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{{#Wiki_filter:B/B                        AMENDMENT 19 DECEMBER 2000 APPENDIX 5.1 RESUMES OF FIRE PROTECTION ENGINEERS AND CONSULTANTS ON THE BYRON/BRAIDWOOD PROJECTS:
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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/B          AMENDMENT 13 DECEMBER 1990 APPENDIX 5.2 CABLE SYSTEMS CRITERIA
 
B/B          AMENDMENT 13 DECEMBER 1990 TABLE OF CONTENTS PAGE A5.2    CABLE SYSTEMS CRITERIA                A5.2-1 A5.2.1  CABLE DERATING AND CABLE TRAY FILL    A5.2-1 A5.2.2  FIRE DETECTION AND PROTECTION IN AREAS WHERE CABLES ARE INSTALLED            A5.2-3 A5.2.3  PHYSICAL INDEPENDENCE OF REDUNDANT SYSTEMS                                A5.2-5 A5.2.3.1 Criteria and Design Basis              A5.2-5 A5.2.3.2 Cable Tray, Cable Penetrations, and Conduit System Design Basis            A5.2-5 A5.2.3.3 Cable Penetrations                    A5.2-5 A5.2.4  CABLE DEFINITIONS AND RATING DESIGN BASIS                                  A5.2-7 A5.2.4.1 Cable Definitions                      A5.2-7 A5.2.4.2 Cable Derating (Cable Ampacities)      A5.2-7 A5.2.5  PHYSICAL SEPARATION CRITERIA          A5.2-9 A5.2.5.1 Class 1E Equipment Separation          A5.2-9 A5.2.5.2 Raceway Separation Criteria            A5.2-9 A5.2.6  CABLE SEPARATION CRITERIA              A5.2-13 A5.2.6.1 Cable Segregation                      A5.2-13 A5.2.6.2 Cable Routing                          A5.2-13 A5.
 
==2.7  REFERENCES==
A5.2-15 A5.2-i
 
B/B                        AMENDMENT 13 DECEMBER 1990 APPENDIX 5.2 CABLE SYSTEMS CRITERIA A5.2.1    CABLE 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/ft2, 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/B                        AMENDMENT 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/B                        AMENDMENT 25 DECEMBER 2012 A5.2.2    FIRE 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 Areas
: a. upper cable spreading room
: 1. automatic Halon 1301 system,
: 2. manual carbon dioxide system and
: 3. manual water hose stations.
: b. lower cable spreading room
: 1. 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/B                        AMENDMENT 19 DECEMBER 2000
: c. 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/B                        AMENDMENT 13 DECEMBER 1990 A5.2.3    PHYSICAL INDEPENDENCE OF REDUNDANT SYSTEMS A5.2.3.1 Criteria and Design Basis The 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.
A5.2.3.2 Cable 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.
A5.2.3.3 Cable 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/B                          AMENDMENT 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 Instrumentation The electrical penetrations meet the requirements of IEEE 317-1972 and IEEE 384-1974.
A5.2-6
 
B/B                        AMENDMENT 13 DECEMBER 1990 A5.2.4  CABLE DEFINITIONS AND RATING DESIGN BASIS A5.2.4.1 Cable Definitions
: a. 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
              #14 AWG conductor cables are also included in this category; e.g., power feeds to valve motor operators.
: b. Control Cables Control 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.
A5.2.4.2 Cable 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/B                        AMENDMENT 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/B                          AMENDMENT 13 DECEMBER 1990 A5.2.5    PHYSICAL SEPARATION CRITERIA A5.2.5.1 Class 1E Equipment Separation Class 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.
A5.2.5.2 Raceway Separation Criteria Cable Tray Segregation
: a. 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), and
: 4. 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),
and
: 4. 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/B                          AMENDMENT 13 DECEMBER 1990 control cable segregation is maintained, where practical, to the point of entering this equipment.
Cable Tray Separation
: a. 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 -
(3 feet 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 -
(1 foot 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/B                          AMENDMENT 13 DECEMBER 1990
: 4. 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 Separation
: a. 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/B                          AMENDMENT 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); and
: 3. 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 -
12 inches; and
: 4. power cable conduit to instrument cable tray - 20 inches.
A5.2-12
 
B/B                        AMENDMENT 13 DECEMBER 1990 A5.2.6    CABLE SEPARATION CRITERIA A5.2.6.1 Cable 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 1            P            1        E 2            C            2        B K            3        R 4        N A        A Type:    P = Power C = Control K = Instrumentation Division:    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 4 Category:    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).
A5.2.6.2 Cable 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/B                          AMENDMENT 13 DECEMBER 1990
: a. 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:
Cable                Tray Category Category            E    B    R    N E                X B                      X R                            X      X N                            X      X
                                  *A                X
                                *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/B                        AMENDMENT 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 10 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 10 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/B            AMENDMENT 13 DECEMBER 1990 TABLE OF CONTENTS PAGE A5.4  FIRE PROTECTION SYSTEM DESCRIPTIONS      A5.4-1 A5.4.1 FIRE PROTECTION WATER SUPPLY SYSTEM      A5.4-2 A5.4.2 AUTOMATIC DELUGE SYSTEMS                A5.4-4 A5.4.3 AUTOMATIC SPRINKLER SYSTEMS              A5.4-6 A5.4.4 FOAM SYSTEMS                            A5.4-8 A5.4.5 HALON 1301 SYSTEMS                      A5.4-10 A5.4.6 CARBON DIOXIDE (CO2) SYSTEM              A5.4-12 A5.4.7 MANUAL EXTINGUISHING CAPABILITY          A5.4-15 A5.4.8 FIRE DETECTION SYSTEM DESCRIPTION        A5.4-16 A5.4-i
 
B/B          AMENDMENT 13 DECEMBER 1990 LIST OF TABLES NUMBER              TITLES                PAGE A5.4-1 Fire Protection Matrix            A5.4-17 A5.4-2 Fire Pump Data                    A5.4-26 A5.4-3 Automatic Deluge Systems          A5.4-26 A5.4-4 Automatic Sprinkler Systems      A5.4-27 A5.4-5 Foam Systems                      A5.4-28 A5.4-6 Halon 1301 Systems                A5.4-29 A5.4-7 Carbon Dioxide Systems            A5.4-30 A5.4-ii
 
B/B                        AMENDMENT 18 DECEMBER 1998 LIST OF FIGURES NUMBER                  TITLE A5.4-1 Unit 1 Fire Protection System Single Line Diagram A5.4-2 Unit 1 Fire Detection Schematic Diagram for Cable Spreading Rooms M-28  Fire Protection Piping and Outdoor Protection M-603  Transformers - Sprinkler Systems M-52  Fire Protection M-58  Carbon Dioxide and Hydrogen Systems A5.4-iii
 
B/B                        AMENDMENT 13 DECEMBER 1990 APPENDIX 5.4 - FIRE PROTECTION SYSTEMS DESCRIPTIONS The 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/B                        AMENDMENT 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 qualified backup 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/B                        AMENDMENT 19 DECEMBER 2000 circulating 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 control room 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 annunciation in 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/B                          AMENDMENT 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/B                        AMENDMENT 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 trouble condition 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/B                        AMENDMENT 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 hazard exists. 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 water supply 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; and
: c. 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/B                        AMENDMENT 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/B                        AMENDMENT 28 DECEMBER 2018 A5.4.4  FOAM SYSTEMS Manual foam systems are provided for the 50,000-gallon diesel oil storage tank rooms in the auxiliary building. A balanced 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. The foam 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/B                        AMENDMENT 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/B                        AMENDMENT 28 DECEMBER 2018 A5.4.5  HALON 1301 SYSTEMS Automatic Halon systems have been provided for the upper cable spreading areas and 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 area because 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 CO2 storage tanks. Halon is less toxic than C02 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 Halon from 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 assigned to 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 the largest 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/B                        AMENDMENT 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 suppression system 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/B                          AMENDMENT 28 DECEMBER 2018 A5.4.6  CARBON DIOXIDE (CO2) SYSTEM The CO2 system receives bulk deliveries of liquid carbon dioxide. It is stored in a temperature controlled CO2 storage unit. Carbon dioxide is supplied from this storage unit to the C02 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 on the 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, at elevation 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 controls operate the master valve on the supply line. A 1-1/2-inch C02 supply line supplies carbon dioxide to the C02 vaporizer in the C02 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/B                        AMENDMENT 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 procedures for 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-op testing, and operating procedures were all reviewd by the Fire 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/B                          AMENDMENT 17 DECEMBER 1996 Local pushbuttons adjacent to the CO2 protected rooms provide manual electrical control for testing purposes, or to initiate the CO2 in an emergency if thermostats should fail to actuate the CO2 system.
In case of electrical failure, local electromanual pilot cabinets (EMPC) are provided for each protected room and at the main storage 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 system are 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 for the 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 operable by 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 each automatic total flooding area. The above 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 of the area before the system discharges. Once the CO2 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 each carbon 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/B                        AMENDMENT 17 DECEMBER 1996
: a. 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 C02 system.
The CO2 storage unit is operated off the 480-V distribution system. The electrical actuation and detector circuits for 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 CO2 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/B                          AMENDMENT 26 DECEMBER 2014 A5.4.7  MANUAL EXTINGUISHING CAPABILITY This section deals with the manual hose stations and 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 of the 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 the extinguisher, 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/B                        AMENDMENT 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 a Class 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 systems protecting 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 OR ZONE  PRIMARY PROTECTION              BACKUP PROTECTION    FIRE DETECTION          CONCENTRATION COMMENTS 1.1-1  Portable extinguishers          Hose stations        Heat 1.1-2  Portable extinguishers          Hose stations        Heat 1.2-1  Portable extinguishers          Hose stations        Ionization (or photoelectric) 1.2-2  Portable extinguishers          Hose stations        Ionization (or photoelectric) 1.3-1  Manual deluge system            Hose stations        Temperature Switch                      Deluge system abandoned on for charcoal units (Byron only)                      in Charcoal Adsorber                    Braidwood Unit 1 Portable extinguishers                                Bank (Byron only)
(See Comment 5)                                      Ionization (or photoelectric) 1.3-2  Portable extinguishers          Hose stations        Temperature Switch                      Deluge system abandoned (See Comment 5)                                      in Charocal Adsorber                    on Byron and Braidwood Unit 2 Bank (Byron only)
Ionization (or photoelectric) 2.1-0  Portable extinguishers          Hose stations        Ionization (or photoelectric) 2.1-1  Portable extinguishers          Hose stations        Ionization (or photoelectric) 2.1-2  Portable extinguishers          Hose stations        Ionization (or photoelectric) 3.1-1  Automatic CO2                  Hose stations 3.1-2                                  and portable extinguishers        See Comment 1          50%          1. The ionization and Fenwal thermal detectors are cross-zoned to re-3.2-0  Portable extinguishers          Hose stations        Ionization (or photoelectric)                  quire both an ionization and a heat detection of 3.2A-1 Automatic CO2                  Hose stations                                                    a fire to actuate the auto-3.2A-2                                and portable                                                    matic fire suppression system.
extinguishers        See Comment 1          50%                Each detection zone provides an independent alarm of a fire (or detector trouble) to 3.2B-l Automatic CO2                  Hose stations                                                    the main control room. The 3.2B-2                                and portable                                                    circuits are designed that extinguishers        See Comment 1          50%                if either of the circuits has a break or a ground fault in 3.2C-l Automatic CO2                  Hose stations                                                    one of the signalling line 3.2C-2                                and portable                                                    circuits, the remaining extinguishers        See Comment 1          50%                detection circuit could then automatically actuate the 3.2D-1 Automatic CO2                  Hose stations                                                    fire suppression system if 3.2D-2                                and portable                                                    a fire was present.
extinguishers        See Comment 1          50%
A5.4-17
 
