ML20010G192

Forwards Addl Info Re Fire Protection in Response to 810603 Request.Info Summarizing Util Analysis of Safe Shutdown of Plant Following Fire Will Be Provided by 811015.Encl Info Will Be Incorporated Into Next FSAR Amend

ML20010G192
Person / Time
Site:	Byron, Braidwood
Issue date:	08/31/1981
From:	Tramm T COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8109150420
Download: ML20010G192 (25)

Text

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/

h Commonwealth Edison

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) One First N:tional Plaza, Chicigo, llhnois

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Address Reply to: Post Office Box 767 N

Chicago. lilinois 60690 August 31, 1981 Mr. Harold R.

Denton, Director Office of Nuclear Reactor Regulation U.S.

Nuclear Regulatory Commission Washington, DC 20555

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Subject:

Byron Station Units 1 and 2

e Braidwood Station Units 1 and 2 g(( /f f

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'800 /j/[A Fire ProtecLlon NRC Dockets 50-454, 50-455, 50-456 S '.

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and 50-457 Reference (a):

June 3, 1981, letter from k ' 'r

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R. L.

Tedesco to J.

S.

Abel.

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Dear Mr. Denton:

This letter provides additional information requested by the NRC in reference (a) regarding fire protection at Byron and Braidwood.

Attachment A to this letter contains our assessment of the conformance of the Byron and Braidwood plants to the provisions of Appendix R to 10 CFR 50.

Additional information summarizing our analysis of the safe shutdown of a plant following a fire will be provided by October 15, 1981.

This information will be incorporated inte the Byron /

Braidwood FSAR in the next amendment.

Fifteen (15) copies are provided now for your early review and approval.

Fif ty-nine (59) copies of this letter are provided.

l Please address further questions regaruing this matter to l

this office.

1 Very truly yours, gb_

T.

R.

Tramm Nuclear Licensing Administrator hg TRT/lm 2471N 9109150420 810831 PDR ADOCK 05000454 F

PDR j

ATTACHMENT A Byron /Braidwood Appendix R Assessment l

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-. f APPENDIX R--FIRE PROTECTION PPOGRAM FOR WUCLEAR POWER FACILITIES OPERATING PRIOR TO JAN.1,1979, 10 CFR 50 APPENDIX R BYRON /BRAIDWOOD CONFORMANCE REMARF S l

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Introduction and Scope This Appendix ipplies to licensed nuclear power electric gererating stations that were operating Although Appendix R to 10 CFR 50 applies prior to January 1, 1979, except to the extent strictly to plants licensed to operate set forth in paragrtph 50.48(b) of this part.

prior to January 1, 1975, the NRC has With respect to certain generic issues for made conformance to 10 CFR 50 Appendix R i

such facilities it sets forth fire protection a licensing requirenent for Byron /Breid-features required to satisfy Criterion 3 of AppenJix A to this part'.

. wood. See NRC question 600.01 (June 2 19813-Criterion 3 of Appendix A to this part specifies l

that

• Structures, systems, and components important to r.atety shall be designed and located to minimize, coasistent with other safety require-ments, the probability and effect of fires and explosions.*

When considering the effects of fire, thoue systers asacciated with achieving and maintain-ing safe shutdown condations assume major ieportance to safety because damage to them can lead to core damsge resulting from loss of i

coolant through bolloff.

The phrases "irportant to safety," or " safety-e related,' will be used throughout this Appendic R as applying to all safety functions.

The design basis of the Eyron/Braidwood The phr3ae " safe shutdown" will be used thrcughout plant has from the beginr.ing been that thic Aprendix R as applying to both hot and cold Hot Standby (as defined in the Technical Specifications) is a "stfe shutdown"

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shutiew.i functions.

condition, since tho plant can be rain-tained in Hot Standby for an extended Because fire may affect safe shutdown systems period of time from outside the control and because the loss of function of systems room. However, an evaluation is pre-l used to mitigate the consequences of design sently being performed of the ability j

basis accidents under postfire conditions does to reach cold shutdown from the remote not per se impact public safety, the need to shutdown panels. Modifications to limit fire damage *o systems required to achieve and naintain safe shutdown conditions is greater enable this will be made if necessary.

than the need to litit fire damage ts.. hose systems required to mitigate the consequences of design basis accidents. Three levels of fira damage limits are established according to

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a; 10 CFR 50 APPENDIX R BYRON /BRAIDWOOD CCNFORMANCE REMARRS s

Safety Function Fire Damage Limits W

H3t Shutdown...One train of equipment necessary to achieve hot shutdown from either the control roca or emergency centrol station (s) must be naintained. free of the damage by a single fire, inciviing an exposure fire.'

