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Responds to NRC Re Violations Noted in IE Insp Repts 50-348/83-21 & 50-364/83-19.Corrective Actions:Mgt Directive Issued Reemphasizing That Fire Protection Program Reevaluation Considered on Same Basis as FSAR
	ML20083J849
Person / Time
Site:	Farley
Issue date:	12/09/1983
From:	Clayton F; ALABAMA POWER CO.
To:	Verrelli D; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20083J843	List: ML20083J849;
References
	NUDOCS 8401050448
	Download: ML20083J849 (67)
	v • d • e

- _ _ _

Malling Address Alabama Power Company

p 600 North 18th Street i

4 Post Office Box 2641 1. ! '7 l J P ; ' " ,

Birmingham. Alabama 35291 + ,1

Telephone 205 783-6081 F. L. Clayton, Jr.

Senior Vice President Flintridge Building o9 LJC~L ne n l{

{ AlabaniaPower December 9, 1983 mmu*a ec wem Docket Nos. 50-348 50-364 l

U. S. Nuclear Regulatory Commission Region II, Suite 3100 Division of Project and Resident Programs 101 Marietta Street, N.W.

Atlanta, Ga. 30303 Attention: Mr. D. M. Verrelli, Chief - Project Branch 1 Inspection Report Nos. 50-348/83-21 and 50-364/83-19 Gentlemen:

Alabama Power Company submits the following in response to the items listed in Appendix A of the Notice of Violation which resulted from the inspection conducted by Mr. W. H. Miller at Farley Nuclear Plant on August 16-19, 1983 (Report Nos. 50-348/83-21 and 50-364/83-19).

NRC Violation A. Technical Specification Section 6.8.1.f requires written procedures to be established, implemented and maintained covering the fire protection program implementation.

Contrary to the above, procedures had not been established to implement the following portions of the fire protection program:

1. Surveillance inspection and test of the fire detection instruments for Unit 1 Communication Room 202, Switchgear Room 335 and Switchgear Room 343 as required by Technical Specification Section 4.3.3.9.1;

2. Surveillance valve cycle test of a number of fire protection E system control and sectional valves as required by Technical Specification Setion 4.7.11.1.1.e and 4.7.11.2.b; and,

3. Surveillance inspection and test of the carbon dioxide system hose reel units located in the auxiliary building as required by Technical Specification Section 4.7.11.3.2.b.

8401050448 831220 PDR ADOCK 05000 0

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Mr. D.11. Verrelli, Chief - Project Branch 1 December 9, 1983 U. S. Nuclear Regulatory Commission Page 2 APCo Response A. Alabama Power Company acknowledges the violation as stated above and concedes a procedural deficiency existed regarding the Farley Nuclear Plant Procedures in administering the cited sections of the Technical Specifications. Corrective action for each item is:

1. Alabama Power Company revised the Farley Nuclear Plant Procedure (FNP-1-STP-131.02) on August 18, 1983 to include the Technical Specification requirement (Section 4.3.3.9.1) for !

surveillance inspection and test of the fire detection

( instruments for Unit 1 Rooms 202, 335 and 343,

2. Alabama Power Company revised the Farley Nuclear Plant Procedure (FNP-0-STP-56.0) on September 2,1983 to include the Technical Specification requirements (Section 4.7.11.1.1.e and

' 4.7.11.2.b) for surveillance valve cycle test of fire protection system control and sectional valves.

3. Alabama Power Company will revise the appropriate Farley Nuclear Plant Procedures by January 1,1984 to include the Technical Specification requirement (Section 4.7.11.3.2.b) for surveillance inspection and test of the carbon dioxide system hose reel units located in the auxiliary building.

NRC Violation B. License Condition paragraph 2.c.(9) requires the licensee to maintain in effect and fully implement all provisions of the approved fire protection plan entitled "Farley Nuclear Plant Fire Protection Program Reevaluation" dated September 15, 1977 through Amendment 4 dated January 3,1979. Section 4.4.4.3.5 of this reevaluation report states that vertical cable tray runs of more thar. 20 feet with no penetration seal will be provided with fire breaks consisting of a Marinite board sealed with a flame retardant coating.

Contrary to the above, vertical cable tray runs of over 20 feet are located in the Unit 2 auxiliary building and are not provided with fire breaks.

The violation is applicable only to Unit 2.

APCo Response B. Alabama Power Company acknowledges the violation as stated above.

The Marinite fire breaks were deleted as a requirement in Unit 2 by a change notice (CN) dated November 20, 1980. The CN resulted from an engineering analysis of these fire breaks which concluded that such stops were not needed since credit was not taken for them in

( .

Mr. D. M. Verrelli, Chief - Project Branch 1 December 9, 1983 U. S. Nuclear Regulatory Commission Page 3

! the Fire Hazard Analysis of the Fire Protection Program Reevaluation (FPPR) or any other Unit 2 fire protection analysis.

Amendment 5 to the FPPR also deleted Section 4.4.4.3.5 of Amendment 4 which required these fire breaks. Marinite or equivalent material fire breaks will be installed as required throughout Unit 2 by the end of the 3rd Unit 2 outage presently scheduled to begin in January 1985.

Based on conversations between the NRC Staff and Alabama Power Company held subsequent to the identification of the above )

violation with respect to fire breaks on vertical cable tray runs, ;

Alabama Power Company conducted an exhaustive review of the Farley I fire protection program. As a result of this review Alabama Power Company has:

1. Issued a management directive with written instructions that re-emphasizes that the FPPR shall be considered on the same basis as the Farley Final Safety Analysis Report (FSAR).

Instructions to the designers have been issued to ensure that future design changes involving fire protection will not decrease the effectiveness of the program as defined by Amendment 5 to the FPPR subject to the clarifications contained in Attachment I to this letter (discussed in more detail in item 3 below). t t

L Reviewed all CN's related to fire protection systems issued 2.

since the fuel load licensing dates of June 25,1977 (Unit 1) and October 23,1980 (Unit 2) and determined that the deletion l

of the marinite fire breaks was the only identified devietion j f rom the approved design criteria in Amendment 4 which could

have decreased the effectiveness of the FPPR as defined in Amendment 4. The corrective action for this item was discussed

[ in the above violation.

3. Conducted an exhaustive comparison of FPPR Amendment 5 to Amendment 4. Amendment 4 is the last amendment referenced in the Farley Nuclear Plant operating licenses. Based on a review l

of this comparison, Alabama Power Company concluded that no change decreases the effectiveness of the Farley Fire Protection System as currently defined except the deletion of 1 the marinite fire breaks. The remaining differences between i

the amendments were divided into two groups. The first group of differences consists of 30 items identified as changes to

the fire protection program which did not decrease the effectiveness of the program. These changes were brought about by refinements in the program as detailed engineering review and analysis was completed. Attachment I describes these l changes. The second group of differences are not considered to be changes to the fire protection program but were only made in

( order to:

l .

December 9, 1983

'Mr. D. M. Verre111, Chief - Project Branch 1 U. S. Nuclear Regulatory Comission Page 4

. a) correct omissions and errors in the earlier revisions b) reflect the as-built status of both units c) clarify program requirements and comitments by issuing a more readable and useable document d) reflect the completion of certain commitments.

These administrative and editorial changes are desciibed in Attachment II.

The changes shown in Attachments I and II are consistent with Amendment 11 to the Farley Nuclear Plant Unit 1 Operating License which states that " Alabama Power Company is authorized to make other changes to the program without prior Comission approval provided that such changes do not result in a decrease in the effectiveness of the program".

Based on the comparisons and reviews outlined above and subject to the clarifications discussed in Attachment I, Alabama Power Company has concluded that Amendment 5 of the FPPR constitutes the current fire protection program at Farley Nuclear Plant and intends to use it as the controlling document for the program. Consistent with the requirements of Amendment 11 to the Farley Nuclear Plant Unit 1 Operating License, Alabama Power Company will continue to obtain Comission approval prior to implementing any program changes which could result in a decrease in program effectiveness. Any changes which in the judgement of Alabama Power Company do not decrease the effectiveness of the program will be documented and included in the next amendment to the FPPR. Future amendments to the FPPR will be sent to the NRC.

If there are any questions or coments, please contact this of fice.

Yours very truly, k h F . L. Cl ayton, J r.

FLCJ r/DRB:ddr-D33 Attachments cc: Mr. R. A. Thomas Mr. C. F. Trowbridge Mr. J. P. O'Reilly Mr. E. A. Reeves Mr. W. H. Bradford

ATTACitENT I FPPR AENDENT #4/f5 COMPARIS0N Page 1 ,

AEND. #4 AEND. #5 SEC/ PARAGRAPH / AE ND. #4 PARAGRAPH / AEND. #5 ITEM # TABLE / FIGURE PAGE NO./N0s. TABLE / FIGURE PAGE N0./N0s. GMENT

1. Amendnent #3 13 Section 6 6-254 In response to Item 18a of Anendnent #3, Alabama Power Conpany stated that portable smoke exhaust fans "can be powered off the nonnal ac outlets or off the outlets supplied from the emergency power sources."

There are no pennanent emergency power outlets installed; however, in the event of .

an emergency condition when smoke removal is !

essential and use of the gasoline powered l equipment is ineffective or unavailable, temporary emergency power supplies can be provided to power this equipment.

2. Fire Area Fire Area Rooms 112,169 and 1% of Unit 1 were added 1-1 (2-1) 4-145 1-1 (2-1) 4-200 to the rooms exempt from smoke detection as proposed by Amendnent #4. These rooms do l not require detection since they are duct l and pipe chases and tendon access rooms containing little or no flansnable material l and no safe shutdown trains. (Footnote "a", l Page 4-8, Amendnent #5).

3. Fim Area Fim Area Amendnent #4 proposed a minimum half-hour 1-1 (2-1) 4-144 1-1 (2-1) fire rated blanket installed over the 1-4 (2-4) 4-155 1-4 (2-4) 4-210 self-expanding cork for the portions of the 1-5(2-5) 4-156 1-5 (2-5) 4-214 area boundary along the containment wall 1-34 (2-34) 4-223 1-34 (2-34) 4-252 which are also boundaries of other fire 1-35 (2-35) 4-225 1-35 (2-35) 4-254 areas for each of the listed fire areas.

Amendnent #5 should have deleted all of these proposals since prior conversations with the NRC had detennined that the elimination would not degrade the fire protection system. Even though the proposals were inadvertently left in Amendnent #5, they are not considered a part of the fire protection system.

ATTACMENT I FPPR AMENDENT #4/#5 COMPARIS0N Page 2 AEND. #4 AEM. #5 .

SEC/ PARAGRAPH / AEND. #4 PARAGRAPH / AEND. #5 ITEM # TABLE / FIGURE PAGE N0./N0s. TABLE / FIGURE PAGE N0./N0s. C014ENT 4 Fim Area Fim Area Roans 342, 424, 425, 426, 427, 448, 449, 1-4 (2-4) 4-155 1-4 (2-4) 4-211 450, 451 and 155 for both units and rooms 176, 328, 340, 306, 308, 329, 341 and 347 for Unit I were added to the rooms exempt from detection system coverage. These rooms do not require detection systems since they contain no or insignificant combustibles and contain no safe shutdown trains except one train in mom 155. (Footnote "b", Page 4-9, Amendnent #5)

5. Fire Area Fire Area Water suppression coverage has been provided 1-4 (2-4) 4-154 1-4 (2-4) 4-204 in accordance with SER requirements except for rooms 2168 and 2222. Sprinkler system design for Room 2168 has been implemented and will be documented in the next amendnent. Room 2222 does not require sprinkler coverage under the provisions of Section 4.2.5.1 since only one safe shutdown train is in this area. (Footnote "c", Page 4-9, Amendnent #5, should have statement about Room 2222 added)

6. Fire Area Fire Area Amendnent #4 proposed a sprinkler system for 1-5 (2-5) 4-23 & 4-157 1-5 (2-5) 4-2 & 4-214 Room 172 and 174 while the SER only mquires sprinkler coverage in Room 172. A fire originating in Roan 174 would be contained within the room because of the quantity of conibustible material and the barriers. Also the room contains only the hot shutdown cable associated with the pump in the room.

Sprinkler coverage requirement has been eliminated for Room 174 in Amendnent #5 and coverage is not provided.

1

ATTACitENT I FPPR AENDENT #4/#5 COMPARIS0N Page 3 '

AEE). #4 AEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / A END. #5 ITEM # TABLE / FIGURE PAGE NO./N0s. TABLE / FIGURE PAGE N0./N0s. COP 9ENT

7. Fire Area Fim Area Amendnent #4 proposed a detection system for 1-6 (2-6) 4-162 1-6 (2-6) 4-219 the entire fire area except Room 195 which contains no flansnable material. Amendnent

5 adds rooms 236, 242 and 243 to the rooms exempt from a detection system. These rooms am duct or pipe chases containing no safe shutdown trains and little or no conbustible material. (Footnote "d", Page 4-9, Amendnent #5)

Amendment #4 states " appropriate barriers are proposed for electrical cable as

8. Fire Area Fire Area requimd by Section 4.3.5.1." Amendnent #5 1-9 (2-9) 4-168 1-9 (2-9) 4-9 deletes that statement since the area contains only one train of safe shutdown cabling. Amendnent #4 erroneously reported two trains. (Footnote "e", Page 4-9, Amendnent #5)

9. Fire Area Fire Area Amendnent #4 proposed the relocation of one 1-12 (2-12) 4-176 & 4-177 1-12 (2-12) 4-226 train of selector switches and the rerouting of the instrumentation cable to be independent of the Cable Spreading Room for Unit 1 and the relocation of one train of selector switches in Unit 2. Amendnent #5 reflects the satisfactory completion of these proposals. The SER required the modification of " instrumentation to panel to make independent of Cable Spreading Room,

ATTAC K NT I FPPR AENDENT #4/#5 C0ffARIS0N Page 4

AEE. #4 AEW. #5 SEC/ PARAGRAPH / AEND. #4 PARAGRAPH / AMEND. #5 ITEM # TABLE / FIGURE PAGE N0./N0s. TABLE / FIGURE PAGE N0./N0s. CDP 0ENT

9. Fire Area Fim Area (cont) 1-12 (2-12) 4-176 & 4-177 1-12 (2-12) 4-226 Control Room and either cable chase".

Independence from either cable chase is not required for hot shutdown and goes beyond the Amendaent #4 connitment. If a fire were to destroy any cable chase, the plant could be brought to hot shutdown from the control room. Thus, independence of the instnrentation from the cable chase is not re@imd. (Footnote "F", Page 4-9, Amendment #5) 10.

