ML19170A311: Difference between revisions

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least one train can be repaired or  
least one train can be repaired or  


made operable within 72 hours using  
made operable within [[estimated NRC review hours::72 hours]] using  


onsite capability.
onsite capability.
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capable of providing for a period  
capable of providing for a period  


of 2 hours the maximum expected  
of [[estimated NRC review hours::2 hours]] the maximum expected  


water demands as determined by the  
water demands as determined by the  
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repaired within 72  
repaired within 72  


hours.achieved within 72 hours, for each fire area in the plant.2.Except as provided for Paragraph G.3 of this  
hours.achieved within [[estimated NRC review hours::72 hours]], for each fire area in the plant.2.Except as provided for Paragraph G.3 of this  


section, where cables or  
section, where cables or  
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over more than one shift, the permit shall be valid  
over more than one shift, the permit shall be valid  


for not more than 24 hours  
for not more than [[estimated NRC review hours::24 hours]]


when the plant is operating  
when the plant is operating  
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and maintain hot standby 7 conditions for a PWR (hot  
and maintain hot standby 7 conditions for a PWR (hot  


shutdown 7 for a BWR) and achieve cold shutdown 7 conditions within 72 hours  
shutdown 7 for a BWR) and achieve cold shutdown 7 conditions within [[estimated NRC review hours::72 hours]]


and maintain cold shutdown  
and maintain cold shutdown  
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offsite power is not  
offsite power is not  


available for 72 hours.   
available for [[estimated NRC review hours::72 hours]].   


Procedures shall be in  
Procedures shall be in  
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and cold shutdown achieved  
and cold shutdown achieved  


within 72 hours. Materials  
within [[estimated NRC review hours::72 hours]]. Materials  


for such repairs shall be  
for such repairs shall be  
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provided. Equipment and  
provided. Equipment and  


systems used after 72 hours  
systems used after [[estimated NRC review hours::72 hours]]


may be powered by offsite  
may be powered by offsite  
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The residual heat removal system is not required for hot shutdown of the plant. Station repair procedures have been written to ensure that the RHR system will be repaired and  
The residual heat removal system is not required for hot shutdown of the plant. Station repair procedures have been written to ensure that the RHR system will be repaired and  


available to achieve cold shutdown conditions within 72 hours after a fire.
available to achieve cold shutdown conditions within [[estimated NRC review hours::72 hours]] after a fire.
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012A5.8 -16 In summary, the large distance separating the two trains of RHR pumps and cubicle coolers, the 2 hour-rated fire barrier, fire detection and manual fire suppression provided, establish a level of fire protection commensurate with the guidelinesof Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012A5.8 -16 In summary, the large distance separating the two trains of RHR pumps and cubicle coolers, the 2 hour-rated fire barrier, fire detection and manual fire suppression provided, establish a level of fire protection commensurate with the guidelinesof Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012A5.8 -17A5.8.10Deviation No: 1A.3 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the Unit 1 Auxiliary Electric Equipment  
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012A5.8 -17A5.8.10Deviation No: 1A.3 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the Unit 1 Auxiliary Electric Equipment  
Line 5,968: Line 5,968:
The residual heat removal system is not required for hot shutdown of the plant. Station repair procedures been written to ensure that the RHR system will be repaired and  
The residual heat removal system is not required for hot shutdown of the plant. Station repair procedures been written to ensure that the RHR system will be repaired and  


available to achieve cold shutdown conditions within 72 hours after a fire.
available to achieve cold shutdown conditions within [[estimated NRC review hours::72 hours]] after a fire.
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012A5.8 -37 In summary, the large distance separating the two trains of RHR pumps and cubicle coolers, the 2 hour-rated fire barrier, fire detection and manual fire suppression provided, establish a level of fire protection commensurate with the guidelines of Section C.5.B(2),
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012A5.8 -37 In summary, the large distance separating the two trains of RHR pumps and cubicle coolers, the 2 hour-rated fire barrier, fire detection and manual fire suppression provided, establish a level of fire protection commensurate with the guidelines of Section C.5.B(2),
paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
Line 6,718: Line 6,718:


Justification for Deviation(s)
Justification for Deviation(s)
Due to the presence of the containment spray pump rooms between the RHR pumprooms, the separation between the two trains of RHR components is greater than75 feet. The 3 walls between the two trains of RHR components are all of 3-hour construction. Two of the walls contain unsealed penetrations orpenetrations with non-fire-rated seals. The wall at column-row W between thetwo containment spray pump rooms is upgraded to a 2-hour-rated fire barrier. The RHR pump rooms and the containment spray pump rooms have low combustibleloadings. All of these rooms are provided with automatic fire detection. Fire Zone 11.2B-1 contains a manual hose station having hose of adequatelength to reach Fire Zones 11.2A-1, 11.2C-1, and 11.2D-1. Also, portableextinguishers are provided in adjacent Fire Zone 11.2-0 (auxiliary buildinggeneral area).The residual heat removal system is not required for hot shutdown of theplant. Station repair procedures have been written to ensure that theRHR system will be repaired and available to achieve cold shutdown conditionswithin 72 hours after a fire.
Due to the presence of the containment spray pump rooms between the RHR pumprooms, the separation between the two trains of RHR components is greater than75 feet. The 3 walls between the two trains of RHR components are all of 3-hour construction. Two of the walls contain unsealed penetrations orpenetrations with non-fire-rated seals. The wall at column-row W between thetwo containment spray pump rooms is upgraded to a 2-hour-rated fire barrier. The RHR pump rooms and the containment spray pump rooms have low combustibleloadings. All of these rooms are provided with automatic fire detection. Fire Zone 11.2B-1 contains a manual hose station having hose of adequatelength to reach Fire Zones 11.2A-1, 11.2C-1, and 11.2D-1. Also, portableextinguishers are provided in adjacent Fire Zone 11.2-0 (auxiliary buildinggeneral area).The residual heat removal system is not required for hot shutdown of theplant. Station repair procedures have been written to ensure that theRHR system will be repaired and available to achieve cold shutdown conditionswithin [[estimated NRC review hours::72 hours]] after a fire.
AMENDMENT 25                                                                                                                DECEMBER 2012A5.8 -10In summary, the large distance separating the two trains of RHR pumps andcubicle coolers, the 2 hour-rated fire barrier, fire detection and manual firesuppression provided, establish a level of fire protection commensurate withthe guidelinesof Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
AMENDMENT 25                                                                                                                DECEMBER 2012A5.8 -10In summary, the large distance separating the two trains of RHR pumps andcubicle coolers, the 2 hour-rated fire barrier, fire detection and manual firesuppression provided, establish a level of fire protection commensurate withthe guidelinesof Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
AMENDMENT 25                                                                                                                DECEMBER 2012A5.8 -11A5.8.5Deviation No.:  1A.3 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the Unit 1 main control room), and for which alternate or dedicated shutdown capability is provided.
AMENDMENT 25                                                                                                                DECEMBER 2012A5.8 -11A5.8.5Deviation No.:  1A.3 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the Unit 1 main control room), and for which alternate or dedicated shutdown capability is provided.
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Description of Equipment/Cables InvolvedThe redundant cables and equipment required for safe shutdown and located inFire Zone 11.4-0 are listed in Table 2.4-4.
Description of Equipment/Cables InvolvedThe redundant cables and equipment required for safe shutdown and located inFire Zone 11.4-0 are listed in Table 2.4-4.
Description of Deviation(s)The redundant safe shutdown equipment and/or cables in Fire Zone 11.4-0 arelocated throughout this area. This area lacks fixed suppression and containscombustible material and has separation distances which are less than 20 feetall of which are not in accordance with the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
Description of Deviation(s)The redundant safe shutdown equipment and/or cables in Fire Zone 11.4-0 arelocated throughout this area. This area lacks fixed suppression and containscombustible material and has separation distances which are less than 20 feetall of which are not in accordance with the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
Justification for Deviation(s)The applicant originally committed to install a 3-hour fire-rated barrieraround Division 11 cable trays, risers and conduits in this area as follows: The risers near 13-15/Q will be wrapped from floor to ceiling. The conduitand tray with cable 1SX001 will be wrapped from Q/13 to L/13. The risers andtrays from L/11 to L/13 will be completely wrapped. In addition, thecentrifugal charging pump cubicle cooler fan fed from MCC 131X3 will be movedto another MCC completely independent of this zone. With these modificationscomplete, the loss of both MCCs 131X3 and 132X3 will be acceptable since theessential service water cubicle coolers will function properly with only twoout of four fans in service. This room is a large open area with a lowcombustible loading. Area-wide detection is provided, and manual suppressioncapability is also present. Subsequent to the above modifications, the component cooling pump 1A powercable and the essential service water pump 1A power cable are rerouted out ofFire Zone 11.4-0, where redundant cables are present. An evaluation has shownthat the charging pumps and the essential service water pumps can performtheir design function for the 72 hours needed to take the plant to coldshutdown without the support of the room cubicle coolers. In addition, the remaining safe shutdown cables in this fire zone have been determined not torequire protection based on an evaluation which demonstrated that alternateequipment and cabling would be available or local manual actions could beperformed as described in station procedures in the event of a fire in thiszone. Therefore, the 3-hour fire-rated barrier described previously asinstalled around the AMENDMENT 25                                                                                                                DECEMBER 2012A5.8 -15Division 11 trays, risers, and conduits on Elevation 383feet 0 inch is no longer required and will not be replaced.
Justification for Deviation(s)The applicant originally committed to install a 3-hour fire-rated barrieraround Division 11 cable trays, risers and conduits in this area as follows: The risers near 13-15/Q will be wrapped from floor to ceiling. The conduitand tray with cable 1SX001 will be wrapped from Q/13 to L/13. The risers andtrays from L/11 to L/13 will be completely wrapped. In addition, thecentrifugal charging pump cubicle cooler fan fed from MCC 131X3 will be movedto another MCC completely independent of this zone. With these modificationscomplete, the loss of both MCCs 131X3 and 132X3 will be acceptable since theessential service water cubicle coolers will function properly with only twoout of four fans in service. This room is a large open area with a lowcombustible loading. Area-wide detection is provided, and manual suppressioncapability is also present. Subsequent to the above modifications, the component cooling pump 1A powercable and the essential service water pump 1A power cable are rerouted out ofFire Zone 11.4-0, where redundant cables are present. An evaluation has shownthat the charging pumps and the essential service water pumps can performtheir design function for the [[estimated NRC review hours::72 hours]] needed to take the plant to coldshutdown without the support of the room cubicle coolers. In addition, the remaining safe shutdown cables in this fire zone have been determined not torequire protection based on an evaluation which demonstrated that alternateequipment and cabling would be available or local manual actions could beperformed as described in station procedures in the event of a fire in thiszone. Therefore, the 3-hour fire-rated barrier described previously asinstalled around the AMENDMENT 25                                                                                                                DECEMBER 2012A5.8 -15Division 11 trays, risers, and conduits on Elevation 383feet 0 inch is no longer required and will not be replaced.
In summary, the low combustible loading, automatic fire detection and manualsuppression capabilities, controlled access, and local operation of safeshutdown equipment provide a level of fire protection equivalent to thatspecified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
In summary, the low combustible loading, automatic fire detection and manualsuppression capabilities, controlled access, and local operation of safeshutdown equipment provide a level of fire protection equivalent to thatspecified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
AMENDMENT 25                                                                                                                DECEMBER 2012A5.8 -16A5.8.9Deviation No: 1A.7 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (general area, Auxiliary Building
AMENDMENT 25                                                                                                                DECEMBER 2012A5.8 -16A5.8.9Deviation No: 1A.7 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (general area, Auxiliary Building
Line 6,770: Line 6,770:
Description of Equipment/Cables InvolvedThe redundant cables and equipment required for safe shutdown and located inFire Zone 11.5-0 are listed in Table 2.4-4.
Description of Equipment/Cables InvolvedThe redundant cables and equipment required for safe shutdown and located inFire Zone 11.5-0 are listed in Table 2.4-4.
Description of Deviation(s)The redundant safe shutdown equipment and/or cables in Fire Zone 11.5-0 arelocated throughout this area. This area lacks fixed suppression and containscombustible material and has separation distances which are less than 20 feetall of which are not in accordance with the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
Description of Deviation(s)The redundant safe shutdown equipment and/or cables in Fire Zone 11.5-0 arelocated throughout this area. This area lacks fixed suppression and containscombustible material and has separation distances which are less than 20 feetall of which are not in accordance with the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
Justification for Deviation(s)the applicant originally committed to provide a 3-hour fire-ratedbarrier around Division 11 cable trays containing redundant safe shutdowncables in three locations. The risers at 13-15/Q, the trays and risers alongRow L between 11 and 12, and the trays and risers by 11/P-Q will all beprotected.The component cooling pump 1A power cable and the essential service water pump1A power cable are rerouted out of Fire Zone 11.5-0 where redundant cables arepresent. An evaluation also shows that the charging pumps and the essentialservice water pumps can perform their design function for the 72 hours neededto take the plant to cold shutdown without the support of the room cubiclecoolers. In addition, the remaining safe shutdown cables in this fire zonehave been determined not to require protection based on an evaluation whichdemonstrates that alternate equipment and cabling would be available for afire in this fire zone or that local manual actions could be performed as described in the station procedures. Therefore, the 3-hour fire-rated barrierinstalled around the Division 11 trays and risers on Elevation 401 feet 0 inchis no longer required and will not be replaced.
Justification for Deviation(s)the applicant originally committed to provide a 3-hour fire-ratedbarrier around Division 11 cable trays containing redundant safe shutdowncables in three locations. The risers at 13-15/Q, the trays and risers alongRow L between 11 and 12, and the trays and risers by 11/P-Q will all beprotected.The component cooling pump 1A power cable and the essential service water pump1A power cable are rerouted out of Fire Zone 11.5-0 where redundant cables arepresent. An evaluation also shows that the charging pumps and the essentialservice water pumps can perform their design function for the [[estimated NRC review hours::72 hours]] neededto take the plant to cold shutdown without the support of the room cubiclecoolers. In addition, the remaining safe shutdown cables in this fire zonehave been determined not to require protection based on an evaluation whichdemonstrates that alternate equipment and cabling would be available for afire in this fire zone or that local manual actions could be performed as described in the station procedures. Therefore, the 3-hour fire-rated barrierinstalled around the Division 11 trays and risers on Elevation 401 feet 0 inchis no longer required and will not be replaced.
In summary, the low combustible loading, automatic fire detection and manualsuppression capabilities, controlled access, and local operation of safeshutdown equipment provide a level of fire protection equivalent to thatspecified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
In summary, the low combustible loading, automatic fire detection and manualsuppression capabilities, controlled access, and local operation of safeshutdown equipment provide a level of fire protection equivalent to thatspecified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
AMENDMENT 25                                                                                                                DECEMBER 2012A5.8 -19A5.8.11Deviation No: 1A.9 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (general area, Auxiliary Building  
AMENDMENT 25                                                                                                                DECEMBER 2012A5.8 -19A5.8.11Deviation No: 1A.9 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (general area, Auxiliary Building  
Line 7,368: Line 7,368:


Justification for Deviation(s)
Justification for Deviation(s)
Due to the presence of the containment spray pump rooms between the RHR pumprooms, the separation between the two trains of RHR components is greater than75 feet. The 3 walls between the two trains of RHR components are all of 3-hour construction. Two of the walls contain unsealed penetrations orpenetrations with non-fire-rated seals. The wall at column-row W between thetwo containment spray pump rooms is upgraded to all 2-hour-rated fire barrier. The RHR pump rooms and the containment spray pump rooms have low combustibleloadings. All of these rooms are provided with automatic fire detection. Fire Zone 11.2B-2 contains a manual hose station having hose of adequatelength to reach Fire Zones 11.2A-2, 11.2C-2, and 11.2D-2. Also, portableextinguishers are provided in adjacent Fire Zone 11.2-0 (auxiliary buildinggeneral area).The residual heat removal system is not required for hot shutdown of theplant. Station repair procedures been written to ensure that theRHR system will be repaired and available to achieve cold shutdown conditionswithin 72 hours after a fire.
Due to the presence of the containment spray pump rooms between the RHR pumprooms, the separation between the two trains of RHR components is greater than75 feet. The 3 walls between the two trains of RHR components are all of 3-hour construction. Two of the walls contain unsealed penetrations orpenetrations with non-fire-rated seals. The wall at column-row W between thetwo containment spray pump rooms is upgraded to all 2-hour-rated fire barrier. The RHR pump rooms and the containment spray pump rooms have low combustibleloadings. All of these rooms are provided with automatic fire detection. Fire Zone 11.2B-2 contains a manual hose station having hose of adequatelength to reach Fire Zones 11.2A-2, 11.2C-2, and 11.2D-2. Also, portableextinguishers are provided in adjacent Fire Zone 11.2-0 (auxiliary buildinggeneral area).The residual heat removal system is not required for hot shutdown of theplant. Station repair procedures been written to ensure that theRHR system will be repaired and available to achieve cold shutdown conditionswithin [[estimated NRC review hours::72 hours]] after a fire.
AMENDMENT 25                                                                                                                DECEMBER 2012A5.8 -38In summary, the large distance separating the two trains of RHR pumps andcubicle coolers, the 2 hour-rated fire barrier, fire detection and manual firesuppression provided, establish a level of fire protection commensurate withthe guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
AMENDMENT 25                                                                                                                DECEMBER 2012A5.8 -38In summary, the large distance separating the two trains of RHR pumps andcubicle coolers, the 2 hour-rated fire barrier, fire detection and manual firesuppression provided, establish a level of fire protection commensurate withthe guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
AMENDMENT 25                                                                                                                DECEMBER 2012A5.8 -39A5.8.16Deviation No: 2A.3This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the Unit 1 main control room), and  
AMENDMENT 25                                                                                                                DECEMBER 2012A5.8 -39A5.8.16Deviation No: 2A.3This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the Unit 1 main control room), and  

Revision as of 01:40, 16 August 2019

Redacted Braidwood Station, Units 1 & 2, and Byron Station, Units 1 & 2, Amendment 28 to Fire Protection Report, Appendix 5.1 (Public Version Pages 1-76 and 129-287)
ML19170A311
Person / Time
Site: Byron, Braidwood  Constellation icon.png
Issue date: 06/19/2019
From: Mahesh Chawla
Plant Licensing Branch III
To:
Wiebe J
Shared Package
ML18355A456 List:
References
Download: ML19170A311 (235)
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Text

B/B AMENDMENT 19 DECEMBER 2000

APPENDIX 5.1

RESUMES OF FIRE PROTECTION ENGINEERS AND CONSULTANTS

ON THE BYRON/BRAIDWOOD PROJECTS:

FIRE PROTECTION ENGINEERS

Carlos Javier Diaz

Thomas G. Hausheer

Eugene W. O'Donnell

CONSULTANTS

Ronald C. Adcock

James B. Biggins

Stanley J. Chingo

Noel F. Malicki John A. Robinson

Robert J. Smith, Jr.

B/B AMENDMENT 13 DECEMBER 1990 CARLOS JAVIER DIAZ

EDUCATION 9/81 to 12/83 Illinois Institute of Technology , Chicago, IL Degree/Major: Bachelor of Science in Fire Protection and Safety Engineering

9/79 to 5/81 Triton College , River Grove, IL Degree/Major: Associate of Science in Engineering

EXPERIENCE

6/2/86 Commonwealth Edison Company , Chicago, IL to Present Nuclear Engineering Department

Fire Protection Engineer - Responsibilities include monitoring the fire protection programs and activities at

Braidwood, Byron and Zion Nuclear Stations to ensure

compliance with NRC requirements, performing design reviews

and working in the development and application of loss

prevention and fire protection engineering applicable to the

utility industry.

4/16/84 Commonwealth Edison Company, Byron Nuclear Station , to Byron, IL

5/30/86 Station Fire Protection Engineer - Responsibilities include the review of the Byron Station Branch Technical Position and applicable NFPA codes in order to ensure compliance of the station fire protection systems and programs. Required to interact directly with the Nuclear Regulatory Commission and offsite consultants during the licensing, startup and operational phases of Byron Units 1 and 2. Other responsibilities include reviewing and approving fire protection preoperational, acceptance and surveillance tests and modifications.

Summer U.S. Department of Energy/Argonne National Laboratory , of Argonne, IL

1983 Fire Prevention Engineer Trainee - Assisted in the testing of various smoke and heat detection systems throughout the site. Also participated in the inspection of site buildings to identify possible fire hazards and/or safety deficiencies. Involved in the development of preliminary design work for numerous automatic sprinkler systems.

PROFESSIONAL Member, National Fire Protection Association AFFILIATIONS Member, Society of Fire Protection Engineers

A5.1-1 B/B AMENDMENT 13 DECEMBER 1990

EUGENE WILLIAM O'DONNELL

EDUCATION Illinois Institute of Technology , Chicago, IL Degree/Major: Bachelor of Science in Fire Protection and Safety Engineering

9/81 - 5/82 Richard J. Daley College , Chicago, IL Major: Engineering

9/78 - 6/81 University of Illinois - Chicago , Chicago, IL Major: Engineering

EXPERIENCE

6/17/85 Commonwealth Edison Company, Braidwood Nuclear to Station Braidwood, IL Present Fire Protection Engineer - involved in development and implementation of the fire protection program. Write and

review fire protection related procedures. Review applicable

codes and regulations, including 10 CFR 50 Appendix R and

identify any and all items of noncompliance. Witness fire

brigade drills and assess effectiveness. Develop station pre-

fire plans. Analyze and make recommendations for fire

protection system impairments.

10/84 Kemper Group , Chicago, IL to 6/85 Technical Representative - responsible for HPR type inspections of various industrial and commercial facilities.

Perform system testing to ensure compliance with applicable

codes and insurance standards. Make recommendations as

necessary.

5/83 Federal Signal Corporation , University Park, IL to 10/84 Systems Engineer - responsible for design of industrial, commercial, and municipal fire protection detection and alarm systems.

A5.1-2 B/B AMENDMENT 13 DECEMBER 1990

PROFESSIONAL Associate member, Chicago Chapter - Society AFFILIATIONS of Fire Protection Engineers

Member, National Fire Protection Association

Member, National Fire Protection Association, Illiana chapter, Industrial Section

SEMINARS Professional Loss Control:

Fire Protection for Nuclear Power Plants (Oct. 1985)

Fire Brigade Leadership (June 1985)

A5.1-3 B/B AMENDMENT 13 DECEMBER 1990 THOMAS G. HAUSHEER

EDUCATION 1979 Illinois Institute of Technology , Chicago, IL Degree/Major: B.S., Fire Protection and Safety Engineering

1970 Illinois Institute of Technology , Chicago, IL Degree/Major: B.S., Electrical Engineering

EXPERIENCE

12/79 Commonwealth Edison Company , Chicago, IL to Nuclear Engineering Department Present Fire Protection Engineer - responsible for compliance with NRC and insurance company requirements, annual/triennial fire

protection audits, and other associated fire protection

activities at nuclear stations.

8/78 to Attended Classes at IIT, received BS FPSE in December 1979.

12/79 10/74 Commonwealth Edison Company , Chicago, IL to General Engineering/Principal Engineering, Technical Staff 8/78 Crawford Station - responsible for conducting tests on various pieces of equipment at a fossil-fueled generating station.

1/71 Commonwealth Edison Company , Chicago, IL to Engineering Department, Chicago North Division

10/74 Engineering/General Engineer - designed 4-KV and 12-KV distribution facilities.

6/70 Commonwealth Edison Company , Chicago, IL to Engineer - Industrial Relations Training Program

1/71

PROFESSIONAL AFFILIATIONS

Member, Chicago Chapter - Society of Fire Protection Engineers

Member, National Fire Protection Association, Industrial and Electrical Sections

Member, National Fire Protection Association, Illiana Chapter, Industrial Section

Member, Institute of Electrical and Electronics Engineers

Member, Society of Fire Protection Engineers

A5.1-4 B/B AMENDMENT 13 DECEMBER 1990 M&M Protection Consultants

PROFESSIONAL PROFILE

Ronald C. Adcock, P. E. - Fire Protection Consultant M&M Consultants A Risk Management Resource of Marsh & McLennan, Inc.

PROFESSIONAL EXPERIENCE

Mr. Adcock is a member of the Gas and Electric Utility Unit-Midwest in the Chicago Office of M&M Protection Consultants. The Gas and Electric

Utility Unit-Midwest provides fire protection consultation services to

numerous utility companies which operate either fossil or nuclear fueled

electric generating stations.

Mr. Adcock has expertise in both construction and operating station fire hazards for either fossil or nuclear generating stations. His experience includes conceptual design, fire hazards analysis preparation, review and

revision, design document review, testing installed fire suppression

systems and design modifications to installed systems. He has performed

loss prevention inspections and design reviews for Nuclear Mutual Limited (NML). NML is a Bermuda based mutual insurance company providing

property insurance for nuclear generating stations. He has a working

knowledge of NFPA codes and also the U. S. Nuclear Regulatory Commission

CMEB 9.5-1 "Guidelines for Fire Protection for Nuclear Power Plants."

Mr. Adcock's other experience includes two years with Rolf Jensen and Associates, Inc. where he provided fire protection consultation services

to architects, developers, building owners and government agencies on a

variety of projects including hospitals, libraries, military training

facilities, office buildings and highway tunnel fire protection.

EDUCATIONAL EXPERIENCE

Mr. Adcock graduated with honors from Illinois Institute of Technology in 1979 with a B. S. in Fire Protection Engineering.

PROFESSIONAL ORGANIZATIONS

Mr. Adcock is a Registered Professional Engineer in the State of Illinois. He meets the qualifications of Member of the Society of Fire

Protection Engineers and is also a member of the National Fire Protection

Association.

January 1986

A5.1-5 B/B AMENDMENT 13 DECEMBER 1990

M&M Protection Consultants

PROFESSIONAL PROFILE

James B. Biggins - Fire Protection Associate M&M Protection Consultants A Risk Management Resource of Marsh & McLennan, Inc.

PROFESSIONAL EXPERIENCE

Mr. Biggins joined M&M Protection Consultants in April 1985 and is a member of

the Gas and Electric Utility Unit-Midwest in the Chicago Office of M&M

Protection Consultants. This unit provides fire protection and boiler and

machinery loss prevention services to major utilities. The services provided

to those utilities include site surveys and fire protection consultation for

new construction for both fossil and nuclear fueled generating stations. His

responsibilities thus far include design review for various types of fire protection systems, loss prevention inspections and on-site reviews of fire protection systems for compliance with the applicable standards.

From 1980 to 1984, Mr. Biggins was employed by Millers National Insurance

Company, under a cooperative education program. After completion of the

company's management training program, he was assigned as a Loss Prevention

Representative in the Chicago area. His responsibilities at this time included

field inspections of risks, implementation of loss prevention activities and

generation of related reports.

EDUCATIONAL EXPERIENCE

Mr. Biggins attended the Illinois Institute of Technology from 1979 to 1984

under a cooperative education program. In 1984 he received a Bachelor of

Science Degree in Fire Protection and Safety Engineering.

PROFESSIONAL ASSOCIATION

Mr. Biggins is a registered Professional Engineer in Training in the State of

Illinois. He was elected to the grade of Associate Member by the Society of

Fire Protection Engineers in October 1985.

January 1986

A5.1-6 B/B AMENDMENT 13 DECEMBER 1990

M&M Protection Consultants

PROFESSIONAL PROFILE

Stanley J. Chingo - Fire Protection Consultant M&M Protection Consultants A Risk Management Resource of Marsh & McLennan, Inc.

PROFESSIONAL EXPERIENCE

Mr. Chingo is a Fire Protection Consultant in the Gas and Electric Utility

Unit-Midwest of M&M Protection Consultants (M&MPC) that services the electric

and gas utility industries. He conducts loss prevention surveys, evaluates

property and business interruption loss exposures and prepares engineering

solutions to potential hazards. Foremost, he advises utility management in the

development and implementation of loss control programs.

Since September 1984, M&MPC has been performing an evaluation of the fire protection program at the Braidwood Nuclear Station with Mr. Chingo supervising

the project. He is responsible for managing the overall review in accordance

with NRC requirements, NFPA codes, technical specifications, and the Fire

Hazard Analysis. Mr. Chingo was also part of the M&MPC team that performed a

similar review of Commonwealth Edison Company's Byron Station in 1984. Mr.

Chingo has also participated in annual and triennial fire protection audits at

several nuclear power plants.

Mr. Chingo is a Nuclear Generating Station Consultant to Nuclear Mutual Limited (NML) and Nuclear Electric Insurance Limited (NEIL). His responsibilities

include design reviews, plant inspections and consultation on hazard control.

He also assists the NML Loss Prevention Supervisor in developing loss

prevention standards, reviewing reports, and conducting special studies on

property loss prevention matters.

Mr. Chingo has given formal presentations and publications entitled:

"Fire Protection for Electrical Cables," Illiana Chapter of NFPA's Industrial

Section (March 1982).

"Coal Characteristics - A Fire Protection Analyses," Coal Technology '82

Conference, Houston, Texas (December 1982).

IEEE Standard 690 - 1984, "Standard for the Design and Installation of Cable

Systems for Class 1E Circuits in Nuclear Power Generating Stations."

A5.1-7 B/B AMENDMENT 13 DECEMBER 1990

M&M Protection Consultants

Professional Profile

Stanley J. Chingo

Page 2

Prior to joining M&MPC in August 1980, Mr. Chingo was previously employed from

April 1977 to August 1980 by Industrial Risk Insurers as a Fire Protection

Engineer. In March 1979 he was promoted to District Supervising Engineer and

was responsible for managing field engineers, conducting underwriting account

reviews, and coordinating loss investigation and adjustment. His overall

administrative responsibility for loss prevention included a wide variety of

industry such as steel mills, chemical manufacturing plants, and hospital

facilities.

EDUCATIONAL EXPERIENCE

Mr. Chingo is a 1976 graduate from the University of Michigan with a Bachelor

of Science Degree from the College of Engineering. He has continued education

in the Insurance School of Chicago enrolling in risk management courses. He

has completed in-house programs by Industrial Risk Insurers that included the

Fire Protection Lab course (1978) and the American Management Association

course in Supervisory Management (1979).

PROFESSIONAL ASSOCIATIONS

Mr. Chingo, a member of the National Fire Protection Association, has attained

the grade of Member in the Society of Fire Protection Engineers.

He is also a member of several Institute of Electrical and Electronics

Engineers (IEEE) Standard Writing Committees.

January 1986

A5.1-8 B/B AMENDMENT 13 DECEMBER 1990

M&M Protection Consultants

PROFESSIONAL PROFILE

Noel F. Malicki - Fire Protection Consultant M&M Protection Consultants A Risk Management Resource of Marsh & McLennan, Inc.

PROFESSIONAL EXPERIENCE

Mr. Malicki is a Fire Protection Consultant in the Gas and Electric Utility

Unit-Midwest. This unit specializes in providing loss prevention services for

fire protection and boiler and machinery activities. These services are

provided to the nuclear and fossil fuel fired generating utilities and natural

gas utilities. The responsibilities of this position are to coordinate and

supervise loss prevention functions such as inspections, hazard analysis, design reviews, and other loss prevention activities for the utility industry.

Mr. Malicki is a qualified Inspector-Contractor for the Nuclear Mutual Limited.

Mr. Malicki joined M&M Protection Consultants in 1979 consulting to various

highly protected risk corporations in property loss prevention activities and

acting as a liaison in their dealings with engineering departments of the

various insurance carriers.

Mr. Malicki was previously employed by Industrial Risk Insurance from 1976 to

1979 achieving the position of engineer. During this time he conducted field

inspections of highly protected risk properties. He completed a six month

training program which included a four-week laboratory course in Hartford, Connecticut, in fire protection engineering.

Prior to his experience with the IRI, Mr. Malicki worked with McCormick Place

Convention Center dealing with the Fire Safety/Security Systems.

EDUCATION EXPERIENCE

Mr. Malicki attended the University of Illinois and received a Bachelor of

Science Degree in Management.

A5.1-9 B/B AMENDMENT 13 DECEMBER 1990

M&M Protection Consultants

Professional Profile

Noel F. Malicki

Page 2

MILITARY EXPERIENCE

U.S. Air Force

Ground Radio Communication Technician

Active Duty 1968 to 1972

Honorable Discharge

PROFESSIONAL ASSOCIATIONS

Mr. Malicki is a member of the National Fire Protection Association.

January 1986

A5.1-10 B/B AMENDMENT 13 DECEMBER 1990

M&M Protection Consultants

PROFESSIONAL PROFILE

John A. Robinson - Fire Protection Consultant M&M Protection Consultants A Risk Management Resource of Marsh & McLennan, Inc.

PROFESSIONAL EXPERIENCE

Mr. Robinson is located in the Chicago office of M&M Protection Consultants.

He is a member of the Gas and Electric Utility Unit-Midwest which provides fire

protection consultation for approximately twenty (20) utility companies, located throughout the United States.

He has a working knowledge of U.S. Nuclear Regulatory Commission APCSB - BTP

9.5-1 "Guidelines for Fire Protection for Nuclear Power Plants," Nuclear Mutual

Limited and the American Nuclear Insurers requirements and philosophies.

Mr. Robinson has also appeared as an expert witness before the Nuclear

Regulatory Commission and is a certified "Lead Auditor" in accordance with ANSI

N 45.2.23, Appendix "A."

Mr. Robinson presented various papers among which are "Fire Hazard Analysis of

Nuclear Power Stations - A Systems Approach," New Demands in Hazard Control in

the Utility Industry," Fire Protection Considerations for Generating Stations

Under Construction" which was published in Electric Light & Power magazine and "Property Loss Prevention Criteria as applied to Coal Gasification Projects."

He participated in a national consensus standards writing group by his

membership on the American Nuclear Society (ANS) 59.2 - HVAC Systems, Important

to Safety, Located Outside Primary Containment.

From January 1971 to September 1973, Mr. Robinson was a Technical

Representative in the Highly Protected Risk Department of the Kemper Insurance

Company where he received extensive specialized training in fire protection

engineering. He reviewed engineering drawings for various types of fire

protection systems.

From September 1969 to January 1971, Mr. Robinson was a Product Engineer and

Laboratory Supervisor for a specialized job production shop. In this capacity, he supervised the Engineering Laboratory, made product evaluations, developed

methods used in the assembly of new products and developed quality control

procedures.

A5.1-11 B/B AMENDMENT 13 DECEMBER 1990 M&M Protection Consultants

Professional Profile

John A. Robinson

Page 2

From March 1968 to September 1969, Mr. Robinson was an Assistant Metallurgist

at a forging company. He was responsible for the quality assurance testing of

various semi-finished drop forged products which included metallographic

microscopic examinations, tensile testing, impact testing and various non-

destructive testing.

EDUCATIONAL EXPERIENCE

Mr. Robinson attended Illinois Institute of Technology and received his B.S.

in Interdisciplinary Engineering (Electrical and Metallurgical options) from

Purdue University in 1978.

Mr. Robinson completed a course at Northwestern University entitled "Safety of

Light-Water-Cooled Nuclear Power Plants" in September 1979.

Mr. Robinson completed a course at the Hartford Steam Boiler entitled "Reactor

Plant Technology."

PROFESSIONAL ASSOCIATIONS

Mr. Robinson is a Registered Professional Engineer in the State of Illinois. He

is a member of the Society of Fire Protection Engineers and National Fire

Protection Association.

January 1986

A5.1-12 B/B AMENDMENT 13 DECEMBER 1990

M&M Protection Consultants

PROFESSIONAL PROFILE

Robert J. Smith, Jr. - Fire Protection Consultant M&M Protection Consultants A Risk Management Resource of Marsh McLennan, Inc.

PROFESSIONAL EXPERIENCE

Mr. R. Smith, Jr. is a Fire Protection Consultant in the Gas and Electric

Utility Unit-Midwest in the Chicago Office of M&M Protection Consultants.

The Gas and Electric Utility Unit specializes in providing fire protection and

boiler and machinery engineering loss prevention services to the utility

industry. These services are provided to the nuclear and fossil fuel fired

electric generating utilities and natural gas utilities. Mr. Smith's

responsibilities involve coordinating and supervising all consulting on account

under his responsibility. These consulting activities consist of coordinating

loss prevention inspections, performing hazard analysis and inspections, applying and recommending fire protection and loss pnevention engineering, performing design reviews and working in the development and application of

loss prevention and fire protection engineering applicable to the utility

industry.

Mr. Smith is a qualified Nuclear Generating Station Consultant and services the

Nuclear Mutual Limited (NML) account. Mr. Smith's primary responsibilities as

a qualified nuclear consultant servicing the NML account including coordinating

and applying the NML Property Loss Prevention Standards, liaison with members

within, and associated with, the Nuclear Mutual Limited concerning loss

prevention related matters, perform plant inspections, witness, audit and

approve plant testing and programs related to fire protection and loss

prevention matters. His responsibilities also include design consultation and

review of systems, equipment and construction and provide general loss

prevention consultation.

Mr. Smith also consults to the Nuclear Electric Insurance Limited (NEIL)

Account. This involves applying the NEIL Loss Prevention Standards related to

property protection and loss prevention.

Mr. Smith was formerly employed at Factory Mutual Engineering Division as a

Loss Prevention Consultant for two years prior to joining M&M Protection

Consultants. His responsibilities included providing fire protection

engineering and loss prevention consultation, relating to the various hazards

and occupancies associated with the industrial community. Consulting included

performing loss prevention inspections, recommending and making the fire

protection analysis required for the various hazards and performing general

design reviews as related to the property protection.

A5.1-13 B/B AMENDMENT 13 DECEMBER 1990

M&M Protection Consultants

Professional Profile

Robert J. Smith, Jr.

Page 2

Mr. Smith has also been involved with the training of Loss Prevention

Consultants.

In 1978, Mr. Smith addressed the Annual Convention of American Physics

Teachers, related to his research project which was under development during

his senior year of college.

EDUCATIONAL EXPERIENCE

In May of 1978, Mr. R. Smith, Jr. received a Bachelor of Science Degree in

Physics and Mathematics from Valparaiso University.

PROFESSIONAL ASSOCIATIONS

Mr. Smith is a member of the National Fire Protection Association and an

Associate Member of the Society of Fire Protection Engineers. Mr. Smith is an

alternate member on the NFPA 214 committee for the Standard on Water Cooling

Towers.

January 1986

A5.1-14 B/BAMENDMENT 13 DECEMBER 1990 APPENDIX 5.2 CABLE SYSTEMS CRITERIA B/BAMENDMENT 13 DECEMBER 1990 TABLE OF CONTENTS PAGEA5.2CABLE SYSTEMS CRITERIA A5.2-1A5.2.1CABLE DERATING AND CABLE TRAY FILL A5.2-1A5.2.2FIRE DETECTION AND PROTECTION IN AREAS WHERE CABLES ARE INSTALLED A5.2-3A5.2.3PHYSICAL INDEPENDENCE OF REDUNDANT SYSTEMS A5.2-5A5.2.3.1Criteria and Design BasisA5.2-5A5.2.3.2Cable Tray, Cable Penetrations, andConduit System Design BasisA5.2-5A5.2.3.3Cable PenetrationsA5.2-5A5.2.4 CABLE DEFINITIONS AND RATING DESIGN BASIS A5.2-7A5.2.4.1Cable DefinitionsA5.2-7A5.2.4.2Cable Derating (Cable Ampacities)A5.2-7A5.2.5PHYSICAL SEPARATION CRITERIA A5.2-9A5.2.5.1Class 1E Equipment SeparationA5.2-9A5.2.5.2Raceway Separation CriteriaA5.2-9A5.2.6CABLE SEPARATION CRITERIA A5.2-13A5.2.6.1Cable SegregationA5.2-13A5.2.6.2Cable RoutingA5.2-13A5.

2.7REFERENCES

A5.2-15 A5.2-i B/BAMENDMENT 13 DECEMBER 1990 APPENDIX 5.2 CABLE SYSTEMS CRITERIAA5.2.1CABLE DERATING AND CABLE TRAY FILL Cable Ampacities The allowable current-carrying capacities (ampacities) for the various power cables and control cables are in accordance with IPCEA P-46-426, 1962, "Power Cable Ampacities - Volume I - Copper Conductors" and IPCEA P-54-440, 1972, "Ampacities - Cables in Open-Top Cable Trays." The ampacities listed in the

IPCEA Standards are derated, as required, to account for cables installed in trays with solid covers and cables installed in areas with ambient

temperatures greater than 40

!C.Cable Tray Loading The quantity of cable in any cable tray (power, control, or instrumentation) does not exceed the maximum number determined by the simultaneous application

of the following three restraints:a.Conductor Temperature (Heat Generation)

The quantity of cable in any cable tray (power, control, or instrumentation) may be limited by the allowable conductor

temperatures. The conductor temperatures are held within the

cable rating by assigning conductor ampacities which include

the effect of appropriate derating factors (as described under "Cable Derating").b.Tray Capacity The quantity of cable in any tray (power, control, or instrumentation) is limited by the net usable cross-sectional

area of that tray. All cables are below the level of the top

of the side rail of the tray.Cable insulation is protected by an overall jacket. Calcula-tions were performed (after the cable was selected and after the trays were designed) to demonstrate that there will be no

failure of cable insulation of the bottom layers of cable due

to compacting (plastic flow) over the design life of the

plant. These calculations verified that the loading was conservative, and for the worst possible case, the stress

produced in the cable is less than the allowable stress which

the cable supplier recommended.c.Structural (Load-Bearing) Capacity of Trays and Supports The quantity of cable in any tray (power, control, or instrumentation) may be limited by the structural capacity of

the trays and their supports. The trays are designed to carry

a distributed load of 40 lb/ft 2 , plus a 200-lb man (concentrated load) located in the middle of an 8-foot span, with a total deflection not to exceed 0.5 inch. Tests have A5.2-1 B/BAMENDMENT 13 DECEMBER 1990 been performed (and documented) to confirm the adequacy of the cable tray design. The total loading, when the installation

is completed, will not exceed the allowable stress for the

materials used under either the static or the seismic loading

conditions and detailed in Chapter 3.0, Section 3.10 of the

FSAR.A5.2-2 B/BAMENDMENT 25 DECEMBER 2012A5.2.2FIRE DETECTION AND PROTECTION IN AREAS WHERE CABLES ARE INSTALLED The plant's fire detection system consists of detectors which are required by the fire hazards analysis and located in zones covering strategic areas

throughout the station. The cable spreading room, the control room, the

battery room, cable penetration areas inside and outside the containment, and

the computer room are included. Any fire (or fire detection system trouble)

is annunciated in the main control room.

Fire Suppression for Cable Spreading Areasa.upper cable spreading room1.automatic Halon 1301 system, 2.manual carbon dioxide system and3.manual water hose stations.b.lower cable spreading room1.automatic carbon dioxide system, and 2.manual water hose stations.

Cable trays located outside of the cable spreading rooms do not have special fire suppression or detection systems dedicated specifically to them.

However, cable trays which are located in a hazardous area which has a fire suppression system or fire detection system will inherently receive fire

protection.

Fire Stops Details for fire stops for conduit, cable tray, and cable riser penetrations through walls and floors have been developed. Fire stops are provided wherever cables penetrate fire barrier walls or floors. The rating of the fire stop is

determined by testing and is consistent with the fire rating associated with

the wall or floor being penetrated as determined by the results of the fire

hazard analysis. Documented records of inspections are used to verify that

each fire stop and seal has been properly installed.

Relaxed criteria for installation of internal conduit seals may be utilized at Byron and Braidwood as follows:a.Conduits that terminate in junction boxes, pull boxes, or other noncombustible closures need no additional sealing.

Panels or Electrical Metallic Tubing (EMT) boxes should

not be considered as an adequate closure. Conduits that run through an area but do not terminate in that area need

not be sealed in that area.b.Conduits smaller than 2" diameter that terminate 1 foot or greater from the barrier need not be sealed.

A5.2-3 B/BAMENDMENT 19 DECEMBER 2000c.Conduits of 2" diameter that terminate 3 feet or greater from the barrier and have a cable fill of 25% or greater

need not be sealed.d.Conduits of greater than 2" diameter that terminate 3 feet or greater from the barrier and have a cable fill of 40%

or greater need not be sealed.e.An approved seal detail that is normally used on both sides of the barrier may be installed on one side only

provided one of the above configurations (A through D)

exists on the other side.

Conduit terminations that do not meet the above criteria should be sealed internally with a noncombustible seal, either at the barrier or on that side

of the barrier. These criteria should be applied to the conduit terminations

on both sides of fire-rated barriers that separate fire areas.

These criteria may be used for both initial installation of new internal conduit seals, or to relax surveillance and repair requirements for existing

conduit seals. Noncombustible seals are not required to maintain the rating

of a fire-rated barrier and, therefore, are not an integral component of a fire-rated assembly. Noncombustible seals are installed to limit the spread

of smoke and hot gases.

A5.2-4 B/BAMENDMENT 13 DECEMBER 1990A5.2.3PHYSICAL INDEPENDENCE OF REDUNDANT SYSTEMSA5.2.3.1Criteria and Design BasisThe power, control, and instrumentation cables for redundant circuits associated with the engineered safety features (ESF) system and the reactor

protection system are physically separated in accordance with IEEE Standards

279-1971, 317-1972, 384-1974, and NRC Regulatory Guides 1.32 and 1.75 to

assure that no single design-basis event will prevent operation of redundant

functions. Physical separation of cables is obtained by the division of the cable tray and conduit system into two ESF divisions, two non-Class 1E divisions, and four reactor protection and control channels. Class 1E

equipment with redundant safety functions are physically separated in accordance with IEEE Standard 384-1974. Non-Class 1E components are

electrically isolated from the Class 1E system by acceptable isolation

devices.A5.2.3.2Cable Tray, Cable Penetrations, and Conduit System Design Basis Steel cable trays are provided throughout the station. Cable ampacities were determined in accordance with the standards of the Insulated Power Cable Engineers Association (IPCEA) as detailed in Section A5.2.1. The cable trays

are of the solid bottom, uncovered type and are generally 6 inches maximum in depth. Exceptions to the solid-bottom trays are the open-bottom, ladder-type tray construction that is used (1) to facilitate cable entry to equipment (e.g., switchgear, motor control centers, etc.), and (2) to allow the routing

of cables from one tray to another directly above or below.

Trays with more than a 6-inch depth were installed in some instances (e.g., cable tray risers, tray intersections, at the interface between the tray

systems, and the reactor containment electrical penetrations, etc.). The

trays of increased depth were provided to allow for an orderly arrangement of cables within the trays. In each case, the deviations from the basic cable

tray system design were limited by the allowable cable tray loading (for both

physical and thermal considerations).