B/B                                      AMENDMENT 28 DECEMBER 2018 TABLE A5.4-1 (Cont'd)
FIRE                                                                        DENSITY OR ZONE  PRIMARY PROTECTION    BACKUP PROTECTION    FIRE DETECTION          CONCENTRATION COMMENTS 3.2E-1 Automatic CO2          Hose stations 3.2E-2                        and portable extinguishers        See Comment 1          50%
3.3A-1 Halon 1301            Manual CO2,          See Comment 1          6% Halon 3.3A-2 Manual deluge system  portable extin-                              50% CO2 for charcoal units    guishers, hose (See Comment 5)        stations 3.3A-1 Halon 1301            Manual CO2,          See Comment 1          6% Halon 3.3A-2                        portable extin-                              50% CO2 guishers, hose stations 3.3B-1 Halon 1301            Manual CO2,          See Comment 1          6% Halon 3.3B-2                        portable extin-                              50% CO2 guishers, hose stations 3.3C-1 Halon 1301            Manual CO2,          See Comment 1          6% Halon 3.3C.1                        portable extin-                              50% CO2 guishers, hose stations 3.3D-l Halon 1301            Manual CO2,          See Comment 1          6% Halon 3.3D-2                        portable extin-                              50% CO2 guishers, hose stations 3.4A-1 Portable extinguishers Hose station        Ionization (or photoelectric)            ---
3.4A-2 4.1-1  Portable extinguishers Hose station        Ionization (or photoelectric)            ---
4.1-2  Portable extinguishers Hose station        Ionization (or photoelectric)            ---
5.1-1  Portable extinguishers Hose stations        Ionization (or photoelectric)            ---
5.1-2 5.2-1  Portable extinguishers Hose stations        Ionization (or photoelectric)            ---
5.2-2 5.3-1  Portable extinguishers Hose stations        Ionization (or photoelectric)            ---
5.3-2 5.4-1  Portable extinguishers Hose stations        Ionization (or photoelectric)            ---
5.4-2 5.5-1  Portable extinguishers Hose stations        Ionization (or photoelectric)            ---
5.5-2 A5.4-18
 
B/B                                                    AMENDMENT 28 DECEMBER 2018 TABLE A5.4-1 (Cont'd)
FIRE                                                                          DENSITY OR ZONE  PRIMARY PROTECTION      BACKUP PROTECTION  FIRE DETECTION            CONCENTRATION COMMENTS 5.6-1  Portable extinguishers  Hose stations      Ionization (or photoelectric)              ---
5.6-2 7.1-1  Hose stations            Portable extin-    Ionization (or photoelectric) 7.1-2                          guishers          (Braidwood)                ---
8.1-0  Automatic sprinklers    Hose stations and  Fusible links on          0.3 gpm/ft2  2. Density is 0.3 gpm/
portable extin-    sprinkler heads                              ft2 per any 3000 guishers          Ionization (or photoelectric)                            ft2 area and 0.2 (Byron only)                                gpm/ft2 for any 10,000 ft2 area.
8.2-1  Automatic sprinklers    Hose stations and  Fusible link on          See Comment 2 8.2-2                          portable extin-    sprinkler heads guishers 8.3-1  Automatic sprinklers    Hose stations and  Fusible links            See Comment 2 3. The deluge sys-8.3-2  Automatic deluge (6)    portable extin-    sprinkler heads                              tem is provide guishers                                                        for the turbine bearings only, 8.4-1  Automatic sprinklers    Hose stations and  Fusible link              0.3 gpm/ft2        and is actuated 8.4-2                          portable extin-    sprinkler heads                              by rate-compensating guishers                                                        detectors.
8.5-1  Automatic sprinklers    Hose stations and  Rate compensated          See Comment 2 8.5-2  Automatic deluge (4)    portable extin-    detectors guishers          Ultraviolet (Byron) 8.6-0  Automatic deluge (3)    Hose stations      None (Braidwood)                        4. The deluge system Manual deluge (5)                          Ultraviolet (Byron)                          is for the hydro-Portable Extinguishers                      Temp. switch in                              gen seal oil units Automatic Sprinklers (7)                    Charcoal bank                                only and is actu-ated by rate com-pensated detectors.
8.7A-0 Automatic sprinkler      Hose stations and  Fusible link 8.7B-0 Automatic sprinkler      portable extin-    sprinkler heads                        7. The automatic sprinkler system Is provided for the Operator Ready room. Density is 0.10 Gpm/ft2 per any 900 ft2 area.
guishers 9.1-1  Automatic CO2            Portable extin-    Rate compensation            34%
9.1-2                          guishers and hose  ultraviolet stations 9.2-1  Automatic CO2            Portable extin-    Rate compensation            34%        6. The deluge system 9.2-2                          guishers and hose  ultraviolet                                  is for the Turbine stations                                                        oil storage Tank Room and is actuated 9.3-1  Automatic CO2            Portable extin-    Rate compensation            34%            by rate compensated 9.3-2                          guishers and hose                                              detectors.
stations          A5.4-19
 
B/B                                                  AMENDMENT 28 DECEMBER 2018 TABLE A5.4-1 (Cont'd)
FIRE                                                                          DENSITY OR ZONE    PRIMARY PROTECTION      BACKUP PROTECTION    FIRE DETECTION          CONCENTRATION COMMENTS 9.4-1  Automatic CO2            Portable extin-      Rate compensation          34%
9.4-2                            guishers and hose stations 10.1-1  Foam (Manual)            Portable extin-      Rate compensated        .16 gpm/ft2 guishers and hose    detectors station              Ionization (or photoelectric) (Byron) 10.1-2  Foam (Manual)            Portable extin-      Rate compensating      .16 gpm/ft2 guishers and hose    Ionization (or photoelectric) (Byron) station 10.2-1  Foam (Manual)            Portable extin-      Rate compensating      .16 gpm/ft2 guishers and hose    Ionization (or photoelectric) (Byron) station 10.2-2  Foam (Manual)            Portable extin-      Rate compensating      .16 gpm/ft2 guishers and hose    Ionization (or photoelectric) (Byron) station 11.1A-0 Portable extinguishers  Hose stations        Ionization (or photoelectric)            ---
11.1B-0 11.2-0  Portable extinguishers  Hose stations        Ionization (or photoelectric)            ---
11.2A-1 Portable extinguishers  Hose stations        Ionization (or photoelectric)            ---
11.2A-2 11.2B-1 Portable extinguishers  Hose stations        Ionization (or photoelectric)            ---
ll.2B-2 11.2C-1 Portable extinguishers  Hose stations        Ionization (or photoelectric)            ---
11.2C-2 11.2D-1 Portable extinguishers  Hose stations        Ionization (or photoelectric)            ---
11.2D-2 11.3-0  Portable extinguishers  Hose stations        Ionization (or photoelectric)            N/A  The sprinklers cover and automatic sprinklers                                                            the component cooling pumps and stairway.
11.3-1  Portable extinguishers  Hose stations        Ionization (or photoelectric)            N/A  Sprinklers protect 11.3-2  and automatic sprinklers                                                            pipe penetrations.
11.3A-1 Portable extinguishers  Hose stations        Ionization (or photoelectric)            ---
11.3A-2 A5.4-20
 
B/B                                                    AMENDMENT 28 DECEMBER 2018 TABLE A5.4-1 (Cont'd)
FIRE                                                                        DENSITY OR ZONE    PRIMARY PROTECTION    BACKUP PROTECTION    FIRE DETECTION          CONCENTRATION COMMENTS 11.3B-1 Portable extinguishers Hose stations        None                      ---
11.3B-2 11.3C-1 Portable extinguishers Hose stations        Ionization (or photoelectric)            ---
11.3C-2 11.3D-1 Portable extinguishers Hose stations        Ionization (or photoelectric)            ---
11.3D-2 11.3E-1 Portable extinguishers Hose stations        None                      ---
11.3E-2 11.3F-1 Portable extinguishers Hose stations        Ionization (or photoelectric) 11.3F-2 11.3G.1 Portable extinguishers Hose stations        Ionization (or photoelectric)            ---
11.3G.2 11.4-0  Portable extinguishers Hose stations        Ionization (or photoelectric)            N/A  Automatic sprinkler Automatic sprinkler                                                              cover stairway hatch.
ll.4A-0 Portable extinguishers Hose stations        Ionization (or photoelectric)            ---
11.4A-1 Automatic CO2          Portable extin-      Rate compensation          34%
11.4A-2                        guishers and hose    Ionization (or photoelectric) Byron stations 11.4B-0 Portable extinguishers Hose stations        None                      ---
11.4B-1 Portable extinguishers Hose stations        None                      ---
ll.4B-2 11.4C-0 Portable extinguishers Hose stations        Ionization (or photoelectric)            ---
11.4C-1 Portable extinguishers Hose stations        None                      ---
11.4C-2 11.4D-1 Portable extinguishers Hose stations        None                      ---
11.4D-2 11.5-0  Portable extinguishers Hose stations        Ionization (or photoelectric)            N/A  Sprinklers protect Automatic sprinkler                                                              stairway and hatch and waste oil tank.
11.5-1  Portable extinguishers Hose stations        Ionization (or photoelectric)            ---
11.5-2 11.5A-0 Portable extinguishers Hose stations        None-Byron                ---
Ionization-Braidwood A5.4-21
 
B/B                                                    AMENDMENT 28 DECEMBER 208 TABLE A5.4-1 (Cont'd)
FIRE                                                                              DENSITY OR ZONE    PRIMARY PROTECTION    BACKUP PROTECTION        FIRE DETECTION          CONCENTRATION COMMENTS 11.5A-1 Portable extinguishers Hose stations            Ionization (or photoelectric)            ---
11.5A-2 11.5B-1 Portable extinguishers Hose stations            Ionization (or photoelectric)            ---
11.5B-2 Portable extinguishers Hose stations            lonization (or photoelectric)            ---
11.6-0  Portable extinguishers Hose stations            Ionization  (or photoelectric)          N/A  Sprinkler protect Automatic sprinkler                                                        ---        stairway and hatch.
11.6-1  Portable extinguishers Hose stations            Ionization (or photoelectric)            ---
11.6-2 11.6A-0 Portable extinguishers Hose stations            Ionization (or photoelectric)            ---
11.6A-1 Portable extinguishers Hose stations            None                      ---
11.6A-2 11.6B-0 Portable extinguishers Hose stations            None                      ---
11.6C-0 Portable extinquishers Hose stations            None-Byron Ionization-Braidwood    ---
11.6D-0 Portable extinguishers Hose stations            Ionization (or photoelectric)            ---
11.6E-0 Portable extinguishers Hose stations            Ionization (or photoelectric)            ---
11.7-0  Manual deluge          Hose stations and        Temp. switch in            N/A        5. The deluge system (See Comment 5)        portable extin-          charcoal bank;                            is provided for guishers                  Ionization (or photoelectric)                  the charcoal filters only manually actuated.
11.7-1  Hose stations          Portable extin-          Temp. switch in            N/A guishers                  charcoal bank; 11.7-2  Manual deluge (5)      Portable extin-          Ionization (or photoelectric) guisher 12.1-0  Hose stations          Portable extin-          Ionization (or photoelectric)            ---
guishers 13.0-0  Automatic Halon        Hose stations and        Ionization (or photoelectric)            5%
portable extin-guishers 14.1-0  Hose stations          Portable extinguishers    None                      ---
14.2-0  Hose stations          Portable extinguishers    None 14.3-0  Hose stations          Portable extinguishers    None A5.4-22
 