Caid thutdown...Both trains or equipment danaget by a single fire, including an ex-

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nscessary to achieve cold shutdown may be posure fire, but damage must be limited so y

that at least one train can be repaired or made operable withir. 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> using onsite capability.

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i; Design Dasis Accidents...Both trains of equip-ment necessary for mitigation of consequences

-following design basis accidents may be E

danaged by a single exposure fire.

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t Tha rost stringent fire damage limit shall apply for those systems that fall into more than one category. Redandant systems used to nitigate the consequences of other design basis f

accidents but not necessary for safe shutdown ray be lost to a single exposure fire.

How.

ever, protection shall be provided so that a fire within only one such system will not dLmaga the redundant system.

General Requirements A.

Fire Protection Program The applicants fire protection program complies with these requirements.

A fire protection program shall be estab-

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lished at each ruclear power plant. The program shall establish the fire protection policy for the protection of structures, systems, and co?ponents important to j

saf ety at each plant and the procedures, equirment, and personnel required to imple-Cent the program at the plant site.

The fire protection program shall be under the direction of an individual who has been dalegated authority connensurate with the

.rarponsibilities of the position and who 4j

• his available staf f personnel knowledgeable 4

in both fire protection and nuclear safety.

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10 CFR 50 APPENDIX R BYRON /BRAIDWOOD CCNFORMANCE REMARKS 3.

Fire detection systems, portable extinguishers, and standpipe and hose stations shall be installed.

4.

Fire barriers or automatic suppression systems or both shall be installed as necessary to protect redundant systems or components necessary for safe shutdown.

5.

A site fire brigade shall be established, trained, and equipped and shall be on site at all times.

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.

7.

Surveillance procedures shall be established to ensure that fire barriers are in place and that fire suppression systems and components are operable.

G.

Alternative or Dedicated Shutdown Capability Not presently demonstrated.

Will be addressed by Safe Shutdown

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In areas where the fire protection features cannot ensure safe shutdown capability in the event of a fire in that area, alter-native or dedicated safe shutdown capability tha11 be provided.

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Specific Requirements A.

Water supplies for Fire Suppression Systems The P/B design complies with this require-ment as described in Appendix 5.4, Sub-Two separate water supplies shall be section A5.4.1 of the FPR.

provided to furnish necessary water volume end pressure to the fire main loop.

Each supply shall consist of a storage tank, pump, piping, and appropriate iso-lation and control valves. Two separate redundant sactions in one or more intake structures from a large body of water (river, lake, etc.) will satisfy the requirement for two separated water storage tnaks.

These supplies,shall be separated so that o failure of one supply will not result in c failure of the other supply.

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a 10 CFR 50 APPENDIX R BYRON /BRAIDWOOD CCNFORMANCE 7tMARKS The fire protection progran shall extend the concept of defense-in-depth to fire protection in fire areas important to ratety, with the following ebjectives:

o to prevent fires from starting o to detect rapidly, control, and ex-tinguish promptly those fires that do

ncurs o to p:r.ide protection for structures, sfstems, and components important to safety so that a fire that is not prorptly extinguished by the fire suppression activities will not prevent the safe shutdown of the plant.

E.

Fire Hazards Analysis A Fire Hazards Analysis was performed for the The applicant is currently performing A fire hazard analysis shall be performed Byron /Braidwood stations and was included a Safe Shutdown Analysis which will by qualified fire protection and reactor with the Fire Protection Report, filed with demonstrate the ability to safely shut-rysters engineers to (1) consider poten.

the NRC on October 31, 1977 This report down the plant following a fire in a9/

tial in situ and transient fire hazards:

documented conformance with BTP APCSB 9.5-1, fire zone. The results of this analysis Appendix A, but did not specifically address-- --

will be included in an.smendment to the (2) determine the consequences of fire in any location in the plant on the ability to safe shutdown capability, the subject of Fire Protaction Report, scheduled for safety shut down the reactor or on the Appendix R.

submittal to the NRC in October 15, 1981

&bility to minimize and control the release of radioactivity to the environment; and (3) specify reasures for fire prevention, fire dete: tion, fire suppression, and fire containment and alternative shutdown capability as required for each fire area containing structures, systems, and com-ponents important to safety in accordance with NPC guidelines and regulations.