Solid covers were provided for all instrumentation cable trays. Solid covers were provided for power cable trays wherever (1) the power cable trays passed

below control cable and/or instrumentation cable trays, or (2) the power cable

trays were involved in approved reduced separation from the stated design

objectives in Section A5.2.5.A5.2.3.3Cable Penetrations The electrical penetrations are arranged in four groups, Groups 2 and 4 on the upper floor and Groups 1 and 3 on the lower floor, with a concrete floor

between the upper and lower groups on the auxiliary building side. The two groups on each floor are spaced approximately 40 feet apart.

Cable separation criteria are applied as follows:

Group 1: ESF Division 11 Cables

Non-Safety-Related Division 11 Cables A5.2-5 B/BAMENDMENT 13 DECEMBER 1990 Reactor Protection Channel I Instrumentation Group 2: ESF Division 12 Cables

Non-Safety-Related Division 12 Cables

Reactor Protection Channel II Instrumentation Group 3: ESF Division 11 Cables

Non-Safety-Related Division 11 Cables

Reactor Protection Channel III Instrumentation Group 4: ESF Division 12 Cables

Non-Safety-Related Division 12 Cables

Reactor Protection Channel IV InstrumentationThe electrical penetrations meet the requirements of IEEE 317-1972 and IEEE 384-1974.A5.2-6 B/BAMENDMENT 13 DECEMBER 1990A5.2.4CABLE DEFINITIONS AND RATING DESIGN BASISA5.2.4.1Cable Definitionsa.Power Cables Power cables are defined as those cables which provide electrical energy for motive power or heating to all 6600-Vac, 4000-Vac, 460-Vac, 208-Vac, 250-Vdc, and 125-Vdc loads.

Cables which provide power from electrical energy sources to

power distribution panels, regardless of voltage, are included

in this definition. Generally, cables with #6 AWG and larger conductors are included in this category. Some 600-V, #10 and

  1. 14 AWG conductor cables are also included in this category;

e.g., power feeds to valve motor operators.b.Control CablesControl cables are defined as those 120-Vac and 125-Vdc circuits (for example) between components responsible for the

automatic or manual initiation of auxiliary electrical

functions and the electrical indication of the state of

auxiliary components. When applying this criterion, cables

which supply electrical energy from distribution panels to

120-Vac and 125-Vdc instrumentation, control, and alarm circuits are treated as control cables. Generally, all 600-V cables with #10 and #14 AWG conductors, except those three-

conductor cables which are power cables, are included in this

category.c.Instrumentation Cables Instrumentation (signal) cables are defined as those cables conducting low-level instrumentation and control signals.

These signals are either analog or digital. Typically, those

cables which carry signals from thermocouples, resistance

temperature detectors, transducers, neutron monitors, etc., to

E/P converters, indicators, recorders, and computer input

circuits, carrying signals of less than 5O milliamperes, are

included in this category. Generally, instrumentation cables

are one of the following types:1.#16 AWG, twisted, shielded conductor pairs, 2.#20 AWG, chromel-constantan conductor pairs, and 3.coaxial or triaxial.A5.2.4.2Cable Derating (Cable Ampacities)The allowable current-carrying capacities (ampacities) for the various power cables and control cables (where applicable) are in accordance with AIEE/IPCEA "Power Cable Ampacities - Volume I -

Copper Conductors" (Section A5.2.1). The specific ampacity for each A5.2-7 B/BAMENDMENT 13 DECEMBER 1990 cable size was determined by applying the appropriate derating factors, thus obtaining the ampacity for cables in solid metal trays

without maintaining spacing. For applications inside the

containment, the ampacities were further adjusted (reduced) to

account for the higher expected ambient temperature.

A5.2-8 B/BAMENDMENT 13 DECEMBER 1990A5.2.5PHYSICAL SEPARATION CRITERIAA5.2.5.1Class 1E Equipment SeparationClass 1E components of an ESF division are physically separated from Class 1E components of the unit's other ESF division as well as from non-Class 1E high

energy components that could cause loss of redundancy as the result of a design-basis event effecting failure of these components. The separation of Class 1E components is in compliance with IEEE 384-1974. Redundant Class 1E

power sources and electrical distribution equipment are located in physically

separate Seismic Category I structures.The main control board is segregated into separate section for control of the plant main power generation and auxiliary systems. Each section containing

wiring and control equipment for a specific ESF division is physically

separated by fireproof barriers from other sections of the MCB.A5.2.5.2Raceway Separation Criteria Cable Tray Segregationa.ESF and non-safety-related divisional trays are separated into four divisions per unit:1.ESF division 11 (21) (for segregation code 1E)(Note: 1A cables allowed in tray),2.ESF division 12 (22) (for segregation code 2E) (Note: 2A cables allowed in tray),3.non-safety-related division 11 (21) (for segregation code 1B cables), and4.non-safety-related division 12 (22) (for segregation code 2B cables). (Note: NIS signal (triaxial) cable shall be

run in iron conduit)b.Trays for reactor protection and reactor control (RPS) are separated into four channels, each separate from the other

channels, and separated from all other trays, as follows:1.RPS channel I (for segregation code cables 1R and 1N),

2.RPS channel II (for segregation code cables 2R and 2N),

3.RPS channel III (for segregation code cables 3R and 3N), and4.RPS channel IV (for segregation code cables 4R and 4N).c.Cable ladder (rack) trays are installed above 480-V MCCs and 480-V switchgear, rod position indication data cabinet and

reactor head area, where top entry is required. Power and A5.2-9 B/BAMENDMENT 13 DECEMBER 1990 control cable segregation is maintained, where practical, to the point of entering this

equipment.

Cable Tray Separationa.Minimum spacing for engineered safety features (ESF) divisions and reactor protection system (RPS) channels are:1.Between redundant ESF division or redundant RPS channels:

vertical - (5 feet 0 inch) metal to metal, horizontal -

(3feet 0 inch) metal to metal. This separation

requirement holds for general plant areas.2.Between redundant ESF division or redundant RPS channels: vertical - (3 feet 0 inch) metal to metal, horizontal -

(1foot 0 inch) metal to metal. This separation require-

ment holds for the cable spreading areas and for those

other areas where high energy electrical equipment (switchgear, transformers, rotating equipment, etc.) is

excluded and power cables are installed in enclosed

raceways that qualify as barriers or there are no power

cables.3.Between power trays within the same ESF division (or between control trays in the same ESF division or between

instrument trays in the same ESF division or between trays

in the same RPS channel): vertical - (1 foot 0 inch) metal

to metal, horizontal - (3 inches) metal to metal.4.Horizontal and vertical spacing between power and instrument trays within the same division are a minimum of

(1 foot 8 inches) metal to metal.5.Horizontal and vertical spacing between control and instrumentation trays within the same division are a

minimum of (1 foot 0 inch) metal to metal.6.In the case of a control cable tray passing (crosswise) over or under an instrument cable tray within the same

division, the minimum vertical spacing is 6 inches.b.Basic separation for non-safety-related cable trays is:1.3 inches horizontal, metal-to-metal; and 12 inches vertical, metal-to-metal;2.horizontal and vertical spacing between power and instrument trays are a minimum of (1 foot 8 inches) metal

to metal;3.horizontal and vertical spacing between control and instrument trays are a minimum of (1 foot 0 inch) metal to

metal; and A5.2-10 B/BAMENDMENT 13 DECEMBER 19904.in the case of a control cable tray passing (crosswise) over or under an instrument cable tray, the minimum

vertical spacing is 6 inches.c.Where termination arrangements or space limitation preclude maintaining the above minimum space separations, the redundant

cables are run in enclosed raceways that qualify as barriers, or other barriers shall be provided between redundant cables.

The minimum distance between these redundant enclosed raceways

and between barriers and raceways is 1 inch.

Conduit Segregation All conduit qualify as barriers. The same rules have been applied to conduit segregation as were applied to cable tray segregation.

Conduit Separationa.All power, control, and instrumentation cables are run in separate conduit.b.The minimum allowable separation between conduit in redundant ESF divisions is 12 inches. However, where practical, the

separation between conduits in redundant ESF divisions is the

same as for cable trays.c.For instrument conduit within the same ESF division, or related RPS channel, the following separation distances apply:1.Minimum vertical and horizontal separation between instrument conduit and control cable conduit is 1 inch.2.Minimum vertical and horizontal separation between instrument conduit and power cable conduit is:a)Shielded instrument cables in conduit running parallel to power cables in conduit where the parallel run is

less than 100 feet have 1 inch minimum separation. If

the conduits run parallel for a distance greater than

100 feet, 1 inch separation is used in some cases for

a distance not exceeding 100 feet, the remaining

separation is 3 inches minimum. Where practicable, the

3-inch minimum separation has been maintained.b)Unshielded instrument cables in conduit are run a minimum of 3 inches from control cables in conduit and

20 inches from power cables in conduit.d.The minimum vertical and horizontal separation between conduit in redundant RPS and NIS channels is 24 inches.Nuclear instrumentation system (NIS) signal (triaxial) cables are run in steel conduit. The conduit fill is limited to 25%

and minimum bending radius is 12 inches. The maximum straight A5.2-11 B/BAMENDMENT 13 DECEMBER 1990 run of conduit is 100 feet, or, where a 90

! bend occurs, the straight run is 10 feet maximum.e.NIS triaxial cable conduit is separated from electrical noise sources by the following distances:1.control or low voltage power cable in conduit - 24 inches; 2.medium voltage power cables in conduit - 6 feet (72 inches); and3.control, low, and medium voltage cables in trays - 6 feet (72 inches).f.Where instrument cable (other than NIS triaxial) conduit and cable trays within the same division are installed adjacent to

each other the following separations apply:1.instrument conduit to power cable tray - 20 inches, 2.instrument conduit to control cable tray - 3 inches, 3.control cable conduit to instrument cable tray -12inches; and4.power cable conduit to instrument cable tray - 20 inches.

A5.2-12 B/BAMENDMENT 13 DECEMBER 1990A5.2.6CABLE SEPARATION CRITERIAA5.2.6.1Cable Segregation A segregation code assigned to each cable was used to check all cables routed in cable trays or conduit for compliance with the required segregation. This

cable segregation code appears in the installation cable tabulation and on

applicable physical installation drawings. The segregation code consists of

one or more characters as indicated in the following table:

Unit Number Type Division Category 1P1E 2C2B K3R 4N AAType:P =PowerC =Control K =InstrumentationDivision:ESF or non-safety-related divisions 1 or 2 RPS input channels 1, 2, 3 or 4

RPS output channels A or B

NIS channels 1, 2, 3 or 4Category:E = engineered safety feature B = non-safety-related

R = reactor protection

N = neutron monitoring A =associated cables that share a power supply, enclosure, or raceway with Class 1E cables (cable category only).

Cable separation is accomplished using this segregation coding of each cable. Each cable associated with safety-related equipment is classified as Class 1E, and so segregated. These cables are assigned to ESF division 11 (21) or 12

(22). Each non-Class 1E cable which has any part of its length in a Division

11 (21) or 12 (22) tray, connects to a Class 1E power system, shares an

enclosure with a Class 1E circuit, or is not physically separated from Class 1E cables by acceptable distance or barriers, is a division-associated cable (Category A).A5.2.6.2Cable Routing Cables associated with the ESF equipment are routed only in cable trays associated with their respective division. A cable associated with ESF equipment of one division has no portion of its run in any cable tray assigned

to another ESF division. The following cable and tray segregation code rules

have been adhered to in the routing of all cables:

A5.2-13 B/BAMENDMENT 13 DECEMBER 1990a.Unit number for a cable and the tray in which it is run must agree.b.Type and division codes of a cable must agree with the corresponding codes for the tray.c.Cable category code must agree with the tray category code insofar as the table below specifies: CableTray CategoryCategoryE B R N EX BX RXX NXX*AX

  • All "A" cables in Safety Category II

Structures shall be installed in conduit.In the case of Class 1E cables associated with redundant ESF equipment enters a common switchboard, such as the unit's main control board, the installation

of barriers and the physical separation of the board's internal wiring and in compliance with those procedures set forth in IEEE 384-174.

A5.2-14 B/BAMENDMENT 13 DECEMBER 1990 A5.

2.7 REFERENCES

General Design Criteria"Appendix A - General Design Criteria for Nuclear Power Plants," 10 CFR 50, U.S. Atomic Energy Commission (July 7, 1971).a.GDC 17 - Electric Power Systems b.GDC 21 - Protection System Reliability and Testability c.GDC 22 - Protection System Independence Regulatory Guides Regulatory Guide 1.75 - "Physical Independence of Electric System," U.S. Nuclear Regulatory Commission, Rev. 1, January 1975.

Other Design Criteria - IEEE Standards IEEE 279-1971, "Criteria for Protection Systems for Nuclear Power Generating Station." IEEE 317-1972, "Criteria for Electrical Penetration Assemblies in Containment Structures for Nuclear Power Generating Station." IEEE 384-1974, "IEEE Trail-Use Standard Criteria for Separation of Class 1E Equipment and Circuits." A5.2-15 B/B AMENDMENT 13 DECEMBER 1990

APPENDIX 5.3

CLASSIFICATION CRITERIA FOR

SAFETY-RELATED

STRUCTURES, SYSTEMS, AND COMPONENTS B/B AMENDMENT 23 DECEMBER 2008

1.0 SCOPE The purpose of this Criteria is to establish the scheme by which structures, systems and components are classified in relation to

their importance to safety. This Criteria also sets the general

classification of the major structures, systems and components and

is to be used as the basis for establishing the more detailed

classification required in project documents such as Design

Criteria, Equipment, Valve and Piping Lists and Cable Tabulations.

2.0 REFERENCES

2.1 10 CFR 50 Appendix A 2.2 Regulatory Guide 1.29 2.3 10 CFR 50 Appendix B 2.4 Regulatory Guide 1.26 2.5 Byron/Braidwood FSAR, Chapter 3.0 2.6 Regulatory Guide 1.32 2.7 RESAR, Chapter 3

3.0 DEFINITIONS

3.1 Safety Classification - Structures, systems and components are classified for design purposes as either

Safety Category I or Safety Category II. Systems and

Components are further classified by the appropriate

Quality Group (See 3.4 below) or Class IE designation (See 3.5 below) as applicable.

3.2 Category I structures , systems, and components are those necessary to assure: (a) the integrity of the reactor

coolant pressure boundary, (b) the capability to shut

down the reactor and maintain it in a safe shutdown

condition, or (c) the capability to prevent or mitigate

the consequences of accidents which could result in off-

site exposures comparable to the guideline exposures of

10 CFR 100 for accidents analyzed using TID-14844 and 10 CFR 50.67 for accidents analyzed using alternative source term in the postulated event of the safe shutdown earthquake (SSE) or other design basis events including

tornado, probable maximum flood, operating basis

earthquake (OBE), missile impact, or accident internal to

the plant.

3.3 Category II - Those structures, systems, and components which are not designated as Safety Category I are

designated as Safety Category II. This category has no

public health or safety implication.

A5.3-1 B/B AMENDMENT 13

DECEMBER 1990

3.4 Quality Group Classification - The quality group classification system defined in Regulatory Guide 1.26, established for water-steam-containing components

important to safety, is directly applicable.

3.5 Class IE - Electric Systems - Electric equipment and systems that are essential to emergency reactor shutdown, containment isolation, reactor core cooling, and contain-

ment and reactor heat removal, or otherwise are essential

in preventing significant release of radioactive material

to the environment.

3.6 Single Failure - A single failure is an occurrence which results in the loss of capability of a component to

perform its intended safety functions when called upon.

Multiple failures resulting from a single occurrence are

considered to be a single failure. Fluid and electrical

systems are considered to be designed against an assumed

single failure if neither (1) a single failure of any

active component (assuming passive components function

properly); nor (2) a single failure of a passive compon-

ent (assuming active components function properly)

results in a loss of the design function.

3.7 Active Failure - An active failure is the failure of a powered component such as a piece of mechanical

equipment, component of the electrical supply system or

instrumentation and control equipment to act on command

to perform its design function.

3.8 Passive Failure - A passive failure is the structural failure of a static component which limits the

component's effectiveness in carrying out its design

function.

3.9 Design Basis Event - A design basis event is a natural phenomenon or failure of a system, component or structure

which is postulated to provide the basis for designing

the safety-related aspects of the plant. Examples are

safe shutdown earthquake (SSE), wind and tornadoes, probable maximum flood, missiles and loss of coolant

accident (LOCA).

4.0 FUNCTIONAL REQUIREMENTS 4.1 Category I structures, systems and components shall perform their intended safety functions in the event of

the safe shutdown earthquake (SSE) and other design basis

events as identified in the applicable design criteria.

A5.3-2 B/B AMENDMENT 13 DECEMBER 1990

4.2 Category I structures, systems and components shall retain their own integrity and/or shall not constitute a hazard to other Category I structures, systems or components during the safe shutdown earthquake

and other design basis events as identified in the applicable design criteria.

4.3 Category I systems and components shall perform their intended safety functions assuming a single failure and

loss of off-site power.

4.4 The plant design shall ensure that Category II structures, systems or components do not constitute a

hazard to Category I structures, systems or components

during the safe shutdown earthquake and other design

basis events.

5.0 DESIGN REQUIREMENTS

5.1 Category I systems and components shall not be located in Category II structures. Exceptions shall be evaluated on

a case by case basis and design requirements established.

5.2 Systems or portions of systems which are designated Category I shall be identified as appropriate in the

various design documents associated with that system.

5.3 The division between Category I and II portions of systems shall be in accordance with the intent of

Regulatory Guide 1.29. The seismic design of Category I

items is in accordance with the requirements of

Regulatory Guide 1.29.

5.4 Quality Assurance Requirements for Category I systems or portions of systems and components shall meet the

requirements of Appendix B to l0 CFR 50.

5.5 Category II structures, systems and components need not be specifically designed for dynamic operating basis-

earthquake loadings; however, a reasonable margin of

safety shall be considered in the design as dictated by

local requirements, such as the Uniform Building Code.

5.6 Category II systems or portions of systems and components need not follow the requirements of Appendix B to l0 CFR 50; however, the Quality Assurance standards for these systems and components shall follow normal industrial

standards and any other requirements deemed necessary.

A5.3-3 B/B AMENDMENT 13 DECEMBER 1990

6.0 SAFETY CLASSIFICATION

6.1 Table 1 indicates the overall correspondence between safety categories and Quality Groups and the general

boundaries of systems to be considered part of each

quality group.

6.2 FSAR Table 3.2-1 lists all major plant structures and components which shall be designated as Category I and

their respective Quality Group/Electrical

classifications. Table 3.2-1 also lists the major plant

structures and components which shall be designated as

Category II.

6.3 Table 2 gives a cross-reference which can be used to translate from the Westinghouse (RESAR or ANS) safety

classification system to the classification system

established in this document when utilizing more detailed

Westinghouse documents such as the NSSS Standard Design

Criteria.

7.0 TABLES

5.3-4 B/B AMENDMENT 13 DECEMBER 1990

TABLE 1 RELATION BETWEEN QUALITY GROUP AND CATEGORY CLASSIFICATIONS

QUALITY GROUP CATEGORY GENERAL SYSTEM DESCRIPTION

A I Reactor coolant pressure boundary and extensions thereof.

B I Emergency core cooling, post-LOCA heat removal and cleanup, safe reactor shutdown and heat removal, portions of main steam and feedwater and other systems associated with containment isolation.

C I Systems required to support those in Quality Group B, spent fuel cooling, radioactive waste systems which normally contain a high level of radio-active material.

D II Parts of portions of systems which contain or may contain radioactive material and all other systems not character-ized as Category I.

5.3-5 B/B AMENDMENT 13 DECEMBER 1990

TABLE 2 CROSS REFERENCE FROM WESTINGHOUSE RESAR (ANS)

SYSTEM OF SAFETY CLASSIFICATION TO BYRON/BRAIDWOOD

SAFETY CLASSIFICATION SYSTEM

WESTINGHOUSE BYRON/BRAIDWOOD ELECTRICAL RESAR-3 (ANS EQUIPMENT SAFETY SAFETY CLASS) QUALITY GROUP SAFETY CATEGORY CLASSIFICATION

1 A I N/A

2 B I Class IE

3 C I Class IE/

Non-IE

NNS D II Non-IE

NNS - Non Nuclear Safety

5.3-6 B/B APPENDIX 5.4 FIRE PROTECTION SYSTEM DESCRIPTIONS

B/BAMENDMENT 13 DECEMBER 1990 TABLE OF CONTENTS PAGEA5.4 FIRE PROTECTION SYSTEM DESCRIPTIONSA5.4-1A5.4.1 FIRE PROTECTION WATER SUPPLY SYSTEMA5.4-2A5.4.2 AUTOMATIC DELUGE SYSTEMSA5.4-4A5.4.3 AUTOMATIC SPRINKLER SYSTEMSA5.4-6A5.4.4 FOAM SYSTEMSA5.4-8A5.4.5 HALON 1301 SYSTEMSA5.4-10 A5.4.6 CARBON DIOXIDE (CO

2) SYSTEMA5.4-12A5.4.7 MANUAL EXTINGUISHING CAPABILITYA5.4-15A5.4.8 FIRE DETECTION SYSTEM DESCRIPTIONA5.4-16 A5.4-i B/BAMENDMENT 13 DECEMBER 1990 LIST OF TABLESNUMBERTITLESPAGEA5.4-1Fire Protection MatrixA5.4-17A5.4-2Fire Pump DataA5.4-26 A5.4-3Automatic Deluge SystemsA5.4-26 A5.4-4Automatic Sprinkler SystemsA5.4-27 A5.4-5Foam SystemsA5.4-28 A5.4-6Halon 1301 SystemsA5.4-29 A5.4-7Carbon Dioxide SystemsA5.4-30 A5.4-ii B/BAMENDMENT 18 DECEMBER 1998 LIST OF FIGURESNUMBERTITLEA5.4-1Unit 1 Fire Protection System Single Line DiagramA5.4-2Unit 1 Fire Detection Schematic Diagram for Cable Spreading RoomsM-28Fire Protection Piping and Outdoor Protection M-603Transformers -Sprinkler Systems M-52Fire Protection M-58Carbon Dioxide and Hydrogen Systems A5.4-iii B/BAMENDMENT 13 DECEMBER 1990APPENDIX 5.4 -FIRE PROTECTION SYSTEMS DESCRIPTIONSThe purpose of this appendix is to describe in detail the fire protection systems provided for Byron and Braidwood.

The fire protection systems have been designed in accordance with the applicable NFPA guidelines and any other codes and standards which apply to these systems. The overall fire protection is in agreement with NFPA Chapter 803 -"Fire Protection Guidelines for Nuclear Power Plants." This appendix is

divided into eight sections. The sections deal with the fire sprinkler water supply system, deluge systems, automatic sprinkler systems, foam systems, Halon 1301 systems, carbon dioxide system, manual fire suppression systems, and the fire detection system.

The relationship of the fire protection systems to the electrical power supply is discussed in Appendix 5.2.

A single line electrical diagram of the fire protection system is provided in Figure A5.4-1. This diagram includes the automatic sprinkler, automatic

deluge, Halon 1301, carbon dioxide and foam fire protection systems.A matrix listing each fire protection zone, its primary and backup fire protection and fire detection is provided as Table A5.4-1.

References used in developing the fire protection systems discussions are listed below.

References Mechanical Drawings M-1 through M-22 General Arrangements M-28 Fire Protection Piping and Outdoor Protection

M-52 Fire Protection

M-58 Carbon Dioxide and Hydrogen Systems

Sargent & Lundy Specifications F/L-2811 Carbon Dioxide Storage Equipment

F/L-2817 Fire Protection Systems

F/L-2854 Fire Detection Systems

F/L-2869 Miscellaneous Vertical Pumps A5.4-1 B/BAMENDMENT 24 DECEMBER 2010 A5.4.1 FIRE PROTECTION WATER SUPPLY SYSTEM The fire protection water supply system is a direct pumping system with pumps taking suction from the basin of the natural draft cooling towers (at Byron)

or the cooling lake (at Braidwood). This system supplies water to the plant

fire hydrants, the water suppression systems, and the standpipe systems.

A cross-tie to the essential service water system is provided to ensure a seismically qualifiedbackup water supply to only the Seismic Category I portions of the fire suppression (standpipe systems) located in safety-related

areas. The system is designed such that the integrity of the ESW system will

be maintained if the cross-tie is utilized.

The fire hydrant system is supplied by separate underground header connections from each of the two fire pumps. Divisional valves are provided to isolate each header. The system consists of a 12-inch ring header (14-inch ring header at Braidwood surrounding the main buildings with strategic placement of

the fire hydrants located approximately 250 feet apart. At Braidwood, a

dedicated fire response vehicle or cart(s) is maintained with hose equivalent to two hose houses and an inventory of equipment adequate for the fire

brigade. At Byron, a dedicated fire response truck or cart is maintained with

hoses and equipment equivalent to that supplied by three hose houses.

Freezing of the fire protection system is prevented by burying the piping below the frost line and by routing indoor piping through heated areas. Wet

standpipe systems are provided for use inside the station. These are located so that any internal area of the station can be reached with 1-1/2-inch hose

and combination nozzle.

Threads on hydrants, hose couplings, and standpipe risers are of standard size and compatible with those used by the local fire department.

The yard main which encircles the entire plant can be isolated into four segments by means of manually operated postindicator valves.

Automatic sprinkler systems and manual hose stations are supplied from interior loop mains. There are five connections between the yard main and the

interior loops.

Sprinkler, foam, and deluge systems can be isolated from the interior loops by supervised and locked isolation gate valves in accordance with NFPA standards.The system is normally kept pressurized by one of the two motor-driven fire protection jockey pumps. They are only used for system pressurization. If a system demand occurs, the pressure will decrease in the fire protection system, thereby automatically starting the motor-driven fire pump. If system demand is in excess of the motor-driven pump or if there is a pump failure, the diesel-driven fire pump will engage. Technical data on the fire pumps and jockey pumps are attached at the end of the section. The motor-driven fire

pumps, diesel-driven fire pump, and jockey pumps are located in the A5.4-2 B/BAMENDMENT 19 DECEMBER 2000circulating water pumphouse (Byron) or the lake screen house (Braidwood) and take suction directly from the intake bay.

The fire pumps cannot be operated from the control room. All fire pumps operate automatically on low system pressure. In case of emergency or maintenance, a locally mounted handswitch is provided for manual operation.

The safety of the power supply for the pump motors is ensured since the power

cabling enters only the switchgear spreading area in the main plant. The power cable is enclosed in rigid steel conduit along its entire length.The following inputs to the control room are provided for the motor-driven fire pump: pump running, fail to start, auto trip, and pump locked out. All

inputs have dedicated annunciator windows. Inputs from the diesel fire pump to the controlroom are as follows: ac power failure, battery 2 failure, low

fuel, high water temperature, overspeed, fail to start, pump running, and

control switch (CS) in OFF position. Inputs pump running, fail to start, and low fuel have dedicated annunciator windows. Inputs high water temperature, low lube oil pressure, overspeed, and CS in OFF position are combined into one "trouble" window. Inputs ac power failure, charger failure, battery 1 failure, and battery 2 failure are combined into one "Loss of Power" window.

The main control room is also provided with alarms for low fire main pressure and a low-low fire main pressure.

Whenever any of the inputs listed above are activated, alarms and annunciationin the control room are activated. As described above,many of the inputs are

combined into a single "trouble" or "loss of power" alarm for the diesel fire

pump. A local control cabinet will provide the necessary indication to

isolate the malfunction or operating condition which activated the alarm.

The pumps are tested monthly per NFPA Standard 20 guidelines as described in Table 3-1 of this report. Fire pump data are given in Table A5.4-2.

A5.4-3 B/BAMENDMENT 13 DECEMBER 1990 A5.4.2 AUTOMATIC DELUGE SYSTEMS Automatic deluge systems have been provided for the main, unit auxiliary and system auxiliary transformers, hydrogen seal oil units, and the turbine oil

reservoir rooms. In all cases water is supplied through the turbine building

ring header.

All deluge systems operate automatically in the same manner as described below.a.Detector signal or pushbutton signal opens a solenoid valve on the deluge valve release line.b.Pressure in the release line is relieved, permitting the deluge valve to open and water to flow to the nozzles.c.As pressure in the discharge line increases, a pressure switch activates the local electric alarms and control room audible

and visual alarms.

In case of electrical power failure, the deluge system may be operated manually by pulling the emergency relief lever on the deluge valve release

line.Additionally, preaction sprinkler systems have been provided for the turbine bearings. Water to these systems is supplied through the turbine building

ring header.Operation of this system combines some aspects of both the automatic deluge and automatic sprinkler systems. This system makes use of a deluge valve

which operates in the same manner as discussed above with the exception that closed sprinkler heads have been used in place of deluge nozzles.

The preaction system operates as follows:a.Actuation of thermal detectors, located near the sprinkler heads at the turbine bearings, or a pull station signal, opens

a solenoid valve on the deluge valve release line.b.Pressure in the release line is relieved, permitting the deluge valve to open thereby charging the system piping up to the

sprinkler heads.c.This increase in pressure actuates a pressure switch in the system piping which activates the local electric alarm and

control room audible and visual alarms.d.If the initiating condition continues unchecked, the sprinkler head fusible links fuse and water flows out of the open heads.

In case of an electrical power failure, the system may be activated manually by pulling the emergency relief valve lever on the deluge valve release line, provided the initiating condition fuses the sprinkler head fusible links.

A5.4-4 B/BAMENDMENT 20 DECEMBER 2002 Each "hazard area" is provided with a local control cabinet. All electrical equipment for that "hazard area" is wired to the cabinet. The cabinet is

equipped with a white "power on" indicating lamp.

Each cabinet provides the following output signals to the control room: hazard area "fire" and hazard area "trouble." The troublecondition consists

of detector circuit failures, power failure, electrical actuation system

failure, and isolation valve closed.

All electrical circuits are supervised.

Contacts are also provided for local electric fire alarms.

Whenever any of the conditions noted under fire or trouble occurs, visual and audible alarms are activated in the control room.

Specific data on each deluge system can be found on the installation drawings kept at the stations.The system can be tested by physically actuating the system and verifying that all components perform as required with the gate valves closed.

Periodically, surveillances are conducted to verify system operability.

Preoperational and surveillance test data for these systems can be found on

file at the stations.

A5.4-5 B/BAMENDMENT 13 DECEMBER 1990 A5.4.3 AUTOMATIC SPRINKLER SYSTEMS Automatic sprinkler systems have been provided in most areas of the turbine building and in other areas where a significant fire hazardexists. Automatic sprinklers were not provided for areas containing safety-related equipment

because inadvertent operation would disable them, thereby reducing plant

safety margins.The sprinkler systems provided in the turbine building take their watersupply from the turbine building ring header. All sprinkler installations are

basically the same and operation is totally automatic.

Specific data on each sprinkler system can be found on the installation drawings kept at the stations.

Each sprinkler system, except the Turbine Tower Sprinkler System, is provided with an isolation valve and alarms. The isolation valve is either supervised

so that closure will result in a "trouble" alarm being activated in the control room or locked or sealed open. The Turbine Tower Sprinkler System

does not alarm in the main control room, and does not have a supervised system

isolation valve, but is equipped with a local fire alarm and has its isolation

valve locked open.

System operation follows this order:a.fire melts the fusible links on the sprinkler heads and water flows out the open heads and activates a flow switch which

activates the local and control room alarms; or if an alarm

check valve is provided,b.as the water pressure drops, the alarm check valve opens, simultaneously opening an auxiliary line to the retarding

chamber; andc.pressure builds in the chamber until a pressure switch activates the local electric alarms and control room alarms.Electricity is not required for the sprinkler system to function, however, it is required for the alarms to function.

Each sprinkler system may be tested at any time by use of the inspector's test connection. Each sprinkler system has a local control cabinet to which all electrical equipment for that hazard area is connected. Each cabinet provides

the following outputs to the control room:a.hazard area "fire" and b.hazard area "trouble" (the trouble condition consists of isolation valve closed).Contacts are provided to operate the local fire alarms. The sprinkler systems provided at the Byron circulating water pump house and Braidwood lake screen A5.4-6 B/BAMENDMENT 13 DECEMBER 1990 house are similar to the other sprinkler systems except the water supply is taken directly from the motor-or diesel-driven fire pump.

A5.4-7 B/BAMENDMENT 28 DECEMBER 2018 A5.4.4 FOAM SYSTEMSManual foam systems are provided for the 50,000-gallon diesel oil storage tankrooms in the auxiliary building.Abalanced pressure foam system utilizing a 100-or 150-gallon diaphragm foam tank and 3% (double strength) fluoroprotein

foam is used.

The 50,000-gallon diesel oil storage tank room foam systems are activated manually by isolation valves. Foam system operation is virtually identical to

deluge system operation. When actuated, water flows through a proportioning

controller where the foam concentrate is introduced into the water. The foam travels from the controller to the foam/water deluge heads where it is blown

down into the room. The foam system for all tank rooms is actuated manually

at the foam tank.Two 100-gallon foam tanks have been provided to protect the indoor 50,000-gallon oil tank rooms. Thefoam tanks are located in the turbine building at grade level and are supplied with water from the turbine ring header. A 10-

minute injection time is required by NFPA guidelines for the indoor tank. All "hazard areas" have some excess foam storage capacity and this permits from 5

to 11 extra minutes of foam injection depending on the "hazard area." The foam systems do not require electricity in order to be operated.

Each "hazard area" is provided with a local control cabinet to which all electrical equipment for that "hazard area" is connected. The following

outputs to the control room are provided:a.hazard area "fire," and b.hazard area "trouble" (the trouble condition may include detection circuit failure, loss of power, or isolation valve

closed).The local cabinet also provides contacts for the local area fire alarms.

Whenever any of the above conditions occur, the control room audible and

visual alarms are activated.

The foam system is tested in accordance with NFPA utilizing operating surveillances.

A5.4-8 B/BAMENDMENT 13 DECEMBER 1990 In the event that the operators decide to let the foam system operate for an extended period on a fire the foam system will continue injecting foam into or

onto the fire until it is exhausted. After the foam is exhausted, water

continues being injected onto the foam blanket in the same manner as a deluge

system.Specific data on each foam system can be found on the installation drawings kept at the stations. Test data for these systems can also be found on file

at the stations.

A5.4-9 B/BAMENDMENT 28 DECEMBER 2018 A5.4.5 HALON 1301 SYSTEMS Automatic Halon systems have been provided for the upper cable spreading areasand the QA vault. Both systems are actuated by ionization (or photoelectric) detectors. The upper cable spreading rooms have a train both of ionization (or photoelectric) and thermal detectors.

An automatic Halon system has been chosen as the primary fire suppression agent for the upper cable spreading areabecause of possible water damage to

control room panels from leakage through floor penetrations.

Halon has been selected as the primary extinguishing agent for the QA vault because of the distance from the CO 2 storage tanks. Halon is less toxic than C0 2 in the concentrations required and there is no damage to records and furniture in the rooms which are not affected directly by the fire as there

would be by using a deluge or sprinkler system.The Halon supply for the upper cable spreading area is located at about L-23 on elevation 468 feet 4 inches and at H.9-45 on elevation 433 feet 0 inch for

the QA vault.

Operation of both Halon systems is identical. If actuated automatically, an electrical signal is sent to a solenoid valve which releases the Halonfrom a

storage cylinder into the manifold header. In the case of the QA vault, all

the Halon is then discharged through the distribution nozzles onto the fire.

For the upper cable spreading area system, only the solenoid valves of the cylinders assignedto the subject fire area are actuated.

The Halon then enters the manifold piping where it passes through the actuated deluge valve of the subject fire area and onto the fire. At Byron, the Halon supply for the cable spreading areas is sized only for thelargest hazard. A

reserve supply for either system is not provided. At Braidwood, the Halon

supply is sized to provide double shot protection, and there is no extended

discharge feature.In response to a staff concern regarding potential adverse effects of active component failures on the automatic Halon primary suppression system for the

upper cable spreading areas, the applicant has modified the system to provide

resistance to single failures. The modifications made consist of the following changes. Additional detectors were added to provide two separate

detection circuits. These circuits are designed that, under normal

conditions, both circuits have to sense a fire in order to initiate the automatic suppression. Each circuit independently annunciates a fire

detection (and circuit trouble) in the control room. If either circuit has a

break or ground fault in one of the signalling line circuits, the remaining

circuit could automatically activate the fire suppression system if a fire was

present. A second train of actuation logic was added in parallel to the

existing logic train. The Halon bottle discharge valve actuators which

consisted of a single pilot valve were replaced with a pair of pilot valves, each connected to one of the two trains of actuation logic, and either of

which can actuate the Halon bottle discharge valve. Additional zone discharge

valves were added so that each cable spreading area has two parallel zone

discharge valves to direct Halon from the discharge manifold to the zone A5.4-10 B/BAMENDMENT 21 DECEMBER 2004 distribution piping. Additional Halon bottles were provided to add redundancy to the Halon supply and to provide an increase in the duration of the design level concentration. For all zones, one additional bottle will be initially

discharged to insure an adequate concentration in the event of a failure of

one bottle to discharge. At Braidwood, the Halon system is designed for

double shot protection. The second shot occurs automatically based on testing

done prior to putting the system in operation. With these changes, the

reliability of the automatic Halon suppression system will be significantly

enhanced. A single failure of principle active components and subsystems of the fire detection and suppressionsystem can now be tolerated without loss of

function.The QA vault Halon system may be operated by a manual electric pushbutton station which is located near the hazard area. In case of electrical failure, either system may be actuated manually at the bottles by pulling the manual

release lever on each bottle and manually activating the control valve at the

selector valve.

Specific data on the Halon systems can be found on the installation drawings kept at the stations.One local control cabinet has been provided for the QA vault. Two local control cabinets have been provided for each upper cable spreading area.

Each local control cabinet has a white "power on" indicating light.

All electrical equipment used in the fire protection system for the hazard area is wired to the local cabinet.

Each local cabinet provides outputs for each of the following conditions to the control room: hazard area "fire" and hazard area "trouble" (the trouble condition includes failure of the automatic detection system, loss of power, or failure of the electrical actuation system).

Pre-discharge alarms are provided locally for the Upper Cable Spreading rooms and the Byron plant simulator. Pre-discharge timers delay the discharge to allow personnel time to leave the area. Egress time from the QA Records Vault is less than 60 seconds, no pre-discharge alarm is provided.

Each Halon system is tested periodically by subjecting each system to a "puff" test in accordance with NFPA guidelines.Preoperational and surveillance test data for these systems can be found on file at the stations.

A5.4-11 B/BAMENDMENT 28 DECEMBER 2018 A5.4.6 CARBON DIOXIDE (CO

2) SYSTEM The CO 2 system receives bulk deliveries of liquid carbon dioxide. It is stored in a temperature controlled CO 2 storage unit. Carbon dioxide is supplied from this storage unit to the C0 2 fire protection systems and for purging hydrogen from the main generators when the generators are shut down.The Cardox storage unit contains a cylindrical all welded, steel storage tank and a refrigeration unit. The storage tank is enclosed in a steel shell. It

is insulated and has a capacity of 10 tons. The working pressure of the tank

is 300 psig.The refrigeration unit consists of a refrigerating coil running lengthwise, near the top, inside the storage tank, and a compressor. The refrigerating

unit cools the liquid carbon dioxide to 0

!F to maintain a pressure between 295 and 305 psig.The temperature is automatically controlled by a pressure switch onthe Cardox unit. As the temperature of the carbon dioxide rises the pressure increases.

When the pressure increases to 305 psig, the pressure switch starts the

refrigerating unit. The unit continues to run until the pressure drops to 295

psig, then the pressure switch trips the refrigerating unit off. If the

pressure drops to 275 psig, an alarm sounds in the control room.

The Cardox storage unit is protected against overpressure by a bleeder relief valve that opens at 341 psig. If this valve malfunctions, two pop-off valves

open at 357 psig. The cardox storage unit would become overpressurized if the

refrigerating unit malfunctions, permitting the carbon dioxide temperature to rise, thus increasing the pressure. In addition to these safety valves, the

Cardox storage unit has a rupture disc that breaks open at 600 psig, releasing

all of the liquid carbon dioxide. A pressure gauge is mounted on the Cardox

unit to display tank pressure.The Cardox storage unit is located inside the turbine building, atelevation 401 feet 0 inch. This is on the ground level, between columns 16 and 18 and

rows K and L.

The fill pipe and equalizing pipe run from the Cardox unit to the 401 Unit 1 Turbine Building Trackway J-3, terminating in a Cardox transport truck hose

connection.

A 4-inch line leaving the Cardox storage unit supplies carbon dioxide to the fire protection systems. Carbon dioxide flow out of this line is controlled

by a master pilot control, mounted on the Cardox storage unit. The master pilot controlsoperate the master valve on the supply line. A 1-1/2-inch C0 2 supply line supplies carbon dioxide to the C0 2 vaporizer in the C0 2 generator hydrogen purge system for Units 1 and 2.The installed carbon dioxide suppression system in the Upper Cable Spreading Rooms and Byron and Braidwood is a manually actuated back-up system to the

automatic halon system. These systems were originally designed in the late

1970s to have a 50% concentration with a 10 minute holding time based on NFPA Standard No. 12-1977 (NFPA Fire Codes -1978 Edition). During the licensing

process, the stations committed to later editions of NFPA 12, which required a

50% concentration with a 20 minute holding time.

A5.4-12 B/BAMENDMENT 28 DECEMBER 2012 Since the installed systems were not provided with extended discharge piping, pre-operational testing verified that the systems were capable of meeting the

50% concentration with a 10 minute holding time. In order to satisfy the 20 minute holding time, the station proceduresfor the manual actuation of the

back-up systems for these zones were revised to require an additional

actuation after the initial 10 minute holding period. The system design, confituration, pre-optesting, and operating procedures were all reviewd by theFire Protection Consultant (M&MPC), and were found to be acceptable.

Automatic initiation of the Cardox system is accomplished by Fenwal rate compensated detectors in areas other than cable spreading and cable tunnel areas, and by both ionization(or photoelectric)and Fenwal type compensated detectors in the cable spreading and cable tunnel areas.

A5.4-12a B/BAMENDMENT 17 DECEMBER 1996 Local pushbuttons adjacent to the CO 2 protected rooms provide manual electrical control for testing purposes, or to initiate the CO 2 in an emergency if thermostats should fail to actuate the CO 2 system.In case of electrical failure, local electromanual pilot cabinets (EMPC) are provided for each protected room and at the mainstorage tank, which permit

manual initiation of the system.

In response to an NRC concern, this system has been modified as described below to improve the reliability of the system for the lower cable spreading

rooms.The active components in the systemare the tank and zone discharge valves.

Redundant tank and zone discharge valves were provided. The new valves and

associated equipment are UL listed. The modifications were implemented in accordance with NFPA 12. A redundant zone discharge valve is provided for the

initial discharge line only. Redundant extended discharge valves are not

required because the capacity of the storage tank is such that multiple shot

capacity is provided for even the largest hazard zones, providing adequate redundancy forthe zone discharge valves.

At Byron, the new tank discharge valve is manually actuated by a lever on the EMPC, which is located near the Cardox storage unit. The new zone discharge valves are also manually actuated by a lever on the appropriate EMPC. The new

zone discharge valve EMPCs are located near the hazard zones they protect.

These new valves are expected to be used only in the event of failure of the

normal tank or zone discharge valves.At Braidwood, the new tank discharge valve has two modes of operation: 1) it has manual pushbuttons located near each lower cable spreading room which it

protects which will electrically operate its EMPC; and 2) it can be manually

actuated by a lever on the EMPC. The new zone discharge valves are only operableby a manual lever on the EMPC, since they are located near the hazard

zones which they protect. These new valves are expected to be used only in

the event of failure of the normal tank or zone discharge valves.A manual abort system is provided for eachautomatic total flooding area. Theabove consist of a supervised 1/4-inch Jamesbury ball valve on the pilot line

and a "deadman" toggle switch. The toggle switch holds the predischarge timer so that a person may enter a room for an abbreviated survey ofthe area before

the system discharges. Once the CO 2 discharge has begun, it cannot be aborted except by shutting off the tank gate valve. The ball valve may be used to

positively prevent any discharge from occurring in the subject hazard area;

however, it cannot stop a discharge that has already begun. The ball valve

will be used whenever maintenance personnel will be present in an area for an

extended period of time.Areas protected by carbon dioxide are listed in Tables A5.4-1. Specific data on eachcarbon dioxide system can be found on the installation drawings kept

at the stations.

Local control cabinets are provided by Cardox for each hazard area. Each cabinet has the following indicating lights:

A5.4-13 B/BAMENDMENT 17 DECEMBER 1996a.Red "fire" light,b.White "power on" light, and c.Amber "trouble" lights.

The "trouble" lights are used to indicate trouble with the following supervised items. Amber lights are used for:a.thermostats, b.remote pushbutton switches, c.local hazard alarms, d.discharge valve solenoid, and e.lock-out valve closed.

The local control cabinet furnishes the following output signals to the control room:a.hazard area trouble, b.hazard area fire, and c.contacts for hazard area alarms.

For each hazard area, audible and visual alarms are provided in the control room to indicate "fire" and "trouble" for the C0 2 system.The CO 2storage unit is operated off the 480-V distribution system. The electrical actuation and detector circuitsfor the fire protection systems are supplied with power from the 125-Vdc distribution system except the cable spreading room and cable tunnel detector circuits which are fed from 120-Vac (ESF). In case of a bus failure, l25-Vdc battery power supply will be

utilized for the 125-Vdc distribution system, and power supplied by the diesel generator will supply power to the l2-Vac ESF circuits. If this should fail, the CO 2 system may be actuated manually by the electromanual pilot cabinets at each protection area.The Byron river screen house also contains a 2-ton carbon dioxide storage tank. Its features are identical to the 10-ton unit except that 3-inch gate

valves, master valves, and selector valves are used. Electrical accessories

are also identical to the main system.

Preoperational and surveillance test data for these systems can be found on file at the stations.

A5.4-14 B/BAMENDMENT 26 DECEMBER 2014 A5.4.7 MANUAL EXTINGUISHING CAPABILITYThis section deals with the manual hose stationsand portable extinguishers provided for Byron and Braidwood.

Figure M-52, Sheets 11 and 12, gives the locations and important physical data on the hose stations. All hose stations except in the cable spreading areas are equipped with a minimum of 50 feet of 1-1/2-inch nylon jacket rubber hose.

Class ABC nozzles are provided in all areas except the fuel handling building

which are Class A only. Hose stations located in the upper and lower cable spreading areas are provided with a minimum of 50 feet of hard rubber hose and

Class ABC nozzles. This figure represents the final design of the hose

stations, although hose stations may be added or moved as work progresses.

