ML091040208

Calculation No. OSC-9295, Rev. 1, NFPA 805 Transition B-1 Table/Report.

ML091040208
Person / Time
Site:	Oconee
Issue date:	05/28/2008
From:	Duke Energy Carolinas
To:	Office of Nuclear Reactor Regulation
Shared Package
ML091040234	List: ML091040205 ML091040206 ML091040207 ML091040208 ML091040214
References
OSC-9295, Rev 1
Download: ML091040208 (249)

Text

{{#Wiki_filter:Form 101.1 (R08-04) CERTIFICATION OF ENGINEERING CALCULATION Station And Unit Number Oconee Units 1, 2 &3 Title Of Calculation NFPA 805 Transition B-1 Table/Report Calculation Number OSC-9295 Total Original Pages i - iv, 1 Through 84 Total Supporting Documentation Attachments 1 (37 pages) Total Microfiche Attachments 0 Total Volumes 1 Active Calculation / Analysis Yes x No fl Microfiche Attachment List 0 Yes x No If Active is this a Type I Calculation/Analysis Yes D No x (See Form 101.4) These engineering Calculations cover QA Condition 3 Items. In accordance with established procedures, the quality has been assured and I certify that the above Calculation has been Originated, Checked, or Approved as noted below: Originated By -j Date Checked By *Wx+1- Date 28A-MY 20c'& Verification Method: Method 1 J Method 2 LI Method 3 E] Other/[I Approved By .- _'___. __",,__ _ Date Date. Issued To Document Marnagement - , Date Received By Document Management c... Date "i7J11 Complete The Spaces Below For Documentation Of Multiple Originators Or Checkers Pages ALL.- Through Originated By '/A Date Checked By _ _ _ _ _ _ . _ Date . AY *-0-0og Verification Method: Method4-] o 2 L- Method 3 LI Other -] Pages Through " Originated By Date. Checked By Date Verification Method:

• Method 1 nI Method 2 L] Method 3 nI Other nI Pages Through Originated By Date Checked By Date Verification Method: Method 1 LI Method 2 LI Method 3 LI Other LI

Form 101.2 (R3-03) Calculation Number OSC-9295 REVISION DOCUMENTATION SHEET Revision Revision Description Number 0 Initial Issue 1 Update for 10/31/08 LAR submittal

CALCULATION IMPACT ASSESSMENT (CIA) Station /Unit ONS Units 1, 2, 3 Calculation No. OSC-9295 Rev. 1 Page iv PIP No. (if applicable) 0-08-2163 By Robert A. Jackson Date 10/2/08 Prob. No. (stress & s/r use only) N/A Checked By James A. Oldham Date 10/2/08 Note: A NEDL search is NEDL reviewed to identify calculation? YES NO NOT required for (formally SAROS) calculation originals (i.e. Rev. O's) Identify in the blocks below, the groups consulted for an Impact Assessment of this calculation origination/revision. Indiv. Contacted/Date hIdiv. Contacted/Date IRES [ NGO [Power, I & C, ERRT, [QA Tech. Services (ISI), Reactor] Severe Accident Analysis, Elect. Sys. & Equip., Design

                                                                       & Reactor Supp., Civil Structural, Core Mech. &

0 MCE Ht. Lefkowitz / 10-1-08 T/H Analysis, Mech. Sys. & [Primary Systems, Balance Equip., Nuclear Design, of Plant, Rotating Equipment, Safety Analysis, and Valves & Heat Exchangers, Matls/Metallurgy/Piping] Civil] E] MOD [Mechanical Engr., Electrical Engr., Civil Engr.] El Training Local IT El Operations - OPS Support El Regulatory Compliance El Maintenance - Tech. Support El Chemistry El Work Control - Program. Supp. El Radiation Protection El Other Group No Group required to be consulted Listed below are the identified documents (ex: TECHNICAL SPECIFICATION SECTIONS, UFSAR SECTIONS, DESIGN BASIS DOCUMENTS, STATION PROCEDURES*, DRAWINGS, OTHER CALCULATIONS, ETC.) that may require revision as a result of the calculation origination or revision, the document owner/group and the change required (including any necessary PIP Corrective Actions).

• Note: Any design changes, which require changes to Station Procedures,must be transmittedas Design Deliverable Documents.

DOCUMENT GROUP CHANGE REQUIRED Multiple associated with PIP MCE See PIP 0-08-2163 OSC-9292 MCE No Changes Required OSC-9290 MCE No Change Required (Attach Additional Sheets As Required)

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 1 of 85 I. PURPOSE The purpose of this calculation is to document the comparison of the existing Oconee Nuclear Station (ONS) Fire Protection Program to the requirements presented in Chapter 3 of NFPA 805. This calculation documents fire protection features needed to protect nuclear safety-related structures, systems, or components which are designated as QA Condition 3 systems. II. BACKGROUND Under its current operating license, Oconee Nuclear Station is required to maintain the provisions of its approved fire protection program. The current licensing basis documents for Oconee are-Appendix A to BTP APCSB 9.5-1 and 1 OCFR50 Appendix R Sections IllI.G, IllI.J, lllL and 111.0. The NRC has added 10CFR50.48(c) as an alternative method of compliance to

  . _0_CF_       R50.be-F                8_(_)_stbeao.tionof       tbe[dstyoassnusstandardNElA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition). Oconee has elected to transition to 10CFR50.48(c).

As part of the transition to NFPA 805, the fundamental fire protection program design elements are required to be identified. NFPA 805 Chapter 3 defines fundamental fire protection program attributes. This report documents the comparison of the existing Oconee NuclearStation Fire Protection Program to the requirements presented in Chapter,3 of NFPA 805. Ill. METHODOLOGY The requirements presented in Chapter 3 of NFPA 805, 2001 Edition, were compared to the existing Oconee Nuclear Station fire protection program. The attributes of fire protection features and administrative programs that satisfy the provisions of NFPA 805 were documented. In addition where direct compliance was not found, a search of previous licensing and station documentation was conducted to determine if the NRC had previously approved alternative methods of compliance. Where compliance could not be determined, an open item was established. The comparison of the Oconee Nuclear Station fire protection program to Chapter 3 of NFPA 805 is summarized and further substantiated with additional detail and references in Section VI, of this report. Section VI provides the descriptions, including background and discussion, for the compliance basis of each requirement presented in Chapter 3 of NFPA 805. Section VI has three components. The first is the verbatim text of NFPA 805 (provided in italics). The second is a detailed discussion for the ONS compliance basis. The third is a list of references. Attachment A, Compliance Table lists the elements of the fire protection program for transition to the new 10 CFR50.48(c) fire protection license. This table includes the NFPA 805 Code

Calculation No..: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 2 of 85 section and text, the Compliance Statement, and the Compliance Basis. The specific elements of Chapter 3 where required by the deterministic or performance based requirements of Chapter 4 are listed in the B-3 Table of the ONS NFPA 805 Transition Report. The ONS 10CFR50.48(c) Fire Protection Program is bounded by the Power Block as defined in Attachment I of the ONS NFPA 805 Transition Report. The following standard Compliance Statements are used in the Compliance Table:

• Comply - Oconee clearly complies with the NFPA 805 requirement, through direct 'literal' compliance or compliance with the intent (e.g. NFPA 805 specifies requirement located in one document and station has it located in another document). Sections may comply and also have, an Area for Improvement which may not submitted in the LAR.
• Complies by Previous NRC Approval - Oconee does not clearly meet the NFPA 805 requirement but has been approved directly by the NRC (typically by
• Complies by Previous Licensee Evaluation - Oconee does not clearly meet the NFPA 805 requirement but the Licensee has completed an equivalency evaluation.
• Submit for NRC Approval - Oconee does not clearly meet the NFPA 805 requirement and will submit the current basis for NRC review and approval.
• Further Action Required - Oconee will take an action to revise documentation or perform additional analysis and/or actions to demonstrate compliance.
• N/A - NFPA 805 requirement does not apply to Oconee.

Open items are divided into three categories:

1. Submit for Approval

2. Further Action Required,

3. Area for Improvement - Area for Improvement are sections where Oconee is currently in compliance and station documentation will be enhanced forfurther clarification. Areas for Improvement may not be submitted in the LAR.

The comparison utilizes NEI 04-02 "Guidance for Implementing A Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)," Revision 1 as a tool to determine the method and extent to which compliance is demonstrated. The Compliance Table, showing cross-reference and compliance statements, was based on Table B-1 of NEI 04-02. IV. REFERENCES

1. Title 10, Section 50.48(c) of the Code of Federal Regulations (10CFR50.48(c)).

2. Regulatory Guide 1.205, Risk-Informed, Performance Based Fire Protection for Existing

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 3 of 85 Light-Water Nuclear Power Plants, May 2006.

3. National Fire Protection Associated (NFPA) standard, NFPA 805, Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants, 2001 edition.

4. Duke Letter to the NRC, FRAQUA Response, dated January 16, 1978.

5. Duke Letter to the NRC, Response to Appendix A to Branch Technical Position APCSB 9.5-1, dated December 31, 1976.

6. Duke Letter to the NRC, Response to AppendixA to Branch Technical Position APCSB 9.5-1, dated February 1982.

7. Duke letter to the NRC dated November 22, 1977.

8. Duke letter to the NRC dated February 17, 1978.

9. Duke Letter to the NRC dated March 18, 1981.

10. Duke to NRC, PIP 0-99-2532/LER 270/1999-04, dated February 16, 2000.

...................... n uatiooe-aReport dated August 11, 1978..

12. NRC Safety Evaluation Report dated April 28,19838.

13. NRC Safety Evaluation Report dated June 7, 1988.

14. NRC Safety Evaluation Report dated May 23, 2000.

15. NRC Letter dated April 14, 1981.

16. NRC Letter to Duke dated February 2, 1982.

17. NRC letter to Duke dated May 23, 2000.

18. NRC Exemption to various Appendix R Requirements dated August 21, 1989.

19. Design Basis Specification for Fire Protection, OSS-0254.00-00-4008, Revision 20.

20. Design Basis Specification for the Fire Detection System, OSS-0254.00-00-2017, Revision 8.

21. Design Basis Specification for the Low Pressure Service Water System, OSS-0254.00 1039, Revision.

22. Design Basis Specification for the High Pressure Service Water System, OSS-0254.00 1002, Revision 25.

23. Engineering Support Program Document for Fire Protection, Revision 4.

24. EM 4.6 "Oconee Engineering Support Program Walkdowns", Revision 6.

25. EDM-201 "Engineering Support Program", Revision 6.

26. EDM-601 "Engineering Change Manual", Revision 2.

27. ERTG-001 "Emergency Response Organization and Emergency Services Training Program".

28. EWP 7.2 "Storing Chemicals", Revision 2.

29. NSD-1 04 "Housekeeping, Materiel Condition, and Foreign Material Exclusion", Revision 27.

30. NSD-1 06 "Configuration Management", Revision 4.

31. NSD-112 "Fire Brigade Organization, Training & Responsibilities", Revision 7.

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 4 of 85

32. NSD-1 16 "Nuclear Chemical Control Program", Revision 2.

33. NSD-228 "Applicability Determination", Revision 3.

34. NSD-301 "Engineering Change Program", Revision 27.

35. NSD-313 "Control of Flammable and Combustible Materials", Revision 6.

36. NSD-314 "Hot Work Authorization", Revision 6.

37. NSD-316 "Fire Protection Impairment and Surveillance", Revision 6.

38. NSD-318 "Coatings Program", Revision 2.

39. NSD-320 "Guidance for Performing Licensing Review of Proposed Changes to the Fire Protection Program", Revision 0.

40. NSD-413 "Fluid Leak Management Program", Revision 4.

41. S.D. 3.2.14 "Fire Protection Program Compensatory Measures Process", Revision 0.

42. PIP 0-99-2753.

---

43--P-P-0-013-492.. -

44. PIP 0-02-3870.

45. PIP 0-02-6047.

46. PIP 0-05-4125.

47. PIP 0-08-2006.

48. PIP 0-08-2163.

49. PIP 0-08-2520.

50. PIP 0-08-4850.

51. Drawing KFD-109A-1.1 "Keowee Hydro Station - Flow Diagram of Service Water System".

52. Drawing Series OFD-124C.

53. Drawing OFD-135A-01-01.

54. Drawing Series O-310 K and L "Fire Protection Plan & Fire, Flood, & Pressure Boundaries".

55. SLC 16.9.2 dated 6/28105.

56. SLC 16.9.3 dated 1/14/04.

57. SLC 16.9.4 dated 1/30/00.

58. SLC 16.9.5 dated 1/30/00.

59. SLC 16.9.6 dated 12/14/04.

60. SLC 16.9.7 dated 3/31/05.

61. SLC 16.13.1 dated 5/13/04.

62. OP/0/A/1 600/004 "Operation of the SSF C02 System".

63. PT/0/AJ0400/002 "SSF C02 Test".

64. PT/1/A/2200/006 "KHU-1 C02 System Surveillance".

65. PT/21A/2200/006 "KHU-2 C02 System Surveillance".

66. PT/O/B/0250/030 "Quarterly Fire Brigade Equipment Inspection", Revision 20.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 5 of 85

67. PT/O/A/2200/010 "KHS Fire Protection Equipment Surveillance" Revision 25.

68. PT/O/B/2000/001 "Preparation and Conduct of Emergency Drills".

69. PT/O/A/0250/010 A "Fire Protection System Monthly Inspection", Revision 65.

70. RPIO/BI1 000/029 "Fire Brigade Response", Revision 11.

71. Calculation OSC-1626, Pressure at Hose Stations in Auxiliary and Turbine Building, Revision 2.

72. Calculation OSC-7185, Fire Evaluation of the East West Penetration Room Wall, Revision 0..

73. Calculation OSC-7350, ONS Penetration Seal Database and 86-10 Evaluations, Revision 6.

74. Calculation OSC-7858, Hydraulic Calculation for 2A Feedwater Turbine and. TO Tank Suppression System, Revision 0.

75. Calculation OSC-7359 (DPC 1435.00-00-0006), Calculation for the Technical Basis for Fire Barrier Penetration Seals, Revision 1.

76. Calculation OSC-9292, NFPA 805 Transition B-3 Table/Report, Revision 1.

77. Calculation OSC-9302, Fire Protection Evaluation for Balance of Plant (BOP) Partitioning, Revision 0.

78. Fire Suppression NFPA Code Review calculations.

79. Duke Corporate Roof Management Program.

80. General Employee Training - Plant Access Training.

81. Oconee Emergency Plan.

82. Oconee NFPA 805 Transition Report, Revision 1.

83. Oconee Nuclear Site Fire Plan.

84. Specification OSS-241.00-00-0004 "Conventional Thermal Insulation", Revision 5.

85. Specification OSS.241A "Reactor Building and Piping Heat Insulation (Metal Reflective Type), Revision 4.

86. UFSAR Section 9.5.1 dated 12/31/05.

V. STATUS OF NFPA 805 COMPLIANCE Compliance Statement Total Notes Comply 47 Comply by Previous NRC 23 Approval Comply by Previous 5 Licensee Evaluation Submit for NRC Approval 3 Section 3.3.1.2(1), Section 3.3.1.3.4, and 3.3.7

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2. & 3 Page 6 of 85 Further Action Required 24 Oconee will take an action to revise documentation or perform additional analysis and/or actions to demonstrate compliance. Area for Improvement 11 Oconee is compliant and areas to enhance station documentation are identified N/A 10 Section 3.9.4, 3.10.1 -3.10.10, and Section 3.11.5 Note that there are more method of compliance statements than code sections as some sections comply by various means or additional actions are required. Open Items The following is a list of open items (Submit for Approval, Further Action Required, Area for Improvement) and actions required for resolution. PIP 0-08-2163 has been generated to track --. ----- the-open-items--in-the*-feollwing-table-Additienal-detail-ean-be-feund-in-the-applicable-report--- section. Section Requirement Action 3.2.2.4 The policy document for the Fire Revise station documentation to state the Protection Plan shall identify the NRC is the AHJ for fire protection appropriate AHJ. changes requiring approval. 3.3.1.2(1) Wood used within the power block Submit for NRC Approval; Oconee shall be listed with a fire-retardant permits non-treated wood for concrete application forming or per design documents. 3.3.1.2(2) Plastic sheeting materials used in Revise NSD-313 (or an alternative the power block shall be fire- administrative control document) to retardant types that have passed specifically address plastic sheeting NFPA 701, or equivalent, materials shall conform to NFPA 701 requirements, or equivalent. 3.3.1.3.1 A hot work safety procedure shall Evaluate NSD-314 to determine if NFPA be developed, implemented, and 241 should be referenced. periodically updated as necessary in accordance with NFPA 51B, and NFPA 241 3.3.1.3.3 Open flames or combustion- Revise station leak testing procedures to generated smoke shall not be ensure open flames and combustion permitted for leak or air flow generated smoke are not used. testing. 3.3.1.3.4 Portable fuel-fired heaters shall Submit for NRC Approval; Oconee not be permitted in plant areas permits fossil fuel (gas and oil-fired) containing equipment important to heaters. nuclear safety or where there is a potential for radiological releases resulting from a fire.

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 7 of 85 Section Requirement Action 3.3.3 Interior wall, floor and ceiling finish Revise NSD-318 to include the classifications shall be in appropriate code specifications. accordance with NFPA 101. 3.3.5.1 Wiring above suspended ceiling Revise applicable station documentation shall be kept to a minimum, for compliance with this section. 3.3.5.2 Only metal tray and metal conduits Revise applicable station documentation shall be used for electrical for compliance with this section. raceways. 3.3.5.3 Electric cable construction shall Revise station documentation that non-comply with a flame propagation rated cables (including data/phone/ test. video) shall not be routed in cable trays with nuclear safety related cables.

                  -~                 -----.--....-...               ______________________________________

3.3.7 Bulk flammable gas storage shall Submit for NRC Approval; Storage of not be permitted inside structures flammable gas cylinders is permitted for housing systems, equipment, or use in plant operations and systems per components important to nuclear design safety. 3.3.7.1 NFPA 50A shall be followed for Perform a NFPA 50A code compliance hydrogen storage. review for outdoor hydrogen storage. 3.3.7.2 Outdoor high pressure flammable Resolve propane tank storage gas storage container shall be configuration; evaluate or modify the located so that the long axis is not tank. pointed at buildings. 3.3.8 Bulk storage of flammable and Perform NFPA 30 code compliance combustible liquids, review for bulk storage of the Turbine Building and Keowee lube oil storage locations. 3.3.9 Transformer oil collection basins Revise Transformer Water Spray test and drain paths shall be procedures to ensure drainage is. periodically inspected to ensure inspected during annual flow tests. they are free of debris and capable of performing their design function. 3.3.10 Administrative controls shall Revise NSD-104 and/or NSD-413 to require the prompt cleanup of oil clearlyindicate itisa NRC requirementto on insulation, promptly remove oil from insulation. 3.3.11 Adequate clearance, free of Revise NSD-313 to include PRA Zone of combustible material, shall be Influence distance from PRA fire maintained around energized modeling as exclusion area for transient electrical equipment. combustibles. 3.4.1(a) The fire brigade shall comply with Ensure NFPA 600 code review is NFPA 600. formally documented.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 8 of 85 Section Requirement Action 3.4.2.1 Pre-Fire Plans shall detail the fire Review ONS Fire Plan for compliance area configuration and fire hazards with NFPA 805 requirements. to be encountered in the fire area, along with any nuclear safety components and fire protection systems and features that are present. 3.4.6 An effective emergency Ensure resolution of PIP 0-08-4820 communications capability shall be satisfies the requirement of this section. provided for the industrial fire brigade.

-        3- 1b-)-- -T h-e--fire w---tr-s-p-ply-sh-ai-b-e- -En-sore--any- --  cre-dited- -s-uppres-si-on-capable of delivering the largest systems are within the design flow system design demand and hose capabilities of the fire pump.

stream. 3.5.3 Fire pumps shall be installed in Ensure the Keowee fire pump accordance with NFPA 20 and replacement satisfies the requirements shall provide 100% of the required of this section flow and pressure. 3.5.4 Electric motor-driven fire pumps Both HPSW pumps are. currently connected to redundant Class IE powered from the same Unit. HPSW emergency power buses capable pumps should not be powered from a of providing 100 percent of the single unit. Consider connection to PSW required flow rate and pressure or an alternate unit. shall be provided. 3.5.6 Fire pumps shall be provided with Document resolution of PIP 0-02-3870 automatic start and manual stop to install manual stop on the HPSW only. pumps. 3.5.10 An underground yard fire main Perform a NFPA 24 code compliance loop, designed and installed in review. accordance with NFPA 24, shall be installed to furnish anticipated water requirements. 3.6.1 For all power block buildings, Perform a NFPA 14 code compliance Class III standpipe and hose review. systems shall be installed in accordance with NFPA 14. 3.7 Where provided, fire extinguishers Perform a NFPA 10 code compliance of the appropriate number, size, review. and type shall be provide in accordance with NFPA 10.

Calculation No.: OSC-9295 Revision No.: I_1 Applicable Units: Oconee Unit 1, 2, & 3 Page 9 of 85 Section Requirement Action 3.8.1 Fire alarm initiating devices shall Perform a NFPA 72 code compliance be installed in accordance with review. NFPA 72. 3.9.1 Automatic or manual water based Review applicable existing code fire suppression systems required compliance reviews. Perform additional by Chapter 4 shall be installed in reviews as necessary. accordance with NFPA 13 or 15. 3.10.1 Automatic total flooding or local Perform a NFPA 12 code compliance application gaseous fire review. Includes addressing open items 3.10.3 suppression systems shall be in subsequent Section 3.10.3, 3.10.9 3.10.9 installed in accordance with NFPA and 3.10.10 in the code compliance

12. review.

3.10.10 3.11.1 Each major building within the Upgrade fire barriers in accordance with power block shall be separated open items identified in OSC-9302. from the others by barriers having a designated fire resistance rating of 3 hours or by open space of at least 50 ft (15.2 m) or space that meets the requirements of NFPA 80A. 3.11.2 Fire barriers required by Chapter 4 Upgrade fire barriers in accordance with shall include a specific fire- open items identified in OSC-9302. resistance rating. 3.11.3 Penetrations in fire barriers shall Upgrade fire barrier penetrations in be provided with listed fire-rated accordance with open items identified in door assemblies or listed rated fire OSC-9302. dampers having a fire resistance rating consistent with the designed fire resistance rating of the barriers as determined by Chapter 4. 3.11.4 Through penetration fire stops for Upgrade fire barrier penetration seals in penetrations shall be protected. accordance with open items identified in OSC-9302. Review if credited penetration seals are evaluated in Calculation OSC-7350.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1,2, & 3 Page 10 of 85 VI. NFPA 805 COMPLIANCE

SUMMARY

The information is a compilation of how the ONS Fire Protection Program supports each requirement of NFPA 805, Chapter 3. Section 3.1 General This chapter contains the fundamental elements of the fire protection programand specifies the minimum design requirements for fire protection systems and features. These fire protection program elements and minimum design requirements shafl not be subject to the performance-based methods permitted elsewhere in this standard. Previously approved alternativesfrom the fundamentalprotectionprogram attributesof this chapterby the AHJ take precedence over the requirements containedherein. Oconee Nuclear Station (ONS) compliance with the fire protection program elements and

               .rnimum-_design-requirements-presented-in-NFP-A-805-Chapter3-is-noLbased-on-the.

performance-based methods permitted elsewhere in the standard. The following discussion of Chapter 3 requirements documents ONS compliance or intended compliance with the individual code sections. In addition documentation is provided where previous NRC approval has been granted for a deviation to the code. Section 3.2 Fire Protection Plan 3.2.1 Intent A site-wide fire protectionplan shall be established. This plan shall document management policy and program direction and shall define the responsibilities of those individuals responsiblefor the plan's implementation. This section establishesthe criteriafor an integrated combination of components, procedures, and personnel to implement all fire protection program activities. The Design Bases Specification for Fire Protection, OSS-0254.00-00-4008, documents the ONS Fire Protection Program including management policy, program direction and defines the organization, responsibilities and requirements of involved personnel. Many of these attributes have been updated and revised since original correspondence with the NRC including the January 16, 1978 letter from Duke to the NRC in response to the Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance (FRAQUA) letter and the original and updated Response to Appendix A to Branch Technical Position APCSB 9.5-1. The ONS fire protection program is currently based on, and complies with, the requirements of 10CFR50.48(a). Note that Oconee uses the terminology Fire Plan to represent the fire pre-plan (fire-fighting strategies) for fire scenarios at the site and uses the term Fire Protection Program (per I OCFR50.48) to delineate the implementation of fire protection policies at the plant. Reference(s): Design Basis Specification for Fire Protection

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page II of 85 Duke Letter to the NRC, FRAQUA Response, January 16, 1978 Duke Letter to the NRC, Response to Appendix A to Branch Technical Position APCSB 9.5-1, December 31, 1976 Duke Letter to the NRC, Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 3.2.2 ManagementPolicy Direction and Responsibility A policy document shallbe preparedthat defines managementauthorityand responsibilities and establishes the generalpolicy for the site fire protectionprogram. The Design Bases Specification for Fire Protection includes the management policy of the fire protection program organization and responsibilities. The Design Bases Specification for Fire Protection and Engineering Support Document for Fire Protection provide detailed information -___ abeu.+t-the-Fi re-PDrotection-Program---,-.he-D-esig.n-Bases-Speeifica-uOn-fr--Fire--PreLeeton------- provides the basis and regulatory framework upon which the Oconee Nuclear Station Fire Protection Program is based. The Engineering Support Program Document for Fire Protection provides the fire protection engineer an aid in defining the Oconee Fire Protection Program. 3.2.2.1 The policy document shalldesignate the seniormanagementposition with immediate authority and responsibilityfor the fire protection program.

        *The Site Vice President has the overall responsibility for the fire protection program at Oconee Nuclear Station. The daily programmatic administration of the fire protection program at Oconee is delegated through line management to the Fire Protection Engineer. Responsibility for the fire brigade and fire brigade training are delegated to the emergency planning and training groups respectively.

Reference(s): Design Basis Specification for Fire Protection 3.2.2.2 The policy document shall designate a position responsible for the daily administrationand coordinationof the fire protectionprogram and its implementation. The Fire Protection Engineer has the overall lead responsibility for the Fire Protection Program and its administration and coordination for all facilities that are important to nuclear safety or covered by the nuclear insurer. The fire protection engineer is experienced in nuclear fire protection and is qualified consistent with member grade status in the Society of Fire Protection Engineers. All other buildings are under the oversight of the Commodities and Facilities organization.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units:' Oconee Unit 1, 2, & 3 Page 12 of 85 Reference(s): Design Basis Specification for Fire Protection 3.2.2.3 The policy document shall define the fire protection interfaces with other organizationsand assign responsibilitiesfor the coordinationof activities.In addition, this policy document shall identify the variousplantpositions having the authorityfor implementing the various areasof the fire protection program. Fire protection interfaces are defined in the Design Basis Specification for Fire Protection and the Engineering Support Program Document for Fire Protection. The positions having responsibilities and authority to implement portions of the fire protection program are described below. These positions were originally described in the ONS FRAQUA response and ONS Comparison to BTP 9.5-1 and have evolved since original publication. Fire Protection Engineer The Fire Protection Engineer (FPE) is responsible for the overall administration of the fire protection program. This individual may not directly control or be responsible for every aspect of fire protection, detection, or mitigation at Oconee; however the individual is required to be knowledgeable of each aspect. This individual will interface with each plant internal and external customer regarding a fire protection concern. Fire Protection concerns can be regulatory, local or national code interpretations, insurance compliance, equipment configurations, equipment specifications, or industry issues. The fire protection program encompasses all structures, systems, and components important to plant and nuclear safety and those other structures, systems, and components covered by the nuclear insurer. The FPE is also the AHJ at the site level. Fire Protection Engineering Fleet Lead The Fire Protection Engineering Fleet Lead provides programmatic support (overall Department direction and policy in matters pertaining to Fire Protection and Appendix R safe shutdown) to the three Duke Energy site Fire Protection Engineers. This was formerly identified as Fire Protection Consultant. Fire Detection and Instrumentation Enqineer The Fire Detection and Instrumentation Engineer responsibilities may be divided among different individuals, ifmanagement thinks this is prudent. The person responsible for fire detection and/ or instrumentation will respond to all questions and system operations concerning operational characteristics, commitments, and regulatory requirements. This person(s) will interface with plant craft personnel, the fire protection engineer, and other internal and external customers. The fire detection and instrumentation engineer is also responsible for keeping the FPE notified of major system problems.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 13 of 85 Service Water System Engineers (HPSW, LPSW, and CCW) The service water system engineers are responsible for notifying the FPE of any problem on their system that will affect the performance of the fire protection systems. The divisions of hydraulic responsibilities among the various engineers are that main flow paths are the concerns of the individual system engineers and the portion of the piping that is specifically designed to support fire fighting and/ or suppression are responsibilities of the FPE. There are instances where both individuals may need to combine input to problem resolution techniques. Standby Shutdown Facility (SSF) Engineer This person is responsible for interfacing with the FPE to ensure the 10 CFR50, Appendix "R" commitments are maintained within compliance. Fire Briqade Specialist

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..-This-person-currentiy-resides--in--Emergericy--Pianning_---They---are-responsible---for--the---.--.

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preparedness, readiness, training, and coordination of all drill exercises for the site fire brigade members. The FPE assists the Fire Brigade Specialist in drill preparation, location, expectations and in drill response observations. The FPE is responsible for assisting in the maintenance of the Pre-Fire Plan, which is owned by the Fire Brigade Specialist. Facilities and Maintenance Coordinator This person works for mrporate Facilities. They are responsible for the fire protection features associated with those structures on Oconee Nuclear site that do not contain structures, systems, and components that are important to nuclear safety and/or covered by the nuclear insurer. This person also manages those individuals directly or indirectly that perform some of the preventative maintenance programs on fire hoses, extinguishers, detection and suppression systems, and

        .misc. equipment repair.

Operations, Radwaste, SPOC and Plant Maintenance' These plant organizations are responsible for the daily general plant maintenance, testing, and inspection of fire protection systems located within the Protected Area. Environmental Manaqement Chemical Control Coordinator This person is responsible for identifying to the fire protection engineer any new chemicals allowed on-site that would increase the combustible/flammable loading while the product is "In-Use" or in storage. Site Personnel Fire prevention is a concern of all individuals on site. Each person shall notify the Control Room via the emergency number (4911) of any fire. Plant personnel should use normal plant communications to ensure notification to the fire protection engineer or appropriate group of any fire protection feature impairment, unsafe combustible/flammable loading, or suspected fire equipment damage.

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 14 of 85 Fire Protection Working Group This team is comprised of each nuclear site's fire protection engineer, the fire brigade specialist from each site and fire protection engineering fleet lead. The Fire Protection Working Group's major goals are communication and team effort on common problems. The Working Group constantly reviews practices, methods, and results to achieve a direct impact on the quality of work practices. Post-Fire Safe Shutdown Engineer This was formerly identified as Appendix R Engineer. The purpose of the Post-Fire Safe Shutdown Engineer is to evaluate the effect of plant mods, failures, and configuration changes on the ability to safely shutdown the plant in the event of a fire. 3=Site-Pst=Fire-Safe-hutdown-Enqineer

        .....                                        .------     -         -----

This was formerly identified as 3-Site Appendix R Engineer. The purpose of the 3-Site Post-Fire Safe Shutdown Engineer is to promote consistency in thought and share resolution of issues which may impact the ability to safely shutdown the plant in the event of a fire.

References:

Design Basis Specification for Fire Protection Engineering Support Program Document for Fire Protection 3.2.2.4 The policy document shall identify the appropriateAHJ for the various areas of the fire protectionprogram. The NRC is the considered AHJ for fire protection changes requiring approval. The NRC is notified of changes to the Fire Protection Program in accordance with NSD-320. NSD-320 screens changes to the Fire Protection Program to determine if NRC approval is required. {Further Action Required - Revise the Design Basis Specification for Fire Protection which is the primary fire protection program policy document to state the NRC is the AHJ for fire protection changes requiring approval.}

References:

NSD-320 "Guidance for Performing Licensing Review of Proposed Changes to the Fire Protection Program" 3.2.3 Procedures Proceduresshall be establishedfor implementation of the fire protection program.In addition to procedures that could be required by other sections of the standard,the procedures to accomplish the following shall be established:

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1,2, &3 Page 15 of 85 (1) Inspection, testing, and maintenance for fire protection systems and features credited by the fire protectionprogram Inspection, testing, and maintenance (ITM) for fire protection systems is provided for the following systems. A brief description of the fire protection system and applicable ITM criteria is provided below from the Engineering Support Program Document for Fire Protection. Detailed listings of the applicable surveillance procedures are documented in the Engineering Support Program Document rather than being repeated here. System Components/Test/Notes Frequency Fire Main Main line HPSW system valves and those Monthly System valves used for fire protection check Fire hydrants and Post Indicator Valves Semi-Annual stroked test and flush Fire water system flow test Every three years Elevated Water Storage Tank (EWST) Every 5 years inspection Automatic Various fire suppression systems are tested Varies based on system Suppression in accordance with NFPA Requirements, Systems except for those systems which could potentially cause inadvertent adverse plant power production interruptions and/or personnel or reactor safety consequences Carbon Carbon Dioxide (Cardox) extinguishing Monthly and semiannual Dioxide system inspection and maintenance basis Extinguishing Systems Halon Vault Halon extinguishing system inspection Annual Extinguishing and maintenance Systems Fire Main plant fire detection panel is monitored Once per shift Detection Fire detection panel and Honeywell Monthly Systems detectors check Accessible fire detectors physical check Semi-annual Detector sensitivity check Annual Standpipe Fire hose inspection Monthly Systems Hose hydro test Hoses considered to be influenced by the environment annually; all others on a 3 year schedule Fire hose in containment inspection Refueling outage or at any time the building is open for

Calculation No.:. OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 16 of 85 System Components/TestlNotes. Frequency more than 30 days during a cycle Portable Fire Fire extinguisher check Monthly Extinguishers Fire extinguisher inspection Annually Carbon Dioxide and Dry Chemical 6 year extinguisher hydro Fire Pumps The HPSW pumps are currently tested to The NFPA requirement is both NFPA and ASME Section XI monthly and the ASME requirements because these pumps serve a requirement is quarterly dual function Fire Brigade Fire brigade equipment inspection and Quarterly Equipment maintenance Fire Barriers Penetration seal and fire stop inspection 1. Ten percent of each type of and NRC committed fire barrier Penetration penetration seal every 18 Seals months with all seals within 15 years

2. 100% of the exposed surface of each rated barrier every 18 months Fire Doors Fire door inspection Bimonthly Fire Fire .damper inspection 1. Ten percent of the NRC Dampers committed.fire dampers every 18 months with all fire dampers within 15 years

2. Electrically controlled fire dampers that use sensors to close in the cable and equipment rooms annually Reference(s): Engineering Support Program Document for Fire Protection Design Basis Specification for Fire Protection (2) Compensatory actions implemented when fire protection systems and other systems creditedby the fireprotectionprogramand this standardcannotperform their intended function and limits on impairment duration Fire protection systems credited for the fire protection program are documented in the

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 17 of 85 Oconee Selected Licensee Commitments (SLCs) 16.9.1 through 16.9.6. The Selected Licensee Commitments include inspection and testing requirements for those fire protection systems and features which are committed to be functional. SLCs also specify remedial actions to be taken in the event that a system orfeature is inoperable. Directions for compensatory actions when systems credited by the fire protection program are not operable are provided in the SLC 16.9.1 through 16.9.6, NSD 316 and S.D. 3.2.14. These documents provide the roadmap and direction to be taken in the event a system is impaired. NSD-316, "Fire Protection Impairment and Surveillance" provides the requirements and responsibilities for reporting fire protection feature impairments and ensures proper compensatory actions are satisfied for licensing, insurance and good fire protection practices. Impairments include any action or condition which inhibits any fire protection feature to function as designed. Compensatory actions are the steps taken to minimize the fire risk potential due to a fire protection feature impairment such as-staging-backup-suppression,Jtemporarvyfire detectiorinJiire-watciLtours,_etc__Tbis --- directive provides the directions and requirements to notify the fire brigade of any fire impairment to ensure restoration of impaired features occurs in a timely manner. This directive applies to all fire protection features in the owner controlled area, and to all work groups that impair fire protection features. Oconee Nuclear Site, Site Directives Manual S.D. 3.2.14 "Fire Protection Program Compensatory Measures Process," assigns responsibilities for actions and provides direction, including process charts, for actions to be taken when a fire protection component or system is not operable. The Site Directive also provides a table that lists fire protection program components, any associated Technical Specification or Selected Licensee Commitment (SLC) and the actions to be implemented if that component is impaired. Reference(s): NSD-316 "Fire Protection Impairment and Surveillance" S.D. 3.2.14 "Fire Protection Program Compensatory Measures Process" SLC 16.9.1_,.2,.3,.4,.5,.6 (3) Reviews of fire protection program - relatedperformance and trends Reviews of the Fire Protection Program are conducted on a routine basis to evaluate performance and determine if any trends exist. The scope and responsibilities for those reviews are listed in Section 6.1 "Parameter Monitoring and Trending" of the Engineering Support Program Document for Fire Protection. The results of the reviews are provided in an annual Fire Protection Program Heath Report. Inaddition, internal 3-year audits and 3-year NRC triennial audits are performed. Reference(s): Engineering Support Program Document for Fire Protection

Calculation No.: OSC-9295 Revision No.: I1_ Applicable Units: Oconee Unit 1, 2, & 3 Page 18 of 85 EDM-201 "Engineering Support Program" (4) Reviews of physicalplant modificationsandprocedure changesfor impact on the fire protection program All physical plant modifications and procedure changes are screened for the impact on the fire protection program. NSD-301 "Engineering Change Program" provides the requirements for changes to a nuclear facility. A table is provided for a screening process for potential Fire Protection System impacts. . . Enngineering Design Manual _(EDM)_ 601 _Engineerinrg Change Manual" provides detailed information to help the reviewer determine if the change has the potential to impact any fire protection feature. The manual specifies the requirements for changes, permanent and temporary, to the nuclear station. The manual specifies the roles and responsibilities for involved personnel and is applicable to both QA and non-QA structures, systems and components (SSC) and includes-the Keowee facility. An extensive screening checklist for fire protection features is provided. In addition, a PRA Impact Review and a Fire Protection (10CFR50.48) Electrical Review is required. Reference(s): NSD-301 "Engineering Change Program" EDM-601 "Engineering Change Manual" * (5) Long-term maintenance and configuration of the fire protection program The fire protection program is maintained through NSD-106. NSD-106 "Configuration Management" provides the basis for ensuring that Fire Protection Program and its features are properly maintained. Appendix A.106 "Functional Areas for Configuration Management" includes Fire Protection/Appendix R in the listing of Key Processes that are required to be considered to maintain the facility design consistent with the licensing bases and other design bases. NSD-228 "Applicability Determination", Appendix E includes a specific screening checklist that will direct user to NSD-320 "Guidance for Performing Licensing Review of Proposed Changes to the Fire Protection Program" to determine impact on the Fire Protection Licensing basis. The NRC approved the ONS Units 1, 2, 3 Operating Licenses in a letter transmittal

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 19 of 85 dated May 23, 2000 and the associated License Renewal SER. Oconee Units 1, 2 and 3 are licensed to operate until 2033. In order to obtain license renewal, detailed guidelines and commitments were provided to ensure fire protection functions are maintained during the period of extended operation. In the letter, the following was stated regarding the fire protection- program: "Duke Energy Corporation shall implement andmaintainin effect all provisions of the approved fire protectionprogram as describedin the UFSAR for the facilityand as approvedin the SER's datedAugust 11, 1978, and April 28, 1983; October5, 1978, and June 9, 1981 Supplements to the SER dated August 11, 1978; and Exemptions dated February2, 1982; August 31, 1983; December 27, 1984; December 5, 1988; and August 21, 1989 subject to the following provision: The licensee may make changes to the approved fire protectionprogram without priorapprovalof the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire." Reference(s): NSD-1 06 "Configuration Management" NSD-228 "Applicability Determination" NRC Letter to Duke dated May 23, 2000 NRC SER dated May 23, 2000 (6) Emergency response procedures for the plantindustrialfire brigade The Emergency Planning Group oversees the Plant Fire Brigade, training and procedures. The Fire Plan (pre-fire plan) includes Fire Brigade Standard Operating Guidance (SOG) for various emergency responses. The Fire Brigade is provided the Fire Plan which details the potential hazards and the available fire fighting equipment for the plant along with a graphic representation of the layout of the area. Additional details on the Fire Brigade are presented in Section 3.4. The coordination between the Fire Brigade and other plant groups during a fire emergency is defined in NSD-112. When the Control Room is notified of a fire, Procedure RP/O/B/1000/029 "Fire Brigade Response" is implemented. The procedure instructs the control room personnel on their response and provides direction on managing the conduct of the fire fighting activities including contacting offsite Fire Departments. Reference(s): Oconee Nuclear Site Fire Plan NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" RP/O/B/1 000/029 "Fire Brigade Response"

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 20 of 85 Section 3.3 Prevention A fire prevention program with the goal of preventing a fire from startingshall be established, documented, and implemented as part of the fire protection program. The two. basic components of the fire prevention program shall consist of both of the following: (1) Preventionof fires and fire spreadby controls on operationalactMties (2) Design controls that restrictthe use of combustible materials The design control requirementslisted in the remainderof this section shall be provided as described. The Oconee Nuclear Station (ONS) fire prevention program is described in the Design Basis Specification for Fire Protection. The Design Basis Specification for Fire Protection identifies activities for fire prevention and design controls for use of combustible materials. Reference(s): Design Basis Specification for Fire Protection 33.1 FirePrevention for OperationalActivities The fire prevention program activitiesshall consist of the necessaryelements to address the control of ignition sourcesandthe use of transientcombustible materialsduring all aspects of plant operations. The fire prevention program shall focus on the human and programmatic elements necessary to prevent fires from starting or, should a fire start, to keep the fire as small as possible. As part of defense-in-depth, administrative fire prevention programs for hot work, storage of combustibles and flammable material, compensatory action plans, safety precautions and employee training contribute to limit fire ignition and/or growth and ONS. Fire prevention programs are implemented to address the control of ignition sources and the use of transient combustible materials and plant access training includes instruction on fire prevention during General Employee Training (GET). Reference(s): General Employee Training - Plant Access Training NSD-1 04, "Housekeeping, Materiel Condition, and Foreign Material Exclusion" NSD-31,3 "Control of Flammable and Combustible Materials" NSD-314 "Hot Work Authorization" NSD-316 "Fire Protection Impairment and Surveillance" 3.3.1.1 GeneralFire PreventionActivities The fire prevention activitiesshall include but not be limited to the following programelements: (1) Trainingon fire safety information for all employees,and contractorsincluding,as a minimum, familiarizationwith plant fire prevention procedures,fire reporting,andplant emergency alarms.

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 21 of 85 The prevention of fires and fire spread are managed through administrative controls and training of personnel. All persons who are authorized access to the plant receive instruction in maintaining fire barriers, controlling fire loading and hot work activities, plant emergency alarms, and the proper response to the discovery of a fire. Reference(s): General Employee Training - Plant Access Training NSD-313 "Control of Flammable and Combustible Materials" NSD-314 "Hot Work Authorization" NSD-316 "Fire Protection Impairment and Surveillance" (2) Documented plant inspections including provisions for corrective actions for conditions where unanalyzed fire hazards are identified. The responsibilities of the Fire Protection Engineer include periodic surveillance of plant areas for compliance with the Fire Protection Program. Plant Engineers, including the FPE, perform plant walkdowns in accordance with Procedure EM 4.6 "Oconee Engineering Support Program Walkdowns" which provides guidance on observations that should be made including fire hazards. Any unanalyzed fire hazards are documented in the PIP program. Plant inspections may be performed by other groups as delegated by the FPE on other frequencies. Reference(s): EM 4.6 "Oconee Engineering Support Program Walkdowns,' Engineering Support Document for Fire Protection (3) Administrative controls addressing the review of plant modifications and maintenance to ensure that both fire hazardsand the impact on plant fire protection systems and features are minimized. All plant modifications and changes are screened for impact on the plant fire protection program through NSD-301, NSD-228, and/or EDM-601. NSD-301 "Engineering Change Program" provides the requirements for evaluation of changes to a nuclear facility. A table is provided for a screening process for potential Fire Protection System impacts. NSD-228 "Applicability Determination", Appendix E includes a specific screening checklist that will direct user to NSD-320 "Guidance for Performing Licensing Review of Proposed Changes to the Fire Protection Program" to determine impact on the Fire Protection Licensing basis.

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 22 of 85 Engineering Directives Manual (EDM) 601 "Engineering Change Manual" provides detailed information to help the reviewer determine ifthe change has the potential to impact any fire protection feature. The EDM specifies the requirements for changes, permanent and temporary, to a nuclear station. The Manual specifies the roles and responsibilities for involved personnel and is applicable to both QA and non-QA structures, systems and components (SSC) and includes the Keowee facility. An extensive screening checklist for fire protection features is provided. In addition, a PRA Impact Review and a Fire Protection (10CFR50.48) Electrical Review is required. Reference(s): NSD-228 "Applicability Determination" NSD-301 "Engineering Change Program" NSD-320 "Guidance for Performing Licensing Review of Proposed Changes to the Fire Protection Program"

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    -----.--.-.-.----.-......----   E M-6 "Engineering- ha nge-M anualI                 ....... ........

3.3.1.2 Control of Combustible Materials Proceduresfor the control of general housekeeping practices and the control of transient combustibles shall be developed and implemented. Control of combustible materials and housekeeping practices at ONS is implemented through NDS-313, NSD-104 and EWP 7.2. The control of combustible materials is implemented by NSD- 313 "Control of Flammable and Combustible Materials." Control of housekeeping is implemented by NSD-104 "Housekeeping, Materiel Condition & Foreign Material Exclusion" which promotes plant cleanliness. EWP 7.2 "Storing Chemicals" provide specific storage requirements for control of chemicals (including flammable and combustible liquids and gases). Reference(s): NSD-1 04 "Housekeeping, Materiel Condition, and Foreign Material Exclusion" NSD-313 "Control of Flammable and Combustible Materials" EWP 7.2 "Storing Chemicals" These proceduresshall include but not be limited to the following program elements: (1) Wood used within the power block shall be listedpressure-impregnatedorcoated with a listed fire-retardantapplication. Exception: Cribbingtimbers 6 in. by 6 in. (15.2 cm by 15.2 cm) or largershall not be requiredto be fire-retardanttreated. NSD-313 requires only fire retardant wood be used within the power production and

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1. 2, & 3 Page 23 of 85 safe shutdown areas unless approval is obtained from the FPE. Three exceptions are allowed; dunnage (large timbers) for specific work activities, concrete forming, and where specified on design documents. {Submit for NRC Approval - NFPA 805 only permits fire retardant treated wood or dunnage. NSD-313 permits concrete forming or per design documents.} Reference(s): NSD-313 "Control of Flammable and Combustible Materials" (2) Plasticsheetingmaterialsused in the power block shall be fire-retardanttypes that have passed NFPA 701, Standard Methods of Fire Tests for Flame Propagationof Textiles and Films, large-scaletests, orequivalent. NSD-31 3 specifies that only fire resistant plastic (i.e. Griffolyn) be used within the power production and safe shutdown areas. {Area for Improvement - Revise NSD-313 to specifically address plastic sheeting materials shall conform to NFPA 701 requirements, or equivalent.} Reference(s): NSD-313 "Control of Flammable and Combustible Materials" (3) Waste, debris, scrap,packing materials,or other combustibles shall be removed from an area immediately following the completion of work or at the end of the shift, whichever comes first. NSD-1 04 "Housekeeping, Materiel Condition, and Foreign Material Exclusion" provides direction on maintaining the cleanliness of the plant. The Directive discusses Housekeeping Zones which specify the level of cleanliness for various areas and states that "Upon completion of the maintenance activity, the work supervisor or designee shall ensure the Housekeeping Zone is returned to at least its original condition." The Directive specifies that"During outage work, the Job Sponsor working with the supervisor for the crew will ensure the work area is returned to a normal or better state of appearance once work is complete." NSD-313 "Control of Flammable and Combustible Materials" provides the following requirements for in-use materials: "At the end of each shift, housekeeping zones/work areas shall be cleared of all unnecessary materials and all waste/trash material removed and properly disposed." Reference(s): NSD-104 "Housekeeping, Materiel Condition, and Foreign Material Exclusion"

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 24 of 85 NSD-313 "Control of Flammable and Combustible Materials" (4) Combustible storage or staging areas shall be designated, and limits shall be established on the types and quantitiesof stored materials. Combustible Material storage and staging areas are specified in NSD-313. The directive discusses generally the temporary and permanent storage of the various types of combustible materials, limitations, and Oconee site specific information. The FPE establishes the material inventory (limit) forthe areas and the amount of material can not be changed without approval of the FPE. Changes to the storage restrictions or locations require completion of a change form. Reference(s): NSD-313 "Control of Flammable and Combustible Materials" (5) Controls on use and storage of flammable and combustible liquids shall be in

                ,accordance with NFPA 30, Flammable and Combustible Liquids Code, or other applicable NFPA standards.

The controls on the use and storage of flammable and combustible liquids are specified in NSD-313. NSD-313 references NFPA 30 as a source document for use and storage of flammable and combustible liquids. EWP 7.2 provides specific storage requirements for control of chemicals (including flammable and combustible liquids) and references NSD-313. Reference(s): NSD-313 "Control of Flammable and Combustible Materials" EWP 7-2 "Storing Chemicals" (6) Controls on use and storage of flammable gases shall be in accordance with applicable NFPA standards. The controls on the use and storage of flammable gases are specified in NSD-313. NSD-313 references NFPA 55 and OSHA as source documents for use and storage of flammable gases. EWP 7.2 provides specific storage requirements for control of chemicals (including flammable gases) and references NSD-313. Reference(s): NSD-313 "Control of Flammable and Combustible Materials" EWP 7-2 "Storing Chemicals"

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 25 of 85 3.3.1.3 Control of Ignition Sources 3.3.1.3.1 A hot work safety procedure shall be developed, implemented, and periodicallyupdated as necessary in accordance with NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, and NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations. NSD-314 "Hot Work Authorization" specifies the controls for performing hot work and the responsibilities of the persons authorizing and performing the activity. The directive requires inspections of the locations by trained personnel prior to hot work activity to ensure that there are no fire hazards present. NFPA 51B is a source document to NSD-314. NSD-314 is periodically updated. NFPA 241 references NFPA 51B with regards to the requirements for administration of Hot Work. ONS was not required to incorporate NFPA 241 as a code of record. {Area for Improvement- Evaluate NSD-314 to determine if NFPA 241 should be referenced.} Reference(s): NSD-314 "Hot Work Authorization" 3.3.1.3.2 Smoking and otherpossible sources of ignition shallbe restrictedto properlydesignatedand supervised safe areas of the plant. Ignition sources including smoking are restricted to designated areas or controlled through a permitting process. NSD-104 restricts the use of smoking and tobacco products to areas clearly posted as a tobacco use area and provides approved receptacles for waste. NSD-314, Hot Work, specifies controls of ignition sources typically associated with hot work including permitting and designation of areas where a permit is not required. Reference(s): NSD-1 04 "Housekeeping, Materiel Condition, and Foreign Material Exclusion" NSD-314 "Hot Work Authorization" 3.3.1.3.3 Open flames or combustion-generatedsmoke shall not be permittedfor leak orairflow testing.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 26 of 85 The Duke response to Appendix A to BTP 9.5-1 states "Open flames or combustion generated smoke is not permitted at ONS for leak or air flow testing. Leak and air flow determinations are accomplished by using commercially available aerosol or soap bubble techniques. Candles may be permitted for search of secondary system condenser vacuum leaks. The secondary system condenser is removed from safety related equipment." 1978 SER Section 6.5 states "Useof open flames or combustion generatedsmoke for leak detection in safety-relatedareashas been prohibited. We find that the control of ignition sources conform to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable." .................-{FrurthTerActia~n-Re~qaired--zz-ReviseF-th-e-appropriate--station-proced~ure~sý)-forl*eak--r-air-fj'ow-testing to preclude the use of open flames or combustion generated smoke.) Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 NRC SER dated August 11, 1978

              .3.3.1.3.4 Plantadministrativeprocedureshall controlthe use of portable electricalheaters in the plant.

Portablefuel-fired heaters shallnot be permittedin plantareascontainingequipmentimportant to nuclear safety or where there is a potentialfor radiologicalreleasesresulting from a fire. The use of portable heating devices is controlled by NSD-316 "Fire Protection and Impairment Surveillance." The Directive defines a heating device as "Atemporary heater that uses greater than or equal to 220 Volts or is powered by a fossil fuel source and is used to heat a general area, enclosure or equipment." Site personnel are, responsible for notifying the FPE of any intended use of a heating device(s). Site Directive 3.2.14 provides a flow chart for measures to take when temporary heaters are installed. This includes consideration of location and risk. The group that requests the placement of the temporary heating device shall be responsible to ensure that fire watches are initiated. A passive fire watch shall be conducted at least once every six (6) hours but may be more frequent if determined by the FPE. Fire watches shall be documented by use of the Impairment and Compensatory Measures (ICM) Form in NSD-316. NSD-316 specifies only steam heaters, UL Listed or FM Approved electric heaters, gas (MAPP, LP, or natural) or oil-fired heaters shall be allowed inside buildings. Gasoline and other fuels are not permitted unless approved by the FPE.

