-1983-5-2.3 All The purposes of these gauges Is to assure that minimum pressure requirements at the hose stations are met.
10 An approved 3-1/2" dial spray pressure gauge should be provided at the top of each standpipe.
Gauges shall be located in a suitable place where water will not freeze.
Each gauge wilt be controlled by a valve having arrangements for draining.
11 Elevation No. 412 in containment No. I Is adequately covered by hose connections from other levels.
Elevation No. 412 does not have any hose connection In containment.
12 All nozzles for Class I1 service hose throughout the plant should be listed for use on Class A. B. and C fires.
is Replace the straight-steam nozzles on hose reels 170.
171, and 173 with U.L. listed nozzles rated for Class A. B.
and C fires.
These hose stations are located in fuel handling areas.
19 The water supply for the hose connections in the "River Screen House" Is not automatic.
Revisions to the water supply should be made to provide an automatic water supply capable for supplying the streams first operated until the secondary sources can be brought into action.
The normal operating pressures of the fire protection system have been reviewed and calculations Indicate adequate pressure will be maintained.
There fore the gauges are not considered necessary.
Elevation 4121 is adequately covered by hose stations from adjacent levels in containment.
All nozzles have been replaced with properly listed nozzles, except for fuel handling building due to NRC not allowing spray nozzles.
Solid stream nozzles will remain in fuel handling areas.
No revisions to be made.
M&N has accepted current design.
- 3-16
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BYRON-I A call must be made to control room to start pump.
COMMENTS 12.1-e (NS) 13LLO A=-
AAR2 LUJAIMU I
I
Ki (i
"BYRON-1 TABLE 3-1 (Cont'd)
RECOIMMENDATION HFPAREFERENCE NUMBER RECOMMENDATION COMMENTS UfA IA IO
EA44.4
- Standotoe and Hose (Cont'd) 27 Provide a U.L. listed valve at the standpipe outlet of hose station 270 for attachment of hose.
28 Verification should be made on all hose racks to assure they are suitable for the. hose installed.
Each rack should be U.L. listed for lined or unlined hose.
Check hose rack at station Nos. 179.
186. 256. 263.
264.
184, 265. and 178.
U.L.
listed replacement hose reels are no longer available.
They will be replaced with similar nonlisted hose reels, as needed.
Non-listed valve does not affect operability of hose station.
Complete.
Fire hose is used by trained fire brigade personnel only.
Nonlisted hose reels do not affect the firefighting performance of the hose station.
14-1983-2-1.3.1 and 2-1.3.2 46 Verification should be made on M&NPC has determined all standpipe under 50 ft In existing design is height to be' a.minimum of 2 acceptable.
inches In size'and all in excess of SO ft shall be at least 2-112 in. in size.
41 Verification should be made to assure that all Class It standpipe systems are sized for a minimum flow of 1eO gpm for 30 minutes.
Where one or more standpipes are required.
ail common supply piping should be hydrostatically sized for a minimum flow of 1ee gpm:
The supply shall be sufficient to maintain a residual pressure of 65 psi at the topmost outlet of each standpipe.
The normal operation pressures of the fire protection system have been reviewed and calculations indicate that adequate pressure and flow will be maintained.
3-17 AMENDIENT 20 DECEMBER 2002 FIRE ZONES 14-1983-4-2.1 14-1983-4-4.3.2 14-1983-2-1.3 and 5-4.1 UrrL0 AMq.L2,a kH.,IL IiJUll I
I
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AMENDMENT 28 DECEMBER 2082 BYRON-I TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE ZONES NFPA REFERENCE NUMBER NFPA 14. 1983 Edition - Standtooe and Hose (Cont'd)
THIS PAGE "S INTENTIONALLY BLANK 3-18
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RESOLUTION I
AMENDMENT 28 DECEMBER 2002 TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE ZONES NFPA REFERENCE NUMBER NFPA 14. 1983 Edition-- Standpioe and Hose (Cont'd)
RECOMMENDATION THIS PAGE IS INTENTIONALLY BLANK 3-19
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BYRON-1
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RESOLUTION I
AMENDMENT 28 DECEMBER 2082 TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE ZONES N
REFERENCE NUMBER NFPA 14. 1983 Edition - Standoioe and "ose (Cont'd)
RjilEv E6a-TWON THIS PAGE IS INTENTIONALLY BLANK 3-2e
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-BYRON -I RESOLUTION I
AMENDHENT 29 DECEMBER 2892 TABLE 3-1 (Cont'd)
RECOMIENDATION FIRE ZONES NFPA REFERENCE NUMBER NFPA 14.
1983 Edition - Standopoe and Hose (Cont'd)
RECOMMENDATIN THIS PAGE IS INTENTIONALLY BLANK 3-21
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BYRON-1
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RESOLUTION I
BYRON-1 AMENDMENT 20 DECEMBER 2092 TABLE 3-1 (Cont'd)
RECOfMMENDATION FIRE ZONES 1FPA, REFERENCE NtMdER NFPA 14.
1983 Edittton -
Standpipe and Rose (Cont'd)
COMENS THIS PAGE IS INTENTIONALLY BLANK 3-22
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RECOMMfENDATION I
BYRON-i DECEMBER 2002 TABLE 3-i (Cont'd)
RECOMMNENDATION FIREZONS NPA RFERNCENUMBER NFpA 14, 1983 Editio)n -Standolpe and Hose (Cont'd)
THIS PACE IS INTENTIONALLY LANK 3-23 RESOLUTION I
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AfEODMENT 20 DECEMBER 20e2 TABLE 3-1 (Cont'd)
RECOMMlENDATION NUMBER RECOMMENDATION JEDA 1K lOQS EA4*4*n U.*.. Cnrav *vtt*mq 18.1eE-1(NS) 8.3-1. 18.10A-1.
18.1eD-1.
- 18. 19E-1(NS) 18.1OA-1.
18.1eB-I, 18.1eC-1.
18.10D-1.
18.10E-1(NS) 15-1983-2-1.1 1S-1983-2-S.1 15-1983-2-1.2 A cock handle should be installed on the alarm test connection for the water spray system protecting the system auxiliary transformer 142-1.
2 The Viking model D-5 deluge valves for the water spray systems protecting the transformers, lube oil storage tank, and turbine bearings are listed for maximum working pressures of 175 psi.
The static pressure on the systems was approximately 186 psi.
Higher pressure fittings should be used on these systems.
3 The equipment used to automatically actuate the transformer water spray systems should be listed by Underwriters' Laboratories for the purpose.
The heat detection equipment is not listed in the 1983 Fire Protection Equipment directory.
A static pressure slightly above the working pressure would probably not be harmful to the equipment.
Higher pressure rated valves and fittings should not be needed if the static stays not more than S to 10 psi above the rated working pressure of 17S psi.
An operator will carry a valve handle during testing and attach It to the stem.
This would guard against malicious operation.
Static pressure slightly above the working pressure would not be harmful to the equipment.
The detection equipment only supply on alarm function and do not actuate the water spray.
Thus the unlisted equipment is considered acceptable.
3-24
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(i BYRON-1 W
C C gtome ULLD AR, A994
%34JAIXLA HARL WLKA J.
I COMMENTS
TABLE 3-1 (Cont'd)
NFPA REFERENCE*
RECOMMENDATION NUMBER NFPA 15. 1983 Edition - Water Soray Systems (Cont'd) 16 The thermostat sensing line on the charcoal filter water spray systems should extend farther than two filter sections to cover the hazard.
11 The transformer water spray systems should operate automatically upon actuation of the heat detection system for proper hazard protection.
14 Provide water spray system test data to verify that.
under test conditions, heat detectors operate within 46 seconds when exposed to standard heat test source.
There are approximately 6 sections each with 9 levels of filter trays.
The only automatic operation is on failure of the transformer.
Detection has been redesigned and will be installedby S% power.
Station does not intend redesign.
Actuation of deluge valve trips transformer.
Detector test procedure will be revised by S%
power.
Test procedure will require work request to be initiated If response times are in excess of maximum allowable time specified in 1-3-8S M&MI letter.
3-26 (B
BYRON-1 FIRE ZONES 11.7-0(S)
- 18. leA-1.
- 18. 6o5-1.
- 18. I6C-1.
- 18. 16D-1.
- 18. leE-1(NS)
Atl (NS) 15-1983-4-3 15-1983-4-3 15-1983-8-6 AMENDMENT 20 DECEMBER 28e2 I
BYRON-1 AMENDMENT 29 DECEMBER 2602 TABLE 3-1 (Cont'd)
RECOMfMENDATION NUMfBER NFPA 15. 1983 Edition - Water Spray Systems (Cont'd) 15-1983-6-2.5 15-1983-6-2.6 1S-1983-6-2.8 15-1983-6-1.3 15-1983-4-6.2 1s Verify that water spray system control valves and automatic detection equipment is tested at least annually.
16 Verify that manual tripping devices and valves for water spray systems are operated at least annually.
17 Verify that all spray nozzles are visually inspected and cleaned, if necessary, at least annually.
28 Provide the frequency of regularly scheduled plant inspections at which water spray equipment is to be visually checked.
21 Verify that provisions are made for effective drainage of water from the filter area during the operation of the systems.
Procedures require testing to be conducted every 18 months.
This is considered adequate.
Procedures require testing to be conducted every 18 months.
This is considered adequate.
Procedures established for 18-month sur veillance.
This is considered adequate.
Procedure for,48 months surveillance has been written; This Is considered adequate.
Drains are purposely closed.
Operators would manually open drains upon system operation.
3-27
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BYRON-i AMENDMENT 20 DECEMBER 2002 TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE ZONES NFPA REFERENCE NUMBER NFPA 15. 1983 Edition - Water Sorav Systems (Cont'd)
COMMENTS INTENTIONALLy IS LEFT BLANK 3-28
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RESOLUTION RECOMM*ENDATION I
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C BYRON-1 TABLE 3-1 (Cont'd)
RECOMMENDATION FPA REFERENCE UMBER RECOMMENDATION N9PA i1 101a 91444n 9 %
atosr Cvwctm*
16-1986-2-1 16.1-.1 1e.2-1(s) 16.1-1. 1.2-i(S) 16.1-1. 10.2-1(S) 16-1986-4-3.3 16-1989-5-2 16-1980-7-1.1 1
All component parts including the foam water sprinkler system shall be listed.
The A-20 activator is pneumatic but is hydraulically supplied.