B/B                                                      AMENDMENT 28 DECEMBER 2018 TABLE A5.4-1 (Cont'd)
FIRE                                                                              DENSITY OR ZONE  PRIMARY PROTECTION    BACKUP PROTECTION        FIRE DETECTION          CONCENTRATION  COMMENTS 14.4-0 Hose stations          Portable extinguishers    None 14.5-0 Hose stations          Portable extinguishers    None 14.6-0 Partial automatic      Hose stations and        Ionization (or photoelectric)              N/A sprinklers            Portable extinguishers    Temp. switch in Manual deluge (5)                                charcoal bank 16.1-1 Hydrants                  ---                    None                        ---
16.1-2 16.2-1 Hydrants                  ---                    None 16.2-2 17.1-0    ---                    ---                    None                        ---          Not required 17.1-1 Hydrants                  ---                    None                        ---
17.1-2 (Byron only)              ---                    ---                        ---
17.2-1 Hydrants                  ---                    None                        ---
17.2-2 (Byron only) 18.1-1 Hose stations          Portable extinguishers    Ionization (or photoelectric)n ducts    ---
18.1-2 18.2-1 Hose stations          Portable extinguishers    Ionization  (or photoelectric)in ducts  ---
18.2-2 18.3-1 Portable extinguisher  Hose station              Ionization (or photoelectric)              ---
18.3-2 18.4-1 Portable extinguisher  Hose station              Ionization (or photoelectric)              N/A  Over charcoal 18.4-2 Manual deluge (5)                                Temp. switch in                          filters charcoal bank 18.5-1 Portable extinguishers Hose stations            None                        ---
18.5-2 Portable extinguishers Hose stations            Ionization (or photoelectric)              ---
18.6-0 Automatic sprinklers  Portable extin-          Fusible link            .2 gpm/ft2 in  For the storeroom and guishers and              sprinkler heads          storeroom and  paint and oil room hose stations                                      .3 gpm/ft2 in  only.
paint and oil room 18.7-0 Portable Extinguishers Hose stations            None A5.4-23
 
B/B                                                    AMENDMENT 28 DECEMBER 2018 TABLE A5.4-1 (Cont'd)
FIRE                                                                                DENSITY OR ZONE      PRIMARY PROTECTION    BACKUP PROTECTION        FIRE DETECTION          CONCENTRATION COMMENTS 18.8-0    Portable Extinguishers Hose stations            None 18.9-0    Portable extinguishers Hose stations            None                      ---
18.10A-1 18.10B-1 18.10C-1  Automatic and manual  Hydrants                  Thermistor wire,                      Manual deluge from 18.10D-1  deluge                                          sudden pressure                      thermistor, auto-18.10E-1                          switch, dif-                                                    matic deluge from 18.10F-1                          ferential relay                                                relay 18.10A-2 18.10B-2 18.10C-2  Automatic and manual  Hydrants                  Thermistor wire,                      Manual deluge from 18.10D-2  deluge                                          sudden pressure                      thermistor, auto-18.10E-2                                                    switch, dif-                          matic deluge from 18.10F-2                                                    ferential relay                      relay 18.11-0    Automatic C02                                    Ionization (or photoelectric)            34%  For oil tank room and (Byron)                          Portable extin-                                                ESW makeup pump guishers                                                        area 18.11-0    Local Fire Department  Portable extinguishers    Ionization (or photoelectric)            ---
(Braidwood)                                                Ultraviolet 18.11-1    Automatic CO2          Por-                      Rate of rise 18.11-2                          table extinguishers (Byron only) 18.12-0    Hose stations          Portable extin-          Ionization (or photoelectric)-B/B guishers                  and ultra-violet (Braidwood) 18.13-0    Automatic sprinklers  Hose stations and        Fusible link            .2 gpm/ft2 portable extin-          sprinkler heads guishers                  Ionization (or photoelectric) (Byron) 18.14A-1  Hose Stations            ---                    Ionization (or photoelectric)            ---
(Byron) 18.14A-2  Hose Stations            ---                    Ionization (or photoelectric)            ---
18.14B-1  Hose Stations            ---                    Ionization (or photoelectric)            ---
(Byron) 18.14B-2  Hose Stations            ---                    Ionization (or photoelectric)            ---
(Byron)
A5.4-24
 
B/B                                            AMENDMENT 25 DECEMBER 2012 TABLE A5.4-1 (Cont'd)
FIRE                                                                        DENSITY OR ZONE      PRIMARY PROTECTION  BACKUP PROTECTION        FIRE DETECTION      CONCENTRATION      COMMENTS 18.15-0    Hose stations      Portable                None                  ---
(Braidwood) extinguishers 18.16-1    Hydrants            Dikes                    None                  ---
18.16-2 18.17-0    Hydrants              ---                  None                  ---
There is no Zone 18.18-0 18.19-0    Hydrants            Dikes                    None                  ---
18.20-0 Hydrants            Dikes                        ---                ---
18.22-0    Hose stations          ---                  None                  ---
(Byron) 18.23-0    Hydrants              ---                  None                  ---
18.24-0    Hose station        Portable                None                  ---
extinguishers 18.25-1    Hose stations          ---                  None                  ---
18.25-2    Hose stations          ---                  None                  ---
18.26-0    Hose stations          ---                  Temp switch in        N/A Manual Deluge(5)                            charcoal bank 18.27-0    Hose stations          ---                  None                  ---
18.28-0    Overhead sprinkler  Hose stations          None                  N/A              Protects waste (partial coverage)  Fire Hydrants                                                  oil tank 18.29-0    Fire hydrants      Portable                None                  ---
extinguishers 18.30-0    Fire hydrants          ---                  None                  ---
18.31-0    Fire hydrant          ---                  None                  ---
18.32-0    Automatic sprinkler Portable extinguisher  None                0.33 gpm/ft2 (0.39 gpm/ft2 and hose stations                          for 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 OR ZONE    PRIMARY PROTECTION BACKUP PROTECTION              FIRE DETECTION          CONCENTRATION COMMENTS 18.33-0 Hose stations      Fire hydrants                None                      ---
18.34-0 Fire hydrant          ---                        None                      ---
18.35-0 Hose stations      Portable extinguishers        Ionization (or photoelectric)            ---
18.36-0 None                  ---                        None                      ---
A5.4-25a
 
B/B          AMENDMENT 20 DECEMBER 2002 TABLE A5.4-2 FIRE PUMP DATA MOTOR-DRIVEN FIRE PUMPS Horsepower - 350 Voltage, phase, frequency - 4160-V, 3-phase, 60 Hz Pump Stages - 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/B                        AMENDMENT 23 DECEMBER 2008 GEAR REDUCER Type - right angle Ratio - 1:1 Coupling - Watson-Spicer Diesel Engine Manufacturer  -  Cummins Engine speed  -  1760 rpm Number of cylinders - 12 Displacement  -  1710 in3 Cycles - 4 Horsepower (max. continuous) - 522 hp Starting signal to full load 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/B                AMENDMENT 20 DECEMBER 2002 TABLE A5.4-2 (Cont'd)
Horsepower - 15 hp Voltage, phase, frequency - 460-V, 3-phase, 60 Hz Pump Stages - 21 rpm - 1800 gpm - 100 Labeled head - 335 feet A5.4-28
 
lsolahon Gate Valve Selector Valve                      Master Valve at C0 Stora11e Tank 2
Protected C0 Storage Tank Byron/Braidwood Power Slahons-Untl 1                                                              Area                                                                                      2                                  AMENDMENT 25 C1rcu1t Arrangement for Detection and Suppression Systems located in buildings                                                                  Pres~ure      S                                I containing safety-related equipment                                                                        Switch          I                                I (A)-Class A Electrical Superv1s1on I                                I (8)-Class B Electrical Superv1s1on I                                I I                                I        Electro-Main Control                                              I                                I Board 1PM09J
                                                                                                    -----,                          I I
I I
Manual Piiot Cab.
I                I                                I                  1 T
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I Detectors (B) 0-----,...            Local Fire IL ____ _  L-------*
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                                                                                                                                    /1------            Water-Foam Stor Tank Rooms                                                                            Tank (Byron & Braidwood) Pressure                  Deluge          Isolation Sw1lch            Valve            Gate Valve BYRON/BRAIDWOOD STATIONS FIRE PROTECTION REPORT
                                                                            ..t:ilfil:
: 1. nus FIGURE IS PROVIDED FOR REFERENCE ONLY ANO IS INTENDED                                                                          FIGURE A5 4-1 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,                                                          UNil l FIRE PROTECTION SYSTEM DETECTORS, HOSE STATIONS, FIRE EXTINGUISHERS ANO SUPPRESSION SYSTEM COVERAGE. APPLICABLE DESIGN DRAWINGS AND DOCUMENTS SHOULD BE REVIEWED SINGLE LINE DIAGRAM FOR SPECIFIC DESIGN DETAILS, INCLUDING LOCATION OF EQUIPMENT.
 