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 27 of 85 {Submit for NRC Approval - S.D. 3.2.14 and NSD-316 permit fossil fuel (gas and oi!-fired) heaters.} Reference(s): NSD-316 "Fire Protection and Impairment Surveillance." S.D. 3.2.14 "Fire Protection Program Compensatory Measures Process" 3.3.2 Structural Walls, floors, and components required to maintain structural integrity shall be of

  ............................

noncombustible construction,--as-defined-in -NFPA 220, Standard-on-Types-of-Building. Construction. ..--.---... - Oconee-is designed-to-minimize--the-probabilit-y-o f-fire-a nd-explosion.-Non~combustibles-and-- fire-resistant materials were used whenever practical throughout the facility. The Reactor Building is built using fire resistive construction. The outsidewalls of the Reactor Building are post-tensioned concrete for the three reactor structures. The roof and supports are also post-tensioned concrete for the three reactor structures. Interior partition walls are concrete containment or shield type walls between reactor, steam generators, coolant pumps, etc. Floors and supports are concrete on grade and various mezzanine levels are supported by concrete beams. The Auxiliary Building is a free standing reinforced concrete structure composed of concrete frames, slabs, and walls and non-structural masonry walls. The facility has exterior walls that are reinforced concrete with fire resistive construction. Interior partition walls are mainly concrete with portions of concrete block. The roof and supports are approved insulated roofing on concrete slab supported on concrete members. Floors and supports are concrete slab on concrete members. The Turbine Building is constructed of reinforced concrete below grade consisting of substructure walls and a mat foundation. Above grade, the building consists of structural steel with metal siding. The steel roof deck is supported by unprotected steel frame. Exteriorwalls are noncombustible, insulated aluminum siding on unprotected steel frame with concrete at lower levels below grade. Interior walls are reinforced concrete and concrete block. Reference(s): Design Basis Specification for Fire Protection 3.3.3 InteriorFinishes Interiorwall or ceiling finish classificationshallbe in accordancewith NFPA 101, Life Safety Code,requirementsfor Class A materials. Interiorfloor finishes shall be in accordancewith NFPA 101 requirementsfor Class I interiorfloor finishes.

'Calculation No.: OSC-9295. Revision No.: I1 Applicable Units: Oconee Unit 1 2, & 3 Page 28 of 85 The Duke Comparison to BTP 9.5-1 letter and the UFSAR Section 9.5.1.4.1.4 state "Interior wall, structural components and radiation shielding are non-combustible. Coatings are non-combustible with flame spread and fuel contribution of 50 or less." NSD-318 "Coatings Program" controls the use of coatings and requires approval for any changes. Records of coating applications are required to be maintained. {Further Action Required - Revise NSD-318 to include the specifications for Class A, walls/ceilings and Class I floor finishes or include in an alternative administrative control document.} Reference(s): NSD-318 "Coatings Program" UFSAR Section 9.5.1.4.1 Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 3.3.4 InsulationMaterials Thermal insulation materials, radiation shielding materials, ventilation duct materials, and soundproofingmaterials shall be noncombustible or limited combustible. The thermal insulation materials used in the power production plant are non-combustible Specifications OSS-0241-00-00-002 and OSS-0241.00-00-0004 state thermal insulation materials are metal reflective type (mirror), calcium silicate, Armaflex, fiberglass and basaltic rock. These insulations are all classified as non-combustible or limited combustible materials. Any new insulation materials would require a screening determination in accordance with EDM-601 "Engineering Directives Manual." Part of the screening process is an evaluation of the potential effects on the Fire Protection Program which would require the use of noncombustible or limited combustible materials. Reference(s): Specification OSS-241.00-00-0004 "Conventional Thermal Insulation" Specification OSS-241.00-00-0002 "Reactor Building and Piping Heat Insulation (Metal Reflective Type) EDM-601 "Engineering Directives Manual" 3.3.5 Electrical 3.3.5.1 Wiring above suspended ceilingshallbe kept to a minimum. Where installed,electricalwiring

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 29 of 85 shallbe listed for plenum use, routed in armoredcable, routedin metallic conduit, orroutedin cable trays with solid metal top and bottom covers. The Duke Comparison to BTP 9.5-1 letter and the UFSAR Sections 9.5.1.4.1 and 9.5.1.4.3 state "Suspended ceilings and their supports are non-combustible. Combustibles in concealed spaces are minimal. There are no power and control cables in the Control Room concealed floor or ceiling space except for miscellaneous 120V power and network cables in the ceiling space supplying small OAC computer room equipment." Currently most cables are IEEE 383 equivalent and not routed in metallic conduit or cable trays with solid metal top and bottom covers. {Further Action Required - Include clear documentation that electrical wiring (including

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........ data/pho neLvideo-cabling.)Js-installed.a-bo-ve_.sussp-ond.edxreiings.and tbe wi rintg-cýmplie~s.wi.tbe .with this section.}

Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 UFSAR Section 9.5.1.4.1 and Section 9.5.1.4.3 Design Basis Specification for Fire Protection 3.3.5.2 Only metal tray and metal conduits shall be used for electricalraceways. Thin wall metallic tubing shall not be used for power, instrumentation, or control cables. Flexible metallic conduits shall only be used in short lengths to connect components. The Duke Comparison to BTP 9.5-1 and the UFSAR Section 9.5.1.4.3 state "Cable trays are constructed of non-combustible materials." The Design Basis Specification for Fire Protection states "Cable trays are constructed of steel with all supports attached to QA condition 1 or 4 structures." {Further Action Required - Include clear documentation that conduits used for electrical raceways are metal and thin walled metallic tubing is not used in accordance with this section.} Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 UFSAR Section 9.5.1.4.3 Design Basis Specification for Fire Protection

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 30 of 85 3.3.5.3 Electric cable construction shall comply with a flame propagationtest as acceptable to the AHJ. The IEEE 383 Standard was developed after Oconee cables were was installed, however, the same cable construction has been used at a later plant and was found acceptable under IEEE 383. The NRC August 11, 1978 SER Section 4.8 states 'The cable insulation used in the plant consists of armored ethylene propylene rubber (EPR) of 5-8 KV cables with a polyvinyl chloride (PVC)jacket, armoredEPR with hypalon orneoprenejacket outside containmentand armored EPR with hypalon jacket, some with a PVC jacket overall, for inside containment. The majority of cables at Oconee are of the metallic armored type. The IEEE standardwas not in effect at the time the plant was constructedand therefore the cables were not required

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--- toýmeaet-i*EE-383.-The-*ice[se~e-hasý-statd,-however;-th-at-the-ýsame--a-ble-constractian-h-asý since been used at a laterplant where the IEEE 383-1971 criteriawere imposed and the cable was acceptable. We find that to retest the IEEE 383 procedure and criteria is unnecessary and would not provide information that would alter our recommendation or conclusions.

Accordingly we find the electricalcables used at the Oconee Nuclear Station acceptable." {Further Action Required - Revise station documentation that non-rated cables (including data/phone/video) shall not be routed in cable trays with nuclear safety related cables.} Reference(s): NRC SER dated August 11, 1978 3.3.6 Roofs Metal roof deck construction shall be designed and installed so the roofing system will not sustain a self-propagatingfire on the underside of the deck when the deck is heated by a fire inside the building. Roof coverings shall be ClassA as determinedby tests describedin NFPA 256, StandardMethods of Fire Tests of Roof Coverings. The Auxiliary Building, Reactor Building and SSF do not utilize metal roof deck construction. The Turbine Building has metal roof deck construction. The Design Basis Specification for Fire Protection Section 3.2.2.1.1.1 states "The roof was constructedin accordancethe Kopper Company's Specification No. 17 and is therefore considered to be in accordance with FM Class 1. In 1985, the Turbine Building roof was re-roofed in accordancewith Underwriter's Laboratories Class A single ply roof system. "FireRating of OS-159.00-00-0002" states all materials of construction are specified to be selected under FM Approval Guide as non-combustible. It is concluded that the Turbine Building built up roof decking assembly is FM Approval Guide Classification1, through not specifically stated in the specification."

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 31 of 85 The Duke Corporate Roof Program specifies new roofs shall be in compliance with FM-1 90 which indicates a FM Class I fire resistant roof is required. A FM Class I roof is equivalent to a NFPA 256 Class A roof classification. Reference(s): Design Basis Specification for Fire Protection Duke Corporate Roof Management Program 3.3.7 Bulk Flammable Gas Storage Bulk compressed or cryogenic flammable gas storageshall not be permitted inside structures housing systems, equipment, or components importantto nuclearsafety. The Design Basis Specification for Fire Protection, Duke Comparison to BTP 9.5-1 letter ........ andJUESAR-Section-9.5.i-.4-3-statei-LThbe-e-is nho bulk-gas-sto.rage-in-areas affecting -safe---------- shutdown equipment." Safe permitted use of compressed gases is controlled by operational procedures. The storage of combustible and flammable materials is controlled by administrative procedures (NSD-313, EWP 7.2). General provisions for the use and storage of chemicals, including gases, are controlled by NSD-1 16 "Nuclear Chemical Control Program." Flammable gas cylinders are located in various areas of the plant, by design, for chemistry labs and for Post Accident Monitoring instrumentation. Previously ONS stated that there is no bulk gas storage in areas affecting safe shutdown equipment. Under NFPA 805, the requirement is no bulk storage inside structures housing systems, equipment or components important to nuclear safety. NFPA 55 (2005 edition) defines bulk hydrogen compressed ?as system as an assembly, including storage containers, with a capacity greater than 400 ft . There are hydrogen storage cylinders located in the Auxiliary Building by design. The Auxiliary Building contains systems, equipment or components important to nuclear safety; however, the immediate areas in which the cylinder storage exists do not contain systems, equipment or components important to nuclear safety. {Submit for NRC Approval - Storage of flammable gas cylinders is permitted for use in plant operations and systems per design.} Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 UFSAR Section 9.5.1.4.3 NSD-1 16 "Nuclear Chemical Control Program" Design Basis Specification for Fire Protection

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 32 of 85 EWP 7.2 "Storing Chemicals" 3.3.7.1 Storage of flammable gas shallbe located outdoors,orin separatedetachedbuildings,so that a fire orexplosion will not adversely impact systems, equipment, or components importantto nuclearsafety. NFPA 50A, Standardfor Gaseous Hydrogen Systems at ConsumerSites, shall be followed for hydrogen storage. Bulk storage of Hydrogen Gas is stored in the northeast yard area. There is also a propane storage tank adjacent to the Unit 1 Transformer area. These storage tanks are located outdoors and away from the SSCs important to safety. NSD-313 "Control of Combustible and Flammable Materials" provided restrictions on the stora-ge-(-c-atio-n-of-combustible-m ateda!s-wit hspe-cifi-c-re-st-cti-os-forlhe-Oconee-Plant.--Any-changes, to the amount of materials or the storage location of materials, require review and approval from the FPE and EWP. Bulk flammable gas is not stored in areas important to nuclear safety unless used in plant operations or systems by design. The chemical control program, which is administered in accordance with NSD-1 16, ensures compliance with applicable regulations and requirements including NFPA Codes. Any changes to the bulk storage of combustible/flammable gases would require authorization in accordance with both NSD-1 16 and NSD-313. {Further Action Required - Perform a code compliance review for the outdoor hydrogen storage per NFPA 50A.) Reference(s): NSD-1 16 "Nuclear Chemical Control Program" NSD-313 "Control of Combustible and Flammable Materials" 3.3.7.2 Outdoorhigh-pressureflammable gas storagecontainersshall be locatedso that the long axis is not pointed at buildings. The bulk hydrogen storage cylinders are located with the long axis parallel to the buildings in the northeast corner of the yard. A propane storage tank is oriented with its long axis toward the Unit 1 Turbine Building. The Design Basis Specification for Fire Protection, Duke Comparison to BTP 9.5-1 letter and UFSAR Section 9.5.1.4.3 state 'There is no bulk gas storage in areas affecting safe shutdown equipment."

Calculation No,: OSC-9295 Revision No.: Applicable Units: -Oconee Unit 1, 2, & 3 Page 33 of 85 1978 SER Section3.1.7 states "Propanetanks located outside the turbine building will be anchoredand provided with excess flow valves." {Further Action Required - Resolve orientation of propane tank. The tank is not anchored per the SER recommendation. Evaluate if the previous approval by the NRC is sufficient with modification. Alternatively, determine if an evaluation is required or modify the tank position.} Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 UFSAR Section 9.5.1.4.3 NSD-1 16 "Nuclear Chemical Control Program" Desigqn Basis Specification for Fire Protection NRC SER dated August .11, 1978 3.3,7.3 Flammablegas storage cylinders not requiredfor normal operationshall be isolatedfrom the system. The use and storage of combustible and flammable materials is controlled by NSD-313 and EWP 7.2. NSD-313 and EWP 7.2 require Compressed Gas Cylinders not in use to be stored with their protective cap in place, adequately secured in an upright position and separated from other flammable/combustible and oxidizing agents. Bulk hydrogen cylinders located in the hydrogen storage areas that are not in use are isolated from the system. Reference(s): NSD-313 "Control of Combustible and Flammable Materials" EWP 7.2 "Storing Chemicals" 3.3.8 Bulk Storage of Flammableand Combustible Liquids Bulk storage of flammable and combustible liquids shall not be permitted inside structures containingsystems, equipment, or components important to nuclear safety. As a minimum, storage and use shall comply with NFPA 30, Flammable and Combustible Liquids Code. The storage of combustible and flammable materials is controlled by NSD-313. NFPA 30, "Flammable and Combustible Liquid Code," is a source document for NSD-313. Storage limitations are provided for power block areas. The general provisions for the use and storage of chemicals are controlled by NSD-1 16 which requires authorization for changes to flammable and combustible liquid storage amounts or location. Although listed below for information the Safe Shutdown Facility (SSF) Diesel Generator day tank and the Turbine Lube Oil reservoirs, while located in structures containing systems, equipment or components important to nuclear

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 34 of 85 safety, are part of the operating systems of the plant and are not considered bulk storage. The fuel oil for the SSF Diesel Generator is provided from a 50,000 gallon underground storage tank to a 550-gallon day tank that is located inside the SSF. The SSF is a Category I structure that is provided with an automatic, total flooding CO 2 system in the diesel generator room that houses the day tank. The SSF buried fuel oil storage tank located outside adjacent to the SSF structure. Turbine Lube Oil is located in the turbine building. The main turbine lube oil reservoir tanks are located in the basement level of each unit and have a capacity of 7,450 gallons. The turbine oil transfer tank and adjoining purifier units have a 14,000 gallon capacity, which is located under the operating floor. Each unit turbine oil transfer tank is.arranged within a four feet high concrete dike designed to hold the entire contents of respective tanks. The adjoining oil purifier unit is located outside of the dike area. The concrete block lubrication oil storage building, located in the lower level of the Unit 1 Turbine Building contains seven (7) steel tanks, each having a 200-gallon capacity. The storage area has a wet-pipe automatic suppression system, fire doors, and fire dampers in the ventilation openings. There are two aboveground fuel oil tanks (30,000 and 45,000 gallon) for the Auxiliary boiler that are located in the northeast yard. These tanks are located in a diked area and are a considerable distance from the actual power production facility. Gasoline, diesel fuel oil and kerosene are stored in underground tanks that are located at the site garage area. The tanks are located a significant distance (greater than 1,000 feet) from the actual power production facility. Keowee has a dedicated lube oil tank room. The storage room contains two 7,150 gallon tanks for storage of oil for the turbine generators. The room is protected by an automatic deluge sprinkler system. {Further Action Required'- Perform a NFPA 30 code review for the Turbine Building lube oil reservoirs, Turbine Building oil storage building and the Keowee lube oil tank room.} Reference(s): NSD-1 16 "Nuclear Chemical Control Program" NSD-313 'Control of Combustible and Flammable Materials" Drawing OFD-135A-01-01 Design Basis Specification for Fire Protection

Calculation No.: OSC-9295 Revision No,: I Applicable Units: Oconee Unit 1, 2, & 3 Page 35 of 85 3.3.9 Transformers Where provided, transformer oil collection basins and drain paths shall be periodically inspected to ensure that they are free of debris and capable of performing their design function. The Main, Auxiliary and Safety Transformers for the three Oconee Units are located outdoors adjacent to their respective portions of the Turbine Building. Each of the transformers is provided with an automatic deluge system. The transformers are mounted on concrete pads within an earthen graveled area. There are no specific retention basins around the main transformers that are designed to retain and direct potential transformer oil leakage to a storage basin or tank. The ground and gravel system will absorb most of the runoff from fire mitigation activities in addition to the yard drain system directing excess flow to Chemical Treatment Pond (CTP) #3. CTP #3 is provided with oil skimmers. Tra-n-sfarm-erCT-Z4- is-i-c-at-d-in-t-the-,Unit-l-12-Bl-ckh~ou se-.-----concrete-oil-retention-basi n-is.---..-..........

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provided under the Blockhouse. The Keowee Transformer is located outside on the West side of the hydro station and is provided with an automatic deluge system. The transformer is mounted on a concrete pad with a gravel bed similar to those discussed above. {Further Action Required - Revise station test procedures to include drainage inspections as part of the annual flow tests.} Reference(s): Engineering Support Document for Fire Protection Design Basis Specification for Fire Protection 3.3.10 Hot Pipes and Surfaces Combustible liquids, including high flashpoint lubricatingoils, shall be kept from coming in contact with hot pipes and surfaces, including insulated pipes and surfaces.Administrative controls shallrequire the prompt cleanup of oil on insulation. NSD-104 addresses general housekeeping requirements that apply to all personnel (permanent and temporary) that perform activities at the plant. The NSD emphasizes the plant areas should be clean and orderly with properly maintained work areas and equipment. NSD-413 "Fluid Leak Management Program" was established to ensure aggressive identification of leaks followed by timely investigation and repair. The Leak Management Program encompasses all fluid leaks which may include high-energy process fluids steam, water, oil, hydraulic fluid, etc occurring throughout the Plant.

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1. 2, & 3 Page 36 of 85 {Area for Improvement - Revise NSD-104 and/or NSD-413 to clearly indicate it is a NRC requirement to promptly remove oil from insulation.} Reference(s): NSD-104 "Housekeeping, Materiel Condition & Foreign Material Exclusion" NSD-413 "Fluid Leak Management Program" 3.3.11 ElectricalEquipment Adequate clearance, free of combustible material, shall be maintained around energized electricalequipment. Placement of combustible materials that could be located near electrical equipment is controlled by NSD-313. NSD-313 includes specific guidance on the location of transient fire

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..----- LQads_.adjacentto-plantequimentsu-sceptible to fire damage_(eg._eletdctal cabinets).

{Further Action Required - Revise NSD-313 to specify the combustible free distance consistent with the PRA Zone of Influence for transients} Reference(s): NSD-313 "Control of Combustible and Flammable Materials" 3.3.12 Reactor CoolantPumps Forfacilities with non-inertedcontainments,reactorcoolantpumps with an externallubrication system shall be provided with an oil collection system. The oil collection system shall be designedand installedsuch that leakagefrom the oil system is safely containedfor off normal conditions such as accident conditions or earthquakes.All of the following shall apply. (1) The oil collection system for each reactor coolant pump shall be capable of collecting lubricating oil from all potential pressurized and nonpressurizedleakage sites in each reactorcoolant pump oil system. A lube oil collection system was installed for each of the Reactor Coolant Pumps (RCPs) at the Oconee Plant - each of the three units has four RCPs. The RCP oil collection systems are designed and sized to collect and contain oil from potentially pressurized and unpressurized leakage areas in a seismic event resulting in failure of the lubrication system. However, the RCP oil collection system has not been designed for containment of atomized oil vapors from all areas for the RCP. The Reactor Coolant Pump (RCP) Lube Oil System for each reactor coolant pump contains approximately 250 gallons of oil in upper and lower tanks, self-contained within each RCP assembly. Reference(s): Duke Letter to the NRC dated March 18, 1981 Design Basis Specification for Fire Protection

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 37 of 85 Letter Duke to NRC, PIP 0-99-2532/LER 270/1999-04, February 16, 2000 Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 (2) Leakage shall be collected and drainedto a vented closed containerthat can hold the inventory of the reactorcoolantpump lubricatingoil system. Any potential leakage is collected and drained to a collection tank sized to accommodate the largest potential leak system inventory (250 gallons). The collection tanks are located in the basement of the Reactor Building. Reference(s): Duke Letter to the NRC dated March 18, 1981 (3) A flame arrestoris required in the vent if the flash point characteristicsof the oil present the hazardof a fire flashback. A flame arrestor is provided for each of the RCP oil collection tank vents. Reference(s): Duke Letter to the NRC dated March 18, 1981 (4) Leakage points on a reactorcoolantpump motor to be protectedshall include but not be limited to the lift pump andpiping, overflow lines, oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and the oil reservoirs,where such features exist on the reactorcoolantpumps. Potential leakage points on the pump motor that are protected include the lift pump and piping, overflow lines, lube oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines and lube oil reservoirs. Reference(s): Duke Letter to the NRC dated March 18, 1981 (5) The collection basin drain line to the collection tank shall be large enough to accommodate the largestpotentialoil leak such that oil leakagedoes not overflow the basin. Potential leakage is collected and drained through an appropriately sized drain line into the collection tank. The collection tank is sized to accommodate the largest potential leak, the entire system inventory of 250 gallons.

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 38 of 85 Reference(s): Duke Letter to the NRC dated March 18, 1981 Section 3.4 Industrial Fire Brigade 3.4.1 On-Site Fire-FightingCapability All of the following requirementsshall apply. (a) A fully staffed, trained,and equipped fire-fighting force shall be available at all times to control and extinguish all fires on site. This force shall have a minimum complement of five persons on duty and shall conform with the following NFPA standardsas applicable: (1) NFPA 600, Standardon IndustrialFire Brigades (interiorstructuralfire fighting) (2) NFPA 1500, Standard on Fire Department Occupational Safety, and Health Program

         ..          I(3NFPA 1T582,Stan-dardon-tvi~edicai-Require-rnents-for-Fire-Fighters-and-infrormation-for Fire Department Physicians Oconee takes exception to the following sections of the aforementioned NFPA standards:
            " NFPA 600 (2005) Chapter 4 Section 4.4, "Requirements for all Industrial Fire Brigades." ONS is structured differently than those described in this section. While all requirements are addressed they are not all the responsibility of the Fire Brigade Leader.
            " NFPA 600 (2005) Chapter 4, Section 4.7 "Industrial Apparatus."                 ONS has no apparatus.

NFPA 1500 and 1582 are not applicable to ONS per in their respective scope statements and consistent with FAQ 06-0007.

• NFPA 1500 (2007) Chapter 1 "Administration" Section 1.3.2 states "This standard does not apply to Industrial Fire Brigades that might also be known as Emergency Brigades, Emergency Response Teams, Response Teams, Fire Teams, Plant Emergency Organizations, or mine emergency response teams."
• NFPA 1582 (2007) Chapter 1 "Administration" Section 1.1.4 states "This standard does not apply to Industrial Fire Brigades that might also be known as Emergency Brigades, Emergency Response Teams, Response Teams, Fire Teams, Plant Emergency Organizations, or mine emergency response teams."

The required staffing levels for the Oconee Plant are specified in SLC 16.13.1 "Minimum Station Staffing Requirements." NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" provides the requirements for becoming, a qualified fire brigade member. When the Control Room alerts the Fire Brigade to a fire, Radiation Protection and Security Personnel are also alerted and tasked to assist the Fire Brigade in accordance with Procedure

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 39 of 85 RPIO/B/I1000/029 "Fire Brigade Response." {Area for Improvement - Ensure the NFPA 600 code review is formally documented.} Reference(s): Selected Licensing Commitment (SLC) 16.13.1 "Minimum Station Staffing Requirements" NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" RPIO/BI1000/029 "Fire Brigade Response" (b) Industrial fire brigade members shall have no other assigned normal plant duties that would prevent immediate response to a fire or otheremergency as required. S uss afr r--p--of-e--members-from-Operations-- and-five--additiona1l -.-.

        .........

members. ONS does not use a dedicated fire department organization. NSD-1 12 states that Fire Brigade members are informed of their responsibilities at the beginning of each shift and during a fire emergency will respond under the direction of the Fire Brigade Leader and perform all duties to control, extinguish and restore the station to a safe condition. SLC 16.13.1 states minimum station staffing requirements of ten, the minimum regulatory requirements of five, and includes in the bases that staff required for fire brigade is independent of other responsibilities during fire events. Reference(s): SLC 16.13.1 "Minimum Station Staffing Requirements" NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" (c) During every shift, the brigade leader and at least two brigade members shall have sufficient trainingand knowledge of nuclear safety systems to understandthe effects of fire and fire suppressantson nuclearsafety performance Exception: Sufficient training and knowledge shall be permitted to be provided by an operationsadvisor dedicated to industrialfire brigadesupport criteria. NSD-1 12 states that the Fire Brigade Leader and at least two brigade members shall have sufficient training in or knowledge of plant safety-related systems to understand the effects of fire and fire suppressants on safe shutdown capability (have completed OPS ISS Training). Reference(s): NSD-112 "Fire Brigade Organization, Training & Responsibilities" (d) The industrialfire brigade shall be notified immediately upon verificationof a fire. Plant employees receive general employee training that includes notifying the control room via the telephone using 4911 of a discovered fire. Once a fire is confirmed via the first responder

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 40 of 85 verifies the fire (or Control Room received multiple indication) the fire brigade is dispatched. NSD-112 states that Control Room personnel are responsible for initiating Fire Brigade response. The fire brigade is dispatched using two methods; a paging system that activated pagers worn by fire brigade members and the plant paging system. Both methods are used in each event. Reference(s): General Employee Training - Plant Access Training NSD-112 "Fire Brigade Organization, Training & Responsibilities" RP/O/B/1000/029 "Fire Brigade Response" (e) Each industrial fire brigade member shall pass an annual physical examination to ______ determinetath&he.orsfhetcanp-erformtbestrenu-ousactivity reguired during manual fire-fighting operations. The physical examination shall determine the ability of each member to use respiratoryprotection equipment. NSD-112 requires that prior to initial training and annually thereafter, each fire brigade member will receive a physical examination by a company approved medical professional to assure that they are medically capable of performing strenuous activities. Each fire brigade member must satisfactorily complete and maintain respirator use clearance as determined by the Corporate Medical Department. NSD-1 12 states that for Fire Brigade Leaders and Members to remain qualified they must pass a medical examination, respiratory training and respirator fit test. The specific program requirements are listed in ERTG-001 "Emergency Response Organization and Emergency Services Training Program." Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" ERTG-001 "Emergency Response Organization and Emergency Services Training Program" 3.4.2 Pre-Fire Plans Currentand detailedpre-fire plans shall be availableto the industrialfire brigadefor all areas in which a fire couldjeopardize the ability to meet the performancecriteriadescribedin Section 1.5. Current and detailed fire plans are provided in the Oconee NuclearSite Fire Plan (Fire Brigade Strategies) for all plant locations that contain systems or components that could impact nuclear safety performance or present a potential for radioactive releases or life safety.

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2. & 3 Page 41 of 85 Reference(s): Oconee Nuclear Site Fire Plan 3.4.2.1 The plans shalldetail the fire area configurationand fire hazardsto be encounteredin the fire area, along with anynuclearsafety components and fire protectionsystems and features that are present. The Fire Plan provides a graphic representation of the various plant areas that depicts the installed fire protection/suppression features. In addition to the suppression features, the Fire Plan also provides information of any equipment important to safety and special hazards (e.g. Radiological, Electrical, Chemical, Physical and Flammable Liquids Gases) that could be encountered. The Fire Plan also provides information on available ventilation equipment. Th-e--Fire-P la-n-*ir-iude-s-Fire-Bri-gade-Guides-(SOGs)-that-provide-generai-instructi-ons-for-the -....... fire brigade hose selection and use and specific hazards consideration such as electrical and bulk Hydrogen fires, hazardous materials response and other generic fire mitigation tactics. {Area for Improvement - Evaluate the Fire Plan and associated documents (SOG, training materials, and directives) for compliance with NFPA 805 requirements.} Reference(s): Oconee Nuclear Site Fire Plan 3.4.2.2 Pre-fireplans shall be reviewed and updated as necessary. The Fire Plan is maintained by the Emergency Planning Group and is updated as required. Modifications to plant features and equipment and changes to plant procedures require a determination of potential effects on the fire protection program or features; potential impacts may lead to revision or additions to the Fire Plan. NSD-301, Appendix B, "Technical Issues Checklist" includes a specific line item for impact on the fire plan. NSD-228, Appendix E, "Fire Protection Program Screening Aid" includes review of the impact on the Fire Brigade which utilize the Fire Plan. Reference(s): NSD-228 "Applicability Determination" NSD-301 "Engineering Change Program" 3.4.2.3 Pre-fireplans shall be available in the control room and made availableto the plantindustrial

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 42 of 85 fire brigade. The Fire Plan is available to the Fire Brigade (FB) Leaders and Members as well as Control Room Personnel. A copy is located in each CR, FB leader's locker, NEO Supervisor's office and the FB Leader's kit. Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" Oconee Nuclear Site Fire Plan 3.4.2.4 Pre-fireplans shall addresscoordination with other plant groups during fire emergencies. The coordination between the Fire Brigade and other plant groups during a fire emergency is defined in NSD-1 12. When the Control Room is notified of a fire, Procedure RP/O/B/1000/029 "Fire Brigade Response" is implemented. The procedure instructs the control room personnel on their response and provides direction on managing the conduct of the fire fighting activities including contacting offsite Fire Departments. Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" RPIOIBIO0010I29 "Fire Brigade Response" 3.4.3 Training andDrills Industrial fire brigade members and other plant personnel who would respond to a fire in conjunction with the brigade shall be provided with training commensurate with their emergency responsibilities. (a) Plant IndustrialFire Brigade Training.All of the following requirementsshall apply. (1) Plant industrialfire brigade members shall receive training consistent with the requirementscontainedin NFPA 600, Standardon IndustrialFire Brigades, or NFPA 1500, Standard on Fire Department OccupationalSafety and Health Program, as appropriate. (2) Industrialfire brigademembers shall be given quarterlytrainingand practicein fire fighting, includingradioactivityand healthphysics considerations,to ensure thateach member is thoroughly familiar with the steps to be taken in the event of a fire. (3) A written program shall detail the industrialfire brigade trainingprogram. (4) Written records that include but are not limited to initial industrialfire brigade classroomand hands-on training,refreshertraining,special trainingschools attended, drill attendance records, and leadership training for industrialfire brigades shall be maintainedfor each industrialfire brigademember.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 43 of 85 The fire brigade training program includes the following essential elements: use of fire fighting equipment, fire fighting principles and techniques, use of fire fighting guidelines (SOGs), annual practices in actual fire fighting and periodic fire drills. The drills implement the fire fighting procedures, including the simulated use of equipment, to assess brigade effectiveness. The drills also evaluate brigade leadership and Control Room coordination for plant control. NSD-1 12 states that for Fire Brigade Leaders and Members to remain qualified they must, among other requirements, participate in an annual practical training session, quarterly training sessions and participate in at least two drills per year. NSD-1 12 references NFPA 600 as a source document. NFPA 1500 is not applicable to ONS. Specific training requirements are specified in ERTG-001 "Emergency Response Organization and Emergency Services Training Program." Records of personnel participation in the training sessions are maintained by the training department.

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Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" ERTG-001 "Emergency Response Organization and Emergency Services Training Program" (b) Trainingfor Non-IndustrialFireBrigade Personnel.Plantpersonnelwho respond with the industrialfire brigade shall be trained as to their responsibilities,potential hazards to be encountered,andinterfacing with the industrialfire brigade. The Oconee Nuclear Station maintains a large fire brigade size and does not typically utilize non-fire brigade qualified personnel to support fire brigade ancillary duties. Persons who perform Fire Watch duties for Hot Work are qualified in the use of the fire extinguisher and are authorized to extinguish any resulting fire of the hot work within their capabilities. Other non-fire brigade personnel that respond to a fire incident include Security, Radiation Protection, Chemistry, Off-Site Fire Department(s), and the Medical Emergency Response Team (MERT). These personnel are trained for interfacing with the Fire Brigade. The Fire Brigade Leader is the overall Incident Commander and uses other personnel as support. Reference(s): NSD-112 "Fire Brigade Organization, Training & Responsibilities" PT/O/B/2000/001 "Preparation and Conduct of Emergency Drills" (c) Drills. All of the following requirementsshall apply. (1) Drillsshall be conducted quarterlyfor each shift to test the responsecapabilityof the industrialfire brigade.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 44 of 85 Drills are performed quarterly for each shift fire brigade. At least one drill per year for each shift fire brigade is unannounced; at least one drill per year for each shift fire brigade is performed on a back shift. At least one drill annually involves a response from the appropriate local fire department(s). Site fire brigade/local fire department interface is critiqued by both site and local fire department staff. Reference(s): NSD-112 "Fire Brigade Organization, Training & Responsibilities" (2) Industrialfire brigadedrillsshall be developed to test andchallenge industrialfire brigaderesponse,including brigadeperformanceas a team, properuse of equipment, effective use of pre-fire plans, and coordination with other groups. These drills shall

   ,- ----.-.......

..---- evaluate-the-ndustriaLfire-brigade-&-abilities-t--react,-resoond-ancddemonstrate-pr-op-er-- fire-fighting techniques to control and extinguish the fire and smoke conditionsbeing simulated by the drill scenario. Each fire drill is pre-planned to establish training objectives and critiqued to determine how well the objectives are met. The Fire Brigade drill performance is critiqued by controllers/evaluators to determine successful drill performance in accordance with stated drill objectives. Performance is documented 'utilizing the Fire Drill Critique Sheet. Drills are pre-planned to determine the appropriate number of controllers/evaluators needed to effectively assess the Fire Brigade Response. Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" ERTG-001 "Emergency Response Organization and Emergency Services Training Program" PTIO/B/2000/001 "Preparation and Conduct of Emergency Drills" (3) Industrialfire brigadedrills shallbe conducted in various plant areas,especiallyin those areas identified to be essential to plant operationand to contain significantfire hazards. Procedure PT/O/B/2000/001 "Preparation and Conduct of Emergency Drills" specifies that drills be conducted with onsite and local offsite fire department personnel. On-site drills are required to be conducted involving different areas and hazards, including "Risk Significant" areas. Fire drills including response of the offsite Fire Departments are conducted annually.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 45 of 85 Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" ERTG-001 "Emergency Response Organization and Emergency Services Training Program" PT/O/B/2000/001 "Preparation and Conduct of Emergency Drills" (4) Drillrecords shall be maintaineddetailingthe drill scenario,industrialfire brigade member response,and ability of the industrialfire brigade to perform as a team. A completed Fire Drill Critique Sheet (Appendix B) and Training Content Summary form shall be sent to the Site Training Division is sent to Document Control for documentation and retention. Retention in document control is life of plant. Performance deficiencies of a shift fire brigade or individual fire brigade members will be noted and appropriate action taken and documented in the corrective action ... ............ .. .. . .. . . .r ogram . Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" (5) A critique shall be held and documented after each drill. A critique is performed for each drill that involves the fire brigade in accordance with NSD-112. The completed Fire Drill Critique Sheet and Training Content Summaryform is required to be sent to the Site Training Division for documentation and retention. Site Training transmits the records to Document Control for documentation and retention. Retention in Document Control is life of plant. Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" 3.4.4 Fire-FightingEquipment Protectiveclothing,respiratoryprotective equipment,radiationmonitoringequipment, personal dosimeters, and fire suppression equipment such as hoses, nozzles, fire extinguishers, and other needed equipment shall be provided for the industrialfire brigade. This equipment shall conform with the applicableNFPA standards. Fire Fighting Equipment is located in various fire areas. The areas are shown graphically and described in the Fire Plan for that area. Fire Brigade Equipment is also specified in the SOG section of the Fire Plan. The equipment is listed by location and includes items such as air packs, spanners, smoke ejectors and nozzles. Hose stations and hydrant houses contain sufficient lengths of hose and nozzles. 7', Fire Brigade personnel turnout gear and air packs are stored in specified fire equipment storage locations. Ops equipment is stored in two storage containers on the Turbine deck.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 46 of 85 Backup gear is stored in the warehouse. Each Fire Brigade member is furnished with a complete set of turn out gear consisting of pants, coat, boots, gloves, helmets and flash hoods. Radios are provided for communication in the Fire Brigade Response storage location. Other equipment available to the brigade includes portable lights, thermal imaging camera, portable ventilation as well as portable generators. Other supporting groups' equipment is stored in their respective work spaces. Air Packs (SCBA's) provided for the brigade are NIOSH approved one hour air bottles with integrated PASS devices as well as amplified SCBA masks. Additional masks are provided within each of the two response sea-lands. In addition to spare air bottles ONS has an electric and a portable a diesel compressor capable of refilling SCBA bottles. Radiation Protection is responsible for the SCBA refill operation. SCBA refill can be performed via the cascade system or the breathing air system. This-equipment-isinspectedin-accGordance-with-2-rocedure*eT-_-O* 01-_250a-3`Quarerv-Fire---- Brigade Equipment Inspection." to ensure the operability and availability of all Fire Brigade equipment. The Keowee Fire Brigade Equipment is inspected in accordance with Procedure PT/O/A/2200/010 "Keowee Equipment Inspection." Fire protection equipment is procured and conforms to the applicable NFPA standards forthe specific equipment. Reference(s): Oconee Nuclear Site Fire Plan PT/01B102501030 "Quarterly Fire Brigade Equipment Inspection" PTIOIA/2200101 0 "Keowee Equipment Inspection" 3.4.5 Off-Site Fire DepartmentInterface 3.4.5.1 Mutual Aid Agreement Off-site fire authorities shal be offered a plan for their interface during fires and related emergencies on site. There are "Letters of Agreement" with local Fire Departments that provide details of the interaction of their organization during a fire or related emergency on the Oconee Site. These Letters of Agreement are maintained as part of the Emergency Plan. Letters of Agreement are in effect with the Corinth-Shiloh Volunteer Fire Department, the Keowee Fire Commission, the Keowee-Ebenezer Volunteer Fire Department, and the Six Mile Volunteer Fire Department. These Letters of Agreement are reviewed by established frequency as required by the Emergency Planning Group. The primary response for fires inside the protected area is the ONS fire brigade with support

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 47 of 85 from off-site fire departments. The primary response for fires outside the protected areais the off-site fire departments. Except for Keowee Hydro where the ONS fire brigade will respond with assistance from the off-site fire departments. Reference(s): Oconee Emergency Plan 3.4.5.2 Site-Specific Training Fire fighters from the off-site fire authoritieswho are expected to respondto a fire at the plant shall be offered site-specific training and shall be invited to participatein a drill at least annually. NSD-112 specifies that at least one fire drill annually will involve response from the appropriate local fire department(s). Site fire brigade/local fire department interface will be

       --ritiqued-by-both-site-and-department-fire-protec on-staff-t-is-the-intent-to-have-off-site-i -re-response act as supplemental support and integrate into the site team, but not act independently.

The Letters of Agreement discussed above contain provisions for annual training of off-site personnel who would respond to an assistance request. Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" Oconee Emergency Plan 3.4.5.3 Security and RadiationProtection Plantsecurity and radiationprotection plans shall address off-site fire authorityresponse. NSD-1 12 "Fire Brigade Organization, Training & Responsibilities," contains requirements that the Security and Radiation Protection organizations assist the fire brigade. The Security and Radiation Protection organizations have plans and provisions that provide for the entry and activities of outside fire fighting organizations. If offsite assistance is determined to be needed during a fire emergency, Procedure RP/O/B/1000/029 "Fire Brigade Response" provides direction to the Control Room personnel on contacting the off-site Fire Department and request assistance. The Fire Dispatcher is instructed to have the responding fire department enter the site through the prescribed entrance and have all responders stage in the appropriate parking lot. The Control Room also contacts Site Security and requests that a security officer escort the fire department(s) to the fire staging location. Off-site fire response may be provided TLD's and electronic dosimeters from Radiation Protection if required.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 48 of 85 The instructions on the methods to be used to contact the off-site fire emergency agencies, as well as site Security and Radiation Protection personnel, are provided in Procedure RP/0/B/1000/029. Reference(s): NSD-112 "Fire Brigade Organization, Training & Responsibilities" RPIOIB/1 000/029 "Fire Brigade Response" 3.4.6 Communications An effective emergency communications capability shall be provided for the industrial fire brigade. ---.....-----

--.------------........----T-he primary-means-of-communication-is-the-two-way-.radio-system;-whieh-has-a-fixed-location-------

repeater base station located above the Unit 112 Control Room in the Ventilation Equipment Room. If the repeater is lost to fire, the system can continue to function on the "talk around" channel. This system assures general coverage of the Turbine Building, Auxiliary Building, and Containment Building areas. The redundant repeaters receive emergency power and the individual radios have their own batteries. PIP 0-99-2753 verified that a radio system is in place which satisfies the above requirements. PIP 0-08-4820 has been initiated to confirm fire brigade communications at various locations with and without the availability of the radio repeaters. {Further Action Required - Ensure resolution of PIP 0-08-4820 satisfies the requirement of this section.} Reference(s): Design Basis Specification for Fire Protection PIP 0-99-2753 PIP 0-08-4820 Section 3.5 Water Supply 3.5.1 A fire protection water supply of adequatereliability,quantity, and durationshall be provided by one of the two following methods. (a) Provide a fire protection water supply of not less than two separate 300,000-gal (1,135,500-L) supplies. Lake Keowee has sufficient inventory (over 390,000 acre-feet) of water available. There are facility operational limitations based on the lake level in SLC 16.9.7 "Keowee Lake Level," that, ensures an adequate supply of water is available. In addition, a 100,000 gallon elevated water storage tank has inventory which is available to provide limited back-up water for fire

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 49 of 85 protection. The High Pressure Service Water (HPSW) System provides water for the fire protection system at the Oconee Plant. The HPSW system is connected to the Condenser Circulating Water (CCW) crossover header. The CCW piping is connected to Lake Keowee at the intake structure. This suction source would remain available on loss of power to the intake pumps because the system can be operated as a siphon. The NRC August 11, 1978 SER Section 4.3.1.1 states "The fire protection water supply is provided by the high-pressureservice water (HPSW)pumps which take suction from separate circulatingcooling water (CCW) system headers. The CCW system is supplied from Lake Keowee by pumps at the intake structure;the lake water would still be available on loss of power to the intake pumps because the system can operate as a siphon. The lake water supply has over 390,000 of water available."

---

-- water-storage-tank-,,atis-n-the-

                        *ia-dti*-n-ta-th-eý-HP$W-prampys;-a-er-O;*0-gallon--elevatiarr HPSW system provides a backup fire protection water supply."
                   "We find that the basic watersupply system satisfies the provisions ofAppendix A to B TP 9.5-1 and is, therefore, acceptable."

The LPSW system provides water to hose stations within the Reactor Buildings. The LPSW pumps takes suction from the CCW crossover line and discharge to a common discharge header in the same arrangement as the HPSW pump described above. The Keowee Hydro Station Water Spray and Fire Hose systems are suppliedbythe combined Service Water (SW)/Fire Protection Water system. The system is generally supplied via lake head pressure which provides sufficient flow and pressure for most operations. In the event additional flow/pressure is necessary an electric fire pump is provided. A portable gasoline fire pump is also provided in the event the electric fire pump is not in service. Reference(s): NRC SER dated August 11, 1978 Design Basis Specification for Fire Protection SLC 16.9.7 (b) Calculate the fire flow rate for 2 hours. This fire flow rate shall be based on 500 gpm (1892.5 L/min) for manual hose streams plus the largestdesign demand of any sprinkler or fixed water spray system(s) in the power block as determined in accordance with NFPA 13, Standard for the Installation of Sprinkler Systems, or NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection. The fire water supply shall be capable of delivering this design demand with the hydraulicallyleastdemanding portion of fire main loop out of service. The greatest demand for fire protection water is based on 1,000 gpm for fire hose plus 2,571

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 50 of 85 gpm (all sprinklerheads opened and flowing in the Unit 3 Turbine Building Mezzanine Level Sprinkler System) plus 500 gpm non-fire related service water for a total of 4,071 gpm. The most demanding water based fire suppression system required for Chapter 4 is the Main Feedwater Pump water spray systems. Calculation OSC-7858 hydraulically determined the water pressure and flow requirements. The results of the calculation determined a required flow of 1,404 gpm at 104.4 psi (including 750 gpm hose stream allowance. The available pressure at the calculated node when flowing 1,404 gpm is 140 psi. This calculation included the shortest flow path out'of service. These demands are all less than the output of one of the HPSW Pumps which is 6,000 gpm at 117 psi. The NRC August 11, 1978 SER Section 4.3.1.2 states "There are two 6,000 gpm HPSW pumps and one 500 gpmjockey pump, all ratedat 117psi net pressure. The two largepumps are consideredredundant,each capable of supplying the largestdesign fire flows plus other simultaneous demands on the HPSW system."

        "We find that the fire pumps meet the objectives outlinedin Section 2.2 of this reportand are, therefore, acceptable."

{Further Action Required - Ensure any credited suppression systems are within the design flow capabilities of the fire pump per NFPA 20.} Reference(s): Design Basis Specification for Fire Protection NRC SER dated August 11, 1978 OSC-7858 3.5.2 The tanks shall be interconnectedsuch thatfire pumps can take suction from eitherorboth. A failure in one tank orits piping shall not allow both tanks to drain. The tanks shall be designed in accordancewith NFPA 22, Standard for Water Tanks for PrivateFire Protection. Exception No. 1: Water storage tanks shall not be requiredwhen fire pumps are able to take suction from a large body of water (such as a lake), provided each fire pump has its own suction and both suctions and pumps are adequatelyseparated. Exception No. 2: Cooling tower basins shall be an acceptable water source for fire pumps when the volume is sufficient for both purposes and water quality is consistent with the demands of the fire service. The HPSW pumps take suction through the CCW crossover header. The crossover header can be supplied from any units CCW intake piping and can be gravity fed from Lake Keowee. The NRC August 11, 1978 SER Section 4.3.1.1 states "The fire protection water supply is providedby the high-pressureservice water (HPSW) pumps which take suction form separate

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 51 of 85 circulatingcooling water (CCW) system headers."

         "The pumps are located in the turbine building, each in a small masonryroom enclosing the pump and motor."
        "We find that the basic water supply system satisfies the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable."

The Keowee Fire Protection Pump takes its suction from Lake Keowee at the spillway wall. The back-up Keowee fire pump is a portable pump which can draw water from the gravity side of the suction piping. Reference(s): NRC SER dated August 11, 1978 Design Basis Specification for Fire Protection Drawing KFD-109A-1.1 "Keowee Hydro Station - Flow Diagram of Service Water System" 3.5.3 Firepumps, designedand installedin accordancewith NFPA 20, Standardfor the Installation of Stationary Pumps for FireProtection, shall be provided to ensure that 100 percent of the requiredflow rate and pressureare available assuming failure of the largestpump or pump power source. The pumps used to supply the fire protection systems at the Oconee Plant are not fire pumps but have been accepted by the NRC. As stated in Section 3.5.1, above, the HPSW System provides water for the fire protection system at Oconee. There are two 6,000 gpm (at 117 psig) HPSW pumps. There is also a 500 gpm (at 117 psig) jockey pump in the HPSW System. The jockey pump normally operates to maintain the system pressure on the fire protection headers and also supplies non fire related loads. In the event of a fire, one 6,000 gpm HPSW pump will automatically provide sufficient water for maintaining fire water demands and elevated water storage tank inventory. The second 6,000 gpm HPSW pump would be available if needed. The LPSW system provides fire water to the Reactor Building hose stations only. The LPSW pumps are rated at 15,000 gpm (at 100 psig) which is more than sufficient for the Reactor Building hose stations. The HPSW jockey pump is not considered part of the required fire protection for NFPA 20. The NRC August 11, 1978 SER Section 4.3.1.2 states "There are two 6,000 gpm HPSW pumps andone 500 gpmjockeypump, all ratedat 117 psi netpressure. The two largepumps are considered redundant,each capable of supplying the largestdesign fire flows plus other simultaneousdemands on the HPSW system. The pumps are electricmotor driven receiving power from separate Unit No. I buses."

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 52 of 85

         'We find that the fire pumps meet the objectives outlined in Section 2.2 of this report and are, therefore, acceptable."

The Keowee Hydro Station has a separate Fire Pump to supply hose stations and fixed suppression systems including the Keowee Main Transformer. The Keowee Fire Pump takes suction from Lake Keowee at the spillway structure. The Keowee Fire Pump is rated at 1,150 gpm at approximately 56 feet of head pressure with a shutoff head of 375 psi. A portable pump is provided and may be used in establishing a backup fire fighting system. Oconee Nuclear Station initiated Problem Identification Program (PIP) 0-99-4487 to evaluate the HPSW and Keowee Fire Water pumps' capabilities. The result of Calculation KC-2135, Revision 8, that was performed for the Keowee Fire Pump concluded that the flow and pressure available'at the Keowee Main Transformer deluge system did not meet NFPA 15-1996 (or -1969 the Code of Record) requirements. {FurtherAction Required - Ensure resolution of the Keowee fire pump replacement (PIP 0 3492) satisfies the requirement of this section.}

       ,Reference(s): NRC SER dated August 11, 1978 Design Basis Specification for Fire Protection PIP 0-01-3492 PIP 0-99-4487 3.5.4 At least one diesel engine-driven fire pump or two more seismic Category I Class IE electric motor-driven fire pumps connected to redundantClass IE emergencypowerbuses capableof providing 100 percent of the required flow rate and pressure shall be provided.

There are no permanently installed dedicated diesel engine-driven or electric motor-driven fire pumps at Oconee. Fire water is supplied via either of the two electric motor-drive HPSW pumps as part of a shared system. The HPSW pump motors are powered from separate buses. HPSW Pump A is located in Oconee 1 and power is furnished directly from 4160V Bus. No. 2 Unit No.l. Power to HPSW Pump B, which is located in Unit 2 along with the jockey pump, is furnished directly from 4160V Bus No. 1 Unit No. 1. The HPSW system is not a seismically designed system. Each HPSW pump is capable of providing 100 percent of the required flow and pressure. The NRC August 11, 1978 SER Section 4.3.1.2 states "There are two 6,000 gpm HPSW pumps andone 500 gpm jockey pump, all ratedat 11 7psi net pressure. The two large pumps are consideredredundant,each capable of supplying the largestdesign fire flows plus other simultaneous demands on the HPSW system. The pumps are electricmotor driven receiving power from separateUnit No. I buses."

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 53 of 85 "We find that the fire pumps meet the objectives outlined in Section 2.2 of this reportand are, therefore, acceptable." Keowee fire water supply is provided by a non-seismic electric fire pump with a portable gasoline engine-driven fire pump as backup. The backup portable gasoline fire pump is sufficient to supply the fire hose demands at Keowee. {Area for Improvement - Both HPSW pumps are currently powered from the same Unit. HPSW pumps should not be powered from a single unit. Consider connection to PSW or an alternate unit.} Reference(s): Design Basis Specification for Fire Protection NRC SER dated August 11, 1978 3.5.5 Each pump and its driver andcontrols shall be separatedfrom the remainingfire pumps and from the rest of the plant by ratedfire barriers. HPSW Pump A is located in Unit 1 and HPSW Pump B is located in Unit 2 Turbine Building basement; each in its own small 3-hour rated or equivalent masonry block room. The power cables to the motors are embedded in the concrete floor. The NRC August 11, 1978 SER Section 4.3.1.1 states "The HPSWpumps are located n the turbine building, each in a small masonry room enclosing the pump and motor. The power supply to each pump extends from the blockhouse via cables which are embedded in the turbine buildingfloor."

        "We find that the fire pumps meet the objectives outlined in Section 2.2 of this report and are, therefore, acceptable."

The 2005 NRC Triennial Fire Protection Inspection identified that the HPSW control circuit could be vulnerable from a Turbine Building Fire. A HPSW Vulnerability Evaluation was performed and is documented in PIP 0-05-4125. The vulnerability study determined that although the potential exists for loss of both HPSW pumps, the postulated fire scenarios that result in loss of the pumps would not affect Standby Shutdown System. In addition, in the event of the unavailability of both HPSW pumps, the EWST can provide a limited quantity of water for fire suppression. Reference(s): NRC SER dated August 11, 1978

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 54 of 85 PIP 0-05-4125 3.5.6 Fire pumps shall be provided with automaticstart and manual stop only. The HPSW Pumps receive an automatic start signal based on the elevated storage tank level. The pumps can be manually controlled from the Control Room. A modification has been initiated to provide manual stop capabilities (PIP 0-02-3870). The NRC August 11, 1978 SER Section 4.3.1.2 states "The HPSW pumps are operated automaticallybased on the water level maintained in the elevated water storage tank. The pumps can also be manuallystarted in the control room or at the pump switchgearlocated in the blockhouse."

        "We find that the fire pumps meet the objectives outlined in Section 2.2 of this report andare, therefore, acceptable."

The Keowee Fire Protection pump automatically starts on receipt of a pressure switch or flow switch alarm. The fire pump can only be stopped manually. {Area for Improvement - Document the resolution of PIP 0-02-3870 for installation HPSW manual stop.} Reference(s): NRC SER dated August 11, 1978 Design Basis Specification for Fire Protection PIP 0-02-3870 3.5.7 Individual fire pump connections to the yard fire main loop shall be provided and separated with sectionalizing valves between connections. Each HPSW Pump has a separate discharge into the HPSW System. Valves are arranged so that a single pipe break in the discharge piping will not remove both pumps from service. The NRC August 11, 1978 SER Section 4.3.1.3 states "Each HPSW Pump has a separate discharge into the HPSW System. Valving is arrangedso that a single pipe break in the dischargepiping will not remove both pumps from service."

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1. 2, & 3 Page 55 of 85 "We conclude that, upon implementation of the modificationsdescribedabove, the fire water piping system meets the objectives outlined in Section 2.2 of this report and are, therefore, acceptable." Note that modifications referred to in the conclusion pertain to cross-connections of the auxiliary building headers to provide dual feed for hose stations in the area. The Keowee Service Water system is a shared service water system that supplies cooling to equipment, fire protection equipment driven from the head of the lake, and the Keowee fire protection pump. The Keowee Fire Pump supplies some of the hydroelectric plant's fire system components. There are appropriate sectional and isolating valves in the system. Reference(s): Design Basis Specification for Fire Protection NRC SER dated August 11, 1978 Drawing Series OFD-124C

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                                                            . ......   -................
                                                                      --
                                                                -----------                   . . .    .

