RS-17-082, Redacted Dresden Nuclear Power Station, Units 2 & 3, Amendment 21 to Fire Protection Report, Updated Fire Hazards Analysis, Vol. 1

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Redacted Dresden Nuclear Power Station, Units 2 & 3, Amendment 21 to Fire Protection Report, Updated Fire Hazards Analysis, Vol. 1
ML18079B075
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Site: Dresden  Constellation icon.png
Issue date: 06/21/2017
From:
Exelon Generation Co
To:
Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
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ML17179A528 List:
References
RS-17-082
Download: ML18079B075 (280)
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AMENDMENT 13 JUNE 2001 DRESDEN 2& 3 FIRE PROTECTION REPORTS Volume Index VOLUME 1 - Updated Fire Hazards Analysis VOLUME 2 - Appendix R Conformance (Sections III.G, III.J, and III.L) - Safe Shutdown Report VOLUME 3 - Technical Specifications, Technical Requirements, and Inspection Reports VOLUME 4 - Interim Measures/Exemption Requests VOLUME 5 - Safety Evaluation Reports i

AMENDMENT 13 JUNE 2001 DRESDEN 2& 3 FIRE PROTECTION REPORTS Volume Index VOLUME 1 - UPDATED FIRE HAZARDS ANALYSIS

1. Introduction
2. Fire Protection Program
3. Fire Hazard Analysis Methodology and Assumptions
4. Fire Hazard Analysis
5. Guidelines of Appendix A to APCSB 9.5-1
6. Unit 1 Fire Protection Report ii

AMENDMENT 21 JUNE 2017 DRESDEN 2& 3 FIRE HAZARDS ANALYSIS REPORT August 1985 Amendment 11 (Original Issue) (June 1998)

Amendment 1 Amendment 12 (January 1986) (March 1999)

Amendment 2 Amendment 13 (February 1986) (June 2001)

Amendment 3 Amendment 14 (July 1986) (June 2003)

Amendment 4 Amendment 15 (March 1987) (June 2005)

Amendment 5 Amendment 16 (August 1987) (June 2007)

Amendment 6 Amendment 17 (April 1988) (June 2009)

Amendment 7 Amendment 18 (July 1988) (June 2011)

Amendment 8 Amendment 19 (April 1992) (June 2013)

Amendment 9 Amendment 20 (July 1993) (June 2015)

Amendment 10 Amendment 21 (December 1994) (June 2017) iii

AMENDMENT 17 JUNE 2009 DRESDEN 2& 3 TABLE OF CONTENTS PAGE

1.0 INTRODUCTION

1.1 Purpose 1.1-1 1.2 Background 1.2-1 1.3 Use of Fire Hazards Analysis 1.3-1 1.3.1 Procedures for Fire Protection Safety Analysis In Regard to Future Modifications 1.3-1 1.3.2 Procedures for Future Updates of the Fire Hazards Analysis 1.3-1 1.4 Definitions 1.4-1 2.0 FIRE PROTECTION PROGRAM 2.1 General Concepts for the Fire Protection Program 2.1-1 2.1.1 Defense-In-Depth 2.1-1 2.1.2 Use of Water on Electrical Fires 2.1-1 2.1.3 Applicability of NFPA Codes 2.1-1 2.2 Fire Protection Organization and Responsibilities 2.2-1 2.3 General Guidelines for Plant Fire Protection 2.3-1 2.3.1 Building Design 2.3-1 2.3.1.1 Plant Layout - Separation 2.3-1 2.3.1.2 Barriers 2.3-1 2.3.1.3 Penetration Seals 2.3-1 2.3.1.4 Grouped Electrical Cables 2.3-1 2.3.1.5 Ventilation 2.3-1 2.3.1.6 Emergency Lighting 2.3-2 2.3.1.7 Communications 2.3-2 2.3.1.8 Drainage 2.3-2 2.3.1.9 Polyurethane Seal Installations 2.3-2 2.3.2 Administrative Controls 2.3-3 2.4 Fire Protection Systems and Equipment 2.4-1 2.4.1 Water Supply and Distribution System 2.4-1 2.4.1.1 Water Supply and Pumps 2.4-1 2.4.1.2 Piping, Valves, and Hydrants 2.4-1 2.4.2 Fire Detection and Alarm Systems 2.4-2 2.4.3 Fixed Fire Suppression Systems 2.4-2 2.4.3.1 Water Suppression Systems 2.4-2 2.4.3.2 Halon Suppression Systems 2.4-3 iv

AMENDMENT 17 JUNE 2009 DRESDEN 2& 3 TABLE OF CONTENTS PAGE 2.4.3.3 CO2 Suppression Systems 2.4-3 2.4.4 Manual Fire Suppression Equipment 2.4-4 2.4.4.1 Manual Hose Stations 2.4-4 2.4.4.2 CO2 Hose Reels 2.4-4 2.4.4.3 Portable Extinguishers 2.4-4 2.5 Fire Brigade 2.5-1 2.5.1 Organization 2.5-1 2.5.2 Training 2.5-1 2.5.3 Equipment 2.5-1 2.5.4 Fire Fighting Strategies 2.5-1 3.0 FIRE HAZARDS ANALYSIS METHODOLOGY AND ASSUMPTIONS 3.1 Introduction 3.1-1 3.2 Assumptions and Approach 3.2-1 3.3 Fire Area Identification 3.3-1 3.4 Combustible Loading Calculation 3.4-1 3.5 Suppression Effects Analysis 3.5-1 3.6 Structural Steel Analysis 3.6-1 3.6.1 Introduction 3.6-1 3.6.2 Methodology 3.6-1 3.6.3 Results 3.6-2 3.6.4 References 3.6-3 3.7 Penetrations 3.7-1 3.7.1 Electrical Penetration Seal Evaluation 3.7-1 3.7.2 Mechanical Penetration 3.7-1 3.7.3 Fire Damper Review (NFPA 90A) 3.7-1 3.8 Cabinet Sealing to Prevent Water Intrusion 3.8-1 4.0 FIRE HAZARDS ANALYSIS 4.1 Reactor Building Fire Area RB2-I 4.1-1 4.1.1 Isolation Condenser Area (Fire Zone 1.1.2.5.A) 4.1-1 4.1.2 Isolation Condenser Pipe Chase (Fire Zone 1.1.2.5.B) 4.1-2 4.1.3 Isolation Condenser Pipe Chase (Fire Zone 1.1.2.5.C) 4.1-4 4.1.4 Shutdown Cooling Pump Room (Fire Zone 1.3.2) 4.1-5 4.2 Reactor Building Fire Area RB2-II 4.2-1 4.2.1 Reactor Building Torus Basement (Fire Zone 1.1.2.1) 4.2-1 v

AMENDMENT 17 JUNE 2009 DRESDEN 2& 3 TABLE OF CONTENTS PAGE 4.2.2 Reactor Building - Elevation 517 Feet 6 Inches (Fire Zone 1.1.2.2) 4.2-3 4.2.3 Reactor Building - Elevation 545 Feet 6 Inches (Fire Zone 1.1.2.3) 4.2-5 4.2.4 Reactor Building - Elevation 570 Feet 0 Inches (Fire Zone 1.1.2.4) 4.2-7 4.2.5 Reactor Building - Standby Liquid Control Area (Fire Zone 4.2-9 1.1.2.5.D) 4.2.6 Refuel Floor (Fire Zone 1.1.2.6/1.1.1.6) 4.2-10 4.2.7 LPCI Pump Room - Division II (Fire Zone 11.2.1) 4.2-11 4.2.8 LPCI Pump Room - Division I (Fire Zone 11.2.2) 4.2-13 4.3 Primary Containment - Unit 2 (Fire Zone 1.2.2) 4.3-1 4.4 Reactor Building Fire Area RB3-I 4.4-1 4.4.1 Isolation Condenser Area (Fire Zone 1.1.1.5.A) 4.4-1 4.4.2 Isolation Condenser Pipe Chase (Fire Zone 1.1.1.5.B) 4.4-2 4.4.3 Isolation Condenser Pipe Chase (Fire Zone 1.1.1.5.C) 4.4-4 4.4.4 TIP Room (Fire Zone 1.4.1) 4.4-5 4.5 Reactor Building Fire Area RB3-II 4.5-1 4.5.1 Reactor Building - Torus Basement (Fire Zone 1.1.1.1) 4.5-1 4.5.2 Reactor Building - Elevation 517 Feet 6 Inches (Fire Zone 1.1.1.2) 4.5-3 4.5.3 Reactor Building - Elevation 545 Feet 6 Inches (Fire Zone 1.1.1.3) 4.5-5 4.5.4 Reactor Building - Elevation 570 Feet 0 Inches (Fire Zone 1.1.1.4) 4.5-7 4.5.5 Reactor Building - Standby Liquid Control Area (Fire Zone 1.1.1.5D) 4.5-9 4.5.6 Refuel Floor (Fire Zone 1.1.1.6/1.1.2.6) 4.5-10 4.5.7 Reactor Building - Elevation 517 Feet 6 Inches - Shutdown Cooling 4.5-11 Pump Room (Fire Zone 1.3.1) 4.5.8 LPCI Pump Room - Division II (Fire Zone 11.1.1) 4.5-13 4.5.9 LPCI Pump Room - Division I (Fire Zone 11.1.2) 4.5-14 4.6 Primary Containment - Unit 3 (Fire Zone 1.2.1) 4.6-1 4.7 Reactor Building Fire Area RB-2/3 4.7-1 4.7.1 2/3 Diesel Generator (Fire Zone 9.0.C) 4.7-1 4.7.2 Unit 3 HPCI Pump Room (Fire Zone 11.1.3) 4.7-2 4.7.3 Unit 2 HPCI Pump Room (Fire Zone 11.2.3) 4.7-4 4.8 Eastern Zone Group (Fire Area TB-I) 4.8-1 4.8.1 Turbine Building - Station Battery Rooms Elevation 549 Feet 0 4.8-1 Inches (Fire Zone 7.0.A) 4.8.2 Clean and Dirty Oil Tank Room - Elevation 517 Feet 6 Inches (Fire 4.8-2 Zone 8.1) 4.8.3 Turbine Building - Basement Floor Elevation 469 Feet 6 Inches (Fire 4.8-4 Zone 8.2.1.A) 4.8.4 Turbine Building - Basement Floor Elevation 495 Feet 0 Inches (Fire 4.8-5 Zone 8.2.2.A) vi

AMENDMENT 17 JUNE 2009 DRESDEN 2& 3 TABLE OF CONTENTS PAGE 4.8.5 Turbine Building - Ground Floor Unit 2 - East Side (Fire Zone 4.8-6 8.2.5.A) 4.8.6 Turbine Building - Ground Floor Low Pressure Heater Bay Area (Fire 4.8-8 Zone 8.2.5.B) 4.8.7 Turbine Building - Mezzanine Elevations 534 Feet 0 Inches and 538 4.8-10 Feet 0 Inches (Fire Zone 8.2.6.A) 4.8.8 Turbine Building - Turbine Pipeway/Heater Bays - Mezzanine 4.8-12 Elevation (Fire Zone 8.2.6.B) 4.8.9 Turbine Building - Mezzanine Elevation 549 Feet 0 Inches (Fire Zone 4.8-13 8.2.7) 4.8.10 Unit 2 Diesel Generator Room Elevation 517 Feet 6 Inches (Fire Zone 4.8-14 9.0.A) 4.9 Central Zone Group (Fire Area TB-II) 4.9-1 4.9.1 Turbine Building - Ground Floor Elevation 517 Feet 6 Inches (Fire 4.9-1 Zone 8.2.5.C) 4.9.2 Turbine Building - Mezzanine Elevation Central Area (Fire zone 4.9-3 8.2.6.C) 4.10 Western Zone Group (Fire Area TB-III) 4.10-1 4.10.1 DC Panel Room - Elevation 538 Feet 0 Inches (Fire Zone 6.1) 4.10-1 4.10.2 Turbine Building - Station Battery Room - Elevation 551 Feet 0 4.10-2 Inches (Fire Zone 7.0.B) 4.10.3 Turbine Building - Basement Floor Elevation 469 Feet 6 Inches (Fire 4.10-3 Zone 8.2.1.B) 4.10.4 Turbine Building - Basement Floor Elevation 495 Feet 0 Inches (Fire 4.10-4 Zone 8.2.2.B) 4.10.5 Unit 3 Cable Tunnel (Fire Zone 8.2.4) 4.10-6 4.10.6 Turbine Building - Ground Floor Low Pressure Heater Bay Area (Fire 4.10-7 Zone 8.2.5.D) 4.10.7 Turbine Building - Ground Floor Unit 3 - West Side (Fire Zone 4.10-8 8.2.5.E) 4.10.8 Turbine Building - Turbine Pipeway/Heater Bays Mezzanine 4.10-10 Elevation (Fire Zone 8.2.6.D) 4.10.9 Turbine Building - Mezzanine Elevation 538 Feet 0 Inches (Fire Zone 4.10-12 8.2.6.E) 4.10.10 Unit 3 Diesel Generator Room - Elevation 517 Feet 6 Inches (Fire 4.10-13 Zone 9.0.B) 4.11 Main Turbine Operating Floor (Fire Area TB-IV) 4.11-1 vii

AMENDMENT 18 JUNE 2011 DRESDEN 2& 3 TABLE OF CONTENTS PAGE 4.11.1 Turbine Building - Main Operating Floor Elevation 561 Feet 6 Inches 4.11-1 (Fire Zone 8.2.8.A) 4.11.2 Turbine Building - Vent Floor Elevation 581 Feet 4 Inches (Fire Zone 4.11-2 8.2.8.B) 4.11.3 Turbine Building - Vent Floor Elevation 601 Feet 4 Inches (Fire Zone 4.11-3 8.2.8.C) 4.11.4 North Turbine Room - Vent Floor Elevation 549 Feet 0 Inches (Fire 4.11-5 Zone 8.2.8.D) 4.11.5 Unit 2 Off-Gas Recovery Rooms Elevations 549 Feet 0 Inches, 571 4.11-6 Feet 0 Inches, and 590 Feet 6 Inches (Fire Zone 14.2) 4.11.6 Unit 3 Off-Gas Recovery Rooms Elevations 549 Feet 0 Inches, 571 4.11.7 Feet 0 Inches and 590 Feet 6 Inches (Fire Zone 14.3) 4.12 Control Room and Auxiliary Electric Equipment Room (FIRE AREA 4.12-1 TB-V) 4.12.1 Main Control Room Elevation 534 Feet 0 Inches (Fire Zone 2.0) 4.12-1 4.12.2 Auxiliary Electric Equipment Room Elevation 517 Feet 6 Inches (Fire 4.12-3 Zone 6.2) 4.13 Crib House Fire Area 4.13-1 4.13.1 Crib House elevations 517 Feet 6 Inches 509 Feet 6 Inches and 4.13-1 Basement (Fire Zone 11.3) 4.14 Radwaste Building 4.14-1 4.14.1 Radwaste Collection and Holding Area (Fire Zone 14.1) 4.14-1 4.14.2 Radwaste Solidification Building (Fire Zone 14.5) 4.14-2 4.14.3 Maximum Recycle Radwaste Building Area (Fire Zone 14.6) 4.14-3 4.15 Miscellaneous Outside Structures 4.15-1 4.15.1 Off-Gas Filter Building Area (Fire Area 14.4) 4.15-1 4.15.2 Unit 3 Main Power Transformer (Fire Zone 18.1.1) 4.15-2 4.15.3 Unit 2 Main Power Transformer (Fire Zone 18.1.2) 4.15-3 4.15.4 Unit 3 Auxiliary Transformer (Fire Zone 18.2.1) 4.15-4 4.15.5 Unit 2 Auxiliary Transformer (Fire Zone 18.2.2) 4.15-5 4.15.6 Unit 3 Reserve Auxiliary Transformer (Fire Zone 18.3.1) 4.15-6 4.15.7 Unit 2 Reserve Auxiliary Transformer (Fire Zone 18.3.2) 4.15-7 4.15.8 Auxiliary Boiler House (Fire Zone 18.4) 4.15-8 4.15.9 Unit 1 Plant Structures 4.15-9 4.15.10 Deleted (Fire Zone 18.5) 4.15-9 4.15.11 U2 125 VDC Alternate Battery Room (Fire Zone 18.6) 4.15-10 4.15.12 Isolation Condenser Pumphouse (Fire Zone 18.7.1) 4.15-10 viii

AMENDMENT 17 JUNE 2009 DRESDEN 2& 3 4.15.13 Isolation Condenser Pumphouse (Fire Zone 18.7.2) 4.15-12 5.0 GUIDELINES OF APPENDIX A TO APCSB 9.5-1 5.1-1 5.1 Overall Requirements of Nuclear Plant Protection Program 5.1-1 5.2 Administrative Procedures, Controls and Fire Brigade 5.2-1 5.3 Quality Assurance Program 5.3-1 5.4 General Guidelines for Plant Protection 5.4-1 5.5 Fire Detection and Suppression 5.5-1 5.6 Guidelines for Specific Plant Areas 5.6-1 5.6.1 Primary and Secondary Containment 5.6-1 5.6.2 Control Room 5.6-4 5.6.3 Cable Room 5.6-6 5.6.4 Plant Computer Room 5.6-8 5.6.5 Switchgear Rooms 5.6-9 5.6.6 Remote Safety-Related Panels 5.6-10 5.6.7 Station Battery Room 5.6-11 5.6.8 Turbine Lubrication and Control Oil Storage and Use Areas 5.6-12 5.6.9 Diesel Generator Area 5.6-13 5.6.10 Diesel Fuel Oil Storage Area 5.6-15 5.6.11 Safety-Related Pumps 5.6-16 5.6.12 New Fuel Area 5.6-17 5.6.13 Spent Fuel Pool Area 5.6-18 5.6.14 Radwaste Building 5.6-19 5.6.15 Decontamination Areas 5.6-20 5.6.16 Safety-Related Water Tanks 5.6-20 5.6.17 Cooling Towers 5.6-21 5.6.18 Miscellaneous Areas 5.6-22 5.7 Special Protection Guidelines 5.7-1 6.0 UNIT 1 FIRE PROTECTION REVIEW 6.1-1 6.1 Introduction 6.1-1 6.2 Definitions 6.2-1 ix

AMENDMENT 19 JUNE 2013 DRESDEN 2& 3 TABLE OF CONTENTS PAGE 6.3 References 6.3-1 6.4 Unit 1 Fire Hazards Analysis 6.4-1 6.4.1 Plant Barriers 6.4-1 6.4.2 Fixed Fire Hazards 6.4-1 6.4.3 Transient Combustibles 6.4-2 6.4.4 Fire Protection Features 6.4-2 6.4.5 Control of Ignition Sources 6.4-3 6.4.6 Fire Pre-Plans 6.4-3 6.5 Impact of a Unit 1 Fire on Unit 2/3 Safe Shutdown 6.5-1 6.6 Overall Assessment 6.6-1 x

AMENDMENT 13 JUNE 2001 DRESDEN 2& 3 LIST OF TABLES Number Title 2.1-1 NFPA Codes Reviewed 2.1-2 2.3-1 Fire Zones Containing Polyurethane and/or Polyethylene Filler at the Top of Block Walls 2.3-4 3.3-1 Index of Fire Areas and Zones 3.3-2 3.6-1 Steel Beams Whose Temperature Exceeds 1100°F If Exposed to a Fire 3.6-4 3.6-2 Beams Requiring Fire Protection Following Study of Beam Stress 3.6-9 Interactions with Dead Load at Elevated Temperatures 3.8-1 Cabinet Sealing Summary 3.8-1 xi

AMENDMENT 18 JUNE 2011 DRESDEN 2& 3 LIST OF FIGURES Number Figures 3.3-1 Legend for Fire Barrier Drawings 3.3-2 Reactor Building, Elev. 476`-6" 3.3-3 Reactor Building, Elev. 517`-6" 3.3-4 Reactor Building, Elev. 545`-6" 3.3-5 Reactor Building, Elev. 570`-0" 3.3-6 Reactor Building, Elev. 589`-0" 3.3-7 Reactor Building, Elev. 613`-0" 3.3-8 Control Room and Misc. Turbine Building Floors 3.3-9 Turbine Building, Basement Floor 3.3-10 Turbine Building, Ground Floor, Unit 2 3.3-11 Turbine Building, Ground Floor, Unit 3 3.3-12 Cable Tunnel 3.3-13 Turbine Building, Mezzanine Floor, Unit 2 3.3-14 Turbine Building, Mezzanine Floor, Unit 3 3.3-15 Vent Floors. Elev. 581`-4" and 601`-4" 3.3-16 Turbine Building, Main Floor, Unit 2 3.3-17 Turbine Building, Main Floor, Unit 3 3.3-18 Crib House 3.3-19 Radwaste Building, Elev. 540`-0", 551`-0", 558`-0" and 579`-0" 3.3-20 Radwaste Building, Elev. 517`-6" and 519`-6" 3.3-21 Radwaste Building. Elev 488`-0" and 507`-0" 3.3-22 Off-Gas Recombiner Rooms, Unit 2 3.3-23 Off-Gas Recombiner Rooms, Unit 3 3.3-24 Outdoor Structures, Unit 2 3.3-25 Outdoor Structures, Unit 3 3.3-26 U2 125 VDC Alternate Battery Room 3.3-27 Isolation Condenser Pumphouse 6.4-1 Deleted 6.4-2 Deleted 6.4-3 Deleted 6.4-4 Turbine Building. Ground Floor Plan, Unit 1 6.4-5 Turbine Building, Mezzanine Floor Plan, Unit 1 6.4-6 Turbine Building, Equipment Location Plan Mezzanine Floor, Unit 1 6.4-7 Turbine Building, Equipment Location Plan Ground Floor, Unit 1 6.5-1 Turbine Building, Appendix R Fire Areas and Safe Shutdown Paths, Units 2 and 3 xii

DRESDEN 2&3 AMENDMENT 13 JUNE 2001

1.0 INTRODUCTION

1.1 Purpose The purpose of the updated Fire Hazards Analysis is to provide, in a single document, a description of the approved station fire protection program that can be used to support the station in NRC audits and procedures to ensure that fire protection issues are addressed in safety reviews of future modifications.

The updated Fire Hazards Analysis Report contains:

1. A summary description of the station fire protection program. This portion of the updated fire hazards analysis contains a summary of the results of various aspects of the station fire protection program. The appropriate documents which contain the evaluation of station compliance with its commitments are referenced. These documents are part of the Fire Protection Program Document Package (F.P.P.D.P.).
2. An update of the 1977 fire hazards analysis including the results of the reevaluation against the NRC's Appendix R clarifications. The fire hazards analysis section contains a zone-by-zone description of the fire hazards and fire protection measures both currently in place and those proposed as a result of the reevaluation. The fire barriers required under both Appendix A and Appendix R are identified in this section. References to the appropriate exemption requests and safe shutdown report sections is provided.
3. The updated comparison of the station's fire protection provisions with the guidelines of Appendix A to Branch Technical Position APCSB 9.5-1 is provided in Section 5.0.

Appendix A guidelines are provided for Administrative Procedures, Quality Assurance, and fire protection features for general and specific plant areas.

This report supersedes the document entitled, "Information Relevant to Fire Protection Systems and Programs - Part 3 Dresden Nuclear Power Station, Units 2 & 3," April 1977 (see F.P.P.D.P.

Volumes 1 and 2). All commitments made in the 1977 document have been included in the "NRC Commitment Matrix for Dresden Nuclear Plant" (F.P.P.D.P.).

If there is a conflict between the information contained within this report and that contained in the Exemption Requests (F.P.R. Volume 4), the information in the Exemption Requests takes precedence.

1.1-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 1.2 Background As part of the continuing NRC evaluation following the fire at the Browns Ferry Nuclear Station in March 1975, Commonwealth Edison Company (CECo) has outlined its fire protection program and features at Dresden Power Station in a number of documents submitted to the NRC between 1976 and the present.

The document entitled, "Information Relevant to Fire Protection Systems and Programs - Parts 1-3, April 1977" (F.P.P.D.P. Historical Volume), provided CECo's response to the NRC initial request for a comparison of the fire protection provisions of Dresden Station with the guidelines of Appendix A to BTP APCSB 9.5-1. This was CECo's first Fire Hazards Analysis of Dresden Station and resulted in a number of fire protection modifications.

CECo also responded to NRC guidelines regarding nuclear power plant fire protection programs issued in the following documents:

1. Supplementary Guidance on Information Needed for Fire Protection Evaluation, September 30, 1976,
2. Sample Technical Specifications, May 12, 1977, and
3. Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance, June 14, 1977.

Following the review of these CECo submittals and a plant inspection, the NRC staff docketed a Fire Protection Safety Evaluation Report (FPSER) for Dresden Units 2 and 3 in March 1978 (F.P.P.D.P. Historical Volume.) A staff letter of February 12, 1981, confirmed that all FPSER items were considered closed with the exception of "Safe Shutdown Capability."

Implementation of these guidelines resulted in additional fire protection measures being incorporated to enhance the existing fire protection program and satisfy the NRC defense-in-depth philosophy. Many studies and much discussion were also associated with the subsequent NRC fire protection guidelines and requirements.

The fire protection rule, 10CFR50.48 and Appendix R of 10CFR50, was issued on February 17, 1981. 10CFR50.48(b) states: "Except for the requirements of Sections III.G, III.J. and III.O., the provisions of Appendix R to this part shall not be applicable to nuclear power plants licensed to operate prior to January 1, 1979, to the extent that fire protection features proposed or implemented by the licensee have been accepted by the NRC staff as satisfying the provisions of Appendix A to Branch Technical Position BTP APCSB 9.5-1 reflected in staff fire protection safety evaluation reports issued prior to the effective date of this rule, or to the extent that fire protection features were accepted by the staff in comprehensive fire protection safety evaluation reports issued before Appendix A to Branch Technical Position BTP APCSB 9.5-1 was published in August 1976." At that time, the shutdown analyses and subsequent related correspondence for Dresden Station were well underway and being reviewed by the NRC staff.

1.2-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 CECo continued to provide the NRC staff with all of the necessary information for their review of the station's safe shutdown capability.

Generic Letter 81-12, "Fire Protection Rule," was issued on February 20, 1981. It presented the NRC staff positions on safe shutdown capability and contained a request for information regarding associated circuits. Subsequently, a clarification to Generic Letter 81-12 was issued which reworded the staff's positions and information requests regarding associated circuits. This clarification was transmitted to CECo for the Dresden Station by letter dated April 30, 1982.

On July 1, 1982 CECo submitted the final response and position on Generic Letter 81-12 questions, Safe Shutdown Capability, Associated Circuits, and a listing of the exact shutdown methods and necessary safe shutdown modifications for Dresden Station. Submitted with this enclosure was Dresden Station's "Fire Protection Associated Circuits Analysis and Modifications Report" (F.P.P.D.P. Historical Volume). The cable discrepancy report was revised and resubmitted August 16, 1982, as a supplement to the Modifications Report.

Enclosure E of the August 16, 1982, submittal included the first formal exemption request from the requirements of Appendix R Section III.G.3.b for fixed fire suppression. This request was made for nine fire zones having electrical equipment critical to the power distribution necessary for normal and emergency operation of safety-related equipment for Units 2 and 3 at Dresden. A formal exemption was granted from the requirements of Appendix R Section III.G.3 on February 2, 1983 (F.P.P.D.P. Historical Volume.)

By cover letter dated January 19, 1983 (F.P.P.D.P. Historical Volume), the NRC staff stated that they had completed the review of Dresden Units 2 and 3 alternate shutdown capability which is used to achieve safe shutdown in the event of a fire. This capability was evaluated against the requirements of Sections III.G and III.L of 10CFR50, Appendix R. Based on this review, the NRC staff concluded that Dresden Units 2 and 3 was in compliance with Appendix R Sections III.G.3 and III.L regarding safe shutdown in the event of a fire. A "Safety Evaluation Report (SER)" was written on this Appendix R review. The conclusion of this evaluation states:

"We (the NRC staff) have reviewed the licensee's proposed alternate shutdown capability for certain designated areas in Dresden Units 2 and 3 in accordance with Appendix R criteria. Based on that review, we conclude that the performance goals for accomplishing safe shutdown in the event of a fire i.e., reactivity control, inventory control, decay heat removal, pressure control, process monitoring, and support functions are met by the proposed alternate in these areas.

Therefore, we conclude that the requirements of Appendix R Sections III.G.3 and III.L are satisfied in the areas identified in Section 2.2 of this Safety Evaluation."

On the basis of these conclusions, CECo management was confident that the intent of Appendix R had been satisfied and continued working to implement the identified modifications in accordance with 10CFR50.48 (c) (4).

On October 19, 1983, Generic Letter 83-33, which reemphasized NRC positions on certain requirements of Appendix R, was transmitted to Dresden Units 2 and 3. As a result, CECo 1.2-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 management decided to perform a reevaluation of the previous analysis to verify that misinterpretations did not exist.

1.2-3

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 1.3 Use of Fire Hazards Analysis 1.3.1 Procedures for Fire Protection Safety Analysis in Regard to Future Modifications To insure that future modifications to plant systems do not adversely impact the fire protection program presently in place, a procedure has been developed to facilitate review of proposed design changes. This procedure, entitled "Fire Protection Program Design Change Impact Evaluation," CC-AA-209 includes a checklist which can serve as a means of documenting the review of a design change.

1.3.2 Procedures for Future Updates of the Fire Hazards Analysis The Fire Hazards Analysis report will be updated on a periodic basis.

1.3-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 1.4 Definitions

1. ANSI - American National Standards Institute
2. Automatic - self-acting, operating by its own mechanism, e.g., a change in current strength, pressure, temperature, or mechanical configuration.
3. Cold Shutdown - A plant condition in which the reactor is subcritical and decay heat is removed by the Shutdown Cooling or LPCI Systems. The primary system temperature is reduced to below 212°F and the heat sink is a heat exchanger with a secondary coolant loop.
4. Combustible Liquid - a liquid having a flash point at or above 100°F (37.8°C).

Combustible liquids are subdivided as follows:

- Class II liquids include those having flash points at or above 100°F (37.8°C) and below 140°F (60°C)

- Class IIIA liquids include those having flash points at or above 140°F (60°C) and below 200°F (93.4°C)

- Class IIIB liquids include those having flash points at or above 200°F (93.4°C)

5. Combustible Material - any material which burns or sustains the combustion process.
6. Design Basis Fires - those fires that are considered to cause the worst reasonable case damage assuming minimal manual, automatic, or other fire fighting actions have been initiated.
7. Electrical Conduit - rigid or flexible tubing usually either steel or aluminum in which electrical cables are run.
8. Equivalent Fire Area - a collection of fire zones whose border with other fire areas or equivalent fire areas is 3-hour rated, or equivalent protection is justified in the Exemption Requests (F.P.P.D.P. Volume 3).
9. Equivalent Fire Barriers - those components of construction (walls, floors, and roofs) which are made of rated materials but contain nonrated penetrations (pipe, HVAC, electrical, and/or doorways). Justification has been provided for each of these barriers in the Exemption Requests (F.P.P.D.P. Volume 3).
10. Fire Area - that portion of a building or plant that is separated from other areas by 3-hr rated fire barriers (walls, floors, or roofs) with any openings or penetrations protected with seals or closures having a fire resistive rating equal to that of the barrier.

1.4-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001

11. Fire Barrier - those components of construction (walls, floors, and roofs) that are rated in hours by approving laboratories for resistance to a standard time/temperature curve to prevent the spread of fire. The primary containment boundary, though not tested, is considered a 3-hour fire barrier.
12. Fire Break - a feature of construction which retards fire propagation along the length of cable(s) or prevents spreading of fire to nearby combustibles within a given fire area or fire zone.
13. Fire Brigade - the team of plant personnel assigned to fire fighting and trained in the manual fighting of fires by an established training program.
14. Fire Detectors - a device designed to automatically detect one or more aspects of the presence of fire and initiate an alarm system. Typical fire detectors are classified as follows:

- Heat or thermal detector - a device which detects abnormally high temperature or rate-of-temperature rise.

- Photoelectric detector - a device which detects the visible particles of combustion.

- Ionization detector - a products-of-combustion detector whose actuation mechanism depends upon invisible pyrolysis or combustion products.

For further definitions, see National Fire Protection Association (NFPA) 72E, Automatic Fire Detectors.

15. Fire Door - a tested door assembly constructed and installed for the purpose of preventing the spread of fire through openings in walls, partitions, or other horizontal or vertical construction. (See NFPA 80 for classification and types of fire doors.)
16. Fire Hose Station - a standpipe and hose system consisting of 1-1/2 inch piping, 100%

Dacron single jacket with Neoprene tube, 300-psi test UL-labeled fire hose; nozzle; and hose valve.

17. Fire Load - the amount of combustibles present in a given fire zone expressed in terms of potential heat release (Btu) due to combustion per square foot of fire zone floor in Btu/ft2.

The fire load of a fire zone equals the heat load divided by its floor area.

18. Fire Protection Plan - encompasses the components, procedures, and personnel utilized in carrying out all activities of fire protection and includes such items as fire prevention, detection, administrative procedures, fire brigade organization, inspection and maintenance, equipment surveillance, training, quality assurance and testing.

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DRESDEN 2&3 AMENDMENT 13 JUNE 2001

19. Fire Rating - refers to the endurance period of a fire barrier or structure and defines the period of resistance to a standard fire exposure elapsing before the first critical point in behavior is observed (refer to NFPA 251).
20. Fire Resistive - Properties or designs to resist the effects of any fire to which a material or structure may be expected to be subjected. Fire resistive materials or assemblies of such materials are noncombustible, but noncombustible materials are not necessarily fire resistive.
21. Fire Retardant - materials or structures which are combustible in whole or part but have been subjected to treatments or have surface coverings to prevent or retard ignition or the spread of fire under the conditions for which they are designed.
22. Fire Suppression - refers to capability for control and/or extinguishment of fires (fire fighting). Manual fire suppression activities refer to the use of manually initiated fixed pipe suppression systems, standpipe and hose, CO2 hose reels, or portable extinguishers.

Automatic fire suppression refers to fixed systems such as wet pipe sprinklers, halon, or carbon dioxide.

23. Fire Zones - subdivisions of fire areas defining natural divisions in fire areas for the purpose of discussion.
24. Flammable Liquids - a liquid having a flash point below 100°F and having a vapor pressure not exceeding 40 lb/in.2 absolute at 100°F shall be known as a Class I liquid.

Flammable liquids (Class I) are subdivided as follows:

- Class IA includes those having flash points below 73°F (22.8°C) and having a boiling point below 100°F (37.8°C).

- Class IB includes those having flash points below 73°F (22.8°C) and having a boiling point at or above 100°F (37.8°C).

- Class IC includes those having flash points at or above 73°F (22.8°C) and below 100°F (37.8°C).

25. Flashover - phenomena of a slowly developing fire producing radiant energy at wall and ceiling surfaces. The radiant feedback from those surfaces gradually heats the contents of the fire area, and when all the combustibles in the space have become heated to their ignition temperature, simultaneous ignition occurs as from a pilot ignition source.
26. FM - Factory Mutual Engineering Corporation and Factory Mutual Research Corporation.
27. Hot Shutdown - a plant condition in which the reactor is subcritical and the primary system temperature is sufficient to allow removal of decay heat by steam generation.

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DRESDEN 2&3 AMENDMENT 13 JUNE 2001

28. Hydraulically designed sprinkler system - a fixed water suppression system in which sprinkler spacing and pipe sizing is, within established limits, determined by hydraulic calculations rather than a standard schedule of allowable pipe sizes.
29. Heat Load - the total amount of potential total heat release (Btu) present in a fire zone.
30. Ignition Temperature - minimum temperature to which a substance in air must be heated in order to initiate, or cause, self-sustained combustion independently of the heating or heat element.
31. MOV - motor-operated valve.
32. NFPA - National Fire Protection Association.
33. Noncombustible - materials which will not ignite, burn, support combustion, or release flammable vapors when subjected to fire or heat.
34. Raceway - any channel for holding wires, cables, or busbars which is designed expressly for and used solely for this purpose.
35. RPS - reactor protection system.
36. Safe shutdown related systems and components - minimum systems and components required to shut down the reactor or maintain it in a safe shutdown condition as identified in the Safe Shutdown Report (F.P.P.D.P. Volume 3).
37. Safety Related Systems and Components - systems and components required to shut down the reactor, mitigate the consequences of postulated accidents or maintain the reactor in a safe shutdown condition.
38. Sprinkler system - a fixed system of piping and components from the supply valve to the point at which water discharges from the system to the fire area. The system is normally activated by heat from a fire.

Sprinkler system classification:

- Wet pipe - a system employing automatic closed-head (fusible link operated) sprinklers and/or nozzles attached to a fixed piping system containing water and connected to a water supply so that water discharges immediately from sprinklers individually opened by a fire.

- Preaction system - a system employing automatic closed-head sprinklers and/or nozzles attached to a fixed piping system containing air that may or may not be under pressure, with a separate fire detection system installed in the same areas as the sprinklers. Actuation of the fire detection system opens a valve which permits 1.4-4

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 water to flow into the sprinkler piping system and then to be discharged from any sprinklers or nozzle which may have been opened by the heat from the fire.

- Water spray system - a system employing directional open-head sprinklers and/or nozzles attached to a piping system connected to a water supply through an automatic valve which is opened by the operation of a separate fire detection system installed in the same areas as the sprinklers and/or nozzles. When this valve opens, water flows into the distribution piping system and discharges from all open sprinklers and/or nozzles simultaneously.

39. Standpipe or Manual Hose Stations - a fixed piping system connected to a water supply to provide effective fire hose streams for manual use by the fire brigade within the building.
40. TIP - Traversing incore probe.
41. UL - Underwriters Laboratories Inc.
42. Zone Group - Same as equivalent fire area.

1.4-5

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 2.0 FIRE PROTECTION PROGRAM 2.1 General Concepts for the Fire Protection Program This section covers some of the topics which must be addressed in the overall fire protection plan. The references to specific documents are those contained in the Dresden Station's Fire Protection Program Documentation Package (F.P.P.D.P.).

2.1.1 Defense-in-Depth Dresden Station utilizes the defense-in-depth concept in order to ensure that safe shutdown capability is not impaired by a fire. The defense-in-depth concept achieves the high degree of safety required through the use of the following echelons of safety systems:

o Prevent fire initiation.

o Quickly detect and suppress fires when they have occurred.

o Contain any unmitigated fires that might occur so that safe shutdown is not affected.

2.1.2 Use of Water on Electrical Fires Water spray is an effective extinguishing agent on electrical fires, particularly in grouped electrical cables, since cable insulation and jacketing are ordinary combustibles and water spray is nonconductive. In plant areas where a water type suppression system is employed, measures have been taken to reduce the probability of equipment being damaged from water spray. These measures include providing adequate area drainage, shielding the equipment from the spray, and curbing and/or placing the equipment on pads or pedestals as needed.

Hose stations, where necessary, are equipped with fog nozzles designed for use on electrical type fires (as well as other types of fires). The fire brigade is trained in the use of water for the extinguishment of electrical fires.

2.1.3 Applicability of NFPA Codes National Fire Protection Association (NFPA) codes were used as guidelines in the design of passive fire protection features (e.g., fire doors, dampers, and walls), active fire protection systems (i.e., fire suppression and detection systems), and in the development of administrative controls of fire hazards. Unique situations and configurations arise in power plants that are not explicitly dealt with in NFPA codes. These require departures from NFPA code requirements.

Technical justifications for deviations from significant provisions of the applicable codes have been developed and are available in the NFPA Code Review (see F.P.P.D.P.). A list of the NFPA codes that were reviewed during the reevaluation program is provided in Table 2.1-1.

2.1-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 TABLE 2.1-1 NFPA CODES REVIEWED NFPA Code NFPA Code Evaluation Title*

4 and 4A An Evaluation of Organization for Fire Services and Organization of a Fire Department 6 An Evaluation of Organization of Industrial Fire Loss Prevention 7 An Evaluation of Management Control of Fire Emergencies 8 An Evaluation of Management Responsibility for Effects of Fires on Operations 10 and 10A An Evaluation of Portable Fire Extinguishers 12, 12A, 13, 15, Fire Suppression Survey 16, 20, 24 14 An Evaluation Standard for the Installation of Standpipe and Hose Systems 24 Outside Protection Survey 26 Fire Suppression System Valve Supervision Survey 27 An Evaluation of Organization, Training and Equipment of Private Fire Brigades 30 and 49 An Evaluation of Flammable Combustible and Highly Reactive Chemical Storage and Handling 50A, 50B and 69 A Survey of the Fire Hazards of Hydrogen Storage and Handling 51 and 51B An Evaluation of the Fire Hazards of Cutting and Welding Processes 70 Applicability of NFPA 70 72D and 72E Fire Protection and Alarm Survey 78 Lightning Protection Survey 80 An Evaluation of Fire Doors 90A Fire Protection Survey of HVAC Systems Installed in Computer and Nuclear Safety-Related Areas 92M Floor Drainage Survey 194 and 196 An Evaluation of Screw Threads and Gaskets for Fire Hose Connections and Standard for Fire Hose 197 An Evaluation of a Training Standard on Initial Fire Attack 232 An Evaluation of Records Storage 251 and 255 Applicability of NFPA 251 and NFPA 255 601 An Evaluation of the Security Force Response to Fire Emergencies

  • See F.P.P.D.P. Volume 8 for the specific evaluations.

2.1-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 2.2 Fire Protection Organization and Responsibilities The following paragraphs describe the compliance of Dresden Station with the intent of the positions of Section A.1 of Branch Technical Position APCSB 9.5-1 regarding fire protection organization and responsibilities.

ComEd is responsible for the establishment and execution of the Dresden Nuclear Plant fire protection and loss prevention program. The position having ultimate responsibility for nuclear station fire protection at the corporate level is the President of the Nuclear Generation Group.

Reporting to the President of the Nuclear Generation Group is the Site Vice President who has the responsibility for implementation, maintenance, and assessment of the nuclear power plant fire protection program effectiveness.

The Station Manager in conjunction with the Site Vice President has the responsibility for implementation and overview of the site fire protection and loss prevention program. He is responsible for assuring program compliance with Nuclear Regulatory Commission (NRC) requirements deemed applicable, Technical Specifications, National Fire Protection Association (NFPA) codes, insurance standards, and other applicable guides, standards and regulations.

Engineering aspects of the site program are assigned to the Engineering Department.

Operational aspects of the site program are assigned to the Operations Department. Maintenance aspects of the site program are assigned to the Maintenance Department.

The fire protection and loss prevention program for the Dresden Station was formulated using the guidance of applicable NRC supplemental guides, NFPA codes, American National Standards Institute (ANSI) standards, consultant recommendations, insurance guidelines, and ComEd corporate policies and procedures. Using these as a basis, along with other standards judged applicable, a program tailored to the unique application of fire protection at a nuclear facility was formulated. The program is assessed by Quality & Safety Assessment and through independent annual and triennial fire protection audits. Results of these assessments are reported to the Station Manager and Site Vice President.

Plant fire protection systems were engineered by or under the cognizance of the Engineering Department. The Engineering Department has the responsibility for the design, or review of the design, of new fire protection systems, review of proposed modifications to existing systems, and for review of all modifications for their potential adverse impact on fire protection.

The Operations Department provides support for surveillances and provides personnel for the fire brigade. The Maintenance Department assists in surveillances and maintenance of fire protection systems. The Quality Control Department provides the necessary inspection of work activities, whether it includes the installation of new systems, modifications, or maintenance of existing systems.

2.2-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 2.3 General Guidelines for Plant Fire Protection This section examines the implementation of the guidelines of Appendix A to BTP APCSB 9.5-1 as they apply to building design and administrative controls. These guidelines are addressed again in Chapter 4.0 of this document, on a plant area-by-area basis.

2.3.1 Building Design 2.3.1.1 Plant Layout - Separation The plant has been divided into fire areas for evaluation against 10CFR50, Appendix R criteria.

Redundant safe shutdown related equipment, components and systems are provided with adequate spatial separation or are separated by fire resistive barriers as described in the Safe Shutdown Report (F.P.R. Volume 2).

2.3.1.2 Barriers Walls enclosing separate fire areas utilize fire resistive construction. All penetrations in a fire resistive barrier are protected so that they have an equivalent fire resistance rating or were evaluated to ensure their adequacy to withstand the hazards associated with the area. This includes doors, wall penetrations, and dampers (see Figures 3.3-1 through 3.3-27).

2.3.1.3 Penetration Seals Fire penetration seals provided in fire barriers are documented on the F-drawings (Drawings F-41 through F-196, F-353 and F-457), in penetration details (see F.P.P.D.P.) for the mechanical penetration seals, and in the report entitled "Preliminary Review of Electrical Penetration Seal Fire Testing and Installation Program" and test reports (see F.P.P.D.P.) for the electrical penetrations. These penetrations are inspected periodically. Open flames or combustion generated smoke are not permitted for this inspection. Penetration seal design details assessments are in the report entitled, Penetration Seal Assessment (see F.P.P.D.P.).

2.3.1.4 Grouped Electrical Cables The cabling initially installed at Dresden Station was not qualified per IEEE 383-1974. New cable installations are qualified per IEEE 383. Cable trays are of noncombustible construction and cable trays, raceways, and conduits are used for cabling only.

Miscellaneous storage in areas housing grouped electrical cables is administratively controlled.

Fire breaks are provided at intervals along horizontal and vertical cable trays as needed.

2.3.1.5 Ventilation The plant does not have a fixed smoke removal system except for the Control Room. Portable smoke ejectors have been provided for fire brigade use in removing smoke in areas that do not have fixed smoke removal systems. All smoke produced in potentially contaminated areas is 2.3-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 monitored before it is released to the environment. The fresh air supply intakes to areas containing safety-related equipment are located away from the exhaust air outlets and smoke vents of other areas.

Fire dampers are used in most fire walls and barriers where ventilation ducts penetrate, or equivalent protection is provided. If fire dampers are not provided, justification for not providing them is found in the Exemption Requests (F.P.R. Volume 4).

In areas where total flooding gaseous suppression systems are used, dampers in the ventilation system are closed before agent discharge occurs.

2.3.1.6 Emergency Lighting Emergency lighting is provided to illuminate the areas housing equipment needed for shutdown as well as the pathways which must be taken to reach the necessary equipment. Emergency lighting consists of sealed beam units with 8-hour emergency backup power supplies (see Safe Shutdown Report Section 7.5, F.P.R. Volume 2).

2.3.1.7 Communications The communication systems are described in FPR Volume 2, Section 7.6.

2.3.1.8 Drainage Drains are available to handle expected run-off from fixed water suppression operation and hose streams in many plant areas. In areas where large, fixed water suppression systems are provided, their operation may temporarily exceed the capacity of the drain system.

Most major equipment is pad or pedestal mounted or encircled by curbs to protect it from localized flooding. Suppression effects are described in the Fire Hazards Analysis (Section 4.0) for each fire zone. All water drains in potentially radioactive areas are routed to the appropriate radwaste systems.

2.3.1.9 Polyurethane Seal Installations As a result of the effects of a fire that occurred at Dresden 3 on January 20, 1986 the report entitled "Evaluation For the Effects of the Dresden Unit 3 Polyurethane Fire", dated May 1986, was prepared by CECo. This report concluded that the safe shutdown capability of the plant was not adversely affected by the fire in the expansion gap. The expansion gap is not the only place where polyurethane is used as a filler material. Both polyurethane and polyethylene have been used as a filler material at the top of block walls and polyurethane is used to seal penetrations.

None of the block walls are considered 3-hour rated fire barriers. Those walls/floors that use polyurethane as a penetration seal are not rated barriers. Thus, the polyurethane or polyethylene as a penetration seal are not rated barriers. Thus, the polyurethane or polyethylene cannot provide a path for fire spread from one fire area to another. Table 2.3-1 provides a list of those fire zones 2.3-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 where polyurethane and polyethylene are used as the filler at the top of block walls. The amount of polyurethane used as penetration seals could not be easily determined. However, even if this amounted to two or three times that used at the top of walls, the percent increase in the fire loading for any zone would still be small (See FPPDP, Volume 13, for the complete Polyurethane Fire Report) 2.3.2 Administrative Controls NFPA codes and recommendations, NRC supplemental guides deemed applicable, CECo corporate guidance and procedures, and insurance standards were used as guidance for the development of the Dresden Station fire protection administrative controls. These administrative controls are used to control ignition sources and limit transient fire hazards in order to reduce the probability of a fire exposure to safe shutdown systems and equipment as well as to reduce the likelihood of a fire being initiated in any plant area. Likewise, the impact of plant modifications are assessed in order to ensure that fire protection will not be compromised by those modifications.

Quality Assurance policies and procedures are covered in detail in the CECo QA Manual.

2.3-3

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 TABLE 2.3-1 FIRE ZONES CONTAINING POLYURETHANE AND/OR POLYETHYLENE FILLER AT THE TOP OF BLOCK WALLS Fire Zone Material Quantity (ft.3) 1.1.1.2 Polyurethane 3.4 1.1.2.2 Polyurethane 3.4 1.1.1.3 Polyurethane 10.8 1.1.2.3 Polyurethane 9.8 Polyethylene 4.9 1.1.1.4 Polyurethane 8.6 1.1.2.4 Polyurethane 9.3 Polyethylene 6.7 1.1.1.5.D Polyethylene 3.8 6.2 Polyethylene 4.9 7.0.A Polyethylene 2.3 8.1 Polyethylene 1.8 8.2.6.A Polyethylene 13.7 8.2.7 Polyethylene 6.5 9.0.A Polyurethane 8.2 Polyethylene 1.5 9.0.C Polyethylene 1.5 14.1 Polyethylene 7.0 14.6 Polyurethane 18.7 1.1.2.5.D Polyurethane 2.8 2.3-4

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 2.4 Fire Protection Systems and Equipment 2.4.1 Water Supply and Distribution System 2.4.1.1 Water Supply and Pumps The fire water system is normally supplied by the service water pump through a restricting orifice, which limits flow to 95 gpm.

Two automatically controlled diesel engine fire pumps are provided as emergency backup to maintain the required water flow during manual or automatic water suppression system operation. The pumps take suction from the two service water intake structures. The river water source is sufficient to ensure more than a 2-hour supply for the largest demand. The Unit 2/3 pump is rated to produce 3000 gpm at 165 psi and the Unit 1 pump is rated to produce 2500 gpm at 147 psi. A relief valve is provided to limit the Unit 2/3 output to 3000 gpm at 150 psig because of concerns related to the pressure rating of the fire protection water piping. Guidelines established in National Fire Protection Association (NFPA) 20 were generally followed for fire pump installation. Both pumps are protected by automatic water suppression systems. The pumps are arranged to automatically actuate upon a decrease in system pressure in a predetermined sequence. A small connection to the service water system is provided to maintain system pressure during low flow drawoffs and system leakages.

The operating status of each fire pump is monitored in the main plant Control Room. Periodic tests and inspections of each pump are conducted in accordance with established procedures to assure that the pumps remain operable.

2.4.1.2 Piping, Valves, and Hydrants An underground yard main system with multiple loops capable of delivering the anticipated largest single fire flow, including 500 gpm for hose streams, is provided for the fire protection system. The system is common to Units 1, 2, and 3 and is provided with valves to facilitate the isolation of portions of the system for maintenance or repairs without interrupting the supply to the remaining system. All control valves are sealed, locked, or electrically supervised in their proper position. The main yard loop is dedicated for the exclusive purpose of fire protection.

Guidelines established in NFPA 24 were generally followed for the design and installation of the piping. Piping in the yard main loop is polyurethane lined steel, unlined steel, ductile iron, transite and PVC. Fire protection system piping is not designed as a Seismic Category 1 system.