Fire Area Fim Area Section 4.4.6.7, Station Battery Rooms in 1-16 (2-16) 4-456 1-16 (2-16) 4-234 Amendnent #4 contains a discussion which states the exhaust fans are nonnally started i when heat detectors reach 110*F. Amendnent

5 states that these exhaust fans n2n continuously which exceeds the comnitment and provides an improved not a degraded degree of protection.

, 11. Fim Area Fim Area Section 4.4.6.7 Station Battery Rooms. (See 1-17 (2-17) 4-456 1-17 (2-17) 4-235 Item 10 above) i

AlTACifENT I FPPR AENDENT #4/#5 COMPARIS0N Page 5

AEE. #4 AEND. #5 SEC/ PARAGRAPH / AEND. #4 PARAGRAPH / AEND. #5 ITEM # TABLE / FIGURE PAGE N0./N0s. TABLE / FIGURE PAGE NO./N0s. QMENT

12. Fim Area Fim Area Amendaent #4 proposed water suppression 1-20 (2-20) 4-193 1-20-(2-20) 4-242 system coverage for rooms in this fire area was expanded by the SER to include Rooms 210, 213, 228 and 234. Amendnent #5 reports automatic water supression systems for all of these except Unit 2, Room 2228.

Inplementation of Appendix R requimd modifications will exempt this room and will be documented in the next amendent.

13. Fire Area Fire Area 1-21 (2-21) 4-1% 1-20 (2-21) 4-245 Amendnent #4 stated that a CO2 hose reel was available for .use in this area from Room 244. Amendnent #5 corrects this by stating that the CO2 hose reel available for this area is in Room 210.

14. Fim Area Fire Area 1-21 (2-21) 4-1% 1-21 (2-21) 4-245 Amendnent #5 states that barriers mquired for electrical cabling have been installed in Unit 1 but due to the physical conditions of Unit 2 are not required by Section 4.3.5.1 of Amendnent #4. A footnote should have been added to exempt Unit 2 on Page 4-9, Amendnent #5.

15. Fire Area Fire Area 1-34 (2-34) 4-224 1-34 (2-34) 4-9 & 4-252 Amendnent #4 proposal to install appropriate barriers for electrical cables as mquimd by Section 4.3.5.1 was deleted by Amendnent

5. This area does not require installation of fire barriers due to the implementation of Appendix R modifications. Footnote "k",

Page 4-9, Amendnent #5, is in error and should have stated the above reason for deletion.

ATTAC E NT I FPPR AENDENT #4/#5 COMPARISON Page 6 AEE. #4 AEW. #5 .

SEC/ PARAGRAPH / AEND. #4 PARAGRAPH / AMEND. #5 ITEM # TABLE / FIGURE PAGE N0./N0s. TABLE / FIGURE PAGE NO./N0s. COMENT

16. Fire Area Fire Area Amenenent #5 deleted the mention of 1-35 (2-35) 4-226 1-35 (2-35) 4-255 " barriers" in the discussion of the consequence of a fire. There is only one safe shutdown train in the area and Section 4.2.5.1 does not mquire a barrier. ,

1

17. Fim Area Fire Area Amendnent #5 deleted the proposal for 1-41 (2-41) 4-238 1-41 (2-41) 4-261 appropriate barriers for electrical cables as mquired by Section 4.5.3.1 of Amendnent

4. Barriers am not required since them is only one train of safe shutdwn cabling in this area. Amendnent #4 erroneously 4 reported two trains in this area (footnote l

"1", page 4-9, Amendnent #5).

18. Fire Area Fire Area Amendnent #5 indicates that a water 1-42(2-42) 4-240 1-42 (2-42) 4-263 suppression system has been installed throughout this area except for the Unit 2 hatch area (Roam 2345). This deletion of water suppression over the hatch area was made because no safe shutdown equipment is acijacent to the hatch. Alabama Power Conpany intends, on its own volition, to ,

install this # ire protection equipment over l the access hatch area in Room 2345 to enhance the fire protection in this area by the end of the 3rd Unit 2 outage presently scheduled to begin in January 1985. This exception should have been noted as a footnote on page 4-9, Amendnent #5.

19. Fim Area Fim Area 1-51 (2-51) 4-260 1-51 (2-51) 4-272 Amendnent #5 deleted the proposal to install a sprinkler system in Roam 501 to protect DC power cables. This area does not contain safe shutdown equipment; therefore, a sprinkler system is not required.

. ,o i

d. Yx ,

,e ATTACW OIT I. -

Y; A #

p '

i FPPR AENDENT #4/#5 COWARISON 'g Page 7 ,

,/

% AEE. #4. AEE. #5 '

v .5 '

AE 2.#5' SEC/PAPAGRAPH/ AEND. #4'. PARAGRAFH/ .

' + ITEM r TABLE /FIGU_RE - PAGE N0./N0s. TABLE / FIGURE .' PAGE NO./N0s.,

, f 00 MENT

.e-

, y c -7 g i- 1 20. Fire Area Fire' Area Amendment #5 deleted the proposal to install j l'51 (2-51) ,f ,

, 4-260 1-51-(2-51) 4-272 approoriate electrical barriers for electrical cable as required by Section -

' y /

'4.3.5.1 in Amendnent #4. Barriers am notp _ ,e [

, required in this area since tnere.is no safe

/- shutdown equipment or cabling in the area. , r ,

c . Amendment #4 ermneously reported the prerence of two trains (footnote "a",

j . page 4-9, Amendment #5). ' -

, .~ ,

21. Fire Area . Fire Area e Amendnent #4. stated that all doors are U.L.

72, Zone A 4-306 72, Zone A 4-316' Class "A" rated. Amendnent #5 corrects this stating that all doors are nonrated since

,these doors.,s'eparate zo9es within fire area

/ / "

=72 ami do' not b:ve to'b

o rated. This'does

- , , ~ ' not' degrade the tim; protection in.the fim area. '

22. Fire Area Fire ~ Area Amendnent #4 stated that all doors are 72, Zone B 4-308 72, Zone B 4-18 U.L. Class "A" rated. Amendnent #5 corrects this stating that all doors am nonrated since double doors to the exterior and open doonvays separating zones within fire area 72 do not have to be rated. This does not degrade the fire protection in the fire area.

23. Fire Area Fire Area Amendnent #4 stated that all doors am U.L.

72, Zone C 4-310 72, Zone C 4-320 Class "A" rated. Amendnent #5 corrects this stating that the door into the Battery Room is U.L. C1 ass "A". rated while the door into the pimp room and the open' doorway do not have to be rated since they separate zones in the same fire area. This does not degrade the fire pmtection in the fire area.

ATTACl#ENT I FPPR AENDENT #4/#5 COPFARISON Page 8 ,

AEE.14 AEE. #5 .

SEC/PARAGFlAPH/ AEND. #4 -PARAGRAPH / AEND. #5 PAGE N0./W0s. TABLE / FIGURE PAGE N0./N0s. C010ENT ITEM # TABLE / FIGURE

24. Fim Area Fim Area See item 23 above.

72, Zone D 4-312 72, Zone D 4-322

25. Fire Area Fire Area See item 22 above.

72, Zone E 4-314 72, Zone E 4-324

26. Fire Area 88 Fim Area Amendment #4 states that backup fim Zones A 4-336 1-88 (2-88) 4-350 suppression capability is available from through F Zones A nearby CO2 hose reels. Since there are no through F nearby 002 hose reels, Amendment #5 corrects this by stating that backup capability is available from nearby water hose stations.

27. Introduction Amendnent #5 st&tes, "This reevaluation is

- 1. 5 1-3 to be updated annually coincident with the Final Safety Analysis Report (FSAR) Update" but Alabama Power Company does not anticipate fire protection changes l

se'74cient for an annual update but does intend to update the FPPR on an "as needed" basis.

1

28. N/A N/A Fim Area These fire areas are new and established 1-90 (2-90) 4-353 & 354 under the mquirements for new conbustible 1-91 4-355 & 356 areas (PCR 81-1037) and were inadvertently l 1-92 (2-92) 4-357 & 358 shown as completed in Amendment #5. Not all 93 4-359 & 360 of the fire protection features have been installed and these areas have not been utilized as pennanent combustible storage areas pending completion.

29. Fire Area Fire Area These rooms wem deleted from fim area 1-4(2-4) 4-154 & 155 1-4(2-4) 4-355 1-4 (2-4) and designated in one of the new -

thmugh fire areas with the same status as stated 4-360 above in item 28.

1 ATTAC K NT I

.FPPR AENDENT #4/#5 COEARIS0N Page 9 ,

AEE. #4 - AE E. #5 .

SEC/PARAGRA>H/ AEND. #4 PARAGRAPH /- AEND.' #5 ITEM # TABLE /FIGUE PAGE N0./N0s. TABLE / FIGURE PAGE NO./N0s. CO M NT

30. N/A N/A Water This Section of Amendment #5 cont & ins a new Suppression 4-180 paragraph which defines a "Special Hazard 4.2.4.1.10 Philosophy" with mspect to the installation of water suppression systens. APCo will follow NFPA Codes 13 and 15 to the maximum extent possible but conditions (particularly congestim in ceiling areas) nay occasionally require deviation fmm strict code compliance. Such deviations will be

pemitted only if equal, superior, or the

maximum practical protection will be

realized and past consitments will not be adversely affected. This definition is in agreement with the statement in Amendnent 11 to the Farley Operating License that

"Alabana Power Company is authorized to make other changes to the program without prior

~

Connission approval provided that such changes do not msult in a oecrease in the effectiveness of the program".

3 f

l 1

1 1

w .

Attachment II PAGE 1 FPPR AMEND. #4/#5 COMPARISON AMEND. #4 AMENO. #5 SEC/PARAGR/,PH/ AMEND. #4 PARAGRAPH / AMEND. #5 TABLE / FIGURE PAGE NO./N05. COMNENT ITEM # TABLE / FIGURE PAGE NO./N05.

Title Page Unnumbered No change.

1 Title Page Unnumbered (No Para, f) (No Para. #)

Distribution Unnumbered Not in Amend. #4.

2 '

List (No Para. #)

Unnumbered Record of Unnumbered Amend. #5 added Amend. #5 issue and date info.

3 Record of i Revision Revision (No Para. #) (No Para. #)

4 Abstract i & 11 Abstract i & 1-1 thru The Amend. #4 abstract contained detafis which would (No Para. #) 1-3 have been more appropriately located in an introductory (No Para. #) section. For this reason the majority of the material

& Introduction 1.1 thru 1.5 was relocated to the Amend. #5 " Introduction" (1.1 thru 1.5). See Item #8 for additional discussion. No sub-stantive changes.

Table of Editorial revision only.

5 Table of 111, iv & v 111 Contents Contents (No Para. f)

List of Tables x Amend. #5 dropped Amend. #4 Table 4.2-1 " Proposed Modifica-6 List of Tables vi tion Summary" from the list of tables; see Item #12 for (No Para. f) rationale. It should be noted that the Amend. #4 " List of Tables" failed to include Tables 4.2-2 (PG 4-261) and 4.2-2A(PG4-26j). These latter two tables were also dropped in Amend. #5. ,

List of Figures vil, viii, ix List of Figures iv, v, vi, vil, Editorial revision only.

7

&x (No Para. #) viii & ix (No Para. f) i

[

FPPR AMEND. #4/#5 COMPARISON PAGE 2 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 PAGE NO./N05. TABLE / FIGURE PAGE NO./N05. COMMENT ITEM # TABLE / FIGURE 1-1 thru l-3 1-1 thru l-3 The Amend. #4 " Introduction" was limited to a description 8 1.0 Introduction 1.1, 1.2, 1.3, of the organizations and individu31s involved in the pre-1.4 & 1.5 paration of the FPPR and a brief description of the Amend.

4 content. The Amend. #5 " Introduction" presents a brief description of the various iterations of NRC tasking which resulted in the publication of and amendments to the FPPR.

It incorporates portions of Amend. #4 abstract (see Item #4) and updates the NRC tasking through the April 13, 1979, NRC Fire Protection Safety Evaluation Report (SER). It also describes the Amend. #5 content and editorial organization.

9 2.0 2-1 & 2-2 2.0 2-1 & 2-2 No change.

(Eval. Criteria) (Eval. Criteria) 3-1 & 3-2 3.0 (Definitions) 3-1 & 3-2 No change.

10 3.0 (Definitions) 11 4.1 & Table 4.1-1 4-1 thru 4-20 4.1 & Table 4.1-1 4-1 thru 4-9 Amend. #4 (Table 4.1-1) provided a complete list of the (Compliance (Mod. & Compliance generic " positions" of Appendix A to BTP APCSB 9.5-1 and Summary) Summary) the associated degree of APC compliance thereto. Amend.

