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| {{#Wiki_filter:N Nebraska Public Power District Always there when you need us 50.90 NLS2012006 April 24, 2012 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 | | {{#Wiki_filter:}} |
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| ==Subject:==
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| Nebraska Public Power District - Cooper Nuclear Station Docket No. 50-298, License No. DPR-46 License Amendment Request to Revise the Fire Protection Licensing Basis to NFPA 805 Per 10 CFR 50.48(c)
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| ==Reference:==
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| Letter from Brian J. O'Grady, Nebraska Public Power District, to U.S. Nuclear Regulatory Commission, dated June 27, 2011, "Revised Submittal Date for 10 CFR 50.48(c) License Amendment Request and Request for Extension of Enforcement Discretion" (NLS2011057)
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| ==Dear Sir or Madam:==
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| The purpose of this letter is for the Nebraska Public Power District (NPPD) to request an amendment to Facility Operating License DPR-46 under the provisions of 10 CFR 50.4 and 10 CFR 50.90, to revise the Cooper Nuclear Station (CNS) Operating License consistent with the adoption of National Fire Protection Association (NFPA) Standard 805 as the CNS Fire Protection Licensing Basis, in accordance with 10 CFR 50.48(c). This request is made consistent with the commitment provided in the referenced letter. A concurrent related change to the CNS Technical Specifications (TS) is also requested.
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| The adoption of NFPA 805 as the CNS Fire Protection Licensing Basis is effected through the replacement of the standard Fire Protection License Condition (License Condition 2.C.(4) of the CNS Operating License) with the License Condition specified in Regulatory Guide 1.205, Revision 1. A corollary change to TS 5.4.1 is also included. NPPD has determined from the No Significant Hazards Consideration determination that these changes do not involve a significant hazard.
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| Enclosure I provides the NFPA 805 Transition Report. This report describes the transition methodology utilized and documents how CNS complies with the new NFPA 805 requirements.
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| The report includes a description of the License Condition and TS changes, the basis for the amendment, the No Significant Hazards Consideration evaluation pursuant to 10 CFR 50.91 (a)(1), and the Environmental Impact evaluation pursuant to 10 CFR 51.22. Attachment I contains a markup of the proposed changes to License Condition 2.C.(4) and TS 5.4.1. contains the clean, retyped License and TS pages.
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| COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3877 / Fax: (402) 825-5211 www.nppd.com
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| NLS2012006 Page 2 of 2 The proposed TS changes have been reviewed by the necessary safety review committees (Station Operations Review Committee and Safety Review and Audit Board). Amendments to the CNS Facility Operating License through Amendment 241 issued February 16, 2012, have been incorporated into this request. This request is submitted under affirmation pursuant to 10 CFR 50.30(b). NPPD proposes an implementation date within six months after issuance of the NFPA 805 License Amendment.
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| By copy of this letter and its attachments, the appropriate State of Nebraska official is notified in accordance with 10 CFR 50.91 (b)(1). Copies are also being provided to the Nuclear Regulatory Commission Region IV office and the CNS Senior Resident Inspector in accordance with 10 CFR 50.4(b)(1).
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| Should you have any questions concerning this matter, please contact Todd Stevens, CNS NFPA 805 Transition Project Manager, at (402) 825-5159.
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| I declare under penalty of perjury that the foregoing is true and correct.
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| Executed on: 1- %ý .--k ,"
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| "k(Date)
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| Sincerelyrly,j yC J Brian J. O'Grady Vice President - Nuclear and Chief Nuclear Officer
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| /WV Enclosure and Attachments cc: Regional Administrator w/Enclosure and Attachments USNRC - Region IV Cooper Project Manager w/Enclosure and Attachments USNRC - NRR Project Directorate IV-1 Senior Resident Inspector w/Enclosure and Attachments USNRC - CNS Nebraska Health and Human Services w/Enclosure and Attachments Department of Regulation and Licensure NPG Distribution w/o Enclosure and Attachments CNS Records w/Enclosure and Attachments
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| 4 ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© 4
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| ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© Correspondence Number: NLS2012006 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
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| COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE NPPD will implement the new NFPA 805 fire Within six months after protection program to include procedure issuance of the NFPA changes, process updates, and training to NLS2012006-01 805 License affected plant personnel as identified in Table Amendment.
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| S-3 of Attachment S to Enclosure 1.
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| .4 .4
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| .4 4
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| .4 .4
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| .4 .4
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| .4 .4
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| .4 .4 4 .4 4 4 4 4 4 4
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| .4 .4
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| NLS2012006 Page 1 of 820 ENCLOSURE 1 Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition Transition Report
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| Nebraska Public Power District Cooper Nuclear Station Docket Number 50-298 Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition Nebraska Public Power District Transition Report April 2012
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| Nebraska Public Power District CNS NFPA 805 Transition Report Table of Contents Executive S um m ary ................................................................................................................... iv List of Acronym s ......................................................................................................................... v
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| ==1.0 INTRODUCTION==
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| ...................................................................................................... I 1 .1 B ac kg ro u n d ................................................................................................................ I 1.1.1 NFPA 805 - Requirements and Guidance .............................................. 1 1.1.2 Transition to 10 CFR 50.48(c) .................................................................. 2 1 .2 P u rp os e ...................................................................................................................... 3 2.0 OVERVIEW OF THE EXISTING FIRE PROTECTION PROGRAM ............................. 4 2.1 Current Fire Protection Licensing Basis ................................................................. 4 2.2 NRC Acceptance of the Fire Protection Licensing Basis ...................................... 4 3.0 TRANSITION PROCESS ............................................................................................. 8 3 .1 B a c kg ro u n d ................................................................................................................ 8 3.2 N FPA 805 P rocess .............................................................................................. 8 3.3 NEI 04 NFPA 805 Transition Process ......................................................... 10 3.4 NFPA 805 Frequently Asked Questions (FAQs) ................................................. 11 4.0 COMPLIANCE WITH NFPA 805 REQUIREMENTS ................................................. 12 4.1 Fundamental Fire Protection Program and Design Elements .............................. 12 4.1.1 Overview of Evaluation Process ............................................................ 12 4.1.2 Results of the Evaluation Process .......................................................... 14 4.1.3 Definition of Power Block and Plant ........................................................ 15 4.2 Nuclear Safety Performance Criteria .................................................................. 15 4.2.1 Nuclear Safety Capability Assessment Methodology ............................. 15 4.2.2 Existing Engineering Equivalency Evaluation Transition ........................ 21 4.2.3 Licensing Action Transition ..................................................................... 22 4.2.4 Fire A rea T ransition ............................................................................... 24 4.3 Non-Power Operational Modes ........................................................................... 27 4.3.1 Overview of Evaluation Process ............................................................ 27 4.3.2 Results of the Evaluation Process .......................................................... 30 4.4 Radioactive Release Performance Criteria .......................................................... 30 4.4.1 Overview of Evaluation Process ............................................................ 30 4.4.2 Results of the Evaluation Process .......................................................... 31 4.5 Fire PRA and Performance-Based Approaches ................................................. 31 4.5.1 Fire PRA Development and Assessment .............................................. 31 4.5.2 Performance-Based Approaches ............................................................ 34 Pagei
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| mI hraska Pubhlic Powe~r Dlistrict flNJS NIPPA 805 Trnncitinn Panvnr k Table of Contents (continued) 4.6 Monitoring Program ............................................................................................ 38 4.6.1 Overview of NFPA 805 Requirements for the NFPA 805 Monitoring P ro g ra m ............................................................................................... . . 39 4.6.2 Overview of Post-Transition NFPA 805 Monitoring Program ................. 39 4.7 Program Documentation, Configuration Control, and Quality Assurance ........... 44 4.7.1 Compliance with Documentation Requirements in Section 2.7.1 of N F PA 805 ............................................................................................ . . 45 4.7.2 Compliance with Configuration Control Requirements in Section 2.7.2 and 2.2.9 of NFPA 805 .................................................................. 47 4.7.3 Compliance with Quality Requirements in Section 2.7.3 of NFPA 8 0 5 ...................................................................................................... ... 50 4.8 S um m ary of R esults ............................................................................................. 52 4.8.1 Results of the Fire Area Review ............................................................ 52 4.8.2 Plant Modifications and Items to be Completed During the Implementation Phase ........................................................................... 52 4.8.3 Supplemental Information - Other Licensee Specific Issues ................. 53
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| ==5.0 REGULATORY EVALUATION==