Interior hose stations have been placed so that all areas of the plant except portions ofthe steam and feedwater tunnels and the River Screen House can be

reached by at least one hose station.

Portable extinguishers have been placed in accordance with NFPA 10 and additionally as necessary. In some areas, fire extinguishers with a lower

rating than that required by NFPA 10 are utilized. This is due to more

stringent UL testing criteria that reduces previous ratings of fire

extinguishers. The NFPA 10 standards did not change to accommodate these new UL ratings. By reducing the rating of theextinguisher, the maximum allowable

square foot coverage per extinguisher per NFPA 10 was also reduced. The

change in UL testing criteria affects fire extinguishers purchased on or after 02/14/2011. The use of the revised UL rated 6A fire extinguisher in place of

an original UL rated 10A fire extinguisher is acceptable. Fire extinguishers

that are rated 6A per the revised UL standard are considered to be equivalent

to fire extinguishers that were rated 10A per the previous UL standard.

Reference EC/Eval 392896 for supporting details.

Portable extinguishers have been identified with a number and an approximate location is known. Quantities and types of extinguishers have been

determined. Expected locations of portable extinguishers are shown on the

Figure M-58, Sheets 5 and 6, which are included with the report.

Hose stations in the Byron Circulating Water Pump House and the Braidwood Lake Screen House are supplied with water directly from the fire pumps.

A5.4-15 B/BAMENDMENT 28 DECEMBER 2018 A5.4.8 FIRE DETECTION SYSTEM DESCRIPTION Separate fire detection systems are provided for Units 1 and 2. The system for each unit consists of ionization(or photoelectric), ultraviolet and thermal detectors located in specific fire zones throughout the plant as

listed in Table 2.2-3. The detectors and the control equipment used in the

fire detection system are supplied or approved by Alison Control, Inc., and

are Factory Mutual approved.The design of the fire detection system generally meets the requirements for aClass B proprietary protective signalling system as defined in NFPA 72D-1975.

Both audible and visual alarms are provided in the main control room for each zone of the fire detection system. Each zone has visual indication for zone "FIRE" and zone "TROUBLE." The system is electrically supervised in

accordance with the requirements of NFPA 72D and is connected to the plant

emergency power supply. In addition, the local fire detection panels 1PA39J, 1PA49J, 2PA39J, and 2PA49J are provided with battery-backed uninterruptible

power supplies. Fire detectors are installed in accordance with the

requirements of NFPA 72E.

The fire detection circuits associated with automatic fire suppression systemsprotecting areas which contain equipment or cables which perform a safety-related function (the Carbon Dioxide System, the water-foam system, and the

Halon system) include the upper and lower cable spreading rooms, the cable tunnel, the diesel oil tank rooms, and the diesel-generator rooms are Class A

supervised circuits. The fire detection circuits in the upper and lower cable

spreading rooms and electrical cable tunnels have been modified to provide two

cross-zoned Class B supervised circuits. Each detection circuit provides an

independent alarm of a fire (or circuit trouble) to the control room. The

circuits are designed that if either of the circuits has a break or a ground

fault in one of its signalling line circuits, the remaining circuit can then

automatically actuate the fire suppression systems if a fire was present. A

circuit arrangement of this type satisfies the redundancy requirement of Class

A circuits in that a fire alarm signal will still be annunciated in the control room even if one assumes a single break or ground fault in one of the

signalling line circuits.

Figure A5.4-2 provides a typical schematic arrangement for the fire detection of each fire zone in the cable spreading rooms.In addition to the system described previously, ionization(or photoelectric) detectors are installed in ventilation ducts. These detectors alarm and annunciate in the main control room. The air duct detector units are manufactured by Pyrotronics (or United Technologies Corporation) and are Factory Mutual approved.

A5.4-16 B/B AMENDMENT 28 DECEMBER 2018 TABLE A5.4-1 FIRE PROTECTION MATRIX FIRE DENSITY ORZONEPRIMARY PROTECTIONBACKUP PROTECTIONFIRE DETECTIONCONCENTRATIONCOMMENTS1.1-1Portable extinguishersHose stationsHeat1.1-2Portable extinguishersHose stationsHeat1.2-1Portable extinguishersHose stationsIonization(or photoelectric)1.2-2Portable extinguishersHose stationsIonization(or photoelectric)1.3-1Manual deluge systemHose stationsTemperature SwitchDeluge system abandoned on for charcoal units(Byron only)in Charcoal AdsorberBraidwood Unit 1 Portable extinguishersBank(Byron only)

(See Comment 5)Ionization(or photoelectric)1.3-2Portable extinguishersHose stationsTemperature SwitchDeluge system abandoned(See Comment 5)in Charocal Adsorberon Byron and Braidwood Unit 2Bank(Byron only)

Ionization(or photoelectric)2.1-0Portable extinguishersHose stationsIonization(or photoelectric)2.1-1Portable extinguishersHose stationsIonization(or photoelectric)2.1-2Portable extinguishersHose stationsIonization(or photoelectric)3.1-1Automatic CO 2 Hose stations 3.1-2and portableextinguishersSee Comment 150%1.The ionization and Fenwal thermal detectors

are cross-zoned to re-3.2-0Portable extinguishersHose stationsIonization(or photoelectric)quire both an ionization and a heat detection of3.2A-1Automatic CO 2Hose stations a fire to actuate the auto-3.2A-2and portable matic fire suppression system.extinguishersSee Comment 150%Each detection zone provides an independent alarm of a

fire (or detector trouble) to3.2B-lAutomatic CO 2Hose stations the main control room. The3.2B-2and portable circuits are designed thatextinguishersSee Comment 150%if either of the circuits has a break or a ground fault in3.2C-lAutomatic CO 2 Hose stations one of the signalling line 3.2C-2and portable circuits, the remaining extinguishersSee Comment 150%detection circuit could then automatically actuate the3.2D-1Automatic CO 2 Hose stations fire suppression system if3.2D-2and portable a fire was present.extinguishersSee Comment 150%

A5.4-17 B/B AMENDMENT 28 DECEMBER 2018 TABLE A5.4-1 (Cont'd)

FIRE DENSITY ORZONEPRIMARY PROTECTIONBACKUP PROTECTIONFIRE DETECTIONCONCENTRATIONCOMMENTS3.2E-1Automatic CO 2 Hose stations3.2E-2andportableextinguishersSee Comment 150%3.3A-1Halon 1301Manual CO 2, See Comment 16% Halon3.3A-2Manual deluge systemportable extin-50% CO 2for charcoal unitsguishers, hose (See Comment 5)stations3.3A-1Halon 1301Manual CO 2,See Comment 16% Halon3.3A-2portable extin-50% CO 2 guishers, hose

stations3.3B-1Halon 1301Manual CO 2,See Comment 16% Halon3.3B-2portable extin-50% CO 2 guishers, hose

stations3.3C-1Halon 1301Manual CO 2,See Comment 16% Halon3.3C.1portable extin-50% CO 2 guishers, hose

stations3.3D-lHalon 1301Manual CO 2,See Comment 16% Halon3.3D-2portable extin-50% CO 2 guishers, hose

stations3.4A-1Portable extinguishersHose stationIonization(or photoelectric) ---

3.4A-2 4.1-1Portable extinguishersHose stationIonization(or photoelectric) ---4.1-2Portable extinguishersHose stationIonization(or photoelectric) ---5.1-1Portable extinguishersHose stationsIonization(or photoelectric) ---

5.1-2 5.2-1Portable extinguishersHose stationsIonization(or photoelectric) ---

5.2-2 5.3-1Portable extinguishersHose stationsIonization(or photoelectric) ---

5.3-25.4-1Portable extinguishersHose stationsIonization(or photoelectric) ---

5.4-25.5-1Portable extinguishersHose stationsIonization(or photoelectric) ---

5.5-2 A5.4-18 B/B AMENDMENT 28 DECEMBER 2018 TABLE A5.4-1 (Cont'd)

FIRE DENSITY ORZONEPRIMARY PROTECTIONBACKUP PROTECTIONFIRE DETECTIONCONCENTRATIONCOMMENTS5.6-1Portable extinguishersHose stationsIonization(or photoelectric) ---

5.6-27.1-1Hose stationsPortable extin-Ionization(or photoelectric)7.1-2guishers(Braidwood) ---

8.1-0AutomaticsprinklersHose stations andFusible links on0.3 gpm/ft 22.Density is 0.3 gpm/portable extin-sprinkler headsft 2 per any 3000guishersIonization(or photoelectric)ft 2 area and 0.2(Byron only)gpm/ft 2 for any 10,000 ft 2 area.8.2-1Automatic sprinklersHose stations andFusible link onSee Comment 2 8.2-2portable extin-sprinkler heads guishers8.3-1Automatic sprinklersHose stations andFusible linksSee Comment 23.The deluge sys-8.3-2Automatic deluge (6)portable extin-sprinkler headstem is provide guishers for the turbine bearings only,8.4-1Automatic sprinklersHose stations andFusible link0.3 gpm/ft 2 and is actuated8.4-2portable extin-sprinkler headsby rate-compensating guishers detectors.8.5-1Automatic sprinklersHose stations andRate compensatedSee Comment 28.5-2Automatic deluge (4)portable extin-detectorsguishersUltraviolet (Byron)8.6-0Automatic deluge (3)Hose stationsNone (Braidwood)4.The deluge systemManual deluge (5)Ultraviolet (Byron)is for the hydro-Portable ExtinguishersTemp. switch ingen seal oil units Automatic Sprinklers (7)Charcoal bankonly and is actu-ated by rate com-

pensated detectors.8.7A-0Automatic sprinklerHose stations andFusible link8.7B-0Automatic sprinklerportable extin-sprinkler heads7.The automatic sprinkler system Is provided for the Operator

Ready room. Density is 0.10

Gpm/ft 2 per any 900 ft 2 area.guishers9.1-1Automatic CO 2Portable extin-Rate compensation 34%9.1-2guishers and hoseultraviolet stations9.2-1Automatic CO 2Portable extin-Rate compensation 34%6.The deluge system9.2-2guishers and hoseultravioletisfor the Turbine stations oil storage Tank Room and is actuated9.3-1Automatic CO 2Portable extin-Rate compensation 34%by rate compensated9.3-2guishers and hose detectors.stationsA5.4-19 B/BAMENDMENT28 DECEMBER 2018 TABLE A5.4-1 (Cont'd)

FIRE DENSITY ORZONEPRIMARY PROTECTIONBACKUP PROTECTIONFIRE DETECTIONCONCENTRATIONCOMMENTS9.4-1Automatic CO2Portable extin-Rate compensation 34%

9.4-2guishers and hose stations10.1-1Foam (Manual)Portable extin-Rate compensated .16 gpm/ft 2guishers and hosedetectorsstationIonization (or photoelectric)(Byron)10.1-2Foam (Manual)Portable extin-Rate compensating .16 gpm/ft 2guishers and hose Ionization (or photoelectric)(Byron) station10.2-1Foam (Manual)Portable extin-Rate compensating .16 gpm/ft 2guishers and hoseIonization (or photoelectric)(Byron) station10.2-2Foam (Manual)Portable extin-Rate compensating.16 gpm/ft 2guishers and hoseIonization (or photoelectric)(Byron) station11.1A-0Portable extinguishersHose stationsIonization(or photoelectric) ---

11.1B-011.2-0Portable extinguishersHose stationsIonization(or photoelectric) ---11.2A-1Portable extinguishersHose stationsIonization(or photoelectric) ---

11.2A-2 11.2B-1Portable extinguishersHose stationsIonization(or photoelectric) ---

ll.2B-2 11.2C-1Portable extinguishersHose stationsIonization(or photoelectric) ---

11.2C-2 11.2D-1PortableextinguishersHose stationsIonization(or photoelectric) ---

11.2D-2 11.3-0Portable extinguishersHose stationsIonization(or photoelectric) N/AThe sprinklers cover and automatic sprinklers the component cooling pumps and stairway.11.3-1Portable extinguishersHose stationsIonization(or photoelectric) N/ASprinklers protect11.3-2and automatic sprinklers pipe penetrations.11.3A-1Portable extinguishersHose stationsIonization(or photoelectric) ---

11.3A-2 A5.4-20 B/B AMENDMENT 28 DECEMBER 2018 TABLE A5.4-1 (Cont'd)

FIRE DENSITY ORZONEPRIMARY PROTECTIONBACKUP PROTECTIONFIRE DETECTIONCONCENTRATIONCOMMENTS11.3B-1Portable extinguishersHose stationsNone ---

11.3B-211.3C-1Portable extinguishersHose stationsIonization(or photoelectric) ---

11.3C-2 11.3D-1Portable extinguishersHose stationsIonization(or photoelectric) ---

11.3D-2 11.3E-1Portable extinguishersHose stationsNone ---

11.3E-211.3F-1Portable extinguishersHose stationsIonization(or photoelectric) 11.3F-2 11.3G.1Portable extinguishersHose stationsIonization(or photoelectric) ---

11.3G.2 11.4-0Portable extinguishersHose stationsIonization(or photoelectric) N/A Automatic sprinkler Automatic sprinkler cover stairway hatch.ll.4A-0Portable extinguishersHose stationsIonization(or photoelectric) ---11.4A-1Automatic CO 2Portable extin-Rate compensation 34%11.4A-2guishers and hoseIonization (or photoelectric)Byron stations11.4B-0Portable extinguishersHose stationsNone ---

11.4B-1Portable extinguishersHose stationsNone ---

ll.4B-211.4C-0Portable extinguishersHose stationsIonization(or photoelectric) ---11.4C-1Portable extinguishersHose stationsNone ---

11.4C-211.4D-1Portable extinguishersHose stationsNone ---

11.4D-211.5-0Portable extinguishersHose stationsIonization(or photoelectric) N/ASprinklers protect Automatic sprinkler stairway and hatch and waste oil tank.11.5-1Portable extinguishersHose stationsIonization(or photoelectric) ---

11.5-2 11.5A-0Portable extinguishersHose stationsNone-Byron ---

Ionization-Braidwood A5.4-21 B/BAMENDMENT28 DECEMBER 208 TABLE A5.4-1 (Cont'd)

FIRE DENSITY ORZONEPRIMARY PROTECTIONBACKUP PROTECTIONFIRE DETECTIONCONCENTRATIONCOMMENTS11.5A-1Portable extinguishersHose stationsIonization(or photoelectric) ---

11.5A-211.5B-1Portable extinguishersHose stationsIonization(or photoelectric) ---11.5B-2Portable extinguishersHose stationslonization(or photoelectric) ---11.6-0Portable extinguishersHose stationsIonization (or photoelectric) N/ASprinkler protect Automatic sprinkler ---stairway and hatch.11.6-1Portable extinguishersHose stationsIonization(or photoelectric) ---

11.6-2 11.6A-0Portable extinguishersHose stationsIonization(or photoelectric) ---11.6A-1Portable extinguishersHose stationsNone ---

11.6A-2 11.6B-0Portable extinguishersHose stationsNone ---11.6C-0Portable extinquishersHose stationsNone-Byron Ionization-Braidwood ---11.6D-0Portable extinguishersHose stationsIonization(orphotoelectric) ---11.6E-0Portable extinguishersHose stationsIonization(or photoelectric) ---11.7-0Manual delugeHose stations andTemp. switch in N/A5.The deluge system(See Comment 5)portable extin-charcoal bank;is provided forguishersIonization(or photoelectric)the charcoal filters only manually actuated.11.7-1Hose stationsPortable extin-Temp. switch in N/Aguisherscharcoal bank;11.7-2Manual deluge (5)Portable extin-Ionization(or photoelectric) guisher12.1-0Hose stationsPortable extin-Ionization(or photoelectric) ---

guishers13.0-0Automatic HalonHose stations andIonization(or photoelectric) 5%

portable extin-guishers14.1-0Hose stationsPortable extinguishersNone ---

14.2-0Hose stationsPortable extinguishersNone 14.3-0Hose stationsPortable extinguishersNone A5.4-22 B/B AMENDMENT 28 DECEMBER 2018 TABLE A5.4-1 (Cont'd)

FIRE DENSITY ORZONEPRIMARY PROTECTIONBACKUP PROTECTIONFIRE DETECTIONCONCENTRATIONCOMMENTS14.4-0Hose stationsPortable extinguishersNone14.5-0Hose stationsPortable extinguishersNone 14.6-0Partial automaticHose stations andIonization(or photoelectric) N/AsprinklersPortable extinguishersTemp. switch inManual deluge (5)charcoal bank16.1-1Hydrants ---None ---

16.1-216.2-1Hydrants ---None 16.2-217.1-0 --- ---None ---Not required17.1-1Hydrants ---None ---

17.1-2(Byron only) ------ ---17.2-1Hydrants ---None ---17.2-2(Byron only)18.1-1Hose stationsPortable extinguishersIonization (or photoelectric)n ducts ---

18.1-2 18.2-1Hose stationsPortable extinguishersIonization(or photoelectric)in ducts ---

18.2-2 18.3-1Portable extinguisherHose stationIonization(or photoelectric) ---

18.3-2 18.4-1Portable extinguisherHose stationIonization(or photoelectric) N/AOver charcoal18.4-2Manual deluge (5)Temp. switch infilters charcoal bank18.5-1Portable extinguishersHose stationsNone ---18.5-2Portable extinguishersHose stationsIonization(or photoelectric) ---18.6-0Automatic sprinklersPortable extin-Fusible link.2 gpm/ft 2inFor the storeroom andguishersand sprinkler headsstoreroom andpaint and oil room hose stations.3 gpm/ft 2inonly.paint and oil

room18.7-0Portable ExtinguishersHose stationsNone A5.4-23 B/B AMENDMENT 28 DECEMBER 2018 TABLE A5.4-1 (Cont'd)

FIRE DENSITY ORZONEPRIMARY PROTECTIONBACKUP PROTECTIONFIRE DETECTIONCONCENTRATIONCOMMENTS18.8-0Portable ExtinguishersHose stationsNone18.9-0Portable extinguishersHose stationsNone ---

18.10A-1 18.10B-1 18.10C-1Automatic and manualHydrantsThermistor wire, Manual deluge from 18.10D-1delugesudden pressurethermistor, auto-18.10E-1switch, dif-matic deluge from18.10F-1ferential relay relay 18.10A-2 18.10B-218.10C-2Automatic and manualHydrantsThermistor wire,Manual deluge from18.10D-2delugesudden pressurethermistor, auto-18.10E-2switch, dif-matic deluge from 18.10F-2ferential relayrelay18.11-0Automatic C0 2Ionization(or photoelectric) 34%For oil tank room and(Byron)Portable extin-ESW makeup pump guishers area18.11-0Local Fire DepartmentPortable extinguishers Ionization(or photoelectric) ---(Braidwood)

Ultraviolet18.11-1Automatic CO 2Por-Rate of rise18.11-2table extinguishers (Byron only)18.12-0Hose stationsPortable extin-Ionization(or photoelectric)-B/Bguishersand ultra-violet (Braidwood)18.13-0Automatic sprinklersHose stations andFusible link.2 gpm/ft 2portable extin-sprinkler headsguishersIonization (or photoelectric)(Byron)18.14A-1Hose Stations ---Ionization(or photoelectric) ---(Byron) 18.14A-2Hose Stations ---Ionization(or photoelectric) ---18.14B-1Hose Stations ---Ionization(or photoelectric) ---(Byron)18.14B-2Hose Stations ---Ionization(or photoelectric) ---(Byron)A5.4-24 B/B AMENDMENT 25 DECEMBER 2012 TABLE A5.4-1 (Cont'd)

FIRE DENSITY ORZONEPRIMARY PROTECTIONBACKUP PROTECTIONFIRE DETECTIONCONCENTRATIONCOMMENTS18.15-0Hose stationsPortableNone --- (Braidwood)extinguishers18.16-1HydrantsDikes None ---

18.16-218.17-0Hydrants ---None ---

There is no Zone 18.18-018.19-0HydrantsDikesNone ---

18.20-0Hydrants Dikes --- ---18.22-0Hose stations ---None ---

(Byron)18.23-0Hydrants ---None ---

18.24-0Hose stationPortableNone ---

extinguishers18.25-1Hose stations ---None ---18.25-2Hose stations ---None ---18.26-0Hose stations ---Temp switch in N/AManual Deluge(5)charcoal bank18.27-0Hose stations ---None ---

18.28-0Overhead sprinklerHose stationsNone N/AProtects waste(partial coverage)Fire Hydrants oil tank18.29-0Fire hydrantsPortableNone ---

extinguishers18.30-0Fire hydrants ---None ---

18.31-0Fire hydrant ---None ---

18.32-0Automatic sprinklerPortable extinguisherNone0.33 gpm/ft 2 (0.39 gpm/ft 2and hose stationsfor warehouse addition on south side of warehouse -

Byron only)

A5.4-25 B/B AMENDMENT 28 DECEMBER 2018 TABLE A5.4-1 (Cont'd)

FIRE DENSITY ORZONEPRIMARY PROTECTIONBACKUP PROTECTIONFIRE DETECTIONCONCENTRATIONCOMMENTS18.33-0Hose stationsFire hydrantsNone ---

18.34-0Fire hydrant ---None ---18.35-0Hose stationsPortable extinguishersIonization(or photoelectric) ---18.36-0None ---None ---

A5.4-25a B/BAMENDMENT 20 DECEMBER 2002 TABLE A5.4-2 FIRE PUMP DATA MOTOR-DRIVEN FIRE PUMPSHorsepower -350 Voltage, phase, frequency -4160-V, 3-phase, 60 Hz PumpStages -4 gpm -2500 Labeled lead -388 feet Code -NFPA 20 Approval authority -UL DIESEL-DRIVEN FIRE PUMP Pump Same as motor-driven A5.4-26 B/BAMENDMENT 23 DECEMBER 2008 GEAR REDUCERType -right angle Ratio -1:1 Coupling -Watson-Spicer Diesel Engine Manufacturer - Cummins Engine speed - 1760 rpm Number of cylinders -12

Displacement - 1710 in 3Cycles -4 Horsepower (max. continuous) -522 hp Starting signal to fullload 15 seconds Fuel consumption:Component Demonstration: 0.29 gpm.

Manufacturer's Normal: 0.47 gpm.

Manufacturer's Maximum: 0.55 gpm.

Note: Fuel consumption data based on original vendor information. Fuel consumption may be slightly higher (1%) as a result of changes in diesel fuel

to Ultra Low Sulfur Diesel fuel. Sufficient excess capacity exists in the day

tank storage requirements to account for the change in consumption.Lube oil capacity -75 quarts JOCKEY PUMPS(2)

Motor A5.4-27 B/BAMENDMENT 20 DECEMBER 2002 TABLE A5.4-2 (Cont'd)Horsepower -15 hpVoltage, phase, frequency -460-V, 3-phase, 60 Hz PumpStages -21rpm -1800 gpm -100 Labeled head -335 feet A5.4-28 Protected Area Selector Valve lsolahon Gate Valve Master Valve at C0 2 Stora11e Tank C0 2 Storage Tank Byron/Braidwood Power Slahons-Untl 1 C1rcu1t Arrangement for Detection and Suppression Systems located in buildings containing safety-related equipment Switch S I I I (A)-Class A Electrical Superv1s1on (8)-Class B Electrical Superv1s1on Main Control Board 1PM09J -----, I I E I I ;i I Ionization D (B) Delectors

, .! I El LL I Ionization Detectors (See Figure 2) D (B) ====================-i (B) I I +

  • I I I I I I Water Supply Fire/Trouble Alarm ________________

...,.. I I I I I I Fire Prot Sys Pwr Dist Cab Fire Protection Input and Detection Control Cabinets 1PA39J, 40J, 49J Local Fire A I I I A I I I (B) Detectors O-----....

Protection

___ J I sot a hon Gate Valve Alarm Check Valve , __ .---s-... Pressure Switch To Diesel 011 Stor Tank Rooms (Byron & Braidwood)

Pressure Sw1lch Cabin els Deluge Valve t I I I I I I I I I I Electro-I I 1 I I T Manual Piiot Cab. I I Electro-L__ D Manual Local C0 2 --1 Manual ----Control Stallons I Pilot Cab. Cabinet -fl I '----...-----'-(A)-;r(ii)

LJ Detectors L _____________

J I Fire/Trouble Alarm I I I I I I _________________ ) Fire/Trouble Alarm Local Fire -]:(B)---0 Detectors Protection cabinets Manual Sta hons Fire/Trouble Alarm t I '-----------------*

I I s (B) Detectors 0-----,...

Local Fire Manual D Station ----Pressure Switch s /1------Isolation Gate Valve Foam Tank Pro! Deluge Viv Cont Cab I I I 1.----s __, _J .__.,.. Deluge Valve I L-------*

L ____ _ To Nozzles lsolal1on Gate Valve Water Supply Deluge Valve AMENDMENT 25 Halon Storage Supply BYRON/BRAIDWOOD STATIONS FIRE PROTECTION REPORT ..t:ilfil:

1. nus FIGURE IS PROVIDED FOR REFERENCE ONLY ANO IS INTENDED TO PROVIDE A GENERAL. HIGH LEVEL REPRESENTATION OF THE PLANT FIRE PROTECTION FEATURES ANO FIRE HAZARDS. THESE FIGURES ARE NOT INTENDED TO PROVIDE SPECIFIC DETAILS FOR FEATURES SUCH AS FIRE BARRIERS, DETECTORS, HOSE STATIONS, FIRE EXTINGUISHERS ANO SUPPRESSION SYSTEM COVERAGE.

APPLICABLE DESIGN DRAWINGS AND DOCUMENTS SHOULD BE REVIEWED FOR SPECIFIC DESIGN DETAILS, INCLUDING LOCATION OF EQUIPMENT.

FIGURE A5 4-1 UNil l FIRE PROTECTION SYSTEM SINGLE LINE DIAGRAM CIRCUIT I IONIZATION DETECT I ON FFIREALARM CONTACT (SHOWN IN THE ABSENCEOFA FIRE)TTRDUBE~CONTACT (SHOWN IN TROUBLE CONDITION)

REND OF INE RESISTOR 1/2 PA39J AMENDMENT 12 DECEMBER1989~CIRCUIT 2 fENWAL RATE COMPENSATED HEAT DETECT I ON CIRCUITS I&2 PROVIDE FIREALARMRECEIPT CAPABILITY LOCATION.AN OPENCIRCUITON EITHER CIRCUIT WILL NOT INITIATION OF THE AUTOMATICFIRESUPPRESSION SYSTEMS.FOR A COMMON AFFECT THEDETECTORDETECTOR CLASS B CLASS B B/B AMENDMENT 13 DECEMBER 1990

APPENDIX 5.5

GLOSSARY OF TERMS

B/B AMENDMENT 13 DECEMBER 1990

APPENDIX 5.5 - GLOSSARY OF TERMS

ANSI - American National Standards Institute.

Combustible Liquids - Liquids have a flash point at or above 100

°F. Combustible liquids are subdivided as follows:

1. Class II - includes liquids having flash points at or above 100

°F and below 140

°F.

2. Class IIIA - liquids having flash points at or above 140°F and below 200

°F.

3. Class IIIB - liquids having flash points at or above 200°F.

ESF - Engineered safety feature.

ESW - Essential service water.

Fire Door - A tested, listed or approved door and 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 No. 80 for classification and types of fire doors.)

Fire Hazard - Any situation, process, material, or condition which on the basis of applicable data, may cause a fire or explosion or provide a ready

fuel supply to augment the spread or intensity of the fire or explosion and

which poses a threat to life, property, or reactor safety.

Fire Load - The amount of combustibles present in a given situation, usually expressed in terms of weight of combustible material (or potential heat

release due to combustion) per square foot. This measure is employed

frequently to calculate the degree of fire resistance required to withstand a

fire or judge the rate of application and quantity of extinguishing agent

needed to control or extinguish a fire.

Fire Point - Lowest temperature of a liquid in an open container at which vapors are evolved fast enough to support continuous combustion. The fire

point is usually a few degrees above the flash point.

Fire Resistance - Relative term used with a numerical or modifying adjective to indicate the extent to which a material or structure resists the effect of

fire.

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 materials are noncombustible, but noncombustible

materials are not necessarily fire resistive; fire resistive implies a higher

degree of fire resistance than noncombustible.

Fire Retardant - Denotes a substantially lower degree of fire resistance than fire resistive and is often used to refer to 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

A5.5-1 B/B AMENDMENT 13 DECEMBER 1990

the conditions for which they are designed.

Flamespread Rating - The comparative performance of fire travel over the surface of a material when tested in accordance with the provisions of NFPA

No. 255.

Flammable - Describes a combustible material that ignites very easily, burns intensely, or has a rapid rate of flamespread. Flammable and inflammable are

identical in meaning.

4. Flammable Liquids - any liquid having a flash point below 100

°F and having a vapor pressure not exceeding 40 psi absolute at 100

°F.

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.

Flash Point - Corresponds roughly to the lowest temperature at which the vapor pressure of the liquid is just sufficient to produce a flammable mixture at

the lower limit of flammability.

GA - General arrangement.

HM - Hollow metal.

HVAC - Heating, Ventilating, and Air Conditioning.

Hydraulic Designed Sprinkler System - A system in which sprinkler spacing and pipe sizing is, within limits, determined by hydraulic calculations rather

than a standard schedule of allowable pipe sizes.

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 heating element.

MCC - Motor control center.

NFPA - National Fire Protection Association.

NLOSH - National Laboratory for Occupational Safety and Health.

NML - Nuclear Mutual Limited.

Noncombustible - Material which, in the form in which it is used and under the conditions anticipated, will not ignite, burn, support combustion, or release

flammable vapors when subjected to fire or heat. Materials reported as

noncombustible, when tested to ASTM E136-1973, shall be considered

noncombustible.

5. Noncombustible and incombustible are identical in meaning.

A5.5-2 B/B AMENDMENT 13 DECEMBER 1990

6. Limited combustible - material which, in the form in which it is used, has a potential heat

value not exceeding 3500 Btu/lb and complies

with (a) or (b). Materials subject to increase

in combustibility or flame spread rating beyond

the limits herein established through the

effects of age, moisture, or other atmospheric

condition shall be considered combustible.

a) Materials having a structural base of incombustible material, with a surfacing

not exceeding a thickness of 1/8 inch which

has a flame rating not greater than 50.

b) Materials, in the form and thickness used, other than described in (a), having neither

a flame spread rating greater than 25 nor

evidence of continued progressive

combustion and of such composition that

surfaces that would be exposed by cutting

through the material on any plane would

have neither a flame spread rating greater

than 25 nor evidence of continued

progressive combustion.

Qualified Fire Protection Engineer - An engineer who has had sufficient technical training, knowledge, and experience in the field of fire protection

to qualify for full membership in the Society of Fire Protection Engineers.

RPS - Reactor Protection System - All equipment which is Category I regardless of whether or not it is required for reactor shutdown.

Standard Time-Temperature Curve - Represents the maximum severity, given in a time-temperature relationship, of a fire completely burning out a brick, wood-

joisted building and its contents. This curve is utilized in NFPA No. 251 and

ASTM E119 as a standard for construction fire resistive rating.

A5.5-3 B/B APPENDIX 5.6 REGULATORY GUIDE 1.120 FIRE PROTECTION GUIDELINES FOR NUCLEAR POWER PLANTS REVISION 1, NOVEMBER 1977 (Regulatory guide is provided as a reference only and is not entered in the WordPerfect 5.1 or Word Search package versions)

B/B APPENDIX 5.7 APPENDIX R--FIRE PROTECTION PROGRAM FOR NUCLEAR POWER FACILITIES OPERATING PRIOR TO JANUARY 1, 1979 B/BAMENDMENT 13 DECEMBER 1990 IntroductionAppendix A5.7 now applies to both the Byron and Braidwood stations. In cases where the description of conformance is only applicable to one of the

stations, this is so indicated by following the description with the station

name in parentheses.

A5.7-i B/B AMENDMENT 20 DECEMBER 2002 APPENDIX R--FIRE PROTECTION PROGRAM FOR NUCLEAR POWER FACILITIES OPERATING PRIOR TO JAN. 1, 1979 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

I.Introduction and Scope This Appendix applies to licensed nuclear power electric generating

stations that were operating prior to

January 1, 1979, except to the extent

set forth in paragraph 50.48(b) of

this part. With respect to certain

generic issues for such facilities it

sets forth fire protection features

required to satisfy Criterion 3 of

Appendix A to this part 5.Although Appendix R to 10 CFR 50 applies strictly to plants licensed to

operate prior to January 1, 1979, the

NRC has made conformance to 10 CFR 50

Appendix R a licensing requirement for

Byron/Braidwood. See NRC question

600.01 (June 3, 1981).

Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety

shall be designed and located to

minimize, consistent with other safety

requirements, the probability and

effect of fires and explosions." When considering the effects of fire, those systems associated with

achieving and maintaining safe

shutdown conditions assume major

importance to safety because damage to

them can lead to core damage resulting

from loss of coolant through boiloff.

The phrases "important," or "safety-related," will be used throughout this

Appendix R as applying to all safety

functions. The phrase "safe shutdown" will be used throughout this Appendix

R as applying to both hot and cold

shutdown functions.

The design basis of the Byron/Braidwood plant has from the beginning been that

Hot Standby (as defined in the

Technical Requirements Manual) is a "safe shutdown" condition, since the

plant can be maintained in Hot Standby

for an extended period of time from

outside the control room.

Because fire may affect safe shutdown systems and because the loss of

function of systems used to mitigate

the consequences of design basis

accidents under postfire conditions

does not per se impact public safety, the need to limit fire damage to A5.7-1 B/B AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

systems required to achieve and maintain safe shutdown conditions is

greater than the need to limit fire

damage to those systems required to

mitigate the consequences of design

basis accidents. Three levels of fire

damage limits are established

according to the safety functions of

the structure, system, or component:

Safety Function Fire Damage Limits

Hot Shutdown...One train of equipment necessary to achieve hot shutdown from

either the control room or emergency

control station(s) must be maintained

free of the damage by a single fire, including an exposure fire.

1 Cold Shutdown...Both trains of

equipment necessary to achieve cold

shutdown may be damaged by a single

fire, including an exposure fire, but

damage must be limited so that at

least one train can be repaired or

made operable within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> using

onsite capability.

Design Basis Accidents...Both trains of equipment necessary for mitigation

of consequences following design basis

accidents may be damaged by a single

exposure fire.

The most stringent fire damage limit shall apply for those systems that

fall into more than one category.

Redundant systems used to mitigate the

consequences of other design basis

accidents but not necessary for safe

shutdown may be lost to a single

exposure fire. However, protection

shall be provided so that a fire A5.7-2 B/B AMENDMENT 20 DECEMBER 2002 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

within only one such system will not damage the redundant system.II.General RequirementsA.Fire Protection ProgramThe applicant's fire protection program complies with these requirements as

described below.

A fire protection program shall be established at each nuclear power

plant. The program shall

establish the fire protection

policy for the protection of

structures, systems, and

components important to safety at

each plant and the procedures, equipment, and personnel required

to implement the program at the

plant site.

Administrative procedures define the requirements for fire prevention. The Fire Protection Report Section 2.3, "Fire Hazards Analysis" and Section 2.4, "Safe

Shutdown Analysis" establish the components

for safe shutdown. Prefire plans establish

the components needed and the protection

for the area.

Administrative Procedures define the responsibilities, procedures, and personnel

for the Fire Protection Program.

The fire protection program shall be under the direction of an

individual who has been delegated

authority commensurate with the

responsibilities of the position

and who has available staff

personnel knowledgeable in both

fire protection and nuclear

safety.Administrative Procedures identify the individual delegated the authority for establishing the fire protection program.

Administrative Procedures describe the organization and staff available to implement the program.

The fire protection program shall extend the concept of defense-in-

depth to fire protection in fire

areas important to safety, with

the following objectives; Comply. The B/B fire protection program includes these general objectives within

it.*to prevent fires from starting;Administrative Procedures outline inspection requirements for spill

prevention.

A5.7-3 B/B AMENDMENT 20 DECEMBER 2002 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

Administrative Procedures control lumber plus other combustibles in the plant

including safety-related areas.

Administrative Procedure control combustibles and flammable liquids.

Administrative Procedures address plant housekeeping and requires periodic

instructions for fire hazards.

Administrative Procedures outline fire prevention when welding and cutting.

Administrative Procedures govern the handling and usage of combustible and

flammable gas cylinders.

  • to detect rapidly, control, and extinguish promptly

those fires that do occur; The detection system alarms in the main control room. The proper method of

reporting fires is identified in

Administrative Procedures.

The Fire Marshall, Chief and brigade respond during a fire in accordance with

Administrative Procedures.

Governing Administrative Procedures provide for a Fire Watch or other compensatory measures in areas where detection or suppression systems are inoperable.

Implementation of the prefire plans for the station is in accordance with

Administrative Procedures.

Fire extinguishing is described by Administrative Procedures. In addition, agreements have been made with the local

fire department for assistance.

Administrative Procedures address the implementation of the Fire Marshall, Fire

Chief and Fire Brigade, respectively, in a

fire situation. Administrative Procedures

address Fire Department response, notification, mutual aid agreements and

expected chain of events during a fire.

A5.7-4 B/B AMENDMENT 20 DECEMBER 2002 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

  • to provide protection for structures, systems, and

components important to

safety so that a fire that

is not promptly extinguished

by the fire suppression

activities will not prevent

the safe shutdown of the

plant.Fire Protection Operating Procedures outline the manual initiation of CO 2 with loss of power.

Fire Protection Operating Procedures outline manual initiation of the charcoal

filter deluge systems.

Fire Protection Operating Procedures outline manual initiation of Halon. These

apply to areas where fire protection may

fail to respond and allow for a longer

duration.The Fire Hazards Analysis 2.3 and Safe Shutdown Analysis 2.4 address components, structures, and safe shutdown capability.

Prefire plans address protection of equipment.B.Fire Hazards Analysis A fire hazard analysis shall be performed by qualified fire

protection and reactor systems

engineers to (1) consider

potential in situ and transient

fire hazards; (2) determine the

consequences of fire in any

location in the plant on the

ability to safely shut down the

reactor or on the ability to

minimize and control and release

of radioactivity to the

environment; and (3) specify

measures for fire prevention, fire

detection, fire suppression, and

fire containment and alternative

shutdown capability as required

for each fire area containing

structures, systems, and

components important to A Fire Hazards Analysis was performed for the Byron/Braidwood stations and was

included with the Fire Protection Report, filed with the NRC on October 31, 1977.

This report documented conformance with BTP

APCSB 9.5-1, Appendix A, but did not

specifically address safe shutdown

capability, the subject of Appendix R.

The Applicant has performed Safe Shutdown Analyses for the Byron and Braidwood units

which demonstrate the ability to safely

shut down the units following a fire in any

zone. The analyses are included in Section

2.4 of the Fire Protection Report.

The fire hazards analysis and the safe shutdown analysis were performed primarily

by the architect/engineer for this plant.

Engineering personnel from the AE's

mechanical, electrical and structural A5.7-5 B/B AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

safety in accordance with NRC guidelines and regulations.

disciplines participated in these efforts.

They are thoroughly familiar with the

overall plant design and with the design of

the many systems and components within the

plant, including the reactor and related

systems. Significant participation was

also obtained from the applicant's

engineering staff and the station personnel (fire marshall and operating staff). A

qualified fire protection engineer

participated in the preparation of the fire

hazards analysis, and reviewed the final

results. The participation by engineers

from all of the relevant disciplines, and

personnel experienced in operation as well

as design ensures that the requirements set

forth here have been met.

Also see FPR Section 3.1.b.C.Fire Prevention Features Fire Protection features shall meet the following general

requirements for all fire areas

that contain or present a fire

hazard to structures, systems, or

components important to safety.

Comply. The fire prevention program and plant features meet these requirements.1.In situ fire hazards shall be identified and suitable

protection provided.

Fire hazards were considered in the plant design as shown in the Fire Protection

Report Section 2.3. In situ combustible

materials have been identified for all fire

zones in the plant and they are listed in

Table 2.2-1 of the Fire Protection Report.

Suitable protection has been provided for

all plant areas. Table 2.2-3 also lists

all detection and suppression available in

each fire zone.2.Transient fire hazards associated with normal

operation, maintenance, repair, or modification

activities shall be

identified and eliminated

where possible. Those

transient fire hazards that The fire hazard analysis includes an allowance for transient combustibles in the

combustible inventory for each fire zone

unless the fire zone is a controlled access

area. Specific transient materials which

could be present are not identified;

rather, a transient hazard equivalent in

Btu content to one or more 55-gallon drums A5.7-6 B/B AMENDMENT 24 DECEMBER 2010 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

cannot be eliminated shall be controlled and suitable

protection provided.

of lubricating oil is assumed and the Btu content is added to that of the identified

in situ combustibles in calculating the

fire zones fire load.

Administrative controls relating to the control of transient combustibles are

established as discussed in FPR Section

3.2.a through 3.2.c.3.Fire detection systems, portable extinguishes, and

standpipe and hose stations

shall be installed.

Byron/Braidwood Stations comply with exceptions as documented in the FPR Section 3.6.4.Fire barriers or automatic suppression systems or both

shall be installed as

necessary to protect

redundant systems or

components necessary for

safe shutdown.

Redundant safe shutdown components and systems are not always separated by fire

barriers and/or protected by automatic

suppression systems. All deviations from

this requirement are identified and

justified in Appendix A5.8 and Generic

Letter 86-10 evaluations.5.A site fire brigade shall be established, trained, and

equipped and shall be on

site at all times.

The site fire brigade is established as described in Administrative Procedures.

Refer to Section III.H and III.I of this

Appendix.6.Fire detection and suppression systems shall be

designed, installed, maintained, and tested by

personnel properly qualified

by experience and training

in fire protection systems.

Byron/Braidwood Stations fire protection and suppression systems are designed and

constructed as described in FPR Section 3.1

of Paragraph 1.a., Responsibility for Fire Protection Program, Design Phase and 1.b, Construction and Operating Phase.

Surveillance procedures are established for

the maintenance and testing of fire

detection and suppression systems.

See also FPR Sections 3.1.a(3) and 3.1.a(5).Surveillance procedures have been established to ensure that fire barriers

are in place and fire suppression systems

are operable.

See also FPR Section 3.2.j.

A5.7-7 B/B AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

7.Surveillance procedures shall be established to

ensure that fire barriers

are in place and that fire

suppression systems and

components are operable.D.Alternative or Dedicated Shutdown Capability In areas where the fire protection features cannot ensure safe

shutdown capability in the event

of a fire in that area, alternative or dedicated safe

shutdown capability shall be

provided.Byron/Braidwood complies with this requirement. Specific plant areas for

which alternate shutdown components or

systems have been installed include the

control room and the auxiliary electrical

equipment room. Specific details for each

room are described in Section 2.4 of the

Fire Protection Report.III.Specific RequirementsA.Water supplies for Fire Suppression Systems Two separate water supplies shall be provided to furnish necessary

water volume and pressure to the

fire main loop.

The B/B design complies with these requirements in Part A as described in

Section 3.6.b and Appendix 5.4, Subsection

A5.4.1 of the FPR.

Each supply shall consist of a storage tank, pump, piping, and

appropriate isolation and control

valves. Two separate redundant

suctions in one or more intake

structures from a large body of

water (river, lake, etc.) will

satisfy the requirement for two

separated water storage tanks.

These supplies shall be separated

so that a failure of one supply

will not result in a failure of

the other supply.

Each supply of the fire water distribution system shall be

capable of providing for a period

of 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br /> the maximum expected

water demands as determined by the

fire hazards analysis for safety-

related areas or other A5.7-8 B/B AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

areas that present a fire exposure hazard to safety-related areas.

When storage tanks are used for combined service-water/fire-water

uses the minimum volume for fire

uses shall be ensured by means of

dedicated tanks or by some

physical means such as vertical

standpipe for other water service.

Administrative controls, including

locks for tank outlet valves, are

unacceptable as the only means to

ensure minimum water volume.

Other water systems used as one of the two fire water supplies shall

be permanently connected to the

fire main system and shall be

capable of automatic alignment to

the fire main system. Pumps, controls, and power supplies in

these systems shall satisfy the

requirements for the main fire

pumps. The use of other water

systems for fire protection shall

not be incompatible with their

functions required for safe plant

shutdown. Failure of the other

system shall not degrade the fire

main system.B.Sectional Isolation Valves Sectional isolation valves such as post indicator valves or key-

operated valves shall be installed

in the fire main loop to permit

isolation of portions of the main

fire main loop for maintenance or

repair without interrupting the

entire water supply.

The B/B design complies with this requirement as described in Section

3.6.b(2) and Appendix 5.4, Subsection 5.4.1

of the FPR.

A5.7-9 B/B AMENDMENT 24 DECEMBER 2010 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

C.Hydrant Isolation Valves Valves shall be installed to permit isolation of outside

hydrants from the fire main for

maintenance or repair without

interrupting the water supply to

automatic or manual fire

suppression systems in any area

containing or presenting a fire

hazard to safety-related or safe

shutdown equipment.

The B/B design complies with this requirement as described in Section

3.6.b(3) and Appendix 5.4, Subsection 5.4.1

of the FPR.D.Manual Fire Suppression Standpipe and hose systems shall be installed so that at least one

effective hose stream will be able

to reach any location that

contains or presents an exposure

fire hazard to structures, systems, or components important

to safety.

B/B complies with exceptions as noted in FPR Section 3.6.c(4) and Appendix 5.4, Subsection A5.4.7.

Access to permit effective functioning of the fire brigade

shall be provided to all areas

that contain or present an

exposure fire hazard to

structures, systems, or components

important to safety.

B/B complies. Access routes for fire fighting are listed in the Pre-Fire Plans.

Standpipe and hose stations, shall be inside PWR containments and BWR

containments that are not inerted.

Standpipe and hose stations inside

containment may be connected to a

high quality water supply of

sufficient quantity and pressure

other than the fire main loop if

plant-specific features prevent

extending the fire main supply

inside containment. For BWR

drywells, standpipe and hose

stations shall be placed outside

the drywell with adequate lengths

of hose to reach any location B/B complies. See FPR Sections 2.3.1, 3.7.a, and Appendix 5.4, Subsection A5.4.7.

A5.7-10 B/B AMENDMENT 21 DECEMBER 2004 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

inside the drywell with an effective hose stream.E.Hydrostatic Hose Tests Fire hose shall be hydrostatically tested at a pressure of 150 psi or

50 psi above maximum fire main

operating pressure, whichever is

greater. Hose stored in outside

hose houses shall be tested

annually. Interior standpipe hose

shall be tested every three years.