AMENDMENT 12
            ,                                                        DECEMBER 1989    ~
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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&deg;F.
Combustible liquids are subdivided as follows:
: 1. Class II - includes liquids having flash points at or above 100&deg;F and below 140&deg;F.
: 2. Class IIIA - liquids having flash points at or above 140&deg;F and below 200&deg;F.
: 3. Class IIIB - liquids having flash points at or above 200&deg;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&deg;F and having a vapor pressure not exceeding 40 psi absolute at 100&deg;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/B                        AMENDMENT 13 DECEMBER 1990 Introduction Appendix 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 Although Appendix R to 10 CFR 50 This Appendix applies to licensed                                                        applies strictly to plants licensed to nuclear power electric generating                                                        operate prior to January 1, 1979, the stations that were operating prior to                                                    NRC has made conformance to 10 CFR 50 January 1, 1979, except to the extent                                                    Appendix R a licensing requirement for set forth in paragraph 50.48(b) of                                                      Byron/Braidwood. See NRC question this part. With respect to certain                                                      600.01 (June 3, 1981).
generic issues for such facilities it sets forth fire protection features required to satisfy Criterion 3 of Appendix A to this part5.
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-                                                    The design basis of the Byron/Braidwood related," will be used throughout this                                                  plant has from the beginning been that Appendix R as applying to all safety                                                    Hot Standby (as defined in the functions. The phrase "safe shutdown"                                                    Technical Requirements Manual) is a will be used throughout this Appendix                                                    "safe shutdown" condition, since the R as applying to both hot and cold                                                      plant can be maintained in Hot Standby shutdown functions.                                                                      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 [[estimated NRC review hours::72 hours]] 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 Requirements A. Fire Protection Program            The applicant's fire protection program complies with these requirements as described below.
A fire protection program shall be  Administrative procedures define the established at each nuclear power  requirements for fire prevention. The Fire plant. The program shall            Protection Report Section 2.3, "Fire establish the fire protection      Hazards Analysis" and Section 2.4, "Safe policy for the protection of        Shutdown Analysis" establish the components structures, systems, and            for safe shutdown. Prefire plans establish components important to safety at  the components needed and the protection each plant and the procedures,      for the area.
equipment, and personnel required to implement the program at the plant site.
Administrative Procedures define the responsibilities, procedures, and personnel for the Fire Protection Program.
The fire protection program shall  Administrative Procedures identify the be under the direction of an        individual delegated the authority for individual who has been delegated  establishing the fire protection program.
authority commensurate with the responsibilities of the position    Administrative Procedures describe the and who has available staff        organization and staff available to personnel knowledgeable in both    implement the program.
fire protection and nuclear safety.
The fire protection program shall  Comply. The B/B fire protection program extend the concept of defense-in-  includes these general objectives within depth to fire protection in fire    it.
areas important to safety, with the following objectives;
* to prevent fires from        Administrative Procedures outline starting;                    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,  The detection system alarms in the main and extinguish promptly      control room. The proper method of those fires that do occur;  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    Fire Protection Operating Procedures structures, systems, and      outline the manual initiation of CO2 with components important to      loss of power.
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 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 Hazards Analysis was performed for A fire hazard analysis shall be    the Byron/Braidwood stations and was performed by qualified fire        included with the Fire Protection Report, protection and reactor systems      filed with the NRC on October 31, 1977.
engineers to (1) consider          This report documented conformance with BTP potential in situ and transient    APCSB 9.5-1, Appendix A, but did not fire hazards; (2) determine the    specifically address safe shutdown consequences of fire in any        capability, the subject of Appendix R.
location in the plant on the ability to safely shut down the    The Applicant has performed Safe Shutdown reactor or on the ability to        Analyses for the Byron and Braidwood units minimize and control and release    which demonstrate the ability to safely of radioactivity to the            shut down the units following a fire in any environment; and (3) specify        zone. The analyses are included in Section measures for fire prevention, fire  2.4 of the Fire Protection Report.
detection, fire suppression, and fire containment and alternative    The fire hazards analysis and the safe shutdown capability as required    shutdown analysis were performed primarily for each fire area containing      by the architect/engineer for this plant.
structures, systems, and            Engineering personnel from the AE's components important to            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          disciplines participated in these efforts.
guidelines and regulations.            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          Comply. The fire prevention program and plant features meet these requirements.
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.
: 1. In situ fire hazards shall  Fire hazards were considered in the plant be identified and suitable  design as shown in the Fire Protection protection provided.        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      The fire hazard analysis includes an associated with normal      allowance for transient combustibles in the operation, maintenance,      combustible inventory for each fire zone repair, or modification      unless the fire zone is a controlled access activities shall be          area. Specific transient materials which identified and eliminated    could be present are not identified; where possible. Those        rather, a transient hazard equivalent in transient fire hazards that  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    of lubricating oil is assumed and the Btu be controlled and suitable    content is added to that of the identified protection provided.          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,      Byron/Braidwood Stations comply with portable extinguishes, and    exceptions as documented in the FPR Section standpipe and hose stations  3.6.
shall be installed.
: 4. Fire barriers or automatic    Redundant safe shutdown components and suppression systems or both  systems are not always separated by fire shall be installed as        barriers and/or protected by automatic necessary to protect          suppression systems. All deviations from redundant systems or          this requirement are identified and components necessary for      justified in Appendix A5.8 and Generic safe shutdown.                Letter 86-10 evaluations.
: 5. A site fire brigade shall be  The site fire brigade is established as established, trained, and    described in Administrative Procedures.
equipped and shall be on      Refer to Section III.H and III.I of this site at all times.            Appendix.
: 6. Fire detection and            Byron/Braidwood Stations fire protection suppression systems shall be  and suppression systems are designed and designed, installed,          constructed as described in FPR Section 3.1 maintained, and tested by    of Paragraph 1.a., Responsibility for Fire personnel properly qualified  Protection Program, Design Phase and 1.b, by experience and training    Construction and Operating Phase.
in fire protection systems.
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  Byron/Braidwood complies with this Capability                          requirement. Specific plant areas for which alternate shutdown components or In areas where the fire protection  systems have been installed include the features cannot ensure safe        control room and the auxiliary electrical shutdown capability in the event    equipment room. Specific details for each of a fire in that area,            room are described in Section 2.4 of the alternative or dedicated safe      Fire Protection Report.
shutdown capability shall be provided.
III. Specific Requirements A. Water supplies for Fire Suppression Systems Two separate water supplies shall  The B/B design complies with these be provided to furnish necessary    requirements in Part A as described in water volume and pressure to the    Section 3.6.b and Appendix 5.4, Subsection fire main loop.                    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 [[estimated NRC review hours::2 hours]] 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  The B/B design complies with this post indicator valves or key-      requirement as described in Section operated valves shall be installed  3.6.b(2) and Appendix 5.4, Subsection 5.4.1 in the fire main loop to permit    of the FPR.
isolation of portions of the main fire main loop for maintenance or repair without interrupting the entire water supply.
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        The B/B design complies with this permit isolation of outside        requirement as described in Section hydrants from the fire main for    3.6.b(3) and Appendix 5.4, Subsection 5.4.1 maintenance or repair without      of the FPR.
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.
D. Manual Fire Suppression Standpipe and hose systems shall    B/B complies with exceptions as noted in be installed so that at least one  FPR Section 3.6.c(4) and Appendix 5.4, effective hose stream will be able  Subsection A5.4.7.
to reach any location that contains or presents an exposure fire hazard to structures, systems, or components important to safety.
Access to permit effective          B/B complies. Access routes for fire functioning of the fire brigade    fighting are listed in the Pre-Fire Plans.
shall be provided to all areas that contain or present an exposure fire hazard to structures, systems, or components important to safety.
Standpipe and hose stations, shall  B/B complies. See FPR Sections 2.3.1, be inside PWR containments and BWR  3.7.a, and Appendix 5.4, Subsection A5.4.7.
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 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  Byron/Braidwood comply by satisfying the tested at a pressure of 150 psi or  recommendations of NFPA 1962 and BTP CMEB 50 psi above maximum fire main      9.5.1. See also FPR Section 3.6.c(6).
operating pressure, whichever is greater. Hose stored in outside hose houses shall be tested annually. Interior standpipe hose shall be tested every three years.
F. Automatic Fire Detection Automatic fire detection systems    B/B complies. See FPR Section 3.6.a and shall be installed in all areas of  Appendix 5.4, Subsection A5.4.8.
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.
G. Fire Protection of Safe Shutdown Capability
: 1. Fire protection features      Byron/Braidwood complies with this shall be provided for          requirement. Certain plant configurations structures, systems, and      exist, each of which is described and components important to safe  justified below under the discussion for shutdown. These features      Section III.G.2 and Appendix A5.8, where shall be capable of limiting  separation of redundant safe shutdown fire damage so that:          components or systems is not as specified in Section III.G.2. Taking credit for the
: a. One train of systems      alternative separation and protection necessary to achieve and  features identified in these deviations maintain hot shutdown    from the requirements of Section III.G.2, conditions from either    one train of systems necessary to achieve the control room or      and maintain hot shutdown will remain free emergency control        of fire damage, and systems required to station(s) is free of    achieve and maintain cold shutdown will fire damage; and          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      achieved within [[estimated NRC review hours::72 hours]], for each fire achieve and maintain      area in the plant.
cold shutdown from either the control room or emergency control station(s) can be repaired within [[estimated NRC review hours::72 hours]].
: 2. Except as provided for        Deviations from the requirements of Section Paragraph G.3 of this          III.G.2 are described in Appendix A5.8 and section, where cables or      Generic Letter 86-10 evaluations. In each equipment, including          case, a detailed description of the associated non-safety          deviations is included, modifications (if circuits that could prevent    any) implemented as a result of the operation or cause            deviation are described, and a maloperation due to hot        justification for the deviation is shorts, open circuits, or      provided.
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:
: 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      Taking credit for the alternative shutdown capability and its    separation and protection features associated circuits,          described above for those plant areas which independent of cables,        deviate from the requirements of Section systems or components in the  III.G.2, Byron/Braidwood complies with this area, room or zone under      requirement.
consideration, shall be provided;
: a. Where the protection of systems whose function is required for hot shutdown does not satisfy the requirement of paragraph G.2 of this section; or
: b. Where redundant trains of systems required for hot shutdown located in the same fire area may be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems.
In addition, fire detection and a fixed fire suppression system shall be installed in the area, room, or zone under consideration.
H. Fire Brigade A site brigade trained and equipped  Byron and Braidwood comply, except as for fire fighting shall be          noted below. The fire brigade will meet established to ensure adequate      the requirements stated herein, except that manual fire fighting capability for  exception is taken to the performance all areas of the plant              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  annual physical examination. The wording components important to safety.    "ability to perform strenuous fire fighting The fire brigade shall be at least  activities" is lacking in specific detail and is five members on each shift. The    open to wide interpretation. The annual brigade leader and at least two    physical will demonstrate that fire brigade brigade members shall have          members are capable of performing unrestricted sufficient training in or          physical activity.
knowledge of plant safety-related systems to understand the effects  The Fire Protection Program Administrative of fire and fire suppressants on    Procedures sets forth the qualifications for the safe shutdown capability. The      members of the fire brigade. These requirements qualification of fire brigade      set forth the training and physical condition of members shall include an annual    the members of the brigade. All brigade members physical examination to determine  complete the training course set forth by the their ability to perform strenuous  Production Training Department Technical fire fighting activities. The      Training Section "Training Standard for Initial shift supervisor shall not be a    Training of Nuclear Station Fire Brigade member of the fire brigade. The    Members." A competent fire brigade leader will brigade leader shall be competent  respond to a fire.
to assess the potential safety consequences of a fire and advise  The Braidwood off-site fire department is the control room personnel. Such        primary responder in the event of a fire at the    Reference EC 361785.
competence by the brigade leader    Braidwood Lake Screen House (LSH). The site        Reference EC 368713 may be evidenced by possession of  Fire Brigade Chief may also respond to a fire at an operator's license or            the LSH. The Custer Park Fire Department is the equivalent knowledge of plant      primary responder in the event of a fire at the safety-related systems.            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.
The minimum equipment provided for  Comply. The Fire Protection Program the brigade shall consist of        Administrative Procedures provides the personal protective equipment such  requirement of the Fire Brigade inventory to be as turnout coats, boots, gloves,    performed and lists the equipment to be hard hats, emergency                inventoried.
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 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        Comply. The extra air bottles are included shall be located onsite for each      in inventory procedures for the fire self-contained breathing unit. In    brigade equipment. The 6-hour supply of addition, an onsite 6-hour supply    reserve air is supplied by a bank of of reserve air shall be provided      cylinders and/or bottles which is under the and arranged to permit quick and      control of the Rad-Chem department.
complete replenishment of            Compressors are not used to meet supply exhausted supply air bottles as      requirements for breathing air for the fire they are returned. If compressors    brigade.
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.
I. Fire Brigade Training The fire brigde training program      The fire brigade training program meets the shall ensure that the capability      requirements presented herein.
to fight potential fires is established and maintained. The      The fire brigade training program is program shall consist of an          administered through a Training Standard initial classroom instruction        for Nuclear Station Fire Brigade Members program followed by periodic          developed by the Braidwood Production classroom instruction, fire          Training Center.
fighting practice, and fire drills.
: 1. Instruction
: a. The initial classroom instruction shall include:
(1)    Indoctrination of  Byron and Braidwood comply with Parts a the plant fire      through e. See Fire Protection fighting plan with  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  All brigade members get the leadership coordination of    course.
the fire fighting activities (fire brigade leaders only).
(9)  Detailed review of  Training of fire-fighting strategies and fire fighting      procedures is included in the initial and strategies and      continued training.
procedures.
(10)  Review of the      This subject is covered during fire brigade latest plant        training.
modifications and corresponding changes in fire fighting plans.
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  Licensed qualified instructors from the provided by qualified    company training department or local fire individuals who are      department have provided the initial knowledgeable,            training of the fire brigade (Byron).
experienced, and suitably trained in      The training of the fire brigade is fighting the types of    conducted by a qualified member of the fires that could occur    training department. State-certified in the plant and in      members of the Fire Marshall's staff using the types of        monitor this training (Braidwood).
equipment available in the nuclear power plant.
: c. Instruction shall be provided to all fire brigade members and fire brigade leaders.
: d. Regular planned meetings  Comply. The Fire Protection Program sets shall be held at least    forth the requirements to hold planned every 3 months for all    meetings quarterly for all brigade members brigade members to        to review changes in the fire protection review changes in the    program, etc.
fire protection program and other subjects as necessary.
: e. Periodic refresher        Comply. Periodic refresher training is training sessions shall  included in the Training Standard for be held to repeat the    Nuclear Station Fire Brigade Members.
classroom instruction program for all brigade members over a two-year period. These sessions may be concurrent with the regular planned meetings.
: 2. Practice Practice sessions shall be held      Byron and Braidwood comply. Practice for each shift fire brigade on the  sessions in actual fire extinguishment and proper method of fighting the        use of emergency breathing apparatus under various types of fires that could    strenuous conditions is accomplished occur in a nuclear power plant.      through the annual fire extinguisher These sessions shall provide A5.7-19
 