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| .................................................................................. 64 5.1 Introduction - 10 CFR 50.48 ............................................................................... 64 5.2 R egulatory Topics ............................................................................................... 68 5.2.1 License Condition Changes .................................................................. 68 5.2.2 Technical Specifications ......................................................................... 69 5.2.3 Orders and Exemptions ......................................................................... 69 5.3 R egulatory Evaluations ........................................................................................ 69 5.3.1 No Significant Hazards Consideration ................................................... 69 5.3.2 Environmental Consideration ................................................................ 69 5.4 Revision to the Updated Safety Analysis Report ................................................. 69 5.5 Transition Implementation Schedule ................................................................... 70 6.0 R E FE R E NC ES ................................................................................................................ 71 ATTACHMENTS A. NEI 04-02 Table B Transition of Fundamental Fire Protection Program and D esign E lem ents ............................................................................................... A -1 B. NEI 04-02 Table B Nuclear Safety Capability Assessment - Methodology R ev ie w ................................................................................................................... B -1 C. NEI 04-02 Table B Fire Area Transition ...................................................... C-1 D. NEI 04-02 Non-Power Operational Modes Transition ........................................ D-1 E. NEI 04-02 Radioactive Release Transition ....................................................... E-1 F. Fire-Induced Multiple Spurious Operations Resolution ...................................... F-1 Page ii
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| Klohr-k- P"hlir- Power DiQtrint KIPPA ME; Trnncifinn Pann
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| (~NI~ NIPPA RA'~ Tr2nQitinn Pc.nnrt NI c~hr~k~ Piihlij- PA~A,~r flktrirt L Table of Contents (continued)
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| G. Recovery Actions Transition .................................................................................. G-1 H. NFPA 805 Frequently Asked Question Summary Table .................................... H-1 I. Definition of Power Block and Plant ..................................................................... I-1 J. F ire Mode ling V &V .................................................................................................. J-1 K. Existing Licensing Action Transition .................................................................. K-1 L. NFPA 805 Chapter 3 Requirements for Approval (10 CFR 50.48(c)(2)(vii)) ........... L-1 M. License Condition Changes ............................................................................. M-1 N. Technical Specification Changes ....................................................................... N-1
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| : 0. Orders and Exemptions ................................................................................... 0 -1 P. RI-PB Alternatives to NFPA 805 10 CFR 50.48(c)(4) ........................................ P-1 Q. No Significant Hazards Evaluations ....................................................................... Q-1 R. Environmental Considerations Evaluation ......................................................... R-1 S. Plant Modifications and Items to be Completed During Implementation ............... S-1 T. Clarification of Prior NRC Approvals .................................................................. T-1 U. Internal Events PRA Quality ............................................................................. U-1 V. Fire PR A Q uality ................................................................................................ V -1 W . Fire PRA Insights ............................................................................................ W-1 Page iii
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| Neb~raska Piihli,, Pnvior flktri-t ('ImJ! NjiPPA ~Ant Troan-cifir Rcannr L Executive Summary Nebraska Public Power District (NPPD) will transition the Cooper Nuclear Station (CNS) fire protection program to a new Risk-Informed, Performance-Based (RI-PB) alternative per 10 CFR 50.48(c) which incorporates by reference NFPA 805. The licensing basis per 10 CFR 50.48(b) and 10 CFR 50 Appendix R will be superseded.
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| NPPD submitted the initial letter of intent in December 2005. The intended submittal date was revised in a September 2008 letter. Most recently, in a letter dated June 27, 2011, NPPD committed to submit the 10 CFR 50.48(c) License Amendment Request (LAR) by April 27, 2012.
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| The transition process consisted of a review and update of CNS documentation, including the development of a Fire Probabilistic Risk Assessment using NUREG/CR-6850 as guidance. This Transition Report summarizes the transition process and results. This Transition Report contains information:
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| " Required by 10 CFR 50.48(c)
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| " Recommended by guidance document Nuclear Energy Institute (NEI) 04-02 Revision 2 and appropriate Frequently Asked Questions (FAQs)
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| " Recommended by guidance document Regulatory Guide 1.205 Revision 1 Section 4 of the Transition Report provides a summary of compliance with the following NFPA 805 requirements:
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| " Fundamental Fire Protection Program Elements and Minimum Design Requirements
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| " Nuclear Safety Performance Criteria
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| * Non-Power Operational Modes
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| * Radioactive Release Performance Criteria
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| " Fire Probabilistic Risk Assessment and Performance-Based Approach
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| " Monitoring Program
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| * Program Documentation, Configuration Control, and Quality Assurance Section 5 of the Transition Report provides regulatory evaluations and associated attachments, including:
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| " Changes to License Condition
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| " Changes to Technical Specifications, Orders, and Exemptions
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| " Determination of No Significant Hazards and evaluation of Environmental Considerations The attachments to the Transition Report include detail to support the transition process and results.
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| Attachment H contains the approved FAQs not yet incorporated into the endorsed revision of NEI 04-02. These FAQs have been used to clarify the guidance in Regulatory Guide 1.205, NEI 04-02, and the requirements of NFPA 805 and in the preparation of this License Amendment Request.
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| Page iv
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| PKIC KIC:DA Q0r, T KlohnneL-n P"hlin r)f%%AP,=r r)icfrL-+
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| k~chr~L~P,.~ig licrir fJLS~ll.J~
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| Jetw r+
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| List of Acronyms AC alternating current ACP Auxiliary Control Panel ADAMS Agency-wide Document Access and Management System ADS Automatic Depressurization System AHJ Authority Having Jurisdiction ANS American Nuclear Society ANSI American National Standards Institute AOV air-operated valve ASD alternate shutdown ASME American Society of Mechanical Engineers BWR boiling water reactor BWROG Boiling Water Reactor Owners Group CC Capability Category CCDP conditional core damage probability CDF core damage frequency CFAST Consolidated Model of Fire Growth and Smoke Transport CFR Code of FederalRegulations CNS Cooper Nuclear Station CRD control rod drive CS Core Spray CT current transformer DC direct current DG Diesel Generator DID defense-in-depth ECCS Emergency Core Cooling System ECST Emergency Condensate Storage Tank EDG Emergency Diesel Generator EEEE Existing Engineering Equivalency Evaluations EPRI Electric Power Research Institute ERFBS electrical raceway fire barrier system F&O facts and observations FAQ frequently asked question FDS Fire Dynamics Simulator FHA Fire Hazards Analysis FPA Foote, Pagni, and Alvares FP Fire Protection FPP Fire Protection Program FPRA fire probabilistic risk assessment FR Federal Register FRE fire risk evaluation FSAR Final Safety Analysis Report GDC general design criterion/criteria GL Generic Letter gpm gallons per minute HEP human error probability HGL hot gas layer HPCI High Pressure Coolant Injection HRE higher risk evolution HRR heat release rate Page v
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| MahmQkm P"Win Pnwor ni ri ('Klq KISZOA 51f)9; Trnneilinn Dim, nvi fk~rrt Pithu Pr~Ar M~hrd~' C~M~MIP ~fI T~tninnPc~~rit!
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| List of Acronyms (continued)
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| HSS high safety significant HVAC heating, ventilation, and air conditioning IMC Inspection Manual Chapter IN Information Notice KSF key safety function LAR license amendment request LPCI Low Pressure Coolant Injection LERF large early release frequency M&TE measurement and test equipment MCB main control board MCC motor control center MCR Main Control Room MOV motor-operated valve MQH McCaffrey, Quintiere, and Harkleroad MSIV main steam isolation valve MSO Multiple Spurious Operations NBI nuclear boiler instrumentation NEI Nuclear Energy Institute NFPA National Fire Protection Association NPO non-power operation NPPD Nebraska Public Power District NRC Nuclear Regulatory Commission NSCA nuclear safety capability analysis OMA operator manual action PC Primary Containment POS plant operational state PRA probabilistic risk assessment PSA probabilistic safety assessment PWR pressurized water reactor QAPD Quality Assurance Program for Operation - Policy Document RA recovery action RAW risk achievement worth RCIC Reactor Core Isolation Cooling REC Reactor Equipment Cooling RG Regulatory Guide RHR Residual Heat Removal RHRSW Residual Heat Removal Service Water RI-PB Risk-Informed, Performance-Based RIS regulatory issue/information summary RP Radiation Protection RPS Reactor Protection System RPV Reactor Pressure Vessel RR Reactor Recirculation RWCU Reactor Water Clean-up SDC Shutdown Cooling SFPE Society of Fire Protection Engineers SPC Suppression Pool Cooling SR Supporting Requirement SRP Standard Review Plan Page vi
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| KliahrooLen D"Wit- Demkjýr r)iefri^+ f'KIQ KICDA Qnr, -r ;4; 0 ý4
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| ,. ~~iOUI ~ .,I~jEli I ~ UU~j iai IVLLIIIXIiJ IXO List of Acronyms (continued)
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| SRV Safety Relief Valve SSA Safe Shutdown Analysis SSC systems, structures, and components SW Service Water USAR Updated Safety Analysis Report V&V verification and validation VAC volts alternating current VDC volts direct current VFDR variance from deterministic requirements yr year ZOI zone of influence Page vii
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| Nebraska Pubhlic Power Distric~t CN5S NFPA 805 Transition Report
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| ==1.0 INTRODUCTION==
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| The Nuclear Regulatory Commission (NRC) has promulgated an alternative rule for fire protection requirements at nuclear power plants, 10 CFR 50.48(c), National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants - 2001 Edition" (Ref. 1). Nebraska Public Power District (NPPD) is implementing the methodology identified in Nuclear Energy Institute (NEI) document NEI 04-02, "Guidance for Implementing a Risk-informed, Performance-based Fire Protection Program Under 10 CFR 50.48(c)" (NEI 04-02, Ref. 2), to transition Cooper Nuclear Station (CNS) from its current fire protection licensing basis to the new requirements as outlined in NFPA 805. This report describes the transition methodology utilized and documents how CNS complies with the new requirements.