5 deleted the Amend. #4 table and substituted another (Table 4.1-1) which lists the specified modifications required by the SER to reach full compliance with Appendix A, BTP 9.5-1; the table also documented the degree of compliance thereto. The Amend. #5 revisions were accomplished to reflect the latest NRC taskings which addressed specific rather than generic require-ments. It should be noted that:

1. The SER include' d , not overrode, continued BTP 9.5-1 compliance.

2. Section 6 of Amend. #5 continues to provide a discussion on BTP 9.5-1 compliance com-mitments.

3. Table 4.1-1, Amend. #4 was "only a capsule summary" of BTP 9.5-1 compliance which was contained elsewhere (Section 4.4 Amend. #4; Section 6, Amend. #5).

4. BTP 9.5-1 compliance has also been incor-parated throughout the FPPR.

d PAGE 3 FPPR AMEND. #4/#5 COMPARISON AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 TABLE / FIGURE PAGE NO./N05. COMMENT ITEM # TABLE / FIGURE PAGE NO./N05.

4-21 thru 4-26, 4.1 & Table 4.1-1 4-1 thru 4-9 Amend. #4 Table 4.2-1 listed proposed fire protection 12 Sect. 4.2 & program modifications. Arend. #5 Table 4.1-1 lists Table 4.2-1 4-26a thru 4-26h (Mod. & Compliance (Proposed Mod. Summary) these same proposed modifications and provides a status Summary) update for each. It shculd be noted that both of these tables, with minor exception, are identical to the modi-fications required by NRC in the SER. Amend. #5 Table 4.1-1 provides rationale where required modifications have not been completed. This rationale falls within i the guidelines of current design criteria. i N/A N/A Deleted in Amend. #5 mods accomplished or not required.

13 Table 4.2-2 4.261 (Proposed Mod Implementstio.

Dates) 4-26j N/A N/A Deleted in Amend. #5 - mods accomplished or not required.

14 Table 4.2-2A (Unit #1 Work Priorities)

Sect. 4.3.1 4.27, 4-28, 4.2 4.11 thru 4-16 No substantive changes; editorial only.

15 (Fire Hazard 4-28a, 4-29 Anal. Descrip.) thru 4-31 Fig. 4.3-1 4-32 Fig. 4.2.1 4-17 No change.

16 (Fire Severity Curve) 17 Fig. 4.3.2

~

4-33 Fig. 4.2-2 4-18 Editorialchange;noimpactoncommitmentsoranagysis.

Amend. #4 had " total hgat' potential" as "X" to 10 power; it should have read 10 power. /

l Sect. 4.3.2 4-34 Sect. 4.2.2 4-19 Amend. #5 repeats the content of Amend. #4 and adds a 18 (Fire Area more comprehensive description of the features of the (Fire Area fire area layout figures (Amend. #5 Figs. 4.2-3 thru Layout) Layout) 4.2-70). Editorial changes only.

4 PAGE 4 FPPR AMEND. #4/#5 COMPARISON AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 TABLE / FIGURE PAGE NO./N05. COMMENT ITEM # TABLE / FIGURE PAGE NO./N05.

Fig. 4.3-3 4-?5/36 Fig. 4.2-3 4-21/22 The fire protection underground water main diagram was 19 was updated to reflect "as-built" conditions. Hose (Fire Main) (Fire Main) house to north cf Diesel Gen. Bldg. shown as installed per commitment.

20 N/A N/A Fig. 4.2-4 4-23/24 This figure added portions of the fire protection (Fire Main) underground water main which Amend. #4 failed to include or which were installed subsequent to Amend. #4 issuance.

Hydrants installed in the vicinity of the service water structure as per commitment are shown.

N/A Fig. 4.2-5 4-25/26 Amend. #5 added a separate " legend". An incomplete 21 N/A (Legend) legend had previously been shown on Fig. 4.3-3, PG 4-35/36 of Amend. #4. Amend. #5 drops the symbology for individual sprinkler and smoke detector heads since this unnecessarily congests the fire area figures.

Instead the figures show areas where water suppression and smoke detection is provided.

Fig. 4.3-4 thru 4-37 thru 4-112 Fig. 4.2-6 thru 4-27 thru 4-156 The Amend. #5 figures update the Amend. #4 figures in 22 consonance with the revisions / additions to design and Fig. 4.3-41 4.2-70 (Location of fire protection features discussed in the individual (Location of fire area hazard analyses. Since, as stated, the figures Fire Protection Fire Protection Equipment) Equipment) duplicate the material in the analyses they will not be addressed individually in this report. The Amend.

5 figures cover the same plant areas as Amend. #4 figures. However they were reformatted with the excep-tion of the Turbine Buildings to fit on a 8\" x 11" page rather than an 8 " x 17"' fold-out. Amend #5 added the fire protection annuncatfor list of both units and an associated legend (Figs. 4.2-35/36/37). It deleted' Amend.

4 figure (4.3-25) on the Unit #1 Auxiliary Building Fire Protection Riser System. This figure required major revision but the FPPR due date did not permit enough time to accomplish this revision.

_.m PAGE 5 FPPR AMEND. #4/#5 COMPARISON AMEND. #4 AMEND. #5 AMEND. #4 PARAGRAPH / AMEND. #5 SEC/ PARAGRAPH / COMMENT PAGE NO./N05. TABLE / FIGURE PAGE NO./N05.

ITEM # TABLE / FIGURE Sect. 4.3.3 4.157 thru 4-160 In the Amend. #5 " Required Auxiliaries" para., PG 4-159, 23 Sect. 4.3.3 4-113, 4-114 4-114a, 4-114b, (Safe Shutdown the containment air coolers were deleted from the list (Safe Shutdown & Radioactivity of systems required for the hot shutdown condition. ,

& Radioactivity 4-115 & 4-116 A change bar for this change was inadvertently left off. '

l Control) Control)

In the Amend. #5 "4.2.3.1.3 Cold Shutdown Requirements" Para., PG 4-168, containment coolers, CCW pump room coolers

& 600-V load center room coolers have been added to the list of systems and equipments to be used in reaching &

maintaining the plant in a cold shutdown condition.

4-l.thru 4-169 All Amend. #5 revisions were editorial except for deleting 24 Table 4.3-1 4-117 thru 4-128 Table 4.2-1 the containment coolers A, B, C & D, CCW pump room coolers i A & B (PG 4-163) and the 600-V load center room coolers (PG 4-164) from the " Required for HS" column (see remarks in item above). A revision bar was inadvertently left off page 4-169 opposite examples 3 & 4.

Fig. 4.2-71 4-171/172 No change.

25 Fig. 4.3-42 4-129/130 Fig. 4.2-72 4-173/174 No change.

26 Fig. 4.3-43 4-131/132 Sect. 4.2.4 4-175 thru l-192 See Items #27 through #63.

27 Sect. 4.3.4 4-133, 4-133a, (Design Features) 4-133b, 4-134, (Design Features) 4-135 & 4-136 Lead-In Para., 4-175 Discussion expanded. Editorial only.

28 Lead-In Para., 4-133 4.3.4 4.2.4.1 ,,

4.2.4.1.1 4-175 No change.

29 Structural 4-133 (Structural) 4.2.4.1.2 4-175 No change.

30 Pumps 4-133 (Pumps)

. . ~ . .

d FPPR AMEND. #4/#5 COMPARISON PAGE 6 AMEND. #4 AMEND. #5 i SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 ITEM # TABLE / FIGURE PAGE NO./NOS. TABLE / FIGURE PAGE NO./N05. COMMENT 31 Electrical 4-133, 4-133a, 4.2.4.1.3 4-176, 4-177 One editorial revision changed " Modifications are proposed" 4-133b, 4-134 (Electrical) to " Modifications have been made".

& 4-135 32 Fire Barrier 4-135, 4-136 4.2.4.1.4 4-177, 4-178 Amend. #4 stated "all fire barrier penetrations used Penetrations (Fire Barrier for electrical cables, except in conduit, are provided Penetrations) with either silicone foam or Nelson multicable transit system penetration seals." It went on to explain how both types of seals were 3-hour rated. Amend. #5 enters an exception to the preceding by stating that the pene-4 trations between containments and electrical penetration rooms are sealed against pressure and are watertight but are not fire rated.

33 Doors 4-136 4.2.4.1.5 4-179 Amend. #5 clarifies the discussion on rated door utiliza-(Doors) tion in exterior walls and stairwells to bring the section in comformance with Amend. #2 commitment (see Amend. 5, PG 6-44; Amend. #4, PG 4-375). No substantive change is made.

! 34 Compressible 4-136 4.2.4.1.6 4-179 Editorial revision only - deleted " Proposal" sentence Material (Compressible since proposals have been incorporated into individual Material) fire area hazard analyses. This is error; see Item 68 (B).

35 N/A N/A 4.2.4.1.7 4-179 New paragraph based on response to Request #27 Amend.

2 ( Amend. #5, PG 6-191v & PG 6-88). No new or revised 4

(Fire Prot.

Water Supply) material. ,,

36 N/A N/A 4.2.4.1.8 4-179 New paragraph based on." discussion" on NRC position E.2(g)

(Hydrant Houses) (Amend. #5, PG 6-89). N) new or revised material.

37 N/A N/A 4.2.4.1.9 4-180 New section describing manual hose station features.

(Man. Water Complied from various Amend. #4 paragraphs (PGS 4-425 Hose Sta.) 4-426,4-427). No new material or impact on commitments.

a FPPR AMEND. #4/#5 COMPARISON PAGE 7 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 ITEM # TABLE / FIGURE PAGE NO./N05. TABLE / FIGURE PAGE NO./N05. COMMENT 38 N/A N/A 4.2.4.1.10 4-180 New section describing overall design philosophy for water (Water suppression systems. It departs from past response regarding Suppression compliance with NFPA 13 & 15. It defines a "special hazard" Systems) concept stating NFPA 13 & 15 will be followed to the maximum extent possible but due to plant conditions deviations may be required, particularly in head or detector placement.

However it states these deviations are to be exercised only if equal or superior protection is afforded. No deviations of this type have been e<ercised to date. The third para-graph of this section sh3uld be changed to read " the fixed water fire protection systems protecting the safety related areas within the Auxiliary Buildings2provide an effective discharge density of 0.30 GAL / MIN /FT of covered floor area.

Also, the last paragraph should be revised to read --- can be manually activated or charged at their -- .

39 N/A N/A 4.2.4.1.11 4-181 New section complied fram numerous sections of Amend. #4 (LP C0p Systems) (PGS 4-431, 4-432, 4-433, 4-435, 4-436 & 4-398). To preclude any misunderstanding, this section should be revised in the next amendment to reflect that C0 Systems are designed, tested and maintained in accordance with2NFPA 12. Absence of this statement in Amend. #5 is in no manner intended to indicate less than full code compliance is acceptable. No substantive changes; editorial only.

40 N/A N/A 4.2.4.1.12 4-182 New section derived from Amend. #4 PGS 4-438/439. Editorial (HP CO Systems) revisions only.

2 4.2 " New section derived from Amend. #4 PG 4-429/430 and "as-built" 41 N/A N/A 4-182 (Halon Sys.) conditions. Editorial changes only.

42 N/A N/A 4.2.4.1.14 4-183 New section derived from Amend. #4, Amend. #2 section, (Smoke Det. Sys.) Page 30. Editorial changes only.

43 N/A N/A 4.2.4.1.15 4-183 New section derived basically from Amend. #4 PG 4-404 (Fire Prot. & Amend. #2 PG 43. Editorial changes only.

Annunciation)

b

.M FPPR AMEND. #4/#5 COMPARISON PAGE 8 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 ITEM # TABLE / FIGURE PAGE NO./NOS. TABLE / FIGURE PAGE NO./N05. COMMENT 44 N/A N/A 4.2.4.17 4-184 New section derived principally frem Amend. #4 PGS 4-403 (Supervisory & 4-408; Amend. #2, PGS 6, 31, 32, 33, 34 & 50 and Amend.

Systems) #3, PG 62. Editorial changes only.

45 N/A N/A 4.2.4.1.18 4-184 New section derived from Amend. #4, PGS 4-401/402 and (Communications) Amend. #2 PGS 28/29. Editorial changes only.

46 N/A N/A 4.2.4.1.19 4-185 New section derived from Amend. #3 PG 15. Changed from (Emergency 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months lights "will be" to "have been" installed. Other

- Lighting) changes are editorial only.

47 N/A N/A 4.2.4.1.20 4-185 New section derived from Amend. #4 PGS 4-330, 329 & 396, (Emer. Smoke Amend. #2, PGS 21 & 22 and Amend. #3 PG 13. Changed from Removal) portable smoke removal equipment "will be" to "is provided vided." NOTE: See Item 1 Attachment 1.

48 N/A N/A 4.2.4.1.21 4-186 New section identical to Amend. #4 PG 4-373/474 except (Floor Drains) "and approved" added to last sentence which now reads

" water drainage from areas which may contain radioactivity is collected in the liquid radwaste system and sampled and approved prior to discharge to the environment.

49 N/A N/A 4.2.4.2 4-186 New section. This is merely an introductory paragraph (Fire Protection with no substantive content. Editorial only.

Systems) i

l l

FPPR AMEND. #4/#5 CDMPARISON PAGE 9 i

AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 TABLE / FIGURE PAGE NO./N05. COMMENT ITEM # TABLE / FIGURE PAGE NO./N05.