C.

Fire Provention Features Fire Protection features shall reet the following general requirements for all fire, The fire prevention program and plant features areas that contain or present a fire hazard

. meet these requirements.

im-to structures, systems, or compc..--

.m portant to safety.

1.

In situ fire hazards shall be identified I and suitable protectio 1 provided, f-

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2.

transient fire hazards c. sociated with normal operation, naintenance, repair, or modification activities shall be identified and eliminated where possible.

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Those transient fire hazards tha: can r.at be eliminated shall be controlled and suitstle protectior troviicJ.

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e 10 CFR 50 ArrENDIX R BYRON /BRAIDWOOD CONFOR?tANCE REMARK S Each supply of the fire water distribution systen shall be capable of providing for a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> the maximum expected water demands as determio rd by the fire hazards analysis for safe.y-related areas or other areas that present a fire exposure hazard to safety-related areas.

When storage tanks are used for combined cervice-water / fire-water uses the minimum volure for fire oses shall be ensured by means of dedicated tanks or by some physical reans such as vertical standpipe for ot..er water service. Administrative controls, including loens for tank outlet valves, are unacceptable as the only means to ensure minimum water volume.

Otter water systems used as one of the two fire water supplies shall be permanently connected to the fire main system and shall te capable of automatic alignment to the fire rain system.

Pumps, controls, and power supplies in these systems shall satisfy tre requirements for 'he main fire p ur p s. The use of other water systems for fire protection shall not be incompatible with their functions required for safe p l a:.t shutdown. Failure of the other system shall not degrade the fire main system.

B.

Sectional Isolation Valves The B/B design complies with this require-ment as described in Appendix 5.4, sub-Sectional isolation valves such as post section 5.4.1 of the FpR.

Indicator valves or key operated valves shall be installed in the fire main loop to permit isolation of portions of the main fire nain loop for maintenance or repair without interrupting the entire water zu; ply.

C.

flydrant Isolation Valves Valves shall be installed to permit isolation The B/B ?r..'qn complies with this require-of outside hydrants from the fire T n for ment as described in Appendix 5.4, sub.

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maintenance or repair without interrupting section 5.4.1 of the FPR.

tha water supply to automatic or manual fire suppression systems in any area containing er presenting a fire hazard to safety-r21sted or safe shutdown equipment.

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10 CTR 50 APPENDIX R BYRON /BRAIDWOOD CONFORMANCE RtMARE S C.

M:nual Fire Suppression Standpipe and hose systems shall be installed B/B complies. See FPR Appendix 5.4, to that at least one 9ffective host steam Subsection A5.4.7.

will be able to reach any location that contains or presents an exposure fire hazard to structures, systems, or components important to safety.

Accass to permit ef fective functioning of Compliance with this requirement has not the fire brigade shall be providJd to all been demonstrated.

Access provisions specifically for creas that contain or present an exposure firefighting have not been discussed, fire hazard to structures, systems, or The fire protection report. discusses co.ip onents impor tant to safety.

access only in general terms. See FPR Section 3.4, paragraph D.4 (f).

Standpipe and hose stations, shall be Inside 11:R contain?cnts and BWR containments 9/B complies. See FPR Section 2.3.1 and that are not incrted. Standpipe and hose Appendix 5.4, Subsection A5.4.7.

stations inside containment may be connected to a high quality watet supply of sufficient quantity and pressure other than the fire main loop if plant-specific features prevent extending the. fire main supply inside L ori t a i r. men t. For B::R dyrwells, standpipe and hose stations shall be placed outside the dry well with adequate lengths of hose to reach any location inside the dry well with an effective hose stream.

E.

Hydrostatic Hose Tests Fire hose shall be hydrostatically tested Compliance with this requirement has not ct a pressure of 300 psi or 50 psi above been demonstrated.

Testing and maintenance of fire pro-nixirun fire main operating pr*ssure' outside tection equipment is discussed in Fen whichever is greater. Hose stered in Section 3.2, paragraph B.5 (a)

• hose houses shall be tested ano2a11y.

Interior standpipe hose shall ut tested svery three years.

F.

Autonatic Fire Detection Automatic fire detection systems shall be B/B cotap les See FPR Appendix $.4.,

g installed in all areas of the plant tha t contain or present an exposure fire hazard to s4fe shutdown or safety-telated systems (r components. These fire detection systems chall be capable of operating with or cithout of f site power.