Byron/Braidwood comply by satisfying the recommendations of NFPA 1962 and BTP CMEB 9.5.1. See also FPR Section 3.6.c(6).F.Automatic Fire Detection Automatic fire detection systems shall be installed in all areas of

the plant that contain or present

an exposure fire hazard to safe

shutdown or safety-related systems

or components. These fire

detection systems shall be capable

of operating with or without

offsite power.

B/B complies. See FPR Section 3.6.a and Appendix 5.4, Subsection A5.4.8.G.Fire Protection of Safe Shutdown Capability1.Fire protection features shall be provided for

structures, systems, and

components important to safe

shutdown. These features

shall be capable of limiting

fire damage so that:a.One train of systems necessary to achieve and

maintain hot shutdown

conditions from either

the control room or

emergency control

station(s) is free of

fire damage; and Byron/Braidwood complies with this requirement. Certain plant configurations

exist, each of which is described and

justified below under the discussion for

Section III.G.2 and Appendix A5.8, where

separation of redundant safe shutdown

components or systems is not as specified

in Section III.G.2. Taking credit for the

alternative separation and protection

features identified in these deviations

from the requirements of Section III.G.2, one train of systems necessary to achieve

and maintain hot shutdown will remain free

of fire damage, and systems required to

achieve and maintain cold shutdown will

either remain free of fire damage or will

be repairable so that cold shutdown can be A5.7-11 B/B AMENDMENT 20 DECEMBER 2002 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS b.Systems necessary to achieve and maintain

cold shutdown from

either the control room

or emergency control

station(s) can be

repaired within 72

hours.achieved within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br />, for each fire area in the plant.2.Except as provided for Paragraph G.3 of this

section, where cables or

equipment, including

associated non-safety

circuits that could prevent

operation or cause

maloperation due to hot

shorts, open circuits, or

shorts to ground, or

redundant trains of systems

necessary to achieve and

maintain hot shutdown

conditions are located within

the same fire area outside of

primary containment, one of

the following means of

ensuring that one of the

redundant trains is free of

fire damage shall be

provided: Deviations from the requirements of Section III.G.2 are described in Appendix A5.8 and Generic Letter 86-10 evaluations. In each case, a detailed description of the

deviations is included, modifications (if

any) implemented as a result of the

deviation are described, and a

justification for the deviation is

provided.a.Separation of cables and equipment and associated

non-safety circuits of

redundant trains by a

fire barrier having a

3-hour rating.

Structural steel forming

a part of or supporting

such fire barriers shall

be provided to provide

fire resistance

equivalent to that

required of the barrier;b.Separation of cables and equipment and associated

non-safety circuits of

redundant trains by a A5.7-12 B/B AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

horizontal distance of more than 20 feet with

no intervening

combustible or fire

hazards. In addition, fire detectors and an

automatic fire

suppression system shall

be installed in the fire

area; or c.Enclosure of cable and equipment and associated

non-safety circuits of

one redundant train in a

fire barrier having a 1-

hour rating. In

addition, fire detectors

and an automatic fire

suppression system shall

be installed in the fire

area;Inside noninerted containments one of the

fire protection means

specified above or one

of the following fire

protection means shall

be provided:d.Separation of cables and equipment and associated

non-safety circuits of

redundant trains by a

horizontal distance of

more than 20 feet with

no intervening

combustibles or fire

hazards;e.Installation of fire detectors and an

automatic fire

suppression system in

the fire area; or A5.7-13 B/B AMENDMENT 22 DECEMBER 2006 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

f.Separation of cables and equipment and associated

non-safety circuits of

redundant trains by a

noncombustible radiant

energy shield.3.Alternative or dedicated shutdown capability and its

associated circuits, independent of cables, systems or components in the

area, room or zone under

consideration, shall be

provided;Taking credit for the alternative separation and protection features

described above for those plant areas which

deviate from the requirements of Section

III.G.2, Byron/Braidwood complies with this

requirement.a.Where the protection of systems whose function

is required for hot

shutdown does not

satisfy the requirement

of paragraph G.2 of this

section; orb.Where redundant trains of systems required for

hot shutdown located in

the same fire area may

be subject to damage

from fire suppression

activities or from the

rupture or inadvertent

operation of fire

suppression systems.

In addition, fire detection and a fixed

fire suppression system

shall be installed in

the area, room, or zone

under consideration.H.Fire Brigade A site brigade trained and equipped for fire fighting shall be

established to ensure adequate

manual fire fighting capability for

all areas of the plantByron and Braidwood comply, except as noted below. The fire brigade will meet the requirements stated herein, except that

exception is taken to the performance

standards required by the A5.7-14 B/B AMENDMENT 23 DECEMBER 2008 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

containing structures, systems, or components important to safety.

The fire brigade shall be at least

five members on each shift. The

brigade leader and at least two

brigade members shall have

sufficient training in or

knowledge of plant safety-related

systems to understand the effects

of fire and fire suppressants on

safe shutdown capability. The

qualification of fire brigade

members shall include an annual

physical examination to determine

their ability to perform strenuous

fire fighting activities. The

shift supervisor shall not be a

member of the fire brigade. The

brigade leader shall be competent

to assess the potential safety

consequences of a fire and advise

control room personnel. Such

competence by the brigade leader

may be evidenced by possession of

an operator's license or

equivalent knowledge of plant

safety-related systems.

annual physical examination. The wording "ability to perform strenuous fire fighting

activities" is lacking in specific detail and is

open to wide interpretation. The annual

physical will demonstrate that fire brigade

members are capable of performing unrestricted

physical activity.

The Fire Protection Program Administrative Procedures sets forth the qualifications for the

members of the fire brigade. These requirements

set forth the training and physical condition of

the members of the brigade. All brigade members

complete the training course set forth by the

Production Training Department Technical

Training Section "Training Standard for Initial

Training of Nuclear Station Fire Brigade

Members." A competent fire brigade leader will

respond to a fire.

The Braidwood off-site fire department is the primary responder in the event of a fire at the

Braidwood Lake Screen House (LSH). The site

Fire Brigade Chief may also respond to a fire at

the LSH. The Custer Park Fire Department is the primary responder in the event of a fire at the

Braidwood River Screen House. The Byron offsite fire department is the primary responder in the event of a fire at the Byron River Screen House (RSH). A Byron Station operator will also respond to a fire at the RSH.

Reference EC 361785.

Reference EC 368713 The minimum equipment provided for

the brigade shall consist of

personal protective equipment such

as turnout coats, boots, gloves, hard hats, emergency

communications equipment, portable

lights, portable ventilation

equipment, and portable

extinguishes. Self-contained

breathing apparatus using full-

face positive-pressure masks

approved by NIOSH (National

Institute for Occupational Safety

and Health-approval formerly given

by the U.S. Bureau of Mines) shall

be provided for fire brigade, damage control, and control room

personnel. At least 10 masks

shall be available for fire

brigade personnel. Control Comply. The Fire Protection Program Administrative Procedures provides the

requirement of the Fire Brigade inventory to be

performed and lists the equipment to be

inventoried.

A5.7-15 B/B AMENDMENT 20 DECEMBER 2002 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

room personnel may be furnished breathing air by a manifold system

piped from a storage reservoir if

practical. Service or rated

operating life shall be a minimum

of one-half hour for the self-

contained units.

At least two extra air bottles shall be located onsite for each

self-contained breathing unit. In

addition, an onsite 6-hour supply

of reserve air shall be provided

and arranged to permit quick and

complete replenishment of

exhausted supply air bottles as

they are returned. If compressors

are used as a source of breathing

air, only units approved for

breathing air shall be used;

compressors shall be operable

assuming a loss of offsite power.

Special care must be taken to

locate the compressor in areas

free of dust and contaminants.

Comply. The extra air bottles are included in inventory procedures for the fire brigade equipment. The 6-hour supply of

reserve air is supplied by a bank of

cylinders and/or bottles which is under the

control of the Rad-Chem department.

Compressors are not used to meet supply

requirements for breathing air for the fire

brigade.I.Fire Brigade Training The fire brigde training program shall ensure that the capability

to fight potential fires is

established and maintained. The

program shall consist of an

initial classroom instruction

program followed by periodic

classroom instruction, fire

fighting practice, and fire

drills.The fire brigade training program meets the requirements presented herein.

The fire brigade training program is administered through a Training Standard

for Nuclear Station Fire Brigade Members

developed by the Braidwood Production

Training Center.1.Instructiona.The initial classroom instruction shall

include:(1)Indoctrination of the plant fire

fighting plan with Byron and Braidwood comply with Parts a through e. See Fire Protection

Administrative Procedures.

A5.7-16 B/B AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

Specific identification of

each individual's

responsibilities.(2)Identification of the type and

location of fire

hazards and

associated types

of fires that

could occur in the

plant.(3)The toxic and corrosive

characteristics of

expected products

of combustion.(4)Identification of the location of

fire fighting

equipment for each

fire area and

familiarization

with the layout of

the plant, including access

and egress routes

to each area.(5)The proper use of available fire

fighting equipment

and the correct

method of fighting

each type of fire.

The types of fires

covered should

include fires in

energized

electrical

equipment, fires

in cables and

cable trays, hydrogen fires, fires involving

flammable and A5.7-17 B/B AMENDMENT 20 DECEMBER 2002 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

Combustible liquids or

hazardous process

chemicals, fires

resulting from

construction or

modifications (welding), and

record file fires.(6)The proper use of communication,

lighting, ventilation, and

emergency

breathing

equipment.(7)The proper method for fighting fires

inside buildings

and confined

spaces.(8)The direction and coordination of

the fire fighting

activities (fire

brigade leaders

only).All brigade members get the leadership course.(9)Detailed review of fire fighting

strategies and

procedures.

Training of fire-fighting strategies and procedures is included in the initial and

continued training.(10)Review of the latest plant

modifications and

corresponding

changes in fire

fighting plans.

This subject is covered during fire brigade training.NOTE: Items (9) and (10) may be deleted from

the training of no more

than two of the non-

operations personnel who A5.7-18 B/B AMENDMENT 20 DECEMBER 2002 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

may be assigned to the fire brigade.b.The instruction shall be provided by qualified

individuals who are

knowledgeable, experienced, and

suitably trained in

fighting the types of

fires that could occur

in the plant and in

using the types of

equipment available in

the nuclear power plant.

Licensed qualified instructors from the company training department or local fire department have provided the initial training of the fire brigade (Byron).

The training of the fire brigade is conducted by a qualified member of the

training department. State-certified

members of the Fire Marshall's staff

monitor this training (Braidwood).c.Instruction shall be provided to all fire

brigade members and fire

brigade leaders.d.Regular planned meetings shall be held at least

every 3 months for all

brigade members to

review changes in the

fire protection program

and other subjects as

necessary.

Comply. The Fire Protection Program sets forth the requirements to hold planned

meetings quarterly for all brigade members

to review changes in the fire protection

program, etc.e.Periodic refresher training sessions shall

be held to repeat the

classroom instruction

program for all brigade

members over a two-year

period. These sessions

may be concurrent with

the regular planned

meetings.Comply. Periodic refresher training is included in the Training Standard for

Nuclear Station Fire Brigade Members.2.Practice Practice sessions shall be held for each shift fire brigade on the

proper method of fighting the

various types of fires that could

occur in a nuclear power plant.

These sessions shall provide Byron and Braidwood comply. Practice sessions in actual fire extinguishment and

use of emergency breathing apparatus under

strenuous conditions is accomplished

through the annual fire extinguisher A5.7-19 B/B AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

brigade members with experience in actual fire extinguishment and the

use of emergency breathing

apparatus under strenuous

conditions encountered in fire

fighting. These practice sessions

shall be provided at least once

per year for each fire brigade

member.training on live fires and annual smokehouse/live fire training.

Practice sessions are also addressed in Administrative Procedures.3.Drillsa.Fire brigade drills shall be performed in the plant so

that the fire brigade can

practice as a team.

Items 3a through 3e are accomplished by Administrative Procedures on Fire Drills.

The type of drills and assessment of the

drills are documented on a "Fire Drill

Critique Record." Byron and Braidwood

comply with parts a through e, except as

noted.b.Drills shall be performed at regular intervals not to

exceed 3 months for each

shift fire brigade. Each

fire brigade member should

participate in each drill, but must participate in at

least two drills per year.

A sufficient number of these drills, but not less than Comply except as noted below:

Byron/Braidwood Stations will perform fire brigade drill training such that the fire

brigade drills once per quarter, so that

each fire brigade member participates in at

least two fire brigade drills per year. The

brigade performs during the drill as a

team. The members may not always be the

same personnel.

one for each shift fire brigade per year, shall be

unannounced to determine the

fire fighting readiness of

the plant fire brigade, brigade leader, and fire

protection systems and

equipment. Persons planning

and authorizing an

unannounced drill shall

ensure that the responding

shift fire brigade members

are not aware that a drill

is being planned until it is A5.7-20 B/B AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

begun. Unannounced drills shall not be scheduled

closer than four weeks.

At least one drill per year shall be performed on a "back-shift" for each shift

fire brigade.c.The drills shall be preplanned to establish the

training objectives of the

drill and shall be critiqued

to determine how well the

training objectives have

been met. Unannounced

drills shall be planned and

critiqued by members of the

management staff responsible

for plant safety and fire

protection. Performance

deficiencies of a fire

brigade or of individual

fire brigade members shall

be remedied by scheduling

additional training for the

brigade or members.

Unsatisfactory drill performance shall be

followed by a repeat drill

within 30 days.d.At 3-year intervals, a randomly selected

unannounced drill shall be

critiqued by qualified

individuals independent of

the licensee's staff. A

copy of the written report

from such individuals shall

be available for NRC review.e.Drills shall as a minimum include the following:(1)Assessment of fire alarm effectiveness, time

required to notify and A5.7-21 B/B AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

assemble fire brigade and selection, placement

and use of equipment, and fire fighting

strategies.(2)Assessment of each brigade member's

knowledge of his or her

role in the fire

fighting strategy for

the area assumed to

contain the fire.

Assessment of the

brigade member's

conformance with

established plant fire

fighting procedures and

use of fire fighting

equipment, including

self-contained emergency

breathing apparatus, communication equipment, and ventilation

equipment to the extent

practicable.(3)The simulated use of fire fighting equipment

required to cope with

the situation and type

of fire selected for the

drill. The area and

type of fire chosen for

the drill should differ

from those used in the

previous drill so that

brigade members are

trained in fighting

fires in various plant

areas. The situation

selected should simulate

the size and arrangement

of a fire that could

reasonably occur in the

area selected, allowing

for fire development due

to the time required to

respond, to obtain A5.7-22 B/B AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

equipment and organize for the fire assuming

loss of automatic

suppression capability.(4)Assessment of brigade leader's direction of

the fire fighting effort

as to thoroughness, accuracy, and

effectiveness.4.Records Individual records of training provided to each

fire brigade member, including drill critiques, shall be maintained for at

least 3 years to ensure that

each member receives

training in all parts of the

training program. These

records of training shall be

available for NRC review.

Retraining or broadened

training for fire fighting

within buildings shall be

scheduled for all those

brigade members whose

performance records show

deficiencies.

Comply. Individual records of training for each brigade member are retained by the

training department and will be available

for review. The drill critique is retained

in central file and will be available for

review.J.Emergency Lighting Emergency lighting units with at least an 8-hour battery power

supply shall be provided in all

areas needed for operation of safe

shutdown equipment and in access

and egress routes thereto.

B/B complies. Eight-hour, battery-powered emergency lights are provided for plant

areas that need to be manned for safe

shutdown and in access and egress routes thereto. Testing will demonstrate the 8-

hour rating of these units.K.Administrative Controls Administrative controls shall be established to minimize fire

hazards in areas containing

structures, systems, and

components important to safety.

Byron and Braidwood comply. Administrative controls will be in effect which will

comply with the requirements of this

section.A5.7-23 B/B AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

These controls shall establish procedures to:1.Govern the handling and limitation of the use of

ordinary combustible

materials, combustible and

flammable gases and liquids, high efficiency particulate

air and charcoal filters, dry ion exchange resins, or

other combustible supplies

in safety-related areas.

Comply. Administrative Procedures on "Fire Prevention For Use of Lumber and Other

Combustibles" govern the handling and

limitation of ordinary combustible

materials. Administrative Procedures on "Control of Flammable and Combustible

Liquids" govern the handling and limitation

of flammable gases and liquids.

Administrative Procedures govern the

handling and usage of combustible/

flammable gas cylinders.2.Prohibit the storage of combustibles in safety-

related areas or establish

designated storage areas

with appropriate fire

protection.

Comply. Routine fire prevention operator rounds are performed on each shift by the

Equipment Operator or Equipment Attendant.

Special periodic fire inspections are

conducted in the storage areas inside or

adjacent to safety-related structures or

systems to identify any buildup of

combustible material or other fire hazards.

Periodic fire inspections are conducted.

Administrative Procedures prohibit bulk

storage of combustible materials inside or

adjacent to safety-related buildings or

systems during operation or maintenance

periods.3.Govern the handling of and limit transient fire loads

such as combustible and

flammable liquids, wood and

plastic products, or other

combustible materials in

buildings containing safety-

related systems or equipment

during all phases of

operating and especially

during maintenance, modification, or refueling

operations.

Comply. Byron will incorporate into administrative procedures provisions to

control transient combustibles. The

procedures will state that transient

combustibles in safety-related areas, which

are not in approved containers, shall not

be left unattended.

Administrative Procedures govern the handling of and limit transient fire loads

such as combustible and flammable liquids, wood and plastic products, compressed gas

cylinders, or other combustible materials

in buildings containing safety-related

systems or equipment.

A5.7-24 B/B AMENDMENT 20 DECEMBER 2002 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

4.Designate the onsite staff member responsible for the

inplant fire protection

review of proposed work

activities to identify

potential transient fire

hazards and specify required

additional fire protection

in the work activity

procedure.

Same procedures as in Item 1 above govern.

Comply. The station Fire Marshall is the

designated staff member as set forth in

Administrative Procedures.5.Govern the use of ignition sources by use of a flame

permit system to control

welding, flame cutting, brazing, or soldering

operations. A separate

permit shall be issued for

each area where work is to

be done. If work continues

over more than one shift, the permit shall be valid

for not more than 24 hours1 days <br />0.143 weeks <br />0.0329 months <br />

when the plant is operating

or for the duration of a

particular job during plant

shutdown.Comply. The welding and flame cutting work is done at each station in accordance with

NFPA 51B.Administrative Procedures cover preparation and inspection for fire prevention when

welding and cutting is performed. It also

covers filling out cutting and welding

permits and precautions during cutting

and/or welding.6.Control the removal from the area of all waste, debris, scrap, oil spills, or other

combustibles resulting from

the work activity, immediately following

completion of the activity, or at the end of each work

shift, whichever comes

first.Comply. Administrative Procedures on "Station Housekeeping Equipment

Preservation Procedure," specifies that

combustible material can not be left

unattended in safety-related areas.7.Maintain the periodic housekeeping inspections to

ensure continued compliance

with these administrative

controls.Comply. Administrative Procedure assures that good housekeeping inspections are met.8.Control the use of specific combustibles in safety-

related areas. All wood

used in safety-related areas Comply, with exceptions below:

A5.7-25 B/B AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

during maintenance, modification, or refueling

operations (such as lay-down

blocks or scaffolding) shall

be treated with a flame

retardant. Equipment or

supplies (such as new fuel)

shipped in untreated

combustible packing

containers may be unpacked

in safety-related areas if

required for valid operating

reasons. However, all

combustible materials shall

be removed from the area

immediately following the

unpacking. Such transient

combustible materials, unless stored in approved

containers, shall not be

left unattended during lunch

breaks, shift changes, or

other similar periods.

Loose combustible packing

material such as wood or

paper excelsior, or

polyethylene sheeting shall

be placed in metal

containers with tight-

fitting self-closing metal

covers.The reactor facility at Byron/Braidwood was designed to ensure that the probability of

events such as fires and explosions and

other potential consequences of such events

will not result in undue risk to the health

and safety of the public. Noncombustible

and fire resistant materials were used

throughout the facility wherever necessary

to preclude such risks, particularly in

areas containing critical portions of the

facility such as containment, control room, and components of engineered safety

features.Combustible materials are not used when substitutes are available. When

combustible materials are used, they are

treated with fire retardant material or

they are controlled as to their fire

hazard.The control and use of specific combustibles in safety-related areas is

assured by Administrative Procedures on "Fire Protection for Use of Lumber and

Other Combustibles." Exception is taken in regards to new fuel which is stored wrapped in polyethylene

bags for cleanliness requirements.9.Control actions to be taken by an individual discovering

a fire. For example, notification of control

room, attempt to extinguish

fire, and actuation of local

fire suppression systems.

Comply. Administrative Procedures on "Fire and Emergency Notification and Evacuation

Plan" states actions to be taken by an

individual discovering a fire.

Comply. Administrative Procedures on "Fire Protection Program", states actions to be

taken by an individual discovering a fire.10.Control actions to be taken by the control room operator

to determine the need for

brigade assistance upon

report of a fire or receipt

of alarm on control room

annunciator panel, for Comply. Administrative Procedures on "Fire and Emergency Notification and

Evacuation Plan" states the actions to be

taken by the control room operator on the

report of a fire.

A5.7-26 B/B AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

example, announcing location of fire over PA system, sounding fire alarms, and

notifying the shift

supervisor and the fire

brigade leader of the type, size, and location of the

fire.Administrative Procedures also describe the sequence of events to take place in the

event of a fire at the Braidwood Station.

Operating procedures address "Plant Wide

Fire Alarm Actuation."11.Control actions to be taken by the fire brigade after

notification by the control

room operator of a fire, for

example, assembling in a

designated location, receiving directions from

the fire brigade leader, and

discharging specific fire

fighting responsibilities

including selection and

transportation of fire

fighting equipment to fire

location, selection of

protective equipment, operating instructions for

use of fire suppression

systems, and use of

preplanned strategies for

fighting fires in specific

areas.Comply. The actions to be taken by the fire brigade after notification by the

control room operator of a fire is

identified in Administrative Procedures.12.Define the strategies for fighting fires in all

safety-related areas and

areas presenting a hazard to

safety-related equipment.

These strategies shall

designate:

Comply, with exceptions noted below.

Pre-fire plans have been developed which

address the concerns listed here as

described below.a.Fire hazards in each area covered by the

specific pre-fire plans.

Comply. The pre-fire plans identify major in situ combustibles for the areas they

cover.b.Fire extinguishants best suited for controlling

the fires associated

with the fire hazards in

that area and the The pre-fire plans identify all automatic and manual suppression equipment in the

area, and its location. The extinguishing

methods provided are chosen to be the best

available to cover identified in situ fire

hazards.A5.7-27 B/B AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

nearest location of these extinguishants.c.Most favorable direction from which to attack a

fire in each area in

view of the ventilation

direction, access

hallways, stairs, and

doors that are most

likely to be free of

fire, and the best

station or elevation for

fighting the fire. All

access and egress routes

that involve locked

doors should be

specifically identified

in the procedure with

the appropriate

precautions and methods

for access specified.

The pre-fire plans identify available access routes for each zone. The most

favorable direction or location to fight

specific fires from are not identified.

The fire brigade can best determine this

upon reaching the scene of an actual fire.

Particularly for large rooms and general areas, the number of possible

fire locations are too numerous to

attempt to develop specific strategies

beforehand.d.Plant systems that should be managed to

reduce the damage

potential during a local

fire and the location of

local and remote con-

trols for such manage-

ment (e.g., any

hydraulic or electrical

systems in the zone

covered by the specific

fire fighting procedure

that could increase the

hazards in the area

because of overpressur-

ization or electrical

hazards).Important plant systems and components and potentially hazardous electrical components

are identified in the pre-fire plans.e.Vital heat-sensitive system components that

need to be kept cool

while fighting a local

fire. Particularly

hazardous combustibles Comply. Vital components have been defined in pre-fire plans.

A5.7-28 B/B AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

that need cooling should be designated.f.Organization of fire fighting brigades and

the assignment of

special duties according

to job title so that all

fire fighting functions

are covered by any

complete shift personnel

complement. These

duties include command

control of the brigade, transporting fire

suppression and support

equipment to the scenes, applying the

extinguishant to the

fire, communication with

the control room, and

coordination with

outside fire

departments.

Byron and Braidwood comply. See Administrative Procedures at the stations.

All fire brigade members receive all of the

specialized training mentioned here.g.Potential radiological and toxic hazards in

fire zones.

Comply. Potential radiological and toxic hazards are identified in the pre-fire

plans.h.Ventilation system operation that ensures

desired plant air

distribution when the

ventilation flow is

modified for fire

containment or smoke

clearing operations.

Comply. Ventilation system operation for smoke removal is addressed. Ventilation

system design is such that fires in

specific rooms will affect only the

ventilation for that room or division.i.Operations requiring control room and shift

engineer coordination or

authorization.

Fire fighting operations per se are not expected to require control room or shift

engineer coordination.j.Instructions for plant operators and general

plant personnel during

fire.This is addressed by station procedures other than the pre-fire plans.

A5.7-29 B/B AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS L.Alternative and Dedicated Shutdown Capability1.Alternative or dedicated shutdown capability provided

for a specific fire area

shall be able to achieve and

maintain subcritical

reactivity conditions in the

reactor, maintain reactor

coolant inventory, achieve

and maintain hot standby 7 conditions for a PWR (hot

shutdown 7 for a BWR) and achieve cold shutdown 7 conditions within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br />

and maintain cold shutdown

conditions thereafter.

During the postfire

shutdown, the reactor

coolant system process

variables shall be

maintained within those

predicted for a loss of

normal ac power and the

fission product boundary

integrity shall not be

affected; i.e., there shall

be no fuel clad damage, rupture or any primary

coolant boundary, or rupture

of the containment boundary.

Byron and Braidwood comply. Alternate shutdown components or systems are provided

for all plant areas where the separation

requirements of Section III.G cannot be

met. The requirements stated herein are

met as described in Section 2.4 of the Fire

Protection Report.2.The performance goals for the shutdown functions shall

be: Byron/Braidwood complies with this requirement as described in Section 2.4 of

the Fire Protection Report.

The performance goals listed have been implemented in conducting the Safe

Shutdown Analysis.a.The reactivity control function shall be

capable of achieving and

maintaining cold

shutdown reactivity

conditions.b.The reactor coolant makeup function shall be

capable of maintaining

the reactor coolant

level above the top of A5.7-30 B/B AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

the core for BWRs and be within the level

indication in the

pressurizer for PWRs.c.The reactor heat removal function shall be

capable of achieving and

maintaining decay heat

removal.d.The process monitoring function shall be

capable of providing

direct readings of the

process variables

necessary to perform and

control the above

functions.e.The supporting functions shall be capable of

providing the process

cooling, lubrication, etc., necessary to

permit the operation of

the equipment used for

safe shutdown functions.3.The shutdown capability for specific fire areas may be

unique for each such area, or it may be one unique

combination of systems for

all such areas. In either

case, the alternative

shutdown capability shall be

independent of the specific

fire area(s) and shall

accommodate postfire

conditions where offsite

power is available and where

offsite power is not

available for 72 hours3 days <br />0.429 weeks <br />0.0986 months <br />.

Procedures shall be in

effect to implement this

capability.

Byron/Braidwood complies with this requirement. Refer to Section 2.4 of the

Fire Protection Report for a description of

safe shutdown capability for each fire

zone.A5.7-31 B/B AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS 4.In the capability to achieve and maintain cold shutdown

will not be available

because of fire damage, the

equipment and systems

comprising the means to

achieve and maintain the hot

standby or hot shutdown

condition shall be capable

of maintaining such

conditions until cold

shutdown can be achieved.

If such equipment and

systems will not be capable

of being powered by both

onsite and offsite electric

power systems because of

fire damage, an independent

onsite power system shall be

provided. The number of

operating shift personnel, exclusive of fire brigade

members, required to operate

such equipment and systems

shall be on site at all

times.B/B complies. Refer to Safe Shutdown Analysis, (Section 2.4 of FPR).5.Equipment and systems comprising the means to

achieve and maintain cold

shutdown conditions shall

not be damaged by fire; or

the fire damage to such

equipment and systems shall

be limited so that the

systems can be made operable

and cold shutdown achieved

within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br />. Materials

for such repairs shall be

readily available on site

and procedures shall be in

effect to implement such

repairs. If such equipment

and systems used prior to 72

hours after the fire will

not be capable of being

powered by both onsite and

offsite electrical power

systems because of fire Byron/Braidwood complies with this requirement provided credit is taken for

alternative separation and protection

features for certain plant areas described

above under Section III.G.2.

A5.7-32 B/B AMENDMENT 20 DECEMBER 2002 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

damage an independent onsite power system shall be

provided. Equipment and

systems used after 72 hours3 days <br />0.429 weeks <br />0.0986 months <br />

may be powered by offsite

power only.6.Shutdown systems installed to ensure postfire shutdown

capability need not be

designed to meet seismic

Category I criteria, single

failure criteria, or other

design basis accident

criteria, except where

required for other reasons, e.g., because of interface

with or impact on existing

safety systems, or because

of adverse valve actions due

to fire damage.

Byron/Braidwood complies with this requirement. The only equipment which has

been installed to ensure postfire safe

shutdown capability is the Fire Hazards

Panel which includes certain instruments

which would otherwise be unavailable

following a fire in either the control room

or the auxiliary electrical equipment room.

This panel is described in Subsection

2.4.2.16 of the Fire Protection Report.

Its design complies with the requirements

stated herein.7.The safe shutdown equipment and systems for each fire

area shall be known to be

isolated from associated

non-safety circuits in the

fire area so that hot

shorts, open circuits, or

shorts to ground in the

associated circuits will not

prevent operation of the

safe shutdown equipment.

The separation and barriers

between trays and conduits

containing associated

circuits of one safe

shutdown division and trays

and conduits containing

associated circuits or safe

shutdown division cables

from the redundant division, or the isolation of these

associated circuits from the

safe shutdown equipment, shall be such that a

postulated fire involving

associated circuits will not

prevent safe shutdown.

There are no associated circuits as defined in IEEE 384-1974 at B/B. Associated

circuits as defined in NRC's April 6, 1982, clarification letters to Generic Letter

81-12 are addressed in Subsection 2.4.1 of the Fire Protection Report.

A5.7-33 B/B AMENDMENT 19 DECEMBER 2000 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

M.Fire Barrier Cable Penetration Seal Qualification Penetration seal designs shall utilize only noncombustible

materials and shall be qualified

by tests that are comparable to

tests used to rate fire barriers.

The acceptance criteria for the

test shall include:

B/B complies. See FPR Sections 3.5(a)

(3)(a) through (c) and Appendix 5.2, Subsection A5.2.2. Fire-rated penetration

seals in fire-rated assemblies separating

safety-related fire areas or separating

portions of redundant systems important to

safe shutdown within a fire area are

inspected by Surveillance Procedures. See

contractors test reports for details on the

acceptability of seals.1.The cable fire barrier penetration seal has

withstood the fire endurance

test without passage of

flame or ignition of cables

on the unexposed side for a

period of time equivalent to

the fire resistance rating

required of the barrier;2.The temperature levels recorded for the unexposed

side are analyzed and

demonstrate that the maximum

temperature is sufficiently

below the cable insulation

ignition temperature; and3.The fire barrier penetration seal remains intact and does

not allow projection of

water beyond the unexposed

surface during the hose

stream test.N.Fire Doors Fire doors shall be self-closing or provided with closing

mechanisms and shall be inspected

semiannually to verify that

automatic hold-open, release, and

closing mechanisms and latches are

operable.Byron/Braidwood complies. See FPR Section 3.5.a (5).

A5.7-34 B/B AMENDMENT 19 DECEMBER 2000 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

One of the following measures shall be provided to ensure they

will protect the opening as

required in case of fire:1.Fire doors shall be kept closed and electrically

supervised at a continuously

manned location; All fire doors have automatic closures.

Cable spreading rooms have electrically

supervised doors alarming in the control

room.2.Fire doors shall be locked and inspected weekly to

verify that the doors are in

the closed position; Personnel will walk down fire doors, which are unlocked or nonelectrically supervised, once per day at Braidwood and every 7 days

at Byron. Locked doors will be surveilled

once per week at Braidwood and every 31

days at Byron. Electrically supervised

fire doors will be surveilled monthly at

Braidwood and every 92 days at Byron.

The Byron surveillance frequency is based on historical analysis of plant specific

records (document identification number

DG99-000873).3.Fire doors shall be provided with automatic hold-open and

release mechanisms and

inspected daily to verify

that doorways are free of

obstructions; or4.Fire doors shall be kept closed and inspected daily

to verify that they are in

the closed position.

The fire brigade leader shall have ready access to

keys for any locked fire

doors.Areas protected by automatic total flooding gas

suppression systems shall

have electrically supervised

self-closing fire doors or

shall satisfy option 1

above.A5.7-35 B/B AMENDMENT 19 DECEMBER 2000 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

O.Oil Collection System for Reactor Coolant Pump The reactor coolant pump shall be equipped with an oil collection

system if the containment is not

inerted during normal operation.

B/B complies.

A drip pan system which meets the guidelines of Appendix R to 10 CFR 50 has

been designed for the reactor coolant pump (RCP) motors for the Byron/Braidwood

Stations.A5.7-35a B/B AMENDMENT 18 DECEMBER 1998 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

The oil collection system shall be so designed, engineered, and

installed that failure will not

lead to fire during normal or

design basis accident conditions

and that there is reasonable

assurance that the system will

withstand the Safe Shutdown

Earthquake.

9 Such collection systems shall be

capable of collecting lube oil

from all potential pressurized and

unpressurized leakage sites in the

reactor coolant pump lube oil

systems. Leakage shall be

collected and drained to a vented

closed container that can hold the

entire lube oil system inventory.

A flame arrester is required in

the vent if the flash point

characteristics of the oil present

the hazard of fire flashback.

Leakage points to be protected

shall include lift pump and

piping, overflow lines, lube oil

cooler, oil fill and drain lines, and plugs, flanged connections on

oil lines, and lube oil reservoirs

where such features exist on the

reactor coolant pumps. The drain

line shall be large enough to

accommodate the largest potential

oil break.

Seven drip pans will be installed on each pump. These seven pans will collect oil

drips from all potential leakage points and

route this oil to a safe collection point.

The following seven pans are installed on

each pump:a.A drip pan inside the motor housing below the lower motor bearing.b.A drip pan under the bottom of the oil cooler.c.A drip pan around the oil cooler under the upper flange.d.A drip pan which encloses the oil lift pump.e.A drip pan under the oil level alarm and sight gauge.f.A drip pan under the flange on the oil line from the RCP motor to the oil

cooler inlet.g.A drip pan under the flange on the oil line from the oil cooler outlet to the

RCP motor; this pan also encompasses

the oil drain valve connection.

The pans are designed such that all external piping connections are above the

pans. A piping system collects all the oil

drips and seepage and routes the oil to

closed containers in the containment which

are sized to collect the amount of oil

expected to be collected between outages.

In the event of a major leak, an overflow

line from the containers will transfer the

oil directly into the containment oil

collection vault. In the unlikely event

the vault is overfilled, the oil would back

up into the containment floor drain sump.

Under no conditions would the oil drain

into an area which is not closed.

A5.7-36 B/B AMENDMENT 19 DECEMBER 2000 10 CFR 50 APPENDIX R BYRON/BRAIDWOOD CONFORMANCE REMARKS

A spare RCP motor is located on elevation 401 feet 0 inch in the Fuel Handling

Building at Braidwood. The RCP assembly

contains 240 gallons of lubricating oil.

An oil collection system is not provided.

Except during a periodic preventative

maintenance surveillance to rotate the

motor, the oil is not normally pressurized.

This configuration does not present a similar fire hazard as an inservice RCP

inside containment. The hazard

presented by the spare RCP

configuration without an oil collection

system has been evaluated, and the

design features are adequate for the

level of hazard.

A5.7-37 BRAIDWOOD - FPR AMENDMENT 24 DECEMBER 2010A5.8-iAPPENDIX 5.8DEVIATIONS FROM BRANCH TECHNICAL POSITION CMEB 9.5-1 SECTION C.5.b BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -ii TABLE OF CONTENTS A5.8 DEVIATIONS FROM BTP CMEB 9.5-1 SECTION C.5.b PAGEA5.8.1Deviation No.: 0A.1 (Fire Zone 2.1-0)A5.8-1A5.8.2Deviation No.: 0A.2 (Fire Zone 11.3-0)A5.8-2 A5.8.3Deviation No.: 0A.3 (Fire Zone 11.4-0)A5.8-4 A5.8.4Deviation No.: 0A.4 (Fire Zone 11.4C-0)A5.8-6 A5.8.5Deviation No.: 0A.5 (Fire Zone 11.5-0)A5.8-7 A5.8.6Deviation No.: 0A.6 (Fire Zone 11.6-0) A5.8-8 A5.8.7Deviation No.: 0A.7 (Fire Zone 11.7-0)A5.8-9 A5.8.8Deviation No.: 1A.1 (Fire Zone 18.3-1)A5.8-12 A5.8.9Deviation No.: 1A.2 (Fire Zone 11.2A-1 & 11.2D-1)A5.8-15 A5.8.10Deviation No.: 1A.3 (Fire Zone 5.5-1)A5.8-17 A5.8.11Deviation No.: 1A.4 (Fire Zone 3.2A-1)A5.8-18 A5.8.12Deviation No.: 1A.5 (Fire Zone 3.2B-1)A5.8-19 A5.8.13Deviation No.: 1C.1 (Fire Zone 1-1)A5.8-20 A5.8.14Deviation No.: 2A.1 (Fire Zone 18.3-2)A5.8-33A5.8.15Deviation No.: 2A.2 (Fire Zone 11.2A-2 & 11.2D-2)A5.8-36A5.8.16Deviation No.: 2A.3 (Fire Zone 5.5-2)A5.8-38A5.8.17Deviation No.: 2C.1 (Fire Zone 1-2)A5.8-39 BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -iiiA5.8DEVIATIONS FROM SECTION C.5.b OF BTP CMEB 9.5-1 INTRODUCTIONThis appendix addresses deviations from Section C.5.b "Safe Shutdown Capability" of BTP CMEB 9.5-1 that exist because of redundant safe shutdown equipment located in a

fire zone. Deviations common to both Unit 1 and Unit 2 begin with the number "0". Unit 1 deviations begin with the number "1" and Unit 2 deviations begin with the number "2".

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -1A5.8.1Deviation No: 0A.1 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone, and for which alternate or dedicated

shutdown capability is provided.

Fire Zone(s) or Elevations Involved451 feet 0 inch (Fire Zone 2.1-0)

Description of Equipment/Cables Involved The cables and equipment required for safe shutdown and located in Fire Zone 2.1-0 are listed in Table 2.4-4.

Description of Deviation(s)The redundant safe shutdown cables located in Fire Zone 2.1-0 are not separated by a 20-foot space free of combustible materials and the area is not covered by a total suppression system. This is not in accordance with the guidelines of Section C.5.B(2),

paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously identified

as deviations 1A.20 and 2A.20 in FPR Amendment 20.)

Justification for Deviation(s)Controls and instrumentation for all plant systems are located in the control room.

Although separation of redundant trains does not meet the requirements of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1, alternative shutdown systems and equipment independent of this zone are provided. Specifically, the remote Shutdown

Panel and Fire Hazards Panel have sufficient controls and instrumentation to bring the

plant to hot standby, and taking credit for local manual operations, cold shutdown can be achieved. This meets the requirements of Section C.5.B(3),and is therefore acceptable.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -2A5.8.2Deviation No: 0A.2 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the auxiliary building general area at

elevation 364 feet).

Fire Zone(s) or Elevations Involved364 feet 0 inch (Fire Zone 11.3-0)

Description of Equipment/Cables Involved The redundant cables and equipment required for safe shutdown and located in Fire Zone 11.3-0 are listed in Table 2.4-4. However, not all of these cables and components are the

subject of this deviation.

Description of Deviation The five component cooling pumps for both units ("0", 1A, 1B, 2A and 2B) and pump power cables are present in Fire Zone 11.3-0, and are located in a small area. For either

of the two units, the separation between the redundant pumps and their associated power

cables is less than 20 horizontal feet.

Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the redundant

pumps and their power cables are located within the same fire zone, and no fire barrier is

present. Section C.5.B(2) paragraph (b) specifies separation between redundant cables

and equipment by 20 feet of horizontal distance with no intervening combustibles and

installation of fire detectors and an automatic suppression system in the area. This

requirement is not met because the redundant pumps and their associated power cables are less than 20 feet apart, and intervening combustibles are present. Although detection is available in this fire zone, this requirement is also not met because an area-wide

automatic fire suppression system is not provided in the fire zone (note that a partial

coverage automatic suppression system is installed in the immediate area of the

component cooling water pumps). Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment of one train by a 1-hour rated fire barrier and installation of fire detectors and an automatic suppression system in the area. As previously stated, no fire barriers are present in the zone, and an area-wide automatic suppression system is

not installed. Therefore, the separation between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This

deviation was previously identified as deviations 1A.15 and 2A.15 in FPR Amendment 20.)

Justification for Deviation In order to ensure that a single fire cannot damage all of the component cooling water pumps and cables in the zone, the following fire protection measures are employed:

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -3 Partial height masonry walls separate the redundant component cooling water pumps. One partial height wall separates the 1A and 1B pumps from the common pump and the

two Unit 2 pumps. A second partial height wall separates the 2A and 2B pumps from the

common pump and the two Unit 1 pumps.

The routing of the power cable for the common component cooling water pump is limited to the area directly adjacent to the pump motor and is separated from the redundant

cables by the partial height masonry walls. This cable is terminated at the motor and is routed directly through the 364-foot slab into the fire zone below.An automatic fixed water suppression system is installed over the component cooling water pumps. This sprinkler system provides adequate coverage for an area out to at

least 20 feet past the pumps in all directions. The pump motors have spray shields to

prevent water damage.The component cooling water heat exchangers separate the pumps from the rest of the area and will act as radiant energy shields should a fire break out elsewhere in the room.

This is a large open area with a low combustible loading. Area wide detection is provided.

Because of the partial height masonry walls, the common pump power cable routing, the area wide detection and the automatic water suppression system over the component

cooling water pumps, and the large area and low combustible loading of this zone, the

damage from a single fire will be limited such that at most two of the pumps could be

affected. For each single fire in the area of the pumps, at least three of the pumps will

remain available to serve the demand for both units. Thus, a level of protection equivalent

to that of Section C.5.B(2) is achieved.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -4 A5.8.3Deviation No: 0A.3 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (general area, Auxiliary Building

Elevation 383 feet).

Fire Zone(s) or Elevations Involved 383 feet 0 inch (Fire Zone 11.4-0)

Description of Equipment/Cables Involved The redundant cables and equipment required for safe shutdown and located inFire Zone 11.4-0 are listed in Table 2.4-4.

Description of Deviation(s)The redundant safe shutdown cables located in Fire Zone 11.4-0 are less than 20 feet apart and the intervening space contains combustible materials and the area is not covered by a total suppression system which is not in accordance with the guidelines of

Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Cables for both trains of the control room ventilation system are present in this zone. The separation of these cables does not meet the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously

identified as deviations 1A.16 and 2A.16 in FPR Amendment 20.)

Justification for Deviation(s)The diesel-driven auxiliary feedwater pumps are located within their own rooms, which have 3-hour fire-rated barriers separating them from the general area outside. These

pumps can be manually started from a local control panel in these rooms, and they will

operate by manual remote start capability completely independent of the associated

cables located outside of the room in the general area on Elevation 383 feet 0 inch (Fire Zone 11.4-0). Thus, the fact that cables for the motor driven and diesel driven AFW pumps are present in the same area in Fire Zone 11.4-0 and could be damaged by a single fire is acceptable, since the Division 1(2)2 diesel-driven AFW pump can still be

manually started and operated.

In order to provide an adequate supply of water to the secondary heat sink in a timely manner following a fire in this zone, remote start capability for the diesel-driven auxiliary

feedwater pumps is required. Therefore, a remote switch has been installed at the elevation below in Fire Zone 11.3-0 to ensure that the diesel-driven auxiliary feedwater

pumps can be manually started in the case of a fire in Fire Zone 11.4-0.Cables 1(2)AF346 and 1(2)AF338 routed through Fire Zone 11.4-0 supply a low-low suction pressure signal that could trip the 1(2)B auxiliary feedwater pump. If this happens, BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -5 the 1(2)B pump can be manually started even if cables 1(2)AF346 and 1(2)AF338 are damaged by a fire. Several other cables associated with both AFW pumps are routed through Fire Zone 11.4-0; however, an evaluation has shown that the 1(2)B AFW pump can be started locally if a fire destroyed these cables. Although cables for both AFW pumps are present in the same area in Fire Zone 11.4-0 and could be damaged by a single fire, the Division 1(2)2 diesel-driven AFW can still be manually started and

operated.In the event of the total loss of the VC system, portable fans will be staged and flow paths established to ventilate the AEERs and main control room from the Turbine Building.

Station evaluations (reference EC#333738 and Calculation #BRW-97-0339-M/BYR97-210), assuming Turbine Building ambient temperatures associated with peak summer

temperatures, have demonstrated that temporary ventilation can maintain the AEER and

main control room temperatures within conditions to assure the control room remains habitable and control room instrumentation would not be adversely affected. Additionally, safe shutdown instrumentation at the unit 1 and unit 2 fire hazards panels would not be

affected by the loss of the VC system. The fire zone is provided with fire detection and

manual suppression capability.

In summary, the automatic fire detection and manual suppression capabilities, controlled access, and manual provisions to manually start the 1(2)B AFW pump and provide ventilation for loss of the VC system, provide a level of fire protection equivalent to that specified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -6A5.8.4Deviation No: 0A.4 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (Auxiliary Building, Remote Shutdown

Panel Rooms, elevation 383 feet).

Fire Zone(s) or Elevations Involved 383 feet 0 inch (Fire Zone 11.4C-0)

Description of Equipment/Cables Involved The redundant cables and equipment required for safe shutdown and located inFire Zone 11.4C-0 are listed in Table 2.4-4.

Description of Deviation(s)

The Units 1 and 2 remote shutdown panels are located in this zone. A fire in this zone could render inoperable the remote shutdown panels and the corresponding controls in

the control room. As a result, redundant systems required for safe shutdown could be adversely affected. In addition, no area-wide automatic fire suppression is provided. This is not in accordance with the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously identified as deviations 1A.24 and 2A.24 in FPR Amendment 20.)

Justification for Deviation(s)

Fire Zone 11.4C-0 is separated from the rest of the plant by 3-hour-rated fire barriers. The remote shutdown control panels for Unit 1 are contained in a room that is separated from

the room containing the Unit 2 remote shutdown control panels by approximately 90 feet.