N/A 4.2.4.2.1 4-186/187 & 188 New section; briefly describes water system from deep wells 50 N/A to fire protection water loop take-offs. It is derived from (Water Supply

& Distribution) Amend. #4 PGS 4-409, 412, 413, 414 & 416, Amend. #2, PG 36 and Amend. #3, PG 16. Two revisions were incorporated:

(1) In the discussion of pump house annunciation to the i control room, the fire pumps were identified by a number i

I but not by type, i.e., motor or engine-driven. The annunciation associated with each type varies. Amend.

5 identifies the pump prime-movers by type and clarifies the annunciation (editorial only); (2) Amend. #4 (PG 4-409) states fifty-five yard hydrants are installed.

Amend. #5 corrects this to ready fifty-two, the number installed at the time of Amend. #5 issuance. This is a substantive revision. Rev. bar should have been added.

4.2.4.2.2 4-188 New section. Derived from Amend. #4, PG 409 except the 51 N/A N/A (Yard Prot.) number of yard hydrants is corrected to read fifty-two.

See comments in preceding item.

4.2.4.2.3 4-188/189 New section. Derived from Amend. #4, PGS 4-409, 418, 443 52 N/A N/A (Aux. Bldgs.) & 449, Amend. #2, PGS 42 & 52 and Amend. #3 PGS 17 & 18.

No revisions to past material. Clarification of portable extinguisher locations philosophy and explanation of the fact smoke detection systems are both suppression-system related and non-suppression system related was added. All revisions of an editorial nature.

4.2.2.2.4 4-189 New section. Derived fro'm Amend. #4 PGS 4-446, 447, Amend.

53 N/A N/A (Containment) #2, PG 54 and Amend. #3, PGS 20 & 21. Editorial changes only.

4.2.4.2.5 4-189 New section. Derived from Amend. #4, PGS 4-433, 434, 435, 54 N/A N/A Editorial changes only.

(Turbine Bldg.) 457 & 458 and Amend. #3, PG 30.

4.2.4.2.6 4-190 New section. Derived from Amend. #4, PGS 4-436, 437, 443 55 N/A N/A (Diesel Gen. & 459. Editorial changes only.

Bldg.)

A I

FPPR AMEND. #4/#5 COMPARISON PAGE 10 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 TABLE / FIGURE PAGE NO./NOS. COMMENT ITEM # TABLE / FIGURE PAGE NO./NOS.

4.2.4.2.7 4-190 New section. Derived from Amend. #2, PG 78 and Amend. #3, 56 N/A N/A (Diesel Gen. PG 26. Editorial changes only.

Cable Tunnels) 4.2.4.2.8 4-190 New section. Derived from Amend. #4, PGS 4-438, 439 57 N/A N/A (Cooling Towers) & 466. Amend. #5 corrected Amend. #4 statement that each cooling tower has 5 cells. They have 14.

I 4.2.4.2.9 4-191 New section. Derived from Amend. #4, PG 4-470. Editorial 58 N/A N/A (Utility Bldg.) change only.

N/A 4.2.4.2.10 4-191 New section. Derived from Amend. #4, PG 4-468. Editorial 59 N/A (River Water changes only.

Int. Structure) 4.2.4.2.11 4-191 New section. Derived from Amend. #4, PG 4-469. Editorial 60 N/A N/A (Service Bldg.) change only.

4.2.4.2.12 4-191 New section. Derived from Amend. #4, PGS 4-461 & 467.

61 N/A N/A (Service Water Editorial changes only.

, Intake Structure) 62 N/A N/A 4.2.4.2.13 4-192 New section. New material based on "as-built" conditions.

(Water Treatment It briefly describes the fire protection equipment available B1dg.) to this building.

63 N/A N/A 4.2.4.2.14 4-192 New section. New material based on "as-built" conditions.

(Low Volt. It briefly describes the, fire protection equipment available Trans.-Area) to this area.

64 N/A N/A Fig. 4.2-73 4-193 This figure is located in Amend. #2, PG 33. It has also (Electrical been utilized in Amend. #5 without revision.

Sources) 65 N/A N/A Fig. 4.2-74 4-194 This figure is located in Amend. #2, PG 34. It has also (Electrical been utilized in Amend. #5 without revision.

Sources)

FPPR AMEND. #4/#5 COMPARISON PAGE 11 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 ITEM # TABLE / FIGURE PAGE NO./N05. TABLE / FIGURE PAGE NO./N05. COMMENT 66 Sec. 4.3.5 4-137 4.2.5 4-195 This introductory paragraph has been editorially revised (Fire Area (Fire Area only.

Hazard Analysis) Hazard Analysis) 67 Sec. 4.3.5.1 4-137/138 4.2.5.1 4-195/196 One substantive revision has been. Amend. #4 sub-(Proposed (Design Criteria- paragraph 4.3.5.1, 5, c has been deleted from Amend.

Modifications- Electrical) #5. It included a "special-case exception" to the Electrical) criteria for the protection of safety-related cable.

It stated no sprinkler or barrier protection was pro-posed for two service water structure cable trains even though they were within 8 feet of each other. This was deleted. Since Kaowool wrapping and sprinkler coverage has been provided per Appendix "R" and PCN 581-1078.

These added fire protection features have been incor-porated into the Area 72 Zone A, fire area hazard analysis (PG 4-316). Other revisions made to the section were of an editorial nature only.

68 Fire Area 4-142 thru 4-145 Fire Area 4-197 thru 4-200 In addition to editorial revisions, the following changes 1-1 (2-1) 1-1 (2-1) were entered:

Tabular Data (A) Deleted Rm 107. Reason - Rm 107 is now a separate fire area (90). See Amend. #5, PGS 4-353/354.

Desian Features - Construction (B) NOTE: See Item 3 Attachment 1.

t i

s FPPR AMEND. #4/#5 COMPARISON PAGE 12 AMEND. #4' AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5

{ COPMENT ITEM # TABLE / FIGURE PAGE NO./N05. TABLE / FIGURE PAGE NO./NOS.

68 Design Fe.itures - Doors (C) Amend. #4 claimed airtight UL rated Class B doors between I (Contd) Res 110, 115 and Stairwell #2. Amend. #5 corrects these i to be non-airtight, Class B doors. I I

(D) The proposed replacement (Amend. #4) of the door

! between Res 184 and 162 with an airtight UL Class A l

j door is reflected as completed in Amend. #5.

Design Features - Piping & Electrical Penetrations l (E) The Amend. f4 proposal to provide 3 HR rated dampers between Ras 169 and 163 is reflected as completed in Amend. #5.

l Fire Protection (F) NOTE: See Item 2 Attachment 1.

Consequence of a Fire (G) Amend. #4 stated that there was only one hot shutdown train in the area contrary to the fact that the area analysis table lists both train A & B in Rs 223. Amend.

5 corrects this error and provides an appropriate discussion.

FPPR AMEND. #4/#5 COMPARISON PAGE 13 AMEND. #4 AMEND. #5

- SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 PAGE NO./NOS. TABLE / FIGURE PAGE NO./N05. COMMENT ITEM # TABLE / FIGURE Fire Area 4-152, 153, 154 Fire Area 4-202 thru 4-212 In addition to editorial revisions, the following changes 69 155, 155a, 155b, 1-4 (2-4) were entered:

1-4 (2-4) 155c, 155d, 155e, 155f, & 155g Tabular Form (A) "C" shutdown train deleted from Rm 168 (2168).

(B) "B" & "C" shutdown trains deleted from Rm 162 (2162).

(C) "C" shutdown train deleted from Rm 163.

(D) Revised name of Rm 779 to " Valve Room / Combustible Storage"; it now has a storage function per PCR 81-1037. .

(E) Deleted Rm 218 from fire area 1-4. It is now designated as Fire Area 1-91 per PCR 81-1037. NOTE: See Item 29 Attachment 1.

i (F) "B" shutdown train deleted from Rm 222 (2222).

(G) Revised name of Rm 447 (2447) to " Cask Wash Storage Area /

Combustible Storage" to reflect utilization as storage for combustible material.

(H) Deleted Res 601 (2601), 602 (2602), & 603 (2503). They are now designated as Fire Area 1-93 per PCR 81-1037.

l s

i

4 FPPR AMEND. #4/#5 COMPARISON PAGE 14 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 PAGE NO./N05. TABLE / FIGURE PAGE NO./N05. COMMENT ITEM # TABLE / FIGURE 69 (1) Revised rm location of shutdown train; deleted "B" train from Rm 2405.

(Contd)

(J) Deleted Ras 420 (2420) & 421 (2421). They are now designated as fire area 1-92 (2-92) per PCR 81-1037.

NOTE: See Item 29 Attachment 1.

(K) Revised name of Rm 404 to reflect utilization for storage of combustible storage.

(L) Revised " maximum fire severity" of Rs 2403 frem < 1 hr to

< 30 min. to correct previous error.

Design Features - Construction (M) NOTE: See Item 3 Attachment 1.

Design Features - Doors (N) Amend. #4, PG 155F stated that the doors between Rm 312 and Rm 323 and Room 312 and Rm 326 were UL Class "B" doors. They are in fact non-rated. Since they do not form a part of the fire area boundary, they are not required to be rated. Rated doors would however strengthen the " defense in depth" concept (see EPPR review). Amend. #4 also erroneously stated the door between Ras 309 & 327 was UL Class B; there is no door between these ras. It is believed that the i

1 door between Rm 309 & Stairwell #8 is the correct one.

Amend. #5 accurately, states that doors which are a part of the fire boundary are UL Class A except for Class B doors at stairwells and elevator shafts used for access and egress and unrated doors leading to the outside.

Design Features - Piping & Electrical Penetrations (0) Amend. #5 reports proposed sealing of all boundary pene-trations to 3 hr rating as completed.

> ,r s n W9e FPPR AMEND. #4/#5 COMPARISON PAGE 15 AMEND. #4 AMEND. #5 SFC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 PAGE NO./NOS. TABLE / FIGURE PAGE NO./N05. COMMENT ITEM # TABLE / FIGURE Design Features - Ventilation 69 (P) Amend. #5 reports proposed installation of fire (Contd) dampers / doors in ducts penetrating the boundary as completed.

Fire Protection (Q) NOTE: See Item 4 Attachment 1.

(R) NOTE: See Item 5 Attachment 1.

(S) Amend. #5 corrects the "3 KV disconnect switches" to read "5 KV".

(T) Amend. #5 reports the proposed hose station installation is completed.

t l i.

6 FPPR AMEND. #4/#5 COMPARISON PAGE 16 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 PAGE NO./NOS. TAhlE/ FIGURE PAGE NO./NOS. COMMENT ITEM # TABLE / FIGURE 69 (U) Amend. #5 reports the proposed barriers for electrical cable as required by Amend. #4 Section 4.3.5.1 (Amend.

(Contd) #5 Section 4.2.5.1) are provided.

Consequence of Fire (V) Amend. #5 has been rewritten to reflect that the pro-posed items (smoke detection & smoke removal equipment) have been completed.

4-156 thru Fire Area 4-213 thru In addition to editorial revisions, the following changes 70 Fire Area i

4-158 1-5 (2-5) 4-216 were entered:

l 1-5 (2-5)

Tabular Data (A) The title of Rm 171 (2171) was revised to identify it as a combustible storage area; Footnote a, PG 4-213 of Amend. #5 provides applifying information.

Design Features - Construction (B) NOTE: See Item 3 Attachment 1.

Design Features - Doors (C) Amend. #5 reflects the replacement of a non-rated airtight door between Rms 161 & 172 with a rated door and the addi-tion of a rated door between Ras 171 & 172.

Design Features - Ventilation (D) Amend. #5 reflects the completion of the proposed instal-lation of four Class,.A dampers in ventilation openings.

Fire Protection /

(E) Amend. #5 reflects the completion of the proposed provision of a smoke detection system.

(F) Amend. #4 states a manual hose station and CO, hose reel are available in Rm 161 for use in Area 1-5 (2-5).

Amend. #5 corrects this to reflect this equipment is available in Rms 161 & 162.

i PAGE 17 FPPR AMEND. #4/#5 COMPARISON AMENO. f4 AMEND. #5 SEC/ PARAGRAPH / . AMEND. #4 PARAGRAPH / AMEND. #5 TABLE / FIGURE PAGE NO./N05. CONNENT ITEM # TABLE / FIGURE PAGE NO./N05.

70 (G) NOTE: See Item 6 Attachment 1.

(Centd)

(H) Amend. #4 proposed the installation of appropriate barriers as required by Section 4.3.5.1. Amend. #5 reports the satisfaction of this proposal.

Consequence of Fire f

(I) Amend. #5 adds CVCS motor-operated valves and charging pump room air handling units to the list of safe shutdown equipment located in the area.

(J) The only other Amend. f5 revisions concern changing

" Proposed System" to " Installed Systems" and noting that Rm 171 is now surrounded by three hour barriers (PCR 81-1037).

4-160 thru Fire Area 4-217 thru 4-220 In addition to editorial revisions, the following 71 Fire Area changes were entered:

1-6 (2-6) 4-162 1-6 (2-6)

Tabular Data (A) The title of Rm 167 was revised to reflect its utilization as a combustible storage area.

(B) Amend. #4 had shutdown train "A" in Rs 193 (2193). Amend.

5 revises this to train "C".

t

FPPR AMEND. #4/#5 COMPARISON PAGE 18 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 ITEM # TABLE / FIGURE PAGE NO./NOS. TABLE / FIGURE PAGE NO./NOS. COMMENT 71 Design Features - Construction (Contd) (C) Amend. #5 adds the fact that there is a removable steel hatch between Rs 185 (Area 1-6) and Rm 234 (Area 1-20).