Valves were noted not to be listed. The Alison control panel is not listed.
2 All fittings shall be listed for pressures greater than 175 pstg.
4 Verification should be given that hydrostatic testing has been conducted at 56 psig over the fire pump's churn.
S The foam water sprinkler system shall be serviced by qualified personnel semiannually.
System pressure relief set at 186 psi.
Procedures are for servicing every 18 months.
Listing of these valves is not considered necessary since this
.system will be manually actuated.
S&L and M&:MPC will demonstrate that panels are functionally equivalent to listed panels prior to S%
power.
The design of the pipe and fittings has been verified to be adequate for the maximum operating pressure of the system.
Hydrostatic testing at 22S psi is considered adequate.
The procedure has been reviewed and approved (including a review by M&MPC).
3-29 AMENDMENT 20 DECEMBER 2002 FIRE ZONES COMMENTS 1e.1-., le.2.LUs)
I
BYRON-1 AMENDMENT 20 DECEMBER 2092 TABLE 3-1 (Cont'd)
RECOMMENDATION NUMBER 20-1983-2-7.1 26-1983-7-1.1.1 18.12-6 18.13-6 18.13-6 18.12-0 & 18.13-0 28-1983-7-1.1.3 20-1983-8-2.7.2 20-1983-8-6.1 20-1983-11-4.5 The electrical motor-driven ftire pump shall be protected against possible interruption of service.
6 The electric motor-driven ftire pump controller shall be listed for electric motor driven service.
7 The electric motor-driven fire pump controller shall be marked to show manufacturer's name and complete electrical rating.
16 The automatic electric solenoid valve located In the exchanger supply line for the 0
ftire pump diesel engine should be specifically listed for fire protection service.
Protected by distance and redundancy.
The controller Is not listed.
NFPA 26 specifies a weekly run of engines for not less than 36 minutes.
NFPA 26 specifies the units are to be operated weekly.
18.12-6 3-30
(
NrPA 7'A IQRA F,14t4nn The electric ftire pump is detached a minimum of 34 feet from a possible oil ftire exposure from the circulating water pumps.
The electric pump is also backed up by a redundant diesel engine-driven fire pump that Is located and protected In a 3-hour fire-rated room.
Justification has been provided to the HRC in a December 14. 1983 letter from T. R. Tram. to H. R. Denton.
Manufacturer's label not required.
Refer to Justitfication noted above.
Existing design justified, "UL does not label solenoid valve in the required range.
The diesel engine ftire pump will be started from ambient'conditions and operated for greater than or equal to 38 minutes every 31 days.
The motor-and diesel driven ftire pumps are operated every 31 days.
Fi rs Pamime 18.12-0 I
I I
BYRON-i AHENDMENT 20 DECEHBER 2002 TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE ZONES NFPA REFERENCE NUMBER NFPA 20. 1984 Edition-Fire Punos (Cont'd)*
THIS PAGE IS INTENTIONALLY LEFT BLANK 3-31
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RESOLUTION I
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RE FIRE-ZONES NFPA REFERENCE NFPA 20. 1984 Edition-Fire Pumis (Cont'd)
BYRON-1 TABLE 3-1 (Cont'd)
ECOMMENDATION NUMBER THIS PAGE 15 INTENTIONALLY LEFT BLANK 3-32 AMENDMENT 2e DECEMBER 2e02 RESOLUTION I
RECO¶MMENDATION N*UMBER
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TABLE 3-1 (Cont'd)
COMMENS Note MFPA 24. 1981 Edition - Fire Mains and Hydrants The following post-Indicator valve (PIVs) are located closer than 46 ft to the buildings:
3 The following hydrants are located closer than 40 ft to buildings they are protecting:
Not practical to relocate.
Not practical to relocate.
isolation capabilities are considered adequate.
Loss of any single hydrant does not affect building coverage.
24-1981-5-1.3 24-1981-8-6.2.9 4
The existing practice is to secure one 2-112-inch hose to the hydrant, but with the remaining part of the hose located in the hose house.
The hose Should be disconnected and completely stored In the hose house.
10 Documentation should be provided that substantiates the decision to omit thrust blocking on underground Piping at tees. elbows. etc.
Welded underground piping except connections to hydrants.
The hose houses have been removed.
A dedicated fire response truck or cart Is now maintained with hoses and equipment equivalent to three hose houses.
Restraints not needed on welded piping; thrust blocking provided at hydrant connections.
3-33 C
AMENDMENT 20 DECEMBER 26e2 BYRON-1 Outside Ring Header 24-1981-3-3.2 Outside Ring Header
- 24-1981-4-2.2 OFP 566 OFP 559 eFP 561 OFP 577 OFP 18S OFP 12S OFP 13S OFP 23S Outside Ring Header Outside Ring Header I
I I
(
TABLE 3-1 (Cont'd)
RECOM1ENDATION NUMBER
- ~AOt A&1-E**
- 4.
12 Check valves should be installed In connections between the fire protection water system and service water system.
13 The butterfly isolation valves on the connections between fire protection water system and service water system should be UL listed.
These connections are normally closed and automatic check valves are not needed.
These valves are on service water system and listing is not necessary.
Service water systems are third order backup water supply and procedures have been written to monitor potential leakage of butterfly valves Installed.
Valves are ASHE Section 1I1. Leakage monitoring procedure addresses leakage concerns.
No further action is required.
3-.4 BYRON-1 AMiENDMENT 20 DECEMBER 2002 FIRE ZONES Ir
-A Outside Ring Header Outside Ring Header 24-1981-8-4 24-1981-8-4 00je[l BELOrr 42-.
A211 9"9lklDn Ere U9JU I
9-Yl~
llUY.YlEui¢R11:
I
(
TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE ZONES pFPA REFERENCE NUMBER Note NFPA 24. 1981 Edition - Fire Mains and Hydrant (Cont'd)
RECOMffATIOM THIS PAGE IS INTENTIONALLY LEFT BLAMS 3-3S
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A?
AMENDMENT 29 DECEMBER 2082 BYRON-1 RESOLUTION I
(
TABLE 3-1 (Cont'd)
RECOMMENDATION NUMIER NFPA REFERENCE RECOMMENOATTON NFPA 26. 1983 Edition - Valve SuoervisiOn NFPA 26 specifies that locked open valves should be inspected monthly.
Locked open valves are Inspected every 92 days to verify the valve is In the correct position.
BYRON-1 AMENDMENT 20 DECEMBER 2e02 FIRE ZONES 26-1983-3-1 CO~MMENT RESOLUTION 3-36 I
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BYRON-1 AMENDMlENT 20 DECEflBER 2002 TABLE 3-1 (Cont'd)
RECOMMIENDATION NUBER FIRE ZONES NFPA 27. 1981 Edition - Private Fire Brigades NFPA specifies training sessions should be held at least monthly for one hour or more per shift.
Training sessions are conducted quarterly.
Training sessions conducted quarterly result in a total of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of training per year for each brigade member.
This level of training Is considered as satisfying NFPA.
3-37
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NFPA 27-1981 4.3 I
RECOMMEN ATION NIFPA REFERENCE
(,
BYRON-1 AMIENDMENT 29 DECEMBER 2082 TABLE 3-1 (Cont'd)
RECO¶MMENDATION NUMBER FIRE ZONES HFPA 30. 1981 Edition-Flamable Lioutds Code 8.2-1 Diesel lube oil drain tank 369(NS) 2 A 6.68-diameter emergency breather vent should be provided for the tank.
The subject tank is not safety-related and is not required for safe shutdown and a fire In this area will not affect safe shutdown of either unit.
Area-wide automatic water suppression is provided for the area where this tank is located.
The tank is provided with an existing vent.
The existing tank design will not be changed.
8.78-0 Station Auxiliary Diesel F.O.
Storage Tank(NS) 8.78-0 Station Auxiliary Diesel F.O.
Storage Tank(NS) 18.20-S (125.ee0 gal.
F.O. Storage Tank)(NS) 37-1979 5-5.3 30-1981 2-4.4.3 37-1979 5.6-1 36-1981 2-4.2 30-1981 2-2.5 38-1981 2-4.2 4
The liquid transfer connections beneath the liquid level of the tank should be provided with either (a) a normally closed remotely activated valve 95 or. (b) an automatic closing heat activated valve, or (c) another approved device to provide for quick cut-off of flow in the event of fire in the vicinity of the tank.
5 Tests should be performed on the 4* breather vent (BV) to determine whether the long length of pipe will create backpressures that can cause the internal pressures in the F.O. storage tank to exceed 2.5 psi when 78,980 CFH needs to be vented.
6 Supplement the existing 6V breather vent (BV) and the 40 overflow line with an 8.8' diameter emergency breather vent (EBV).
Neat activated valves will be added prior to the end of the first refueling outage.
The subject tank Is not safety-related. is not required for safe shutdown, and a fire in the area will not affect safe shutdown of either unit.
An automatic suppression system is provided.
Existing vents are provided.
The subject tank is not safety-related, is not required for safe shutdown, and a fire in the area will not affect safe shutdown of either unit.
Existing vents are provided.
The existing tank design will not change.
The existing tank design will not change.
3-38
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38-1981 2-4.2 30-1981 2-2.5 I
I I
COMMENTS
AMENDMENT 20 DECEMBER 2002 TABLE 3-1 (Cont'd)
RECOMMENDATION FIEe ZONES EE& REFERNCE-$
lME NFPA 30. 1981 Edition - Flamable Liautds Code (Cont'd)
RE;OU*1iN.YT"I, COMMENT RESOLUTION THIS PAGE IS INTENTIONALLY LEFT BLANK I
3-39
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BYRON-1
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BYRON-I TABLE 3-1 (Cont'd)
RECOMMENDATION NUMBER-FIE BZONES COMMENT fFPA 37. 1979 Edition - Stationary Combustion Engines 9.3-1 9.4-1 EMD's Day Tanks(S) 9.3-1 9.4-1 END's Day Tanks(S) 16.1-1 1e.2-1 (25.ee6-gallon diesel F.O. storage tanks) (S)
The tank should be equipped with (1).a high level alarm.
and (2) a high level shutoff.
The fuel oil circulates to storage tanks to maintain full capacity.
Fuel does not overflow into room.
Shutoff will not be permitted for this equipment since it IS safety-related.