B/B                          AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R                BYRON/BRAIDWOOD CONFORMANCE                  REMARKS brigade members with experience in  training on live fires and annual actual fire extinguishment and the  smokehouse/live fire training.
use of emergency breathing apparatus under strenuous          Practice sessions are also addressed in conditions encountered in fire      Administrative Procedures.
fighting. These practice sessions shall be provided at least once per year for each fire brigade member.
: 3. Drills
: a. Fire brigade drills shall be  Items 3a through 3e are accomplished by performed in the plant so    Administrative Procedures on Fire Drills.
that the fire brigade can    The type of drills and assessment of the practice as a team.          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  Comply except as noted below:
regular intervals not to exceed 3 months for each      Byron/Braidwood Stations will perform fire shift fire brigade. Each      brigade drill training such that the fire fire brigade member should    brigade drills once per quarter, so that participate in each drill,    each fire brigade member participates in at but must participate in at    least two fire brigade drills per year. The least two drills per year. brigade performs during the drill as a team. The members may not always be the A sufficient number of these  same personnel.
drills, but not less than 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          Comply. Individual records of training for training provided to each      each brigade member are retained by the fire brigade member,          training department and will be available including drill critiques,    for review. The drill critique is retained shall be maintained for at    in central file and will be available for least 3 years to ensure that  review.
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.
J. Emergency Lighting Emergency lighting units with at    B/B complies. Eight-hour, battery-powered least an 8-hour battery power        emergency lights are provided for plant supply shall be provided in all      areas that need to be manned for safe areas needed for operation of safe  shutdown and in access and egress routes shutdown equipment and in access    thereto. Testing will demonstrate the 8-and egress routes thereto.          hour rating of these units.
K. Administrative Controls Administrative controls shall be    Byron and Braidwood comply. Administrative established to minimize fire        controls will be in effect which will hazards in areas containing          comply with the requirements of this structures, systems, and            section.
components important to safety.
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      Comply. Administrative Procedures on "Fire limitation of the use of      Prevention For Use of Lumber and Other ordinary combustible          Combustibles" govern the handling and materials, combustible and    limitation of ordinary combustible flammable gases and liquids,  materials. Administrative Procedures on high efficiency particulate  "Control of Flammable and Combustible air and charcoal filters,    Liquids" govern the handling and limitation dry ion exchange resins, or  of flammable gases and liquids.
other combustible supplies    Administrative Procedures govern the in safety-related areas.      handling and usage of combustible/
flammable gas cylinders.
: 2. Prohibit the storage of      Comply. Routine fire prevention operator combustibles in safety-      rounds are performed on each shift by the related areas or establish    Equipment Operator or Equipment Attendant.
designated storage areas      Special periodic fire inspections are with appropriate fire        conducted in the storage areas inside or protection.                  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    Comply. Byron will incorporate into limit transient fire loads    administrative procedures provisions to such as combustible and      control transient combustibles. The flammable liquids, wood and  procedures will state that transient plastic products, or other    combustibles in safety-related areas, which combustible materials in      are not in approved containers, shall not buildings containing safety-  be left unattended.
related systems or equipment during all phases of          Administrative Procedures govern the operating and especially      handling of and limit transient fire loads during maintenance,          such as combustible and flammable liquids, modification, or refueling    wood and plastic products, compressed gas operations.                  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    Same procedures as in Item 1 above govern.
member responsible for the    Comply. The station Fire Marshall is the inplant fire protection      designated staff member as set forth in review of proposed work      Administrative Procedures.
activities to identify potential transient fire hazards and specify required additional fire protection in the work activity procedure.
: 5. Govern the use of ignition    Comply. The welding and flame cutting work sources by use of a flame    is done at each station in accordance with permit system to control      NFPA 51B.
welding, flame cutting, brazing, or soldering        Administrative Procedures cover preparation operations. A separate        and inspection for fire prevention when permit shall be issued for    welding and cutting is performed. It also each area where work is to    covers filling out cutting and welding be done. If work continues    permits and precautions during cutting over more than one shift,    and/or welding.
the permit shall be valid for not more than [[estimated NRC review hours::24 hours]] when the plant is operating or for the duration of a particular job during plant shutdown.
: 6. Control the removal from the  Comply. Administrative Procedures on area of all waste, debris,    "Station Housekeeping Equipment scrap, oil spills, or other  Preservation Procedure," specifies that combustibles resulting from  combustible material can not be left the work activity,            unattended in safety-related areas.
immediately following completion of the activity, or at the end of each work shift, whichever comes first.
: 7. Maintain the periodic        Comply. Administrative Procedure assures housekeeping inspections to  that good housekeeping inspections are met.
ensure continued compliance with these administrative controls.
: 8. Control the use of specific  Comply, with exceptions below:
combustibles in safety-related areas. All wood used in safety-related areas A5.7-25
 
B/B                          AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R                BYRON/BRAIDWOOD CONFORMANCE                  REMARKS during maintenance,          The reactor facility at Byron/Braidwood was modification, or refueling    designed to ensure that the probability of operations (such as lay-down  events such as fires and explosions and blocks or scaffolding) shall  other potential consequences of such events be treated with a flame      will not result in undue risk to the health retardant. Equipment or      and safety of the public. Noncombustible supplies (such as new fuel)  and fire resistant materials were used shipped in untreated          throughout the facility wherever necessary combustible packing          to preclude such risks, particularly in containers may be unpacked    areas containing critical portions of the in safety-related areas if    facility such as containment, control room, required for valid operating  and components of engineered safety reasons. However, all        features.
combustible materials shall be removed from the area      Combustible materials are not used when immediately following the    substitutes are available. When unpacking. Such transient    combustible materials are used, they are combustible materials,        treated with fire retardant material or unless stored in approved    they are controlled as to their fire containers, shall not be      hazard.
left unattended during lunch breaks, shift changes, or    The control and use of specific other similar periods.        combustibles in safety-related areas is Loose combustible packing    assured by Administrative Procedures on material such as wood or      "Fire Protection for Use of Lumber and paper excelsior, or          Other Combustibles."
polyethylene sheeting shall be placed in metal            Exception is taken in regards to new fuel containers with tight-        which is stored wrapped in polyethylene fitting self-closing metal    bags for cleanliness requirements.
covers.
: 9. Control actions to be taken  Comply. Administrative Procedures on "Fire by an individual discovering  and Emergency Notification and Evacuation a fire. For example,          Plan" states actions to be taken by an notification of control      individual discovering a fire.
room, attempt to extinguish fire, and actuation of local  Comply. Administrative Procedures on "Fire fire suppression systems. Protection Program", states actions to be taken by an individual discovering a fire.
: 10. Control actions to be taken  Comply. Administrative Procedures on by the control room operator  "Fire and Emergency Notification and to determine the need for    Evacuation Plan" states the actions to be brigade assistance upon      taken by the control room operator on the report of a fire or receipt  report of a fire.
of alarm on control room annunciator panel, for A5.7-26
 
B/B                          AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R                  BYRON/BRAIDWOOD CONFORMANCE                  REMARKS example, announcing location    Administrative Procedures also describe the of fire over PA system,        sequence of events to take place in the sounding fire alarms, and      event of a fire at the Braidwood Station.
notifying the shift            Operating procedures address "Plant Wide supervisor and the fire        Fire Alarm Actuation."
brigade leader of the type, size, and location of the fire.
: 11. Control actions to be taken    Comply. The actions to be taken by the by the fire brigade after      fire brigade after notification by the notification by the control    control room operator of a fire is room operator of a fire, for    identified in Administrative Procedures.
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.
: 12. Define the strategies for      Comply, with exceptions noted below.
fighting fires in all          Pre-fire plans have been developed which safety-related areas and        address the concerns listed here as areas presenting a hazard to    described below.
safety-related equipment.
These strategies shall designate:
: a. Fire hazards in each      Comply. The pre-fire plans identify major area covered by the      in situ combustibles for the areas they specific pre-fire plans. cover.
: b. Fire extinguishants best  The pre-fire plans identify all automatic suited for controlling    and manual suppression equipment in the the fires associated      area, and its location. The extinguishing with the fire hazards in  methods provided are chosen to be the best that area and the        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  The pre-fire plans identify available      Particularly for large rooms and from which to attack a    access routes for each zone. The most      general areas, the number of possible fire in each area in      favorable direction or location to fight    fire locations are too numerous to view of the ventilation  specific fires from are not identified. attempt to develop specific strategies direction, access        The fire brigade can best determine this    beforehand.
hallways, stairs, and    upon reaching the scene of an actual fire.
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.
: d. Plant systems that        Important plant systems and components and should be managed to      potentially hazardous electrical components reduce the damage        are identified in the pre-fire plans.
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).
: e. Vital heat-sensitive      Comply. Vital components have been defined system components that    in pre-fire plans.
need to be kept cool while fighting a local fire. Particularly hazardous combustibles 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      Byron and Braidwood comply. See fighting brigades and    Administrative Procedures at the stations.
the assignment of        All fire brigade members receive all of the special duties according  specialized training mentioned here.
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. Potential radiological    Comply. Potential radiological and toxic and toxic hazards in      hazards are identified in the pre-fire fire zones.              plans.
: h. Ventilation system        Comply. Ventilation system operation for operation that ensures    smoke removal is addressed. Ventilation desired plant air        system design is such that fires in distribution when the    specific rooms will affect only the ventilation flow is      ventilation for that room or division.
modified for fire containment or smoke clearing operations.
: i. Operations requiring      Fire fighting operations per se are not control room and shift    expected to require control room or shift engineer coordination or  engineer coordination.
authorization.
: j. Instructions for plant    This is addressed by station procedures operators and general    other than the pre-fire plans.
plant personnel during fire.
A5.7-29
 