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10 CFR 50 APTENDIX R BYRON /SRAIDWOOD CONFORMANCE PIMARKS 0.

Fire Protection of Safe Shutdown Capability 1.

Fire protection features shall be Cowpliasco has not been demonstrated.

components important to safe shutdown.

Will be addressed by Safe Shutdown providei for structures, systems, and Analysis There features shall be capable of limiting fire damage su that P

i One train of systems necessary to a.

achieve and maintain hot shutdown conditions from either the control roon j

or emergency control station (s) is free of fire damage; and b.

Systems necessary to achieve and maintain cold shutdown from either the control room or e.mergeney control station (s) can be repaired witnin 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

2.

Except as provided for paragraph C.3 Compliance has not been demonstrated.

of this section, where cables or equip-Will be addressed by Safe Shu'tdown ment, incluJing associat-d non-safety Analysis.

circuits that could prevent operation or cause maloperation due to hot shorts, open circuite, or shorts to ground, or redundant trains of systems necessary to achieve and maintain hot shutdown con-ditions are located within the same fire area uutside of primary containment, one of the following neans of ensuring that one of the redundant trains is free of fire damage shall be provided:

l' Separation of cables and equipment and.

a.

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 l

to provide fire resistance equivalent to that required of the barriers b.

Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizortal dis-tance of more than 20 feet wi6h no l

intervening combustible or fire hazards.

in addition, fire detectors and an i

automatic fire suppression system shall h

be installed in the fire areas or l

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10 CFR 50 APPENDIX R BYROW/BRAIDWOOD CCWFORMANCE REMARKS s

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Enclosure of cable and equipment and I

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 rystem shall be installed in the fire area Inside noninerted containments one of l

the fire protection mears specified '

above or one of the following fire protection means chall be provided d.

separation of cables and equipment l

and associated non-safety circuits of redanjant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards:

o.

Installation of fire detectors and an automatic fire suppression system in the fire arcas or j

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 capa.

Compliance has not been demons,trated.

Will be addressed by Safe Shutocwn l

bility and its associated circuits, Analysis independent of cables, systems or components in the area, room or zone under consideration, shall be provided3 c.

Where the protection of systems whose function is required for hot shutdown l

does not satisfy the requirement of paragraph G.2 of this sections or b.

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

In addition, fire detection and a fixed fire suppression systen shall be installed in tre area, room, or some under consideration.

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10 CFR 50 APPENDIX R BTCN/BRAIDWOOD CC#t?CRMNCE DEMARKS D.

Fire Brigade A site brigade trained and equipped for The fire brigade will reet the requirements fire fighting shall be estebitshed to stated herein, except that exception is taken ensure adequate manual fire fighting capa-to the performance standards required by the i

bility for all areas of the plant containing annual physical examination. The wcrding j

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• +ructures, syster,s, or components important

• dbility to perform strenuous fire fighting to safety. The fire brigade shall be at activities is lacking in specif.c detail and least five membprs on each shift. The is open to wide interpretation. The annual j

brigade leader and at least two brigade physical will demonstrate that fire brigade i

members shall have suf ficient training in members are capable of performing unrestricted or kr.ewledge of plant safety-related systems physical activity.

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to ur.derstand the effects of fire and fire surpressants on ssic shutdown capaLility.

7he qua11fication of fire brigade members l

shall include an annual physical examination to determine their ability to perform j

i strenuous fire fighting activities. The I

shif t supervisor shall not be a member.of

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2 the fire brigade. The brigade leader a

shall be competent to assess the potertial safety consequences of a fire and advise control roon personnel. Such ccmpetence by the brigade leader nay be evidenced by possession of an operator's license ot

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equivalent knowledge of plant safety-related systems.

The minimum equipment provided for the brigade shall consist of personal protective equip-ment such as turnout coats, boots, gloves,

.a hard hats, emergency communications equip-i nent, portable lights, portable ventilation 4'

equip.ent, and portable extinguishers.

Self-contained breathing apparatus using full-face positive-pressure masks approved 4

by ::105H U;ational Institute for Occupational Safety and Health-approval formerly given by the U. S. Bureau of Mines) shall be

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provided for fire brigade, damage control,

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and control room personnel. At least 10 1

1 masks shall be available for fire brigade

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personnel. Control room personnel may be

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furnished breathing air by a manifold system piped from a storage reservoir if practical.