3.5.8 A method of automatic pressure maintenance of the fire protection water system shall be provided independent of the fire pumps. Pressure is maintained in the fire water system by the head of the water contained in the EWST. One method to maintain the water level in the EWST is the jockey pump. In the event the jockey pump is not available, the EWST can be filled by cycling a HPSW pump. At Keowee, the elevation of the lake maintains header pressure (no jockey pump). Reference(s): Design Basis Specification for Fire Protection 3.5.9 Means shallbe provided to immediately notify the controlroom, or other suitable constantly attendedlocation, of operation of fire pumps. The following alarms are provided in the Unit I Control Room:

                   "   Low HPSW system header pressure
                   "   Low elevated water storage tank level

• Elevated water storage tank overflow.

In addition to standard alarms, the control room computer alarms operators of the HPSW pump start

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1. 2. & 3 Page 56 of 85 The Keowee Fire Protection pump start alarms to the ONS Unit 2 Control Room and the Keowee Control Room. Reference(s): Design Basis Specification for Fire Protection 3.5.10 An undergroundyard fire main -loop, designed and installed in accordance with NFPA 24, Standardfor the Installationof PrivateFire Service Mains and TheirAppurtenances,shallbe installed to furnish anticipatedwater requirements. An underground fire loop (16 inch cement-lined, ductile iron pipe) is provided around the perimeter of theplant site. Post indicator valves are provided and are sealed or locked open to prevent inadvertent closing of valves required open for fire protection. Post indicator valves are arranged to provide isolation to portions of the main for maintenance or repair without shutting off the complete system. Valves will allow other service water systems to be removed from the HPSW system without compromising fire protection systems. The NRC August 11, 1978 SER Section 4.3.1.3 states "All yard fire hydrants, fixed water suppression systems, and interior hose lines are supplied by the HPSW system through undergroundyard mains and headers inside buildings."

       -"We conclude that, upon implementation of the modifications describedabove, the fire water piping system meets the objectives outlined in Section 2.2 of this reportand are, therefore, acceptable." Note that modifications referred to in the conclusion pertain to cross-connections of the auxiliary building headers to provide dual feed for hose stations in the area and are not applicable to this NFPA 805 section.

The Keowee Fire Water System does not have an underground loop. Underground fire water piping supplies two external fire hydrants. Appropriate isolation valves are provided for that portion of the system. {Further Action Required - Perform a NFPA 24 code compliance review.} Reference(s): NRC SER dated August 11, 1978 Design Basis Specification for Fire Protection Drawing series OFD-124C Drawing KFD-109A-1 .1

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 57 of 85 3.5.11 Meansshall be provided to isolate portionsof the yard fire main loop for maintenanceorrepair without simultaneouslyshutting off the supply to both fixed fire suppressionsystems and fire hose stations provided for manual backup. Sprinkler systems and manual hose station standpipes shall be connected to the plant fire protection water main so that a single active failure or a crack to the water supply piping to these systems can be isolated so as not to impair both the primaryand backup fire suppressionsystems. A 16 inch loop is provided around the perimeter of the plant. In-line isolation valves are provided such that a break can be isolated without losing system capabilities from a single break. Connections from this header to the units are redundant. Auxiliary Building headers are fed from a 16 inch line coming from the yard and a 4 inch and 16 inch line from the Turbine Building. The 16 inch line that cross connects the yard loop with the Turbine Building through the Auxiliary Building is normally isolated to reduce the potential consequences of an Auxiliary Building flood event. The isolation valves can be manually opened when the cross -.. ............. connect-is-required-to-be-pjlaced-in-service.-A-4-inch-line-from-the-Turbine-Building-Wiii-remain---- in service during normal operation in order to supply normal Auxiliary Building HPSW header requirements. The 4 inch line is capable of providing adequate initial HPSW flow and pressure and for fire mitigation and .service water demands in all areas of the Auxiliary Building. The 4 inch line contains a 500 gpm flow limiting device. The 500 gpm flow limiting device is sized to supply two 2-1/2" hose stations. The NRC August 11, 1978 SER Section 4.3.1.3 states "All yard fire hydrants, fixed water suppression systems, and interiorhose lines are supplied by the HPSW system through undergroundyard mains andheadersinside buildings. Sectionalizingvalves areprovided to allow isolation of varioussectionsof the system for maintenance;however there arelocations in the turbine building where a single piping break could affect both automatic water suppressionsystems andmanual hose stations. The licensee has proposedto cross-connect the ends of the two auxiliarybuilding headersto provide dual feed for the hose stations in this area.

                  "We conclude that, upon implementation of the modificationsdescribedabove, the fire water piping system meets the objectives outlined in Section 2.2 of this report and are, therefore, acceptable." The modifications referenced above to providing auxiliary building cross-connect have been implemented.

The Keowee fire protection system incorporates isolation valves for the various service water and fire system components. Reference(s): NRC SER dated August 11, 1978 Engineering Support Program Document for Fire Protection Design Basis Specification for Fire Protection Drawing series OFD-124C Drawing KFD-109A-1.1

Calculation No.: OSC-9295 Revision No.: Applicable Units: Oconee Unit 1, 2, & 3 Page 58 of 85 3.5.12 Threads compatible with those used by local fire departments shall be provided on all hydrants, hose couplings, and standpipe risers. Exception: Fire departments shall be permitted to be provided with adapters that allow interconnection between plant equipment and the fire department equipment if adequate trainingand procedures are provided. The fire water connections at the Oconee Plant and the Keowee Hydro Station utilize standard fire hose threads that are compatible with local fire department equipment., Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 3.5.13 Headers fed from each end shall be permitted inside buildings to supply both sprinkler and standpipe systems, providedsteel piping and fittings meeting the requirementsofANSI B31.1, Code for Power Piping,are used for the headers (up to andincluding the first valve) supplying the sprinklersystems where such headers arepartof the seismicallyanalyzed hose standpipe system. Where provided, such headers shall be considered an extension of the yard main system. Each sprinkler and standpipe system shall be equipped with an outside screw and yoke (OS&Y) gate valve or other approvedshutoff valve. The header system for the Turbine Building and Auxiliary Building sprinkler and standpipe systems are not part of a seismically analyzed hose standpipe system. Each sprinkler and standpipe system is equipped with an approved shutoff valve. During construction ANSI B31.1 excluded fire protection; NFPA codes were applicable at this time. The NRC August 11, 1978 SER Section 4.3.1.1 states "The fire protection water supply is provided by the high-pressureservice water(HPSW) pumps which take suction from separate circulatingcooling water (CCW) system headers."

        'We find that the basic watersupply system satisfies the provisionsofAppendixA to BTP 9.5-1 and is, therefore, acceptable."

The NRC August 11, 1978 SER Section 4.3.1.3 states "All yard fire hydrants, fixed water suppression systems, and interiorhose lines are supplied by the HPSW system through undergroundyard mains and headersinside buildings. Sectionalizing valves are provided to allowisolation of varioussections of the system for maintenance;however there arelocations in the turbine building where a single piping break could affect both automatic water suppressionsystems and manual hose stations. The licensee hasproposed to cross-connect the ends ofthe two auxiliarybuildingheaders to provide dual feed for the hose stationsin this

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 59 of 85 area.

        "We conclude that, upon implementation of the modifications describedabove, the fire water piping system meets the objectives outlined in Section 2.2 of this reportand are, therefore, acceptable." Note that modifications referred to in the conclusion pertain to cross-connections of the auxiliary building headers to provide dual feed for hose stations in the area and are not applicable to this NFPA 805 section.

Reference(s): Response to Appendix A to Branch Technical .Position APCSB 9.5-1, February 1982 NRC SER dated August 11, 1978 3.5.14 All fire protection water supply and fire suppression system control valves shall be under a periodicinspection programand shall be supervised by one of the following methods. (a) Electricalsupervision with audible and visual signals in the main control room or other suitable constantly attended location. (b) Locking valves in their normalposition. Keys shall be made available only to authorized personnel. (c) Sealing valves in theirnormalpositions.This option shallbe utilized only where valves are located within fenced areas or under the direct controlof the owner/operator. Oconee utilizes a locked or sealed method to control valve positions rather than electrical supervision. The site area fence is the Owner Controlled fence for sealing consideration. Valves are checked every 31 days per PT/O/A/0250/010 A. Reference(s): PT/O/AI0250/01 0 A "Fire Protection Systems Monthly Check" 3.5.15 Hydrants shallbe installedapproximatelyevery 250 ft (76 m) aparton the yardmain system. A hose house equipped with hose and combination nozzle and other auxiliary equipment specified in NFPA 24, Standardfor the Installation of Private Fire Service Mains and Their Appurtenances, shall be provided at intervalsof not more than 1000 ft (305 m) along the yard main system. Exception: Mobile means of providing hose andassociatedequipment, such ashose cartsor trucks, shall be permitted in lieu of hose houses. Where provided, such mobile equipment shall be equivalentto the equipment supplied by three hose houses. Fire hydrants are installed at a maximum of every 300 feet. Hose supplies are adequate to provide fire protection to all perimeter areas. Post indicatorvalves are provided and sections of the fire loop can be isolated for maintenance or repairs. Hose houses are located at several

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 60 of 85 yard hydrants and are equipped with at least 200 feet of 11/2 inch hose, 200 feet of 21/2 inch hose, one-21/2 inch gated wye and two-11/2 inch nozzles and one-21/2 inch to 11/2inch reducer. In addition to the hose houses, there is an equipment storage trailer located north of the Radwaste Building, a equipment storage trailer beside the OOB and the Fire and Rescue Vehicle that each contain additional fire hose and fire fighting tools. The NRC August 11, 1978 SER Section 4.3.1.3 states "Yard fire hydrantshave been provided at approximately 300 ft. intervals aroundthe exteriorof the plant. Auxiliary gate valves arenot provided on the hydrant laterals, with the result that a portion of the fire water heads would have to be removed from service if a fire hydrant has to be isolatedfor maintenance."

        "Hosehouses have been provided at seven of the yard hydrants, each equipped with at least 200 ft. of 2-1/2 inch hose, 200 ft. of 1-1/2 inch hose and other manual fire fighting tools."
        "We conclude that, upon implementation of the modifications described above, the fire water piping system meets the objectives outlined in Section 2.2 of this report and are, therefore, acceptable." Note that modifications referred to in the conclusion pertain to cross-connections of the auxiliary building headers to provide dual feed for hose stations in the area and are not applicable to this NFPA 805 section.

The Keowee service water system incorporates two fire hydrants and one outside hose cabinet. Reference(s): NRC SER dated August 11, 1978 Design Basis Specification for Fire Protection PT/0/B/0250/030 "Quarterly Fire Brigade Equipment Inspection" 3.5.16 The fire protection water supply system shall be dedicated for fire protection use only. Exception No. 1: Fire protection water supply systems shall be permitted to be used to provide backup to nuclearsafety systems, provided the fire protection water supply systems are designedand maintainedto deliver the combined fire and nuclearsafety flow demands for the durationspecified by the applicable analysis. Exception No. 2: Fireprotection water storagecan be providedby plant systems servingother functions, provided the storage has a dedicated capacitycapable of providing the maximum fire protection demand for the specified duration as determined in this section. The fire water systems for the Oconee Plant are supplied from the HPSW System. The HPSW system is designed to support fire protection and essential service water systems flow demands. The HPSW system draws water from Lake Keowee which has sufficient capacity to meet fire protection demands.

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 61 of 85 The NRC August 11, 1978 SER Section 4.3.1.2 states "There are two 6,000 gpm HPSW pumps and one 500 gpm jockey pump, all ratedat 117 psi net pressure. The two largepumps are consideredredundant,each capable of supplying the largestdesign fire flows plus other simultaneous demands on the HPSW system."

                   'We find that the fire pumps meet the objectives outlined in Section 2.2 of this reportand are, therefore, acceptable."

The Reactor Building hose stations are supplied via the LPSW system. The LPSW system is sized to be capable of essential service water flow demands and to support fire hose stations. The NRC August 11, 1978 SER Section 4.3.1.4 states "Interiorhosestationsequipped with I-1/2 inch fire hose have been provided through the plant except in containment. Some areas ........ are too far away from a hose stationfor effective fire fighting. The licensee has proposedto

          --.....- provide--additional-hose-st-atie'n~sý--th',at-al,-areas--contariPing-or--e.-posing-safety-related--.--.- -

equipment Will be within effective fire fighting range of at leastone hose station using not more than 100 ft. of 1-1/2 inch fire hose, and to provide hose stations inside containmentsupplied by the LPSW system."

                   "Upon completion of the proposedmodification,we find that the interiorhose stationsmeet the requirementsof Appendix A to BTP 9.5-1 and are, therefore, acceptable." The modification referenced above to provide hose stations inside containments supplied by the LPSW system has been implemented.

The fire water supply for the Keowee Hydro Stationvis supplied by the Service Water System. The Service Water system draws water from Lake Keowee which has sufficient capacity to meet fire protection demands. Reference(s): NRC SER dated August 11, 1978 Design Basis Specification for Fire Protection Section 3.6 Standpipe and Hose Stations 3.6.1 For all power block buildings, Class Ill standpipe and hose systems shall be installed in accordance with NFPA 14, Standardfor the Installation of Standpipe, Private Hydrant,and Hose Systems. Standpipes and hose stations required to meet the deterministic or performance based requirements of Chapter 4 are defined in NEI 04-02 Table B-3, Fire Area Transition report. In addition, systems required by licensing actions and engineering evaluations are included in Table B-3.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 62 of 85 Hose stations at the Oconee site (including Keowee) are arranged to reach any location, including containment, with 100 feet of 1-1/2 inch fire hose. Some hose stations are located outside of the affected fire area but this was found acceptable by the NRC. Current NRC committed fire hose stations are listed in SLC 16.9.4. The NRC August 11, 1978 SER Section 4.3.1.4 states "Interiorhosestations equipped with 1-1/2 inch fire hose have been providedthrough the plantexcept in containment. Some areas are too far away from a hose station for effective fire fighting. The licensee has proposedto provide additional hose stations so that all areas containing or exposing safety-related equipment will be within effective fire fightingrange of atleastone hose stationusing not more than 100 ft. of 1-1/2 inch fire hose, and to provide hose stations inside containment supplied by the LPS W system."

        "Upon completion of the proposedmodification, we find that the interiorhose stationsmeet the requirementsof Appendix A to BTP 9.5-1 and are, therefore, acceptable." The modification referenced above to provide additional hose stations has been implemented.

The NRC June 7, 1988 SER states "The licensee hasproposed a modification to move five fire hose station presently located within the Cable Spreadingrooms to stairwell locations outside the rooms. The purpose of this modification is to make the fire hose stationaccessible for fire fighting activities in these rooms."

        "The proposedmodification of fire hose stations will enhance the fire fighting capabilitiesin the Cable Spreading Rooms and meets the intent of the guidance provided in National Fire ProtectionAssociation (NFPA) Std. 14, Standpipe and Hose Systems, for the location of fire hose connections. After reviewing these proposed TS changes,the staff has determinedthey are acceptable." The modification referenced above to relocate fire hose stations from the Cable Spreading rooms has been implemented.

{Further Action Required - Perform a NFPA 14 code compliance review.} Reference(s): NRC SER dated August 11, 1978 NRC SER dated June 7,1988 Duke letter to the NRC dated 2/17/78 SLC 16.9.4 Design Basis Specification for Fire Protection OSC-9292 3.6.2 A capabilityshall be provided to ensure an adequatewater flow rate and nozzle pressure for all hose stations. This capability includes the provision of hose station pressure reducers

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2. & 3 Page 63 of 85 where necessary for the safety of plant industrial fire brigade members and off-site fire departmentpersonnel. Fire hose station piping is sized based on hydraulic calculations to provide a minimum of 100 gpm at 65 psi at the hose station isolation valve required for Chapter 4. The previously discussed fire water distribution system is capable of supplying this demand. The Reactor Building hose stations are supplied via the LPSW system which provides acceptable flow and pressure. The Keowee hose stations are supplied via the Service Water system which can provide adequate flow and pressure. Internal evaluations have been performed to confirm flow and pressure requirements are met. Calculation OSC-1 626 validates adequate NFPA 14 flow and pressure to the required and credited fire hose stations. Reference(s): Design Basis Specification for Fire Protection Calculation OSC-1626 3.6.3 The propertype of hose nozzle to be supplied to each power block areashallbe basedon the area fire hazards. The usual combination spray/straightstream nozzle shall not be used in areas where the straight stream can cause unacceptable damage or present an electrical hazardto fire-fightingpersonnel.Listed electricallysafe fixed fog nozzles shall be providedat locations where high-voltage shock hazards exist. All hose nozzles shall have shutoff capabilityand be able to control water flow from full open to full closed. Adjustable nozzles are provided on hoses at the hose stations of both the Oconee Plant and the Keowee Station. These nozzles are appropriate for the type fires that might occur at those locations. In addition, the fire brigade has specialized nozzles such as low pressure/high flow and articulating. Fire Brigade Guide (SOG) #3 includes guidance on electrical fires and the proper hose stream application. Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 Duke letter to the NRC dated November 22, 1977 Design Basis Specification for Fire Protection Fire Plan, SOG #3, Electrical Fires 3.6.4 Provisionsshall be made to supply water at least to standpipes andhose stationsfor manual fire suppression in all areas containing systems and components needed to perform the nuclearsafety functions in the event of a safe shutdown earthquake (SSE). Exception: Forexisting plants that are not capable of meeting this requirement,provisionsto

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 64' of 85 restorea water supply and distributionsystem for manualfire-fightingpurposesshallbe made. The provisional manual fire-fighting standpipe/hose station system shall be capable of providingmanual fire-fightingprotection to the variousplantlocationsimportantto supporting and maintaining the nuclearsafety function. The provisions for establishingthis provisional system shallbe preplannedandbe capable of being implementedin a timely mannerfollowing an SSE Fire hose stations (with the exception of those in the Reactor Building and Unit 1/2 and Unit 3 Cable Room to Control Room back stair hose stations) are not seismically designed. NFPA 14-1969 (code of record) did not have provisions for seismically designed hose stations. The HPSW system is not seismically designed. The NRC previously found the hose stations acceptable per Section 3.6.1 above. Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 __---sg-- a* iti-ffft-e Pt--t-----i Design Basis Specification for the High Pressure Service Water System 3.6.5 Where the seismic requiredhose stations are cross-connectedto essentialseismic non-fire protection water supply systems, the fire flow shall not degrade the essentialwater system requirement. The fire hose stations at the Oconee Plant and the Keowee Hydro Station were not designed to meet seismic requirements with the exception of the Reactor Building :fire hose stations. The Reactor Building fire hose stations are seismically designed supplied from the LPSW system. The LPSW system is seismically designed. The LPSW system is capable of supplying the essential water system requirements and the fire flow simultaneously. Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 Design Basis Specification for Fire Protection Design Basis Specification for the Low Pressure Service Water System Section 3.7 Fire Extinguishers Where provided, fire extinguishersof the appropriatenumber,size, and type shallbe provided in accordancewith NFPA 10, Standardfor PortableFireExtinguishers.Extinguishersshall be permitted to be positionedoutside of fire areas due to radiologicalconditions. Portable fire extinguishers required to meet the deterministic or performance based requirements of Chapter 4 are defined in NEI 04-02 Table B-3, Fire Area Transition report. In addition, systems required by licensing actions and engineering evaluations are included in Table B-3.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 65 of 85 Portable fire extinguishers are generally provided in accordance with NFPA 10, "Standard For Portable Fire Extinguishers." The portable extinguishers used on site are either "ABC", Carbon Dioxide, or Halon type fire extinguishers. In some instances extinguishers are not located in all areas due to ALARA. In these cases the extinguishers are located near the entrance to the areas The NRC August 11, 1978 SER Section 4.3.3 states "Portablefire extinguishershave been distributed throughout the plant in accordance with NFPA guidelines. The licensee has proposed to provide Halon 1211 extinguisherin the control room."

         "Upon completion of the proposed modification, we find that portable fire extinguishers will conform to the provisions of Appendix A to BTP 9.5-1 and accordinglyis acceptable."The modification referenced above to provide Halon extinguishers in the control rooms has been implemented.

{Further Action Required - Perform a NFPA 10 code compliance review.} Reference(s): NRC SER date August 11, 1978 Design Basis Specification for Fire Protection OSC-9292 3.8 Fire Alarm and Detection Systems 3.8.1 FireAlarm Alarm initiating devices shall be installed in accordance with NFPA 72, National Fire Alarm Code.Alarm annunciation shall allow the proprietaryalarm system to transmit fire-related alarms, supervisory signals, and trouble signals to the control room or other constantly attendedlocation from which requirednotifications and responsecan be initiated.Personnel assignedto the proprietaryalarm stationshallbe permitted to have otherduties. The following fire-relatedsignalsshall be transmitted: (1) Actuation of any fire detection device (2) Actuation of any fixed fire suppressionsystem (3) Actuation of any manual fire alarm station (4) Starting of any fire pump (5) Actuation of any fire protection supervisory device (6) Indicationof alarm system trouble condition The Oconee Nuclear Station power production areas are protected by two fire alarm systems. The fire alarm control panel for Units 1 and 2 is located in the Unit 1&2 Control Room and the fire alarm control panel for Unit 3 is located in the Unit 3 Control Room. The Keowee Hydro Plant, SSF and Radwaste Facility each have their own fire alarm system which alarm to the

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 66 of 85 Unit 1&2 and/or Unit 3 Control Room. The Fire Alarm and Detection Devices in general are installed in accordance with NFPA 72D (1975). The Design Basis Specification for the Fire Detection System, Design Basis Specification for Fire Protection, and BTP comparison provide additional detail on the Oconee fire detection system. The fire alarm systems are provided with capabilities to relay the fire-related signals from any fire detection device, actuation of fixed fire suppression systems, actuation of manual fire alarm stations, actuation of supervisory signals, and alarm of trouble conditions. Start of the HPSW pumps used for the fire protection systems also alarm in the control room. Deviations from NFPA 72D are identified and justified by paragraph number per National Fire Code, 1975 as documented in the UFSAR, BTP comparison and Design Specification for Fire Protection. These Deviations from NFPA 72D are as follows: o 1221, 1223 - At Oconee, the alarm comes into the control room. The operator then

                     -no-iesp-la-t-pe-sonnelo-the_-eA-ca-ion..                                            -

o 1231 - Alarms on the control board are tested on.each 12-hour shift by operator procedures. o 1232 - Procedures require annual testing of transmitters and water flow actuated devices. Water spray (deluge) systems for safety-related equipment are tested on an annual basis. o 2110 - The Oconee fire detection system is cabled using steel/aluminum sheathed #16 AWG cable for signal transmission. This cable meets or exceeds the requirements for physical and electrical protection as defined in NEC, Article 760. o 2222, 2223 - The fire detection system at Oconee is powered from a battery backed power supply through a static inverter to provide 240/120 VAC. These batteries which are Class 1E but utilized as Non-Class 1E are continuously charged from normal station power. On loss of normal station power, the system is designed to provide power to the fire detection system for one hour. In addition, a transfer switch is provided for transferring the inverter loads to regulated normal station AC power should a malfimction of the battery inverter supply occur. o 2521 - The annunciator audible alert at Oconee serves the fire detection system as well as other plant systems. The visual indicator provided by the visual display prevents operator confusion regarding source of the alarm. The fire detection system provides an audible and visual alarm and annunciation in the control room. Local audible alarms do not sound at the location of the fire. The operator receives the alarm in the control room, dispatches plant personnel to the location of the alarm to ascertain the local conditions and then, if necessary, summons the fire brigade via the Public Address System (PA) and a radio paging system. Radwaste Fire Detection system alarms to the Unit 3 Control Room and Radwaste Facility control room. The SSF Fire Detection system alarm to the Unit 1&2 Control Room, Unit 3 Control Room and the SSF Control Room.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 67 of 85 Keowee Hydro Station Fire. Detection system provides an audible and visual alarm and annunciation in Keowee and ONS Unit 2 Control Room. The NRC August 11, 1978 SER Section 4.2 states "The plant has a protective signaling system which transmits alarms from fire detectors and water spray system actuation to the controlroom. Water flow on wet pipe sprinklersystems does not alarmin the control room. In general, the system complies with those provision of NFPA 72D which are considered essential for the facility, including requirements for emergency power supply and circuit supervision. There is no distinct audible fire alarm signalprovided in the control room."

        "The licensee has proposed to provide water flow alarmsin the control room for all wet pipe sprinklersystems, and a unique audible signal in the controlroom for fire alarmnotification of the operators."
        "We find that, subject to the implementation of the proposed modifications, the fire detection and signalingsystem in conjunction with the safe shutdown system satisfies the objectives of Section 2.2 of this report and is, therefore, acceptable." Modifications referenced above to, providing water flow alarms and a distinct audible fire alarm signal in the control room have been implemented.

{Further Action Required - Perform a NFPA 72 code compliance review of the fire alarm and detection systems.} Reference(s): NRC SER dated August 11, 1978 Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 Design Basis Specification for Fire Protection Design Basis Specification for the Fire Detection System UFSAR Section 9.5.1.5.1 3.8A1.1 Means shall be provided to allow a person observing a fire. at any location in 'the plant to quickly and reliably communicate to the control room or other suitable constantly attended location. All persons authorized access to the Oconee site receive instruction on the proper actions to be taken upon the discovery of a fire and the proper response to a fire alarm. The primary method of communication is the telephone system with outside as well as in-plant connections. In conjunction with the telephone, a page system is used for calls throughoutthe plant. Each telephone is marked with the emergency reporting numbers. Emergency*

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 68 of 85 reporting numbers communicate to a constantly attended location (Control Room or Security). The Keowee Hydro Station has several methods of communication. There are in-station page phones and telephones connected to Oconee. There is an automatic ring down phone to Oconee Unit 2 Control Room. Reference(s): Design Basis Specification for Fire Protection" General Employee Training - Plant Access Training 3.8.1.2 Means shall be provided to promptly notify the following of any fire emergency in such a way as to allow them to determine an appropriatecourse of action: .................... r,-*. e,-a,--s,-,te-p ,ulatie,,-in-all ,eeeupiedareas-- - - --- -----------

                           ,,-)G                                                                            .-

(2) Members of the industrialfire brigadeand othergroups supporting fire emergency response (3) Off-site fire emergency response agencies. Two independent means shall be available (e.g., telephone and radio)for notification of off-site emergency services Oconee is provided with a plant-wide PA system that is used to alert the general site population to any necessary instructions. Operations informs plant personnel of the location of a fire emergency by using the PA, dispatches personnel to ascertain the local conditions and then, if necessary, summons the fire brigade by the PA, fire brigade pagers and radio communication. The Radiation Protection, Safety, and Security personnel are alerted by the PA announcement and respond as necessary to support the Fire Brigade as determined by the Fire Brigade Leader as Incident Commander. If off-site assistance .is determined to be prudent, the Control Room will contact the appropriate agencies via telephone. Secondary communication to off-site fire departments is through off-site radio communication. Off-site radios capable of communication with the off-site emergency response agencies are located in the Control Room, Security, and the station rescue vehicle. The instructions on the methods to be used to contact the off-site fire emergency agencies are provided in Procedure RP/0/B/1000/029 "Fire Brigade Response." Reference(s): RP/0/B/1 000/029 "Fire Brigade Response"

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 69 of 85 3.8.2 Detection If automaticfire detectionis requiredto meet the performance or deterministicrequirementsof Chapter4, then'these devices shall be installedin accordance with NFPA 72, National Fire Alarm Code, and its applicableappendixes. Automatic fire detection systems required to meet the deterministic or performance based requirements of Chapter 4 are defined in NEI 04-02 Table B-3, Fire Area Transition report. In addition, systems required by licensing actions and engineering evaluations are included in Table B-3. The NRC August 11, 1978 SER Section 4.2 states "The plant has a protective signaling system which transmits alarms from fire detectors and water spray system actuation to the controlroom. Waterflow on wet pipe sprinklersystems does not alarm in the control room. In general, the system complies with those provision of NFPA 72D which are considered ............. *ssent'iai'-flor-th'-e-ilciiity,

                                          ,-*ircluding-requireument's-fi~oj-emergency,--poet-supp~y-anld--circuit'-

supervision. There is no distinct audible fire alarm signalprovided in the control room."

             "Smoke detectors in some areasof the plant containingelectricalcable insulationare located lower than the ceilinglevel and,therefore, maynot respondas rapidlyas they would if located at the ceiling. However, since fires in cable insulation generate heavy quantities of smoke, reasonablyprompt detection can be expected. Ionization type smoke detectors are used throughoutthe plant. In some tests, ionizationtype detectorshave not respondedasrapidlyto a fire involving PVC as they do to a fire involving other types of insulation. Tests have shown that they are, however, adequate to detect first in their early stages. To assure that fires in safe shutdown areasof the plant are detected, the licensee has proposed,in addition to the exiting detection system, to provide detectorsin all areas containingsafe shutdown equipment and combustibles. In addition, the licensee has proposed to provide a dedicated safe shutdown system which would be unaffected by fires involving safe shutdown equipmentsuch that the plantcan be safely shut down in the event of a fire in any location in the plant."
             "We find that, subject to the implementation of the proposedmodifications, the fire detection and signalingsystem in conjunction with the safe shutdown system satisfiesthe objectives of Section 2.2 of this report and is, therefore, acceptable." Modifications referenced above including addition of detectors in areas containing safe shutdown equipment and providing a dedicated safe shutdown system have been implemented.

Original deviations to the fire detection system are listed in the Design Basis Specification for Fire Protection and the Design Basis Specification for the Fire Detection System. Modifications to the fire detection system have since been performed. Modifications are performed in accordance with NFPA 72. A major upgrade to the fire detection system was performed under modification NSM-52796 in 1992. Currently the NRC committed fire detection instrumentation devices are listed in SLC 16.9.6.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 70 of 85 {Further Action Required - Perform a NFPA 72 code compliance review of the fire alarm and detection systems.} Reference(s): NRC SER dated August 11, 1978 Design Basis Specification for Fire Protection Design Basis Specification for the Fire Detection System SLC 16.9.6 OSC-9292 Section 3.9 Automatic and Manual Water-Based Fire Suppression Systems 3.9.1 If an automatic or manual water-based fire suppression system is required to meet the performance or deterministicrequirementsof Chapter4, then the system shall be installed in accordance with the appropriateNFPA standardsincluding the following: (1) NFPA 13, Standardfor the Installation of Sprinkler Systems (2) NFPA 15, Standardfor Water Spray Fixed Systems for Fire Protection (3) NFPA 750, Standardon Water Mist Fire Protection Systems (4) NFPA 16, Standard for the Installation of Foam-Water Sprinkler and Foam-Water Spray Systems There are no NFPA 750 water mist systems. The power block contains one NFPA 16 foam-water system located in Radwaste and is abandoned in place. Automatic or manual water based fire suppression systems required to meet the deterministic or performance based requirements of Chapter 4 are defined in NEI 04-02 Table B-3, Fire Area Transition report. In addition, systems required by licensing actions and engineering evaluations are included in Table B-3. The Oconee Nuclear Station is protected by automatic wet pipe sprinkler systems, water spray system, and deluge systems. The Design Basis Specification for Fire Protection and Engineering Support Program Document for Fire Protection provide additional detail on the Oconee water based fire suppression systems. The automatic sprinkler systems were designed to conform to requirements of appropriate NFPA Standards with deviations as identified by the individual system as-built code compliance calculations. Each automatic sprinkler system has an independent connection to the plant HPSW System. The Keowee Service Water System supplies the Keowee main transformer deluge system, lube oil room and gravity oil room. Valves for the HPSW and SW systems are not electrically supervised; however, the station requires fire protection valves to be sealed or locked in the normal open position.

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 71 of 85 Currently the NRC committed fire suppression systems are listed in SLC 16.9.2. Code compliance calculations are prepared for each Turbine Building and Auxiliary Building suppression system. PIP 0-02-6047 has been initiated to disposition comments from the Fire Suppression NFPA Code Review project. The NRC August 11, 1978 SER Section 4.3.1.3 states "Wetpipe automaticsprinklerprovide area coverage over those portions of the turbine building basement and mezzanine levels which contain the turbine oil piping systems."

        "Automatic water spray systems are installed on the turbine oil headersandreservoirs, feed waterpumps, and hydrogen seal oil units in the turbine building; andon oil-filled transformers andreactorsin the yard areas. The waterspray systems are designed accordingto applicable NFPA Standards."
        "We find that the sprinkler systems meet the requirements of Appendix A of BTP 9.5-1 and are, therefore, acceptable."

{Further Action Required - Review the applicable Fire Suppression NFPA Code Review calculations for adequacy. Perform new code compliance reviews as necessary.} Reference(s): NRC SER dated August 11, 1978 SLC 16.9.2 Engineering Support Program Document for Fire Protection Design Basis Specification for Fire Protection NRC Letter to Duke dated February 2, 1982 Fire Suppression NFPA Code Review calculations PIP 0-02-6047 OSC-9292 3.9.2 Each system shall be equipped with a water flow alarm. All fixed extinguishing systems are provided with alarms. Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 Duke letter to the NRC dated November 22, 1977

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 72 ' of 85 Design Basis Specification for Fire Protection 3.9.3 All alarms from fire suppressionsystems shallannunciatein the control room or othersuitable constantly attended location. All water based suppression systems alarm to the Control Room and/or Security. Alarms associated with the Keowee Fire Protection System are annunciated in the Unit 2 Main Control Room and the Keowee Control Room. Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 Duke letter to the NRC dated November 22, 1977 Design Basis Specification for Fire Protection Design Basis Specification for the Fire Detection System 3.9.4 Diesel-driven fire pumps shallbe protected by automatic sprinklers. The Oconee Plant does not utilize a diesel driven fire water pump. Reference(s); Design Basis Specification for Fire Protection 3.9.5 Each system shall be equipped with an OS&Y gate valve or other approved shutoff valve. Each automatic sprinkler system has a connection to the plant HPSW System. Each system can be isolated from the main header with an approved control valve. The NRC August 11, 1978 SER Section 4.3.1.3 states "All yard fire hydrants, fixed water suppression systems, and interiorhose lines are supplied by the HPSW system through undergroundyard mains andheaders inside buildings. Sectionalizing valves are providedto allow isolation of varioussections of the system for maintenance;however there arelocations in the turbine building where a single piping break could affect both automatic water suppressionsystems and manualhose stations. The licensee hasproposedto cross-connect the ends of the two auxiliarybuilding headersto provide dualfeed for the hose stations in this area."

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 73 of 85 "We conclude that, upon implementation of the modifications described above, the fire water piping system meets the objectives outlined in Section 2.2 of this report and are, therefore, acceptable." Note that modifications referred to in the conclusion pertain to cross-connections of the auxiliary building headers to provide dual feed for hose stations in the area and are not applicable to this NFPA 805 section. Reference(s): NRC SER dated August 11, 1978 Response to AppendixA to Branch Technical Position APCSB 9.5-1, February 1982 3.9.6 All valves controllingwater-basedfire suppressionsystems requiredto meet the performance or deterministicrequirementsof Chapter4 shall be supervised as described in 3.5.14. Valves for the ONS Plant HPSW and Keowee SW System are not electrically supervised. A program at the station requires fire protection valves to be sealed or locked inthe normal open position. A periodic recorded inspection is conducted to ensure that the fire protection valve positions are correct. See Section 3.5.14. Reference(s): N/A Section 3.10 Gaseous Fire Suppression Systems 3.10.1 If an automatictotal flooding and local applicationgaseous fire suppressionsystem is required to meet the performanceor deterministicrequirementsof Chapter4, then the system shallbe designed and installed in accordance with the following applicable NFPA codes: (1) NFPA 12, Standardon Carbon Dioxide Extinguishing Systems (2) NFPA 12A, Standardon Halon 1301 FireExtinguishing Systems (3) NFPA 2001, Standardon Clean Agent Fire Extinguishing Systems The existing gaseous fire suppression systems at Oconee are not required to meet the deterministic or performance based requirements of Chapter 4 are defined in NEI 04-02 Table B-3, Fire Area Transition report. The gaseous fire suppression systems at the Oconee Nuclear Plant are utilized to protect unique components and/or hazards. The SSF Diesel Generator Room is protected by a low pressure total flooding carbon dioxide suppression system. The two Keowee Hydroelectric generators are each protected by a High Pressure Carbon Dioxide Suppression System that provides CO 2 directly into the generator

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 74 of 85 housing. The Administration Building Record Storage Vault, Oconee Operator Training Center Simulator, and Complex Office Building communication room is protected by a Halon 1301 total flood fire suppression system. These buildings are not part of the power block. {Area for Improvement - Perform a NFPA 12 code compliance review) Reference(s): Design Basis Specification for Fire Protection OSC-9292 3.10.2 Operationof gaseousfire suppressionsyst-s-or other constantly attendedlocation identified. Actuation of the Keowee Hydro Station CO 2 system is alarmed in the ONS Unit 2 Control Room and at Keowee. Operation of the SSF Diesel Room C02 system is alarmed in the Unit 2 Control Room and Security. Reference(s): Design Basis Specification for Fire Protection Design Basis Specification for the Fire Detection System 3.10.3 Ventilation system design shall take into account prevention from over-pressurizationduring agent injection, adequate sealing to prevent loss of agent, and confinement of radioactive contaminants. The Keowee Hydro Station system injects into the respective hydroelectric generator's housing and not into a ventilation system. The leak tightness of the housings is included in the system testing procedure to ensure substantial concentration. The SSF CO2 System injects only into the Diesel Generator Room. The ventilation system to the room is isolated during system actuation to ensure concentration for at least 30 minutes. There are no radioactive contaminants involved ateither location protected by the gaseous fire suppression systems.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 75 of 85 {Area for Improvement- Evaluate and document the potential effects of over pressurization in the areas of C02 System discharge.} Reference(s): Design Basis Specification for Fire Protection 3.10.4 In any area required to be protected by both primary and backup gaseous fire suppression systems, a single active failure or a crack in any pipe in the fire suppressionsystem shall not impairboth the primaryand backup fire suppression capability. There are no installed backup gaseous fire suppression systems utilized at Oconee. The Keowee C02 is designed for a "dual shot" capacity. The installed gaseous suppression systems can be manually initiated. The C02 system in the SSF Diesel Generator Room is installed for property conservation and is not a NRC committed system, however the tank is sized for "dual shot" capability. Reference(s): Design Basis Specification for Fire Protection 3.10.5 Provisionsfor locally disarmingautomaticgaseoussuppressionsystems shall be securedand under strict administrativecontrol. Any change to any plant system or component is strictly controlled at the Oconee Nuclear Station. Only mechanical lock-outs are allowed when personnel safety is involved. In addition, any change to the alignment for automatic actuation of either the Keowee Hydro Station C02 system or the SSF CO 2 system would result in an alarm. Maintenance and testing of the C02 Systems is controlled through approved work authorizations and appropriate implementing procedures. Reference(s): OP!O/A/1600/004 "Operation of the SSF C02 System" PT/O/A/0400/002 "SSF C02 Test' PT/1/A/2200/006 "KHU-1 C02 System Surveillance" PT/2/A/2200/006 "KHU-2 C02 System Surveillance" 3.10.6 Total flooding carbondioxide systems shall not be used in normally occupiedareas.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1,2, & 3 Page 76 of 85 The Keowee Generator housing and the SSF Diesel generator room are not normally occupied areas. When access for testing and/or maintenance purposes is authorized, plant procedures require disarming the automatic actuation feature. Reference(s): OP/0/A/1600/004 "Operation of the SSF C02 System" PT/O/A/0400/002 "SSF C02 Test" PT/1/A/2200/006 "KHU-1 C02 System Surveillance" PTI2/A/22001006 "KHU-2 C02 System Surveillance" 3.10.7 Automatic total flooding carbon dioxide systems shall be equipped with an audible pre- -.-------..-.--....... discharge-alarm-and-discharge-delay-sufficient-to-perm--.it-egress--ofpersonnel--.....- The carbon dioxide system shallbe provided with an odorizer. Any work conducted inside the Keowee Hydro generator housings or inside the SSF Diesel Generator Room would require authorization via the work control process which may require manually isolating and Red Tagging the CO2 System prior to entry. The Keowee CO 2 System whistles on discharge. The Keowee Hydro Station's CO 2 supply is not provided with an odorizer because the area inside the generator housing would not be occupied unless testing or maintenance work was being conducted which would require the C02 system to be manually isolated. Work inside the SSF Diesel Generator Room would require the issuance of a work authorization which would include a restriction to manually isolate the C02 System prior to entry if work was above the floor level such that egress time is impaired. There is a Pre-Discharge Alarm for the SSF Diesel Generator Room and the alarm is set between 60 and 70

                      'seconds. There is an odorizer in the SSF CO 2 System that uses a "garlic" scent.

Reference(s): PT/0/A/0400/002 "SSF C02 Test" 3.10.8 Positive mechanicalmeans shallbe providedto lock out total flooding carbon dioxide systems during work in the protected space. Each CO 2 system has manual isolation valves. The SSF CO 2 system can be locked out by manually closing the tank shutoff valve. The Keowee Hydro Station C02 system contains an interlock requiring the generator doors to be closed for actuation. This interlock feature is routinely verified during system surveillance. In addition, the Keowee C02 supply header

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 77 of 85 isolation valve can be manually closed. Closure of the supply tank valve would be included as a prerequisite for work authorization involving access to the inside of the generator housing. Reference(s): OP/O/AI1 600/004 "Operation of the SSF C02 System" PT/0/A/0400/002 "SSF C02 Test" PT/1/A/2200/006 "KHU-1 C02 System Surveillance" PT/2/A/2200/006 "KHU-2 C02 System Surveillance" 3.10.9 The possibilityof secondary thermal shock (cooling)damage shall be considered during the design of any gaseous fire suppressionsystem, but particularlywith carbon dioxide.

      -

---

... a-rX-t- - 7Hd *-Sta-*Ge to- H 5u- i-and the SSF Diesel Generator Room. There are no sensitive components that would be damaged by the rapid cooling resulting from a C0 2 system discharge into either of these locations.

{Area for Improvement - Evaluate and document the potential effects of rapid cooling of the Keowee Generators or the SSF Diesel Generator and their associate components in the area of C0 2 System discharge.} Reference(s): None 3.10.10 Particularattention shall be given to corrosivecharacteristicsof agent decompositionproducts on safety systems. The CO 2 system for the winding brushes on the Keowee Hydro Station Generator Housings would be considered a spatially separate safety system. Only one generator is needed to provide emergency power to the Oconee Plant. Fires are not assumed simultaneously at Keowee and Oconee The SSF CO 2 system discharges only to the Diesel Generator Room which is considered a safety system. {Area for, Improvement - Evaluate and document the potential effects of corrosivity on the Keowee Generators or the SSF Diesel Generator and their associate components in the area of CO 2 System discharge.}

Calculation No,: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, &3 Page 78 of 85 Reference(s): Design Basis Specification for Fire Protection Section 3.11 Passive Fire Protection Features This section shall be used to determine the design and installationrequirements for passive protectionfeatures. Passive fire protection features include wall, ceiling, and floor assemblies, fire doors, fire dampers, and through fire barrierpenetration seals. Passive fire protection features also include electrical raceway fire barriersystems (ERFBS) that are provided to protect cables and electricalcomponents and equipment from the effects of fire. Passive fire protection features at Oconee include fire rated assemblies for building separation including fire wall, fire doors, fire dampers and penetration seals. Oconee does not utilize electrical raceway fire barrier systems (ERFBS) for passive fire protection.

       -3A-I-A-Building- Separation--__

Each majorbuilding within the power block shall be separatedfrom the others by barriers having a designatedfire resistanceratingof 3 hours orby open space of at least 50 ft (15.2 m) or space thatmeets the requirementsof NFPA 80A, Recommended Practicefor Protectionof Buildings from Exterior FireExposures. Exception: Where a performance-based analysis determines the adequacy of building separation,the requirementsof 3.11.1 shall not apply. There are four main buildings in the power block; the Turbine Building, the Auxiliary Building, the Control Complex, and the Reactor Building. These buildings are separated by evaluated and qualified three-hour rated fire barriers. The NRC August 11, 1978 SER Section 4.11 states "Firebarriers have been provided to separatethe turbine building from the auxiliarybuilding, and to cut off the equipment rooms, cable spreadingrooms, control rooms, penetrationareasandblockhouses from surrounding fire areas. Based on the type andquantity of combustiblespresent,the basicfire resistance of the barrierswould prevent the spreadof fire between fire areas."

        "Upon completion of the dedicatedsafe shutdown system, the facility will be able to sustain a fire in any fire area and still achieve safe shutdown of the three units. We conclude that, upon completion of the dedicatedsafe shutdown system, the fire barriersmeet the objectives outlinedin Section 2.2 of this reportand are,therefore, acceptable." The dedicated shutdown system (SSF) has been completed.

The SSF is of substantial concrete (non-combustible) construction and is physically separated from the Reactor and Auxiliary Buildings by a distance of greater than 50 feet. The electrical and mechanical connections from the SSF to the Auxiliary Building are all located underground.

Calculation No.: OSC-9295 Revision No.: .I Applicable Units: Oconee Unit 1, 2, & 3 Page 79 of 85 The Keowee Powerhouse is a noncombustible structure that is physically located a significant distance from the other Oconee power block structures with no direct connections other than electrical wiring. {Further Action Required - Upgrade fire barriers in accordance with the open items in PIP 0-08-2006 and PIP 0-08-2520.}

References:

NRC SER dated August 11, 1978 Drawing Series 0-310 K and L NRC Exemption to various Appendix R Requirements dated August 21,1989 NRC Letter dated April 14, 1981 Design Basis Specification for Fire Protection

          --- ------- -. NRC RC-SER-dated-Apri
                     ----------                                                               .28v-1983-----------

SLC 16.9.5 OSC-9302 PIP 0-08-2006 PIP 0-08-2520 3.11.2 Fire Barriers Fire barriersrequiredby Chapter4 shall include a specific fire-resistancerating.Fire barriers shall be designed and installed to meet the specific fire resistancerating using assemblies qualified by fire tests. The qualification fire tests shall be in accordance with, NFPA 251, StandardMethods of Tests ofFireEnduranceof BuildingConstructionand Materials,orASTM

       .E 119, Standard Test Methods for Fire Tests of Building Constructionand Materials.

Fire barriers required to meet the deterministic or performance based requirements of Chapter 4 are defined in NEI 04-02 Table B-3, Fire Area Transition report. In addition, systems required by licensing actions and engineering evaluations are included in Table B-3. Fire barriers are provided to separate the Turbine Building and Auxiliary Building and to cut off the Equipment. Rooms, Cable Spreading Rooms, Control Rooms, Penetration Rooms and Blockhouses from the surrounding areas. Construction of these fire barriers are equivalent to a three-hour barrier. Committed and non-committed fire barriers for the Turbine Building, Auxiliary Building and Reactor Building (including mechanical and electrical penetrations, fire doors, fire dampers, walls, ceiling and floors) boundaries are shown on the 0-310-K and 0-31 0-L series drawings. NRC committed fire barriers are discussed in SLC 16.9.5.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 80 of 85 The use of unrated seismic joints between the East Penetration Rooms and the West Penetration Rooms were evaluated by the NRC and found to be acceptable in the August 21, 1989 evaluation that granted an Exemption from the Fire Protection Requirements of Section III.G of 10 CFR Part 50, Appendix R. The NRC also evaluated the separation between the East and West penetration rooms and determined that the electrical divisions were "effectivelyseparatedby a three-hourfire barrier." This determination was documented in the NRC Letter dated April 14, 1981. The wall qualification is further supported by OSC-7185. The NRC August 11, 1978 SER Section 4.11 states "Firebarriershave been provided to separatethe turbine buildingfrom the auxiliarybuilding, and to cut off the equipment rooms, cable spreadingrooms, controlrooms, penetrationareas and blockhouses from surrounding fire areas. Based on the type andquantityof combustibles present,the basic fire resistance of the barrierswould prevent the spreadof fire between fire areas-"'.............

        "Upon completion of the dedicated safe shutdown system, the facility will be able to sustain a fire in any fire area and still achieve safe shutdown of the three units. We conclude that, upon completion of the dedicatedsafe shutdown system, the fire barriersmeet the objectives outlinedin Section 2.2 of this report and are, therefore, acceptable." The dedicated shutdown system (SSF) has been completed.

{Further Action Required - Upgrade fire barriers in accordance with the open items in PIP 0-08-2006 and PIP 0-08-2520.} Reference(s): NRC SER dated August 11, 1978 Drawing Series 0-310 K and L NRC Exemption to various Appendix R Requirements dated August 21, 1989 NRC Letter dated April 14, 1981 Design Basis Specification for Fire Protection SLC 16.9.5 OSC-7185 OSC-9292 PIP 0-08-2006 PIP 0-08-2520 3.11.3 Fire BarrierPenetrations Penetrationsin fire barriersshall be provided with listed fire-rateddoor assemblies orlisted ratedfire dampershaving a fire resistancerating consistent with the designatedfire resistance rating of the barrieras determined by the performancerequirementsestablishedby Chapter4.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3. Page 81 of 85 (See 3.11.4 for penetration seals for through penetration fire stops.) Passive fire protection devices such as doors and dampers shall conform with the following NFPA standards,as applicable: (1) NFPA 80, Standard for Fire Doors and Fire Windows (2) NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems (3) NFPA 101, Life Safety Code Exception: Where fire area boundariesare not wall-to-wall, floor-to-ceilingboundarieswith all penetrations sealed to the fire rating required of the boundaries, a performance-based analysisshall be requiredto assess the adequacy of fire barrierforming the fire boundary to determine if the barrierwill withstand the fire effects of the hazardsin the area. Openingsin fire barriersshall be permitted to be protectedby other means as acceptable to the AHJ. Fire barrier penetrations required to meet the deterministic or performance based requirements of Chapter 4 are defined in NEI 04-02 Table B-3, Fire Area Transition report. In addition, systems required by licensing actions and engineering evaluations are included in Table B-3. Committed and non-committed fire barriers for the Turbine Building, Auxiliary Building and Reactor Building (including mechanical and electrical penetrations, fire doors, fire dampers, walls, ceiling and floors) boundaries are shown on the 0-310-K and 0-310-L series drawings. NRC committed fire barriers are discussed in SLC 16.9.5. The NRC August 11, 1978 SER Section 4.9.2 states "The licensee has proposedto make the following modification on doors and hatches in fire barriers: (1) Replace unlabeled fire doors and frames in fire barrierswith properly labeled fire doors and frames. (2) Modify double-leaffire doors to normally keep one door closed to assureproper closure. (3) Modify the door arrangement of openings between the turbine building and auxiliary building to prevent glass doors from obstructing automatic fire door closure. (4) Upgradethe metal hatchplates in the floor between the cable spreadingroom and control room to provide a 3-hour fire rated barrier. The license has statedthat doors separateredundantsafe shutdown equipment orprotecting safe shutdown equipment from large hazards are alarmed to the control room and provided with automaticclosure devices."

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page 82 of 85

          'Upon completion of these modifications, the doorway andhatch penetrationsof fire barriers will conform to the provisions of Appendix A to BTP 9.5-1 and are, therefore, acceptable."

The fire door modifications referenced above have been implemented. Duke letter to the NRC dated May 15, 1981 responded to some modifications indicating completion or insurance company approval of existing fire door configurations. The NRC August 11, 1978 SER Section 4.9.3 states "Firedampers have been provide at some locations where ventilation ducts penetratefire barriers. The licensee has proposedto upgrade ventilation duct penetrations with dampers having fire ratings equivalent to that requiredby fire barriers."

          "We find that, subject to implementation of the above modifications, ventilation duct
        -penetrations will satisfythe_bjectives identified in Section 2.2 of this reportand are,therefore, acceptable." Current fire barrier ventilation duct penetrations are provided with fire dampers.

{Further Action Required - Upgrade fire barriers in accordance with the open items in PIP 0-08-2006 and PIP 0-08-2520.} Reference(s): NRC SER dated August 11, 1978 Duke Letter to the NRC, dated May 15, 1981 Drawing Series 0-310 K and L Design Basis Specification for Fire Protection SLC 16.9.5 OSC-9292 PIP 0-08-2006 PIP 0-08-2520 3.11.4 Through PenetrationFireStops Through penetrationfire stops for penetrationssuch as pipes, conduits, bus ducts, cables, wires, pneumatic tubes and ducts, and similarbuilding service equipmentthat pass through fire barriersshall be protected as follows. (a) The annularspace between the penetratingitem and the through opening in the fire barriershall be filled with a qualified fire-resistive penetration seal assembly capable of maintainingthe fire resistance of the fire barrier.The assembly shall be qualifiedby tests in accordancewith a fire test protocolacceptableto the AHJ or be protectedby a listed fire-rated device for the specified fire-resistive period. (b) Conduits shall be provided with an internalfire seal that has an equivalent fire-resistive ratingto that of the fire barrierthrough opening fire stop andshall be permitted to be installed on either side of the barrierin a location that is as close to the barrieras possible.