2 The liquid transfer connections beneath the liquid level of the tank should be provided with either (a) A normally closed remotely activated valve. (b) an automatic closing heat activated valve, or (c) another approved device to provide for quick cut-off of flow In the event of fire in the vicinity of the tank.
3 The liquid transfer connections beneath the liquid level of the tank should be provided with either (a) a normally closed remotely activated valve or (b) an automatic losing heat activated valve or (c) another approved device to provide for quick cut-off of flow in the event of fire in the vicinity of the tank.
Shutoff will not be permitted for this equipment since it Is safety-related.
3-40 AMENDMENT 20 DECEMBER 2092 37-1979 S-4.1 S-4.2 37-1979 5-S.3 36-1981 2-4.4.3 37-1979 5-5.3 3e-1981 2-4.4.3 NfFPA REFERENCE I
(
BYRON-1 AMENDMENT 20 DECEMBER 2002 TABLE 3-1 (Cont'd)
RECOMMENOATION NUMBER NFPA REFERENCE NFPA SeA. 1984 Edition - Gaseous Hydrofen Systems 18.18-0 and all interior zones in which the piping crosses (NS areas) 5eA-1984 2-6.1 SOA-1984 2-4.1 4
All piping, tubing, and fittings shall be tested and proven gas-tight at maximum operating pressure.
5 All valves, gauges, and other accessories shall be proven suitable for hydrogen services.
MMdPC will review station documentation and resolve prior to S%
power.
N&MPC will review vendor documentation and resolve prior to 5%
power.
3-43
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FIRE ZONES I
BYRON-1 AMENDMENT 20 DECEMBER 2082 TABLE 3-1 (Cont'd)
RECOMMENDATION NUM1ER FIRE ZONES NFPA 72D.
1979 Edition - Proprietary Protective SilnattLn Systems 720-7S-1232(b)/
1234 72D-79-2-4.3 72D-75-1254 72D-79-4-7.3 72D-75-2622 72D-79-2-2.2 Test gate valve supervising switches semiannually and perform drain test.
3 Upon receipt of trouble signals. the control room operator shall notify the authority having jurisdiction where interruption of normal service will exist for more than four hours and provide written notice to the authority having jurisdiction when equipment has been out of service for eight hours.
4 All devices. combinations of devices and equipment constructed shall be approved/listed for the purposes Intended.
(This pertains to the Alison Control Panels).
Documentation could not be found substantiating the listing or approval of the Alison Panels.
Note:
P.O.
4280*356 and Specification F2854 specified U.L. listed or FM approval.
Switches will be periodically tested annually.
Drain tests will be conducted.
The annual testing period is considered adequate.
The procedure has been written and approved.
The authority having jurisdiction is not notified when detection equipment Is out of service for an extended period.
Rather. the limiting conditions for operation are specified in the Technical Requirements Manual.
Section 3.10.a.
Additional fire protection measures are specified for such cases.
This Is considered to be adequate.
All panels are equivalent to F.M.
approved.
M&M to document Justification prior to 5% power.
3-44 I
I COMMENTS NFPA REFERENCE
(
BYRON-1 AIENDMENT 20 DECEMBER 2e62 TABLE 3-1 (Cont'd)
RECOMMENDATION NUMBER HFPA REFERENCE 6
Automatic fire detectors which have integral trouble contacts shall be wired on the initiating device circuit so that a trouble condition on one detector will not impair the alarm operation from other initiating devices.
7 Automatic sprinkler system signals:shall indicate distinctively the particular function (valve position.
grounds. opens, etc.).
a when central station primary power is provided from a commercial light and power source and engine-driven generator. storage batteries having the capacity to operate the system under maximum load for four hours shall be provided.
Bus 132 (ESF Bus) Is the primary power supply to the proprietary alarm systems.
Bus 134 is the secondary power supply.
An impairment In Bus 142 could impair all sources of power to Bus 132.
Upon receipt of a trouble atarm, an operator Is dispatched to the area and a fire watch may be initiated until trouble Is cleared.
This Is considered to be acceptable.
Upon receipt of a trouble alarm, an operator is dispatched to the area and a tire watch may be initiated until trouble is cleared.
This is considered to be acceptable.
Bus 142 is a safety related ESF power source.
it Is normally fed from the system auxiliary transformer, but is also has a diesel generator backup in case of a loss-of-offsite power.
In addition, a manual crosstie to Unit 2 Bus 242 is provided.
This supply is as reli able as was intended by the NFPA code. and is 3-45 (j
NPpA 72D. 1979 Edition - Proprietary Protective SIenaIttn Systems (Cont'd) 72D-79-3-5.12 720-79-3-6.2.2 720-75-2223 720-79-2-6.2.3 I
(i BYRON-1 TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE ZONES NFPA ERE NUMBER RECOMMENDATI NFPA 72D. 1979 Edition-- Proorietary Protective Signaling Systems (Cont'd) 72D-75-2224 72D-79-2-6.24 72D-75-2461 9
A separate power supply.
Independent of the main power supply, shall be provided for the operation of trouble signals (may use the secondary power supply).
11 Provide distinctive trouble and alarm signals in the control room for Units No. I and No.
2.
Trouble signals are fed from the primary source.
Signals used for Unit 1 and No. 2 are distinctive from other plant signals but not from the Unit No.
I and Unit No. 1 control panels.
considered to be accept able as Is.
Due to the high reliability of the primary power supply, as mentioned above, this is considered to be acceptable.
The Unit 1 and Unit 2 fire alarm panels are located not adjacent to one another in the control room.
It will be obvious to an operator responding to a fire alarm which unit Is affected.
The existing design is considered to be acceptable.
3-46
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AMENDMENT 28 DECEMBER 2002 I
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BYRON-1 A
ADEMDBENT 26 DECEtIBER 2962 TABLE 3-1 (Cont'd)
RECOMMENDATION MMER "NFpA 72E. 1982 Edition-Fire Detectors 72E-1982-8-3.3 72E-1982-8-3.2.2 Test smoke detectors semiannually.
Test a restorable heat detector on each circuit semiannually.
After S years.
all must be tested.
Justification for this deviation is documented in PSO FP transmittal 92-113.
Justification for this deviation is documented in PSD FP transmittal 92-113.
Smoke detectors are tested every 18 months.
All restorable heat detectors are tested every 18 months.
3-47 All All I
RESOLUTION COMENTmS
C TABLE 3-1 (Cont'd)
RECOMMENDATION NUMfBER RESOLUTION NFPA 86. 1981 Edttton Fire Doors (Cont'd) 6 The clearance between the bottom of the door and a raised noncombustible sill shall not exceed 318 inch.
Where there is no sill, the maximum clearance between the bottom of the door and floor shall not exceed 3/4 inch.
Reduce clearance.
Remaining thresholds will be installed when Phase 11 security is implemented.
All work required for 5% power has been completed.
8 Holder/release devices shall Security hardware Is be permitted when acceptable necessary for controlled to the authority having areas.
Refer to page jurisdiction.
The devices 2.1-9 of the FPR.
shall be Installed in accordance with the manufacturer's Instructions and only in conformance with the Individual manufacturer's published listings.
3-50 AMENDMENT 20 DECEMBER 2002 FIRE ZONES BYRON-1 509-523 553-554 649-669 726 143-152 155-170 173-326 569 86-1981 2-5.4 86-1981 2-8.5 2-8.8 SD 169-17e SO 171-175 SD 189-181 234 319-348 351-373 381-383 398-4ee 411-41S 420-427 477-489 538-S51 552-648 649-761 729-730 NFPA 89 1281 Edition I
COMMENTS
(
(i BYRON-1 TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE ZONES NFPA REFERENCE NUMBER NFPA 80, 1981 Edition - Fire Doors (Cont'd)
RESOLUTION THIS PAGE IS INTENTIONALLY LEFT BLANK 3-51 AMENODENT 20 DECEMBER 2002
(,
TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE ZONES FPA-REFERENCE NUnMBER NFPA gq. 1981 Edittton - Firg DOMr (Cont'd)
RESOLUTION RECOMMENDATION THIS PAGE IS INTENTIONALLY LEFT BLANK I
3-52 A
AMENDMENT 20 DECEMBER 2902 BYRON -1
Ci K
BYRON-1 TABLE 3-1 (Cont'd)
RECOMMENDATION NUMBER anti Vant4lsttnn bICb*
S*A tBOl UI4*4.
A4. *,neH44*nn4A@
18.1-1 (ESF Div.
elev. 426')
18.2-1 (ESF Div.
11 elev. 426') 18.1-1 (Lower cable sprd. rm. elev.
439')
11.7-1 (Cont.
purge supply elev.
467')
11.7-0 (Cont.
purge exhaust elev. 451')
18.2-1 (Non-ESF supply unit elev.
451') 18.4-1 (Control Rm. NVAC elev.
451')(S) 11.3F-1 and 11.3G-i(S) 11.7-0 (Cont.
purge exhaust duct elev. 475')(S) 5.6-i(S)
"90A-1981-2-4.1.1 9eA-1981-3-3.1 96A-1981-4-3(b) 90A-1981-4-3(a)
I Air filters shall be approved such as Class 1 and Class 2 that will not burn or emit excessive smoke.
2 Duct openings through fire walls shall be protected by an automatic closing 3-hr-rated fire damper.
4 Duct smoke detectors shall be Installed in the return air stream prior to exhausting from the building or being diluted by outside air.
5 Duct smoke detectors shall be installed in the main supply duct downstream of filters.
These filter enclosures contain Class 2 filters with combustible pegboard panels In the frame.
Combustible pegboard should be removed.
(f) Common 3-hr fire wall between safety inl.
pump and charging pump/cooler is violated by common duct system outside the room that does not have fire dampers.
(b)
Couldn't locate detector if any.
Containment purge system may be connected to Aux. Bldg.
exhaust shaft.
(b) 32" x 18" supply duct from Div. 12 Elec.
Equipment Room (zone 5.4-1) to Div. 11 Elec.
Equipment Room (zone 5.6-1)
Temporary condition.
Pegboard was removed by fuel load on systems required to be operable at that time.
Other systems will be completed when required to be operable.
Neither area comprises a 3-hr fire-rated room.
Safe shutdown does not require 3-hr rated separation.
Not necessary to install damper in duct.
S&. review with M&H resulted in cancel lation of change.
Existing design is acceptable.
Adequate area smoke detection has been provided.
This is adequate In lieu of duct detector.
3-S3 AIENDMENT 20 DECEMBER 2002 nrrn~~~~~~
14*.