S4rvice or rated operating life shall be

- a minimum of on-half hour for the self-contained units.

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y 10 CFR 50 APPENDIX R BYRON /BRAIDWOOD CONFORMANCE REMARKS At least two extra air bottles shall be Exception is also taken to the requirement located onsite for each self-contained for "at least two extra air bottles" for breathing unit.

In addition, an onsite each of ten masks. Since the station fire 6-hour supply of reserve air shall be brigade is only needed for a maximum of provided and arranged to permit quick and 20 minutes until the Byron Fire Department es.mplete replenishment of exhausted supply arrives, the need for extra air bottles does r

air bottles as they are returned. If not exist. At least 20 extra air bottles, co: pressors are used as a source of breathing not exclusively reserved for fire fighting, sir, or.1y units approved for breathing air will be available on site.

shall be used cenpressors shall be operable assuming a loss of o.fsite power. Special care must be taken to locate the compressor in areas free of dust and contalminants.

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Fire Drigade Training The fire brigade train (ng program meets the T!.e fire brigade training program shall requirements presented herein, with one ensure that the capability to fight poten-exception noted below.

taal fires is established and maintained.

The program shall.-nsist of an initial classroom instruction program followed by periodic classroom instruction, fire fighting practice, and fire drills.

1.

Instruction a.

The initial classroom instruction shall includes (1) Indoctrination of the plant fire fire fighting plan with specific identification of each indivi-duit's responsibilities.

2 (2) Identification of the type and location of fire hazards and associated types of fires that could occur in the plar.t.

(3) The toxic and corrosive character-istics of expected products of combustion.

(4) Identification of the location of fire fighting equipment for each fire area and familiarization wf ;h the layout of the plant, ii<luding access and egress routes to each area.

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.'* Crn 50 APFENDIX R BYRON /BRAIDWOOD CCNFORMANCE REMARKS s

(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, hydro-gen fires, fires involving flarrable and 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, ana b

emergency breathing eqtdament.

(1)

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

(8) The direc*.lon and coordination of the fire fighting activitiec (fire brigade leaders only).

Detailed review of fire f aghting (9) strategies and procedures.

(10) Review of the latest plant modi-fications and corresponding changes in fire fighting plans.

NOTE: Items (9) and (10) may be deleted from the training ei no more than two of the non-operations per-sonnel who may be assigned to the fire brigade.

h.

The instruction shall be provided by qualifJti individuals who are knowledge-able, execrienced, and suitably trained in fighting the types of fires that j

could occur in the plant and in using

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the types of equipment available in e.

the nuclear power plant.

Instruction shall be provided to all c.

fire brigade members and fire brigade leaders.

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10 CPR 50 APPENDIX R BYRON /BRAIDWOOD CONFORMANCE REMARKS 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 j

as necessary.

o.

Periodic refrether training sessions shall be hell to repeat the class-room instruction program for all brigade members over a two-year pe riod. These sessions may be con-current with the regular planned

reetings, 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-brigade members with experinece 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 vember.

3.

Drills c.

ri e brigade drills shall be perforaed Exception is taken to the frequency of in the plant so that the fire brigade drills. Dyron/Braidwood stations will can practice as a team, operate with six rotating shif ts.

tlc six shift rotation precludes meeting the b.

Drills shall be performed at regular requirements specified in paragraph f.3 b.

intervals not to exceed 3 montha far Shif ts will be drilled at regular intervals each shift fire brigade. Each fire not to exceed 6 months and each fire brigade member should participate in brigade member must participate in at each drill, but must participate in least one drill per year.

at least two drills per year.

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?6 fi A sufficient number of these drills, but not less than one for each shift t

fire brigade per year, shall be un-F l

announced to determine the fire fighting readiness of the plant fire brigade, l

brigade Icader, and fire protection systems and equipment. Persons i

planning and authorizing an un-I aracunced drill shall ensure that the responding shift fire brigade members are not aware that a drill is being planned until it is begun.

Un-ar.nounce.l. trills shall not be schedaleJ closer than four weels.

At 1cist cne drill per year shall be performed on a "back-shift

• for each shift fire brigade, t

c.

The drills shall be preplanned to establish the training objectives of the drill ar? shall be critiqued to determine ho.* well the training objec-tives 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 tcmedied l

by scheduling additional training for the brigade or members.