An inside main loop is provided in each turbine and reactor building. The inside loop supplies all automatic sprinkler systems, water spray systems, standpipe risers, and hose stations. The inside main loop is supplied directly by the underground yard main loop and is independent of other plant water systems.

Fire hydrants are installed on the yard main loop to provide a means for applying effective fire hose lines throughout the plant for use by the fire brigade. Each hydrant outlet is provided with hose threads compatible with those used by the local fire department in the event of the need for 2.4-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2009 outside assistance. The flow from hydrants will cause a pressure drop in the system sufficient to start one or more fire pumps, which will actuate an alarm in the Control Room.

Established procedures are provided for the periodic flushing of the piping system as well as systematic operation of all valves and hydrants.

2.4.2 Fire Detection and Alarm Systems The fire alarm and detection systems, where provided, are designed and installed under the general guidance of NFPA 72D. However, certain specific problem areas encountered in nuclear power plants were not always addressed in NFPA codes. Where such situations occurred, deviations from code provisions were necessary. In all cases, the intent of the NFPA codes were followed (modified, as required, by sound engineering judgment) with major deviations justified and documented in the NFPA Code Review (see F.P.P.D.P.). The number, type, and location of detectors was determined in general in accordance with the recommendations of the manufacturer and the guidelines established in NFPA 72E. All fire alarms and fire detectors in safety related areas provide an audible and visual alarm in the plant control room. The alarms are annunciated on an interactive printer or on annunciator windows connected to the printer.

Each of the detectors has a unique "address". The computer based system scans for trouble and alarms. When any trouble or alarm is detected, an alarm typer prints out the affected device's number, location, date and time of occurrence, which the Center Deck NSO acknowledges. Once per hour, on the hour, the alarm typer prints out the number of devices in alarm or in trouble, and the number of these, which have been acknowledged.

Fire Panel 2223-113 is located in the Computer Room within the Auxiliary Electric Equipment Room, and is powered from the computer UPS with an additional battery backup, as required by the NFPA Codes.

Periodic tests and inspections of each alarm system (including wiring, detectors, alarm panels, etc.) are conducted according to established procedures to assure system operability. All alarm circuits are either electrically supervised or are tested to assure operability.

2.4.3 Fixed Fire Suppression Systems 2.4.3.1 Water Suppression Systems Automatic sprinkler and water spray protection is provided in many areas of the plant with emphasis on protecting equipment and operations involving combustible and flammable liquids as well as specific areas containing safety related systems, equipment, and components. The design and installation of these systems is generally based on guidelines established in NFPA 13 and 15 giving due consideration to maintaining the ability to perform safe plant shutdown functions. However, in specific instances, it is not always possible or practical to comply with the literal provisions of the code. Where code deviations are required or are desirable, they are made 2.4-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 under the intent of the code using sound engineering principles. (See Fire Suppression Systems Hydraulic Verification Study, F.P.P.D.P. Volume 10.)

Water suppression systems consist of wet pipe sprinkler, water spray, and preaction type sprinkler systems. Actuation of sprinkler systems is effected by operation of the thermal element within each head/nozzle. Operation of the preaction sprinkler systems is effected by actuation of an associated heat or smoke detection system in addition to the operation of the individual thermal element in each head/nozzle. Actuation of the open head water spray systems is effected by operation of the associated heat detection system installed in the protected area. Steps have been taken to ensure that inadvertent water discharge from a suppression system will not affect the ability to safely shut down the plant for each fire zone (see Section 4.0).

Each water suppression system in the turbine, reactor, radwaste, and control buildings is supplied by the inside main loops for the turbine and reactor buildings. Each system is provided with an OS&Y gate valve where the system connects to the main loop. Periodic tests and inspections of all valve seals and tamper alarm systems are conducted according to established procedures to assure the operability of the water suppression, control valves, and alarms.

2.4.3.2 Halon Suppression Systems Automatic Halon fire suppression systems are provided in areas of the plant where other forms of suppression could damage valuable equipment or documents (AEER and Computer rooms).

The ability of the plant to safely shut down is not affected by inadvertent operation of these systems (see Section 4.0). Guidelines established in NFPA 12A were used as general guidance in system design and installation. Periodic tests and inspections are conducted in accordance with established procedures.

2.4.3.3 CO2 Suppression Systems Total flooding carbon dioxide (CO2) suppression systems are provided in the AEER, three diesel generator rooms, and diesel day tank rooms. Guidelines established in NFPA 12 were used as general guidance in system design and installation with consideration given to sufficient design concentration and soak time. The system in the AEER is arranged for manual actuation only. The manually operated fixed suppression system has associated automatic detection systems, which notify control room personnel. All other systems are arranged for automatic actuation with manual capability provided as a backup. Automatic actuation is effected by operation of thermal detectors located in the protected area. Each CO2 system is designed with appropriate electrical interlocks arranged to close dampers and/or shut down ventilation systems prior to CO2 discharge. In addition, each system is provided with a predischarge local alarm to allow personnel evacuation prior to system discharge. Periodic tests and inspections are conducted in accordance with established procedures to assure operability of each CO2 system.

2.4-3

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 2.4.4 Manual Fire Suppression Equipment 2.4.4.1 Manual Hose Stations Manually operable, water-supplied hose stations are strategically located throughout the interior of the plant and are located so as to reach any location containing safety-related equipment or systems with an effective hose stream. Each hose station is equipped with 1-1/2-inch fire hose with a 1-1/2-inch nozzle. Electrically safe-type nozzles are provided where electrical equipment and cable concentrations warrant. The basic guidelines established in NFPA 14 were followed in the design and installation of the standpipe system. Hose outlets are provided with hose threads compatible with those used by the local fire department in the event of the need for outside assistance.

Flows from the standpipe system beyond the capacity of the service water connection will result in a system pressure drop which will cause one or more fire pumps to start, activating an alarm in the control room.

Periodic tests and inspections of the standpipe systems are conducted according to established procedures to assure system operability.

2.4.4.2 CO2 Hose Reels Manually operated hose reels employing carbon dioxide (CO2) are strategically located in specific areas of the turbine building for fire brigade use. The hose reels are supplied by one low pressure CO2 storage tank which also supplies CO2 to the total flooding suppression systems described in subsection 2.4.3.3. The periodic tests and inspections of the CO2 storage tank are conducted in accordance with established procedures.

2.4.4.3 Portable Extinguishers Portable fire extinguishers are located throughout all safety-related plant areas. The majority of extinguishers provided are of the CO2 type with dry chemical type extinguishers installed only where appropriate with due consideration given to possible adverse effects on equipment located in the area. Periodic inspections and tests of portable extinguishers are conducted in accordance with established procedures to assure operability.

2.4-4

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 2.5 Fire Brigade 2.5.1 Organization A fire brigade of at least five trained members is maintained on site at all times. Their responsibilities and duties are reviewed and discussed during training sessions and coordination with local fire departments is emphasized during leadership training. Local fire departments are afforded the opportunity for training in the operational precautions during fire emergencies (e.g.,

radiation protection, special hazards at a nuclear power plant).

Local fire departments have agreed to provide support and their response is considered in the overall fire protection program. Plant training is provided for local fire departments.

2.5.2 Training Each member of the fire brigade is required to complete an established amount of classroom instruction and additional hands-on practical training. The training department is responsible for all fire training which covers all basic topics. In addition to the initial training program, all brigade personnel attend retraining classes on a regular basis. Training is established such that brigade members understand their duties and learn to operate as a team. Fire drills are conducted quarterly providing opportunity for fire fighting personnel to become familiar with fire fighting equipment and major areas of the plant. Drills are pre-planned and post-critiqued to establish training objectives and determine how well those objectives have been met.

2.5.3 Equipment The fire brigade is provided with sufficient equipment to perform manual fire suppression operations, as required. Full personnel protective gear, including self-contained breathing apparatus with reserve breathing air, is provided. Fire fighting equipment is located through the plant to facilitate brigade use and response. Portable smoke removal equipment is available for use by the fire brigade, if necessary.

Portable radios are used for primary communications in fire emergencies. The plant fire siren and all fire emergencies are broadcast over the plant-wide loudspeaker system.

2.5.4 Fire Fighting Strategies Pre-fire plans are provided for all safety-related areas of the plant. The plans provide necessary information, including a diagram showing fire equipment location to aid the fire brigade in executing manual fire fighting operations.

2.5-1

DRESDEN 2&3 AMENDMENT 14 JUNE 2003 3.0 FIRE HAZARDS ANALYSIS METHODOLOGY AND ASSUMPTIONS 3.1 Introduction A systematic approach was established for the review of the fire hazards and their exposure to safety-related equipment and components necessary for safe shutdown within the area. The combustible materials, the type of fire hazard, the quantity, the combustible loading the material imposes in the area, and the fire detection present as well as any manual or automatic fire suppression capability for the area were reviewed. The effects of postulated fires on the performance of safe shutdown functions and the minimization of radioactive releases to the environment were evaluated.

Actual arrangement of the equipment and combustible materials in the area, location of barriers, provisions of the ventilation system and the penetrations in the fire barriers were considered in determining fire zones. Smoke removal requirements resulting from a fire in any plant area is discussed in prefire plans for each specific plant area.

A safe shutdown analysis has been performed on an area-by-area basis to satisfy the provisions of 10CFR50 Appendix R. The safe shutdown analysis is contained in the Safe Shutdown Report (F.P.R. Volume 2) and referenced in this Fire Hazards Analysis. To facilitate station personnel in assessing fire hazards within each zone, the Fire Hazards Analysis has been performed on a zone by zone basis.

Figures used in the Fire Hazards Analysis (FHA) are for Reference Only and are not controlled drawings.

3.1-1

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 3.2 Assumptions and Approach This fire hazards analysis, as updated to include the concerns in 10CFR50 Appendix R, and more recently, Generic Letter 83-33, is based on the following assumptions:

a. Fire areas are designated, based on as-built conditions, as those portions of a building which are separated from other areas by physical boundaries whose construction provided a 3-hour rated fire barrier or equivalent as described in the exemption requests. This is necessary since the plant did not incorporate the "fire area" concept in its original design.

It is felt, however, that the intent of a physical impedance to fire spread is satisfied based on the relatively low fire loading which exists throughout the plant and the adequacy of the barriers due to other design considerations (e.g., radiation shielding, pipe whip, tornado, seismic). Deficient barriers have been upgraded to rated barriers as needed.

Deficiencies in defined fire barriers have been identified where Dresden does not meet the separation requirements of 10CFR50 Appendix R, and detailed justifications have been developed and submitted to the NRC. These justifications are contained in the Exemption Requests (F.P.R. Volume 4).

b. For the purpose of facilitating the fire hazards analysis, fire areas are further subdivided into fire zones based on logical fire break points and/or substantial barriers. This approach is based on the relatively low fire loading that generally exists throughout the plant, no continuity of combustibles between fire zones (except along the access corridor on the ground floor of the turbine building), and the existence of noncombustible penetration seals in electrical penetrations between zones (though other unsealed penetrations may exist). The validity and application of this approach has been verified in site visits by the fire protection engineer. While CECo still believes that this is valid, to more fully comply with Appendix R as clarified by the NRC in Generic Letter 83-33, the plant has been divided into fire areas or equivalent fires areas or zone groups. Any deviation to the fire area concept is specifically justified in an exemption request.

Exception: Penetrations between fire zones 8.2.5.A and 8.2.6.A contain unsealed electrical penetrations for cables that provide service to 4kV Busses 21,22, 23 & 24 and for the Unit 2 generator voltage regulator cabinet. Penetrations between fire zones 8.2.5.E and 8.2.6.E contain unsealed electrical penetrations for cables that provide service to 4kV Busses 33 & 34 and for 480 V MCC 35-2.

c. For the evaluation of structural steel in fire barriers, localized combustible concentrations are taken into account.
d. The design-basis fire is the most severe fire that can credibly occur within a fire area or zone.

Fire initiation is assumed, as is the failure of existing automatic protection systems except for those systems installed to prevent fire spread between areas. Failure of all cables or equipment within a fire area or zone group is generally postulated except for cables or equipment provided with passive fire protection (e.g., rated fire wraps) and components, such as pipes, heat exchangers and CRD hydraulic units which are filled with water. At least one 3.2-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 method of shutdown is available at Dresden independent of each fire area, equivalent fire area, or zone group. The safe shutdown method available for each fire area is described in Section 4.0 of the Safe Shutdown Report (F.P.R. Volume 2).

e. Electrical cable tray fire propagation is limited by the provision of existing noncombustible horizontal and vertical fire breaks. However, no credit is taken for them in preventing fire spread between redundant safe shutdown equipment within a fire area or zone group.
f. Radioactive waste handling systems will not be considered in the evaluation unless a hazard can result in a major release and concurrently prevent building containment features from accomplishing their intended function.
g. External fires exposing buildings containing safe shutdown equipment were also considered.
h. Credit is taken for the primary containment boundary as a 3-hour rated fire barrier.

3.2-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 3.3 Fire Area Identification Appendix R states that where alternate or dedicated shutdown is utilized, appropriate shutdown procedures should exist for all areas of the plant. To conform with this requirement, Dresden 2 and 3 was subdivided into 15 fire areas, equivalent fire areas or zone groups. The justification for treating equivalent fire areas and zone groups as fire areas is contained specifically in the report "Appendix R Reevaluation-Interim Compensatory Measures and Exemption Requests" (F.P.R.

Volume 4). These separations were selected because of the substantial natural and/or structural barriers present. Also, of concern in the selection of the fire areas was the shutdown path, which may ultimately be used throughout a particular fire area or equivalent. Each fire area or equivalent is a composite of one or more fire zones. Table 3.3-1 lists the various fire zones throughout Dresden 2 and 3, the assigned fire area or equivalent, the applicable Fire Hazards Analysis Section, and the F drawing(s) on which the zone appears. The methodology for identification and description of fire areas is contained in Chapter 2 of the Safe Shutdown Report (F.P.R. Volume 2).

The following penetration seal requirements should be considered when a modification involves penetration of a fire area boundary or rated barrier.

a. All penetrations in fire rated walls should be sealed to the same rating as the wall.
b. All penetrations in unrated fire area boundaries should be sealed with noncombustible material.

By making a careful evaluation of penetration seal requirements, the fire area boundaries identified in the analysis and any other fire barrier commitments will not be violated.

3.3-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 TABLE 3.3-1 INDEX OF FIRE AREAS AND ZONES Description of Equivalent FHA Fire Zone Fire Zone Area/Zone Group Section F Drawing 1.1.1.1 Basement Floor RB3-II 4.5.1 F-2 1.1.1.2 Ground Floor RB3-II 4.5.2 F-3 1.1.1.3 Mezzanine Floor RB3-II 4.5.3 F-4 1.1.1.4 Main Floor RB3-II 4.5.4 F-5 1.1.1.5.A Isolation Condenser Floor RB3-I 4.4.1 F-6 1.1.1.5.B Isolation Condenser Pipe Chase RB3-I 4.4.2 F-5 1.1.1.5.C Isolation Condenser Pipe Chase RB3-I 4.4.3 F-4 1.1.1.5.D Standby Liquid Control Floor RB3-II 4.5.5 F-6 1.1.1.6 Refueling Floor RB3-II 4.5.6 F-7 1.1.2.1 Basement Floor RB2-II 4.2.1 F-2 1.1.2.2 Ground Floor RB2-II 4.2.2 F-3 1.1.2.3 Mezzanine Floor RB2-II 4.2.3 F-4 1.1.2.4 Main Floor RB2-II 4.2.4 F-5 1.1.2.5.A Isolation Condenser Floor RB2-I 4.1.1 F-6 1.1.2.5.B Isolation Condenser Pipe Chase RB2-I 4.1.2 F-5 1.1.2.5.C Isolation Condenser Pipe Chase RB2-I 4.1.3 F-4 1.1.2.5.D 4th Floor North RB2-II 4.2.5 F-6 1.1.2.6 Refueling Floor RB2-II 4.2.6 F-7 1.2.1 Primary Containment Drywell 4.6 F-2 thru F-6 1.2.2 Primary Containment Drywell 4.3 F-2 thru F-6 1.3.1 Shutdown Cooling Pump Room RB3-II 4.5.7 F-3 1.3.2 Shutdown Cooling Pump Room RB2-I 4.1.4 F-3 1.4.1 TIP Room RB3-I 4.4.4 F-3 2.0 Main Control Room TB-V 4.12.1 F-8 6.1 DC Panel Room TB-III 4.10.1 F-14 6.2 Aux. Elec. Equipment Room TB-V 4.12.2 F-8 7.0.A.1 DC Panel Room TB-I 4.8.1 F-8 7.0.A.2 125-Vdc Battery Room TB-I 4.8.2 F-8 7.0.A.3 250-Vdc Battery Room TB-I 4.8.3 F-8 7.0.B Station Battery Room TB-III 4.10.2 F-14 3.3-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 TABLE 3.3-1 INDEX OF FIRE AREAS AND ZONES Description of Equivalent FHA Fire Zone Fire Zone Area/Zone Group Section F Drawing 8.1 Clean and Dirty Oil Tank Room TB-I 4.8.2 F-10 8.2.1.A Basement Floor TB-I 4.8.3 F-9 8.2.1.B Basement Floor TB-III 4.10.3 F-9 8.2.2.A Basement Floor TB-I 4.8.4 F-9 8.2.2.B Basement Floor TB-III 4.10.4 F-9 8.2.4 Unit 3 Cable Tunnel TB-III 4.10.5 F-12 8.2.5.A Ground Floor TB-I 4.8.5 F-8, F-10 8.2.5.B Ground Floor TB-I 4.8.6 F-10 8.2.5.C Ground Floor TB-II 4.9.1 F-10, F-11 8.2.5.D Ground Floor TB-III 4.10.6 F-11 8.2.5.E Ground Floor TB-III 4.10.7 F-11 8.2.6.A Mezzanine Floor TB-I 4.8.7 F-8, F-13 8.2.6.B Mezzanine Floor TB-I 4.8.8 F-13 8.2.6.C Mezzanine Floor TB-II 4.9.2 F-13, F-14 8.2.6.D Mezzanine Floor TB-III 4.10.8 F-14 8.2.6.E Mezzanine Floor TB-III 4.10.9 F-14 8.2.7 Mezzanine Floor TB-I 4.8.9 F-8 8.2.8.A Main Operating Floor TB-IV 4.11.1 F-16, F-17 8.2.8.B Vent Floor TB-IV 4.11.2 F-15 8.2.8.C Vent Floor TB-IV 4.11.3 F-15 8.2.8.D Vent Floor TB-IV 4.11.4 F-22, F-33 9.0.A Unit 2 DG Room TB-I 4.8.10 F-10 9.0.B Unit 3 DG Room TB-III 4.10.10 F-11 9.0.C Unit 2/3 DG Room RB-2/3 4.7.1 F-3 11.1.1 Southwest Corner Room RB3-II 4.5.8 F-2 11.1.2 Southeast Corner Room RB3-II 4.5.9 F-2 11.1.3 HPCI Pump Room (Unit 3) RB-2/3 4.7.2 F-2 11.2.1 Southwest Corner Room RB2-II 4.2.7 F-2 11.2.2 Southeast Corner Room RB2-II 4.2.8 F-2 11.2.3 HPCI Pump Room (Unit 2) RB-2/3 4.7.3 F-2 3.3-3

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 TABLE 3.3-1 INDEX OF FIRE AREAS AND ZONES Description of Equivalent FHA Fire Zone Fire Zone Area/Zone Group Section F Drawing 11.3 Crib House Crib House 4.13.1 F-18 14.1 Radwaste Building Area Radwaste 4.14.1 F-19 thru F-21 14.2.A Steam Air Ejector Room TB-IV 4.11.5 F-22 14.2.B Off-Gas Recombiner and TB-IV 4.11.5 F-22 Condenser Room 14.2.C Off-Gas Condenser Room TB-IV 4.11.5 F-22 14.3.A Steam Air Ejector Room TB-IV 4.11.6 F-23 14.3.B Off-Gas Recombiner and TB-IV 4.11.6 F-23 Condenser Room 14.3.C Off-Gas Condenser Room TB-IV 4.11.6 F-23 14.4 Off-Gas Filter Building Area Outdoor 4.15.1 -

14.5 Radwaste Solidification Building Radwaste 4.14.2 F-16, F-20 Area 14.6 Maximum Recycle Radwaste Radwaste 4.14.3 F-19, F-20 Building Area 18.1.1 Unit 3 Main Power Trans. Outdoor 4.15.2 F-25 18.1.2 Unit 2 Main Power Trans. Outdoor 4.15.3 F-24 18.2.1 Unit 3 Aux. Transformer Outdoor 4.15.4 F-25 18.2.2 Unit 2 Aux. Transformer Outdoor 4.15.5 F-24 18.3.1 Unit 3 Reserve Aux. Transformer Outdoor 4.15.6 F-25 18.3.2 Unit 2 Reserve Aux. Transformer Outdoor 4.15.7 F-24 18.4 Aux. Boiler House Outdoor 4.15.8 F-25 Unit 1 Plant Structures Outdoor 4.15.9 18.6 U2 125 VDC Alternate Battery Outdoor 4.15.11 Room 18.7.1 Isolation Condenser Pumphouse - Outdoor 14.15.12 F-353 North Cubicle 18.7.2 Isolation Condenser Pumphouse - Outdoor 14.15.13 F-353 South Cubicle 3.3-4

DRESDEN 2&3 AMENDMENT 15 JUNE 2005 3.4 Combustible Loading Calculation The station combustible loading calculation identifies combustible materials and calculates fire loading within each fire zone/area. The methodology, assumptions, and input data are included within the latest revision of combustible loading calculation DRE97-0105.

3.4-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 3.5 Suppression Effects Analysis Appendix R of 10CFR50 requires that alternative or dedicated shutdown capability shall be provided "where redundant trains of systems required for hot shutdown located in the same fire area may be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems" (Section III.G.3.b). The NRC went on to establish four lines of inquiry that should be considered when performing a suppression effects analysis in Inspection and Enforcement Manual, Temporary Instruction 2515/62, Rev. 1. These lines of inquiry are as follows:

1. Whether a fire in a single location (or inadvertent actuation of a fire suppression system) could cause activation of potentially damaging automatic fire suppression systems for all redundant trains, or;
2. Whether a fire in a single location could, through the production of smoke, heat, or hot gases, cause activation of potentially damaging fire suppression for all redundant trains, or;
3. Whether a fire in a single location (or inadvertent actuation or rupture of a fire suppression system) could, through local fire suppression activity, indirectly cause damage...or:
4. Whether, in response to a fire in a single location the utilization of manually controlled fire suppression systems could cause damage to all redundant trains."

The safe shutdown approach used at Dresden 2 & 3 is primarily based upon an alternative shutdown method rather than redundant trains of equipment. For this reason, the suppression effects analysis was conducted to ensure that although redundant, equipment might be subject to the effects of suppression discharge under conservative assumptions.

The analysis included the effects of piping breaks or leakage and the use of manual hose streams.

Effects of portable extinguisher use, however, were not analyzed since it is unrealistic to assume that the use of an extinguisher will affect alternative shutdown paths due to the wide physical separation of equipment and cabling that makes up the paths.

Insulated, undamaged electrical cable will not be affected by water spray, water accumulations, smoke or CO2 discharge. Cables which could have been damaged by an actual fire have been postulated to be unusable and the application of water to these circuits will not degrade the situation beyond that assumed in the Appendix R safe shutdown analysis (see Section 5.0 of the Safe Shutdown Report, F.P.R. Volume 2).

The results of this analysis are summarized for each fire zone in Section 4.0. Recommendations to correct minor deficiencies in water drainage were addressed in the NFPA Code Review (NFPA 92M) (see F.P.P.D.P.).

3.5-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 3.6 Structural Steel Analysis 3.6.1 Introduction Based on the guidance contained in Generic Letters 83-33 and 84-09, the survivability of the structural steel at the Dresden Nuclear Power Station was evaluated to ensure fire related structural damage would not have an adverse effect on the plant's ability to safely shut down. The Unit 2/3 crib house, turbine building (including the control room and AEER), and reactor buildings were also reviewed in detail since all mechanical and electrical equipment needed to support either hot or cold shutdown are contained in these plant areas. This evaluation was conducted in three steps as follows:

1. Plant areas with protected steel (either fire resistive cover and/or automatic sprinkler protection) were eliminated from the review.
2. The fire exposure was quantified to determine the thermal environment for the steel beams.
3. Calculations were conducted to determine heat transfer to the steel beams.
4. The structural load supported by the beams was compared to the degraded strength of the beams resulting from the elevated temperatures.

3.6.2 Methodology The first step in the evaluation was to identify those areas required for safe shutdown, which contained unprotected exposed steel necessary to support the structure (ceiling above area). This resulted in a list of areas in the turbine building, which required evaluation. Areas which contained steel with approved fire resistive coverage and/or automatic sprinkler protection were considered adequately protected without further analysis (the NRC accepted automatic water suppression systems in lieu of passive steel protection at Limerick Generating Station as described in Reference 1). The fire detection and automatic suppression drawings in the Exemption Requests (F.P.R. Volume 2), Figures B-1 through B-23, were used as the basis of determining where sprinkler protection was, or would be, provided.

The next step was to quantify the severity of the fire exposure in terms of a thermal environment seen by the structural steel element. The methodology applied in this step was approved by the NRC for use at Limerick Generating Station (Reference 1). A detailed discussion of the methodology is provided in Appendix A to the Structural Steel Beam Fire Exposure Evaluation (see Volume 5 of the F.P.P.D.P.).

The generalized methodology then incorporated the specific condition (cable materials) at the Dresden Station. The conservative assumption was made that the bulk of the cables installed in the plant were non IEEE 383 qualified, PE/PVC jacket and insulation. Test data obtained from fire research conducted by both Factory Mutual Research Corporation (Reference 2), and Sandia 3.6-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 National Laboratories (Reference 3) was used to develop heat release rates, plume temperatures and separation criteria for cable tray arrays.

With the exception of the Unit 3 battery room, Unit 3 125-Vdc panel room, Unit 2 battery room, and Unit 2/3 control room, all of the areas evaluated were large open areas so only the effects of fire plumes needed to be evaluated.

Since transient combustibles were assumed to be only at floor level, the most severe fire exposure to ceiling level structural steel would be from direct plume or flame impingement from localized cable tray fires.

In order to determine which structural steel elements needed heat transfer evaluation, the heat release rate data and the temperature profile data from the Factory Mutual Research Corporation tests and Sandia National Laboratories test were used to develop separation criteria and plume temperature. This yielded a separation/exposure criteria given in Appendix B to the Structural Steel Beam Fire Exposure Evaluation (see Volume 5 of the F.P.P.D.P.).

In order to determine the duration of localized exposure fires, it was necessary to evaluate the number of cables and their characteristic burning rates (mass combustion rates, and heat release rates). Cable raceway drawings contained the number of cables in each tray, identified from reference point to reference point. (No documentation was available on subsequent cable additions to those shown on the base documents, which could influence the fire exposure to the structural steel.) To translate this cable information into the mass of combustible material available to burn and subsequently into exposure duration, cable specification data supplied by Sargent & Lundy and the cable manufacturers (General Electric and Simplex) were used to quantify an "average" cable. This portion of the evaluation is attached in Appendix C to the Structural Steel Beam Fire Exposure Evaluation (see Volume 5 of the F.P.P.D.P.).

3.6.3 Results Based on the results of these evaluations, the majority of structural steel supporting the unrated walls in the general area of the turbine building would not fail due to fire exposure. When calculated structural steel temperatures exceeded 1100°F, the result was considered a failure because the load carrying ability of the steel has degraded the typical safety factor to a point where the steel can only carry its design load. Table 3.6-1 contains a list of the beams for which the 1100°F temperature has been exceeded. Also included on the table are the beam size, the cable trays which expose them, the plume temperature and duration, and the resulting steel temperatures.

A review of the dead load stresses was conducted for the beams experiencing an exposure temperature higher than 1100°F. These stresses were compared to the yield stresses at elevated temperatures of ASTM-A36 steel published in "U.S.S. Steel Design Manual" to determine beam failure temperatures. Table 3.6-2 lists the 15 beams that cannot accept the higher temperatures along with the recommended type of fire protection.

3.6-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 3.6.4 References

1. "Safety Evaluation Report related to the operation of the Limerick Generating Station, Units 1 and 2," Supplement 2, Nuclear Regulatory Commission, NUREG-0991, October 1984.
2. FMRC, "Categorization of Cable Flammability, Intermediate Scale Fire Tests of Cable Tray Installations," Electric Power Research Institute, EPRI NP-1881, August 1982.
3. W.H. Schmidt and F.R. Krause, "Burn Mode Analysis of Horizontal Cable Tray Fires,"

SAND 81-0079, NUREG/CR-2431, Sandia National Laboratories, February 1982.

3.6-3

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 TABLE 3.6-1 STEEL BEAMS WHOSE TEMPERATURE EXCEEDS 1100°F IF EXPOSED TO A FIRE Beam Cable Calculated Steel Fire Zone Size Tray(s) Localized Exposure Temp.(°F) 2.0 36WF135 154 1500°F for 45 min. 1399 Unit 2/3 Control 136 1500°F for 70 min. 1469 Room 137 1500°F for 73 min. 1469 24WF76 1051 1500°F for 27 min. 1315 (3 beams) 136 1500°F for 70 min. 1490+

137 1500°F for 73 min. 1490+

24WF68 1051 1500°F for 27 min. 1360 (2 beams) 1056 1500°F for 16 min. 1140 1050 1500°F for 25 min. 1336 12WF27 136 1300°F for 70 min. 1300+

(4 beams) 137 1300°F for 73 min. 1300+

138 1300°F for 15 min. 1167 139 1300°F for 71 min. 1300+

140 1300°F for 27 min. 1278 1043 1500°F for 13 min. 1275 1044 1500°F for 14 min. 1310 7.0.A.1 21WF62 1M3 1500°F for 24 min. 1310 Unit 2 Battery (6 beams) 1M3W 1500°F for 23 min. 1290 Room 1M4E 1500°F for 23 min. 1290 1M4S 1500°F for 23 min. 1290 1M4W 1500°F for 21 min. 1255 2M4N 1500°F for 22 min. 1275 2M4S 1500°F for 23 min. 1290 81M4 1500°F for 20 min. 1237 2M3N 1500°F for 23 min. 1290 2M3S 1500°F for 24 min. 1310 21WF55 362 1500°F for 15 min. 1124 (3 beams) 1M3 1500°F for 24 min. 1330 1M3W 1500°F for 23 min. 1310 1M4E 1500°F for 23 min. 1310 1M4S 1500°F for 23 min. 1310 1M4W 1500°F for 21 min. 1275 81M3 1500°F for 20 min. 1259 3.6-4

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 TABLE 3.6-1 STEEL BEAMS WHOSE TEMPERATURE EXCEEDS 1100°F IF EXPOSED TO A FIRE Beam Cable Calculated Steel Fire Zone Size Tray(s) Localized Exposure Temp.(°F) 8.2.5.A 36WF170 263B 1500°F for 34 min. 1195 Unit 2 Turbine K2025 1500°F for 69 min. 1427+

Building, 30WF99 203T&B 1500°F for 34 min. 1365 Trackway Area (2 beams) 206 1500°F for 35 min. 1375 24WF100 236T,M,B 1500°F for 23 min. 1175 24WF76 263B 1300°F for 34 min. 1206 21WF68 185T&B 1500°F for 18 min. 1130 (2 beams) 186T&B 1500°F for 18 min. 1130 238T,M,B 1500°F for 18 min. 1130 21WF59 185T,B 1500°F for 18 min. 1185 21WF55 263B 1500°F for 34 min. 1430 (3 beams) 266T&B 1500°F for 23 min. 1310 14WF38 236T,M,B 1500°F for 23 min. 1370 14WF30 189T,M,B 1500°F for 12 min. 1230 (2 beams) 8WF17 178T,M,B 1500°F for 12 min. 1330 (4 beams) 189T,M,B 1500°F for 12 min. 1330 203T&B 1500°F for 34 min. 1495 236T,M,B 1500°F for 23 min. 1475 6WF20 185T&B 1500°F for 18 min. 1360 (2 beams) 192T&B 1300°F for 22 min. 1230 8.2.5.C 27WF84 321 1500°F for 29 min. 1345 Unit 2/3 Turbine (3 beams)

Building Ground 24WF68 284T 1500°F for 15 min. 1120 Floor Common (5 beams) 748T&B 1500°F for 16 min. 1235 Area 21WF55 750T&B 1500°F for 26 min. 1355 (2 beams) 18WF45 752 1500°F for 22 min. 1330 16WF36 283T 1500°F for 11 min. 1135 741T&B 1500°F for 12 min. 1175 12WF27 741T&B 1500°F for 12 min. 1245 (2 beams) 8WF17 741T&B 1500°F for 12 min. 1330 743T&B 1500°F for 12 min. 1330 3.6-5

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 TABLE 3.6-1 STEEL BEAMS WHOSE TEMPERATURE EXCEEDS 1100°F IF EXPOSED TO A FIRE Beam Cable Calculated Steel Fire Zone Size Tray(s) Localized Exposure Temp.(°F) 8.2.5.E 21WF62 717T&B 1500°F for 22 min. 1275 Unit 3 Turbine (2 beams)

Building, 18WF50 714T&B 1300°F for 27 min. 1200 Trackway Area 16WF40 714T&B 1300°F for 27 min. 1235 (2 beams) 722T&B 1500°F for 12 min. 1110 10WF21 717T&B 1500°F for 20 min. 1453 (4 beams) 8WF17 717T&B 1500°F for 20 min. 1464 (2 beams) 3.6-6

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 TABLE 3.6-1 STEEL BEAMS WHOSE TEMPERATURE EXCEEDS 1100°F IF EXPOSED TO A FIRE Beam Cable Calculated Steel Fire Zone Size Tray(s) Localized Exposure Temp.(°F) 8.2.6.A 33WF118 120T&B 1500°F for 21 min. 1120 Unit 2 Turbine (2 beams) K2047 1500°F for 28 min. 1255 Building, East 30WF99 121T 1500°F for 19 min. 1115 Mezzanine (3 beams) 120T&B 1500°F for 21 min. 1165 Level K2047 1500°F for 28 min. 1295 K2048 1500°F for 29 min. 1310 8WF17 120T&B 1300°F for 21 min. 1275 (3 beams) 123 1500°F for 20 min. 1464 127 1500°F for 13 min. 1355 128T&B 1500°F for 21 min. 1470 132T&B 1500°F for 14 min. 1385 27WF94 123 1500°F for 20 min. 1129 24WF76 135 1500°F for 38 min. 1420 133T&B 1500°F for 31 min. 1365 130T&B 1500°F for 30 min. 1354 128T&B 1500°F for 21 min. 1205 24WF68 85B 1500°F for 35 min. 1431 142 1500°F for 21 min. 1265 21WF55 128T&B 1500°F for 21 min. 1275 129B 1500°F for 18 min. 1205 16WF36 123 1500°F for 20 min. 1387 (2 beams) 125 1500°F for 11 min. 1135 14WF43 85B 1500°F for 35 min. 1450 (2 beams) 132T&B 1500°F for 14 min. 1115 130T&B 1500°F for 30 min. 1419 142 1500°F for 21 min. 1305 327T&B 1500°F for 27 min. 1390 326T&B 1500°F for 26 min. 1380 135 1500°F for 38 min. 1460 133T&B 1500°F for 31 min. 1425 14WF30 130T&B 1500°F for 30 min. 1481 123 1500°F for 20 min. 1419 128 1500°F for 21 min. 1430 326T&B 1500°F for 26 min. 1465 3.6-7

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 TABLE 3.6-1 STEEL BEAMS WHOSE TEMPERATURE EXCEEDS 1100°F IF EXPOSED TO A FIRE Beam Cable Calculated Steel Fire Zone Size Tray(s) Localized Exposure Temp.(°F) 8.2.6.E 27WF94 K3028, 807T&B 1500°F for 20 min. 1129 Unit 3 Turbine K3029, 811T&B 1500°F for 25 min. 1235 Building, West 24WF76 K3028, 807T&B 1500°F for 20 min. 1187 Mezzanine (2 beams)

Level 24WF68 K3024, 810T&B 1500°F for 20 min. 1247 K3029, 811T&B 1500°F for 25 min. 1336 8.2.7 36WF245 K2048 1500°F for 46 min. 1210 Unit 2 Turbine 36WF230 K2048 1500°F for 46 min. 1240 Building, Area 36WF150 K2048 1500°F for 46 min. 1370 Around Battery K2049 1500°F for 29 min. 1185 Room K2030, 86M1, 1500°F for 47 min. 1375 36WF182 85B 1500°F for 47 min. 1305 K2030, 86M1, 85B 8.2.7 27WF94 K2031, 90T,M,B 1500°F for 29 min. 1295 South of Unit 2 21WF62 K2031, 90T,M,B 1500°F for 29 min. 1375 Battery Room 6.1 16WF40 800T&B 1500°F for 17 min. 1275 Unit 3 (3 beams) 801 1500°F for 12 min. 1110 Distribution 802 1500°F for 16 min. 1250 Panel Room 803 1500°F for 25 min. 1410 804 1500°F for 16 min. 1250 805 1500°F for 15 min. 1229 3.6-8

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 TABLE 3.6-2 BEAMS REQUIRING FIRE PROTECTION FOLLOWING STUDY OF BEAM STRESS INTERACTIONS WITH DEAD LOAD AT ELEVATED TEMPERATURES Calculated Fire Beam Cable Localized Steel Zone Size Tray(s) Exposure Temp(°F) Recommended Fire Protection 2.0 36WF135 154, 136, 1500°F for 1469 Exemption Requested (If 137 73 min. Exemption not granted, fireproof beam) 2.0 24WF76 1051 1500°F for 1315 Exemption Requested (If 27 min. Exemption not granted, fireproof beam) 2.0 24WF76 136, 137 1500°F for 1490 Exemption Requested (If 70 min. Exemption not granted, fireproof beam) 2.0 24WF68 1051, 1056, 1500°F for 1360 Exemption Requested (If 1050 27 min. Exemption not granted, fireproof beam) 8.2.5.A 36WF170 263B 1500°F for 1427 Add Sprinkler System K2025 69 min.

8.2.5.C 27WF84 321 1500°F for 1345 Fireproof beams and provide (3 Beams) 29 min. fire stops in tray 8.2.5.C 16WF36 283T 1500°F for 1175 Fireproof beam outside of block 741T&B 12 min. wall 8.2.5.E 10WF21 717T&B 1500°F for 1453 Fireproof beam 20 min.

8.2.6.A 16WF36 123 1500°F for 1387 Fireproof beam 125 20 min.

8.2.6.A 14WF30 130T&B 1500°F for 1481 Fireproof beam 123, 128 30 min.

326T&B 8.2.6.A 14WF43 130T&B 1500°F for 1425 Fireproof beam 327T&B 31 min.

326T&B 135T&B 8.2.6.A 14WF43 85B, 142, 1500°F for 1460 Fireproof beam 132T&B, 38 min.

327T&B, 135, 133T&B 3.6-9

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 TABLE 3.6-2 BEAMS REQUIRING FIRE PROTECTION FOLLOWING STUDY OF BEAM STRESS INTERACTIONS WITH DEAD LOAD AT ELEVATED TEMPERATURES Calculated Fire Beam Cable Localized Steel Zone Size Tray(s) Exposure Temp(°F) Recommended Fire Protection 8.2.6.A 24WF68 85B, 142 1500°F for 1431 Fireproof beam in corridor 35 min.

8.2.6.A 24WF76 135, 1500°F for 1420 Fireproof beam 133T&B, 38 min.

130T&B, 128T&B 8.2.6.A 21WF55 128T&B, 1500°F for 1275 Fireproof beam 129B 21 min.

6.1 16WF40 800T&B, 1500°F for 1410 Fireproof beam 802, 803, 25 min.

804 6.1 16WF40 800T&B, 1500°F for 1250 Fireproof beam 802, 801, 16 min.

805 6.1 16WF40 801, 805, 1500°F for 1229 Fireproof beam 806 15 min.

3.6-10

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 3.7 Penetrations 3.7.1 Electrical Penetration Seal Evaluation Wherever cables pass through barriers for which credit is taken in the Appendix R analysis or a previous commitment was made, it was demonstrated that the penetrations are sealed in a manner that preserves the integrity of the fire barriers in accordance with the requirements of Appendix A to BTP APCSB 9.5-1. Walkdowns were conducted to gather data on the penetrations. The data recorded for each penetration included the location, seal detail and degree of cable fill. These data were reviewed to determine the adequacy of the seals. This evaluation is summarized in the report entitled "Review of Electrical Penetration Seal Fire Testing and Installation Program" (see F.P.P.D.P). As a result of the evaluation, tests were conducted to ensure that the existing seals met the specifications of CECo commitments. The reports of these tests are found in F.P.P.D.P.

The evaluation of existing penetration seal design details is provided in the report entitled, Penetration Seal Assessment (see F.P.P.D.P.).

3.7.2 Mechanical Penetration In accordance with the Appendix R safe shutdown analysis, certain walls and floors in the reactor building, turbine building and service building are required to have a 3-hour fire resistance rating. To justify the 3-hour rating of a wall all mechanical penetrations must be sealed and those seals must be 3-hour fire rated.

A walkdown of all mechanical penetration seals was conducted. The data from the walkdown was compared against current seal details to confirm that they apply and the adequacy of the existing seal was verified (the data sheets verifying the adequacy of existing seals are found in F.P.P.D.P. Barrier drawings were then developed (see drawings F-41 through F-196) based on the walkdown to show the size and location of every penetration in the fire barriers.

3.7.3 Fire Damper Review (NFPA 90A)

Fire barriers carrying a 3-hour fire rating must also have 3-hour rated fire dampers in any HVAC ducts that penetrate the barrier. All barriers that were designated as being 3-hour barriers were reviewed to determine if HVAC ducts penetrated them and then a check was made to determine if fire dampers had been installed. If no damper had been installed either a fire damper was installed or an exemption request from the requirements of 10CFR50 Appendix R was submitted to justify not installing a damper (see Sections 3.3 and 4.3 of the Exemption Requests, F.P.R.

Volume 4).

Fire dampers that have been installed in HVAC ducts that penetrate fire barriers should be designed and installed according to guidance in NFPA 90A (1976). All of these fire dampers were reviewed for compliance with criteria in NFPA 90 and justification for significant deviations was provided (see NFPA Code Review, F.P.P.D.P.).

3.7-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 A fire damper surveillance program was established for all 3-hour rated fire dampers. This program consists of a fire damper surveillance procedure (see the fire protection procedure list in F.P.P.D.P. Volume 12).

3.7-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 3.8 Cabinet Sealing to Prevent Water Intrusion Branch Technical Position (BTP) APCSB 9.5-1, Appendix A, recommends that safety-related equipment, which does not itself require water fire protection, but is in the vicinity of sprinkler-protected cable trays and subject to unacceptable damage from sprinkler water discharge, should be protected from sprinkler system operation or malfunction.

Equipment listed in Table 3.8-1 shall be sealed for protection to comply with water intrusion commitments to the NRC.

TABLE 3.8-1 CABINET SEALING

SUMMARY

Component Commitment 23 4KV SWGR The top of the switchgear will be sealed to prevent water damage 24 4KV SWGR The top of the switchgear will be sealed to prevent water damage 28 480V SWGR The top of the switchgear will be sealed to prevent water damage 29 480V SWGR The top of the switchgear will be sealed to prevent water damage 33 4KV SWGR The top of the panel is sealed to reduce the probability of water entry 34 4KV SWGR The top of the panel is sealed to reduce the probability of water entry 38 480V SWGR The top of the switchgear will be sealed to prevent water damage 39 480V SWGR The top of the switchgear will be sealed to prevent water damage 28-1 480V MCC The top of the panel is sealed to reduce the probability of water entry 28-2 480V MCC The top of the panel is sealed to reduce the probability of water entry 28-3 480V MCC The top of the switchgear will be sealed to prevent water damage 28-7 480V MCC The top of the MCC will be sealed to prevent water damage 29-1 480V MCC The top of the panel is sealed to reduce the probability of water entry 29-2 480V MCC The top of the MCC will be sealed to provide water damage protection 29-3 480V MCC The top of the MCC will be sealed to provide water damage protection 29-4 480V MCC The top of the panel is sealed to reduce the probability of water entry 29-7 480V MCC The top of the panel is sealed to reduce the probability of water entry 38-1 480V MCC The top of the panel is sealed to reduce the probability of water entry 38-2 480V MCC The top of the panel is sealed to reduce the probability of water entry 38-3 480V MCC The top of the panel is sealed to reduce the probability of water entry 39-1 480V MCC The top of the panel is sealed to reduce the probability of water entry 39-2 480V MCC The top of the panel is sealed to reduce the probability of water entry 3.8-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 TABLE 3.8-1 CABINET SEALING

SUMMARY

Component Commitment 39-7 480V MCC The top of the MCC is sealed to prevent water damage 902-29, 903-29* The tops of the SR panels will be sealed to prevent water damage 902-32, 903-32 The tops of the SR panels will be sealed to prevent water damage 902-33, 903-33 The tops of the SR panels will be sealed to prevent water damage 902-39, 903-39 The tops of the SR panels will be sealed to prevent water damage 902-40, 903-40 The tops of the SR panels will be sealed to prevent water damage 902-41, 903-41 The tops of the SR panels will be sealed to prevent water damage 902-46, 903-46 The tops of the SR panels will be sealed to prevent water damage 902-47, 903-47 The tops of the SR panels will be sealed to prevent water damage 902-52A,B The tops of the SR panels will be sealed to prevent water damage 903-52A,B 902-61 The tops of the SR panels will be sealed to prevent water damage 903-62 The tops of the SR panels will be sealed to prevent water damage 902-64A,B The tops of the SR panels will be sealed to prevent water damage 903-64A,B 903-68 The tops of the SR panels will be sealed to prevent water damage 902-69, 903-69 The tops of the SR panels will be sealed to prevent water damage 2202-70A,B The tops of the SR panels will be sealed to prevent water damage 2203-70A,B 2253-91,92 The tops of the SR panels will be sealed to prevent water damage 2A-1,2 The tops of the SR panels will be sealed to prevent water damage 3A-1,2 2B-1,2 The tops of the SR panels will be sealed to prevent water damage 3B-1,2 Unit 2 & Unit 3 The tops of the SR panels will be sealed to prevent water damage Inverters A & B Unit 2 & Unit 3 Ess The tops of the SR panels will be sealed to prevent water damage Auto X-fer Switch 23-1 4kV Swgr Water shield is installed over Swgr 24-1 4kV Swgr Water shield is installed over Swgr 33-1 4kV Swgr Water shield is installed over Swgr 34-1 4kV Swgr Water shield is installed over Swgr 3.8-2

ArlEN Ot1ENT 1 JAHUARY 1936 Fire Zone Boundries 3 - Hour Fire Barrier (Except Where Noted)

  • Class "A" Fire Door

~ 3 - Hour Rated Floor DRESDEN STATION Units 2 &. 3 FIGURE 3.3-1 LEGEND FOR FIRE BARRIER DRA~IINGS

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CY Figure Withheld Under 10 CFR 2.390

Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESDEN STATION Units 2 &. 3 FIGURE 3.3-3 REACTOR BUILDING ELEV.

Security-Related Information Figure Withheld Under 10 CFR 2.390 Security-Related Information Figure Withheld Under 10 CFR DRESDEN STATION Unitt 2 &. 3 FIGURE 3.3-4 REACTOR BUILDING ELEV.

Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESDEN STATION Units 2 &,. 3 FIGURE 3;3-5 REACTOR BUILDING ELEV.

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AMENDMENT 1 JANUARY 1986 Security-Related Information Figure Withheld Under 10 CFR 2.390

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DRESDEN STATION Units 2 &. 3 FI GURE 3.3-6 REACTOR BUILDING ELEV.

. AMENDMENT 1 JAIlUARY 1986 Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESDEN STATION UnIts 2 &. 3 FIGURE 3:3'-7 REACTOR BUILDING ELEV.

Security-Related Information Figure Withheld Under 10 CFR 2.390 Security-Related Information Figure Withheld Under 10 CFR 2.39 DRESDEN STATION Units 2 &. 3 FIGURE 3.3-8 CONTROL ROOM AND MISC. TURBINE BUILDING FLOORS

Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESDEN STATION Units 2 &. 3 FIGURE 3;3-9 TURBINE BUILDING BASEMENT no OR

Security-Related Information Figure Withheld Under 10 CFR 2.390 STATION 28.3 t1GURE 3.3-10 TURBINE BUILDING GROUND rLOOR, UNIT 2

Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESDEN STATION Units 2 &. 3 rIGURE 3.3-11 TURBINE BUILDING GROUND rLOOR. UNIT 3

Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESDEN STATION Units 2 8. 3 neURE 3.3-12 CABLE: TUNNEL

Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESDEN STATION Units 2 B. 3 rIGURE 3.3-13 TURBINE BUILDING MEZZANINE rLOOR, UNIT 2

Security-Related Information Figure Withheld Under 10 CFR 2.390 D~ESDEN STA nON t Units 2 B. 3 rlGURE 3.3-1" TURBINE BUILDING MEZZANINE rLOOR, UNIT 3

Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESDEN STATION UNITS 2 8. 3 FIGURE 3.3-15 VENT FLOOR ELEV.

Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESDEN STATION Units 2 S. 3 tIGURE 3.3-16 TURBINE BUILDING MAIN FLOOR, UNIT 2

Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESDEN ST AT ION Units 2 S. 3 rtGURE: 3.3-17 TURBINE BUILDING MAIN rLOOR, UNlT 3

.- r"'"

Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESDEN STATION Unit. 2 " 3 FIGURE 3.3-18 CRIB HOUSE

Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESD EN STATIO N Units 2 &. 3 FIGURE 3.3-19 RADWASTE BUILDING ELEV.

Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESDEN STAT'ION Units 2 a. 3'

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J Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESDEN STATION Unit. 2 &. 3 FIGURE 3.3-21 RADWAST

Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESDEN STATION Units 2 &. 3 FIGURE 3.3-2Z OFF-GAS RECOMBINER ROOM, UNIT 2

Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESDEN STATION Units 2 &. 3 FIGURE 3.3-23 OFF-GAS RECOI-llINER ROOM. UNIT 3

Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESDEN STATION Units 2 " 3 FIGURE 3.3-24 OUTDOOR STRUCTURES. UNIT 2

Security-Related Information Figure Withheld Under 10 CFR 2.390 r .DRESD EN STATIO N Units 2 &. 3 FIGURE 3.3-25 OUTDOOR STRUCTURES. UNIT 3

Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESDEN STAtiON Unl1ll2 &3 FIGURE 3,3,26 U2 125VDC ALTERNATE BATTERV ROOM

Security-Related Information Figure Withheld Under 10 CFR 2.390 DRESDEN STATION Unit s 2 & 3 FIGURE 3.3-27 ISOLATION CONDENSER PUMPHOUSE

DRESDEN 2&3 AMENDMENT 15 JUNE 2005 4.0 FIRE HAZARDS ANALYSIS 4.1 Reactor Building Fire Area RB2-I The fire zones which are included in this fire area are:

1.1.2.5.A 1.1.2.5.B 1.1.2.5.C 1.3.2 4.1.1 Isolation Condenser Area (Fire Zone 1.1.2.5.A)

This zone is shown on the F-6 drawings and Figure 3.3-6.