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| 1.1 Background 1.1.1 NFPA 805 - Requirements and Guidance On July 16, 2004, the NRC amended 10 CFR 50.48, Fire Protection, to add a new subsection, 10 GFR 50.48(c), which established new Risk-Informed, Performance-Based (RI-PB) fire protection requirements. 10 CFR 50.48(c) incorporates by reference, with exceptions, NFPA 805, as a voluntary alternative to 10 CFR 50.48 Sections (b) and (f).
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| As stated in 10 CFR 50.48(c)(3)(i), any licensee's adoption of a RI-PB program that complies with the rule is voluntary. This rule may be adopted as an acceptable alternative method for complying with either 10 CFR 50.48(b), for plants licensed to operate before January 1, 1979, or the fire protection license conditions for plants licensed to operate after January 1, 1979, or 10 CFR 50.48(f), for plants shutdown in accordance with 10 CFR 50.82(a)(1).
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| NEI developed NEI 04-02 to assist licensees in adopting NFPA 805 and making the transition from their current fire protection licensing basis to one based on NFPA 805. The NRC issued Regulatory Guide (RG) 1.205, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants" (Ref. 3), which endorses NEI 04-02, with exceptions, in December 2009.1 A depiction of the primary document relationships is shown in Figure 1-1:
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| Where referred to in this document NEI 04-02 is Revision 2 and RG 1.205 is Revision 1.
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| Page 1
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| Nebrask~a Pubhlic- Power Distric~t CJ~l5 NEPA ARO Trznncitinn Painnrf 10 CFR Incorporation by 42 Reference
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| -___ 50.48(c)
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| C 0
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| E ------291914 ad 0r
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| "----'- National Fire Protection LIMIn:rla GenrarMU Association Standard NFPA 805.
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| I I z z 11 NEI 04-02 RG 1.205 U Endorsement C
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| 48 GUIDANCE FOR RI-PB FP FOR EXISTING IMPLEMENTING A RI.PB LIGHT-WATER NUCLEAR FP PROGRAM UNDER 10 POWER PLANTS CFR 50.48(c)
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| N Figure 1 NFPA 805 Transition - Implementation Requirements/Guidance 1.1.2 Transition to 10 CFR 50.48(c) 1.1.2.1 Start of Transition NPPD submitted a letter of intent to the NRC on December 22, 2005 (Ref. 4), for CNS to adopt NFPA 805 in accordance with 10 CFR 50.48(c).
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| By letter dated March 7, 2006, the NRC acknowledged receipt of the letter of intent. The letter stated that the CNS discretion period would begin on December 31, 2005, and expire on December 31, 2007. The letter did not specifically grant the four-year enforcement discretion period requested in the letter of intent (Ref. 5).
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| The NRC granted a third year of enforcement discretion by Federal Register Notice 71 FR 19905, dated April 18, 2006. In accordance with NRC Enforcement Policy, the enforcement discretion period would continue until the NRC approval of the License Amendment Request (LAR) is completed.
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| On the basis of a revision to the Enforcement Policy (71 FR 19905), a three-year enforcement discretion period was granted to CNS by the NRC in a letter dated October 30, 2006 (Ref. 6).
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| Therefore, the NRC considered the discretion period for CNS, which began on December 22, 2005, to expire on December 22, 2008.
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| On September 10, 2008, the NRC published in the Federal Register (73 FR 52705) a revision to its Interim Enforcement Policy regarding enforcement discretion for certain fire protection Page 2
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| Neraska Pubichi Power District ('Ni NIPPA 805! Transition Rernort issues, allowing licensees the option to request an extended enforcement discretion period for submittal of a LAR if they are pursuing transition to 10 CFR 50.48(c). This revision states that an additional period of enforcement discretion may be granted on a case-by-case basis, if a licensee has made substantial progress in its transition effort. This additional period of enforcement discretion, if granted, would end six months after the date of the safety evaluation approving the second pilot plant LAR review. The enforcement discretion would continue in place, without interruption, until NRC approval of the LAR to transition to 10 CFR 50.48(c).
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| By letter dated September 19, 2008, and in accordance with Federal Register Notice 73 FR 52705, NPPD requested that enforcement discretion be extended for CNS until six months after the safety evaluation is issued for the second pilot plant (Ref. 7).
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| By letter dated December 19, 2008, the NRC staff reviewed Nebraska Public Power District's request, and determined that the licensee had made substantial enough progress in its transition to NFPA 805 to grant the additional enforcement discretion. Accordingly, the enforcement discretion period was extended until six months after the date of the safety evaluation approving the second pilot plant LAR (Ref. 8).
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| On December 29, 2010, the NRC issued a safety evaluation for the second pilot plant (Ref. 9).
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| Based on this document, the period of enforcement discretion for CNS was to end June 29, 2011.
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| On June 27, 2011, and in accordance with SECY-11-0033, NPPD committed to submit the NFPA 805 LAR by April 27, 2012 (Ref. 10). This was accepted in an NRC letter dated July 28, 2011, which extended enforcement discretion for CNS until NRC approval of the NFPA 805 LAR is obtained (Ref. 11).
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| 1.1.2.2 Transition Process The transition to NFPA 805 includes the following high level activities:
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| * A new fire safe shutdown analysis
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| * A new Fire Probabilistic Risk Assessment (FPRA) using NUREG/CR-6850, "EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities" (Ref. 12), as guidance and a revision to the Internal Events Probabilistic Risk Assessment (PRA) to support the FPRA
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| * Completion of activities required to transition the pre-transition Licensing Basis to 10 CFR 50.48(c) as specified in NEI 04-02 and RG 1.205 1.2 Purpose The purpose of the Transition Report is as follows:
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| : 1) Describe the process implemented to transition the current fire protection program (FPP) to compliance with the additional requirements of 10 CFR 50.48(c);
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| : 2) Summarize the results of the transition process;
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| : 3) Explain the bases for conclusions that the FPP complies with 10 CFR 50.48(c) requirements;
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| : 4) Describe the new fire protection licensing basis; and,
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| : 5) Describe the configuration management processes used to manage post-transition changes to the station and the FPP, and resulting impact on the Licensing Basis.
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| Page 3
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| Klýk ýoL, D"kflý D^ r)io+r;^f I-KIC KICDA Qnr T ;#; D rf Ia n
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| ... .litItvv~ILJOItf .r.,Iu in fJJ I I caai I WOLI.J .'J L 2.0 OVERVIEW OF THE EXISTING FIRE PROTECTION PROGRAM 2.1 Current Fire Protection Licensing Basis CNS was licensed to operate on January 18, 1974. As a result, CNS has a fire protection program based on compliance with 10 CFR 50.48(a), 10 CFR 50.48(b), 10 CFR 50 Appendix R (Sections III.G 2, Ill.J, and 111.O3), Branch Technical Position APCSB 9.5-1, Appendix A, and the following License Condition.