Although this plate is non-rated, we did not claim rated boundaries in Amend. #4 which states " Floors and walls forming the area boundary are of reinforced concrete or open to the outside."

(D) The SER requires the construction of a curb between the CCW pumps. This has been accomplished as noted in Amend. #5, Table 4.1-1, PG 4-2. This should have been noted in this section of the fire area hazard analysis and on the appropriate area figures.

Design Features - Doors (E) Amend. #4 states the pressure-tight door between Rm 241

& Stairway No. 1 is non rated. Amend. #5 corrects this to be a Class B rated door.

Fire Protection (F) NOTE: See Item 7 Attachment 1.

(G) The proposed hose cabinet for Rm 734 is reflected as installed by Amend. #5.

(H) The Amend. #4 statement that "the hose located in Room 345 (Area 1-42) is available for use in this area" was inadvertently omitted from Amend. #5. However the hose remains available as committed.

FPPR AMEND. #4/#5 COMPARISON PAGE 19 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 PAGE NO./N05. TABLE / FIGURE PAGE NO./N05. COMNENT ITEM # TABLE / FIGURE 71 (I) Amend. #5 reflects that the proposed automatic water (Contd) suppression systems", appropriate barriers for electrical cable and safe shutdown cable rerouting has been cocpleted.

It should be noted that Amend. #4 proposed the rerouting of Train B; however Train B of Unit 1 & Train A of Unit 2 were rerouted. The design intent was met.

Consecuence of Fire (J) Amend. #5 added "various valves in the main steam and feedwater valve room" to the list of safe stutdown equipment in Area 1-6 (2-6).

72 Fire Area 4-166 & 4-167 Fire Area 4-221 & 4-222 In addition to editorial revisions, the following changes 1-8 (2-8) 1-8 (2-8) were entered:

(A) Amend. #5 added a list of Ras which comprise this fire area in Unit #2. In Unit #1 the entire area is assigned only one Rm number; in Unit #2, because of a different room numbering system, the fire area is made up of 4 rooms.

Design Features - Doors (B) Amend. #5 reflects the replacement of the steel plate between Res 116 ani 335 as proposed in Amend. #4.

Fire Protection (C) Amend. #5 reflects the installation of the proposed smoke detection and water suppression systems.

(D) Amend. #4 states a hose proposed for Rm 339 will be available for use as a backup in this fire area. A hose cabinet was installed in Rm 319, which is adjacent to Rm 339. This hose can also be utilized as backtp in Area 1-8. Design intent was met.

Includes Rm 194 which was added by the SER; Amend. #4 proposed Rms 185, 189 & 190 only.

PAGE 20 FPPR AMEND. #4/#5 COMPARISON J

AMEND. #4 AMEND. #5 AMEND. #4 PARAGRAPH / AMEND. #5 SEC/ PARAGRAPH / COMMENT fi ITEM # TABLE / FIGURE PAGE NO /NOS. TABLE / FIGURE PAGE NO./N05.

Consequence of Fire 72 (E) The Amend. #4 statement that " fire stops are located (Contd) every 20 feet along vertical cable trays" has been deleted from Amend. #5.

(F) The location of a backup hose station was revised from Rm 339 to Rm 319; see (C) above.

Fire Area 4-223 & 4-224 In addition to editorial revisions, the following changes i 73 Fire Area 4-168 & 4-169 1-9 (2-9) were entered:

1-9 (2-9)

~ Tabular Data !

1 (A) Amend. #5 added a list of Ras of Unit #2 which are in I

this fire area. The Unit 2 counterpart of Unit #1 Rm 246 l is comprised of 5 different rooms due to a different room l numbering system utilized in Unit #2.

(B) Amend. #5 deleted Train "A" from Rs 246 (2246); it had been relocated as proposed in Amend. #4. Amend. #5, Table 4.1-1, Footnote "e", PG 4-9 is incorrect. The second sentence should be deleted.

Fire Protection (C) Amend. #5 reflects that the proposed smoke detection and automatic water suppression systems have been provided.

(D) Amend. 14 states that a hose cabinet proposed for installation in Rm $39 would be available for backup.

Amend. #5 corrects the hose cabinet location to Rm 319.

See Item #72(D).

(E) NOTE: See Item 8 Attachment 1.

PAGE 21 FPPR AMEND. #4/#5 COMPARISON AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 TABLE / FIGURE PAGE NO./N05. COMMENT ITEM # TABLE / FIGURE PAGE NO./N05.

Consequence of Fire 73 (F) Amend. #4 states " fire stops are located every 20 feet (Contd) along vertical cable trays." Amend. #5 deleted this statement.

(G) Amend. #5 corrects the backup hose cabinet location from Rm 339 to 319; see Item #22 (D).

(H) Amend. #5 reflects there is only one train of safe shutdown cable now in the area; see (B) above.

4-176 & 4-177 Fire Area 4-225 & 4-226 In addition to editorial revisions, the following changes 74 Fire Area were entered:

1-12 (2-12) 1-12 (2-12)

Design Features - Construction (A) Amend. #5 adds the statement that the area boundaries now have a 3-hr rating; this satisfies an Amend. #4 proposal.

Design Features - Doors '

(B) Amend. #5 reflects that the proposed upgrading to Class A of the door between Ras 254 and 211 is completed.

Design Features - Piping and Electrical Penetrations (C) Amend. #5 reflects that all wall penetrations are now 3-hour rated as proposed.

Fire Protection (D) Amend. #5 reflects that proposed detection system has been provided. l Consequence of Fire !

(E) NOTE: See Item 9 .ittachment 1.

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FPPR AMEND. #4/#5 COMPARISON PAGE 22~

i AMEND. #4 AMEND. #5 4 SEC/ PARAGRAPH / AMENO. #4 PARAGRAPH / AMEND. #5 PAGE NO./N05. TA8LE/FIGUEE PAGE NO./N05. COMMENT ITEM # TABLE / FIGURE 75 Fire Area 4-178 & 4-179 Fire Area 4-227 & 4-228 In addition to editorial revisions, the following changes 1-13 (2-13) 1-13 (2-13) were entered:

Tabular Data (A) Amend.' #4 failed to include Rm 500 in this fire area.

heend. #5 added it'specifying it contained shutdown 4

Train A and Channels 2, 3 & 4. Amend. #5 also added Channels 2, 3 & 4 to Rm 300.

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Design Features - Doors 1

(B) Amend. #5 reflects the completion of all proposed door replacements.

j Desion Features - Piping and Electrical Penetrations (C) Amend. #4 proposed replacement of a non-rated steel plate leading to a cable chase leading to the Turbine Building with a Class A door. Amend. #5 states that the opening covered by the steel plate was instead sealed with a 1

3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated concrete block wall and all penetrations l were properly sealed. See Table 4.1-1, Footnote G, 1

PG 4-9, Amend. #5. Design intent was met.

' Design Features - Ventilation i

(D) This section was amended to state that dampers were i installed in ducts wherever they penetrated the area boundary, not just in floor penetrations as stated

]' in Amend. #4.

I Fire' Protection (E) Amend. #5 states that 2 each vice,1 each water' hose l and portable C07 extinguishers are available in Rm 319 for utilization in Rm 300.

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e FPPR AMEND. #4/#5 COMPARISON PAGE 23 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 ITEM # TABLE / FIGURE PAGE NO./N05. TABLE / FIGURE PAGE NO./N05. COMMENT 75 (Contd) (F) Amend. #5 reflects the installation of the proposed water suppression system.

(G) Amend. #5 reflects the completion of the proposed barriers for electrical cable as required by Sec.

4.2.6.1 (Amend. #5).

76 Fire Area 4-180 & 4-181 Fire Area 4-229 & 4-230 In addition to editorial revisions, the following changes 1-14 (2-14) 1-14 (2-14) were entered:

Tabular Data (A) Because it contains shutdowr, trains and has combustible loadings which differ from Unit #1, the Unit #2 Computer Room (2201) was split out from the Unit #1 Computer Room (201) in the fire area hazard analysis table.

Consequence of Fire (B) The list of safe shutdown equipment in the area was revised for Unit #2 (See [A] above).

(C) Amend. #5 deletes the statement of the proposed redesign of instrumentation cable. The proposed action is complete and is addressed under fire area 1-40 (2-40).

77 Fire Area 4-182 & 4-183 Fire Area 4-231 & 4-232 In addition to editorial revisions, the following changes 1-15 (2-15) 1-15 (2-15) were entered: ,

Tabular Data (A) In~the Amend. #5 fire area hazard analysis table, Room 2202 was listed separately since it differs signficantly from its Unit #1 counterpart, Room 202.

Room 2202 contains Trains A, B & C.

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FPPR AMEND. #4/#5 COMPARISON PAGE 24 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 PAGE NO./N05. TABLE / FIGURE PAGE NO./N05. COMMENT ITEM # TABLE / FIGURE 77 Design Features - Ventilation (Contd) (B) Amend. #5 reflects that the proposed installation of fire dampers at the ceiling penetrations for the exhuast ducts from the battery room exhaust fans is complete.

Consequence of Fire (C) Anend. #5 corrects the list of safe shutdown equipment .

located in Areas 1-15 and 2-15 (see [A] above). Future FPPR revision shouid discuss in detail the location of the hot shutdown panels noting the differences between Unit #1 & Unit #2.

(D) Anend. #5 revises the final paragraph of this section concluding that "although there is safe shutdown elec-trical cable in the area relocation of selector switches for the hot shutdown panel and the addition of protective wrapping to cabling permits safe shutdown capability to be maintained since only one safe shutdown train would be affected by fire."

78 Fire Area 4-184 & 4-185 Fire Area 4-233 & 4-234 In addition to editorial revisions, the following changes 1-16 (2-16) 1-16 (2-16) were entered:

Design Features - Doors (A) Anend. #5 corrects an Amend. #4 error; there is a UL Class A door located between Ras 212 and 213 not between 212 and 210.

Design Features - Ventilation (B) A revision bar was incorrectly included opposite this section in Amend. #5.

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PAGE 25 FPPR AMEND..#4/#5 COMPARISON AMEND. #4 AMEND. #5 AMEND. #4 PARAGRAPH / . AMEND. #5 SEC/ PARAGRAPH / COMMENT PAGE NO./N05. TABLE / FIGURE- PAGE NO./N05.

ITEM # TABLE / FIGURE Fire Protection 78

' (C) NOTE: See Item 10 Attachment 1.

(Contd)

Fire Area 4-235 t'4-236 Except for (B), the comments on Area 1-16 (2-16 apply to this 79 Fire Area 4-186 & 4-187 1-17 (2-17) fire area. NOTE: See Item 11 Attachment 1.

1-17 (2-17)

Fire Area 4-237 & 4-238 In addition to editorial revisions, the following changes 80 Fire Area 4-188 & 4-189 "

1-18 (2-18) were entered:

1-18 (2-18)

Tabular Data (A) Amend. #5 added Channel 2 to the safe shutdown cabling contained within this area.

Fire Protection L (B) Amend. #5 reflects that the proposed relocation of a CO extinguisher from Room 225 to 225 has been completed.

2 extinguishers are (C) Amend. #5 reflects that additional CO2 available for backup.

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FPPR AMEND. #4/f5 COMPARISON PAGE 26 AMEF. f4 AMEND. f5 SEC/ PARAGRAPH / AMEND. f4 PARAGRAPH / AMEND. #5 PAGE NO./N05. TABLE / FIGURE PAGE NO./NOS. C0f98ENT ITEM f TABLE / FIGURE 81 Fire Area 4-190 & 4-191. Fire Area 4-239 & 4-240 In addition to editorial revisions, the following changes 1-19 (2-19) 1-19 (2-19) were entered:

Tabular Data (A) Amend. f5 added Channels 3 and 4 to the safe shutdown cabling contained within this area.

Fire Protection (B) Amend. #5 reflects that the proposed relocation of a CO2 extinguisher has been completed.

82 Fire Area 4-192, 4-193 Fire Area 4-241, 4-242 & 4-243 In addition to editerial revisions, the following changes 1-20 (2-20) & 4-194 1-20 (2-20) were entered:

s Tabular Data (A) Amend. f5 added Channel 3 to Room 211 and deleted Channel 2 from and added Train C to Room 225 in the list of safe shutdown trains in this area.

Design Features - Construction (B) Amend. f5 noted that there were two steel hatches in Rm 234 instead of one as reported in Amend. 84. The

' revision bar was inadvertently left off of this revision.

Design Features - Doors (C) Amend. f5 reflects the proposed replacement of the door between Ras 210 and 254 with a Class A door has been completed. ,

Design Features - Piping and Electrical Penetratiens (D) Amend. #5 reflects the proposed sealing of penetrations through the area boundary has been completed. The Amend. f 5 revision bar was inadvertently lef t off.

FPPR AMEND. #4/#5 COMPARISON PAGE 27 AMEND. #4 AMEle. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. (5 PAGE NO./N05. TA8LE/ FIGURE PAGE NO./h05. COPMENT ITEM # TASLE/ FIGURE 82 Fire Protection (E) Amend. #5 reflects completion of the proposed instal-(Contd) lation of a smoke detection system throughout the area.

(F) Amend. #5 reflects completion of the proposed water hose cabinet in Rm 234.

(G) NOTE: See Item 12 Attachment 1. ,

(H) Amend. #5 reflects completion of the proposed installa-tion of appropriate barriers as required by Para. 4.2.5.1 i

l (Amend. #5).