Fire Barrier Description The north wall separates this fire zone from the fuel pool, the dryer-separator storage pool, the inerted drywell, and Fire Zone 1.1.2.5.D which is part of Fire Area RB2-II. This wall is minimum 3-foot 0-inch thick reinforced concrete and contains two HVAC ducts to the pools which do not contain fire dampers, unsealed Mechanical Penetrations, and a 3-hour rated fire door. The south and east walls of this fire zone form the exterior of the plant. These walls are constructed of minimum 1-foot 0-inch thick reinforced concrete. The west wall separates this fire zone from Fire Zone 1.1.1.5.A which is part of Fire Area RB3-I. The wall is a 2-foot 0-inch thick reinforced concrete fire barrier which contains a 3-hour rated fire door. The floor separates this fire zone from Fire Zone 1.1.2.4 which is part of Fire Area RB2-II and is minimum 1-foot 6-inch thick reinforced concrete. The penetrations in the floor are sealed with six exceptions, i.e., the stairwell, the access ladder hatch, two HVAC duct penetrations, one pipe penetration area, and the 20-foot by 20-foot equipment hatch. Access is provided through the floor to Fire Zone 1.1.2.5.B by way of an opening cut in the intervening grating. The ceiling separates this fire zone from Fire Zone 1.1.2.6 which is part of Fire Area RB2-II and is minimum 1-foot 6-inch thick reinforced concrete. The ceiling contains unsealed mechanical penetration in addition to four large unsealed penetrations, i.e., the stairwell, two HVAC ducts, and the 20-foot by 20-foot equipment hatch. Electrical penetrations in the ceiling are sealed.

Safe Shutdown Equipment The hot shutdown equipment located in this fire zone is as follows:

Unit 2 Isolation Condenser 2-1302 Isolation Condenser Valves MO2-1301-10, MO2-4102 AO2-1301-17, AO2-1301-20 2-1301-633, 2-1301-634 2-1301-39, 2-1301-40, 2-1301-16 Isolation Condenser Sightglass 2-1301-644 There is no equipment or cabling associated with cold shutdown located in this fire zone.

4.1-1

DRESDEN 2&3 AMENDMENT 15 JUNE 2005 Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone has a complete ionization smoke/fire detection system which alarms locally and in the control room. The unsealed openings as well as the HVAC ducts in floor and ceiling are protected by automatic thermally actuated closed head preaction water curtains or wet pipe sprinklers. The HVAC ducts which penetrate the wall into the refuel pool and dryer separator area are not protected. There are two manual hose stations located in this fire zone.

Design-Basis Fire This fire zone is part of Fire Area RB2-I. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.1 of the Safe Shutdown Report (F.P.R.

Volume 2).

A redundant shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression have not been provided. This is justified in Section 3.4 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.1.2.5.A shares a boundary with Fire Areas RB2-II and RB3-I. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Area RB2-II. The adequacy of these barriers in preventing fire spread is discussed in Section 3.3 of the Exemption Requests (F.P.R. Volume 4) and EC 353102.

Fire Suppression Effects Since the only hot shutdown equipment in this zone consists of the isolation condenser and various valves, operation of fixed or manual water suppression equipment, as well as piping leaks, will not affect safe shutdown. Any adverse effects on hot shutdown equipment would be less severe than those determined to be acceptable for a design-basis fire. Water runoff would be handled by the floor drainage system as well as open hatches, grating, and stairs to the floor below. Important electrical equipment located near the hatch opening in the floor below is protected from water spray with shields.

4.1.2 Isolation Condenser Pipe Chase (Fire Zone 1.1.2.5.B)

This zone is shown on the F-5 drawings and Figure 3.3-5.

4.1-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Fire Barrier Description The north wall of this fire zone is shared with the inerted drywell and is a minimum 4-foot 0-inch thick reinforced concrete fire barrier. The south, east, and west walls separate this fire zone from Fire Zone 1.1.2.4 which is part of Fire Area RB2-II and are 3-hour rated fire barriers constructed of 1-foot 0-inch thick reinforced concrete. All penetrations in these walls are sealed to a 3-hour rating. Access to this fire zone is gained through a 3-hour rated fire door located in the east wall.

The floor and ceiling of this fire zone are made of open grating support on unprotected steel and separate this fire zone from Fire Zones 1.1.2.5.C and 1.1.2.5.A which are part of Fire Area RB2-I. There is an access ladder which runs through the zone to Fire Zone 1.1.2.5.A.

Safe Shutdown Equipment The following is the only safe shutdown equipment located in this fire zone.

Isolation Condenser Valve MO2-1301-2 Combustible Material and Fire Loadings Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone does not contain either fire/smoke detection capabilities or automatic fixed-suppression systems. A manual hose station, located outside this zone in Fire Zone 1.1.2.4, is available in the event of a fire in Fire Zone 1.1.2.5.B. A fire in this fire zone would be detected by the ionization detection located directly above the open grated ceiling in Fire Zone 1.1.2.5.A (see Figures B-4 and B-5 of the Exemption Requests, F.P.R., Volume 4 ).

Design-Basis Fire This fire zone is part of Fire Area RB2-I. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.1 of the Safe Shutdown Report (F.P.R.

Volume 2).

A redundant shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression have not been provided. This is justified in Section 3.4 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.1.2.5.B shares a boundary with Fire Areas RB2-II and the drywell. A fire is prevented from spreading into these fire areas by 3-hour fire barriers.

4.1-3

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Fire Suppression Effects Since the only safe shutdown equipment in this zone consists of valve MO2-1301-2, piping breaks or the operation of the manual hose equipment should not affect safe hot shutdown since this valve can be operated manually. Adverse effects on hot shutdown equipment would be less severe than those determined to be acceptable for a design-basis fire. Water runoff would drain through metal gratings to the floor below.

4.1.3 Isolation Condenser Pipe Chase (Fire Zone 1.1.2.5.C)

This fire zone is shown on the F-4 drawings and Figure 3.3-4.

Fire Barrier Description The north wall of this fire zone is shared with the inerted drywell and is constructed of minimum 4-foot 0-inch thick reinforced concrete fire barrier. The south, east, and west walls separate this fire zone from Fire Zone 1.1.2.3 which is part of Fire Area RB2-II and are 3-hour rated fire barriers constructed of 2-foot 0-inch thick reinforced concrete. All penetrations in these walls are sealed to a 3-hour rating. Access to this fire zone is gained through a 3-hour rated fire door located in the east wall. The floor separates this fire zone from Fire Zone 1.1.2.2 which is part of Fire Area RB2-II and is a minimum 1-foot 0-inch thick reinforced concrete 3-hour rated fire barrier.

The ceiling of this fire zone consists of open grating connecting this fire zone to Fire Zone 1.1.2.5.B which is part of Fire Area RB2-I.

Safe Shutdown Equipment The following is the only safe shutdown equipment located in this fire zone.

Isolation Condenser Valve MO2-1301-3 Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone does not contain either fire/smoke detection capabilities or automatic fixed suppression systems. A manual hose station, located outside this fire zone in Fire Zone 1.1.2.3, is available in the event of a fire in Fire Zone 1.1.2.5.C. A fire in this zone would be detected by the ionization detection located at the ceiling of Fire Zone 1.1.2.5.A because of the open grating between the zones (see Figures B-3 and B-5 of the Exemption Requests, F.P.R., Volume 4 ).

4.1-4

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 Design-Basis Fire This fire zone is part of Fire Area RB2-I. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.1 of the Safe Shutdown Report (F.P.R.

Volume 2).

A redundant shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression have not been provided. This is justified in Section 3.4 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.1.2.5.C shares a boundary with Fire Areas RB2-II and the drywell. A fire is prevented from spreading into these fire areas by 3-hour fire barriers.

Fire Suppression Effects Since the only safe shutdown equipment in this zone consists of valve MO2-1301-3, piping breaks or the operation of the manual hose equipment would not affect safe shutdown. Adverse effects on hot shutdown equipment would be less severe than those determined to be acceptable for a design-basis fire. Water would run to the personnel access door where it could be transferred to the floor drainage system in Fire Zone 1.1.2.3.

4.1.4 Shutdown Cooling Pump Room (Fire Zone 1.3.2)

This fire zone is shown on the F-3 drawings and Figure 3.3-3.

Fire Barrier Description The north wall separates this zone from the Turbine Building Fire Zone 8.2.5.A which is part of Fire Area TB-I and is constructed of minimum 2-foot 0-inch thick reinforced concrete. The east and southeast walls of this fire zone separate it from Fire Zone 1.1.2.2 which is part of Fire Area RB2-II. These walls are minimum 2-foot 0-inch thick reinforced concrete 3-hour rated fire barriers. A 3-hour rated fire door along with an HVAC opening with a 3-hour rated fire damper are located in this wall. A magnetic closure device closes the door upon fire detector actuation.

The west wall separates this fire zone from the inerted drywell, Fire Zone 1.2.2 and the main steam pipe area (TB-I). The portion of the wall which borders the drywell is 5-foot 0-inch thick reinforced concrete fire barrier. The wall bordering the pipe area is 5-foot 0-inch thick reinforced concrete containing a ventilation louver which does not contain a fire damper, and an unsealed mechanical penetration. The floor separates this fire zone from Fire Zone 1.1.2.1 which is part of Fire Area RB2-II and is minimum 2-foot 0-inch thick reinforced concrete. The floor contains a 3-foot 0-inch by 4-foot 3-inch opening which is covered by steel plate with cutouts for piping and six unsealed mechanical penetrations. The ceiling separates this fire zone from Fire Zone 1.1.2.3 which is part of Fire Area RB2-II and is minimum 1-foot 0-inch thick reinforced concrete. A 2-foot 3-inch by 3-foot 6-inch opening is in the ceiling which contains three pipes and a 3-foot 4-inch by 1-foot 0-inch HVAC duct. A 1-foot 6-inch thick block shield wall from elevation 545-feet 6-inch to 551-feet 6-inch covered with a steel plate partially separates this opening from Fire Zone 1.1.2.3.

4.1-5

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Safe Shutdown Equipment There is no hot shutdown equipment located in this fire zone. However, the main and redundant power and control cables for the inboard isolation condenser valves are routed through this fire zone.

The cold shutdown equipment located in this fire zone is as follows:

Shutdown Cooling Pumps 2A-1002, 2B-1002, and 2C-1002 Shutdown Cooling Pump Suction Valves MO2-1001-2A, MO2-1001-2B, and MO2-1001-2C Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures The fire zone is provided with complete photoelectric fire smoke detection which alarms locally and in the control room. This fire zone does not contain fixed suppression. An automatic sprinkler system is installed in Fire Zone 1.1.2.3 above the unsealed penetration. A hose station which is available for use in this fire zone is located in adjacent Fire Zone 1.1.2.2.

Design-Basis Fire This fire zone is part of Fire Area RB2-I. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.1 of the Safe Shutdown Report (F.P.R.

Volume 2).

A redundant shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression have not been provided. This is justified in Section 3.4 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.3.2 shares a boundary with Fire Areas RB2-II, TB-I and the Unit 2 drywell. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Area RB2-II. The adequacy of these barriers in preventing fire spread is discussed in Section 3.4 of the Exemption Requests (F.P.R.

Volume 4).

Fire Suppression Effects There are no fixed suppression systems or supply piping in this fire zone. Therefore, operation of such a system is not a concern. Use of manual hose is not a concern for hot shutdown as no hot shutdown equipment is located within the room. Hose stream runoff would be handled by the floor drainage system in the general area.

4.1-6

DRESDEN 2&3 AMENDMENT 14 JUNE 2003 4.2 Reactor Building Fire Area RB2-II Following is a list of fire zones in fire area RB2-II.

1.1.2.1 1.1.2.3 1.1.2.5.D 11.2.1 1.1.2.2 1.1.2.4 1.1.2.6/1.1.1.6 11.2.2 4.2.1 Reactor Building Torus Basement (Fire Zone 1.1.2.1)

This fire zone is shown in the F-2 drawings and Figure 3.3-2.

Fire Barrier Description The north, south, and east walls of this fire zone form the exterior of the plant. These walls are minimum 1-foot 0-inch thick reinforced concrete. The west wall is a minimum 2-foot 0-inch thick reinforced concrete wall which separates this fire zone from Fire Zone 1.1.1.1 which is part of the Fire Area RB3-II. The penetrations in this wall are sealed to a 3-hour rating except for the wall between the Unit 2 and Unit 3 equipment drain tank rooms which contains an unrated door.

The floor of this fire zone is 2-foot 6-inch thick reinforced concrete which is the basement of the Reactor Building. The ceiling separates this fire zone from Fire Zone 1.1.2.2 which is part of Fire Area RB2-II. Fire Zone 1.3.2 which is part of Fire Area RB2-I, Fire Zones 8.2.5.A and 8.1 which are part of Fire Area TB-I and Fire Zone 8.2.5.C which is part of Fire Area TB-II and is minimum 2-foot 0-inch thick reinforced concrete with penetrations sealed with noncombustible seals. The southeast and southwest corner rooms of this elevation (Fire Zones 11.2.1 and 11.2.2 which are part of Fire Area RB2-II) are separated from Fire Zone 1.1.2.1 by a minimum 2-foot 6-inch thick concrete wall which contains penetrations sealed with noncombustible seals and watertight doors. This fire zone also borders the inerted drywell, Fire Zone 1.2.2. This barrier is described in Section 4.3.

Safe Shutdown Equipment The safe shutdown equipment located in this fire zone is listed below:

LPCI Discharge Valve to Suppression Pool MO2-1501-13B LPCI Valve to Spray Ring Header MO2-1501-18B LPCI Valve to Spray Ring Header MO2-1501-19B LPCI Valve to Suppression Pool MO2-1501-20B LPCI Valve to Suppression Pool MO2-1501-21B LPCI Valve to Suppression Pool MO2-1501-38B HPCI Valve MO2-2301-5 Shutdown Cooling Pump Common Header Discharge MO2-1001-5A and MO2-1001-5B Valves RBCCW Outboard Isolation Valves MO2-3702 and MO2-3703 LPCI Valves to Core MO2-1501-22A and MO2-1501-22B 4.2-1

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone shares linear thermal detectors with fire zones 11.2.1 and 11.2.2 in and under the cable trays which alarm locally and in the control room. The fire zone has hose stations and portable extinguishers available for fire brigade use in the event of a fire. Fire extinguishers and hose stations are also located in Fire Zones 11.2.1 and 11.2.2. The alternate power and control cables to the inboard isolation condenser valves are routed through this zone and are protected by a 1-hour rated wrap (see Figure B-1 of the Exemption Requests, F.P.R. Volume 4).

Design-Basis Fire This fire zone is part of Fire Area RB2-II. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.2 of the Safe Shutdown Report (F.P.R.

Volume 2).

The redundant power and control cables for the inboard isolation condenser valves are routed through this zone and are protected by a 1-hour fire wrap. Exemption Request Section 3.7 (F.P.R. Volume 4) provides justification for this protection.

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression have not been provided. This is justified in Subsection 3.5 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.1.2.1 shares a boundary with Fire Areas RB2-I, RB3-II, TB-I and TB-II. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Areas RB2-I, RB3-II, TB-I and TB-II. The adequacy of these barriers in preventing fire spread is discussed in Section 3.3 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects The safe shutdown equipment located in this zone consists of valves which will not be adversely affected by application of water or leakage of water from floor levels above. Water will collect in the basement floor sump where it will be pumped to the floor drain collector tank for processing by Radwaste.

4.2-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 4.2.2 Reactor Building - Elevation 517 Feet 6 Inches (Fire Zone 1.1.2.2)

This fire zone is shown on the F-3 drawings and Figure 3.3-3.

Fire Barrier Description The north wall separates this fire zone from Fire Zones 8.2.5.A and 8.1 which are part of Fire Area TB-I and Fire Zone 8.2.5.C which is part of Fire Area TB-II and is constructed of minimum 1-foot 0-inch thick reinforced concrete which is 3-hour rated. The east wall adjoins the personnel access area and also forms the exterior. The Isolation Condenser Pumphouse (Fire Zones 18.7.1 and 18.7.2) is located adjacent to the east wall. The wall is minimum 1-foot 0-inch thick reinforced concrete with the portion adjoining the personnel access area and access door being 3-hour rated, and the portion in the vicinity of the Isolation Condenser Pumphouse being 3-hour rated to an exterior exposure fire. The mechanical penetration in the east wall is sealed to a 3-hour rating. The south wall forms the exterior and adjoins the equipment access tunnel and Fire Zone 9.0.C which is part of Fire Area RB-2/3. The wall is a minimum 1-foot 0-inch thick reinforced concrete. The equipment access tunnel has unrated interlocking doors leading to the exterior. The portion of this wall which separates this fire zone from Fire Zone 9.0.C is 3-hour rated and contains a 3-hour rated fire door. The west wall separates this fire zone from Fire Zone 1.1.1.2 which is part of Fire Area RB3-II and is a minimum 2-foot 0-inch thick reinforced concrete 3-hour fire barrier. The access door in this wall is 3-hour rated. The floor separates this fire zone from Fire Zone 1.1.2.1 which is part of Fire Area RB2-II and is a minimum 2-foot 0-inch reinforced concrete with all electrical penetrations sealed. Stairwells are provided in the floor to allow access to Fire Zones 11.2.1 and 11.2.2 which are part of Fire Area RB2-II. The ceiling separates this fire zone from Fire Zone 1.1.2.3 which is part of Fire Area RB2-II and Fire Zone 1.1.2.5.C which is part of Fire Area RB2-I and is constructed of a minimum 1-foot 0-inch thick reinforced concrete. All electrical penetrations through the ceiling are sealed. All mechanical and electrical penetrations which lead to Fire Zone 1.1.2.5.C are sealed to a 3-hour rating. The ceiling contains a 20-foot by 20-foot open equipment hatch. This hatch is open from this elevation to the refueling floor. Two stairwells connect this fire zone to Fire Zone 1.1.2.3.

Fire Zone 1.3.2 which is part of Fire Area RB2-I and Fire Zone 1.2.2 (the inerted drywell) are separated from this fire zone by equivalent 3-hour rated barriers. The barrier between Fire Zone 1.3.2 and 1.1.2.2 is described in subsection 4.1.4. The barrier between Fire Zone 1.2.2 and 1.1.2.2 is described in section 4.3.

Safe Shutdown Equipment The following safe shutdown equipment is located in this fire zone.

480-V MCC 28-1, 29-1, 29-4, 27-7 Drive Water Filter Inlet Valves 2-0301-9A, 2-0301-9B 2-0301-9A, 2-0301-9B LPCI Valve to Core MO2-1501-21B 4.2-3

DRESDEN 2&3 AMENDMENT 16 JUNE 2007 Control Rod Drive Hydraulic Equipment 177 HCUs Reactor Level and Pressure Instrumentation Racks 2202-7 and 2202-8 Reactor Local Level and Pressure Instrumentation LI2-263-151A&B, PI2-263-139A&B Combustible Material and Fire Loadings Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone has complete ionization or photoelectric fire detection. Automatic local water suppression is provided to protect the ACAD air compressors located on top of the drywell access and the mechanical penetration above Fire Zone 1.3.2. Hose stations and fire extinguishers are available for manual fire suppression in the fire zone.

Design-Basis Fire This fire zone is part of Fire Area RB2-II. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.2 of the Safe Shutdown Report.

The redundant divisions of reactor pressure and level instrumentation are present in this fire zone. Separation of this instrumentation is justified in Section 3.6 of the Exemption Requests (F.P.R. Volume 4).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression have not been provided. This is justified in Section 3.5 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.1.2.2 shares a boundary with Fire Areas RB2-I, RB3-II, RB-2/3, TB-I and TB-II. A fire is prevented from spreading into these fire areas by 3-hour fire barriers. The bus ducts penetrating the fire barriers between this fire zone and Fire Zones 1.1.1.2 (Fire Area RB3-II) and 8.2.5.A (Fire Area TB-III) do not have interior seals. This is justified in Section 9.1 of the Exemption Requests (F.P.R. Volume 4). The Standby Gas Treatment System pipe penetrating the fire barrier separating Fire Zone 1.1.2.2 and Fire Zone 8.2.5.6 (Fire Area TB-II) is not provided with a fire damper. This is justified in Section 9.2 of the Exemption Requests (F.P.R.

Volume 4).

Fire Suppression Effects Small suppression systems protecting the drywell instrument air compressors will not release water directly onto safe shutdown equipment. Release of water or CO2 onto equipment in this zone can be tolerated as any adverse effects would be less severe than those determined to be acceptable for a design basis fire. Water runoff would be handled by the floor drainage system in the general area. Panels 28-1, 29-1, 29-4 and 29-7 are mounted on pedestals and their tops are sealed.

4.2-4

DRESDEN 2&3 AMENDMENT 16 JUNE 2007 4.2.3 Reactor Building - Elevation 545 Feet 6 Inches (Fire Zone 1.1.2.3)

This fire zone is shown on the F-4 drawings and Figure 3.3-4.

Fire Barrier Description The north wall separates this fire zone from Fire Zone 8.2.6.B which is part of Fire Area TB-I and Fire Zone 8.2.6.C which is part of Fire Area TB-II and is minimum 1-foot 0-inch thick reinforced concrete. All penetrations in this wall are sealed except for an HVAC duct which does not contain a fire damper. The east and south walls are minimum 1-foot 0-inch thick reinforced concrete and are exterior walls. The west wall separates this fire zone from Fire Zone 1.1.1.3 which is part of Fire Area RB3-II and is a minimum 1-foot 0-inch thick reinforced concrete 3-hour fire barrier. The door contained in this wall is 3-hour rated. The floor separates this fire zone from Fire Zone 1.3.2 which is part of Fire Area RB2-I and Fire Zone 1.1.2.2 which is part of Fire Area RB2-II. The floor is minimum 1-foot 0-inch thick reinforced concrete with electrical penetrations sealed. The mechanical penetrations in the portion of the floor above Fire Zone 1.3.2 are 3-hour rated except for the penetration containing the HVAC duct without fire dampers and the three pipes. The top of this penetration is covered with a steel plate. The ceiling separates this fire zone from Fire Zone 1.1.2.4 which is part of Fire Area RB2-II and is minimum 3-foot 0-inch thick reinforced concrete with electrical penetrations sealed, except underneath switchgear.

Both the floor and the ceiling contain a 20-foot by 20-foot open equipment hatch which connects the 517-foot 6-inch elevation to the 613-foot 0-inch elevation. Two stairwells are present on this floor which allow access to other elevations. This fire zone is separated from Fire Zone 1.2.2 (inerted drywell) and Fire Zone 1.1.2.5.C, which is part of Fire Area RB2-I, by 3-hour rated barriers. The barriers to these Fire Zones are described in section 4.3 and subsection 4.1.3 respectively. The regenerative and nonregenerative heat exchanger rooms are located within this fire zone but are separated from it by unrated concrete and concrete block walls which contain unrated doors.

Safe Shutdown Equipment The safe shutdown equipment located in this fire zone is as follows:

4-kV SWGR 23-1, 24-1 Shutdown Cooling Pump Discharge Valves MO2-1001-4A, MO2-1001-4B, and MO2-1001-4C Reactor Building Closed Cooling Water 2A-3701, 2B-3701 (RBCCW) Pumps RBCCW HXs 2A-3702, 2B-3702, 2C-3702 Shutdown Cooling HXs 2A-1003, 2B-1003, 2C-1003 RBCCW Discharge Valve MO2-3701 Reactor Water Cleanup (RWCU) Valves MO2-1201-2, MO2-1201-3 PCV-2-1217 4.2-5

DRESDEN 2&3 AMENDMENT 16 JUNE 2007 Valve Allowing Service Water Flow Through TCV-2-3904A, TCV-2-3904B, RBCCW HXs TCV-2-3904C Valve Connecting Shutdown Cooling HXs to MO2-3704 RBCCW System LPCI Valve to Containment Spray MO2-1501-27B, MO2-1501-28B Reactor Pressure and Level Instrumentation Rack 2202-5 and 2202-6 Reactor Local Pressure and Level PI2-263-60A&B, LI2-263-59A&B Instrumentation Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone has complete ionization or photoelectric fire detection which alarms locally and in the control room with the exception of the regenerative and nonregenerative heat exchanger rooms which have no detection capability. The fire zone is also equipped with manual hose stations and fire extinguishers for manual fire suppression. A wet pipe sprinkler is installed over the HVAC duct and pipe penetration leading to Fire Zone 1.3.2 (see Figure B-3 of the Exemption Requests, F.P.R., Volume 4 ).

A water shield is installed over the 4-kV switchgear located in this fire zone. Also, the Divisions I and II switchgear are separated by a concrete block wall.

Design-Basis Fire This fire zone is part of Fire Area RB2-II. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.2 of the Safe Shutdown Report (F.P.R.

Volume 2).

Redundant divisions of reactor pressure and level instrumentation are present in this fire zone.

Separation of this instrumentation is justified in Section 3.6 of the Exemption Requests (F.P.R.

Volume 4).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression have not been provided. This is justified in Section 3.5 of the Exemption Requests (F.P.R. Volume 4). The bus duct penetrating the fire barrier between this fire zone and Fire Zone 1.1.1.3 (Fire Area RB3-II) does not have an interior seal.

This is justified in Section 9.1 of the Exemption Requests (F.P.R. Volume 4).

The justification for separation between the redundant cold shutdown equipment, LPCI and RBCCW pumps, is presented in Section 3.8 of the Exemption Requests (F.P.R. Volume 4).

4.2-6

DRESDEN 2&3 AMENDMENT 16 JUNE 2007 Fire Zone 1.1.2.3 shares a boundary with Fire Areas RB2-I, RB3-II, TB-I and TB-II. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Areas RB2-I and TB-I. The adequacy of these barriers in preventing fire spread is discussed in Sections 3.2 and 3.3 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Water discharge onto equipment can be tolerated as any adverse effects would be less severe than those determined to be acceptable for a design-basis fire. Water release could travel down stairs and hatch openings to Fire Zone 1.1.2.2 below. There is the potential for water exposure to redundant instrument racks (2202-5, 2202-6, 2202-7, and 2202-8) in both areas. However, this possibility is extremely remote due to numerous floor drains provided and at least a 40-foot separation distance between hatch openings and instrument racks 2202-7 and 2202-8 in Fire Zone 1.1.2.2. The instrument racks are situated on legs preventing damage from flooding. The wiring from the racks is routed in closed conduit.

A water shield installed over 4-kV Switchgear Panels 23-1 and 24-1, as well as concrete curbs, further reduces the potential for water damage to this equipment.

4.2.4 Reactor Building - Elevation 570 Feet 0 Inches (Fire Zone 1.1.2.4)

This fire zone is shown on the F-5 drawings and Figure 3.3-5.

Fire Barrier Description The north wall separates this fire zone from Fire Zone 8.2.8.A which is part of Fire Area TB-IV and is minimum 1-foot 0-inch thick reinforced concrete. This wall contains an HVAC duct without a damper and a 3-hour rated fire door. All penetrations in the wall are sealed except for the HVAC duct. The east and south walls form the exterior. The west wall separates this fire zone from Fire Zone 1.1.1.4 which is part of Fire Area RB3-II and is minimum 2-foot 0-inch thick reinforced concrete 3-hour rated fire barrier. This wall contains a 3-hour rated fire door.

The floor separates this fire zone from Fire Zone 1.1.2.3 which is part of Fire Area RB2-II and is minimum 3-foot 0-inch thick reinforced concrete. This floor has electrical penetrations sealed, except underneath switchgear. The ceiling separates this fire zone from Fire Zone 1.1.2.5.A which is part of Fire Area RB2-I and Fire Zone 1.1.2.5.D which is part of Fire Area RB2-II and is minimum 1-foot 6-inch thick reinforced concrete. This ceiling has electrical and mechanical penetrations leading to Fire Zone 1.1.2.5.A sealed except for two HVAC ducts, a pipe penetration area and a ladder opening. Also contained in both the ceiling and the floor is an open equipment hatch which connects the 517-foot 6-inch elevation and the 613-foot 0-inch elevation and two stairwells which allow access to other floors. This fire zone is separated from Fire Zone 4.2-7

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 1.2.2 and Fire Zone 1.1.2.5.B which is part of Fire Area RB2-I by 3-hour rated barriers. These barriers are described in section 4.3 and subsection 4.1.2 respectively.

Safe Shutdown Equipment The hot shutdown equipment located in this fire zone is as follows:

125-V dc Reactor Building Distribution Panel 250-V dc MCC 2A 250-V dc MCC 2B 480-V SWGR 28 480-V SWGR 29 There is no cold shutdown equipment located in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures The openings and the HVAC ducts in the ceiling which lead to Fire Zone 1.1.2.5.A are protected from possible fire transmission by automatic thermally activated closed head preaction water curtains or wet pipe sprinklers. This fire zone has complete ionization detection, which alarms locally and in the control room with the exception of the cleanup demineralizer and filter area which have no detection capability. Manual hose stations and fire extinguishers are located in this fire zone for manual fire suppression.

Design-Basis Fire This fire zone is part of Fire Area RB2-II. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.2 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression have not been provided. This is justified in Section 3.5 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.1.2.4 shares a boundary with Fire Areas RB2-I, RB3-II, and TB-IV. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Areas RB2-I and TB-IV. The adequacy of these barriers in preventing fire spread is discussed in Section 3.3 of the Exemption Requests (F.P.R. Volume 4).

4.2-8

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 Fire Suppression Effects Direct release of hose streams onto hot shutdown equipment in this area can be tolerated as any adverse effects would be less severe than those determined to be acceptable for a design-basis fire. Similarly, release of water from piping breaks can be tolerated. Water runoff would be handled by the floor drainage system in the general area. Discharge from fixed water suppression systems installed to protect hatch openings above is protected by the installation of new spray shields.

4.2.5 Reactor Building -Standby Liquid Control Area (Fire Zone 1.1.2.5.D)

This fire zone is shown on the F-6 drawings and Figure 3.3-6.

Fire Barrier Description The north wall separates this fire zone from Fire Zones 8.2.8.B and 8.2.8.C which are part of Fire Area TB-IV and is minimum 1-foot 0-inch thick reinforced concrete. This wall contains an HVAC duct with no fire damper, however all other penetrations are sealed. The east wall forms the exterior and is minimum 1-foot 0-inch thick reinforced concrete. The south wall separates this fire zone from Fire Zone 1.1.2.5.A which is part of Fire Area RB2-I and the inerted drywell, dryer separator storage pool and the fuel storage pool. This wall is minimum 3-foot 0-inch thick reinforced concrete and contains unsealed Mechanical Penetrations and a rated door leading to Fire Zone 1.1.2.5.A with all other penetrations sealed to a 3-hour rating. The west wall separates this fire zone from Fire Zone 1.1.1.5.D which is part of Fire Area RB3-II and is minimum 2-foot 0-inch thick reinforced concrete. This wall has all penetrations sealed. The floor separates this fire zone from Fire Zone 1.1.2.4 which is part of Fire Area RB2-II and is minimum 1-foot 6-inch thick reinforced concrete. This floor has electrical penetrations sealed and contains removable slabs and a stairwell leading to Fire Zone 1.1.2.4. The ceiling separates this fire zone from Fire Zone 1.1.2.6 which is part of Fire Area RB2-II and is minimum 1-foot 6-inch thick reinforced concrete. This ceiling has electrical penetrations sealed and contains unsealed hatches and a stairwell leading to Fire Zone 1.1.1.6.

Safe Shutdown Equipment No equipment needed for safe shutdown is located in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures There is local ionization detection over the standby liquid control system pumps that alarms locally and in the control room. Manual suppression is in the form of manual hose stations and 4.2-9

DRESDEN 2&3 AMENDMENT 15 JUNE 2005 fire extinguishers are present in this fire zone (see Figure B-5 of the Exemption Requests, F.P.R.,

Volume 4 ).

Design-Basis Fire This fire zone is part of Fire Area RB2-II. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.2 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression have not been provided. This is justified in Section 3.5 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.1.2.5.D shares a boundary with Fire Areas RB2-I, RB3-II, TB-IV and the drywell. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barrier separates this fire zone from Fire Area TB-IV and RB2-I. The adequacy of these barriers in preventing fire spread is discussed in Section 3.3 of the Exemption Requests (F.P.R. Volume 4) and EC 353102.

Fire Suppression Effects Piping breaks or use of manual hose would not affect safe shutdown as no hot shutdown equipment is located in this zone. Water runoff would be handled by the floor drainage system in the general area.

4.2.6 Refuel Floor (Fire Zone 1.1.2.6/1.1.1.6)

This fire zone is shown on the F-7 drawings and Figure 3.3-7.

Fire Barrier Description The Unit 2 (Fire Zone 1.1.2.6) and the Unit 3 (Fire Zone 1.1.1.6.) refueling floors are not separated from each other by any wall or fire barrier. The north wall of the refueling floor separates this fire zone from Fire Area TB-IV and the exterior and is minimum 1-foot 0-inch thick reinforced concrete 3-hour rated fire barrier from plant elevation 613-feet 0-inch to elevation 622-feet 0-inch. Above elevation 622-feet 0-inch, the wall is constructed of steel siding supported by unprotected steel columns. The south, east, and west walls of the refueling floor are made of unprotected steel siding supported by unprotected steel columns. The floor of the refueling floor is the ceiling of Fire Zones 1.1.2.5.A and 1.1.2.5.D. The ceiling of Fire Zone 1.1.2.5.D is minimum 1-foot 6-inch reinforced concrete. The portion of the floor which acts as a ceiling of Fire Zone 1.1.2.5.A has unsealed penetrations which include a 20-foot by 20-foot equipment hatch, HVAC duct penetrations and a stairwell which is open between Fire Zones 1.1.2.6 and 1.1.2.5.A. The roof is a Class II metal roof deck of built-up roofing over 1-inch rigid insulation supported by exposed structural steel. The Unit 3 portion of this fire zone is discussed in Subsection 4.5.6 of this report.

4.2-10

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 Safe Shutdown Equipment There is no safe shutdown equipment located in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone has manual suppression in the form of manual hose stations and fire extinguishers.

The stairwell, equipment hatch, and HVAC ducts leading from this fire zone to Fire Zone 1.1.2.5.A are protected to an equivalent 3-hour level of protection by an automatic thermally activated closed head preaction water curtain or wet pipe sprinklers.

Design-Basis Fire This fire zone contains no safe shutdown equipment, has a low fire loading, and the hot and cold shutdown paths, normal loss of offsite power shutdown path A and shutdown cooling, remain free of fire damage as a result of a fire in this zone. The lack of a 3-hour barrier between Fire Zones 1.1.2.6 and 1.1.2.5.A is justified in Exemption Requests Section 3.3 (F.P.R. Volume 4).

The lack of complete suppression and detection is justified in Section 3.5 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Piping breaks or use of manual hose would not affect safe shutdown as no hot shutdown equipment is located in this zone. Water runoff would be handled by the floor drainage system in the general area although these drains can be controlled by valves. Straight stream nozzles are provided for stand pipes in this zone to eliminate the remote possibility of achieving criticality as a result of inadvertent application of a fog stream to new fuel.

4.2.7 LPCI Pump Room - Division II (Fire Zone 11.2.1)

This fire zone is shown on the F-2 drawings and Figure 3.3-2.

Fire Barrier Description The northeast wall separates this fire zone from Fire Zone 1.1.2.1 which is part of Fire Area RB2-II and is minimum 2 foot 6-inch thick reinforced concrete. This wall contains an unrated door and electrical penetrations through the wall are sealed with noncombustible seals. The south wall forms the exterior and is minimum 1-foot 6-inch thick reinforced concrete. The west wall separates this fire zone from Fire Zone 11.2.3 which is part of Fire Area RB-2/3 and Fire Zone 11.1.2 which is part of Fire Area RB3-II and is minimum 3-foot 0-inch thick reinforced concrete 4.2-11

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 This wall contains a rated fire door and has all penetrations sealed except for an HVAC duct leading to Fire Zone 11.2.3 without a fire damper. The floor is the basement and is minimum 2-foot 6-inch thick reinforced concrete. The ceiling separates this fire zone from Fire Zone 1.1.2.2 which is part of Fire Area RB2-II and is minimum 2-foot 0-inch thick reinforced concrete. This ceiling has electrical penetrations sealed and contains a stairwell leading to Fire Zone 1.1.2.2.

Safe Shutdown Equipment The following safe shutdown equipment is located in this fire zone.

HPCI Valve MO2-2301-36 LPCI Emergency Air Cooler 2-5746B LPCI Pump 2C-1502 LPCI Pump 2D-1502 LPCI Valve MO2-1501-11B LPCI Valve MO2-1501-32B LPCI Valve MO2-1501-3B LPCI Valve MO2-1501-5C LPCI Valve MO2-1501-5D Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone shares linear thermal fire detection with fire zones 11.2.2 and 1.1.2.1, which alarm locally and in the control room. Manual suppression in the form of hose stations and fire extinguishers is available in this fire zone.

Design-Basis Fire This fire zone is part of Fire Area RB2-II. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.2 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 3.5 of the Exemption Requests (F.P.R. Volume 4).

The justification for separation between the redundant cold shutdown equipment, LPCI and RBCCW pumps, is presented in Section 3.8 of the Exemption Requests (F.P.R. Volume 4).

4.2-12

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 Fire Zone 11.2.1 shares a boundary with Fire Areas RB-2/3 and RB3-II. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barrier separates this fire zone from Fire Area RB-2/3. The adequacy of these barriers in preventing fire spread is discussed in Section 3.3 of the Exemption Requests (F.P.R. Volume 4).

The Standby Gas Treatment System pipe which penetrates the fire barrier separating Fire Zone 11.2.1 from Fire Zone 11.2.3 (Fire Area RB-2/3) is not provided with a fire damper. This is justified in Section 9.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Any adverse effects on hot shutdown equipment by water discharge would be less severe than those determined to be acceptable for a design basis fire. Damage to valves and pumps by water discharge would be negligible. Water removal would be accomplished by drainage to the Reactor Building sump where it would be pumped to the floor drain collection tank for processing by Radwaste.

4.2.8 LPCI Pump Room - Division I (Fire Zone 11.2.2)

This fire zone is shown on the F-2 drawings and Figure 3.3-2.

Fire Barrier Description The northwest wall separates this fire zone from Fire Zone 1.1.2.1 which is part of Fire Area RB2-II and is minimum 3-foot 6-inch thick reinforced concrete. This wall contains an unrated door and electrical penetrations through this wall are sealed. The east and south walls are minimum 3-foot 0-inch thick reinforced concrete exterior walls. The floor is the basement of the plant and is minimum 2-foot 6-inch thick reinforced concrete. The ceiling separates this fire zone from Fire Zone 1.1.2.2 which is part of Fire Area RB2-II and is minimum 2-foot 0-inch thick reinforced concrete. This ceiling has sealed electrical and unsealed mechanical penetrations. A stairwell is located in this fire zone leading to Fire Zone 1.1.2.2.

Safe Shutdown Equipment There is no safe shutdown equipment located in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone shares linear thermal detection with fire zones 11.2.1 and 1.1.2.1, which alarms locally and in the control room. Manual suppression in the form of hose stations and fire extinguishers is available in this fire zone.

4.2-13

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Design-Basis Fire This fire zone is part of Fire Area RB2-II. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.2 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 3.5 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.1.2.1 does not share a boundary with any other fire area, therefore, a fire in this zone cannot impact other fire areas.

Fire Suppression Effects Water release would not affect safe shutdown as no hot shutdown equipment is located in this zone. Water removal would be accomplished by drainage to the Reactor Building sump where it will be pumped to the floor drain collector tank for processing by Radwaste.

4.2-14

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 4.3 Primary Containment - Unit 2 (Fire Zone 1.2.2)

This fire zone is shown on the F-2, F-3, F-4, F-5, and F-6 drawings and Figures 3.3-2, 3.3-3, 3.3-4, 3.3-5, and 3.3-6.

Fire Barrier Description The walls of the drywell, up to Elevation 606 feet 0 inch, are composed of curved structural concrete and have a minimum thickness of 4 feet 0 inch. The walls of the drywell which adjoin the refuel pool and the dryer-separator storage pool are composed of 4-foot 0-inch thick structural concrete and steel plate lined plugs. These walls extend from Elevation 606 feet 0 inch down to 588 feet 8-1/2 inches on the fuel storage pool side and down to 592 feet 6 inches on the dryer-separator storage pool side. The floor of the drywell is an 8-inch separate concrete finish on 17 feet 4 inches of structural concrete and layers of steel plate lining. The floor contains drains which run to the Reactor Building equipment drain tank. The drywell head is covered by three 2-foot thick reinforced concrete keyed layers for the reactor shield plug. In addition to this general structure, there is one removable concrete shield plug equipment door and one man opening (personnel airlock). The walls of the personnel airlock are 1-foot 6-inch thick structural concrete. The floor is 2-foot 6-inch reinforced concrete with floor drains. The ceiling consists of 1-foot 6-inch reinforced concrete.

The primary containment boundaries are accepted as 3-hour rated firewalls without test. The primary containment electrical penetrations are typical double-gasketed testable penetrations.

Safe Shutdown Equipment The following safe shutdown equipment is located in the drywell:

Recirculation Loop Pumps 2A-202, 2B-202 Control Rod Drive Units 2-201-20 Shutdown Cooling Pump Suction Valves MO2-1001-1A, MO2-1001-1B Recirculation Loop Valves MO2-0202-4A, MO2-0202-4B MO2-0202-5A, MO2-0202-5B RBCCW Inboard Isolation Valve MO2-3706 Target Rock Valve 2-203-3A Electromatic Relief Valves 2-203-3B, 2-203-3C, 2-203-3D, 2-203-3E Main Steam Isolation Valves 2-203-1A, 2-203-1B, 2-203-1C, 2-203-1D Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

4.3-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Fire Protection Criteria and Measures Fire protection requirements for the primary containment were recognized in the plant design. In the primary containment, ESS cables are completely enclosed in solid steel cable trays. The drywell is inerted with nitrogen during operation to preclude the spread of fire along cables.

No specific water damage protection is afforded to equipment within the primary containment.

Design-Basis Fire A design-basis fire is not postulated for the drywell since the drywell atmosphere is inerted during normal reactor operation. Managerial procedures and controls are enforced during refueling and maintenance operations to control any additional hazards that would be introduced to the primary containment area.

Fire Suppression Effects No fire suppression systems or piping exist in this area which is inerted with nitrogen. Therefore, damaging effects of water release are not contemplated.

4.3-2

DRESDEN 2&3 AMENDMENT 15 JUNE 2005 4.4 Reactor Building Fire Area RB3-I The fire zones which are included in this fire area are:

1.1.1.5.A 1.1.1.5.B 1.1.1.5.C 1.4.1 4.4.1 Isolation Condenser Area (Fire Zone 1.1.1.5.A)

This zone is shown on the F-6 drawings and Figure 3.3-6.

Fire Barrier Description The north wall separates this fire zone from Fire Zone 1.1.1.5.D which is part of Fire Area RB3-II and the dryer-separator and fuel storage pools and the drywell. This Wall is a minimum 3-foot thick reinforced concrete and contains two HVAC ducts to the pools, which do not contain fire dampers, unsealed Mechanical Penetrations and a 3-hour rated fire door. The east wall separates this fire zone from Fire Zone 1.1.2.5.A which is part of Fire Area RB2-I and is minimum 2-foot 0-inch thick reinforced concrete 3-hour rated barrier. This wall contains a 3-hour rated fire door.

The south and west walls are minimum 1-foot 0-inch thick reinforced concrete exterior walls.

The floor separates this fire zone from Fire Zone 1.1.2.4 which is part of Fire Area RB3-II and is minimum 1-foot 0-inch thick reinforced concrete. This floor contains HVAC ducts with no fire dampers, an unsealed ladder hatch cover and an open 20-foot by 20-foot equipment hatch. A grating in the center of the floor connects this fire zone to Fire Zone 1.1.1.5.B which is part of Fire Area RB3-I. The ceiling separates this fire zone from Fire Zone 1.1.1.6 which is part of Fire Area RB3-II and is minimum 1-foot 6-inch thick reinforced concrete. This ceiling contains unsealed mechanical penetrations, HVAC ducts with no fire dampers and an open 20-foot by 20-foot equipment hatch.

Safe Shutdown Equipment The hot shutdown equipment located in this fire zone is as follows:

Unit 3 Isolation Condenser 3-1302 Isolation Condenser Valves MO3-1301-10, MO3-4102 AO3-1301-17, AO3-1301-20 3-1300-202, 3-1300-203 3-1301-39, 3-1301-40, 3-1301-16 Isolation Condenser Sightglass 3-1301-644 There is no equipment or cabling associated with cold shutdown located in this fire zone.

4.4-1

DRESDEN 2&3 AMENDMENT 15 JUNE 2005 Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone has a complete ionization detection system, which alarms locally and in the control room. The large unsealed openings in floor and ceiling are protected by automatic thermally actuated closed head preaction water curtains or wet pipe sprinklers. There are two manual hose stations located in this fire zone. There is also a hose station located in Fire Zone 1.1.1.5.D near the entrance to this fire zone.

Design-Basis Fire This fire zone is part of Fire Area RB3-I. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.4 of the Safe Shutdown Report (F.P.R.

Volume 2).

Complete detection and suppression has not been provided in this zone. This is justified in Section 4.3 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.1.1.5.A shares a boundary with Fire Areas RB2-I, RB3-II and the inerted drywell. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barrier separates this fire zone from Fire Area RB3-II. The adequacy of these barriers in preventing fire spread is discussed in Section 4.2 of the Exemption Requeests (F.P.R.

Volume 4) and EC 353102.

Fire Suppression Effects Since the only hot shutdown equipment in this zone consists of the isolation condenser and various valves, operation of fixed or manual water suppression equipment, as well as piping leaks, should not affect safe shutdown. Any adverse effects on hot shutdown equipment would be less severe than those determined to be acceptable for a design-basis fire. Sprinkler and hose stream runoff would be handled by the floor drainage system as well as open hatches, grating, and stairs to the floor below. Important electrical equipment located near the hatch opening on the floor below is protected by spray shields.

4.4.2 Isolation Condenser Pipe Chase (Fire Zone 1.1.1.5.B)

This zone is shown on the F-5 drawings and Figure 3.3-5.

4.4-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Fire Barrier Description The north wall of this fire zone is shared with the inerted drywell and is a minimum 4-foot 0-inch thick reinforced concrete fire barrier. The south, east, and west walls separate this fire zone from Fire Zone 1.1.1.4 which is part of Fire Area RB3-II and are 3-hour rated fire barriers constructed of 1-foot 0-inch thick reinforced concrete. Access to this fire zone is gained through a Class "A" rated fire door located in the west wall. The floor and ceiling separate this fire from Fire Zones 1.1.1.5.C and 1.1.1.5.A which are part of Fire Area RB3-I. They are made of open grating supported by unprotected steel. There is an access ladder which runs through the zone for additional access.

Safe Shutdown Equipment The following is the only safe shutdown equipment located in this fire zone.

Isolation Condenser Valve MO3-1301-2 Combustible Material and Fire Loadings Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone does not contain either fire detection capabilities or automatic fixed-suppression systems. A manual hose station, located outside this zone in Fire Zone 1.1.1.3, is available for manual suppression in the event of a fire in Fire Zone 1.1.1.5.B. A fire in this fire zone would be detected by the ionization detection located at the ceiling of Fire Zone 1.1.1.5.A above the open grating (see Figures B-4 and B-5 of the Exemption Requests, F.P.R., Volume 4 ).

Design-Basis Fire This fire zone is part of Fire Area RB3-I. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.4 of the Safe Shutdown Report (F.P.R.

Volume 2).

Complete detection and suppression has not been provided in this zone. This is justified in Subsection 4.3 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.1.1.5.B shares a boundary with Fire Areas RB3-II and the drywell. A fire is prevented from spreading into these fire areas by 3-hour fire barriers.

4.4-3

DRESDEN 2&3 AMENDMENT 15 JUNE 2005 Fire Suppression Effects Since the only safe shutdown equipment in this zone consists of valve MO3-1301-2, piping breaks or the operation of the manual hose equipment should not affect safe shutdown. Adverse effects on hot shutdown equipment would be less severe than those determined to be acceptable for a design-basis fire. Water runoff would drain through metal gratings to the floor below.

4.4.3 Isolation Condenser Pipe Chase (Fire Zone 1.1.1.5.C)

This fire zone is shown on the F-4 drawings and Figure 3.3-4.

Fire Barrier Description The north wall of this fire zone is shared with the inerted drywell and is constructed of minimum 4-foot 0-inch thick reinforced concrete. The penetrations in this 3-hour rated fire barrier are sealed. The south, east, and west walls separate this fire zone from Fire Zone 1.1.1.3 which is part of Fire Area RB3-II and are 3-hour (or equivalent) rated fire barriers constructed of 2-foot 0-inch thick reinforced concrete. The East Wall contains unsealed Mechanical Penetrations.

Access to this fire zone is gained through a class "A" rated fire door located in the west wall. The floor separates this fire zone from Fire Zone 1.1.1.2 which is part of Fire Area RB3-II and is a minimum 1-foot 0-inch thick reinforced concrete, 3-hour rated fire barrier. The ceiling separates this fire zone from Fire Zone 1.1.1.5.B which is part of Fire Area RB3-I and consists of open grating.

Safe Shutdown Equipment The following is the only safe shutdown equipment located in this fire zone.

Isolation Condenser Valve MO3-1301-3 Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone does not contain either fire detection capabilities or automatic fixed suppression systems. A manual hose station, located outside this fire zone in Fire Zone 1.1.1.3, is available for manual fire suppression in the event of a fire in Fire Zone 1.1.1.5.C. A fire in this zone would be detected with the ceiling level ionization detection located in Fire Zone 1.1.1.5.A (see Figures B-3 and B-5 of the Exemption Requests, F.P.R., Volume 4).

4.4-4

DRESDEN 2&3 AMENDMENT 15 JUNE 2005 Design-Basis Fire This fire zone is part of Fire Area RB3-I. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.4 of the Safe Shutdown Report (F.P.R.

Volume 2).

Complete detection and suppression has not been provided in this zone. This is justified in Section 4.3 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.1.1.5.C shares a boundary with Fire Areas RB3-II and the drywell. A fire is prevented from spreading into these fire areas by 3-hour (or Equivalent) fire barriers. The adequacy of these barriers in preventing fire spread is justified in EC 353102.

Fire Suppression Effects Since the only safe shutdown equipment in this zone consists of valve MO3-1301-3, piping breaks or the operation of the manual hose equipment should not affect safe shutdown. Adverse effects on hot shutdown equipment would be less severe than those determined to be acceptable for a design-basis fire. Water would run to the personnel access door where it could be transferred to the floor drainage system in Fire Zone 1.1.1.3.

4.4.4 TIP Room (Fire Zone 1.4.1)

This fire zone is shown on the F-3 drawings and Figure 3.3-3.

Fire Barrier Description The north wall separates this fire zone from Fire Zone 8.2.5.C which is part of Fire Area TB-II and is minimum 2-foot 0-inch thick reinforced concrete rated fire barrier. The east and south walls separate this fire zone from Fire Zone 1.1.1.2 which is part of Fire Area RB3-II and is minimum 2-foot 0-inch thick reinforced concrete rated fire barriers. The east wall contains a 3-hour rated fire door. The west wall separates this fire zone from Fire Zone 1.2.1 (drywell) and the main steam pipe area and is minimum 4-foot 0-inch thick reinforced concrete. This wall contains an unsealed mechanical penetration leading to the steam tunnel. The floor separates this fire zone from Fire Zone 1.1.1.1 which is part of Fire Area RB3-II and is minimum 2-foot 0-inch thick reinforced concrete. This floor contains unsealed mechanical penetrations. The ceiling separates this fire zone from the Fire Zone 1.1.1.3 which is part of Fire Area RB3-II and is minimum 2-foot 0-inch thick reinforced concrete. This ceiling is a 3-hour rated fire barrier.