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Unsatisfactory drill performance shall l

be followed by a r peat drill within l

30 days.

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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 i

3 NRC icview.

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Drills shall as a minimum include the

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following:

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(1) Assessment of fire alarm effective-

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assemble fire brigade, and selec-

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tion, placement and use of equip-(

ment, and fire fighting strategies.

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10 CTR 50 APPENDIX R BYRON /BRAIDWOOD CCWFORMANCE D

(2)

REMARKS Assessment of each brigade member's knowledge of his or her role in the fire fighting strategy for the area assuned to contain the 1

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 equipr.ent, and ventilation equip-rent to the extent practicable.

(3)

The simulated use of fire fighting 4

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 u:ed in the previous drill so that brigade members are trained in fighting fires in various 1

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 equipment and organize for the fire assuming loss of automatic suppression capability.

Assessment of brigade leader's (4) direction of the fire fighting ef fort as to thoroughness.

i accuracy, and effectiveness.

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Individual records of training provided to ecch fire bri crill critiques,gade member, including shall be maintained for at least 3 years to ensure that eAch member receives training in all parts of the training program. These records 4

of training shall be available for N*C review.

for fire fighting within buildingsRetraining or broadened traaning~

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members whose dificiencies. performance records show

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10 CFR 50 APPENDIX R BYRON /BRAIDWOOD CCNFORMANCE REMARKS J.

Emergency Lighting 9

Emergency lighting units with at 1 cast an 8-hcur battery power supply shall be 8/8 complies.

provided in all areas needed for operation paragraph D.5. See FPR Section 3.4, of safe shutdown equipment and in access and 7

egress routes thereto.

R.

Administrative Controls Administrative controls shall be established to minimize fire hazards in areas containing Administrative controls which will be in structu es, systems, and components import-ef fect will comply with these requirements ant to safety.

except for the exceptions noted below.

Thrse controls shall establish procedures tot s

Govern the handling and limitation of

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the use of ordinary combustible materials, combustible and flammable i

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

2.

Prohibit the storage of combustibles in safety-related areas or establish I

designated storage araas with appro-priate fire protection.

3.

Govern the handling of and limit transient firc loads such as combustible and flammable liquids, wood and plastic products, or other combustible materials d

in buildings containing safety-related systems or equipment during all phases of operating and especially during naintenance, modification, or refueling operations.

4 DIsignate the onsite staff member

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rasponsible for the inplant fire protec-tion review of proposed work activities to identify potential transient fire hszards and specify required additional fire protection in the work activity procedure.

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15 10 CTR 50 APPENDIX R 1

SYRON/BRAIDWOOD CCNFORMANCE REMARKS 5.' Covern the use of ignition sources by use of a flame permit system to control welding, flame cutting, brazing, or i

soldering operations. A separate permit i

shall be issued for each area where

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work is to be done. If work continues over more than one shift, the permit shall be valid for not more than 24 hous when the plant is operating or for the duration of a particular job during l

l plant shutdown.

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 firs *.

l 7

Maintain the periodic housekeeping inspections to ensure continued com-pliance with these administrative controls..

8 Control the use of specific combustibles The requirement that transient comburtible in a safety-related areas. All wood used in safety-related areas during materials not be left unattended during maintenance, modification, or refueling lunch breaks is impracticle to comply with,

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(such as lay-down blocks

' Prudent actions by the stations will ensure operations that wher.ever such trar.sient materials or scaffolding) shall be treated with

.must be left unattended, no ignition 4

e flame retardant. Equipment or supplies

-* sources will be available. This will J

6 (such as new fuel) shipped in un-suffice.

treated combustible packing containers nay be unpacked in safety-related areas if required for valid operating reasons. However, all combustible materials shall te removed from the immediately following the un-area packing. Such transient combustible

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material, unless stored in approved M

containers, shall not be lef t un-9' '

attended during lunch breaks,

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periods. Loose combustible packing material such as woot or paper

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excelsior, or polyetnylene sheeting ahall be placed in metal containers with tight-fitting self-closing metal,

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L 10 CFR 50 APPENDIX R BYRON /BRAIDWOOD CONFORMANCE RE MA*.X S 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.

10.

Control actions to be taken by the con-t rol r oom operator to determine the need for brigade assistance upon re: ort of a fire or receipt of alarm on control room annunciator panel, for example, announcing location of fire over PA system, sounding fire alarms, and notifying the shift supervisor and the fire brigade leader of the type, size, and location of the fire.