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| CNS Operating License Condition 2.C.(4) states:
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| The licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Cooper Nuclear Station (CNS)
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| Updated Safety Analysis Report and as approved in the Safety Evaluations dated November 29, 1977; May 23, 1979; November 21, 1980; April 29, 1983; April 16, 1984; June 1, 1984; January 3, 1985; August 21, 1985; April 10, 1986; September 9, 1986; November 7, 1988; February 3, 1989; August 15, 1995; and July 31, 1998, subject to the following provision:
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| The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
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| 2.2 NRC Acceptance of the Fire Protection Licensing Basis An NRC letter dated May 3, 1976, transmitted to NPPD a copy of Standard Review Plan (SRP) 9.5.1 "Fire Protection System" (Ref. 13). In a letter dated May 11, 1976 (Ref. 14) (and later clarified in a letter dated September 30, 1976 (Ref. 15)), the NRC requested NPPD compare the existing fire protection provisions at CNS with Appendix A of the SRP guidelines. The NRC also requested that Fire Protection Technical Specifications be proposed. The Fire Hazards Analysis (FHA) was developed in response to this request, and submitted to the NRC on December 17, 1976 (Ref. 16) (with a supplemental FHA submittals on March 31, 1977, and April 6, 1977 (Ref. 17 and 18)). Proposed Fire Protection Technical Specifications were submitted on February 4, 1977 (Ref. 19) (as revised on July 20, 1977, and December 19, 1977 (Ref. 20 and 21)). The NRC Staff reviewed these submittals and issued fire protection review questions, which NPPD responded to in letters dated May 11, 1978, June 21, 1978, August 16, 1978, December 11, 1978, and April 12, 1979 (Ref. 22, 23, 24, 25, and 26). On November 29, 1977, the NRC issued the initial Fire Protection Technical Specifications (Ref.
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| 27). On May 23, 1979, the NRC issued the Safety Evaluation Report with License Amendment 56, which summarized the status of their evaluation of the FPP at CNS, and revised the CNS Fire Protection Technical Specifications (Ref. 28). By letters dated October 22, 1979, and January 16, 1980 (Ref. 29 and 30), NPPD proposed additional changes to the Fire Protection Technical Specifications, and submitted additional information concerning fire protection modifications. On November 21, 1980, the NRC issued License Amendment 66, which contained Supplement No. 1 to the Fire Protection Safety Evaluation (Ref. 31). This completed the staff's fire protection review for CNS.
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| 2 In response to Generic Letter 86-10 Question 5.1.3, the NRC established that Section III.L is applicable to Paragraph III.G.3, where that option is chosen by the licensee.
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| 3 The 10 CFR 50 Appendix R Section 111.0 requirements for a reactor coolant pump oil collection system are not applicable to CNS since the containment is inerted during normal operation.
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| Page 4
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| Nhrmcka Pubichi Poweur Dlistrict flN5 NFPA 805~ Transition Rponrt Pursuant to a scheduler exemption from the requirements of the previously issued 10 CFR 50.48 and 10 CFR 50 Appendix R, NPPD provided the NRC on June 28, 1982, the "Response to 10 CFR 50 Appendix R 'Fire Protection of Safe Shutdown Capability,"' Volumes I and II (Ref. 32). On December 2, 1983, NPPD submitted Volume III to that analysis (Ref. 33).
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| On April 16, 1984, the NRC issued a Safety Evaluation which concluded that CNS met the requirements of Appendix R, Section III.G.3 and III.L (Ref. 34). In a letter dated July 29, 2002, NPPD provided to the NRC clarifying information contained in the April 16, 1984 Safety Evaluation, while reaffirming that the NRC's conclusion that CNS meets the requirements of Appendix R, Section III.G.3 and III.L remained valid (Ref. 35).
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| In letters dated May 9, 1985, and June 7, 1985, NPPD reported to the NRC the results of the re-developed Appendix R analysis and identified additional required modifications (Ref. 36 and 37). On August 21, 1985, the NRC issued a Safety Evaluation which concluded that the proposed modifications were in accordance with the technical requirements of Appendix R and were acceptable (Ref. 38).
| |
| In response to NPPD LARs, various Fire Protection Technical Specification changes were approved by the NRC:
| |
| - Amendment 82, dated April 29, 1983, regarding the Fire Protection Clean Water Supply (Ref. 39).
| |
| - Amendment 86, dated June 1, 1984, regarding submittal of 30-day Special Reports (Ref.
| |
| 40).
| |
| - Amendment 90, dated January 3, 1985, regarding installation of additional fire detection instruments (Ref. 41).
| |
| - Amendment 98, dated April 10, 1986, regarding the addition of a Halon fire suppression system and fire detectors in the Service Water Pump Room (Ref. 42)
| |
| - Amendment 101, dated September 9, 1986, regarding usage of Fire Protection procedures (Ref. 43).
| |
| - Amendment 126, dated November 7, 1988, regarding Alternate Shutdown Capability (Ref. 44).
| |
| - Amendment 127, dated February 3, 1989, regarding miscellaneous changes to the FPP (Ref. 45).
| |
| Ultimately, as a result of the conversion to the Improved Standard Technical Specifications (License Amendment 178, dated July 31, 1998), the CNS Fire Protection Technical Specifications were relocated to the Technical Requirements Manual, a document incorporated by reference into the CNS Updated Safety Analysis Report (USAR) (Ref. 46).
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| In a letter dated December 16, 1994, NPPD identified to the NRC a number of commitment revisions, several of which affected the bases used to support specific exemptions granted by the NRC (Ref. 47). In this letter, NPPD also withdrew an exemption granted for the Critical Switchgear Rooms 1F and 1G that was determined to no longer be necessary. On August 15, 1995, the NRC issued a Safety Evaluation which revoked the exemption for the Critical Switchgear Rooms 1F and 1G (Ref. 48).
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| Page 5
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| Nebraska~ Pubhlic Power flktrint ('KlJq KIPJPA RO-R Trmn--ifir Pcannrt The following currently granted exemptions to 10 CFR 50 Appendix R, Section III.G are noted as having been previously approved by the NRC:
| |
| : 1. Exemption for lack of twenty foot separation between redundant Service Water Pumps in the Intake Structure as described in an NPPD submittal dated June 28, 1982. The NRC granted the exemption in a letter to NPPD dated September 21, 1983 (Ref. 49).
| |
| : 2. Exemption for lack of twenty foot separation free of intervening combustibles or one-hour barriers between redundant trains in the Cable Spreading Room as described in NPPD submittals dated June 28, 1982, March 18, 1983 (Ref. 50), and June 2, 1983 (Ref. 51). The NRC granted the exemption in a letter to NPPD dated September 21, 1983.
| |
| : 3. Exemption for lack of twenty foot separation or one-hour barriers between redundant trains in the Cable Expansion Room as described in NPPD submittals dated June 28, 1982, March 18, 1983, and June 2, 1983. The NRC granted the exemption in a letter to NPPD dated September 21, 1983.
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| : 4. Exemption for lack of one-hour rated fire barriers for redundant conduits and area wide automatic suppression system in the Reactor Building northeast corner at the 903'-6" Elevation as described in NPPD submittals dated June 28, 1982, March 18, 1983, and June 2, 1983. The NRC granted the exemption in a letter to NPPD dated September 21, 1983.
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| : 5. Exemption for lack of an automatic suppression system in the Control Building basement as described in NPPD submittals dated June 28, 1982, March 18, 1983, and June 2, 1983. The NRC granted the exemption in a letter to NPPD dated September 21, 1983.
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| : 6. Exemption for lack of a fixed suppression system in the Auxiliary Relay Room as described in NPPD submittals dated June 28, 1982, March 18, 1983, and June 2, 1983. The NRC granted the exemption in a letter to NPPD dated September 21, 1983.
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| : 7. Exemption for lack of a fixed suppression system in the Control Room as described in NPPD submittals dated June 28, 1982, March 18, 1983, and June 2, 1983. The NRC granted the exemption in a letter to NPPD dated September 21, 1983.
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| : 8. Exemption for lack of a three-hour barrier, or twenty feet of separation free of intervening combustibles combined with automatic suppression and detection for the redundant reactor vessel level and pressure instrument racks at the Reactor Building 931' Elevation, as described in an NPPD submittal dated March 18, 1983. The NRC granted the exemption in a letter to NPPD dated September 21, 1983.
| |
| : 9. Exemption for lack of a three-hour barrier, or twenty feet of separation free of intervening combustibles combined with automatic suppression and detection, and lack of alternate shutdown capability independent of the area, at the Reactor Building 903'-6" Elevation (excluding northeast corner), as described in an NPPD submittal dated March 18, 1983. The NRC granted the exemption in a letter to NPPD dated September 21, 1983.
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| : 10. Exemption for lack of three-hour barrier, or twenty feet of separation free of intervening combustibles combined with automatic suppression and detection, and lack of alternate shutdown capability independent of the area, at the Reactor Building 859' and 881' Elevations - Quadrants and Torus Area, as described in an NPPD Page 6
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report submittal dated March 18, 1983. The NRC granted the exemption in a letter to NPPD dated September 21, 1983.
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| Page 7
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| | |
| N-hr-ska Pubhlic Power District C'NS5 NFPA 8n-r! Transition Reno~r L 3.0 TRANSITION PROCESS 3.1 Background Section 4.1.2 of NEI 04-02 describes the process for transitioning from compliance with the current fire protection licensing basis to the new requirements of 10 CFR 50.48(c):
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| Phase 1: Preliminary Assessment and Letter of Intent
| |
| * Make preliminary determination of the activities that will be necessary to support the transition.