Safe Shutdown Equipment The following safe shutdown equipment is located in this fire zone:

Inboard Isolation Condenser Valve Transfer Panel 2203-75 4.4-5

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 The redundant power and control feeds for the inboard isolation condenser valves are also routed through this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Measures and Criteria The fire zone is provided with complete photoelectric detection, which alarms locally and in the control room. This fire area does not contain fixed suppression. A hose station is located in adjacent Fire Zone 1.1.1.2 (see Figure B-2 of the Exemption Requests, F.P.R., Volume 4 ).

Design-Basis Fire This fire zone is part of Fire Area RB3-I. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.4 of the Safe Shutdown Report (F.P.R.

Volume 2).

Complete detection and suppression have not been provided in this zone. This is justified in Section 4.3 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.4.1 shares a boundary with Fire Areas RB3-II, TB-II and the inerted drywell. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Area RB3-II. The adequacy of these barriers in preventing fire spread is discussed in Section 4.8 of the Exemption Requests (F.P.R.

Volume 4).

Fire Suppression Effects Use of manual hose in this fire zone would not affect safe shutdown as only cabling is located here, and these cables would not be adversely affected by water. Water runoff would be handled by the floor drainage system.

4.4-6

DRESDEN 2&3 AMENDMENT 14 JUNE 2003 4.5 Reactor Building Fire Area RB3-II Following is a list of fire zones in Fire Area RB3-II.

1.1.1.1 1.1.1.2 1.1.1.3 1.1.1.4 1.1.1.5.D 1.1.1.6/1.1.2.6 1.3.1 11.1.1 11.1.2 4.5.1 Reactor Building Torus Basement (Fire Zone 1.1.1.1)

This fire zone is shown on the F-2 drawings and Figure 3.3-2.

Fire Barrier Description The north wall is a minimum 1-foot 0-inch thick reinforced concrete exterior wall. The east wall separates this fire zone from Fire Zone 1.1.2.1 which is part of Fire Area RB2-II and is minimum 2-foot 0-inch thick reinforced concrete. This wall has all penetrations sealed to a 3-hour rating except for an unrated door between the Unit 2 and Unit 3 equipment drain tank rooms. The south wall separates this fire zone from Fire Zones 11.1.1 and 11.1.2 which are part of Fire Area RB3-II and Fire Zone 11.1.3 which is part of Fire Area RB-2/3 and is minimum 3-foot 0-inch thick reinforced concrete. The portion of this wall adjoining Fire Zone 11.1.3 is 3-hour rated. The west wall is a minimum 1-foot 0-inch thick reinforced concrete exterior wall. The floor is the basement of the plant and is minimum 2-foot 6-inch thick reinforced concrete. The ceiling separates this fire zone from Fire Zones 1.1.1.2 and 1.3.1 which are part of Fire Area RB3-II, Fire Zone 1.4.1 which is part of Fire Area RB3-I, Fire Zone 8.2.5.C which is part of Fire Area TB-II and Fire Zone 8.2.5.E which is part of Fire Area TB-III and is minimum 2-foot 0-inch thick reinforced concrete. This ceiling contains sealed electrical penetrations and unsealed mechanical penetrations.

This fire zone borders the inerted drywell. This barrier is described in Section 4.6.

Safe Shutdown Equipment The safe shutdown equipment located in this fire zone is listed below.

LPCI Discharge Valve to Suppression Pool MO3-1501-13B LPCI Valve to Spray Ring Header MO3-1501-18B LPCI Valve to Spray Ring Header MO3-1501-19B LPCI Valve to Suppression Pool MO3-1501-20B LPCI Valve to Suppression Pool MO3-1501-21B LPCI Valve to Suppression Pool MO3-1501-38B HPCI Valve MO3-2301-5 and MO3-2301-36 Shutdown Cooling Pump Common Header Discharge MO3-1001-5A and MO3-1001-5B Valves 4.5-1

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 RBCCW Outboard Isolation Valves MO3-3702 and MO3-3703 LPCI Valve to Core MO3-1501-22B Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone shares linear thermal detectors with fire zones 11.1.1 and 11.1.2 in and under the cable trays, which alarm locally and in the control room. The fire zone has hose stations and portable extinguishers available for manual fire suppression in the event of a fire. Fire extinguishers and hose stations are also located in the LPCI pump rooms. The alternate power and control feeds to the inboard isolation condenser valve are routed in this zone and protected by a 1-hour rated wrap (see Figure B-1 of the Exemption Requests, F.P.R. Volume 4).

Design-Basis Fire This fire zone is part of Fire Area RB3-II. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.5 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 4.4 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.1.1.1 shares a boundary with Fire Areas TB-II, TB-III, RB3-I, and RB2-II. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separates this fire zone from Fire Areas TB-II, TB-III, RB3-I and RB2-II. The adequacy of these barriers in preventing fire spread is discussed in Section 4.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects The safe shutdown equipment located in this zone consists of valves which will not be adversely affected by application of water or leakage of water from floor levels above, water will collect in the basement floor where it will be pumped to the floor drain collector tank for processing by Radwaste.

4.5-2

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 4.5.2 Reactor Building - Elevation 517 Feet 6 Inches (Fire Zone 1.1.1.2)

This fire zone is shown on the F-3 drawings and Figure 3.3-3.

Fire Barrier Description The north wall separates this fire zone from Fire Zone 8.2.5.C which is a part of Fire TB-II and Fire Zone 8.2.5.E which is a part of Fire Area TB-III and is minimum 1-foot 6-inch thick reinforced concrete 3-hour rated fire barrier. The east wall separates this fire zone from Fire Zone 1.1.2.2 which is part of Fire Area RB2-II and is minimum 2-foot 0-inch thick reinforced concrete 3-hour rated fire barrier. This wall contains a 3-hour rated fire door leading to Fire Zone 1.1.2.2. A portion of the south wall separates this fire zone from Fire Zone 9.0.C which is part of Fire Area RB-2/3 and the remaining portion is an exterior wall which is minimum 1-foot 0-inch thick reinforced concrete.

This wall is a 3-hour barrier between this fire zone and Fire Zone 9.0.C. A portion of the west wall separates this fire zone from Fire Zone 8.2.5.E which is part of Fire Area TB-III and the remaining portion is an exterior wall and is minimum 1-foot 0-inch thick reinforced concrete.

This wall is a 3-hour fire barrier between this fire zone and Fire Zone 8.2.5.E. The floor separates this fire zone from Fire Zone 1.1.1.1 which is part of Fire Area RB3-II and is minimum 2-foot 0-inch thick reinforced concrete. This floor contains stairwells leading to the LPCI pump rooms and also contains unsealed mechanical penetrations. The ceiling separates this fire zone from Fire Zone 1.1.1.3 which is part of Fire Area RB3-II and is minimum 1-foot 0-inch thick reinforced concrete. This ceiling contains a stairwell leading to upper elevations, a 20-foot by 20-foot equipment hatch and unsealed mechanical penetrations. This fire zone is separated from Fire Zone 1.4.1, which is part of Fire Area RB3-I, by a 3-hour rated fire barrier and locked closed fire door. This fire zone is separated from Fire Zone 1.3.1, which is part of Fire Area RB3-II, by a 3-hour rated fire barrier and a fire door held open by a magnetic closure device.

The fire door will close upon actuation of the fire detection system. The inerted drywell is separated from this fire zone by substantial concrete barriers.

Safe Shutdown Equipment The following safe shutdown equipment is located in this fire zone:

480-V MCC 38-1, 38-4, 39-1 LPCI Valve to Core MO3-1501-21B Control Rod Drive Hydraulic Equipment 177 HCUs LPCI Valve to Containment Spray MO3-1501-27B, MO3-1501-28B Reactor Pressure and Level Instrumentation Racks 2203-7 and 2203-8 Local Reactor Pressure and Level LI3-263-151A&B Instrumentation LITS-2-263-151A&B PI2-263-139A&B, PI3-263-139A&B 4.5-3

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone has complete ionization fire detection. Automatic local water suppression is provided to protect the ACAD air compressors, which are located on top of the drywell access.

Hose stations and fire extinguishers are available in the fire zone (see Figure B-2 of the Exemption Requests, F.P.P.D.P. Volume 3).

Design-Basis Fire This fire zone is part of Fire Area RB3-II. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.5 of the Safe Shutdown Report (F.P.R.

Volume 2).

The Unit 2 4kV bus duct and the power and control cables to the 2/3 Diesel Generator and its auxiliaries are routed through this fire zone. These cables are being protected by a 1-hour fire wrap as justified in Section 4.7 of the Exemption Requests (F.P.R. Volume 4).

Both Division I and Division II instrument racks are present in the fire zone. Instrumentation readings will still be available in the control room during and after a fire in the zone as justified in Section 4.5 of the Exemption Request (F.P.R. Volume 4).

An alternative shutdown method is to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 4.4 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.1.1.2 shares a boundary with Fire Areas RB3-I, RB2-II, RB-2/3, TB-II, and TB-III.

A fire is prevented from spreading into these fire areas by 3-hour fire barriers. The bus duct penetrating the barriers between this fire zone and Fire Zones 9.0.C (Fire Area RB 2/3), 1.1.2.2 (Fire Area RB2-II) and 8.2.6.E (Fire Area TB-III) does not have interior seals. This is justified in Section 9.1 of the Exemption Requests (F.P.R. Volume 4). The Standby Gas Treatment System pipe which penetrates the fire barrier separating Fire Zone 1.1.1.2 and Fire Zone 8.2.5.C (Fire Area TB-II) is not provided with a fire damper. This is justified in Section 9.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Small suppression systems protecting the drywell instrument air compressors will not release water directly onto safe shutdown equipment. Release of water of CO2 onto equipment in this zone can be tolerated as any adverse effects would be less severe than those determined to be 4.5-4

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 acceptable for a design basis fire. Water runoff would be handled by the floor drainage system in the general area. Panels 38-1, 39-1 and 39-7 are mounted on pedestals and their tops sealed.

4.5.3 Reactor Building-Elevation 545 Feet 6 Inches (Fire Zone 1.1.1.3)

This fire zone is shown on the F-4 drawing and Figure 3.3-4.

Fire Barrier Description The north wall separates this fire zone from Fire Zones 8.2.6.C which is part of Fire Area TB-II and Fire Zone 8.2.6.D which is part of Fire Area TB-III and is minimum 1-foot 0-inch thick reinforced concrete. This wall has all penetrations sealed except for an HVAC duct which does not contain a fire damper. The east wall separates this fire zone from Fire Zone 1.1.2.3 which is part of Fire Area RB2-II and is minimum 1-foot 0-inch thick reinforced concrete. This wall has all penetrations sealed and contains a rated fire door. The south and west walls are minimum 1-foot 0-inch thick reinforced concrete exterior walls. The floor separates this fire zone from Fire Zones 1.1.1.2 and 1.3.1 which are part of Fire Area RB3-II and Fire Zone 1.4.1, which is part of Fire Area RB3-I and is minimum 1-foot 0-inch thick reinforced concrete. This floor contains an unsealed mechanical penetration, a stairwell, and a 20-foot by 20-foot open equipment hatch.

The penetrations to Fire Zones 1.4.1 and 1.3.1 are sealed to 3-hour rating except for a mechanical penetration leading to Fire Zone 1.3.1 which contains an HVAC duct and 3 pipes. The ceiling separates this fire zone from Fire Zone 1.1.1.4 which is part of Fire Area RB3-II and is minimum 1-foot 0-inch thick reinforced concrete. This ceiling has unsealed mechanical penetrations, a 20-foot by 20-foot equipment hatch and a stairwell leading to Fire Zone 1.1.1.4. This fire zone is separated from Fire Zone 1.1.1.5.C which is part of Fire Area RB3-I by 3-hour barriers, as described in Subsection 4.4.3 and from the inerted drywell, Fire Zone 1.2.1, by substantial concrete barriers as described in Section 4.6.

Safe Shutdown Equipment The safe shutdown equipment located in this fire zone is as follows:

4-kV SWGR 33-1, 34-1 Shutdown Cooling Pump Discharge Valves MO3-1001-4A, MO3-1001-4B, and MO3-1001-4C Reactor Water Cleanup (RWCU) Valves MO3-1201-2, MO3-1201-3, PCV-3-1217 Reactor Building Closed Cooling Water 3A-3701, 3B-3701 (RBCCW) Pumps RBCCW HXs 3A-3702, 3B-3702 Shutdown Cooling HXs 3A-1003, 3B-1003, 3C-1003 RBCCW Discharge Valve MO3-3701 Valve Allowing Service Water Flow Through TCV-3-3904A, TCV-3-3904B RBCCW HXs 4.5-5

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Valve Connecting Shutdown Cooling HXs to MO3-3704 RBCCW System Reactor Pressure and Level Instrumentation Racks 2203-5 and 2203-6 Local Reactor Pressure and Level PI3-263-60A&B, LI3-263-72B&C Instrumentation LI3-263-59A&B LI3-263-72A, LI3-633-72D Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone is protected by complete ionization or photoelectric fire detection, which alarms locally and in the control room with the exception of the regenerative and nonregenerative heat exchanger rooms, which have no detection capability. The fire zone is also equipped with manual hose stations and fire extinguishers for manual fire suppression. A water shield is installed over the 4-kV switchgear located in this fire zone. Also, the Division I and II switchgears are separated by a concrete block wall (see Figure B-3 of the Exemption Requests, F.P.R., Volume 4).

Design-Basis Fire This fire zone is part of Fire Area RB3-II. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.5 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 4.4 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.1.1.3 shares a boundary with Fire Area TB-II, TB-III, RB2-II, and RB3-I. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barrier separates this fire zone from Fire Area TB-III and Fire Zone 1.3.1. The adequacy of these barriers in preventing fire spread is discussed in Sections 4.2 and 4.9 of the Exemption Requests (F.P.R. Volume 4). The bus duct penetrating the fire barrier between this fire zone and Fire Zone 1.1.2.3 (Fire Area RB2-II) does not have an interior seal. This is justified in Section 9.1 of the Exemption Requests (F.P.R. Volume 4).

The justification for separation between the redundant cold shutdown equipment, LPCI and RBCCW pumps, is presented in Section 4.10 of the Exemption Requests (F.P.R. Volume 4).

4.5-6

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Both Division I and Division II instrument racks are present in this fire zone. Instrumentation readings will still be available in the control room during and after a fire in this fire zone as justified in Section 4.5 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Water discharge onto equipment can be tolerated as any adverse effects would be less severe than those determined to be acceptable for a design basis fire. Water release could travel down stairs and hatch openings to Fire Zone 1.1.1.2 below. There is the potential for water exposure to redundant instrument racks (2203-5, 2203-6, 2203-7, and 2203-8) in both areas. However, this possibility is extremely remote due to numerous floor drains provided and at least 40 ft.

separation distance between hatch openings and instrument racks 2203-7 and 2203-8 in Fire Zone 1.1.1.2. The instrument racks are situated on legs preventing damage from flooding. The wiring from the racks is routed in closed conduit.

A water shield installed over 4-kV Switchgear Panels 33-1 and 34-1, as well as concrete curbs, further reduces the potential for water damage to this equipment.

4.5.4 Reactor Building - Elevation 570 Feet 0 Inch (Fire Zone 1.1.1.4)

This fire zone is shown on the F-5 drawings and Figure 3.3-5.

Fire Barrier Description The north wall separates this fire zone from Fire Zone 8.2.8.A and 8.2.8.B which are part of Fire Area TB-IV and is minimum 1-foot 0-inch thick reinforced concrete. This wall contains a rated fire door and has all penetrations sealed except for a HVAC duct which does not contain a fire damper. The east wall separates this fire zone from Fire Zone 1.1.2.4 which is part of Fire Area RB2-II and is minimum 2-foot 0-inch thick reinforced concrete 3-hour rated fire barrier. This wall contains a 3-hour rated fire door. The south and west walls are minimum 1-foot 0-inch thick reinforced concrete exterior walls. The floor separates this fire zone from Fire Zone 1.1.1.3 which is part of Fire Area RB3-II and is minimum 1-foot 0-inch thick reinforced concrete. This floor contains unsealed mechanical penetrations, a stairwell leading to Fire Zone 1.1.1.3 and a 20-foot by 20-foot equipment hatch. The ceiling separates this fire zone from Fire Zone 1.1.2.5.D which is part of Fire Area RB3-II, and Fire Zone 1.1.1.5.A which is part of Fire Area RB3-I and is minimum 1-foot 0-inch thick reinforced concrete. The mechanical penetrations leading to Fire Zone 1.1.1.5.A are sealed except for a ladder opening, HVAC ducts with no fire dampers and a 20-foot by 20-foot equipment hatch. The remainder of the ceiling leading to Fire Zone 1.1.1.5.D contains unsealed mechanical penetrations and a stairwell. This fire zone is separated from the fuel storage pool and the inerted drywell by substantial concrete barriers and from Fire Zone 1.1.1.5.B by 3-hour rated barriers as described in Section 4.6.

4.5-7

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Safe Shutdown Equipment The hot shutdown equipment located in this fire zone is as follows:

125-Vdc Reactor Building Distribution Panel 250-Vdc MCC 3A 250-Vdc MCC 3B 480-V SWGR 38 480-V SWGR 39 There is no cold shutdown equipment located in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures The openings in the ceiling which lead to Fire Zone 1.1.1.5.A are protected from possible fire transmission by either wet pipe sprinklers or automatic thermally activated closed head preaction water curtains. This fire zone has complete ionization detection which alarms locally and in the control room with the exception of the cleanup demineralizer and filter area which have no detection capability. Manual hose stations and fire extinguishers are located in this fire zone.

Design-Basis Fire This fire zone is part of Fire Area RB2-II. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.5 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is used to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 4.4 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.1.1.4 shares a boundary with Fire Areas RB2-II, RB3-I and TB-IV. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Areas RB3-I and TB-IV. The adequacy of these barriers in preventing fire spread is discussed in Section 4.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Direct release of hose streams onto hot shutdown equipment in this area can be tolerated as any adverse effects would be less severe than those determined to be acceptable for a design basis 4.5-8

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 fire. Similarly, release of water from piping breaks can be tolerated. Water runoff would be handled by the floor drainage system in the general area. Discharge from fixed water suppression systems installed to protect hatch openings above is protected by the installation of new spray shields.

Switchgear panels 38 and 39 are mounted on pedestals.

4.5.5 Reactor Building -Standby Liquid Control Area(Fire Zone 1.1.1.5.D)

This fire zone is shown on the F-6 drawing and Figure 3.3-6.

Fire Barrier Description The north wall separates this fire zone from Fire Zone 8.2.8.B which is part of Fire Area TB-IV and is minimum 1-foot 0-inch thick reinforced concrete. This wall has all penetrations sealed except for an HVAC duct which does not contain a fire damper. The east wall separates this fire zone from Fire Zone 1.1.2.5.D which is part of Fire Area RB2-II and is minimum 2-foot 0-inch thick reinforced concrete 3-hour rated fire barrier. The south wall separates this fire zone from Fire Zone 1.1.1.5.A which is part of Fire Area RB3-I, the inerted drywell, the fuel storage pool and the drier separator storage pool, and is minimum 3-foot 0-inch thick reinforced concrete. The portion of the wall leading to Fire Zone 1.1.1.5.A is 3-hour (or equivalent) rated, contains unsealed Mechanical Penetrations and contains a 3-hour rated door. The west wall is minimum 1-foot 0-inch thick reinforced concrete exterior wall. The floor separates this fire zone from Fire Zone 1.1.1.4 which is part of Fire Area RB3-II and is minimum 1-foot 0-inch thick reinforced concrete. This floor contains unsealed mechanical penetrations and a stairwell. The ceiling separates this fire zone from Fire Zone 1.1.1.6 which is part of Fire Area RB3-II and is minimum 1-foot 0-inch thick reinforced concrete. This ceiling contains unsealed mechanical penetrations and a stairwell.

Safe Shutdown Equipment There is no equipment needed for safe shutdown located in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures Local ionization detection is provided over the standby liquid control system pumps that alarms locally and in the control room. Manual hose stations and fire extinguishers are present in this fire zone for manual fire suppression.

4.5-9

DRESDEN 2&3 AMENDMENT 15 JUNE 2005 Design-Basis Fire The fire zone is part of Fire Area RB3-II. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.5 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is used to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Subsection 4.4 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.1.1.5.D shares a boundary with Fire Areas TB-IV, RB3-I and RB2-II. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barrier separates this fire zone from Fire Area TB-IV and RB2-II. The adequacy of these barriers in preventing fire spread is discussed in Section 4.2. of the Exemption Requests (F.P.R. Volume 4) and EC 353102.

Fire Suppression Effects Piping breaks or use of a manual hose would not affect safe shutdown as no equipment associated with safe shutdown is located in this zone. Water runoff would be handled by the floor drainage system in the general area.

4.5.6 Refuel Floor (Fire Zone 1.1.1.6/1.1.2.6)

This fire zone is shown on the F-7 drawing and Figure 3.3-7.

Fire Barrier Description This fire zone is not separated from the Unit 2 refuel floor (Fire Zone 1.1.2.6, Fire Area RB2-II) by any wall or fire barrier. The north wall separates this fire zone from Fire Zone 8.2.8.C which is part of Fire Area TB-IV and the exterior, and is minimum 1-foot 0-inch thick reinforced concrete 3-hour rated fire barrier up to elevation 622-feet 0-inch. The remainder of this wall above elevation 622-feet 0-inch as well as the east, south, and west walls are unprotected steel siding supported by unprotected steel columns. The floor separates this fire zone from Fire Zone 1.1.1.5.A which is part of Fire Area RB3-I and Fire Zone 1.1.1.5.D which is part of Fire Area RB3-II, and is minimum 1-foot 0-inch thick reinforced concrete. This floor contains a 20-foot by 20-foot equipment hatch, unsealed HVAC ducts, and mechanical penetrations leading to Fire Zone 1.1.1.5.A, and a stairwell and unsealed mechanical penetrations leading to Fire Zone 1.1.1.5.D. This ceiling is the roof of the Reactor Building and is a Class II metal roof deck of built-up roofing over 1-inch rigid insulation supported on exposed structural steel.

Safe Shutdown Equipment There is no safe shutdown equipment located in this fire zone.

4.5-10

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone has manual suppression equipment available in the form of manual hose stations and fire extinguishers. The equipment hatch and HVAC penetration leading from this fire zone to Fire Zone 1.1.1.5.A are protected to an equivalent 3-hour level of protection by an automatic thermally activated closed head preaction water curtain or wet pipe sprinklers (see Figure B-6 of the Exemption Requests, F.P.R., Volume 4 ).

Design-Basis Fire This fire zone is part of Fire Area RB3-II. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.5 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is used to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Subsection 4.4 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.1.1.6 shares a boundary with Fire Areas RB3-I and TB-IV. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barrier separates this fire zone from Fire Areas RB3-I. The adequacy of these barriers in preventing fire spread is discussed in Section 4.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Piping breaks or use of manual hose would not affect safe shutdown as no equipment associated with safe shutdown is located in this zone. Water runoff would be handled by the floor drainage system in the general area that can be valved out from the floor below. Straight stream nozzles are provided for standpipes in this zone to preclude the remote possibility of achieving criticality as a result of inadvertent application of a fog stream to new fuel.

4.5.7 Reactor Building - Elevation 517 Feet 6 Inches - Shutdown Cooling Pump Room (Fire Zone 1.3.1)

This fire zone is shown on the F-3 drawings and Figure 3.3-3.

Fire Barrier Description The north wall separates this fire zone from Fire Zone 8.2.5.E which is part of Fire Area TB-III and is minimum 1-foot 0-inch thick reinforced concrete 3-hour rated fire barrier. The east wall 4.5-11

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 separates this fire zone from the main steam line area and the inerted drywell and is minimum 4-foot 0-inch thick reinforced concrete. This wall contains an unsealed ventilation louver and pipe penetration leading to the steam tunnel. The west and southwest wall separates this fire zone from Fire Zone 1.1.1.2 which is part of Fire Area RB3-II and is minimum 2-foot 0-inch thick reinforced concrete 3-hour rated fire barrier. This wall contains a 3-hour rated fire door. A magnetic closure device closes the door upon fire detector actuation. The floor separates this fire zone from Fire Zone 1.1.1.1 which is part of Fire Area RB3-II and is minimum 2-foot 0-inch thick reinforced concrete. This floor contains unsealed mechanical penetrations. The ceiling separates this fire zone from Fire Zone 1.1.1.3 which is part of Fire Area RB3-II and is minimum 2-foot 0-inch thick reinforced concrete. This ceiling contains sealed penetrations except for a mechanical opening containing an HVAC duct and 3 pipes. This opening is partially protected by a steel plate.

Safe Shutdown Equipment There is no hot shutdown equipment located in this fire zone. The following cold shutdown equipment is located in this fire zone:

Shutdown Cooling Pumps 3A-1002, 3B-1002, 3C-1002 Shutdown Cooling Pump Suction Valves MO3-1001-2A, MO3-1001-2B, MO3-1001-2C Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone has complete photoelectric fire detection, which alarms locally and in the control room.

Design-Basis Fire This fire zone is part of Fire Area RB3-II. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.5 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is used to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 4.4 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 1.3.1 shares a boundary with Fire Area RB3-II, TB-III and the inerted drywell. A fire is prevented from spreading into these fire areas by equivalent 3-hour fire barriers. The equivalent fire barriers separate this fire zone from Fire Area RB3-II as justified in Section 4.9 of the Exemption Requests (F.P.R. Volume 4).

4.5-12

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Fire Suppression Effects There are no fixed suppression systems or supply piping in this fire zone. Therefore, operation of such a system is not a concern. Use of manual hose is not a concern for hot shutdown as no hot shutdown equipment is located within the room. Hose stream runoff would be handled by the floor drainage system in the general area.

4.5.8 LPCI Pump Room - Division II (Fire Zone 11.1.1)

This fire zone is shown on the F-2 drawings and Figure 3.3-2.

Fire Barrier Description The northeast wall separates this fire zone from Fire Zone 1.1.1.1 which is part of Fire Area RB3-II and is minimum 3-foot 6-inch thick reinforced concrete. This wall contains an unrated door and penetrations sealed with noncombustible seals. The south and west walls are minimum 1-foot 0-inch thick reinforced concrete exterior walls. The floor is the basement of the Reactor Building and is minimum 2-foot 6-inch thick reinforced concrete. The ceiling separates this fire zone from Fire Zone 1.1.1.2 which is part of Fire Area RB3-II and is minimum 2-foot 0-inch thick reinforced concrete. This ceiling contains unsealed mechanical penetrations and a stairwell to Fire Zone 1.1.1.2.

Safe Shutdown Equipment The following safe shutdown equipment is located in this fire zone:

LPCI Emergency Air Cooler 3-5746B LPCI Pump 3C-1502 LPCI Pump 3D-1502 LPCI Valve MO3-1501-11B LPCI Valve MO3-1501-32B LPCI Valve MO3-1501-3B LPCI Valve MO3-1501-5C LPCI Valve MO3-1501-5D Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

4.5-13

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 Fire Protection Criteria and Measures This fire zone shares linear thermal fire detection with fire zones 1.1.1.1 and 11.1.2 that alarms locally and in the control room. Manual suppression in the form of hose stations and fire extinguishers is available in this fire zone for manual fire suppression.

Design-Basis Fire This fire zone is part of Fire Area RB3-II. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.5 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 4.4 of the Exemption Requests (F.P.R. Volume 4).

The justification for separation between the redundant cold shutdown equipment, LPCI and RBCCW pumps, is presented in Section 4.10 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 11.1.1 does not share a boundary with any other fire area, therefore, a fire in this zone cannot impact other fire areas.

Fire Suppression Effects Any adverse effects on hot shutdown equipment by water discharge would be less severe than those determined to be acceptable for a design-basis fire. Damage to valves and pumps by water discharge should be negligible. Water removal would be accomplished by drainage to the Reactor Building sump where it will be pumped to the floor drain collector tank for processing by Radwaste.

4.5.9 LPCI Pump Room - Division I (Fire Zone 11.1.2)

This fire zone is shown on the F-2 drawing and Figure 3.3-2.

Fire Barrier Description The northwest wall separates this fire zone from Fire Zone 1.1.1.1 which is part of Fire Area RB3-II and is minimum 3-foot 6-inch thick reinforced concrete. This wall contains penetrations sealed with noncombustible seals and an unrated door. The east wall separates this fire zone from Fire Zone 11.2.3 which is part of Fire Area RB-2/3 and Fire Zone 11.2.1 which is part of Fire Area RB2-II and is minimum 2-foot 0-inch thick reinforced concrete 3-hour rated fire barrier.

This wall contains a 3-hour rated door leading to Fire Zone 11.2.3. The south wall separates this fire zone from Fire Zones 11.1.3 and 11.2.3 which are part of Fire Area RB-2/3 and is a 3-hour rated fire barrier. This wall contains a 3-hour rated door leading to Fire Zone 11.1.3. The floor is the basement of the Reactor Building and is minimum 2-foot 6-inch thick reinforced concrete.

4.5-14

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 The ceiling separates this fire zone from Fire Zone 1.1.1.2 which is part of Fire Area RB3-II and is minimum 2-foot 0-inch thick reinforced concrete. This ceiling contains unsealed mechanical penetrations and an open stairwell.

Safe Shutdown Equipment There is no safe shutdown equipment located in this fire zone since LPCI Division I is not identified for use in either a hot or cold shutdown path.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone shares linear thermal detection with fire zones 1.1.1.1 and 11.1.1, which alarms locally and in the control room. Manual hose stations are located in this fire zone. Also, fire extinguishers which are located in Fire Zone 1.1.1.1 are available for use in this fire zone for manual fire suppression.

Design-Basis Fire This fire zone is part of Fire Area RB3-II. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.5 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 4.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 11.1.2 shares a boundary with Fire Area RB2-II and RB-2/3. A fire is prevented from spreading into these fire areas by 3-hour fire barriers. The Standby Gas Treatment System pipe which penetrates the fire barrier separating Fire Zone 11.1.2 from Fire Zone 11.1.3 (Fire Area RB-2/3) is not provided with a fire damper. This is justified in Section 9.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Water release would not affect safe shutdown as no equipment required for safe shutdown is located in this zone. Water removal would be accomplished by drainage to the Reactor Building sump where it would be pumped to the floor drain collector tank for processing by Radwaste.

4.5-15

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 4.6 Primary Containment - Unit 3 (Fire Zone 1.2.1)

This fire zone is shown on the F-2, F-3, F-4, F-5, and F-6 drawings and Figures 3.3-2, 3.3-3, 3.3-4, 3.3-5 and 3.3-6.

Fire Barrier Description The walls of the drywell, up to Elevation 606 feet 0 inch, are composed of curved structural concrete and have a minimum thickness of 4 feet 0 inch. The walls of the drywell which adjoin the refuel pool and the dryer-separator storage pool are composed of 4-foot 0-inch thick structural concrete and steel plate lined plugs. These walls extend from Elevation 606 feet 0 inch down to 588 feet 8-1/2 inches on the fuel storage pool side and down to 592 feet 6 inches on the dryer-separator storage pool side. The floor of the drywell is an 8-inch separate concrete finish on 17 feet 4 inches of structural concrete and layers of steel plate lining. The floor contains drains which run to the Reactor Building equipment drain tank. The drywell head is covered with three 2-foot thick reinforced concrete keyed layers for the reactor shield plug.

In addition to this general structure, there is one removable concrete shield plug equipment door and one man opening (personnel airlock). The walls of the personnel airlock are 1-foot 6-Inch thick structural concrete. The floor is 2-foot 6-inch reinforced concrete with floor drains. The ceiling consists of 1-foot 6-inch reinforced concrete.

The primary containment boundaries are accepted as 3-hour rated firewalls without test. The primary containment electrical penetrations are typical double-gasketed testable penetrations.

Safe Shutdown Equipment The following safe shutdown equipment is located in the drywell:

Recirculation Loop Pumps 3A-202, 3B-202 Control Rod Drive Units 3-201-20 Shutdown Cooling Pump Suction Valves MO3-1001-1A, MO3-1001-1B Main Steam Isolation Valves 3-203-1A, 3-203-1B 3-203-1C, 3-203-1D Recirculation Loop Valves MO3-0202-4A, MO3-0202-4B MO3-0202-5A, MO3-0202-5B RBCCW Inboard Isolation Valve MO3-3706 Target Rock Valve 3-203-3A Electromatic Relief Valves 3-203-3B, 3-203-3C 3-203-3D, 3-203-3E 4.6-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures Fire protection requirements for the primary containment were recognized in the plant design. In the primary containment, ESS cables are completely enclosed in solid steel cable trays. The drywell is inerted with nitrogen during operation to preclude the spread of fire along cables.

The primary containment walls are 3-hour fire rated. No specific water damage protection is afforded to equipment within the primary containment.

Design-Basis Fire This inerted drywell constitutes its own fire area. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.6 of the Safe Shutdown Report (F.P.R. Volume 2).

Fire Suppression Effects No fire suppression systems or piping exist in this area which is inerted with nitrogen. Therefore, damaging effects of water release are not contemplated.

4.6-2

DRESDEN 2&3 AMENDMENT 20 JUNE 2015 4.7 Reactor Building Fire Area RB-2/3 This fire area is comprised of the following fire zones.

9.0.C 11.1.3 11.2.3 4.7.1 2/3 Diesel Generator (Fire Zone 9.0.C)

This fire zone is shown on the F-3 drawings and Figure 3.3-3.

Fire Barrier Description The north wall separates this fire zone from Fire Zones 11.1.2 and 1.1.1.2 which are part of Fire Area RB3-II, and Fire Zone 1.1.2.2 which is part of Fire Area RB2-II and is minimum 1-foot 6-inch thick reinforced concrete 3-hour rated fire barrier. This wall contains a 3-hour rated door leading to Fire Zone 1.1.2.2. The east, south and west walls are minimum 3-foot 0-inch thick reinforced concrete exterior walls. The floor separates this fire zone from Fire Zones 11.1.3 and 11.2.3 which are part of Fire Area RB-2/3 and is minimum 3-foot 6-inch thick reinforced concrete. This floor contains sealed penetrations except for the concrete access plugs and the HPCI room access ladder enclosures. The ceiling is minimum 1-foot 0-inch thick reinforced concrete roof with removable concrete plugs.

Safe Shutdown Equipment This fire zone contains the following safe shutdown equipment:

2/3 Diesel Generator 2/3 Diesel Generator Oil Transfer Pump 2/3 Diesel Generator Vent Fan 2/3 Diesel Generator Cooling Water Pump Flow Indicator FI 2/3-3941-882A Unit 2 and 3 Isolation Breakers 4-kV Feed Breakers Unit 2 Control Board for the Inboard Isolation Condenser Valves 2-2202-76 Unit 3 Control Board for the Inboard Isolation Condenser Valves 3-2203-76 2/3 Diesel Generator Cooling Water Pump Flow Element FE 2/3-3941-882 Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

4.7-1

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 Fire Protection Criteria and Measures This fire zone is covered by complete thermal fire detection which alarms locally and in the control room. This fire zone is also protected by a complete, automatic, total flooding CO2 suppression system. In addition, the diesel fuel day tank is also protected by wet pipe sprinkler protection. Hose stations are located on the ground floor of the Unit 2 Reactor Building and a hose station is provided in the vestibule between the Unit 2 Reactor Building and the 2/3 diesel generator room.

Design-Basis Fire This fire zone is part of Fire Area RB-2/3. In the event of a fire in this zone, both hot and cold shutdown can be achieved as discussed in Section 4.7 of the (F.P.R. Volume 2).

Fire Zone 9.0.C shares a boundary with Fire Areas RB2-II and RB3-II. A fire is prevented from spreading into these fire areas by 3-hour fire barriers. The bus duct penetrating the fire barrier between this fire zone and Fire Zone 1.1.1.2 (Fire Area RB2-II) does not contain interior seals.

This is justified in Section 9.1 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Any adverse effects on safe shutdown through the discharge of water or CO2 in this area would be no more severe than those determined to be acceptable for a design-basis fire. Most water runoff would be handled by the floor drainage system which runs to the sumps in the HPCI room but runoff could exit this area directly to the HPCI rooms (Fire Zones 11.1.3 and 11.2.3) located below the Unit 2/3 DG Cell. Both the HPCI and DG areas utilize the same shutdown path, which would not be affected by water in these areas.

Full discharge concentration tests have been conducted to verify actual conditions during system actuation. Pressure vents are not provided for the room.

4.7.2 Unit 3 HPCI Pump Room (Fire Zone 11.1.3)

This fire zone is shown on the F-2 drawings and Figure 3.3-2.

Fire Barrier Description The north wall separates this fire zone from Fire Zone 1.1.1.1 and 11.1.2 which are part of Fire Area RB3-II and is minimum 3-foot 0-inch thick reinforced concrete except for the wall adjoining Fire Zone 11.1.2 which is a 3-hour rated wire mesh wall. This wall contains a 3-hour rated door. The east wall separates this fire zone from Fire Zone 11.2.3 which is part of Fire Area RB-2/3 and is minimum 3-foot 0-inch thick reinforced concrete 3-hour rated fire barrier. The 4.7-2

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 south and west walls are minimum 3-foot 0-inch thick reinforced concrete exterior walls. The floor is the basement of the building and is minimum 2-foot 6-inch thick reinforced concrete.

The ceiling separates this fire zone from Fire Zone 9.0.C which is part of Fire Area RB-2/3 and is minimum 3-foot 6-inch thick reinforced concrete. This ceiling contains unsealed concrete access plugs.

Safe Shutdown Equipment The following safe shutdown equipment is located in this fire zone:

HPCI Auxiliary Oil Pump 3 HPCI Condensate Pump 3 HPCI Condenser Air Exhaust Fan 3 HPCI Cooling Water Pump HPCI Emergency Air Cooler 3 HPCI Emergency Bearing Oil Pump 3 HPCI Oil Tank Heater HPCI Valves MO3-2301-3, MO3-2301-6 MO3-2301-9, MO3-2301-10 MO3-2301-14, MO3-2301-15, MO3-2301-35 Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures The fire zone is protected from fire by an ionization detection system and an automatic preaction water suppression system. The detection system charges the suppression system with water and alarms in the control room. A manual hose station is available in adjacent Fire Zone 11.1.2 (see Figure B-1 of the Exemption Requests, F.P.R., Volume 4 ).

Design-Basis Fire This fire zone is part of Fire Area RB-2/3. In the event of a fire in this zone, both hot and cold shutdown can be achieved as discussed in Section 4.7 of the Safe Shutdown Report (F.P.R.

Volume 2).

Fire Zone 11.1.3 shares a boundary with Fire Area RB3-II. A fire is prevented from spreading into these fire areas by 3-hour fire barriers. The Standby Gas Treatment System pipe which penetrates the fire barrier separating Fire Zone 11.1.3 from Fire Zone 11.1.2 (Fire Area RB3-II) is not provided with a fire damper. This is justified in Section 9.2 of the Exemption Requests (F.P.R. Volume 4).

4.7-3

DRESDEN 2&3 AMENDMENT 16 JUNE 2007 Fire Suppression Effects Any adverse effects on safe shutdown through the discharge of water in this area would be no more severe than those determined to be acceptable for a design-basis fire. This would also include any CO2 or water leakage from the Unit 2/3 Diesel Generator fire zone above. Water would collect in the HPCI room sump pit until pumped to the Reactor Building sump. Water from this sump is then pumped to the floor drain collector tank for processing by Radwaste.

Also, the preaction arrangement of the sprinkler system will limit the probability for accidental water discharge within the room.

4.7.3 Unit 2 HPCI Pump Room (Fire Zone 11.2.3)

This fire zone is shown on the F-2 drawings and Figure 3.3-2.

Fire Barrier Description The north wall separates this fire zone from Fire Zone 11.1.2 which is part of Fire Area RB3-II and is minimum 1-foot 0-inch thick reinforced concrete 3-hour rated fire barrier. This wall contains a 3-hour rated door. The east wall separates this fire zone from Fire Zone 11.2.1 which is part of Fire Area RB2-II and is minimum 3-foot 0-inch thick reinforced concrete. A portion of this wall is also an exterior wall which is minimum 3-foot 0-inch thick reinforced concrete. The penetrations in the wall leading to Fire Zone 11.2.1 are sealed except for an HVAC duct which does not contain fire dampers. A 3-hour rated fire door is also present in this wall. The south wall is minimum 3-foot 0-inch thick reinforced concrete exterior wall. The west wall separates this fire zone from Fire Zone 11.1.3 which is part of Fire Area RB-2/3 and is minimum 3-foot 0-inch thick reinforced concrete 3-hour rated fire barrier. The floor is the basement of the building and is minimum 2-foot 6-inch thick reinforced concrete. The ceiling separates this fire zone from Fire Zone 9.0.C which is part of Fire Area RB-2/3 and is minimum 3-foot 6-inch thick reinforced concrete. This ceiling contains unsealed concrete access plugs. The HPCI Steam Pipe Tunnel is considered part of the U2 HPCI Room Fire Zone 11.2.3 for Appendix R safe shut down purposes. It is separated from the 2/3 Diesel Generator Room, by thick concrete walls, and ceiling and an unrated (for fire barrier purposes) secondary containment door. There is an unsealed opening to the Unit 2 Torus Area (86-10, EC 355027).

Safe Shutdown Equipment The following safe shutdown equipment is located in this fire zone:

HPCI Auxiliary Oil Pump HPCI Condensate Pump HPCI Condenser Air Exhaust Fan HPCI Cooling Water Pump HPCI Emergency Air Cooler HPCI Emergency Bearing Oil Pump HPCI Oil Tank Heater HPCI Valves MO2-2301-3, MO2-2301-6 MO2-2301-9, MO2-2301-10 4.7-4

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 MO2-2301-14, MO2-2301-15, MO2-2301-35 Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone is protected from fire by an ionization detection system and an automatic preaction water suppression system. The detection system charges the suppression system with water and alarms in the control room. A manual hose station is available is adjacent Fire Zone 11.1.2 for manual fire suppression (see Figure B-1 of the Exemption Requests, F.P.R., Volume 4).

Design-Basis Fire This fire zone is part of Fire Area RB-2/3. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.7 of the Safe Shutdown Report (F.P.R.

Volume 2).

Fire Zone 11.2.3 shares a boundary with Fire Areas RB2-II and RB3-II. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barrier separates this fire zone from Fire Area RB2-II. The adequacy of these barriers in preventing fire spread is discussed in Section 3.3 of the Exemption Requests (F.P.R. Volume 4).

The Standby Gas Treatment System pipe which penetrates the fire barrier separating Fire Zone 11.2.3 and Fire Zone 11.2.1 (Fire Area RB2-II) is not provided with a fire damper. This is justified in Section 9.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Any adverse effects on safe shutdown through the discharge of water in this area would be no more severe than those determined to be acceptable for a design-basis fire. This would also include any CO2 or water leakage from the Unit 2/3 Diesel Generator fire zone above. Water would collect in the HPCI room sump pit until pumped to the Reactor Building sump, from which it is pumped to the floor drain collector tank for processing by Radwaste. Also, the reaction arrangement of the sprinkler system will limit the probability for accidental water discharge within the room.

4.7-5

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 4.8 Eastern Zone Group (Fire Area TB-I)

The fire zones which comprise the eastern zone group are:

7.0.A 8.2.1.A 8.2.5.A 8.2.6.A 8.2.7 8.1 8.2.2.A 8.2.5.B 8.2.6.B 9.0.A 4.8.1 Turbine Building--Station Battery Rooms Elevation 549 Feet 0 Inch (Fire Zone 7.0.A)

This fire zone is shown on the F-8 drawings and Figure 3.3-8.

Fire Barrier Description This fire zone is subdivided into Fire Zones 7.0.A.1 (DC Panel Room), 7.0.A.2 (125 Vdc Battery Room), and 7.0.A.3 (250 Vdc Battery Room). The latter two fire zones are contained within Fire Zone 7.0.A.1 and are separated from it by fire barriers and structural steel possessing a 1-hour fire rating against a fire from within the battery enclosures. Fire doors and dampers also possess at least 1-hour fire resistance where they protect penetrations of these walls.

The north wall separates this fire zone from Fire Zone 8.2.7 which is a part of Fire Area TB-I and is minimum 1-foot 6-inch thick reinforced concrete with exposed structural steel. This wall contains unsealed mechanical penetrations and openings. The east wall separates this fire zone from Unit 1 Turbine Building and is minimum 3-foot 3-inch thick reinforced concrete with exposed structural steel. This wall contains unsealed mechanical penetrations and openings. The south wall separates this fire zone from Fire Zone 8.2.7 which is part of Fire Area TB-I and is minimum 1-foot 6-inch thick reinforced concrete with exposed structural steel. This wall contains unsealed mechanical penetrations and openings and an unrated door. The west wall separates this fire zone from Fire Zone 8.2.6.A which is part of Fire Area TB-I and is minimum 1-foot 6-inch thick reinforced concrete with exposed structural steel. This wall contains unsealed mechanical penetrations and openings. The floor separates this fire zone from Fire Zone 2.0 which is part of Fire Area TB-V and is minimum 1-foot 6-inch thick reinforced concrete with exposed structural steel. This floor has penetrations sealed with noncombustible seals. The ceiling separates this fire zone from Fire Zone 8.2.8 which is part of Fire Area TB-IV and is minimum 1-foot 6-inch thick reinforced concrete with exposed structural steel.

Safe Shutdown Equipment The following safe shutdown equipment is located in this fire zone:

125 Vdc Battery Charger 2 125 Vdc MCC 2 125 Vdc Battery Charger 2A 125 Vdc Batteries 125 Vdc Main Bus 2 250 Vdc Battery Charger 2/3 125 Vdc Reserve Bus 2 250 Vdc Batteries 4.8-1

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone is provided with an ionization smoke detection system throughout. No automatic suppression is provided. Hose stations and portable extinguishers are available for manual fire suppression.

Design-Basis Fire This fire zone is part of Fire Area TB-I. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.8 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 5.3 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 7.0.A shares a boundary with Fire Areas TB-IV and TB-V. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Areas TB-IV and TB-V. The adequacy of these barriers in preventing fire spread is discussed in Section 5.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Water release in this zone would not result in adverse effects of greater severity than those determined to be acceptable for a design-basis fire. Water runoff would be through the north HVAC room (see 8.2.7). The floor penetrations are sealed to Fire Zone 2.0 to prevent water from being released into this area.

4.8.2 Clean and Dirty Oil Tank Room - Elevation 517 Feet 6 Inches (Fire Zone 8.1)

This fire zone is shown on the F-10 drawings and Figure 3.3-10.

Fire Barrier Description The north wall separates this fire zone from Fire Zone 8.2.5.A which is a part of Fire Area TB-I and is minimum 1-foot 0-inch thick concrete block wall. This wall contains a sliding Class "A" fire door and an equivalent 3-hour rated metal flap valve for hose access. The east wall separates this fire zone from main steam pipe area and is minimum 5-foot 0-inch thick reinforced concrete.

This wall has a 3-hour fire rating. The south wall separates this zone from Fire Zone 1.1.2.2 4.8-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 which is part of Fire Area RB2-II and is minimum 4-foot 0-inch thick reinforced concrete. This wall has a 3-hour fire rating. The west wall separates this fire zone from Fire Zone 8.2.5.C which is part of Fire Area TB-II and is minimum 1-foot 0-inch thick concrete block wall. This wall contains a sliding Class "A" fire door and an equivalent 3-hour rated metal flap valve for hose access. The floor separates this fire zone from Fire Zone 1.1.2.1 which is part of Fire Are RB2-II and is minimum 2-foot 4-inch thick reinforced concrete 3-hour rated fire barrier. The ceiling separates this fire zone from Fire Zone 8.2.6.B which is part of Fire Area TB-I and is minimum 4-foot 0-inch reinforced concrete with protected steel.

Safe Shutdown Equipment There is no safe shutdown equipment located in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures The 4-foot high door curbs are provided to prevent the spread of oil to other plant areas should a tank rupture occur. The room is enclosed in 3-hour fire barriers.

The clean and dirty oil room is protected by a wet-pipe sprinkler system. A water flow alarms in the control room. A hose station and CO2 hose reel (with 200 feet of hose) are provided within 50 feet of the north and west entrances. A CO2 portable fire extinguisher and two 150-pound dry chemical wheel units are also available for manual fire suppression (see Figure B-9 of the Exemption Requests, F.P.R., Volume 4 ).

Design-Basis Fire This fire zone is part of Fire Area TB-I. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.8 of the Safe Shutdown Report (F.P.R.

Volume 2).

No safety-related equipment or cabling needed for safe shutdown is located in this fire zone. All methods of shutdown are available.

Fire Zone 8.1 shares a boundary with Fire Areas TB-II and RB2-II. A fire is prevented from spreading into this fire area by 3-hour fire barriers.

4.8-3

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Fire Suppression Effects Piping breaks or use of a manual hose would not affect safe shutdown as no equipment associated with safe shutdown is located in this zone. Water runoff would be handled by the floor drainage system in the general area.

4.8.3 Turbine Building - Basement Floor Elevation 469 Feet 6 Inches (Fire Zone 8.2.1.A)

This fire zone is shown on the F-9 drawing and Figure 3.3-9.

Fire Barrier Description The north, south, east, and west walls are exterior walls and are minimum 3-foot 0-inch thick reinforced concrete with exposed structural steel. The floor forms the basement and is minimum 2-foot 6-inch thick reinforced concrete. The ceiling separates this fire zone from Fire Zone 8.2.2.A which is part of Fire Area TB-I and is minimum 1-foot 6-inch thick reinforced concrete.

This ceiling contains unsealed mechanical penetrations and openings and a stairwell.

Safe Shutdown Equipment There is no safe shutdown equipment located in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone is protected by a complete wet pipe sprinkler automatic suppression system.

Design-Basis Fire This fire zone is part of Fire Area TB-I. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.8 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 5.3 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 8.2.1.A does not share a boundary with any other fire area, therefore, a fire in this zone cannot impact other fire areas.

4.8-4

DRESDEN 2&3 AMENDMENT 19 JUNE 2013 Fire Suppression Effects The operation of water suppression systems, use of manual hose, or piping breaks will not affect safe shutdown as no safe shutdown equipment is located in this zone. Water runoff would be handled by the general area drainage system and sump pits. Water from the Turbine Building sump is pumped to the floor drain collector tank for processing by Radwaste.

4.8.4 Turbine Building--Basement Floor Elevation 495 Feet 0 Inch (Fire Zone 8.2.2.A)

This fire zone is shown on the F-9 drawings and Figure 3.3-9.

Fire Barrier Description The north, east and west walls are exterior walls made of reinforced concrete. The south wall separates this fire zone from the Unit 2 condenser and is minimum 4-foot 0-inch thick reinforced concrete with exposed structural steel. The floor separates this fire zone from Fire Zone 8.2.1.A which is part of Fire Area TB-I and is minimum 1-foot 6-inch thick reinforced concrete with exposed structural steel. This floor contains unsealed mechanical penetrations and openings and a stairwell. The ceiling separates this fire zone from Fire Zones 8.2.5.B which is part of Fire Area TB-I and 8.2.5.C which is part of Fire Area TB-II and is minimum 1-foot 6-inch thick reinforced concrete with exposed structural steel. This ceiling contains unsealed mechanical penetrations and openings to Fire Zone 8.2.5.B and a stairwell up to Fire Zone 8.2.5.C.

Safe Shutdown Equipment The following safe shutdown equipment is located in this fire zone:

CCSW Pump and Room Coolers 2A, 2B, 2C, 2D CRD Pumps 2A-302-3, 2B-302-3 CRD Local Start Panel 2252-76 Service Water Cooling to CRD Pump Valves 2-3999-360, 2-3999-361 2-3999-348, 2-3999-349 2-3999-357, 2-3999-358 TBCCW Cooling to CRD Pump Valves 2-3999-357, 2-3899-205 CRD Discharge Valves 2-0301-2A, 2-0301-2B Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

4.8-5

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 Fire Protection Criteria and Measures This fire zone is protected throughout by a wet pipe sprinkler automatic suppression system. No separate detection is provided (see Figure B-8 of the Exemption Requests, F.P.R., Volume 4 ).