B/B                                                  AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R                  BYRON/BRAIDWOOD CONFORMANCE                    REMARKS L. Alternative and Dedicated Shutdown Capability
: 1. Alternative or dedicated      Byron and Braidwood comply. Alternate shutdown capability provided  shutdown components or systems are provided for a specific fire area      for all plant areas where the separation shall be able to achieve and  requirements of Section III.G cannot be maintain subcritical          met. The requirements stated herein are reactivity conditions in the  met as described in Section 2.4 of the Fire reactor, maintain reactor      Protection Report.
coolant inventory, achieve and maintain hot standby7 conditions for a PWR (hot shutdown7 for a BWR) and achieve cold shutdown7 conditions within [[estimated NRC review hours::72 hours]] 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.
: 2. The performance goals for      Byron/Braidwood complies with this          The performance goals listed have been the shutdown functions shall  requirement as described in Section 2.4 of  implemented in conducting the Safe be:                            the Fire Protection Report.                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    Byron/Braidwood complies with this specific fire areas may be    requirement. Refer to Section 2.4 of the unique for each such area,    Fire Protection Report for a description of or it may be one unique        safe shutdown capability for each fire combination of systems for    zone.
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 [[estimated NRC review hours::72 hours]].
Procedures shall be in effect to implement this capability.
A5.7-31
 
B/B                          AMENDMENT 13 DECEMBER 1990 10 CFR 50 APPENDIX R                BYRON/BRAIDWOOD CONFORMANCE                REMARKS
: 4. In the capability to achieve  B/B complies. Refer to Safe Shutdown and maintain cold shutdown    Analysis, (Section 2.4 of FPR).
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.
: 5. Equipment and systems        Byron/Braidwood complies with this comprising the means to      requirement provided credit is taken for achieve and maintain cold    alternative separation and protection shutdown conditions shall    features for certain plant areas described not be damaged by fire; or    above under Section III.G.2.
the fire damage to such equipment and systems shall be limited so that the systems can be made operable and cold shutdown achieved within [[estimated NRC review hours::72 hours]]. 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 [[estimated NRC review hours::72 hours]] after the fire will not be capable of being powered by both onsite and offsite electrical power systems because of fire 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 [[estimated NRC review hours::72 hours]] may be powered by offsite power only.
: 6. Shutdown systems installed    Byron/Braidwood complies with this to ensure postfire shutdown  requirement. The only equipment which has capability need not be        been installed to ensure postfire safe designed to meet seismic      shutdown capability is the Fire Hazards Category I criteria, single  Panel which includes certain instruments failure criteria, or other    which would otherwise be unavailable design basis accident        following a fire in either the control room criteria, except where        or the auxiliary electrical equipment room.
required for other reasons,  This panel is described in Subsection e.g., because of interface    2.4.2.16 of the Fire Protection Report.
with or impact on existing    Its design complies with the requirements safety systems, or because    stated herein.
of adverse valve actions due to fire damage.
: 7. The safe shutdown equipment  There are no associated circuits as defined and systems for each fire    in IEEE 384-1974 at B/B. Associated area shall be known to be    circuits as defined in NRC's April 6, 1982, isolated from associated      clarification letters to Generic Letter non-safety circuits in the    81-12 are addressed in Subsection 2.4.1 of fire area so that hot        the Fire Protection Report.
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.
A5.7-33
 
B/B                          AMENDMENT 19 DECEMBER 2000 10 CFR 50 APPENDIX R                BYRON/BRAIDWOOD CONFORMANCE                  REMARKS M. Fire Barrier Cable Penetration      B/B complies. See FPR Sections 3.5(a)
Seal Qualification                  (3)(a) through (c) and Appendix 5.2, Subsection A5.2.2. Fire-rated penetration Penetration seal designs shall      seals in fire-rated assemblies separating utilize only noncombustible        safety-related fire areas or separating materials and shall be qualified    portions of redundant systems important to by tests that are comparable to    safe shutdown within a fire area are tests used to rate fire barriers. inspected by Surveillance Procedures. See The acceptance criteria for the    contractors test reports for details on the test shall include:                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; and
: 3. 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    Byron/Braidwood complies. See FPR Section or provided with closing            3.5.a (5).
mechanisms and shall be inspected semiannually to verify that automatic hold-open, release, and closing mechanisms and latches are operable.
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      All fire doors have automatic closures.
closed and electrically      Cable spreading rooms have electrically supervised at a continuously  supervised doors alarming in the control manned location;              room.
: 2. Fire doors shall be locked    Personnel will walk down fire doors, which and inspected weekly to      are unlocked or nonelectrically supervised, verify that the doors are in  once per day at Braidwood and every 7 days the closed position;          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; 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 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  B/B complies.
Coolant Pump A drip pan system which meets the The reactor coolant pump shall be  guidelines of Appendix R to 10 CFR 50 has equipped with an oil collection    been designed for the reactor coolant pump system if the containment is not  (RCP) motors for the Byron/Braidwood inerted during normal operation. 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    Seven drip pans will be installed on each lead to fire during normal or      pump. These seven pans will collect oil design basis accident conditions    drips from all potential leakage points and and that there is reasonable        route this oil to a safe collection point.
assurance that the system will      The following seven pans are installed on withstand the Safe Shutdown        each pump:
Earthquake.9
: a. A drip pan inside the motor housing Such collection systems shall be        below the lower motor bearing.
capable of collecting lube oil from all potential pressurized and  b. A drip pan under the bottom of the oil unpressurized leakage sites in the      cooler.
reactor coolant pump lube oil systems. Leakage shall be          c. A drip pan around the oil cooler under collected and drained to a vented        the upper flange.
closed container that can hold the entire lube oil system inventory. d. A drip pan which encloses the oil lift A flame arrester is required in          pump.
the vent if the flash point characteristics of the oil present  e. A drip pan under the oil level alarm the hazard of fire flashback.            and sight gauge.
Leakage points to be protected shall include lift pump and        f. A drip pan under the flange on the oil piping, overflow lines, lube oil        line from the RCP motor to the oil cooler, oil fill and drain lines,        cooler inlet.
and plugs, flanged connections on oil lines, and lube oil reservoirs  g. A drip pan under the flange on the oil where such features exist on the        line from the oil cooler outlet to the reactor coolant pumps. The drain        RCP motor; this pan also encompasses line shall be large enough to            the oil drain valve connection.
accommodate the largest potential oil break.                          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  This configuration does not present a 401 feet 0 inch in the Fuel Handling        similar fire hazard as an inservice RCP Building at Braidwood. The RCP assembly    inside containment. The hazard contains 240 gallons of lubricating oil. presented by the spare RCP An oil collection system is not provided. configuration without an oil collection Except during a periodic preventative      system has been evaluated, and the maintenance surveillance to rotate the      design features are adequate for the motor, the oil is not normally pressurized. level of hazard.
A5.7-37
 
BRAIDWOOD - FPR    AMENDMENT 24 DECEMBER 2010 APPENDIX 5.8 DEVIATIONS FROM BRANCH TECHNICAL POSITION CMEB 9.5-1 SECTION C.5.b A5.8-i
 
BRAIDWOOD - FPR      AMENDMENT 25 DECEMBER 2012 TABLE OF CONTENTS A5.8    DEVIATIONS FROM BTP CMEB 9.5-1 SECTION C.5.b            PAGE A5.8.1  Deviation No.: 0A.1 (Fire Zone 2.1-0)                  A5.8-1 A5.8.2  Deviation No.: 0A.2 (Fire Zone 11.3-0)                  A5.8-2 A5.8.3  Deviation No.: 0A.3 (Fire Zone 11.4-0)                  A5.8-4 A5.8.4  Deviation No.: 0A.4 (Fire Zone 11.4C-0)                A5.8-6 A5.8.5  Deviation No.: 0A.5 (Fire Zone 11.5-0)                  A5.8-7 A5.8.6  Deviation No.: 0A.6 (Fire Zone 11.6-0)                  A5.8-8 A5.8.7  Deviation No.: 0A.7 (Fire Zone 11.7-0)                  A5.8-9 A5.8.8  Deviation No.: 1A.1 (Fire Zone 18.3-1)                  A5.8-12 A5.8.9  Deviation No.: 1A.2 (Fire Zone 11.2A-1 & 11.2D-1)      A5.8-15 A5.8.10 Deviation No.: 1A.3 (Fire Zone 5.5-1)                  A5.8-17 A5.8.11 Deviation No.: 1A.4 (Fire Zone 3.2A-1)                  A5.8-18 A5.8.12 Deviation No.: 1A.5 (Fire Zone 3.2B-1)                  A5.8-19 A5.8.13 Deviation No.: 1C.1 (Fire Zone 1-1)                    A5.8-20 A5.8.14 Deviation No.: 2A.1 (Fire Zone 18.3-2)                  A5.8-33 A5.8.15 Deviation No.: 2A.2 (Fire Zone 11.2A-2 & 11.2D-2)      A5.8-36 A5.8.16 Deviation No.: 2A.3 (Fire Zone 5.5-2)                  A5.8-38 A5.8.17 Deviation No.: 2C.1 (Fire Zone 1-2)                    A5.8-39 A5.8 - ii
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 A5.8 DEVIATIONS FROM SECTION C.5.b OF BTP CMEB 9.5-1 INTRODUCTION This 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".
A5.8 - iii
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 A5.8.1        Deviation 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 Involved 451 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.
A5.8 - 1
 
BRAIDWOOD - FPR                AMENDMENT 25 DECEMBER 2012 A5.8.2          Deviation 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 Involved 364 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:
A5.8 - 2
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 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.
A5.8 - 3
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 A5.8.3        Deviation 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 in Fire 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, A5.8 - 4
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 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.
A5.8 - 5
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 A5.8.4          Deviation 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 in Fire 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.
A5.8 - 6
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 A5.8.5        Deviation 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.
A5.8 - 7
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 A5.8.6        Deviation 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.
A5.8 - 8
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 A5.8.7          Deviation 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 Involved Auxiliary 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 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 installation of fire detectors and an automatic suppression system in the area. As previously stated, no fire barriers are A5.8 - 9
 
BRAIDWOOD - FPR                    AMENDMENT 25 DECEMBER 2012 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 A5.8 - 10
 
BRAIDWOOD - FPR                AMENDMENT 25 DECEMBER 2012 provided for major safe shutdown components. Thus, a level of protection equivalent to that of Section C.5.B(2) is achieved.
A5.8 - 11
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 A5.8.8          Deviation No: 1A.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 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 Involved The 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 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 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 A5.8 - 12
 
BRAIDWOOD - FPR                    AMENDMENT 25 DECEMBER 2012 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 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.
A5.8 - 13
 
BRAIDWOOD - FPR                    AMENDMENT 25 DECEMBER 2012 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.
A5.8 - 14
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 A5.8.9            Deviation 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 Involved The 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 [[estimated NRC review hours::72 hours]] after a fire.
A5.8 - 15
 
BRAIDWOOD - FPR                AMENDMENT 25 DECEMBER 2012 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.
A5.8 - 16
 