Consequence of Fire

( (I) Amend. #5 states that safe shutdown equipment located in the area consists of electrical cable of both shutdown trains as well as the Swing Charger Room air handler unit, Battery Room air handling unit, swing charger and discon-nect switches. The Amend. #4 listing was incomplete.

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i FPPR AMEND. #4/#5 COMPARISON PAGE 28 AMEND. M AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 ITEM # TABLE / FIGURE PAGE NO./N05. TABLE / FIGURE PAGE NO./N05. Co MENT 83 Fire Area 4-195 & 4-1 % Fire Area 4-244 & 245 In addition to editorial revisions, the following changes 1-21 (2-21 1-21 (2-21) were entered:

Tabular Data (A) Amend. #5 deletes shutdown Train "C" from Rooms 229 &

233.

Fire Protection (B) Amend. #5 reflects the completion of the proposed installation of an area wide smoke detection system.

(C) Amend. #5 reflects the completion of the proposed installation of a water hose cabinet in Re 234.

(D) NOTE: See Item 13 Attachment 1.

(E) NOTE: See Ites 14 Attachment 1.

Consequence of Fire (F) Amend. #5 added safe shutdown trains, local control panels, bus sequencer and 125 V-DC distribution panel

. to the list of safe shutdown equipment in the area.

Amend. #4 list was incomplete.

(G) Amend. #5 corrects the location of the backup 03y hose reel; see (D) above.

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t o-eme-FPPR AMEND. #4/#5 COMPARISON PAGE 29 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 PAGE NO./N05. TABLE / FIGURE PAGE NO./N05. COMMENT ITEM # TABLE / FIGURE 84 Fire A ea 4-199 & 4-200 Fire A ea 4-246 & 4-247 In addition to editorial revisions, the following changes 1-23 (2-23) 1-23 (2-23) were entered:

Design Features - Doors (A) Amend. #5 reflec;s the completion of the proposed replacement of a steel plate with a Class "A" door i

between Rooms 235 and 249. It also states a Class "A" door is installed between Rooms 235 and 250 which was overlooked in Amend. #4. 9 i

Fire Protection (B) Amend. #5 reflects the completion of a proposal to install a water host cabinet in Rs 234 for use as l

backup in this area.

(C) Amend. #5 corrects the type of installed suppression system from CO2 to Halon.

j 85 Fire Area 4-213 & 4-214 Fire Area 4-248 & 4-249 In addition to editorial revisions, the following changes 1-30 (2-30) 1-30 (2-30) were entered:

Tabular Data (A) Amend. #5 contains a typographical error. It states Room 252 contains 4,172 pounds ,f cable insulation rather than 5,172 pounds. This error has no impact on the remainder of the fire area analysis.

Design Features - Doors (B) Amend. #5 reflects that the steel access plate between Rooms 249 and 235 has been replaced with a Class "A" door as proposed, it should be noted that the SER i

' required the replacement of a steel access plate between Rooms 249 and 346. There is no access between these rooms. This fact is point out in Footnote (i) to Table 4.1-1, PG 4-9, Amend. #5.

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d FPPR AMEND. #4/#5 COMPARISON PAGE 30 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 ITEM # TABLE /FIGUPE PAGE NO./N05. TABLE / FIGURE PAGE NO./N05. COMMENT 85 Fire Protection (Contd)

(C) Amend. #5 reflects completion of the proposed installa-tion of automatic water suppression and smoke detection systems and a manual water hose station.

Consequence of Fire (D) The Amend. #4 statement that " fire stops are located every 20 feet along vertical cable trays" has been deleted in Amend. #5.

86 Fire Area 4-215 & 4-216 Fire Area 4-250 & 4-251 In addition to editorial revisions, the fcilowing changes 1-31 (2-31) 1-31 (2-31) were entered:

Design Features - Doors (A) Amend. #5 reflects the replacement of an air-tight steel access plate between Rooms 250 and 235 with an air-tight Class A door as proposed. The statement that this replacement door is air-tight is in error.

However the SER required only a UL Class A rated door; air tightness was not a requirement.

(B) The SER required replacement of a steel access plate between Rooms 250 and 346. There is no access between these rooms. Footnote "J" to Table 4.1-1 of Amend.

5 (PG 4-4) points this out.

Fire Protection (C) Amend. #5 reflects completion of the proposed installation of automatic smoke detection and water supressfore systems and a manual hose station in Room 234.

Consequence of Fire (D) The Amend. #4 statement that " fire stops are located every 20 feet along vertical cable trays" has been deleted in Amend. #5.

FPPR AMEND. #4/#5 C M ARISON PAGE 31 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 TABLE / FIGURE PAGE NO./N05. CDP 9fENT ITEM J TABLE / FIGURE PAGE NO./N05.

4-223 & 4-224 Fire Area 4-252 & 4-253 In addition to editorial revisions, the following changes 87 Fire Area 2-34 (2-34) were entered: l 1-34 (2-34)

Design Features - Construction (A) NOTE: See Item 3 Attachment 1.

Design Features - Doors (B) Amend. #5 reflects the completion of the proposed replace-ment of a non-rated door between Room 317 and 322 with a Class A rated door. Amend. #5 however contains an error.

It reports a UL Class B door exists between Room 334 and the stairwell. It should have stated a UL Class A door exists between Rooms 334 and 322.

Design Features - Pipe and Electrical Requirements (C) Amend. #5 reflects completion of the proposed sealing to a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rating of all penetratons in Room 317.

However Amend. #5 corrects the Amend. #4 statement that all Room 334 boundary penetrations are sealed with silicone foam. Those into containment are sedled to be watertight only; they are not fire rated.

Design Features - Ventilation (D) Amend. #5 reflects completion of the proposed installa-tion of 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated dampers in area duct penetrations.

Fire Protection (E) Amend. #5 reflects completion of the proposal to install smoke detection in Room 317.

(F) Amend. #5 reflects completion of the proposal to install water suppression around the tendor access openings in Room 334.

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FPPR AMEND. #4/#5 COMPARISON PAGE 32 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 PAGE NO./N05. TABLE / FIGURE PAGE NO./N05. COMMENT ITEM # TABLE / FIGURE 87 (G) NOTE: Sea Item 15 Amendment 1.

(Contd)

Consequence of Fire (H) Amend. #5 revised the statement on the location of safe shutdown equipment in that aret. to include that in Room 317 (Train "A" cable). Amend. #4 had omitted this information.

(I) Amend. #5 deleted mention of " barriers" in the analysis of the consequences of a fire. See (G) above.

88 Fire Area 4-225 & 4-226 Fire Area 4-254 & 4-255 In addition to editorial revisions, the following changes 1-35 (2-35) 1-35 (2-35) were entered:

Design Features - Construction (A) NOTE: See Item 3 Attachment 1.

Design Features - Doors (B) Amend. #5 identifies a UL Class "A" door between Rooms 333 and 347.

Consequence of Fire (C) NOTE: See Item 16 Attachment 1.

89 Fire Area 4-233 & 4-234 Fire Area 4-256 & 4-257 In addition to editorial revisions, the following changes 1-39 (2-39) 1-39 (2-39) were entered:

DesidnFeatures-Doors (A) Amend. #5 corrected an Amend. #4 statement concerning the location of a removable concrete hatch. It is

, between Rooms 349 and 240, i

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P GE 33 FPPR AMEND. f4/f5 COMPARISON AMEND. f5 AMEND. #4 AMEND. f5 C0petENT SEC/ PARAGRAPH / MM. f4 PARAGRAPH /

TABLE / FIGURE PAGE N0./N05._

PAGE NO./N05._

ITEM f TABLE / FIGURE Design Features - Ventilation

! AmenJ. f5 (B) routed to the points out that the area exhaust durts are 89 atmosphere through the roof.

(Contd)

Fire Protection (C)

Amend. f5 reflects completion of the proposed instal-lation of a detection system and a portable e:.tinguisher.

Consecuence of Fire '

(D) Amend. f5 clarifies that a non-rated door in .he area boundary leads to the outside. Exterfor door are not required to be rated.

In addition to editorial revisions, the following :hanges Fire Area 4-258 & 4-259 Fire Area 4-235 & 4-236 were entered:

90 1-40 (2-40) 1-40 (2-40) Fire Protection (A) Amend. #5 reflects completion of the proposed installation of an automatic sprinkler system.

(B)

Amend. #5 reflects satisfaction of the proposed installation of a water hose. According to theHowever proposal, installation was the hose was at.tu-to have taken place in Room 339. Roos 339 and 319 are adjacent.

ally installed in Roce 319. Location of the hose in Room 319 up support for fighting a fire in the Cable Spreading doce.

The intent of our commitment is satisflad.

Amend. #5 inadvertently left off a statement that the ters-(C) ination cabinets are protected from sprinkler system water The cabinets have damage as was proposed in Amend. P4 Completion of this require been sealed on their tops.

is reported as couplete in Table 4.1-1, PG 4-5, Amend. f5.

FPPR AMEND. #4/#5 CDMPARISON PAGE 34 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 ITEM # TABLE / FIGURE PAGE NO./N05. TABLE / FIGURE PAGE NO./N05. COMMENT 90 Consequence of Fire (Contd) (D) Amend. #5 reflects that the proposed rerouting of instru-mentation cable to the hot shutdown panel to be idependent of the Cable Spreading Room has been completed.

91 Fire Area 4-237 & 4-238 Fire Area 4-260 & 4-261 In addition to editorial revisfors, the following changes 1-41 (2-41) 1-41 (2-41) were entered:

Tabular Data (A) Train "C" was deleted from the list of shutdown equipment in Rs 335 (2335).

Design Features - Doors (B) Amend. #5 notes that 2 of the 4 Class "A" doors listed in Amend. #4 are double doors.

(C) Amend. #5 deletes all reference to the Amend. #4 proposal to replace the steel plates between Room 346 and Rooms 249 and 250; there is no access between these rooms.

Fire Protection (D) Amend. #5 reflects the installation of a hose cabinet in Room 319 for backup in this area. Also see Item

90 (B) for additional background.

(E) Both Amend. #4 and #5 state " heat detectors will actuate a total flooding system in -- ". This system should have been described as a '"In-Cabinet CO, Flooding System".

Future FPPR amendments should correct this.

(F) NOTE: See Item 17 Attachment 1.

4 FPPR AMENO. #4/#5 COMPARISON PAGE 35 k

AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 TABLE / FIGURE PAGE NO./N05. COMMENT ITEM # TABLE / FIGURE PAGE NO./N05.

Consequence of Fire 91 (G) Amend. #5 states that safe shutdown equipment located (Contd) in the area is of one train. Amend. #4 stated two were in the area.

(H) Reference to barriers has been deleted from this section; see "F" above.

i 4-239 & 4-240 Fire Area 4-262 & 4-253 In addition to editorial revisions, the following changes 92 Fire Area 1-42 (2-42) were entered:

1-42 (2-42) i Tabular Data i (A) Amend. #5 adds Channel "2" to the shutdown train in 1

Room 319 (2319).

1 (B) Amend. #5 deletes Train "C" from Room 239 (2339). j Design Features - Construction (C) Amend. #5 corrects Amend. #4 by identifying 2, not 1, hatches in the floor and ceiling of Room 345.

Design Features - Doors (D) Amend. #5 reflects the completion of the proposed replacement of a non-rated door between Rooms 319 and 300 with a Class "A" door.

Design Features - Pipe and Electrical Penetrations (E) Amend. #s reflects completion of a proposal to seal all penetrations in'the area to a three hour resis-tance rating.

Fire Protection (F) Amend. #5 states that the entire area, not just Room 319, is provided with smoke detection.

(G) Amend. #5 states that three portable CO2 and an* pcrtable dry chemical extinguishers are located In Rvons 319 and 339.

Amend. #4 had stated that all of these extinguishers were

e FPPR AMEND. #4/#5 COMPARISON PAGE 36 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 PAGE NO./N05. TABLE / FIGURE PAGE NO./N05. COMMENT ITEM # TABLE / FIGURE located in Room 319. Rooms 319 and 339 are adjacent 92 and all of the extinguishers are located so as to be (Contd) readily available to support this and adjacent fire areas, design fr. tent is met.

(H) NOTE: See Item 18 Attachment 1.

Consequence of Fire (I) Amend. #5 states that electrical cable of 2 shutdown trains is located in the area; Amend. #4 failed to clarify this fact.

93 Fire Area 4-241 & 4-242 Fire Area 4-264 & 4-265 Note: Amend. #4 addressed fire areas 1-43 and 2-43 within 1-43 (2-43) the same fire area hazard analysis (PGS 4-241,4-242). In i 1-43 (2-43) fact the internal room configurations and the contents of the two fire areas differ significantly. For this reason, Amend.

5 devotes a separate fire area hazard analysis to each.

In addition to editorial revisions, the following changes were entered in the Area 1-43 analysis:

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FPPR AMEND. #4/#5 COMPARISON PAGE 37 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 ITEM # TABLE / FIGURE PAGE NO./N05. TABLE / FIGURE PAGE NO./N05. CDMMENT 93 Tabular Data (C:ntd) (A) Amend. #5 added shutdown train Channels 2, 3 & 4 to the contents of Room 453.

(B) Amend. #5 deleted shutdown train Channels 2, 3 & 4 from Room 452.

(C) Amend. #5 added shutdown train Channels 2, 3 & 4 to the contents of Room 444.

1 (D) Amend. #5 deleted Room 2432 from the list of rooms in Area 1-43.

Fire Protection (E) Amend. #5 reflects completion of the proposed hose cabinet installation and adds that an additional water hose and CO hose reel are available for backup.