Design-Basis Fire This fire zone is part of Fire Area TB-I. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.8 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 5.3 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 8.2.2.A shares a boundary with Fire Area TB-II. A fire is prevented from spreading into this fire area by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barrier separates this fire zone from Fire Area TB-II. The adequacy of these barriers in preventing fire spread is discussed in Section 5.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Water release in this zone would not result in adverse effects of greater severity than those determined to be acceptable for a design-basis fire in this zone. Safe shutdown equipment present consists of pumps and coolers that would not be seriously affected by water discharge. In addition, hot shutdown can be achieved independent of this zone. Water release would be handled by the drainage system in the general area.

4.8.5 Turbine Building--Ground Floor -Unit 2- East Side(Fire Zone 8.2.5.A)

This fire zone is shown on the F-8 and F-10 drawings and Figures 3.3-8 and 3.3-10.

Fire Barrier Description The north wall separates this fire zone from Fire Zone 8.2.5.B which is part of Fire Area TB-I and the exterior, and is minimum 1-foot 0-inch thick reinforced concrete with exposed structural steel. The exterior wall has a 3-hour rating from an outside exposure fire. The penetrations to Fire Zone 8.2.5.B contain noncombustible seals. The east wall separates this fire zone from Fire Zone 6.2 which is part of Fire Area TB-V and the Unit 1 Turbine Building and is a minimum 1-foot 6-inch thick reinforced concrete 3-hour fire barrier around Fire Zone 6.2. The wall adjoining the Unit 1 Turbine Building is minimum 1-foot 0-inch thick reinforced concrete from elevation 517-foot 6-inch to elevation 521-foot 0-inch between columns D to D.8 and metal siding supported by exposed structural steel elsewhere. The south wall separates this fire zone from Fire Zones 9.0.A and 8.1 which are part of Fire Area TB-I, Fire Zone 1.1.2.2 which is part of Fire Area RB2-II, Fire Zone 1.3.2 which is part of Fire Area RB2-I and the inerted drywell. This wall 4.8-6

DRESDEN 2&3 AMENDMENT 19 JUNE 2013 is minimum 1-foot 0-inch reinforced concrete. The portion of this wall which borders Fire Zones 1.1.2.2, 1.3.2, 9.0.A, 8.1 and the drywell is 3-hour rated. A portion of this wall borders the exterior and is minimum 1-foot 0-inch thick reinforced concrete and contains an unrated rolling steel door along with other unsealed mechanical penetrations. The west wall separates this fire zone from Fire Zone 8.2.5.B which is part of Fire Area TB-I and is minimum 3-foot 0-inch thick reinforced concrete shield wall. This wall has mechanical penetrations sealed with noncombustible seals and an unrated door. At the western boundary there is no wall separating this fire zone from Fire Zone 8.2.5.C along column row 43 at the access corridor. Fire Zone 8.2.5.C is in Fire Area TB-II. The floor separates this fire zone from Fire Zone 8.2.4 which is part of Fire Area TB-III, Fire Zone 8.2.2.A which is part of Fire Area TB-I and Fire Zone 1.1.2.1 which is part of Fire Area RB2-II. This floor has an access to Fire Zone 8.2.4 through a locked manhole cover near column row 40.2/F.3. All other penetrations to Fire Zone 8.2.4 are sealed.

The floor contains unsealed mechanical penetrations and openings to Fire Zone 8.2.2.A. All mechanical penetrations leading to Fire Zone 1.1.2.1 are sealed with noncombustible seals. The ceiling separates this fire zone from Fire Zones 8.2.6.A and 8.2.6.B which are part of Fire Area TB-I and is minimum 1-foot 6-inch thick reinforced concrete. This ceiling has 2 stairwells leading to Fire Zone 8.2.6.A, 1 stairwell leading to Fire Zone 8.2.6.B and unsealed mechanical penetrations and openings. In addition, this ceiling contains unsealed electrical penetrations leading to fire zone 8.2.6.A for 4kV Busses 21, 22, 23 & 24 and for the Unit 2 generator voltage regulator cabinet.

Safe Shutdown Equipment The following hot shutdown equipment is located in this fire zone:

480-V MCC 29-2 HPCI Valve MO2-2301-8 Main Steam Isolation Valve 2-203-2A, 2-203-2B 2-203-2C, 2-203-2D Condensate Storage Tank 2/3-3341-77A Level Indicator 2/3-3341-77B Diesel Generator 2 Cooling Water Flow Indicator FI2-3941-880A The following cold shutdown equipment is located in this fire zone:

480-V MCC 29-2 This fire zone contains both Unit 2 and Unit 3 control cabling and only Unit 2 power cabling.

The Unit 3 control cables are for both hot and cold shutdown equipment and are located in risers R379 and R380 adjacent to the Fire Area TB-V. These risers are protected by a 1-hour fire wrap and suppression and detection.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

4.8-7

DRESDEN 2&3 AMENDMENT 20 JUNE 2015 Fire Protection Criteria and Measures Major fire hazards in this fire zone are protected by automatic fire suppression and/or detection.

A wet pipe sprinkler system protects the reactor feed pumps and Unit 2 trackway (the areas bounded by column/rows 36-38/G-H and 33-34/F-H) and a preaction sprinkler system protects the service and instrument air compressors (the area bounded by 33-35/D-D.5) and in the U2 trackway (the area bounded by 32.5-33/E-F). Also, ionization detection and wet pipe sprinkler protection are provided throughout the corridor which connects Fire Zones 8.2.5.C and 8.2.5.E to Fire Zone 8.2.5.A. Wet pipe sprinklers are also provided in the Turbine Building south cavities.

Curbs around SWGR 25 and 26 protect the AEER from the only fixed hazards in the vicinity.

Design-Basis Fire This fire zone is part of Fire Area TB-I. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.8 of the Safe Shutdown Report (F.P.R.

Volume 2).

The Unit 3 cabling in the risers outside the control room have been protected in accordance with Appendix R Section III.G.2.c.

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 5.3 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 8.2.5.A shares a boundary with Fire Areas TB-III, TB-IV, TB-V, RB2-I, RB2-II and the drywell. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barrier separates this fire zone from Fire Areas TB-III and TB-IV. The adequacy of these barriers in preventing fire spread is discussed in Section 5.2 of the Exemption Requests (F.P.R. Volume 4). The bus duct penetrating the fire barrier between this fire zone and Fire Zone 1.1.2.2 (Fire Area RB2-II) does not contain an interior seal. The justification is provided in Section 9.1 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects The operation of water suppression systems, use of manual hose, CO2, or water piping breaks would not affect safe shutdown. The effects from these actions would be of no greater severity than those already determined to be acceptable for a design-basis fire. Water runoff would be handled by the general area drainage system. MCC panel 29-2 is mounted on a pedestal and the top is sealed to reduce the probability of water entry.

4.8.6 Turbine Building - Ground Floor Low Pressure Heater Bay Area (Fire Zone 8.2.5.B)

This fire zone is shown on the F-10 drawings and Figure 3.3-10.

4.8-8

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Fire Barrier Description The north wall separates this fire zone from Fire Zone 8.2.5.C which is part of Fire Area TB-II and is minimum 2-foot 6-inch thick reinforced concrete. This wall has penetrations sealed with noncombustible seals. The east wall separates this fire zone from the exterior and Fire Zone 8.2.5.A which is part of Fire Area TB-I and is minimum 3-foot 0-inch thick reinforced concrete.

This wall contains unsealed mechanical penetrations and openings and an unrated door leading to Fire Zone 8.2.5.A. The exterior portion of this wall is 3-hour rated for an exterior exposure fire. The south wall separates this fire zone from Fire Zone 8.2.5.A which is part of Fire Area TB-I and is minimum 1-foot 0-inch thick reinforced concrete with exposed structural steel. The west wall separates this fire zone from Fire Zone 8.2.5.C which is part of Fire Area TB-II and is minimum 4-foot 0-inch thick reinforced concrete shield wall. This wall contains 2 unrated doors and has mechanical penetrations sealed with noncombustible seals. The floor separates this fire zone from Fire Zone 8.2.2.A which is part of Fire Area TB-I and is minimum 1-foot 6-inch thick reinforced concrete with exposed structural steel. This floor contains unsealed mechanical penetrations and openings and a stairwell. The ceiling separates this fire zone from Fire Zone 8.2.6.B which is part of Fire Area TB-I and is minimum 1-foot 6-inch thick reinforced concrete with exposed structural steel. This ceiling contains unsealed mechanical penetrations and openings and 3 stairwells.

Safe Shutdown Equipment There is no safe shutdown equipment located in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for\r this zone.

Fire Protection Criteria and Measures This fire zone is protected throughout by an automatic wet pipe sprinkler system. No separate automatic detection is provided.

Design-Basis Fire The fire zone is part of Fire Area TB-I. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.8 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 5.3 of the Exemption Requests (F.P.R. Volume 4).

4.8-9

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 Fire Zone 8.2.5.B shares a boundary with Fire Area TB-II. A fire is prevented from spreading into this fire area by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Area TB-II. The adequacy of these barriers in preventing fire spread is discussed in Section 5.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects The operation of water suppression systems, use of manual hose, or piping breaks would not affect safe shutdown as no safe shutdown equipment is located in this zone. Cabling for Unit 2 is present; however, water would not affect undamaged insulated cable and the hot shutdown path utilized is separate from this area. Water runoff would be handled by the general area drainage system, or would flow to the Turbine Condenser Pit where it could be removed.

4.8.7 Turbine Building--Mezzanine Elevations 534 Feet 0 Inch and 538 Feet 0 Inch (Fire Zone 8.2.6.A)

This fire zone is shown on the F-8 and F-13 drawings and Figures 3.3-8 and 3.3-13.

Fire Barrier Description The north wall is an exterior wall and is minimum 1-foot 0-inch thick reinforced concrete with a 3-hour exposure rating to an exterior fire up to elevation 551-feet 6-inches and metal siding above that elevation. The wall is supported on exposed structural steel. The east wall separates this fire zone from the Unit 1 Turbine Building and is made of metal siding supported by exposed structural steel. This wall contains unsealed mechanical penetrations and openings. The east wall also separates this fire zone from Fire Zone 2.0 which is part of Fire Area TB-V. The walls separating this fire zone from Fire Zone 2.0 are 3-hour rated and contain two 3-hour rated fire doors. The south wall is an exterior wall and is minimum 1-foot 0-inch thick reinforced concrete. This wall contains unsealed mechanical penetrations and openings. The west wall separates this fire zone from Fire Zone 8.2.6.B which is part of Fire Area TB-I and is minimum 3-foot 0-inch thick reinforced concrete shield wall. This wall contains an unrated door and mechanical penetration sealed with noncombustible seals. The floor separates this fire zone from Fire Zone 8.2.5.A which is part of Fire Area TB-I and is minimum 1-foot 6-inch thick reinforced concrete with exposed structural steel. This floor contains 2 stairwells and unsealed mechanical penetrations and openings. In addition, this floor contains unsealed electrical penetrations leading to fire zone 8.2.5.A from 4kV Busses 21, 22, 23, & 24 and from the Unit 2 generator voltage regulator cabinet. The ceiling separates this fire zone from Fire Zones 8.2.7 which is part of Fire Area TB-1 and 8.2.8.A which is part of Fire Area TB-IV and is minimum 1-foot 0-inch thick reinforced concrete with exposed structural steel. This ceiling contains two stairwells and unsealed mechanical penetrations and openings.

Safe Shutdown Equipment The following safe shutdown equipment is located in this fire zone:

4-kV SWGR 23 4-kV SWGR 24 480 V MCC 28-2 480 V MCC 28-3 4.8-10

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 This fire zone contains both Unit 2 and Unit 3 control cabling and only Unit 2 power cabling.

The Unit 3 control cables are for both hot and cold shutdown equipment and are located in risers R379 and R380 adjacent to the control room. These risers are protected by a 1-hour fire wrap and suppression and detection.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures Ionization detection is generally provided throughout this fire zone. Major fire hazards in this fire zone are protected by automatic water suppression system. The hydrogen seal oil unit is protected by a thermally actuated water spray system. The cable concentration area on the south mezzanine is protected by a preaction water suppression system using closed-head directional spray nozzles in the trays. The system is actuated by ionization detectors. Manual hose stations and fire extinguishers are also available in this fire zone for manual fire suppression. Suppression and detection are provided in the area of cable risers R379 and R380 (see Figure B-12 of the Exemption Requests, F. P. P. D. P. Volume 3).

Design-Basis Fire This fire zone is part of Fire Area TB-I. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.8 of the Safe Shutdown Report (F.P.R.

Volume 2).

The Unit 3 cabling in the risers outside the control room have been protected in accordance with Appendix R Section III.G.2.c.

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 5.3 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 8.2.6.A shares a boundary with Fire Areas TB-IV and TB-V and the Unit 1 Turbine Building. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Area TB-II and the Unit 1 Turbine Building. The adequacy of these barriers in preventing fire spread is discussed in Section 5.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects The use of water or CO2 in this area will not affect safe shutdown as any adverse effects on hot shutdown equipment would be of no greater severity than those determined to be acceptable for a design-basis fire. Water runoff would be controlled by the general area floor drainage system as 4.8-11

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 well as hatches and stairways. Pedestals are not provided for the 4-kV Switchgear panels 23 and 24 (exposed by hose) but are provided for MCC panels 28-2 and 28-3 (exposed by hose and the H2 seal oil unit water spray system). The tops of panels 23, 24, 28-2 and 28-3 are sealed to reduce the probability of water entry.

4.8.8 Turbine Building Turbine Pipeway/Heater Bays - Mezzanine Elevation (Fire Zone 8.2.6.B)

This fire zone is shown on the F-13 drawings and Figure 3.3-13.

Fire Barrier Description The north wall separates this fire zone from Fire Zone 8.2.6.C which is part of Fire Area TB-II and is minimum 2 foot 6 inch thick reinforced concrete. This wall has all penetrations sealed with noncombustible seals. The east wall separates this fire zone exterior and Fire Zone 8.2.6.A which is part of Fire Area TB-I and is minimum 3-foot 0-inch thick reinforced concrete. This wall contains an unrated door and unsealed mechanical penetrations and openings. The south wall separates this fire zone from Fire Zones 1.1.2.3 which is part of Fire Area RB2-II and 8.2.6.A which is part of Fire Area TB-I, and is minimum 1-foot 0-inch thick reinforced concrete.

The wall adjoining Fire Zone 1.1.2.3 has penetrations sealed with the exception of an HVAC duct without a fire damper. The wall adjoining Fire Zone 8.2.6.A has penetrations sealed with noncombustible seals. The west wall separates this fire zone from Fire Zone 8.2.6.C which is part of Fire Area TB-II and is minimum 2-foot 6-inch thick reinforced concrete. This wall has all penetrations sealed with noncombustible seals with the exception of an unrated door to Fire Zone 8.2.6.C. The floor separates this fire zone from Fire Zones 8.2.5.A and 8.2.5.B which are part of Fire Area TB-I and 8.2.5.C which is part of Fire Area TB-II, and is minimum 1-foot 6-inch thick reinforced concrete with exposed structural steel. This floor contains unsealed mechanical penetrations and openings, three stairwells down to Fire Zone 8.2.5.B and one stairwell down to Fire Zone 8.2.5.A. The ceiling separates this fire zone from Fire Zone 8.2.8.A which is part of fire Area TB-IV and is minimum 1-foot 6-inch thick reinforced concrete with exposed structural steel. This ceiling contains unsealed mechanical penetrations and openings.

Safe Shutdown Equipment This fire zone contains no safe shutdown equipment.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone is protected throughout by an automatic wet pipe sprinkler system. Manual hose stations and fire extinguishers are available in the adjoining fire zones for manual fire suppression.

4.8-12

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Design-Basis Fire This fire zone is part of Fire Area TB-I. In the event of a fire in this zone, both hot and cold shutdown can be achieved as discussed in Section 4.8 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 5.3 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 8.2.6.B shares a boundary with Fire Areas RB2-II, TB-II and TB-IV. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Areas TB-II, TB-IV and RB2-II. The adequacy of these barriers in preventing fire spread is discussed in Section 5.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects The operation of water suppression systems, use of manual hose, or piping breaks would not affect safe shutdown as no safe shutdown equipment is located in this zone. Cabling for Unit 2 is present, however, water would not affect undamaged insulated cable and the hot shutdown path utilized is separate from this area. Water runoff would be handled by the general area drainage system, or would flow to the Turbine Condenser Pit where it could be removed.

4.8.9 Turbine Building--Mezzanine Elevation 549 Feet 0 Inches (Fire Zone 8.2.7)

This fire zone is shown in the F-8 drawings and Figure 3.3-8.

Fire-Barrier Description The north wall is an exterior wall made of metal siding supported by exposed structural steel.

The east wall separates this fire zone from the Unit 1 Turbine Building and is made of metal siding supported by exposed structural steel. The south wall is an exterior wall made of metal siding supported by exposed structural steel. The west side of this fire zone is open to Fire Zone 8.2.6.A which is part of Fire Area TB-I. The floor separates this fire zone from Fire Zone 8.2.6.A which is part of Fire Area TB-I and is minimum 1-foot 6-inch reinforced concrete with exposed structural steel. This floor contains unsealed mechanical penetrations and openings and a stairwell leading to Fire Zone 8.2.6.A. The ceiling separates this fire zone from Fire Zone 8.2.8.A which is part of Fire Area TB-IV and is minimum 1-foot 6-inch thick reinforced concrete with exposed structural steel. This ceiling contains unsealed mechanical penetrations and openings. Fire Zone 7.0.A which is part of Fire Area TB-I is contained within this fire zone and separated from it by minimum 1-foot 6-inch reinforced concrete walls.

4.8-13

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Safe Shutdown Equipment There is no safe shutdown equipment in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone has a fixed ionization detection system and its west side is open to Fire Zone 8.2.6.A which has an ionization detection system as well. The detection systems alarm locally and in the control room. No automatic suppression system is provided in this fire zone. Hose stations and portable fire extinguishers are available for manual fire suppression.

Design-Basis Fire This fire zone is part of Fire Area TB-I. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.8 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 5.3 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 8.2.7 shares a boundary with Fire Area TB-IV and the Unit 1 Turbine Building. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Area TB-IV and the Unit 1 Turbine Building. The adequacy of these barriers in preventing fire spread is discussed in Section 5.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Piping breaks or use of manual hose would not affect safe shutdown as no equipment associated with safe shutdown is located in this zone. Water runoff would be handled by the floor drainage system as well as hatches and stairways in the general area.

4.8.10 Unit 2 Diesel Generator Room Elevation 517 Feet 6 inches (Fire Zone 9.0.A)

This fire zone is shown on the F-10 drawings and Figure 3.3-10.

4.8-14

DRESDEN 2&3 AMENDMENT 14 JUNE 2003 Fire Barrier Description The north, east and west walls separate this fire zone from Fire Zone 8.2.5.A which is a part of Fire TB-I and are minimum 1-foot 0-inch thick reinforced concrete. These walls are 3-hour rated and access through the north wall is through 2 Class "A" fire doors. The south wall is an exterior wall and is minimum 1-foot 0-inch thick reinforced concrete. The floor separates this fire zone from the exterior and is minimum 1-foot 6-inch thick reinforced concrete on protected steel. The ceiling separates this fire zone from Fire Zone 8.2.6.A which is part of Fire Area TB-I and is 6-inch thick reinforced concrete on protected steel. This ceiling contains unsealed mechanical penetrations for diesel air supply and exhaust.

Safe Shutdown Equipment The following safe shutdown equipment is located in this fire zone:

Unit 2 Diesel Generator Unit 2 Diesel Generator Fuel Oil Transfer Pump Unit 2 Diesel Generator Vent Fan Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone is provided with a total flooding CO2 fire suppression system which is activated by a thermal detection system provided throughout. Wet pipe sprinklers provide additional protection for the day tank room. This fire zone is separated from other fire zones by 3-hour rated barriers except as noted above. A manual hose station is located in Fire Zone 8.2.5.A and is available for manual suppression in this fire zone. Curbs are provided to prevent the spread of oil spill fires from the diesel generator rooms and day tank rooms.

Design-Basis Fire This fire zone is part of Fire Area TB-I. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.8 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 5.3 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 9.0.A does not share a boundary with any other fire area, therefore, a fire in this zone cannot impact other fire areas.

4.8-15

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 Fire Suppression Effects Water or CO2 release in this zone would not result in adverse effects of greater sensitivity than those determined to be acceptable for a design-basis fire. Water runoff would be controlled through utilization of floor drains in the general area. The room is curbed.

Full discharge concentration tests have been conducted to verify actual conditions during system actuation. Pressure vents are not provided for the room.

4.8-16

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 4.9 Central Zone Group (Fire Area TB-II)

The fire zones which comprise this fire area contain cabling and equipment for the normal operation of both units. These fire zones are:

8.2.5.C 8.2.6.C 4.9.1 Turbine Building - Ground Floor Central Area (Fire Zone 8.2.5.C)

This fire zone is shown on the F-10 and F-11 drawings and Figures 3.3-10 and 3.3-11.

Fire Barrier Description The north wall separates this fire zone from Fire Zones 14.1 and 14.5 which are part of the Radwaste Fire Area. This wall is minimum 2-foot 0-inch thick concrete except for precast concrete block pull area sections and between column rows 42 and 46 where the wall is 1-foot 0-inch thick reinforced concrete. A portion of the north wall is a minimum 2-foot 0-inch thick 3-hour exterior rated reinforced concrete wall. The east wall separates this fire zone from Fire Zone 8.2.5.A, 8.2.5.B and 8.1 which are part of Fire Area TB-I. The shield wall bordering 8.2.5.B is minimum 3-foot 0-inch thick reinforced concrete with all penetrations sealed with noncombustible seals. The wall contains a non-label access door. The border with Fire Zone 8.1 is made of 12 inch concrete block that is 3-hour rated. This wall also has a 3-hour rated fire door.

The metal flap cover in this wall is an equivalent 3-hour rated seal. There is no wall separating this fire zone from Fire Zone 8.2.5.A along the access corridor. The south wall separates this fire zone from Fire Zone 1.1.2.2 which is part of Fire Area RB2-II and Fire Zone 1.1.1.2 which is part of Fire Area RB3-II and is minimum 1-foot 0-inch thick reinforced concrete fire barrier. The west wall separates this fire zone from Fire Zone 8.2.5.D and 8.2.5.E which are part of Fire Area TB-III and is minimum 3-foot 0-inch thick reinforced concrete shield walls with penetrations sealed with noncombustible seals. There is no wall separating this fire zone from Fire Zone 8.2.5.E along the access corridor. The floor separates this fire zone from Fire Zone 8.2.2.A which is part of Fire Area TB-I, Fire Zones 8.2.4 and 8.2.2.B which are part of Fire Area TB-III, Fire Zone 1.1.2.1 which is part of Fire Area RB2-II and Fire Zone 1.1.1.1 which is part of Fire Area near column row 45/F.5. The penetrations to Fire Zones 1.1.2.1 and 1.1.1.1 are sealed with noncombustible seals. There are hatches which connect this fire zone to Fire Zones 8.2.2.A and 8.2.2.B. A stairwell also leads from this fire zone to Fire Zone 8.2.2.A. The ceiling separates this fire zone from Fire Zone 8.2.6.B which is part of Fire Area TB-I, Fire Zone 8.2.6.C which is part of Fire Area TB-II, and Fire Zone 8.2.6.D which is part of Fire Area TB-III. The ceiling is minimum 1-foot 6-inch thick reinforced concrete supported by exposed structural steel with all penetrations leading to Fire Zones 8.2.6.B and 8.2.6.D sealed with noncombustible seals. The ceiling contains stairwells and unsealed hatches leading to Fire Zone 8.2.6.C.

4.9-1

DRESDEN 2&3 AMENDMENT 20 JUNE 2015 Safe Shutdown Equipment The following safe shutdown equipment is located in this fire zone:

Cabling from both Units 2 and 3 is located in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures Fixed ionization detection and/or wet pipe sprinklers protect all portions of this fire zone south of column/row E. Fire detection alone is provided in the portions of the zone between column/rows 43-45/C-E. An area wide automatic sprinkler system and ionization type smoke detectors protect the two EHC units. The Unit 2 low pressure heater pull region on elevation 517 feet 6 inches, used as an oil storage area, is provided with a fixed water suppression system. The southern portion of this zone also contains equipment for use in manual fire fighting.

Design-Basis Fire This fire zone is part of Fire Area TB-II. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.9 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Subsection 5.5 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 8.2.5.C shares a boundary with Fire Areas RB2-II, RB3-II, TB-I, TB-III and Radwaste. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Areas TB-I, TB-III, RB2-II, RB3-II and Radwaste. The adequacy of these barriers in preventing fire spread is discussed in Section 5.2 of the Exemption Requests (F.P.R. Volume 4). The Standby Gas Treatment System pipes which penetrate the fire barriers separating Fire Zone 8.2.5.C from Fire Zone 1.1.1.2 (Fire Area RB3-II) and Fire Zone 1.1.2.2 (Fire Area RB2-II) are not provided with fire dampers. This is justified in Section 9.2 of the Exemption Requests (F.P.R. Volume 4).

4.9-2

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 Fire Suppression Effects Water release in this zone (including drainage from upper levels of the plant) would not result in adverse effects of greater severity than those determined to be acceptable for a design-basis fire.

Cables are the only safe shutdown related equipment in this area, and the water will not adversely affect undamaged cable. Water runoff would be controlled through utilization of floor drains in the general area.

The CO2 storage tank is located in this area. A major release of CO2 would not present a thermal shock hazard (since only cables are present in this area). The probability of catastrophic failure of this tank is considered negligible.

4.9.2 Turbine Building - Mezzanine Elevation - Central Area (Fire Zone 8.2.6.C)

This fire zone is shown on the F-13 and F-14 drawings and Figures 3.3-13 and 3.3-14.

Fire Barrier Description The north wall separates this fire zone from the Radwaste Fire Area and the exterior and is minimum 2-foot 0-inch thick reinforced concrete. This wall has an opening filled with precast concrete block sections, one non-label door and a louvered opening leading to Radwaste Fire Area. The east wall separates this fire zone from Fire Zone 8.2.6.B, which is part of Fire Area TB-I, and is minimum 2-foot 6-inch-thick reinforced concrete. This wall has all penetrations sealed with noncombustible seals and contains an unrated door to Fire Zone 8.2.6.B. The south wall separates this fire zone from Fire Zones 1.1.1.3 and 1.1.2.3, which are part of Fire Areas RB3-II and RB2-II, and is minimum 1-foot 0-inch-thick reinforced concrete. This wall is a 3-hour rated wall. The west wall separates this fire zone from Fire Zone 8.2.6.D, which is part of Fire Area TB-III and is minimum 4-foot 0-inch-thick reinforced concrete. This wall has all mechanical penetrations sealed with noncombustible seals. The floor separates this fire zone from Fire Zone 8.2.5.C, which is part of Fire Area TB-II, and is minimum 1-foot 6-inch-thick reinforced concrete with exposed structural steel. This floor has unsealed mechanical penetrations and openings and two stairwells. The ceiling separates this fire zone from Fire Zone 8.2.8.A and Fire Zone 8.2.8.D, which are part of Fire Area TB-IV, and is minimum 1-foot 6-inch-thick reinforced concrete with exposed structural steel. This ceiling has unsealed mechanical penetrations and openings and three stairwells.

Safe Shutdown Equipment The following safe shutdown equipment is located in this fire zone:

TBCCW Heat Exchanger Outlet Isolation Valves 2-3904-501, 3-3904-501 2-3904-500, 3-3904-500 Turbine Oil Cooler Outlet Isolation Valves 2-3906-500, 3-3906-500 2-3906-501, 3-3906-501 4.9-3

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Concentrator Condenser Outlet Isolation Valves 2/3-3999-241, 2/3-3999-240 480-V MCC 39-2 Mechanical CRD Cross-Tie Valves 2/3-0301-162, 2/3-0301-163 Both Unit 2 and Unit 3 cables are located in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone is provided with a wet pipe sprinkler system at the ceiling throughout except for LP heater pull region in the northeast corner of the zone. The two turbine oil reservoirs are also protected by open head water spray actuated by thermal detection systems. The reservoirs are surrounded by drained, open grating. This zone is also provided with equipment for manual fire fighting which includes hose stations and portable extinguishers (see Figures B-12 and B-13 of the Exemption Requests, F.P.R., Volume 4 ).

Design-Basis Fire This fire zone is part of Fire Area TB-II. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.9 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 5.5 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 8.2.6.C shares a boundary with Fire Areas TB-I, TB-III, TB-IV, RB2-II and RB3-II. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Areas TB-I, TB-III and TB-IV. The adequacy of these barriers in preventing fire spread is discussed in Section 5.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Water or CO2 release in this zone would not result in adverse effects of greater severity than those determined to be acceptable for a design-basis fire. MCC 39-2 is mounted on an equipment pedestal and the top is sealed to reduce the probability of water entry. Water runoff would be handled by the general area floor drain system as well as stairways to lower levels.

4.9-4

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 4.10 Western Zone Group (Fire Area TB-III)

The fire zones which comprise the western zone group are:

6.1 8.2.4 8.2.6.D 7.0.B 8.2.5.D 8.2.6.E 8.2.1.B 8.2.5.E 9.0.B 8.2.2.B 4.10.1 DC Panel Room -- Elevation 538 Feet 0 Inch (Fire Zone 6.1)

This fire zone is shown on the F-14 drawings and Figure 3.3-14.

Fire Barrier Description The south and west walls are minimum 1-foot 0-inch reinforced concrete exterior walls with coated steel columns and exterior metal siding with exposed structural steel on the outside face of the concrete walls. The north and east walls separate this fire zone from Fire Zone 8.2.6.E which is part of TB-III and is minimum 1-foot 0-inch reinforced concrete. The north wall has a non-labeled door and a 1-foot 4-inch exhaust fan. The floor separates this fire zone from Fire Zone 8.2.5.E which is part of Fire Area TB-III, has 4-foot 4-inch high equipment pads and floor drains, and consists of 5-inch reinforced concrete slab supported on exposed structural steel framing. The ceiling separates this fire zone from Fire Zone 7.0.B which is part of Fire Area TB-III and is 6-inch reinforced concrete slab on exposed structural steel framing.

Safe Shutdown Equipment The following safe shutdown equipment is located in this fire zone:

125-Vdc Battery Charger 3 125-Vdc Battery Charger 3A 125-Vdc TB Main Bus 3 125-Vdc TB Reserve Bus 3 250-Vdc TB MCC 3 250-Vdc Battery Charger 3 Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

4.10-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Fire Protection Criteria and Measures This fire zone is provided throughout with an ionization detection system. No automatic suppression system is provided because maloperation of such a system could affect the electrical equipment located in this zone. A manual hose station and portable extinguishers are available for manual fire suppression.

Design-Basis Fire This fire zone is part of Fire Area TB-III. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.10 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 5.4 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 6.1 does not share a boundary with any other fire area, therefore, a fire in this zone cannot impact other fire areas.

Fire Suppression Effects Hose line use or CO2 release in this zone would not result in adverse effects of greater severity than those determined to be acceptable for a design-basis fire. Water run-off would be controlled through utilization of floor drains immediately outside of the room.

4.10.2 Turbine Building - Station Battery Room - Elevation 551 Feet 0 Inch (Fire Zone 7.0.B)

This fire zone is shown on the F-14 drawings and Figure 3.3-14.

Fire Barrier Description The north and east walls separate this fire zone from Fire Zone 8.2.6.E which is part of Fire Area TB-III and are minimum 1-foot 0-inch thick concrete and concrete block. The east wall contains an unrated door. The south and west walls of this fire zone are minimum 2-foot 3-inch thick reinforced concrete exterior walls. The floor separates this fire zone from Fire Zone 6.1 which is part of Fire Area TB-III and is minimum 6-inch thick reinforced concrete supported by exposed structural steel. The ceiling separates this fire zone from the exterior and is minimum 1-foot 0-inch thick reinforced concrete.

Safe Shutdown Equipment The following safe shutdown equipment is located in this fire zone:

125 V dc Batteries 250 V dc Batteries 4.10-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Measures and Criteria This fire zone is provided with an ionization smoke detection system throughout. No automatic suppression is provided. A manual hose station and fire extinguisher are available for use in this fire zone (see Figure B-13 of the Exemption Requests. F.P.R. Volume 4).

Design-Basis Fire This fire zone is part of Fire Area TB-III. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.10 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression have not been provided. This is justified in Section 5.4 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 7.0.B does not share a boundary with any other fire area; therefore, a fire in this zone cannot impact other fire areas.

Fire Suppression Effects Hose line use or CO2 release in this zone would not result in adverse effects of greater severity than those determined to be acceptable for a design-basis fire. Water runoff would be controlled through utilization of floor drains in the general area, outside of this zone.

4.10.3 Turbine Building--Basement Floor Elevation 469 Feet 6 Inches (Fire Zone 8.2.1.B)

This fire zone is shown on the F-6 drawing and Figure 3.3-9.

Fire Barrier Description The north, east, south, and west walls of this fire zone are minimum 3-foot 0-inch thick reinforced concrete exterior walls. The wall separating the north and south portions of this fire zone is minimum 4-foot 0-inch thick reinforced concrete shield wall. The floor of this fire zone is the basement of the building. The ceiling separates this fire zone from Fire Zone 8.2.2.B, which is part of Fire Area TB-III, and is minimum 1-foot 6-inch thick reinforced concrete with exposed structural beams. This ceiling contains stairwells and open hatches, as well as unsealed mechanical penetrations.

4.10-3

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Safe Shutdown Equipment There is no safe shutdown equipment located in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone is protected by a complete wet pipe sprinkler automatic suppression system (see Figure B-8 of the Exemption Requests, F.P.R., Volume 4 ).

Design-Basis Fire This fire zone is part of Fire Area TB-III. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.10 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 5.4 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 8.2.1.B does not share a boundary with any other fire area; therefore, a fire in this zone cannot impact other fire areas.

Fire Suppression Effects The operation of water suppression systems, use of manual hose, or piping breaks will not affect safe shutdown as no safe shutdown equipment is located in this zone. Water runoff would be handled by the general area drainage system and sump pumps. Water from the Turbine Building sump is pumped to the floor drain collector tank for processing by Radwaste.

4.10.4 Turbine Building -- Basement Floor Elevation 495 Feet 0 Inch (Fire Zone 8.2.2.B)

This fire zone is shown on the F-9 drawings and Figure 3.3-9.

Fire Barrier Description The north, west, and east walls of this fire zone are reinforced concrete exterior walls. The south wall separates this fire zone from the condenser and is minimum 4-foot 0-inch thick reinforced concrete shield wall. The floor separates this fire zone from Fire Zone 8.2.1.B, which is part of Fire Area TB-III, and is minimum 1-foot 6-inch thick reinforced concrete with exposed structural beams. This floor contains a stairwell and open penetrations to Fire Zone 8.2.1.B. The ceiling 4.10-4

DRESDEN 2&3 AMENDMENT 14 JUNE 2003 separates this fire zone from Fire Zone 8.2.5.D, which is part of Fire Area TB-III, and Fire Zone 8.2.5.C, which is part of Fire Area TB-II, and is minimum 1-foot 6-inch thick reinforced concrete with exposed structural beams. This ceiling contains unsealed penetrations and hatches and a stairwell leading to Fire Zone 8.2.5.C.

Safe Shutdown Equipment The following safe shutdown equipment is located in this zone:

CCSW Pump and Room Coolers 3A, 3B, 3C, 3D CRD Pumps 3A-302-3, 3B-302-3 Service Water Cooling to CRD Pump Valves 3-3999-360, 3-3999-361, 3-3999-357 3-3999-348, 3-3999-349 TBCCW Cooling to CRD Pump Valves 3-3899-205, 3-3899-204 CRD Discharge Valves 3-0301-2A, 3-0301-2B CRD Pump Suction Gages 3-302-50A(B)

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone is protected throughout by a wet pipe sprinkler automatic suppression system. No separate detection is provided (see Figure B-8 of the Exemption Requests, F.P.R., Volume 4 ).

Design-Basis Fire This fire zone is part of Fire Area TB-III. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.10 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 5.4 of the Exemption Requests (F.P.P.D.P Volume 3).

Fire Zone 8.2.2.B shares a boundary with Fire Area TB-II. A fire is prevented from spreading into this fire area by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barrier separates this fire zone from Fire Area TB-II. The adequacy of these barriers in preventing fire spread is discussed in Section 5.2 of the Exemption Requests (F.P.R. Volume 4).

4.10-5

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 Fire Suppression Effects Water release in this zone would not result in adverse effects of greater severity than those determined to be acceptable for a design-basis fire in this zone. Safe shutdown equipment present consists of pumps and coolers that would not be seriously affected by water discharge. In addition, hot shutdown can be achieved independent of this zone. Water release would be handled by the drainage system in the general area.

4.10.5 Unit 3 Cable Tunnel (Fire Zone 8.2.4)

This fire zone is shown on the F-12 drawings and Figure 3.3-12.

Fire Barrier Description The walls and floor of the cable tunnel are reinforced concrete exterior walls. The eastern part of the cable tunnel terminates at a 1-foot 6-inch reinforced concrete 3-hour fire wall which separates this fire zone from Fire Zone 6.2, which is part of Fire Area TB-V. The ceiling separates this fire zone from Fire Zones 8.2.5.A and 8.2.5.B, which are part of Fire Area TB-I; Fire Zone 8.2.5.C, which is part of TB-II; and Fire Zones 8.2.5.D and 8.2.5.E, which are part of Fire Area TB-II. The ceiling under Fire Areas TB-I and TB-II have all penetrations sealed, except for the steel manhole covers. The electrical penetrations from the cable tunnel to Fire Area TB-III are sealed.

Safe Shutdown Equipment There is no safe shutdown equipment located in this fire zone although both Divisions I and II Unit 3 cabling is routed in the cable tunnel.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures The cable tunnel is protected by automatic detection and a wet-pipe sprinkler system, which protects the cable trays. The actuation of this system alarms in the control room.

Design-Basis Fire This fire zone is part of Fire Area TB-III. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.10 of the Safe Shutdown Report (F.P.R.

Volume 2).

Fire Zone 8.2.4 shares a boundary with Fire Areas TB-I, TB-III, and TB-V. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour 4.10-6

DRESDEN 2&3 AMENDMENT 19 JUNE 2013 barriers separate this fire zone from Fire Areas TB-I and TB-II. The adequacy of these barriers in preventing fire spread is discussed in Section 5.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Water release in this zone (including drainage from upper levels of the plant) would not result in adverse effects of greater severity than those determined to be acceptable for a design-basis fire.

Water will not affect undamaged insulated cable and only cables are present in this zone. Water runoff would be controlled through utilization of trenches and floor drains in the cable tunnel.

4.10.6 Turbine Building--Ground Floor Low Pressure Heater Bay Area (Fire Zone 8.2.5.D)

This fire zone is shown on the F-11 drawing and Figure 3.3-11.

Fire Barrier Description A portion of the north wall separates this fire zone from Fire Zone 8.2.5.C, which is part of Fire Area TB-II, and the remainder forms the exterior and is minimum 1-foot 6-inch thick reinforced concrete. The shield wall adjoining Fire Zone 8.2.5.C has the penetrations sealed with noncombustible seals. The east wall separates this fire zone from Fire Zone 8.2.5.C, which is part of Fire Area TB-II, and is minimum 3-foot 0-inch thick reinforced concrete shield wall. This wall contains two unrated access doors, and the penetrations are sealed with noncombustible seals. The south wall separates this fire zone from Fire Zone 8.2.5.E, which is part of Fire Area TB-III and is minimum 3-foot 0-inch thick reinforced concrete shield wall. This wall has penetrations sealed with noncombustible seals. The west wall separates this fire zone from Fire Zone 8.2.5.E, which is part of Fire Area TB-III, and is minimum 3-foot 0-inch thick reinforced concrete shield wall with penetrations sealed with noncombustible seals. This wall also forms part of the exterior and is minimum 4-foot 0-inch thick reinforced concrete supported on unprotected steel. The exterior of this wall is 3-hour rated for an exposure fire. The floor separates this fire zone from Fire Zones 8.2.2.B and 8.2.4, which are part of Fire Area TB-III, and is minimum 1-foot 6-inch thick reinforced concrete. This floor contains unsealed penetrations and open hatches. The ceiling separates this fire zone from Fire Zone 8.2.6.D, which is part of Fire Area TB-III, and is minimum 1-foot 6-inch thick reinforced concrete. This ceiling contains unsealed penetrations and open hatches.

Safe Shutdown Equipment There is no safe shutdown equipment is located in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

4.10-7

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 Fire Protection Criteria and Measures This fire zone is protected throughout by an automatic wet pipe sprinkler system. No separate automatic detection is provided (see Figure B-10 of the Exemption Requests, F.P.R., Volume 4 ).

Design-Basis Fire This fire zone is part of Fire Area TB-III. In the event of a fire in this zone, both hot and cold shutdown can be achieved as discussed in Section 4.10 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is used to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 5.4 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 8.2.5.D shares a boundary with Fire Area TB-II. A fire is prevented from spreading into this fire area by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barrier separates this fire zone from Fire Area TB-II. The adequacy of these barriers in preventing fire spread is discussed in Section 5.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects The operation of water suppression systems, use of manual hose, or piping breaks would not affect safe shutdown as no safe shutdown equipment is located in this zone. Cabling for Unit 2 is present, however, water would not affect undamaged insulated cable and the hot shutdown path utilized is separate from this area. Water runoff would be handled by the general area drainage system, or would flow to the Turbine Condenser Pit where it could be removed.

4.10.7 Turbine Building -- Ground Floor Unit 3 - West Side (Fire Zone 8.2.5.E)

This fire zone is shown on the F-11 drawings and Figure 3.3-11.

Fire Barrier Description The north wall separates this fire zone from Fire Zone 8.2.5.D, which is part of Fire Area TB-III, and is minimum 3-foot 0-inch thick reinforced concrete shield wall with penetrations sealed with noncombustible seals. This wall is also an exterior wall which is minimum 1-foot 0-inch thick reinforced concrete supported by exposed structural steel. This exterior wall is 3-hour rated from an exterior exposure fire. The east wall separates this fire zone from Fire Zone 8.2.5.D, which is part of Fire Area TB-III and is minimum 3-foot 0-inch thick reinforced concrete shield wall with penetrations sealed with noncombustible seals. A portion of the interface between this fire zone and Fire Zone 8.2.5.C which is part of Fire Area TB-II, is an open hallway. The south wall separates this fire zone from Fire Zones 1.1.1.2 and 1.3.1, which are part of Fire Area RB3-II, and is minimum 1-foot 0-inch thick reinforced concrete 3-hour fire barrier. This wall also borders Fire Zone 9.0.B, which is part of Fire Area TB-III, and the 4.10-8

DRESDEN 2&3 AMENDMENT 19 JUNE 2013 exterior, and is minimum 1-foot 0-inch thick reinforced concrete. There are 3-hour rated fire doors leading to Fire Zone 9.0.C and an unrated rolling door which allows access to the track way located in this wall. The west wall of this fire zone is a minimum 1-foot 6-inch thick reinforced concrete exterior wall. This wall contains an unrated door. The floor separates this fire zone from Fire Zone 8.2.4, which is part of Fire Area TB-III, and Fire Zone 1.1.1.1 which is part of Fire Area RB3-II, and is minimum 1-foot 6-inch thick reinforced concrete. This floor contains unsealed hatches leading to the Fire Zone 8.2.4. The floor above Fire Zone 1.1.1.1 contains penetrations sealed with noncombustible seals. The ceiling separates this fire zone from Fire Zones 8.2.6.D, 8.2.6.E, and 6.1, which are part of Fire Area TB-III, and is minimum 1-foot 6-inch thick reinforced concrete. This ceiling contains unsealed penetrations and hatches. In addition, this ceiling contains unsealed electrical penetrations leading to fire zone 8.2.6.E for 4kV Busses 33 & 34 and for 480 V MCC 35-2.

Safe Shutdown Equipment The following hot shutdown equipment is located in this fire zone:

HPCI Valve MO3-2301-8 Main Steam Isolation Valves 3-203-2A, 3-203-2B, 3-203-2C, 3-203-2D Diesel Generator 3 Cooling Water Flow Indicator FI3-3941-34A There is no equipment needed for cold shutdown located in this fire zone. Cabling for both Division I and II is located in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures Major fire hazards in this fire zone are protected by an automatic water suppression system.

Ionization detection and wet pipe sprinkler protection is provided throughout the corridor which connects Fire Zones 8.2.5.C and 8.2.5.E to Fire Zone 8.2.5.A. In addition, detection is generally provided in the zone where suppression is not provided. A wet pipe sprinkler system is provided to protect the Unit 3 trackway, reactor feed pumps, and Turbine Building south cavities. The cable trays containing the 2/3 diesel generator auxiliaries are enclosed in a 1-hour fire wrap (see Figure B-10 of the Exemption Requests, F.P.R., Volume 4 ).

4.10-9

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 Design-Basis Fire This fire zone is part of Fire Area TB-III. In the event of a fire in this zone, both hot and cold shutdown can be achieved as discussed in Section 4.10 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 5.4 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 8.2.5.E shares a boundary with Fire Areas TB-II and RB3-II. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barrier separates this fire zone from Fire Area TB-II. The adequacy of these barriers in preventing fire spread is discussed in Section 5.2 of the Exemption Requests (F.P.R. Volume 4).

The 4-kV bus duct which penetrates the fire barrier separating Fire Zone 8.2.5.E from Fire Zone 1.1.1.2 does not have an interior seal. Justification for this configuration is provided in Section 9.1 of the Exemption Requests (F.P.R. Volume 4).

The 2/3 diesel generator auxiliaries are routed from this fire zone into Fire Zone 8.2.5.C. The cable trays containing these cables are protected in accordance with Appendix R Section III.G.2c.

Fire Suppression Effects The operation of water suppression systems, use of manual hose, CO2, or water piping breaks would not affect safe shutdown. The effects of these actions would be of no greater severity than those already determined to be acceptable for a design-basis fire. Water runoff would be handled by the general area drainage system as well as hatches and stairways.

4.10.8 Turbine Building - Turbine Pipeway/Heater Bays Mezzanine Elevation (Fire Zone 8.2.6.D)

This zone is shown on the F-14 drawing and Figure 3.3-14.

Fire Barrier Description The north wall separates this fire zone from the exterior and Fire Zone 8.2.6.C, which is part of Fire Area TB-II, and Fire Zones 8.2.8.D and 14.3.A, which are part of Fire Area TB-IV, and is minimum 1-foot 6-inch thick reinforced concrete. This wall has penetrations sealed with noncombustible seals. The east wall separates this fire zone from Fire Zone 8.2.6.C, which is part of Fire Area TB-II, and Fire Zones 8.2.8.D and 14.3.A, which are part of Fire Area TB-IV, and is minimum 4-foot 0-inch thick reinforced concrete. This wall has penetrations sealed with noncombustible seals. The south wall separates this fire zone from Fire Zone 1.1.1.3, which is part of Fire Area RB3-II, and is minimum 1-foot 6-inch thick reinforced concrete. This wall has penetrations 3-hour sealed, except for an HVAC duct which does not contain a fire damper. The west wall separates this fire zone from Fire Zone 8.2.6.E, which is part of Fire Area TB-III, and 4.10-10

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 is minimum 4-foot 0-inch thick reinforced concrete shield wall. This wall has penetrations sealed with noncombustible seals. The floor separates this fire zone from Fire Zones 8.2.5.D and 8.2.5.E, which are part of Fire Area TB-III, and Fire Zone 8.2.5.C, which is part of Fire Area TB-II, and is minimum 1-foot 6-inch thick reinforced concrete. This floor contains unsealed penetrations and hatches. The ceiling separates this fire zone from Fire Zones 8.2.8.A, 14.3.A, and 8.2.8.D, which are part of Fire Area TB-IV, and is minimum 1-foot 6-inch thick reinforced concrete. This ceiling contains unsealed penetrations and hatches.

Safe Shutdown Equipment There is no safe shutdown equipment located in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone is protected throughout by an automatic wet pipe sprinkler system except in the Unit 3 low pressure heater pull region and the region where the main condenser is located.

Design-Basis Fire This fire zone is part of Fire TB-III. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.10 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 5.4 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 8.2.6.D shares a boundary with Fire Areas TB-II, TB-IV and RB3-II. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Areas TB-II, TB-IV and RB3-II. The adequacy of these barriers in preventing fire spread is discussed in Section 5.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects The operation of water suppression systems, use of a manual hose, or piping breaks would not affect safe shutdown as no safe shutdown equipment is located in this zone. Cabling for Unit 2 is present, however, water will not affect undamaged insulated cable and the shutdown path utilized is separate from this area. Water runoff would be handled by the general area drainage system, or would flow to the Turbine Condenser Pit where it could be removed.

4.10-11

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 4.10.9 Turbine Building--Mezzanine Elevation 538 Feet 0 Inch (Fire Zone 8.2.6.E)

This fire zone is shown on the F-14 drawing and Figure 3.3-14.

Fire Barrier Description The north wall separates this fire zone from the exterior and is minimum 1-foot 0-inch thick reinforced concrete supported by exposed structural steel. This wall has a 3-hour fire rating to an exterior exposure fire. The east wall separates this fire zone from Fire Zone 8.2.6.D, which is part of Fire Area TB-III, and is minimum 4-foot 0-inch thick reinforced concrete shield wall.

This wall has an unrated door and penetrations through the wall are sealed with noncombustible seals. The south & west walls separate this fire zone from the exterior. These walls are primarily corrugated steel supported by exposed structural steel, except for the battery and charger room in the southwest corner. The south & west walls at the battery and charger room are reinforced concrete. The floor separates this fire zone from Fire Zones 8.2.5.E and 9.0.B, which are part of Fire Area TB-III, and is 6-inch thick reinforced concrete supported by exposed structural steel.

This floor contains unsealed penetrations and hatches. In addition, this floor contains unsealed electrical penetrations leading to fire zone 8.2.5.E from 4kV Busses 33 & 34 and from 480 V MCC 35-2. The ceiling separates this fire zone from Fire Zone 8.2.8.A, which is part of Fire Area TB-IV, and is minimum 1-foot 6-inch thick reinforced concrete supported by exposed structural steel. This ceiling contains unsealed penetrations and hatches. Fire Zones 6.1 and 7.0.B, which are part of Fire Area TB-III, are separated from this fire zone by concrete walls.

Safe Shutdown Equipment The following safe shutdown equipment is located in this fire zone:

4-kV SWGR 33 4-kV SWGR 34 480 V MCC 38-2 480 V MCC 38-3 Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures Ionization detection is provided throughout most of this zone. This fire zone is also provided with automatic fire suppression systems.

Specifically, a wet pipe sprinkler system protects the area bounded by column/row 52-54/F where the hydrogen seal oil unit and hydrogen station cooling cabinets are located. An open head water spray system protects the seal oil unit itself and is actuated by thermal detectors. Hose 4.10-12

DRESDEN 2&3 AMENDMENT 14 JUNE 2003 stations and fire extinguishers are also located in this fire zone (see Figure B-13 of the Exemption Requests, F.P.R., Volume 4 ).

Design-Basis Fire This fire zone is part of Fire Area TB-III. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.10 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 5.4 of the Exemption Requests (F.P.R. Volume 4).