Calculation No.: .OSC-9295 Revision No.: I1_ Applicable Units: Oconee Unit 1, 2, & 3 Page 83 of 85 Exception: Openings inside conduit 4 in. (10.2 cm) or less in diametershall be sealed at the fire barrierwith a fire-ratedinternalseal unless the conduit extends greaterthan 5 ft (1.5 m) on each side of the fire barrier. In this case the conduit opening shall be provided with noncombustiblematerialto prevent the passage of smoke and hot gases. The fill depth of the materialpacked to a depth of 2 in. (5.1 cm) shall constitute an acceptable smoke and hot gas seal in this application. Fire barrier penetration seams required to meet the deterministic or performance based requirements of Chapter 4 are defined in NEI 04-02 Table B-3, Fire Area Transition report. In addition, systems -required by licensing actions and engineering evaluations are included in Table B-3. Through penetration fire stops for penetrations such as pipes, conduits, cables, pneumatic tubes, etc in rated fire barriers are generally provided with rated penetration seals. The site FPE maintains the Penetration Seal Database in the site EDB and 86-10 Evaluation calculation documenting the acceptability of the station penetration seals in Calculation OSC-7350. OSC-7359 (DPC 1435.00-00-0006) identifies that Oconee is committed to the criteria of IEEE P634 for electrical and mechanical fire barrier penetration seals. UFSAR Section 9.5.1.4.3 Item 4 states "Electricalpenetrationseal designs shallbe subjected to a standardexposure fire that follows the AS TM E-1 19 StandardTime-Temperature Curve. The acceptance criteriafrom IEEE 634 (which is identical to that of IEEE P6341D4)shall be used to evaluate the acceptabilityof test assemblies.The IEEE 634 acceptancelimit for ONS unexposed side electrical penetration temperature shall be 700°F. This temperature was selected because the IEEE 634 acceptance criteria is the auto-ignition temperature of the outer cable covering and material in contact with the cable penetration fire stop, or 700 0F, whichever is lower. The ignition temperatureof outer cablejacketing has been determined to be 7350F. Mechanicalpenetration seal designs shall be subjected to a standardexposure fire that follows the ASTM E-1 19 Standard Time-Temperature Curve. The acceptancecriteria from IEEE-634 (which is, identical to that of IEEE P634/D4) shall be used to evaluate the acceptabilityof test assemblies. The IEEE 634 acceptancelimit for Duke Powermechanical penetration seals shall be 6800F. This temperature was selected because it represents the lowest auto ignition temperature of any materialnormally found in close proximity to piping penetrations (ArmstrongArmalok pipe insulation)." The use of unrated fire penetrations in the ceiling of the West Penetration Room and unrated mechanical pipe penetrations between the Reactor Building and Penetration Rooms were evaluated by the NRC and found to be acceptable in the August 21, 1,989 evaluation that granted an Exemption from the Fire Protection Requirements of Section IIl.G of 10 CFR Part 50, Appendix R.

Calculation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1. 2, & 3 Page 84 of 85 The NRC also evaluated the separation between the East and West penetration rooms and determined that the electrical divisions were "effectively separatedby a three-hourfire barrier." This determination was documented in the NRC Letter dated April 14, 1981. {Further Action Required - Upgrade fire barriers in accordance with the open items in PIP 0-08-2006 and PIP 0-08-2520.} Reference(s): Drawing Series 0-310 K and L NRC Exemption to various Appendix R Requirements dated August 21, 1989 NRC Letter dated April 14, 1981 Design Basis Specification for Fire Protection SLC 16.9.5 .. .........-.------.

                ...      .. alculation -OSC-7-350,--OtS--Penetration---Seal--Database-and--86-10 Evaluations UFSAR Section 9.5.1.4.3 OSC-7359 (DPC 1435.00-00-0006), Calculation for the Technical Basis for Fire Barrier Penetration Seals OSC-9292 PIP 0-08-2006 PIP 0-08-2520 3.11.5 ElectricalRaceway Fire BarrierSystems (ERFBS)

ERFBS requiredby Chapter4 shall be capableofresistingthe fire effects of the hazardsin the area. ERFBS shall be tested in accordancewith and shall meet the acceptance criteriaof NRC GenericLetter 86-10, Supplement 1, "FireEndurance Test Acceptance Criteriafor Fire BarrierSystems Used to Separate Safe Shutdown Trains Within the Same Fire Area." The ERFBS needs to adequatelyaddressthe designrequirementsandlimitations of supportsand interveningitems and their impact on the fire barriersystem rating. The fire barriersystem's ability to maintainthe requirednuclearsafety circuitsfree of fire damage for a specific thermal exposure, barrier design, raceway size and type, cable size, fill, and type shall be demonstrated. Exception No. 1: When the temperaturesinside the fire barriersystem exceed the maximum temperature allowed by the acceptance criteria of Generic Letter 86-10, "Fire Endurance Acceptance Test Criteria for Fire Barrier Systems Used to Separate Redundant Safe Shutdown Training Within the Same Fire Area," Supplement 1, functionality of the cable at these elevated temperatures shall be demonstrated. Qualification demonstration of these cables shall be performed in accordance with the electrical testing requirementsof Generic Letter 86-10, Supplement 1, Attachment 1, 'Attachment Methods for Demonstrating Functionalityof Cables Protected by Raceway Fire Barrier Systems During and After Fire Endurance Test Exposure." Exception No. 2: ERFBS systems employed priorto the issuance of Generic Letter 86-10, Supplement 1, are acceptableproviding that the system successfullymet the limiting endpoint

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 85 of 85 temperaturerequirements as specified by the AHJ at the time of acceptance. The Oconee design does not currently utilize ERFBS. No ERFBS are required by the Fire PRA or credited by the change evaluations as required for defense-in-depth. Reference(s): Design Basis Specification for Fire Protection VII. CONCLUSIONS The Oconee fire protection program complies with the requirements of NFPA 805, Chapter 3 upon resolution of open items and N-Rt-ao5*56Ws--iitl-on-sspeifi-e--d-e-6-iýn-_........ ... VIII. ATTACHMENTS Attachment A - Compliance Table

Calculation No.: OSC-9295 Revision No.: Applicable Units: Oconee Unit 1, 2'& 3 Attachment A Attachment A Compliance Table 35 Total Pages

Cai...-aation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1. 2. & 3 Page Al of A35 NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis Note: All information below is summarized; for complete details, see the report in Attachment A Links are provided below. Turn on Web Toolbar. Section 3.1 General This chapter contains the fundamental elements of the fire protection program and specifies the minimum design requirements for fire protection systems and features. These fire protection program elements and minimum design requirements shall not be subject to the performance-basedmethods permitted elsewhere in this standard.Previously approvel alternativesfrom the fundamental protection programattributes of this chapterby the AHJ take precedence over the requirements dontained herein. Section 3.2 Fire Protection Plan 3.2.1 Intent Comply A site-wide Fire Protection A site-wide fire protection plan shall be established. This plan shall Program has been document managementpolicy and program direction and shall define established and is the responsibilitiesof those individuals responsible for the plan's documented in the Design implementation. This section establishesthe criteriafor an integrated Basis Specification for Fire combination of components, procedures,and personnelto implement Protection. all fire protectionprogram activities. 3.2.2 Management Policy Direction and Responsibility Comply A policy document has

                                                                                                       ~been               developed and is A policy document shall be preparedthat defines management                                               b authority and responsibilitiesand establishes the generalpolicy for the                                  documented in the Design site fire protectionprogram.                                                                             Basis Specification for Fire Protection.

3.2.2.1 Comply The Site Vice President is The policy document shall designate the seniormanagement position documented as responsible with immediate authority and responsibilityfor the fire protection for the implementation of program. the fire protection program. program

Caiwation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page A2 of A35 NFPA 805 Chapter 3 Section Compliancb Statement Compliance Basis 3.2.2.2 Comply i The Fire Protection I Engineer is responsible for The policy document shall designate a position responsiblefor the daily enginistresponsible for administrationand coordinationof the fire protection programand its the administration of the fire implementation, protection program, 3.2.2.3 Comply The interfaces between the J fire protection program and The policy document shall define the fire protection interfaces with f other organizationsand assign responsibilitiesfor the coordinationof other organizations and fire activities. In addition, this policy document shall identify the various protection programs are plantpositions having the authorityfor implementing the various areas documented in the Design of the fire protectionprogram. Specification for Fire Protection. 3.2.2.4 Further Acti on Required Oconee will enhance The policy document shall identify the appropriateAHJ for the various current documentation, prior areas of the fire protection program. to implementation of the NFPA 805 program, to include the NRC as the authority having jurisdiction (AHJ) for fire protection changes requiring approval. 3.2.3 Procedures Comply i Procedures have been t established for Procedures protection shall be Inestablished program. addition tofor implementation procedures of the that could befire requiredby eaished implementing theforfire other sections of the standard, the procedures to accomplish the p following shall be established: i 1. The Engineering (1) Inspection, testing, and maintenance for fire protection Support Document for systems and features credited by the fire protection program Fire Protection provides

Cah.uiation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2. & 3 Page A3 of A35

• i NFPA 805 Chapter 3 Section Compliancp Statement Compliance Basis (2) Compensatoryactions implemented when fire protection a detailed listing of systems and other systems credited by the fire protection applicable surveillance program and this standardcannot perform theirintended procedures.

function and limits on impairment duration 2. Compensatory actions (3) Reviews of fire protectionprogram - relatedperformance I have been established. and trends a r3. Fire protection program (4) Reviews of physical plant modifications and procedure reviews are performed. changes for impact on the fire protectionprogram (5) Long-term maintenance and configuration of the fire protection program ireviews

4. Plant modification for impact on the fire protection (6) Emergency responseprocedures for the plant industrialfire program are performed.

brigade g 5. Long term maintenance and configuration procedures for the fire protection program have been established.

6. Emergency response procedures for the plant fire brigade are documented.

Section 3.3 Prevention A fire prevention program with the goal of preventing a fire from startingshall be established, documented, and implemented as partof the fire protection program. The two basic components of the fire preventionprogram shall I consist of both of the following: (1) Prevention of fires and fire spreadby controls on operational'activities (2) Design controls that restrictthe use of combustible materials The design control requirementsfisted in the remainderof this section shall be provided as described.

Calculation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1. 2, & 3 Page A4 of A35 NFPA-805 Chapter 3 Section Compliance Statement Compliance Basis 3.3. 1 Fire Prevention for OperationalActivities Comply Fire prevention program, i activities for control of The fire prevention program activities shall consist of the necessary a elements to address the control of ignition sources and the use of ignition sources and transientcombustible materials during all aspects of plant operations. transient combustibles The fire prevention program shall focus on the human and include training, inspections programmaticelements necessaryto prevent fires from startingor, and administrative controls. should a fire start, to keep the fire as small as possible. 3.3.1.1 GeneralFire Prevention Activities Comply I The prevention of fires and The fire prevention activities shall include but not be limited to the fire spread are managed following program elements: i through training of (1) Training on fire safety information for all employees and personnel, documented contractorsincluding, as a minimum, familiarizationwith plant plant inspections, and fire prevention procedures,fire reporting, and plant emergency. administrative controls. alarms. (2) Documented plant inspections includingprovisions for corrective actions for conditions where unanalyzed fire hazards are identified. (3) Administrative controls addressingthe review of plant modifications and maintenanceto ensure that both fire hazards and the impact on plant fire protection systems and features - are minimized: 3.3.1.2 Controlof Combustible Materials Comply . Sections 3.3.1.2(2) through Proceduresfor the control of general housekeeping practices and the 3.3.1.2(6) - Specific control of transient combustibles shall be developed and implemented. administrative directives have been developed for These proceduresshall include but not be limited to the following control of combustible program elements: materials. (1) Wood used within the power block shall be listed

Calk.,.ition No.: OSC-9295 Revision No.: 1*.. Applicable Units: Oconee Unit 1, 2. & 3 Page A5 of A35 NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis pressure-Impregnatedor coated with a listed fire-retardant Submit for NRC Approval NFPA 805 Section application. '3.3.1.2(1); NSD-313 permits Exception: Cribbing timbers 6 in. by6 in. (15.2 cm by 15.2 cm) non treated wood for or largershall not be required to be fire-retardanttreated, i concrete forming and where (2) Plastic sheeting materials used in the power block shall be specified in design fire-retardanttypes that have passed NFPA 701, Standard drawings. Methods of Fire Tests for Flame Propagationof Textiles and Films, large-scale tests, or equivalent. (3) Waste, debris, scrap, packing materials,or other A For compliance with Section combustibles shall be removed from an area immediately o Ip 3.31.2 Ocoeei following the completion of work or at the end of the shift, e whichever comes first. documentation, prior to implementation of the NFPA (4) Combustible storageor staging areas shall be designated, 805 program, to specifically and limits stored shall be establishedon the types and quantitiesof materials. address plastic sheeting iI material conformance to (5) Controls on use and storage of flammable and NFPA 701 requirements or combustible liquids shall be in accordance with NFPA 30, equivalent. Flammable and Combustible Liquids Code, or other applicable NFPA standards. (6) Controls on use and storage of flammable gases shall be in accordancewith applicableNFPA standards. 3.3.1.3 Control of Ignition Sources _ 3.3.1.3.1 Comply Hot work is controlled

• through administrative A hot work safety procedure shall be developed, implemented, and throughvadministratie periodicallyupdated as necessaryin accordancewith NFPA 51B, Standardfor Fire Prevention During Welding, Cutting, and Other Hot with NFPA51B.

Work, and NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations. Area for Improvement Evaluate NSD-314 to Area for ~~~~~~Imrvmn EvlaeND34t

Cal,,ation No.: OSC-9295 *Revision No.: 1 Applicable Units: Oconee Unit 1.2. & 3 Page A6 of A35 NFPA 805 Chapter 3 Section Complianc6 Statement Compliance Basis determine if NFPA 241 should be referenced. 3.3.1.3.2 Comply Smoking, is restricted to Smoking and other possible sources of ignition shall be restricted to approved locations and properly designated and supervisedsafe areas of the plant. other sources of ignition are I controlled. 3.3.1.3.3 Further Actipn Required Open flame or combustion-Open flames or combustion-generatedsmoke shall not be permitted for I generated smoke is leak or airflow testing. prohibited for use in leak and air flow testing. Oconee will enhance current documentation, prior to implementation of the NFPA 805 program, to revise procedures to preclude the use of open flame or combustion generated smoke for leak or air flow testing. 3.3.1.3.4 Submit for NRC ~is Approval The use of portable controlled by heaters Plant administrative procedureshall control the use of portable isiotrolle by electrical heatersin the plant. Portable fuel-fired heaters shall not be permitted in plant areascontaining equipment importantto nuclear. Gas and oil-fired heaters safety or where there is a potentialfor radiologicalreleases resulting i are permitted per station from a fire. procedures.

Cai.,alation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1. 2, & 3 Page A7 of A35

• I NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis 3.3.2 Structural Comply Power block buildings are Walls, floors, and components required to maintain structuralintegrity constructed of non-shall be of noncombustible construction, as defined in NFPA 220, combustible materials.

Standardon Types of Building Construction. 3.3.3 InteriorFinishes Further Acti n Required Interior finishes are non-Interiorwall or ceiling finish classificationshall be in accordance with I combustible. NFPA 101,Life Safety Code,requirements for ClassA materials. Interiorfloor finishes shall be in accordancewith NFPA 101 requirementsfor Class I interiorfloor finishes. Oconee will enhance current documentation, prior to implementation of the NFPA 805 program, to include the specifications for Class A walls/ceilings and Class I floor finishes. 3.3.4 Insulation Materials Comply Thermal insulation materials Thermal insulation materials,radiation shielding materials,ventilation are non-combustible or duct materials, and soundproofingmaterialsshall be noncombustible or limited combustible. limited combustible. I 3.3.5 Electrical 3.3.5.1 Further Action Required Combustibles in concealed Wiring above suspended ceiling shall be kept to a minimum. Where spaces are minimized. installed, electricalwiring shall be listed for plenum use, routed in armoredcable, routed in metallic conduit, or routed in cable trays with O solid metal top and bottom covers. Oconee will enhance _ _current documentation, prior

Cak.iation No.: OSC-9295 Revision No.: I1 Applicable Units: Oconee Unit 1. 2, & 3 Page A8 of A35 NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis to implementation of the NFPA 805 program, to i include clear guidance that electrical wiring (including data/phone/video cabling) if installed above suspended ceilings will comply with the requirements of this section. 3.3.5.2 Further Action Required Cable trays are constructed Only metal tray and metal conduits shall be used for electrical ofnon-combustible raceways. Thin wall metallic tubing shall not be used for power, materials. instrumentation,or control cables. Flexible metallic conduits shall only be used in short lengths to connect components. Oconee will enhance current documentation, prior to implementation of the NFPA 805 program, to include clear guidance that conduits used for electrical raceways are metal and thin walled metallic tubing is not used in accordance with the requirements of this section. 3.3.5.3 Complies by Previous The installed wiring has Electric cable constructionshall comply with a flame propagationtest NRC Approval been found acceptable. as acceptable to the AHJ. Further Action Required Oconee will enhance I _current documentation, prior .. I

Caicalation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1. 2. & 3 Page A9, of A35 NFPA 805 Chapter 3 Section Compliance' Statement Compliance Basis to implementation of the NFPA 805 program, to document that non-rated cables (including data/phone/video) shall not be routed in cable trays with nuclear safety related cables. 3.3.6 Roofs Comply Roofs comply with Class A Metal roof deck construction shall be designed and installed so the requirements. A roof roofing system will not sustain a self-propagatingfire on the underside management program has of the deck when the deck is heated by a fire inside the building. Roof been implemented requiring coverings shall be Class A as determined by tests describedin NFPA Class A equivalent roof 256,-StandardMethods of Fire Tests of Roof Coverings. I installations. 3.3.7 Bulk Flammable Gas Storage Submit for ýJRC Approval Submit for NRC Approval -. i Storage of flammable gas Bulk compressed or cryogenic flammable gas storage shall not be - Storage of flamable gas permitted inside structureshousing systems, equipment, or c components importantto nuclear safety. in plant operations and systems per design. 3.3.7.1 Comply Bulk flammable gas is not Storage of flammable gas shall be locatedoutdoors, or in separate. stored in areas important to Storagenuclear safety unless used detached buildings, so that a fire or explosion will not adversely impact systems, equipment, or components important to nuclearsafety. NFPA in plant operations or 50A, Standardfor Gaseous Hydrogen Systems at Consumer Sites, I systems by design. shall be followed for hydrogen storage. _ _Oconee will enhance

Catculation No.: OSC-9295 Revision No.: _ 1,_ :I Applicable Units: Oconee Unit 1, 2, & 3 Page A10 of A35 NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis Further Action Required current documentation, prior to implementation of the NFPA 805 program, to perform a NFPA 50A a code compliance review for the outdoor hydrogen storage. 3.3.7.2 Comply Hydrogen gas tanks are Outdoor high-pressureflammable gas storage containers shall be orientated with the long axis locatedso that the long axis is not pointed at buildings, parallel to plant buildings. Resolve orientation of Further Action Required propane tank. The tank is not anchored per the SER recommendation. Evaluate ifthe previous approval by the NRC is sufficient with the modification. Alternatively, determine if an evaluation is required or modify the tank position. 3.3.7.3 Comply Gas cylinders are isolated Flammable gas storage cylinders not requiredfor normal operation when not in use and shall be isolatedfrom the system. controlled by plant I directives.

Caiýalation No.: OSC-9295 Revision No.: Applicable Units: Oconee Unit 1, 2, & 3 Page All of A35 NFPA 805 Chapter 3 Section ComplIance Statement Compliance Basis 3.3.8 Bulk Storage of Flammable and Combustible Liquids Further Actilpn Required The storage of combustible Bulk storage of flammable and combustible liquids shallnot be I and flammable materials is permitted inside structures containing systems, equipment, or I controlled by plant components important to nuclear safety. As a minimum, storage and i directives. use shall comply with NFPA 30, Flammable and Combustible Liquids Code. Oconee will enhance current documentation, prior to implementation of the NFPA 805 program, to perform a NFPA 30 code compliance review for the Turbine Building lube oil reservoirs, Turbine Building lube oil storage room, and the Keowee lube oil storage room. 3.3.9 Transformers Further Action Required Oconee will enhance Where provided, transformeroil collection basins and drain paths shall current documentation, prior be periodicallyinspected to ensure that they are free of debris and to implementation of the capable of performing their design function. NFPA 805 program, to include drainage inspections as part of the annual flow tests. 3.3.10 Hot Pipesand Surfaces Comply Administrative directives Combustible liquids, including high flashpoint lubricatingoils, shall be ensure upon identification kept from coming in contact with.hot pipes and surfaces, including prompt correction of any oil insulated pipes and surfaces.Administrative controls shall require the _ leakage.

Caa;alation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1. 2, & 3 Page A12 of A35 NFPA 805 Chapter 3 Section Compliancle Statement Compliance Basis prompt cleanup of oil on insulation. Area for Improvement Oconee will enhance icurrent documentation, prior to implementation of the NFPA 805 program, to clearly indicate it is a NRC requirement to promptly remove oil from insulation. 3.3.11 ElectricalEquipment Comply Administrative directives Adequate clearance,free of combustible material,shall be maintained control combustible material aroundenergizedelectrical equipment. near electrical equipment. Further Action Required Oconee will enhance current documentation, prior to implementation of the NFPA 805 program, to specify the combustible free distance consistent with the PRA Zone of Influence for transients. 3.3.12 Reactor Coolant Pumps Comply The RCP oil collection i system meets the five For facilities with non-inertedcontainments, reactorcoolantpumps with , scriteria presented in this an external lubricationsystem shall be provided with an oil collection ctian t system. The oil collection system shall be designed and installed such section. that leakage from the oil system is safely contained for off normal conditions such as accident conditions or earthquakes.All of the. following shall apply. _

Cai*.ulation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2. & 3 Page A13 of A35 NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis (1) The oil collection system for each reactorcoolantpump shall be capable of collecting lubricatingoil from alf potential pressurized and nonpressurizedleakage sites in each reactor coolant pump oil system, (2) Leakage shall be collected and drainedto a vented closed containerthat can hold the inventory of the reactorcoolant pump lubricating oil system. (3) A flame arrestoris requiredin the vent if the flash point characteristicsof the oil present the hazardof a fire flashback. (4) Leakage points on a reactor coolantpump motor to be protected shall include but not be limited to the lift pump and piping, overflow lines, oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and the oil reservoirs, where such features exist on the reactorcoolantpumps. (5) The collection basin drain line to the collection tank shall be large enough to accommodate the largestpotential oil leak such that oil leakage does not overflow the basin.. Section 3.4 Industrial Fire Brigade, 3.4.1 On-Site Fire-FightingCapability Comply The onsite Fire Brigade is All of the following requirementsshall apply. appropriately staffed,

                                                ~trained                                                              and equipped.

(a) A fully staffed, trained,and equipped fire-fighting force shall be t available at all times to control and extinguish all fires on site. This force shall have a minimum complement of five persons on duty and Ensure NFPA 600 code shall conform with the following NFPA standardsas applicable: Area for Imirovement review is formally (1) NFPA 600, Standardon IndustrialFire Brigades (interior documented. structuralfire fighting) (2) NFPA 1500, Standardon Fire Department Occupational Safety and Health Program _

Catwulation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1.2. & 3 Page A14 of A35 NFPA 805 Chapter 3 Section ComplianCde Statement Compliance Basis (3) NFPA 1582, Standardon Medical Requirements for Fire Fightersand Information for Fire DepartmentPhysicians (b) Industrialfire brigade members shall have no other assigned normal plant duties that would prevent immediate response to a fire or other emergency as required.. (c) Duringevery shift, the brigade leader and at least two brigade members shall have sufficient training and knowledge of nuclearsafety systems to understandthe effects of fire and fire suppressantson nuclear safety performance Exception: Sufficient trainingand knowledge shall be permitted to be providedby an operationsadvisordedicated to industrialfire brigade support criteria. (d) The industrialfire brigade shall be notified immediately upon verification of a fire. (e) Each industrialfire brigade member shall pass an annualphysical examination to determine that he or she can perform the strenuous activity requiredduring manual fire-fighting operations. The physical examination shall determine the ability of each member to use respiratoryprotection equipment. 3.4.2 Pre-FirePlans Comply Current and detailed pre-fire Current and detailed pre-fire plansshall be availableto the industrial I plans are available in the fire brigadefor all areas in which a fire couldjeopardize the ability to Oconee Plant Fire Plan. meet the performance criteria describedin Section 1.5. 3.4.2.1 Comply Detailed pre-fire plans are available in the Oconee The plans shall detail the fire area configurationand fire hazards to be N encountered in the fire area,along with any nuclearsafety components Nuclear Site Fire Plan. and fire protection systems and features that are present.

Cai*,alation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1. 2. & 3 Page A15 of A35 NFPA 805 Chapter 3 Section ComplianCe Statement Compliance Basis Area for Improvement Review the Fire Plan and associated documentation for compliance with NFPA 805 requirements. 3.4.2.2 Comply i The Fire Plan is maintained Pre-fireplans shall be reviewed and updated as necessary. current. Plant directives require review of the Fire Plan. 3.4.2.3 Comply The Fire Plan is available in Pre-fire plans shall be available in the control room and made available the Control Room and to to the plant industrialfire brigade, the Fire Brigade at multiple locations. 3.4.2.4 Comply Plant directives and fire Pre-fireplans shall.addresscoordinationwith other plant groups during brigade procedures address fire emergencies. freeeiscoordination grus with other plant groups: 3.4.3 Training and Drills, Comply The Fire Brigade personnel Industrialfire brigade members and otherplant personnel who wouldreceive appropriate training respond to a fire in conjunction with the brigade shall be provided with and the training records are trainingcommensurate with their emergency responsibilities. maintained. (a) Plant IndustrialFire Brigade Training.All of the following requirements shall apply. All plant personnel are (1) Plantindustrialfire brigade members shall receive training . trained on reporting fires consistentwith the requirementscontained In NFPA .600, _ and interfacing with the Fire

Ca.-,alation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1. 2. & 3 Page A16 of A35 NFPA 805 Chapter 3 Section Compliance Statement {Compliance Basis Standardon IndustrialFire Brigades, or NFPA 1500, Standard Brigade. on Fire Department OccupationalSafety and Health Program, as appropriate. (2) Industrialfire brigade members shall be given quarterly Drills are conducted on a trainingand practice in fire fighting, including radioactivityand regular basis and involve health physics considerations,to ensure that each member is various plant areas. The thoroughly familiarwith the steps to be taken in the event of a drills are critiqued and fire. records are maintained. (3) A written programshall detail the industrialfire brigade trainingprogram. (4) Written records that Include but are not limited to initial industrialfire brigade classroom and hands-on training, refresher training,special trainingschools attended, drill attendancerecords, and leadershiptrainingfor industrialfire brigadesshall be maintained for each industrialfire brigade member. (b) Trainingfor Non-Industrial Fire Brigade Personnel.Plantpersonnel who respondwith the industrialfire brigadeshall be trainedas to their responsibilities,potentialhazards to be encountered,and interfacing with the industrialfire brigade. (c) Drills. All of the following requirements shall apply. (1) Drills shall be conducted quarterlyfor each shift to test the response capability of the industrialfire brigade. (2) Industrialfire brigade drills shall be developed to test and challenge industrialfire brigade response, including brigade performance as a team, properuse of equipment, effective use of pre-fire plans, and coordinationwith othergroups. These drills shall evaluate the industrialfire brigade's abilitiesto react, respond, and demonstrateproper fire-fighting techniques to control and extinguish the fire and smoke conditions being simulated by the drill scenario.

Cawalation No.: OSC-9295 Revision No.: I Applicable Units: Oconce Unit 1, 2, & 3 Page A17 of A35 i NFPA 805 Chapter 3 Section Compllance Statement Compliance Basis (3) Industrialfire brigade drills shall be conducted in various plant areas, especially in those areasidentifiedto be essential to plant operation and to contain significant fire hazards. (4) Drill records shall be maintaineddetailing the drill scenario, industrialfire brigademember response, and abilityof the industrialfire brigade to perform as a team. (5) A critique shall be held and documented after each drill. 3.4.4 Fire-FightingEquipment Comply Fire brigade personnel are Protective clothing, respiratoryprotective equipment, radiation provided with the necessary monitoringequipment, personal dosimeters, and fire suppression equipment. equipment such as hoses, nozzles, fire extinguishers,and other needed equipment shall be provided for the industrialfire brigade. This equipment shall conform with the applicableNFPA standards. 3.4.5 Off-Site Fire Department Interface 3.4.5.1 Mutual Aid Agreement Comply Letters of Agreement are in Off-site fire authoritiesshall be offered a plan for their interface during maintained with local off-fires and related emergencies on site. site fire fighting organizations. 3.4.5.2 Site-Specific Training Comply Annual trainingofisAgreement. specified

                                                                                                  !       in the Letters Fire fighters from the off-site fire authorities who are expected to                             i respond to a fire at the plant shall be offered site-specific trainingand shall be invited to participatein a drill at least annually.

3.4.5.3 Security and Radiation Protection Comply Site directives include Security and Radiation

Cawalation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1. 2. & 3 Page AI18 of A35 NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis Plantsecurity and radiationprotectionplans shall address off-site fire I Protection provisions for authorityresponse. assistance to off-site fire authorities. 3.4.6 Communications Comply Emergency communication An effective emergency communications capabilityshall be provided for capabilities are provided. the industrialfire brigade. Furte AEnsure resolution of PIP 0-08-4820 satisfies the requirement of this section. Section 3.5 Water Supply _ 3.5.1 Complies b9' Previous The fire protection water NRC ApproVal supply is adequate and A fire protection water supply of adequate reliability, quantity,and duration shall be provided by one of the two following methods. reliable. (a) Provide a fire'protectionwater supply of not less than two separate 300,000-gal (1,135,500-L) supplies. Prior to implementation of (b) Calculate the fire flow rate for 2 hours. This fire flow rate shall be F the NFPA 805 program, based on 500 gpm (1892.5 Umin) for manual hose streamsplus the Oconee will ensure that any largest design demand of any sprinkler or fixed water spray system(s) I credited suppression in the power block as determined in accordance with NFPA 13, systems for the Nuclear Standardfor the Installationof Sprinkler Systems, or NFPA 15, Safety Capability Transition Standardfor Water Spray Fixed Systems for Fire Protection. The fire areawithinathe capabithie thedesign fire flow pump water supply shall be capable of delivering this design demand with the aper NaFPA 20. hydraulicallyleast demanding portion of fire main loop out of service. I____ 20.

Cdaulation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1. 2, & 3 Page A19 of A35 NFPA 805 Chapter 3 Section ComplIanc e Statement Compliance Basis 3.5.2 Comply Oconee utilizes Lake The tanks shall be interconnected such that fire pumps can take Keowee as the primary fire suction from either or both. A failure in one tank or its piping shall not water source. allow both tanks to drain. The tanks shall be designed in accordance with NFPA 22, Standardfor Water Tanks for Private Fire Protection. Exception No. 1: Water storage tanks shall not be requiredwhen fire pumps are able to take suction from a large body of water (such as a lake), provided each fire pump has its own suction and both suctions and pumps are adequatelyseparated. Exception No. 2: Cooling tower basins shall be an acceptable water source for fire pumps when the volume is sufficient for both purposes and water quality is consistent with the demands of the fire service. 3.5.3 Complies by Previous The use of the High Fire pumps, designed and installedin accordance with NFPA 20, NRC Approfral Pressure (HPSW) pumpsServicetoWater supply Standardfor the Installationof StationaryPumps for Fire Protection, p shall be provided to ensure that 100 percent of the requiredflow rate fire water is acceptable. and pressure are available assuming failure of the largestpump or pump power source. Further Acti on Required Upon replacement of the Keowee fire pump (PIP 0-01-3492) ensure the installation meets the requirements of this section. 3.5.4 Complies bý Previous Diesel-engine driven fire At least one diesel engine-driven fire pump or two more seismic NRC Appro*,al water pumps are not CategoryI Class IE electric motor-driven fire pumps connected to utilized. Keowee uses an redundant Class IE emergency power buses capable of providing 100 electric fire pump. The percentof the requiredflow rate and pressure shall be provided. NRC has accepted the use

Caikalation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2. & 3 Page A20 of A35 NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis of the HPSW pumps as Oconee fire pumps. Area for Imp,.rovement Both HPSW pumps are currently powered from the same Unit. HPSW pumps should not be powered from a single unit. Consider connection to PSW or an alternate unit. 3.5.5 Complies by, Previous The HPSW pumps are Each pump and its driver and controls shall be separatedfrom the NRC Approal separated from the rest of remaining fire pumps and from the rest of the plant by rated fire the plant and the NRC has barriers, iapproved the use and

                                                                ..                     !installation               of the HPSW Ipumps                 for fire protection use.

3.5.6 Complies by Previous Fire pumps (HPSW and NRC Approval Keowee) auto-start. Fire pumps shall be provided with automatic start and manual stop N only. Area for Improvement Document that PIP 0 3870 has resolved HPSW manual stop.

Cawulation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1. 2, & 3 Page A21 of A35 NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis 3.5.7 Comply There are separate Individualfire pump connections to the yard fire main loop shall be connections from pumps to provided and separatedwith sectionalizingvalves between the fire loops for ONS. connections. Keowee does not have a yard main loop only underground piping. 3.5.8 Comply The pressure in the HPSW A method of automaticpressure maintenance of the fire protection i system EWST. isKeowee usesbylake maintained the water system shall be provided independentof the fire pumps. EWhea towee sesle head to maintain system pressure. 3.5.9 Comply The Control Room(s) are Means shall be provided to immediately notify the controlroom, or automatically notified of other suitable constantly attended location, of operationof fire pumps. operation of the pumps used for fire protection. 3.5.10 Complies by Previous The fire water piping system An undergroundyard fire main loop, designed and installedin NRC Appro~ai was found acceptable by accordance with NFPA 24, Standardfor the Installation of Private Fire the NRC. Service Mains and TheirAppurtenances, shall be installed to furnish i anticipated waterrequirements. c Further ~current Actilon Required documentan cunt documentation, pr prior to implementation of the NFPA 805 program, to perform a'NFPA 24 code _compliance review.

Ca,,lation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page A22 of A35 NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis 3.5.11 Comply Sectionalizing valves are Means shall be provided to isolate portions of the yard fire main loop for provided to allow isolation maintenance or repairwithout simultaneouslyshutting off the supply to of various sections of the both fixed fire suppression systems and fire hose stationsprovided for fire water system for manualbackup. Sprinklersystems and manual hose station standpipes maintenance or repair. shall be connected to the plant fire protection water main so that a single active failure or a crack to the water supply piping to these systems can be isolatedso as not to impairboth the primary and backup fire suppressionsystems. 3.5.12 Comply I Compatible threads are Threads compatible with those used by local fire departments shall be provided. provided on all hydrants, hose couplings, and standpipe risers. Exception: Fire departments shall be permitted to be provided with adaptersthat allow interconnectionbetween plant equipment and the fire department equipment if adequate trainingand proceduresare provided. 3.5.13 Complies by Previous The fire water supply Headersfed from each end shall be permitted inside buildings to supply NRC Approi/al system has been approved both sprinkler and standpipe systems, provided steel piping and fittings by the NRC. Each header meeting the requirementsof ANSI B31.1, Code for Power Piping,are has a separate connection used for the headers (up to and including the first valve) supplying the with shutoff valve to the fire sprinklersystems where such headers are part of the' seismically water system. analyzed hose standpipe system. Where provided, such headersshall be considered an extension of the yard main system. Each sprinkler and standpipe system shall be equipped with an outside screw and yoke (OS&Y) gate valve or other approved shutoff valve.

Cai.nalation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1. 2, & 3 Page A23 of A35 NFPA 805 Chapter 3 Section Compllanc!eI Statement Compliance Basis 3.5.14 Comply Fire protection valves are All fire protection water supply and fire suppression system control locked or sealed and valves shall be under a periodic inspection program and shall be inspected monthly for supervised by one of the following methods. I position. (a) Electricalsupervision with audible and visual signals in the main controlroom or other suitable constantly attended location. i (b) Locking valves in their normal position. Keys shall be made availableonly to authorizedpersonnel. (c) Sealing valves in their normal positions. This option shall be utilized only where valves are located within fenced areasor under the direct controlof the owner/operator. 3.5.15 Complies by Previous The NRC determined that NRC Approý,al the hydrants installed at Hydrants shall be installed approximatelyevery 250 ft (76 m) aparton ~approximately 300 feet the yard main system. A hose house equipped with hose and approeimaly 300 feet combination nozzle and other auxiliary equipment specified in NFPA n 24, Standardfor the Installationof PrivateFire Service Mains and Their Appurtenances,shall be provided at intervals of not more than 1000 ft (305 m) along the yard main system. Exception: Mobile means of providing hose and associatedequipment, such as hose carts or trucks, shall be permitted in lieu of hose houses. Where provided, such mobile equipment shall be equivalent to the equipment supplied by three hose houses. 3.5.16 Complies b' Previous The use of the HPSW The fire protection water supply system shall be dedicated for fire NRC ApproVal system and LPSW system protection use only. ifor fire protection was found acceptable by the NRC. Exception No. 1: Fire protection water supply systems shall be permitted to be used to provide backup to nuclear safety systems, provided the fire protection water supply systems are designed and _

Caiwtalation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1,. 2, & 3 Page A24 of A35 NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis maintainedto deliver the combined fire and nuclearsafety flow demands for the duration specified by the applicable analysis. Exception No. 2: Fire protection water storage can be providedby plant systems servingother functions, provided the storage has a dedicatedcapacity capable of providing the maximum fire protection demand for the specified duration as determinedin this section. Section 3.6 Standpipe and Hose Stations 3.6.1 Complies bi Previous The standpipe and fire hose For all power block buildings, Class Ill standpipe and hose systems NRC ApproVal systems were found shall be installed in accordance with NFPA 14, Standardfor the acceptable by the NRC. Installationof Standpipe, PrivateHydrant, and Hose Systems. in Oconee will enhance current documentation, prior to implementation of the NFPA 805 program, to perform a NFPA 14 code compliance review for standpipe systems not addressed by the previous SER approval but included in the new power block definition. 3.6.2 Comply The fire water supply A capabilityshall be provided to ensure an adequatewater flow rate system can provide and nozzle pressure for all hose stations. This capabilityincludes the adequate water flow and provisionof hose station pressure reducerswhere necessaryfor the pressure at the hose station safety of plant industrialfire brigade members and off-site fire I isolation valves per NFPA departmentpersonnel. i 14.

Cawaflation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1. 2. & 3 Page A25 of A35 NFPA 805 Chapter 3 Section ComphiancI Statement Compliance Basis 3.6.3 Comply The appropriate hose The propertype of hose nozzle to be supplied to each power block I nozzles have been area shall be based on the areafire hazards. The usual combination provided. spray/straightstream nozzle shall not be used in areas where the straight stream can cause unacceptable damage or presentan electricalhazard to fire-fighting personnel.Listed electricallysafe fixed fog nozzles shall be provided at locations where high-voltage shock hazards exist. All hose nozzles shall have shutoff capabilityand be able to control water flow from full open to full closed. 3.6.4 Complies b' Previous The interior hose stations Provisionsshall be made to supply water at least to standpipesand NRC ApproVal were found acceptable by hose stations for manual fire suppression in all areas containing. the NRC. Seismically systems and components needed to perform the nuclearsafety designed hose stations are functions in the event of a safe shutdown earthquake (SSE). t provided in the Reactor Exception: For existing plants that are not capable of meeting this Building and the Cable requirement,provisions to restore a water supply and distributionsystem Room to Control Room for manual fire-fighting purposesshall be made. The provisionalmanual back stairwells. The HPSW fire-fighting standpipe/hose station system shall be capable of providing manual fire-fighting protection to the various plant locationsimportantto supportingand maintainingthe nuclearsafety function. The provisionsfor sydesigned. establishingthis provisionalsystem shall be preplannedand be capable of dg being implemented in a timely mannerfollowing an SSE. 3.6.5 Comply Fire flow will not affect the essential water system. Where the seismic requiredhose stations are cross-connected to essentialseismic non-fire protectionwater supply systems, the fire flow shallnot degrade the essential water system requirement.

Caiualation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page A26 of A35 NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis Section 3.7 Fire Extinguishers Complies by' Previous The portable fire Where provided, fire extinguishers of the appropriatenumber, size, and NRC ApproIal extinguishers (location and type shallbe provided in accordancewith NFPA 10, Standard for type) meet the requirements Portable Fire Extinguishers. Extinguishersshall be permitted to be of NFPA 10 where positionedoutside of fire areas due to radiologicalconditions. provided. Further Action Required Oconee will enhance current documentation, prior to implementation of the NFPA 805 program, to perform a NFPA 10 code compliance review. 3.8 Fire Alarm and Detection Systems 3.8:1 Fire Alarm Complies by Previous Fire related signals are Alarm initiatingdevices shall be installed in accordancewith NFPA 72, NRC APproral transmitted to the control NationalFire Alarm Code.Alarm annunciationshall allow the derooms or security. The fire proprietaryalarm system to transmit fire-relatedalarms, supervisory detection and signaling signals, and trouble signals to the controlroom or other constantly i system was found attended location from which requirednotifications and response can acceptable by the NRC. be initiated. Personnelassigned to the proprietaryalarm station shall be permitted to have other duties. The following fire-relatedsignals shall be transmitted: Further Acti.n Required Perform a NFPA 72 code (1) Actuation of any fire detection device compliance review for fire alarm and detection (2) Actuation of any fixed fire suppression system systems (Sections 3.8.1 (3) Actuation of any manual fire alarmstation and 3.8.2). (4) Starting of any fire pump (5) Actuation of any fire protection supervisory device

Caiculation No.: OSC-9295 Revision No.: I "" Applicable Units: Oconee Unit 1, 2, & 3 Page A27 of A35 NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis (6) Indication of alarm system trouble condition 3.8.1.1 Comply Means to report a fire are Means shall be provided to allow a person observing a fire at any provided. location in the plant to quickly and reliablycommunicate to the control room or other suitable constantly attended location. 3.8.1.2 Comply The Control Room notifies Means shall be provided to promptly notify the following of any fire station personnel of a fire emergency in such a way as to allow them to determine an appropriate event over the Plant PA course of action: System and can communicate with Brigade (1) Generalsite population in all occupied areas personnel and Off-Site (2) Members of the industrialfire brigade and other groups agencies by various means. supporting fire emergency response (3) Off-site fire emergency response agencies. Two independent means shall be available (e.g., telephone and radio) for notification of off-site emergency services 3.8.2 Detection Complies by Previous The fire detection and If automatic fire detection is required to meet the performance or NRC ApproVal signaling system was found deterministicrequirementsof Chapter 4, then these devices shall be acceptable by the NRC. installedin accordance with NFPA 72, National FireAlarm Code, and The system was installed in its applicable appendixes. accordance with applicable codes of record with documented deviations. _ _Perform a NFPA 72 code

Cam alation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1. 2. & 3 Page A28 of A35 NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis FurtherAction Required compliance review of the fire alarm and detection systems.} Section 3.9 Automatic and Manual Water-Based Fire Suppression Systems _ 3.9.1 Complies by Previous NFPA code compliance Licensee E*aluation calculations have been If an automaticor manualwater-based fire suppressionsystem is performed for automatic required to meet the performance or deterministicrequirements of p Chapter4, then the system shall be installedin accordancewith the and manual water-based appropriateNFPA standardsincluding the following: fire suppression systems. (1) NFPA 13, Standardfor the Installationof Sprinkler Systems Further Action Required Review the applicable Fire (2) NFPA 15, Standard for Water Spray Fixed Systems for Suppression NFPA Code Fire Protection Review calculations of the (3) NFPA 750, Standardon Water Mist Fire Protection water based fire Systems suppression systems required to meet the nuclear (4) NFPA 16, Standardfor the Installation of Foam-Water safety performance criteria Sprinkler and Foam-WaterSpray Systems 3.9.2 Comply Each fixed extinguishing Each system shall be equipped with a water flow alarm. system is provided with an alarm of flow indication. 3.9.3 Comply I Alarms are annunciated in All alarms from fire suppressionsystems shall annunciate in the control i theteControl Contl Roomsatten or other room or other suitable constantly attended location. remote constantly attended area.

Camcdation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1. 2. & 3 Page A29 of A35 NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis 3.9.4 N/A There are no diesel-driven i fire water pumps utilized at Diesel-drivenfire pumps shall be protected by automatic sprinklers. the Oconee Plant. 3.9.5 Complies NRC Approby61Previous Each suppression connected system is to the header Each system shalltbe equipped with an OS&Y gate valve or other with an approved control approved shutoff valve. i valve. 3.9.6 Comply I 't The valves are not electrically supervised but All valves controlling water-based fire suppression systems requiredto e meet the performance or deterministicrequirementsof Chapter4 shall are locked or sealed in be supervised as described in 3.5.14. accordance with Section 3.5.14. Section 3.10 Gaseous Fire Suppression Systems _ ___ 3.10.1 N/A There are no required If an automatictotal flooding and localapplicationgaseous fire gaseous fire suppression suppression system is required to meet the performance or is only fire

                                                                                                ~suppressionsystems. Gaseous        utilized deterministicrequirements of Chapter4, then the system shall be                                       spesiois onlyuiie designed and installedin accordancewith the following applicable                  Ifor                 specific components -

NFPA codes: the Keowee Hydro Station's Generators and the SSF (1) NFPA 12, Standardon Carbon Dioxide Extinguishing Diesel Generator are Systems Eprovided with CO 2 (2) NFPA 12A, Standard on Halon 1301 Fire Extinguishing extinguishing systems. Systems (3) NFPA 2001, Standardon CleanAgent Fire Extinguishing I Systems I

Ciwitlation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page A30 of A35 T NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis 3.10.2 N/A N/A Operationof gaseous fire suppressionsystems shall annunciate and alarm in the control room or other constantly attended location identified. 3.10.3 N/A N/A Ventilation system design shall take into accountprevention from over-pressurizationduring agent injection, adequate sealing to prevent loss of agent, and confinement of radioactivecontaminants. 3.10.4 N/A N/A In any area requiredto be protected by both primaryand backup gaseous fire suppressionsystems, a single active failure or a crack in any pipe in the fire suppression system shall not impairboth the primaryand backup fire suppression capability. 3.10.5 N/A N/A Provisionsfor locally disarming automatic gaseous suppression systems shall be secured and under strict administrative control. 3.10.6 N/A N/A Total flooding carbon dioxide systems shall not be used in normally occupied areas. 1_______________________ _________________ ____________________________________________

CUicalation No.: OSC-9295 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page A31 of A35 NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis

 .3.10.7                                                                              N/A                               N/A N

Automatic total flooding carbon dioxide.systems shall be equipped with an audible pre-dischargealarm and discharge delay sufficient to permit egress of personnel. The carbon dioxide system shall be provided with an odorizer. 3.10.8 N/A N/A Positive mechanicalmeans shall be provided to lock out total flooding carbon dioxide systems during work in the protected space. 3.10.9 N/A N/A The possibility of secondarythermal shock (cooling) damage shall be considered during the design of any gaseous fire suppressionsystem, but particularlywith carbon dioxide. 3.10.10 N/A N/A Particularattentionshall be given to corrosive characteristicsof agent decomposition products on safety systems, Section 3.11 Passive Fire Protection Features This section shall be used to determine the design and installationrequirementsfor passive protection features. Passive fire protection features include wall, ceiling, and floor assemblies, fire doors, fire dampers, and throug,I fire barrierpenetrationseals. Passive fire protection features also include electricalraceway fire barriersystems (ERFBS) that ar6 provided to protect cables and electrical components and equipment from the effects of fire.

Cairilation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1. 2, & 3 Page A32 of A35 NFPA 805 Chapter 3 Section ComplianceI Statement Compliance Basis 3.11.1 Building Separation Complies by Previous Adequate building Each major building within the power block shall be separatedfrom the NRC Approyal separation has been found others by barriershaving a designated fire resistancerating of 3 hours acceptable by the NRC or or by open space of at least 50 ft (15.2 m) or space that meets the by licensee evaluation. requirements of NFPA 80A, Recommended Practice for Protectionof Comply by IPrevious Buildings from Exterior Fire Exposures. Licensee Evaluation Exception: Where a performance-basedanalysis determines the I The Keowee Hydro Station adequacy of building separation,the requirements of 3.11.1 shall not I and the SSF are separated apply- from the other buildings by apya distance of greater than 50 feet. Further Action, Required Upgrade fire barriers in accordance with the open Iitems in PIP 0-08-2006 and PIP 0-08-2520. 3.11.2 Fire Barriers Complies b,' Previous The fire barriers between Fire barriersrequired by Chapter4 shall include a specific fire- NRC Approyal the major plant buildings resistancerating. Fire barriersshall be designed and installed to meet were found to be the specific fire resistancerating using assemblies qualifiedby fire . acceptable by the NRC or tests. The qualificationfire tests shall be in accordance with NFPA 251, Comply by Previous by licensee evaluation. StandardMethods of Tests of Fire Enduranceof Building Construction Licensee Evaluation and Materials, or ASTM E 119, Standard Test Methods for Fire Tests of Building Constructionand Materials. Upgrade fire barriers in Further Action Required accordance with the open items in PIP 0-08-2006 and PIP 0-08-2520.

Ca'rcitlation No.: OSC-9295 Revision No.: Applicable Units: Oconee Unit 1. 2, & 3 Page A33 of A35 NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis 3.11.3 FireBarrierPenetrations Complies b, Previous The fire barrier penetrations Penetrationsin fire barriersshall be provided with listed fire-rateddoor NRC Appro~val were found to be assembliesor listed ratedfire dampers having a fire resistance rating acceptable by the NRC or consistent with the designated fire resistancerating of the barrieras by licensee evaluation. determinedby the performance requirements established by Chapter 4. (See 3.11.4 for penetrationseals for through penetrationfire stops.) Comply by Previous Passive fire protection devices such as doors and dampers shall Licensee Evaluation conform with the following NFPA standards,as applicable: (1) NFPA 80, Standardfor Fire Doors and Fire Windows Ub (2) NFPA 90A, Standardfor the Installationof Air-Conditioning Further Action Required Upgrade fire barriers in and Ventilating Systems items in PIP 0-08-2006 and (3) NFPA 101, Life Safety Code PIP 0-08-2520. Exception: Where fire areaboundariesare not wall-to-wall, floor-to-ceiling boundarieswith all penetrationssealed to the fire ratingrequired of the boundaries,a performance-basedanalysis shall be requiredto assess the adequacyof fire barrierforming the fire boundary to determine if the barrierwill withstand the fire effects of the hazards in the area. Openings in fire barriersshall be permitted to be protected by other means as acceptable to the AHJ. 3.11.4 Through PenetrationFire Stops Comply by Previous The Penetration Seal Through penetration fire stops for penetrationssuch as pipes, conduits, Licensee Etaluation Database and 86-10 bus ducts, cables, wires, pneumatic tubes and ducts, and similar Evaluation calculation building service equipment that pass through fire barriersshall be document the acceptability protected as follows, of the station penetration seals (a) The annularspace between the penetratingitem and the through opening in the fire barriershall be filled with a qualified fire-resistive penetrationseal assembly capable of maintaining the fire resistance of the fire barrier.The assembly shall be qualified by tests in accordance Complies by Previous exemNsh rspecifi with a fire test protocol acceptableto the AHJ or be protected by a NRC Approval exemptionsforspecific

Cait*lation No.: OSC-9295 Revision No.: 1 Applicable Units: Oconee Unit 1, 2, & 3 Page A34 of A35 NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis listed fire-rateddevice for the specified fire-resistive period. i penetration seals. (b) Conduits shall be provided with an internal fire seal that has an equivalent fire-resistive rating to that of the fire barrierthrough opening fire stop and shall be permitted to be installed on either side of the Further Action Required Upgrade fire barriers in barrierin a location that is as close to the barrieras possible. accordance with the open items in PIP 0-08-2006 and Exception: Openings inside conduit 4 in. (10.2 cm) or less in diameter iP 0-0-25 20. shall be sealed at the fire barrierwith a fire-ratedinternalseal unless the conduit extends greaterthan 5 ft (1.5 m) on each side of the fire barrier.In this case the conduit opening shall be provided with noncombustible material to prevent the passage of smoke and hot gases. The fill depth .ofthe materialpacked to a depth of 2 in. (5.1 cm) shall constitute an acceptable smoke and hot gas seal in this application. 3.11.5 ElectricalRaceway Fire BarrierSystems (ERFBS) N/A Oconee does not utilize L ERFBS. ERFBS requiredby Chapter4 shall be capable of resisting the fire F effects of the hazards in the area. ERFBS shall be tested in accordance with and shall meet the acceptance criteriaof NRC Generic Letter 86-10, Supplement 1, "FireEndurance Test Acceptance Criteriafor Fire BarrierSystems Used to Separate Safe Shutdown Trains Within the Same Fire Area." The ERFBS needs to adequatelyaddress the design requirementsand limitations of supports and interveningitems and their impact on the fire barriersystem rating. The fire barriersystem's ability to maintain the requirednuclearsafety circuits free of fire damage for a specific thermal exposure, barrierdesign, raceway size and type, cable size, fill, and type shall be demonstrated. Exception No. 1: When the temperaturesinside the fire barriersystem exceed the maximum temperature allowed by the acceptance criteriaof Generic Letter 86-10, "FireEnduranceAcceptance Test Criteriafor Fire BarrierSystems Used to Separate Redundant Safe Shutdown Training Within the Same Fire Area," Supplement 1, functionality of the cable at these elevated temperaturesshall be demonstrated. Qualification

Calciclation No.: OSC-9295 R e vis io n N o .: I .... Applicable Units: Oconee Unit 1, 2. & 3 Page A35 of A35 NFPA 805 Chapter 3 Section Compliance Statement Compliance Basis demonstrationof these cables shall be performed in accordance with the electricaltesting requirementsof Generic Letter 86-10, Supplement 1, Attachment 1, 'Attachment Methods for DemonstratingFunctionality of Cables Protectedby Raceway Fire BarrierSystems During and After Fire Endurance Test Exposure." Exception No. 2: ERFBS systems employed prior to the issuance of Generic Letter 86-10, Supplement 1, are acceptable providing that the system successfully met the limiting end point temperature requirementsas specified by the AHJ at the time of acceptance.

Form 101.2 (R3-03) Calculation Number OSC-9295 REVISION DOCUMENTATION SHEET Revision Number Revision Description 0 Initial Issue

FORM 101.3 (R08-04) CERTIFICATION OF ENGINEERING CALCULATION - REVISION LOG Station And Unit Number Oconee Units 1, 2 & 3 Title Of Calculation NFPA 805 Transition B-1 Table/Report Calculation Number OSC-9295 Active Calculation / Analysis Yes x No 0 Calculation Pages (Vol) Supporting Volumes Verif. Appr1 Issue Documentation (Vol) Volus Oig Chkd Meth. Date Rev. No. Revised Deleted Added 1Revised

                                  --

Rev.----- Deleted Added Deleted

                                                          -e       Added     Date       Date 1,2,.3, "Other" 2-       Date Rec'd Date Note 1: When approving a Calculation revision with multiple Originators or Checkers, the Approver need sign only one block.