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| * Make initial determination of any changes to the plant or FPP that may be necessary.
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| * Establish a tentative schedule for completing all of the actions necessary for the transition.
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| * Submit a Letter of Intent to the NRC.
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| Phase 2: Analysis and License Amendment Request
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| * Conduct the transition activities to demonstrate compliance. Section 4.3 describes in detail how the current fire protection licensing basis can be used to support demonstrations of compliance with the requirements in NFPA 805.
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| * Determine extent to which the current fire protection licensing basis can be shown to demonstrate compliance with the new fire protection requirements.
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| " Determine any changes to the plant that will require a license amendment.
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| " Determine any alternative methods and analytical approaches that will be relied on to demonstrate compliance with the new fire protection requirements and will require a license amendment.
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| * Document the new fire protection licensing basis in a Transition Report.
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| * Update the schedule for completion of transition activities.
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| * Submit a LAR to the NRC.
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| Phase 3: Completion of Transition
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| * While the NRC reviews the LAR, complete all of the transition activities which do not require prior NRC approval, including plant changes which do not require a license amendment under the current license condition, procedure changes, and training.
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| " After the NRC issues the license amendment, complete any changes to the plant that required a license amendment.
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| * Rely on alternative methods and analytical approaches acceptable to the NRC to demonstrate compliance with the new fire protection requirements.
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| " Adopt the new licensing basis.
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| 3.2 NFPA 805 Process Section 2.2 of NFPA 805 establishes the general process for demonstrating compliance with NFPA 805. This process is illustrated in Figure 3-1. It shows that except for the fundamental fire protection requirements, compliance can be achieved on a fire area basis either by deterministic or risk-informed, performance-based (RI-PB) methods. Consistent with the Page 8
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| Nebras~ka Pubichi Power Dlistrict r.N5R NIFPA Rns; TrnnQitinn Ranni-t guidance in NEI 04-02, CNS has implemented the NFPA 805 Section 2.2 process by first determining the extent to which its current FPP supports findings of deterministic compliance with the requirements in NFPA 805. RI-PB methods are being applied to the requirements for which deterministic compliance could not be shown.
| |
| a.
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| 1kGiE5SDdenteff #PA 806 Section 2-"~)
| |
| (Chap- 31 kf int h.,dti NPA 805 Section, 221b eb mve SO.Ifie WWl oaut Esubis mcnwhon tFPA 806 Section 2--f I N~U" Figure 3 NFPA 805 Process (NEI 04-02 Figure 3-1 based on NFPA 805 Figure 2.2)4 4 Note: 10 CFR 50.48(c) does not incorporate by reference Life Safety and Plant Damage/Business Interruption goals, objectives and criteria. See 10 CFR 50.48(c) for specific exceptions to the incorporation by reference of NFPA 805.
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| Page 9
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| Klýkrn L-n Do akli D %Aj r M 4 ;^# r'KIC KICDA On= -r ;+; D ý+
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| I %JII.~W 0jVILI~I1L F aiMiui 10"aIs V"l xIWIIJ.
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| 3.3 NEI 04 NFPA 805 Transition Process NFPA 805 contains technical processes and requirements for a RI-PB FPP. NEI 04-02 was developed to provide guidance on the overall process (programmatic, technical, and licensing) for transitioning from a traditional fire protection licensing basis to a new RI-PB method based upon NFPA 805, as shown below in Figure 3-2.
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| Section 4.0 of NEI 04-02 describes the detailed process for assessing an FPP for the extent to which it complies with NFPA 805, as shown in Figure 3-2.
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| Transition Report Transition Report Sect. 4.1 Sect. 4.2 tA A SUse PB Approach if Report Needed (Fire Modeling or Fire Risk Evaluations) } Sect. 4.5 Transition Figure 3 Transition Process (Simplified) (based on NEI 04-02 Figure 4-1)
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| Page 10
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| Nebraska Public Power District CNS NFPA 805 Transition Renort 3.4 NFPA 805 Frequently Asked Questions (FAQs)
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| The NRC has worked with NEI and two Pilot Plants (Oconee Nuclear Station and Harris Nuclear Plant) to define the licensing process for transitioning to a new licensing basis under 10 CFR 50.48(c) and NFPA 805. Both the NRC and the industry recognized the need for additional clarifications to the guidance provided in RG 1.205, NEI 04-02, and the requirements of NFPA 805. The NFPA 805 FAQ process was jointly developed by NEI and NRC to facilitate timely clarifications of NRC positions. This process is described in a letter from the NRC dated July 12, 2006, to NEI (Ref. 52) and in Regulatory Issues Summary 2007-19, "Process for Communicating Clarifications of Staff Positions Provided in RG 1.205 Concerning Issues Identified during the Pilot Application of NFPA Standard 805", dated August 20, 2007 (Ref. 53).
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| Under the FAQ Process, transition issues are submitted to the NEI NFPA 805 Task Force for review, and subsequently presented to the NRC during public FAQ meetings. Once the NEI NFPA 805 Task Force and NRC reach agreement, the NRC issues a memorandum to indicate that the FAQ is acceptable. NEI 04-02 will be revised to incorporate the approved FAQs. This is an on-going revision process that will continue through the transition of non-pilot NFPA 805 plants. Final closure of the FAQs will occur when future revisions of RG 1.205, endorsing the related revisions of NEI 04-02, are approved by the NRC. It is expected that additional FAQs will be written and existing FAQs will be revised as plants continue NFPA 805 transition after the Pilot Plant Safety Evaluations.
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| Attachment H contains the list of approved FAQs not yet incorporated into the endorsed revision of NEI 04-02. These FAQs have been used to clarify the guidance in RG 1.205, NEI 04-02, and the requirements of NFPA 805 and in the preparation of this LAR.
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| Page 11
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| Khmhroolen P"hlit- DemAjear Mcfriý+ f'KI(Z K11:DA RnA T 4; D ý+
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| 4.0 COMPLIANCE WITH NFPA 805 REQUIREMENTS 4.1 Fundamental Fire Protection Program and Design Elements The Fundamental Fire Protection Program and Design Elements are established in Chapter 3 of NFPA 805. Section 4.3.1 of NEI 04-02 provides a systematic process for determining the extent to which the pre-transition licensing basis and plant configuration meets these criteria and for identifying the FPP changes that would be necessary for compliance with NFPA 805. NEI 04-02 Appendix B, Section B.1, provides guidance on documenting compliance with the program requirements of NFPA 805 Chapter 3.
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| 4.1.1 Overview of Evaluation Process The comparison of the CNS FPP to the requirements of NFPA 805 Chapter 3 was performed and documented in CNS Calculation NEDC 10-080 entitled "Transition of Fundamental Fire Protection Program and Design Elements". Calculation NEDC 10-080 used the guidance contained in NEI 04-02, Section 4.3.1 and Appendix B, Section B.1 (See Figure 4-1).
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| Each section and subsection of NFPA 805 Chapter 3 was reviewed against the current FPP, as described in Attachment A. Upon completion of the activities associated with the review, the following compliance statements were used:
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| * Complies - For those sections/subsections determined to meet the specific requirements of NFPA 805.
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| " Complies with Clarification - For those sections/subsections determined to meet the requirements of NFPA 805 with clarification.
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| * Complies by previous NRC approval - For those sections/subsections where the specific NFPA 805 Chapter 3 requirements are not met, but previous NRC approval of the configuration exists.
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| " Complies with use of Existing Engineering Equivalency Evaluations (EEEEs) - For those sections/subsections determined to be equivalent to the NFPA 805 Chapter 3 requirements, as documented by engineering analysis.
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| * Submit for NRC Approval - For those sections/subsections for which approval is sought in this LAR submittal in accordance with 10 CFR 50.48(c)(2)(vii). A summary of the bases of acceptability is provided (see Attachment L for details).
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| * Complies with Required Action - Assigned to those NFPA 805 Chapter 3 sections/subsections determined to be met by the CNS FPP after completion of an action, to be completed after submittal of the NFPA 805 LAR.
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| " N/A - No compliance basis is necessary or applicable.
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| In some cases multiple compliance statements have been assigned to a specific NFPA 805 Chapter 3 section/subsection. Where this is the case, each compliance/compliance basis statement clearly references the corresponding requirement of NFPA 805 Chapter 3.