The Zone 8.2.6.E shares a boundary with Fire Area TB-IV. A fire is prevented from spreading into this fire area by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barrier separates this fire zone from Fire Area TB-IV. The adequacy of these barriers in preventing fire spread is discussed in Section 5.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects The use of water or CO2 in this area will not affect safe shutdown as any adverse effects on hot shutdown equipment would be of no greater severity than those determined to be acceptable for a design-basis fire. Water runoff would be controlled by the general area floor drainage system.

Pedestals are not provided for the 4-kV Switchgear Panels 33 and 34 (exposed by hose) but are provided for MCC panels 38-2 and 38-3 (exposed by hose and the H2 seal oil unit water spray system). The tops of panels 33, 34, 38-2, and 38-3 are sealed to reduce the probability of water entry.

4.10.10 Unit 3 Diesel Generator Room - Elevation 517 Feet 6 Inches Fire Zone 9.0.B)

This fire zone is shown on the F-11 drawing and Figure 3.3-11.

Fire Barrier Description The north, east, and west walls separate this fire zone from Fire Zone 8.2.5.E, which is part of Fire Area TB-III, and are minimum 1-foot 0-inch thick reinforced concrete. The north wall contains two 3-hour rated doors. The south wall of this fire zone is a minimum 1-foot 0-inch thick reinforced concrete exterior wall. The floor of this fire zone is on grade and is minimum 1-foot 6-inch thick reinforced concrete. The ceiling separates this fire zone from Fire Zone 8.2.6.E, which is part of Fire Area TB-III, and is 6-inch thick reinforced concrete.

4.10-13

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 Safe Shutdown Equipment The following safe shutdown equipment is located in this fire zone:

Unit 3 Diesel Generator Unit 3 Diesel Generator Oil Transfer Pump Unit 3 Diesel Generator Vent Fan Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone is provided with a total flooding CO2 fire suppression system and a thermal detection system throughout. Additional protection of the fuel oil day tank is provided by wet pipe sprinklers. A manual hose station is located in Fire Zone 8.2.5.E and is available for use in this fire zone. Curbs are provided to prevent the spread of oil spill fires from the diesel generator rooms and day tank rooms.

Design-Basis Fire This fire zone is part of Fire Area TB-III. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.10 of the Safe Shutdown Report (F.P.R.

Volume 2).

Fire Zone 9.0.B does not share a boundary with any other fire area; therefore, a fire in this zone cannot impact other fire areas.

Fire Suppression Effects Water or CO2 release in this zone would not result in adverse effects of greater severity than those determined to be acceptable for a design-basis fire. Water runoff would be controlled through utilization of floor drains in the general area. The room is curbed.

Full discharge concentration tests have been conducted to verify actual conditions during system actuation. Pressure vents are not provided for the room.

4.10-14

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 4.11 Main Turbine Operating Floor (Fire Area TB-IV)

The Turbine Building operating floor is composed of the following fire zones:

8.2.8.A 8.2.8.C 14.2 8.2.8.B 8.2.8.D 14.3 4.11.1 Turbine Building -- Main Operating Floor Elevation 561 Feet 6 Inches (Fire Zone 8.2.8.A)

This fire zone is shown on the F-16 and F-17 drawings and Figures 3.3-16 and 3.3-17.

Fire Barrier Description The north wall separates this fire zone from the exterior, and Fire Zones 14.2, 14.3, and 8.2.8.D, which are part of Fire Area TB-IV. The exterior portion is steel siding supported by unprotected steel. The portion of the wall adjoining Fire Zones 14.2 and 14.3 is minimum 4-foot 0-inch reinforced concrete with exposed structural steel. The wall adjoining Fire Zone 8.2.8.D is minimum 6-inch thick concrete block up to elevation 566-feet 6-inches. Above 566-feet 6-inches this wall is metal siding supported by exposed structural steel. There are unsealed penetrations and openings in this wall. The east wall separates this fire zone from the Unit 1 Turbine Building and is metal siding supported on exposed structural steel. The south wall separates this fire zone from the exterior; Fire Zones 1.1.2.4, 1.1.2.5.D and 1.1.2.6, which are part of Fire Area RB2-II; Fire Zones 1.1.1.4, 1.1.1.5.D and 1.1.1.6, which are part of Fire Area RB3-II; and Fire Zones 8.2.8.B and 8.2.8.C, which are part of Fire Area TB-IV. The exterior portion of this wall and the portion adjoining Fire Areas RB2-II and RB3-II are minimum 1-foot 6-inch thick reinforced concrete with unsealed penetrations. The portion of the wall separating this fire zone and Fire Zones 8.2.8.B and 8.2.8.C is a minimum 6-inch thick reinforced concrete containing unsealed penetrations and openings. The west wall of this fire zone is an exterior wall of metal siding supported by exposed structural steel. The floor separates this fire zone from Fire Zones 8.2.7, 7.0.A, 8.2.6.A, 8.2.6.B, which are part of Fire Area TB-I; Fire Zone 8.2.6.C, which is part of Fire Area TB-II; and Fire Zones 8.2.6.D and 8.2.6.E, which are part of Fire Area TB-III, and is minimum 1-foot 6-inch thick reinforced concrete supported by exposed structural steel. This floor contains unsealed penetrations and hatches. The ceiling of this fire zone is the roof of the Turbine Building and is built-up roofing on rigid insulation over precast concrete channel slabs supported by exposed structural steel.

Safe Shutdown Equipment There is no safe shutdown equipment located in this fire zone; however, Unit 3 safe shutdown instrument cables are routed through this zone.

4.11-1

DRESDEN 2&3 AMENDMENT 20 JUNE 2015 Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone has automatic fixed suppression in the form of wet pipe sprinkler protection directly over the bearing lift pumps. The suppression systems installed directly over the Unit 2 and Unit 3 MG sets have been isolated and abandoned in place, as the Unit 2 and 3 MG sets have been abandoned in place and drained of combustible oil. The rest of the fire zone does not have either fixed suppression or detection. There are numerous manual hose stations and fire extinguishers distributed throughout this fire zone.

Design-Basis Fire This fire zone is part of Fire Area TB-IV. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.11 of the Safe Shutdown Report (F.P.R.

Volume 2).

Fire Zone 8.2.8.A shares a boundary with Fire Areas RB2-II, RB3-II, TB-I, TB-II, TB-III, and TB-V. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Areas RB2-II and RB3-II. The adequacy of these barriers in preventing fire spread is discussed in Sections 3.3, 4.2, and 5.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Water or CO2 discharge in this zone would not affect safe shutdown, since no safe shutdown equipment is located in this zone. Water runoff would be handled by the floor drainage system in the general area.

4.11.2 Turbine Building--Vent Floor Elevation 581 Feet 4 Inches (Fire Zone 8.2.8.B)

This fire zone is shown on the F-15 drawing and Figure 3.3-15.

Fire Barrier Description The north, east, and west walls separate this fire zone from Fire Zone 8.2.8.A, which is part of Fire Area TB-IV, and are minimum 6-inch thick reinforced concrete. These walls contain unsealed penetrations and openings. The south wall separates this fire zone from Fire Zone 1.1.2.5.D, which is part of Fire Area RB2-II, and Fire Zone 1.1.1.5.D, which is part of Fire Area RB3-II, and is minimum 1-foot 0-inch thick reinforced concrete. This wall contains HVAC ducts which do not have fire dampers. The floor separates this fire zone from Fire Zone 8.2.8.A, which is part of Fire Area TB-IV, and is minimum 1-foot 6-inch thick reinforced concrete supported by unprotected steel. This floor contains a stairwell and unsealed penetrations. The ceiling separates this fire zone from Fire Zone 8.2.8.C, which is part of Fire Area TB-IV, and is minimum 1-foot 4.11-2

DRESDEN 2&3 AMENDMENT 20 JUNE 2015 6-inch thick reinforced concrete supported on unprotected steel. This ceiling contains an open stairwell and unsealed penetrations.

Safe Shutdown Equipment There is no safe shutdown equipment located in this fire zone. This floor does contain the Reactor Building venting system for both units.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures The suppression system installed directly under this fire zone to cover the Unit 2 and 3 MG sets on the main operating floor has been isolated and abandoned in place, as the Unit 2 and 3 MG sets have been abandoned in place and drained of combustible oil. Located in this fire zone are portable CO2 fire extinguishers. Manual hose stations located on the main operating floor are available to this fire zone.

Design-Basis Fire This fire zone is part of Fire Area TB-IV. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.11 of the Safe Shutdown Report (F.P.R.

Volume 2).

Fire Zone 8.2.8.B shares a boundary with Fire Area RB2-II and RB3-II. A fire is prevented from spreading into this fire area by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barrier separates this fire zone from Fire Area RB3-II. The adequacy of these barriers in preventing fire spread is discussed in Section 3.3 and 4.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Water release in this zone would not result in adverse effects of greater severity than those determined to be acceptable for a design-basis fire. No safe shutdown paths would be affected.

Water runoff would be controlled through utilization of floor drains in the general area.

4.11.3 Turbine Building - Vent Floor Elevation 601 Feet 4 Inches (Fire Zone 8.2.8.C)

This fire zone is shown on the F-15 drawing and Figure 3.3-15.

4.11-3

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Fire Barrier Description The north, east and west walls separate this fire zone from Fire Zone 8.2.8.A, which is part of Fire Area TB-IV, and is minimum 6-inch thick reinforced concrete. This wall contains unsealed mechanical penetrations and openings. The south wall separates this fire zone from Fire Zones 1.1.1.6 and 1.1.2.6, which are part of Fire Areas RB3-II and RB2-II, respectively, and is minimum 1-foot 0-inch thick reinforced concrete. All penetrations are sealed with noncombustible seals. The floor separates this fire zone from Fire Zone 8.2.8.B, which is part of Fire Area TB-IV, and is minimum 1-foot 0-inch thick reinforced concrete with exposed structural steel. This floor contains an open stairwell and unsealed penetrations. The ceiling separates this fire zone from the exterior and is built-up roofing on rigid insulation over precast concrete channel slabs supported by exposed structural steel.

Safe Shutdown Equipment There is no safe shutdown located in this fire zone. The Turbine Building ventilation fans are located in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures This fire zone does not have any fixed suppression or detection present. CO2 fire extinguishers are located in this fire zone.

Design-Basis Fire This fire zone is part of Fire Area TB-IV. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.11 of the Safe Shutdown Report (F.P.R.

Volume 2).

Fire Zone 8.2.8.C shares a boundary with Fire Areas RB2-II and RB3-II. A fire is prevented from spreading into these fire areas by 3-hour (or equivalent) fire barriers.

The equivalent 3-hour barriers separate this fire zone from Fire Area RB2-II and RB3-II. The adequacy of these barriers in preventing fire spread is discussed in Sections 3.3 and 4.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects There are no fixed or manual suppression systems in this area. Therefore, there are no effects on safe shutdown.

4.11-4

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 4.11.4 North Turbine Room--Vent Floor Multiple Elevations (Fire Zone 8.2.8.D)

This fire zone is shown on the F-22 and F-23 drawings and Figures 3.3-22 and 3.3-23.

Fire Barrier Description The north wall separates this fire zone from the Radwaste Fire Area and the exterior, and is metal siding supported by exposed structural steel. The east and west walls are exterior walls and are minimum 1-foot 0-inch thick reinforced concrete. The south wall separates this fire zone from Fire Zone 8.2.8.A which is part of Fire Area TB-IV and Fire Zone 8.2.6.C which is part of Fire Area TB-II, and is minimum 4-foot 0-inch thick reinforced concrete. The floor separates this fire zone from Fire Zone 8.2.6.C which is part of Fire Area TB-II and Fire Zone 8.2.6.D which is part of Fire Area TB-III, and is minimum 6-inch thick reinforced concrete. This floor contains a stairwell leading to Fire Zones 8.2.6.C and 8.2.6.D and unsealed mechanical penetrations. The ceiling separates this fire zone from the exterior and consists of precast concrete channel slabs on exposed structural steel.

Safe Shutdown Equipment There is no equipment associated with safe shutdown systems located in this fire zone. This fire zone contains Turbine Building supply and exhaust ventilation systems. These systems include fans, filters, chillers, and other associated equipment.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Measures and Criteria This fire zone is equipped with fire extinguishers and manual hose stations are available for use in this fire zone. This fire zone contains Turbine Building venting system equipment which is not associated with any hot shutdown method and therefore normal shutdown methods will be employed.

Design-Basis Fire This fire zone is part of Fire Area TB-IV. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.11 of the Safe Shutdown Report (F.P.R.

Volume 2).

Fire Zone 8.2.8.D shares a boundary with Fire Areas TB-II and TB-III. A fire is prevented from spreading into these areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Areas TB-II and TB-III. The adequacy of these barriers in preventing fire spread is discussed in Section 5.2 of the Exemption Requests (F.P.R. Volume 4).

4.11-5

DRESDEN 2&3 AMENDMENT 13 JUNE 2009 Fire Suppression Effects Water release in this zone would not result in adverse effects of greater severity than those determined to be acceptable for a design-basis fire. No safe shutdown paths would be affected.

Water runoff would be controlled through utilization of floor drains in the general area.

4.11.5 Unit 2 Off-Gas Recovery Rooms Elevations 549 Feet 0 Inch, 571 Feet 0 Inch, and 590 Feet 6 Inches (Fire Zone 14.2)

This fire zone is shown on the F-22 drawing and Figure 3.3-22.

Fire Barrier Description This fire zone is subdivided into fire zones A, B, and C which correspond to elevations 549 feet 0 inch, 571 feet 0 inch, and 590 feet 6 inches, respectively.

The north wall separates this fire zone from Fire Zone 8.2.8.D, which is part of Fire Area TB-IV, and is minimum 4-foot 0-inch thick reinforced concrete. This wall contains unsealed mechanical penetrations and five unrated doors to Fire Zone 8.2.8.D. The east wall separates this fire zone from the exterior and is minimum 4-foot 0-inch thick reinforced concrete up to elevation 590 feet 6 inches. Above elevation 590 feet 6 inches, this wall is constructed of concrete block with insulated metal siding. The south wall separates this fire zone from Fire Zone 8.2.6.B, which is part of Fire Area TB-I, and Fire Zone 8.2.8.A, which is part of Fire Area TB-IV, and is minimum 4-foot 0-inch thick reinforced concrete with exposed structural steel inside the Turbine Building.

The west wall separates this fire zone from the exterior and Fire Zone 8.2.8.D, which is part of Fire Area TB-IV, and is minimum 4-foot 0-inch thick reinforced concrete up to elevation 590 feet 6 inches. Above elevation 590 feet 6 inches, this wall is constructed of concrete block with insulated metal siding. The floor separates this fire zone from Fire Zone 8.2.6.B, which is part of Fire Area TB-I, and is minimum 2-feet 0-inch thick reinforced concrete with exposed structural steel under a 6-inch concrete slab. The ceiling separates this fire zone from the exterior and is minimum 4-feet 0-inch thick reinforced concrete slab on exposed structural steel.

Safe Shutdown Equipment There is no safe shutdown equipment located in this fire zone. This fire zone does contain the steam jet air ejectors, the gland seal condenser and off-gas condensers and water separators.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

4.11-6

DRESDEN 2&3 AMENDMENT 13 JUNE 2009 Fire Protection Measures and Criteria Fire Zones 14.2.B and 14.2.C are equipped with manual hose stations. Fire extinguishers are located outside of Fire Zone 14.2.A (see Figure B-21 of the Exemption Requests, F.P.R.,

Volume 4).

Design-Basis Fire This fire zone is part of Fire Area TB-IV. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.11 of the Safe Shutdown Report (F.P.R.

Volume 2).

Fire Zone 14.2 shares a boundary with Fire Area TB-I. A fire is prevented from spreading into these areas by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Area TB-I. The adequacy of these barriers in preventing fire spread is discussed in Section 5.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Water release in this zone would not result in adverse effects of greater severity than those determined to be acceptable for a design-basis fire. No safe shutdown paths would be affected.

Water runoff would be controlled through utilization of floor drains in the general area.

4.11.6 Unit 3 Off-Gas Recovery Rooms Elevations 549 Feet 0 Inch, 571 Feet 0 Inch and 590 Feet 6 Inches (Fire Zone 14.3)

This fire zone is shown on the F-23 drawings and Figure 3.3-23.

Fire Barrier Description This fire zone is subdivided into fire zones A, B, and C which correspond to elevations 549 feet 0 inch, 571 feet 0 inch, and 590 feet 6 inches, respectively. The north wall separates this fire zone from Fire Zone 8.2.8.D, which is part of Fire Area TB-IV, and is minimum 4-foot 0-inch thick reinforced concrete. This wall contains unsealed mechanical penetrations and five doors to Fire Zone 8.2.8.D. The east wall separates this fire zone from the exterior and Fire Zone 8.2.8.D, which is part of Fire Area TB-IV, and is minimum 4-foot 0-inch thick reinforced concrete up to elevation 590 feet 6 inches. Above elevation 590 feet 6 inches, this wall is constructed of concrete block with insulated metal siding. The south wall separates this fire zone from Fire zone 8.2.6.D, which is part of Fire Area TB-III, and Fire Area 8.3.8.A, which is part of Fire Area TB-IV, and is minimum 4-foot 0-inch thick reinforced concrete with exposed structural steel inside the Turbine Building. The west wall separates this fire zone from the exterior and is minimum 4-foot 0-inch thick reinforced concrete up to elevation 590 feet 6 inches. Above elevation 590 feet 6 inches, this wall is constructed of concrete block with insulated metal siding. The floor separates this fire zone from Fire Zone 8.2.6.D, which is part of Fire Area TB-III, and is minimum 2-feet 0-inch thick reinforced concrete with exposed structural steel under a 6-inch 4.11-7

DRESDEN 2&3 AMENDMENT 13 JUNE 2009 concrete slab. The ceiling separates this fire zone from the exterior and is minimum 4-foot 0-inch thick reinforced concrete slab with exposed structural steel.

Safe Shutdown Equipment There is no safe shutdown located in this fire zone. This fire zone does contain the steam jet air ejectors, the gland seal condenser and off-gas condensers and water separators.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures Fire Zones 14.3.B and 14.3.C are equipped with manual hose stations. Fire extinguishers are located outside of Fire Zone 14.3.A (see Figure B-22 of the Exemption Requests, F.P.R.,

Volume 4).

Design-Basis Fire This fire zone is part of Fire Area TB-IV. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.11 of the Safe Shutdown Report (F.P.R.

Volume 2).

Fire Zone 14.3 shares a boundary with Fire Area TB-III. A fire is prevented from spreading into this fire area by 3-hour (or equivalent) fire barriers. The equivalent 3-hour barriers separate this fire zone from Fire Area TB-III. The adequacy of these barriers in preventing fire spread is discussed in Section 5.2 of the Exemption Requests (F.P.R. Volume 4).

Fire Suppression Effects Water release in this zone would not result in adverse effects of greater severity than those determined to be acceptable for a design-basis fire. No safe shutdown paths would be affected.

Water runoff would be controlled through utilization of floor drains in the general area.

4.11-8

DRESDEN 2&3 AMENDMENT 19 JUNE 2013 4.12 Control Room Auxiliary Electric Equipment Room (Fire Area TB-V)

This fire area contains the majority of the control and switching equipment for the operation of both units. The following are the fire zones contained in this fire area:

2.0 6.2 4.12.1 Main Control Room Elevation 534 Feet 0 Inch (Fire Zone 2.0)

This fire zone is shown on the F-8 drawings and Figure 3.3-8.

Fire Barrier Description The north, west and south walls separate this fire zone from Fire Zone 8.2.6.A, which is part of Fire Area TB-1, and are constructed of a minimum 1-foot-6-inch reinforced concrete or concrete block that carries a 3-hour rating. The east wall is a 3-hour fire rated wall and space, which separates this fire zone from Unit 1. Locker room and kitchen areas are included within this fire zone, which were constructed within a portion of the former Unit 1 Control Room. The kitchen area is separated from the control room by a one-hour fire barrier including a 45- minute fire door. The ceiling of the Unit 2/3 Control Room separates this fire zone from Fire Zone 7.0.A, which is part of Fire Area TB-1, and is a minimum 1-foot 6-inch thick reinforced concrete supported by unprotected steel. A portion of the ceiling separates this fire zone from Unit 1.

The HVAC ducts, which penetrate the walls and ceilings, contain 3-hour fire rated dampers.

The floor of the Unit 2/3 control room separates this fire zone from Fire Zone 6.2, which is also part of Fire Area TB-V, and is a minimum 6-inch thick reinforced concrete slab which is supported on protected structural steel beams and columns with all penetrations sealed with noncombustible material. The kitchen and locker room portion of the control room floor separates this fire zone from Unit 1 and is also a 3-hour fire rated barrier constructed of a minimum 6-inch thick reinforced concrete slab which is supported on protected structural steel beams and columns with all penetrations sealed with noncombustible material. The access doors to the control room are Class A rated fire doors.

Safe Shutdown Equipment:

The following is a list of safe shutdown equipment:

Main Control Boards 902-3 902-15 903-3 903-17 902-4 902-17 903-4 903-18 902-5 902-18 903-5 903-19 902-6 902-19 903-6 903-20 902-7 902-20 903-7 903-39 902-8 902-39 903-8 903-54 902-10 902-54 903-13 903-55 902-13 902-55 903-15 903-56 903-16 923-1 ADS Inhibit Switch 4.12-1

DRESDEN 2&3 AMENDMENT 19 JUNE 2013 Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures Smoke detectors are present in the HVAC ducts leaving the control room. The fire zone is also provided with ceiling level ionization detection. Fire extinguishers are located both in and outside the access doors to this fire zone. Manual hose stations located in Fire Zone 8.2.6.A are available for use in the control room.

A fire detection system including smoke detectors and electromagnetic door closers (in the locker room and kitchen areas) is installed to provide area wide detection in the area previously used for the Unit 1 control room. The detection system is interlocked with the 45-minute fire-rated door in the kitchen and the 3-hour fire-rated door in the locker room.

Whenever the detectors installed with relay bases sense any smoke, the door closer will be released, and the door will automatically close. This system also allows the doors to close on loss of power which puts it in a "Fail-Safe" mode.

Design-Basis Fire This fire zone is part of Fire Area TB-V. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.12 of the Safe Shutdown Report (F.P.R.

Volume 2).

An alternative shutdown method is available to achieve hot shutdown in the event of a fire in this zone, but complete detection and suppression has not been provided. This is justified in Section 8.2 of the Exemption Requests (F.P.R. Volume 4,Section III.8).

The ceiling of this zone is not fire rated, due only to the exposed structural steel supporting the ceiling. Justification for not protecting the structural steel in the control room ceiling is provided in Section 10.1 of the Exemption Requests (F.P.R. Volume 4).

Fire Zone 2.0 shares a boundary with Fire Areas TB-1 and Unit 1. A fire is prevented from spreading into these fire areas by 3-hour barriers.

Fire Suppression Effects Since there are no water suppression systems or piping within the Control Room, water entry would arise from use of manual hose streams inside the Control Room from hose stations located outside this zone. Any damage resulting from water discharge within the room would be of no greater severity than that which would result from a design basis fire. Therefore, water discharge from hose streams is tolerable, and the runoff would be handled by general area floor drains located outside of the Control Room. Penetrations in the ceiling are sealed.

4.12-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2009 4.12.2 Auxiliary Electric Equipment Room Elevation 517 Feet 6 Inches (Fire Zone 6.2)

This fire zone is shown on the F-8 drawings and Figure 3.3-8.

Fire Barrier Description The north, west and south walls separate this fire zone from Fire Zone 8.2.5.A, which is part of Fire Area TB-I, and are minimum 1-foot 6-inch thick, 3-hour rated reinforced concrete fire barriers. Access is gained to the AEER through two "A" label fire doors. The east wall which contacts the metal siding of the Unit 1 Turbine Building is a 3-foot 3-inch thick, 3-hour rated reinforced concrete fire barrier. A sealed sleeve exists through the east wall and allows connection between the Unit 2/3 computer room and the Unit 1 battery room. The ceiling separates this fire zone from Fire Zone 2.0, which is part of Fire Area TB-V, and is a minimum 6-inch thick reinforced concrete which is supported on protected structural steel beams and columns with all penetrations sealed with noncombustible material. The floor which forms a portion of the basement of the Turbine Building also has an opening which leads to Fire Zone 8.2.4, which is part of Fire Area TB-III. This opening is covered by checker plating with the actual access to the tunnel protected by a Class "A" fire door and 3-hour seals.

Safe Shutdown Equipment 120/240V Essential Service Distribution Panels 902-49, 903-49 120/240V Instrument Buses 902-50, 903-50 This fire zone also contains logic and trip circuitry for the following systems:

Auto Blowdown Main Steam Isolation Inboard/Outboard Core Spray PCIS HPCI Process Radiation Monitor LPCI Reactor Protection M-G sets Combustible Material and Fire Load Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Measures and Criteria This fire zone is protected by a cross-zoned ionization detection system which actuates an automatic Halon suppression system. A manual CO2, total flooding, suppression system is also provided for the AEER. Access to this fire zone is controlled through administrative procedure for the locked doors. The original cabling in this room has been coated with a fire retardant material to make them more difficult to ignite. Hose stations and portable extinguishers are provided near the access doors to the room for manual fire suppression. Curbs in the AEER west 4.12-3

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 door protect the AEER from potential transient combustibles in the Unit 2 trackway. Curbs around SWGR 25 and 26 (Fire Zone 8.2.5.A) protect the AEER from the only fixed hazards in the vicinity.

Design-Basis Fire This fire zone is part of Fire Area TB-V. In the event of a fire in this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.12 of the Safe Shutdown Report (F.P.R.

Volume 2).

Fire Zone 6.2 shares a boundary with Fire Areas TB-I, TB-III, and Unit 1. A fire is prevented from spreading into these fire areas by 3-hour fire barriers.

Fire Suppression Effects Since there are no water suppression systems or piping within the AEER, water entry would arise from use of manual hose streams inside the AEER from hose stations located outside this zone.

Any damage resulting from water discharge within the room would be of no greater severity than that which would result from a design-basis fire. Therefore, water discharge from hose streams is tolerable. The runoff would travel to access doors to the Unit 3 Cable Tunnel (which would have to be opened manually to facilitate this travel) where it would be removed by floor drains.

Penetrations in the ceiling are sealed. The tops of safety-related panels are sealed.

CO2 discharge presents the possibility of thermal shock to the distribution panels due to the extremely low temperature of CO2 near the discharge nozzles. This could result in an icing condition on this equipment or condensation within the panels from moisture in the air.

However, these effects would be of no greater severity than those of a design-basis fire in the room.

No full discharge concentration tests have been conducted to verify actual conditions during systems actuation. Pressure vents are not provided for the room.

Halon discharge should have no adverse effects on safe shutdown equipment, except for the possibility of overpressurization as noted for CO2 above.

4.12-4

DRESDEN 2&3 AMENDMENT 16 JUNE 2007 4.13 Crib House Fire Area Fire Zone 11.3 makes up the Crib House Fire Area.

4.13.1 Crib House Elevations 517 Feet 6 Inches, 509 Feet 6 Inches and Basement (Fire Zone 11.3)

This fire zone is shown on the F-18 drawings and Figure 3.3-18.

Fire Barrier Description The crib house walls are 11-5/8 inch concrete block construction with exposed structural steel.

The floor separating Elevation 517-feet 6-inch and the basement is a concrete slab but contains open stairwells and hatches and is unrated. The floor of Elevation 509-feet 6-inches is exposed to the inlet water. There is a partial wall between Elevation 517-feet 6-inches and 509-feet 6-inches.

This wall contains both unsealed mechanical and electrical openings. The roof is unrated built up roofing over 1-inch insulation on three, 2-inch precast concrete channel roof slabs supported by exposed structural steel. The roof has four fan openings and drains.

Safe Shutdown Equipment The safe shutdown equipment in this fire area consists of the five service water pumps on elevation 509-feet 6-inches and the three diesel generator cooling water pumps in the basement.

This equipment is:

Service water pumps 2A, 2B & 2/3-3901, 3A, 3B-3901 Unit 2 Diesel Generator cooling water pump 2-3903 B Unit 3 Diesel Generator cooling water pump 3-3903 B 2/3 Diesel Generator cooling water pump 2/3-3903 B Service Water Connection to Fire System 2-3906 Diesel Fire Pump Discharge Pressure Indicator PI 2/3-4141-2 Service Water Pressure Indicator 2-3941-8A, 2-3941-8B, 3-3941-8A, 3-3941-8B 2/3 Diesel Fire Pump 2/3-4101 The fire pump is also located in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

4.13-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Fire Protection Measures and Criteria Automatic wet pipe sprinklers are provided throughout the ceiling level of Elevation 517 feet 6 inches and 509 feet 6 inches. Curbs along column/row 3.7 and column/row B and a curb around the diesel fire pump day tank will prevent combustible liquid from spreading throughout the crib house floor. The curb around the day tank has a drain line to the yard drain system. The diesel fire pump and associated day tank are provided with local open head automatic water spray system and thermal detection for actuation. A curb along the entire column/row B at the 517-foot 6-inch level will prevent exposure of the service water pumps at elevation 509-feet 6-inches to combustible liquid spills in the area of the circulating water pump on the higher elevation.

An open head water spray system activated by linear thermal detectors will protect all cable trays and conduits along the north, east, and west basement walls. These raceways contain power cables for the service water pumps and 2/3 diesel generator cooling water pump. The conduits from both units' cable trays to the 2/3 diesel generator cooling water pump automatic transfer switch and from the switch to the pump are enclosed in a 1-hour rated barrier. Separate photoelectric detection is provided throughout this level. Ceiling level sprinklers are provided between column/rows 3.5 and 4.5 to separate the cables from each unit at opposite ends of the building at this level. Additionally, the 2/3 diesel generator cooling water pump is specifically protected by a curb and a thermally-actuated automatic open head water spray system. Portable extinguishers and hose stations are available for manual fire suppression.

See Figure B-17 of the Exemption Requests (F.P.R. Volume 4) for an illustration of these fire protection measures.

Design-Basis Fire This fire zone is part of the Crib House fire area. In the event of a fire is this fire zone, both hot and cold shutdown can be achieved as discussed in Section 4.13 of the Safe Shutdown Report (F.P.R. Volume 2). Fire Zone 11.3 does not share a boundary with any other fire area, therefore, a fire in this zone cannot impact other fire areas.

Fire Suppression Effects The effects of water discharge in this area would be less severe than those postulated for a design-basis fire. Only one of the widely spaced service water pumps on the elevation 509 feet 6 inches is needed for safe shutdown, and a single failure could not affect all five of the pumps.

Water will not adversely affect undamaged insulated cables. Water runoff would travel to drains or the lowest level of the Crib House. Sump pumps remove water from this level and discharge it to the intake area. The DG cooling water pumps are the only safe shutdown equipment located at the lower level, but are submersible and, therefore, are not subject to water damage.

4.13-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 4.14 Radwaste Building The following fire zones are included in the Radwaste Building Fire Area:

14.1 14.5 14.6 4.14.1 Radwaste Collection and Holding Area (Fire Zone 14.1)

This fire zone is shown on the F-19, F-20, and F-21 drawings and Figures 3.3-19, 3.3-20, and 3.3-21.

Fire Barrier Description Elevation 488 feet 0 inch and a major portion of elevation 507 feet 0 inch are below grade (elevation 517 feet 0 inch), and the reinforced concrete walls are in contact with the exterior. The portion of elevation 507 feet 0 inch which is above ground as well as elevations 519 feet 6 inches and 529 feet 6 inches have 2-foot 0-inch thick concrete shield walls which separate them from Fire Zones 14.5 and 14.6. The exterior walls of this fire zone are minimum 1-foot 0-inch thick reinforced concrete with the exception of the exterior walls of the radwaste access building, which are metal frame. The wall separating this fire zone from the Turbine Building is constructed of 2-foot 0-inch concrete from elevation 517 feet 6 inches to 555 feet 7 inches, with an opening filled with removable precast concrete block sections. Between rows 42 and 46, it consists of 1-foot 0-inch concrete from elevation 517 feet 6 inches to 529 feet 6 inches and 7-5/8 inch hollow concrete block from elevation 529 feet 6 inches to 541 feet 2 inches. There are two openings in this section consisting of one non-labeled door and one louvered opening. West of row 45 with the exception of the radwaste access building, an exterior 3-foot 0-inch concrete wall is constructed from elevation 517 feet 6 inches to 534 feet 8 inches, with an opening consisting of removable precast concrete blocks. The roof and floor are of concrete construction.

Safe Shutdown Equipment There is not safe shutdown equipment in this fire zone. This fire zone does contain equipment associated with the various radwaste systems.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for inforration on combustible material and fire loading for this zone.

Fire Protection Measures and Criteria There are hose stations located at elevations 503-feet 3/4-inch, two at 507-feet 0-inch, two at 517-feet 6-inches, 519-feet 6-inches, 540-feet 0-inch, 551-feet 0-inch. There are also nine portable CO2 fire extinguishers located at elevations 488-feet 0-inch 507-feet 0-inch, four at 517-4.14-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 feet 6-inches, 519-feet 6-inches, and two at 540-feet 0-inch. One dry chemical extinguisher is located at 517-feet 6-inches.

The Radwaste Access Building is protected by a wet-pipe sprinkler system. Portable extinguishers are located within the Access Building.

Design-Basis Fire The existing fire hazards are not significant enough to present a problem by breaching radioactive systems and building confinement which would allow a release of radioactive material to the environment in excess of 10 CFR 100 limits. Any fire which could generate radioactive combustion products will sound high radiation alarms inside the radwaste control room, resulting in manual isolation of the HVAC for that area by the operator. Since no safe shutdown systems are located in this fire zone, a design-basis fire would not prevent the safe shutdown of the plant.

Within the radwaste system, dry active materials (such as paper, rags, etc.) are located in the dry active waste compactor and storage area of the Radwaste Building. These are the only combustible radioactive materials in the radwaste system. Because of the low level activity of this material a fire would not produce radiological release consequences exceeding 10 CFR 20 limits. All other radwaste material is contained in tanks with water or in 55-gallon drums solidified in cement. It is inconceivable to postulate a fire involving this material.

Fire Suppression Effects No safe shutdown paths would be affected by water discharge in this area. Water runoff would be handled by the floor drains in the general area.

4.14.2 Radwaste Solidification Building (Fire Zone 14.5)

This fire zone is shown on the F-19 and F-20 drawings and Figures 3.3-19 and 3.3-20.

Fire Barrier Description The north wall is an exterior wall of reinforced concrete and solid concrete block with non-labeled doors. Attached to the north side of the building is the empty drum storage building with exposed steel and metal siding and a metal deck roof. The east wall is an exterior wall of 24-inch concrete and 2-hour external fire rated metal siding with openings for a Class "B" pass door and Class "B" rolling-steel truck door. The south wall, an interior wall shared with the Turbine Building is concrete and concrete block with an unrated door and non-rated louvered openings.

HVAC penetrations are provided with rated fire dampers. The west wall is shared with Fire Zone 14.1 and 14.6 and is concrete with many non-rated openings. The floor at elevation 529 feet 6 inches is made of 24-inch reinforced concrete and forms the basement of the building.

4.14-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 The roof of the main building is built-up roofing on concrete decking on exposed structural steel.

The roof of the HVAC equipment room is built-up roofing on 2-inch insulation on metal decking supported by exposed steel.

Safe Shutdown Equipment There is no safe shutdown equipment located in this fire zone. This fire zone does contain radwaste equipment.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Measures and Criteria There are two fire hose stations located in this building. One portable CO2 fire extinguisher is located in this area. Seven automatic fire detectors are provided (see Figures B-18 and B-19 of the Exemption Requests, F.P.R., Volume 4 ).

Design-Basis Fire The existing fire hazards are not significant enough to present a problem due to the breaching of the radioactive systems and building constraints allowing a release of radioactive material to the environment in excess of 10 CFR 100 limits. Any fire which could generate radioactive combustion products will sound high radiation alarms inside the building's control room, which will result in manual isolation of the HVAC for the area by the operator. Four of the seven fire detectors also are interlocked to shut down HVAC equipment upon receipt of an alarm.

Fire Suppression Effects No safe shutdown paths would be affected by water discharge in this area. Water runoff would be handled by the floor drains in the general area.

4.14.3 Maximum Recycle Radwaste Building Area (Fire Zone 14.6)

This fire zone is shown on the F-19 and F-20 drawings and Figures 3.3-19 and 3.3-20.

Fire Barrier Description The building below elevation 558-feet 0-inch is composed of structural concrete supported by protected structural steel with non-rated openings. The building above elevation 558-feet 0-inch contains unrated structural concrete, exposed structural steel, and metal siding. The structural steel is not fireproofed.

4.14-3

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Safe Shutdown Equipment There is no safe shutdown equipment located in this fire zone. This fire zone does contain radwaste equipment.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Measures and Criteria There are three fire hose stations located at elevation 523 feet 0 inch, one at 544 feet 6 inches, and one at 562 feet 0 inches. There are also six CO2 portable fire extinguishers.

Design-Basis Fire The existing fire hazards are not significant enough to present a problem by breaching of radioactive systems and building confinement and allowing a release of radioactive material to the environment in excess of the 10 CFR 100 limits. Any fire which could generate radioactive combustion products will sound high radiation alarms inside the radwaste control room, which will result in manual isolation of the HVAC for that area by the operator.

Fire Suppression Effects No safe shutdown paths would be affected by water discharge in this area. Water runoff would be handled by the floor drains in the general area.

4.14-4

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 4.15 Miscellaneous Outside Structures The following fire zones are included in the miscellaneous outside structure fire area:

14.4 18.2.1 18.3.2 18.6 18.1.1 18.2.2 18.4 18.7.1 18.1.2 18.3.1 Unit 1 Plant Structures 18.7.2 4.15.1 Off-Gas Filter Building Area (Fire Area 14.4)

This area is shown on general arrangement Drawing M-10A.

Fire Barrier Description Walls are concrete and metal siding with exposed structural steel and non-labeled doors. East and south side walls each contain two open louvers. The floor at elevation 484 feet 0 inch and elevation 476 feet 0 inch is reinforced concrete and forms the basement of the building. The roof at elevation 517 feet 6 inches is 24-inch concrete with removable plugs. At the 537-foot level, the roof is built-up roofing over rigid insulation over precast concrete slabs or supported by exposed structural steel and structural concrete and has no fire rating. There are no fire dampers in HVAC ducts.

Safe Shutdown There is no equipment located in this area needed for safe shutdown.

Combustible Material Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Measures and Criteria There is a fire hose station at elevation 521 feet 6 inches. There are also two portable CO2 fire extinguishers and five dry chemical extinguishers located in this area.

Design-Basis Fire The existing fire hazards are not significant enough to present a problem due to the breaching of the radioactive systems and building constraints allowing a release of radioactive material to the environment in excess of 10 CFR 100 limits. Any fire which could generate radioactive combustion products will sound high radiation alarms inside the control room, which will result in manual isolation of the HVAC for that area by the operator.

4.15-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 The potential radiological consequences of the Dresden Units 2 & 3 off-gas system component failure have been submitted to the Atomic Energy Commission (now the Nuclear Regulatory Commission) in Table 4 of Quad Cities Units 1 & 2 Special Report No. 1 and Supplementary Information for Dresden Units 2 & 3 Special Report No. 4A, Modified Off-Gas System, Commonwealth Edison Company, June 11, 1974. The docket number is 50-237. No credible hypothetical fires in the off-gas system could produce doses to the public above those calculated, using very conservative assumptions, in this report.

Should a fire occur in a charcoal vessel, the temperature elements on the charcoal vessels would initiate a high temperature alarm in the control room and provide warning of a fire. In addition, radiation instrumentation in the stack would provide high radiation warnings, providing further assurance that the abnormal condition would be recognized and that timely action would be taken by the operating staff.

However, in the event a fire should occur, a very conservative analysis would assume a release of 100% of the iodine from a fire in the first charcoal bed (this also conservatively assumes the loss of function of all subsequent charcoal beds) and 100% of the noble Gas Source term, described in Table 3 of the previously referenced report, through the station chimney. The off-gas system charcoal beds are in steel vessels. However, in the unlikely event that the system integrity is not maintained, the result of this analysis would not be changed since the off-gas charcoal beds are located in the Off-gas Filter Building and the Off-gas Filter Building HVAC would exhaust through the station chimney.

Assuming a fumigation accident meteorology consistent with Regulatory Guide 1.3, the resultant calculated radiological consequences at the exclusion area boundary are 332 mrem thyroid and 2.7 mrem whole body (see Sargent & Lundy Calc No. 2-78-D2&3 in F.P.P.D.P. Volume 6).

These postulated doses are well within 10 CFR 20 limits (1,500 mrem and 500 mrem, respectively).

Fire Suppression Effects No safe shutdown paths would be affected by water discharge in this area. Water runoff would be handled by floor drains in the general area.

4.15.2 Unit 3 Main Power Transformer (Fire Zone 18.1.1)

This structure is shown on the F-25 drawings and Figure 3.3-25.

Fire Barrier Description This transformer sits on an 8-foot 0-inch thick reinforced concrete base. There are no walls or ceiling to act as fire barriers, but a crushed rock sump is provided around the transformer to contain transformer oil if a leak should occur.

4.15-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Safe Shutdown Equipment There is no equipment or cabling needed for safe shutdown in this fire zone.

Fire Protection Measures and Criteria The transformer is protected by an automatic deluge spray system, which is activated from the transformers protective relaying and not the thermal detectors (thermal detectors provide alarm signaling only). Alarms are provided which annunciate locally and in the control room to indicate operation of the system (see Figure B-24 of the Exemption Requests, (F.P.R. Volume 4).

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Design Basis Fire If a fire started in the transformer, it would be quickly extinguished by the deluge system. It would not spread to the Turbine Building, because the walls of the Turbine Building carry a 3-hour rating to an external exposure fire in the vicinity of the transformers. A fire involving a transformer would cause the respective unit to trip, as well as probable loss of offsite power for that unit. The unit would be shut down using the normal shutdown path by making use of onsite power.

Fire Suppression Effects No safe shutdown paths would be affected by water discharge in this area. Water runoff would be handled by the crushed rock sumps surrounding the transformers.

4.15.3 Unit 2 Main Power Transformer (Fire Zone 18.1.2)

This structure is shown on the F-24 drawings and Figure 3.3-24.

Fire Barrier Description This transformer sits on an 8-foot 0-inch thick reinforced concrete base. There are no walls or ceiling to act as fire barriers, but a crushed rock sump is provided around the transformer to contain transformer oil if a leak should occur.

Safe Shutdown Equipment There is no equipment or cabling needed for safe shutdown in this fire zone.

4.15-3

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Fire Protection Measures and Criteria The transformer is protected by an automatic deluge spray system, which is activated from the transformers protective relaying and not the thermal detectors (thermal detectors provide alarm signaling only). Alarms are provided which annunciate locally and in the control room to indicate operation of the system (see Figure B-23 of the Exemption Requests, F.P.R., Vol. 4).

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Design Basis Fire If a fire started in the transformer, it would be quickly extinguished by the deluge system. It would not spread to the Turbine Building, because the walls of the Turbine Building carry a 3-hour rating to an external exposure fire in the vicinity of the transformers though the door in this wall is unrated. A fire involving a transformer would cause the respective unit to trip, as well as probable loss of offsite power for that unit. The unit would be shut down using the normal shutdown path by making use of onsite power.

Fire Suppression Effects No safe shutdown paths would be affected by water discharge in this area. Water runoff would be handled by the crushed rock sumps surrounding the transformers.

4.15.4 Unit 3 Auxiliary Transformer (Fire Zone 18.2.1)

This structure is shown on the F-25 drawings and Figure 3.3-25.

Fire Barrier Description This transformer sits on a 12-foot 9-inch thick reinforced concrete base. There are no walls or ceiling to act as fire barriers, but a crushed rock sump is provided around the transformer to contain transformer oil if a leak should occur.

Safe Shutdown Equipment There is no equipment or cabling needed for safe shutdown in this fire zone.

Fire Protection Measures and Criteria The transformer is protected by an automatic deluge spray system, which is activated from the transformers protective relaying and not the thermal detectors (thermal detectors provide alarm signaling only). Alarms are provided which annunciate locally and in the control room to indicate operation of the system (see Figure B-24 of the Exemption Requests, F.P.R., Vol. 4).

4.15-4

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Design-Basis Fire If a fire started in the transformer, it would be quickly extinguished by the deluge system. It would not spread to the Turbine Building, because the walls of the Turbine Building carry a 3-hour rating to an external exposure fire in the vicinity of the transformers. A fire involving a transformer would cause the respective unit to trip, as well as probable loss of offsite power for that unit. The unit would be shut down using the normal shutdown path by making use of onsite power.

Fire Suppression Effects No safe shutdown paths would be affected by water discharge in this area. Water runoff would be handled by the crushed rock sumps surrounding the transformers.

4.15.5 Unit 2 Auxiliary Transformer (Fire Zone 18.2.2)

This structure is shown on the F-24 drawings and Figure 3.3-24.

Fire Barrier Description This transformer sits on a 12-foot 9-inch thick reinforced concrete base. there are no walls or ceiling to act as fire barriers, but a crushed rock sump is provided around the transformer to contain transformer oil if a leak should occur.

Safe Shutdown Equipment There is no equipment or cabling needed for safe shutdown in this fire zone.

Fire Protection Measures and Criteria The transformer is protected by an automatic deluge spray system, which is activated from the transformers protective relaying and not the thermal detectors (thermal detectors provide alarm signaling only). Alarms are provided which annunciate locally and in the control room to indicate operation of the system (see Figure B-23 of the Exemption Requests, F.P.R., Vol. 4).

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

4.15-5

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Design-Basis Fire If a fire started in the transformer, it would be quickly extinguished by the deluge system. It would not spread to the Turbine Building, because the walls of the Turbine Building carry a 3-hour rating to an external exposure fire in the vicinity of the transformers through the door in this wall is unrated. A fire involving a transformer would cause the respective unit to trip, as well as probable loss of offsite power for that unit. The unit would be shut down using the normal shutdown path by making use of onsite power.

Fire Suppression Effects No safe shutdown paths would be affected by water discharge in this area. Water runoff would be handled by the crushed rock sumps surrounding the transformers.

4.15.6 Unit 3 Reserve Auxiliary Transformer (Fire Zone 18.3.1)

This structure is shown on the F-25 drawings and Figure 3.3-25.

Fire Barrier Description This transformer sits on a 7-foot 9-inch thick reinforced concrete base. There are not walls or ceiling to act as fire barriers, but a crushed rock sump is provided around the transformer to contain transformer oil if a leak should occur.

Safe Shutdown Equipment There is no equipment or cabling needed for safe shutdown in this fire zone.

Fire Protection Measures and Criteria The transformer is protected by an automatic deluge spray system, which is activated from the transformers protective relaying and not the thermal detectors (thermal detectors provide alarm signaling only). Alarms are provided which annunciate locally and in the control room to indicate operation of the system (see Figure B-24 of the Exemption Requests, F.P.R., Volume 4).

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

4.15-6

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Design-Basis Fire If a fire started in the transformer, it would be quickly extinguished by the deluge system. It would not spread to the Turbine Building, because the walls of the Turbine Building carry a 3-hour rating to an external exposure fire in the vicinity of the transformers. A fire involving a transformer would cause the respective unit to trip, as well as probable loss of offsite power for that unit. The unit would be shut down using the normal shutdown path by making use of onsite power.

Fire Suppression Effects No safe shutdown paths would be affected by water discharge in this area. Water runoff would be handled by the crushed rock sumps surrounding the transformers.

4.15.7 Unit 2 Reserve Auxiliary Transformer (Fire Zone 18.3.2)

This structure is shown on the F-24 drawings and Figure 3.3-24.

Fire Barrier Description This transformer sites on a 7-foot 9-inch thick reinforced concrete base. There are no walls or ceiling to act as fire barriers, but a crushed rock sump is provided around the transformer to contain transformer oil if a leak should occur.

Safe Shutdown Equipment There is no equipment or cabling needed for safe shutdown in this fire zone.

Fire Protection Measures and Criteria The transformer is protected by an automatic deluge spray system, which is activated from the transformers protective relaying and not the thermal detectors (thermal detectors provide alarm signaling only). Alarms are provided which annunciate locally and in the control room to indicate operation of the system (see Figure B-23 of the Exemption Requests, F.P.R. Volume 4).

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Design-Basis Fire If a fire started in the transformer, it would be quickly extinguished by the deluge system. It would not spread to the Turbine Building, because the walls of the Turbine Building carry a 3-hour rating to an external exposure fire in the vicinity of the transformers though the door in this 4.15-7

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 wall is unrated. A fire involving a transformer would cause the respective unit to trip, as well as probable loss of offsite power for that unit. The unit would be shut down using the normal shutdown path by making use of onsite power.

Fire Suppression Effects No safe shutdown paths would be affected by water discharge in this area. Water runoff would be handled by the crushed rock sumps surrounding the transformers.

4.15.8 Auxiliary Boiler House (Fire Zone 18.4)

This structure is shown on the F-25 drawings and Figure 3.3-25.

Fire Barrier Description The auxiliary boiler is surrounded by walls made of insulated metal siding and supported by exposed structural steel. The access doors on the south and west walls are unrated. The roof is constructed of built-up roofing over 4-inch thick precast concrete panels. The floor is a smooth, finished, 3-foot 6-inch thick reinforced concrete slab.

Safe Shutdown Equipment There is no equipment or cabling required for safe shutdown located in the auxiliary boiler area.

Fire Protection Measures and Criteria The auxiliary boiler is provided with a water based suppression system.

Design Basis Fire The auxiliary boiler is not required for safe shutdown. This fire zone has a complete suppression and detection system. A fire in the boiler structure would be quickly detected and extinguished by the system present. Because of the relative location of this structure to other plant structures, a fire in the auxiliary boiler house will not affect safe shutdown equipment in other structures.

Fire Suppression Effects No safe shutdown paths would be affected by water discharge in this area. Water runoff would be handled by the floor drains in the general area.

4.15-8

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 4.15.9 Unit 1 Plant Structures Fire Barrier Description The only portion of the Unit 1 Structures which contact the Unit 2/3 Structures is the west wall of Unit 1 Turbine Building. The border between Fire Zone 2.0 (Unit 2/3 control room) and Unit 1 structures is described in Subsection 4.12.1 of this report.

The wall separating the Unit 1 Turbine Building from Fire Zone 6.2 (Auxiliary Electrical Equipment Room) is a minimum 3-foot 3-inch reinforced concrete 3-hour fire barrier. The remaining wall west of Unit 1 Turbine Building is generally metal siding on exposed structural steel.

Safe Shutdown Equipment There is no equipment or cabling required for safe shutdown located in Unit 1 structures.

Combustible Material and Fire Loading Administrative controls limit fire hazards in Unit 1 areas exposing Unit 2 (See Section 6.0).

Fire Protection Measures and Criteria The Unit 2 and 3 Fire Zones in contact with a Unit 1 structures contain extensive suppression and detection systems. Cable concentrations in the Unit 1 West Auxiliary Bay, located below the Unit 2 Control Room, are protected by automatic water-spray systems. Detection systems as well as operating personnel are present in the Unit 2/3 control room.

Design Basis Fire In the event of a design basis fire in Unit 1 structures, only Fire Area TB-I could be affected. In the event that a fire were to spread to TB-I both hot and cold shutdown can be achieved as discussed in Section 4.8 of the Safe Shutdown Report (F.P.R. Volume 2).

Fire Suppression Effects No safe shutdown paths would be affected by water discharge in this area. Water runoff would be handled by the floor drains in the general area.

4.15.10 --Deleted--(Fire Zone 18.5) 4.15-9

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 4.15.11 U2 125VDC Alternate Battery Room (Fire Zone 18.6)

Fire Barrier Description The south and west walls of this fire zone separate it from the rest of the SBO Building and are 1'-0" thick reinforced concrete. The east wall is part of the SBO Building dividing wall, and the north wall is the outdoor wall, both are 2'-0" thick reinforced concrete.