One manual hose station and several portable fire extinguishers are available in this zone.

Ionization detectors are provided throughout the fire zone, including the rooms with the

remote shutdown panels, which annunciate and alarm in the control room. The fire load is

moderately low and the bulk of combustible materials consist of cable insulation. In the

event of a fire in this zone, safe shutdown of the plant can be achieved by local operation

of equipment. Also, instruments located at the remote shutdown panels are isolated so that a fire in the room will not affect the instruments in the control room.

In summary, the low combustible loading, automatic fire detection and manual suppression capabilities, and local operation of safe shutdown equipment provide a level of fire protection equivalent to that specified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -7A5.8.5Deviation No: 0A.5 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (general area, Auxiliary Building

Elevation 401 feet).

Fire Zone(s) or Elevations Involved 401 feet 0 inch (Fire Zone 11.5-0)

Description of Equipment/Cables Involved The redundant cables and equipment required for safe shutdown and located in Fire Zone 11.5-0 are listed in Table 2.4-4.

Description of Deviation(s)

Cables for both trains of the control room ventilation system are present in this zone. The separation of these cables does not meet the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously

identified as deviations 1A.27 and 2A.29 in FPR Amendment 20.)

Justification for Deviation(s)

In the event of the total loss of the VC system, portable fans will be staged and flow paths established to ventilate the AEERs and main control room from the Turbine Building.

Station evaluations (reference EC#333738 and Calculation #BRW-97-0339-M/BYR97-

210), assuming Turbine Building ambient temperatures associated with peak summer

temperatures, have demonstrated that temporary ventilation can maintain the AEER and

main control room temperatures within conditions to assure the control room remains

habitable and control room instrumentation would not be adversely affected. Additionally, safe shutdown instrumentation at the unit 1 and unit 2 fire hazards panels would not be

affected by the loss of the VC system. The fire zone is provided with fire detection and

manual suppression capability.The automatic fire detection and manual suppression capabilities described in the Fire Hazard Analysis and manual provisions to provide ventilation for loss of the VC system, provide a level of fire protection equivalent to that specified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -8A5.8.6Deviation No: 0A.6 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (general area, Auxiliary Building

Elevation 426 feet).

Fire Zone(s) or Elevations Involved 426 feet 0 inch (Fire Zone 11.6-0)

Description of Equipment/Cables Involved The redundant cables and equipment required for safe shutdown and located in Fire Zone 11.6-0 are listed in Table 2.4-4.

Description of Deviation(s)Cables for both trains of the control room ventilation system are present in this zone. The separation of these cables does not meet the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously identified as deviations 1A.28 and 2A.30 in FPR Amendment 20.)

Justification for Deviation(s)

In the event of the total loss of the VC system, portable fans will be staged and flow paths established to ventilate the AEERs and main control room from the Turbine Building.

Station evaluations (reference EC#333738 and Calculation #BRW-97-0339-M/BYR97-

210), assuming Turbine Building ambient temperatures associated with peak summer

temperatures, have demonstrated that temporary ventilation can maintain the AEER and

main control room temperatures within conditions to assure the control room remains

habitable and control room instrumentation would not be adversely affected. Additionally, safe shutdown instrumentation at the unit 1 and unit 2 fire hazards panels would not be

affected by the loss of the VC system. The fire zone is provided with fire detection and

manual suppression capability.

The automatic fire detection and manual suppression capabilities described in the Fire Hazard Analysis and manual provisions to provide ventilation for loss of the VC system, provide a level of fire protection equivalent to that specified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -9A5.8.7Deviation No: 0A.7 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the auxiliary building HVAC exhaust

complex).Fire Zone(s) or Elevations InvolvedAuxiliary Building HVAC Exhaust Complex (Fire Zone 11.7-0). This fire zone encompasses multiple elevations of the auxiliary building, including portions of 451 feet -

0 inch, 459 feet - 0 inch, 467 feet - 4 inch and 475 feet - 6 inch.

Description of Equipment/Cables Involved The redundant cables and equipment required for safe shutdown and located in Fire Zone 11.7-0 are listed in Table 2.4-4. However, not all of these cables and components are the

subject of this deviation. The equipment and cables that are the subject of this deviation include the four auxiliary building HVAC supply fans, their respective power cables, the

four auxiliary building HVAC exhaust fans and their respective power cables.The four VA system exhaust fans are located on the 475 feet - 6 inch level. The A and B fans are located close together on the Unit 1 side. The C and D fans are located close

together on the Unit 2 side. The A and B fans and their cables are separated from the C

and D fans and their cables by approximately 40 feet with no significant quantities of intervening combustibles. The four VA system supply fans are located on the 451 feet -0

inch level. The A and B fans are located close together on the Unit 1 side. The C and D

fans are located close together on the Unit 2 side. The A and B fans and their cables are separated from the C and D fans and their cables by a minimum of 40 feet with no

significant quantities of intervening combustibles (although the charcoal filter units are

located to the east side of this room on this elevation).

Description of DeviationThe four VA system supply fans and their power cables, and the four VA system exhaust fans and their power cables are present in the same zone.

Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the redundant

fans and their power cables are located within the same fire zone, and no fire barrier is

present. Section C.5.B(2) paragraph (b) specifies separation between redundant cables

and equipment by 20 feet of horizontal distance with no intervening combustibles and

installation of fire detectors and an automatic suppression system in the area. Although

detection is available in this fire zone (except on elevation 475 feet 6 inch), this requirement is not met because an automatic fire suppression system is not provided in

the fire zone. Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment of one train by a 1-hour rated fire barrier and installation of fire detectors and

an automatic suppression system in the area. As previously stated, no fire barriers are BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -10 present in the zone, and an automatic suppression system is not installed. Therefore, the separation between redundant cables deviates from the guidelines of Section C.5.B(2),

paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously identified

as deviations 1A.22 and 2A.22 in FPR Amendment 20.)

Justification for Deviation The primary justification for this deviation consists of the judgement that a single fire in this zone will not affect all four trains of the auxiliary building ventilation system. This

conclusion is based on the following information. The two Unit 1 (A and B) exhaust fans

and their power feed cables are separated from the two Unit 2 (C and D) exhaust fans and

their power feed cables by approximately 40 feet with no significant quantities of

intervening combustible materials. The two Unit 1 (A and B) supply fans and their power feed cables are separated from the two Unit 2 (C and D) supply fans and their power feed

cables by approximately 40 feet with no significant quantities of intervening combustible

materials. The charcoal filters are present in this area. The filter units are housed in

substantial steel enclosures that separate the combustible charcoal from the rest of the

area. The charcoal filter units are provided with an independent detection system, and a

manual deluge suppression system. This area is provided with ionization detection (except for El. 475 feet - 6 inch) that annunciates and alarms in the main control room.

Manual hose stations and portable extinguishers are provided. Because of the type and

configuration of combustible materials, the detection and suppression capabilities provided, and the existing physical separation between the Unit 1 / Unit 2 supply and

exhaust fans and their cables, a single fire will not affect all four trains of the system.

Additional justification for the deviation is provided by an evaluation of the safe shutdown function of these components. The supply and exhaust fans together provide airflow to

the auxiliary building general areas and the various cubicles and rooms containing plant

equipment. This airflow serves the dual purpose of providing temperature control for the auxiliary building general areas, and establishing pressure balances to ensure air flows

from general areas towards potentially contaminated areas (i.e., for radiological control).

For major safe shutdown components located in their own rooms or cubicles, the primary

cooling function is provided by cubicle coolers. Although the auxiliary building supply and

exhaust fans are relied upon for cooling of some safe shutdown components in some fire

zones, that is not the case for this particular fire zone. The safe shutdown cubicle coolers

for the affected components are independent of the auxiliary building supply and exhaust

fans and this fire zone. Therefore, a fire in this zone would not result in loss of the cooling function for major safe shutdown components, even should all four trains of the auxiliary

building ventilation system be disabled. Loss of the radiological control function could not

prevent safe shutdown of the plant, although it would present operation difficulties to the

operating staff.In consideration of the conditions and features discussed above, the separation between the A/B and C/D trains of the VA system supply and exhaust fans is judged to be

adequate to prevent a fire from disabling all four trains. In addition, redundant cooling capability independent of this zone and the VA system supply and exhaust fans is BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -11 provided for major safe shutdown components. Thus, a level of protection equivalent to that of Section C.5.B(2) is achieved.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -12A5.8.8Deviation No: 1A.1This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the Unit 1 main steam tunnel).

Fire Zone(s) or Elevations Involved Unit 1 Main Steam and Feedwater Pipe Tunnels at various elevations between 357 feet 0 inch and 377 feet 0 inch (Fire Zone 18.3-1). The two valve enclosures that extend up to

grade elevation are also a part of this fire zone.

Description of Equipment/Cables InvolvedThe cables and equipment, required for safe shutdown and located in Fire Zone 18.3-1, are listed in Table 2.4-4. The redundant components and cables consist of valves and

instruments in the main steam and auxiliary feedwater systems.

Description of DeviationThis fire zone encompasses two pipe tunnels and two physically separated valve houses.

The two valve houses are located approximately 120 degrees apart at the northeast and

northwest sides of the exterior containment wall. The below grade main steam and feedwater pipe tunnels connect the two valve houses. The northeast valve house

contains safe components and piping associated with the "B" and "C" steam generators.

The northwest valve house contains safe shutdown components and piping associated with the "A" and "D" steam generators. Safe shutdown components located in (or near to)

the valve houses include the main steam safety valves, the steam generator PORVs, the

MSIVs, MSIV bypass valves, steam generator pressure instruments and auxiliary

feedwater system containment isolation valves. Cables associated with these

components are present in the valve houses, and are also routed through the main steam

and/or feedwater pipe tunnels to the auxiliary building. In the area of the pipe tunnels bounded by column-rows 5 to 10 and P to Q, cables for all of the redundant components

may be present.

The combustible material present in this zone consists of hydraulic fluid that is located in the two valve houses. All cables routed through the pipe tunnels are located in conduit, and thus do not count as exposed combustibles. The main steam and feedwater pipe

tunnels themselves have no combustible materials and no fire loading. Ionization

detection is available in the two valve houses. The pipe tunnels themselves have no detection. Manual extinguishing capability consisting of portable extinguishers and a hose

station is available to the area.

Separation between redundant component located in the two valve houses: Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by

a fire barrier having a 3-hour rating. This is not met because the redundant components

involved are located within the same fire zone, and no fire barrier is present. Section

C.5.B(2) paragraph (b) specifies separation between redundant cables and equipment by BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -1320 feet of horizontal distance with no intervening combustibles and installation of fire detectors and an automatic suppression system in the area. The separation through the

pipe tunnels between the two valve houses is in excess of 200 linear feet with no

intervening combustibles. However, this requirement is not met because neither detection

nor an automatic fire suppression system are provided in the pipe tunnels. Section

C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment of one

train by a 1-hour rated fire barrier and installation of fire detectors and an automatic

suppression system in the area. As previously stated, no fire barriers are present in the

zone, and neither detection nor an automatic suppression system are installed.

Therefore, the separation between redundant components in the two valve houses

deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.Separation between redundant cables within the pipe tunnels: Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having

a 3-hour rating. This is not met because the redundant cables involved are located within the same fire zone, and no fire barrier is present. Section C.5.B(2) paragraph (b) specifies

separation between redundant cables and equipment by 20 feet of horizontal distance

with no intervening combustibles and installation of fire detectors and an automatic suppression system in the area. Although the pipe tunnels have no fire loading (i.e., no

combustible materials), this requirement is not met because existing separation is less

than 20 horizontal feet. In addition, neither detection nor an automatic fire suppression system are provided in the pipe tunnels. Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment of one train by a 1-hour rated fire barrier

and installation of fire detectors and an automatic suppression system in the area. As

previously stated, no fire barriers are present in the zone, and neither detection nor an

automatic suppression system are installed in the pipe tunnels. Therefore, the separation

between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously identified as deviation

1A.23 in FPR Amendment 20.)

Justification for Deviation Separation between redundant component located in the two valve houses: Other than the oil associated with the valve hydraulic systems in both valve enclosures, there are no

combustible materials in the main steam and feedwater tunnels, which then have no fire

load. Detection and manual suppression capability are provided in the valve enclosures.

The separation between the two valve houses, coupled with the absence of combustible

materials in the connecting pipe tunnels, is sufficient to ensure that no single fire could

affect both valve enclosures at once.

Separation between redundant cables within the pipe tunnels: All safe shutdown cables located in this fire zone are routed in conduit. This fact, in conjunction with the absence of

combustible materials within the pipe tunnels, is sufficient to ensure a single fire (involving transient combustible materials) will not affect redundant safe shutdown cables.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -14 In summary, because the cables are routed in conduit, and considering the configuration of combustible materials, and detection and manual suppression capability, a level of protection equivalent to Section C.5.B(2) of BTP CMEB 9.5-1 is achieved. The existing

separation is judged to be adequate to preclude a single fire in the pipe tunnels or within

one of the valve houses from affecting redundant safe shutdown components or cables.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -15A5.8.9 Deviation No.: 1A.2This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) between fire zones (1A RHR pump room and 1B RHR pump

room).Fire Zone(s) or Elevations Involved 346 feet 0 inch (Fire Zone 11.2A-1) 346 feet 0 inch (Fire Zone 11.2D-1)

Description of Equipment/Cables InvolvedThe cables and equipment, required for safe shutdown and located in Fire Zones 11.2A-1 and 11.2D-1, are listed in Table 2.4-4. The redundant components and cables consist of RHR pump 1A and its cubicle cooler located in Fire Zone 11.2A-1 and RHR pump

1B and its cubicle cooler located in Fire Zone 11.2D-1.

Description of Deviation(s)The RHR pumps and cubicle coolers located in Fire Zone 11.2A-1 are separated from the redundant RHR pump and cubicle cooler, located in Fire Zone 11.2D-1, by a 2-hour-rated fire barrier. Also, area-wide automatic fire suppression is not provided in either zone; nor

is it provided in Fire Zones 11.2B-1and 11.2C-1 (containment spray pump rooms), which are located between the RHR pump rooms.This is not in accordance with the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously identified as deviation 1A.8 in FPR Amendment 20.)

Justification for Deviation(s)

Due to the presence of the containment spray pump rooms between the RHR pump rooms, the separation between the two trains of RHR components is greater than 75 feet.

The 3 walls between the two trains of RHR components are all of 3-hour construction.

Two of the walls contain unsealed penetrations or penetrations with non-fire-rated seals.

The wall at column-row W between the two containment spray pump rooms is upgraded to

a 2-hour-rated fire barrier. The RHR pump rooms and the containment spray pump rooms have low combustible loadings. All of these rooms are provided with automatic fire

detection. Fire Zone 11.2B-1 contains a manual hose station having hose of adequate length to reach Fire Zones 11.2A-1, 11.2C-1, and 11.2D-1. Also, portable extinguishers are provided in adjacent Fire Zone 11.2-0 (auxiliary building general area).

The residual heat removal system is not required for hot shutdown of the plant. Station repair procedures have been written to ensure that the RHR system will be repaired and

available to achieve cold shutdown conditions within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> after a fire.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -16 In summary, the large distance separating the two trains of RHR pumps and cubicle coolers, the 2 hour-rated fire barrier, fire detection and manual fire suppression provided, establish a level of fire protection commensurate with the guidelinesof Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -17A5.8.10Deviation No: 1A.3 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the Unit 1 Auxiliary Electric Equipment

Room), and for which alternate or dedicated shutdown capability is provided.

Fire Zone(s) or Elevations Involved451 feet 0 inch (Fire Zone 5.5-1)Description of of Equipment/Cables Involved The cables and equipment required for safe shutdown and located in Fire Zone 5.5-1 are listed in Table 2.4-4.

Description of Deviation(s)The redundant safe shutdown cables present in Fire Zone 5.5-1 are not separated by 20 feet with the intervening space free of combustible materials. Also the area is not covered

by a total suppression system. This is not in accordance with the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously

identified as deviations 1A.21 in FPR Amendment 20.)

Justification for Deviation(s)

Instrumentation for both trains of safe shutdown equipment is located in this zone. Although separation of this redundant equipment does not meet the requirements of guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1, alternative

shutdown instrumentation independent of this zone is provided. Specifically, the Fire Hazards Panel, described in Subsection 2.4 of the Fire Protection Report, has sufficient

instrumentation to bring the plant to the hot standby condition, and taking credit for local

manual operation, cold shutdown can be achieved. This meets the requirements of

Section C.5.B(3) and is therefore acceptable.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -18 A5.8.11Deviation No: 1A.4 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone.

Fire Zone(s) or Elevations Involved 439 feet 0 inch (Fire Zone 3.2A-1)

Description of Equipment/Cables Involved The redundant cables and equipment required for safe shutdown and located in Fire Zone 3.2A-1 are listed in Table 2.4-4.

Description of Deviation(s)

Cables for both trains of the control room ventilation system are present in this zone. The separation of these cables does not meet the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously

identified as deviations 1A.19 in FPR Amendment 20.)

Justification for Deviation(s)The fire zone is provided with fire detection and an area-wide automatic suppression system.In the event of the total loss of the VC system, portable fans will be staged and flow paths established to ventilate the AEERs and main control room from the Turbine Building.

Station evaluations (reference EC#333738 and Calculation #BRW-97-0339-M/BYR97-

210), assuming Turbine Building ambient temperatures associated with peak summer

temperatures, have demonstrated that temporary ventilation can maintain the AEER and

main control room temperatures within conditions to assure the control room remains

habitable and control room instrumentation would not be adversely affected. Additionally, safe shutdown instrumentation at the unit 1 and unit 2 fire hazards panels would not be

affected by the loss of the VC system.

The automatic fire detection and suppression capabilities described in the Fire Hazard Analysis, controlled access, and manual provisions to provide ventilation for loss of the VC system, provide a level of fire protection equivalent to that specified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -19A5.8.12Deviation No: 1A.5 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone.

Fire Zone(s) or Elevations Involved 439 feet 0 inch (Fire Zone 3.2B-1)

Description of Equipment/Cables Involved The redundant cables and equipment required for safe shutdown and located inFire Zone 3.2B-1 are listed inTable 2.4-4.

Description of Deviation(s)

Cables for both trains of the control room ventilation system are present in this zone. The separation of these cables does not meet the separation requirements of Section

C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously

identified as deviations 1A.29 in FPR Amendment 20.)

Justification for Deviation(s)

In the event of the total loss of the VC system, portable fans will be staged and flow paths established to ventilate the AEERs and main control room from the Turbine Building.

Station evaluations (reference EC#333738 and Calculation #BRW-97-0339-M/BYR97-

210), assuming Turbine Building ambient temperatures associated with peak summer

temperatures, have demonstrated that temporary ventilation can maintain the AEER and

main control room temperatures within conditions to assure the control room remains

habitable and control room instrumentation would not be adversely affected. Additionally, safe shutdown instrumentation at the unit 1 and unit 2 fire hazards panels would not be

affected by the loss of the VC system. The fire zone is provided with fire detection and an

area-wide automatic suppression system.

The automatic fire detection and suppression capabilities described in the Fire Hazard Analysis, controlled access, and manual provisions to provide ventilation for loss of the VC

system, provide a level of fire protection equivalent to that specified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -20A5.8.13Deviation No: 1C.1 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) for a single fire zone (the containment).

Fire Zone(s) or Elevations InvolvedUnit 1 Containment (Fire Zone 1-1)

A5.8.13.1Description of Equipment/Cables Involved Pressurizer Power-Operated Relief Valves (PORV) and Block Valves Pressurizer power-operated relief valves, block valves and associated power and control cables which are required for safe shutdown are located in containment. For the Division

11 PORV, the associated control cables are 1RY247, 1RY248, 1RY249, 1RY388 and

1RY490. Cable 1RY490 is routed between the containment electrical penetration and a

junction box located within the pressurizer cubicle. The remaining four cables are located

entirely within the pressurizer cubicle. For the Division 11 PORV block valve, the

associated power and control cables are 1RY002 and 1RY004, which are routed between the containment electrical penetrations and the block valve itself, which is located within

the pressurizer cubicle.

For the Division 12 PORV, the associated control cables are 1RY253, 1RY254, 1RY255, 1RY389 and 1RY491. Cable 1RY491 is routed between the containment electrical

penetration and a junction box located within the pressurizer cubicle. The remaining four

cables are located entirely within the pressurizer cubicle. For the Division 12 PORV block

valve, the associated power and control cables are 1RY007 and 1RY009, which are

routed between the containment electrical penetrations and the block valve itself, which is

located within the pressurizer cubicle.A5.8.13.1Description of Deviation Due to the proximity of both power-operated relief valves and block valves within the pressurizer cubicle, Division 11 cables (1RY002, 1RY004, 1RY247, 1RY248, 1RY249, 1RY388 and 1RY490) and Division 12 cables (1RY007, 1RY009, 1RY253, 1RY254, 1RY255, 1RY389 and 1RY491) are separated by as little as 1 foot. The pressurizer

cubicle is separated from the rest of containment by concrete walls that extend between

Elevations 426 feet 0 inch and 471 feet 0 inch.

Outside of the pressurizer cubicle, all Division 11 and Division 12 cables are horizontally separated by approximately 15 feet on the vertical run along the shield wall between

Elevations 448 feet 0 inch and 467 feet 0 inch, and azimuth angles R7 and R8. Also, between Elevations 421 feet 0 inch and 448 feet 0 inch, azimuth angles R8 and R9, all cables are separated by a vertical distance of approximately 14 feet with intervening

combustibles in the form of cable trays.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -21 Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the redundant

cables are located within the same fire zone, and no fire barrier is present. Section

C.5.B(2) paragraph (b) specifies separation between redundant cables and equipment by

20 feet of horizontal distance with no intervening combustibles and installation of fire detectors and an automatic suppression system in the area. This is not met because the

separation between the redundant cables is less than that specified, and intervening

combustibles in the form of cable insulation in cable trays are present in the area and although detection is available in the affected area, an automatic fire suppression system

is not provided. Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment of one train by a 1-hour rated fire barrier and installation of fire detectors

and an automatic suppression system in the area. As previously stated, no fire barriers

are present in the zone, and an automatic suppression system is not installed. Therefore, the separation between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously

identified as deviations 1C.1 in FPR Amendment 20.)A5.8.13.1Justification for DeviationWithin the pressurizer cubicle, all cables are routed in rigid or flexible conduit. There are no exposed combustible materials within the cubicle that represent a fire hazard. Thus, a

fire within the pressurizer cubicle is considered to be extremely unlikely and the existing

separation is considered to be adequate.

Immediately outside of the pressurizer cubicle, where the cables run vertically along the outside of the shield wall, both sets of cables are in conduit. The minimum horizontal separation is about 15 feet. The only combustible materials here are in cable trays and negligible amounts of free-air routed cable. The only combustible materials here are

cables in cable trays. In this area, the existing separation between redundant cables is considered to be adequate to preclude a single fire from damaging both trains due to the

nature of combustible materials present and the fact that the cables in question are routed

in conduit.

Elsewhere outside of the pressurizer cubicle, Division 11 cables pass underneath Division 12 cables with a minimum vertical separation of 14 feet. This occurs near the penetration

area between R8 and R9. In this area, the Division 11 and Division 12 PORV control

cables (1RY490 and 1RY491, respectively) are routed individually in conduit from their respective penetrations to inside the pressurizer enclosure. Therefore, in the penetration

area, the existing separation between redundant cables is considered to be adequate to

preclude a single fire from damaging both trains due to the nature of the combustible materials present and the fact that the PORV control cables are routed in conduit.

Furthermore, even if both pressurizer PORVs were inoperable, the ability to safely shut down the plant would not be lost. Hot standby could be maintained utilizing the pressurizer safety valves for overpressure protection. Cooldown and depressurization

could be accomplished using the steam generators to remove decay heat, and if required, BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -22 utilizing the letdown system. This mode of operation will take the primary system to a low enough temperature and pressure to initiate RHR system operation.

In summary, because of the low combustible loading coupled with the large size of the area, and the routing of the affected PORV cables within conduit from the electrical

penetrations to the valves, a level of fire protection equivalent to that specified in paragraphs (a), (b) or (c) of BTP CMEB 9.5-1 Section III. G. 2 is provided. The existing

separation between the redundant safe shutdown cables for these components is judged

to be adequate to prevent a single fire from simultaneously damaging both pressurizer

PORVs.A5.8.13.2Description of Equipment/Cables InvolvedSteam Generator Wide Range Level Instrumentation Cables for all four channels of steam generator wide range level instrumentation are located in containment. Only one steam generator is required to achieve and maintain hot

standby. Each of the steam generators has one instrumentation cable which provides wide range level indication; steam generator (SG) 1A - instrumentation cable 1FW018, SG 1B - 1FW020, SG 1C - 1FW022, and SG 1D - 1FW024.A5.8.13.2Description of DeviationAll four water level instrumentation cables (Division 11 - 1FW018 and 1FW024, Division 12 - 1FW020 and 1FW022) have a minimum separation of approximately 15 feet vertically

and 60 feet horizontally in the area bounded by elevations 421 feet 0 inch and 438 feet 0 inch, azimuth angles 141 -15' and 197 -30', at a radius of about 67 feet from the centerline

of containment.Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the redundant

cables are located within the same fire zone, and no fire barrier is present. Section C.5.B(2) paragraph (b) specifies separation between redundant cables and equipment by

20 feet of horizontal distance with no intervening combustibles and installation of fire detectors and an automatic suppression system in the area. This is not met because intervening combustibles in the form of cable insulation in cable trays are present in the

area and although detection is available in the affected area, an automatic fire

suppression system is not provided. Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment of one train by a 1-hour rated fire barrier and installation

of fire detectors and an automatic suppression system in the area. As previously stated, no fire barriers are present in the zone, and an automatic suppression system is not

installed. Therefore, the separation between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This

deviation was previously identified as deviations 1C.2 in FPR Amendment 20.)

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -23A5.8.13.2Justification for Deviation Although intervening combustibles in the form of cable insulation in cable trays and negligible amounts of free-air routed cable are present in the affected area, the cables utilized at Braidwood are constructed per IEEE 383. These cables will not propagate a fire without the presence of an external flame. No other combustible materials are

present in this area in significant quantities. The fire loading in this area is low. The containment is a large open area. The heat and products of combustion of any fire which

may be postulated to start will be dissipated in the upper levels of the containment

building, and will not be concentrated in the immediate area of the fire near potential targets (i.e., other cable trays). In addition, fire detection is provided in this area. For

these reasons, the existing separation between redundant cables is considered to be

adequate to preclude a single fire from damaging all four of these safe shutdown

instruments.A5.8.13.3Description of Equipment/Cables Involved Source Range Neutron Monitoring InstrumentsTwo channels of source range neutron monitoring instruments are provided. Two channels of post-accident nuclear instrumentation are also provided. A single channel of

nuclear indication (of either system) is required to achieve and maintain hot standby.

Cables for the two available channels of source range neutron monitoring instruments are

1NR009 (Division 11) and 1NR130 (Division 12). Cables for the two available channels of post-accident nuclear instrumentation are 1NR251 and 1NR252 (Division 11) and 1NR267

and 1NR 268 (Division 12). All of these cables are routed in containment.

The detectors for the Division 11 and Division 12 channels of the source range nuclear instrument system are located 180 degrees apart to the east and west of the reactor

vessel. The Division 11 detector is located on the west side of the reactor vessel. Its

cable (1NR009) is routed directly south toward the missile barrier. It passes through the missile barrier and is routed to an electrical penetration between azimuth R7 and R8. The

Division 12 detector is located on the east side of the reactor vessel. Its cable (1NR130)

is routed around the north side of the primary shield wall and over to the missile barrier. It follows along the interior side of the missile barrier to near azimuth angle R12. There it

passes through the missile barrier and is routed over to an electrical penetration near R12.The detectors for the Division 11 and Division 12 post-accident nuclear instrument system are located 180 degrees apart to the north and south of the reactor vessel. The Division

11 detector is located on the north side of the reactor vessel. Cable 1NR252 is routed around the outside of the primary shield wall to a box on the east side of the primary

shield wall. Cable 1NR251 is routed from this box directly east to the missile barrier, through the missile barrier, and to an electrical penetration near azimuth R11. The Division 12 detector is located on the south side of the reactor vessel. Cable 1NR267 is

routed in a southwest direction from the detector to a box in the southeast quadrant of the

containment building. Cable 1NR268 is routed from the box directly south to the missile BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -24barrier. After passing through the missile barrier, the cable follows along the exterior containment wall to an electrical penetration between azimuth R8 and R9.

A5.8.13.3Description of Deviation Inside the missile barrier (in the northwest quadrant of the containment building), the separation between cables 1NR009 (Division 11) and 1NR130 (Division 12) is

approximately between 23 feet to 30 feet in the area bounded by Elevations 395 feet 1

inch and 409 feet 2 inches, azimuth angles R12 and R15. The cables for the Division 11

post-accident channel are also located in this same area. Intervening combustibles are

also present in the form of cable trays and lubricating oil in the reactor coolant pump 1A.

The cables for the Division 12 post-accident channel are located a substantial distance

away in the southeast quadrant, and are separated from this area by the primary shield

wall and other internal containment structures.

Outside of the missile barrier, both source range nuclear instrument channels are separated by approximately 65 feet in the area bounded by Elevations 408 feet 0 inch and 435 feet 0 inch, azimuth angles R/8 and R/12. Cables for the two post-accident channels

are present between these two cables. Intervening combustibles are present in the form of cable trays. In addition, area-wide fire detection or suppression is not provided in these

zones.Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the redundant

cables are located within the same fire zone, and no fire barrier is present. Section

C.5.B(2) paragraph (b) specifies separation between redundant cables and equipment by

20 feet of horizontal distance with no intervening combustibles and installation of fire

detectors and an automatic suppression system in the area. This is not met because

intervening combustibles in the form of cable insulation in cable trays are present in the

area and although detection is available in the affected area, an automatic fire

suppression system is not provided. Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment of one train by a 1-hour rated fire barrier and installation

of fire detectors and an automatic suppression system in the area. As previously stated, no fire barriers are present in the zone, and an automatic suppression system is not

installed. Therefore, the separation between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This

deviation was previously identified as deviations 1C.3 in FPR Amendment 20.)A5.8.13.3Justification for Deviation The cables are routed in conduit inside the missile barrier, in the area where cables for three of the four instruments are present. The reactor coolant pump is not considered to

represent a major fire hazard since it is provided with an oil collection system.

Furthermore, heat detectors are provided over the pump. Only two cable trays are located in the area. They are located near radii R12 and R13, where the separation is 30 feet, and not in the area where the separation is 23 feet. In addition, the cable trays are

oriented parallel to the conduits carrying the neutron source range monitoring cables.

Thus, they are not likely to serve as a means to transmit a fire between these cables. A BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -25negligible amount of free-air cable is routed along the primary shield wall at approximate elevation 409 feet 0 inch. In the area of the deviation (azimuth R12 to R15) in will not

come in contact with either conduit for cable 1NR009 (Division 11) or 1NR130 (Division

12). The cables utilized at Braidwood are constructed per IEEE 383 and will not propagate a fire without the presence of an external flame. Therefore, these free-air

cables are not likely to service as a means to transmit a fire between these cables. In addition, the cables for the other post-accident instrument are located on the opposite side

of the primary shield wall, and are not subject to the same fire hazards. Outside of the

missile barrier, the minimum separation between the two source range instrument cables (the pair which are farthest apart) is approximately 65 feet. In view of the fact that the

neutron monitoring cables are in conduit for the majority of their routings, and in

consideration of the nature and orientation of intervening combustibles, the existing

separation is considered to be adequate to preclude a single fire from disabling all of the

instruments.A5.8.13.4Description of Equipment/Cables Involved Pressurizer Pressure Instrumentation Four channels of pressurizer pressure instrumentation are provided. Only one of the four available pressurizer pressure instrumentation channels is required to achieve and

maintain hot standby. Inside containment, a single cable is associated with each of the

four channels. The four instrumentation cables are 1RY199 and 1RY207 in Division 11, and 1RY203 and 1RY211 in Division 12.A5.8.13.4Description of Deviation All four pressurizer pressure instrumentation cables have a minimum separation of approximately 15 feet vertically and 60 feet horizontally in the area bounded by Elevation 421 feet 0 inch and 438 feet 0 inch, azimuth angles 141 -15' and 197 -30', at a radius at

about 67 feet from the centerline of containment.

Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the redundant cables are located within the same fire zone, and no fire barrier is present. Section

C.5.B(2) paragraph (b) specifies separation between redundant cables and equipment by

20 feet of horizontal distance with no intervening combustibles and installation of fire detectors and an automatic suppression system in the area. This is not met because

intervening combustibles in the form of cable insulation in cable trays are present in the

area and although detection is available in the affected area, an automatic fire suppression system is not provided. Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment of one train by a 1-hour rated fire barrier and installation

of fire detectors and an automatic suppression system in the area. As previously stated, no fire barriers are present in the zone, and an automatic suppression system is not

installed. Therefore, the separation between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This

deviation was previously identified as deviations 1C.4 in FPR Amendment 20.)

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -26A5.8.13.4Justification for Deviation A single fire large enough to damage both Division 11 and Division 12 cables would have to span more than 60 feet in the horizontal direction between azimuth angles R9 and R12.

Although intervening combustibles in the form of cable insulation in cable trays and negligible amounts of free-air routed cable are present in the affected area, the cables

utilized at Braidwood are constructed per IEEE 383. These cables will not propagate a

fire without the presence of an external flame. No other combustible materials are

present in this area in significant quantities. The fire loading in this area is low. The

containment is a large open area. The heat and products of combustion of any fire which may be postulated to start will be dissipated in the upper levels of the containment

building, and will not be concentrated in the immediate area of the fire near potential

targets (i.e., other cable trays). In addition, fire detection is provided in this area. For

these reasons, the existing separation between redundant cables is considered to be

adequate to preclude a single fire from damaging all four of these safe shutdown

instruments.A5.8.13.5Description of Equipment/Cables Involved Pressurizer Level Instrumentation Three channels of pressurizer level instrumentation are provided. One of the three pressurizer level instrumentation channels is required to achieve and maintain hot

standby. Inside containment, a single cable is associated with each of the three channels.

The three instrumentation cables are 1RY20l and 1RY209 in Division 11, and 1RY205 in

Division 12.A5.8.13.5Description of Deviation All three pressurizer level instrumentation cables have a minimum separation of approximately 15 feet vertically and 22 feet horizontally in the area bounded by Elevations 410 feet 6 inches and 423 feet 6 inches, azimuth angles 178 -15' and 197 -30', at a radius

of about 67 feet from the centerline of containment.Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the redundant

cables are located within the same fire zone, and no fire barrier is present. Section

C.5.B(2) paragraph (b) specifies separation between redundant cables and equipment by

20 feet of horizontal distance with no intervening combustibles and installation of fire

detectors and an automatic suppression system in the area. This is not met because

intervening combustibles in the form of cable insulation in cable trays are present in the

area and although detection is available in the affected area, an automatic fire

suppression system is not provided. Section C.5.B(2) paragraph (c) specifies enclosure of

redundant cables and equipment of one train by a 1-hour rated fire barrier and installation

of fire detectors and an automatic suppression system in the area. As previously stated, no fire barriers are present in the zone, and an automatic suppression system is not

installed. Therefore, the separation between redundant cables deviates from the BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -27guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously identified as deviations 1C.5 in FPR Amendment 20.)A5.8.13.5Justification for Deviation The pressurizer level instrumentation cables are routed in conduit. Combustibles in the form of cable insulation in cable trays and negligible amounts of free-air routed cable are

present in the affected area, BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -28 the cables utilized at Braidwood are constructed per IEEE 383. These cables will not propagate a fire without the presence of an external flame. No other combustible

materials are present in this area in significant quantities. The fire loading in this area is

low. The containment is a large open area. The heat and products of combustion of any

fire which may be postulated to start will be dissipated in the upper levels of the

containment building, and will not be concentrated in the immediate area of the fire near

potential targets (i.e., other cable trays). In addition, fire detection is provided in this area.

For these reasons, the existing separation between redundant cables is considered to be

adequate to preclude a single fire from damaging all three of these safe shutdown

instruments.A5.8.13.6Description of Equipment/Cables Involved Reactor Coolant Hot Leg Temperature Or Core Exit Temperature Indication for reactor coolant hot leg temperature for one RCS loop or indication of core exit temperature from one division of the incore thermocouples is required to achieve and

maintain hot standby.

Each reactor coolant system hot leg has a dual element RTD. The loop "A" and "D" RTDs are located between the primary and secondary shield walls on the west side of the

reactor cavity. The loop "B" and "C" RTDs are located between the primary and

secondary shield walls on the east side of the reactor cavity.

One of the two elements for each RTD provides a signal to indication in the main control room and at the remote shutdown panel. The four cables associated with the MCR/RSP

indication are 1RC351, 1RC356, 1RC361 and 1RC366. All four of these cables are

Division 11 cables. These four cables are routed in a generally southern direction from their respective RTDs to outside of the secondary shield wall, and from there they follow

along the exterior containment wall over to their Division 11 electrical penetration located

near R8. The remaining element for each RTD provides a signal to electrically independent indication located on the Fire Hazards Panel. The four cables associated with the FHP

indication are 1RC743, 1RC745, 1RC747 and 1RC749. All four of these cables are

Division 12 cables. Starting at their respective RTDs, these four cables are routed in a

generally northerly direction to outside of the secondary shield wall, and from there they

follow along the exterior containment wall over to their Division 12 electrical penetration

located near R11.The Division 11 incore thermocouple cables are 1IT308 through 1IT340, 1IT343, 1IT344, 1IT425 and the 33 incore thermocouple circuits combined into five multiconductor mineral

insulated cables 1IT428, 1IT429, 1IT432, 1IT433, 1IT436, 1IT437, 1IT440, 1IT441, 1IT444, and 1IT445 (two cable numbers assigned per multiconductor cable) from junction

box 1JB634R to the reactor vessel head. The Division 12 incore thermocouple cables are

1IT351 through 1IT382, 1IT347, 1IT348, 1IT427, and the 32 incore thermocouple circuits BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -29 combined into five multiconductor mineral insulated cables 1IT430, 1IT431, 1IT434, 1IT435, 1IT438, 1IT439, 1IT442, 1IT443, 1IT446, and 1IT447 (two cable numbers

assigned per multiconductor cable) from junction box 1JB635R to the reactor vessel head.The Division 11 incore thermocouple cables are routed in conduit from a containment penetration at Elevation 417 feet 6 inches between R8 and R9 to junction box 1JB634R

outside the missile barrier at Elevation 431 feet 9 inches between R11 and R12. The

Division 12 incore thermocouple cables are routed in conduit from a containment

penetration at Elevation 439 feet 3 inches near R8 to junction box 1JB635R outside the

missile barrier at Elevation 435 feet 9 inches between R11 and R12. The mineral insulated cables for both divisions are routed in conduit from junction boxes 1JB634R and

1JB635R, between steam generators 1A and 1D, to the primary shield wall. These same

cables are then routed in cable trays (Elevation 430 feet) from the primary shield wall to a

connector plate above the reactor vessel, and from there routed vertically down to the

reactor vessel head.A5.8.13.6Description of Deviation Section C.5.B (2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the redundant

cables are located within the same fire zone, and no fire barrier is present. Section

C.5.B(2) paragraph (b) specifies separation between redundant cables and equipment by

20 feet of horizontal distance with no intervening combustibles and installation of fire

detectors and an automatic suppression system in the area. This is not met because the

separation between the redundant cables is less than that specified, and intervening

combustibles in the form of cable insulation in cable trays are present in the area and

although detection is available in the affected area, an automatic fire suppression system

is not provided. The Divisions 11 and 12 reactor coolant hot leg temperature and incore thermocouple cables are routed in the closest proximity to each other outside of the

secondary shield wall. The minimum horizontal separation between a single division of

either the hot leg cables or the incore thermocouple cables is approximately 52 feet in the sector bounded by R8 and R11. Section C.5.B (2) paragraph (c) specifies enclosure of redundant cables and equipment of one train by a 1-hour rated fire barrier and installation

of fire detectors and an automatic suppression system in the area. As previously stated, no fire barriers are present in the zone, and an automatic suppression system is not

installed. Therefore, the separation between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This

deviation was previously identified as deviations 1C.6 in FPR Amendment 20.)A5.8.13.6Justification for Deviation Between the primary and secondary shield walls, the RCS loop "B" and "C" RTDs and their cables are separated from the RCS loop "A" and "D" RTDs and their cables and the

incore thermocouple cables by the primary shield wall and/or the refueling pool structure.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -30 The primary shield wall is a concrete structure approximately 34 feet in diameter that encloses the reactor cavity and reactor vessel. These structures serve the purpose of a noncombustible radiant energy shield that separates the loop "B" and "C" RTDs and

cables from the redundant loop "A" and "D" RTDs and cables and incore thermocouple

cables. Away from the penetration, the divisional routings of the RTD cables provide good spatial separation, ensuring that indication for at least one loop of reactor coolant hot leg

temperature will be available. As previously stated, the minimum separation of cables

occurs between the containment penetrations and secondary shield wall. The minimum horizontal separation between a single division of either the hot leg cables or the incore

thermocouple cables is approximately 52 feet at the containment penetrations in the

sector bounded by R8 and R11. Therefore, a fire would have to span a horizontal

distance of approximately 52 feet to damage all of the reactor coolant hot leg and incore

thermocouple cables. Although intervening combustibles in the form of cable insulation in cable trays and negligible amounts of free-air routed cable are present in the affected

area, the cables utilized at Braidwood are constructed per IEEE 383. These cables will

not propagate a fire without the presence of an external flame. No other combustible materials (i.e., an external flame source for the cables are present in this area in

significant quantities. The fire loading in this area is low. The containment is a large open

area. The heat and products of combustion of any fire which may be postulated to start will be dissipated in the upper levels of the containment building, and will not be

concentrated in the immediate area of the fire near potential targets (i.e., other cable

trays). In addition, fire detection is provided in this area. For these reasons, the existing separation between redundant cables is considered to be adequate to preclude a single

fire from damaging all of these safe shutdown instruments.A5.8.13.7Description of Equipment/Cables Involved Reactor Coolant Cold Leg Temperature Indication for reactor coolant cold leg temperature for one RCS loop is credited to achieve and maintain hot standby. Each reactor coolant system cold leg has a dual element RTD.

The loop "A" and "D" RTDs are located between the primary and secondary shield walls on the west side of the reactor cavity. The loop "B" and "C" RTDs are located between

the primary and secondary shield walls on the east side of the reactor cavity.

One of the two elements for each RTD provides a signal to indication in the main control room and at the remote shutdown panel. The four cables associated with the MCR/RSP

indication are 1RC373, 1RC392, 1RC397 and 1RC402. All four of these cables are

Division 12 cables. Some of these four cables are routed in a generally northerly direction from their respective RTDs to outside of the secondary shield wall, and from there they

follow along the exterior containment wall over to their Division 12 electrical penetration

located near R12. The other cables remain inside the secondary shield wall until they

pass through it in the immediate vicinity of the electrical penetration located by R12.

The remaining element for each RTD provides a signal to electrically independent indication located on the Fire Hazards Panel. The four cables associated with the FHP

indication are 1RC751, 1RC753, 1RC755 and 1RC757. All four of these cables are also BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -31 Division 12 cables. Starting at their respective RTDs, these four cables are routed in a generally northerly direction to outside of the secondary shield wall, and from there they follow along the exterior containment wall over to their Division 12 electrical penetration

located near R9.A5.8.13.7Description of Deviation The eight cold leg RTD cables have a minimum separation of approximately 1 foot vertically near R12. Combustibles are present in the immediate area in the form of cable

trays.Section C.5.B(2) paragraph (a) is not met because the separation between these cables is less than the specified 20 horizontal feet, and because combustibles in the form of cable insulation in cable trays are present in the area. Section C.5.B(2) paragraph (b) is not met

because an automatic fire suppression system is not provided. Section C.5.B(2) paragraph (c) is not met because non-combustible shields are not provided. Therefore, the separation between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously

identified as deviations 1C.7 in FPR Amendment 20.)A5.8.13.7Justification for DeviationAlthough intervening combustibles in the form of cable insulation in cable trays and negligible amounts of free-air routed cable are present in the affected area, the cables

utilized at Braidwood are constructed per IEEE 383. These cables will not propagate a

fire without the presence of an external flame. No other combustible materials (i.e., an

external flame source for the cables are present in this area in significant quantities. The

fire loading in this area is low. The containment is a large open area. The heat and

products of combustion of any fire which may be postulated to start will be dissipated in

the upper levels of the containment building, and will not be concentrated in the immediate

area of the fire near potential targets (i.e., other cable trays). In addition, fire detection is

provided in this area. For these reasons, the existing separation between redundant

cables is considered to be adequate to preclude a single fire from damaging all of these

safe shutdown instruments. Additionally, the loss of all cold leg RTDs is acceptable for the

following reasons. The cold leg RTDs would normally be used in conjunction with the hot

leg RTDs to verify adequate core cooling, i.e., that natural circulation is present. This condition can also be verified by trending the temperatures indicated by the core exit

thermocouples. As noted in Section A5.8.4.6, the thermocouple cables are routed in

conduit in the area of concern. Furthermore, cold leg temperature can be inferred from steam generator pressure. As indicated in Section 2.4, steam generator pressure

instrumentation and cabling are independent of this zone. Plant emergency procedures

are written to refer to these alternate methods of verifying primary system conditions In fact, the core exit thermocouples are the preferred method. The Byron and Braidwood plant procedures are written using guidance from the Westinghouse Owners Group.

Therefore, this deviation from BTP CMEB 9.5-1 requirements is considered to be

acceptable.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -32A5.8.13.8Description of Equipment/Cables Involved Reactor Containment Fan Cooler (RCFC) FansTwo of the four RCFC fans are required to operate in the high-speed mode to achieve and maintain hot standby. The four RCFCs themselves are located outside of the secondary shield wall at widely spaced intervals around the containment. The high speed power

cables for the RCFC fans routed inside containment are 1VP004, 1VP026, 1VP048, and

1VP070.A5.8.13.8Description of DeviationAll four RCFC power cables (Division 11 - 1VP004 and 1VP048, Division 12 - 1VP026 and 1VP070) have a minimum separation of approximately 36 horizontal feet. This minimum

separation occurs in the area bounded by elevations 393 feet 5 inches and 439 feet 3 inches, azimuth angles R/9 and R/12, at a radius of about 60 feet from the centerline of

containment. There are intervening combustibles in this area in the form of cable

insulation.