11.

Coatrol actions to be taken by the fire brigade after notification by the control room operator of a fire, tor example.asserblang in a desinnated location, receiving directions from the fire brigado 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 surpression systems, and use of preplanned strategies for fighting fires in specific areas.

12.

Define the strategies for fighting It is impossible to write specific stategies fires in all safety-related areas and to cover all items discussed. Generic pro-areas presenting a hazard to safety.

cedures will be developed to provide the fire related equipment. These strategies brigade with guidelines for fighting fires shall designates of any nature in any area.

Fire hazards in each area covered by O.

the specific prefire plans.'

b.

Fire extinguishants best suited for controlling the fires associated with m....

...4 the fire hazards in that area and the nearest location of thesr extinguishants.

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10 CFR 50 APPENDIX R BYRON /BRAIDWOOD CONFORMANCE REMARKS 3

8.

Pfo s t 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 involse locked doors should be specifically identified in the procedure with the appropriate precautions and methods for access specified.

d.

Plant systems that should be managed to reduce the damage potential during a local fire and the location of local an1 remote controls for such management (e.g.,

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

G.

Vital t. eat-sensitive system compcnents that need to te kept cool while fighting a Iccal fire.

Particularly hazardous combustibles that need cooling should be designated.

f.

Organization of fire fighting brigades ar.d 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.

g.

P0tential radiological and toxic harards in fire zones.

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Ventilation system operation t *s -

ensures desired plant air distritution when the ventilation flow is modified f or fire containment or swoke clearing operatings.

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Operations requiring control room and shif t engineer coordination or authori-zation.

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t 10 CTR 50 APPEND 1X R B)RON/BRAIDWOOD CCHFORMANCE REMAPXS s

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j. Instructions for plant operators and general plant personnel during fire.

L.

Alternative and Dedicated Shutdown capability Compliance has not been demonstrated.

Will be addressed by the Safe Shutdown 1.

Alternative or dedicated shutdown Analysis capability provided for a specific fire area shall be able to achieve and main-tain suberatical reactivity conditions in the reactor, maintain reactor coolant inventor standby'y, achieve and maintain hot conditions for a PWR (hot shutdown' for a DWR) and achieve cold shutdown' conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and rsintain cold shutdown conditions thereafter. During the postfire shut.

dnwn, the reactor coolant system a

l process variables shall be maintained e

within those predicted for a lo'ss of normal a.c. power and the fission product I

boandary integrity shall not be affecteds i.e., there shall be no fuel clad i

danage, rupture or any primary coolant l

bound ary, or rupture of the contain-I ment boundary.

2.

The performance goals for the shutdown l

functions shall be B/B complies.

the performance goals listed are presently being implemented in conducting the Safe c.

The reactivity control function shall Shutdown Analysis, be capable of achieving and main-tiining cold shutdown reactivity con-ditions.

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b.

The reactor coolant makeup function shall be capable of maintaining the reactor coolant level above the top of the core for LWRs and be within the IcVel indication in the pressurizer for FKRs.

The reactor heat removal function shall c.

be capable of achieving and maintaining decay heat removal.

6.

The process monitoring funct;c.. shall be capable of providing direct readings of the process variables necessary to perform and control the above functions.

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10 CFR 50 APPENDIX R BYRON /BRAIDWOOD CCNFORMANCE REMARKS c.

The supporting f unctione shall be capable of providing the process cooling, lubri-cation, etc., necessary to permit the operation of the quipment used for safe shutdown functions.

3.

The shutdown capability for specific i Compliance has not been demonstrated..

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fire areas may be unique for each such I

will be addressed by the safe Shutdown area, or it may be one unique combi-Analysis.

nation of systems for all such areas.

In citter case, the alternative shut-down capability shall be independent of the specific fire area (s) and shall acconmodate postfire conditions schere offsite power is available and where offsite pover is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Procedures shall ba in effect to implement this capability.

4 If the capability t schieve and Compliance has not been demorstratad.

Will be addressed by the Safe Shutdown maintain cold shutdo.n will not be

Analysis, available because of fire damage, the

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equipment and systems comprising the means to achieve and maintain the hot standby or hot shutdcwn condition shall be capable of maintaining such conditions until cold shutdown can be

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achieved. If such equipment and sys-tems will not be capable of 1eing po.ered by both onsite and offsite electric power systems because of fire damage, an independent onsite power systen shall be provided. The number of opersting shift personnel, exclusive of fire brigade members, required to operate such equipment and systems shall be on site at all times.