C.ALCULATION IMPACT ASSESSM~ENT (CIA) Stau-on!'Unit 0t,,& I t, 3 Caicultou No-MC i f- Re-,. _D_ ?,age i PIP No. (if a~pphcable) Q!-h* A

                                 -Zj                                 By                                 Dat DVZtdMrC,4Kft4 Prob. No. (st~ess & vt use oupv)        MA                   Checked By                                  Date NEDL reviewed to idtntifr,vaklcnionsQ                          1ITY S   UMv       N,:- NOT   EIsahi                 reure Idenlil- in the blocks bdow, the groups consulted for an Impart Assessment of this calculation originationlrevision.

Thdiv.T Cateit {Power. ! & C, EP.RTi,_ _ _ _ _ _ _ fQA Tech. Serices (151). P..e cto," Slect Sysý & Bqgi,t Dtsigp

                                                                        & Rtecler Sqp, Civil                _______

Strucual. Core Mech. & tinnmury Sysems, Balincec T/H Amilysis, Mtch- Sys & Ralf LK Plant, Roýrating Equipment. . . Squip., Ntclear Design and Vahves &. Heat Excbangmr, Safety Aunalysis, Civ-il] o MOD _ ______ _ _ _ _ _ _ Matt~M~alrYPTlpingJ ________ EnLr-Civil Ensr.1 Local IT___ ___ o Opernuons - OPS Sappcst ______ O Mainenance - TeO&. Spport Co Work ContrQ) - paeegrea W.. ______ Radiation I'rotedga________ o Othi-e Oroup____ No Group r'equired to be consulted Llited below are the identifled documests (ex: TECHLNICAL SPECiIRCATIOX SECTIONS, UTSAR SECTIONS, DESIGIN-BASIS DOCUMENTS, STATION PROCEDUIE~i., DIUVIVENGS, OTHER CALCV1ATIONS,35ETCJ) that way requite revision as a re-sult of the calculation origiinatiotr or rvvisian, the documern ownerigroup and thte change requireA (ioch~diii navnyset-m PIP Cor-r&tfie Actions). N*ter: An desig-a rfmng, lphich requvre- elmugas; to St~tion Prore~itr#-, must be tzransm &Mfe as Design DehvotaW1 Dorliments. DOCUMENT C20-UP CHNEROIRED O itzSt hdA 6j/ Pit, KCIE Se

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 1 of 84 PURPOSE The purpose of this calculation is to document the comparison of the existing Oconee Nuclear Station Fire Protection Program to the requirements presented in Chapter 3 of NFPA 805. This calculation documents fire protection features needed to protect nuclear safety-related structures, systems, or components which are designated as QA Condition 3 systems. II. BACKGROUND Under its current operating-license, Oconee Nuclear Station is required to maintain the provisions of its approved fire protection program. The current licensing basis documents for Oconee are Appendix A to BTP APCSB 9.5-1 and 10CFR50 Appendix R Sections Ill.G, Ill.J, 11.L and 111.0. The NRC has added 10CFR50.48(c) as an alternative method of compliance to 10CFR50.48(b). 10CFR50.48(c) is the adoption of the industry consensus standard NFPA

...................
 -                  8*5-Performance*Based-Standa~rd--fT-PireF-Protection-for-Light-WaterReactur-E-iectric-          .........

Generating Plants (2001 Edition). Oconee has elected to transition to 10CFR50.48(c). As part of the transition to NFPA 805, the fundamental fire protection program design elements are required to be identified. NFPA 805 Chapter 3 defines fundamental fire protection program attributes. This report documents the comparison of the existing Oconee Nuclear Station Fire Protection Program to the requirements presented in Chapter 3 of NFPA 805. Ill. METHODOLOGY The requirements presented in Chapter 3 of NFPA 805, 2001 Edition, were compared to the existing Oconee Nuclear Station fire protection program. The attributes of fire protection features and administrative programs that satisfy the provisions of NFPA 805 were documented. Where direct compliance was not found, a search of previous licensing documentation was conducted to determine if the NRC had previously approved alternative methods of compliance. Where compliance could not be determined, an open item was established. The comparison of the Oconee Nuclear Station fire protection program to Chapter 3 of NFPA 805 is summarized in Attachment A - Compliance Table'and further substantiated with additional detail and references in Section VI, of this report. The compliance table is a brief overview which includes the NFPA 805 Code section and text, the Compliance Statement, and a Compliance Basis summary. Section VI has three components. The first is the verbatim text of NFPA 805 (provided in italics). The second is a detailed discussion of the ONS compliance basis. Finally a list of references is provided. The following standard Compliance Statements are used in the Compliance Table:

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 2 of 84 Comply - Oconee clearly complies with the NFPA 805 requirement, through direct 'literal' compliance or compliance with the intent (e.g. NFPA 805 specifies requirement located in one document and station has it located in another document). Sections may comply and also have an Area for Improvement which may not submitted in the LAR.

                    " Complies by Previous NRC Approval - Oconee does not clearly meet the NFPA 805 requirement but has been approved directlybythe NRC (typically by SER).

• Complies by Previous Licensee Evaluation- Oconee does not clearly meet the NFPA 805 requirement but the Licensee has completed an equivalency evaluation.

                    " Submit for NRC Approval - Oconee does not clearly meet the NFPA 805 requirement and will submit the current basis for NRC review and approval.
                    " Further Action Required - Oconee will take an action to revise documentation or perform additional analysis and/or actions to demonstrate compliance.

• N/A - NFPA 805 requirement does not apply to Oconee.

Open items are divided into three categories:

1. Submit for Approval

2. Further Action Required

3. Area for Improvement - Area for Improvement are sections where Oconee is currently in compliance and station documentation will be enhanced for further clarification. Areas for Improvement may not be submitted in the LAR.

The comparison utilizes NEI 04-02 "Guidance for Implementing A Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)," Revision 1 as a tool to determine the method and extent to which compliance is demonstrated. The Compliance Table, showing cross-reference and compliance statements, was based on Table B-1 of NEI 04-02. IV. REFERENCES

1. Duke Letter to the NRC, FRAQUA Response, dated January 16, 1978.

2. Duke Letter to the NRC, Response to Appendix A to Branch Technical Position APCSB 9.5-1, dated December 31, 1976.

3. Duke Letter to the NRC, Response to Appendix A to Branch Technical Position APCSB 9.5-1, dated February 1982.

4. Duke letter to the NRC dated November 22, 1977.

5. Duke letter to the NRC dated February 17, 1978.

6. Duke Letter tothe NRC dated March 18, 1981.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2. & 3 Page 3 of 84

7. Duke to NRC, PIP 0-99-2532/LER 270/1999-04, dated February 16, 2000.

8. NRC Safety Evaluation Report dated August 11, 1978.

9. NRC Safety Evaluation Report dated April 28, 1983.

10. NRC Safety Evaluation Report dated June 7, 1988.

11. NRC Safety Evaluation Report dated May 23, 2000.

12. NRC Letter dated April 14,1981.

13. NRC Letter to Duke dated February 2, 1982.

14. NRC letter to Duke dated May 23, 2000.

15. NRC Exemption to various Appendix R Requirements dated August 21, 1989.

16. Design Basis Specification for Fire Protection, OSS-0254.00-00-4008, Revision 16.

17. Design Basis Specification for the Fire Detection System, OSS-0254.00-00-2017, Revision 8.

l-8.--D-e-i-gn-B-sis-S p-ecifi~ti io-for-th-e-dw-Pressu-te-SerVic-e-Wate-r ÷Syste,-O SS_025-4.0000*-........ 1039, Revision.

19. Design Basis Specification for the High Pressure Service Water System, OSS-0254.00 1002, Revision 25.

20. Engineering Support Program Document for Fire Protection, Revision 4.

21. EM 4.6 "Oconee Engineering Support Program Walkdowns", Revision 6.

22. EDM-201 "Engineering Support Program", Revision 6.

23. EDM-601 "Engineering Change Manual", Revision 2.

24. ERTG-001 "Emergency Response Organization and Emergency Services Training Program".

25. EWP 7.2 "Storing Chemicals", Revision 2.

26. NSD-1 04 "Housekeeping, Materiel Condition, and Foreign Material Exclusion", Revision 27.

27. NSD-106 "Configuration Management", Revision 4.

28. NSD-1 12 "Fire Brigade Organization, Training & Responsibilities", Revision 7.

29. NSD-1 16 "Nuclear Chemical Control Program", Revision 2.

30. NSD-228 "Applicability Determination", Revision 3.

31. NSD-301 "Engineering Change Program", Revision 27.

32. NSD-313 "Control of Flammable and Combustible Materials", Revision 6.

33. NSD-314 "Hot Work Authorization", Revision 6.

34. NSD-316 "Fire Protection Impairment and Surveillance", Revision 6.

35. NSD-318 "Coatings Program", Revision 2.

36. NSD-320 "Guidance for Performing Licensing Review of Proposed Changes to the Fire Protection Program", Revision 0.

37. NSD-413 "Fluid Leak Management Program", Revision 4.

38. S.D. 3.2.14 "Fire Protection Program Compensatory Measures Process", Revision 0.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 4 of 84

39. PiP 0-1999-02753.

40. PIP 0-2001-03492.

41. PIP 0-2002-03870.

42. PIP 0-2002-06047.

43. PIP 0-2005-04125.

44. PIP 0-2008-02163.

45. Drawing KFD-1 09A-1.1 "Keowee Hydro Station - Flow Diagram of Service Water System".

46. Drawing Series OFD-124C.

47. Drawing OFD-1 35A-01 -01.

48. Drawing Series 0-310 K and L "Fire Protection Plan & Fire, Flood, & Pressure Boundaries".

49. SLC 16.9.2 dated 6/28/05.

50. SLC 16.9.3 dated 1/14/04.

52. SLC 16.9.5 dated 1/30/00.

53. SLC 16.9.6 dated 12/14/04.

54. SLC 16.9.7 dated 3/31/05.

55. SLC 16.13.1 dated 5/13/04.

56. OP/0/A/1600/004 "Operation of the SSF C02 System".

57. PT/OIA/0400/002 "SSF C02 Test'.

58. PT/i/A/2200/006 "KHU-1 C02 System Surveillance".

59. PT/2/A/2200/006 "KHU-2 C02 System Surveillance".

60. PT/0/B/0250/030 "Quarterly Fire Brigade Equipment Inspection", Revision 20.

61. PT/O/A/2200/01 0 "KHS Fire Protection Equipment Surveillance" Revision 25.

62. PT/0/B/2000/001 "Preparation and Conduct of Emergency Drills".

63. PT/O/A/0250/01 0 A "Fire Protection System Monthly Inspection", Revision 65.

64. RP/0/B/1000/029 "Fire Brigade Response", Revision 11.

65. Calculation OSC-1626, Pressure at Hose Stations in Auxiliary and Turbine Building, Revision 2.

66. Calculation OSC-7185, Fire Evaluation of the East West Penetration Room Wall, Revision 0.

67. Calculation OSC-7350, ONS Penetration Seal Database and 86-10 Evaluations, Revision 6.

68. Calculation OSC-7359 (DPC 1435.00-00-0006), Calculation for the Technical Basis for Fire Barrier Penetration Seals, Revision 1.

69. Fire Suppression NFPA Code Review calculations.

70. Duke Corporate Roof Management Program.

71. General Employee Training - Plant Access Training.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 5 of 84

72. Oconee Emergency Plan.

73. Oconee Nuclear Site Fire Plan.

74. Specification OSS-241.00-00-0004 "Conventional Thermal Insulation", Revision 5.

75. Specification OSS.241A "Reactor Building and Piping Heat Insulation (Metal Reflective Type), Revision 4.

76. UFSAR Section 9.5.1 dated 12/31/05.

V. STATUS OF NFPA 805 COMPLIANCE Compliance Statement Total Notes Comply 54 Comply by Previous NRC 22 Approval

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C-om p ly-by-Pr ev io us -----

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2 . . . . .. .. . . . . . . . . . .. .

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Licensee Evaluation Submit for NRC Approval 2 Section 3.3.1.2(1) and Section 3.3.1.3.4 Further Action Required 27 Oconee will take an action to revise documentation or perform additional analysis and/or actions to demonstrate compliance. Area for Improvement 6 Oconee is compliant and areas to enhance station documentation are identified N/A 2 Section 3.9.4 and Section 3.11.5 Note that there are more method of compliance statements than code sections as some sections comply by various means or additional actions are required. Open Items The following is a list of open items (Submit for Approval, Further Action Required, Area for Improvement) and actions required for resolution. PIP 0-08-2163 has been generated to track the open items in the following table. Additional detail can be found in the applicable report section. Section Requirement Action 3.2.2.4 The policy document for the Fire Revise station documentation to state the Protection Plan shall identify the NRC is the AHJ for fire protection appropriate AHJ. changes requiring approval. 3.3.1.2(1) Wood used within the power block Submit for NRC Approval; Oconee shall be listed with a fire-retardant permits non-treated wood for concrete application forming or per design documents. 3.3.1.2(2) Plastic sheeting materials used in Revise NSD-313 (or an alternative I the power block shall be fire- administrative control document) to

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 6. of 84 retardant types that have passed specifically address plastic sheeting NFPA 701, or equivalent, materials shall conform to NFPA 701 requirements, or equivalent.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page *7 of 84 Section Requirement Action 3.3.1.3.1 A hot work safety procedure shall Evaluate NSD-314 to determine if NFPA be developed, implemented, and 241 should be included. periodically updated as necessary in accordance with NFPA 51 B, and NFPA 241 3.3.1.3.3 Open flames or combustion- Revise station leak testing procedures to generated smoke shall not be ensure open flames and combustion permitted for leak or air flow generated smoke are not used. testing. 3.3.1.3.4 Portable fuel-fired heaters shall not Submit for NRC Approval; Oconee be. permitted in plant areas permits fossil fuel (gas, and oil-fired) containing equipment important to heaters. nuclear safety or where there is a

            ..      ptential--for--radielogical-releases---                                ------.--

resulting from a fire. 3.3.3 Interior wall, floor and ceiling finish Revise NSD-318 to include the classifications shall be in appropriate code specifications. accordance with NFPA 101. 3.3.5.1 Wiring above suspended ceiling Revise applicable station documentation shall be kept to a minimum. .for compliance with this section. 3.3.5.2 Only metal tray and metal conduits Revise applicable station documentation shall be used for electrical for compliance with this section. raceways. _ 3.3.5.3 Electric cable construction shall Revise station documentation that non-comply with a flame propagation rated cables (including data/phone/video) test. shall not be routed in cable trays with nuclear safety related cables. 3.3.7.1 NFPA 50A shall be followed for Perform a NFPA 50A code compliance hydrogen storage. review for outdoor hydrogen storage. 3.3.7.2 Outdoor high pressure flammable Resolve propane tank storage gas storage container shall be configuration; submit for NRC approval, located so that the long axis is not evaluate or modify the tank. pointed at buildings. 3.3.8 Bulk storage of flammable and Perform NFPA 30 code compliance combustible liquids. review for bulk storage of the Turbine Building and Keowee lube oil storage locations. 3.3.9 Transformer oil collection basins Revise Transformer Water Spray test and drain paths shall be procedures to ensure drainage is periodically inspected to ensure inspected during annual flow tests. they are free of debris and capable of performing their design function.

Calculation No.: OSC-9295 Revision No.: 0' Applicable Units: Oconee Unit 1, 2, & 3 Page 8 of 84 Section Requirement Action 3.3.10 Administrative controls shall Revise NSD-104 and/or NSD-413 to require the prompt cleanup of oil clearly indicate it is a NRC requirement to on insulation, promptly remove oil from insulation. 3.3.11 Adequate clearance, free of Revise NSD-313 to include PRA Zone of combustible material, shall be Influence distance from PRA fire maintained around energized modeling as exclusion area for transient electrical equipment. combustibles. 3.4.1(a) The fire brigade shall comply with Ensure NFPA 600 code review is NFPA 600. included in the Fire Brigade Functional Area Management (FAM) manual. 3.4.2.1 Pre-Fire Plans shall detail the fire Review ONS Fire Plan to ensure area configuration and fire hazards minimum pre-plan content is included per

         .......... to be encountered in the fire area, FAQ 06-0025..

along with any nuclear safety components and fire protection systems and features that are present. 3.5.1(b) The fire water supply shall be Ensure any required suppression systems capable of delivering the largest for Chapter 4 are within the design flow system design demand and hose capabilities of the fire pump. stream. 3.5.3 Fire pumps shall be installed in Ensure the Keowee fire pump accordance with NFPA 20 and replacement is done in accordance with shall provide 100% of the required NFPA 20 and properly sized for the flow and pressure. required maximum fire flow and pressure requirements. 3.5.6 Fire pumps shall be provided with Document resolution of PIP 02-3870 to automatic start and manual stop install manual stop on the HPSW pumps. only. 3.6.1 For all power block buildings, Perform a NFPA 14 code compliance Class III standpipe and hose review. systems shall be installed in accordance with NFPA 14. 3.7 Where provided,fire extinguishers Perform a NFPA 10 code compliance of the appropriate number, size, review. and type shall be provide in accordance with NFPA 10. 3.8.1 Fire alarm initiating devices shall Perform a NFPA 72 code compliance be installed in accordance with review (Sections 3.8.1 and 3.8.2). NFPA 72.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 9 of 84 Section Requirement Action 3.8.2 Automatic fire detection devices Identify fire detection devices credited for required by Chapter 4 shall be PRA, defense-in-depth or as part of the installed in accordance with NFPA change evaluation process. 72. 3.9.1 Automatic or manual water based Identify automatic or manual water based fire suppression systems required fire suppression systems credited for by Chapter 4 shall be installed in PRA, defense-in-depth or as part of the accordance with NFPA 13 or 15. change evaluation process. Review applicable existing code compliance reviews. Perform additional reviews as necessary. 3.10.1 Automatic total flooding or local Identify gaseous fire suppression systems 3.10.3 application gaseous fire credited for PRA, defense-in-depth or as

                 .suppression-systems--required--by- -part-of-the--ehange-evaluatien-preeess 7 --

3.10.4 Chapter 4 shall be installed in Perform a NFPA 12 code compliance 3.10.9 accordance with NFPA 12. review. Includes addressing open items in subsequent Section 3.10.3, 3.10.4, 3.10.10 3.10.9 and 3.10.10 in the code compliance review. 3.11.2 Fire barrierg required by Chapter 4 Identify fire barriers credited for PRA, shall include a specific fire- defense-in-depth or as part of the change resistance rating. evaluation process. Review if credited fire barriers are adequate. 3.11.3 Penetrations in fire barriers shall Identify fire barriers credited for PRA, be provided Wvith listed fire-rated defense-in-depth or as part of the change door assemblies or listed rated fire evaluation process. Review if credited dampers having a fire resistance fire barrier penetrations are adequate. rating consistent with the designed fire resistance rating of the barriers as determined by Chapter 4. 3.11.4 Through penetration fire stops for Identify fire barriers credited for PRA, penetrations shall be protected. defense-in-depth or as part of the change evaluation process. Review if credited penetration seals are evaluated in Calculation OSC-7350. 3.11.5 ERFBS required byChapter4 shall Identify ERFBS credited for PRA, be capable of resisting the fire defense-in-depth or as part of the change effects of the hazards in the area. evaluation process. Review if credited ERFBS are rated appropriately.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 10 of 84 VI. STATEMENTS OF NFPA 805 COMPLIANCE Each Section of Chapter 3 of NFPA 805 is individually addressed below: Section 3.1 General This chaptercontains the fundamental elements of the fire protectionprogram and specifies the minimum design requirements for fire protection systems and features. These fire protectionprogram elements and minimum design requirements shall not be subject to the performance-based methods permitted elsewhere in this standard. Previously approved alternativesfrom the fundamentalprotectionprogramattributesof this chapterby the AHJ take precedence over the requirements containedherein. Oconee Nuclear Station (ONS) compliance with the fire protection program elements and minimum design requirements presented in NFPA 805 Chapter 3 is not based on the performance-based methods permitted elsewhere in the standard. The following discussion of

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Chapter--3-requirements-documents-ONS-compliance-or-intended--compliance-with-the-individual code sections. Inaddition documentation is provided where previous NRC approval has been granted for a deviation to the code.

Section 3.2 Fire Protection Plan 3.21 Intent A site-wide fire protection plan shall be established.This plan shall document management policy and program direction and shall define the responsibilities of those individuals responsiblefor the plan'simplementation. This section establishesthe criteriafor an integrated combination of components, procedures, and personnel to implement all fire protection programactivities. The Design Bases Specification for Fire Protection, OSS-0254.00-00-4008, documents the ONS Fire Protection Program including management policy, program direction and defines the organization, responsibilities and requirements of involved personnel. Many of these attributes have been updated and revised since original correspondence with the NRC including the January 16, 1978 letter from Duke to the NRC in response to the Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and QualityAssurance (FRAQUA) letter and the original and updated Response to Appendix A to Branch Technical Position APCSB 9.5-1. The ONS fire protection program is currently based on, and complies with, the requirements of 1 OCFR50.48(a). Note that Oconee uses the terminology Fire Plan to represent the fire pre-plan (fire-fighting strategies) for fire scenarios at the site and uses the term Fire Protection Program (per 10CFR50.48) to delineate the implementation of fire protection policies at the plant. Reference(s): Design Basis Specification for Fire Protection Duke Letter to the NRC, FRAQUA Response, January 16, 1978

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 11 of 84 Duke Letter to the NRC, Response to Appendix A to Branch Technical Position APCSB 9.5-1, December 31, 1976 Duke Letter to the NRC, Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 3.2.2 Management Policy Directionand Responsibility A policy document shall be preparedthat defines management authorityand responsibilities and establishes the generalpolicy for the site fire protection program. The Design Bases Specification for Fire Protection includes the management policy of the fire protection program organization and responsibilities. The Design Bases Specification for Fire Protection and Engineering Support Document for Fire Protection provide detailed information about the Fire Protection Program. The Design Bases Specification for Fire Protection provides the basis and regulatory framework upon which the Oconee Nuclear Station Fire -P-.-t...n..................Pretecton-gP-rogram-is--based,-.-T-he-Engineering--Support--P-rogram-Document-for--Fire-- Protection provides the fire protection engineer an aid in defining the Oconee Fire Protection Program. 3.2.2.1 The policy document shalldesignate the seniormanagementposition with immediateauthority and responsibilityfor the fire protectionprogram. The Site Vice President has the overall responsibility for the fire protection program at Oconee Nuclear Station. The daily programmatic administration of the fire protection program at Oconee is delegated through line management to the Fire Protection Engineer. Responsibility for the fire brigade and fire brigade training are delegated to the emergency planning and training groups respectively. Reference(s): Design Basis Specification for Fire Protection 3.2.2.2 The policy document shall designate a position responsible for the daily administrationand coordinationof the fire protectionprogram and its implementation. The Fire Protection Engineer has the overall lead responsibility forthe Fire Protection Program and its administration and coordination for all facilities that are important to nuclear safety or covered by the nuclear insurer. The fire protection engineer is experienced in nuclear fire protection and is qualified consistent with member grade status in the Society of Fire Protection Engineers. All other buildings are under the oversight of the Commodities and Facilities organization. Reference(s): Design Basis Specification for Fire Protection

Calculation No.: OSC-9295 Revision No.: *0 Applicable Units: Oconee Unit 1, 2, & 3 Page 12 of 84 3.2.2.3 The policy document shall define the fire protection interfaces with other organizationsand assign responsibilitiesfor the coordinationof activities. In addition, this policy document shall identify the variousplant positions having the authorityfor implementing the various areas of the fire protection program. Fire protection interfaces are defined in the Design Basis Specification for Fire Protection and the Engineering Support Program Document for Fire Protection. The positions having responsibilities and authority to implement portions of the fire protection program are described below. These positions were originally described in the ONS FRAQUA response and ONS Comparison to BTP 9.5-1 and have evolved since original publication. Fire Protection Engineer ............ Th-e--Fir-Proteii-Eh-gineer (FPE)-i isF-6iWfortheoverall- t r protection program. This individual may not directly control or be responsible for every aspect of fire protection, detection, or mitigation at Oconee; however the individual is required to be knowledgeable of each aspect. This individual will interface with each plant intemal and external customer regarding a fire protection concern. Fire Protection concerns can be regulatory, local or national code interpretations, insurance compliance, equipment configurations, equipment specifications, or industry issues. The fire protection program encompasses all structures, systems, and components important to plant and nuclear safety and those other structures, systems, and components covered by the nuclear insurer. The FPE is also the AHJ at the site level. Fire Protection Engineerinq Fleet Lead The Fire Protection Engineering Fleet Lead provides programmatic support (overall Department direction and policy in matters pertaining to Fire Protection and Appendix R safe shutdown) to the three Duke Energy site Fire Protection Engineers. This was formerly identified as Fire Protection Consultant. Fire Detection and Instrumentation Engineer The Fire Detection and Instrumentation Engineer responsibilities maybe divided among different individuals, if management thinks this is prudent. The person responsible for fire detection and/ or instrumentation will respond to all questions and system operations concerning operational characteristics, commitments, and regulatory requirements. This person(s) will interface with plant craft personnel, the fire protection engineer, and other internal and external customers. The fire detection and instrumentation engineer is also responsible for keeping the FPE notified of major system problems. Service Water System Engineers (HPSW, LPSW, and CCW) The service water system engineers are responsible for notifying the FPE of any problem on their system that will affect the performance of the fire protection systems. The divisions of

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 13 of 84 hydraulic responsibilities among the various engineers are that main flow paths are the concerns of the individual system engineers and the portion of the piping that is specifically designed to support fire fighting and/ or suppression are responsibilities of the FPE. There are instances where both individuals may need to combine input to problem resolution techniques. Standby Shutdown Facility (SSF) Engineer This person is responsible for interfacing with the FPE to ensure the 10 CFR50, Appendix "R" commitments are maintained within compliance. Fire Brigade Specialist This person currently resides in Emergency Planning. They are responsible for the preparedness, readiness, training, and coordination of all drill exercises for the site fire brigade members. The FPE assists the Fire Brigade Specialist in drill preparation, location, expectations and in drill response observations. The FPE is responsible for assisting in the maintenance of ______ - -the-P-re-Fire--P-lan,-which-is-owned-by-the-Fire-Brigade-Specialist* --------------------- Facilities and Maintenance Coordinator This person works for Corporate Facilities. They are responsible for the fire protection features associated with those structures on Oconee Nuclear site that do not contain structures, systems, and components that are important to nuclear safety and/or covered bythe nuclear insurer. This person also manages those individuals directly or indirectly that perform some of the preventative maintenance programs on fire hoses, extinguishers, detection and suppression systems, and misc. equipment repair. Operations, Radwaste, SPOC and Plant Maintenance These plant organizations are responsible for the daily general plant maintenance, testing, and inspection of fire protection systems located within the Protected Area.. Environmental Management Chemical Control Coordinator This person is responsible for identifying to the fire protection engineer any new chemicals allowed on-site that would increase the combustible/flammable loading while the product is "In-Use" or in storage. Site Personnel Fire prevention is a concern of all individuals on site. Each person shall notify the Control Room via the emergency number (4911) of any fire. Plant personnel should use normal plant communications to ensure notification to the fire protection engineer or appropriate group of any fire protection feature impairment, unsafe combustible/flammable loading, or suspected fire equipment damage.

Calculation No.: 6SC-9295 j?,evision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 14 of 84 Fire Protection Workinq Group This team is comprised of each nuclear site's fire protection engineer, the fire brigade specialist from each site and fire protection engineering fleet lead. The Fire Protection Working Group's major goals are communication and team effort on common problems. The Working Group constantly reviews practices, methods, and results to achieve a direct impact on the quality of work practices. Post-Fire Safe Shutdown Engineer This was formerly identified as Appendix R Engineer. The purpose of the Post-Fire Safe Shutdown Engineer is to evaluate the effect of plant mods, failures, and configuration changes on the ability to safely shutdown the plant in the event of a fire. 3-Site Post-Fire Safe Shutdown Enqiineer This was formerly identified as 3-Site Appendix R Engineer. The purpose of the 3-Site Post-Fire Safe Shutdown Engineer is to promote consistency in thought and share resolution of issues which may impact the ability to safely shutdown the plant in the event of a fire.

References:

Design Basis Specification for Fire Protection Engineering Support Program Document for Fire Protection 3.2.2.4 The policy document shall identify the appropriateAHJ for the various areas*of the fire protectionprogram. The NRC is the considered AHJ for fire protection changes requiring approval. The NRC is notified of changes to the Fire Protection Program in accordance with NSD-320. NSD-320 screens changes to the Fire Protection Program to determine if NRC approval is required.. {Further Action Required - Revise the Design Basis Specification for Fire Protectionwhich is the primary fire protection program policy document to state the NRC is the AHJ for fire protection changes requiring approval.}

References:

NSD-320 "Guidance for Performing Licensing Review of Proposed Changes to the Fire Protection Program" 3.2.3 Procedures Proceduresshallbe establishedfor implementationof the fire protectionprogram.In addition to procedures that could be requiredby other sections of the standard,the procedures to accomplish the following shall be established:

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 15 of 84 (1) Inspection, testing, and maintenance for fire protection systems and features creditedby the fire protectionprogram Inspection, testing, and maintenance (ITM) for fire protection systems is provided for the following systems. A brief description of the fire protection system and applicable ITM criteria is provided below from the Engineering Support Program Document for Fire Protection. Detailed listings of the applicable surveillance procedures are documented in the Engineering Support Program Document rather than being repeated here. System Components/Test/Notes Frequency Fire Main Main line HPSW system valves and those Monthly System valves used for fire protection check Fire hydrants and Post Indicator Valves Semi-Annual stroked test and flush

        -..-......-           Fire-water-system-flow-test-            -------    -Every--three-years----

Elevated Water Storage Tank (EWST) Every 5 years inspection Automatic Various fire suppression systems are tested Varies based on system Suppression in accordance with NFPA Requirements, Systems except for those systems which could potentially cause inadvertent adverse plant power production interruptions and/or personnel or reactor safety consequences Carbon Carbon Dioxide (Cardox) extinguishing Monthly and semiannual Dioxide system inspection and maintenance basis Extinguishing Systems Halon Vault Halon extinguishing system inspection Annual Extinguishing and maintenance Systems Fire Main plant fire detection panel is monitored Once per shift Detection Fire detection panel and Honeywell Monthly Systems detectors check Accessible fire detectors physical check Semi-annual Detector sensitivity check Annual Standpipe Fire hose inspection Monthly Systems Hose hydro test Hoses considered to be influenced by the environment annually; all others on a 3 year schedule Fire hose in containment inspection Refueling outage or at any time the building is open for

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 16 of 84 System Components/Test/Notes Frequency more than 30 days during a cycle Portable Fire Fire extinguisher check Monthly Extinguishers Fire extinguisher inspection Annually Carbon Dioxide and Dry Chemical 6 year extinguisher hydro Fire Pumps The HPSW pumps are currently tested to The NFPA requirement is both NFPA and ASME Section X1 monthly and the ASME requirements because these pumps serve a requirement is quarterly dual function Fire Brigade Fire brigade equipment inspection and Quarterly Equipment maintenance Fire Barriers Penetration seal and fire stop inspection 1. Ten percent of each type of and NRC committed fire barrier Penetration penetration seal every 18 Seals months with all seals within 15 years

2. 100% of the exposed surface of each rated barrier every 18 months Fire Doors Fire door inspection Bimonthly Fire Fire damper inspection 1. Ten percent of the NRC Dampers committed fire dampers every 18 months with all fire dampers within 15 years

2. Electrically controlled fire dampers that use sensors to close in the cable and equipment rooms annually Reference(s): Engineering Support Program Document for Fire Protection Design Basis Specification for Fire Protection (2) Compensatory actions implemented when fire protection systems and other systems creditedby the fire protectionprogramand this standardcannotperform their intended function and limits on impairment duration Fire protection systems credited for the fire protection program are documented in the

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 17 of 84 Oconee Selected Licensee Commitments (SLCs) 16.9.1 through 16.9.6. The Selected Licensee Commitments include inspection and testing requirements for those fire protection systems and features which are committed to be functional. SLCs also specify remedial actions to be taken in the event that a system or feature is inoperable. Directions for compensatory actions when systems credited by the fire protection program are not operable are provided in the SLC 16.9.1 through 16.9.6, NSD 316 and S.D. 3.2.14. These documents provide the roadmap and direction to be taken in the event a system is impaired. NSD-316, "Fire Protection Impairment and Surveillance" provides the requirements and responsibilities for reporting fire protection feature impairments and ensures proper compensatory actions are satisfied for licensing, insurance and good fire protection practices. Impairments include any action or condition which inhibits any fire protection feature to function as designed. Compensatory actions are the steps taken to minimize the fire risk potential due to a fire protection feature impairment such as staging backup suppression, temporary fire detection, fire watch tours, etc. This

        ...............--------

................. directive-provides-the-directions-and-requirements-to-notiy -the-fire-brigade-of-any-fire-impairment to ensure restoration of impaired features occurs in a timely manner. This directive applies to all fire protection features in the owner controlled area, and to all work groups that impair fire protection features. Oconee Nuclear Site, Site Directives Manual S.D. 3.2.14 "Fire Protection Program Compensatory Measures Process," assigns responsibilities for actions and provides direction, including process charts, for actions to be taken when a fire protection component or system is not operable. The Site Directive also provides a table that lists fire protection program components, any associated Technical Specification or Selected Licensee Commitment (SLC) and the actions to be implemented if that component is impaired. Reference(s): NSD-316 "Fire Protection Impairment and Surveillance" S.D. 3.2.14 "Fire Protection Program Compensatory Measures Process" SLC 16.9.1, .2,.3,.4,.5, .6 (3) Reviews of fire protectionprogram- relatedperformance and trends Reviews of the Fire Protection Program are conducted on a routine basis to evaluate performance and determine if any trends exist. The scope and responsibilities for those reviews are listed in Section 6.1 "Parameter Monitoring and Trending" of the Engineering Support Program Document for Fire Protection. The results of the reviews are provided in an annual Fire Protection Program Heath Report. Inaddition, internal 3-year audits and 3-year NRC triennial audits are performed. Reference(s): Engineering Support Program Document for Fire Protection

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1,2, & 3 Page 18 of 84 EDM-201 "Engineering Support Program" (4) Reviews of physical plant modifications and procedurechanges for impact on the fire protectionprogram All physical plant modifications and procedure changes are screened forthe impact on the fire protection program. NSD-301 "Engineering Change Program" provides the requirements for changes to a nuclear facility. A table is provided for a screening process for potential Fire Protection System impacts. Engineering Design Manual (EDM) 601 "Engineering Change Manual" provides

      ........................ e aied inrmatio n-to-b~elp-thbe-re~v~ie~w~er-determine-if-the-change-has-tbe-po-tetntial-to--

impact any fire protection feature. The manual specifies the requirements for changes, permanent and temporary, to the nuclear station. The manual specifies the roles and responsibilities for involved personnel and is applicable to both QA and non-QA structures, systems and components (SSC) and includes the Keowee facility. An extensive screening checklist for fire protection features is provided. In addition, a PRA Impact Review and a Fire Protection (1 CFR50.48) Electrical Review is required. Reference(s): NSD-301 "Engineering Change Program" EDM-601 "Engineering Change Manual" (5) Long-term maintenanceand configurationof the fire protection program The fire protection program is maintained through NSD-106. NSD-106 "Configuration Management" provides the basis for ensuring that Fire Protection Program and its features are properly maintained. Appendix A.106 "Functional Areas for Configuration Management" includes Fire Protection/Appendix R in the listing of Key Processes that are required to be considered to maintain the facility design consistent with the licensing bases and other design bases. NSD-228 "Applicability Determination", Appendix E includes a specific screening checklist that will direct user to NSD-320 "Guidance for Performing Licensing Review of Proposed Changes to the Fire Protection Program" to determine impact on the Fire Protection Licensing basis. The NRC approved the ONS Units 1, 2, 3 Operating Licenses in a letter transmittal

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 19 . of 84 dated May 23, 2000 and the associated License Renewal SER. Oconee Units 1, 2 and 3 are licensed to operate until 2033. In order to obtain license renewal, detailed guidelines and commitments were provided to ensure fire protection functions are maintained during the period of extended operation. In the letter, the following was stated regarding the fire protection program: "Duke Energy Corporation shall implement and maintainin effect allprovisions of the approvedfire protectionprogram as describedin the UFSAR for the facility andas approvedin the SER's dated August 11, 1978, andApril28, 1983; October5, 1978, andJune 9, 1981 Supplements to the SER dated August 11, 1978; and Exemptions dated February2, 1982; August 31, 1983; December27, 1984; December 5, 1988; and August 21, 1989 subject to the following provision: The licensee may make changes to the approved fire protection program without prior approvalof the Commission only if those changes would not adversely affect the ability to achieve and maintainsafe shutdown in the event of a fire." Reference(s): NSD-1 06 "Configuration Management' NSD-228 "Applicability Determination" NRC Letter to Duke dated May 23, 2000 NRC SER dated May 23, 2000 (6) Emergency responseprocedures for the plant industrialfire brigade The Emergency Planning Group oversees the Plant Fire Brigade, training and procedures. The Fire Plan (pre-fire plan) includes Fire Brigade Standard Operating Guidance (SOG) for various emergency responses. The Fire Brigade is provided the Fire Plan which details the potential hazards and the available fire fighting equipment for the plant along with a graphic representation of the layout of the area. Additional details on the Fire Brigade are presented in Section 3.4. The coordination between the Fire Brigade and other plant groups during a fire emergency is defined in NSD-1 12. When the Control Room is notified of a fire, Procedure RP/O/B/1 000/029 "Fire Brigade Response" is implemented. The procedure instructs the control room personnel on their response and provides' direction on managing the conduct of the fire fighting activities including contacting offsite Fire Departments. Reference(s): Oconee Nuclear Site Fire Plan NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" RP/O/B/1 000/029 "Fire Brigade Response"

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1,2, & 3 Page 20 of 84 Section 3.3 Prevention A fire preventionprogram with the goal of preventinga fire from startingshall be established, documented, and implemented as part of the fire protection program. The two basic components of the fire prevention programshall consist of both of the following: (1) Prevention of fires and fire spreadby controls on operationalactivities (2) Design controls that restrictthe use of combustible materials The design control requirementslisted in the remainder of this section shall be provided as described. The Oconee Nuclear Station (ONS) fire prevention program is described in the Design Basis Specification for Fire Protection. The Design Basis Specification for Fire Protection identifies activities for fire prevention and design controls for use of combustible materials.

                                                                                              .............----.---
     . . . . .. . . Referenee(s)--Design-Basis--Specification-for--Fire-Protection ---..................----           .

3.3.1 FirePrevention for OperationalActivities The fire prevention programactivities shall consist of the necessaryelements to address the controlof ignitionsources and the use of transientcombustible materialsduringall aspects of plant operations. The fire prevention program shall focus on the human and programmatic elements necessary to prevent fires from starting or, should a fire start,to keep the fire as small as possible. As part of defense-in-depth, administrative fire prevention programs for hot work, storage of combustibles and flammable material, compensatory action plans, safety precautions and employee training contribute to limit fire ignition and/or growth and ONS. Fire prevention programs are implemented to address the control of ignition sources and the use of transient combustible materials and plant access training includes instruction on fire prevention during General Employee Training (GET). Reference(s): General Employee Training - Plant Access Training NSD-104, "Housekeeping, Materiel Condition, and Foreign Material Exclusion" NSD-313 "Control of Flammable and Combustible Materials" NSD-314 "Hot Work Authorization" NSD-316 "Fire Protection Impairment and Surveillance" 3.3.1.1 General Fire PreventionActivities The fire prevention activitiesshallinclude but not be limitedto the following programelements: (1) Trainingon fire safety informationfor all employees andcontractorsincluding,as a minimum, familiarizationwith plant fire prevention procedures,fire reporting,andplant emergency alarms.

Calculation No.: OSC-9295 Revision No.:. 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 21 of 84 The prevention of fires and fire spread are managed through administrative controls and training of personnel. All persons who are authorized access to the plant receive instruction in maintaining fire barriers, controlling fire loading and hot work activities, plant emergency alarms, and the proper response to the discovery of a fire. Reference(s): General Employee Training - Plant Access Training NSD-313 "Control of Flammable and Combustible Materials" NSD-314 "Hot Work Authorization" NSD-316 "Fire Protection Impairment and Surveillance" (2) Documented plant inspections including provisions for corrective actions for conditions where unanalyzed fire hazards are identified. The responsibilities of the Fire Protection Engineer include periodic surveillance of plant areas for compliance with the Fire Protection Program. Plant Engineers, including the FPE, perform plant walkdowns in accordance with Procedure EM 4.6 "Oconee Engineering Support Program Walkdowns" which provides guidance on observations that should be made including fire hazards. Any unanalyzed fire hazards are documented in the PIP program. Plant inspections may be performed by other groups as delegated by the FPE on other frequencies. Reference(s): EM 4.6 "Oconee Engineering Support Program Walkdowns" Engineering Support Document for Fire Protection (3) Administrative controls addressing the review of plant modifications and maintenance to ensure that both fire hazards and the impact on plant fire protection systems and features are minimized. All plant modifications and changes are screened for impact on the plant fire protection program through NSD-301, NSD-228, and/or EDM-601. NSD-301 "Engineering Change Program" provides the requirements for evaluation of changes to a nuclear facility. A table is provided for a screening process for potential Fire Protection System impacts. NSD-228 "Applicability Determination", Appendix E includes a specific screening checklist that will direct user to NSD-320 "Guidance for Performing Licensing Review of Proposed Changes to the Fire Protection Program" to determine impact on the Fire Protection Licensing basis.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 22 of 84 Engineering Directives Manual (EDM) 601 "Engineering Change Manual" provides detailed information to help the reviewer determine ifthe change has the potential to impact any fire protection feature. The EDM specifies the requirements for changes, permanent and temporary, to a nuclear station. The Manual specifies the roles and responsibilities for involved personnel and is applicable to both QA and non-QA structures, systems and components (SSC) and includes the Keowee facility. An extensive screening checklist for fire protection features is provided. In addition, a PRA Impact Review and a Fire Protection (10CFR50.48) Electrical Review is required. Reference(s): NSD-228 "Applicability Determination" NSD-301 "Engineering Change Program" NSD-320 "Guidance for Performing Licensing Review of Proposed Changes to the Fire Protection Program" EDM-601 "Engineering Change Manual" 3.3.1.2 Control of Combustible Materials Procedures for the control of general housekeeping practicesand the control of transient combustibles shall be developed and implemented. Control of combustible materials at ONS is implemented through NDS-313, NSD-104 and EWP 7.2. The control of combustible materials:is implemented by NSD- 313 "Control of Flammable and Combustible Materials." Control of housekeeping and the amount of material that is taken into the plant is implemented by NSD-104 "Housekeeping, Materiel Condition & Foreign Material Exclusion" which promotes cleanliness and limits the amount of combustible/flammable material. EWP 7.2 "Storing Chemicals" provide specific storage requirements for control of chemicals (including flammable and combustible liquids and gases). Reference(s): NSD-1 04 "Housekeeping, Materiel Condition, and Foreign Material Exclusion" NSD-313 "Control of Flammable and Combustible Materials" EWP 7.2 "Storing Chemicals" These proceduresshall include but not be limited to the following program elements: (1) Wood used within the powerblock shall be listed pressure-impregnatedor coated with a listed fire-retardantapplication. Exception: Cribbingtimbers 6 in. by 6 in. (15.2 cm by 15.2 cm) or largershall not be required to be fire-retardanttreated.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 23 of 84 NSD-313 requires only fire retardant wood be used within the power production and safe shutdown areas unless approval is obtained from the FPE. Three exceptions are allowed; dunnage (large timbers) for specific work activities, concrete forming, and where specified on design documents. {Submit for NRC Approval - NFPA 805 only permits fire retardant treated wood or dunnage. NSD-313 permits concrete forming or per design documents.} Reference(s): NSD-313 "Control of Flammable and Combustible Materials" (2) Plasticsheeting materialsused in the power block shallbe fire-retardanttypes that have passed NFPA 701, StandardMethods of Fire Tests for Flame Propagationof Textiles and Films, large-scale tests, or equivalent. NSD-313 specifies that only fire resistant plastic (i.e. Griffolyn) be used within the power production and safe shutdown areas. {Area for Improvement - Revise NSD-313 to specifically address plastic sheeting materials shall conform to NFPA 701 requirements, or equivalent.} Reference(s): NSD-313 "Control of Flammable and Combustible Materials" (3) Waste, debris, scrap,packing materials,or other combustibles shall be removed from an area immediately following the completion of work or at the end of the shift, whichever comes first. NSD-1 04 "Housekeeping, Materiel Condition, and Foreign Material Exclusion" provides direction on maintaining the cleanliness of the plant. The Directive discusses Housekeeping Zones which specify the level of cleanliness for various areas and states that "Upon completion of the maintenance activity, the work supervisor or designee shall ensure the Housekeeping Zone is returned to at least its original condition." The Directive specifies that"During outage work, the Job Sponsorworking with the supervisor for the crew will ensure the work area is returned to a normal or better state of appearance once work is complete." NSD-313 "Control of Flammable and Combustible Materials" provides the following requirements for in-use materials: "At the end of each shift, housekeeping zones/work areas shall be cleared of all unnecessary materials and all waste/trash material removed and properly disposed." Reference(s): NSD-104 "Housekeeping, Materiel Condition, and Foreign Material Exclusion"

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 24 of 84 NSD-313 "Control of Flammable and Combustible Materials" (4)- Combustible storage or staging areas shall be designated,and limits shall be establishedon the types and quantities of stored materials. Control of combustible materials is implemented through NSD-104 "Housekeeping, Materiel Condition, and Foreign Material Exclusion." Combustible Material storage and staging areas are specified in NSD-313. The directive discusses the temporary and permanent storage of the various types of combustible materials and provides the Oconee site specific details. The FPE approves the material inventory (limit) for the area and the amount of material can not be changed without approval of the FPE. Changes to the storage restrictions require completion of a change form and approval by the FPE.

           ........ Reference(s).:-NSD--04--'Housekeeping,,-Materiel -Condition,.-and.-Foreign-Material-Exclusion" NSD-313 "Control of Flammable and Combustible Materials" (5) Controls on use and storage of flammable and combustible liquids shall be in accordance with NFPA 30, Flammable'and Combustible Liquids Code, or other applicableNFPA standards.

The controls on the use and storage of flammable and combustible liquids are specified in NSD-313. NSD-313 referencesNFPA 30 as a source document for use and storage of flammable and combustible liquids. EWP 7.2 provides specific storage requirements for control of chemicals (including flammable and combustible liquids) and references NSD-313. Reference(s): NSD-313 "Control of Flammable and Combustible Materials" EWP 7-2 "Storing Chemicals" (6) Controls on use and storage of flammable gases shall be in accordance with applicableNFPA standards. The controls on the use and storage of flammable gases are specified in NSD-313. NSD-313 references NFPA 55 and OSHA as source documents for use and storage of flammable gases. EWP 7.2 provides specific storage requirements for control of chemicals (including flammable gases) and references NSD-313. Reference(s): NSD-313 "Control of Flammable and Combustible Materials" EWP 7-2 "Storing Chemicals"

Calculation No.: I OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 25 of 84 3.3.1.3 Control of Ignition Sources 3.3.1.3.1 A hot work safety procedureshall be developed, implemented, and periodicallyupdated as necessary in accordance with NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, and NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations. NSD-314 "Hot Work Authorization" specifies the controls for performing hot work and the responsibilities of the persons authorizing and performing the activity. The directive requires inspections of the locations by trained personnel prior to hot work activity to ensure that there are no fire hazards present. There are Special Precautions from the FPE and EH&S for various situations that require additional levels of review and approval for granting a Hot Work Permit. NFPA 51 B is a source document to NSD-314. NSD-314 is periodically updated. ONS has not identified NFPA 241 as a NFPA code of record. In addition, NFPA 241 references NFPA 51 B with regards to the requirements for administration of Hot Work. [Area for Improvement - Evaluate NSD-314 to determine if NFPA 241 should be referenced.} Reference(s): NSD-314 "Hot Work Authorization" 3.3.1.3.2 Smoking and otherpossiblesources of ignition shallbe restrictedto properly designatedand supervisedsafe areas of the plant. Ignition sources including smoking are restricted to designated areas or controlled through a permitting process. NSD-104 restricts the use of smoking and tobacco products to areas clearly posted as a tobacco use area and provides approved receptacles for waste. NSD-314, Hot Work, specifies controls of ignition sources typically associated with hot work including permitting and designation of areas where a permit is not required. Reference(s): !NSD-104 "Housekeeping, Materiel Condition, and Foreign Material Exclusion" NSD-314 "Hot Work Authorization" 3.3.1.3.3 Open flames orcombustion-generatedsmoke shallnot be permittedfor leak orairflow testing.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 26 of 84 The Duke response to Appendix A to BTP 9.5-1 states "Open flames or combustion generated smoke is not permitted at ONS for leak or air flow testing. Leak and air flow determinations are accomplished by using commercially available aerosol or soap bubble techniques. Candles may be permitted for search of secondary system condenser vacuum leaks. The secondary system condenser is removed from safety related equipment." 1978 SER Section 6.5 states "Use of open flames or combustion generated smoke for leak detection in safety-relatedareas has been prohibited. We find that the control of ignition sources conform to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable." {Further Action Required - Revise the appropriate station procedure(s) for leak or air flow

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Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 NRC SER dated August 11, 1978 3.3.1.3.4 Plantadministrativeprocedureshall control the use of portable electricalheaters in the plant. Portablefuel-fired heatersshallnot be permittedin plant areascontainingequipment important to nuclear safety or where there is a potential for radioi~gicalreleases resulting from a fire. The use of portable heating devices is controlled by NSD-316 "Fire Protection and Impairment Surveillance." The Directive defines a heating device as "A temporary heater that uses greater than or equal to 220 Volts or is powered by a fossil fuel source and is used to heat a general area, enclosure or equipment." Site personnel are responsible for notifying the FPE of any intended use of a heating device(s). Site Directive 3.2.14 provides a flow chart for measures to take when temporary heaters are installed. This includes consideration of location and risk. The group that requests the placement of the temporary heating device shall be responsible to ensure that fire watches are initiated. A passive fire watch shall be conducted at least once every six (6) hours but may be more frequent if determined by the FPE. Fire watches shall be documented by use of the Impairment and Compensatory Measures (ICM) Form in NSD-316. NSD-316 specifies only steam heaters, UL Listed or FM Approved electric heaters, gas (MAPP, LP, or natural) or oil-fired heaters shall be allowed inside buildings. Gasoline and other fuels are not permitted unless approved by the. FPE.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 27 of 84 (Submit for NRC Approval - S.D. 3.2.14 and NSD-316 permit fossil fuel (gas and oil-fired) heaters.} Reference(s): NSD-316 "Fire Protection and Impairment Surveillance." S.D. 3.2.14 "Fire Protection Program Compensatory Measures Process" 3.3.2 Structural Walls, floors, and components required to maintain structural integrity shall be of noncombustible construction, as defined in NFPA 220, Standard on Types of Building Construction. Oconee is designed to minimize the probability of fire and explosion. Non-combustibles and

         -ire-r- is-fntmatn* a- 1A*~

iii~w r -ed-f --*pr i l-iroughout-te-ef~lfj The Reactor Building is built using fire resistive construction. The outside walls of the Reactor Building are post-tensioned concrete for the three reactor structures. The roof and supports are also post-tensioned concrete for the three reactor structures. Interior partition walls are concrete containment or shield type walls between reactor, steam generators, coolant pumps, etc. Floors and supports are concrete on grade and various mezzanine levels are supported by concrete beams. The Auxiliary Building is a free standing reinforced concrete strcture composed of concrete frames, slabs, and walls and non-structural masonry walls. Thefacility has exterior walls that are reinforced concrete with fire resistive construction. Interiorl partition walls are mainly concrete with portions of concrete block. The roof and supports are approved insulated roofing on concrete slab supported on concrete members. Floors and supports are concrete slab on concrete members. The Turbine Building is constructed of reinforced concrete below grade consisting of substructure walls and a mat foundation. Above grade, the building consists of structural steel with metal siding. The steel roof deck is supported by unprotected steel frame. Exterior walls are noncombustible, insulated aluminum siding on unprotected steel frame with concrete at lower levels below grade. Interior walls are reinforced concrete and concrete block. Reference(s): Design Basis Specification for Fire Protection 3.3.3 InteriorFinishes Interiorwall or ceilingfinish classificationshallbe in accordancewith NFPA 1010, Life Safety CodeQ,requirementsfor Class A materials.Interiorfloor finishes shall be in accordancewith NFPA 101 requirements for Class I interiorfloor finishes.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 28 of 84 The Duke Comparison to BTP 9.5-1 letter and the UFSAR Section 9.5.1.4.1.4 state "Interior wall, structural components and radiation shielding are non-combustible. Coatings are non-combustible with flame spread and fuel contribution of 50 or less." NSD-318 "Coatings Program" controls the use of coatings and requires approval for any changes. Records of coating applications are required to be maintained. {Further Action Required - Revise NSD-318 to include the specifications for Class A. walls/ceilings and Class I floor finishes or include in an alternative administrative control document.} Reference(s): NSD-318 "Coatings Program" S ESARS ection9.5.. ................ .. .. ......... . . .. . Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 3.3.4 Insulation Materials Thermal insulation materials, radiation shielding materials, ventilation duct materials, and soundproofing materialsshallbe noncombustible or limited combustible. The thermal insulation materials used in the power production plant are non-combustible Specifications OSS-0241-00-00-002 and OSS-0241.00-00-0004 state thermal insulation materials are metal reflective type (mirror), calcium silicate, Armaflex, fiberglass and basaltic rock. These insulations are all classified as non-combustible or limited combustible materials. Any new insulation materials would require a screening determination in accordancewith EDM-601 "Engineering Directives Manual." Part of the screening process is an evaluation of the potential effects on the Fire Protection Program which would require the use of noncombustible or limited combustible materials. Reference(s): Specification OSS-241.00-00-0004 "Conventional Thermal Insulation" Specification OSS-241.00-00-0002 "Reactor Building and Piping Heat Insulation (Metal Reflective Type) EDM-601 "Engineering Directives Manual" 3.3.5 Electrical 3.3.5.1 Wiring above suspended ceilingshall be kept to a minimum. Where installed,electricalwiring

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 29 of 84 shall be listedfor plenum use, routed in armoredcable, routedin metallic conduit, or routed in cable trays with solid metal top and bottom covers. The Duke Comparison to BTP 9.5-1 letter and the UFSAR Sections 9.5.1.4.1 and 9.5.1.4.3 state "Suspended ceilings and their supports are non-combustible. Combustibles in concealed spaces are minimal. There are no power and control cables in the Control Room concealed floor or ceiling space except for miscellaneous 120V power and network cables inthe ceiling space supplying small OAC computer room equipment." {Further Action Required - Include clear documentation that electrical wiring (including data/phone/video cabling) is installed above suspended ceilings the wiring complies with this section.} Reference(s): Response to Appendix Ato Branch Technical Position APCSB 9.5-1, February UFSAR Section 9.5.1.4.1 and Section 9.5.1.4.3 Design Basis Specification for Fire Protection 3.3.5.2 Only metal tray and metal conduits shall be used for electrical raceways. Thin wall metallic tubing shall not be used for power, instrumentation, or control cables. Flexible metallic conduits shall only be used in short lengths to connect components. The Duke Comparison to BTP 9.5-1 and the UFSAR Section 9.5.1.4.3 state "Cable trays are constructed of non-combustible materials." The Design Basis Specification for Fire Protection states "Cable trays are constructed of steel with all supports attached to QA condition 1 or 4 structures." {Further Action Required - Include clear documentation that conduits used for electrical raceways are metal and thin walled metallic tubing is not used in accordance with this section.} Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 UFSAR Section 9.5.1.4.3 Design Basis Specification for Fire Protection 3.3.5.3 Electric cable construction shall comply with a flame propagationtest as acceptable to the AHJ.

'Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 30 of 84 The IEEE 383 Standard was developed after Oconee cables were was installed, however, the same cable construction has been used at a later plant and was found acceptable under IEEE 383. The NRC August 11, 1978 SER Section 4.8 states "The cable insulation used in the plant consists of armored ethylene propylene rubber (EPR) of 5-8 KV cables with a polyvinyl chloride (PVC)jacket, armoredEPR with hypalon or neoprenejacket outside containmentand armored EPR with hypalon jacket, some with a PVC jacket overall, for inside containment. The majority of cables at Oconee are of the metallic armored type. The IEEE standardwas not in effect at the time the plant was constructedand therefore the cables were not required to meet IEEE 383. The licensee has stated,however, that the same cable construction has since been used at a laterplantwhere the IEEE 383-1971 criteriawere imposedand the cable was acceptable. We find that to retest the IEEE 383 procedureand criteriais unnecessary and would not provide information that would alter our recommendation or conclusions. Accordingly we find the electricalcables used at the Oconee Nuclear Station acceptable." (Further Action Required - Revise station documentation that non-rated cables (including data/phone/video) shall not be routed in cable trays with nuclear safety related cables.} Reference(s): NRC SER dated August 11, 1978 3.3.6 Roofs Metal roof deck construction shall be designed and installedso the roofing system will not sustaina self-propagatingfire on the undersideof the deck when the deck is heated by a fire inside the building. Roof coveringsshallbe ClassA as determinedby tests describedin NFPA 256, StandardMethods of Fire Tests of Roof Coverings. The Auxiliary Building, Reactor Building and SSF do not utilize metal roof deck construction. The Turbine Building has metal roof deck construction. The Design Basis Specification for Fire Protection Section 3.2.2.1.1.1 states 'The roofwas constructedin accordance the Kopper Company's Specification No. 17 and is therefore considered to be in accordance with FM Class 1. In 1985, the Turbine Building roof was re-roofed in accordance with Underwriter's LaboratoriesClass A single ply roof system. "FireRating of OS- 159.00-00-0002"states all materials of construction are specified to be selected under FM Approval Guide at non-combustible. It is concluded that the Turbine Building built up roof decking assembly is FM Approval Guide Classification 1, through not specifically statedin the specification." The Duke Corporate Roof Program specifies new roofs shall be in compliance with FM-1 90 which indicates a FM Class I fire resistant roof is required. A FM Class I roof is equivalent to a NFPA 256 Class A roof classification. Reference(s): Design Basis Specification for Fire Protection

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 31 of 84 Duke Corporate Roof Management Program 3.3.7 Bulk Flammable Gas Storage Bulk compressed or cryogenic flammable gas storage shall not be permittedinside structures housing systems, equipment, or components important to nuclearsafety. The Design Basis Specification for Fire Protection, Duke Comparison to BTP 9.5-1 letter and UFSAR Section 9.5.1.4.3 state "There is no bulk gas storage in areas affecting safe shutdown equipment." The storage of combustible and flammable materials is controlled by administrative procedures (NSD-313, EWP 7.2). General provisions for the use and storage of chemicals, including gases, are controlled by NSD-116 "Nuclear Chemical Control Program." . . . .. . . . . . . . . .. . . ... . ... . ....

                                                . . . . . . . .. . . . .... - - .... .... .... ........ ..... ........ . . .. . . .. . . . ..  . . . . . ... .... .... .. . .

Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 UFSAR Section 9.5.1.4.3 NSD-1 16 "Nuclear Chemical Control Program." Design Basis Specification for Fire Protection EWP 7.2 "Storing Chemicals" 3.3.7.1 Storage of flammable gas shallbe located outdoors,orin separatedetached buildings,so that a fire orexplosion will not adverselyimpact systems, equipment, or components importantto nuclearsafety. NFPA 50A, Standardfor Gaseous HydrogenSystems at ConsumerSites, shall be followed for hydrogen storage. Bulk storage of Hydrogen Gas is stored in the northeast yard area. There is also a propane storage tank adjacent to the Unit 1 Transformer area. These storage tanks are located outdoors and away from the SSCs important to safety. NSD-313 "Control of Combustible and Flammable Materials" provided restrictions on the storage location of combustible materials with specific restrictions for the Oconee Plant. Any changes, to the amount of materials or the storage location of materials, require review and approval from the FPE and EWP. The chemical control program, which is administered in accordance with NSD-1 16, ensures compliance with applicable regulations and requirements including NFPA Codes. Any changes to the bulk storage of combustible/flammable gases would require authorization in accordance with both NSD-1 16 and NSD-313.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 32 of 84 {Further Action Required - Perform a code compliance review for the outdoor hydrogen storage per NFPA 50A.} Reference(s): NSD-1 16 "Nuclear Chemical Control Program" NSD-313 "Control of Combustible and Flammable Materials" 3.3.7.2 Outdoorhigh-pressureflammablegas storagecontainersshallbe located so thatthe long axis is not pointedat buildings. The bulk hydrogen storage cylinders are located with the long axis parallel to the buildings in the northeast corner of the yard. A propane storage tank is oriented with its long axis toward the Unit 1 Turbine Building. The Design Basis Specification for Fire Protection, Duke Comparison to BTP 9.5-1 letter and UFSAR Section 9.5.1.4.3 state 'There is no bulk gas storage in areas affecting safe shutdown equipment." 1978 SER Section 3.1.7 states "Propanetanks located outside the turbinebuilding will be anchoredandprovided with excess flow valves." {Further Action Required - Resolve orientation of propane tank. The6tank is not anchored per the SER recommendation. Evaluate if the previous approval by the NRC is sufficient with modification: Alternatively, determine ifan evaluation is required or modify the tank position.} Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 UFSAR Section 9.5.1.4.3 NSD-1 16 "Nuclear Chemical Control Program" Design Basis Specification for Fire Protection NRC SER dated August 11, 1978 3.3.7.3 Flammablegas storagecylinders not requiredfor normal operationshall be isolatedfrom the system. The use and storage of combustible and flammable materials is controlled by NSD-313 and

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 33 of 84 EWP 7.2. NSD-313 and EWP 7.2 require Compressed Gas Cylinders not in use to be stored with their protective cap in place, adequately secured in an upright position and separated from other flammable/combustible and oxidizing agents. Bulk hydrogen cylinders located in the hydrogen storage areas that are not in use are isolated from the system. Reference(s): NSD-313 "Control of Combustible and Flammable Materials" EWP 7.2 "Storing Chemicals" 3.3.8 Bulk Storage of Flammable and Combustible Liquids Bulk storage of flammable and combustible liquids shall not be permitted inside structures containing systems, equipment, or components important to nuclearsafety. As a minimum, storage and use shall comply with NFPA 30, Flammable and Combustible Liquids Code. ---...--...- T-he-.storage--of-corm bustible.-and-flammable-materials--is-controlled-by-NSD=31.3.. NSD-313.--.--...-..-. states that Oconee is proactive in following the guidance of OSHA 29CFR1910 "Fire Protection" and lists NFPA 30-2000, "Flammable and Combustible Liquid Code," as a source document. Additional storage limitations are provided for warehouse storage within power production areas and for materials in the yard areas. The general provisions for the use and storage of chemicals are controlled by NSD-1 16 which requires authorization for changes to flammable and combustible liquid storage amounts or location. Although listed below for information the Safe Shutdown Facility (SSF) Diesel Generator day tank and the Turbine Lube Oil reservoirs, while located in structures containing systems, equipment or components important to nuclear safety, are part of the operating systems of the plant and are not considered bulk storage. The fuel oil for the SSF Diesel Generator is provided from a 50,000 gallon underground storage tank to a 550-gallon day tank that is located inside the SSF. The SSF is a Category I structure that is provided with an automatic, total flooding CO 2 system in the diesel generator room that houses the day tank. The SSF buried fuel oil storage tank located outside adjacent to the SSF structure. There are two aboveground fuel oil tanks (30,000 and 45,000 gallon) for the Auxiliary boiler that are located in the northeast yard. These tanks are located in a diked area and are a considerable distance from the actual power production facility. Gasoline, diesel fuel oil and kerosene are stored in underground tanks that are located at the site garage area. The tanks are located a significant distance (greater than 1,000 feet) from the actual power production facility. Turbine Lube Oil is located in the turbine building. The main turbine lube oil reservoir tanks are located in the basement level of each unit and have a capacity of 7,450 gallons. The turbine oil transfer tank and adjoining purifier units have a 14,000 gallon capacity, which is located under the operating floor. Each unit turbine oil transfer tank is arranged

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2. & 3 Page 34 of 84 within a four feet high concrete dike designed to hold the entire contents of respective tanks. The adjoining oil purifier unit is located outside of the dike area. The concrete block lubrication oil storage building, located in the lower level of the Unit 1 Turbine Building contains seven (7) steel tanks, each having a 200-gallon capacity. The storage area has a wet-pipe automatic suppression system, fire doors, and fire dampers in the ventilation openings. Keowee has a dedicated lube oil tank room. The storage room contains two 7,150 gallon tanks for storage of oil for the turbine generators. The room is protected by an automatic deluge sprinkler system. {Further Action Requried - Perform a NFPA 30 code review for the Turbine Building lube oil reservoirs, Turbine Building oil storage building and the Keowee lube oil tank room.} Reference(s): NSD-1 16 "Nuclear Chemical Control Program" NSD-313 "Control of Combustible and Flammable Materials" Drawing OFD-1 35A-01 -01 Design Basis Specification for Fire Protection 3.3.9 Transformers Where provided, transformer oil collection basins and drain paths shall be periodically inspected to ensure that they are free of debris and capable of performing their design function. The Main, Auxiliary and Safety Transformers for the three Oconee Units are located outdoors adjacent to their respective portions of the Turbine Building. Each of the transformers is provided with an automatic deluge system. The transformers are mounted on concrete pads within an earthen graveled area. There are no specific retention basins around the main transformers that are designed to retain and direct potential transformer oil leakage to a storage basin or tank. The ground and gravel system will absorb most of the runoff from fire mitigation activities in addition to the yard drain system directing excess flow to Chemical Treatment Pond (CTP) #3. CTP #3 is provided with oil skimmers. Transformer CT-4 is located in the Unit 1/2 Blockhouse. A concrete oil retention basin is provided under the Blockhouse. The Keowee Transformer is located outside on the West side of the hydro station and is provided with an automatic deluge system. The transformer is mounted on a concrete pad with a gravel bed similar to those discussed above.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 35 of 84 (Further Action Required - Revise station test procedures to include drainage inspections as part of the annual flow tests.) Reference(s): Engineering Support Document for Fire Protection Design Basis Specification for Fire Protection 3.3. 10 Hot Pipes and Surfaces Combustible liquids, including high flashpoint lubricating oils, shall be kept from coming in contact with hot pipes and surfaces, including insulatedpipes and surfaces.Administrative controls shall requirethe prompt cleanup of oil on insulation. NSD-104 addresses general housekeeping requirements that apply to all personnel

        -(pe7rmanýe-nt ~d-te-mp-dr-ary]th-ta -p-e*7r*&~-fftei~iti*s-atfth-e-pl--ft. Thl-*NSD-em-p5h--si2-es-tlf-lnt-areas should be clean and orderly with properly maintained work areas and equipment.

NSD-413 "Fluid Leak Management Program" was established to ensure aggressive identification of leaks followed by timely investigation and repair. The Leak Management Program encompasses all fluid leaks which may include high-energy process fluids steam, water, oil, hydraulic fluid, etc occurring throughout the Plant. {Area for Improvement - Revise NSD-104 and/or NSD-413 to clearly indicate it is a NRC requirement to promptly remove oil from insulation.} Reference(s): NSD-104 "Housekeeping, Materiel Condition & Foreign Material Exclusion" NSD-413 "Fluid Leak Management Program" 3.3.11 ElectricalEquipment Adequate clearance, free of combustible material, shall be maintained around energized electricalequipment. Placement of combustible materials that could be located near electrical equipment is controlled by NSD-1 04 and NSD-313. NSD-313 includes specific guidance on the location of transient fire loads adjacent to plant equipment susceptible to fire damage (e.g. electrical cabinets). (Further Action Required - Revise NSD-313 to specify the combustible free distance consistent with the PRA Zone of Influence for transients)

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1,2. & 3 Page 36 of 84 Reference(s): NSD-1 04 "Housekeeping, Materiel Condition & Foreign Material Exclusion" NSD-313 "Control of Combustible and Flammable Materials" 3.3.12 Reactor Coolant Pumps Forfacilities with non-inertedcontainments,reactorcoolantpumps with an externallubrication system shall be provided with an oil collection system. The oil collection system shall be designedand installedsuch that leakagefrom the oil system is safely contained foroff normal conditions such as accidentconditions or earthquakes.All of the following shall apply. (1) The oil collection system for each reactor coolant pump shall be capable of collecting lubricating,oil from all potentialpressuri.zed and nonpressurizedleakage sites in each reactorcoolant pump oil system. A lube oil collection system was installed for each of the Reactor Coolant Pumps (RCPs) at the Oconee Plant - each of the three units has four RCPs. The RCP oil collection systems are deig-n-ie a--d-ni-d--iz---d-ot--co-1*6-t-a-nf-d-6-o-ntihh-il-frc-o6t--tially-pressurized and unpressurized leakage areas in a seismic event resulting in failure of the lubrication system. The Reactor Coolant Pump (RCP) Lube Oil System for each reactor coolant pump contains approximately 250 gallons of oil in upper and lower tanks, self-contained within each RCP assembly. Reference(s): Duke Letter to the NRC dated March 18, 1981 Design Basis Specification for Fire Protection Letter Duke to NRC, PIP 0-99-2532/LER 270/1999-04, February 16, 2000 Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 (2) Leakage shallbe collected anddrainedto a vented closedcontainerthatcan hold the inventory of the reactorcoolantpump lubricatingoil system. Any potential leakage is collected and drained to a collection tank sized to accommodate the largest potential leak system inventory (250 gallons). The collection tanks are located in the basement of the Reactor Building. Reference(s): Duke Letter to the NRC dated March 18, 1981 (3) A flame arrestoris required in the vent if the flash point characteristicsof the oil present the hazardof a fire flashback. A flame arrestor is provided for each of the RCP oil collection tank vents.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 37 of 84 Reference(s): Duke Letter to the NRC dated March 18, 1981 (4) Leakage points on a reactorcoolantpump motor to be protectedshall include but not be limited to the lift pump andpiping, overflow lines, oil cooler,oil fill and drainlines andplugs, flangedconnections on oil lines, andthe oil reservoirs,where such features exist on the reactorcoolantpumps. Potential leakage points on the pump motor that are protected include the lift pump and piping, overflow lines, lube oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines and lube oil reservoirs. Reference(s): Duke Letter to the NRC dated March 18, 1981 (5) The collection basin drain line to the collection tank shall be large enough to accommodate the largestpotentialoil leak such that oil leakage does not overflow the basin. Potential leakage is collected and drained through an appropriately sized drain line into the collection tank. The collection tank is sized to accommodate the largest potential leak, the entire system inventory of 250 gallons. Reference(s): Duke Letter to the NRC dated March 18, 1981 Section 3.4 Industrial Fire Brigade 3.4.1 On-Site Fire-FightingCapability All of the following requirements shallapply. (a) A fully staffed, trained,and equipped fire-fighting force shall be available at all times to control and extinguish all fires on site. This force shall have a minimum complement of five persons on duty and shall conform with the following NFPA standardsas applicable: (1) NFPA 600, Standardon IndustrialFire Brigades (interiorstructuralfire fighting) (2) NFPA 1500, Standard on Fire Department Occupational Safety and Health Program (3) NFPA 1582, Standardon Medical Requirements for Fire Fightersand Information for Fire DepartmentPhysicians Oconee takes exception to the following sections of the aforementioned NFPA standards:

• NFPA 600 (2005) Chapter 4 Section 4.4, "Requirements for all Industrial Fire Brigades." ONS is structured differently than those described in this section. While all

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 38 of. 84 requirements are addressed they are not all the responsibility of the Fire Brigade Leader. NFPA 600 (2005) Chapter 4, Section 4.7 "Industrial Apparatus." ONS has no apparatus. NFPA 1500 and 1582 are not applicable to ONS per in their respective scope statements and consistent with FAQ 06-0007.

            "    NFPA 1500 (2007) Chapter 1 "Administration" Section 1.3.2 states 'This standard does not apply to Industrial Fire Brigades that might also be known as Emergency Brigades, Emergency Response Teams, Response Teams, Fire Teams, Plant Emergency Organizations, or mine emergency response teams."
            "    NFPA 1582 (2007) Chapter 1 "Administration" Section 1.1.4 states 'This standard does not apply to Industrial Fire Brigades that might also be known as Emergency Brigades, Emergency Response Teams, Response Teams, Fire Teams, Plant Emergen-cy Organizations, or mine emergency response teams."

The required staffing levels for the Oconee Plant are specified in SLC 16.13.1 "Minimum Station Staffing Requirements." NSD-112 "Fire Brigade Organization, Training & Responsibilities" provides the requirements for becoming a qualified fire brigade member. When the Control Room alerts the Fire Brigade to a fire, Radiation Protection and Security Personnel are also alerted and tasked to assist the Fire Brigade in accordance with Procedure RP/O/B/1000/029 "Fire Brigade Response." {Area for Improvement - Ensure the NFPA 600 code review is included in the Fire Brigade Functional Area Management (FAM) Manual.} Reference(s): Selected Licensing Commitment (SLC) 16.13.1 "Minimum Station Staffing Requirements" NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" RP/O/B/1 000/029 "Fire Brigade Response" (b) Industrialfire brigademembers shall have no other assignednormal plant duties that would prevent immediate response to a fire or other emergency as required. ONS uses a fire brigade made up of five members from Operations and five additional members. ONS does not use a dedicated fire department organization. NSD-1 12 states that Fire Brigade members are informed of their responsibilities at the beginning of each shift and during a fire emergency will respond under the direction of the Fire Brigade Leader and perform all duties to control, extinguish and restore the station to a safe condition. SLC 16.13.1 states minimum station staffing requirements and includes in the bases that staff is required for fire brigade independent of other responsibilities.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3. Page 39 of 84 Reference(s): SLC 16.13.1 "Minimum Station Staffing Requirements" NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" (c) During every shift, the brigade leader and at least two brigade members shall have sufficient trainingand knowledge of nuclearsafety systems to understandthe effects of fire and fire suppressants on nuclearsafety performance Exception: Sufficient training and knowledge shall be permitted to be provided by an operationsadvisor dedicated to industrialfire brigadesupportcriteria. NSD-1 12 states that the Fire Brigade Leader and at least two brigade members shall have sufficient training in or knowledge of plant safety-related systems to understand the effects of fire and fire suppressants on safe shutdown capability (have completed OPS ISS Training). Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" (d) The industrialfire brigadeshall be notified immediately upon verification of a fire. Plant employees receive general employee training that includes notifying the control room via the telephone using 4911 of a discovered fire. Once a fire is confirmed via the first responder verifies the fire (or Control Room received multiple indication) the fire brigade is dispatched. NSD-1 12 states that Control Room personnel are responsible for initiating Fire Brigade response. The fire brigade is dispatched using two methods; a paging system that activated pagers worn by fire brigade members and the plant paging system. Both methods are used in each event. Reference(s): General Employee Training - Plant Access Training NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" RP/O/B/1 000/029 "Fire Brigade Response" (e) Each industrial fire brigade member shall pass an annual physical examination to determine that he or she can perform the strenuous activity required during manual fire-fighting operations. The physical examinationshall determine the ability of each member to use respiratoryprotection equipment. NSD-1 12 requires that prior to initial training and annually thereafter, each fire brigade member will receive a physical examination by a company approved medical professional to assure that they are medically capable of performing strenuous activities. Each fire brigade member must satisfactorily complete and maintain respirator use clearance as determined by

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 40 of 84 the Corporate Medical Department. NSD-112 states that for Fire Brigade Leaders and Members to remain qualified they must pass a medical examination, respiratory training and respirator fit test. The specific program requirements are listed in ERTG-001 "Emergency Response Organization and Emergency Services Training Program." Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" ERTG-001 "Emergency Response Organization and Emergency Services Training Program" 3.4.2 Pre-Fire Plans Currentand detailedpre-fire plans shafl be availableto the industrialfire brigade for all areas

     -- inLw-hictbafiraeouldjeopardizehtb.e.abilityomeet

---

.-.- the-perforrnance-criteriadescribedinSection 1.5.

Current and detailed fire plans are provided in the Oconee Nuclear Site Fire Plan (Fire Brigade Strategies) for all plant locations that contain systems or components that could impact nuclear safety performance or present a potential for radioactive releases or life safety. Reference(s): Oconee Nuclear Site Fire Plan 3.4.2.1 The plans shall detail the fire area configurationand fire hazards to be encounteredin the fire area,along with any nuclearsafetycomponents and fire protection systems andfeatures that are present. The Fire Plan provides a graphic representation of the various plant areas that depicts the installed fire protection/suppression features. In addition to the suppression features, the Fire Plan also provides information of any equipment important to safety and special hazards (e.g. Radiological, Electrical, Chemical, Physical and Flammable Liquids Gases) that could be encountered. The Fire Plan also provides information on available ventilation equipment. The Fire Plan includes Fire Brigade Guides (SOGs) that provide general instructions for the fire brigade hose selection and use and specific hazards consideration such as electrical and bulk Hydrogen fires, hazardous materials response and other generic fire mitigation tactics. {Area for Improvement - Evaluate the Fire Plan and associated documents (SOG, training materials, and directives) to ensure the minimum pre-plan content listed in FAQ 06-0025 is addressed.)

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 41 of 84 Reference(s): Oconee Nuclear Site Fire Plan 3.4.2.2 Pre-fireplans shall be reviewed and updated as necessary. The Fire Plan is maintained by the Emergency Planning Group and is updated as required. Modifications to plant features and equipment and changes to plant procedures require a determination of potential effects on the fire protection program or features; potential impacts may lead to revision or additions to the Fire Plan. NSD-301, Appendix B, 'Technical Issues Checklist" includes a specific line item for impact on the fire plan. NSD-228, Appendix E, "Fire Protection Program Screening Aid" includes review . -------..-------..... of.theJmpact-onrlheFireBrgadea which-itilize-theFirePJan . . Reference(s): NSD-228 "Applicability Determination" NSD-301 "Engineering Change Program" 3.4.2.3 Pre-fireplans shall be availablein the control room andmade availableto the plantindustrial fire brigade. The Fire Plan is available to the Fire Brigade Leaders and Members as well as Control Room Personnel. A copy is located in each CR, FB leader's locker, NEO Supervisor's office and the FB Leader's kit. Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" Oconee Nuclear Site Fire Plan 3.4.2.4 Pre-fireplans shall address coordinationwith other plant groups during fire emergencies. The coordination between the Fire Brigade and other plant groups during a fire emergency is defined in NSD-112. When the Control Room is notified of a fire, Procedure RP/O/B/1000/029 "Fire Brigade Response" is implemented. The procedure instructs the control room personnel on their response and provides direction on managing the conduct of the fire fighting activities including contacting offsite Fire Departments.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2. & 3 Page 42 of 84 Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" RP/O/B/1 000/029 "Fire Brigade Response" 3.4.3 Training and Drills Industrialfire brigade members and other plant personnel who would respond to a fire in conjunction with the, brigade shall be provided with training commensurate with their emergency responsibilities. (a) PlantIndustrialFire Brigade Training.All of the following requirementsshall apply. (1) Plant industrialfire brigade members shall receive training consistent with the requirementscontainedin NFPA 600, Standardon IndustrialFire Brigades,or NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, as appropriate.

     .........
            -... (**nc~rea-i         riade- embers--shaltbe-given-quarterly-training-and~practice-in--fre-fighting, including radioactivityandhealth physics considerations,to ensure thateach member is thoroughly familiar with the steps to be taken in the event of a fire.

(3) A written programshall detail the industrialfire brigade trainingprogram. (4) Written records that include but are not limited to initial industrialfire brigade classroom andhands-on training,refreshertraining,specialtrainingschools attended, drill attendance records, and leadership training for industrialfire brigades shall be maintainedfor each industrialfire brigademember. The fire brigade training program includes the following essential elements: use of fire fighting equipment, fire fighting principles and techniques, use of fire fighting guidelines (SOGs), annual practices in actual fire fighting and periodic fire drills. The drills implement the fire fighting procedures, including the simulated use of equipment, to assess brigade effectiveness. The drills also evaluate brigade leadership and Control Room coordination for plant control. NSD-1 12 states that for Fire Brigade Leaders and Members to remain qualified they must, among other requirements, participate in an annual practical training session, quarterly training sessions and participate in at least two drills per year. NSD-1 12 references NFPA 600 as a source document. NFPA 1500 is not applicable to ONS. Specific training requirements are specified in ERTG-001 "Emergency Response Organization and Emergency Services Training Program." Records of personnel participation in the training sessions are maintained by the training department. Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" ERTG-001 "Emergency Response Organization and Emergency Services Training Program" (b) Trainingfor Non-IndustrialFireBrigade Personnel.Plantpersonnel who respond with the

Calculation No.: OSC-9295 Revision No.: 0. Applicable Units: Oconee Unit 1, 2, & 3 Page 43 of 84 industrial fire brigade shall be trained as to their responsibilities,potential hazards to be encountered,andinterfacing with the industrialfire brigade. The Oconee Nuclear Station maintains a large fire brigade size and does not utilize non-fire brigade qualified personnel to respond to a fire. Persons who perform Fire Watch duties for Hot Work are qualified in the use of the fire extinguisher and are authorized to extinguish any resulting fire of the hot work within their capabilities. Other non-fire brigade personnel that may response to a fire incident include Security, Radiation Protection, Chemistry, Off-Site Fire Department and the Medical Emergency Response Team (MERT). These personnel are trained for interfacing with the Fire Brigade. The Fire Brigade Leader is the overall Incident Commander and uses other personnel as support. _-- .....-.... Reference(s): -NSD4 -112--`Fire-Brigade-Organization,-Training-&-ResponsibilitiesI-PT/O/B/2000/001 "Preparation and Conduct of Emergency Drills" (c) Drills. All of the following requirementsshall apply. (1) Drills shall be conducted quarterlyfor each shift to test the response capabilityof the industrialfire brigade. Drills are performed quarterly for each shift fire brigade. At least one drill per year for each shift fire brigade is unannounced; at least one drill per year for each shift fire brigade is performed on a back shift. At least one drill annually involves a response from the appropriate local fire department(s). Site fire brigade/local fire department interface is critiqued by both site andlocal fire department staff. Reference(s): NSD-112 "Fire Brigade Organization, Training & Responsibilities" (2) Industrialfire brigadedrills shall be developed to test andchallengeindustrialfire brigaderesponse,including brigadeperformance as a team, properuse of equipment, effective use of pre-fire plans, and coordinationwith other groups. These drills shall evaluate the industrialfire brigade'sabilitiesto react,respond,and demonstrateproper fire-fighting techniques to controland extinguish the fire and smoke conditionsbeing simulated by the drill scenario. Each fire drill is pre-planned to establish training objectives and critiqued to determine how well the objectives are met. The Fire Brigade drill performance is critiqued by controllers/evaluators to determine successful drill performance in accordance with

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 44 of 84 stated drill objectives. Performance is documented utilizing the Fire Drill Critique Sheet. Drills are pre-planned to determine the appropriate number of controllers/evaluators needed to effectively assess the Fire Brigade Response. Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" ERTG-O01 "Emergency Response Organization and Emergency Services Training Program" PT/O/B/2000/O01 "Preparation and Conduct of Emergency Drills" (3) Industrialfire brigade drills shallbe conductedin various plantareas,especially in those areas identified to be essential to plant operationand to contain significant fire

          ----   -hazards.-         -    -     - .   -    -  -     -        _

Procedure PT/O/B/2000/O01 "Preparation and Conduct of Emergency Drills" specifies that drills be conducted with onsite and local offsite fire department personnel. On-site drills are required to be conducted involving different areas and hazards, including "Risk Significant" areas. Fire drills including response of the offsite Fire Departments are conducted annually. Reference(s)': NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" ERTG-001 "Emergency Response Organization and Emergency Services Training Program" PT/OIB/2000/O01 "Preparation and Conduct of Emergency Drills" (4) Drill records shall be maintaineddetailing the drill scenario,industrialfire brigade member response, and ability of the industrialfire brigadeto perform as a team. A completed Fire Drill Critique Sheet (Appendix B) and Training Content Summary form shall be sent to the Site Training Division is sent to Document Control for documentation and retention. Retention in document control is life of plant., Performance deficiencies of a shift fire brigade or individual fire brigade members will be noted and appropriate action taken and documented in the corrective action program. Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" (5) A critiqueshall be held and documented after each drill.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 45 of 84 A critique is performed for each drill that involves the fire brigade in accordance with NSD-1 12. The completed Fire Drill Critique Sheet and Training Content Summary form is required to be sent to the Site Training Division for documentation and retention. Site Training transmits the records to Document Control for documentation and retention. Retention in Document Control is life of plant. Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" 3.4.4 Fire-FightingEquipment Protective clothing, respiratoryprotective equipment,radiationmonitoringequipment, personal dosimeters, and fire suppression equipment such as hoses, nozzles, fire extinguishers,and other needed equipmentshall be providedfor the industrialfire brigade. This equipmentshall conform with the applicableNFPA standards. Fir6-Fi-0 fti- ElGP -f it-1biocat-Rtd iiVaiUf irfie areas-.T h areas are sh-on grap-otiflhalY-ad described in the Fire Plan for that area. Fire Brigade Equipment is also specified in the SOG section of the Fire Plan. The equipment is listed by location and includes items such as air packs, spanners, smoke ejectors and nozzles. Hose stations and hydrant houses contain sufficient lengths of hose and nozzles. Fire Brigade personnel turnout gear and air packs are stored in specified fire equipment storage locations. Ops equipment is stored in two storage containers on the Turbine deck. Backup gear is stored in the warehouse. Each Fire Brigade member is furnished with a complete set of turn out gear consisting of pants, coat, boots, gloves, helmets and flash hoods. Radios are provided for communication in the Fire .Brigade Response storage location. Other equipment available to the brigade includes portable lights, thermal imaging camera, portable ventilation as well as portable generators. Other supporting groups' equipment is stored in their respective work spaces. Air Packs (SCBA's) provided for the brigade are NIOSH approved one hour air bottles with integrated PASS devices as well as amplified SCBA masks. Additional masks are provided within each of the two response sea-lands. In addition to spare air bottles ONS has an electric and a portable a diesel compressor capable of refilling SCBA bottles. Radiation Protection is responsible for the SCBA refill operation. SCBA refill can be performed via the cascade system or the breathing air system. This equipment is inspected in accordance with Procedure PT/O/B/0250/030 "Quarterly Fire Brigade Equipment Inspection." to ensure the operability and availability of all Fire Brigade equipment. The Keowee Fire Brigade Equipment is inspected in accordance with Procedure PT/O/A/2200/01 0 "Keowee Equipment Inspection." Fire protection equipment is procured and conforms to the applicable NFPA standards for the specific equipment.

Calculation No.: OSC-9295 Revision No.: ý0 Applicable Units: Oconee Unit 1, 2, & 3 Page 46 of 84 Reference(s): Oconee Nuclear Site Fire Plan PT/O/B/0250/030 "Quarterly Fire Brigade Equipment Inspection" PT/O/A/2200/01 0 "Keowee Equipment Inspection" 3.4.5 Off-Site FireDepartmentInterface 3.4.5.1 Mutual Aid Agreement Off-site fire authorities shall be offered a plan for their interface during fires and related emergencies on site. There are "Letters of Agreement" with local Fire Departments that provide details of the interaction of their organization during a fire or related emergency on the Oconee Site. These Letters of Agreement are maintained as part of the Emergency Plan. Letters of Agreement are in effect with the Corinth-Shiloh Volunteer Fire Department, the Keowee Fire Commission, the Keowee-Ebenezer Volunteer Fire Department, and the Six Mile Volunteer Fire Department. These Letters of Agreement are reviewed by established frequency as required by the Emergency Planning Group. The primary response for fires inside the protected area is the ONS fire brigade with support from off-site fire departments. The primary response for fires outside the protected area is the off-site fire departments. Except for Keowee Hydro where the ONS fire brigade will respond with assistance from the off-site fire departments. Reference(s): Oconee Emergency Plan 3.4.5.2 Site-Specific Training Fire fighters from the off-site fire authoritieswho are expected to respondto a fire at the plant shall be offered site-specific training and shall be invited to participatein a drill at least annually. NSD-112 specifies that at least one fire drill annually will involve response from the appropriate local fire department(s). Site fire brigade/local fire department interface will be critiqued by both site and department fire protection staff. It is the intent to have off-site fire response act as supplemental support and integrate into the site team, but not act independently. The Letters of Agreement discussed above contain provisions for annual training of off-site personnel who would respond to an assistance request.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1 2. & 3 Page 47 of 84 Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" Oconee Emergency Plan 3.4.5.3 Security and Radiation Protection Plantsecurity and radiationprotectionplans shall address off-site fire authorityresponse. NSD-1 12 "Fire Bdgade Organization, Training & Responsibilities," contains requirements that the Security and Radiation Protection organizations assist the fire brigade. The Security and Radiation Protection organizations have plans and provisions that provide for the entry and activities of outside fire fighting organizations. If offsite assistance is determined to be needed during a fire emergency, Procedure RP/O/B/1 000/029 "Fire Brigade Response" provides direction to the Control Room personnel ............... -*n-contacting-the-o-fsite-EFire-Department-and-request-assistance....-T-he-FjreDispatch.r-is-instructed to have the responding fire department enter the site through the prescribed entrance and have all responders stage in the appropriate parking lot. The Control Room also contacts Site Security and requests that a security officer escort the fire department(s) to the fire staging location. Off-site fire response may be provided TLD's and electronic dosimeters from Radiation Protection if required. The instructions on the methods to be used to contact the off-site fire emergency agencies, as well as site Security and Radiation Protection personnel, are provided in Procedure R P/0/B/1000/029. Reference(s): NSD-1 12 "Fire Brigade Organization, Training & Responsibilities" RP/O/B/1000/029 "Fire Brigade Response" 3.4.6 Communications An effective emergency communications capability shall be provided for the industrialfire brigade. The primary means of communication is the two-way radio system, which has a fixed location repeater base station located above the Unit 1/2 Control Room in the Ventilation Equipment Room. If the repeater is lost to fire, the system can continue to function on the "talk around" channel. This system assures general coverage of the Turbine Building, Auxiliary Building, and Containment Building areas. The redundant repeaters receive emergency power and the individual radios have their own batteries. PIP-0-099-02753 verified that a radio system is in place which satisfies the above requirements.

Calculation No,: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 48 of 84 Reference(s): Design Basis Specification for Fire Protection PIP-0-099-02753 Section 3.5 Water Supply 3.5.1 A fire protection water supply of adequatereliability,quantity, and duration shall be provided by one of the two following methods. (a) Provide a fire protection water supply of not less than two separate 300,000-gal (1,,135,500-L) supplies. The High Pressure Service Water (HPSW) System provides water for the fire protection system at the Oconee Plant. The HPSW system is connected to the Condenser Circulating Water (CCW) crossover header. The CCW piping is connected to Lake Keowee at the intake .............--.-structure.-This-suction.sou rce__would.-remain-available-on-loss-of-power-to-thelntake-pumps-because the system can be operated as a siphon. The lake has sufficient inventory (over 390,000 acre-feet) of water available. There are facility operational limitations based on the lake level in SLC 16.9.7 "Keowee Lake Level," that ensures an adequate supply of water is available. In addition, a 100,000 gallon elevated water storage tank has inventory which is available to provide limited back-up water for fire protection. The NRC August 11, 1978 SER Section 4.3.1.1 states 'The fire protection water supply is providedby the high-pressureservice water (HPSW)pumps which take suction from separate circulating cooling water (CCW) system headers. The CCW system is supplied from Lake Keowee by pumps at the intake structure; the lake water would still be available on loss of power to the intake pumps because the system can operate as a siphon. The lake water supply has over 390,000 of water available."

                "In additionto the HPSW pumps, a 100,000 gallon elevation waterstorage tank floats on the HPSW system provides a backup fire protection water supply."
                'We find that the basic watersupplysystem satisfies the provisionsof Appendix A to BTP 9.5-1 and is, therefore, acceptable."

The LPSW system provides water to hose stations within the Reactor Buildings. The LPSW pumps takes suction from the CCW crossover line and discharge to a common discharge header in the same arrangement as the HPSW pump described above. The Keowee Hydro Station Water Spray and Fire Hose systems are supplied by the combined Service Water (SW)/Fire Protection Water system. The system is generally supplied via lake head pressure which provides sufficient flow and pressure for most operations. In the event additional flow/pressure is necessary an electric fire pump is provided. A portable gasoline fire pump is also provided in the event the electric fire pump is not in service.

A-Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 49 of 84 Reference(s): NRC SER dated August 11, 1978 Design Basis Specification for Fire Protection SLC 16.9.7 (b) Calculate the fire flow rate for 2 hours. This fire flow rate shall be based on 500 gpm (1892.5 Llmin) for manual hose streams plus the largestdesign demand of any sprinkleror fixed waterspray system(s) in the power block as determined in accordance with NFPA 13, Standard for the Installation of Sprnkler Systems, or NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection. The fire water supply shall be capable of delivering this design demand with the hydraulicallyleast demandingportion of fire main loop out of service. The greatest demand for fire protection water is based on 1,000 gpm for fire hose plus 2,571 gpm (all sprinkler heads opened and flowing in the Unit 3 Turbine Building Mezzanine Level

        -lQ--500                         gpm n--on-fire re-at-d searvice -t-d-for-- a--oto--t-f-4ý07-1-p-m-Currently the largest NRC committed BTP demand is 1,738 gpm required by the Unit 3 Cable Room Water Spray System. The system demand is 1,238 gpm plus a 500 gpm non-fire related service water demand. A hose stream allowance is not included for this system based upon its expected usage. These demands are all less than the output of one of the HPSW Pumps which is 6,000 gpm.

The NRC August 11, 1978 SER Section 4.3.1.2 states "There are two 6,000 gpm HPSW pumps and one 500 gpm jockey pump, all ratedat 11 7psinet pressure. The two largepumps are consideredredundant,each capable of supplying the largestdesign fire flows plus other simultaneousdemands on the HPSW system." ,

         "We find that the fire pumps meet the objectives outlined in Section 2.2 of this reportand are, therefore, acceptable."

{Further Action Required - Ensure any required suppression systems for Chapter 4 are within the design flow capabilities of the fire pumps per NFPA 20.} Reference(s): Design Basis Specification for Fire Protection NRC SER dated August 11, 1978 3.5.2 The tanks shall be interconnectedsuch that fire pumps can take suctionfrom eitherorboth.A failure in one tank orits piping shall not allow both tanks to drain. The tanks shall be designed in accordancewith NFPA 22, Standardfor Water Tanks for PrivateFire Protection. Exception No. 1: Water storage tanks shall not be requiredwhen fire pumps are able to take suction from a large body of water (such as a lake), provided each fire pump has its own

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 50 of 84 suction and both suctions and pumps are adequately separated. Exception No. 2: Cooling tower basins shall be an acceptable water source for fire pumps when the volume is sufficient for both purposes and water quality is consistent with the demands of the fire service. The H PSW pumps take suction through the CCW crossover header that is connected to Lake Keowee at the intake structure. The crossover header can be supplied from any units CCW piping/pumps and can be gravity fed. The NRC August 11, 1978 SER Section 4.3.1.1 states "The fire protection water supply is providedby the high-pressureservice water (HPSW)pumps which take suction form separate circulating cooling water (CCW) system headers."

         'The pumps are locatedin the turbine building, each in a small masonry room enclosing the pump a-dmo-d-motor.
         'We find that the basic water supply system satisfiesthe provisions of Appendix A to BTP 9.5-I and is, therefore, acceptable."

The Keowee Fire Protection Pump takes its suction from Lake Keowee at the spillway wall. The back-up Keowee fire pump is a portable pump which can draw water from the gravity side of the suction piping. Reference(s): NRC SER dated August 11, 1978 Design Basis Specification for Fire Protection Drawing KFD-109A-1.1 "Keowee Hydro Station - Flow Diagram of Service Water System" 3.5.3 Firepumps, designedand installedin accordancewith NFPA 20, Standardfor the Installation of Stationary Pumps for Fire Protection,shall be provided to ensure that 100 percent of the requiredflow rate and pressure are availableassuming failure of the largestpump or pump power source. The pumps used to supply the fire protection systems at the Oconee Plant are not fire pumps but have been accepted by the NRC. As stated in Section 3.5.1, above, the HPSW System provides water for the fire protection system at Oconee. There are two 6,000 gpm (at 117 psig) HPSW pumps. There is also a 500 gpm (at 117 psig) jockey pump in the HPSW System. The jockey pump normally operates to maintain the system pressure on the fire protection headers and also supplies non fire related loads. In the event of a fire, one 6,000 gpm HPSW pump will automatically provide sufficient water for maintaining fire water demands and elevated

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 51 of 84 water storage tank inventory. The second 6,000 gpm HPSW pump would be available if needed. The LPSW system provides fire water to the Reactor Building hose stations only. The LPSW pumps are rated at 15,000 gpm (at 100 psig) which is more than sufficient for the Reactor Building hose stations. The HPSW jockey pump is not considered part of the required fire pumps. The NRC August 11, 1978 SER Section 4.3.1.2 states "There are two 6,000 gpm HPSW pumps and one 500 gpm jockey pump, allratedat 117psi net pressure. The two largepumps are considered redundant,each capable of supplying the largest design fire flows plus other simultaneous demands on the HPSW system. The pumps are electricmotordriven receiving power from separate Unit No. 1 buses."

        'We find that the firepumps meet the objectives outlined in Section 2.2 of this reportand are, therefore,acceptable."

The Keowee Hydro Station has a separate Fire Pump to supply hose stations and fixed suppression systems including the Keowee Main Transformer. The Keowee Fire Pump takes suction from Lake Keowee at the spillway structure. The Keowee Fire Pump is rated at 1,150 gpm at approximately 56 feet of head pressure with a shutoff head of 375 psi. A portable pump is provided and may be used in establishing a backup fire fighting system. Oconee Nuclear Station initiated Problem Identification Program (PIP) 99-4487 to evaluate the HPSW and Keowee Fire Water pumps' capabilities. The result of Calculation KC-2135, Revision 8, that was performed for the Keowee Fire Pump concluded that the flow and pressure available at the Keowee Main Transformer deluge system did not meet NFPA 15-1996 (or -1969 the Code of Record) requirements. {Further Action Required - Ensure resolution of the Keowee fire pump replacement (PIP 0-2001-03492) satisfies the requirement of this section.} Reference(s): NRC SER dated August 11, 1978 Design Basis Specification for Fire Protection PIP 2001-3492 PIP 1999-4487 3.5.4 At least one diesel engine-driven fire pump or two more seismic CategoryI Class IE electric motor-driven fire pumps connectedto redundantClass IE emergency power buses capableof providing 100 percent of the requiredflow rate andpressureshall be provided. There are no permanently installed dedicated diesel engine-driven or electric motor-driven fire

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1. 2. & 3 Page 52 of 84 pumps at Oconee. Fire water is supplied via either of the two electric motor-drive-HPSW pumps as part of a shared system. The HPSW pump motors are powered from separate buses. HPSW Pump A is located in Oconee 1 and power is furnished directly from 4160V Bus. No. 2 Unit No.1. Power to HPSW Pump B, which is located in Unit 2 along with the jockey pump, is furnished directly from 4160V Bus No. 1 Unit No. 1. The HPSW system is not a seismically designed system. Each HPSW pump is capable of providing 100 percent of the required flow and pressure. The NRC August 11, 1978 SER Section 4.3.1.2 states "There are two 6,000 gpm HPSW pumps and one 500 gpm jockey pump, allratedat 117 psi net pressure. The two largepumps are considered redundant,each capable of supplying the largestdesign fire flows plus other simultaneous demands on the HPSW system. The pumps are electricmotordriven receiving power from separate Unit No. 1 buses."

         'We find that the fire pumps meet the objectives outlined in Section 2.2 of this reportand are,

---

4-herefore,.-acceptable."-.-.--... - ....

Keowee fire water supply is provided by a non-seismic electric fire pump with a portable gasoline engine-driven fire pump as backup. The backup portable gasoline fire pump is sufficient to supply the fire hose demands at Keowee. Reference(s): Design Basis Specification for Fire Protection NRC SER dated August 11, 1978 3.5.5 Each pump and its driverand controls shall be separatedfrom the remainingfire pumps and from the rest of the plant by ratedfire barriers. HPSW Pump A is located in Unit 1 and HPSW Pump B is located in Unit 2 Turbine Building basement; each in its own small 3-hour rated or equivalent masonry block room. The power cables to the motors are embedded in the concrete floor. The NRC August 11, 1978 SER Section 4.3.1.1 states 'The HPSWpumps arelocatedn the turbine building, each in a small masonry room enclosing the pump and motor. The power supply to each pump extends from the blockhouse via cables which are embedded in the turbine building floor."

         'We find that the fire pumps meet the objectives outlinedin Section 2.2 of this reportand are, therefore, acceptable."

The 2005 NRC Triennial Fire Protection Inspection identified that the HPSW control circuit

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 53 of 84 could be vulnerable from a Turbine Building Fire. A HPSW Vulnerability Evaluation was performed and is documented in PIP-O-05-04125. The vulnerability study determined that although the potential exists for loss of both HPSW pumps, the postulated fire scenarios that result in loss of the pumps would not affect Standby Shutdown System. In addition, in the event of the unavailability of both HPSW pumps, the EWST can provide a limited quantity of water for fire suppression. Reference(s): NRC SER dated August 11, 1978 PIP-O-05-04125 3.5.6 Firepumps shall be provided with automaticstart and manualstop only. -....------ The H PSW-P-u mps-receive-an-auto matic-start-signal-bas.ed-.nntihe.evate.d-storag.etaanklevel.... The pumps can be manually controlled from the Control Room. A modification has been initiated to provide manual stop capabilities (PIP 02-3870). The NRC August 11, 1978 SER Section 4.3.1.2 states 'The HPSW pumps are operated automaticallybased on the water level maintained in the elevated water storage tank. The pumps can also be manuallystartedin the controlroom or at the pump switchgearlocatedin the blockhouse."

            'We find that the fire pumps meet the objectives outlinedin Section 2.2 of this reportand are, therefore, acceptable."

The Keowee Fire Protection pump automatically starts on receipt of a pressure switch or flow switch alarm. The fire pump can only be stopped manually. {Area for Improvement - Document the resolution of PIP 2002-3870 for installation HPSW manual stop.) Reference(s): NRC SER dated August 11, 1978 Design Basis Specification for Fire Protection PIP 02-3870 3.5.7 Individual fire pump connections to the yard fire main loop shall be provided and separated with sectionalizingvalves between connections.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 54 of 84 Each HPSW Pump has a separate discharge into the HPSW System. Valves are arranged so that a single pipe break in the discharge piping will not remove both pumps from service. The NRC August 11, 1978 SER Section 4.3.1.3 states "EachHPSW Pump has a separate discharge into the HPSW System. Valving is arrangedso that a single pipe break in the dischargepiping will not remove both pumps from service."

                    "We conclude that, upon implementation of the modifications describedabove, the fire water piping system meets the objectives outlined in Section 2.2 of this report and are, therefore, acceptable." Note that modifications referred to in the conclusion pertain to cross-connections of the auxiliary building headers to provide dual feed for hose stations in the area.

The Keowee Service Water system is a shared service water system that supplies cooling to equipment, fire protection equipment driven from the head of the lake, and the Keowee fire -.---.-.-.......... protectlon--pump-_-TheKeowee.FireP-ump-supplies-som e-of-the-hydroelectric--plant's-fire-system components. There are appropriate sectional and isolating valves in the system. Reference(s): Design Basis Specification for Fire Protection NRC SER dated August 11, 1978 Drawing Series OFD-1 24C Drawing KFD-109A-1 .1 3.5.8 A method of automaticpressure maintenance of the fire protection water system shall be provided independent of the fire pumps. At ONS a 500 gpm Jockey Pump operates continuously to meet non-fire protection related HPSW loads and to maintain pressure in the fire protection headers. Power for the Jockey Pump is provided from 600 Volt Motor Control Center (MCC) 1XE. The Jockey Pump has no fire protection requirements and is not intended to meet the fire protection demands. At Keowee, the elevation of the lake maintains header pressure (no jockey pump). Reference(s): Design Basis Specification for Fire Protection 3.5.9 Means shall be provided to immediately notify the control room, or other suitable constantly attendedlocation, of operation of fire pumps.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 55 of 84 The following alarms are provided in the Unit 1 Control Room:

• Jockey pump stopped
• Low HPSW system header pressure
• Low elevated water storage tank level

               " Elevated water storage tank overflow.

In addition to standard alarms, the control room computer alarms operators of the HPSW pump start The Keowee Fire Protection pump start alarms to the ONS Unit 2 Control Room and the Keowee Control Room.

---

Referenee(s)--Design-Basis-Speeifieation-for-Fir-e-.Proteetio _

3.5.10 An undergroundyard fire main loop, designedand installed in accordance with NFPA 24, Standardfor the Installationof PrivateFireService Mains and TheirAppurtenances, shallbe installed to furnish anticipatedwater requirements. An underground fire loop (16 inch cement-lined, ductile iron pipe) is provided around the perimeter of the plant site. Post indicator valves are provided and are sealed or locked open to prevent inadvertent closing of valves required open for fire protection. Post indicator valves are arranged to provide isolation to portions of the main for maintenance or repair without shutting off the complete system. Valves will allow other service water systems to be removed from the HPSW system without compromising fire protection systems. The NRC August 11, 1978 SER Section 4.3.1.3 states "Allyard fire hydrants, fixed water suppression systems, and interior hose lines are supplied by the HPSW system through undergroundyard mains and headers inside buildings."

          "We conclude that, upon implementation of the modifications describedabove, the fire water piping system meets the objectives outlined in Section 2.2 of this reportand are, therefore, acceptable."Note that modifications referred to in the conclusion pertain to cross-connections of the auxiliary building headers to provide dual feed for hose stations in the area and are not applicable to this NFPA 805 section.

The Keowee Fire Water System does not have an underground loop. Underground fire water piping supplies two external fire hydrants. Appropriate isolation valves are provided for that portion of the system.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 56 of 84 Reference(s): NRC SER dated August 11, 1978 Design Basis Specification for Fire Protection Drawing series OFD-124C Drawing KFD-109A-1.1 3.5.11 Means shallbe provided to isolateportions of the yard fire main loop for maintenanceorrepair without simultaneouslyshutting off the supply to both fixed fire suppression systems and fire hose stations provided for manual backup. Sprinkler systems and manual hose station standpipes shall be connected to the plant fire protection water main so that a single active failure or a crack to the water supply piping to these systems can be isolatedso as not to impairboth the primary and backup fire suppressionsystems.

----..--.-.......... A-1-6-inch-loop-is-provided--around-the-perimeter-of -the-plant.--In=line-isolation-valves-are-

-.. provided such that a break can be isolated without losing system capabilities from a single break. Connections from this header to the units are redundant. Auxiliary Building headers are fed from a 16 inch line coming from the yard and a 4 inch and 16 inch line from the Turbine Building. The 16 inch line that cross connects the yard loop with the Turbine Building through the Auxiliary Building is normally isolated to reduce the potential consequences of an Auxiliary Building flood event. The isolation valves can be manually opened when the cross connect is required to be placed in service. A 4 inch line from the Turbine Building will remain in service during normal operation in order to supply normal Auxiliary Building HPSW header requirements. The 4 inch line is capable of providing adequate initial HPSW flow and pressure and for fire mitigation and service water demands in all areas of the Auxiliary Building. The 4 inch line contains a 500 gpm flow limiting device. The 500 gpm flow limiting device is sized to supply two 2-1/2" hose stations. The NRC August 11, 1978 SER Section 4.3.1.3 states WAll yard fire hydrants, fixed water suppression systems, and interiorhose lines are supplied by the HPSW system through undergroundyard mains and headers inside buildings. Sectionalizingvalves are providedto allow isolationof varioussections of the system for maintenance;however there are locations in the turbine building where a single piping break could affect both automatic water suppressionsystems andmanualhose stations. The licensee has proposedto cross-connect the ends of the two auxiliarybuilding headersto provide dualfeed for the hose stationsin this area."