2 Consequence of Fire (F) Amend. #4 stated the area contained no safe shutdown equipment. Amend. #5 corrects thiat stating that safe shutdown equipment consists of cabling of the "A" train and three redundant instrumentation channels. It adds that this safe shutdown cabling has been protected in accordance with the requirements of Section 4.2.5.1.

(G) The last paragraph of this section has been revised to reflect the existence of safe shutdown cabling in the area (see above)i It concludes that in the event of a fire safe shutdown capability would be maintained since only one train of electrical cable would be i

effected. The revision bar was inadvertently left off.

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1 PAGE 38 FPPR AMEND. f4/f5 COMPARISON AMEND. #5 AMEND. M ANEND. #5 AfEND. M PARAGRAPH / C0peqENT SEC/ PARAGRAPH / PAGE NO./N05.

PAGE NO./MOS. TABLE / FIGURE ITEM # TABLE / FIGURE N/A Fire Area 2-43 4-266 & 4-267 (See Note to Item 93) 94 N/A This is an entirely new section. All design criteria and commitments are satisfied.

Consequence of Fire .

(A) The narrative states that safe shutdown equ' ament in this area consists of electrical cable of one train. It should i have included "3 redundant instrument channels" in order to have been consistent with the tabular data. This cable has been wrapped in Kaowool in accordance with Itction 4.2.5.1.

4-268, 269 & 270 The unit i designation has been deleted frot the name of 95 Firo Area 4-243, 244 & 245 Fire Area 44 this fire area since it is common to Units t1 and #2. In 1-44 (2-44) addition to this and other editorial revisitns, the following changes were entered:

Tabular Data (A) Amend. f5 updates the rooms which comprise

his area. Room 476, coat closet, is deleted. kooms 471, 2453, 2454, 2455 and 2456 are added. Shutdtwn train content and combustible loading is also upd.ted.

Design Features - Construction (B) Amend f5 notes that all floors and walls forminal the area bcundary are of reinforced concrete with the exception of the west (exterior) wall of Room 475 which is of concrete block construction. Since it is an exterior wall it does not have to be fire rated.

Design Features - Doors f door betw*en Rooms 416 (C) Amend.

and 415.#4 claimed Amend.a#5 ULcorrects Class "A"this. The do r is a pres-suretight bullet-resistant non-rated door. Alatama Power has been unable to obtain a UL Class "A" ooor which is pressuretight and also bullet-resistant.

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FPPR AMEND. #4/#5 COMPARISON PAGE 39 AMEND. #4 AMEK). #5 SEC/ PARAGRAPH / AMEND. #4 PARAIRAPH/ AMEND. #5 ITEM # TABLE / FIGURE PAGE NO./N05. TABLE / FIGURE PAGE NO./N05. COMMENT 95 (D) Amend. #4 stated a certification of UL Class A construction (C:ntd) would be obtained for the door between Room 474 and the out-side. Amend. #5 deleted this proposal inasmuch as the access between Room 474 and the outside has been blocked up; see (C) above.

Fire Protection (E) Amend. #5 reflects completion of the proposed installations of water hose cabinets in Rooms 415 and 2452, an additional portable water extinguisher in the control room, two additional portable Class C extinguishers in adjacent areas, the enclosure of the kitchen, supply room and kitchen closet to a one-hour rating and the extention of the smoke detection systems to the space above the Control Room and the office and kitchen areas. All proposals were completed.

Consequence of Fire (F) NOTE: See Item 19 Attachment 1.

(G) Amend. #5 discussed the fact that the area boundary has one door without a 3-hour rating (see [C] above) but high-lights the fact that is is located adjacent to the constantly manned " primary access point".

96 Fire Area 4-260 & 4-261 Fire Area 51 4-271 & 4-272 The Unit # designation has been deleted from the name of this 1-51 (2-51) fire area since it is common to Units #1 and #2. In addition to this and other editorial revisions, the following changes were entered. ,

Tabular Data /

(A) Amend. #5 deleted shutdown Trains "A" and "B" from the list of safe shutdown equipment in this area.

S FPPR AMEND. #4/#5 COMPARISON PAGE 40 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 ITEM # TABLE / FIGURE PAGE NO./N05. TABLE / FIGURE PAGE NO./NOS. COMMENT 96 .

Design Features - Doors (Contd) (B) Amend. #4 claimed a pressure tight non-rated double door

, between Rooms 501 and 2501. Amend. #5 corrects to a non-pressure tight, non-rated door. Since this door does not lead to the exterior, it need not be pressure tight.

Design Features - Ventilation (C) Amend. #5 reflects completion of the proposal to relocate fire dampers to where the duct penetrates the area boundary.

Fire Protection (D) Amend. #5 reflects the installation of the proposed smoke detection system.

(E) Amend. #4 stated one water hose was located in the area but proposed to relocate it closer to the entrance doorway.

This hose was relocated in the Unit #1 side. The Unit #2 side does not have a hose cabinet in the area and does not require one. Since a hose cabinet is located immedi-ately outside of the door in the adjacent room (2502).

This area has one hose cabinet in it and another in an adjacent room. Design intent is met.

(F) Amend. #4 proposed installation of a sprinkler system in Room 501 to protect DC power cables. This area does not contain safe shutdown equipment hence no sprinkler system is reqJired. ,

(G) NOTE: See Item 20 Attachment 1.

PAGE 41 FPPR AMEND. #4/#5 COMPARISON )

AMEND. #4 .

AMF.ND. #5 AMEND. #4 PARAGRAPH / AMEND. #5 SEC/ PARAGRAPH / COMMENT PAGE NO /N05. TABLE / FIGURE PAGE NO./N05.

TABLE / FIGURE ITEM _f Consequence of Fire 96 (H) Amend. #5 states no safe shutdown equipment or cabling (C:ntd) is located in this area. Amend. #1 had noted the existence of two trains.

(I) The concluding paragraph of this section was revised to reflect the absence of safe shutdown equipment or cabling.

See (A) above. t 4-273 & 4-274 This area is applicable only to Unit #1. There is no area 4-264 & 4-265 Fire Area 1-53 97 Fire Area 2-53. In additicn to this and other editorial revisions, the 1-53(2-53) followirg changes were entered: l 1

Tabular Data

! (A) Room 2502 was deleted; it does not exist.

l Fire Area 4-275 & 4-276 In addition to editorial revisions, the following changes 98 Fire Area 4-266 & 4-267 were entered:

l 1-54 (2-54) 1-54 (2-54)

Design Features - Doors i l

(A) Amend.

elevator#5 states shaft arethat the doors UL Class in each elevation "B" pressure of the tight. Amend. l

4 had them noted as UL Class "B" only.

[

4-277, 278 & 279 In addition to editorial revisions, the following changes 99 Fire Area 4-268 & 8-269 Fire Area 1-55 (2-55) were entered:

1-55 (2-55)

Tabular Data (A) Amend. #5 deleted Channels 2, 3 and 4 and added Train "C" and Channel "N" to the list of safe shutdown cabling in this area.

Design Features - Construction (B) Amend. #5 stated that all penetration openings are watertight. Amend. #4 had erroneously stated that they were watertight and " fire rated".

FPPR AMEND. #4/#5 COMPARISON PAGE 42 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 PAGE NO./N05. TABLE / FIGURE PAGE NO./N05. COMMENT ITEM # TABLE / FIGURE 99 Design Features - Piping and Electrical Penetrations (C) Amend. f4 had erroneously claimed that all boundary pene-(Contd) trations were sealed with silicone foam or Nelson fittings.

Amend. #5 corrects this stating they are " sealed and watertight".

Fire Protection (D) Amend. #5 notes that Unit #2 has two fonization smoke detectors per steam generator; Unit #1 has one each steam generator.

(E) Amend. #5 reflects completion of proposed installations of a standpipe system and an oil collection system for the reactor coolant pups.

Consequence of Fire

. (F) Amend. #5 notes that this area contains safe shutdown equipment of both trains. Amend. #4 had failed to identify this presence.

{s 100 Fire Area 4-270 & 4-271 Fire Area 4-280 & 4-281 In addition to editorial revisions, the following changes i

56, Zone A 56, Zone A were entered:

Design Features - Doors t (A) Amend. #5 reflects the completion of the proposed installation of a Class "A" door between Fire Areas 56A and 568.

i Fire' Protection (B) Amend. #5 reflects the completion of the propused installations of a detection system and a yard hydrant i to the north of the Diesel Generator Building. ,

i Consequence of Fire

?

(C) Amend. #5 reflects completion of the proposed installation i

of a detection system. See "B" above.

1

. . . ~ . .-- . - -

b 4

4 FPPR AMEND. #4/85 COMPARISON PAGE 43 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMENO. #4 PARAGRAPH / AMENO. f5 PAGE NO./NOS. TA8LE/ FIGURE PAGE NO./N05.: COMMENT ITEM # TABLE / FIGURE In addition to editorial revisions, the following changes 101 Fire Area 4-272 & 4-273 Fire Area 4-282 & 4-283 56, Zone B 56, Zone B were entered:

Design Features - Doors i

(A) Amend. #5 reflects the completion of the proposed instal-lation of a Class "A" door between Zones 568 and 56A.

(B) Amend. #5 notes that a nonrated double and a nonrated single door lead to the exterior.

Fire Protection (C) Amend. #5 reflects completion of the proposed smoke detection system and hydrant installations.

j

! Consequence of Fire (D) Amend. #5 reflects completion of the proposed smoke detection system installation. See (C) above.

4 102 Fire Area 4-274 & 4-275 Fire Area 4-284 & 4-285 In addition to editorial revisions, the following changes 56, Zone C 56, Zone C were entered:

Fire Protection (A) Amend. #5 reflects completion of the proposed smoke a

detection system and hydrant installations.

Consequence of Fire (B) Amend. #5 reflects completion of the proposed smoke detection system. See above.

[

e

h

, ~ . . ...

FPPR AMEND. #4/#5 COMPARISON PAGE 44 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 PAGE NO./NOS. C0petENT ITEM # TABLE / FIGURE PAGE NO./N05. TABLE / FIGURE

.133 Fire Area 57 4-276 & 4-277 Fire Area 57 4-286 & 4-287 In addition to editorial revisions, the following changes vee entered:

Fire Protection (A) Amend. #5 indicates that dry chemical and CO, extinguishers are available as backup for this area. % n0. #4 listed only dry chemical extinguishers.

(B) Amend. #5 reflects completion of the pror:> sed installation of a hydrant to the north of the Diesel Generator Building.

104 Fire Area 58 4-278 & 4-279 Fire Area 58 4-2S8 & 4-289 Comments on this area are identical to those on Area 57.

105 Fire Area 59 4-280 & 4-281 Fire Area 59 4-290 & 4-291 Comments on this area are identical to those on Area 57.

106 Fire Area 60 4-282 & 4-283 Fire Area 60 4-292 & 4-293 Comments on this area are identical to those on Area 57.

107 Fire Area 61 4-284 & 4-285 Fire Area 61 4-294 & 4-295 Comments on this area are identical to those on Area 57.

108 Fire Area 62 4-286 & 4-287 Fire Area 62 4-296 & 4-297 In addition to editorial revisions, the following changes were entered:

Fire Protection (A) Amend. #5 reflects completion of the proposed installation of a hydrant to the north of the Diesel Generator Building.

FPPR AMEND. #4/#5 COMPARISON PAGE 45 AMEND. #4 AMENJ. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 TABLE / FIGURE PAGE NO./N05. COMNENT ITEM # TABLE / FIGURE PAGE NO./N05.

4-288 & 4-289 Fire Area 63 4-298 & 4-299 In addition to editorial revisions, the following changes 109 Fire Area 63 were entered:

Tabular Data (A) The quantity of diesel fuel in the day tank was revised to 1325 gallons and the fire loading was adjusted accordingly. Maximum fire severity remains at > 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months .

Fire Protection (B) Amend. #5 reflects completion of the proposed installation of a hydrant to the north of the Diesel Generator Building.

4-290 & 4-291 Fire Area 64 4-300 & 4-301 Comments on this area are ide;.tical to those on Area 63.

110 Fire Area 64 111 Fire Area 65 4-292 & 4-293 Fire Area 65 4-302 & 4-303 Comments on this area are identical to those on Area 62.

112 Fire Area 66 4-294 & 4-295 Fire Area 66 4-304 & 4-305 Comments on this area are identical to those on Area 63.

Fire Area 67 4-296 & 4-297 Fire Area 67 4-306 & 4-307 In addition to editorial revisions, the following changes 113 were entered:

Design Features - Doors (A) Amend. #5 corrects the Amend. f4 statement that all doors are UL Class A rated; doors leading to the exterior are '

nonrated and are not required to be so.

Fire trotection (B)

Amend. #5 notes that this area has been providedjwith a smoke detection system. I ,

t

e FPPR AMEND. #4/#5 COMPARISON PAGE 46

! AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 TABLE / FIGURE PAGE NO./N05. COMMENT j ITEM # TABLE / FIGURE PAGE NO /N05.

114 Fire Area 68 4-298 & 4-299 Fire Area 68 4-308 & 4-309 Comments on this area are identical to those on Area 67.

Fire Area 69 4-300 & 4-301 Fire Area 69 4-310 & 4-311 Except for editorial revisions, Amend. #4 and Amend. #5 are 115 the same for this fire area.

Fire Area 70 4-302 & 4-303 Fire Area 70 4-312 & 4-313 Except for editorial revisions, Amend. #4 and Amend. #5 are 116 the same for this fire area.

4-304 & 4-305 Fire Area 71 4-314 & 4-315 In addition to editorial revisions, the following changes 117 Fire Area 71 were entered:

Tabular Data (A) Amend. #4 listed no safe shutdown train in the crea.