4n u
m.mm n
m *m~~v m*
I
(.
ANENDNENT 28 DECEMBER 2002 BYRON-1 TABLE 3-1 (Cont'd)
RECOMMENDATION FiPA REELRENE UPPA OAA 1qnl Mdtitnn
- Air Condittoning and Ventilation (Cont'd)
All Zones 8.3-1 (Supply duct for heater drain pump area. elev. 401')
(NS) 8.3-1 (Boiler Room exhaust (72.e cfm elev. 418')
(Ns) 8.5-1 (Air return
- col. F1 (14.e0 cfm) elev.
426')(NS) 5.2-1 (ESF Div. 11 supply) (S) 8.3-1 (Supply for cond. pump area.
elev. 40'11(NS) 18.3 1 (Steam pipe tunnel and safety valve vent, system Area 2 col. 27 elev. 414')(S) 11.6A
- (Lab fume exhaust duct elev. 426')(S) 90A-1981-2-1.4.2 9OA-1981-4-S.1 (9) 72E-19B2-9-1. 1.4 7
Service openings shall be Identified with letters to indicate location of fire protection devices.
9 Detectors shall be installed in accordance with NFPA 72E.
Pertains to aUt dampers and detectors for entire plant.
The pyrotronics model CA-4 is listed for air velocities of 560-3100 FPM.
In reference to the S&L HVAC drawings and actual detector location, the following areas exceed 3190 FPM: should verify actual airflows.
Will identify location of ftire protection equipment prior to performing damper and detector surveillances scheduled for the first refueling outage.
New detectors have been furnished for the VT system.
Additional detectors for the VA system will be provided by. S% power.
3-54 (i
mc A Oa 14al RESOLUTION
(.
TABLE 3-1 (Cont'd)
RECOMMENDATION EA REFE*fRENCE NUMBER RECOMMENDATION NFPA 9eA.
1981 Edition -Air Conditioning and Ventilation (Cont'd) 8.6-0 (Control le Detectors shall be Installed Room office supply in accordance with NFPA 72E.
fans A&B elev.
468')
Generic to all duct smoke detectors(S)
Generic to all HVAC systems(S)
Generic to all detectors 9eA-1981-4-3 (a)&(b)
"9A-1981-4-4 9eA-1981-4-S.1 11 Detectors in the main supply and return air ducts shall automatically stop the fan(s).
12 Smoke dampers shall be installed in systems over IS,1e8 cfm.
13 Detectors shall be Installed in accordance with NFPA 72E.
initial and periodic tests shall be conducted.
(e)
Detectors adjacent to fans.
Sampling tubes should be a minimum of two duct widths from sources of turbulence.
Describe where and what HVAC systems are utilized for smoke control.
Provide documentation for testing sensitivity, in terlocks, alarms, smoke test.
in accordance mfg's Instructions.
Will relocate sample tubes per manufacturer's instructtfons by 5%
power.
S&L to use a design change.
MNIPC will review and approve fan interlock design by 5% power.
"&"PC will review smoke removal plans to verify smoke detectors are not necessary prior to 5%
power.
Functional system testing procedures are adequate.
Agreement reached with NRC.
3-55 BYRON-1 AMENDMENT 20 DECEMBER 20802 FIRE ZONES I
BYRON-1 TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION NFPA 90A 1981 Edition-Air Conditioning and Ventilation (Cont'd)
THIS PAGE IS INTENTIONALLY LEFT BLANK AMENDMENT 20 DECEMBER 2802 COMMENTS RSOLUTION 3-56 I
(
BYRON-1
(
TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE ZONES NFPA REFERENCE NUMBER RECI NFPA 99A. 1981 Edition - Air Conditioning and Ventilation (Cont'd)
IMENDATION COMENTS RESOLUTION THIS PAGE IS INTENTIONALLY LEFT BLANK I
3-S7 AMENDMENT 28 DECEMBER 2002
P4 CD q4 A go L
93 Ul Ui E
- 4.
u
(,.
BYRON-1
(*4 TABLE 3-1 (Cont'd)
RECOMMENDATION FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATIO4 NFPA 99A. 1981 Edition - Air Conditioning and Ventilation (Cont'd)
THIS PAGE IS INTENTIONALLY LEFT BLANK 3-59 AMENDMENT 20 DECEMBER 2002 RESOLUTION I
AMENDMENT 20 DECEMBER 2e02 SECTION NRC POSITION (3)
Responsibility for the overall fire protection program should be assigned to a person who has management control over all organizations involved in fire protection activities.
Formula tion and assurance of program implementation may be delegated to a staff composed of personnel prepared by training and exper ience in fire protection and personnel prepared by training and experience in nuclear plant safety to provide a balanced approach in directing the fire protection program for the nuclear power plant.
The staff should be responsible for:
(a)
Fire protection program 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, suppres sion systems, barriers, dampers, doors, penetration seals, and fire brigade equipment).
(d)
Fire prevention activities (administrative controls and.
training).
IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE Administrative procedures identify the individual delegated the authority for establishing the fire protection program.
The Fire Marshall developed the Fire Protection Administrative Procedure.
He has nuclear plant safety expertise available as part of the operating department.
Using the prefire plans for safety related areas, hazards are defined.
structures and system identified.
The Fire Marshall (as administrator) maintains the plans.
The Shift Manager is responsible for operating safely and can order shutdown if he deems it necessary for safety per Administrative Procedures.
Maintenance and surveillance are handled by the station Operating, Maintenance and Engineering programs and procedures.
Offsite QA (Nuclear Oversight) is a separate organization. Onsite QA (Nuclear Oversight) organization provides review of maintenance, and purchase activities in accordance with the corporate QA Manual.
The Fire Marshall and Training
.Department direct training per Administrative Procedures.
3.1-2 BRAI DWOOD
BRAIDWOOD AMENDMENT 20 DECEMBER 2e02 SECTION NRC POSITION (e)
Fire brigade organization and training.
(f)
Prefire planning.
IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE The Fire Marshall administers the station fire protection program (see 3.1.a(2)).
Prefire plans are written for safety related areas and are controlled by the Fire Marshall.
Preplans were reviewed by a Fire Protection Engineer.
Comply.
- 1. Responsibility for the Fire Protection Program
- a. Initial Design and Construction Phase The fire protection system design for "the EGC plants was developed by the
,1 project consulting engineer using members of his staff who were
, I experienced in nuclear plant design.
Exelon Generation Company is a member of Nuclear Electric Insurance Limited (NEIL) and therefore guidelines for fire protection design were provided in the NEIL Property Loss Prevention Standards for Nuclear Generating Stations.
The building design was done by the consulting engineer.
All design drawings which were pertinent to fire protection were submitted to a fire protection consultant as required by NEIL for their review and comment.
The fire protection consultant was employed by NEIL and was therefore independent of EGC.
The comments on design information made by the fire protection consultant were submitted to EGC for their action.
Exelon Generation Company reviewed the project consultants' design drawings 3.1-3
.1 1 I
BRAIDWOOD AMENDMENT 28 DECEMBER 28e2 IMPLEMENTATION OR JUSTIFICATION. FOR SECTION NRC POSITION NONCOMPLIANCE and the fire protection consultants' comments.
Judgments were made on a cost-benefit basis as to whether or not the fire protection features were to be incorporated into the plant.
Consideration was given to the following plant features when evaluation of fire protection was made:
- a. plant and personnel safety.
- b. credibility of a fire or fire
- hazard,
- c. loss of generation because of fire loss, and
- d. protection of surrounding or adjacent equipment resulting from a fire.
A Project Engineer Who' reported to the Project Engineering Manager coordinated fire protection design features at Braidwood.
"Likewise, a review of design and design changes was performed by a Fire Protection Engineer in the Station Support Services Department and by Independent Fire Protection Engineers working under contract to EGC.
Resumes for the reviewers are in Appendix A5.1.
Surveillance tests were performed by the Project Construction Department and by the Station.
The Fire Protection Engineers were involved in pre-operational and surveillance tests.
3.1-4
BRAIDWOOD AMENDMENT 2e DECEMBER 2602
'IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE
- b. operating Phase Exelon Generation Company has a Fire Marshall and Fire Protection System Engineer at each nuclear plant.
In addition, there are Fire Protection Engineers in the Corporate and/or Site design engineering departments.
- 1. Prooerties and Eouioment -
The Fire Protection Engineers furnish informa tion on underwriting standards, fire insurance rating standards and other information.
When necessary they arrange for procuring advice from 3.1-4a
BRAIDWOOD AMENDMENT 2e DECEMBER 2e02
-IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE outside fire prevention agencies or other outside sources.
When neces sary, arrange and set up meetings to discuss and resolve any questions on current standards or fire protection equipment..
- 2. Fire Insoections -
Site personnel, QA (Nuclear Oversight),
and NEIL perform fire protection inspections of plant facilities.
- 3. Fire Fighting Equipment -The Station Fire Marshall sees that adequate fire fighting equipment is provided and that such equipment is maintained in good operating condition.
- 4. Tests - The Project Startup Group performs preoperational testing of new fire fighting equipment and automatic fire protection systems to ensure that each is in good condition and operat ing satisfactorily. During normal or routine inspections, one or more of the following tests may be made:
- a. alarm tests,
- b. drain tests,
- c. churning of fire pumps,
- d.
inspecting of control valves,
- e. physical testing of fire pumps and yard hydrants.
3.1-5
BRAIDWOOD AMENDMENT 20 DECEMBER 2802 IMPLEMENTATION OR JUSTIFICATION FOR S
SECTION NRC POSITION NONCOMPLIANCE
- f. checking or testing water deluge
- systems,
- g. checking of automatic sprinkler systems, and
- h. testing of standpipes and hoses.
- 5. Contacts - The Station Fire Marshall maintains company contacts with local fire departments.
The Station Fire Marshall and the Fire Protection Engineers maintain contact with fire prevention organizations, insurance companies.
and others on matters relating to fire fighting.
- 6. Reoorting Fires -
Fire reports are issued by the station.
The Fire Marshall reports fires as necessary to the insurance company.
- 7. Training of Personnel - The Station Training Department. Corporate Training Department, and Fire Marshall are responsible for personnel training.
This is done to ensure that individuals trained become familiar with the operation and use of. fire fighting equipment.
- 8. Rules and Standards - The Fire Protection Engineers assist and advise departments concerned with established rules and standards relative to fire prevention and protection as may be necessary.