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| Page 12
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| | |
| Np.hrncdki Piihlin Pnw*.r fki.trirt C.JR NFPA ROFR Tr~nnitinn la~nnrt Nebraska Public Po er District rKi.q KiPPA Rn-R Trnncitinn Poninirt Enter In tre Compliance Basin Field In Reference Document Field Docamant anyOpen NOTE 1:
| |
| 7oamantdi n - RefeAenois that Items found ducng Although not included in the submittal to the NRC. the basis for compliance in C ompliance PlaidmeN Addviod (see Note 1) ifictioces nny DColaer demonstrate cornpliance Review should be recorded in the transiton database for reference purposes.
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| NOTE 2:
| |
| Edobng Engineering Equiuelency Evaluations (previously known as Generic Letter 86-10 evaluations, evemptions and deviahions were performed for fire prctection design variances such as fire protection system designs and fire barrier component deviations hmomthe speciic fireprotection Enter In the Compliance Bass Field In ReferenceDocument Field Documentany Open deterministc requirements Section 2.2 7 of NFPA 805 allows eitsbng EEE
| |
| 'Complies WithClarification' provide. pro de n Rtrn s tteme fend daring that dearly demonstates an equivalent level at fire protection compared to in ComplianceStatementField - Details on Clarngicahon D ent Reference Review the determinisborequirements to be tnansitioned. Those EEEEs that demonstrate that a system or feature is rated or compliant li.e.. equivalent level or protection) do not need to be summarized and submitted as part of the LAR.Those EEEEs against Sections 3.1 through 3.7 of NFPA 805 that determine the fire protection system or feature is adequate for the hazard should be summarized inthe LAR.
| |
| Enter provide verbapime erpt fnom -itihde Ch a 3 NOTE 3:
| |
| replie ApproCal bybPrvosNC In theCm ance aals Fie re
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| - YeaL*IniR
| |
| -Apoalcdocum'n:we I-roidDefe. ..nc Docmn References ....
| |
| (Submit.el Field and atctenItems ment Dc found during has PC tAiflurtber achons required" should be addressed prior to submittal to the Peiroslan Review NRC Actone that remain open willbe identfied as "Implementaion Rems" le nd In C m i Anpproval) that *il reference a plant acton tnackangnumber and will demonstrate that approval)Demonstrate Compliance the attibute wtll be in compliance once the action is closed.
| |
| riienn u~sn al y "Emp ..s .....
| |
| RequiredIn provide.
| |
| the Compliance Basis Field 1pride:D InRefen....r e.. oe ue.....p FieldE ytesfuduhg.....
| |
| C c Dei
| |
| ,Eau i'Engeela approvalbyPeiosNC pe r3Revuirea en gu raelens -EESummary of subject of prva ou Document References that -. mRi ny0 se )in , Compliance Statement Field EungineeringEvaluation demonstrate compliance EnterovSabm to-R provide: t Reeene th rvatAtona tl_ o I -I Compliance is I Eneq~ri Furtherco In Compliance Basis Field I ,Refeec n Document..
| |
| Field provide:
| |
| Indeterminate Fun rthat i prnde: - Correchve Actons as Document any Open
| |
| - Items found during F Action Required. (seeNote 3) Urnof Actlonsta be Taken Dcmn~flne Review (se Noe31e~tRfrn Does not meet sprate3 nor is '=er previous approval In ReeecDcmn Document any Open NR prvlEnter'Subm for RC InrOmlde cBss il Field provide"
| |
| *IR Aproa Aptv nCmliance P ' . - Corrcv Actions. a. - items toond daring Choose One is Required -~oSumnr --- o -ujc Coaciv Statement Field Summary of,sujec of,,*apopit Review I I I I . p..
| |
| . . DocumantReterences In Compliance FieldDocment Compliance be achieved Enter Co pes Summary of Md or Action Field provide: Document any Open through a.modother W Required 0.0cr in to m. a dr t - CorrectnveActions. an Items found during action. compliance fiad - Identify Implementation Item appropriate Review and/or Corrective Acton Document References number as appropriate 13 Figure 4 Fundamental Fire Protection Program and Design Elements Transition Process (based on NEI 04-02 Figure 4-2) 5 5 Figure 4-1 depicts the process used during the transition and therefore contains elements (i.e., open items) that represent interim resolutions.
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| Additional detail on the transition of EEEEs is included in Section 4.2.2.
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| Page Page 13
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| | |
| Nebraska Pubhlic Power District C~NS NFPA 805 Transitio~n Repo~rt 4.1.2 Results of the Evaluation Process 4.1.2.1 NFPA 805 Chapter 3 Requirements Met or Previously Approved by the NRC Attachment A contains the NEI 04-02 Table B-I, "Transition of Fundamental Fire Protection Program and Design Elements." This table provides the compliance basis for the requirements in NFPA 805 Chapter 3. Except as identified in Section 4.1.2.3, Attachment A demonstrates that the fire protection program at CNS either:
| |
| " Complies directly with the requirements of NFPA 805 Chapter 3.
| |
| " Complies with clarification with the requirements of NFPA 805 Chapter 3.
| |
| " Complies with a previously NRC approved alternative to NFPA 805 Chapter 3, and therefore the specific requirement of NFPA 805 Chapter 3 is supplanted.
| |
| " Complies through the use of EEEEs which are valid and of appropriate quality.
| |
| " Complies upon the completion of a required action. Implementation items are identified for those sections and/or subsections determined to meet the specific requirements of NFPA 805 after the completion of a modification or other action, such as a procedure change or a work request. (See Attachment S for details).
| |
| " None - No compliance basis is necessary or applicable.
| |
| 4.1.2.2 NFPA 805 Chapter 3 Requirements Requiring Clarification of Prior NRC Approval NPFA 805 Section 3.1 states in part, "Previously approved alternatives from the fundamental protection program attributes of this chapter by the AHJ take precedence over the requirements contained herein." In some cases prior NRC approval of an NFPA 805 Chapter 3 program attribute may be unclear. NPPD requests that the NRC concur with their finding of prior approval for the following sections of NFPA 805 Chapter 3:
| |
| 0 None.
| |
| 4.1.2.3 NFPA 805 Chapter 3 Requirements Not Previously Approved by NRC The following sections of NFPA 805 Chapter 3 are not specifically met nor do previous NRC approvals of alternatives exist:
| |
| 0 3.3.1.2(1) - Approval is requested for the use of commercially available products which utilize small quantities of non-treated wood as an integral part of a finished product (e.g.,
| |
| tools, janitorial supplies, special fixtures, measurement and test equipment, and office type furniture).
| |
| 0 3.3.5.1 - Approval is requested for certain wiring configurations above suspended ceilings that is not approved for plenum use, and not installed in conduit.
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| 0 3.3.5.2 - Approval is requested for the use of plastic conduit in lieu of metallic raceways when installed embedded in concrete or below grade.
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| * 3.3.7.2 - Approval is requested for the configuration of the bulk storage hydrogen gas cylinders, which have their long axis pointing toward the Intake Structure.
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| * 3.5.3 (NFPA 20-1999, Section 7-5.2.4) - Approval is requested for the ability to stop the electric fire pump remotely from the Control Room.
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| Page 14
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| | |
| Nphrq-,k;; Pijhlir Pnwpr niqtrirt NFPA 805 Transition Renort N..br.....P.bli P.w.r..i..ri......NS
| |
| * 3.6.1 (NFPA 14-1974, Sections 322, 442, 625, and 671) - Approval is requested for the use of lengths of hose at hose stations greater than lengths allowed by NFPA 14, standpipe outlet pressures exceeding 100 psi, the lack of approved extra heavy flanged pattern valves where the system pressure exceeds 175 psi, and the lack of water flow alarms on standpipe risers.
| |
| 0 3.7 (NFPA 10-1975, Section 3-3) - Approval is requested for the placement of Class B fire extinguishers with respect to travel distance requirements for Class B hazards (flammable liquids) that are not of appreciable depth.
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| 0 3.10.5 - Approval is requested for the lack of local keyed abort switches interlocked with the Diesel Generator (DG) CO 2 systems.
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| * 3.10.7 - Approval is requested for the lack of an odorizer on the DG CO 2 system.