BRAIDWOOD - FPR                    AMENDMENT 25 DECEMBER 2012 A5.8.10        Deviation 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 Involved 451 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.
A5.8 - 17
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 A5.8.11      Deviation 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.
A5.8 - 18
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 A5.8.12        Deviation 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 in Fire 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 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.
A5.8 - 19
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 A5.8.13        Deviation 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 Involved Unit 1 Containment (Fire Zone 1-1)
A5.8.13.1      Description 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.
A5.8.13.1      Description 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.
A5.8 - 20
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 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.)
A5.8.13.1      Justification for Deviation Within 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, A5.8 - 21
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 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.
A5.8.13.2      Description of Equipment/Cables Involved Steam 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.
A5.8.13.2      Description of Deviation All 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.)
A5.8 - 22
 
BRAIDWOOD - FPR                    AMENDMENT 25 DECEMBER 2012 A5.8.13.2      Justification 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.
A5.8.13.3      Description of Equipment/Cables Involved Source Range Neutron Monitoring Instruments Two 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 A5.8 - 23
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 barrier. After passing through the missile barrier, the cable follows along the exterior containment wall to an electrical penetration between azimuth R8 and R9.
A5.8.13.3      Description 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.)
A5.8.13.3      Justification 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 A5.8 - 24
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 negligible 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.
A5.8.13.4      Description 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.
A5.8.13.4      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 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.)
A5.8 - 25
 
BRAIDWOOD - FPR                    AMENDMENT 25 DECEMBER 2012 A5.8.13.4      Justification 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.
A5.8.13.5      Description 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.
A5.8.13.5      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 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 A5.8 - 26
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 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.5 in FPR Amendment 20.)
A5.8.13.5    Justification 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, A5.8 - 27
 
BRAIDWOOD - FPR                    AMENDMENT 25 DECEMBER 2012 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.
A5.8.13.6      Description 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 A5.8 - 28
 
BRAIDWOOD - FPR                AMENDMENT 25 DECEMBER 2012 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.
A5.8.13.6      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. (This deviation was previously identified as deviations 1C.6 in FPR Amendment 20.)
A5.8.13.6      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.
A5.8 - 29
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 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.
A5.8.13.7      Description 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 A5.8 - 30
 
BRAIDWOOD - FPR                    AMENDMENT 25 DECEMBER 2012 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.
A5.8.13.7      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.
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.)
A5.8.13.7      Justification 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 (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.
A5.8 - 31
 
BRAIDWOOD - FPR                    AMENDMENT 25 DECEMBER 2012 A5.8.13.8      Description of Equipment/Cables Involved Reactor Containment Fan Cooler (RCFC) Fans Two 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.
A5.8.13.8      Description of Deviation All 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.)
A5.8.13.8      Justification 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.
A5.8 - 32
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 A5.8.14        Deviation No: 2A.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 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 Involved The 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 A5.8 - 33
 
BRAIDWOOD - FPR                    AMENDMENT 25 DECEMBER 2012 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.
A5.8 - 34
 
BRAIDWOOD - FPR                    AMENDMENT 25 DECEMBER 2012 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.
A5.8 - 35
 
BRAIDWOOD - FPR                AMENDMENT 25 DECEMBER 2012 A5.8.15        Deviation 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 Involved RHR pump 2A and its cubicle cooler are located in Fire Zone 11.2A-2. RHR pump 2B 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 separated from 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 [[estimated NRC review hours::72 hours]] after a fire.
A5.8 - 36
 
BRAIDWOOD - FPR                AMENDMENT 25 DECEMBER 2012 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.
A5.8 - 37
 
BRAIDWOOD - FPR                    AMENDMENT 25 DECEMBER 2012 A5.8.16        Deviation 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 Involved 451 feet 0 inch (Fire Zone 5.5-2)
Description of Equipment/Cables Involved The 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.
A5.8 - 38
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 A5.8.17        Deviation 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 Involved Unit 2 Containment (Fire Zone 1-2)
A5.8.17.1      Description 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 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.
A5.8.17.1      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, 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.
A5.8 - 39
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 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.)
A5.8.17.1      Justification for Deviation Within 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 A5.8 - 40
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 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.
A5.8.17.2      Description of Equipment/Cables Involved Steam 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.
A5.8.17.2      Description of Deviation All 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.)
A5.8.17.2      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 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 A5.8 - 41
 
BRAIDWOOD - FPR                    AMENDMENT 25 DECEMBER 2012 redundant cables is considered to be adequate to preclude a single fire from damaging all four of these safe shutdown instruments.
A5.8.17.3      Description of Equipment/Cables Involved Source Range Neutron Monitoring Instruments Two 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.
A5.8.17.3      Description 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 A5.8 - 42
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 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.)
A5.8.17.3      Justification 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.
A5.8 - 43
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 A5.8.17.4      Description 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.
A5.8.17.4      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 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.)
A5.8.17.4      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 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.
A5.8.17.5      Description of Equipment/Cables Involved A5.8 - 44
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 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.
A5.8.17.5      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 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.)
A5.8.17.5      Justification 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.
A5.8.17.6      Description of Equipment/Cables Involved A5.8 - 45
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 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 A5.8 - 46
 
BRAIDWOOD - FPR                  AMENDMENT 25 DECEMBER 2012 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.
A5.8.17.6      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 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.)
A5.8.17.6      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 A5.8 - 47
 
BRAIDWOOD - FPR                    AMENDMENT 25 DECEMBER 2012 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.
A5.8.17.7      Description 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.
A5.8.17.7      Description 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.
A5.8 - 48
 
BRAIDWOOD - FPR                    AMENDMENT 25 DECEMBER 2012 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.)
A5.8.17.7      Justification 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 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.
A5.8.17.8      Description of Equipment/Cables Involved Reactor Containment Fan Cooler (RCFC) Fans Two 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.
A5.8.17.8      Description of Deviation A5.8 - 49
 
BRAIDWOOD - FPR                    AMENDMENT 25 DECEMBER 2012 All 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.)
A5.8.17.8      Justification 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.
A5.8 - 50
 
BYRON - FPR        AMENDMENT 20 DECEMBER 2002 APPENDIX 5.8 DEVIATIONS FROM BRANCH TECHNICAL POSITION CMEB 9.5-1 SECTION C.5.b A5.8 - i
 
BYRON - FPR          AMENDMENT 20 DECEMBER 2002 TABLE OF CONTENTS A5.8    DEVIATIONS FROM BTP CMEB 9.5-1 SECTION C.5.b              PAGE A5.8.1  Deviation No.: 0A.1 (Fire Zone 11.3-0)                  A5.8-1 A5.8.2  Deviation No.: 0A.2 (Fire Zone11.7-0)                    A5.8-3 A5.8.3  Deviation No.: 1A.1 (Fire Zone 18.3-1)                  A5.8-6 A5.8.4  Deviation No.: 1A.2 (Fire Zone 11.2A-1 & 11.2D-1)        A5.8-9 A5.8.5  Deviation No.: 1A.3 (Fire Zone 2.1-0)                    A5.8-11 A5.8.6  Deviation No.: 1A.4 (Fire Zone 5.5-1)                    A5.8-12 A5.8.7  Deviation No.: 1A.5 (Fire Zone 11.4C-0)                  A5.8-13 A5.8.8  Deviation No.: 1A.6 (Fire Zone 11.4-0)                  A5.8-14 A5.8.9  Deviation No.: 1A.7 (Fire Zone 11.4-0)                  A5.8-16 A5.8.10 Deviation No.: 1A.8 (Fire Zone 11.5-0)                  A5.8-18 A5.8.11 Deviation No.: 1A.9 (Fire Zone 11.6-0)                  A5.8-19 A5.8.12 Deviation No.: 1A.10 (Fire Zone 3.2B-1)                  A5.8-21 A5.8.13 Deviation No.: 1C.1 (Fire Zone 1-1)                      A5.8-22 A5.8.14 Deviation No.: 2A.1 (Fire Zone 18.3-2)                  A5.8-34 A5.8.15 Deviation No.: 2A.2 (Fire Zone 11.2A-2 & 11.2D-2)        A5.8-37 A5.8.16 Deviation No.: 2A.3 (Fire Zone 2.1-0)                    A5.8-39 A5.8.17 Deviation No.: 2A.4 (Fire Zone 5.5-2)                    A5.8-40 A5.8.18 Deviation No.: 2A.5 (Fire Zone 11.4C-0)                  A5.8-41 A5.8.19 Deviation No.: 2A.6 (Fire Zone 11.4-0)                  A5.8-42 A5.8.20 Deviation No.: 2A.7 (Fire Zone 3.2B-1)                  A5.8-44 A5.8.21 Deviation No.: 2A.8 (Fire Zone 11.5-0)                  A5.8-45 A5.8.22 Deviation No.: 2A.9 (Fire Zone 11.6-0)                  A5.8-46 A5.8.23 Deviation No.: 2C.1 (Fire Zone 1-2)                      A5.8-47 A5.8 - ii
 
BYRON - FPR                      AMENDMENT 20 DECEMBER 2002 A5.8 DEVIATIONS FROM SECTION C.5.b OF BTP CMEB 9.5-1 INTRODUCTION This 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".
A5.8 - iii
 
AMENDMENT 25 DECEMBER 2012 A5.8.1        Deviation 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 Involved 364 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 A5.8 - 1
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8 - 2
 
AMENDMENT 25 DECEMBER 2012 A5.8.2        Deviation 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 Involved Auxiliary 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 A5.8 - 3
 
AMENDMENT 25 DECEMBER 2012 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 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 A5.8 - 4
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8 - 5
 
AMENDMENT 25 DECEMBER 2012 A5.8.3        Deviation No: 1A.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 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 Involved The 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 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 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 A5.8 - 6
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8 - 7
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8 - 8
 
AMENDMENT 25 DECEMBER 2012 A5.8.4        Deviation 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 Involved The 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.
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 [[estimated NRC review hours::72 hours]] after a fire.
A5.8 - 9
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8 - 10
 
AMENDMENT 25 DECEMBER 2012 A5.8.5        Deviation 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 Involved 451 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.
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.
A5.8 - 11
 
AMENDMENT 25 DECEMBER 2012 A5.8.6          Deviation 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 Involved 451 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.
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.
A5.8 - 12
 
AMENDMENT 25 DECEMBER 2012 A5.8.7        Deviation 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 Involved The redundant cables and equipment required for safe shutdown and located in Fire 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 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.
Justification for Deviation(s)
Fire Zone 11.4C-0 is separated from the rest of the plant by 3-hour-rated fire barriers and is a controlled access area. The remote shutdown control panels for Unit 1 are separated from those for Unit 2 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 room with the remote shutdown panel, which annunciate and alarm in the control room. The fire load is moderately low and the bulk of combustible materials 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 a fire in this room will not affect the instruments in the control room.
In summary, the low combustible loading, automatic fire detection and manual suppression capabilities, controlled access, 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.
A5.8 - 13
 
AMENDMENT 25 DECEMBER 2012 A5.8.8        Deviation 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 Involved The redundant cables and equipment required for safe shutdown and located in Fire 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 are located throughout this area. This area lacks fixed suppression and contains combustible material and has separation distances which are less than 20 feet all 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 barrier around 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 conduit and tray with cable 1SX001 will be wrapped from Q/13 to L/13. The risers and trays from L/11 to L/13 will be completely wrapped. In addition, the centrifugal charging pump cubicle cooler fan fed from MCC 131X3 will be moved to another MCC completely independent of this zone. With these modifications complete, the loss of both MCCs 131X3 and 132X3 will be acceptable since the essential service water cubicle coolers will function properly with only two out of four fans in service. This room is a large open area with a low combustible loading.
Area-wide detection is provided, and manual suppression capability is also present.
Subsequent to the above modifications, the component cooling pump 1A power cable and the essential service water pump 1A power cable are rerouted out of Fire Zone 11.4-0, where redundant cables are present. An evaluation has shown that the charging pumps and the essential service water pumps can perform their design function for the [[estimated NRC review hours::72 hours]] needed to take the plant to cold shutdown without the support of the room cubicle coolers. In addition, the remaining safe shutdown cables in this fire zone have been determined not to require protection based on an evaluation which demonstrated that alternate equipment and cabling would be available or local manual actions could be performed as described in station procedures in the event of a fire in this zone.
Therefore, the 3-hour fire-rated barrier described previously as installed around the A5.8 - 14
 