Section C.5.B(2) paragraph (a) is not met because intervening combustibles in the form of cable insulation in cable trays are present in the area. Section C.5.B(2) paragraph (b) is

not met because an automatic fire suppression system is not provided. Section C.5.B(2) paragraph (c) is not met because non-combustible shields are not provided. Therefore, the separation between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously

identified as deviations 1C.8 in FPR Amendment 20.)A5.8.13.8Justification for Deviation Although intervening combustibles in the form of cable insulation in cable trays and negligible amounts of free-air routed cable are present in the affected area, the cables

utilized at Braidwood are constructed per IEEE 383. These cables will not propagate a fire without the presence of an external flame. No other combustible materials are present

in this area in significant quantities. The fire loading in this area is low. The containment

is a large open area. The heat and products of combustion of any fire which may be postulated to start will be dissipated in the upper levels of the containment building, and

will not be concentrated in the immediate area of the fire near potential targets (i.e., other cable trays). In addition, fire detection is provided in this area. For these reasons, the

existing separation between redundant cables is considered to be adequate to preclude a

single fire from damaging all of these safe shutdown cables.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -33 A5.8.14Deviation No: 2A.1This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the Unit 2 main steam tunnel).

Fire Zone(s) or Elevations Involved Unit 2 Main Steam and Feedwater Pipe Tunnels at various elevations between 357 feet 0 inch and 377 feet 0 inch (Fire Zone 18.3-2). The two valve enclosures that extend up to

grade elevation are also a part of this fire zone.

Description of Equipment/Cables InvolvedThe cables and equipment required for safe shutdown and located in Fire Zone 18.3-2 are listed in Table 2.4-4. The redundant components and cables consist of valves and

instruments in the main steam and auxiliary feedwater systems.

Description of Deviation This fire zone encompasses two pipe tunnels and two physically separated valve houses.

The two valve houses are located approximately 120 degrees apart at the southeast and

southwest sides of the exterior containment wall. The below grade main steam and

feedwater pipe tunnels connect the two valve houses. The southeast valve house contains safe components and piping associated with the "B" and "C" steam generators.

The southwest valve house contains safe shutdown components and piping associated

with the "A" and "D" steam generators. Safe shutdown components located in (or near to) the valve houses include the main steam safety valves, the steam generator PORVs, the

MSIVs, MSIV bypass valves, steam generator pressure instruments and auxiliary

feedwater system containment isolation valves. Cables associated with these components are present in the valve houses, and are also routed through the main steam

and/or feedwater pipe tunnels to the auxiliary building. In the area of the pipe tunnels bounded by column-rows 26 to 31 and P to Q, cables for all of the redundant components

may be present.The combustible material present in this zone consists of hydraulic fluid that is located in the two valve houses. All cables routed through the pipe tunnels are located in conduit, and thus do not count as exposed combustibles. The main steam and feedwater pipe

tunnels themselves have no combustible materials and no fire loading. Ionization

detection is available in the two valve houses. The pipe tunnels themselves have no detection. Manual extinguishing capability consisting of portable extinguishers and a hose

station is available to the area.

Separation between redundant components located in the two valve houses: Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the redundant components

involved are located within the same fire zone, and no fire barrier is present. Section

C.5.B(2) paragraph (b) specifies separation between redundant cables and equipment by BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -34 20 feet of horizontal distance with no intervening combustibles and installation of fire detectors and an automatic suppression system in the area. The separation through the

pipe tunnels between the two valve houses is in excess of 200 linear feet with no intervening combustibles. However, this requirement is not met because neither detection

nor an automatic fire suppression system are provided in the pipe tunnels. Section

C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment of one

train by a 1-hour rated fire barrier and installation of fire detectors and an automatic

suppression system in the area. As previously stated, no fire barriers are present in the

zone, and neither detection nor an automatic suppression system are installed.

Therefore, the separation between redundant components in the two valve houses

deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.Separation between redundant cables within the pipe tunnels: Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having

a 3-hour rating. This is not met because the redundant cables involved are located within

the same fire zone, and no fire barrier is present. Section C.5.B(2) paragraph (b) specifies

separation between redundant cables and equipment by 20 feet of horizontal distance

with no intervening combustibles and installation of fire detectors and an automatic

suppression system in the area. Although the pipe tunnels have no fire loading (i.e., no

combustible materials), this requirement is not met because existing separation is less

than 20 horizontal feet. In addition, neither detection nor an automatic fire suppression system are provided in the pipe tunnels. Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment of one train by a 1-hour rated fire barrier

and installation of fire detectors and an automatic suppression system in the area. As previously stated, no fire barriers are present in the zone, and neither detection nor an

automatic suppression system are installed in the pipe tunnels. Therefore, the separation

between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously identified as

deviations 2A.23 in FPR Amendment 20.)

Justification for Deviation Separation between redundant component located in the two valve houses: Other than the oil associated with the valve hydraulic systems in both valve enclosures, there are no

combustible materials in the main steam and feedwater tunnels, which then have no fire

load. Detection and manual suppression capability are provided in the valve enclosures.

The separation between the two valve houses, coupled with the absence of combustible

materials in the connecting pipe tunnels, is sufficient to ensure that no single fire could

affect both valve enclosures at once.

Separation between redundant cables within the pipe tunnels: All safe shutdown cables located in this fire zone are routed in conduit. This fact, in conjunction with the absence of

combustible materials within the pipe tunnels, is sufficient to ensure a single fire (involving

transient combustible materials) will not affect redundant safe shutdown cables.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -35 In summary, because the cables are routed in conduit, and considering the configuration of combustible materials, and detection and manual suppression capability, a level of protection equivalent to Section C.5.B(2) of BTP CMEB 9.5-1 is achieved. The existing

separation is judged to be adequate to preclude a single fire in the pipe tunnels or within

one of the valve houses from affecting redundant safe shutdown components or cables.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -36A5.8.15Deviation No: 2A.2 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) between fire zones (2A RHR pump room and 2B RHR pump

room).Fire Zone(s) or Elevations Involved 346 feet 0 inch (Fire Zone 11.2A-2)

346 feet 0 inch (Fire Zone 11.2D-2)

Description of Equipment/Cables InvolvedRHR pump 2A and its cubicle cooler are located in Fire Zone 11.2A-2. RHR pump2B and its cubicle cooler are located in Fire Zone 11.2D-2. Refer to Table 2.4-4 for a

specific list of redundant equipment and cables in these zones.

Description of Deviation(s)The RHR pumps and cubicle coolers located in Fire Zone 11.2A-2 are separatedfrom the redundant RHR pump and cubicle cooler, located in Fire Zone 11.2D-2, by a 2-hour-rated fire barrier. Also, area-wide automatic fire suppression is not provided in either zone; nor is it provided in Fire Zones 11.2B-2 and

11.2C-2 (containment spray pump rooms), which are located between the RHR pump

rooms. This is not in accordance with the guidelines of Section C.5.B(2), paragraphs (a),

(b) and (c) of BTP CMEB 9.5-1. (This deviation was previously identified as deviations

2A.8 in FPR Amendment 20.)

Justification for Deviation(s)

Due to the presence of the containment spray pump rooms between the RHR pump rooms, the separation between the two trains of RHR components is greater than 75 feet.

The 3 walls between the two trains of RHR components are all of 3-hour construction.

Two of the walls contain unsealed penetrations or penetrations with non-fire-rated seals.

The wall at column-row W between the two containment spray pump rooms is upgraded to

a 2-hour-rated fire barrier. The RHR pump rooms and the containment spray pump rooms

have low combustible loading. All of these rooms are provided with automatic fire

detection. Fire Zone 11.2B-2 contains a manual hose station having hose of adequate length to reach Fire Zones 11.2A-2, 11.2C-2, and 11.2D-2. Also, portable extinguishers are provided in adjacent Fire Zone 11.2-0 (auxiliary building general area).

The residual heat removal system is not required for hot shutdown of the plant. Station repair procedures been written to ensure that the RHR system will be repaired and

available to achieve cold shutdown conditions within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> after a fire.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -37 In summary, the large distance separating the two trains of RHR pumps and cubicle coolers, the 2 hour-rated fire barrier, fire detection and manual fire suppression provided, establish a level of fire protection commensurate with the guidelines of Section C.5.B(2),

paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -38A5.8.16Deviation No: 2A.3 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the Unit 2 Auxiliary Electric Equipment Room), and for which alternate or dedicated shutdown capability is provided.

Fire Zone(s) or Elevations Involved451 feet 0 inch (Fire Zone 5.5-2)

Description of Equipment/Cables InvolvedThe cables and equipment required for safe shutdown and located in Fire Zone 5.5-2 are listed in Table 2.4-4.

Description of Deviation(s)The redundant safe shutdown cables present in Fire Zone 5.5-2 are not separated by 20 feet with the intervening space free of combustible materials. Also the area is not covered by a total suppression system. This is not in accordance with the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously

identified as deviations 2A.21 in FPR Amendment 20.)

Justification for Deviation(s)

Instrumentation for both trains of safe shutdown equipment is located in this zone.

Although separation of this redundant equipment does not meet the requirements of

Section III.G.2, alternative shutdown instrumentation independent of this zone is provided.

Specifically, the Fire Hazards Panel, described in Subsection 2.4 of the Fire Protection

Report, has sufficient instrumentation to bring the plant to the hot standby condition, and

taking credit for local manual operation, cold shutdown can be achieved. This meets the

requirements of Section C.5.B(3) and is therefore acceptable.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -39A5.8.17Deviation No: 2C.1 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) for a single fire zone (the containment).

Fire Zone(s) or Elevations InvolvedUnit 2 Containment (Fire Zone 1-2)

A5.8.17.1Description of Equipment/Cables Involved Pressurizer Power-Operated Relief Valves (PORV) and Block ValvesPressurizer power-operated relief valves, block valves and associated power and control cables which are required for safe shutdown are located in containment. For the Division

21 PORV, the associated control cables are 2RY246, 2RY247, 2RY248, 2RY249 and 2RY388. Cable 2RY246 is routed between the containment electrical penetration and a

junction box located within the pressurizer cubicle. The remaining four cables are located

entirely within the pressurizer cubicle. For the Division 21 PORV block valve, the associated power and control cables are 2RY002 and 2RY004, which are routed between

the containment electrical penetrations and the block valve itself, which is located within

the pressurizer cubicle.

For the Division 22 PORV, the associated control cables are 2RY252, 2RY253, 2RY254, 2RY255 and 2RY389. Cable 2RY252 is routed between the containment electrical

penetration and a junction box located within the pressurizer cubicle. The remaining four

cables are located entirely within the pressurizer cubicle. For the Division 22 PORV block

valve, the associated power and control cables are 2RY007 and 2RY009, which are

routed between the containment electrical penetrations and the block valve itself, which is

located within the pressurizer cubicle.A5.8.17.1Description of Deviation Due to the proximity of both power-operated relief valves and block valves within the pressurizer cubicle, Division 21 cables (2RY002, 2RY004, 2RY246, 2RY247, 2RY248, 2RY49 and 2RY388) and Division 22 cables (2RY007, 2RY009, 2RY252, 2RY253, 2RY254, 2RY255, and 2RY389) are separated by as little as 1 foot. The pressurizer

cubicle is separated from the rest of containment by concrete walls that extend between

Elevations 426 feet 0 inch and 471 feet 0 inch.

Outside of the pressurizer cubicle, all Division 21 and Division 22 cables are horizontally separated by approximately 15 feet on the vertical run along the shield wall between

Elevations 440 feet 0 inch and 467 feet 0 inch, and azimuth angles R25 and R26. Also, between Elevations 421 feet 0 inch and 440 feet 0 inch, azimuth angles R24 and R25, all

cables are separated by a vertical distance of approximately 14 feet with intervening

combustibles in the form of cable trays.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -40 Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment of 20 horizontal feet with no intervening combustibles. This is not met because

the separation between the redundant cables is less than that specified, and intervening

combustibles in the form of cable insulation in cable trays are present in the area. Section C.5.B(2) paragraph (b) specifies installation of fire detectors and an automatic

suppression system in the area. Although detection is available in the affected area, this

is not met because an automatic fire suppression system is not provided. Section C.5.B(2) paragraph (c) specifies separation of redundant cables by a non-combustible radiant energy shields. Non-combustible shields are not provided. Therefore, the

separation between redundant cables deviates from the guidelines of Section C.5.B(2),

paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously identified

as deviations 2C.1 in FPR Amendment 20.)A5.8.17.1Justification for DeviationWithin the pressurizer cubicle, all cables are routed in rigid or flexible conduit. There are no exposed combustible materials within the cubicle that represent a fire hazard. Thus, a

fire within the pressurizer cubicle is considered to be extremely unlikely and the existing

separation is considered to be adequate.Immediately outside of the pressurizer cubicle, where the cables run vertically along the outside of the shield wall, both sets of cables are in conduit. The minimum horizontal separation is about 2 feet. The only combustible materials here are in cable trays and negligible amounts of free-air routed cable. In this area, the existing separation between

redundant cables is considered to be adequate to preclude a single fire from damaging

both trains due to the nature of combustible materials present and the fact that the cables in question are routed in conduit.

Elsewhere outside of the pressurizer cubicle, Division 21 cables pass underneath Division 22 cables with a minimum vertical separation of 13 feet. This occurs near the penetration area between R24 and R25. In this area, the Division 21 and Division 22 PORV control

cables (2RY246 and 2RY252, respectively) are routed individually in conduit from their

respective penetrations to inside the pressurizer enclosure. Therefore, in the penetration area, the existing separation between redundant cables is considered to be adequate to

preclude a single fire from damaging both trains due to the nature of the combustible

materials present and the fact that the PORV control cables are routed in conduit.Furthermore, even if both pressurizer PORVs were inoperable, the ability to safely shut down the plant would not be lost. Hot standby could be maintained utilizing the

pressurizer safety valves for overpressure protection. Cooldown and depressurization could be accomplished using the steam generators to remove decay heat, and if required, utilizing the letdown system. This mode of operation will take the primary system to a low

enough temperature and pressure to initiate RHR system operation.

In summary, because of the low combustible loading coupled with the large size of the area, and the routing of the affected PORV cables within conduit from the electrical

penetrations to the valves, a level of fire protection equivalent to that specified in BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -41paragraphs (a), (b) or (c) of BTP CMEB 9.5-1 is provided. The existing separation between the redundant safe shutdown cables for these components is judged to be

adequate to prevent a single fire from simultaneously damaging both pressurizer PORVs

.A5.8.17.2Description of Equipment/Cables InvolvedSteam Generator Wide Range Level Instrumentation Cables for all four channels of steam generator wide range level instrumentation are

located in containment. Only one steam generator is required to achieve and maintain hot standby. Each of the steam generators has one instrumentation cable which provides wide range level indication; steam generator (SG) 2A - instrumentation cable 2FW018, SG 2B - 2FW020, SG 2C - 2FW022, and SG 2D - 2FW024.A5.8.17.2Description of DeviationAll four water level instrumentation cables (Division 21 - 2FW018 and 2FW024, Division 22 - 2FW020 and 2FW022) have a minimum separation of approximately 15 feet vertically

and 60 feet horizontally in the area bounded by elevations 400 feet 0 inch and 440 feet 0 inch, azimuth angles R25 and R42, at a radius of about 67 feet from the centerline of

containment.

Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment of 20 horizontal feet with no intervening combustibles. This is not met because

intervening combustibles in the form of cable insulation in cable trays are present in the

area. Section C.5.B(2) paragraph (b) specifies installation of fire detectors and an

automatic suppression system in the area. Although detection is available in the affected

area, this is not met because an automatic fire suppression system is not provided.

Section C.5.B(2) paragraph (c) specifies separation of redundant cables by a non-combustible radiant energy shields. Non-combustible shields are not provided.

Therefore, the separation between redundant cables deviates from the guidelines of

Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was

previously identified as deviations 2C.2 in FPR Amendment 20.)A5.8.17.2Justification for Deviation A single fire large enough to damage all four cables would have to span more than 60 feet in the horizontal direction between azimuth angles R25 and R42. Although intervening combustibles in the form of cable insulation in cable trays and negligible amounts of free-air routed cable are present in the affected area, the cables utilized at Braidwood are

constructed per IEEE 383. These cables will not propagate a fire without the presence of an external flame. No other combustible materials are present in this area in significant

quantities. The fire loading in this area is low. The containment is a large open area. The

heat and products of combustion of any fire which may be postulated to start will be dissipated in the upper levels of the containment building, and will not be concentrated in

the immediate area of the fire near potential targets (i.e., other cable trays). In addition, fire detection is provided in this area. For these reasons, the existing separation between BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -42redundant cables is considered to be adequate to preclude a single fire from damaging all four of these safe shutdown instruments.A5.8.17.3Description of Equipment/Cables Involved Source Range Neutron Monitoring InstrumentsTwo channels of source range neutron monitoring instruments are provided. Two channels of post-accident nuclear instrumentation are also provided. A single channel of

nuclear indication (of either system) is required to achieve and maintain hot standby.

Cables for the two available channels of source range neutron monitoring instruments are

2NR009 (Division 21) and 2NR130 (Division 22). Cables for the two available channels of

post-accident nuclear instrumentation are 2NR251 and 2NR252 (Division 21) and 2NR267

and 2NR 268 (Division 22). All of these cables are routed in containment.

The detectors for the Division 21 and division 22 channels of the source range nuclear instrument system are located 180 degrees apart to the east and west of the reactor vessel. The Division 21 detector is located on the west side of the reactor vessel. Its

cable (2NR009) is routed directly north toward the missile barrier. It passes through the

missile barrier and is routed to an electrical penetration between azimuth R25 and R26.

The Division 22 detector is located on the east side of the reactor vessel. Its cable

(2NR130) is routed around the south side of the primary shield wall and over to the missile

barrier. It follows along the interior side of the missile barrier to near azimuth angle R42.

There it passes through the missile barrier and is routed over to an electrical penetration

near R42.The detectors for the Division 21 and Division 22 post-accident nuclear instrument system are located 180 degrees apart to the north and south of the reactor vessel. The Division 21 detector is located on the south side of the reactor vessel. Cable 2NR252 is routed

around the outside of the primary shield wall to a box on the southwest side of the primary shield wall. Cable 2NR251 is routed from this box directly southwest to the missile barrier, along the inside wall of the missile barrier, through the missile barrier near R22, and to an

electrical penetration near azimuth R22. The Division 22 detector is located on the north side of the reactor vessel. Cable 2NR267 is routed in a northeast direction from the

detector to a box in the northeast quadrant of the containment building. Cable 2NR268 is

routed from the box directly north to the missile barrier. After passing through the missile

barrier, the cable follows along the exterior containment wall to an electrical penetration

between azimuth R24 and R25.A5.8.17.3Description of Deviation Inside of the missile barrier, the separation between cables 2NR009 (Division 21) and 2NR130 (Division 12) is approximately between 23 feet to 30 feet in the area bounded by

Elevations 399 feet and 408 feet, azimuth angles R39 and R42. The cables for the

Division 21 post-accident channel are also located in this same area. Intervening combustibles are also present in the form of cable trays and lubricating oil in the reactor coolant pump 2A. The cables for the Division 22 post-accident channel are located a BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -43 substantial distance away in the northeast quadrant, and are separated from this area by the primary shield wall and other internal containment structures.

Outside of the missile barrier, both source range nuclear instrument channels are separated by approximately 65 feet in the area bounded by Elevations 408 feet 0 inch and 435 feet 0 inch, azimuth angles R26 and R42. Cables for the two post-accident channels

are present between these two cables. Intervening combustibles are present in the form of cable trays. In addition, area-wide fire detection or suppression is not provided in these

zones.Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment of 20 horizontal feet with no intervening combustibles. This is not met because

intervening combustibles in the form of cable insulation in cable trays are present in the area. Section C.5.B(2) paragraph (b) specifies installation of fire detectors and an

automatic suppression system in the area. Although detection is available in the affected

area, this is not met because an automatic fire suppression system is not provided.

Section C.5.B(2) paragraph (c) specifies separation of redundant cables by a non-combustible radiant energy shields. Non-combustible shields are not provided.

Therefore, the separation between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was

previously identified as deviations 2C.3 in FPR Amendment 20.)A5.8.17.3Justification for Deviation The cables are routed in conduit inside the missile barrier, in the area where cables for three of the four instruments are present. The reactor coolant pump is not considered to

represent a major fire hazard since it is provided with an oil collection system.

Furthermore, heat detectors are provided over the pump. Only two cable trays are located in the area. They are located near radii R41 and R42, where the separation is 30 feet, and not in the area where the separation is 23 feet. In addition, the cable trays are

oriented parallel to the conduits carrying the neutron source range monitoring cables.

Thus, they are not likely to serve as a means to transmit a fire between these cables. A negligible amount of free-air cable is routed along the primary shield wall at approximate EL. 409 feet 0 inch. In the area of the deviation (azimuth angles R39 to R42) it will not

come in contact with either conduit for cable 2NR009 (Division 21) or 2NR130 (Division

22). The cables utilized at Braidwood are constructed per IEEE 383 and will not propagate a fire without the presence of an external flame. Therefore, these free-air cables are not likely to serve as a means to transmit a fire between these cables. In addition, the cables for the other post-accident instrument are located on the opposite side

of the primary shield wall, and are not subject to the same fire hazards. Outside of the

missile barrier, the minimum separation between the two source range instrument cables (the pair which are farthest apart) is approximately 65 feet. In view of the fact that the

neutron monitoring cables are in conduit for the majority of their routings, and in

consideration of the nature and orientation of intervening combustibles, the existing

separation is considered to be adequate to preclude a single fire from disabling all of the

instruments.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -44A5.8.17.4Description of Equipment/Cables Involved Pressurizer Pressure Instrumentation Four channels of pressurizer pressure instrumentation are provided. Only one of the four available pressurizer pressure instrumentation channels is required to achieve and

maintain hot standby. Inside containment, a single cable is associated with each of the

four channels. The four instrumentation cables are 2RY199 and 2RY207 in Division 21, and 2RY203 and 2RY211 in Division 22.A5.8.17.4Description of DeviationAll four pressurizer pressure instrumentation cables have a minimum separation of approximately 15 feet vertically and 60 feet horizontally in the area bounded by Elevation

400 feet and 440 feet, azimuth angles R25 and R42, at a radius at about 67 feet from the

centerline of containment.

Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment of 20 horizontal feet with no intervening combustibles. This is not met because intervening combustibles in the form of cable insulation in cable trays are present in the

area. Section C.5.B(2) paragraph (b) specifies installation of fire detectors and an

automatic suppression system in the area. Although detection is available in the affected

area, this is not met because an automatic fire suppression system is not provided.

Section C.5.B(2) paragraph (c) specifies separation of redundant cables by a non-combustible radiant energy shields. Non-combustible shields are not provided.

Therefore, the separation between redundant cables deviates from the guidelines of

Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was

previously identified as deviations 2C.4 in FPR Amendment 20.)A5.8.17.4Justification for Deviation A single fire large enough to damage both Division 21 and Division 22 cables would have to span more than 60 feet in the horizontal direction between azimuth angles R25 and

R42. Although intervening combustibles in the form of cable insulation in cable trays are present in the affected area, the cables utilized at Braidwood are constructed per IEEE 383. These cables will not propagate a fire without the presence of an external flame. No other combustible materials and negligible amounts of free-air routed cable are present in this area in significant quantities. The fire loading in this area is low. The containment is a

large open area. The heat and products of combustion of any fire which may be

postulated to start will be dissipated in the upper levels of the containment building, and

will not be concentrated in the immediate area of the fire near potential targets (i.e., other

cable trays). In addition, fire detection is provided in this area. For these reasons, the

existing separation between redundant cables is considered to be adequate to preclude a single fire from damaging all four of these safe shutdown instruments.A5.8.17.5Description of Equipment/Cables Involved BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -45 Pressurizer Level Instrumentation Three channels of pressurizer level instrumentation are provided. One of the three pressurizer level instrumentation channels is required to achieve and maintain hot

standby. Inside containment, a single cable is associated with each of the three channels.

The three instrumentation cables are 2RY20l and 2RY209 in Division 21, and 2RY205 in

Division 22.A5.8.17.5Description of Deviation All three pressurizer level instrumentation cables have a minimum separation of approximately 15 feet vertically and 22 feet horizontally in the area bounded by Elevations 408 feet and 423 feet 6 inches, azimuth angles R23 and R42, at a radius of about 67 feet

from the centerline of containment.

Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment of 20 horizontal feet with no intervening combustibles. This is not met because

intervening combustibles in the form of cable insulation in cable trays are present in the

area. Section C.5.B(2) paragraph (b) specifies installation of fire detectors and an automatic suppression system in the area. Although detection is available in the affected

area, this is not met because an automatic fire suppression system is not provided.

Section C.5.B(2) paragraph (c) specifies separation of redundant cables by a non-combustible radiant energy shields. Non-combustible shields are not provided.

Therefore, the separation between redundant cables deviates from the guidelines of

Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously identified as deviations 2C.5 in FPR Amendment 20.)A5.8.17.5Justification for Deviation The pressurizer level instrumentation cables are routed in conduit. Although intervening combustibles in the form of cable insulation in cable trays and negligible amounts of free-air routed cable are present in the affected area, the cables utilized at Braidwood are

constructed per IEEE 383. These cables will not propagate a fire without the presence of

an external flame. No other combustible materials are present in this area in significant

quantities. The fire loading in this area is low. The containment is a large open area. The

heat and products of combustion of any fire which may be postulated to start will be

dissipated in the upper levels of the containment building, and will not be concentrated in the immediate area of the fire near potential targets (i.e., other cable trays). In addition, fire detection is provided in this area. For these reasons, the existing separation between

redundant cables is considered to be adequate to preclude a single fire from damaging all

three of these safe shutdown instruments.A5.8.17.6Description of Equipment/Cables Involved BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -46 Reactor Coolant Hot Leg Temperature Or Core Exit Temperature Indication for reactor coolant hot leg temperature for one RCS loop or indication of core exit temperature from one division of the incore thermocouples is required to achieve and

maintain hot standby.

Each reactor coolant system hot leg has a dual element RTD. The loop "A" and "D" RTDs are located between the primary and secondary shield walls on the west side of the

reactor cavity. The loop "B" and "C" RTDs are located between the primary and

secondary shield walls on the east side of the reactor cavity.

One of the two elements for each RTD provides a signal to indication in the main control room and at the remote shutdown panel. The four cables associated with the MCR/RSP

indication are 2RC351, 2RC356, 2RC361 and 2RC366. All four of these cables are

Division 21 cables. These four cables are routed in a generally northerly direction from

their respective RTDs to outside of the secondary shield wall, and from there they follow

along the exterior containment wall over to their Division 21 electrical penetration located

near R25. The remaining element for each RTD provides a signal to electrically independent indication located on the Fire Hazards Panel. The four cables associated with the FHP

indication are 2RC743, 2RC745, 2RC747 and 2RC749. All four of these cables are Division 22 cables. Starting at their respective RTDs, the two cables for the loop "B" and "C" RTDs are routed in a generally southerly direction to outside of the secondary shield wall, and from there they follow along the exterior containment wall over to their Division 22 electrical penetration located near R22. The two loop "A" and "D" cables are routed

west through the secondary shield wall and then along over their Division 22 electrical

penetration located near R24.

The Division 21 incore thermocouple cables are 2IT308 through 2IT340, 2IT343, 2IT344, 2IT425 and the 33 incore thermocouple circuits combined into five multiconductor mineral

insulated cables 2IT428, 2IT429, 2IT432, 2IT433, 2IT436, 2IT437, 2IT440, 2IT441, 2IT444, and 2IT445 (two cable numbers assigned per multiconductor cable) from junction box 2JB697R to the reactor vessel head. The Division 22 incore thermocouple cables are

2IT351 through 2IT382, 2IT347, 2IT348, 2IT427, and the 32 incore thermocouple circuits

combined into five multiconductor mineral insulated cables 2IT430, 2IT431, 2IT434, 2IT435, 2IT438, 2IT439, 2IT442, 2IT443, 2IT446, and 2IT447 (two cable numbers

assigned per multiconductor cable) from junction box 2JB698R to the reactor vessel head.

The Division 21 incore thermocouple cables are routed in conduit from a containment penetration at Elevation 417 feet 6 inches between R24 and R25 to junction box 2JB697R

outside the missile barrier at Elevation 435 feet 9 inches between R22 and R42. The

Division 22 incore thermocouple cables are routed in conduit from a containment

penetration at Elevation 439 feet 3 inches between R25 and R26 to junction box 2JB698R

outside the missile barrier at Elevation 456 feet 0 inches between R22 and R42. The

mineral insulated cables for both divisions are routed in conduit from junction boxes BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -472JB697R and 2JB698R, between steam generators 2A and 2D, to the primary shield wall.

These same cables are then routed in cable trays (Elevation 430 feet) from the primary

shield wall to a connector plate above the reactor vessel, and from there routed vertically

down to the reactor vessel head.A5.8.17.6Description of Deviation Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the redundant cables are located within the same fire zone, and no fire barrier is present. Section

C.5.B(2) paragraph (b) specifies separation between redundant cables and equipment by

20 feet of horizontal distance with no intervening combustibles and installation of fire detectors and an automatic suppression system in the area. This is not met because the

separation between the redundant cables is less than that specified, and intervening

combustibles in the form of cable insulation in cable trays are present in the area and

although detection is available in the affected area, an automatic fire suppression system

is not provided. The Divisions 21 and 22 reactor coolant hot leg temperature and incore

thermocouple cables are routed in the closest proximity to each other outside of the secondary shield wall. The minimum horizontal separation between a single division of

either the hot leg cables or the incore thermocouple cables is approximately 52 feet in the

sector bounded by R22 and R25. Section C.5.B(2) paragraph (c) specifies enclosure of

redundant cables and equipment of one train by a 1-hour rated fire barrier and installation

of fire detectors and an automatic suppression system in the area. As previously stated, no fire barriers are present in the zone, and an automatic suppression system is not

installed. Therefore, the separation between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This

deviation was previously identified as deviations 2C.6 in FPR Amendment 20.)A5.8.17.6Justification for Deviation Between the primary and secondary shield walls, the RCS loop "B" and "C" RTDs and their cables are separated from the RCS loop "A" and "D" RTDs and their cables and the incore thermocouple cables by the primary shield wall and/or the refueling pool structure.

The primary shield wall is a concrete structure approximately 34 feet in diameter that

encloses the reactor cavity and reactor vessel. These structures serve the purpose of a

noncombustible radiant energy shield that separates the loop "B" and "C" RTDs and

cables from the redundant loop "A" and "D" RTDs and cables and incore thermocouple

cables. Away from the penetration, the divisional routings of the RTD cables provide good

spatial separation, ensuring that indication for at least one loop of reactor coolant hot leg

temperature will be available. As previously stated, the minimum separation of cables

occurs between the containment penetrations and secondary shield wall. The minimum

horizontal separation between a single division of either the hot leg cables or the incore

thermocouple cables is approximately 52 feet at the containment penetrations in the

sector bounded by R22 and R25. Therefore, a fire would have to span a horizontal distance of approximately 52 feet to damage all of the reactor coolant hot leg and incore

thermocouple cables. Although intervening combustibles in the form of cable insulation in BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -48 cable trays and negligible amounts of free-air routed cable are present in the affected area, the cables utilized at Braidwood are constructed per IEEE 383. These cables will

not propagate a fire without the presence of an external flame. No other combustible

materials are present in this area in significant quantities. The fire loading in this area is

low. The containment is a large open area. The heat and products of combustion of any

fire which may be postulated to start will be dissipated in the upper levels of the

containment building, and will not be concentrated in the immediate area of the fire near

potential targets (i.e., other cable trays). In addition, fire detection is provided in this area.

For these reasons, the existing separation between redundant cables is considered to be adequate to preclude a single fire from damaging all of these safe shutdown instruments.A5.8.17.7Description of Equipment/Cables Involved Reactor Coolant Cold Leg Temperature Indication for reactor coolant cold leg temperature for one RCS loop is credited to achieve and maintain hot standby. Each reactor coolant system cold leg has a dual element RTD.

The loop "A" and "D" RTDs are located between the primary and secondary shield walls

on the west side of the reactor cavity. The loop "B" and "C" RTDs are located between

the primary and secondary shield walls on the east side of the reactor cavity.

One of the two elements for each RTD provides a signal to indication in the main control room and at the remote shutdown panel. The four cables associated with the MCR/RSP

indication are 2RC373, 2RC392, 2RC397 and 2RC402. All four of these cables are

Division 22 cables. Some of these four cables are routed in a generally southerly direction

from their respective RTDs to outside of the secondary shield wall, and from there they follow along the exterior containment wall over to their Division 22 electrical penetration

located near R42. The other cables remain inside the secondary shield wall until they

pass through it in the immediate vicinity of the electrical penetration located by R42. The remaining element for each RTD provides a signal to electrically independent indication located on the Fire Hazards Panel. The four cables associated with the FHP

indication are 2RC751, 2RC753, 2RC755 and 2RC757. All four of these cables are also

Division 22 cables. Starting at their respective RTDs, these four cables are routed in a

generally northerly direction to outside of the secondary shield wall, and from there they

follow along the exterior containment wall over to their Division 22 electrical penetration

located near R24.A5.8.17.7Description of Deviation Three of the four FHP cold leg RTD cables have a minimum separation of approximately 1 foot vertically from the four MCR/RSP cold leg RTD cables near R42. The remaining FHP cold leg RTD cable is separated from the four MCR/RSP cold leg RDT cables by approximately 35 feet.

BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -49 Section C.5.B(2) paragraph (a) is not met because intervening combustibles in the form of cable insulation in cable trays are present in the area. Section C.5.B(2) paragraph (b) is

not met because an automatic fire suppression system is not provided. Section C.5.B(2) paragraph (c) is not met because non-combustible shields are not provided. Therefore, the separation between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously

identified as deviations 2C.7 in FPR Amendment 20.)A5.8.17.7Justification for DeviationAlthough intervening combustibles in the form of cable insulation in cable trays and negligible amounts of free-air routed cable are present in the affected area, the cables

utilized at Braidwood are constructed per IEEE 383. These cables will not propagate a

fire without the presence of an external flame. No other combustible materials are

present in this area in significant quantities. The fire loading in this area is low. The

containment is a large open area. The heat and products of combustion of any fire which

may be postulated to start will be dissipated in the upper levels of the containment

building, and will not be concentrated in the immediate area of the fire near potential

targets (i.e., other cable trays). In addition, fire detection is provided in this area. For

these reasons, the existing separation between redundant cables is considered to be

adequate to preclude a single fire from damaging all of these safe shutdown instruments.

Additionally, the loss of all cold leg RTDs is acceptable for the following reasons. The cold leg RTDs would normally be used in conjunction with the hot leg RTDs to verify adequate

core cooling, i.e., that natural circulation is present. This condition can also be verified by

trending the temperatures indicated by the core exit thermocouples. As noted in Section A5.8.6.6, the thermocouple cables are routed in conduit in the area of concern.

Furthermore, cold leg temperature can be inferred from steam generator pressure. As

indicated in Section 2.4, steam generator pressure instrumentation and cabling are independent of this zone. Plant emergency procedures are written to refer to these

alternate methods of verifying primary system conditions. In fact, the core exit

thermocouples are the preferred method. The Byron and Braidwood plant procedures are written using guidance from the Westinghouse Owners Group. Therefore, this deviation

from BTP CMEB 9.5-1 requirements is considered to be acceptable.A5.8.17.8Description of Equipment/Cables Involved Reactor Containment Fan Cooler (RCFC) FansTwo of the four RCFC fans are required to operate in the high-speed mode to achieve and maintain hot standby. The four RCFCs themselves are located outside of the secondary

shield wall at widely spaced intervals around the containment. The high speed power cables for the RCFC fans routed inside containment are 2VP004, 2VP026, 2VP048, and

2VP070.A5.8.17.8Description of Deviation BRAIDWOOD - FPR AMENDMENT 25 DECEMBER 2012A5.8 -50All four RCFC power cables (Division 21 - 2VP004 and 2VP048, Division 22 - 2VP026 and 2VP070) have a minimum separation of approximately 36 horizontal feet. This minimum

separation occurs in the area bounded by elevations 393 feet 5 inches and 439 feet 3

inches, azimuth angles R26 and R42, at a radius of about 60 feet from the centerline of

containment. There are intervening combustibles in this area in the form of cable

insulation.

Section C.5.B(2) paragraph (a) is not met because intervening combustibles in the form of cable insulation in cable trays are present in the area. Section C.5.B(2) paragraph (b) is not met because an automatic fire suppression system is not provided. Section C.5.B(2) paragraph (c) is not met because non-combustible shields are not provided. Therefore, the separation between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1. (This deviation was previously

identified as deviations 2C.8 in FPR Amendment 20.)A5.8.17.8Justification for DeviationAlthough intervening combustibles in the form of cable insulation in cable trays and negligible amounts of free-air routed cable are present in the affected area, the cables

utilized at Braidwood are constructed per IEEE 383. These cables will not propagate a

fire without the presence of an external flame. No other combustible materials are present in this area in significant quantities. The fire loading in this area is low. The containment

is a large open area. The heat and products of combustion of any fire which may be

postulated to start will be dissipated in the upper levels of the containment building, and will not be concentrated in the immediate area of the fire near potential targets (i.e., other

cable trays). In addition, fire detection is provided in this area. For these reasons, the

existing separation between redundant cables is considered to be adequate to preclude a

single fire from damaging all of these safe shutdown cables.

BYRON - FPR AMENDMENT 20 DECEMBER 2002A5.8-iAPPENDIX 5.8DEVIATIONS FROM BRANCH TECHNICAL POSITION CMEB 9.5-1 SECTION C.5.b BYRON - FPR AMENDMENT 20 DECEMBER 2002A5.8 -ii TABLE OF CONTENTS A5.8 DEVIATIONS FROM BTP CMEB 9.5-1 SECTION C.5.b PAGEA5.8.1Deviation No.: 0A.1 (Fire Zone 11.3-0)A5.8-1A5.8.2Deviation No.: 0A.2 (Fire Zone11.7-0)A5.8-3 A5.8.3Deviation No.: 1A.1 (Fire Zone 18.3-1)A5.8-6 A5.8.4Deviation No.: 1A.2 (Fire Zone 11.2A-1 & 11.2D-1)A5.8-9 A5.8.5Deviation No.: 1A.3 (Fire Zone 2.1-0)A5.8-11 A5.8.6Deviation No.: 1A.4 (Fire Zone 5.5-1)A5.8-12 A5.8.7Deviation No.: 1A.5 (Fire Zone 11.4C-0)A5.8-13 A5.8.8Deviation No.: 1A.6 (Fire Zone 11.4-0)A5.8-14 A5.8.9Deviation No.: 1A.7 (Fire Zone 11.4-0)A5.8-16 A5.8.10Deviation No.: 1A.8 (Fire Zone 11.5-0)A5.8-18 A5.8.11Deviation No.: 1A.9 (Fire Zone 11.6-0)A5.8-19 A5.8.12Deviation No.: 1A.10 (Fire Zone 3.2B-1)A5.8-21 A5.8.13Deviation No.: 1C.1 (Fire Zone 1-1)A5.8-22 A5.8.14Deviation No.: 2A.1 (Fire Zone 18.3-2)A5.8-34 A5.8.15Deviation No.: 2A.2 (Fire Zone 11.2A-2 & 11.2D-2)A5.8-37 A5.8.16Deviation No.: 2A.3 (Fire Zone 2.1-0)A5.8-39 A5.8.17Deviation No.: 2A.4 (Fire Zone 5.5-2)A5.8-40 A5.8.18Deviation No.: 2A.5 (Fire Zone 11.4C-0)A5.8-41 A5.8.19Deviation No.: 2A.6 (Fire Zone 11.4-0)A5.8-42 A5.8.20Deviation No.: 2A.7 (Fire Zone 3.2B-1)A5.8-44 A5.8.21Deviation No.: 2A.8 (Fire Zone 11.5-0)A5.8-45 A5.8.22Deviation No.: 2A.9 (Fire Zone 11.6-0)A5.8-46 A5.8.23Deviation No.: 2C.1 (Fire Zone 1-2)A5.8-47 BYRON - FPR AMENDMENT 20 DECEMBER 2002A5.8 -iiiA5.8DEVIATIONS FROM SECTION C.5.b OF BTP CMEB 9.5-1 INTRODUCTIONThis appendix addresses deviations from Section C.5.b "Safe Shutdown Capability" of BTP CMEB 9.5-1 that exist because of redundant safe shutdown equipment located in a

fire zone. Deviations common to both Unit 1 and Unit 2 begin with the number "0". Unit

1 deviations begin with the number "1" and Unit 2 deviations begin with the number "2".

AMENDMENT 25 DECEMBER 2012A5.8 -1A5.8.1Deviation No: 0A.1 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the auxiliary building general area

at elevation 364 feet).

Fire Zone(s) or Elevations Involved364 feet 0 inch (Fire Zone 11.3-0)

Description of Equipment/Cables Involved The redundant cables and equipment required for safe shutdown and located in Fire Zone 11.3-0 are listed in Table 2.4-4. However, not all of these cables and components

are the subject of this deviation.

Description of Deviation The five component cooling pumps for both units ("0", 1A, 1B, 2A and 2B) and pump power cables are present in Fire Zone 11.3-0, and are located in a small area. For

either of the two units, the separation between the redundant pumps and their

associated power cables is less than 20 horizontal feet.

Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the

redundant pumps and their power cables are located within the same fire zone, and

only a 1-hour fire barrier is present to protect the power cable (1CC020) for the common

component cooling water pump. Section C.5.B(2) paragraph (b) specifies separation

between redundant cables and equipment by 20 feet of horizontal distance with no

intervening combustibles and installation of fire detectors and an automatic suppression

system in the area. This requirement is not met because the redundant pumps and

their associated power cables are less than 20 feet apart, and intervening combustibles

are present. Although detection is available in this fire zone, this requirement is also not met because an area-wide automatic fire suppression system is not provided in the fire

zone (note that a partial coverage automatic suppression system is installed in the

immediate area of the component cooling water pumps). Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment of one train by a 1-hour

rated fire barrier and installation of fire detectors and an automatic suppression system in the area. As previously stated, a 1-hour rated fire barrier is present in the zone to

protect the power cable (1CC020) for the common component cooling water pump, however, an area-wide automatic suppression system is not installed. Therefore, the

separation between redundant cables deviates from the guidelines of Section C.5.B(2),

paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation AMENDMENT 25 DECEMBER 2012A5.8 -2 In order to ensure that a single fire cannot damage all of the component cooling water pumps and cables in the zone, the following fire protection measures are employed:Partial height masonry walls separate the redundant component cooling water pumps.

One partial height wall separates the 1A and 1B pumps from the common pump and the

two Unit 2 pumps. A second partial height wall separates the 2A and 2B pumps from

the common pump and the two Unit 1 pumps.

A 1-hour fire rated barrier is provided around the conduit for the Division 12 common component cooling pump power cable (1CC020) (Note: Although cable 1CC020 carries a Division 12 designation, power will be provided to the "0" pump from Division 11

switchgear bus 141. This is consistent with the protection of Division 11 cables in Fire

Zone 11.3-0, as described in Byron Section 2.4.)

An automatic fixed water suppression system is installed over the component cooling water pumps. This sprinkler system provides adequate coverage for an area out to at

least 20 feet past the pumps in all directions. The pump motors have spray shields to

prevent water damage.The component cooling water heat exchangers separate the pumps from the rest of the area and will act as radiant energy shields should a fire break out elsewhere in the

room.This is a large open area with a low combustible loading. Area wide detection is provided.Because of the partial height masonry walls, 1-hour rated fire barrier protecting the common pump power cable, the area wide detection and the automatic water

suppression system over the component cooling water pumps, and the large area and low combustible loading of this zone, the damage from a single fire will be limited such

that at most two of the pumps could be affected. For each single fire in the area of the

pumps, at least three of the pumps will remain available to serve the demand for both

units. Thus, a level of protection equivalent to that of Section C.5.B(2) is achieved.

AMENDMENT 25 DECEMBER 2012A5.8 -3A5.8.2Deviation No: 0A.2 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the auxiliary building HVAC exhaust

complex).Fire Zone(s) or Elevations InvolvedAuxiliary Building HVAC Exhaust Complex (Fire Zone 11.7-0). This fire zone encompasses multiple elevations of the auxiliary building, including portions of 451 feet

- 0 inch, 459 feet - 0 inch, 467 feet - 4 inch and 475 feet - 6 inch.

Description of Equipment/Cables Involved The redundant cables and equipment required for safe shutdown and located in Fire Zone 11.7-0 are listed in Table 2.4-4. However, not all of these cables and components

are the subject of this deviation. The equipment and cables that are the subject of this

deviation include the four auxiliary building HVAC supply fans, their respective power

cables, the four auxiliary building HVAC exhaust fans and their respective power cables.The four VA system exhaust fans are located on the 475 feet - 6 inch level. The A and B fans are located close together on the Unit 1 side. The C and D fans are located

close together on the Unit 2 side. The A and B fans and their cables are separated from the C and D fans and their cables by approximately 40 feet with no significant quantities

of intervening combustibles. The four VA system supply fans are located on the 451 feet -0 inch level. The A and B fans are located close together on the Unit 1 side. The C and D fans are located close together on the Unit 2 side. The A and B fans and their

cables are separated from the C and D fans and their cables by a minimum of 40 feet

with no significant quantities of intervening combustibles (although the charcoal filter units are located to the west side of this room on this elevation).

Description of Deviation The four VA system supply fans and their power cables, and the four VA system exhaust fans and their power cables are present in the same zone.

Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the

redundant fans and their power cables are located within the same fire zone, and no fire

barrier is present. Section C.5.B(2) paragraph (b) specifies separation between

redundant cables and equipment by 20 feet of horizontal distance with no intervening

combustibles and installation of fire detectors and an automatic suppression system in the area. Although detection is available in this fire zone (except on elevation 475 feet 6

inch), this requirement is not met because an automatic fire suppression system is not

provided in the fire zone. Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment of one train by a 1-hour rated fire barrier and AMENDMENT 25 DECEMBER 2012A5.8 -4 installation of fire detectors and an automatic suppression system in the area. As previously stated, no fire barriers are present in the zone, and an automatic suppression system is not installed. Therefore, the separation between redundant cables deviates

from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for DeviationThe primary justification for this deviation consists of the judgement that a single fire in this zone will not affect all four trains of the auxiliary building ventilation system. This

conclusion is based on the following information. The two Unit 1 (A and B) exhaust fans and their power feed cables are separated from the two Unit 2 (C and D) exhaust fans

and their power feed cables by approximately 40 feet with no significant quantities of

intervening combustible materials. The two Unit 1 (A and B) supply fans and their power feed cables are separated from the two Unit 2 (C and D) supply fans and their

power feed cables by approximately 40 feet with no significant quantities of intervening

combustible materials. The charcoal filters are present in this area. The filter units are housed in substantial steel enclosures that separate the combustible charcoal from the

rest of the area. The charcoal filter units are provided with an independent detection

system, and a manual deluge suppression system. This area is provided with ionization

detection (except for El. 475 feet - 6 inch) that annunciates and alarms in the main

control room. Manual hose stations and portable extinguishers are provided. Because

of the type and configuration of combustible materials, the detection and suppression capabilities provided, and the existing physical separation between the Unit 1 / Unit 2

supply and exhaust fans and their cables, a single fire will not affect all four trains of the

system.Additional justification for the deviation is provided by an evaluation of the safe shutdown function of these components. The supply and exhaust fans together provide

airflow to the auxiliary building general areas and the various cubicles and rooms

containing plant equipment. This airflow serves the dual purpose of providing

temperature control for the auxiliary building general areas, and establishing pressure

balances to ensure air flows from general areas towards potentially contaminated areas (i.e., for radiological control). For major safe shutdown components located in their own

rooms or cubicles, the primary cooling function is provided by cubicle coolers. Although

the auxiliary building supply and exhaust fans are relied upon for cooling of some safe

shutdown components in some fire zones, that is not the case for this particular fire

zone. The safe shutdown cubicle coolers for the affected components are independent

of the auxiliary building supply and exhaust fans and this fire zone. Therefore, a fire in

this zone would not result in loss of the cooling function for major safe shutdown

components, even should all four trains of the auxiliary building ventilation system be

disabled. Loss of the radiological control function could not prevent safe shutdown of

the plant, although it would present operation difficulties to the operating staff.In consideration of the conditions and features discussed above, the separation between the A/B and C/D trains of the VA system supply and exhaust fans is judged to

be adequate to prevent a fire from disabling all four trains. In addition, redundant AMENDMENT 25 DECEMBER 2012A5.8 -5 cooling capability independent of this zone and the VA system supply and exhaust fans is provided for major safe shutdown components. Thus, a level of protection equivalent

to that of Section C.5.B(2) is achieved.

AMENDMENT 25 DECEMBER 2012A5.8 -6A5.8.3Deviation No: 1A.1This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the Unit 1 main steam tunnel).

Fire Zone(s) or Elevations InvolvedUnit 1 Main Steam and Feedwater Pipe Tunnels at various elevations between 357 feet 0 inch and 377 feet 0 inch (Fire Zone 18.3-1). The two valve enclosures that extend up

to grade elevation are also a part of this fire zone.

Description of Equipment/Cables InvolvedThe cables and equipment, required for safe shutdown and located in Fire Zone 18.3-1, are listed in Table 2.4-4. The redundant components and cables consist of valves and

instruments in the main steam and auxiliary feedwater systems.

Description of DeviationThis fire zone encompasses two pipe tunnels and two physically separated valve houses. The two valve houses are located approximately 120 degrees apart at the

southwest and southeast sides of the exterior containment wall. The below grade main steam and feedwater pipe tunnels connect the two valve houses. The southwest valve house contains safe shutdown components and piping associated with the "B" and "C" steam generators. The southeast valve house contains safe shutdown components and piping associated with the "A" and "D" steam generators. Safe shutdown components

located in (or near to) the valve houses include the main steam safety valves, the steam

generator PORVs, the MSIVs, MSIV bypass valves, steam generator pressure

instruments and auxiliary feedwater system containment isolation valves. Cables

associated with these components are present in the valve houses, and are also routed

through the main steam and/or feedwater pipe tunnels to the auxiliary building. In the area of the pipe tunnels bounded by column-rows 5 to 10 and P to Q, cables for all of

the redundant components may be present.

The combustible material present in this zone consists of hydraulic fluid that is located in the two valve houses. All cables routed through the pipe tunnels are located in

conduit, and thus do not count as exposed combustibles. The main steam and

feedwater pipe tunnels themselves have no combustible materials and no fire loading.

Ionization detection is available in the two valve houses. The pipe tunnels themselves have no detection. Manual extinguishing capability consisting of portable extinguishers

and a hose station is available to the area.

Separation between redundant component located in the two valve houses: Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the redundant

components involved are located within the same fire zone, and no fire barrier is AMENDMENT 25 DECEMBER 2012A5.8 -7 present. Section C.5.B(2) paragraph (b) specifies separation between redundant cables and equipment by 20 feet of horizontal distance with no intervening combustibles and

installation of fire detectors and an automatic suppression system in the area. The

separation through the pipe tunnels between the two valve houses is in excess of 200

linear feet with no intervening combustibles. However, this requirement is not met

because neither detection nor an automatic fire suppression system are provided in the

pipe tunnels. Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables

and equipment of one train by a 1-hour rated fire barrier and installation of fire detectors

and an automatic suppression system in the area. As previously stated, no fire barriers are present in the zone, and neither detection nor an automatic suppression system are

installed. Therefore, the separation between redundant components in the two valve

houses deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of

BTP CMEB 9.5-1.Separation between redundant cables within the pipe tunnels: Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the redundant cables involved are located within the same fire zone, and no fire barrier is present. Section C.5.B(2)

paragraph (b) specifies separation between redundant cables and equipment by 20 feet

of horizontal distance with no intervening combustibles and installation of fire detectors

and an automatic suppression system in the area. Although the pipe tunnels have no

fire loading (i.e., no combustible materials), this requirement is not met because existing

separation is less than 20 horizontal feet. In addition, neither detection nor an automatic fire suppression system are provided in the pipe tunnels. Section C.5.B(2)

paragraph (c) specifies enclosure of redundant cables and equipment of one train by a

1-hour rated fire barrier and installation of fire detectors and an automatic suppression system in the area. As previously stated, no fire barriers are present in the zone, and

neither detection nor an automatic suppression system are installed in the pipe tunnels.

Therefore, the separation between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation Separation between redundant component located in the two valve houses: Other than the oil associated with the valve hydraulic systems in both valve enclosures, there are no combustible materials in the main steam and feedwater tunnels, which then have no

fire load. Detection and manual suppression capability are provided in the valve

enclosures. The separation between the two valve houses, coupled with the absence of

combustible materials in the connecting pipe tunnels, is sufficient to ensure that no

single fire could affect both valve enclosures at once.

Separation between redundant cables within the pipe tunnels: All safe shutdown cables located in this fire zone are routed in conduit. This fact, in conjunction with the absence

of combustible materials within the pipe tunnels, is sufficient to ensure a single fire (involving transient combustible materials) will not affect redundant safe shutdown

cables.

AMENDMENT 25 DECEMBER 2012A5.8 -8 In summary, because the cables are routed in conduit, and considering the configuration of combustible materials, and detection and manual suppression

capability, a level of protection equivalent to Section C.5.B(2) of BTP CMEB 9.5-1 is achieved. The existing separation is judged to be adequate to preclude a single fire in

the pipe tunnels or within one of the valve houses from affecting redundant safe

shutdown components or cables.

AMENDMENT 25 DECEMBER 2012A5.8 -9A5.8.4Deviation No.: 1A.2 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) between fire zones (1A RHR pump room and 1B RHR pump

room).Fire Zone(s) or Elevations Involved 346 feet 0 inch (Fire Zone 11.2A-1)

346 feet 0 inch (Fire Zone 11.2D-1)

Description of Equipment/Cables InvolvedThe cables and equipment, required for safe shutdown and located in Fire Zones 11.2A-1 and 11.2D-1, are listed in Table 2.4-4. The redundant components and cables consist of RHR pump 1A and its cubicle cooler located in Fire Zone 11.2A-1 and RHR pump1B and its cubicle cooler located in Fire Zone 11.2D-1.

Description of Deviation(s)The RHR pumps and cubicle coolers located in Fire Zone 11.2A-1 are separatedfrom the redundant RHR pump and cubicle cooler, located in Fire Zone 11.2D-1,by a 2-hour-rated fire barrier. Also, area-wide automatic fire suppression isnot provided in either zone; nor is it provided in Fire Zones 11.2B-1and11.2C-1 (containment spray pump rooms), which are located between the RHR pumprooms.This is not in accordance with the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation(s)

Due to the presence of the containment spray pump rooms between the RHR pumprooms, the separation between the two trains of RHR components is greater than75 feet. The 3 walls between the two trains of RHR components are all of 3-hour construction. Two of the walls contain unsealed penetrations orpenetrations with non-fire-rated seals. The wall at column-row W between thetwo containment spray pump rooms is upgraded to a 2-hour-rated fire barrier. The RHR pump rooms and the containment spray pump rooms have low combustibleloadings. All of these rooms are provided with automatic fire detection. Fire Zone 11.2B-1 contains a manual hose station having hose of adequatelength to reach Fire Zones 11.2A-1, 11.2C-1, and 11.2D-1. Also, portableextinguishers are provided in adjacent Fire Zone 11.2-0 (auxiliary buildinggeneral area).The residual heat removal system is not required for hot shutdown of theplant. Station repair procedures have been written to ensure that theRHR system will be repaired and available to achieve cold shutdown conditionswithin 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> after a fire.

AMENDMENT 25 DECEMBER 2012A5.8 -10In summary, the large distance separating the two trains of RHR pumps andcubicle coolers, the 2 hour-rated fire barrier, fire detection and manual firesuppression provided, establish a level of fire protection commensurate withthe guidelinesof Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

AMENDMENT 25 DECEMBER 2012A5.8 -11A5.8.5Deviation No.: 1A.3 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the Unit 1 main control room), and for which alternate or dedicated shutdown capability is provided.

Fire Zone(s) or Elevations Involved451 feet 0 inch (Fire Zone 2.1-0)

Description of Equipment/Cables InvolvedThe cables and equipment required for safe shutdown and located in Fire Zone2.1-0 are listed in Table 2.4-4.

Description of Deviation(s)The redundant safe shutdown cables located in Fire Zone 2.1-0 are notseparated by a 20-foot space free of combustible materials and the area is notcovered by a total suppression system. This is not in accordance with the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation(s)Controls and instrumentation for all plant systems are located in the controlroom. Although separation of redundant trains does not meet the requirementsof Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1, alternative shutdown systems and equipment independent of this zone are provided. Specifically, the remote Shutdown Panel and Fire Hazards Panel have sufficient controls and instrumentation to

bring the plant to hot standby, and taking credit for local manual operations, coldshutdown can be achieved. This meets the requirements of Section C.5.B(3),andis therefore acceptable.

AMENDMENT 25 DECEMBER 2012A5.8 -12A5.8.6Deviation No: 1A.4 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the Unit 1 Auxiliary Electric

Equipment Room), and for which alternate or dedicated shutdown capability is provided.

Fire Zone(s) or Elevations Involved451 feet 0 inch (Fire Zone 5.5-1)

Description of of Equipment/Cables Involved The cables and equipment required for safe shutdown and located in Fire Zone 5.5-1 are listed in Table 2.4-4.

Description of Deviation(s)The redundant safe shutdown cables present in Fire Zone 5.5-1 are notseparated by 20 feet with the intervening space free of combustible materials. Also the area is not covered by a total suppression system. This is not inaccordance with the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation(s)Instrumentation for both trains of safe shutdown equipment is located in thiszone. Although separation of this redundant equipment does not meet therequirements of guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1, alternative shutdown instrumentation independent of this zone is provided. Specifically, the Fire Hazards Panel, described in Subsection 2.4 of the Fire Protection Report, has

sufficient instrumentation to bring the plant to the hot standby condition, and taking credit for local manual operation, cold shutdown can be achieved. This meetsthe requirements of Section C.5.B(3) and is therefore acceptable.

AMENDMENT 25 DECEMBER 2012A5.8 -13A5.8.7Deviation No: 1A5 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the Unit 1 Remote Shutdown Panel

Room).Fire Zone(s) or Elevations Involved 383 feet 0 inch (Fire Zone 11.4C-0)

Description of Equipment/Cables InvolvedThe redundant cables and equipment required for safe shutdown and located inFire Zone 11.4C-0 are listed in Table 2.4-4.

Description of Deviation(s)The remote shutdown panels for both units are located in this zone. A fire inthis zone could render inoperable the remote shutdown panels and thecorresponding controls in the control room. As a result, redundant systemsrequired for safe shutdown could be adversely affected. In addition, no area-wide automatic fire suppression is provided. This is not in accordance withthe guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation(s)Fire Zone 11.4C-0 is separated from the rest of the plant by 3-hour-rated firebarriers and is a controlled access area. The remote shutdown control panelsfor Unit 1 are separated from those for Unit 2 by approximately 90 feet. Onemanual hose station and several portable fire extinguishers are available inthis zone. Ionization detectors are provided throughout the fire zone,including the room with the remote shutdown panel, which annunciate and alarmin the control room. The fire load is moderately low and the bulk ofcombustible materials consists of cable insulation. In the event of a fire inthis zone, safe shutdown of the plant can be achieved by local operation ofequipment. Also, instruments located at the remote shutdown panel areisolated so that a fire in this room will not affect the instruments in thecontrol room.

In summary, the low combustible loading, automatic fire detection and manualsuppression capabilities, controlled access, and local operation of safeshutdown equipment provide a level of fire protection equivalent to thatspecified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

AMENDMENT 25 DECEMBER 2012A5.8 -14A5.8.8Deviation No: 1A.6 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (general area, Auxiliary Building

Elevation 383 feet).

Fire Zone(s) or Elevations Involved 383 feet 0 inch (Fire Zone 11.4-0)

Description of Equipment/Cables InvolvedThe redundant cables and equipment required for safe shutdown and located inFire Zone 11.4-0 are listed in Table 2.4-4.

Description of Deviation(s)The redundant safe shutdown equipment and/or cables in Fire Zone 11.4-0 arelocated throughout this area. This area lacks fixed suppression and containscombustible material and has separation distances which are less than 20 feetall of which are not in accordance with the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation(s)The applicant originally committed to install a 3-hour fire-rated barrieraround Division 11 cable trays, risers and conduits in this area as follows: The risers near 13-15/Q will be wrapped from floor to ceiling. The conduitand tray with cable 1SX001 will be wrapped from Q/13 to L/13. The risers andtrays from L/11 to L/13 will be completely wrapped. In addition, thecentrifugal charging pump cubicle cooler fan fed from MCC 131X3 will be movedto another MCC completely independent of this zone. With these modificationscomplete, the loss of both MCCs 131X3 and 132X3 will be acceptable since theessential service water cubicle coolers will function properly with only twoout of four fans in service. This room is a large open area with a lowcombustible loading. Area-wide detection is provided, and manual suppressioncapability is also present. Subsequent to the above modifications, the component cooling pump 1A powercable and the essential service water pump 1A power cable are rerouted out ofFire Zone 11.4-0, where redundant cables are present. An evaluation has shownthat the charging pumps and the essential service water pumps can performtheir design function for the 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> needed to take the plant to coldshutdown without the support of the room cubicle coolers. In addition, the remaining safe shutdown cables in this fire zone have been determined not torequire protection based on an evaluation which demonstrated that alternateequipment and cabling would be available or local manual actions could beperformed as described in station procedures in the event of a fire in thiszone. Therefore, the 3-hour fire-rated barrier described previously asinstalled around the AMENDMENT 25 DECEMBER 2012A5.8 -15Division 11 trays, risers, and conduits on Elevation 383feet 0 inch is no longer required and will not be replaced.

In summary, the low combustible loading, automatic fire detection and manualsuppression capabilities, controlled access, and local operation of safeshutdown equipment provide a level of fire protection equivalent to thatspecified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

AMENDMENT 25 DECEMBER 2012A5.8 -16A5.8.9Deviation No: 1A.7 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (general area, Auxiliary Building

Elevation 383 feet, Auxiliary Feedwater pumps).

Fire Zone(s) or Elevations Involved 383 feet 0 inch (Fire Zone 11.4-0)

Description of Equipment/Cables InvolvedThe redundant cables and equipment required for safe shutdown and located inFire Zone 11.4-0 are listed in Table 2.4-4.

Description of Deviation(s)The redundant safe shutdown cables located in Fire Zone 11.4-0 are less than20 feet apart and the intervening space contains combustible materials and thearea is not covered by a total suppression system which is not in accordancewith the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation(s)The diesel-driven auxiliary feedwater pump is located within its own room,which has 3-hour fire-rated barriers separating it from the general areaoutside. This pump can be manually started from a local control panel in thisroom, and it will operate completely independent of the associated cableslocated outside of the room in the general area on Elevation 383 feet 0 inch(Fire Zone 11.4-0). Thus, the fact that cables for both AFW pumps are presentin the same area in Fire Zone 11.4-0 and could be damaged by a single fire isacceptable, since the Division 12 diesel-driven AFW pump can still be manuallystarted and operated.In order to provide an adequate supply of water to the secondary heat sink ina timely manner following a fire in this zone, remote start capability for thediesel-driven auxiliary feedwater pump is required. Therefore, a remoteswitch has been installed at the elevation below in Fire Zone 11.3-0 to ensurethat the diesel-driven auxiliary feedwater pump can be manually started in thecase of a fire in Fire Zone 11.4-0.Cables 1AF346 and 1AF338 routed through Fire Zone 11.4-0 supply a low-lowsuction pressure signal that could trip the 1B auxiliary feedwater pump. Ifthis happens, the 1B pump can be manually started even if cables 1AF346 and1AF338 are damaged by a fire. Several other cables associated with both AFWpumps are routed through Fire Zone 11.4-0; however, an evaluation has shownthat the 1B AFW pump can be started locally if a fire destroyed these cables. Although cables for both AFW pumps are AMENDMENT 25 DECEMBER 2012A5.8 -17present in the same area in Fire Zone11.4-0 and could be damaged by a single fire, the Division 12 diesel-drivenAFW can still be manually started and operated.

AMENDMENT 25 DECEMBER 2012A5.8 -18A5.8.10Deviation No: 1A.8 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (general area, Auxiliary Building

Elevation 401 feet).

Fire Zone(s) or Elevations Involved 401 feet 0 inch (Fire Zone 11.5-0)

Description of Equipment/Cables InvolvedThe redundant cables and equipment required for safe shutdown and located inFire Zone 11.5-0 are listed in Table 2.4-4.

Description of Deviation(s)The redundant safe shutdown equipment and/or cables in Fire Zone 11.5-0 arelocated throughout this area. This area lacks fixed suppression and containscombustible material and has separation distances which are less than 20 feetall of which are not in accordance with the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation(s)the applicant originally committed to provide a 3-hour fire-ratedbarrier around Division 11 cable trays containing redundant safe shutdowncables in three locations. The risers at 13-15/Q, the trays and risers alongRow L between 11 and 12, and the trays and risers by 11/P-Q will all beprotected.The component cooling pump 1A power cable and the essential service water pump1A power cable are rerouted out of Fire Zone 11.5-0 where redundant cables arepresent. An evaluation also shows that the charging pumps and the essentialservice water pumps can perform their design function for the 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> neededto take the plant to cold shutdown without the support of the room cubiclecoolers. In addition, the remaining safe shutdown cables in this fire zonehave been determined not to require protection based on an evaluation whichdemonstrates that alternate equipment and cabling would be available for afire in this fire zone or that local manual actions could be performed as described in the station procedures. Therefore, the 3-hour fire-rated barrierinstalled around the Division 11 trays and risers on Elevation 401 feet 0 inchis no longer required and will not be replaced.

In summary, the low combustible loading, automatic fire detection and manualsuppression capabilities, controlled access, and local operation of safeshutdown equipment provide a level of fire protection equivalent to thatspecified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

AMENDMENT 25 DECEMBER 2012A5.8 -19A5.8.11Deviation No: 1A.9 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (general area, Auxiliary Building

Elevation 426 feet).

Fire Zone(s) or Elevations Involved 426 feet 0 inch (Fire Zone 11.6-0)

Description of Equipment/Cables InvolvedThe redundant cables and equipment required for safe shutdown and located inFire Zone 11.6-0 are listed in Table 2.4-4.

Description of Deviation(s)The redundant safe shutdown equipment and/or cables in Fire Zone 11.6-0 arelocated throughout this area. This area lacks fixed suppression and containscombustible material and has separation distances which are less than 20 feetall of which are not in accordance with the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation(s)The applicant has initiated a design change to move the Division 12 ESFswitchgear supply fan to another MCC, independent of this zone. Also, thecontrol cable for the Division 12 MEER supply fan will be re-routed to avoidthis zone. Upon completion of this modification, MCC 132X5 will not serve anyequipment which is redundant to the Division 11 MCC and cables in the room. Control cable 1VE028, which is routed in the risers near column-row 16/P,originally was protected with a 3-hour-rated barrier to ensure that the supplyfan for the miscellaneous electric equipment room remains operational after afire. Loss of the Division 12 AFW control cables will still leave the diesel-driven AFW pump manually operable from a local panel. Only one oil transferpump is required to provide sufficient flow of diesel fuel oil for continuousoperation of an emergency diesel generator. Thus, safe shutdown would not beprevented by a fire in this zone. This zone is a large open area with a lowcombustible load. Area-wide detection and manual suppression capability areprovided. Because of this, and the modification being implemented, a level ofprotection equivalent to Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Subsequent to the above modifications, the switchgear room/cable tunnel ventfan 1VX01C control cable is rerouted out of Fire Zone 11.6-0. Control cable1VE042 (which replaced 1VE028) was to be protected with a 3-hour barrier. Reanalysis shows that this cable is not required for safe shutdown. As aresult, the barrier will not be replaced and the cable will not be rerouted.

AMENDMENT 25 DECEMBER 2012A5.8 -20 In addition, the remaining safe shutdown cables in this fire zone have been determined not to require protection based on an evaluation which demonstrates

that alternate equipment or cabling is available or local manual actions can

be performed as described in the station procedures in the event of a fire.

AMENDMENT 25 DECEMBER 2012A5.8 -21A5.8.12Deviation No: 1A10 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone.

Fire Zone(s) or Elevations Involved 439 feet 0 inch (Fire Zone 3.2B-1)

Description of Equipment/Cables InvolvedThe redundant cables and equipment required for safe shutdown and located inFire Zone 3.2B-1 are listed in Table 2.4-4.

Description of Deviation(s)Cables for both trains of the control room ventilation system are present inthis zone. The separation of these cables does not meet the separationrequirements of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation(s)The fire zone is provided with fire detection and an area-wide automatic suppression system.

In the event of the total loss of the VC system, portable fans will be staged and flow paths established to ventilate the AEERs and main control room from the Turbine Building. Station evaluations (reference EC#333738 and Calculation #BRW-97-0339-

M/BYR97-210), assuming Turbine Building ambient temperatures associated with peak

summer temperatures, have demonstrated that temporary ventilation can maintain the

AEER and main control room temperatures within conditions to assure the control room

remains habitable and control room instrumentation would not be adversely affected.

Additionally, safe shutdown instrumentation at the unit 1 and unit 2 fire hazards panels

would not be affected by the loss of the VC system.In summary, the low combustible loading, automatic fire detection and suppression capabilities, controlled access, and manual provisions to provide ventilation for loss of the VC system, provide a level of fire protection equivalent to thatspecified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

AMENDMENT 25 DECEMBER 2012A5.8 -22A5.8.13Deviation No: 1C.1 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) for a single fire zone (the containment).

Fire Zone(s) or Elevations InvolvedUnit 1 Containment (Fire Zone 1-1)

A5.8.13.1Description of Equipment/Cables Involved Pressurizer Power-Operated Relief Valves (PORV) and Block Valves Pressurizer power-operated relief valves, block valves and associated power and control cables which are required for safe shutdown are located in containment. For the

Division 11 PORV, the associated control cables are 1RY246, 1RY247, 1RY248, 1RY249 and 1RY388. Cable 1RY246 is routed between the containment electrical penetration and a junction box located within the pressurizer cubicle. The remaining

four cables are located entirely within the pressurizer cubicle. For the Division 11

PORV block valve, the associated power and control cables are 1RY002 and 1RY004, which are routed between the containment electrical penetrations and the block valve

itself, which is located within the pressurizer cubicle.

For the Division 12 PORV, the associated control cables are 1RY252, 1RY253, 1RY254, 1RY255 and 1RY389. Cable 1RY252 is routed between the containment

electrical penetration and a junction box located within the pressurizer cubicle. The

remaining four cables are located entirely within the pressurizer cubicle. For the

Division 12 PORV block valve, the associated power and control cables are 1RY007

and 1RY009, which are routed between the containment electrical penetrations and the

block valve itself, which is located within the pressurizer cubicle.

Description of DeviationDue to the proximity of both power-operated relief valves and block valves within the pressurizer cubicle, Division 11 cables (1RY002, 1RY004, 1RY246, 1RY247, 1RY248, 1RY249 and 1RY388) and Division 12 cables (1RY007, 1RY009, 1RY252, 1RY253, 1RY254, 1RY255 and 1RY389) are separated by as little as 5 or 6 feet. The

pressurizer cubicle is separated from the rest of containment by concrete walls that

extend between Elevations 426 feet 0 inch and 471 feet 0 inch.Outside of the pressurizer cubicle, all Division 11 and Division 12 cables are horizontally separated by approximately 13 feet on the vertical run along the shield wall between Elevations 448 feet 0 inch and 467 feet 0 inch, and azimuth angles R7 and R8. Also, between Elevations 421 feet 0 inch and 448 feet 0 inch, azimuth angles R8 and R9, all

cables are separated by a vertical distance of approximately 27 feet with intervening

combustibles in the form of cable trays.

AMENDMENT 25 DECEMBER 2012A5.8 -23 Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the

redundant cables are located within the same fire zone, and no fire barrier is present.

Section C.5.B(2) paragraph (b) specifies separation between redundant cables and equipment by 20 feet of horizontal distance with no intervening combustibles and

installation of fire detectors and an automatic suppression system in the area. This is

not met because the separation between the redundant cables is less than that

specified, and intervening combustibles in the form of cable insulation in cable trays are

present in the area and although detection is available in the affected area, an

automatic fire suppression system is not provided. Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment of one train by a 1-hour rated

fire barrier and installation of fire detectors and an automatic suppression system in the

area. As previously stated, no fire barriers are present in the zone, and an automatic suppression system is not installed. Therefore, the separation between redundant

cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of

BTP CMEB 9.5-1.

Justification for DeviationWithin the pressurizer cubicle, all cables are routed in rigid or flexible conduit. There are no exposed combustible materials within the cubicle that represent a fire hazard.

Thus, a fire within the pressurizer cubicle is considered to be extremely unlikely and the

existing separation is considered to be adequate.Immediately outside of the pressurizer cubicle, where the cables run vertically along the outside of the shield wall, both sets of cables are in conduit. The minimum horizontal

separation is about 13 feet. The only combustible materials here are cables in cable

trays. In this area, the existing separation between redundant cables is considered to

be adequate to preclude a single fire from damaging both trains due to the nature of

combustible materials present and the fact that the cables in question are routed in

conduit.Elsewhere outside of the pressurizer cubicle, Division 11 cables pass underneath Division 12 cables with a minimum vertical separation of 27 feet. This occurs near the

penetration area between R8 and R9. In this area, the Division 11 and Division 12

PORV control cables (1RY246 and 1RY252, respectively) are routed individually in

conduit from their respective penetrations to inside the pressurizer enclosure.

Therefore, in the penetration area, the existing separation between redundant cables is

considered to be adequate to preclude a single fire from damaging both trains due to

the nature of the combustible materials present and the fact that the PORV control

cables are routed in conduit.

Furthermore, even if both pressurizer PORVs were inoperable, the ability to safely shut down the plant would not be lost. Hot standby could be maintained utilizing the

pressurizer safety valves for overpressure protection. Cooldown and depressurization could be accomplished using the steam generators to remove decay heat, and if AMENDMENT 25 DECEMBER 2012A5.8 -24 required, utilizing the letdown system. This mode of operation will take the primary system to a low enough temperature and pressure to initiate RHR system operation.In summary, because of the low combustible loading coupled with the large size of the area, and the routing of the affected PORV cables within conduit from the electrical

penetrations to the valves, a level of fire protection equivalent to that specified in paragraphs (a), (b) or (c) of BTP CMEB 9.5-1 Section III. G. 2 is provided. The existing

separation between the redundant safe shutdown cables for these components is

judged to be adequate to prevent a single fire from simultaneously damaging both

pressurizer PORVs.A5.8.13.2Description of Equipment/Cables InvolvedSteam Generator Wide Range Level Instrumentation Cables for all four channels of steam generator wide range level instrumentation are located in containment. Only one steam generator is required to achieve and maintain

hot standby. Each of the steam generators has one instrumentation cable which provides wide range level indication; steam generator (SG) 1A - instrumentation cable 1FW018, SG 1B - 1FW020, SG 1C - 1FW022, and SG 1D - 1FW024.

Description of DeviationAll four water level instrumentation cables (Division 11 - 1FW018 and 1FW024, Division 12 - 1FW020 and 1FW022) have a minimum separation of approximately 17 feet vertically and 65 feet horizontally in the area bounded by elevations 421 feet 0 inch and 438 feet 0 inch, azimuth angles 141 -15' and 197 -30', at a radius of about 67 feet from

the centerline of containment.

Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the

redundant cables are located within the same fire zone, and no fire barrier is present.

Section C.5.B(2) paragraph (b) specifies separation between redundant cables and

equipment by 20 feet of horizontal distance with no intervening combustibles and

installation of fire detectors and an automatic suppression system in the area. This is not met because intervening combustibles in the form of cable insulation in cable trays are present in the area and although detection is available in the affected area, an

automatic fire suppression system is not provided. Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment of one train by a 1-hour rated

fire barrier and installation of fire detectors and an automatic suppression system in the

area. As previously stated, no fire barriers are present in the zone, and an automatic

suppression system is not installed. Therefore, the separation between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of

BTP CMEB 9.5-1.

Justification for Deviation AMENDMENT 25 DECEMBER 2012A5.8 -25 Although intervening combustibles in the form of cable insulation in cable trays are present in the affected area, the cables utilized at Byron are constructed per IEEE 383.

These cables will not propagate a fire without the presence of an external flame. No

other combustible materials (i.e., an external flame source for the cables) are present in

this area in significant quantities. The fire loading in this area is low. The containment is a large open area. The heat and products of combustion of any fire which may be

postulated to start will be dissipated in the upper levels of the containment building, and

will not be concentrated in the immediate area of the fire near potential targets (i.e.,

other cable trays). In addition, fire detection is provided in this area. For these reasons, the existing separation between redundant cables is considered to be adequate to

preclude a single fire from damaging all four of these safe shutdown instruments.A5.8.13.3Description of Equipment/Cables Involved Source Range Neutron Monitoring InstrumentsTwo channels of source range neutron monitoring instruments are provided. Two channels of post-accident nuclear instrumentation are also provided. A single channel

of nuclear indication (of either system) is required to achieve and maintain hot standby.

Cables for the two available channels of source range neutron monitoring and post-accident nuclear instrumentation are 1NR251 and 1NR252 (Division 11) and 1NR267

and 1NR 268 (Division 12). All of these cables are routed in containment.The detectors for the Division 11 and Division 12 source range neutron monitoring and post-accident nuclear instrument system are located 180 degrees apart to the south and north of the reactor vessel. The Division 11 detector is located on the south side of the

reactor vessel. Cable 1NR252 is routed around the outside of the primary shield wall to

a box on the east side of the primary shield wall. Cable 1NR251 is routed from this box directly east to the missile barrier, through the missile barrier, and to an electrical penetration near azimuth R11. The Division 12 detector is located on the north side of the reactor vessel. Cable 1NR268 is routed in a northwest direction from the detector to a box in the northwest quadrant of the containment building. Cable 1NR267 is routed from the box directly north to the missile barrier. After passing through the missile

barrier, the cable follows along the exterior containment wall to an electrical penetration

between azimuth R8 and R9.

Description of Deviation Inside the missile barrier, the separation between cables 1NR251 (Division 11) and 1NR267 (Division 12) is approximately 50 feet in the area bounded by Elevations 401feet and 424 feet, azimuth angles R11 and R7. Intervening combustibles are present in the form of lubricating oil in the reactor coolant pump 1D and cable tray. Outside of the missile barrier, the instrument channels are separated by approximately 36 feet in the area bounded by Elevations 412 feet and 420 feet, azimuth angles R9 and AMENDMENT 25 DECEMBER 2012A5.8 -26R11. Intervening combustibles are present in the form of cable trays. In addition, area-wide fire detection or suppression is not provided in these zones.

Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the redundant cables are located within the same fire zone, and no fire barrier is present.

Section C.5.B(2) paragraph (b) specifies separation between redundant cables and

equipment by 20 feet of horizontal distance with no intervening combustibles and installation of fire detectors and an automatic suppression system in the area. This is

not met because intervening combustibles in the form of cable insulation in cable trays

are present in the area and although detection is available in the affected area, an automatic fire suppression system is not provided. Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment of one train by a 1-hour rated

fire barrier and installation of fire detectors and an automatic suppression system in the

area. As previously stated, no fire barriers are present in the zone, and an automatic

suppression system is not installed. Therefore, the separation between redundant

cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of

BTP CMEB 9.5-1.Justification for Deviation The cables are routed in conduit inside the missile barrier. The minimum separation between the two instrument cables is approximately 50 feet. The reactor coolant pump is not considered to represent a major fire hazard since it is provided with an oil collection system. Furthermore, heat detectors are provided over the pump. Only one 12 inch wide cable tray is located in this area of Fire Zone 1.1-1. The cable tray is located near radii R7 to R11 where the separation between redundant cables is 50 feet. The tray is filled to less than one quarter of its total cross sectional area. The cablesare primarily located on the opposite sides of the primary shield wall, and are not subject to the same fire hazards. Outside of the missile barrier, the minimum separation between the two instrument cables is approximately 36 feet. Only two 12 inch wide cable trays are located in this area of Fire Zone 1.2-1. The cable trays are located near radii R11 to R9. One tray is filled to less than half its total cross sectional area andthe other tray is filled to less than one quarter of its total cross sectional area. In view of the fact that the neutron monitoring cables are in conduit for the majority of their routings, and in

consideration of the nature and orientation of intervening combustibles, the existing

separation is considered to be adequate to preclude a single fire from disabling all of the

instruments.A5.8.13.4Description of Equipment/Cables Involved Pressurizer Pressure Instrumentation Four channels of pressurizer pressure instrumentation are provided. Only one of the four available pressurizer pressure instrumentation channels is required to achieve and

maintain hot standby. Inside containment, a single cable is associated with each of the AMENDMENT 25 DECEMBER 2012A5.8 -27 four channels. The four instrumentation cables are 1RY199 and 1RY207 in Division 11, and 1RY203 and 1RY211 in Division 12.

Description of Deviation All four pressurizer pressure instrumentation cables have a minimum separation of approximately 17 feet vertically and 65 feet horizontally in the area bounded by Elevation 421 feet 0 inch and 438 feet 0 inch, azimuth angles 141 -15' and 197 -30', at a radius at about 67 feet from the centerline of containment.

Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the redundant cables are located within the same fire zone, and no fire barrier is present.

Section C.5.B(2) paragraph (b) specifies separation between redundant cables and

equipment by 20 feet of horizontal distance with no intervening combustibles and installation of fire detectors and an automatic suppression system in the area. This is

not met because intervening combustibles in the form of cable insulation in cable trays

are present in the area and although detection is available in the affected area, an automatic fire suppression system is not provided. Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment of one train by a 1-hour rated

fire barrier and installation of fire detectors and an automatic suppression system in the area. As previously stated, no fire barriers are present in the zone, and an automatic

suppression system is not installed. Therefore, the separation between redundant

cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of

BTP CMEB 9.5-1.

Justification for DeviationA single fire large enough to damage both Division 11 and Division 12 cables would have to span more than 60 feet in the horizontal direction between azimuth angles R9

and R12. Although intervening combustibles in the form of cable insulation in cable

trays are present in the affected area, the cables utilized at Byron are constructed per

IEEE 383. These cables will not propagate a fire without the presence of an external

flame. No other combustible materials (i.e., an external flame source for the cables) are

present in this area in significant quantities. The fire loading in this area is low. The

containment is a large open area. The heat and products of combustion of any fire

which may be postulated to start will be dissipated in the upper levels of the

containment building, and will not be concentrated in the immediate area of the fire near

potential targets (i.e., other cable trays). In addition, fire detection is provided in this area. For these reasons, the existing separation between redundant cables is

considered to be adequate to preclude a single fire from damaging all four of these safe

shutdown instruments.A5.8.13.5Description of Equipment/Cables Involved Pressurizer Level Instrumentation AMENDMENT 25 DECEMBER 2012A5.8 -28Three channels of pressurizer level instrumentation are provided. One of the three pressurizer level instrumentation channels is required to achieve and maintain hot

standby. Inside containment, a single cable is associated with each of the three channels. The three instrumentation cables are 1RY20l and 1RY209 in Division 11, and

1RY205 in Division 12.

Description of Deviation All three pressurizer level instrumentation cables have a minimum separation of approximately 13 feet vertically and 22 feet horizontally in the area bounded by Elevations 410 feet 6 inches and 423 feet 6 inches, azimuth angles 178 -15' and 197 -

30', at a radius of about 67 feet from the centerline of containment.

Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the

redundant cables are located within the same fire zone, and no fire barrier is present.

Section C.5.B(2) paragraph (b) specifies separation between redundant cables and equipment by 20 feet of horizontal distance with no intervening combustibles and

installation of fire detectors and an automatic suppression system in the area. This is

not met because intervening combustibles in the form of cable insulation in cable trays

are present in the area and although detection is available in the affected area, an

automatic fire suppression system is not provided. Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment of one train by a 1-hour rated

fire barrier and installation of fire detectors and an automatic suppression system in the

area. As previously stated, no fire barriers are present in the zone, and an automatic

suppression system is not installed. Therefore, the separation between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of

BTP CMEB 9.5-1.

Justification for Deviation The pressurizer level instrumentation cables are routed in conduit. Although intervening combustibles in the form of cable insulation in cable trays are present in the affected

area, the cables utilized at Byron are constructed per IEEE 383. These cables will not

propagate a fire without the presence of an external flame. No other combustible materials (i.e., an external flame source for the cables) are present in this area in

significant quantities. The fire loading in this area is low. The containment is a large

open area. The heat and products of combustion of any fire which may be postulated to start will be dissipated in the upper levels of the containment building, and will not be

concentrated in the immediate area of the fire near potential targets (i.e., other cable

trays). In addition, fire detection is provided in this area. For these reasons, the existing separation between redundant cables is considered to be adequate to preclude

a single fire from damaging all three of these safe shutdown instruments.A5.8.13.6Description of Equipment/Cables Involved AMENDMENT 25 DECEMBER 2012A5.8 -29 Reactor Coolant Hot Leg Temperature Or Core Exit Temperature Indication for reactor coolant hot leg temperature for one RCS loop or indication of core exit temperature from one division of the incore thermocouples is required to achieve

and maintain hot standby.

Each reactor coolant system hot leg has a dual element RTD. The loop "A" and "D" RTDs are located between the primary and secondary shield walls on the eastside of

the reactor cavity. The loop "B" and "C" RTDs are located between the primary and

secondary shield walls on the west side of the reactor cavity.

One of the two elements for each RTD provides a signal to indication in the main control room and at the remote shutdown panel. The four cables associated with the

MCR/RSP indication are 1RC351, 1RC356, 1RC361 and 1RC366. All four of these

cables are Division 11 cables. These four cables are routed in a generally northern direction from their respective RTDs to outside of the secondary shield wall, and from

there they follow along the exterior containment wall over to their Division 11 electrical

penetration located near R8.

The remaining element for each RTD provides a signal to electrically independent indication located on the Fire Hazards Panel. The four cables associated with the FHP

indication are 1RC743, 1RC745, 1RC747 and 1RC749. All four of these cables are

Division 12 cables. Starting at their respective RTDs, these four cables are routed in a

generally southerly direction to outside of the secondary shield wall, and from there they

follow along the exterior containment wall over to their Division 12 electrical penetration

located near R11.The Division 11 incore thermocouple cables are 1IT308 through 1IT340, 1IT343, 1IT344, 1IT425 and the 33 incore thermocouple circuits combined into five

multiconductor mineral insulated cables 1IT428, 1IT429, 1IT432, 1IT433, 1IT436, 1IT437, 1IT440, 1IT441, 1IT444, and 1IT445 (two cable numbers assigned per multiconductor cable) from junction box 1JB656R to the reactor vessel head. The

Division 12 incore thermocouple cables are 1IT351 through 1IT382, 1IT347, 1IT348, 1IT427, and the 32 incore thermocouple circuits combined into five multiconductor

mineral insulated cables 1IT430, 1IT431, 1IT434, 1IT435, 1IT438, 1IT439, 1IT442, 1IT443, 1IT446, and 1IT447 (two cable numbers assigned per multiconductor cable)

from junction box 1JB657R to the reactor vessel head.

The Division 11 incore thermocouple cables are routed in conduit from a containment penetration at Elevation 417 feet 6 inches between R8 and R9 to junction box 1JB656R

outside the missile barrier at Elevation 431 feet 9 inches between R11 and R12. The

Division 12 incore thermocouple cables are routed in conduit from a containment

penetration at Elevation 439 feet 3 inches near R8 to junction box 1JB657R outside the

missile barrier at Elevation 435 feet 9 inches between R11 and R12. The mineral insulated cables for both divisions are routed in conduit from junction boxes 1JB656R AMENDMENT 25 DECEMBER 2012A5.8 -30 and 1JB657R, between steam generators 1A and 1D, to the primary shield wall. These same cables are then routed in cable trays (Elevation 430 feet) from the primary shield wall to a connector plate above the reactor vessel, and from there routed vertically down

to the reactor vessel head.

Description of Deviation Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the

redundant cables are located within the same fire zone, and no fire barrier is present.

Section C.5.B(2) paragraph (b) specifies separation between redundant cables and

equipment by 20 feet of horizontal distance with no intervening combustibles and

installation of fire detectors and an automatic suppression system in the area. This is

not met because the separation between the redundant cables is less than that

specified, and intervening combustibles in the form of cable insulation in cable trays are present in the area and although detection is available in the affected area, an

automatic fire suppression system is not provided. The Divisions 11 and 12 reactor

coolant hot leg temperature and incore thermocouple cables are routed in the closest proximity to each other outside of the secondary shield wall. The minimum horizontal

separation between a single division of either the hot leg cables or the incore thermocouple cables is approximately 52 feet in the sector bounded by R8 and R11.

Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment of one train by a 1-hour rated fire barrier and installation of fire detectors and an

automatic suppression system in the area. As previously stated, no fire barriers are

present in the zone, and an automatic suppression system is not installed. Therefore, the separation between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation Between the primary and secondary shield walls, the RCS loop "B" and "C" RTDs and their cables are separated from the RCS loop "A" and "D" RTDs and their cables and

the incore thermocouple cables by the primary shield wall and/or the refueling pool

structure. The primary shield wall is a concrete structure approximately 34 feet in

diameter that encloses the reactor cavity and reactor vessel. These structures serve

the purpose of a noncombustible radiant energy shield that separates the loop "B" and "C" RTDs and cables from the redundant loop "A" and "D" RTDs and cables and incore

thermocouple cables. Away from the penetration, the divisional routings of the RTD

cables provide good spatial separation, ensuring that indication for at least one loop of

reactor coolant hot leg temperature will be available. As previously stated, the minimum

separation of cables occurs between the containment penetrations and secondary

shield wall. The minimum horizontal separation between a single division of either the hot leg cables or the incore thermocouple cables is approximately 52 feet at the

containment penetrations in the sector bounded by R8 and R11. Therefore, a fire would

have to span a horizontal distance of approximately 52 feet to damage all of the reactor coolant hot leg and incore thermocouple cables. Although intervening combustibles in AMENDMENT 25 DECEMBER 2012A5.8 -31 the form of cable insulation in cable trays are present in the affected area, the cables utilized at Byron are constructed per IEEE 383. These cables will not propagate a fire

without the presence of an external flame. No other combustible materials (i.e., an

external flame source for the cables) are present in this area in significant quantities.

The fire loading in this area is low. The containment is a large open area. The heat and

products of combustion of any fire which may be postulated to start will be dissipated in

the upper levels of the containment building, and will not be concentrated in the immediate area of the fire near potential targets (i.e., other cable trays). In addition, fire

detection is provided in this area. For these reasons, the existing separation between

redundant cables is considered to be adequate to preclude a single fire from damaging

all of these safe shutdown instruments.A5.8.13.7Description of Equipment/Cables Involved Reactor Coolant Cold Leg Temperature Indication for reactor coolant cold leg temperature for one RCS loop is credited to achieve and maintain hot standby. Each reactor coolant system cold leg has a dual element RTD. The loop "A" and "D" RTDs are located between the primary and secondary shield walls on the eastside of the reactor cavity. The loop "B" and "C" RTDs

are located between the primary and secondary shield walls on the west side of the

reactor cavity.

One of the two elements for each RTD provides a signal to indication in the main control room and at the remote shutdown panel. The four cables associated with the

MCR/RSP indication are 1RC373, 1RC392, 1RC397 and 1RC402. All four of these

cables are Division 12 cables. Some of these four cables are routed in a generally southerly direction from their respective RTDs to outside of the secondary shield wall, and from there they follow along the exterior containment wall over to their Division 12

electrical penetration located near R12. The other cables remain inside the secondary

shield wall until they pass through it in the immediate vicinity of the electrical penetration

located by R12.

The remaining element for each RTD provides a signal to electrically independent indication located on the Fire Hazards Panel. The four cables associated with the FHP indication are 1RC751, 1RC753, 1RC755 and 1RC757. All four of these cables are

also Division 12 cables. Starting at their respective RTDs, these four cables are routed

in a generally southerly direction to outside of the secondary shield wall, and from there

they follow along the exterior containment wall over to their Division 12 electrical

penetration located near R9.

Description of Deviation The eight cold leg RTD cables have a minimum separation of approximately 1 foot vertically near R12. Combustibles are present in the immediate area in the form of cable trays.

AMENDMENT 25 DECEMBER 2012A5.8 -32 Section C.5.B(2) paragraph (a) is not met because the separation between these cables is less than the specified 20 horizontal feet, and because combustibles in the form of

cable insulation in cable trays are present in the area. Section C.5.B(2) paragraph (b) is

not met because an automatic fire suppression system is not provided. Section

C.5.B(2) paragraph (c) is not met because non-combustible shields are not provided.

Therefore, the separation between redundant cables deviates from the guidelines of

Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation Although intervening combustibles in the form of cable insulation in cable trays are present in the affected area, the cables utilized at Byron are constructed per IEEE 383.