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| The specific deviation and a discussion of how the alternative satisfies 10 CFR 50.48(c)(2)(vii) requirements are provided in Attachment L. NPPD requests NRC approval of these performance-based methods.
| |
| 4.1.3 Definition of Power Block and Plant Where used in NFPA 805 Chapter 3 the terms "Power Block" and "Plant" refer to structures that contain equipment required for nuclear plant operations, such as Reactor Building, Control Building, Turbine Generator Building, Diesel Generator Building, Radwaste Buildings, Intake Structure, and other structures (or areas) that are identified in the facility's pre-transition licensing basis.
| |
| These structures/areas are listed in Attachment I and define the "Power Block" and "Plant".
| |
| 4.2 Nuclear Safety Performance Criteria The Nuclear Safety Performance Criteria are established in Section 1.5 of NFPA 805.
| |
| Chapter 4 of NFPA 805 provides the methodology to determine the fire protection systems and features required to achieve the performance criteria outlined in Section 1.5. Section 4.3.2 of NEI 04-02 provides a systematic process for determining the extent to which the pre-transition licensing basis meets these criteria and for identifying any necessary FPP changes. NEI 04-02, Section B.2 provides guidance on documenting the transition of Nuclear Safety Capability Assessment (NSCA) Methodology and the Fire Area compliance strategies.
| |
| 4.2.1 Nuclear Safety Capability Assessment Methodology The NSCA Methodology review consists of four processes:
| |
| " Establishing compliance with NFPA 805 Section 2.4.2
| |
| " Establishing the Safe and Stable Conditions for the Plant
| |
| * Establishing Recovery Actions
| |
| " Evaluating Multiple Spurious Operations (MSO)
| |
| The methodology for demonstrating reasonable assurance that a fire during non-power operation (NPO) modes will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition is an additional requirement of 10 CFR 50.48(c) and is addressed in Section 4.3.
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| Page 15
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| | |
| K1,=krncL-n P"Win Pnwnr nia+rit-+ ('KIQ KIPPA SZOR Trnneifinn Pm n t:! L 4.2.1.1 Compliance with NFPA 805 Section 2.4.2 Overview of Process NFPA 805 Section 2.4.2, "Nuclear Safety Capability Assessment" states:
| |
| The purpose of this section is to define the methodology for performing a nuclear safety capability assessment. The following steps shall be performed:
| |
| (1) Selection of systems and equipment and their interrelationships necessary to achieve the nuclear safety performance criteria in Chapter 1 (2) Selection of cables necessary to achieve the nuclear safety performance criteria in Chapter 1 (3) Identification of the location of nuclear safety equipment and cables (4) Assessment of the ability to achieve the nuclear safety performance criteria given a fire in each fire area The NSCA methodology review evaluated the existing post-fire safe shutdown analysis (SSA) methodology against the guidance for transitioning to NFPA 805 provided in NEI 00-01, Revision 1 (Ref. 54), Chapter 3, "Deterministic Methodology," as discussed in Appendix B-2 of NEI 04-02. The methodology is depicted in Figure 4-2 and consisted of the following activities:
| |
| " Each specific section of NFPA 805 2.4.2 was correlated to the corresponding section of Chapter 3 of NEI 00-01 Revision 1. Based upon the content of the NEI 00-01 methodology statements, a determination was made of the applicability of the section to the station.
| |
| " The plant-specific methodology was compared to applicable sections of NEI 00-01 and one of the following alignment statements and its associated basis were assigned to the section:
| |
| " Aligns o Aligns with intent o Not in Alignment o Not in Alignment, but Prior NRC Approval o Not in Alignment, but no adverse consequences
| |
| * For those sections that do not align, an assessment was made to determine if the failure to maintain strict alignment with the guidance in NEI 00-01 could have adverse consequences. Since NEI 00-01 is a guidance document, portions of its text could be interpreted as 'good practice' or intended as an example of an efficient means of performing the analyses. If the section has no adverse consequences, these sections of NEI 00-01 can be dispositioned without further review.
| |
| The comparison of the CNS existing post-fire SSA methodology to NEI 00-01 Chapter 3 (NEI 04-02 Table B-2) for transitioning to NFPA 805 was performed and documented in CNS Calculation NEDC 10-039, Revision 1, "Nuclear Safety Performance Analysis Methodology Review."
| |
| Results from Evaluation Process The method used to perform the SSA with respect to selection of systems and equipment, selection of cables, and identification of the location of equipment and cables, either meets the Page 16
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| | |
| KI k I%_1JI L- D k1i
| |
| * UIJ I D
| |
| FVVII r1l; + ;
| |
| LJl ll 1.'
| |
| fIKIQ KICDA i~l I'11 F,,
| |
| ana U.J
| |
| -rI ;+; D 4 ICIIIILIIJII iCJIJUIL NRC endorsed guidance for transitioning to NFPA 805 directly or met the intent of the endorsed guidance with adequate justification as documented in Attachment B.
| |
| It is important to note that the NRC, through the issuance of RG 1.205, endorsed Chapter 3 of industry guidance document NEI 00-01 as one acceptable approach to circuit analysis for a plant transitioning their FPP to NFPA 805. This endorsement was made initially on revision 1 and subsequently revision 2 of the NEI guidance document. To ensure that changes to the text in Chapter 3 that did occur between revisions did not alter the conclusions reached during the review, a gap analysis was performed in CNS Calculation NEDC 10-039, "Nuclear Safety Performance Analysis Methodology review EPM Report R1906-004-001." There were no additional justifications to address the impact of changes due to the gap analysis that required inclusion in Attachment B.
| |
| 3"p3 (St*v 4 Figure 4 Summary of Nuclear Safety Methodology Review Process (FAQ 07-0039) 4.2.1.2 Safe and Stable Conditions for the Plant Overview of Process The nuclear safety goals, objectives and performance criteria of NFPA 805 allow more flexibility than the previous deterministic programs based on 10 CFR 50 Appendix R and NUREG 0800, Section 9.5-1 (and NEI 00-01, Chapter 3) since NFPA 805 only requires the licensee to maintain the fuel in a safe and stable condition rather than achieve and maintain cold shutdown.
| |
| NFPA 805, Section 1.6.56, defines Safe and Stable Conditions as follows:
| |
| For fuel in the reactor vessel, head on and tensioned, safe and stable conditions are defined as the ability to maintain Keff <0.99, with a reactor coolant temperature at or below the requirements for hot shutdown for a boiling water reactor and hot standby for Page 17
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| U=Krnolen D"klif- DmAimr niofriý+
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| KIhrca fictir
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| .JOLDih~,Lt'.I*'.Jfi O~~~
| |
| r'KIQ KIP D-A Af)r, Trnncifinn Pý ^
| |
| '.fJ*a~w(K~tl~fJ II JVL. Al %~Z
| |
| .t/J rn~+rn OUIOLtJ ~rrr~I II~~'V a pressurized water reactor. For all other configurations, safe and stable conditions are defined as maintaining Keff <0.99 and fuel coolant temperature below boiling.
| |
| The nuclear safety goal of NFPA 805 requires "...reasonable assurance that a fire during any operational mode and plant configuration will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition" without a specific reference to a mission time or event coping duration.
| |
| For the plant to be in a safe and stable condition, it may not be necessary to perform a transition to cold shutdown as currently required under 10 CFR 50, Appendix R. Therefore, the unit may remain at or below the temperature defined by a hot shutdown plant operating state for the event.
| |
| Results Based on CNS Calculation NEDC 11-019, "Nuclear Safety Capability Assessment" (NSCA), the proposed NFPA 805 licensing basis for CNS is to ensure the plant can achieve and maintain the fuel in a "safe and stable" condition assuming a fire occurs during Mode 1 (Power Operation),
| |
| Mode 2 (Startup), or Mode 3 (Hot Shutdown). The Mode 3 applicability for the analysis is defined as being up to the point at which the direct current (DC) breaker for the shutdown cooling suction valve is un-locked and closed, at which point spurious operation of these high/low pressure interface valves can occur due to fire damage to the valve control circuitry.
| |
| As part of the transition to NFPA 805, each fire area was evaluated for maintaining safe and stable hot shutdown conditions for a 24 hour coping period through either a "Deterministic Approach" (NFPA 805 Section 4.2.3) or "Performance Based Approach" (NFPA 805 Section 4.2.4). During the 24 hour coping period, the necessary systems and equipment have been evaluated to ensure their capability to achieve a safe and stable fuel condition as described within NFPA Section 1.3 and 1.6.56.
| |
| For the most limiting fire scenarios, the NSCA documents the availability of long term decay heat removal provided by water from the torus, with temperature maintained by the Residual Heat Removal (RHR) system operating in the suppression pool cooling mode. Initiation of the RHR system in the suppression pool cooling mode does not imply that the plant would then proceed all the way to cold shutdown. Following stabilization at hot shutdown, a long term strategy for reactivity control, decay heat removal, and inventory/pressure control would be determined based on the extent of equipment damage. If an assessment of the post-fire conditions indicated that placing RHR in the shutdown cooling mode would be advisable, then repair activities would commence, if necessary, in a safe and controlled manner to restore plant equipment necessary for reactor cooldown.
| |
| The mitigation strategies, damage assessment procedures, and repair of equipment to maintain safe and stable conditions are to be re-established within the scope of the NFPA 805 program.