                      'We conclude that, upon implementation of the modifications describedabove, the fire water piping system meets the objectives outlined in Section 2.2 of this reportand are, therefore, acceptable."The modifications referenced above to providing auxiliary building cross-connect have been implemented.

The Keowee fire protection system incorporates isolation valves for the various service water and fire system components.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1.2, & 3 Page 57 of 84 Reference(s): NRC SER dated August 11, 1978 Engineering Support Program Document for Fire Protection Design Basis Specification for Fire Protection Drawing series OFD-124C Drawing KFD-109A-1.1 3.5.12 Threads compatible with those used by local fire departments shall be provided on all hydrants, hose couplings, and standpipe risers. Exception: Fire departments shall be permitted to be provided with adapters that allow. interconnection between plant equipment and the fire department equipment if adequate trainingand proceduresare provided. The fire water connections atthe Oconee Plant and the Keowee Hydro Station utilize standard fire hose threads that are compatible with local fire department equipment. Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 3.5.13 Headers fed from each end shall be permitted inside buildings to supply both sprinkler and standpipe systems, providedsteel piping andfittings meeting the requirementsof ANSI B31.1, Code for Power Piping,are used for the headers (up to andincluding the first valve) supplying the sprinklersystems where such headersarepartof the seismicallyanalyzedhose standpipe system. Where provided, such headers shall be considered an extension of the yard main system. Each sprinkler and standpipe system shall be equipped with an outside screw and yoke (OS&Y) gate valve or other approved shutoff valve. The header system for the Turbine Building and Auxiliary Building sprinkler and standpipe systems are not part of a seismically analyzed hose standpipe system. Each sprinkler and standpipe system is equipped with an approved shutoff valve. During construction ANSI B31.1 excluded fire protection; NFPA codes were applicable at this time. The NRC August 11, 1978 SER Section 4.3.1.1 states 'The fire protection water supply is providedby the high-pressureservice water (HPSW)pumps which take suction from separate circulating cooling water (CCW) system headers."

        'We find that the basicwater supply system satisfies the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable."

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 58 of 84 The NRC August 11, 1978 SER Section 4.3.1.3 states "All yard fire hydrants, fixed water suppression systems, and interiorhose lines are supplied by the HPSW system through undergroundyardmains and headersinside buildings. Sectionalizing valves are providedto allow isolationof varioussections of the system for maintenance;however there are locations in the turbine building where a single piping break could affect both automatic water suppressionsystems andmanualhose stations. The licenseehas proposedto cross-connect the ends of the two auxiliarybuildingheaders to provide dual feed for the hose stations in this area.

           'We conclude that, upon implementation of the modifications describedabove, the fire water piping system meets the objectives outlined in Section 2.2 of this report and are, therefore, acceptable." Note that modifications referred to in the conclusion pertain to cross-connections of the auxiliary building headers to provide dual feed for hose stations in the area and are not applicable to this NFPA 805 section.

-...---. -Reference(s).-Response-to-Appendix-A-to-Branch-Technical-Position-AP-CSB-9.5-1.,--Februavy. ....-...-....-...... 1982 NRC SER dated August 11, 1978 3.5.14 All fire protection water supply and fire suppressionsystem control valves shall be under a periodicinspection program and shall be supervisedby one of the following methods. (a) Electricalsupervision with audible and visual signals in the main control room or other suitable constantly attendedlocation. (b) Locking valves in their normalposition. Keys shall be made available only to authorized personnel. (c) Sealing valves in theirnormalpositions. This optionshall be utilized only where valves are located within fenced areas or underthe direct control of the owner/operator. Oconee utilizes a locked or sealed method to control valve positions rather than electrical supervision. The site area fence is the Owner Controlled fence for sealing consideration. Valves are checked every 31 days per PT/0/A/0250/01 0 A. Reference(s): PT/O/A/0250/01 0 A "Fire Protection Systems Monthly Check" 3.5.15 Hydrants shall be installedapproximatelyevery 250 ft (76 m) aparton the yardmain system. A hose house equipped with hose and combination nozzle and other auxiliary equipment specified in NFPA 24, Standardfor the Installationof Private Fire Service Mains and Their Appurtenances, shall be providedat intervalsof not more than 1000 ft (305 m) along the yard main system. Exception: Mobile means of providinghose and associatedequipment,such as hose carts or

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 59 of 84 trucks, shall be permitted in lieu of hose houses. Where provided, such mobile equipment shall be equivalent to the equipment supplied by three hose houses. Fire hydrants are installed at a maximum of every 300 feet. Hose supplies are adequate to provide fire protection to all perimeter areas. Post indicator valves are provided and sections of the fire loop can be isolated for maintenance or repairs. Hose houses are located at several yard hydrants and are equipped with at least 200 feet of 11/2/2 inch hose, 200 feet of 21/2 inch hose, one-21/2 inch gated wye and two-1 1/2 inch nozzles and one-21/2 inch to 11/2 inch reducer. In addition to the hose houses, there is an equipment storage trailer located north of the Radwaste Building, a equipment storage trailer beside the 0OB and the Fire and Rescue Vehicle that each contain additional fire hose and fire fighting tools. The NRC August 11, 1978 SER Section 4.3.1.3 states 'Yard fire hydrantshave been provided at approximately300 ft. intervalsaroundthe exteriorof the plant. Auxiliaty gate valves arenot provided on the hydrant laterals, with the result that a portion of the fire water heads would -..--. ---- have-to-be-remotved-fro.m-ser-vice-if-a.-fire-.hydrant-has-to-be-isolated-for-maintenance......

           "Hosehouses have been providedat seven of the yardhydrants, each equipped with atleast 200 ft. of 2-1/2 inch hose, 200 ft. of 1-1/2 inch hose and othermanual fire fighting tools."
           'We conclude that, upon implementation of the modifications describedabove, the fire water piping system meets the objectives outlined in Section 2.2 of this report and are, therefore, acceptable." Note that modifications referred to in the conclusion pertain to cross-connections of the auxiliary building headers to provide dual feed for hose stations in the area and are not applicable to this NFPA 805 section.

The Keowee service water system incorporates two fire hydrants and one outside hose cabinet. Reference(s): NRC SER dated August 11, 1978 Design Basis Specification for Fire Protection PT/0/B/0250/030 "Quarterly Fire Brigade Equipment Inspection" 3.5.16 The fire protection water supply system shallbe dedicated for fire protection use only. Exception No. 1: Fire protection water supply systems shall be permitted to be used to provide backup to nuclearsafety systems, providedthe fire protection watersupply systems are designedand maintainedto deliverthe combined fire and nuclearsafetyflow demands for the durationspecified by the applicableanalysis. Exception No.2: Fireprotection waterstoragecan be providedby plantsystems serving other functions, provided the storagehas a dedicatedcapacity capable of providing the maximum fire protection demand for the specified durationas determined in this section.

Calculation No.: OSC-9295 .Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 60 of , 84 The fire water systems for the Oconee Plant are supplied from the HPSW System. The HPSW system is designed to support fire protection and essential service water systems flow demands. The HPSW system draws water from Lake Keowee which has sufficient capacity to meet fire protection demands. The NRC August 11, 1978 SER Section 4.3..1.2 states "There are two 6,000 gpm HPSW pumps and one 500 gpm jockey pump, all ratedat 11 7psi netpressure. The two largepumps are consideredredundant,each capable of supplying the largest design fire flows plus other simultaneous demands on the HPSW system."

         'We find that the fire pumps meet the objectives outlinedin Section 2.2 of this reportand are, therefore, acceptable."

sized to be capable of essential service water flow demands and to support fire hose stations. The NRC August 11, 1978 SER Section 4.3.1.4 states "Interiorhose stations equipped with 1-1/2 inch fire hose have been provided through the plantexcept in containment. Some areas are too far away from a hose station for effective fire fighting. The licensee has proposedto provide additional hose stations so that all areas containing or exposing safety-related equipment will be within effective fire fighting range of at leastone hose station using not more than 100 ft. of 1-1/2 inch fire hose, and to provide hose stations inside containment supplied by the LPSW system."

        "Upon completion of the proposedmodification, we find that the interiorhose stationsmeet the requirements of Appendix A to BTP 9.5-1 and are, therefore,acceptable." The modification referenced above to provide hose stations inside containments supplied by the LPSW system has been implemented.

The fire water supply for the Keowee Hydro Station is supplied by the Service Water System. The Service Water system draws water from Lake Keowee which has sufficient capacity to meet fire protection demands. Reference(s): NRC SER dated August 11, 1978 Design Basis Specification for Fire Protection Section 3.6 Standpipe and Hose Stations 3.6.1 For all power block buildings, Class Ill standpipe and hose systems shall be installed in accordance with NFPA 14, Standardfor the Installationof Standpipe, Private Hydrant, and Hose Systems.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 61 of 84 Hose stations at the Oconee site (including Keowee) are arranged to reach any location, including containment, with 100 feet of 1-1/2 inch fire hose. Some hose stations are located outside of the affected fire area but this was found acceptable by the NRC. Current NRC committed fire hose stations are listed in SLC 16.9.4. The NRC August 11,1978 SER Section 4.3.1.4 states "Interior hose stations equippedwith 1-1/2 inch fire hose have been provided through the plant except in containment. Some areas are too far away from a hose station for effective fire fighting. The licensee has proposedto provide additional hose stations so that all areas containing or exposing safety-related equipment will be within effective fire fighting range of at least one hose station using notmore than 100 ft. of 1-1/2 inch fire hose, and to provide hose stations inside containment supplied by the LPSW system."

             "Uponcompletion of the proposedmodification, we find that the interiorhose stationsmeet the requirements of Appendix A to BTP 9.5-1 and are, therefore, acceptable." The modification

............. referenced-above-to-provide-additional-hose-stations--has-been-implementedL..........- .... *........... The NRC June 7, 1988 SER states "The licensee has proposed a modification to move five fire hose station presently located within the Cable Spreading rooms to stairwell locations outside the rooms. The purpose of this modification is to make the fire hose stationaccessible for fire fighting activities in these rooms."

             'The proposedmodification of fire hose stationswill enhance the fire fighting capabilitiesin the Cable Spreading Rooms and meets the intent of the guidance provided in National Fire ProtectionAssociation (NFPA) Std. 14, Standpipe and Hose Systems, for the location of fire hose connections. After reviewing these proposed TS changes, the staff has determinedthey are acceptable." The modification referenced above to relocate fire hose stations from the Cable Spreading rooms has been implemented.

{Further Action Required - Perform a NFPA 14 code compliance review.} Reference(s): NRC SER dated August 11, 1978 NRC SER dated June 7,1988 Duke letter to the NRC dated 2/17/78 SLC 16.9.4 Design Basis Specification for Fire Protection 3.6.2 A capabilityshall be provided to ensure an adequate water flow rate and nozzle pressurefor all hose stations. This capability includes the provision of hose station pressure reducers where necessary for.the safety of plant industrial fire brigade members and off-site fire departmentpersonnel.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 62 of 84 Fire hose station piping is sized based on hydraulic calculations to provide a minimum of 100 gpm at 65 psi at the committed hose station isolation valve. The previously discussed fire water distribution system is capable of supplying this demand. The Reactor Building hose stations are supplied via the LPSW system which provides acceptable flow and pressure. The Keowee hose stations are supplied via the Service Water system which can provide adequate flow and pressure. Internal evaluations have been performed to confirm flow and pressure requirements are met. Calculation OSC-1 626 validates adequate NFPA 14 flow and pressure to the committed fire hose stations. Reference(s): Design Basis Specification for Fire Protection Calculation OSC-1 626 3.6.3 popertype-of h-os-e n-o prTh eahzbe-.t s-or-ki~k&,.JFli- - rh ebasedont .. area fire hazards. The usual combination spray/straightstream nozzle shall not be used in areas where the straightstream can cause unacceptable damage or present an electrical hazardto fire-fightingpersonnel.Listed electricallysafe fixed fog nozzles shall be providedat locations where high-voltage shock hazards exist. All hose nozzles shall have shutoff capabilityandbe able to control water flow from full open to full closed. Adjustable nozzles are provided on hoses at the hose stations of both the Oconee Plant and. the Keowee Station. These nozzles are appropriate for the type fires that might occur at those locations. The fire brigade has specialized nozzles such as low pressure/high flow and articulating for various situations. Fire Brigade Guide (SOG) #3 includes guidance on electrical fires and the proper hose stream application. Reference(s):' Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 Duke letter to the NRC dated November 22, 1977 Design Basis Specification for Fire Protection Fire Plan, SOG #3, Electrical Fires 3.6.4 Provisionsshall be made to supply water at least to standpipes and hose stations for manual fire suppression in all areas containing systems and components needed to perform the nuclearsafety functions in the event of a safe shutdown earthquake(SSE). Exception: Forexisting plants that are not capable of meeting this requirement,provisionsto restore a watersupply and distributionsystem formanual fire-fightingpurposes shallbe made. The provisional manual fire-fighting standpipe/hose station system shall be capable of providing manual fire-fightingprotection to the various plant locationsimportantto supporting and maintainingthe nuclearsafety function. . The provisions for establishing this provisional

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 63 of 84 system shall be preplannedand be capableof being implementedin a timely mannerfollowing an SSE. Fire hose stations (with the exception of those in the Reactor Building and Unit 1/2 and Unit 3 Cable Room to Control Room back stair hose stations) are not seismically designed. NFPA 14-1969 (code of record) did not have provisions for seismically designed hose stations. The HPSW system is not seismically designed. The NRC previously found the hose stations acceptable per Section 3.6.1 above. Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 Design Basis Specification for Fire Protection Design Basis Specification for the High Pressure Service Water System Where the seismic requiredhose stations are cross-connected to essentialseismic non-fire protection water supply systems, the fire flow shall not degrade the essential water system requirement. The fire hose stations at the Oconee Plant and the Keowee Hydro Station were not designed to meet seismic requirements with the exception of the Reactor Building fire hose stations. The Reactor Building fire hose stations are seismically designed supplied from the LPSW system. The LPSW system is seismically designed. The LPSW system is capable of supplying the essential water system requirements and the fire flow simultaneously. Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 Design Basis Specification for Fire Protection Design Basis Specification for the Low Pressure Service Water System Section 3.7 Fire Extinguishers Where provided, fire extinguishersof the appropriatenumber,size, and type shall be provided in accordancewith NFPA 10, Standardfor PortableFireExtinguishers.Extinguishersshallbe permitted to be positioned outside of fire areas due to radiologicalconditions. Portable fire extinguishers are provided in accordance with NFPA 10, "Standard For Portable Fire Extinguishers." The portable extinguishers used on site are either "ABC", Carbon Dioxide, or Halon type fire extinguishers. Fire extinguishers are generally stationed in accordance the requirements of NFPA 10. In some instances extinguishers are not located in all areas due to ALARA. In these cases the extinguishers are located near the entrance to the areas. Halon fire extinguishers are provided in the Main Control Room, Training Simulator Room, the Communications Room, and at the vault in the first floor of Administrative Building.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 64 of 84 The NRC August 11, 1978 SER Section 4.3.3 states "Portablefire extinguishershave been distributed throughout the plant in accordance with NFPA guidelines. The licensee has proposedto provide Halon 1211 extinguisherin the control room."

         "Upon completion of the proposed modification, we find that portable fire extinguishers will conform to the provisions of Appendix A to BTP 9.5-1 and accordinglyis acceptable."The modification referenced above to install Halon extinguishers in the control rooms has been implemented.

{Further Action Required - Perform a NFPA 10 code compliance review.} Reference(s): NRC SER date August 11, 1978 __-------Design.-Basis-Specification-for-Eire-P-rotection_ _ 3.8 Fire Alarm and Detection Systems 3.8.1 FireAlarm Alarm initiatingdevices shall be installed in accordance with NFPA 72, National FireAlarm CodeO.Alarm annunciation shall allow the proprietaryalarm system to transmitfirei-related alarms, supervisory signals, and trouble signals to the'control room or other constantly attendedlocation from which requirednotifications and response can be initiated.Personnel assignedto the proprietaryalarmstation shallbe permitted to have otherduties. The following fire-relatedsignals shall be transmitted: (1) Actuation of any fire detection device (2) Actuation of any fixed fire suppressionsystem (3) Actuation of any manual fire alarm station (4) Starting of any fire pump (5) Actuation of any fire protection supervisory device (6) Indication of alarm system trouble condition The Oconee Nuclear Station power production areas are protected by two fire alarm systems. The fire alarm control panel for Units 1 and 2 is located in the Unit 1 &2 Control Room and the fire alarm control panel for Unit 3 is located in the Unit 3 Control Room. The Keowee Hydro Plant, SSF and Radwaste Facility each have their own fire alarm system which alarm to the Unit 1&2 and/or Unit 3 Control Room. The Fire Alarm and Detection Devices in general are installed in accordance with NFPA 72D (1975). The Design Basis Specification for the Fire Detection System, Design Basis Specification for Fire Protection, and BTP comparison provide additional detail on the Oconee fire detection system. The fire alarm systems are provided with capabilities to relay the fire-related signals from any

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 65 of 84 fire detection device, actuation of fixed fire suppression systems, actuation of manual fire alarm stations, actuation of supervisory signals, and alarm of trouble conditions. Start of the HPSW pumps used for the fire protection systems also alarm in the control room. Deviations from NFPA 72D are identified and justified by paragraph number per National Fire Code, 1975 as documented in the UFSAR, BTP comparison and Design Specification for Fire Protection. These Deviations from NFPA 72D are as follows: o 1221, 1223 - At Oconee, the alarm comes into the control room. The operator then notifies plant personnel of the fire location. o 1231 - Alarms on the control board are tested on each 12-hour shift by operator procedures. o 1232 - Procedures require annual testing of transmitters and water flow actuated devices. Water spray (deluge) systems for safety-related equipment are tested on an annual basis. o 2110 - The Oconee fire detection system is cabled using steel/aluminum sheathed #16 AWG cable for signal transmission. This cable meets or exceeds the requirements for physical and electrical protection as defined inNCA i i Ty o 2222, 2223 - The fire detection system at Oconee is powered from a battery backed power supply through a static inverter to provide 240/120 VAC. These batteries which are Class 1E but utilized as Non-Class 1E are continuously charged from normal station power. On loss of normal station power, the system is designed to provide power to the fire detection system for one hour. In addition, a transfer switch is provided for transferring the inverter loads to regulated normal station AC power should a maffunction of the battery inverter supply occur. o 2521 - The annunciator audible alert at Oconee serves the fire detection system as well as other plant systems. The visual indicator provided by the visual display prevents operator confusion regarding source of the alarm. The fire detection system provides an audible and visual alarm and annunciation in the control room. Local audible alarms do not sound at the location of the fire. The operator receives the alarm in the control room, dispatches plant personnel to the location of the alarm to ascertain the local conditions and then, if necessary, summons the fire brigade via the Public Address System (PA) and a radio paging system. Radwaste Fire Detection system alarms to the Unit 3 Control Room and Radwaste Facility control room. The SSF Fire Detection system alarm to the Unit 1 &2 Control Room, Unit 3 Control Room and the SSF Control Room. Keowee Hydro Station Fire Detection system provides an audible and visual alarm and annunciation in Keowee and ONS Unit 2 Control Room. The NRC August 11, 1978 SER Section 4.2 states 'The plant has a protective signaling

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 66 of 84 system which transmits alarms from fire detectors and water spray system actuation to the controlroom. Water flow on wet pipe sprinklersystems does not alarmin the control room. In general, the system complies with those provision of NFPA 72D which are considered essential for the facility, including requirements for emergency power supply and circuit supervision. There is no distinct audible fire alarm signalprovided in the control room."

        'The licensee has proposed to provide water flow alarms in the control room for all wet pipe sprinklersystems, and a unique audible signalin the control room for fire alarmnotification of the operators."
         'We find that, subject to the implementation of the proposedmodifications, the fire detection and signalingsystem in conjunction with the safe shutdown system satisfies the objectives of Section 2.2 of this report and is, therefore, acceptable." Modifications referenced above to providing water flow alarms and a distinct audible fire alarm signal in the control room have been implemented.

{Further Action Required - Perform a NFPA 72 code compliance review.) Reference(s): NRC SER dated August 11, 1978 Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 Design Basis Specification for Fire Protection Design Basis Specification for the Fire Detection System UFSAR Section 9.5.1.5.1 3.8.1.1 Means shall be provided to allow a person observing a fire at any location in the plant to quickly and reliably communicate to the control room or other suitable constantly attended location. All persons authorized access to the Oconee site receive instruction on the proper actions to be taken upon the discovery of a fire and the proper response to a fire alarm. The primary method of communication is the telephone system with outside as well as in-plant connections. In conjunction with the telephone, a page system is used for calls throughout the plant. Each telephone is marked with the emergency reporting numbers. Emergency reporting numbers communicate to a constantly attended location (Control Room or Security). The Keowee Hydro Station has several methods of communication. There are in-station page phones and telephones connected to Oconee. There is an automatic ring down phone to Oconee Unit 2 Control Room.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 67 of 84 Reference(s): Design Basis Specification for Fire Protection General Employee Training - Plant Access Training 3.8.1.2 Means shall be provided to promptly notify the following of any fire emergency in such a way as to allow them to determine an appropriatecourse of action: (1) Generalsite population in all occupied areas (2) Members of the industrialfire brigadeand othergroups supportingfire emergency response (3) Off-site fire emergency response agencies. Two independent means shall be available (e.g., telephone and radio) for notificationof off-site emergency services Oconee is provided with a plant-wide PA system that is used to alert the general site ..-- any necessary -instructions.

                                                  -.             .    ..                   .   .    ..

Operations informs plant personnel of the location of a fire emergency by using the PA, dispatches personnel to ascertain the local conditions and then, if necessary, summons the fire brigade by the PA, fire brigade pagers and radio communication. The Radiation Protection, Safety, and Security personnel are alerted by the PA announcement and respond as necessary to support the Fire Brigade as determined by the Fire Brigade Leader as Incident Commander' If off-site assistance is determined to be prudent, the Control Room will contact the appropriate agencies via telephone. Secondary communication to off-site fire departments is through off-site radio communication. Off-site radios capable of communication with the off-site emergency response agencies are located in the Control Room, Security, and the station rescue vehicle. The instructions on the methods to be used to contact the off-site fire emergency agencies are provided in Procedure RP/0/B/1 000/029 "Fire Brigade Response." Reference(s): RP/O/B/1000/029 "Fire Brigade Response" 3.8.2 Detection If automatic fire detection is requiredto meet the performanceordeterministicrequirementsof Chapter4, then these devices shall be installed in accordancewith NFPA 72, NationalFire Alarm Code, and its applicableappendixes. The NRC August 11, 1978 SER Section 4.2 states 'The plant has a protective signaling system which transmits alarms from fire detectors and water spray system actuation to the control room. Water flow on wet pipe sprinklersystems does not alarmin the control room. In

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 68 of 84 general, the system complies with those provision of NFPA 72D which are considered essential for the facility, including requirements for emergency power supply and circuit supervision. There is no distinctaudible fire alarm signalprovided in the control room."

         "Smoke detectors in some areasof the plant containingelectricalcable insulationare located lower than the ceiling level and, therefore,may not respondas rapidly as they would if located at the ceiling. However, since fires in cable insulation generateheavy quantities of smoke, reasonablyprompt detection can be expected. Ionization type smoke detectors are used throughout the plant. In some tests, ionizationtype detectors have not respondedas rapidlyto a fire involving PVC as they do to a fire involving othertypes of insulation. Tests have shown that they are, however, adequate to detect first in their early stages. To assure that fires in safe shutdown areas of the plant are detected, the licensee has proposed,in addition to the exiting detection system, to provide detectorsin allareas containingsafe shutdown equipment and combustibles. In addition, the licensee has proposed to provide a dedicated safe shutdown system which would be unaffected by fires involving safe shutdown equipment such that the plant can be safely shut down in the event of a fire in any location in the plant."
         "We find that,subject to the implementation of the proposed modifications, the fire detection and signalingsystem in conjunction with the safe shutdown system satisfies the objectives of Section 2.2 of this report and is, therefore, acceptable." Modifications referenced above including addition of detectors in areas containing safe shutdown equipment and providing a dedicated safe shutdown system have been implemented.

Original deviations to the fire detection system are listed in the Design Basis Specification for Fire Protection and the Design Basis Specification for the Fire Detection System. Modifications to the fire detection system have since been performed. Modifications are performed in accordance with NFPA 72. A major upgrade to the fire detection system was performed under modification NSM-52796 in 1992. Currently the NRC committed fire detection instrumentation devices are listed in SLC 16.9.6. {Further Action Required - Upon completion of Chapter 4 work and determination where automatic fire detection is required to meet the performance or deterministic requirements of NFPA 805, PRA, change evaluation or defense-in-depth. Perform a NFPA 72 code compliance review of the fire alarm and detection systems.} Reference(s): NRC SER dated August 11, 1978 Design Basis Specification for Fire Protection Design Basis Specification for the Fire Detection System SLC 16.9.6

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2. & 3 Page 69 of 84 Section 3.9 Automatic and Manual Water-Based Fire Suppression Systems 3.9.1 If an automatic or manual water-based fire suppression system is required to meet the performance or deterministicrequirementsof Chapter4, then the system shallbe installedin accordancewith the appropriateNFPA standards including the following: (1) NFPA 13, Standardfor the Installation of Sprinkler Systems (2) NFPA 15, Standardfor Water Spray Fixed Systems for Fire Protection (3) NFPA 750, Standardon Water Mist Fire Protection Systems (4) NFPA 16, Standard for the Installation of Foam-WaterSprinkler and Foam-Water Spray Systems There are no NFPA 750 water mist systems. The one NFPA 16 foam-water system in Radwaste is abandoned in place. The Oconee Nuclear Station is protected by automatic wet pipe sprinkler systems, water spray system, and deluge systems. The Design Basis Specification for Fire Protection and Engineering Support Program Document for Fire Protection provide additional detail on the Oconee water based fire suppression systems. The automatic sprinkler systems were designed to conform to requirements of appropriate NFPA Standards with deviations as identified by the individual system as-built code compliance calculations. Each automatic sprinkler system has an independent connection to the plant HPSW System. The Keowee Service Water System supplies the Keowee main transformer deluge system, lube oil room and gravity oil room. Valves for the HPSW and SW systems are not electrically supervised; however, the station requires fire protection valves to be sealed or locked in the normal open position. Currently the NRC committed fire suppression systems are listed in SLC 16.9.2. Code compliance calculations are prepared for each Turbine Building and Auxiliary Building suppression system. PIP 0-02-06047 has been initiated to disposition comments from the Fire Suppression NFPA Code Review project. The NRC August 11, 1978 SER Section 4.3.1.3 states 'Wetpipe automaticsprinklerprovide area coverage over those portions of the turbine building basement and mezzanine levels which contain the turbine oil piping systems."

        "Automaticwater spray systems are installed on the turbine oil headers and reservoirs,feed waterpumps, andhydrogen sealoil units in the turbinebuilding;and on oil-filled transformers and reactorsin the yard areas. The waterspray systems are designedaccordingto applicable NFPA Standards."

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 70 of 84

         'We find that the sprinklersystems meet the requirements of Appendix A of BTP 9.5-1 and are, therefore, acceptable."

{Further Action Required - Upon completion of Chapter 4 work and determination where water based fire suppression systems are required to meet the performance or deterministic

        *requirements of NFPA 805, PRA, change evaluation or defense-in-depth; review the applicable Fire Suppression NFPA Code Review calculations for adequacy. Perform new code compliance reviews as necessary.)

Reference(s): NRC SER dated August 11, 1978 SLC 16.9.2 Engineering Support Program Document for Fire Protection Design Basis Specification for Fire Protection N........t....e.a.e............ ............

                                                                                      .

Fire Suppression NFPA Code Review calculations PIP 0-02-06047 3.9.2 Each system shall be equipped with a water flow alarm. All fixed extinguishing systems are provided with alarms. Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 Duke letter to the NRC-dated November 22, 1977 Design Basis Specification for Fire Protection 3.9.3 All alarms from fire suppressionsystems shallannunciatein the control room or othersuitable constantly attendedlocation. All extinguishing systems including sprinklers and deluge systems alarm to the Control Room and/or Security. Alarms associated with the Keowee Fire Protection System are annunciated in the Unit 2 Main Control Room and the Keowee Control Room. Reference(s): Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 Duke letter to the NRC dated November 22, 1977

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 71 of 84 Design Basis Specification for Fire Protection Design Basis Specification for the Fire Detection System 3.9.4 Diesel-driven fire pumps shall be protectedby automatic sprinklers. The Oconee Plant does not utilize a diesel driven fire water pump. Reference(s): Design Basis Specification for Fire Protection 3.9.5 Each system shall be equipped with an OS&Y gate valve or other approvedshutoff valve. Each automatic sprinkler system has a connection to the plant HPSW System. Each system can be isolated from the main header with an approved control valve. The NRC August 11, 1978 SER Section 4.3.1.3 states 'All yard fire hydrants, fixed water suppressionsystems, and interiorhose lines are supplied by the HPSW system through undergroundyard mains andheaders inside buildings. Sectionalizing valves areprovided to allow isolationof varioussections of the system for maintenance;however there arelocations in the turbine building where a single piping break could affect both automatic water suppressionsystems and manual hose stations. The licensee has proposedto cross-connect the ends of the two auxiliarybuildingheadersto provide dual feed for the hose stationsin this area.

        'We conclude that, upon implementation of the modifications describedabove, the fire water piping system meets the objectives outlined in Section 2.2 of this report and are, therefore, acceptable." Note that modifications referred to in the conclusion pertain to cross-connections of the auxiliary building headers to provide dual feed for hose stations in the area and are not applicable to this NFPA 805 section.

Reference(s): NRC SER dated August 11, 1978 Response to Appendix A to Branch Technical Position APCSB 9.5-1, February 1982 3.9.6 All valves controllingwater-basedfire suppressionsystems requiredto meet the performance or deterministic requirementsof Chapter4 shallbe supervised as describedin 3.5.14.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 72 of 84 Valves for the ONS Plant HPSW and Keowee SW System are not electrically supervised. A program at the station requires fire protection valves to be sealed or locked in the normal open position. A periodic recorded inspection is conducted to ensure that the fire protection valve positions are correct. See Section 3.5.14. Reference(s): N/A Section 3.10 Gaseous Fire Suppression Systems 3.10.1 If an automatictotal flooding andlocal applicationgaseous fire suppressionsystem is required to meet the performanceor deterministicrequirementsof Chapter4, then the system shallbe designed and installedin accordancewith the following applicableNFPA codes: (1) NFPA 12, Standardon Carbon Dioxide Extinguishing Systems (2) NFPA 12A, Standardon Halon 1301 Fire ExtinguishingSystems (3) NFPA 2001, Standardon Clean Agent Fire Extinguishing Systems, The gaseous fire suppression systems at the Oconee Nuclear Plant are utilized to protect unique components and/or hazards. The SSF Diesel Generator Room is protected by a low pressure total flooding carbon dioxide suppression system. SSF Diesel Generator Room C0 2 system is not a regulatory committed system. The two Keowee Hydroelectric generators are each protected by a High Pressure Carbon Dioxide Suppression System that provides CO 2 directly into the generator housing. The Keowee C02 Fire Suppression System is currently a NRC committed system listed in SLC 16.9.3. The Administration Building Record Storage Vault, Oconee Operator Training Center Simulator, and Complex Office Building communication room is protected by a Halon 1301 total flood fire suppression system. These buildings are, however, not part of the power production plant covered by these fire protection requirements and are not discussed in the following sections {Further Action Required - Upon completion of Chapter 4 work. and determination where gaseous fire suppression systems are required to meet the performance or deterministic requirements of NFPA 805, PRA, change evaluation or defense-in-depth. Perform a NFPA 12 code compliance review.} Reference(s): Design Basis Specification for Fire Protection SLC 16.9.3

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 73 of 84 3.10.2 Operationof gaseous fire suppressionsystems shall annunciateandalarmin the control room or other constantly attended location identified. Actuation of the Keowee Hydro Station C02 system is alarmed in the ONS Unit 2 Control Room and at Keowee. Operation of the SSF Diesel Room C02 system is alarmed in the Unit 2 Control Room and Security. Reference(s): Design Basis Specification for Fire Protection Design Basis Specification for the Fire Detection System 3.10.3 Ventilation system design shall take into account prevention from over-pressurizationduring agent injection, adequate sealing to prevent loss of agent, and confinement of radioactive contaminants. The Keowee Hydro Station system injects into the respective hydroelectric generator's housing and not into a ventilation system. The leak tightness of the housings is included in the system testing procedure to ensure substantial concentration. The SSF C02 System injects only into the Diesel Generator Room. The ventilation system to the room is isolated during system actuation to ensure concentration for at least 30 minutes. There are no radioactive contaminants involved at either location protected by the gaseous fire suppression systems. {Further Action Required - Evaluate and documentthe potential effects of over pressurization in the areas of C02 System discharge.} Reference(s): Design Basis Specification for Fire Protection 3.10.4 In any area requiredto be protectedby both primary and backup gaseous fire suppression systems, a single active failure or a crack in any pipe in the fire suppressionsystem shall not impairboth the primary and backup fire suppressioncapability.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 74 of 84 There are no installed backup gaseous fire suppression systems utilized at Oconee. The Keowee C0 2 is designed for a "dual shot" capacity. The installed gaseous suppression systems can be manually initiated. The CO2 system in the SSF Diesel Generator Room is installed for property conservation and is not a NRC committed system, however the tank is sized for "dual shot" capability. {Further Action Required - Upon completion of Chapter 4 work and determination if backup gaseous fire suppression systems are required to meet the performance or deterministic requirements, PRA, change evaluation or defense-in-depth; compliance with this section should be reviewed.) Reference(s): Design Basis Specification for Fire Protection 3.10.5 Provisionsfor locally disarmingautomaticgaseous suppressionsystems shall be securedand under strict administrativecontrol. Any change to any plant system or component is strictly controlled at the Oconee Nuclear Station. Only mechanical lock-outs are allowed when personnel safety is involved. In addition, any change to the alignment for automatic actuation of either the Keowee Hydro Station C0 2 system or the SSF C0 2 system would result in an alarm. Maintenance and testing of the C0 2 Systems is controlled through approved work authorizations and appropriate implementing procedures. Reference(s): OP/0/A1 600/004 "Operation of the SSF C02 System" PT/O/A/0400/002 "SSF C02 Test" PT/1/A/2200/006 "KHU-1 C02 System Surveillance" PT/2/1A2200/006 "KHU-2 C02 System Surveillance" 3.10.6 Total flooding carbon dioxide systems shall not be used in normally occupied areas. The Keowee Generator housing and the SSF Diesel, generator room are not normally occupied areas. When access for testing and/or maintenance purposes is authorized, plant procedures require disarming the automatic actuation feature. Reference(s): OP/O/A/1 600/004 "Operation of the SSF C02 System"

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 75 of 84 PT/0/A/0400/002 "SSF C02 Test" PT/1/A/2200/006 "KHU-1 C02 System Surveillance" PT/2/A/22001006 "KHU-2 C02 System Surveillance" 3.10.7 Automatic total flooding carbon dioxide systems shall be equipped with an audible pre-dischargealarm and discharge delay sufficient to permit egress of personnel. The carbon dioxide system shall be provided with an odorizer. Any work conducted inside the Keowee Hydro generator housings or inside the SSF Diesel Generator Room would require authorization via the work control process which may require manually isolating and Red Tagging the CO 2 System prior to entry. The Keowee C02 System whistles on discharge. The Keowee Hydro Station's C02 supply is not provided with an odorizer because the area inside the generator housing would not be occupied unless testing or maintenance work was being conducted which would require the C02 system to be manually isolated. Work inside the SSF Diesel Generator Room would require the issuance of a work authorization which would include a restriction to manually isolate the C02 System prior to entry if work was above the floor level such that egress time is impaired. There is a Pre-Discharge Alarm for the SSF Diesel Generator Room and the alarm is set between 60 and 70 seconds. There is an odorizer in the SSF C02 System that uses a "garlic" scent. Reference(s): PT/O/A/0400/002 "SSF C02 Test" 3.10.8 Positivemechanicalmeans shall be provided to lock out total flooding carbondioxide systems during work in the protected space. Each C02 system has manual isolation valves. The SSF C02 system can be locked out by manually closing the tank shutoff valve. The Keowee Hydro Station C02 system contains an interlock requiring the generator doors to be closed for actuation. This interlock feature is routinely verified during system surveillance. In addition, the Keowee C02 supply header isolation valve can be manually closed. Closure of the supply tank valve would be included as a prerequisite for work authorization involving access to the inside of the generator housing. Reference(s): OP/OIA/1 600/004 "Operation of the SSF C02 System" PT/O/A/0400/002 "SSF C02 Test" PT/1/A/2200/006 "KHU-1 C02 System Surveillance" n

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 76 of 84 PT/2/A/2200/006 "KHU-2 C02 System Surveillance" 3.10.9 The possibility of secondary thermalshock (cooling) damage shall be considered during the design of any gaseous fire suppressionsystem, but particularlywith carbon dioxide. The only locations that utilize C02 systems are the Keowee Hydro Station Generator Housings and the SSF Diesel Generator Room. There are no sensitive components that would be damaged by the rapid cooling resulting from a C02 system discharge into either of these locations. (Further Action Required - Evaluate and document the potential effects of rapid cooling of the Keowee Generators or the SSF Diesel Generator and their associate components in the area of C02 System discharge.} Reference(s): None 3.10.10 Particularattentionshallbe given to corrosivecharacteristicsof agentdecompositionproducts on safety systems. The C02 system for the winding brushes on the Keowee Hydro Station Generator Housings would be considered a spatially separate safety system. Only one generator is needed to provide emergency power to the Oconee Plant. Fires are not assumed simultaneously at Keowee and Oconee The SSF C02 system discharges only to the Diesel Generator Room which is considered a safety system. [Further Action Required - Evaluate and document the potential effects of corrosivity on the Keowee Generators or the SSF Diesel Generator and their associate components in the area of C02 System discharge.} Reference(s): Design Basis Specification for Fire Protection Section 3.11 Passive Fire Protection Features This section shall be used to determine the design and installationrequirementsfor passive protection features. Passive fire protectionfeatures include wall, ceiling, andfloor assemblies, fire doors, fire dampers, and through fire barrierpenetration seals. Passive fire protection features also include electricalraceway fire barriersystems (ERFBS) that are provided to

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 77 of 84 protectcables and electricalcomponents and equipment from the effects of fire. Passive fire protection features at Oconee include fire rated assemblies for building separation including fire wall, fire doors, fire dampers and penetration seals. Oconee does not utilize electrical raceway fire barrier systems (ERFBS) for passive fire protection. 3.11.1 Building Separation Each major building within the power block shall be separatedfrom the others by barriers having a designatedfire resistanceratingof 3 hours orby open space of at least 50 ft (15.2 m) or space that meets the requirementsof NFPA 80A, Recommended Practicefor Protectionof Buildings from ExteriorFire Exposures. Exception: Where a performance-based analysis determines the adequacy of building separation,the requirements of 3.11. 1 shall not apply. There are three main buildings in the power block; the Turbine Building, the Auxiliary Building and the Reactor Building. The Turbine Building and Auxiliary Building are separated by a three-hour rated fire barrier. The fire barrier is not a fully committed BTP 9.5-1 barrier and thus not maintained as such. Committed three hour fire barriers are controlled by SLC 16.9.5 and shown on the 0-310-K and 0-31 0-L series drawings include: 0 Unit 1 & 2 Equipment Rooms from 5'-4" north of column line 68 to 6'-4" south of column line 78.

• Unit 3 Equipment Room from column line N to column line R and from column line 87 to 6'-7" south of column line 93.
• Unit 1 & 2 Cable Rooms from 6'-7" north of column line 68 to 6'-10" south of column line 93.
• Unit 3 Cable Rooms from column line 87 to 6'-7" south of column line 93
• Unit 1 & 2 Control Room from column line 69 to 77
• Unit 3 Control Room from column line 87 to 92.

Note: The above wall sections outlines the Turbine Building to Control Complex portion of the Control Rooms, Cable Rooms, and Equipment Rooms. The committed portion of the above barrier extends 50 feet beyond the Control Complex. The Auxiliary Building and the Reactor Building are separated by a substantial reinforced concrete wall. Certain areas of this AB/RB common wall are rated for three hours between the Reactor Building. These areas include some areas of the general Auxiliary Building rooms, the East Penetration Room and West Penetration Room. The remainder of the AB/RB common wails are not considered a fire barrier. In addition, the East Penetration Room and the West Penetration Room are separated by a qualified three-hour fire wall.

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1- 2, & 3 Page 78 of 84 The NRC August 11, 1978 SER Section 4.11 states "Firebarriershave been provided to separate the turbine building from the auxiliarybuilding, and to cut off the equipment rooms, cable spreadingrooms, controlrooms, penetrationareasand blockhouses from surrounding fire areas. Based on the type andquantity of combustiblespresent, the basic fire resistanceof the barrierswould prevent the spread of fire between fire areas."

            "Upon completion of the dedicated safe shutdown system, the facility will be able to sustain a fire in any fire area and still achieve safe shutdown of the three units. We conclude that, upon completion of the dedicatedsafe shutdown system, the fire barriersmeet the objectives outlinedin Section 2.2 of this reportandare, therefore,acceptable." The dedicated shutdown system (SSF) has been completed.

The SSF is of substantial concrete (non-combustible) construction and is physically separated from the Reactor and Auxiliary Buildings by a distance of greater than 50 feet. The electrical

                                 -nn-6c-t -fhii--rffi---to4e--SS F--to---thd--A-0 IliaF- -B-0i d iig -ar -9t

--....-.. ---- -d-e.-.... i c-a-nl-oi-underground. The Keowee Powerhouse is a noncombustible structure that is physically located a significant distance from the other Oconee power block structures with no direct connections other than electrical wiring.

References:

NRC SER dated August 11, 1978 Drawing Series 0-310 K and L NRC Exemption to various Appendix R Requiremen'ts dated August 21,1989 NRC Letter dated April 14, 1981 Design Basis Specification for Fire Protection NRC SER dated April 28,1983 SLC 16.9.5 3.11.2 Fire Barriers Fire barriersrequiredby Chapter4 shall include a specific fire-resistancerating. Firebarriers shall be designed and installed to meet the specific fire resistance rating using assemblies qualified by fire tests. The qualification fire tests shall be in accordance with NFPA 251, StandardMethods of Tests of FireEnduranceof Building ConstructionandMaterials,orASTM E 119, Standard Test Methods for Fire Tests of Building Constructionand Materials. Fire barriers are provided to separate the Turbine Building and Auxiliary Building and to cut off the Equipment Rooms, Cable Spreading Rooms, Control Rooms, Penetration Rooms and Blockhouses from the surrounding areas. Construction of these fire barriers are equivalent to a three-hour barrier.

'Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 79 of 84 Committed and non-committed fire barriers for the Turbine Building, Auxiliary Building and Reactor Building (including mechanical and electrical penetrations, fire doors, fire dampers, walls, ceiling and floors) boundaries are shown on the 0-310-K and 0-31 0-L series drawings. NRC committed fire barriers are discussed in SLC 16.9.5. The use of unrated seismic joints between the East Penetration Rooms and the West Penetration Rooms were evaluated by the NRC and found to be acceptable in the August 21, 1989 evaluation that granted an Exemption from the Fire Protection Requirements of Section I*II.G of 10 CFR Part 50, Appendix R. The NRC also evaluated the separation between the East and West penetration rooms and determined that the electrical divisions were "effectively separatedby a three-hourfire barrier." This determination was documented in the NRC Letter dated April 14, 1981. The wall qualification is further supported by OSC-71 85. The NRC August 11, 1978 SER Section 4.11 states "Firebarriershave been provided to separatethe turbine building from the auxiliary building, and to cut off the equipment rooms, cable spreadingrooms, control rooms, penetrationareasandblockhouses from surrounding fire areas. Basedon the type andquantity of combustiblespresent,the basicfire resistanceof the barrierswould prevent the spreadof fire between fire areas."

         "Upon completion of the dedicatedsafe shutdown system, the facility will be able to sustaina fire in any fire area and still achieve safe shutdown of the three units. We conclude that, upon completion of the dedicatedsafe shutdown system, the fire barriersmeet the objectives outlinedin Section 2.2 of this reportand are, therefore, acceptable." The dedicated shutdown system (SSF) has been completed.

{Further Action Required - Upon completion of Chapter 4 work, identify barriers credited for compliance, PRA, defense-in-depth or as part of the change evaluation process. Review if credited barriers are adequate.} Reference(s): NRC SER dated August 11, 1978 Drawing Series 0-310 K and L NRC Exemption to various Appendix R Requirements dated August 21,1989 NRC Letter dated April 14, 1981 Design Basis Specification for Fire Protection SLC 16.9.5 OSC-7185

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 80 of 84 3.11.3 Fire BarrierPenetrations Penetrationsin fire barriersshall be provided with listed fire-rated door assemblies or listed rated fire dampers having a fire resistanceratingconsistent with the designatedfire resistance rating of the barrieras determinedby the performance requirementsestablishedby Chapter4. (See 3.11.4 for penetrationseals for through penetration fire stops.) Passivefire protection devices such as doors and dampers shall conform with the following NFPA standards,as applicable: (1) NFPA 80, Standardfor.Fire Doors and Fire Windows (2) NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems (3) NFPA 101, Life Safety Code Exception: Where ...............--------- bh-bfire -if - ff i - are areaboundaries l-t-*hb u wall-to-wall, re not floor-to-ceilingboundaries with all _e6-f-_thJ*--b -5*-h-----,-*--f if *--

• d ..

penetrations sealedT&toe fi? u7caUhboid oui s, aperformandc-b.ýd-- analysis shall be requiredto assess the adequacy of fire barrierforming the fire boundaryto determine if the barrierwill withstandthe fire effects of the hazards in the area. Openings in fire barriersshall be permitted to be protectedby other means as acceptable to the AHJ. Committed and non-committed fire barriers for the Turbine Building, Auxiliary Building and Reactor Building (including mechanical and electrical penetrations, fire doors, fire dampers, walls, ceiling and floors) boundaries are shown on the 0-310-K and 0-31 0-L series drawings. NRC committed fire barriers are discussed in SLO 16.9.5. The NRC August 11,1978 SER Section 4.9.2 states "Thelicensee hasproposed to make the following modification on doors and hatches in fire barriers: (1) Replace unlabeled fire doors and frames in fire barrierswith properlylabeled fire doors and frames. (2) Modify double-leaf fire doors to normally keep one door closed to assure proper closure. (3) Modify the door arrangement of openings between the turbine building and auxiliary.building to prevent glass doors from obstructing automatic fire door closure. (4) Upgradethe metal hatch plates in the floor between the cable spreadingroom and control room to provide a 3-hour fire ratedbarrier. The license has stated that doors separateredundantsafe shutdown equipment orprotecting safe shutdown equipment from large hazards are alarmed to the control room andprovided with automatic closure devices."

                "Upon completion of these modifications, the doorway and hatch penetrationsof fire barriers will conform to the provisions of Appendix A to BTP 9.5-1 and are, therefore, acceptable."

Calculation No.: - OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 81- of 84 The fire door modifications referenced above have been implemented. Duke letter to the NRC dated May 15, 1981 responded to some modifications indicating completion or insurance company approval of existing fire door configurations. The NRC August 11, 1978 SER Section 4.9.3 states "Firedampers have been provide at some locations where ventilation ducts penetratefire barriers. The licensee hasproposedto upgrade ventilation duct penetrations with dampers having fire ratings equivalent to that requiredby fire barriers."

         'We find that, subject to implementation of the above modifications, ventilation duct penetrationswill satisfy the objectives identified in Section 2.2 of this reportandare, therefore, acceptable." Current fire barrier ventilation duct penetrations are provided with fire dampers.

[Further Action Required - Upon completion of Chapter 4 work, identify barriers credited for compliance, PRA, defense-in-depth or as part of the change evaluation process. Review if credited barrier penetrations are adequate.) Reference(s): NRC SER dated August 11, 1978 Duke Letter to the NRC, dated May 15, 1981 Drawing Series 0-310 K and L Design Basis Specification for Fire Protection SLC 16.9.5 3.11.4 Through PenetrationFire Stops Through penetrationfire stops for penetrationssuch as pipes, conduits, bus ducts, cables, wires, pneumatic tubes and ducts, andsimilar building service equipment thatpass through fire barriersshall be protected as follows. (a) -The annular space between the penetrating item and the through opening in the fire barriershall be filled with a qualified fire-resistive penetration seal assembly capable of maintaining the fire resistanceof the fire barrier.The assembly shall be qualified by tests in accordancewith a fire test protocolacceptableto the AHJ or be protectedby a listedfire-rated device for the specified fire-resistive period. (b) Conduits shall be provided with an internalfire seal that has an equivalent fire-resistive ratingto thatof the fire barrierthrough opening fire stop and shallbe permittedto be installed on eitherside of the barrierin a location that is as close to the barrieras possible. Exception: Openings inside conduit 4 in. (10.2 cm) or less in diametershall be sealedat the fire barrierwith a fire-ratedinternalseal unless the conduit extends greaterthan 5 ft (1.5 m) on each side of the fire barrier. In this case the conduit opening shall be provided with noncombustible materialto prevent the passageof smoke andhot gases. The fill depth of the materialpacked to a depth of 2 in. (5.1 cm) shall constitutean acceptablesmoke andhot gas

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 82 of 84 seal in this application. Through penetration fire stops for penetrations such as pipes, conduits, cables, pneumatic tubes, etc in rated fire barriers are generally provided with rated penetration seals. The site FPE maintains the Penetration Seal Database in the site EDB and 86-10 Evaluation calculation documenting the acceptability of the station penetration seals in Calculation OSC-7350. OSC-7359 (DPC 1435.00-00-0006) identifies that Oconee is committed to the criteria of IEEE P634 for electrical and mechanical fire barrier penetration seals. UFSAR Section 9.5.1.4.3 Item 4 states "Electricalpenetrationsealdesigns shallbe subjected to a standardexposure fire that follows the ASTM E- 119 StandardTime- Temperature Curve. The acceptance criteria from IEEE 634 (which is identicalto that of IEEE P634/D4)_ shall be used to evaluate the acceptabilityof test assemblies. The IEEE 634 acceptancelimit for ONS unexposed side electrical penetration temperature shall be 700 0F. This temperature was selected because the IEEE 634 acceptance criteria is the auto-ignition temperature of the outer cable covering and materialin contact with the cable penetration fire stop, or 700 0F, whichever is lower. The ignition temperatureof outer cablejacketing has been determined to be 7350 F. Mechanical penetrationseal designs shall be subjected to a standard exposure fire that follows the ASTM E- 119 Standard Time-Temperature Curve. The acceptance criteria from IEEE-634 (which is identical to that of IEEE P634/D4) shall be used to evaluate the acceptabilityof test assemblies. The IEEE 634 acceptancelimit for Duke Powermechanical penetrationseals shall be 6800F. This temperature was selected because it represents the lowest auto ignition temperature of any material normally found in close proximity to piping penetrations(Armstrong Armalok pipe insulation)." The use of unrated fire penetrations in the ceiling of the West Penetration Room and unrated mechanical pipe penetrations between the Reactor Building and Penetration Rooms were evaluated by the NRC and found to be acceptable in the August 21, 1989 evaluation that granted an Exemption from the Fire Protection Requirements of Section III.G of 10 CFR Part 50, Appendix R. The NRC also evaluated the separation between the East and West penetration rooms and determined that the electrical divisions were "effectively separatedby a three-hourfire barrier." This determination was documented in the NRC Letter dated April 14, 1981. {Further Action Required - Upon completion of Chapter 4 work, identify barriers credited for compliance, PRA, defense-in-depth or as part of the change evaluation process. Review if credited penetration seals are evaluated by Calculation OSC-7350.} Reference(s): Drawing Series 0-310 K and L

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page 83 of 84 NRC Exemption to various Appendix R Requirements dated August 21, 1989 NRC Letter dated April 14, 1981 Design Basis Specification for Fire Protection SLC 16.9.5 Calculation OSC-7350, ONS Penetration Seal Database and 86-10 Evaluations UFSAR Section 9.5.1.4.3 OSC-7359 (DPC 1435.00-00-0006), Calculation for the Technical Basis for Fire Barrier Penetration Seals 3.11.5 ElectricalRaceway Fire BarrierSystems (ERFBS) ERFBS requiredby Chapter4 shallbe capable of resisting the fire effects of the hazardsin the area. ERFBS shall be tested in accordancewith and shall meet the acceptance criteria of BarrierSystems Used to Separate Safe Shutdown Trains Within the Same FireArea." The ERFBS needs to adequatelyaddress the design requirementsandlimitationsof supports and intervening items and their impact on the fire barriersystem rating. The fire barriersystem's ability.to maintainthe requirednuclearsafetycircuits free of fire damage for a specific thermal exposure, barrier design, raceway size and type, cable size, fill, and type shall be demonstrated. Exception No. 1: When the temperaturesinside the fire barriersystem exceed the maximum temperature allowed by the acceptance criteria of Generic Letter 86-10, "Fire Endurance Acceptance Test Criteria for Fire Barrier Systems Used to Separate Redundant Safe Shutdown Training Within the Same Fire Area," Supplement 1, functionality of the cable at these elevatedtemperaturesshall be demonstrated. Qualificationdemonstration of these cables shall be performed in accordance with the electrical testing requirements of Generic Letter 86-10, Supplement 1, Attachment 1, 'Attachment Methods for Demonstrating Functionality of Cables Protectedby Raceway Fire BarrierSystems During and After Fire Endurance Test Exposure." Exception No. 2: ERFBS systems employed prior to the issuance of Generic Letter 86-10, Supplement 1, areacceptableproviding that the system successfully met the limitingendpoint temperature requirements as specified by the AHJ at the time of acceptance. The Oconee design does not currently utilize ERFBS {Further Action Required - Upon completion of Chapter 4 work, identify barriers credited for compliance, PRA, defense-in-depth or as part of the change evaluation process. Review if credited ERFBS are rated appropriately.} Reference(s): Design Basis Specification for Fire Protection VII. CONCLUSIONS

Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1,2. & 3 Page 84 of 84 The Oconee fire protection program complies with the requirements of NFPA 805, Chapter 3 upon resolution of open items and NRC approval on specified sections. VIII. ATTACHMENTS Attachment A - Compliance Table

                                                                                ........
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Calculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Attachment A Attachment A Compliance Table 37 Total Pages

Cafiulation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page Al of A37 NFPA 805 Chapter 3 Section Complian ce Statement Compliance Summary Note: All informationbelow is summarized; for complete details, see the reportin AttachmentlA, Links are provided below. Turn on Web Toolbar. Section 3.1 General This chaptercontains the fundamental elements of the fire protection program and specifies the minimum design requirements for fire protection systems and features. These fire protection programelements and minimum design requirements shall not be subject to the performance-basedmethods permitted elsewhere in this standard.Previously approvedalternatives from the fundamentalprotection program attributesof this chapter by the AHJ take precedence over the requirements,containedherein. Section 3.2 Fire Protection Plan 3.2.1 Intent Comply A site-wide Fire Protection Plan has been established. A site-wide fire protectionplan shall be established.This plan shall The haS Fie Protecion document managementpolicy and program directionand shall define the responsibilitiesof those individualsresponsible for the plan's Program is documented in implementation. This section establishes the criteriafor an integrated the Design Basis combination of components, procedures,and personnelto implement Specification for Fire all fire protection program activities. Protection. 3.2.2 Management Policy Direction and Responsibility Comply I A policy document has i been developed. The ONS A policy document shall be preparedthat defines management b authorityand responsibilitiesand establishes the generalpolicy for the Fire Protection Program site fire protection program. policy is documented in the Design Basis Specification for Fire Protection. 3.2.2.1 Comply The Site Vice President is The policy document shall designate the seniormanagementposition I documented as responsible with immediate authority and responsibilityfor the fire protection for the implementation of program. the fire protection program.