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10 CFR $0 APPENDIX R BYRON /BRAIDWOOD CCNFORMANCE REMARKS 5.

Equipment and systems comprising the Compliance has not been demonstrated.

means to achieve and maintain cold Will be addressed by the Safe Shutdown shutdown conditions shall not be Analysis.

damaged by firer or the fire damage to such equipment and systems shall be limited so that the systens can be made operable and cold shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Materials for such repairs shall be readily available on site and procedures shall be in effect to irplement such repairs. If such equipncnt and systems used prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> af ter the fire will not be capable of being powered by both l

onsite and offsite cicctrical power l

systems because of fire damage an inJependent onsite power system shall be provided. Equipment and systems used after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be powered by offsite power only.

' 6.

Shutdown systems installed to ensure

Compliance has not been demonstrated.

Will be addressed by the. Safe Shutdown postfire shutdown capability need not be designed to meet seismic Category I

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criteria, single failure criteria, or other design basis accident criteria, execpt where rcquired for other reasons, e.g., because of interface with or impact on existing safety systems, or j

because of adverse valve actions due to fire damage.

7 The safe shutdown equipment and systems Compliance has not been demonstrated.

for each fire area shall'be known to Will be addressed by the Safe Shutdown Le isolated from associated non-safety Analysis.

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 equirment. 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.

f rom 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 prever.t

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10 CFR 50 APPENDIX R BYRON /BRAIDWOOD CONFORMANCE REMARKS A.

Fire Barrier Cable Penetration Seal Qualification B/B complies. See FPR Appendix 5.2, Subsection A5.2.2.

Penetration seal designs shall utilize only noncombustible materials and shall be qualified by tests that are comparable to tests usc3 to rate fire barriers. The acceptance criteria for the test shall inelade:

1.

The cable fire barrier penetration seal has withstood the fire endurance test without passige of flame or ignition of cables on the unexposed side for a Period of time equivalent to the fire resistance ratirg required of the barriers s

2.

The tempera *ure levels recorded for the unexposed side are analyzed and demonstrate th&t the maximum temper-ature is sufficient 1'; below the cable insulation ignition temperatures and 3.

The fire bar-ier penetration seal remains intact and does not allow pro 3cetion of water beyond the un-exposed surface during the hose stream test.

C.

Fire Doors 1

i Fire doors shall be self-closing or provided '

B/B complies to the extent that all fire with closing mechanisms and shall be doors are self-closing as described in inspected semiannually to verify that FPR Subsection 2.1.4.1.

The nc'.ure and cutomatic hold-open. release, and closing extent of electrical or adminstrative machanisms and latches are operable.

supervision of fire doors is not presently addressed in the FPR.

One of the following measures shall be provided to en ure they will protect the opening as required in case of fire:

1.

Fire doors shall be kept closed and electrically supervised at a con-3 tinuously manned location;

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Fire doors shall be locked and inspected weekly to verify that the doors are

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10 CFR 50 APPENDIX R BYRON /BRAIDWOOD CCNFORMANCE REMARKS 3.

Fire doors shall be provided with automatic hold-open and release mechanisms and inspected daily to verify that doorways are f ree of obstructions: or 4.

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 firo doors or shall satisfy option 1 above.

O.

Cil Collection System for Heactor Coolant Pump B/B Soes not comply.

A"o,"[andedanalysisofafireresulting g

urning the lubricating oil in a The reactor coolant pump shall be equipped with an oil collection system if the con-reactor coolant pump motor will be provided in Subsection 2.3.1.1 of the B/B Fire tainment is not inerted during normal operation. The oil collection system Protection Report shall be so designed, engineered, and installed that failure will not ?ead to fire during normal or design basis accident conditions and that there is reasonable assurance that the system will withsta.2J the Safe Shutdown Earthquake.'

Such collection =vstems shall be capable of collecting lube oil from all potential

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pressurize 3 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 characteris-tics of the oil present the hazard of fire flashback. Leakage points to be nr'tected 7

x... :.m.ee.4 shall include lif t pump and piping, overflow

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-y lines, lube oil cooler, oil fill and drain

,o lines and plugs, flanged connections on oil lines, and lube oil reservoirs where such features exist on the reactor coolant pumps.

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The drain line shall be large enough to.

eccomodate the largest potential oil leak.

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