Safe Shutdown Equipment There is no safe shutdown equipment in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Measures and Criteria This fire zone has fire detection system.

Design Basis Fire The batteries in the SBO Building are not required for safe shutdown. This fire zone is protected by a fire detection system. A fire in this fire zone would be quickly detected and extinguished using equipment that is present in the building. Because of the relative location of this structure to other plant structures, a fire in this fire zone will not affect safe shutdown equipment in other structures.

Fire Suppression Effects Water release in this zone would not result in adverse effects of greater severity than those determined to be acceptable for a design basis fire. Water run off from would be controlled by floor drains in the general area.

4.15.12 Isolation Condenser Pumphouse (Fire Zone 18.7.1)

This fire zone is shown on the F-353 drawing and Figure 3.3-27.

Fire Barrier Description This fire zone is the north cubicle of the Isolation Condenser Pumphouse. Fire Zone 18.7.1 is separated by a 3-hour rated fire barrier constructed of 1-foot 0-inch thick reinforced concrete below elevation 517-feet 6-inches and 1-foot 0-inch masonry block above elevation 517-feet 6-inches. All penetrations in this concrete wall are sealed to a 3-hour fire rating. Access between 4.15-10

DRESDEN 2&3 AMENDMENT 16 JUNE 2007 fire zones 18.7.1 and 18.7.2 is gained through a Class "A" fire door located in the concrete wall.

The north, south, and east exterior walls are 1-foot 0-inch thick concrete. Louvers for Pumphouse ventilation and diesel engine combustion and cooling air are located in these walls as shown on Figure 3.3-27. The west wall is an exterior wall, and is 1-foot 0-inch thick reinforced concrete, with 4-inches of Rodofoam on the exterior side of the wall. The Rodofoam is adjacent to the east wall of the Unit 2 Reactor building (Fire Zone 1.1.2.2); this wall is reinforced concrete and is 3-hour rated in the vicinity of the Pumphouse (refer to Section 4.2.2). The west wall of the Pumphouse contains an unsealed mechanical penetration. The Pumphouse roof separates these fire zones from the exterior, and is 1-1/2 inch metal decking covered with insulation and a single ply membrane. The junction between the roof deck and the 3-hour rated dividing wall is sealed with metal flute closures and UL rated caulk and closure material-UL 1479.

Safe Shutdown Equipment The hot shutdown equipment and instrumentation located in this fire zone are as follows:

Isolation Condenser Makeup Pump 2/3-43122A Isolation Condenser Makeup Pump Driver 2/3-43123A Diesel Oil Day Tank 2/3-5215A Diesel Oil Day Tank A Level Indicator 2/3-5241-22 Diesel Oil Day Tank A Level Indicator 2/3-4341-23 Isolation Condenser Makeup Pump Flow Indicator 2/3-4341-152 Control Panel 2223-126A Isolation Condenser Makeup Pump Discharge Pressure Indicator 2/3-4341-150A There is no cold shutdown equipment in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures The fire hazards in this fire zone are protected by fixed automatic fire suppression and detection.

The fire detection system alarms in the Control Room. Wet pipe sprinkler protection is provided for the equipment in the fire zone. The suppression system is equipped with a flow switch which alarms in the Control Room.

Design Basis Fire Fire Zone 18.7.1 has an automatic suppression and detection system. A fire in the Pumphouse is prevented from spreading into the adjacent Pumphouse zone by the 3-hour rated wall separating the fire zones. A fire in the Pumphouse will not spread to the Unit 2 Reactor Building because 4.15-11

DRESDEN 2&3 AMENDMENT 16 JUNE 2007 the Reactor Building wall, in the vicinity of the Pumphouse, carries a 3-hour rating to an external fire.

Fire Suppression Effects The operation of the water suppression system, use of manual hose, or water piping breaks would not affect safe shutdown. The effects of these actions would be of no greater severity than those already determined to be acceptable for a design basis fire. Water runoff would be controlled through utilization of the floor drains.

4.15.13 Isolation Condenser Pumphouse (Fire Zone 18.7.2)

This fire zone is shown on the F-353 drawing and Figure 3.3-27.

Fire Barrier Description This fire zone is the south cubicle of the Isolation Condenser Pumphouse. Fire Zone 18.7.2 is separated by a 3-hour rated fire barrier constructed of 1-foot 0-inch thick reinforced concrete below elevation 517-feet 6-inches and 1-foot 0-inch masonry block above elevation 517-feet 6-inches. All penetrations in this concrete wall are sealed to a 3-hour fire rating. Access between fire zones 18.7.1 and 18.7.2 is gained through a Class "A" fire door located in the concrete wall.

The north, south, and east exterior walls are 1-foot 0-inch thick concrete. Louvers for Pumphouse ventilation and diesel engine combustion and cooling air are located in these walls as shown on Figure 3.3-27. The west wall is an exterior wall, and is 1-foot 0-inch thick reinforced concrete, with 4-inches of Rodofoam on the exterior side of the wall. The Rodofoam is adjacent to the east wall of the Unit 2 Reactor building (Fire Zone 1.1.2.2); this wall is reinforced concrete and is 3-hour rated in the vicinity of the Pumphouse (refer to Section 4.2.2). The west wall of the Pumphouse contains an unsealed mechanical penetration. The Pumphouse roof separates these fire zones from the exterior, and is 1-1/2 inch metal decking covered with insulation and a single ply membrane. The junction between the roof deck and the 3-hour rated dividing wall is sealed with metal flute closures and UL rated caulk and closure material-UL 1479.

Safe Shutdown Equipment The hot shutdown equipment and instrumentation located in this fire zone are as follows:

Isolation Condenser Makeup Pump 2/3-43122B Isolation Condenser Makeup Pump Driver 2/3-43123B Diesel Oil Day Tank 2/3-5215B Diesel Oil Day Tank A Level Indicator 2/3-5241-24 Diesel Oil Day Tank A Level Indicator 2/3-4341-25 Isolation Condenser Makeup Pump Flow Indicator 2/3-4341-152 Control Panel 2223-126B Isolation Condenser Makeup Pump Discharge Pressure 2/3-4341-150B Indicator 4.15-12

DRESDEN 2&3 AMENDMENT 15 JUNE 2005 There is no cold shutdown equipment in this fire zone.

Combustible Material and Fire Loading Refer to the station combustible loading calculation DRE97-0105 for information on combustible material and fire loading for this zone.

Fire Protection Criteria and Measures The fire hazards in this fire zone are protected by fixed automatic fire suppression system. Wet pipe sprinkler protection is provided for the equipment in the fire zone. The suppression system is equipped with a flow switch, which alarms in the control room.

Design Basis Fire Fire Zone 18.7.2 has an automatic fire suppression system. A fire in the Pumphouse is prevented from spreading into the adjacent Pumphouse zone by the 3-hour rated wall separating the fire zones. A fire in the Pumphouse will not spread to the Unit 2 Reactor Building because the Reactor Building wall, in the vicinity of the Pumphouse, carries a 3-hour rating to an external fire.

Fire Suppression Effects The operation of the water suppression system, use of manual hose, or water piping breaks would not affect safe shutdown. The effects of these actions would be of no greater severity than those already determined to be acceptable for a design basis fire. Water runoff would be controlled through utilization of the floor drains.

4.15-13

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 5.0 GUIDELINES OF APPENDIX A TO APCSB 9.5-1 5.1 Overall Requirements of Nuclear Plant Fire Protection Program Implementation or Justification Section NRC Position for Noncompliance A.1 Personnel Responsibility for the overall fire protection Comply with intent:

program should be assigned to a designated The administrative program was person in the upper level of management. This compared with the detailed person should retain ultimate responsibility even recommendations in a 1977 NRC though formulation and assurance of program Supplementary Guidance document implementation is delegated. Such delegation of entitled, "Nuclear Plant Fire authority should be to staff personnel prepared Protection Functional by training and experience in fire protection and Responsibilities, Administrative nuclear plant safety to provide a balanced Controls and Quality Assurance."

approach in directing the fire protection See Supplementary Guidance Review programs for nuclear power plants. The (F.P.P.D.P. Volume 7).

qualification requirements for the fire protection engineer or consultant who will assist in the design and selection of equipment, inspect and test the completed physical aspects of the system, develop the fire protection program, and assist in the fire-fighting training for the operating plant should be stated. Subsequently, the FSAR should discuss the training and updating provisions such as fire drills provided for maintaining the competence of the station fire-fighting and operation crew, including personnel responsible for maintaining and inspecting the fire protection equipment.

5.1-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance The fire protection staff should be responsible for:

(a) coordination of building layout and systems design with fire area requirements, including consideration of potential hazards associated with postulated design basis fires, (b) design and maintenance of fire detection, suppression, and extinguishing systems, (c) fire prevention activities, (d) training and manual fire-fighting activities of plant personnel and the fire brigade.

(Note: NFPA 6 - "Recommendations for See NFPA Code Review (F.P.P.D.P.

Organization of Industrial Fire Loss Volumes 8 and 9).

Prevention", contains useful guidance for organization and operation of the entire fire loss prevention program.)

A.2 Design Bases The overall fire protection program should be Comply:

based upon evaluation of potential fire hazards See Section 3.0 and 4.0 of this report throughout the plant and the effect of postulated and Safe Shutdown Report design basis fires relative to maintaining ability (F.P.P.D.P. Volume 3).

to perform safety shutdown functions and minimize radioactive releases to the environment.

A.3 Backup Total reliance should not be placed on a single Comply:

automatic fire suppression system. Appropriate See Section 4.0 of this report for backup fire suppression capability should be description of available automatic provided. suppression systems. Backup fire suppression equipment is provided in the form of manual hose stations and/or portable fire extinguishers.

5.1-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance A.4 Single Failure Criterion A single failure in the fire suppression system Comply with intent:

should not impair both the primary and backup A single failure would not impair both fire suppression capability. For example, the primary and backup fire redundant fire water pumps with independent suppression capability. Fire water power supplies and controls should be provided. supply is provided by redundant Postulated fires or fire protection system failures diesel driven fire pumps (see Section need not be considered concurrent with other 4.0 of this report for a discussion of plant accidents or the most severe natural suppression system arrangements).

phenomena.

The effects of lightning strikes should be Lightning protection was compared included in the overall plant fire protection with the requirements of NFPA 78.

program. See NFPA Code Review (F.P.P.D.P.

Volumes 8 and 9).

A.5 Fire Suppression Systems Failure or inadvertent operation of the fire Partially comply:

suppression system should not incapacitate A suppression effects analysis has safety-related systems or components. Fire been conducted to ensure that suppression systems that are pressurized during inadvertent operation or a pipe break normal plant operation should meet the would not adversely affect safe guidelines specified in APCSB Branch shutdown. This review was conducted Technical Position 3-1, "Protection Against in accordance with NRC I&E Postulated Piping Failures in Fluid Systems Temporary Instruction 2515/62 Rev.

Outside Containment." 1, Section 0.4.1.f (See Section 4.0 of this report for suppression effects.)

A.6 Fuel Storage Areas Schedule for implementation of modifications, Not applicable.

if any, will be established on a case-by-case basis.

A.7 Fuel Loading Schedule for implementation of modifications, Not applicable.

if any, will be established on a case-by-case basis.

5.1-3

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance A.8 On multiple-reactor sites where there are Not applicable. Dresden is an operating reactors and construction of remaining operating station with no units under units is being completed, the fire protection construction. Dresden Unit 1 is in program should provide continuing evaluation decommissioning status (SAFSTOR) and include additional fire barriers, fire and is not operating. The site fire protection capability, and administrative protection program addresses controls necessary to protect the operating units activities conducted on Units 1, 2 and from construction fire hazards. The 3. The Unit 2/3 Station Manager has superintendent of the operating plant should the lead responsibility for site fire have the lead responsibility for site fire protection.

protection.

A.9 Simultaneous fires in more than one reactor Separation between shared equipment need not be postulated, where separation has been addressed in the Safe requirements are met. A fire involving more Shutdown Report (F.P.P.D.P. Volume than one reactor unit need not be postulated 3) and Exemption Requests (F.P.R except for facilities shared between units. Volume 4).

5.1-4

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 5.2 Administrative Procedures, Controls, and Fire Brigade Implementation or Justification Section NRC Position for Noncompliance B.1 Administrative procedures consistent with the Comply with intent:

need for maintaining the performance of the Administrative procedure guidance in fire protection system and personnel in nuclear NFPA 4, 4A, 6, 7, and 8 were power plants should be provided. reviewed for applicability. NFPA 4A was found not to be applicable. The Guidance is contained in the following results of the rest of the reviews are publications. found in the NFPA Code Review (F.P.P.D.P. Volumes 8 and 9).

NFPA 4 - Organization for Fire Services NFPA 4A - Organization for Fire Department NFPA 6 - Industrial Fire Loss Prevention NFPA 7 - Management of Fire Emergencies NFPA 8 - Management Responsibility for Effects of Fire on Operations NFPA 27 - Private Fire Brigades B.2 Effective administrative measures should be Comply:

implemented to prohibit bulk storage of The administrative program was combustible materials inside or adjacent to compared with the detailed safety-related buildings or systems during recommendations in a 1977 NRC operation or maintenance periods. Regulatory Supplementary Guidance document Guide 1.39, "Housekeeping Requirements for entitled, "Nuclear Plant Fire Water-Cooled Nuclear Power Plants" provides Protection Functional guidance on housekeeping, including the Responsibilities, Administrative disposal of combustible materials. Controls and Quality Assurance."

See Supplementary Guidance Review (F.P.P.D.P. Volume 7).

B.3 Normal and abnormal conditions or other anticipated operations such as modifications (e.g., breaking fire stops, impairment of fire detection and suppression systems) and refueling activities should be reviewed by appropriate levels of management and appropriate special actions and procedures such as fire watches or temporary fire barriers implemented to assure adequate fire protection and reactor safety. In particular:

5.2-1

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 Implementation or Justification Section NRC Position for Noncompliance (a) Work involving ignition sources such as Comply:

welding and flame cutting should be done Work involving ignition sources is under closely controlled conditions. controlled via fire protection Procedures governing such work should be administrative procedures. The reviewed and approved by persons trained procedures have been reviewed and experienced in fire protection. Persons against the criteria of NFPA 51B and performing and directly assisting in such the 1977 NRC Supplementary work should be trained and equipped to Guidance entitled, "Nuclear Plant Fire prevent and combat fires. If this is not Protection Functional possible, a person qualified in fire Responsibilities, Administrative protection should directly monitor the work Controls and Quality Assurance." The and function as a fire watch. results of these reviews are found in the NFPA Code Review (F.P.P.D.P.

Volumes 8 and 9) and the Supplementary Guidance Review (F.P.P.D.P. Volume 7).

(b) Leak testing, and similar procedures such Comply:The leak test procedures as air flow determination, should use one of contain a cautionary statement the commercially available aerosol prohibiting the use of open flames and techniques. Open flames or combustion freon for any testing of penetration generated smoke should not be permitted. leakage. These test procedures were reviewed against the guidelines of the 1977 NRC Supplementary Guidance entitled, "Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance." The results of these reviews are found in the Supplementary Guidance Review (F.P.P.D.P. Volume 7).

5.2-2

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 Implementation or Justification Section NRC Position for Noncompliance (c) Use of combustible material, e.g., HEPA Comply with intent:

and charcoal filters, dry ion exchange resins Control of combustibles is or other combustible supplies in safety- accomplished through use of the fire related areas should be controlled. Use of protection administrative procedures.

wood inside buildings containing safety- These procedures recommend that related systems or equipment should be flame retardant materials, including permitted only when suitable fire retardant treated wood. be used in noncombustible substitutes are not the plant. The procedure was available. If wood must be used, only fire reviewed against the guidelines of the retardant treated wood (scaffolding, lay 1977 NRC Supplementary Guidance down blocks) should be permitted. Such entitled, "Nuclear Plant Fire materials should be allowed into safety- Protection Functional related areas only when they are to be used Responsibilities, Administrative immediately. Their possible and probable Controls and Quality Assurance." The use should be considered in the fire hazards results of this review are found in the analysis to determine the adequacy of the Supplementary Guidance Review installed fire protection systems. (F.P.P.D.P. Volume 7).

B.4 Nuclear power plants are frequently located in Comply:

remote areas, at some distance from public fire The station fire brigade is designed to departments. Also, first response fire be self-sufficient. However, other fire departments are often volunteer. Public fire agencies are used in periodic drills for department response should be considered in experience and adaptability to the overall fire protection program. However, function with the station brigade.

the plant should be designed to be self-sufficient with respect to fire fighting activities and rely on the public response only for supplemental or backup capability.

B.5 The need for good organization, training and equipping of fire brigades at nuclear power plant sites requires effective measures be implemented to assure proper discharge of these functions. The guidance in Regulatory Guide 1.101, "Emergency Planning for Nuclear Power Plants," should be followed as applicable.

5.2-3

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (a) Successful fire fighting requires testing and Comply with intent:

maintenance of the fire protection Fire protection system surveillances equipment, emergency lighting and are performed using detailed communication, as well as practice as procedures describing the surveillance brigades for the people who must utilize the and acceptance criteria. Periodic equipment. A test plan that lists the testing of fire protection systems and individuals and their responsibilities in equipment is scheduled and connection with routine tests and performed with documented inspections of the fire detection and procedures to assure that the protection systems should be developed. equipment will properly function and The test plan should contain the types, continue to meet the design criteria.

frequency and detailed procedures for This test program was reviewed testing. Procedures should also contain against the guidelines of the 1977 instructions on maintaining fire protection NRC Supplementary Guidance during those periods when the fire entitled. "Nuclear Plant Fire protection system is impaired or during Protection Functional periods of plant maintenance, e.g., fire Responsibilities, Administrative watches or temporary hose connections to Controls and Quality Assurance." The water systems. results of this review are found in the Supplementary Guidance Review (F.P.P.D.P. Volume 7).

5.2-4

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 Implementation or Justification Section NRC Position for Noncompliance (b) Basic training is a necessary element in Comply with intent:

effective fire fighting operation. In order Fire drills are controlled and for a fire brigade to operate effectively, it conducted by the Station Fire Marshal must operate as a team. All members must (or designee) via the fire protection know what their individual duties are. They administrative control procedures.

must be familiar with the layout of the These drills are conducted so that plant and equipment location and operation there is one drill held per shift per in order to permit effective fire-fighting quarter. The fire scenarios include operations during times when a particular various fire hazards throughout the area is filled with smoke or is insufficiently plant covering different safety-related lighted. Such training can only be areas. The fire drill procedures were accomplished by conducting drills several reviewed against the guidelines of the times a year (at least quarterly) so that all 1977 NRC Supplementary Guidance members of the fire brigade have had the entitled, "Nuclear Plant Fire opportunity to train as a team, testing itself Protection Functional in the major areas of the plant. The drills Responsibilities, Administrative should include the simulated use of Controls and Quality Assurance." The equipment in each area and should be results of this review are found in the preplanned and post-critiqued to establish Supplementary Guidance Review the training objective of the drills and (F.P.P.D.P. Volume 7).

determine how well these objectives have been met. These drills should periodically (at least annually) include local fire department participation where possible.

Such drills also permit supervising personnel to evaluate the effectiveness of communications within the fire brigade and with the on-scene fire team leader, the reactor operator in the control room, and the offsite command post.

5.2-5

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (c) To have proper coverage during all phases Comply with intent:

of operation, members of each shift crew The training procedures for training should be trained in fire protection. both site personnel and off-site fire Training of the plant fire brigade should be department personnel were reviewed coordinated with the local fire department against the guidelines of the 1977 so that responsibilities and duties are NRC Supplementary Guidance delineated in advance. This coordination entitled, "Nuclear Plant Fire should be part of the training course and Protection Functional implemented into the training of the local Responsibilities, Administrative fire department staff. Local fire Controls and Quality Assurance." The departments should be educated in the results of this review are found in the operational precautions when fighting fires supplementary Guidance Review on nuclear power plant sites. Local fire (F.P.P.D.P. Volume 7).

departments should be made aware of the need for radioactive protection of personnel and the special hazards associated with a nuclear power plant site.

(d) NFPA 27, "Private Fire Brigade" should be Comply with intent:

followed in organization, training, and fire The criteria of NFPA 27, 194, 196, drills. This standard also is applicable for 197 and 601 were reviewed during the the inspection and maintenance of fire NFPA Code Review. The results of fighting equipment. Among the standards this review are documented in the referenced in this document, the following NFPA Code Review (F.P.P.D.P.

should be utilized: NFPA 194, "Standard Volumes 8 and 9).

for Screw Threads and Gaskets for Fire Hose Couplings," NFPA 196, "Standard for Fire Hose," NFPA 197, "Training Standard on Initial Fire Attacks," NFPA 601, "Recommended Manual of Instructions and Duties for the Plant Watchman on Guard."

NFPA booklets and pamphlets listed on Page 27-11 of Volume 8, 1971-72 are also applicable for good training references. In addition, courses in fire prevention and fire suppression which are recognized and/or sponsored by the fire protection industry should be utilized.

5.2-6

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 5.3 Quality Assurance Program Implementation or Justification Section NRC Position for Noncompliance C. Quality Assurance (QA) programs of applicants Comply:

and contractors should be developed and Augmented Quality (regulatory implemented to assure that the requirements for related) items are addressed in the design, procurement, installation, testing and appropriate sections of the 10CFR50 administrative controls for the fire protection Appendix B program. See the program for safety-related areas as defined in Supplementary Guidance Review this Branch Position are satisfied. The program (F.P.P.D.P. Volume 7).

should be under the management control of the QA organization. The QA program criteria that apply to the fire protection program should include the following:

C.1 Design Control and Procurement Document Control Measures should be established to assure that all design-related guidelines of the Branch Technical Position are included in design and procurement documents and that deviations therefrom are controlled.

C.2 Instructions, Procedure and Drawings Inspections, tests, administrative controls, fire drills and training that govern the fire protection program should be prescribed by documented instructions, procedures, or drawings and should be accomplished in accordance with these documents.

C.3 Control of Purchased Material, Equipment and Services Measures should be established to assure that purchased material, equipment, and services conform to the procurement documents.

5.3-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance C.4 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 documented installation drawings and test procedures for accomplishing the activities.

C.5 Test and Test Control A test program should be established and implemented to assure 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.

C.6 Inspection Test and Operating Status Measures should be established to provide for the identification of items that have satisfactorily passed required tests and inspections.

C.7 Nonconforming Items Measures should be established to control items that do not conform to specified requirements to prevent inadvertent use of installation.

C.8 Corrective Action Measures should be established to assure that conditions adverse to fire protection, such as failures, malfunctions, deficiencies, deviations, defective components, uncontrolled combustible material and nonconformances are promptly identified, reported, and corrected.

5.3-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance C.9 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.

C.10 Audits 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.

5.3-3

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 5.4 General Guidelines for Plant Protection Implementation or Justification Section NRC Position for Noncompliance D.1 Building Design Comply with intent:

The fire area concept as it relates to (a) Plant layouts should be arranged to: reactor safety was not implemented in the initial design of Dresden Units 2 (1) Isolate safety related Systems from & 3. Safety related and non-safety unacceptable fire hazards, and related equipment was reviewed. This equipment was combined into specific (2) Alternatives: shutdown paths. Assurance that one path to achieve safe shutdown will (a) Redundant safety related systems remain free of fire damage is that are subject to damage from a described in the Safe Shutdown single fire hazard should be Report (F.P.R. Volume 2). Major fire protected by a combination of fire hazards are protected with fixed retardant coatings and fire detection suppression systems.

and suppression systems, or (b) a separate system to perform the safety function should be provided.

(b) In order to accomplish (1) (a) above, safety The fire hazard analysis is contained related systems and fire hazards should be in Sections 1 through 4 of this report.

identified throughout the plant. Therefore, a The fire hazards analysis will be detailed fire hazard analysis should be made. updated as discussed in Subsection The fire hazards analysis should be reviewed 1.3.2.

and updated as necessary.

Additional fire hazards analysis should be See Section 5.3 (C.1) of this report.

done after any plant modification.

5.4-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (c) For multiple reactor sites, cable spreading Do not comply:

rooms should not be shared between The Auxiliary Electric Equipment reactors. Each cable spreading room should Room (AEER) is used as a cable be separated from other areas of the plant by spread room, and is shared between barriers (walls and floors) having a both units. The AEER and control minimum fire resistance of three hours. room form one fire area. Both safety Cabling for redundant safety divisions divisions of both units are in the should be separated by walls having three AEER. Safe shutdown for both units hour fire barriers. can be achieved independent of this fire area. See Sub-Section 4.0 and Alternative guidance for constructed plants Subsection 5.6.3 (F.3) of this report is shown in Section E.3, Cable Spreading for more details.

Room.

The barrier between the AEER and the control room is 6-inch-thick concrete supported on coated structural steel.

5.4-2

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 Implementation or Justification Section NRC Position for Noncompliance (d) Interior wall and structural components, Do not comply:

thermal insulation materials and radiation Minor amounts of combustibles were shielding materials and soundproofing originally used as nailers, seals, should be noncombustible. Interior finishes caulking and joint fillers, etc. These should be noncombustible or listed by a existing materials do not significantly nationally recognized testing laboratory, contribute to the fire loadings in the such as Factory Mutual or Underwriters plant and do not expose safety-related Laboratory, Inc. for flame spread, smoke systems to undue risks. Installations and fuel contribution of 25 or less in its use since the late 1970s have specified configuration (ASTM E-84 Test, Surface noncombustible or limited Burning Characteristics of Building combustible surface finishes.

Materials).

Floor coverings in areas containing systems or equipment required for safe shutdown of the plant are generally Class I material as defined in NFPA 101, or generally a flame spread of 25 or less as defined by ASTM E-84. For fire hazard analysis purposes, floor coatings are considered non-combustible if the material has a structural base of non-combustible material, with a nominal depth not over 1/8-inch thick, and has a flame spread rating not higher than 50 as defined by ASTM E-84.

Exceptions to these guidelines are evaluated for acceptability by Fire Protection Engineering on a case by case basis.

(e) Metal deck roof construction should be Do not comply:

noncombustible (see the building materials All the roofs at Dresden are of Class directory of the Underwriters Laboratory, II construction.

Inc.) or listed as Class I by Factory Mutual Systems Approval Guide. Where combustible material is used in metal deck roofing design, acceptable alternatives are (i) replace combustibles with noncombustible materials, (ii) provide an automatic sprinkler system, or (iii) provide ability to cover roof exterior and interior with adequate water volume and pressure.

5.4-3

DRESDEN 2&3 AMENDMENT 20 JUNE 2015 Implementation or Justification Section NRC Position for Noncompliance (f) Suspended ceilings and their supports Do not comply:

should be of noncombustible construction. Suspended ceilings are provided only Concealed spaces should be devoid of in the control room (Fire Zone 2.0) combustibles. and are made of noncombustible open grid material. Fire detection is Adequate fire detection and suppression provided throughout the control room systems should be provided where full above the open grid ceiling. Unit 2 implementation is not practicable. cables are routed through the ceiling into the Unit 2 control panels.

(g) High voltage - high amperage transformers Comply with intent:

installed inside buildings containing safety- The power transformers installed at related systems should be of the dry type or Dresden are filled with less insulated and cooled with noncombustible flammable dielectric fluid meeting liquid. NFPA 70 requirements for indoor transformers filled with less Safety related systems that are exposed to flammable fluid.

flammable oil filled transformers should be protected from the effects of a fire by:

2. replacing with dry transformers or transformers that are insulated and cooled with noncombustible liquid; or (ii) enclosing the transformer with a three-hour fire barrier and installing automatic water spray protection.

(h) Buildings containing safety related systems Comply with intent:

having openings in exterior walls closer Protection from the transformer fire than 50 feet to flammable oil filled hazard is provided by:

transformers should be protected from the effects of a fire by: 2. Water spray system above the transformers.

2. closing of the opening to have fire resistance equal to three hours, 2. Reinforced concrete wall up to elevation 551 feet 6 inches. Door openings are protected by fire doors.
2. Constructing a three hour fire barrier between the transformers and the wall 3. Water spray protection of bus duct openings, or penetrations.

(iii) closing the opening and providing the capability to maintain a water curtain in case of a fire.

5.4-4

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (i) Floor drains, sized to remove expected fire Comply with intent:

fighting water flow should be provided in Suppression effects analysis was those areas where fixed water fire conducted to ensure that fire fighting suppression systems are installed. Drains water would not adversely affect safe should also be provided in other areas shutdown (see Section 4.0 of this where hand hose lines may be used if such report). NFPA Code 92M was fire fighting water could cause unacceptable reviewed and deviations justified damage to equipment in the area. (F.P.P.D.P. Volumes 8 and 9).

Equipment should be installed on pedestals, or curbs should be provided as required to contain water and direct it to floor drains.

(See NFPA 92M, "Waterproofing and Draining of Floors.") Drains in areas containing combustible liquids should have provisions for preventing the spread of the fire throughout the drain system. Water drainage from areas which may contain radioactivity should be sampled and analyzed before discharge to the environment.

In operating plants or plants under construction, if accumulation of water from the operation of new fire suppression systems does not create unacceptable consequences, drains need not be installed.

5.4-5

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 Implementation or Justification Section NRC Position for Noncompliance (j) Floors, walls and ceilings enclosing separate Comply:

fire areas should have minimum fire rating Fire areas are surrounded by 3-hour of three hours. Penetrations in these fire rated barriers and are defined in the barriers, including conduits and piping, Safe Shutdown Analysis. Deviations should be sealed or closed to provide a fire in these barriers are justified in the resistance rating at least equal to that of the Exemption Requests (F.P.R. Volume fire barrier itself. Door openings should be 4).

protected with equivalent rated doors, frames and hardware that have been tested See the discussion on NFPA 80 and approved by a nationally recognized (doors) and NFPA 90A (HVAC) in laboratory. Such doors should be normally the NFPA Code Review (F.P.P.D.P.

closed and locked or alarmed with alarm and Volumes 8 and 9).

annunciation in the control room.

Penetrations for ventilation system should Fire doors are provided in rated be protected by a standard "fire door barriers between fire areas. These damper" where required. (Refer to NFPA doors are normally closed or held 80, "Fire Doors and Windows.") open with fusible links.

The normally open fire door between U2 and U3 Reactor Building 517-6 elevation closes on either a fusible link or fire detector actuation.

For both units, the normally open shutdown cooling pump room doors are operated by a magnetic closure device that causes the door to close on fire detector activation.

The fire hazard in each area should be evaluated to determine barrier requirements.

If barrier fire resistance cannot be made adequate, fire detection and suppression should be provided, such as:

(i) water curtain in case of fire, Water curtains are used at the floor and ceiling of the 4th floor of the (ii) flame retardant coatings, reactor building as discussed in the Exemption Requests (F.P.R. Volume (iii) additional fire barriers. 4) 5.4-6

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance D.2 Control of Combustibles (a) Safety related systems should be isolated or Comply:

separated from combustible materials. When Major fire hazards are protected by this is not possible because of the nature of appropriate fixed fire suppression the safety system or the combustible systems as identified in Section 4.0 of material, special protection should be this report.

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:

Emergency diesel generator fuel oil day tanks (1) Turbine-generator oil and hydraulic control fluid systems (1) Reactor coolant pump lube oil system 5.4-7

DRESDEN 2&3 AMENDMENT 21 JUNE 2017 Implementation or Justification Section NRC Position for Noncompliance (b) Bulk gas storage (either compressed or Comply with intent:

cryogenic), should not be permitted inside Outside bulk hydrogen storage is structures housing safety-related equipment. located in the yard south of the Storage of flammable gas such as hydrogen, training building and is arranged in a should be located outdoors or in separate standard manner. Hydrogen piping is detached buildings so that a fire or properly color coded and marked.

explosion will not adversely affect any NFPA 50A and NFPA 6 are safety related systems or equipment. addressed in the NFPA code review (F.P.P.D.P. Volumes 8 and 9). Use (Refer to NFPA 50A, "Gaseous Hydrogen and storage of compressed gas Systems.") cylinders are controlled in accordance with station procedures.

Care should be taken to locate high pressure gas storage containers with the long axis parallel to building walls. This will minimize the possibility 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.")

(c) The use of plastic materials should be Comply:

minimized. In particular, halogenated The use of plastic materials is plastics such as polyvinyl chloride (PVC) minimized. The use of PVC and and neoprene should be used only when neoprene has been severely restricted.

substitute noncombustible materials are not New cable will meet the requirements available. All plastic materials, including of IEEE 383. A minimal amount of flame and fire retardant materials, will burn PVC pipe is used.

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 releases free chlorine and hydrogen chloride when burning which are toxic to humans and corrosive to equipment.

(d) Storage of flammable liquids should as a Comply with intent:

minimum, comply with the requirements of NFPA 30 is used as a guideline. See NFPA 30, "Flammable and Combustible NFPA code review (F.P.P.D.P.

Liquids Code." Volumes 8 and 9).

5.4-8

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance D.3 Electric Cable Construction, Cable Trays and Cable Penetrations (a) Only noncombustible materials should be Comply:

used for cable tray construction. All cable trays are constructed of noncombustible materials (galvanized sheet metal).

(b) See Section F.3 for fire protection guidelines See Subsection 5.6.3 (F.3) for for cable spreading rooms. response.

(c) Automatic water sprinkler systems should Partially comply:

be provided for cable trays outside the cable Water suppression is provided over spreading room. Cables should be designed major cable concentrations (i.e., Unit to allow wetting down with deluge water 3 cable tunnel, Unit 2 Mezzanine without electrical faulting. Manual hose cable concentration, ground floor stations and portable hand extinguishers common access corridor, Turbine should be provided as backup. Safety-related Building Central Area, and crib equipment in the vicinity of such cable trays, house). Water suppression is not that does not itself require water fire provided in areas containing major protection, but is subject to unacceptable electrical equipment. Fire detection is damage from sprinkler water discharge, provided in these areas. See should be protected from sprinkler system Exemption Requests (F.P.R. Volume operation or malfunction. 4).

Cables are of the water proof type and not subject to electrical faulting due to water exposure. Manual hose stations and portable extinguishers are provided for all cable areas except the cable tunnels, however, manual equipment is available to the tunnels from the ground floor of the Turbine Building. A suppression effects analysis was conducted to ensure that unacceptable damage would not result (see Section 4.0 of this report).

When safety related cables do not satisfy the Alternative safe shutdown capability provisions of Regulatory Guide 1.75, all is available independent of all fire exposed cables should be covered with an areas - lack of complete suppression approved fire retardant coating and a fixed and detection in these areas is automatic water fire suppression system justified in the Exemption Requests should be provided. (F.P.R. Volume 4).

5.4-9

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (d) Cable and cable tray penetration of fire Comply:

barriers (vertical and horizontal) should be Cable and cable tray penetrations are sealed to give protection at least equivalent sealed to give protection equivalent to to that fire barrier. The design of fire that of the rated fire barrier. The barriers for horizontal and vertical cable evaluation of existing penetration trays should, as a minimum, meet the seals is provided in the report entitled requirements of ASTM E-119, "Fire Test of "Review of Existing and Proposed Building Construction and Materials," Penetration Seal Fire Testing and including the hose stream test. Where Installation Program" (F.P.P.D.P.

installed penetration seals are deficient with Volume 6). The evaluation of respect to fire resistance, these seals may be existing penetration seal design protected by covering both sides with an details is provided in the report approved fire retardant material. The entitled, Penetration Seal adequacy of using such material should be Assessment (see F.P.P.D.P.).

demonstrated by suitable testing.

(e) Fire breaks should be provided as deemed Comply with intent:

necessary by the fire hazards analysis. Flame The Appendix R analysis or flame retardant coatings may be used as a demonstrates safe shutdown fire break for grouped electrical cables to capability using alternate shutdown limit spread of fire in cable ventings. equipment. It has been shown in this (Possible cable derating owing to use of analysis that for a fire involving such coating materials must be considered redundant cable trains in a fire area, during design.) an alternate shutdown path will be available outside of the affected fire area. (See Appendix R Analysis which identifies the method to ensure separation of alternate shutdown paths.) Therefore, the fire stops identified in the 1978 SER Section 3.1.14 and 12/1/77 letter do not have the significance for safe shutdown they did at the time of the SER. These fire stops no longer need to be maintained in the manner of other SER commitments except for those located on the first and second floor of the Unit 2 and 3 reactor building which provide separation between redundant instrumentation divisions.

5.4-10

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (f) Electric cable constructions should as a Do not comply:

minimum pass the current IEEE No. 383 IEEE-383 did not exist at the time of flame test. (This does not imply that cables plant construction. Modifications after passing this test will not require additional issuance of IEEE-383 have utilized fire protection.) cables designed to meet the requirements of IEEE-383. All the For cable installation in operating plants and cables in the AEER as of the August plants under construction that do not meet 1977 FHA submittal were coated with the IEEE No. 383 flame test requirements, a fire retardant coating, subsequent all cables must be covered with an approved modifications utilized IEEE-383 flame retardant coating and properly qualified cable and are therefore not derated. coated. Automatic fire suppression and/or detection is provided where deemed necessary as discussed in the Section 4.0 of this report.

(g) To the extent practical, cable construction Future cable installation will specify that does not give off corrosive gases while cable insulation which has been rated burning should be used. For operating to IEEE-383. Modifications after plants, this position is only applicable to issuance of IEEE-383 have utilized new cable installations. cables designed to meet the requirements of IEEE 383. Upon combustion, this cable may give off gases which are corrosive in nature.

(h) Cable trays, raceways, conduit, trenches, or Comply:

culverts should be used only for cables. Cable trays, raceways, conduit, Miscellaneous storage should not be trenches and culverts are used only for permitted, nor should piping for flammable cables.

or combustible liquids or gases be installed in these areas.

Installed equipment in cable tunnels or culverts, need not be removed if they present no hazard to the cable runs as determined by the fire hazards analysis.

(i) The design of cable tunnels, culverts and Comply:

spreading rooms should provide for Portable ventilating equipment automatic or manual smoke venting as (smoke ejectors) is available for fire required to facilitate manual fire fighting brigade use.

capability.

5.4-11

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (j) Cables in the control room should be kept to Comply with intent:

the minimum necessary for operation of the Cabling in the control room is control room. All cables entering the control generally kept to a minimum for room should terminate there. Cables should control room operation. All cables not be installed in floor trenches or culverts entering the control room terminate in the control room. there. There are no cable trenches or culverts in the control room floor.

Existing cabling installed in concealed floor and ceiling spaces should be protected with A small central console area is located an automatic total flooding Halon system. on a raised floor. Only cables for equipment on this platform are located under this floor. These cables are routed from the AEER and are sealed at the floor penetration.

Unit 2 control cables are routed through the ceiling of the control room to the appropriate cabinets. No automatic suppression system is installed in the control room. See Exemption Requests for justification for lack of automatic suppression (F.P.R. Volume 4).

D.4 Ventilation (a) The products of combustion that need to be Partially comply:

removed from a specific fire area should be All existing ventilation exhaust air evaluated to determine how they will be which is potentially contaminated is controlled. Smoke and corrosive gases monitored prior to release to the should generally be automatically atmosphere to ensure that releases are discharged directly outside to a safe within the plant technical location. Smoke and gases containing specification limits. Generally, the radioactive materials should be monitored in normal ventilation system would be the fire area to determine if release to the shut down in a fire area and manually environment is within the permissible limits restarted post-fire. Portable of the plant Technical Specifications. ventilating equipment would be used to remove smoke from the area.

The products of combustion which need to be removed from a specific fire area should be evaluated to determine how they will be controlled.

5.4-12

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (b) Any ventilation system designed to exhaust Comply:

smoke or corrosive gases should be Existing ventilation systems are not evaluated to ensure that inadvertent designed to exhaust smoke or operation or single failures will not violate corrosive gas concurrently with a fire.

the controlled areas of the plant design. This It is the intent to manually restart requirement includes containment functions existing ventilation systems to for protection of the public and maintaining provide purge on a post fire basis.

habitability for operations personnel. These systems are monitored as noted in Position D.4(a) above.

(c) The power supply and controls for Do not comply:

mechanical ventilation systems should be Power supply and controls for run outside the fire area served by the mechanical ventilation equipment are system. not necessarily routed outside of fire hazard areas served by the system.

Most ventilation equipment is located within the fire hazard area, thereby requiring electrical cable to be routed accordingly.

(d) Fire suppression systems should be installed Do not comply:

to protect charcoal filters in accordance with Fixed automatic sprinkler system for Regulatory Guide 1.52, "Design Testing and charcoal filters are not provided. This Maintenance Criteria for Atmospheric design predated requirements for fire Cleanup Air Filtration." protection. The charcoal is contained in an enclosed metal cabinet and the spread of fire is remote. Manual water spray systems are provided for charcoal filter in the control room, technical support center and HRSS building.

It should be noted that Regulatory Guide 1.52 does not specifically require charcoal filters to have fixed automatic suppression systems.

5.4-13

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (e) The fresh air supply intakes to areas Comply:

containing safety related equipment or Fresh air intakes for the ventilation systems should be located remote from the systems are currently constructed with exhaust air outlets and smoke vents of other physical separation between exhaust fire areas to minimize the possibility of outlets. This is accomplished by contaminating the intake air with the routing plant ventilation exhaust air to products of combustion. the station stack which is remotely located from the station. Exhaust air not routed to the stack is separated from the air intakes.

(f) Stairwells should be designed to minimize Do not comply:

smoke infiltration during a fire. Staircases All stairwells are not enclosed.

should serve as escape routes and access Elevators are enclosed in masonry routes for fire fighting. Fire exit route shafts with 2-hour fire ratings. Escape should be clearly marked. Stairwells, and access routes are established.

elevators and chutes should be enclosed in masonry towers with minimum fire rating of three hours and automatic fire doors at least equal to the enclosure construction, at each opening into the building. Elevators should not be used during fire emergencies.

Where stairwells or elevators cannot be enclosed in three-hour fire rated barrier with equivalent fire doors, escape and access routes should be established by pre-fire plan and practiced in drills by operating and fire brigade personnel.

(g) Smoke and heat vents may be useful in Do not comply:

specific areas such as cable spreading rooms Specifically designed smoke and heat and diesel fuel oil storage areas and vents are not and will not be installed switchgear rooms. When natural-convection in structures or identified fire hazard ventilation is used, a minimum ratio of 1 sq. areas. Existing ventilation systems foot of venting area per 200 sq. feet of floor will be utilized for post fire purging as area should be provided. If forced- applicable.

convection ventilation is used, 300 CFM should be provided for every 200 sq. feet of floor area. See NFPA No. 204 for additional guidance on smoke control.

5.4-14

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (h) Self-contained breathing apparatus, using Comply:

full face positive pressure masks, approved Adequate self-contained breathing by NIOSH (National Institute for apparatus and spare bottles are Occupational Safety and Health - approval available for use. A manifold formerly given by the U.S. Bureau of Mines) breathing air system is available for should be provided for fire brigade, damage control room personnel.

control and control room personnel. Control room personnel may be furnished breathing air by a manifold system piped from a storage reservoir if practical. Service or operating life should be a minimum of one half hour for the self-contained units.

At least two extra air bottles should be located onsite for each self-contained breathing unit. In addition, an onsite 6-hour supply of reserve air should be provided and arranged to permit quick and complete replenishment of exhausted supply air bottles as they are returned. If compressors are used as a source of breathing air, only units approved for breathing air should be used. Special care must be taken to locate the compressor in areas free of dust and contaminants.

(i) Where total flooding gas extinguishing Comply:

systems are used, area intake and exhaust Where total flooding gas ventilation dampers should close upon extinguishing systems method is initiation of gas flow to maintain necessary utilized, dampers are installed to gas concentration. (See NFPA 12, "Carbon isolate the ventilation supply and Dioxide Systems," and 12A, "Halon 1301 exhaust ductwork. These dampers are Systems.") interlocked to close on the initiation of the gas system and are reopened to permit post fire purging. An example would be the diesel generator room at the station.

NFPA 12 and 12A were reviewed and deviation justified (F.P.P.D.P.

Volumes 8 and 9).

5.4-15

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 D.5 Lighting and Communication Lighting and two way voice communication are vital to safe shutdown and emergency response in the event of fire. Suitable fixed and portable emergency lighting and communication devices should be provided to satisfy the following requirements:

(a) Fixed emergency lighting should consist of Comply:

sealed beam units with individual 8-hour Fixed 8-hour emergency lighting is minimum battery power supplies. installed at selected locations throughout the plant per Appendix R,Section III.J requirements. See Section 7.5 of the Safe Shutdown Report (F.P.R. Volume 2).

(b) Suitable sealed beam battery powered Comply:

portable hand lights should be provided for Sealed beam battery powered portable emergency use. hand lights are available at the station for emergency use.

(c) Fixed emergency communication should use Comply:

voice powered head sets at pre-selected Two-way telephones and a paging stations. system exist throughout the plant. A limited number of voice powered head set stations are provided for maintenance use. In the event of fire damage to these systems, portable radios are available.

(d) Fixed repeaters installed to permit use of Comply with Intent:

portable radio communication units should Most fires remote from the repeaters be protected from exposure fire damage. will have no impact on the repeater equipment. However, communications will not be interrupted in the event of a fire as described in Section 7.6 of the Sate Shutdown Report. (F.P.R. Volume 2).

5.4-16

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 5.5 Fire Detection and Suppression Implementation or Justification Section NRC Position for Noncompliance E.1 Fire Detection (a) Fire detection systems should as a minimum Comply:

comply with NFPA 72D, "Standard for the Fire detection systems have been Installation, Maintenance and Use of reviewed against the criteria of NFPA Proprietary Protective Signaling Systems." 72D. The results of this review are found in the NFPA Code Review Deviations from the requirements of NFPA (F.P.P.D.P. Volumes 8 and 9).

72D should be identified and justified.

(b) Fire detection system should give audible Comply:

and visual alarm and annunciation in the Audible and visual alarms and control room. Local audible alarms should annunciation are provided in the also sound at the location of the fire. control room. Bells annunciate locally.

(c) Fire alarms should be distinctive and Comply:

unique. They should not be capable of being The station fire alarm is distinct from confused with any other plant system other station alarms.

alarms.

(d) Fire detection and actuation systems should Comply with intent:

be connected to the plant emergency power The fire detection and actuation supply. system is connected to uninterruptible and/or reliable power source.

E.2 Fire Protection Water Supply Systems (a) An underground yard fire main loop should Partially comply:

be installed to furnish anticipated firewater An underground yard fire main of requirements. NFPA 24, "Standard for polyurethane lined steel, unlimed Outside Protection", gives necessary steel, ductile iron, transite and PVC guidance for installation. pipe surrounds the units.

5.5-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance It references other design codes and standards Additional cross connections are developed by such organizations as the provided to improve system American National Standards Institute (ANSI) hydraulics and reliability.

and the American Water Works Association Sectionalizing valves are provided to (AWWA). Lined steel or cast iron pipe should minimize adverse impact on systems.

be used to reduce internal tuberculation. Such tuberculation deposits in an unlined pipe over a NFPA 24 code reviews justified the period of years can significantly reduce water deviation of the unlined piping in the flow through the combination of increased yard main. Condition of piping friction and reduced pipe diameter. Means for interior is monitored by conducting C-treating and flushing the systems should be factor tests every 3 years. Suppression provided. Approved visually indicating sectional systems were conservatively designed control valves, such as Post Indicator Valve, to allow for deterioration in the should be provided to isolate portions of the underground piping. Hydrants are main for maintenance or repair without shutting utilized in the periodic flushing of the off the entire system. system.

The fire main system piping should be separated NFPA 24 was reviewed and from service or sanitary water system piping. deviations are justified (F.P.P.D.P.

Volumes 8 and 9). See Hydraulic Visible location marking signs for underground Calculations (F.P.P.D.P. Volume 5).

valves are acceptable. Alternative valve position indicators should also be provided. No underground valves are provided within the security fence except for For operating plants, fire main system piping hydrant laterals.

that can be isolated from service or sanitary water system piping is acceptable.

(b) A common yard fire main loop may serve Comply with intent:

multi-unit nuclear power plant sites, if cross Common yard main fire loops and connected between units. Sectional control water supplies are utilized for valves should permit maintaining multiple units. Individual loops are independence of the individual loop around not provided around each unit, since each unit. For such installations, common units are not separated from one water supplies may also be utilized. The another. Refer to Section 5E.2(e) for water supply should be sized for the largest fire water supply capacity.

single expected flow. For multiple reactor sites with widely separated plants (approaching 1 mile or more), separate yard fire main loops should be used.

Sectionalized systems are acceptable.

5.5-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (c) If pumps are required to meet systems Partially Comply:

pressure or flow requirements, a sufficient Two 100% diesel driven fire pumps number of pumps should be provided so that are provided. These pumps are 100% capacity will be available with one located in the Unit 1 crib house and pump inactive (e.g., three 50% pumps or the Units 2 and 3 crib house, which two 100% pumps). The connection to the are widely separated. The fire pump yard fire main loop from each fire pump located in the Units 2 and 3 crib house should be widely separated, preferably is rated at 3000 gpm at 165 psig. A located on opposite sides of the plant. Each relief valve is provided to limit the pump should have its own driver with Unit 2/3 output to 3000 gpm at 150 independent power supplies and control. At psig because of concerns related to the least one pump (if not powered from the pressure rating of the fire protection emergency diesels) should be driven by non- water piping. The fire pump located in electrical means, preferably diesel engine. the Unit 1 crib house is rated at 2500 Pumps and drivers should be located in gpm at 147 psig. The fire pumps take rooms separated from the remaining pumps suction from intake canals which are and equipment by a minimum three-hour supplied from the cooling lake or the fire wall, alarms indicating pump running, Kankakee River. The fire pumps are driven availability, or failure to start should not separated from other equipment be provided in the control room. by fire walls. The connections to the loop from the fire pumps are approximately 300 feet apart, with a sectional valve between connections.

The fire system does not have a pressure maintenance pump because it is normally supplied by the house service water pumps. The five 15,000 gpm house service water pumps in the Units 2 and 3 crib house are connected by a 10-inch line to the fire system.

Details of the fire pump installation should as a Fire pumps as generally installed in minimum conform to NFPA 20, "Standard for accordance with NFPA 20, "Standard the Installation of Centrifugal Fire Pumps". for the Installation of Centrifugal Fire Pumps." Alarms indicating pump running, mechanical trouble, loss of d-c power and diesel day tank level are provided. NFPA 20 Code Review justified any deviation in the installation of these pumps (See F.P.P.D.P. Volumes 8 and 9).

5.5-3

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (d) Two separate reliable water supplies should Comply with intent:

be provided. If tanks are used, two 100% The fire pumps take suction from (minimum of 300,000 gallons each) system their respective intake canals which capacity tanks should be installed. They are fed from the Kankakee River.

should be so interconnected that pumps can Storage tanks are not used.

take suction from either or both. However, a leak in one tank or its piping should not cause both tanks to drain. The main plant fire water supply capacity should be capable of refilling either tank in a minimum of eight hours.

Common tanks are permitted for fire sanitary or service water storage. When this is done, however, minimum fire water storage requirements should be dedicated by means of a vertical standpipe for other water services.

(e) The fire water supply (total capacity and Comply with intent:

flow rate) should be calculated on the basis Hydraulic calculations have been of the largest expected flow rate for a period conducted to verify that each system of two hours, but not less than 300,000 demand can be satisfied with 1) either gallons. This flow rate should be based fire pump operating or 2) the (conservatively) on 1,000 gpm for manual hydraulically shortest leg of the fire hose streams plus the greater of: protection supply out of service. An allowance of 500 gpm was utilized for (1) all sprinkler heads opened and flowing additional hose stream use in the largest designed fire area; or simultaneous with fixed system operation.