- 9. Recommendations -
On all recommendations initiated by insurance agencies, fire prevention organizations, and other outside activities or company departments, the Fire Protection Engineers investigate, evaluate, discuss, and review such recommendations, where necessary, before making final recommendations as to specific action to be taken.
3.1-6
BRAIDWOOD SECTION NRC POSITION AMENDMENT 26 DECEMBER 2802 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE le.Desitn Chan e - All design changes are reviewed for impact upon the Fire.
Protection Program per Administrative Procedures.
3.1-6a
BRAIDWOOD SECTION NRC POSITION AMENDMENT-2e DECEMBER 2e82 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE (4)
The organizational responsibili ties and lines of communication pertaining to fire protection should be defined between the various positions through the use of organizational charts and functional descriptions of each position's responsibilities.
The following positions/organi zations should be designated:
(a)
The upper level offsite management position which has management responsibil ity for the formulation, implementation, and assess ment of the effectiveness of the nuclear plant fire protection program.
(b)
The offsite management position(s) directly responsible for formu lating. implementing, and periodically assessing the effectiveness of the fire protection program for the licensee's nuclear power plant including fire drills and training conducted by the fire brigade and plant personnel.
The results of these assessments should be reported to the upper level management position responsible for fire pro tection with recommenda tions for improvements or corrective actions as deemed necessary.
It is our opinion that the intent of the Branch Technical Position is met by the above outlined organizational structure in design, construction-and operation of the EGC nuclear plants.
Administrative procedures define the organizational responsibilities and lines of communication for the Fire Protection Program.
Administrative procedures identify the offsite-delegated individual responsible for the nuclear plant fire protection program.
Assessment of the program is made by:
a)
EGC Fire Protection Engineers b) EGC QA (Nuclear Oversight)
The Site Nuclear Oversight Manager and EGC Fire Protection Engineers have these responsibilities.
3.1-7
BRAIDWOOD SECTION NRC POSITION (c)
The onsite management posi tion responsible for the overall administration of the plant operations and emergency plans which include the fire protection and prevention program and which provide a single point of control and con tact for all contingenctes.
(d)
The onsite position(s)*
which:
- i.
Implements periodic inspections to:
mini mize the amount of combustibles in safety-related areas; determine the effec tiveness of housekeep ing practices; assure the availability and acceptable condition of all fire protection systems/equipment, emergency breathing apparatus. emergency lighting. communica tion equipment, fire stops, penetration seals, and fire retardant coatings; and assures the prompt and effective correc tive actions are taken to correct conditions adverse to fire pro tection and preclude their recurrence.
ii. Is responsible for the fire fighting training for operating plant personnel and the plant's fire brigade; design and selection of equipment; periodic AMENDMENT 28 DECEMBER 2602 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE Administrative Procedures identify the onsite-delegated individual responsible for the overall administration of the plant operations and emergency plans.
Administrative Procedures require the Fire Marshall to conduct periodic plant tours, identify unacceptable conditions and initiate corrective actions.
Administrative Procedures state the Fire Marshall is responsible for implementation and administration of the fire protection program.
Administrative Procedures state the Radiation. Protection department will control and maintain emergency breathing apparatus.
Administrative Procedures state Electrical Maintenance will maintain emergency lighting and communications.
Fire barriers, seals, and doors are inspected per the appropriate operating, maintenance, and engineering surveillance.
Administrative Procedures state the Fire Marshall will investigate fires, evaluate prevention recommendations and make recommendations when needed.
Fire brigade training is a responsi bility of both the Fire Marshall and the training department per Administrative Procedures.
Operating personnel are trained periodically through the Training Department on fire fighting.
I I
3.1-8
BRAIDWOOD SECTION NRC POSITION Inspection and testing of fire protection systems and equipment in accordance with established procedures, and evaluate test results and determine the accept-ability of the systems under test.
iii. Assists in the critique of all fire drills to determine how well the training objectives have been met.
iv.
Reviews and evaluates proposed work activities to identify potential transient fire loads.
- v.
Implements a program for indoctrination of all plant contractor personnel in appropriate administrative AMENDMENT 2e DECEMBER 2ee2 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE The-Operating Manager ensures all operating surveillances are done in accordance to required guides.
The Maintenance, Engineering, and Operating Managers are responsible for station procedures performed by their department.
The Fire Marshall will review the surveillances he deems necessary.
Evaluation of tests and surveillances are specified in test, surveillance
- and administrative procedures.
The Fire Marshall is responsible for.
the purchase of fire brigade equipment.
Critique of all fire drills is a responsibility of the Fire Marshall per Administrative Procedures.
The Fire Marshall will have these responsibilities.
Contractor's training through NGET fulfills this requirement.
They are informed of emergency procedures relative to fire protection.
3.1-9
BRAIDWOOD SECTION NRC POSITION AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE procedures which Implement the fire protection program, and the emergency procedures relative to fire protection.
vi.
Implements a program for instruction of personnel on the proper handling of accidental events such as leaks or spills of flammable materials that are related to fire protection.
(e)
The onsite position respon sible for fire protection quality assurance.
This position should be respon sible for assuring the effective implementation or the fire protection program by planned inspections, scheduled audits, and veri fication that the results of these inspections or audits are promptly re ported to cognizant management personnel.
(f)
The positions which are part of the plant fire brigade:
- i.
The plant fire brigade positions should be responsible for fight ing fires.
The authority and respon sibility of each fire brigade position rela tive to fire The procedure for instruction of personnel on the proper handling of oil spills is identified in Administrative Procedure for the "Control and Cleanup of Oil Spills.n The procedure references corporate general instruction on spill prevention and countermeasu~res.
The Fire Protection Program Admini strative Procedure identifies that Fire Protection Activities are treated as augmented quality per the QA program.
Site/Offsite QA (Nuclear Oversight) Department personnel conduct audits and surveillances to ensure proper implementation and administration of the Fire Protection Program.
The Fire Protection Program Administrative Procedure defines the Fire Chief and Brigade responsibili ties and meets the requirements for authority and duties.
3.1710 I
BRAIDWOOD SECTION NRC POSITION operating a plant fire brigade.
(5)
Personnel Qualifications (a)
The position responsible for formulation and implementa tion of the fire protection program should have within his organization or as a consultant a fire protection engineer who is a graduate of I an engineering curriculum of accepted standing and shall have completed not less than 6 years of engineering attainment indicative of growth in engineering com petency and achievement, 3
years of which shall have been in responsible charge of fire protection engineering work.
These requirements are the eligibility requirements as a Member in the Society of Fire Protection Engineers.
(b)
The fire brigade members' qualifications should include satisfactory completion of a physical examination for performing strenuous acti vity, and of the fire brigade training described in Posi tion C.3.d.
(c)
The personnel responsible for the maintenance and testing of the fire protection systems should be qualified by training and experience for such work..
(d)
The personnel responsible for the training of the fire brigade should be qualified by training and experience for such work.
AMENDMENT 20 DECEMBER 2602 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE Comply.
The position responsible for the fire protection program has the use of a Fire Protection Consultant.
These Consultants meet SFPE member grade requirements.
Exelon Generation, Company also employs Fire Protection Engineers who meet the qualification for member grade in SFPE.
(The EGC Fire Protection Engineer's duties are identified in the Fire Protection Program administrative procedure.)
The fire brigade members have an annual physical which shows them capable of unrestricted activity.
The personnel responsible for maintenance and testing of the fire protection systems receive training scheduled by the training department.
The training of the fire conducted by a qualified EGC Training Department.
certified members of the Marshall's staff monitor training.
brigade is member of the State EGC Fire this 3.1-12 I
BRAIDWOOD SECTION NRC POSITION combustible materials should be removed from the area immediately following unpacking.
Such tran sient combustible material, unless stored in approved con tainers, should not be left unattended during lunch breaks, shift changes, or other similar periods.
Loose combustible packing materials such as wood or paper excelsior, or polyethylene sheeting should be placed in metal containers with tight fitting self-closing metal covers.
- j.
Disarming of fire detection or fire suppression systems should be controlled by a permit system.
Fire watches should be estab lished in areas where systems are so disarmed.
- k.
Successful fire protection requires testing and maintenance of the fire protection equipment and the emergency lighting and communication.
A test plan that lists the individuals and their responsibilities in connection with routine tests and inspec tions of the fire detection and protection systems should be developed.
The test plan should contain the types, frequency, and detailed procedures for testing.
Procedures should also contain instructions on maintaining fire protection during those periods when the fire protection system is impaired or during periods of plant maintenance, e.g., fire AMENDMENT 26 DECEMBER 2062 IMPLEMENTATION OR JUSTIFICATION FOR
-NONCOMPLIANCE Comply.
Disarming of fire detection or fire suppression systems is controlled by administrative procedure.
Compensatory measures are established as required by the governing procedure.
Comply.
The scope of the job classification for maintenance personnel identifies job responsibilities in the area of fire protection.
An administrative procedure for "Fire Protection Impairment," provides instructions in the use of fire protection impairment permit cards in the event a fire protection component is taken out of service.
The surveillance program (Test Plan) contains the types, frequency, and detailed procedures for testing.
3.2-3 I
BRAIDWOOD SECTION NRC POSITION AMENDMENT 2e DECEMBER 2e92 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE in the area selected, allowing for fire develop ment due to the time required to respond, to obtain equipment. and organize for the fire, assuming loss of automatic suppression capability.
iv.
Assessment of brigade leader's direction of the fire fighting effort as to thoroughness, accuracy, and effectiveness.
(8)
Records Individual records of train ing provided to each fire brigade member, including drill critiques, should be maintained for at least 3 years to ensure that each member receives training in all parts of the training.
program.
These records of training should be available for NRC review.
Retraining or broadened training for fire fighting within build ings should be scheduled for all those brigade members whose performance records show deficiencies.
Comply.
Refer to Section 111.1.4 of Appendix A5.7.
(9)
Guidance Documents NFPA 27, "Private Fire Brigade." should be followed in organization, training.
and fire drills.
This stan dard also is applicable for Comply.
Fire training by responsible instructors is done periodically.
See Table 3-1 for delineation of conformance with NFPA 27 and NFPA 197.
3.3-10
AMENDMENT 26 DECEMBER 2e62 3.4 OUALITY ASSURANCE PROGRAM SECTION NRC POSITION IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE The quality assurance (QA) 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 control of the QA organiza tion.