These cables will not propagate a fire without the presence of an external flame. No

other combustible materials (i.e., an external flame source for the cables) are present in

this area in significant quantities. The fire loading in this area is low. The containment

is a large open area. The heat and products of combustion of any fire which may be

postulated to start will be dissipated in the upper levels of the containment building, and will not be concentrated in the immediate area of the fire near potential targets (i.e.,

other cable trays). In addition, fire detection is provided in this area. For these reasons, the existing separation between redundant cables is considered to be adequate to

preclude a single fire from damaging all of these safe shutdown instruments.

Additionally, the loss of all cold leg RTDs is acceptable for the following reasons. The cold leg RTDs would normally be used in conjunction with the hot leg RTDs to verify

adequate core cooling, i.e., that natural circulation is present. This condition can also

be verified by trending the temperatures indicated by the core exit thermocouples. As noted in Section A5.8.13.6, the thermocouple cables are routed in conduit in the area of concern. Furthermore, cold leg temperature can be inferred from steam generator

pressure. As indicated in Section 2.4, steam generator pressure instrumentation and cabling are independent of this zone. Plant emergency procedures are written to refer

to these alternate methods of verifying primary system conditions. In fact, the core exit

thermocouples are the preferred method. The Byron and Braidwood plant procedures are written using guidance from the Westinghouse Owners Group. Therefore, this deviation from BTP CMEB 9.5-1 requirements is considered to be acceptable.A5.8.13.8Description of Equipment/Cables Involved Reactor Containment Fan Cooler (RCFC) FansTwo of the four RCFC fans are required to operate in the high-speed mode to achieve and maintain hot standby. The four RCFCs themselves are located outside of the

secondary shield wall at widely spaced intervals around the containment. The high

speed power cables for the RCFC fans routed inside containment are 1VP004, 1VP026, 1VP048, and 1VP070.

Description of Deviation AMENDMENT 25 DECEMBER 2012A5.8 -33All four RCFC power cables (Division 11 - 1VP004 and 1VP048, Division 12 - 1VP026 and 1VP070) have a minimum separation of approximately 36 horizontal feet. This minimum separation occurs in the area bounded by elevations 393 feet 5 inches and

439 feet 3 inches, R/8 and R/12, at a radius of about 60 feet from the centerline of

containment. There are intervening combustibles in this area in the form of cable

insulation.

Section C.5.B(2) paragraph (a) is not met because intervening combustibles in the form of cable insulation in cable trays are present in the area. Section C.5.B(2) paragraph (b) is not met because an automatic fire suppression system is not provided. Section

C.5.B(2) paragraph (c) is not met because non-combustible shields are not provided.

Therefore, the separation between redundant cables deviates from the guidelines of

Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.Justification for Deviation Although intervening combustibles in the form of cable insulation in cable trays are present in the affected area, the cables utilized at Byron are constructed per IEEE 383.

These cables will not propagate a fire without the presence of an external flame. No

other combustible materials (i.e., an external flame source for the cables) are present in

this area in significant quantities. The fire loading in this area is low. The containment is a large open area. The heat and products of combustion of any fire which may be

postulated to start will be dissipated in the upper levels of the containment building, and

will not be concentrated in the immediate area of the fire near potential targets (i.e.,

other cable trays). In addition, fire detection is provided in this area. For these reasons, the existing separation between redundant cables is considered to be adequate to

preclude a single fire from damaging all of these safe shutdown cables.

AMENDMENT 25 DECEMBER 2012A5.8 -34A5.8.14Deviation No: 2A.1This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the Unit 2 main steam tunnel).

Fire Zone(s) or Elevations Involved Unit 2 Main Steam and Feedwater Pipe Tunnels at various elevations between 357 feet 0 inch and 377 feet 0 inch (Fire Zone 18.3-2). The two valve enclosures that extend up

to grade elevation are also a part of this fire zone.

Description of Equipment/Cables InvolvedThe cables and equipment required for safe shutdown and located in Fire Zone 18.3-2 are listed in Table 2.4-4. The redundant components and cables consist of valves and

instruments in the main steam and auxiliary feedwater systems.

Description of DeviationThis fire zone encompasses two pipe tunnels and two physically separated valve houses. The two valve houses are located approximately 120 degrees apart at the

northwest and northeast sides of the exterior containment wall. The below grade main steam and feedwater pipe tunnels connect the two valve houses. The northwest valve

house contains safe components and piping associated with the "B" and "C" steam

generators. The northeast valve house contains safe shutdown components and piping associated with the "A" and "D" steam generators. Safe shutdown components located

in (or near to) the valve houses include the main steam safety valves, the steam

generator PORVs, the MSIVs, MSIV bypass valves, steam generator pressure

instruments and auxiliary feedwater system containment isolation valves. Cables

associated with these components are present in the valve houses, and are also routed

through the main steam and/or feedwater pipe tunnels to the auxiliary building. In the area of the pipe tunnels bounded by column-rows 26 to 31 and P to Q, cables for all of

the redundant components may be present.

The combustible material present in this zone consists of hydraulic fluid that is located in the two valve houses. All cables routed through the pipe tunnels are located in conduit, and thus do not count as exposed combustibles. The main steam and

feedwater pipe tunnels themselves have no combustible materials and no fire loading.

Ionization detection is available in the two valve houses. The pipe tunnels themselves have no detection. Manual extinguishing capability consisting of portable extinguishers

and a hose station is available to the area.

Separation between redundant components located in the two valve houses: Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the redundant

components involved are located within the same fire zone, and no fire barrier is AMENDMENT 25 DECEMBER 2012A5.8 -35 present. Section C.5.B(2) paragraph (b) specifies separation between redundant cables and equipment by 20 feet of horizontal distance with no intervening combustibles and

installation of fire detectors and an automatic suppression system in the area. The

separation through the pipe tunnels between the two valve houses is in excess of 200 linear feet with no intervening combustibles. However, this requirement is not met

because neither detection nor an automatic fire suppression system are provided in the

pipe tunnels. Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables

and equipment of one train by a 1-hour rated fire barrier and installation of fire detectors

and an automatic suppression system in the area. As previously stated, no fire barriers

are present in the zone, and neither detection nor an automatic suppression system are

installed. Therefore, the separation between redundant components in the two valve

houses deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of

BTP CMEB 9.5-1.Separation between redundant cables within the pipe tunnels: Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the redundant cables involved are located within the same fire zone, and no fire barrier is present. Section C.5.B(2)

paragraph (b) specifies separation between redundant cables and equipment by 20 feet

of horizontal distance with no intervening combustibles and installation of fire detectors and an automatic suppression system in the area. Although the pipe tunnels have no

fire loading (i.e., no combustible materials), this requirement is not met because existing

separation is less than 20 horizontal feet. In addition, neither detection nor an automatic fire suppression system are provided in the pipe tunnels. Section C.5.B(2)

paragraph (c) specifies enclosure of redundant cables and equipment of one train by a

1-hour rated fire barrier and installation of fire detectors and an automatic suppression system in the area. As previously stated, no fire barriers are present in the zone, and

neither detection nor an automatic suppression system are installed in the pipe tunnels.

Therefore, the separation between redundant cables deviates from the guidelines of

Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation Separation between redundant component located in the two valve houses: Other than the oil associated with the valve hydraulic systems in both valve enclosures, there are

no combustible materials in the main steam and feedwater tunnels, which then have no

fire load. Detection and manual suppression capability are provided in the valve

enclosures. The separation between the two valve houses, coupled with the absence of combustible materials in the connecting pipe tunnels, is sufficient to ensure that no

single fire could affect both valve enclosures at once.

Separation between redundant cables within the pipe tunnels: All safe shutdown cables located in this fire zone are routed in conduit. This fact, in conjunction with the absence

of combustible materials within the pipe tunnels, is sufficient to ensure a single fire (involving transient combustible materials) will not affect redundant safe shutdown

cables.

AMENDMENT 25 DECEMBER 2012A5.8 -36 In summary, because the cables are routed in conduit, and considering the configuration of combustible materials, and detection and manual suppression

capability, a level of protection equivalent to Section C.5.B(2) of BTP CMEB 9.5-1 is achieved. The existing separation is judged to be adequate to preclude a single fire in

the pipe tunnels or within one of the valve houses from affecting redundant safe

shutdown components or cables.

AMENDMENT 25 DECEMBER 2012A5.8 -37A5.8.15Deviation No: 2A.2 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) between fire zones (2A RHR pump room and 2B RHR pump

room).Fire Zone(s) or Elevations Involved 346 feet 0 inch (Fire Zone 11.2A-2)

346 feet 0 inch (Fire Zone 11.2D-2)

Description of Equipment/Cables InvolvedRHR pump 2A and its cubicle cooler are located in Fire Zone 11.2A-2. RHR pump2B and its cubicle cooler are located in Fire Zone 11.2D-2. Refer to Table2.4-4 for a specific list of redundant equipment and cables in these zones. Figure 2.3-15 shows the location of the equipment involved.

Description of Deviation(s)The RHR pumps and cubicle coolers located in Fire Zone 11.2A-2 are separatedfrom the redundant RHR pump and cubicle cooler, located in Fire Zone 11.2D-2,by a 2-hour-rated fire barrier. Also, area-wide automatic fire suppression isnot provided in either zone; nor is it provided in Fire Zones 11.2B-2 and11.2C-2 (containment spray pump rooms), which are located between the RHR pumprooms. This is not in accordance with the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation(s)

Due to the presence of the containment spray pump rooms between the RHR pumprooms, the separation between the two trains of RHR components is greater than75 feet. The 3 walls between the two trains of RHR components are all of 3-hour construction. Two of the walls contain unsealed penetrations orpenetrations with non-fire-rated seals. The wall at column-row W between thetwo containment spray pump rooms is upgraded to all 2-hour-rated fire barrier. The RHR pump rooms and the containment spray pump rooms have low combustibleloadings. All of these rooms are provided with automatic fire detection. Fire Zone 11.2B-2 contains a manual hose station having hose of adequatelength to reach Fire Zones 11.2A-2, 11.2C-2, and 11.2D-2. Also, portableextinguishers are provided in adjacent Fire Zone 11.2-0 (auxiliary buildinggeneral area).The residual heat removal system is not required for hot shutdown of theplant. Station repair procedures been written to ensure that theRHR system will be repaired and available to achieve cold shutdown conditionswithin 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> after a fire.

AMENDMENT 25 DECEMBER 2012A5.8 -38In summary, the large distance separating the two trains of RHR pumps andcubicle coolers, the 2 hour-rated fire barrier, fire detection and manual firesuppression provided, establish a level of fire protection commensurate withthe guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

AMENDMENT 25 DECEMBER 2012A5.8 -39A5.8.16Deviation No: 2A.3This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the Unit 1 main control room), and

for which alternate or dedicated shutdown capability is provided.

Fire Zone(s) or Elevations Involved451 feet 0 inch (Fire Zone 2.1-0)

Description of Equipment/Cables InvolvedThe cables and equipment required for safe shutdown and located in Fire Zone2.1-0 are listed in Table 2.4-4.

Description of Deviation(s)The redundant safe shutdown cables located in Fire Zone 2.1-0 are notseparated by a 20-foot space free of combustible materials and the area is notcovered by a total suppression system. This is not in accordance with theguidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation(s)Controls and instrumentation for all plant systems are located in the controlroom. Although separation of redundant trains does not meet the requirementsof Section III.G.2, alternative shutdown systems and equipment independent ofthis zone are provided. Specifically, the remote Shutdown Panel and FireHazards Panel have sufficient controls and instrumentation to bring the plantto hot standby, and taking credit for limited local manual operations, coldshutdown can be achieved. This meets the requirements of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1and is therefore acceptable.

AMENDMENT 25 DECEMBER 2012A5.8 -40A5.8.17Deviation No: 2A.4This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the Unit 2 Auxiliary Electric

Equipment Room), and for which alternate or dedicated shutdown capability is provided.

Fire Zone(s) or Elevations Involved451 feet 0 inch (Fire Zone 5.5-2)

Description of Equipment/Cables InvolvedThe cables and equipment required for safe shutdown and located in Fire Zone5.5-2 are listed in Table 2.4-4.

Description of Deviation(s)The redundant safe shutdown cables present in Fire Zone 5.5-2 are notseparated by 20 feet with the intervening space free of combustible materials. Also the area is not covered by a total suppression system. This is not inaccordance with the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation(s)Instrumentation for both trains of safe shutdown equipment is located in thiszone. Although separation of this redundant equipment does not meet therequirements of Section III.G.2, alternative shutdown instrumentationindependent of this zone is provided. Specifically, the Fire Hazards Panel,described in Subsection 2.4 of the Fire Protection Report, has sufficientinstrumentation to bring the plant to the hot standby condition, and takingcredit for local manual operation, cold shutdown can be achieved. This meetsthe requirements of Section C.5.B(3) and is therefore acceptable.

AMENDMENT 25 DECEMBER 2012A5.8 -41A5.8.18Deviation No: 2A.5This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (the Unit 2 Remote Shutdown Panel

Room).Fire Zone(s) or Elevations Involved 383 feet 0 inch (Fire Zone 11.4C-0)

Description of Equipment/Cables InvolvedThe redundant cables and equipment required for safe shutdown and located inFire Zone 11.4C-0 are listed in Table 2.4-4.

Description of Deviation(s)The remote shutdown panels for both units are located in this zone. A fire inthis zone could render inoperable the remote shutdown panels and thecorresponding controls in the control room. As a result, redundant systemsrequired for safe shutdown could be adversely affected. In addition, no area-wide automatic fire suppression is provided. This is not in accordance withthe guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation(s)Fire Zone 11.4C-0 is separated from the rest of the plant by 3-hour-rated firebarriers and is a controlled access area. The remote shutdown control panelsfor Unit 1 are separated from those for Unit 2 by approximately 90 feet. Onemanual hose station and portable fire extinguishers are available in thiszone. Ionization detectors are provided throughout the fire zone, includingthe room with the remote shutdown panel, which annunciate and alarm in thecontrol room. The fire load is moderately low and the bulk of combustiblematerials consists of cable insulation. In the event of a fire in this zone,safe shutdown of the plant can be achieved by local operation of equipment. Also, instruments located at the remote shutdown panel are isolated so that afire in this room will not affect the instruments in the control room.

In summary, the low combustible loading, automatic fire detection and manualsuppression capabilities, controlled access, and local operation of safeshutdown equipment provide a level of fire protection equivalent to thatspecified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

AMENDMENT 25 DECEMBER 2012A5.8 -42A5.8.19Deviation No: 2A.6 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone (general area, Auxiliary Building

Elevation 383 feet).

Fire Zone(s) or Elevations Involved 383 feet 0 inch (Fire Zone 11.4-0)

Description of Equipment/Cables InvolvedThe redundant cables and equipment required for safe shutdown and located inFire Zone 11.4-0 are listed in Table 2.4-4.

Description of Deviation(s)Redundant power and/or control cables serving auxiliary feedwater pumps 2A and2B routed in Fire Zone 11.4-0 are less than 20 feet apart and the interveningspace contains combustible materials and the area is not covered by a totalsuppression system which is not in accordance with the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation(s)The diesel-driven auxiliary feedwater pump is located within its own room,which has 3-hour fire-rated barriers separating it from the general areaoutside. This pump can be manually started from a local control panel in thisroom, and it will operate completely independent of the associated cableslocated outside of the room in the general area on Elevation 383 feet 0 inch(Fire Zone 11.4-0). Thus, the fact that cables for both AFW pumps are presentin the same area in Fire Zone 11.4-0 and could be damaged by a single fire isacceptable, since the Division 22 diesel-driven AFW pump can still be manuallystarted and operated.In order to provide an adequate supply of water to the secondary heat sink ina timely manner following a fire in this zone, remote start capability for thediesel-driven auxiliary feedwater pump is required. Therefore, a remoteswitch has been installed at the elevation below in Fire Zone 11.3-0 to ensurethat the diesel-driven auxiliary feedwater pump can be manually started in thecase of a fire in Fire Zone 11.4-0.Cables 2AF346 and 2AF338 (which are routed in Fire Zone 11.4-0 in amodification subsequent to this deviation) supply a lo-lo suction pressuresignal that could trip the 2B auxiliary feedwater (AFW) pump. To precludethis from happening, a modification is implemented to allow the 2B pump to bemanually started even if these cables, 2AF346 and 2AF338, are damaged by fire. Besides these cables, several other cables associated with both AFW pumps arerouted through Fire Zone 11.4-0; however, an AMENDMENT 25 DECEMBER 2012A5.8 -43evaluation has shown that the 2BAFW pump can be started locally if a fire destroyed these cables.

AMENDMENT 25 DECEMBER 2012A5.8 -44A5.8.20Deviation No: 2A.7 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone.

Fire Zone(s) or Elevations Involved 439 feet 0 inch (Fire Zone 3.2B-1)

Description of Equipment/Cables InvolvedThe redundant cables and equipment required for safe shutdown and located inFire Zone 3.2B-1 are listed in Table 2.4-4.

Description of Deviation(s)Cables for both trains of the control room ventilation system are present inthis zone. The separation of these cables does not meet the separationrequirements of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation(s)The fire zone is provided with fire detection and an area-wide automatic suppression system.

In the event of the total loss of the VC system, portable fans will be staged and flow paths established to ventilate the AEERs and main control room from the Turbine Building. Station evaluations (reference EC#333738 and Calculation #BRW-97-0339-

M/BYR97-210), assuming Turbine Building ambient temperatures associated with peak

summer temperatures, have demonstrated that temporary ventilation can maintain the AEER and main control room temperatures within conditions to assure the control room

remains habitable and control room instrumentation would not be adversely affected.

Additionally, safe shutdown instrumentation at the unit 1 and unit 2 fire hazards panels

would not be affected by the loss of the VC system.In summary, the low combustible loading, automatic fire detection and suppression capabilities, controlled access, and manual provisions to provide ventilation for loss of the VC system, provide a level of fire protection equivalent to thatspecified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

AMENDMENT 25 DECEMBER 2012A5.8 -45A.5.8.21Deviation No: 2A.8 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone.Fire Zone(s) or Elevations Involved 401 feet 0 inch (Fire Zone 11.5-0)

Description of Equipment/Cables InvolvedThe redundant cables and equipment required for safe shutdown and located inFire Zone 11.5-0 are listed in Table 2.4-4.

Description of Deviation(s)Cables for both trains of the control room ventilation system are present inthis zone. The separation of these cables does not meet the separationrequirements of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation(s)The fire zone is provided with an area-wide automaticfire detection system.

In the event of the total loss of the VC system, portable fans will be staged and flow paths established to ventilate the AEERs and main control room from the Turbine Building. Station evaluations (reference EC#333738 and Calculation #BRW-97-0339-

M/BYR97-210), assuming Turbine Building ambient temperatures associated with peak summer temperatures, have demonstrated that temporary ventilation can maintain the

AEER and main control room temperatures within conditions to assure the control room

remains habitable and control room instrumentation would not be adversely affected.

Additionally, safe shutdown instrumentation at the unit 1 and unit 2 fire hazards panels

would not be affected by the loss of the VC system.In summary, the low combustible loading, automatic fire detection capability, and manual provisions to provide ventilation for loss of the VC system, provide a level of fire protection equivalent to thatspecified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

AMENDMENT 25 DECEMBER 2012A5.8 -46A.5.8.22Deviation No: 2A.9 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) within a single fire zone.

Fire Zone(s) or Elevations Involved 426 feet 0 inch (Fire Zone 11.6-0)

Description of Equipment/Cables InvolvedThe redundant cables and equipment required for safe shutdown and located inFire Zone 11.6-0 are listed in Table 2.4-4.

Description of Deviation(s)Cables for both trains of the control room ventilation system are present inthis zone. The separation of these cables does not meet the separationrequirements of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation(s)The fire zone is provided with an area-wide automaticfire detection system.In the event of the total loss of the VC system, portable fans will be staged and flow paths established to ventilate the AEERs and main control room from the Turbine Building. Station evaluations (reference EC#333738 and Calculation #BRW-97-0339-M/BYR97-210), assuming Turbine Building ambient temperatures associated with peak

summer temperatures, have demonstrated that temporary ventilation can maintain the

AEER and main control room temperatures within conditions to assure the control room

remains habitable and control room instrumentation would not be adversely affected.

Additionally, safe shutdown instrumentation at the unit 1 and unit 2 fire hazards panels

would not be affected by the loss of the VC system.In summary, the low combustible loading, automatic fire detection capability, and manual provisions to provide ventilation for loss of the VC system, provide a level of fire protection equivalent to thatspecified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

AMENDMENT 25 DECEMBER 2012A5.8 -47 A5.8.23Deviation No: 2C.1 This item represents a deviation from the separation requirements of Section C.5.B(2), paragraphs (a), (b) and (c) for a single fire zone (the containment).

Fire Zone(s) or Elevations InvolvedUnit 2 Containment (Fire Zone 1-2)

A5.8.23.1Description of Equipment/Cables Involved Pressurizer Power-Operated Relief Valves (PORV) and Block Valves Pressurizer power-operated relief valves, block valves and associated power and control cables which are required for safe shutdown are located in containment. For the

Division 21 PORV, the associated control cables are 2RY247, 2RY248, 2RY249, 2RY388 and 2RY490. Cable 2RY490 is routed between the containment electrical

penetration and a junction box located within the pressurizer cubicle. The remaining

four cables are located entirely within the pressurizer cubicle. For the Division 21

PORV block valve, the associated power and control cables are 2RY002 and 2RY004, which are routed between the containment electrical penetrations and the block valve itself, which is located within the pressurizer cubicle.

For the Division 22 PORV, the associated control cables are 2RY253, 2RY254, 2RY255, 2RY389 and 2RY491. Cable 2RY491 is routed between the containment

electrical penetration and a junction box located within the pressurizer cubicle. The

remaining four cables are located entirely within the pressurizer cubicle. For the

Division 22 PORV block valve, the associated power and control cables are 2RY007 and 2RY009, which are routed between the containment electrical penetrations and the

block valve itself, which is located within the pressurizer cubicle.

Description of Deviation Due to the proximity of both power-operated relief valves and block valves within the pressurizer cubicle, Division 21 cables (2RY002, 2RY004, 2RY247, 2RY248, 2RY249, 2RY388 and 2RY490) and Division 22 cables (2RY007, 2RY009, 2RY253, 2RY254, 2RY255, 2RY389 and 2RY491) are separated by as little as 1 foot. The pressurizer cubicle is separated from the rest of containment by concrete walls that extend between

Elevations 426 feet 0 inch and 471 feet 0 inch.

Outside of the pressurizer cubicle, all Division 21 and Division 22 cables are horizontally separated by approximately 15 feet on the vertical run along the shield wall between Elevations 440 feet 0 inch and 467 feet 0 inch, and azimuth angles R25 and R26. Also, between Elevations 421 feet 0 inch and 440 feet 0 inch, azimuth angles R24 and R25, all cables are separated by a vertical distance of approximately 5 feet at the closest

point with intervening combustibles in the form of cable trays.

AMENDMENT 25 DECEMBER 2012A5.8 -48 Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment of 20 horizontal feet with no intervening combustibles. This is not met because the separation between the redundant cables is less than that specified, and

intervening combustibles in the form of cable insulation in cable trays are present in the

area. Section C.5.B(2) paragraph (b) specifies installation of fire detectors and an

automatic suppression system in the area. Although detection is available in the

affected area, this is not met because an automatic fire suppression system is not

provided. Section C.5.B(2) paragraph (c) specifies separation of redundant cables by a

non-combustible radiant energy shields. Non-combustible shields are not provided.

Therefore, the separation between redundant cables deviates from the guidelines of

Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for DeviationWithin the pressurizer cubicle, all cables are routed in rigid or flexible conduit. There are no exposed combustible materials within the cubicle that represent a fire hazard.

Thus, a fire within the pressurizer cubicle is considered to be extremely unlikely and the

existing separation is considered to be adequate.

Immediately outside of the pressurizer cubicle, where the cables run vertically along the outside of the shield wall, both sets of cables are in conduit. The minimum horizontal separation is about 15 feet. The only combustible materials here are cables in cable

trays. In this area, the existing separation between redundant cables is considered to

be adequate to preclude a single fire from damaging both trains due to the nature of combustible materials present and the fact that the cables in question are routed in

conduit.Elsewhere outside of the pressurizer cubicle, Division 21 cables pass underneath Division 22 cables with a minimum vertical separation of 5 feet. This occurs near the

penetration area between R24 and R25. In this area, the Division 21 and Division 22

PORV control cables (2RY490 and 2RY491, respectively) are routed individually in

conduit from their respective penetrations to inside the pressurizer enclosure.

Therefore, in the penetration area, the existing separation between redundant cables is

considered to be adequate to preclude a single fire from damaging both trains due to

the nature of the combustible materials present and the fact that the PORV control

cables are routed in conduit.

Furthermore, even if both pressurizer PORVs were inoperable, the ability to safely shut down the plant would not be lost. Hot standby could be maintained utilizing the pressurizer safety valves for overpressure protection. Cooldown and depressurization

could be accomplished using the steam generators to remove decay heat, and if

required, utilizing the letdown system. This mode of operation will take the primary

system to a low enough temperature and pressure to initiate RHR system operation.

AMENDMENT 25 DECEMBER 2012A5.8 -49 In summary, because of the low combustible loading coupled with the large size of the area, and the routing of the affected PORV cables within conduit from the electrical penetrations to the valves, a level of fire protection equivalent to that specified in paragraphs (a), (b) or (c) of BTP CMEB 9.5-1 is provided. The existing separation

between the redundant safe shutdown cables for these components is judged to be

adequate to prevent a single fire from simultaneously damaging both pressurizer

PORVs.A5.8.23.2Description of Equipment/Cables InvolvedSteam Generator Wide Range Level Instrumentation Cables for all four channels of steam generator wide range level instrumentation are located in containment. Only one steam generator is required to achieve and maintain

hot standby. Each of the steam generators has one instrumentation cable which provides wide range level indication; steam generator (SG) 2A - instrumentation cable 2FW018, SG 2B - 2FW020, SG 2C - 2FW022, and SG 2D - 2FW024.

Description of DeviationAll four water level instrumentation cables (Division 21 - 2FW018 and 2FW024, Division 22 - 2FW020 and 2FW022) have a minimum separation of approximately 15 feet vertically and 60 feet horizontally in the area bounded by elevations 400 feet 0 inch and

440 feet 0 inch, azimuth angles R25 and R42, at a radius of about 67 feet from the

centerline of containment.

Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment of 20 horizontal feet with no intervening combustibles. This is not met

because intervening combustibles in the form of cable insulation in cable trays are

present in the area. Section C.5.B(2) paragraph (b) specifies installation of fire

detectors and an automatic suppression system in the area. Although detection is

available in the affected area, this is not met because an automatic fire suppression

system is not provided. Section C.5.B(2) paragraph (c) specifies separation of redundant cables by a non-combustible radiant energy shields. Non-combustible

shields are not provided. Therefore, the separation between redundant cables deviates

from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation A single fire large enough to damage all four cables would have to span more than 60 feet in the horizontal direction between azimuth angles R25 and R42. Although

intervening combustibles in the form of cable insulation in cable trays are present in the

affected area, the cables utilized at Byron are constructed per IEEE 383. These cables

will not propagate a fire without the presence of an external flame. No other

combustible materials (i.e., an external flame source for the cables) are present in this area in significant quantities. The fire loading in this area is low. The containment is a AMENDMENT 25 DECEMBER 2012A5.8 -50 large open area. The heat and products of combustion of any fire which may be postulated to start will be dissipated in the upper levels of the containment building, and

will not be concentrated in the immediate area of the fire near potential targets (i.e.,

other cable trays). In addition, fire detection is provided in this area. For these reasons, the existing separation between redundant cables is considered to be adequate to

preclude a single fire from damaging all four of these safe shutdown instruments.A5.8.23.3Description of Equipment/Cables Involved Source Range Neutron Monitoring InstrumentsTwo channels of source range neutron monitoring instruments are provided. Two channels of post-accident nuclear instrumentation are also provided. A single channel

of nuclear indication (of either system) is required to achieve and maintain hot standby.

Cables for the two available channels of source range neutron monitoring and post-accident nuclear instrumentation are 2NR251 and 2NR252 (Division 21) and 2NR267 and 2NR 268 (Division 22). All of these cables are routed in containment.The detectors for the Division 21 and Division 22 source range neutron monitoring and post-accident nuclear instrument system are located 180 degrees apart to the north and south of the reactor vessel. The Division 21 detector is located on the north side of the

reactor vessel. Cable 2NR252 is routed around the outside of the primary shield wall to

a box on the northeast side of the primary shield wall. Cable 2NR251 is routed from this

box east to and through the missile barrier near R22, and to an electrical penetration near azimuth R22. The Division 22 detector is located on the south side of the reactor vessel. Cable 2NR268 is routed in a southwest direction from the detector to a box in the southwest quadrant of the containment building. Cable 2NR267 is routed from the box directly south to the missile barrier. After passing through the missile barrier, the

cable follows along the exterior containment wall to an electrical penetration between

azimuth R24 and R25.

Description of DeviationOutside of the missile barrier, the separation between cables 2NR251 (Division 21) and 2NR267 (Division 22) is approximately 32 feet in the area bounded by Elevations 412feet and 420 feet, azimuth angles R22 and R24. Intervening combustibles are also present in the form of cable trays.Inside of the missile barrier, the instrument channels are separated by approximately 50feet in the area bounded by Elevations 380 feet and 421 feet, azimuth angles R27 and R22. Intervening combustibles are present in the form of cable trays. In addition, area-wide fire detection or suppression is not provided in these zones.

Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment of 20 horizontal feet with no intervening combustibles. This is not met

because intervening combustibles in the form of cable insulation in cable trays are AMENDMENT 25 DECEMBER 2012A5.8 -51 present in the area. Section C.5.B(2) paragraph (b) specifies installation of fire detectors and an automatic suppression system in the area. Although detection is

available in the affected area, this is not met because an automatic fire suppression

system is not provided. Section C.5.B(2) paragraph (c) specifies separation of redundant cables by a non-combustible radiant energy shields. Non-combustible

shields are not provided. Therefore, the separation between redundant cables deviates

from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for DeviationThe cables are routed in conduit inside the missile barrier. The minimum separation between the two instrument cables is approximately 50 feet. The reactor coolant pump is not considered to represent a major fire hazard since it is provided with an oil collection system. Furthermore, heat detectors are provided over the pump. Only onecable trayis located in the area. It is located near radii R22 and R25, where the separation between redundant cablesis 50 feet. The tray is 12 inches wide and is filled to less than one quarter of its total cross sectional area.In addition, the cables areprimarily located on the opposite sides of the primary shield wall, and are not subject to the same fire hazards. Outside of the missile barrier, the minimum separation between the two instrument cables is approximately 32 feet. Only two 12 inch wide cable trays are located in the area. They are located near radii R22 and R24. One tray is filled to less than half its total cross sectional area. The other tray is filled to less than one quarter of its cross sectional area. In view of the fact that the neutron monitoring cables are in conduit for the majority of their routings, and in consideration of the nature and

orientation of intervening combustibles, the existing separation is considered to be

adequate to preclude a single fire from disabling all of the instruments.A5.8.23.4Description of Equipment/Cables Involved Pressurizer Pressure Instrumentation Four channels of pressurizer pressure instrumentation are provided. Only one of the four available pressurizer pressure instrumentation channels is required to achieve and

maintain hot standby. Inside containment, a single cable is associated with each of the

four channels. The four instrumentation cables are 2RY199 and 2RY207 in Division 21, and 2RY203 and 2RY211 in Division 22.

Description of Deviation All four pressurizer pressure instrumentation cables have a minimum separation of approximately 15 feet vertically and 60 feet horizontally in the area bounded by Elevation 400 feet and 440 feet, azimuth angles R25 and R42, at a radius at about 67

feet from the centerline of containment.

Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment of 20 horizontal feet with no intervening combustibles. This is not met AMENDMENT 25 DECEMBER 2012A5.8 -52because intervening combustibles in the form of cable insulation in cable trays are present in the area. Section C.5.B(2) paragraph (b) specifies installation of fire

detectors and an automatic suppression system in the area. Although detection is

available in the affected area, this is not met because an automatic fire suppression

system is not provided. Section C.5.B(2) paragraph (c) specifies separation of redundant cables by a non-combustible radiant energy shields. Non-combustible

shields are not provided. Therefore, the separation between redundant cables deviates

from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation A single fire large enough to damage both Division 21 and Division 22 cables would have to span more than 60 feet in the horizontal direction between azimuth angles R25

and R42. Although intervening combustibles in the form of cable insulation in cable

trays are present in the affected area, the cables utilized at Byron are constructed per

IEEE 383. These cables will not propagate a fire without the presence of an external

flame. No other combustible materials (i.e., an external flame source for the cables) are present in this area in significant quantities. The fire loading in this area is low. The

containment is a large open area. The heat and products of combustion of any fire

which may be postulated to start will be dissipated in the upper levels of the

containment building, and will not be concentrated in the immediate area of the fire near

potential targets (i.e., other cable trays). In addition, fire detection is provided in this

area. For these reasons, the existing separation between redundant cables is considered to be adequate to preclude a single fire from damaging all four of these safe

shutdown instruments.A5.8.23.5Description of Equipment/Cables Involved Pressurizer Level Instrumentation Three channels of pressurizer level instrumentation are provided. One of the three pressurizer level instrumentation channels is required to achieve and maintain hot

standby. Inside containment, a single cable is associated with each of the three

channels. The three instrumentation cables are 2RY20l and 2RY209 in Division 21, and

2RY205 in Division 22.

Description of Deviation All three pressurizer level instrumentation cables have a minimum separation of approximately 15 feet vertically and 22 feet horizontally in the area bounded by Elevations 408 feet and 423 feet 6 inches, azimuth angles R23 and R42, at a radius of

about 67 feet from the centerline of containment.

Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment of 20 horizontal feet with no intervening combustibles. This is not met because intervening combustibles in the form of cable insulation in cable trays are AMENDMENT 25 DECEMBER 2012A5.8 -53 present in the area. Section C.5.B(2) paragraph (b) specifies installation of fire detectors and an automatic suppression system in the area. Although detection is available in the affected area, this is not met because an automatic fire suppression

system is not provided. Section C.5.B(2) paragraph (c) specifies separation of redundant cables by a non-combustible radiant energy shields. Non-combustible

shields are not provided. Therefore, the separation between redundant cables deviates

from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation The pressurizer level instrumentation cables are routed in conduit. Although intervening combustibles in the form of cable insulation in cable trays are present in the affected

area, the cables utilized at Byron are constructed per IEEE 383. These cables will not

propagate a fire without the presence of an external flame. No other combustible

materials (i.e., an external flame source for the cables) are present in this area in

significant quantities. The fire loading in this area is low. The containment is a large

open area. The heat and products of combustion of any fire which may be postulated to

start will be dissipated in the upper levels of the containment building, and will not be

concentrated in the immediate area of the fire near potential targets (i.e., other cable

trays). In addition, fire detection is provided in this area. For these reasons, the

existing separation between redundant cables is considered to be adequate to preclude

a single fire from damaging all three of these safe shutdown instruments.A5.8.23.6Description of Equipment/Cables InvolvedReactor Coolant Hot Leg Temperature Or Core Exit Temperature Indication for reactor coolant hot leg temperature for one RCS loop or indication of core exit temperature from one division of the incore thermocouples is required to achieve

and maintain hot standby.

Each reactor coolant system hot leg has a dual element RTD. The loop "A" and "D" RTDs are located between the primary and secondary shield walls on the eastside of

the reactor cavity. The loop "B" and "C" RTDs are located between the primary and

secondary shield walls on the west side of the reactor cavity.One of the two elements for each RTD provides a signal to indication in the main control room and at the remote shutdown panel. The four cables associated with the

MCR/RSP indication are 2RC351, 2RC356, 2RC361 and 2RC366. All four of these

cables are Division 21 cables. These four cables are routed in a generally southerly

direction from their respective RTDs to outside of the secondary shield wall, and from

there they follow along the exterior containment wall over to their Division 21 electrical

penetration located near R25.

The remaining element for each RTD provides a signal to electrically independent indication located on the Fire Hazards Panel. The four cables associated with the FHP AMENDMENT 25 DECEMBER 2012A5.8 -54 indication are 2RC743, 2RC745, 2RC747 and 2RC749. All four of these cables are Division 22 cables. These four cables are routed in a generally northerly direction from

their respective RTDs to outside of the secondary shield wall, and from there they follow

along the exterior containment wall over to their Division 22 electrical penetration

located near R22.

The Division 21 incore thermocouple cables are 2IT308 through 2IT340, 2IT343, 2IT344, 2IT425 and the 33 incore thermocouple circuits combined into five

multiconductor mineral insulated cables 2IT428, 2IT429, 2IT432, 2IT433, 2IT436, 2IT437, 2IT440, 2IT441, 2IT444, and 2IT445 (two cable numbers assigned per

multiconductor cable) from junction box 2JB697R to the reactor vessel head. The

Division 22 incore thermocouple cables are 2IT351 through 2IT382, 2IT347, 2IT348, 2IT427, and the 32 incore thermocouple circuits combined into five multiconductor

mineral insulated cables 2IT430, 2IT431, 2IT434, 2IT435, 2IT438, 2IT439, 2IT442, 2IT443, 2IT446, and 2IT447 (two cable numbers assigned per multiconductor cable)

from junction box 2JB698R to the reactor vessel head.

The Division 21 incore thermocouple cables are routed in conduit from a containment penetration at Elevation 417 feet 6 inches between R24 and R25 to junction box

2JB697R outside the missile barrier at Elevation 435 feet 9 inches between R22 and

R42. The Division 22 incore thermocouple cables are routed in conduit from a

containment penetration at Elevation 439 feet 3 inches between R25 and R26 to

junction box 2JB698R outside the missile barrier at Elevation 456 feet 0 inches between R22 and R42. The mineral insulated cables for both divisions are routed in conduit from

junction boxes 2JB697R and 2JB698R, between steam generators 2A and 2D, to the

primary shield wall. These same cables are then routed in cable trays (Elevation 430 feet) from the primary shield wall to a connector plate above the reactor vessel, and

from there routed vertically down to the reactor vessel head.

Description of Deviation Section C.5.B(2) paragraph (a) specifies separation between redundant cables and equipment by a fire barrier having a 3-hour rating. This is not met because the

redundant cables are located within the same fire zone, and no fire barrier is present.

Section C.5.B(2) paragraph (b) specifies separation between redundant cables and equipment by 20 feet of horizontal distance with no intervening combustibles and

installation of fire detectors and an automatic suppression system in the area. This is

not met because the separation between the redundant cables is less than that specified, and intervening combustibles in the form of cable insulation in cable trays are

present in the area and although detection is available in the affected area, an

automatic fire suppression system is not provided. The Divisions 21 and 22 reactor

coolant hot leg temperature and incore thermocouple cables are routed in the closest

proximity to each other outside of the secondary shield wall. The minimum horizontal

separation between a single division of either the hot leg cables or the incore

thermocouple cables is approximately 52 feet in the sector bounded by R22 and R25.

Section C.5.B(2) paragraph (c) specifies enclosure of redundant cables and equipment AMENDMENT 25 DECEMBER 2012A5.8 -55of one train by a 1-hour rated fire barrier and installation of fire detectors and an automatic suppression system in the area. As previously stated, no fire barriers are

present in the zone, and an automatic suppression system is not installed. Therefore, the separation between redundant cables deviates from the guidelines of Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation Between the primary and secondary shield walls, the RCS loop "B" and "C" RTDs and their cables are separated from the RCS loop "A" and "D" RTDs and their cables and the incore thermocouple cables by the primary shield wall and/or the refueling pool

structure. The primary shield wall is a concrete structure approximately 34 feet in

diameter that encloses the reactor cavity and reactor vessel. These structures serve the purpose of a noncombustible radiant energy shield that separates the loop "B" and "C" RTDs and cables from the redundant loop "A" and "D" RTDs and cables and incore

thermocouple cables. Away from the penetration, the divisional routings of the RTD cables provide good spatial separation, ensuring that indication for at least one loop of

reactor coolant hot leg temperature will be available. As previously stated, the minimum

separation of cables occurs between the containment penetrations and secondary shield wall. The minimum horizontal separation between a single division of either the

hot leg cables or the incore thermocouple cables is approximately 52 feet at the

containment penetrations in the sector bounded by R22 and R25. Therefore, a fire would have to span a horizontal distance of approximately 52 feet to damage all of the

reactor coolant hot leg and incore thermocouple cables. Although intervening

combustibles in the form of cable insulation in cable trays are present in the affected

area, the cables utilized at Byron are constructed per IEEE 383. These cables will not

propagate a fire without the presence of an external flame. No other combustible

materials (i.e., an external flame source for the cables) are present in this area in significant quantities. The fire loading in this area is low. The containment is a large

open area. The heat and products of combustion of any fire which may be postulated to

start will be dissipated in the upper levels of the containment building, and will not be

concentrated in the immediate area of the fire near potential targets (i.e., other cable

trays). In addition, fire detection is provided in this area. For these reasons, the

existing separation between redundant cables is considered to be adequate to preclude a single fire from damaging all of these safe shutdown instruments.A5.8.23.7Description of Equipment/Cables Involved Reactor Coolant Cold Leg Temperature Indication for reactor coolant cold leg temperature for one RCS loop is credited to achieve and maintain hot standby.

Each reactor coolant system cold leg has a dual element RTD. The loop "A" and "D" RTDs are located between the primary and secondary shield walls on the eastside of AMENDMENT 25 DECEMBER 2012A5.8 -56 the reactor cavity. The loop "B" and "C" RTDs are located between the primary and secondary shield walls on the west side of the reactor cavity.

One of the two elements for each RTD provides a signal to indication in the main control room (MCR) and at the remote shutdown panel (RSP). The four cables associated with the MCR/RSP indication are 2RC373, 2RC392, 2RC397 and 2RC402. All four of these

cables are Division 22 cables. Some of these four cables are routed in a generally northerly direction from their respective RTDs to outside of the secondary shield wall, and from there they follow along the exterior containment wall over to their Division 22

electrical penetration located near R42. The other cables remain inside the secondary

shield wall until they pass through it in the immediate vicinity of the electrical penetration

located by R42.

The remaining element for each RTD provides a signal to electrically independent indication located on the Fire Hazards Panel (FHP). The four cables associated with the FHP indication are 2RC751, 2RC753, 2RC755 and 2RC757. All four of these

cables are also Division 22 cables. Starting at their respective RTDs, these four cables are routed in a generally southerly direction to outside of the secondary shield wall, and

from there they follow along the exterior containment wall over to their Division 22

electrical penetration located near R24.

Description of Deviation The four FHP cold leg RTD cables have a minimum separation of approximately 1 foot vertically from the four MCR/RSP cold leg RTD cables near R42.

Section C.5.B(2) paragraph (a) is not met because intervening combustibles in the form

of cable insulation in cable trays are present in the area. Section C.5.B(2) paragraph (b) is not met because an automatic fire suppression system is not provided. Section

C.5.B(2) paragraph (c) is not met because non-combustible shields are not provided.

Therefore, the separation between redundant cables deviates from the guidelines of

Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation Although intervening combustibles in the form of cable insulation in cable trays are present in the affected area, the cables utilized at Byron are constructed per IEEE 383.

These cables will not propagate a fire without the presence of an external flame. No

other combustible materials (i.e., an external flame source for the cables) are present in this area in significant quantities. The fire loading in this area is low. The containment

is a large open area. The heat and products of combustion of any fire which may be

postulated to start will be dissipated in the upper levels of the containment building, and will not be concentrated in the immediate area of the fire near potential targets (i.e.,

other cable trays). In addition, fire detection is provided in this area. For these reasons, the existing separation between redundant cables is considered to be adequate to

preclude a single fire from damaging all of these safe shutdown instruments.

AMENDMENT 25 DECEMBER 2012A5.8 -57 Additionally, the loss of all cold leg RTDs is acceptable for the following reasons. The cold leg RTDs would normally be used in conjunction with the hot leg RTDs to verify adequate core cooling, i.e., that natural circulation is present. This condition can also

be verified by trending the temperatures indicated by the core exit thermocouples. As

noted in Section A5.8.6.6, the thermocouple cables are routed in conduit in the area of concern. Furthermore, cold leg temperature can be inferred from steam generator

pressure. As indicated in Section 2.4, steam generator pressure instrumentation and

cabling are independent of this zone. Plant emergency procedures are written to refer

to these alternate methods of verifying primary system conditions. In fact, the core exit

thermocouples are the preferred method. The Byron and Braidwood plant procedures are written using guidance from the Westinghouse Owners Group. Therefore, this deviation from BTP CMEB 9.5-1 requirements is considered to be acceptable.A5.8.23.8Description of Equipment/Cables Involved Reactor Containment Fan Cooler (RCFC) FansTwo of the four RCFC fans are required to operate in the high-speed mode to achieve and maintain hot standby. The four RCFCs themselves are located outside of the

secondary shield wall at widely spaced intervals around the containment. The high

speed power cables for the RCFC fans routed inside containment are 2VP004, 2VP026, 2VP048, and 2VP070.

Description of DeviationAll four RCFC power cables (Division 21 - 2VP004 and 2VP048, Division 22 - 2VP026 and 2VP070) have a minimum separation of approximately 36 horizontal feet. This minimum separation occurs in the area bounded by elevations 393 feet 5 inches and

439 feet 3 inches, azimuth angles R26 and R42, at a radius of about 60 feet from the

centerline of containment. There are intervening combustibles in this area in the form of

cable insulation.Section C.5.B(2) paragraph (a) is not met because intervening combustibles in the form of cable insulation in cable trays are present in the area. Section C.5.B(2) paragraph (b) is not met because an automatic fire suppression system is not provided. Section

C.5.B(2) paragraph (c) is not met because non-combustible shields are not provided.

Therefore, the separation between redundant cables deviates from the guidelines of

Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.

Justification for Deviation Although intervening combustibles in the form of cable insulation in cable trays are present in the affected area, the cables utilized at Byron are constructed per IEEE 383.

These cables will not propagate a fire without the presence of an external flame. No other combustible materials (i.e., an external flame source for the cables) are present in

this area in significant quantities. The fire loading in this area is low. The containment AMENDMENT 25 DECEMBER 2012A5.8 -58 is a large open area. The heat and products of combustion of any fire which may be postulated to start will be dissipated in the upper levels of the containment building, and

will not be concentrated in the immediate area of the fire near potential targets (i.e.,

other cable trays). In addition, fire detection is provided in this area. For these reasons, the existing separation between redundant cables is considered to be adequate to

preclude a single fire from damaging all of these safe shutdown cables.

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