Catculation No.: OSC-9295 Revision No.: b Applicable Units: Oconee Unit 1, 2, & 3 Page A2 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary 3.2.2.2 Comply The Fire Protection The policy document shall designate a position responsible for the daily Engineer is responsible for administrationand coordinationof the fire protection program and its the administration of the fire implementation. protection program. 3.2.2.3 Comply I The interfaces between the The policy document shall define the fire protection interfaces with fire protection program and other organizationsand assign responsibilitiesfor the coordinationof other organizations and fire activities. In addition, this policy document shall identify the various protection programs are plant positions having the authority for implementing the variousareas I documented in the Design of the fire protectionprogram. Specification for Fire Protection.

                                                                                                                     --- -- - ------

3.2.2.4 Further A61tion Required Oconee will enhance The policy document shall identify the appropriateAHJ for the various current documentation, prior areas of the fire protection program. to implementation of the NFPA 805 program, to include the NRC as the authority having jurisdiction for fire protection changes requiring approval. 3.2.3 Procedures Comply Procedures have been Proceduresshall be establishedfor implementation of the fire established for

        *protectionprogram. In additionto procedures that could be requiredby                               implementing the fire othersections of the standard,the proceduresto accomplish the                                      protection program.

following shall be established: 1. The Engineering (1) Inspection, testing, and maintenance for fire protection Support Document for systems and features creditedby the fire protectionprogram Fire Protection provides

C(aculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page A3 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary (2) Compensatoryactions implemented when fire protection a detailed listing of systems and other systems credited by the fire protection - applicable surveillance program and this standardcannot perform their intended procedures. function and limits on impairmentduration (3) Reviews of fire protection program- relatedperformance have been established. and trends

3. Fire protection program (4) Reviews of physicalplant modifications and procedure reviews are performed.

changes for impact on the fire protection program

4. Plant modification (5)Long-term maintenanceand configurationof the fire reviews for impact on protectionprogram the fire protection (6) Emergency response procedures for the plant industrialfire program are performed.

brigade ba5. Long term maintenance and configuration procedures for the fire protection program have been established.

6. Emergency response procedures for the plant fire brigade are documented.

Section 3.3 Prevention A fire prevention program with the goal of preventinga fire from starting shall be established,documented, and implemented as part of the fire protection program. The two basic components of the fire prevention program!shall consist of both of the following: (1) Preventionof fires and fire spreadby controls on operationalactivities (2) Design controls that restrict the use of combustible materials The design control requirements listed in the remainderof this section shall be providd as described.

(-,culation No.: OSC-9295 Revision No.: U Applicable Units: Oconee Unit 1. 2, & 3 Page A4 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary 3.3.31 Fire Prevention for OperationalActivities Comply Fire prevention program, The fire prevention program activities shall consist of the necessary activities for control of elements to addressthe control of ignition sources and the use of . ignition sources and transientcombustible materials during all aspects of plant operations. i transient combustibles The fire preventionprogramshall focus on the human and include training, inspections programmaticelements necessary to prevent fires from startingor, and administrative controls. should a fire start, to keep the fire as small as possible. - 3.3.1. 1 GeneralFire PreventionActivities Comply The prevention of fires and The fire prevention activities shall include but not be limited to the fire spread are managed following program elements: through training of (1) Trainingon fire safety informationfor all employees and personnel, documented contractors including, as a minimum, familiarization with plant plant inspections, and fire prevention procedures,fire reporting, andplant emergency - administrative controls. alarms. (2) Documented plant inspections includingprovisions for corrective actions for conditions where unanalyzed fire hazards are identified. (3) Administrative controls addressingthe review of plant modifications and maintenance to ensure that both fire hazards and the impact on plant fire protectionsystems and features are minimized. 3.3.1.2 Control of Combustible Materials Comply ~3.3.1.2(6) Sections 3.3.1.2(2)

                                                                                                                         - Specific through Proceduresfor the control of general housekeeping practicesand the                                3     .2(6)      diSectifi control of transientcombustibles shall be developed and implemented.                              a have been developed for These procedures shall include but not be limited to the following                                control of combustible program elements:                                                                I                materials.

(1) Wood used within the power block shall be listed

Caciulation No.: OSC-9295 Revision No.; 0-Applicable Units: Oconee Unit 1, 2, & 3 Page A5 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary pressure-impregnatedorcoated with a listed fire-retardant Submit for NRC Approval NFPA 805 Section application. ,3.3.1.2(1); NSD-313 permits Exception: Cribbing timbers 6 in. by 6 in. (15.2 cm by 15.2 cm) I non treated wood for orlargershall not be requiredto be fire-retardanttreated. concrete forming and where (2) Plasticsheeting materials used in the power block shall be specified in design fire-retardanttypes that have passedNFPA 701, Standard i drawings. Methods of Fire Tests for Flame Propagationof Textiles and Films, large-scale tests, or equivalent. Area for I Improvement (3) Waste, debris, scrap,packing materials,or other 3.r .2(2licnee will combustibles shall be removed from an area immediately 3.3.1.2(2) Oconee will i enhance current. following the completion of work or at the end of the shift, whichever comes first. documentation, prior to implementation 6f the NFPA (4) Combustible storage or staging areasshall be designated, 85prgmnto sfically and limits shall be establishedon the typesmatsterihetin and quantities of address address plastic sheeting stored materials. imaterial conformance to (5) Controls on use andstorage of flammable and NFPA 701 requirements or combustible liquids shall be in accordance with NFPA 30, equivalent. Flammableand Combustible Liquids Code, or otherapplicable NFPA standards. (6) Controls on use and storage of flammable gases shall be in accordance with applicable NFPA standards, 3.3.1.3 Control of Ignition Sources 3.3.1.3.1 Comply i Hot workadministrative through is controlled A hot work safety procedure shall be developed, implemented, and throughvadminiscranie periodicallyupdatedas necessary in accordancewith NFPA 51B, directives in accordance Standardfor Fire Prevention DuringWelding, Cutting, and Other Hot with N FPA 51 B. Note Work, and NFPA 241, Standardfor Safeguarding Construction, NFPA 241 references Alteration, and Demolition Operations. NFPA 51 B with regards to the requirements for the

C-culation No.: - OSC-9295 Revision No.: O-Applicable Units: Oconee Unit 1, 2, & 3 Page A6 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary administration of hot work Area for lrnprovement Evaluate NSD-314 to determine if NFPA 241 should be included. 3.3.1.3.2 Comply i. Smoking is restricted to Smoking and other possible sources of ignition shall be restricted to approved locations and properlydesignatedand supervised safe areasof the plant. other sources of ignition are controlled. 3.3.1.3.3 Further Adtion Required Open flame or combustion-Open flames or combustion-generatedsmoke shall not be permittedfor generated smoke is leak or air flow testing. prohibited for use in leak and air flow testing. Oconee will enhance current documentation, prior to implementation of the NFPA 805 program, to revise procedures to preclude the use of open

                                                             -                           I.              flame or combustion generated smoke for leak or air flow testing.

3.3.1.3.4 Submit fofi NRC Approval The use of portable heaters Plantadministrativeprocedure shall control the use of portable is controlled by

Carculation No.: OSC-9295 Revision No.: Applicable Units: Oconee Unit 1.2, & 3 Page A7 of A37 NFPA 805 Chapter 3 Section Complian'ce Statement Compliance Summary electrical heaters in the plant. Portablefuel-fired heaters shall not be I administrative directives. permittedin plant areascontaining equipment importantto nuclear Gas and oil-fired heaters safety or where there is a potential for radiologicalreleases resulting are permitted per station from a fire. procedures. 3.3.2 Structural Comply Powerproduction buildings Walls, floors, and.components required to maintain structuralintegrity are constructed of non-shall be of noncombustible construction, as defined in NFPA 220, combustible matenals. Standardon Types of Building Construction. 3.3.3 Interior Finishes Further Action Required Interior finishes are non-Interiorwall or ceiling finish classificationshall be in accordancewith combustible. NFPA 1010, Life Safety CodeQ, requirementsfor Class A materials. Interiorfloor finishes shall be in accordancewith NFPA 101 requirements for Class I interiorfloor finishes. Oconee will enhance current documentation, prior to implementation of the

                                                                                              -*NFPA               805 program, to include the specifications for Class A walls/ceilings and Class I floor finishes.

3.3.4 Insulation Materials Comply Thermal insulation materials I are non-combustible or Thermal insulation materials,radiationshieldingmaterials, ventilation a duct materials,and soundproofingmaterials shall be noncombustible or limited combustible. limited combustible.

Caiculation No.: OSC-9295 Revision No.: ( Applicable Units; Oconiee Unit 1. 2.& 3 Page A8 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary 3.3.5 Electrical 3.3.5.1 Further Ac*tion Required Combustibles in concealed Wiring above suspended ceiling shall be kept to a minimum. Where spaces are minimized. installed, electricalwiring shall be listed for plenum use, routed in armoredcable, routed in metallic conduit, or routedin cable trays with solid metal top and bottom covers. Oconee will enhance current documentation, prior to implementation of the NFPA 805 program, to include clear guidance that electrical wiring (including data/phone/video cabling) if installed above suspended ceilings will comply with the requirements of this section. 3.3.5.2 Further A~tion Required Cable trays are constructed Only metal tray and metal conduits shall be used for electrical of m non-combustible raceways. Thin wall metallic tubing shall not be used for power, materials. instrumentation,or control cables. Flexible metallic conduits shall only be used in short lengths to connect components.  ! Oconee will enhance i current documentation, prior to implementation of the NFPA 805 program, to include clear guidance that conduits used for electrical raceways are metal and thin walled metallic tubing is not used in accordance with the requirements of this section.

Ciaculation No.: OSC-9295 Revision No.: b Applicable Units: Oconee Unit 1, 2, & 3 Page A9 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary 3.3.5.3 Complies by I Previous The installed wiring has Electric cable construction shall comply with a flame propagationtest NRC Approval been found acceptable. as acceptable to the AHJ. I Further Altion Required Oconee will enhance current documentation, prior to implementation of the NFPA 805 program, to document that non-rated cables (including data/phone/video) shall not be routed in cable trays with nuclear safety related cables. 3.3.6 Roofs Comply Roofs comply with Class A Metal roof deck construction shall be designed and installedso the requirements. A roof roofing system will not sustaina self-propagatingfire on the underside management program has of the deck when the deck is heated by a fire inside the building. Roof been implemented requiring coverings shall be Class A as determinedby tests describedin NFPA i Class A equivalent roof 256, StandardMethods of Fire Tests of Roof Coverings. ] installations. 3.3.7 Bulk Flammable Gas Storage Comply Bulk gas is not stored in Bulk compressed or cryogenic flammable gas storage shall not be I areas with equipment permitted inside structureshousing systems, equipment, or important to nuclear safety. components important to nuclearsafety. Storage of flammable gases are controlled by plant directives.

(,.ýculation No.: OSC-9295 Revision No.: _ Applicable Units: Oconee Unit 1. 2. & 3 Page A10 of A37 NFPA 805 Chapter 3 Section ComplIanlce Statement Compliance Summary 3.3.7.1 Comply Bulk gas is not stored in Storage of flammable gas shall be locatedoutdoors, or in separate I areas important to nuclear detached buildings, so that a fire or explosion will not adversely impact I safety. systems, equipment, or components importantto nuclear safety. NFPA 50A, Standardfor Gaseous Hydrogen Systems at Consumer Sites, Further Action Required shall be followed for hydrogen storage. Oconee will enhance current documentation, prior to implementation of the NFPA 805 program, to perform a NFPA 50A a code compliance review for the outdoor hydrogen storage. 3.3.7.2 Comply I Hydrogen gas tanks are Outdoor high-pressure flammable gas storage containersshall be orientated with the long axis located so that the long axis is not pointed at buildings. parallel to plant buildings. Resolve orientation of Further Action Required propane tank. The tank is not anchored per the SER recommendation. Evaluate if the pervious approval by the NRC is sufficient with the modification. Alternatively, determine if an evaluation is required or modify the tank position.

Cwuculation No.: OSC-9295 Revision No.: (- Applicable Units: Oconee Unit 1. 2. & 3 Page All of A37 NFPA 805 Chapter 3 Section Complianlce Statement Compliance Summary 3.3.7.3 Comply Gas cylinders are isolated Flammablegas storagecylinders not required for normal operation when not in use and shall be isolated from the system. !controlled l bdirectives. by plant 3.3.8 Bulk Storage of Flammable and Combustible Liquids Further Adtion Required The storage of combustible Bulk storage of flammable and combustible liquids shall not be and flammable materials is permitted inside structures containing systems, equipment, or controlled by plant components important to nuclearsafety. As a minimum, storage and directives. use shall comply with NFPA 30, Flammable and Combustible Liquids i Code. Oconee will enhance current documentation, prior to implementation of the NFPA 805 program, to perform a NFPA 30 code compliance review for the Turbine Building lube oil reservoirs, Turbine Building lube oil storage room, and the Keowee lube oil storage room. 3.3.9 Transformers Further Action Required Oconee will enhance Where provided, transformeroil collection basins and drainpaths shall current documentation, prior be periodicallyinspected to ensure that they are free of debris and to implementation of the capable of performing their design function. NFPA 805 program, to include drainage inspections as part of the annual flow tests.

Cuciulation No.: OSC-9295 Revision No.: _ _ _. Applicable Units: Oconee Unit 1, 2, & 3 Page A12 of A37 NFPA 805 Chapter 3 Section Complianice Statement Compliance Summary 3.3.10 Hot Pipes and Surfaces Comply Administrative directives Combustible liquids, including high flashpoint lubricatingoils, shall be ensure the prompt kept from coming in contact with hot pipes and surfaces, including identification and correction insulated pipes and surfaces. Administrative controls shall require the of any oil leakage. prompt cleanup of oil on insulation. Area for Im'provement Oconee will enhance current documentation, prior to implementation of the NFPA 805 program, to clearly indicate it is a NRC requirement to promptly remove oil from insulation. 3.3.11 ElectricalEquipment Comply Administrative directives Adequate clearance,free of combustible material, shall be maintained control combustible material around energized electrical equipment. near electrical equipment. Further Action Required

                                                                                                 ~Oconee             will enhance current documentation, prior to implementation of the NFPA 805 program, to specify the combustible free distance consistent with the PRA Zone of Influence for transients and change evaluation results.

Caitulation No.: OSC-9295 Revision No.: 6 Applicable Units: Oconee Unit 1, 2, & 3 Page A13 of A37 NFPA 805 Chapter 3 Section Compllan'ce Statement Compliance Summary 3.3.12 Reactor CoolantPumps Comply The RCP oil collection For facilities with non-inertedcontainments,reactorcoolant pumps with system meets the five an external lubricationsystem shall be provided with an oil collection criteria presented in this system. The oil collection system shallbe designed and installedsuch section. that leakage from the oil system is safely containedfor off normal conditions such as accident conditions or earthquakes.All of the following shall apply. (1) The oil collection system for each reactorcoolant pump shall be capable of collecting lubricatingoil from all potential pressurizedand nonpressurizedleakage sites in each reactor coolantpump oil system. (2)Leakage shall be collected and drained to a vented closed containerthat can hold the inventory of the reactorcoolant pump lubricatingoil system. (3) A flame arrestoris required in the vent if the flash point characteristicsof the oil present the hazardof a fire flashback. (4) Leakage points on a reactorcoolantpump motor to be protectedshall include but not be limited to the lift pump and piping, overflow lines, oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and the oil reservoirs, where such features exist on the reactorcoolant pumps. (5) The collection basin drain line to the collection tank shall be large enough to accommodate the largestpotential oil leak such that oil leakage does not overflow the basin. Section 3.4 Industrial Fire Brigade 3.4.1 On-Site Fire-FightingCapability The onsite Fire Brigade is All of the following requirements shallapply. appropriately staffed, trained and equipped. (a) A fully staffed, trained,and equipped fire-fighting force shall be

Lciculation No.: OSC-9295 Revision No.: Applicable Units: Oconee Unit 1, 2, & 3 Page A14 of A37 NFPA 805 Chapter 3 Section Complianrce Statement Compliance Summary available at all times to controland extinguish all fires on site. This force shall have a minimum complement of five persons on duty and shall conform with the following NFPA standardsas applicable: Area for Inprovement Ensure NFPA 600 code iFire review documented Brigade in the Functional (1) NFPA 600, Standardon IndustrialFire Brigades (interior iFreBigd Funtinal structuralfire fighting) Area Management (FAM) (2) NFPA 1500, Standardon Fire DepartmentOccupational manual. Safety and Health Program F (3) NFPA 1582, Standardon Medical Requirements for Fire Fightersand Information for Fire Department Physicians (b) Industrialfire brigade members shall have no other assigned normal plant duties that would prevent immediate response to a fire or other emergency as required. (c) During every shift, the brigade leaderand at least two brigade members shall have sufficient trainingand knowledge of nuclear safety I systems to understandthe effects of fire and fire suppressantson nuclearsafety performance Exception: Sufficient training and knowledge shall be permitted to be provided by an operationsadvisordedicated to industrialfire brigade support criteria. (d) The industrialfire brigade shallbe notified immediately upon verification of a fire. (e) Each industrialfire brigade member shallpass an annual physical examination to determine that he or she can perform the strenuous activity requiredduring manual fire-fighting operations. The physical examinationshall determinethe ability of each member to use respiratoryprotection equipment.

Laiculation No.: OSC-9295 Revision No.: 0' Applicable Units: Oconee Unit 1. 2, & 3 Page A15 of A37 NFPA 805 Chapter 3 Section Complianlce Statement Compliance Summary 3.4.2 Pre-FirePlans Comply Current and detailed pre-fire Currentand detailedpre-fire plans shall be availableto the industrial Ocplans are available in the fire brigadefor all areas in which a fire couldjeopardize the ability to Oconee Plant Fire Plan. meet the performance criteria describedin Section 1.5. 3.4.2.1 Comply Detailed pre-fire plans are i available in the Oconee The plans shall detail the fire area configurationand fire hazards to be avalale itheOcone encounteredin the fire area, along with any nuclearsafety components Nuclear Site Fire Plan. and fire protection systems~and features thatare present. Review the Fire Plan and Area for Improvement associated documentation for compliance with FAQ 06-- 0025. 3.4.2.2 Comply The Fire Plan is maintained I current. Plant directives Pre-fireplans shall be reviewed and updated as necessary. require review of the Fire Plan. 3.4.2.3 Comply The Fire Plan is available in

                                                                                                ~the           Control Room and to Pre-fireplans shall be availablein the controlroom and made available                           the Cnro room an to to the plant industrialfire brigade,                                                            the Fire Brigade at multiple locations.

3.4.2.4 Comply Plant directives and fire Pre-fireplans shall address coordinationwith otherplant groups during cobrigade procedures address fire emergencies. coordination with other plant

CGwculation No.: OSC-9295 Revision No.: '- Applicable Units: Oconee Unit 1, 2, & 3 Page A16 of A37 NFPA 805 Chapter 3 Section Complianpe Statement Compliance Summary groups. 3.4.3 Training and Drills Comply I The Fire Brigade personnel t receive appropriate training Industrialfire brigade members and other plantpersonnelwho would r respond to a fire in conjunction with the brigade shall be provided with and the training records are trainingcommensurate with their emergency responsibilities. Imaintained. (a) Plant IndustrialFire Brigade Training.All of the following requirements shall apply. ~All A plant personnel are (1) Plant industrialfire brigademembers shall receive training trained on reporting fires consistent with the requirements containedin NFPA 600, and interfacing with the Fire Standardon IndustrialFire Brigades, or NFPA 1500, Standard Brigade. on Fire DepartmentOccupationalSafety and Health Program, as appropriate. (2) Industrial fire brigade members shall be given quarterly Drills are conducted on a trainingand practicein fire fighting, including radioactivityand regular basis and involve health physics considerations,to ensure that each member is various plant areas. The thoroughly familiar with the steps to be taken in the event of a drills are critiqued and fire. records are maintained. (3) A written program shall detail the industrialfire brigade trainingprogram. (4) Written records that include but are not limited to initial industrialfire brigade classroom andhands-on training, refreshertraining,special trainingschools attended, drill attendancerecords,and leadership trainingfor industrialfire brigades shall be maintainedfor each industrialfire brigade member. (b) Training for Non-Industrial Fire Brigade Personnel.Plant personnel who respond with the industrialfire brigadeshall be trainedas to their responsibilities,potentialhazards to be encountered, and interfacing with the industrialfire brigade. _

,c;ulationNo.:                OSC-9295                                                                                   Revision No.:          b Applicable Units:         Oconee Unit 1, 2. & 3                                                                           Page        A17    of    A37 NFPA 805 Chapter 3 Section                                                               Complian!ce Statement            Compliance Summary (c) Drills. All of the following requirements shall apply.

(1) Drillsshall be conducted quarterly for each shift to test the response capability of the industrialfire brigade. (2) Industrialfire brigade drills shall be developed to test and challenge industrialfire brigade response, including brigade performance as a team, proper use of equipment, effective use of pre-fire plans, and coordinationwith other groups. These drills shall evaluate the industrialfire brigade'sabilities to react,. respond, and demonstrateproper fire-fighting techniques to control and extinguish the fire and smoke conditionsbeing simulated by the drill scenario. (3) Industrialfire brigadedrills shall be conductedin various plant areas,especially in those areas identifiedto be essential to plant operationand to contain significant fire hazards. (4) Drillrecords shall be maintaineddetailing the drill scenario, industrialfire brigade member response, and ability of the industrialfire brigade to perform as a team. (5) A critiqueshall be held and documented after each drill. 3.4.4 Fire-FightingEquipment Comply T Fire brigade personnel are

                                                                                                        ,                 provided with the necessary Protective clothing, respiratoryprotective equipment, radiation                                                   epr edth monitoringequipment, personaldosimeters, and fire suppression                                                    equipment.

equipment such as hoses, nozzles, fire extinguishers, and other needed equipment shall be provided for the industrialfire brigade. This equipment shall conform with the applicableNFPA standards. 3.4.5 Off-Site Fire Department Interface 3.4.5.1 Mutual Aid Agreement Comply Letters of Agreement are in maintained with local off-Off-site fire authorities shall be offered a plan for their interface during _____ ____________________

CaIlulation No.: OSC-9295 Revision No.: 6 Applicable Units: Oconee Unit 1. 2, & 3 Page A18 of A37 NFPA 805 Chapter 3 Section Complianice Statement Compliance Summary fires and relatedemergencies on site. site fire fighting organizations. 3.4.5.2 Site-Specific Training Comply Annual training is specified Fire fighters from the off-site fire authorities who are expected to in the Letters of Agreement. respond to a fire at the plant shall be offered site-specific trainingand shall be invited to participatein a drill at least annually. 3.4.5.3 Security and RadiationProtection. Comply Site directives include Plantsecurity and radiationprotection plans shall address off-site fire Security and Radiation authority response. Protection provisions for assistance to off-site fire authorities. 3.4.6 Communications Comply Emergency communication An effective emergency communications capabilityshall be providedfor Icapabilities are provided. the industrialfire brigade. _ Section 3.5 Water Supply 3.5.1 Complies by Previous The fire protection water A fire protection water supply of adequatereliability,quantity, and NRC Approval supply is adequate and duration shall be provided by one of the two following methods. reliable. (a) Provide a fire protection watersupply of not less than two separate 300,000-gal (1, 135,500-L) supplies. Further Prior to implementation of FrhrAction Required thNFA85porm (b) Calculate the fire flow rate for2 hours. This fire flow rate shall be the NFPA 805 program, based on 500 gpm (1892.5 L/min) for manual hose streamsplus the I Oconee will ensurethat any largestdesign demand of any sprinkler or fixed waterspray system(s) _ required suppression

C-.,.,ulation No.: OSC-9295 Revision No.: 0 - - Applicable Units: Oconee Unit 1, 2. & 3 Page A19 of A37 NFPA 805 Chapter 3 Section Complian!ce Statement Compliance Summary I in the power block as determinedin accordancewith NFPA 13, systems for the Nuclear Standardfor the Installationof SprinklerSystems, or NFPA 15, Safety Capability Transition Standardfor Water Spray Fixed Systems for Fire Protection. The fire are within the design flow water supply shall be capable of delivering this design demand with the capabilities of the fire pump hydraulicallyleast demanding portion of fire main loop out of service, per NFPA 20. 3.5.2 Comply Oconee utilizes Lake The tanks shall be interconnectedsuch that fire pumps can take Keowee as the primary fire suction from either or both. A failure in one tank or its piping shall not water source. allow both tanks to drain. The tanks shall be designed in accordance with NFPA 22, Standardfor Water Tanks for Private FireProtection. Exception No. 1: Water storage tanks shallnot be requiredwhen fire pumps are able to take suction from a large body of water (such as a lake), provided each fire pump has its own suction and both suctions and pumps are adequately separated, Exception No. 2: Cooling tower basins shall be an acceptable water source for fire pumps when the volume is sufficient for both purposes and water quality is consistent with the demands of the fire service. 3.5.3 Complies by Previous The use of the High Firepumps, designed and installedin accordancewith NFPA 20, NRC Apprloval Pressure Service Water Standardfor the Installation of Stationary Pumps for FireProtection, i (HPSW) pumps to supply shall be provided to ensure that 100 percent of the requiredflow rate fire water is acceptable. and pressure are availableassuming failure of the largestpump or pump power source. Further Ad*tion Required Upon replacement of the Keowee fire pump (PIP 2001-3492) ensure the installation meets the requirements of this section.

C iculation No.: OSC-9295 Revision No.: _ 6 Applicable Units: Oconee Unit 1. 2. & 3 Page A20 of A37 NFPA 805 Chapter 3 Section Compllanýe Statement Compliance Summary 3.5.4 Complies by Previous Diesel-engine driven fire At least one diesel engine-driven fire pump or two more seismic NRC Approval water pumps are not At lastone fre umputilized. iesl eginedrien Keowee uses an Category I Class IE electric motor-driven fire pumps connected to u redundant Class IE emergency power buses capable of providing 100 1 electric fire pump. The percent of the requiredflow rate andpressureshall be provided. i NRC has accepted the use of the HPSW pumps as Oconee fire pumps. 3.5.5 Complies by Previous The HPSW pumps are NRC Appr~oval separated from the rest of Each pump and its driverand controls shall be separatedfrom the remaining fire pumps and from the rest of the plant by rated fire i the plant and the NRC has barriers, approved the use and installation of the HPSW pumps for fire protection use. 3.5.6 Complies by Previous Fire pumps (HPSW and Firepump Approvalauto Firepumps shall be provided with automaticstart and manualstop NRC Keowee) auto-start. only. Area for IpImprovement Document that PIP 2002-3870 has resolved HPSW manual stop. 3.5.7 Comply There are separate Individual fire pump connections to the yard fire main loop shall be connections from pumps to provided and separatedwith sectionalizingvalves between the fire loops for ONS. connections. _ _Keowee does not have a

C'-meulation No.: OSC-9295 Revision No.: LY Applicable Units: Oconee Unit 1, 2, & 3 Page A21 of A37 NFPA 805 Chapter 3 Section Complian' e Statement Compliance Summary yard main loop only underground piping. 3.5.8 Comply The pressure in the HPSW A method of automaticpressuremaintenance of the fire protection system is maintained by the water system shall be provided independentof the fire pumps. jockey pump. Keowee uses lake head to maintain system pressure. 3.5.9 Comply The Control Room(s) are Means shall be provided to immediately notify the control room, or automatically notified of other suitable constantly attended location, of operationof fire pumps. operation of the pumps used for fire protection. 3.5.10 Complies by Previous The fire water piping system An undergroundyard fire main loop, designed and installed in NRC Appioval was found acceptable by accordancewith NFPA 24, Standardfor the Installationof PrivateFire the NRC. Service Mains and Their Appurtenances, shall be installedto furnish anticipatedwater requirements. _ 3.5.11 Comply Sectionalizing valves are

                                                                                                          'provided to allow isolation Means shall be provided to isolate portionsof the yard fire main loop for                         p maintenance or repairwithout simultaneously shutting off the supply to                           of various sections of the both fixed fire suppressionsystems and fire hose stations provided for                           fire water system for manual backup. Sprinklersystems and manual hose station standpipes                                maintenance or repair.

shall be connected to the plant fire protection water main so that a single active failure or a crack to the watersupply piping to these systems can be isolated so as not to impairboth the primary and backup.fire suppression systems. __ 3.5.12 Comply __ Compatible threads are

Catculation No.: OSC-9295 Revision No.: 0: " Applicable Units: Oconee Unit 1, 2. & 3 Page A22 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary Threads compatible with those used by local fire departments shall be provided. provided on all hydrants, hose couplings, and standpiperisers. Exception: Fire departmentsshall be permitted to be provided with adaptersthat allow interconnectionbetween plant equipment and the fire department equipment if adequatetrainingand procedures are provided. 3.5.13 Complies by Previous The fire water supply Headers fed from each end shall be permitted inside buildings to supply NRC Approval system has been approved both sprinkler and standpipe systems, providedsteel piping and fittings by the NRC. Each header meeting the requirements of ANSI B3 1.1, Code for Power Piping,are has a separate connection used for the headers (up to and including the first valve) supplying the with shutoff valve to the fire sprinklersystems where such headersare part of the seismically' water system. analyzed hose standpipe system. Where provided,such headers shall be consideredan extension of the yard main system. Each sprinkler and standpipe system shall be equipped with an outside screw and yoke (OS&Y) gate valve or other approvedshutoff valve. 3.5.14 Comply Fire protection valves are

                                                                                                   +       locked or sealed.

All fire protection watersupply and fire suppressionsystem control l valves shall be under a periodicinspection program and shall be supervisedby one of the following methods. (a) Electricalsupervision with audible and visual signalsin the main controlroom or other suitable constantlyattended location. (b) Locking valves in their normal position. Keys shall be made available only to authorizedpersonnel. (c) Sealing valves in their normalpositions. This option shall be utilized only where valves are located within fenced areas or under the direct control of the ownerloperator. _"_ 3.5.15 Complies by Previous The NRC determined that

Caiculation No.: OSC-9295 Revision No.: _ Applicable Units: Oconee Unit 1, 2, & 3 Page A23 of A37 NFPA 805 Chapter 3 Section Complianbe Statement Compliance Summary Hydrants shall be installed approximately every 250 ft (76 m) aparton NRC Approval the hydrants installed at the yard main system. A hose house equipped with hose and approximately 300 feet combination nozzle and other auxiliaryequipment specified in NFPA intervals are acceptable. 24, Standardfor the Installationof PrivateFire Service Mains and Their Appurtenances, shall be provided at intervals of not more than 1000 ft (305 m) along the yard main system. Exception: Mobile means of providing hose and associatedequipment, such as hose carts or trucks, shall be permitted in lieu of hose houses. Where provided, such mobile equipment shall be equivalent to the equipment supplied by three hose houses. 3.5.16 Complies by Previous The use of the HPSW The fire protection water supply system shall be dedicated for fire NRC Approval system and LPSW system protection use only. for fire protection was found p i oacceptable by the NRC. Exception No. 1: Fireprotection watersupply systems shall be permitted to be used to provide backup to nuclearsafety systems, provided the fire protection water supply systems are designedand maintainedto deliver the combined fire and nuclearsafety flow demands for the duration specified by the applicable analysis. Exception No. 2: Fire protection water storage can be provided by plant systems serving other functions, provided the storage has a dedicatedcapacity capable of providing the maximum fire protection demand for the specified duration as determinedin this section. Section 3.6 Standpipe and Hose Stations _ 3.6.1 Complies Py Previous The standpipe and fire hose For all power block buildings, Class Ill standpipe and hose systems NRC AppIoval systems were found shall be installed in accordancewith NFPA 14, Standardfor the Iacceptable. Installationof Standpipe, Private Hydrant, and Hose Systems.

Caiculation No.: OSC-9295 Revision No.: 0 Applicable Units: Oconee Unit I, 2. & 3 Page A26 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary

                                                                                           +

3.8 Fire Alarm and Detection Systems 3.8.1 FireAlarm Complies by Previous Fire related signals are NRC ApprI val transmitted to the control Alarm initiatingdevices shall be installedin accordancewith NFPA 72, N rooms. The fire detection National FireAlarm CodeO. Alarm annunciationshall allow the r proprietaryalarm system to transmitfire-relatedalarms,supervisory and signaling system was signals, and trouble signals to the control room or otherconstantly found acceptable by the attended location from which requirednotificationsand response can NRC. be initiated.Personnelassignedto the proprietaryalarm stationshall be permitted to have other duties. The following fire-relatedsignals shall be transmitted:. Further Adtion Required Perform a NFPA 72 code (1) Actuation of any fire detection device compliance review for fire alarm and detection (2) Actuation of any fixed fire suppression system sc systems (Sections 3.8.1 (3) Actuation of any manual fire alarm station and 3.8.2). (4) Starting of any fire pump (5) Actuation of any fire protection supervisorydevice (6) Indication of alarm system trouble condition 3.8.1.1 Comply i Means to report a fire are Means shall be provided to allow a person observing a fire at any provided. location in the plant to quickly and reliablycommunicate to the control room or other suitable constantly attended location. 3.8.1.2 Comply The Control Room notifies Means shall be provided to promptly notify the following of any fire station personnel of a fire emergency in such a way as to allow them to determine an appropriate event over the Plant PA course of action: System and can communicate with Brigade (1) Generalsite population in all occupied areas. _ _ personnel and Off-Site

(-,,culation No.: OSC-9295 Revision No.: U, Applicable Units: Oconee Unit 1, 2, & 3 Page A24 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary Further Action Required Oconee will enhance current documentation, prior to implementation of the NFPA 805 program, to perform a NFPA 14 code compliance review for standpipe systems not addressed by the previous SER approval but included in the new power block definition. 3.6.2 Comply The fire water supply A capabilityshall be provided to ensure an adequate water flow rate system can provide and nozzle pressure for all hose stations. This capabilityincludes the adequate water flow and provision of hose station pressure reducers where necessary for the pressure at all hose safety of plant industrialfire brigade members and off-site fire stations. department personnel. 3.6.3 Comply The appropriate hose The proper type of hose nozzle to be supplied to each power block I nozzles have been area shall be based on the area fire hazards. The usual combination provided. spray/straightstream nozzle shall not be used in areas where the I straight stream can cause unacceptable damage or present an electricalhazardto fire-fightingpersonnel. Listed electricallysafe fixed fog nozzles shall be provided at locations where high-voltage shock. hazards exist. All hose nozzles shall have shutoff capabilityand be able to control water flow from full open to full closed. 3.6.4 Complies 'by Previous The interior hose stations

Caiulation No.: OSC-9295 Revision No.: U Applicable Units: Oconee Unit 1, 2, & 3 Page A25 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary Provisions shall be made to supply waterat least to standpipes and NRC Approval were found acceptable by hose stations for manual fire suppression in all areascontaining the NRC. Seismically systems and components needed to perform the nuclearsafety designed hose stations are functions in the event of a safe shutdown earthquake(SSE). provided in the Reactor Exception: For existing plants that are not capable of meeting this Building and the Cable requirement,provisionsto restore a watersupply and distributionsystem for manual fire-fighting purposes shall be made. The provisionalmanual bRoom to Control Room fire-fighting standpipe/hose station system shall be capable of providing I system is not seismically manual fire-fightingprotection to the various plant locations important to Idssisnoe supportingand maintainingthe nuclearsafetyfunction. The provisionsfor d establishing thisprovisionalsystem shall be preplannedand be capableof being implemented in a timely manner following an SSE. 3.6.5 Comply Fire flow will not affect the Where the seismic requiredhose stations are cross.connectedto essential water system. essentialseismic non-fire protection water supply systems, the fire flow shall not degrade the essential water system requirement. Section 3.7 Fire Extinguishers Complies by Previous The portable fire Where provided, fire extinguishersof the appropriatenumber, size, and NRC extinguishers meet the type shall be providedin accordancewith NFPA 10, Standardfor A requirements of NFPA 10. PortableFire Extinguishers. Extinguishersshall be permittedto be positionedoutside of fire areas due to radiologicalconditions. F rAction Required Oconee will enhance current documentation, prior to implementation of the NFPA 805 program, to perform a NFPA 10 code compliance review.

CQcuIation No.: OSC-9295 Revision No.: U Applicable Units: Oconee Unit 1, 2, & 3 Page A27 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary (2) Members of the industrialfire brigadeand othergroups agencies by various means. supportingfire emergency response (3) Off-site fire emergency response agencies. Two independentmeans shall be available(e.g., telephone and radio) for notification of off-site emergency services 3.8.2 Detection Complies by Previous The fire detection and If automatic fire detection is requiredto meet the performanceor NRC Appipval signaling system was found deterministic requirements of Chapter4, then these devices shall be a installed in accordancewith NFPA 72, NationalFire Alarm Code, and The system was installed in its applicableappendixes. accordance with applicable codes of record with documented deviations. Upon completion of the Further Action Required Nuclear Safety Capability Transition, Oconee will perform a NFPA 72 code compliance review of the fire alarm and detection systems required to meet the nuclear safety performance criteria (compliance with deterministic criteria, or as a defense-in-depth feature for a change evaluation or transitioning licensing i action).

C6ardulation No.: OSC-9295 Revision No.: _ Applicable Units: Oconee Unit 1, 2, & 3 Page A28 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary Section 3.9 Automatic and Manual Water-Based Fire Suppression Systems _ i 3.9.1 Complies by Previous NFPA code compliance Licensee Evaluation calculations have been If an automatic ormanual water-basedfire suppressionsystem is performed for automatic required to meet the performance or deterministicrequirements of Chapter4, then the system shallbe installedin accordancewith the and manual water-based appropriateNFPA standardsincluding the following: fire suppression systems. (1) NFPA 13, Standardfor the Installationof Sprinkler Systems Complies Iýy Previous The installed sprinkler (2) NFPA 15, Standardfor Water Spray Fixed Systems for NRC Approval systems were found Fire Protection acceptable by the NRC. (3) NFPA 750, Standardon Water Mist Fire Protection Systems Upon completion of the (4) NFPA 16, Standardfor the Installationof Foam-Water Further Action Required Nuclear Safety Capability Sprinklerand Foam-Water Spray Systems Transition, Oconee will perform code compliance

                                                                                                   .review and/or review the applicable Fire Suppression NFPA Code Review calculations of the water based fire suppression systems required to meet the nuclear safety performance criteria (compliance with deterministic criteria, or as a defense-in-depth feature for a change evaluation or transitioning licensing action).

tŽ-iculation No.; OSC-9295 Revision No.: 0: Applicable Units: Oconee Unit 1, 2, & 3 Page A29 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary 3.9.2 Comply Each fixed extinguishing Each system shall be equippedwith a water flow alarm. system is provided with an alarm. 3.9.3 Comply Alarms are annunciated the Control in Rooms or other All alarms from fire suppressionsystems shall annunciatein the control te contlR other room or othersuitable constantly attended location, remote constantly attended area. 3.9.4 N/A There are no diesel-driven fire water pumps utilized at Diesel-driven fire pumps shall be protected by automatic sprinklers, fire water ulizd the Oconee Plant. 3.9.5 Complies" y Previous Each suppression system is Each system shall be equippedwith an OS&Y gate valve or other NRC Approval connected to the header approvedshutoff valve. with an approved control valve. 3.9.6 Complies ,by Previous The valves are not All valves controlling water-basedfire suppression systems requiredto NRC Approval electrically supervised but meet the performance or deterministicrequirements of Chapter4 shall are locked or sealed in be supervisedas describedin 3.5.14. accordance with Section 3.5.14. Section 3.10 Gaseous Fire Suppression Systems _

Caiculation No.: OSC-9295 Revision No.: 0 ; Applicable Units: Oconee Unit 1, 2, & 3 Page A30 of A37 NFPA 805 Chapter 3 Section Complian e Statement Compliance Summary 3.10.1 Further Action Required Gaseous fire suppression is If an automatictotal flooding and local applicationgaseous fire only utilized for specific suppressionsystem is required to meet the performance or components - the Keowee deterministicrequirements of Chapter4, then the system shall be Hydro Station's Generators designed and installed in accordancewith the following applicable and the SSF Diesel NFPA codes: Generator are provided with (1) NFPA 12, Standardon Carbon Dioxide Extinguishing 002 extinguishing systems. Systems (2) NFPA 12A, Standardon Halon 1301 Fire Extinguishing Upon completion of the Systems Nuclear Safety Capability Transition, Oconee will (3) NFPA 2001, Standardon Clean Agent Fire Extinguishing perform a code compliance Systems review of gaseous fire suppression systems required to meet the nuclear safety performance criteria (compliance with deterministic criteria, or as a defense-in-depth feature for a change evaluation or transitioning licensing action). 3.10.2 Comply Operation of a Keowee t+ gaseous suppression Operationof gaseous fire suppression systems shall annunciate and g alarm in the control room or other constantly attendedlocation system is annunciated in identified. the Unit 2 Control Room and Keowee; operation of the SSF gaseous suppression system is annunciated in the Unit 2

Cw6ulation No.: OSC-9295 Revision No.: 0 ... Applicable Units; Oconee Unit 1. 2. & 3 Page A31 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary Control Room and Security. 3.10.3 Comply The Keowee Hydro Station Ventilation system design shall take into account prevention from over- system injects into the pressurizationduring agent injection, adequate sealing to prevent loss respective hydroelectric of agent, and confinement of radioactive contaminants, generator's housing and not into a ventilation system. The leak tightness of the housings is included in the system testing procedure to ensure substantial concentration. The SSF 0C2 System injects only into the Diesel Generator Room. The ventilation system to the room is isolated during system actuation to ensure concentration for at least 30 minutes. There are no radioactive contaminants involved at either location protected by the gaseous fire suppression systems. Evaluate and document the Further Action Required potential effects of over-pressurization in the areas of C02 system discharge

Uaiculation No.: OSC-9295 Revision No.: 0.. Applicable Units: Oconee Unit 1, 2, & 3 Page A32 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary 3.10.4 Comply There are no installed In any area requiredto be protectedby both primaryand backup backup gaseous fire gaseous fire suppression systems, a single active failure or a crack in suppression systems any pipe in the fire suppressionsystem shall not impairboth the utilized at Oconee. primaryand backup fire suppression capability. Further Ac tion Required Upon completion of the Nuclear Safety Capability Transition and determination if backup gaseous fire suppression systems are required to meet the nuclear safety performance criteria (compliance with deterministic criteria, or as a defense-in-depth feature for a change evaluation or transitioning licensing action) this section should be reviewed. 3.10.5 Comply Locally disarming an Provisionsfor locally disarming automaticgaseous suppression automatic gaseous fire systems shall be secured and under strict administrativecontrol, suppression system is controlled. 3.10.6 Comply ~installed The areasCO protected by.the 2 systems are Total flooding carbon dioxide systems shall not be used in normally i occupied areas, not normally occupied.

C-,uculation No.: OSC-9295 Revision No.: (i Applicable Units: Oconee Unit 1, 2, & 3 Page A33 of A37 NFPA 805 Chapter 3 Section Complianpe Statement Compliance Summary 3.10.7 Comply A pre-discharge alarm is slep wprovided for the SSF C02 Automatic total flooding carbon dioxide systems shall be equipped withw t an audiblepre-dischargealarm and dischargedelay sufficient to permit egress of personneL on discharge. The SSF System is provided with an The carbon dioxide system shall be provided with an odorizer. I odorizer. The Keowee Hydro Station's C02 supply is not provided with an odorizer because the area is not occupied. 3.10.8 Comply There are positive means to Positive mechanicalmeans shall be provided to lock out total flooding lock out the respective 002 carbon dioxide systems during work in the protected space. system during work in the area. 3.10.9 Further Action Required Evaluate and document the

                                                                                                  ! "        potential effect of rapid The possibility of secondary thermalshock (cooling) damage shall be                               p consideredduring the design of any gaseous fire suppressionsystem,                                 cooling of the Keowee but particularlywith carbon dioxide.                                                               Generators and the SSF Diesel Generator and their associated components in the area of C02 System discharge.

3.10.10 Further Action Required There are safety systems Particularattention shall be given to corrosive characteristicsof agent protected by 002 systems. decomposition products on safety systems. _

aichulation No.: OSC-9295 Revision No.: 0. Applicable Units: Oconee Unit 1, 2, & 3 Page A34 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary Evaluate and document the potential effect of corrosivity on the Keowee Generators and the SSF Diesel Generator and their associated components in the area of C02 System discharge. Section 3.11 Passive Fire Protection Features This section shall be used to determine the design and installationrequirements for passive protection features. Passive fire protection features include wall, ceiling, and floor assemblies, fire doors, fire dampers, and throdgh fire barrierpenetrationseals. Passive fire protection features also include electricalraceway fire barriersystems (ERFBS) that ýre provided to protect cables and electrical components and equipment from the effects of fire. 3.11.1 Building Separation Complies by Previous Building separation has NRC App',oval been approved by the NRC. Each major building within the power block shall be separatedfrom the C others by barriershaving a designated fire resistancerating of 3 hours or by open space of at least 50 ft (15.2 m) or space that meets the requirements of NFPA 80A, Recommended Practice for Protectionof The Keowee Hydro Station Buildings from ExteriorFire Exposures. and the SSF are separated Efrom the other buildings by, Exception: Where a performance-basedanalysis determines the la distance of greater than adequacy apply. of building separation,the requirements of 3.11.1 shall not feet. 3.11.2 Fire Barriers Complies by Previous The fire barriers between Fire barriersrequiredby Chapter4 shall include a specific fire- NRC Approval the major plant buildings resistancerating. Firebarriersshall be designed andinstalled to meet were found to be the specific fire resistancerating using assemblies qualified by fire _ acceptable by the NRC.

Caiaulation No.: OSC-295 Revision No.: 0 Applicable Units: Oconee Unit 1, 2, & 3 Page A35 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary tests. The qualification fire tests shall be in accordancewith NFPA 251, StandardMethods of Tests of Fire Endurance of Building Construction- - and Materials,or ASTM E 119, Standard Test Methods for Fire Tests of Upon completion of the Building Constructionand Materials. Further Adction Required Nuclear Safety Capability Transition, identify barriers required to meet the nuclear safety performance criteria (compliance with deterministic criteria, or as a defense-in-depth feature for a change evaluation or transitioning licensing action). Review the credited barriers to determine their adequacy. 3.11.3 Fire BarrierPenetrations Complies by Previous The fire barrier penetrations Penetrationsin fire barriersshall be provided with listed fire-rateddoo NRC Appoval were found to be door acceptable by the NRC. assemblies or listed rated fire'dampers having a fire resistancerating consistent with the designatedfire resistance rating of the barrieras

• determined by the performance requirements established by Chapter4.

(See 3.11.42forpenetrationseals for through penetrationfire stops.) Further Action Required Upon completion of the Passive fire protection devices such as doors and dampers shall Nuclear Safety Capability conform with the following NFPA standards, as applicable: Transition, identify barriers (1) NFPA 80, Standardfor Fire Doors and Fire Windows required to meet the nuclear safety performance criteria (2)NFPA90A, Standardfor the Installationof Air-Conditioning (compliance with and Ventilating Systems deterministic criteria, or as a (3) NFPA 101, Life Safety Code defense-in-depth feature for Exception: Where fire area boundariesare not wall-to-wall, floor-to- a change evaluation or ceiling boundaries with all penetrations.sealedto the fire rating required transitioning licensing of the boundaries,a performance-basedanalysis shall be requiredto

• action). Review the

wmUlation No.: OSC-9295 Revision No.: 6 - Applicable Units: OconieeUnit 1,2,& 3 Page A36 of A37 NFPA 805 Chapter 3 Section Complian e Statement Compliance Summary assess the adequacy of fire barrierforming the fire boundaryto credited barrier penetrations determine if the barrierwill withstand the fire effects of the hazards in to determine their the area. Openings in fire barriersshall be permitted to be protectedby I adequacy. other means as acceptable to the AHJ. 3.11.4 Through PenetrationFire Stops Comply bý Previous The Penetration Seal Through penetration fire stops for penetrationssuch as pipes, conduits, Licensee rvaluation Database and 86-10 bus ducts, cables, wires, pneumatic tubes and ducts, and similar Evaluation calculation building service equipment that pass through fire barriersshall be document the acceptability protected as follows, of the station penetration seals (a) The annularspace between the penetratingitem and the through opening in the fire barriershall be filled with a qualified fire-resistive penetrationseal assembly capable of maintaining the fire resistance of T the fire barrier.The assembly shall be qualified by tests in accordance Complies by Previous The NxRC has approved with a fire test protocol acceptable to the AHJ or be protected by a NRC Approval listed fire-rateddevice for the specified fire-resistiveperiod, penetration seals. (b) Conduits shall be provided with an internal fire seal thathas an equivalent fire-resistive ratingto that of the fire barrierthrough opening Further Action Required Upon completion of the

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fire stop and shall be permitted to be installedon either side of the i NUcoa Safety Nuclear Safety.Cpity Capability barrierin a location that is as close to the barrieras possible. Transition, identify barriers Exception: Openings inside conduit 4 in. (10.2 cm) or less in diameter required to meet the nuclear shall be sealed at the fire barrierwith a fire-ratedinternalseal unless safety performance criteria the conduit extends greaterthan 5ft (1.5 m) on each side of the fire (compliance with barrier.In this case the conduit opening shall be provided with deterministic criteria, or as a noncombustible materialto prevent the passage of smoke and hot defense-in-depth feature for gases. The fill depth of the materialpacked to a depth of 2 in. (5.1 cm) a change-evaluati or shall constitute an acceptable smoke and hot gas seal in this application. "transitioning licensing action). Review the credited barrier penetration seals to determine their adequacy.

Ciu*¢lation No.: OSC-9295 Revision No.: U Applicable Units: Oconee Unit 1. 2. & 3 Page A37 of A37 NFPA 805 Chapter 3 Section Compliance Statement Compliance Summary 3.11.5 Electrical Raceway Fire BarrierSystems (ERFBS) N/A Oconee does not utilize ERFBS requiredby Chapter4 shall be capable of resisting the fire ERFBS. effects of the hazards in the area. ERFBS shall be tested in accordance with and shall meet the acceptance criteriaof NRC Generic Letter 86- ] U Upon completion of the 10, Supplement 1, "FireEndurance Test Acceptance Criteria for Fire Further Aetion Required BarrierSystems Used to Separate Safe Shutdown Trains Within the Nuclear Safety Capability Same Fire Area." The ERFBS needs to adequatelyaddress the design Transition, identify ERFBS requirements and limitations of supports and intervening items and their required to meet the nuclear impact on the fire barriersystem rating.The fire barriersystem's ability I safety performance criteria to maintain the requirednuclear safety circuits free of fire damage for a (compliance with specific thermal exposure, barrierdesign, raceway size and type, cable deterministic criteria, or as a size, fill, and type shall be demonstrated. defense-in-depth feature for Exception No. 1: When the temperaturesinside the fire barriersystem a change evaluation or exceed the maximum temperatureallowed by the acceptance criteriaof transitioning licensing Generic Letter 86-10, "FireEnduranceAcceptance Test Criteria for Fire action). Determine if BarrierSystems Used to Separate Redundant Safe Shutdown Training credited ERFBS is rated Within the Same Fire Area," Supplement 1, functionality of the cable at appropriately. these elevated temperatures shall be demonstrated.Qualification demonstrationof these cables shall be performed in accordancewith the electricaltesting requirements of Generic Letter 86-10, Supplement 1, Attachment 1, "AttachmentMethods for DemonstratingFunctionality of Cables Protectedby Raceway Fire BarrierSystems During andAfter Fire Endurance Test Exposure." Exception No. 2: ERFBS systems employed prior to the issuance of Generic Letter 86-10, Supplement 1,are acceptableproviding that the system successfully met the limiting end point temperature requirementsas specified by the AHJ at the time of acceptance.}}