This control consists of (1) formulating a fire protection QA program that incorporates suitable requirements and is acceptable to the management responsible for fire pro tection 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 func tions for meeting the fire protection program requirements may be performed by personnel outside of the QA organi zation.
The QA program for fire protection should be part of the overall plant QA program.
It should satisfy the specific criteria listed "below.
The fire protection systems at Byron/Braidwood Stations Units 1 and 2 are addressed in two different manners under the Quality Assurance Program.
- 1.
Fire protection systems classed as safety-related are covered by the entire Quality Assurance Program which includes the cri teria set forth in Appendix B of 10 CFR 56.
- 2.
Fire protection systems that are classed as non-safety-related and that are awarded after September 1, 1978 are procured and in stalled in accordance with the Branch Technical Position 9.5-1.
Vendors awarded with supplying or installing a fire protection system after September 1, 1978 must have an approved QA Program as required by the Quality Assurance Program and be on the Approved Bidder's List.
However, exceptions may be made for selected non-safety-related systems to allow installation without an approved QA program.
Each installation of this type requires a separate analysis that includes, as a minimum, a regulatory change evaluation; a definable augmented quality class break point, such as an isolation valve; and a hydraulic evaluation for added sprinklers or fire hose stations, as applicable.
The applicable fire and building codes (such as NFPA codes) will be followed and a fire'protection engineer will review the change.
3.4-1 BRAIDWOOD
BRAIDWOOD AMENDMENT 20 DECEMBER 28e2 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Scheduled fire protection inspections.are conducted under the direction of..QA (Nuclear Oversight) with direct participation by a qualified fire protection engineer consultant.
New designs or revisions to plant fire protection systems are reviewed as outlined in the response to Section 3.1.
The Quality Assurance Program applies to procurement, design.
installation, modifications and maintenance activities involving fire protection systems.
As such, each specific criteria listed as "a* through "J* of Section NRC Position are covered by the Quality Assurance Program and by Department and Station Procedures.
Further Implementation 3.4-1a
BRAIDWOOD SECTION NRC POSITION
- a.
Design and Procurement Document Control Measures should be established to ensure that the guidelines of the regulatory position of this guide are included in design and pro curement documents and that devi ations therefrom are controlled.
- b.
Instructions. Procedures.
and Drawlns Inspections, tests, administrative controls, fire drills, and training that govern the fire protection program should be prescribed by documented instructions, pro cedures, or drawings and should be accomplished in accordance with these documents.
- c.
Control of Purchased Material.
Eguioment.
and Services Measures should be established to ensure that purchased material, equipment, and services conform to the procurement documents.
- d.
Inspection A program for Independent inspec tion of activities affecting fire protection should be established and executed by or for the organ ization performing the activity to verify conformance with docu mented installation drawings and test procedures for accomplishing the activities.
- e.
Test and Test Control A test program should be estab lished and Implemented to ensure AMENDMENT 28 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE relating to specific criteria, where deemed appropriate, follow:
- b.
Department and station procedures are established to cover specific instructions such as for inspec tions, tests, administrative con trols, fire drills and training that govern the fire protection program.
- c.
Carbon dioxide (C02) is controlled as a non-safety-related item per Material Engineering Group Evaluation M-94-0585-ee.
- d.
Independent inspections are performed by Quality Assurance (Nuclear Oversight), utilizing fire protection consultants as required.
- e.
Tests of fire protection equipment and systems are included in regularly scheduled station operating surveillance 3.4-2
BRAIDWOOD SECTION NRC POSITION that testing is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements.
The tests should be performed in accordance with written test.procedures; test results should be properly evalu ated and acted on.
- f.
Inspection. Test. and ODerating Status Measures should be established to provide for the identification of items that have satisfactorily passed required tests and inspections.
0_
Nonconforminr Items
.AMENDMENT 20 DECEMBER 2e02 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE procedures.
These procedures and test results are reviewed and evaluated by appropriate station personnel.
QA (Nuclear Oversight) also audits this area.
Measures should be established to control items that do not conform to specified requirements to pre vent inadvertent use or installa tion.
- h.
Corrective Action Measures should be established to ensure that conditions adverse to fire protection, such as fail ures, malfunctions, deficiencies.
deviations, defective components, uncontrolled combustible material and nonconformances, are promptly identified, reported, and corrected.
- i.
Records Records should be prepared and maintained to furnish evidence that the criteria enumerated above are being met for activities affecting the fire protection program.
- h.
Tests of fire protection equip ment and systems are included in regularly scheduled operating surveillance procedures.
Noncon forming equipment is identified as a result of their test and corrective action taken to rec tify any deficiencies as provided by the QA Program.
- i. Documentation involving the fire protection program is retained in a central file or QA vault as provided by the QA Program.
3.4-3 I
Do
BRAIDWOOD SECTION NRC POSITION that automatic hold-open, release, and closing mechanisms and latches are operable.
(See NFPA 80, "Fire Doors and Windows.0)
One of the following measures should be provided to ensure they will protect the opening as required in case of fire:
(a)
Fire doors should be kept closed and electrically supervised at a contin uously manned location; (b)
Fire doors should be locked closed and inspected weekly to verify that the doors are in the closed position; (c)
Fire doors should be provided with automatic hold-open and release mechanisms and inspected daily to verify that doorways are free of obstructions; or (4d)
Fire doors should be kept closed and inspected daily to verify that they are in the closed position.
The fire brigade leader should have ready access to keys for any locked fire doors.
Areas protected by automatic total flooding gas suppression systems should have electrically supervised self-closing fire doors or should satisfy option (a) above.
AMENDMENT 20.
.DECEMBER 26e2 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE All fire doors have automatic closers.
Options a, b, and d are used on various doors in the plant.
Cable spreading room interior doors alarm in the control room.
The other supervised doors are monitored by security.
Required fire doors are inspected per the appropriate operating surveillance.
The brigade chief can obtain a key to access all areas.
The diesel generator day tank rooms and the auxiliary feedwater diesel driven pump and day tank rooms are not electrically supervised, although they are protected.by:automatic total flooding gas suppression systems.
The fire doors to these rooms are sur veilled to ensure they are in their proper position.
3.5-4 I
I
BRAIDWOOD SECTION NRC POSITION (6)
Personnel access routes and escape routes should be provided for each fire area.
Stairwells outside primary containment serving as escape routes, access routes for fire fighting, or access routes to areas contain ing equipment necessary for safe shutdown should be enclosed in masonry or concrete towers with a minimum fire rating of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and self-closing Class B fire doors.
(7)
Fire exit routes should be clearly marked.
(8)
Each cable spreading room should contain only one redundant safety division.
Cable spreading rooms should not be shared between reactors.
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 <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
(9)
Interior wall and structural components, thermal insulation materials, radiation shielding materials, and soundproofing should be noncombustible.
Interior finishes should be noncombustible.
Materials that are acceptable for use as interior finish without evidence of test and listing by a nationally recognized laboratory are the following:
Plaster, acoustic plaster.
gypsum plasterboard (gypsum wallboard), either plain, wallpapered, or painted with oil-or water-base paint; Ceramic tile, ceramic panels; AMENDMENT 26 DECEMBER 2602 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE The stairwells at Braidwood which serve as escape routes for station personnel and access routes for fire fighting personnel, as per the requirements of building codes, are enclosed by 2-hour fire-rated masonry walls with self-closing fire doors, and are clearly marked.
- Comply, see item 6 above.
The Braidwood design complies, except for instances where cables from both safety divisions are routed in the same cable spreading room.
Fire Protection Report Section 2.4.2 describes the measures taken in these areas to assure safe shutdown.
Minor amounts of combustibles are used as architectural finish materials.
These existing materials do not significantly contribute to the fire loading in the plant, and do not expose safety-related systems to undue risks; 3.5-5
BRAIDWOOD AMENDMENT 28 DECEMBER 2B92 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (c)
Enclosure of cable and equipment and associated circuits of one redundant train in a fire barrier having a 1-hour rating.
In addition, fire detectors and an automatic fire suppression system should be installed in the fire area.
(3)
If the guidelines of Positions C5.b.1 and C5.b.2 cannot be met, then alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room, or zone under.
consideration should be provided.
- c.
Alternative or Dedicated Shutdown Capability (1)
Alternative or dedicated Comply.
shutdown capability provided for a specific fire area should be able to achieve and maintain subcritical reactivity condi tions in the reactor, maintain reactor coolant inventory, achieve and maintain hot standby* conditions for a PWR (hot shutdown* for a BWR) and achieve cold shutdown*
conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and maintain cold shutdown conditions thereafter.
During the postfire shutdown, the reactor coolant system process variables shall be maintained within those predicted for a loss of normal ac power, and the fission product boundary integrity shall not be affected; i.e., there shall be no fuel clad damage, rupture, or any
- As defined in the Technical Requirements Manual.
3.5-9
BRAIDWOOD SECTION NRC POSITION
.- may be one unique combination of systems for all such areas.
In either case, the alternative shutdown capability shall be independent of the specific fire area(s) and shall accommodate postfire conditions where offsite power is available and where offsite power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Procedures shall be in effect to implement this capability.
(4)
If the capability to achieve and maintain cold shutdown will not be available because of fire
- damage, the equipment and systems comprising the means to achieve and maintain the hot standby or hot shutdown condition shall be capable of maintaining such conditions until cold shutdown can be achieved.
If such equipment and systems will not be capable of being powered by both onsite and offsite electric power systems because of fire damage, an independent onsite power system shall be provided.
The number of operating shift personnel, exclusive of fire brigade
- members, required to operate such equipment and systems shall be onsite at all times.
(5)
Equipment and systems comprising the means to achieve and main tain cold shutdown conditions should not be damaged by fire; or the fire damage to such equipment and systems should be limited so that the systems can be made operable and cold shut down achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Materials for such repairs shall be readily available on-site and AMENDMENT 26 DECEMBER 2662 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE Comply.
Comply.
A repair procedure has been prepared to cover any repairs required.
All materials and equipment needed to make these repairs will be maintained onsite.
3.5-11 I
BRAIDWOOD SECTION NRC POSITION procedures shall be in effect to implement such repairs.
If such equipment and systems used prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the fire will not be capable of being powered by both onsite and offslte elec tric power systems because of fire damage, an independent onsite power system should be provided.
Equipment and systems used after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be powered by offsite power only.