Amend. #5 stated Train "A" is located in this area.

I Fire Protection (B) Amend. #5 reflects completion of the proposed installation of a smoke detection system and of a hydrant to the north of the Diesel Generator Building.

Consequence of Fire (C) Amend. #4 stated this area contained electrical cable of both safe shutdown trains. Amend. #5 revised this to electrical cable of a single safe shutdown train.

(D) Amend. #5 reflects installation of a smoke detection system. See (B) above.

(E) Amend. 65 concludes that " safe shutdown capability is maintained in the event of a fire because of a single safe shutdown train is located in this area".

Amend. #4 had stated "no safe shutdown equipment is located in this area".

PAGE 47 FPPR AMEND. #4/#5 COMPARISON AMEND. #4 AMEND. #5 AMEND. #4 PARAGRAPH / AMEND. #5 SEC/ PARAGRAPH / C0feeENT PAGE NO./N05. TABLE / FIGURE PAGE NO./N05.

ITEM # TABLE / FIGURE Fire Area 4-316 & 4-317 In addition to editorial revisions, the following changes 118 Fire Area 4-306 & 4-307 72, Zone A were entered:

72, Zone A Design Features - Doors (A) NOTE: See Item 21 Attachment 1.

Fire Protection j (B) Amend. #5 reflects the installation of the proposed I

{

smoke detection system, the proposed fire barriers between redundant service water pumps, the two proposed yard fire hydrants and the proposed preaction sprinkler system for the area immediately around the pumps. It also noted that two additional preaction sprinkler systems had been provided for coverage of the entire j pump deck, the area in the strainer pit below the pump deck and to safety related cabling in the upper north-eastern corner of the Pump Room.

Consequence of Fire (C) Completion of all proposed fire protection enhancements and their impact on minimizing the consequences of a fire are noted in Amend. #5.

Fire Area 4-318 & 4-319 In addition to editorial revisions, the following changes !

119 Fire Area 4-308 & 4-309 72, Zone 8 were entered:

72, Zone B Design Features - Doors (A) NOTE: See Item 22 Attachment 1.

1

e PAGE 48 FPPR AMEND. #4/#5 COMF ARISON AMENO. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 TABLE / FIGURE PAGE NO./N05. COMMENT ITEM # TABLE / FIGURE PAGE NO./N05.

Fire Protection 119 (B) Amend. #5 reflects completion of the proposed installation (Centd) of two yard hydrants within the security fence.

Consequence of Fire (C) Amend. #4 states this zone is separated from other zones by reinforced concrete. Amend. #5 corrects this statement by noting the open doorway between this zone and Zone 72C.

(D) Amend. #5 pointed out that upon receipt of warning by the detection system fire hydrants and portable extinguishers must be utilized for fires not inside the switchgear cabinets. Amend. #4 had addressed only fires inside the cabinets.

4-310 & 4-311 Fire Area 4-320 & 4-321 In addition to editorial revisions, the following changes 120 Fire Area were entered:

72, Zone C 72, Zone C Tabular Data (A) Amend. #4 identified the disconnect switchgear as being "4 KV". Amend. #5 corrects this to be "5 KV".

Design Features - Doors (B) NOTE: See Item 23 Attachment 1.

Fire Protection (C) Amend. #5 reflects installation of the proposed smoke detection system and,, yard hydrants.

i PAGE 49 FPPR AMEND. #4/#5 CDMFARISON AMEND. #4 AMEND. #5 AMEND. #4 PARAGRAPH / AMEND. #5 SEC/ PARAGRAPH / COMMENT TABLE / FIGURE PAGE NO./N05. TABLE / FIGURE PAGE NO./N05.

ITEM #

Consequence of Fire 120 (D) Amend. #5 notes the different fire fighting requirements (Contd) within the zone; see Item 119 (D) above.

Fire Area 4-322 & 4-323 In addition to editorial revisions, the following changes 121 Fire Area 4-312 & 4-313 72, Zone D were entered:

72, Zone D Tabular Data t (A) See Item 120 (A) above, Design Features - Doors (B) NOTE: See Itec 24 Attachment 1.

Fire Protection (C) Amend. #5 reflects installation of the proposed smoke detection system and yard hydrants.

Consequence of Fire (D) Amend. #5 failed to revise the disconnect switch rating from 4 to 5-K'/. This is an administrative error. See Item 120 (A) above.

(E) Amend. #5 notes the differing fire fighting requirements within the zone; see Ites 119 (D) above.

4-134 & 4-135 Fire Area 4-324 & 4-325 In addition to editorial revisions, the following changes 122 Fire Area were entered:

72, Zone E 72, Zone E Desidn Features - Doors (A) NOTE: See Item 25 Attachment 1.

m._

i a

FPPR AMEND. #4/#5 COMPARISON PAGE 50 AMEND. #4 AMENO. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 ITEM # TABLE / FIGURE PAGE NO./N05. TABLE / FIGURE PAGE NO./N05. COMNENT 122 Fire Protection (Contd) (B) Amend. #5 reflects installation of the proposed yard hydrants.

Consequence of Fire (C) Amend. #5 notes the differing fire fighting requirements within the zone; see Item 119 (C) above.

123 Fire Area 73 4-316 & 4-317 Fire Area 73 4-326 & 4-327 In addition to editorial revisions, the fo11ering changes were entered:

Fire Protection (A) Amend. #5 reflects that the proposed installation of the two ya'rd hydrants has been completed. It also notes that this area is provided with a smoke cetection system.

Consequence of Fire (B) Completion of the above proposed fire protection enhancements and their impact on minimizing the consequences of a fire are noted in Amend. #5.

124 Fire Area 74 4-318 & 4-319 Fire Area 74 4-328 & 4-329 Comments on this area are identical to those on Area 73.

125 Fire Area 4-320 & 4-321 Fire Area 4-330 & 4-331 In addition to editorial revisions, the following changes 1-75 (2-75) 1-75 (2-75) were entered:

Design Features - Doors (A) Amend. #5 reflects the completto,of the proposed application of fire' resistant coating to the watertight door and bulkhead leading into the Auxiliary Building.

Design Features - Floor Drains (B) Amend. #5 notes that a sump and sump pump are located within the cable tunnel.

i

e d

FPPR AMEND. #4/#5 COMPARISON PAGE 51 AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4 PARAGRAPH / AMEND. #5 ITEM # TABLE / FIGURE PAGE NO./N05. TABLE / FIGURE PAGE NO./NOS. COMMENT 125 Fire Protection (Contd) (C) Amend. #5 notes that the proposed installation of an automatic sprinkler system is complete. Amend. #5 should have noted that hose cabinets have been installed in the Unit #2 cable tunnel.

Consequence of Fire (D) Completion of the above proposed fire protection j enhancements and their impact on minimizing the !

consequences of a fire are noted in Amend. #5.

The availability of hose cabinets in the Unit #2 tunnel should have been included; see (C) above.

126 Fire Area 1-76 4-322 & 4-323 Fire Area 1-76 4-332 & 4-333 Comments on this area are identical to those on Area 1-75 (2-76) (2-75).

127 Fire Area 77 4-324 Fire Area 1-77 4-334 Editorial changes only.

(2-77) 128 Fire Area 78 4-325 Fire Area 1-78 4-335 Editorial changes only.

(2-78) 129 Fire Area 79 4-326 Fire Area 1-79 4-336 Editorial changes only.

(2-79) 130 Fire Area 80, 4-327 Fire Area 1-80 4-337 & 4-338 Editorial changes only, Zones A thru H (2-80), Zones A thru H 131 Fire Area 81 4-328 Fire Area 1-81 4-339 & 4-340 In addition to editorial revisions, the following cha ge (2-81) was entered.

I Design Features - Construction (A) Amend. #5 hotes that portions of the area boundary are of 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated concrete block construction. Amend. #4 had stated the boundaries were entirely reinforced concrete.

f-r l

PAGE 52 FPPR AMEND. #4/#5 COMPARISON AMEND #4 AltEND. #5 AMEND. #4 PARAGRAPH / AMEND. #5 SEC/ PARAGRAPH / PAGE NO./N05. COM9ENT PAGE NO./N05. TABLE / FIGURE ITEM # TABLE / FIGURE Fire Area 1-82 4-341 & 4-342 Comments on this arta are identical to those on Area 1-81.

132 Fire Area 82 4-329 Fire Area 1-83 4-343 & 4-344 Comments on this area are identical to those on Area 1-81.

133 Fire Area 83 4-330 4-345 Editorial changes only.

I 134 Fire Area 84, 4-331 Fire Area 1-84 Zones A thru E (2-84) Zones A thru E Editorial changes only. I Fire Area 85, 4-332 Fire Area 1-85 4-346 l 135 Zones A & B (2-85) Zones A 1

&B 4-347 & 4-348 Editorial changes only.

136 Fire Area 86 4-333 & 4-334 Fire Area 1-86 !

4-349 In addition to editorial revisions, the following changes Fire Area 87, 4-335 Fire Area 1-87 137 were entered:

Zone C A thru I (?-87)

Tabular Data (A) Amend. f4 erroneously identified Zones "H" and "I" as being associated with the feedwater pump turbine bearings. Amend. #4 also erroneously identified this '

i fire area hazard analysis as addressing Zoner, "/"

through "I". Actually the zones in this area are "A" through "J" with "I" and "J" being associated with the feedwater pump turbine bearings. Amend. #5 corrected these errors.

Fire Protection (B) Zones "A" through "If' are now provided with closed head, manually actuated spray systems. At the time of issuance of Amend. #4, open head systems were installed. Amend. #5 notes the current status.

Design intent is met.

4 1 - - - - - - - - - _ _ _ - .___

o FPPR AMEND. #4/#5 COMPARIS0N PAGE 53

.< x AMEND. #4 AMEND. #5 SEC/ PARAGRAPH / AMEND. #4.- PARAGRAPH / AMEND. #5 PAGE NO./N05. TABLE / FIGURE PAGE NO./N05. COMENT ITEM # TABLE / FIGURE Fire Area 88, 4-336 Fire Area 1-88 4-350 In addition to editorial provisions, the following changes 138 Zones A thru F (2-88), Zones A were entered:

thru F Fire Protection (A) NOTE: See Item 26 Attachment 1.

4-337 & 4-338 Fire trea 2-89 4-351 & 4-352 ' - In addition to editorial revisions, the following changes 139'. Fire Area 2-89 '

were entered:

Design Features - Construction (A) Amend. #5 added the information that a 6 inch sill is provided at the room entrance to contain oil spills.

~ DesignFeatures-hentilation (8) Amend. #5 added the information that fire dampers are provided at duct penetrations. The revision bar was inadvertently left off.

Fire Protection (C) Amend. #5 reflects that a temperature sensor now

' activates the automatic fire suppression system rather than an ionization smoke detector.

N/A Fire Area 1-90 4-353 & 4-354 This is a new area established under the requirements of 140 N/A (2-90) PCR 81-1037, new combustible storage areas. NOTE: See Item 28 Attachment 1.

f s

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i PAGE 54 FPPR AMEND.<f4/f5 COMFARISON

-43 4 AMENo. 84 AMEND. 85 -- <

AMEND. f4 PARAGRAPH / - AMEND. #5 -

SEC/ PARAGRAPH / COMENT PAGE N0./N05. TABLE /FIGURi . - PAGE NO./N05.

ITEM # TABLE / FIGURE 4-355 & 4-356 This is a new area estabitshed under the requirements of 141 N/A 5 i N/A Fire Area 1-M > PCR 81-1037, new combustible storage areas. NOTE: See .

s

( ,.

N Item 28 Attachment 1.

s- 3,

' 'M/A Fire h ea 1-92 ^4-357 & 4-358 The cassents on this section are identical to those for Area '

142 N/A 1-91, Item 141.

(2-92) .

4-359 & 4-360 This is a new area established under the requirements of

. 143 N/f. M/A Fire Area 93 PCR 81-103?, new combustible stcrage areas, NOTE: See Item 28 Attachment 1.

Sample Tech. Specs. 5-1 thru 5-44 This is a new section which is intended to acquaint a reader 144 N/A N/A of the FPPR with the general scope of the technical specifi- .

cations under which the Farley Fire Protection Program ss ,

conducted. The introduction to this section cautions readers to the fact the sample technical specifications are included for background information only and do not represent currently approved specifications.

Section 6.0 6-1 thru 6-301 Amend. #5 Sectioh 6 is a verbatim transcript of Section 4.4 145 Section 4.4 4-339 thru of Amend. #4. Only pagination has been effected and the Appendix A (?) Appendix A Position / Responses content and sequence of content is unchanged.

Compliance Review f

t i

Olsk F9/ Job B 11-30-83 l

@@ Line 2: / Line 2: @@
 | number = ML20083J849
 | issue date = 12/09/1983
-| title = Responds to NRC 830909 Ltr Re Violations Noted in IE Insp Repts 50-348/83-21 & 50-364/83-19.Corrective Actions:Mgt Directive Issued Reemphasizing That Fire Protection Program Reevaluation Considered on Same Basis as FSAR
+| title = Responds to NRC Re Violations Noted in IE Insp Repts 50-348/83-21 & 50-364/83-19.Corrective Actions:Mgt Directive Issued Reemphasizing That Fire Protection Program Reevaluation Considered on Same Basis as FSAR
 | author name = Clayton F
 | author affiliation = ALABAMA POWER CO.
@@ Line 11: / Line 11: @@
 | contact person =
 | document report number = NUDOCS 8401050448
+| title reference date = 09-09-1983
 | package number = ML20083J843
 | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC

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