(1) the largest open head deluge system(s) operating. This hose stream allowance assumed a 100 gpm flow from a nearby hose station and 400 gpm from a hydrant in the yard main. The water supply exceeds water requirements.

Hydraulic calculations are located in FPPDP Volumes 10 and 11 and station calculation files.

5.5-4

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (f) Lakes or fresh water ponds of sufficient size Comply:

may qualify as sole source of water for fire The additional fire protection water protection, but require at least two intakes to requirements are designed into the the pump supply. When a common water total storage capacity. Total supply is permitted for fire protection and requirements are 16,000 gpm by the ultimate heat sink, the following shutdown systems and fire protection conditions should also be satisfied: water requirements with 1,320, 000 gpm available from the Kankakee (1) The additional fire protection water River. Failure of the fire protection requirements are designed into the system will not degrade the function total storage capacity; and of the ultimate heat sink. The redundant fire pumps take suction (1) Failure of the fire protection system from separate intake canals.

should not degrade the function of the ultimate heat sink.

(g) Outside manual hose installation should be Comply with intent:

sufficient to reach any location with an Dresden Units 2 and 3 are in partial effective hose stream. To accomplish this, compliance with this position. Fire hydrants should be installed approximately hydrant spacing is in accordance with every 250 feet on the yard main system. The NFPA 24 and is less than 300 feet, lateral to each hydrant from the yard main except in the area of the crib house should be controlled by a visually indicating which has outside 2-1/2-inch hose or key operated (curb) valve. A hose house, connections and in the area of fire equipped with hose and combination nozzle, hydrants FH-3 and FH-27. Post and other auxiliary equipment recommended indicator type valves and/or in NFPA 24, "Outside Protection," should sectionalizing valves can be used for be provided as needed but at least every hydrant isolation and replacement.

1,000 feet. Threads compatible with those used by local fire departments should be NFPA 24 was reviewed and provided on all hydrants, hose couplings and deviations have been justified (see standpipe risers. F.P.P.D.P. Volumes 8 and 9).

Dresden Units 2 and 3 fire hydrants are provided with cabinets with sufficient 1-1/2-inch fire hose to reach outside locations. Hose houses or alternate mobile means of providing hose and associated equipment, such as hose carts or trucks, may be used.

All fire hose threads are compatible with the local fire department hose threads.

5.5-5

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance E.3 Water Sprinklers and Hose Standpipe Systems (a) Each automatic sprinkler system and manual hose station standpipe should have an Comply with intent:

independent connection to the plant Automatic sprinkler system and underground water main. Headers fed from manual hose stations are supplied each end are permitted inside buildings to from interior loops and mains. All supply multiple sprinkler and standpipe loops and interior mains have a systems. When provided, such headers are minimum of two connections to the considered an extension of the yard main underground loop. No single failure system. The header arrangement should be will impair both primary and backup such that no single failure can impair both systems.

the primary and backup fire protection system. Automatic sprinkler systems and standpipe systems are equipped with OS&Y gate valves or other approved valves. Water flow alarms are provided for automatic sprinkler systems, but not for standpipe systems.

Each sprinkler and standpipe system should Special water shields or baffles are be equipped with OS&Y (outside screw and provided for some safety-related yoke) gate valve, or other approved shutoff equipment. A suppression effects valve, and water flow alarm. Safety-related analysis was performed to ensure that equipment that does not itself require water discharge would not adversely sprinkler water fire protection, but is subject affect safe shutdown of the plant. The to unacceptable damage if wetted by results of this analysis are sprinkler water discharge should be documented in Section 4.0 of this protected by water shields or baffles. report.

(b) All valves in the fire water systems should Comply:

be electrically supervised. The electrical Electrical supervision is generally supervision signal should indicate in the provided for valves controlling control room and other appropriate individual fixed extinguishing command locations in the plant (See NFPA systems. Interior and exterior 26 "Supervision of Valves.") sectional control valves are not electrically supervised. Valves are When electrical supervision of fire sealed or locked in the proper position protection valves is not practicable, an and inspected monthly. NFPA 26 was adequate management supervision program reviewed and deviations justified should be provided. Such a program should (F.P.P.D.P. Volumes 8 and 9).

include locking valves open with strict key control; tamper proof seals; and periodic, visual check of all valves.

5.5-6

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (c) Automatic sprinkler systems should as a Comply with intent:

minimum conform to requirements of Fixed water extinguishing systems are appropriate standards such as NFPA 13, installed in accordance with the "Standard for the Installation of Sprinkler appropriate NFPA standards. NFPA Systems," and NFPA 15, "Standard for 13 and 15 have been reviewed and Water Spray Fixed Systems." deviations justified (F.P.P.D.P.

Volumes 8 and 9) 5.5-7

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (d) Interior manual hose installation should be Comply with intent:

able to reach any location with at least one Manual hose stations are not provided effective hose stream. To accomplish this, for cable tunnel and containment standpipes with hose connections equipped drywells, however adequate hose is with a maximum of 75 feet of 1-1/2-inch provided for access to these areas.

woven jacket-lined fire hose and suitable nozzles should be provided in all buildings, Dresden utilizes rubber lined hose and including containment, on all floors and hose lengths do not exceed 100 feet.

should be spaced at not more than 100-foot A few hose standpipes serving intervals. Individual stand-pipes should be multiple hose connections are less of at least 4-inch diameter for multiple hose than 4-inch diameter, and several connections and 2-1/2-inch diameter for standpipes serving single hose single hose connections. These systems connections are less than 2-1/2-inch should follow the requirements of NFPA 14 diameter. Other portions of the for sizing, spacing and pipe support standpipe and hose systems comply requirements (NELPIA). with NFPA 14, "Standpipe and Hose Systems."

Hose stations should be located outside entrances to normally unoccupied areas and Hose stations are generally located inside normally occupied areas. Standpipes outside of unoccupied areas. Shutoff serving hose stations in areas housing valves are provided for all standpipes safety-related equipment should have or sections of interior piping.

shutoff valves and pressure reducing devices Additional shutoff valves are not (if applicable) outside the area. provided for areas housing safety-related equipment. Standpipe systems are installed and tested in accordance with NFPA 14, "Standpipe and Hose Systems" Cross connections to essential service water systems are not provided within the plant.

NFPA 14 was reviewed and deviations justified (F.P.P.D.P.

Volumes 8 and 9).

Signs are installed warning of hose station high pressure.

5.5-8

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (e) The proper type of hose nozzles to be Comply:

supplied to each area should be based on the Electrical safe nozzles are provided at fire hazard analysis. The usual combination locations where electrical equipment spray/straight-stream nozzle may cause or cabling is located.

unacceptable mechanical damage (for example, the delicate electronic equipment in the control room) and be unsuitable.

Electronically safe nozzles should be provided at locations where electrical equipment or cabling is located.

(f) Certain fires such as those involving Fixed foam protection is not provided flammable liquids respond well to foam for flammable or combustible liquid suppression. Consideration should be given hazards. Portable foam extinguishers to use of any of the available foams for such are provided to supplement manual specialized protection application. These equipment.

include the more common chemical and mechanical low expansion foams, high expansion foam and the relatively new aqueous film forming foam (AFFF).

E.4 Halon Suppression Systems The use of Halon fire extinguishing agents Comply with intent:

should as a minimum comply with the Dresden Units 2 and 3 utilize Halon requirements of NFPA 12A and 12B, 1301 for protection of the Auxiliary "Halogenated Fire Extinguishing Agent Electric Equipment Room. This Systems-Halon 1301 and Halon 1211." Only UL installation meets the requirements of or FM approved agents should be used. NFPA 12A.

In addition to the guidelines of NFPA 12A and NFPA 12A was reviewed and 12B, preventative maintenance and testing of deviations justified (F.P.P.D.P.

the systems, including check weighing of the Volumes 8 and 9).

Halon cylinders should be done at least quarterly. Surveillance is conducted in accordance with tech specs and Particular consideration should also be given to: related procedures.

(a) minimum required Halon concentration and soak time, (b) toxicity of Halon, (c) toxicity and corrosive characteristics of thermal decomposition products of Halon.

5.5-9

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 E.5 Carbon Dioxide Suppression Systems The use of carbon dioxide extinguishing systems should as a minimum comply with the requirements of NFPA 12, "Carbon Dioxide Extinguishing Systems."

Particular consideration should also be given to:

(a) minimum required CO2 concentration and Partially comply:

soak time; (a) NFPA 12 was used in design although installation acceptance tests were not specifically performed.

(b) toxicity of CO2; (b) All carbon dioxide systems have predischarge alarms.

(c) possibility of secondary thermal shock (c) Nozzles do not discharge directly (cooling) damage; on equipment.

(d) offsetting requirements for venting during (d) See part (a).

CO2 injection to prevent overpressurization versus sealing to prevent loss of agent; (e) design requirements from (e) See part (a).

overpressurization; and (f) possibility and probability of CO2 systems (f) Carbon dioxide systems are not being out of service because of personnel provided with individual shutoff safety consideration. CO2 systems are valves and are not taken out of disarmed whenever people are present in an service for equipment area so protected. Areas entered frequently maintenance or at other times (even though duration time for any visit is when personnel are present.

short) have often been found with CO2 systems shut off.

5.5-10

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 E.6 Portable Extinguishers Fire extinguishers should be provided in Do not comply:

accordance with guidelines of NFPA 10 and Standpipes are generally used in lieu 10A, "Portable Fire Extinguishers, Installation, of Class A extinguishers. CO2 and dry Maintenance, and Use." Dry Chemical chemical portable extinguishers are extinguishers should be installed with due available for use on Class B and C consideration given to cleanup problems after hazards.

use and possible adverse effects on equipment installed in the area. NFPA 10 and 10A were reviewed and deviations justified (F.P.P.D.P.

Volumes 8 and 9).

5.5-11

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 5.6 Guidelines for Specific Plant Areas 5.6.1 Primary and Secondary Containment Implementation or Justification Section NRC Position for Noncompliance F.1 (a) Normal Operation Fire protection requirements for the primary Comply with intent:

and secondary containment areas should be Fire protection for the primary and provided on the basis of specific identified secondary containment fire hazards hazards. For example: were considered in plant design.

(i) Lubricating oil or hydraulic fluid systems for the coolant pumps (ii) Cable tray arrangements and cable penetrations (iii) Charcoal filters Fire suppression systems should be provided Local water suppression systems are based on the fire hazards analysis. provided over specific fire hazards (i.e., HPCI room and ACAD Fixed fire suppression capability should be compressors). Water suppression provided for hazards that could jeopardize systems are also provided to separate safe plant shutdown. Automatic sprinklers fire areas as described in the are preferred. An acceptable alternate is Exemption Requests (Sections 3.2, automatic gas (Halon or CO2) for hazards 3.3, 4.2, and 4.9) (F.P.R. Volume 4).

identified as requiring fixed suppression There are no fire protection features protection. inside primary containment. The primary containment is inerted with nitrogen during operation, no gaseous suppression is used in secondary containment.

An enclosure may be required to confine the The Safe Shutdown Report (F.P.R.

agent if a gas system is used. Such Volume 2) describes the effects of a enclosures should not adversely affect safe fire on safe plant shutdown. The shutdown, or other operating equipment in Exemption Requests (F.P.R. Volume containment. 4) provide justification for not installing complete suppression.

5.6-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance Operation of the fire protection systems should not compromise integrity of the containment or the other safety related systems. Fire protection activities in the containment areas should function in conjunction with total containment requirements such as control of contaminated liquid and gaseous release and ventilation.

Automatic fire suppression capability need Administrative procedures and not be provided in the primary containment controls are enforced during refueling atmospheres that are inerted during normal and maintenance operations to control operation. However, special fire protection any additional hazards that would be requirements during refueling and introduced to the primary containment maintenance operations should be satisfied area.

as provided below.

Fire detection systems should alarm and Automatic fire detection is provided annunciate in the control room. The type of throughout most areas of the reactor detection used and the location of the building (secondary containment).

detectors should be most suitable to the (See Section 4.0 of this report). The particular type of fire that could be expected Exemption Requests (F.P.R. Volume from the identified hazard. A primary 4) provide justification for not containment general area fire detection installing complete fire detection capability should be provided as backup for systems. Suppression or detection the above described hazard detection. To systems are not being installed in the accomplish this, suitable smoke detection primary containment since it is inerted (e.g., visual obscuration, light scattering and during operation.

particle counting) should be installed in the air recirculation system ahead of any filters.

5.6-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (b) Refueling and Maintenance Refueling and maintenance operations in Comply:

containment may introduce additional Combustibles and ignition sources are hazards such as contamination control controlled through administrative materials, decontamination supplies, wood procedures.

planking, temporary wiring, welding and flame cutting (with portable compressed fuel gas supply). Possible fires would not necessarily be in the vicinity of fixed detection and suppression systems.

Management procedures and controls necessary to assure adequate fire protection are discussed in Section 3a.

In addition, manual fire fighting capability Water standpipes, hose stations and should be permanently installed in portable CO2 extinguishers are located containment. Standpipes with hose stations, at various areas in the secondary and portable fire extinguishers, should be containment. Sufficient hose length is installed at strategic locations throughout provided to reach into the primary containment for any required manual fire containment.

fighting operations.

Equivalent protection from portable systems should be provided if it is impractical to install standpipes with hose stations.

Adequate self-contained breathing apparatus Adequate self-contained breathing should be provided near the containment apparatus is provided near primary entrances for fire fighting and damage containment entrances.

control personnel. These units should be independent of any breathing apparatus or air supply systems provided for general plant activities.

5.6-3

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 5.6.2 Control Room Implementation or Justification Section NRC Position for Noncompliance F.2 The control room is essential to safe reactor Comply with intent:

operation. It must be protected against disabling Complete 3-hour fire barriers are fire damage and should be separated from other provided with the exception of the areas of the plant by floors, walls, and roofs floor between the control room and having minimum fire resistance rating of three the AEER, which is 6-inch-thick hours. concrete supported on coated structural steel. The AEER and control room form one fire area. Safe shutdown for both units can be achieved independent of this fire area.

In addition, the ceiling of the control room is supported by unprotected steel. A justification for the control room steel is provided in the Exemption Requests (F.P.R. Volume 4).

See Safe Shutdown Report (F.P.R.

Volume 2).

Unit 1 is separated from the Unit 2/3 control room by a 3-hour rated barrier.

Hose stations adjacent to the control room with Comply:

the portable extinguishers in the control room Hose stations and portable are acceptable.

extinguishers are provided as shown on F drawing F-8-1.

Nozzles that are compatible with the hazards Comply:

and equipment in the control room should be Appropriate nozzles are provided.

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

5.6-4

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 Implementation or Justification Section NRC Position for Noncompliance Fire detection in the control room cabinets and Comply with intent:

consoles should be provided by smoke and heat Ceiling level ionization detection is detectors in each fire area. Alarm and provided throughout the control room.

annunciation should be provided in the control Fire detection however, is not room. Fire alarms in other parts of the plant provided in control room cabinets or should also be alarmed and annunciated in the consoles since personnel in the control room.

control room would be able to quickly detect and extinguish a fire. Fire alarms throughout the plant will alarm and annunciate in the control room.

Breathing apparatus for control room operators Comply with intent:

should be readily available. Control room floors, Breathing apparatus is available for ceiling, supporting structures, and walls, control room operators (see Section including penetrations and doors, should be 5.4 (D.4.h.)). Discussion of fire designed to a minimum fire rating of three barriers is provided in the first hours. All penetration seals should be air tight. paragraph above.

The control room ventilation intake should be Comply:

provided with smoke detection capability to The control room HVAC system is alarm locally in order to allow control room designed to isolate and maintain the personnel to manually operate ventilation design conditions within the control dampers to prevent smoke from entering the room during a fire in either the control control room. Manually operating venting room, the auxiliary computer room or should be available so that operators have the outside the emergency zone. The option of venting for visibility. Control Room ventilation system has smoke detectors installed in the intake and return air ducts. Upon detection of smoke in the intake duct, the operators will manually reposition the dampers to isolate outside air upon detection of smoke in the return air ducts the ventilation system may be manually switched to the smoke purge mode.

Cables should not be located in concealed floor Do not comply:

and ceiling spaces. All cables that enter the A small central console area is located control room should terminate in the control on a raised floor. Only cables for room. That is, no cabling should be simply equipment on this platform are routed through the control room from one area located under this floor. These cables to another. are routed from the AEER and are sealed at the floor penetration.

5.6-5

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 5.6.3 Cable Room Implementation or Justification Section NRC Position for Noncompliance F.3 (a) (1) Automatic water system such as closed There are no dedicated cable head sprinklers, open head deluge, or spreading rooms at the Dresden open directional spray nozzles. Deluge station. The AEER is similar to a and open spray systems should have cable spread room and contains both provisions for manual operation at a divisions of cabling for both units.

remote station; however, there should The protection provided for the AEER also be provisions to preclude is described in F.3.(b) below.

inadvertent operation. Location of sprinkler heads or spray nozzles should The Unit 2 Battery Room also consider cable tray sizing and contains a cable concentration related arrangements to assure adequate water to a limited amount of both divisions coverage. Cables should be designed to of only Unit 2 cabling (see Section allow wetting down with deluge water 5.6.7 for additional detail). Safe without electrical faulting. Open head shutdown for both units can be deluge and open directional spray achieved independent of these fire systems should be zoned so that a areas. This area has complete single failure will not deprive the entire detection. See Safe Shutdown area of automatic fire suppression Analysis (F.P.R. Volume 2) and capability. The use of foam is Exemption Requests (F.P.R. Volume acceptable, provided it is of a type 4).

capable of being delivered by a sprinkler or deluge system, such as an Aqueous Film Forming Foam (AFFF).

(2) Manual hoses and portable Comply:

extinguishers should be provided as Manual hoses and portable backup. extinguishers are provided (3) Each cable spreading room of each unit Do not comply:

should have divisional cable separation, Both divisions for each unit are and be separated from the rest of the located in the areas used as cable plant by a minimum three-hour rated spread rooms. Alternative shutdown fire wall (Refer to MEPA 251 or ASTM capability has been provided per E-119 for the fire test resistance rating. provisions of Appendix R. See Safe Shutdown Analysis (F.P.R. Volume 2).

Comply:

(4) At least two remote and separate Two separate entrances are provided entrances are provided to the room for for the AEER and battery room access by fire brigade personnel.

(5) Aisle separation provided between tray Comply with intent:

stacks should be at least three feet wide All cable trays are accessible for and eight feet high. manual suppression.

5.6-6

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (b) For cable spreading rooms that do not Comply:

provide divisional cable separation of (a)

(3), in addition to meeting (a) (1), (2), (4), The AEER is protected by an and (5) above, the following should also be automatic halon suppression system provided: actuated by a cross-zoned ionization detection system. Manually actuated (1) Divisional cable separation should total flooding CO2 suppression is meet the guidelines of Regulatory provided to back up the automatic Guide 1.75, "Physical Independence of system. All non-qualified IEEE-383 Electric Systems." cables have been coated with a fire retardant coating. The AEER is (2) All cabling should be covered with a separated from all other plant areas by suitable fire retardant coating. complete three-hour barriers except for the Control Room above, which is (3) As an alternate to (a) (1) above, considered part of the same fire area.

automatically initiated gas systems Safe shutdown can be achieved (Halon or CO2) may be used for independent of this fire area. See primary fire suppression, provided a Safe Shutdown Report, Section 4.12 fixed water system is used as a backup. (F.P.R. Volume 2)

(4) Plants that cannot meet the guidelines of Regulatory Guide 1.75, in addition to meeting (a) (1), (2), (4), and (5) above, an auxiliary shutdown system will all cabling independent of the cable spreading room should be provided.

5.6-7

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 5.6.4 Plant Computer Room Implementation or Justification Section NRC Position for Noncompliance F.4 Safety-related computers should be separated The plant computers are not safety-from other areas of the plant by barriers related at Dresden.

having a minimum three-hour resistant rating. Automatic fire detection should be provided to alarm and annunciate in the control room and alarm locally. Manual hose stations and portable water and halon fire extinguishers should be provided.

5.6-8

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 5.6.5 Switchgear Rooms Implementation or Justification Section NRC Position for Noncompliance F.5 Switchgear rooms should be separated from the Comply with intent:

remainder of the plant by minimum three-hour No switchgear rooms were provided rated fire barriers to the extent practicable. in the design of Dresden 2 & 3.

Essential switchgear and MCCs are located in the turbine and reactor buildings. Alternative shutdown capability has been identified in all areas containing switchgear and MCCs. See Safe Shutdown Report (F.P.R. Volume 2).

Automatic fire detection should alarm and Automatic fire detection is provided annunciate in the control room and alarm in the vicinity of all switchgear and locally. MCCs, which alarms is the control room.

Fire hose stations and portable extinguishers Hose stations and portable fire should be readily available. extinguishers are provided for switchgear and MCCs.

Acceptable protection for cables that pass Not applicable (see above).

through the switchgear room is automatic water or gas agent suppression. Such automatic suppression must consider preventing unacceptable damage to electrical equipment and possible necessary containment of agent following discharge.

5.6-9

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 5.6.6 Remote Safety-Related Panels Implementation or Justification Section NRC Position for Noncompliance F.6 The general area housing remote safety-related Comply with intent:

panels should be protected with automatic fire In general, local panels which are detectors that alarm and annunciate in the used for safe shutdown are in areas control room. Combustible materials should be that are provided with fire detectors controlled and limited to those required for and/or suppression.

operation. Portable extinguishers and manual hose stations should be provided.

5.6-10

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 5.6.7 Station Battery Room Implementation or Justification Section NRC Position for Noncompliance F.7 Battery rooms should be protected against fire Comply:

explosions. NFPA 69 was reviewed and deviations justified (F.P.R. Volumes 8 and 9). Air flow alarms are provided in ventilation system to notify the control room upon loss of ventilation.

Battery rooms should be separated from each Do not comply:

other and other areas of the plant by barriers Unit 2 battery rooms are surrounded having a minimum fire rating of three-hours by 1-hour barriers. The 1-hour inclusive of all penetrations and openings. protection is provided to contain a fire within the battery rooms. Unit 3 battery room is surrounded by noncombustible barriers.

Ventilation system in the battery rooms should Comply:

be capable of maintaining the hydrogen NFPA 69 was reviewed and deviation concentration well below 2 volume percent justified (F.P.P.D.P. Volumes 8 and hydrogen concentration. 9). Air flow alarms are provided in ventilation system to notify the control room upon loss of ventilation.

Standpipe and hose and portable extinguishers Comply:

should be provided. See F-drawings F-8-1 and F-14-1.

Alternatives: Not applicable.

(a) Provide a total fire rated barrier enclosure of the battery room complex that exceeds the fire load contained in the room.

(b) Reduce the fire load to be within the fire barrier capability of 1-1/2-hours.

(c) Provide a remote manual actuated sprinkler system in each room and provide the 1-1/2-hour fire barrier separation.

5.6-11

DRESDEN 2&3 AMENDMENT 20 JUNE 2015 5.6.8 Turbine Lubrication and Control Oil Storage and Use Areas Implementation or Justification Section NRC Position for Noncompliance F.8 A blank fire wall having a minimum resistance The clean and dirty oil room has a 3-rating of three hours should separate all areas hour fire rating and is protected by containing safety-related systems and equipment wet pipe sprinklers.

from the turbine oil system.

All other areas containing oil are When a blank wall is not present, open head provided with an automatic water deluge protection should be provided for the protection system as described below.

turbine oil hazards and automatic open head water curtain protection should be provided for The turbines for Units 2 and 3 are wall openings. equipped with separate electrohydraulic control (EHC) systems using approved fire retardant fluid. The EHC reservoirs are protected by water spray actuated by thermal detection. Automatic water spray protects the bearing lift pumps.

Bearing lift pump oil systems are located on the turbine floor outside of the radiation shield wall. The turbine oil reservoir tanks with a capacity of 11,450 gallons are located on the mezzanine floor of the turbine building. These tanks are protected with an automatic water spray actuated by thermal detectors supplemented by a ceiling-level wet pipe sprinkler system. The sprinklers provided for the turbine oil reservoirs will also provide protection for the standby gas treatment equipment which is safety-related. Drainage sumps are also provided. The hydrogen seal oil reservoirs are protected with automatic water spray systems actuated by thermal detectors.

5.6-12

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 5.6.9 Diesel Generator Area Implementation or Justification Section NRC Position for Noncompliance F.9 Diesel generators should be separated from each Comply with intent:

other and other areas of the plant by fire barriers DG cells 2 and 3 are separated and having a minimum resistance rating of three each is enclosed with complete 3-hour hours. rated barriers except for the annular spaces around the DG exhaust and air supply pipes. The 2/3 DG cell is separated from the reactor buildings by complete 3-hour barriers and from the HPCI rooms located below, by reinforced concrete which contains removable concrete plugs. These are also two unrated doors in series which provide access to each HPCI room from the 2/3 DG room. The HPCI rooms and the 2/3 DG room form a fire area which has identified shutdown paths independent of this area.

Automatic fire suppression such as AFFF foam, Comply:

or sprinklers, should be installed to combat any An automatic total flooding CO2 diesel generator or lubricating oil fires system is provided in each DG room.

(automatic gas systems may be used in lieu of Manual smoke venting is provided by foam or sprinklers). Automatic fire detection portable smoke ejectors.

should be provided to alarm and annunciate in the control room and alarm locally. Drainage for fire fighting water and means for local manual venting of smoke should be provided.

Day tanks with total capacity up to 1100 gallons Do not comply:

are permitted in the diesel generator area under Although the day tank enclosure is the following conditions: masonry, it is not 3-hour rated.

Furthermore, the room is not (a) The day tank is located in a separate ventilated although the tanks are enclosure, with a minimum fire resistance vented to outside the building. The rating of three hours, including doors or day tank rooms are considered part of penetrations. These enclosures should be the DG cell.

capable of containing the entire contents of the day tanks. The enclosure should be ventilated to avoid accumulation of oil fumes.

5.6-13

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance (b) The enclosure should be protected by Comply:

automatic fire suppression systems such as The DG day tank rooms are provided AFFF or sprinklers. with automatic sprinkler protection.

Upon actuation of the CO2 systems in the DG area, CO2 is discharged into the day tank rooms.

5.6-14

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 5.6.10 Diesel Fuel Oil Storage Area Implementation or Justification Section NRC Position for Noncompliance F.10 Diesel fuel oil tanks with a capacity greater than Comply:

1100 gallons should not be located inside the Diesel fuel oil storage tanks are buildings containing safety-related equipment. buried underground, thus meeting the They should be located at least 50 feet from any 3-hour fire separation criteria.

building containing safety-related equipment, or if located within 50 feet, they should be housed in a separated building with construction having a minimum fire resistance rating of three hours.

Buried tanks are considered as meeting the three hour fire resistance requirements. See NFPA 30, "Flammable and Combustible Liquids Code,"

for additional guidance.

5.6-15

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 5.6.11 Safety-Related Pumps Implementation or Justification Section NRC Position for Noncompliance F.11 Pump houses and rooms housing safety-related Comply with intent:

pumps should be protected by automatic Safety-related pumps are located in sprinkler protection unless a fire hazards the turbine and reactor buildings.

analysis can demonstrate that a fire will not Automatic sprinkler protection and/or endanger other safety-related equipment detection is provided as deemed required for safe plant shutdown. Early warning appropriate by the fire hazards fire detection should be installed with alarm and analysis (see Section 4.0).

annunciation locally and in the control room.

Local hose stations and portable extinguishers Local hose stations and portable fire should also be provided. extinguishers are provided throughout safety-related pump areas.

Equipment pedestals or curbs and drains should Equipment pedestals, curbs and drains be provided to remove and direct water away are provided to remove and direct from safety-related equipment. water away from safety-related equipment.

Provisions should be made for manual control of Ventilation of safety-related pump the ventilation system to facilitate smoke areas may be manually controlled by removal if required for manual fire fighting adjusting the balancing dampers to operation. either reduce or increase the air flow rate into these areas. Exhaust from these areas is vented through the reactor building stack.

5.6-16

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 5.6.12 New Fuel Area Implementation or Justification Section NRC Position for Noncompliance F.12 Hand portable extinguishers should be located Partially comply:

within this area. Also, local hose stations should Portable fire extinguishers and local be located outside but within hose reach of this hose stations are located immediately area. outside of the new fuel storage area.

Automatic fire detection should alarm and Automatic fire detection is not annunciate in the control room and alarm provided for this area since the locally. combustible loadings present are minor and would not affect any systems or equipment important to safe reactor shutdown or radioactivity control.

Combustibles should be limited to a minimum Combustibles are limited by in the new fuel area. administrative controls in the new fuel area.

The storage area should be provided with a The storage area is provided with a drainage system to preclude accumulation of drain to preclude accumulation of water. water.

The storage configuration of new fuel should The geometric configuration of the always be so maintained as to preclude new fuel storage racks preclude criticality for any water density that might occur criticality for any water density that during fire water application. might occur during a fire water application.

5.6-17

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 5.6.13 Spent Fuel Pool Area Implementation or Justification Section NRC Position for Noncompliance F.13 Protection for the spent fuel pool area should Partially comply:

be provided by local hose stations and portable Portable fire extinguishers and local extinguishers. hose stations are located throughout the spent fuel pool area.

Automatic fire detection should be provided to No automatic fire detection is alarm and annunciate in the control room and provided for this area since the to alarm locally. combustible loadings present are minor and would not affect any systems or equipment important to safety reactor shutdown or radioactivity control.

5.6-18

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 5.6.14 Radwaste Building Implementation or Justification Section NRC Position for Noncompliance F.14 The Radwaste Building should be separated Do not comply:

from other areas of the plant by fire barriers The wall shared with the Turbine having at least three-hour ratings. Building is constructed of unrated masonry. The safe shutdown analysis has demonstrated that a fire in the Radwaste Building will not prevent safe shutdown.

Automatic sprinklers should be used in all No automatic sprinklers are provided areas where combustible materials are located. based on a fire hazards analysis of the Radwaste Building.

Automatic fire detection should be provided to No fire detection is provided. Area annunciate an alarm in the control room and radiation monitors are present in the alarm locally. Radwaste Building. A fire would probably result in airborne activity which would be detected by area radiation monitors. Hose stations and portable fire extinguishers are provided throughout the Radwaste Building.

During a fire, the ventilation systems in these The ventilation system is independent areas should be capable of being isolated. of other plant ventilation systems and is capable of being shut down in the event of a fire and restarted for post-fire purge.

Water should drain to liquid Radwaste Water drains to the liquid Radwaste Building sumps. Building sumps.

Acceptable alternative fire protection is No fire detection is provided. Hose automatic fire detection to alarm and stations and portable fire annunciate in the control room, in addition to extinguishers are provided throughout manual hose stations and portable extinguishers the Radwaste Building.

consisting of hand held and large wheeled units.

5.6-19

DRESDEN 2&3 AMENDMENT 21 JUNE 2017 5.6.15 Decontamination Areas Implementation or Justification Section NRC Position for Noncompliance F.15 The decontamination areas should be protected Not applicable:

by automatic sprinklers if flammable liquids Decontamination areas are treated as are stored. part of the areas in which they are located. No flammable liquids are Automatic fire detection should be provided to stored in these areas.

annunciate and alarm in the control room and alarm locally.

The ventilation system should be capable of being isolated.

Local hose stations and hand portable extinguishers should be provided as backup to the sprinkler system.

5.6.16 Safety-Related Water Tanks Implementation or Justification Section NRC Position for Noncompliance F.16 Storage tanks that supply water for safe Comply:

shutdown should be protected from the effects Safety related water tanks consist of of fire. the U2 and U3 torus, which are surrounded by 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated walls and exterior walls of a minimum of 1ft thick reinforced concrete. Each fire zone is protected with thermal detection in and under the cable trays which alarm locally and in the control room the fire zone has hose stations and portable fire extinguisher available for fire brigade use in the event of a fire.

Local hose stations and portable extinguishers See position above.

should be provided. Portable extinguishers should be located in nearby hose houses.

Combustible materials should not be stored Not Applicable:

next to outdoor tanks. A minimum of 50 feet of There are no safety-related outdoor separation should be provided between outdoor water tanks.

tanks and combustible materials where feasible.

While the CSTs are called upon during a post-fire safe shutdown, such 5.6-20

DRESDEN 2&3 AMENDMENT 21 JUNE 2017 Implementation or Justification Section NRC Position for Noncompliance an event is not considered a design basis event per 10CFR50 Appx. F,Section III.L.6. Thus, the CSTs are NOT safety related water tanks.

5.6.17 Cooling Towers Implementation or Justification Section NRC Position for Noncompliance F.17 Cooling towers should be of non- Cooling Towers are installed for Combustible construction or so supplemental cooling during warm located that a fire will not weather. These Cooling Towers are well detached from the power block adversely affect any safety re-are non-safety related and do not lated systems or equipment. Cooling expose safe shutdown equipment towers should be of non-combustible construction when the basins are .

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

5.6-21

DRESDEN 2&3 AMENDMENT 18 JUNE 2011 5.6.18 Miscellaneous Areas Implementation or Justification Section NRC Position for Noncompliance F.18 Miscellaneous areas such as records storage Comply:

areas, shops, warehouses, and auxiliary boiler Miscellaneous areas are located or rooms should be so located that a fire or effects protected so as to minimize effects of of a fire, including smoke, will not adversely a fire on any safety-related systems affect any safety-related systems or equipment. and equipment. Fuel oil tanks for the Fuel oil tanks for auxiliary boilers should be auxiliary boilers are provided with buried or provided with dikes to contain the earth dikes to contain the entire tank entire tank contents. contents. Portable fire extinguishers and hose stations are provided in the various areas. Outside bulk hydrogen storage is located in the yard south of the training building. Hydrogen piping is properly color coded and marked. Units 2/3 boiler house is constructed of noncombustible material and is protected by automatic sprinklers.

5.6-22

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 5.7 Special Protection Guidelines Implementation or Justification Section NRC Position for Noncompliance G.1 Welding and Cutting, Acetylene - Oxygen Fuel Gas Systems This equipment is used in various areas Comply with intent:

throughout the plant. Storage locations should A permit system is used when be chosen to permit fire protection by automatic welding and cutting work is being sprinkler systems. Local hose stations and done. The bulk storage of this portable equipment should be provided as material is outdoors in designated backup. The requirements of NFPA 51 and 51B storage areas under administrative are applicable to these hazards. A permit system procedures. Hose stations and should be required to utilize this equipment. portable fire extinguishers are (Also refer to 2f herein.) provided throughout the plant. NFPA 51 and 51B were reviewed and deviation justified (F.P.P.D.P.

Volumes 8 and 9).

G.2 Storage Areas for Dry Ion Exchange Resins Dry ion exchange resins should not be stored Comply with intent:

near essential safety-related systems. Dry Resins are temporarily stored in unused resins should be protected by automatic various locations within the Turbine wet pipe sprinkler installations. Detection by Building away from vital equipment.

smoke and heat detectors should alarm and annunciate in the control room and alarm locally. Local hose stations and portable extinguishers should provide backup for these areas. Storage areas of dry resin should have curbs and drains. (Refer to NFPA 92M, "Waterproofing and Draining of Floors.")

G.3 Hazardous Chemicals Hazardous chemicals should be stored and Comply:

protected in accordance with the Hazardous chemicals are kept in recommendations of NFPA 49, "Hazardous proper containers in accordance with Chemicals Data." fire protection recommendations.

Chemicals storage areas should be well Ventilation and flood protection are ventilated and protected against flooding provided. NFPA 49 and 30 were conditions since some chemicals may react with reviewed and deviations justified in water to produce ignition. the NFPA code review (F.P.P.D.P.

Volumes 8 and 9).

5.7-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 Implementation or Justification Section NRC Position for Noncompliance Materials Containing Radioactivity G.4 Materials that collect and contain radioactivity Comply with intent:

such as spent ion exchange resins, charcoal Materials such as resins and filters filters, and HEPA filters should be stored in which collect and contain closed metal tanks or containers that are located radioactivity are stored in controlled in areas free from ignition sources or areas and kept in closed containers.

combustibles. These materials should be protected from exposure to fires in adjacent areas as well. Consideration should be given to requirements for removal of isotopic decay heat from entrained radioactive materials.

5.7-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 6.0 UNIT 1 FIRE PROTECTION REVIEW 6.1 Introduction Dresden Unit 1 ceased operation in October 1978 when it was shut down for safety system upgrades and chemical decontamination of major piping systems. While shut down, the Three Mile Accident occurred resulting in a number of sweeping changes in regulatory requirements.

In October 1984, Commonwealth Edison Company decided to place Dresden Unit 1 in a safe storage condition (SAFSTOR), rather than undergo the additional capital expenditures required to bring the unit into conformance with the new regulatory requirements. Unit 1 dismantlement is planned to occur concurrent with the decommissioning of Units 2 and 3.

Since Dresden Unit 1 is undergoing decommissioning, safe shutdown under 10 CFR 50 Appendix R is no longer a concern. The Fire Protection Program requirements applicable to the unit are delineated by 10 CFR 50.48(f). The Dresden Unit 1 Fire Protection Program has the following objectives:

Reasonably prevent fires from occurring that could result in an unacceptable release of radioactive materials; Rapidly detect, control, and extinguish fires which occur that could result in an unacceptable release of radioactive materials; Minimize the risk to the public, environment, and plant personnel resulting from fires that could result in an unacceptable release of radioactive materials; And prevent the possibility of a fire occurring in Unit 1 from posing an adverse safe shutdown risk to Units 2/3.

The Unit 1 Decommissioning Plant Manager has delegated, to the Unit 2/3 Station Manager, the responsibility to provide the site fire protection program. As such, all decommissioning work activities on Dresden Unit 1 are carried out under the same procedures and practices as applicable for Units 2/3.

6.1-1

DRESDEN 2&3 AMENDMENT 17 JUNE 2009 6.2 Definitions

1. West Auxiliary Bay For purposes of this discussion, the West Auxiliary Bay is considered to be all Unit 1 elevations west of column line 28. The West Auxiliary Bay is comprised of the following Unit 1 Fire Zones, or portions thereof (Reference 3):

7.1, Unit 1 Battery Room, elevation 517-0, borders Unit 2 Fire Zone 6.2, and is located beneath the Unit 2/3 Control Room Portion that extends into Unit 1.

4.1, Unit 2 Main Computer Room, elevation 517-0, borders Unit 2 Fire Zone 6.2, and is located beneath the Unit 2/3 Control Room Portion that extends into Unit 1.

9.1, Diesel Generator, elevation 517-0, borders Unit 2 Fire Zone 8.2.5.A.

8.4.1, Turbine Building Ground Floor, elevation 517-6, principal Unit 1 fire zone on ground floor, borders Unit 2/3 Fire Zones 8.2.5.A, 6.2, and 2.0.

2.1, Work Execution Center (WEC), elevation 534-0, was formed out of the balance of the Unit 1 Control Room area that was not incorporated into the Unit 2/3 Control Room, borders Unit 2/3 Fire Zone 2.0 7.2, Computer UPS and Battery Rooms, elevation 534-0, borders Unit 2/3 Fire Zone 2.0.

8.4.7, Turbine Building Intermediate Level, elevation 534-0, primary Unit 1 Fire Zone for elevation 534-0, borders Unit 2/3 Fire Zones 2.0 and 8.2.6.A.

8.4.11, Turbine Deck Maintenance and Tool Storage Area, elevation 551-0, borders Unit 2 Fire Zones 7.0.A.1, 8.2.7, and 8.2.8.A.

2. SAFSTOR Dresden Unit 1 is in the process of being decommissioned. Decommissioning will proceed in a two-phase approach: placing Unit 1 in a safe storage condition (i.e.,

SAFSTOR) and delayed dismantlement. Unit 1 will be maintained in the SAFSTOR condition until Units 2 and 3 are ready for decommissioning. The principal schedule milestones and primary activities associated with the Unit 1 SAFSTOR plan are contained in the Post Shutdown Decommissioning Report (Reference 2).

6.2-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 6.3 References

1. Defueled Safety Analysis Report, Dresden Nuclear Power Station Unit 1, Commonwealth Edison Company, June 1998.
2. Dresden Nuclear Power Station Unit 1, Post-Shutdown Decommissioning Activities Report, May 1998.
3. DHP 0230-01, Rev. 3, Control of Hot Work.
4. DHP 0230-02, Rev. 3, Fire Protection for Transient Combustibles.
5. DHP 0220-01, Rev. 1, Use of Heat Generating Equipment and Heat Sources.
6. Safe Shutdown Analysis, Sections 2.2.15 and 4.15.1 (FPR, Volume 2) and Figures 3.3-8, 3.3-10 and 3.3-13 of the FHA (FPR, Volume 1).

6.3-1

DRESDEN 2&3 AMENDMENT 19 JUNE 2013 6.4 Unit 1 Fire Hazards Analysis The Defueled Safety Analysis Report (Reference 1) provides an overall summary description of the Dresden Fire Protection Program as it relates to Unit 1. Procedural controls (Reference 8) are in place to assure that all changes made on Unit 1 are assessed for their impact to the Updated FHA Report and for potential adverse fire impact to Unit 2/3 prior to implementation. The principal Unit 1 fire hazards as they relate to Unit 2/3 are discussed in the remainder of this section.

6.4.1 Plant Barriers The major barrier between Unit 1 and Unit 2 Turbine Building is a composite transite siding wall supported by structural steel, with selected portions of fire rated construction. A two-level fire area (TB-V), which contains the Unit 2/3 Auxiliary Electric Equipment Room, is adjacent to Unit

1. Appendix R fire barriers separate this fire area from both Unit 1 and the balance of Units 2/3.

The Unit 2/3 Control Room extends into a portion of the former Unit 1 Control Room (see Figure 3.3-8). This extension is separated from the remainder of the Unit 2 and Unit 1 areas by 3-hour rated walls, ceiling and floor. The steel supporting the floor of the Unit 1 Control Room is coated with UL approved material providing a 3-hour fire resistance rating.

Additional fire barriers are provided for selected Unit 2 fire zones that provide 3-hour separation from Unit 1 hazards (see figure 3.3-8).

A 2-hour fire barrier is located between columns 29 and 30 along the north wall between the Unit 1 Turbine Building and transformer TR-12.

6.4.2 Fixed Fire Hazards The fixed combustibles in Unit 1 primarily consist of electrical cable in trays, electrical cabinets and transformers. The unit also contains a diesel generator and several pumps from which fuel and lubricating oil have been drained. Certain areas in Unit 1 are being used for minor storage of ordinary combustibles and flammable/combustible liquids in safety cans and storage cabinets.

These storage areas on the 517 ft.-6 in. elevation are located east of the Unit 1 West Auxiliary Bay outside of the designated low combustible zone as discussed in Section 6.4.3.

A Computer Room (Unit 1 Fire Zone 4.1) in the West Auxiliary Bay is located near the Unit 2 separating wall and under a portion of the Control Room on the 517 ft.-6 in. elevation. The Computer Room is protected with a total flooding halon system. Battery Rooms on the 517 ft.-6 in. (Unit 1 Fire Zone 7.1) and the 524 ft. elevations (Fire Zone 7.2) are enclosed by non-combustible barriers and separated from Unit 2/3 by 3-hour rated fire walls/floor.

6.4-1

DRESDEN 2&3 AMENDMENT 21 JUNE 2017 6.4.3 Transient Combustibles Dresden Station procedures regulate transient combustibles located in the Unit 1 West Auxiliary Bay (Reference 5). The station maintains a 20 ft. zone as a low transient fire loading area on elevations 517-6 and 534-0 of the Unit 1 side of the Unit 1/Unit 2 separating wall. This is to reduce the chance of fire exposure to combustible cables in trays located within this zone and any fire exposure to combustible cables in trays located within this zone and any direct fire exposure Unit 2 at the separating direct wall. The only fixed combustibles within 20 ft. of the sheet metal separating wall on the 517 ft.-6 in. elevation of the Unit 1 West Auxiliary Bay are the combustible cables in trays (see Figures 6.4-4 through 6.4-7).

The primary ignition source posing a threat to the cables in the Unit 1 West Auxiliary Bay is from a floor based transient combustible exposure fire on elevation 517-6. A transient combustible fire would have to ignite the cable trays and spread at least 20 ft. before it would reach the Unit 2 separating wall and expose Unit 2. Fire propagates along horizontal cable trays at a rate of approximately 10-ft. per hour, based on actual fire test data of fires in horizontal cable trays. Therefore, a cable tray fire would take considerable time to reach the Unit 2 separating wall. The fire brigade should be able to respond within adequate time to fight a fire while it is still on the Unit 1 side. In addition, the ceiling based automatic sprinkler system that is provided on this level would serve to control any fire involving the cable trays until the fire brigade responds and ensures that the fire has been extinguished. Also, the structural steel in this area, which supports the floor of the control room, is protected with 3-hour rated fire proofing material that provides additional assurance that a fire in this area would not affect Unit 2/3 operations.

6.4.4 Fire Protection Features Manual fire hose stations and portable fire extinguishers are being maintained in service throughout the Unit 1 Turbine Building. Six of the hose stations in the Unit 1 Turbine Building are listed in the Technical Requirements Manual (TRM) to assure their availability for manual fire fighting activities in the West Auxiliary Bay. Fire detection is provided in the Unit 2/3 Control Room and in significant Unit 2 fire zones directly adjacent to Unit 1. The Unit 1 West Auxiliary Bay area underneath the Control Room (elevation 517-0) is provided an automatic fire suppression system to protect the electrical cable in trays located there that are within at least 20 ft. of the Unit 2 Turbine Building separating wall. This sprinkler system will assist fire-fighting activities in controlling fire propagation along cables in trays. These cables are the only significant fixed combustibles that are located in the 20 ft. zone. The fire suppression system, in combination with the fire brigade response, should serve to provide adequate assurance that a fire originating on the Unit 1 side will not propagate to the Unit 2 side or threaten the Control Room. In addition, partial smoke detection is installed for the portion of the Unit 1 Turbine Deck Maintenance and Tool Storage Area used for storage (elevation 551-0) and serves to provide early warning and summon the fire brigade should any fire develop at this location.

Also, the fire detection system in the Control Room serves to provide early warning of any fire that may occur within the area.

6.4-2

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 6.4.5 Control of Ignition Sources Hot work in Unit 1 is controlled through approved station procedures. Smoking at Dresden Station is prohibited except in designated outside smoking areas. The Unit 1 West Auxiliary Bay is not such a designated area.

6.4.6 Fire Pre-Plans Fire pre-plans developed for the Unit 1 West Auxiliary Bay serve to assist the fire brigade in effectively training and planning to suppress a fire in Unit 1.

6.4-3

AMENDMENT 13 DRESDEN 2 &3 Figure 6.4-1 Deleted

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DRESDEN STATION Units 2 &3 FIGURE 6.4-6 TURBINE BUILDING EQUIPMENT LOCATION PLAN MEZZANINE FLOOR, UNIT 1

DRESDEN STATION Units 2 & 3 FIGURE 6.4-7 TURBINE BUILDING EQUIP MENT LOCATION PLAN GROUND FLOOR, UNIT 1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 6.5 Impact of a Unit 1 Fire on Unit 2/3 Safe Shutdown In a worst case scenario, a fire in Unit 1 should not prevent safe shutdown of Units 2 and 3 based on the Safe Shutdown Analysis for Dresden 2&3, (FPR Volume 2).

The Unit 1 West Auxiliary Bay borders Unit 2 as follows: (See Figure 6.5.1).

FIRE DESCRIPTION FIRE AREA/ SHUTDOWN SAFE ZONE EQUIVALENT PATH SHUTDOWN AREA/ZONE ANALYSIS GROUP SECTION 8.2.5.A Turbine Building Ground TB-I B1 4.8 Floor -517-6 8.2.6.A Turbine Building Elevation TB-I B1 4.8 534 and 538 Mezzanine Floor Eastern Area 8.2.7 Turbine Building Elevation TB-I B1 4.8 549 Mezzanine Floor 7.0.A Unit 2 Battery Room Area TB-I B1 4.8 6.2 Aux. Electric Equip. Room TB-V A2/B2 4.12 2.0 Control Room including the TB-V A2/B2 4.12 Unit 1 Portion of the Control Room 8.2.8.A Unit 2 Main Turbine Floor TB-IV All Paths 4.11 Available Fire Zones 8.2.5.A, 8.2.6.A, 8.2.7 and 7.0.A are all combined in the same Equivalent Fire Area/Zone Group (TB-I) which uses cable and equipment to shutdown that is associated with the B1 safe shutdown path located outside of these fire zones.

Fire Zone 8.2.8.A is part of Fire Area/Zone Group TV-IV. There is no safe shutdown equipment located in 8.2.8.A and all safe shutdown paths are available.

Fire Zones 6.2 and 2.0 (Auxiliary Electric Equipment Room and Control Room) are combined into one equivalent Fire Area (TB-V) which uses equipment and cabling associated with the A2/B2 path for shutdown. TB-V is separated from TB-I and the Unit 1 West Auxiliary Bay by Appendix R barriers.

The safe shutdown analysis was performed to ensure that all cable and equipment associated with a selected shutdown path is independent of the Equivalent Fire Area/Zone Group in accordance with Appendix R separation criteria. From a safe shutdown standpoint, a fire that originates in Unit 1 and spreads through the West Auxiliary Bay to Unit 2 is no different than a fire originating in the TB-I or TB-IV Zone Groups. Shutdown path B1 will be available for 6.5-1

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 shutdown.

Fire Area TB-V which includes the Unit 2/3 Control Room is separated by an Appendix R fire enclosure. A fire that spreads through the Unit 1 West Auxiliary Bay will be prevented from spreading into Fire Area TB-V by Appendix R fire barriers that separate TB-V from the adjacent TB-I and TB-V Fire Zone Groups and the Unit 1 West Auxiliary Bay.

The Unit 2/3 Control Room is provided with early warning smoke detection and is manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. In a worst case scenario, if a fire occurred in the Control Room, the plant can achieve shutdown using the A2/B2 Shutdown path, which is independent of the Control Room.

6.5-2

AMENDMENT 13 8.2.8 Turbine Opero.tl ng Floor Unit 1 Turbine 561'6' - 7.0.A Opero.tl ng Bo.ttery Floor 0 549' 7.0.B 8.2.6.D o.nd E 8.2.6.C B.2.6.A o.nd B 2.0 6.1 C.R.

534'

@ Unit 1 Vest 8.2.S.A o.nd B 6.2 AuxlUo.ry 8.2.S.D o.nd E 8.2.5.C AEER Bo.y 9.0.B 517'6' -

Unit 3 Co.ble Tunnel 8.2.4 502'6' -

1. Heo.vy lines Identify fire o.reo. boundo. rles
2. Alpho.nu Merlc code In circle Identifi es hot shutdow n po.th DRESDEN STAT ION UNITS 2 & 3 FIGURE 6.5-1 TURBINE BUILDING APPENDIX R FIRE AREAS AND SAFE SHUTDO\JN PATHS, UNITS 2 @. 3

DRESDEN 2&3 AMENDMENT 13 JUNE 2001 6.6 Overall Assessment The fire protection program measures as applied to Unit 1 serves to reasonably prevent from occurring, rapidly detect, control and extinguish fires that could result in an unacceptable release of radioactive materials thus minimizing the resulting risk to the public, environment and plant personnel. In addition, the program serves to reasonably prevent the possibility of a fire occurring in Unit 1 from posing an adverse safe shutdown risk to Units 2 and 3. In the remote chance that a fire originating within Unit 1 propagates to an adjacent Unit 2 Fire Zone, safe shutdown of Units 2 and 3 can still be achieved.

6.6-1

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