(6)
Shutdown systems installed to ensure postfire shutdown capability need not be designed to meet seismic Category I criteria, single failure criteria, or other design basis accident criteria, except where required for other reasons.
e.g., because of interface with or impact on existing safety systems, or because of adverse valve actions due to fire damage.
(7)
The safe shutdown equipment and systems for each fire area should be known to be isolated from associated citrcuits in the fire area so that hot shorts, open circuits, or shorts to ground in the associated cir cuits will not prevent operation of the safe shutdown equipment.
The separation and barriers between trays and conduits containing associated circuits of one safe shutdown division and trays and conduits contain ing associated circuits or safe shutdown cables from the redun dant division, or the isolation of these associated circuits from the safe shutdown equip ment. should be such that a AMENDMENT 2e DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE Comply.
Comply.
There are no associated circuits as defined in IEEE 384-1974 at BIB.
Associated circuits as defined in the NRC's April 6, 1982 clarification letter to Generic Letter 81-12 are addressed in Subsection 2.4.1.
3.5-12 I
BRAIDWOOD SECTION NRC POSITION postulated fire involving associated circuits will not prevent safe shutdown.
- d.
Control of Combustibles (1)
Safety-related systems should be isolated or separated from combustible materials.
When this is not possible because of the nature of the safety system or the combustible material, special protection should be provided to prevent a fire from defeating the safety system function.
Such protection may involve a combination of automatic fire suppression. and construction capable of withstanding and containing a fire that consumes all combustibles present.
Examples of such combustible materials that may not be separable from the remainder of its system are:
(a)
Emergency diesel generator fuel oil day tanks.
(b)
Turbine-generator oil and hydraulic control fluid systems.
(c)
Reactor coolant pump lube oil system.
(2)
Bulk gas storage (either compressed or cryogenic),
should not be permitted inside struc tures housing safety-related equipment.
Storage of flammable gas such as hydrogen should be located outdoors or in separate AMENDMENT 20 DECEMBER 2e02 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE Comply.
The emergency diesel generator fuel oil day tanks are provided with automatic fire suppression.
The turbine-generator oil and hydraulic control fluid system are contained in the Turbine Building and thus separated from all safety-related areas.
Fire Protection of the reactor coolant pump lube oil system is described in A5.7 Section III.e and 3.7.a(1)(e).
See Table 3-1 for delineation of conformance with NFPA 58A.
3.5-13 I
BRAIDWOOD SECTION NRC POSITION detached buildings so that a fire or explosion will not adversely affect any safety related systems or equipment.
(Refer to NFPA 50A, NGaseous Hydrogen Systems.")
Care should be taken to locate high-pressure gas storage containers with the long axis parallel to building walls.
This will minimize the possi bility of wall penetration in the event of a container failure.
Use of compressed gases (especially flammable and fuel gases) inside buildings should be controlled.
(Refer to
.NFPA 6, "Industrial Fire Loss Prevention.")
(3)
The use of plastic materials should be minimized.
In particular, halogenated plastics such as polyvinyl chloride (PVC) and neoprene should be used only when substitute noncombustible materials are not available.
All plastic materials, including flame and fire retardant materials, will burn with an intensity and BTU production in a range similar to that of ordinary hydrocarbons.
When burning, they produce heavy smoke that obscures visibility and can plug air filters, especially charcoal and HEPA.
The halogenated plastics also release free chlorine and hydrogen chloride when burning which are toxic to humans and corrosive to equipment.
(4)
Storage of flammable liquids should, as a minimum, comply with the requirements of NFPA AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE Comply.
The use of plastic material is minimized.
The use of PVC and neoprene has been severely restricted.
See Table 3-1 for delineation of conformance with NFPA 3e.
3.5-14 I
BRAIDWOOD SECTION NRC POSITION plenums for ventilation of the control room.
Fully enclosed electrical raceways located in such underfloor and ceiling spaces, if over 1 square foot in cross-sectional area, should have automatic fire suppression inside.
Area automatic fire suppression should be provided for underfloor and ceiling spaces if used for cable runs unless all cable is run in 4 inch or smaller steel conduit or the cables are in fully enclosed raceways internally protected by automatic fire suppression.
There should be no carpeting in the control room.
- c.
Cable Soreading Room The primary fire suppression in the cable spreading room should be an automatic water system such-as closed-head sprinklers, open-head deluge system. or open directional water spray system.
Deluge and open spray systems should have provisions for manual operation at a remote station; however, there should be provisions to preclude inadvertent operation.
Location of sprinkler heads or spray nozzles should consider cable tray arrangements and possible transient combustibles to ensure adequate water coverage for areas that could present exposure hazards to the cable system.
Cables should be designed to allow wetting down with water supplied by the fire suppression system without electrical faulting.
AMENDMENT 20 DECEMBER 2e02 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE There are-no electrical cable trays located under floor and ceiling spaces.
Currently, this is also true for the raised floor in the process
.computer room, which is part of the control room complex.
There are some conduits above dropped ceiling.
Upper cable spreading room has automatic halon and lower cable spreading room has automatic C02.
Upper cable spreading room has manual C02 as a backup.
Carpeting in the main control room has a flame spread of 25 or less.
Comply, except as explained below:
The Byron/Braidwood design Includes several cable spreading rooms at elevation 439'-6" and 463'-4-1/2" The rooms are designed such that redundant safe shutdown cabling is routed through separate rooms (except as noted in Section 2.4.2) and isolated by 3-hour fire barriers.
The upper cable spreading rooms are protected by an automatic Halon 1301 system with a manual C02 backup system.
Manual hose stations and portable extinguishers provide additional backup.
The lower cable spreading areas are protected by an automatic C02 system.
Backup is provided by manual hose stations and portable extinguishers.
Conformance of the halon and C02 systems as installed at Braidwood to the requirements of the governing codes, NFPA 12 and NFPA 12A, will be evaluated.
3.7-8 I
BRAIDWOOD SECTION NRC POSITION Open-head deluge and open directional spray system should be zoned.
The use of foam is acceptable.
Cable spreading rooms should have:
(1)
At least two remote and separate entrances for access by fire brigade personnel:
(2)
An aisle separation betweet tray stacks at least 3 fee, wide and 8 feet high:
(3)
Hose stations and portable extinguishers installed immediately outside the room; (4)
Area smoke detection; and (5)
Continuous line-type heat detectors for cable trays inside the cable spreading room.
Drains to remove fire fighting water should be provided.. When gas systems are installed, drains should have adequate seals or the gas extinguishing systems should be sized to compensate for losses through the drains.
A separate cable spreading roon should be provided for each redundan division.
Cable spreading rooms shouldnot be shared between reactor Each cable sprgading room should.be separated from the others and. from other areas of the plant by barriers with a minimum fire AMENDMENT 20 DECEMBER 2082 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE Cable spreading rooms 3.3B-1 and 3.3B 2 have only one access door.
The BTP position is that an automatic water suppression system should be installed in the cable spreading rooms.
The Braidwood system provides adequate fire protection in the cable spreading rooms without an automatic water system.
Hose stations are available for use in the cable spreading rooms if required.
An automatic water suppression system was not installed in the cable rooms because of concerns about the probability and effects of inadvertent actuations.
The thermal elements in the Fenwal rate compensated heat detectors are very similar to the thermal elements in the automatic water suppression systems.
Since a cable fire would generate large quantities of smoke In a very early stage of a fire, the ionization detectors would be ver.y effective in detecting small cable. fires and.
annunciating in the control room.
If the fire was of such magnitudqe that the thermal detectors sensed the fire, the automation actuation of the fire suppression system would then be initiated.
The detector circuits are designed that if either of the redundant detection zones failed, the remaining detection zone could then solely initiate the, automatic, suppression system.
For this application the cross-zoning of rate compensated. heat detectors with ionization detectors would not reduce the responsiveness of a fire detection system compared to a closed-head.
sprinkler system.
A deluge system.
which Indiscriminately sprays a large area will result in a significant effort to restore the cable spreading room to normal conditions and could 3.7-9 a
I
BRAIDWOOD
- SECTION NRC POSITION
- d.
Plant Computer Rooms Computer rooms for computers performing safety-related functions that are not part-of the control room complex should be separated from other areas of the plant by barriers having a minimum fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and should be pro tected by automatic detection and fixed automatic suppression.
Computers that are part of the control room complex but not in the control room should be sepa rated and protected as described in Position C.7.b.
Computer cabinets located in the control room should be protected as other control room equipment and cable runs therein.
Non-safety related computers outside the control room complex should be separated from safety-related areas by fire barriers with a minimum rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and should be protected as needed to prevent fire and smoke damage to safety-related equipment.
AMENDMENT 20 DECEMBER. 2602 IMPLEMENTATION OR JUSTIFICATION FOR NONCOMPLIANCE of a plant shutdown or equipment damage in. the event of a spurious actuation.
Additionally, the area is well supplied with manual hose stations and portable fire extinguishers.
The process computer at Braidwood is non-safety-related and is part of the control room complex.
Automatic fixed suppression is not provided.
Fire protection features which are provided are described in Subsection 2.3.4 of this report.
- e.
Switchgear Rooms Swltchgear rooms containing safety-related equipment should be separated from the remainder of the plant by barriers with a minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
Redundant switchgear safety divisions should.be separated from each other by barriers with a 3-hour fire rating; Automatic fire detectors should alarm and annunciate in the control room Comply, except alarms do not annunciate locally.
3.7-11 I
(
TABLE 3-1
-PRAiC OOD UNT E1 NFPA CODE DEVATTON REOR NFPA 10 9
1984. "Standard for Portable Fire Extinguishers" IENPA REFERENCE 1
NFPA 10. para. 4-4.3. Each extinguisher shall have a tag or label securely attached that Indicates the month and year the maintenance was performed and shall identify the person performing the service.
2 NFPA 18. para. 4.3.1, Fire extinguishers shall be inspected when Initially placed In service and there after at approximately 30-day Intervals.
NFPA 18. para. 4.4.1. Extinguishers shall be subjected to maintenance not more than a year apart.
DEVIATION
-Permanently mounted fire extinguishers located in the Containment Building do not have tags or labels securely attached.
Portable hand held extinguishers are inspected at approximately a 90-day frequency based on historical review of failure rate.
"Hand portable extinguishers inside containment during at power conditions are inspected during planned refuel outages.
Compliance will be met for all hand portable extinguishers except for those located inside containment during at power conditions.