AMENDMENT 25 DECEMBER 2012 Division 11 trays, risers, and conduits on Elevation 383 feet 0 inch is no longer required and will not be replaced.
In summary, the low combustible loading, automatic fire detection and manual suppression capabilities, controlled access, 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.
A5.8 - 15
 
AMENDMENT 25 DECEMBER 2012 A5.8.9          Deviation 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 Involved The redundant cables and equipment required for safe shutdown and located in Fire 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.
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 area outside. This pump can be manually started from a local control panel in this room, and it will operate 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 both 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 12 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 pump 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 pump can be manually started in the case of a fire in Fire Zone 11.4-0.
Cables 1AF346 and 1AF338 routed through Fire Zone 11.4-0 supply a low-low suction pressure signal that could trip the 1B auxiliary feedwater pump. If this happens, the 1B pump can be manually started even if cables 1AF346 and 1AF338 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 1B AFW pump can be started locally if a fire destroyed these cables. Although cables for both AFW pumps are A5.8 - 16
 
AMENDMENT 25 DECEMBER 2012 present in the same area in Fire Zone 11.4-0 and could be damaged by a single fire, the Division 12 diesel-driven AFW can still be manually started and operated.
A5.8 - 17
 
AMENDMENT 25 DECEMBER 2012 A5.8.10        Deviation 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 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)
The redundant safe shutdown equipment and/or cables in Fire Zone 11.5-0 are located throughout this area. This area lacks fixed suppression and contains combustible material and has separation distances which are less than 20 feet all 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-rated barrier around Division 11 cable trays containing redundant safe shutdown cables in three locations. The risers at 13-15/Q, the trays and risers along Row L between 11 and 12, and the trays and risers by 11/P-Q will all be protected.
The component cooling pump 1A power cable and the essential service water pump 1A power cable are rerouted out of Fire Zone 11.5-0 where redundant cables are present.
An evaluation also shows that the charging pumps and the essential service water pumps can perform their design function for the [[estimated NRC review hours::72 hours]] needed to take the plant to cold shutdown without the support of the room cubicle coolers. 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 and cabling would be available for a fire in this fire zone or that local manual actions could be performed as described in the station procedures. Therefore, the 3-hour fire-rated barrier installed around the Division 11 trays and risers on Elevation 401 feet 0 inch is no longer required and will not be replaced.
In summary, the low combustible loading, automatic fire detection and manual suppression capabilities, controlled access, 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.
A5.8 - 18
 
AMENDMENT 25 DECEMBER 2012 A5.8.11        Deviation 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 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)
The redundant safe shutdown equipment and/or cables in Fire Zone 11.6-0 are located throughout this area. This area lacks fixed suppression and contains combustible material and has separation distances which are less than 20 feet all 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 ESF switchgear supply fan to another MCC, independent of this zone. Also, the control cable for the Division 12 MEER supply fan will be re-routed to avoid this zone. Upon completion of this modification, MCC 132X5 will not serve any equipment 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 supply fan for the miscellaneous electric equipment room remains operational after a fire. 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 transfer pump is required to provide sufficient flow of diesel fuel oil for continuous operation of an emergency diesel generator. Thus, safe shutdown would not be prevented by a fire in this zone. This zone is a large open area with a low combustible load. Area-wide detection and manual suppression capability are provided. Because of this, and the modification being implemented, a level of protection 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 vent fan 1VX01C control cable is rerouted out of Fire Zone 11.6-0. Control cable 1VE042 (which replaced 1VE028) was to be protected with a 3-hour barrier. Reanalysis shows that this cable is not required for safe shutdown. As a result, the barrier will not be replaced and the cable will not be rerouted.
A5.8 - 19
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8 - 20
 
AMENDMENT 25 DECEMBER 2012 A5.8.12        Deviation 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 Involved The redundant cables and equipment required for safe shutdown and located in Fire 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 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.
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 that specified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
A5.8 - 21
 
AMENDMENT 25 DECEMBER 2012 A5.8.13                Deviation 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 Involved Unit 1 Containment (Fire Zone 1-1)
A5.8.13.1      Description 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 Deviation Due 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.
A5.8 - 22
 
AMENDMENT 25 DECEMBER 2012 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 Deviation Within 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 A5.8 - 23
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8.13.2      Description of Equipment/Cables Involved Steam 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 Deviation All 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 A5.8 - 24
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8.13.3      Description of Equipment/Cables Involved Source Range Neutron Monitoring Instruments Two 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 401 feet 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 A5.8 - 25
 
AMENDMENT 25 DECEMBER 2012 R11. 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 cables are 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 and the 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.
A5.8.13.4      Description 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 A5.8 - 26
 
AMENDMENT 25 DECEMBER 2012 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 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 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.
A5.8.13.5      Description of Equipment/Cables Involved Pressurizer Level Instrumentation A5.8 - 27
 
AMENDMENT 25 DECEMBER 2012 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.
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.
A5.8.13.6      Description of Equipment/Cables Involved A5.8 - 28
 
AMENDMENT 25 DECEMBER 2012 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 A5.8 - 29
 
AMENDMENT 25 DECEMBER 2012 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 A5.8 - 30
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8.13.7      Description 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.
A5.8 - 31
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8.13.8      Description of Equipment/Cables Involved Reactor Containment Fan Cooler (RCFC) Fans Two 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 A5.8 - 32
 
AMENDMENT 25 DECEMBER 2012 All 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.
A5.8 - 33
 
AMENDMENT 25 DECEMBER 2012 A5.8.14        Deviation No: 2A.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 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 Involved The 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 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 A5.8 - 34
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8 - 35
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8 - 36
 
AMENDMENT 25 DECEMBER 2012 A5.8.15        Deviation 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 Involved RHR pump 2A and its cubicle cooler are located in Fire Zone 11.2A-2. RHR pump 2B 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. 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 separated from 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.
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 all 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-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 [[estimated NRC review hours::72 hours]] after a fire.
A5.8 - 37
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8 - 38
 
AMENDMENT 25 DECEMBER 2012 A5.8.16        Deviation 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 1 main control room), and for which alternate or dedicated shutdown capability is provided.
Fire Zone(s) or Elevations Involved 451 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.
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 III.G.2, 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 limited local manual operations, cold shutdown 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.
A5.8 - 39
 
AMENDMENT 25 DECEMBER 2012 A5.8.17        Deviation No: 2A.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 2 Auxiliary Electric Equipment Room), and for which alternate or dedicated shutdown capability is provided.
Fire Zone(s) or Elevations Involved 451 feet 0 inch (Fire Zone 5.5-2)
Description of Equipment/Cables Involved The 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.
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.
A5.8 - 40
 
AMENDMENT 25 DECEMBER 2012 A5.8.18        Deviation No: 2A.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 (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 Involved The redundant cables and equipment required for safe shutdown and located in Fire 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 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.
Justification for Deviation(s)
Fire Zone 11.4C-0 is separated from the rest of the plant by 3-hour-rated fire barriers and is a controlled access area. The remote shutdown control panels for Unit 1 are separated from those for Unit 2 by approximately 90 feet. One manual hose station and portable fire extinguishers are available in this zone. Ionization detectors are provided throughout the fire zone, including the room with the remote shutdown panel, which annunciate and alarm in the control room. The fire load is moderately low and the bulk of combustible materials 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 a fire in this room will not affect the instruments in the control room.
In summary, the low combustible loading, automatic fire detection and manual suppression capabilities, controlled access, 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.
A5.8 - 41
 
AMENDMENT 25 DECEMBER 2012 A5.8.19        Deviation 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 Involved The redundant cables and equipment required for safe shutdown and located in Fire 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 and 2B routed 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.
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 area outside. This pump can be manually started from a local control panel in this room, and it will operate 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 both 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 22 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 pump 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 pump can be manually started in the case of a fire in Fire Zone 11.4-0.
Cables 2AF346 and 2AF338 (which are routed in Fire Zone 11.4-0 in a modification subsequent to this deviation) supply a lo-lo suction pressure signal that could trip the 2B auxiliary feedwater (AFW) pump. To preclude this from happening, a modification is implemented to allow the 2B pump to be manually started even if these cables, 2AF346 and 2AF338, are damaged by fire. Besides these cables, several other cables associated with both AFW pumps are routed through Fire Zone 11.4-0; however, an A5.8 - 42
 
AMENDMENT 25 DECEMBER 2012 evaluation has shown that the 2B AFW pump can be started locally if a fire destroyed these cables.
A5.8 - 43
 
AMENDMENT 25 DECEMBER 2012 A5.8.20        Deviation 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 Involved The redundant cables and equipment required for safe shutdown and located in Fire 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 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.
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 that specified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
A5.8 - 44
 
AMENDMENT 25 DECEMBER 2012 A.5.8.21      Deviation 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 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.
Justification for Deviation(s)
The fire zone is provided with an area-wide automatic fire 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 that specified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
A5.8 - 45
 
AMENDMENT 25 DECEMBER 2012 A.5.8.22      Deviation 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 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.
Justification for Deviation(s)
The fire zone is provided with an area-wide automatic fire 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 that specified by Section C.5.B(2), paragraphs (a), (b) and (c) of BTP CMEB 9.5-1.
A5.8 - 46
 
AMENDMENT 25 DECEMBER 2012 A5.8.23        Deviation 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 Involved Unit 2 Containment (Fire Zone 1-2)
A5.8.23.1      Description 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.
A5.8 - 47
 
AMENDMENT 25 DECEMBER 2012 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 Deviation Within 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.
A5.8 - 48
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8.23.2      Description of Equipment/Cables Involved Steam 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 Deviation All 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 A5.8 - 49
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8.23.3      Description of Equipment/Cables Involved Source Range Neutron Monitoring Instruments Two 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 Deviation Outside 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 412 feet 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 50 feet 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 A5.8 - 50
 
AMENDMENT 25 DECEMBER 2012 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 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 cable tray is located in the area. It is located near radii R22 and R25, where the separation between redundant cables is 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 are 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 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.
A5.8.23.4      Description 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 A5.8 - 51
 
AMENDMENT 25 DECEMBER 2012 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 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.
A5.8.23.5      Description 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 A5.8 - 52
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8.23.6      Description 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 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 A5.8 - 53
 
AMENDMENT 25 DECEMBER 2012 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 A5.8 - 54
 
AMENDMENT 25 DECEMBER 2012 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 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.
A5.8.23.7      Description 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 A5.8 - 55
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8 - 56
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8.23.8      Description of Equipment/Cables Involved Reactor Containment Fan Cooler (RCFC) Fans Two 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 Deviation All 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 A5.8 - 57
 
AMENDMENT 25 DECEMBER 2012 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.
A5.8 - 58}}

Latest revision as of 01:50, 5 January 2025

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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