These extinguishers are subjected to maintenance during planned refuel, outages.
COMMENTSIRESOLUTTON Completed surveillance procedure records that contain this information are maintained.
This practice is considered equivalent.
Paper tags are not provided in the Containment Building due to sump blockage concerns.
Historical review indicates a failure rate of <1%.
Administrative procedure allows extension of interval for inspection if failure rate Is <1%.
During at power conditions, access to containment is controlled administratively to prevent unauthorized Entry.
The risk that fire extinguishers located in containment will be tampered with Is very small.
Inspections and maintenance or replacement of fire extinguishers in containment is performed during planned refuel outages.
During at power conditions, access to containment is controlled administratively to prevent unauthorized Entry.
The risk that fire extinguishers located in containment will be tampered with' is very small. Maintenance or replacement of fire extinguishers in containment is performed during planned refuel outages.
3-3
(
AMENDMENT 20 DECEMBER 2002 BRAIDWOOD-1
BRAIDWOOD-1 TABLE 3-1 AMENDMENT 20 DECEMBER 2992 NFPA 18 -
1984. 'Standard for Portable Fire Extinguishers' NFPA REFERENCE NFPA le. para. 4-3.1. Extinguishers shall be inspected monthly, or at more frequent intervals when circumstances require.
"NFPA 10. para. 4-3.1. Extinguishers shall be inspected monthly, or at more frequent intervals when circumstances require.
NFPA 18. para. 4-3.1. Extinguishers shall be inspected monthly, or at more frequent intervals when circumstances require.
DEVIATION Wheeled portable extinguishers are Inspected at quarterly frequency based on historical review of failure rate.
C02 portable extinguishers are Inspected at annual frequency based ort historical review of failure rate.
AFFF Wheeled portable extinguishers are Inspected at annual frequency based on historical review of failure rate.
COMMEHTS/RESOLUTION Historical review Indicates a failure rate of 4 1%.
Administrative procedure allows extension of frequency interval for inspection if the failure rate is -
1%.
Historical review Indicates a failure rate of < 1%.
Administrative procedure allows extension of frequency interval for inspection If the failure rate is < 1%.
Historical review indicates a failure rate of < 1%.
Administrative procedure allows extension of frequency interval for inspection if the failure rate is 4 I1.
3-3a 4
5 6
(
Table 3-1 (Cont'd)
NFPA 13A - 1981. Inspection. Testing and Maintenance of Sprinkler Systems ITEM NFPA REFERENCE HFPA 13A. para. 2-7.1.4. All control valves of the sprinkler system should be inspected at regular intervals Seated valves -weekly Locked valves and valves with tamper switches - monthly NFPA 13A. para. 2-7.1.4. All control valves of the sprinkler system should be inspected at regular intervals Sealed valves -weekly Locked valves and valves with tamper switches - monthly MFPA 13A. para. 4-7.1. Test alarms quarterly by opening the inspector's test connections.
HFPA 13A, para. 4-5.3. Water flow alarm devices should be tested at least quarterly, weather permitting.
HFPA 13A, para. 2-6.1. Main drain valves water flow tests should be made quarterly from water supply test pipes.
DEVIATION The sprinkler system alarm shutoff valves position verification is performed at quarterly frequency based on historical review of failure rate.
The automatic deluge system trim valves position verification is performed at quarterly frequency based on historical review of failure rate.
The automatic deluge (Turbine Bearing) system alarm test is performed at semiannual frequency based on historical review of failure rate.
The automatic deluge (Turbine Bearing) system alarm test is performed at semiannual frequency based on historical review of failure rate.
The automatic deluge system main drain tests are performed at semiannual frequency based on historical review of failure rate.
3-9a AMENDMENT 20 DECEMBER 2002 COMMENTS/RESOLUTION Historical review indicates a failure rate of 4 1%.
Administrative procedure allows extension of frequency interval for inspection if the failure rate Is c 1%.
Historical review Indicates a failure rate of < 1%.
Administrative procedure allows extension of frequency interval for inspection if the failure rate is < 1%.
Historical review indicates a failure rate of 4 1%.
Administrative procedure allows extension of frequency interval for Inspection if the failure rate Is < 1%.
Historical review indicates a failure rate of 4 1%.
Administrative procedure allows extension of frequency interval for inspection if the failure rate is < 1%.
Historical review indicates a failure rate of < 1%.
Administrative procedure allows extension of frequency Interval for inspection if the failure rate Is < 1%.
BRAIDWOOD-1
BRAIDWOOD-1 Table 3-1 (Cont'd)
NFPA 14 - 1983, 'Standard for the Installation of Standpipe and Hose Systems" AMENDMENT 28 DECEMBER 2002 ITEM MFPA REFERENCE NFPA 14, para. 5-2.3 At least one water supply shall be automatic and capable of supplying the stream first operated until secondary sources can be brought into action.
NFPA 14. para. 3-3.1 Standpipes shall be located in fire rated stair enclosures.
NFPA 14. para. 7-6.1.1.
Pipe hangers shall be approved.
DEVIATION A water supply is not available at the River Screenhouse.
Standpipes are located throughout the plant.
Pipe hangers in safety-related areas are not listed.
3-11 CONMENTS/RESOLUTION The hose stations at the River Screenhouse have been removed.
The water supply from the Circulating Water Make-up Pumps is insufficient to support the proper operation of the hose stations.
The local fire department provides water suppression capability.
This is considered acceptable.
16 order to provide adequate distribution of hose stations throughout the facility. It is not possible to enclose the entire standpipe system.
Sectionalizing valves are provided to isolate a minimum number of hose stations if necessary.
This design Is considered acceptable.
In containment. Auxiliary Building and Fuel Handling the piping supports are seismically designed by Sargent & Lundy in accordance with ANSI B31.1.
Therefore, the hanger design is considered acceptable.
(
BRAIVDOOD-1 Table 3-1 (Cont'd)
NFPA 26 -
1983. *Supervision of Valves Controllin$ Water Supplies for Fire Protection*
ITEM 1
2 3
4 NFPA REFERENCE NFPA 26. para. 3-1. The locked open valves should be inspected monthly.
NFPA 26. para. 3-1. A systematic weekly inspection (or monthly in the case of locked - open valves) of each valve should be made.
NFPA 26. para. 3-1. A systematic weekly Inspection (or monthly In the case of locked - open valves) of each valve should be made.
NFPA 26. para. 3-1, A systematic weekly inspection (or monthly in the case of locked - open valves) of each valve should be made.
DEVIATION Locked open valves are inspected every 92 days.
The outdoor foam system valves position verification Is performed at quarterly frequency based on historical review of failure rate.
The sprinkler system alarm shutoff valves position verification Is performed at quarterly frequency based on historical review of failure rate.
The automatic deluge system trim valves position verification is performed at quarterly frequency based on historical review of failure rate.
3-22a
(
AIENDMENT 20 DECEMBER 2002 COmMENTS/RESOLUTTON Locked open valves are Inspected every 92 days to verity the valve is in the correct position.
Historical review Indicates a failure rate of a
1%.
Administrative procedure allows.
extension of frequency interval for Inspection if the failure rate is <
Historical review indicates a failure rate of < 1%.
Administrative procedure allows extension of frequency interval for inspection if the failure rate is 4 Historical review Indicates a failure rate of 4 1%.
Administrative procedure allows extension of frequency interval for inspection If the failure-rate is 4 1%.
(
BRAIDWOOD-1 Table 3-1 (Cont'd)
NFPA 27 - 1981. -Recommendations for Organization, Training and Equipment of Private Fire Brigades*
ITEM DEVIATION Classroom training is conducted by training department Instructors.
Training sessions are conducted quarterly.
PCB exposures are not included in training.
COMMENTS/RESOLUTION NFPA REFERENCE NFPA 27. para. 4-2.1, Training should be conducted and supervised, where possible, by a State Certified Fire Service Instructor.
NFPA 27. para. 4-3.
Training sessions should be held at least monthly for one hour or more per shift.
NFPA 27, para. 4-1.4.
The training program should keep up with the problems presented by new fire hazards.
3-23 AMENDMENT 20 DECEMBER 2882 The classroom instructors are qualified for the subject areas presented.
In addition, two state certified Fire Service Instructors are involved in all live fire training and some classroom Instruction.
The training program is considered acceptable.
Training sessions conducted quarterly result in a total of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of training per year for each brigade member..
This level of training is considered as satisfying NFPA.
The module on special hazards will be modified to Include fires involving PCBs prior to exceeding 5%
power.
2 3
I
(.
BRAIDWOOD-1 (J
Table 3-1 (Cont'd)
NFPA 72D -
1979. "Standard for the installation. Maintenance and Use of Proprietary Protective Signaling Systems" 4ITEM 1
2 3
4 MFPA REFERENCE NFPA 72D, para. 2-2.2.1(C).
Equipment shall be so designed that It shall be capable of performing Its Intended function at a relative humidity of 85 t S%
and an ambient temperature of "96 *.4 'F for a duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
NFPA 72D, para. 2-2.3.
Satisfactory acceptance tests shall be conducted.
All functions of the systems shall be tested including operation of the system in various alarm and trouble modes for which it is designed (e.g..
open circuit, grounded circuit.
power outage, etc.).
NFPA 72D. para. 2-4.3(b).
Every two months or more frequently. test shall be performed for all circuit interfaces and water flow acutuated devices.
NFPA 72D. para. 2-4.3(c).
Gate valve supervisory switches shall be tested semiannually.
3-28 AMENDMENT 20 DECEMOER 2962 DFVIATTON Equipment is designed for a 7e%
relative humidity (fire protection panels).
Acceptance are tests not complete.
The automatic deluge system alarm tests are performed at semiannual frequency based on historical review of failure rate.
Gate valve supervisory switches are tested annually.
COMMENTS/RESOLUTION The environment is controlled by the HVAC system that contains a humidity controller which maintains a setting of 4e% RH +/-_5% RH and heating controls which maintain a temperature setting of 75"F __2*F.
This design is Considered acceptable for the ftire protection panel environment.
Testing to be complete and M&MPC is to review results prior to exceeding 5% power.
HVAC alarms to be complete In conjunction with system completion.
Historical review indicates a failure rate of 4 1%.
Administrative procedure allows extension of frequency interval for inspection if the failure rate Is 4 1%.
Supervised valves are also surveilled monthly.
Therefore, annual alarm tests should be acceptable.