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| Based on the initial achievement of safe and stable conditions in conjunction with the availability of procedural actions, repair of equipment, and initial coping period, recovery of NSCA equipment that may be required beyond 24 hours is qualitatively deemed to have no significant measurable contribution to risk based on the following factors:
| |
| * Offsite resources (e.g., equipment, power, vehicles) that could be made available as backups to primary methods of prevention and mitigation.
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| " The expertise of the Technical Support Center and Emergency Operations Facility staff that would be in place and additional expertise that could be made available by phone or transported to these facilities.
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| Page 18
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| | |
| r'KICZ KIPDA SlOr Trnneifi^n Dn ^rf K1,nkrncL-n 13nuinr r)io+riý+
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| k~e~racL'aDi hlir ~MQMID Pri~rfli,+rr~i £~' Trnc~~irn Dnbe
| |
| " Existing Emergency Operating Procedures and other emergency response procedures in place to assist the plant operating staff with an option to proceed and implement actions and/or repairs for the plant to transition to, and enter, Mode 4 (Cold Shutdown), if necessary.
| |
| " Additional procedures that can be written and reviewed to perform alignments and equipment usage that may be beneficial and are not part of current plant practices or training. Such procedures and equipment usage can cover such a wide spectrum of possibilities that it is judged not useful to develop all possible contingencies at this time.
| |
| The above strategies with supporting procedures provides reasonable assurance that the fuel will be maintained in a safe and stable condition following a fire. The revision to existing procedural guidance is to be completed as part of implementation activities (Attachment S, Item S-3.3). Any changes that need to be made during implementation will be resolved using the change evaluation process.
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| Demonstration of the Nuclear Safety Performance Criteria for safe and stable conditions at CNS was performed in two analyses.
| |
| " At-Power analysis, Modes 1-3. This analysis is discussed in Section 4.2.4.
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| " Non-Power analysis, which includes portions of Mode 3, Mode 4 and Mode 5. This analysis is discussed in Section 4.3.
| |
| 4.2.1.3 Establishing Recovery Actions Overview of Process NEI 04-02 and RG 1.205 suggest that a licensee submit a summary of its approach for addressing the transition of operator manual actions (OMA) as recovery actions in the LAR (Regulatory Position 2.2.1 and NEI 04-02, Section 4.6). As a minimum, NEI 04-02 suggests that the assumptions, criteria, methodology, and overall results be included for the NRC to determine the acceptability of the licensee's methodology.
| |
| The discussion below provides the methodology used to transition pre-transition OMA and to determine the population of post-transition recovery actions. This process is based on FAQ 07-0030 (Ref. 55) and consists of the following steps:
| |
| " Step 1: Clearly define the primary control station(s) and determine which pre-transition OMAs are taken at primary control station(s) (Activities that occur in the Control Room are not considered pre-transition OMA). Activities that take place at primary control station(s) or in the Control Room are not recovery actions, by definition.
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| * Step 2: Determine the population of recovery actions that are required to resolve variances from deterministic requirements (VFDR) (to meet the risk acceptance criteria or maintain a sufficient level of defense-in-depth).
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| * Step 3: Evaluate the additional risk presented by the use of recovery actions required to demonstrate the availability of a success path.
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| * Step 4: Evaluate the feasibility of the recovery actions.
| |
| " Step 5: Evaluate the reliability of the recovery actions.
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| Page 19
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| | |
| Nehrq--,kq Puhlir Pnwpr Di-,trirt MR NFPA 9013 Trnn.-,itinn Rpnort Results The review results are documented in CNS Calculation NEDC 11-020. Refer to Attachment G for the detailed evaluation process and summary of the results from the process.
| |
| 4.2.1.4 Evaluation of Multiple Spurious Operations Overview of Process NEI 04-02 suggests that a licensee submit a summary of its approach for addressing potential fire-induced MSOs for NRC review and approval. As a minimum, NEI 04-02 suggests that the summary contain sufficient information relevant to methods, tools, and acceptance criteria used to enable the NRC to determine the acceptability of the licensee's methodology. The methodology utilized to address MSOs for CNS is summarized below.
| |
| As part of the NFPA 805 transition project, a review and evaluation of CNS susceptibility to fire-induced MSOs was performed. The process was conducted in accordance with NEI 04-02 and RG 1.205, as supplemented by FAQ 07-0038 Revision 3 (Ref. 56). The Boiling Water Reactor (BWR) Generic MSO list dated May 2009 was utilized.
| |
| The approach outlined in Figure 4-3 (based on Figure XX from FAQ 07-0038) is one acceptable method to address fire-induced MSOs. This method used insights from the Fire PRA developed in support of transition to NFPA 805 and consists of the following:
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| " Identifying potential MSOs of concern.
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| " Conducting an expert panel to assess plant specific vulnerabilities (e.g., per NEI 00-01, Rev. 2 Section F.4.1).
| |
| " Updating the Fire PRA model and NSCA to include the MSOs of concern.
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| " Evaluating for NFPA 805 Compliance.
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| * Documenting Results.
| |
| This process is intended to support the transition to a new licensing basis. Post-transition changes will use the RI-PB change process. The post-transition change process for the assessment of a specific MSO is a simplified version of this process, and does not need the level of detail shown in the following section (e.g., An expert panel may not be necessary to identify and assess a new potential MSO. Identification of new potential MSOs may be part of the plant change review process and/or inspection process).
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| Page 20
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| Nebraska Public Power District CNS NFPA 805 Transition Renort Identify Potential MSOs of Concern
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| / SSA Step 1
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| * Generic List of MSOs l Self Assessments
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| * PRA Insights
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| * Operating Experience Expert Panel Step 2 Identify and Document MSOs of Concern Update PRA model & NSCA (as appropriate) to include MSOs of concern Step 3
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| * ID equipment
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| * ID logical relationships
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| * ID cables
| |
| * ID cable routing valuate for NFPA 805 N Step 4 Comoliance Pursue other resolution options Compliant with NFPA 8057 Yes Step 5
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| * Document Results Figure 4 Multiple Spurious Operations - Transition Resolution Process (Based on FAQ 07-0038)
| |
| Results Refer to Attachment F for the process used by CNS and the results from the process.
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| 4.2.2 Existing Engineering Equivalency Evaluation Transition Overview of Evaluation Process The EEEEs that support compliance with NFPA 805 Chapter 3 or Chapter 4 (both those that existed prior to the transition and those that were created during the transition) were reviewed using the methodology contained in NEI 04-02. The methodology for performing the EEEE review included the following determinations:
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| . The EEEE is not based solely on quantitative risk evaluations, Page 21
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| Mahrnck-n P"Win Pnimar Metrir-f ('M.q MF=PA POR Trnneifinn Po nrf
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| * The EEEE is an appropriate use of an engineering equivalency evaluation,
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| * The EEEE is of appropriate quality,
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| * The standard license condition is met,
| |
| " The EEEE is technically adequate,
| |
| * The EEEE reflects the plant as-built condition, and
| |
| " The basis for acceptability of the EEEE remains valid In accordance with the guidance in RG 1.205, Regulatory Position 2.3.2, NEI 04-02, as clarified by FAQ 08-0054, "Demonstrating Compliance with Chapter 4 of NFPA 805" (Ref. 57), EEEEs that demonstrate that a fire protection system or feature is "adequate for the hazard" are summarized in the LAR as follows:
| |
| " If not requesting specific approval for "adequate for the hazard" EEEEs, then the EEEE was referenced where required and a brief description of the evaluated condition was provided.
| |
| " If requesting specific NRC approval for "adequate for the hazard" EEEEs, then EEEE was referenced where required to demonstrate compliance and was included in Attachment L for NRC review and approval.
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| In all cases, the reliance on EEEEs to demonstrate compliance with NFPA 805 requirements was documented in the LAR.
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| Results The review results for EEEEs are documented by fire area in NEDC 12-008.
| |
| In accordance with the guidance in RG 1.205, Regulatory Position 2.3.2, and NEI 04-02, as clarified by FAQ 08-0054, Revision 1, EEEEs used to demonstrate compliance with Chapters 3 and 4 of NFPA 805 are referenced in the Attachments A and C as appropriate. In addition, none of the transitioning EEEEs require NRC approval.
| |
| 4.2.3 Licensing Action Transition Overview of Evaluation Process The existing licensing actions (exemption requests / safety evaluations) review was performed in accordance with NEI 04-02. The methodology for the licensing action review included the following:
| |
| " Determination of the bases for acceptability of the licensing action.
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| " Determination that these bases for acceptability are still valid and required for NFPA 805.
| |
| Results Attachment K contains the detailed results of the Licensing Action Review.
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| The following licensing actions will be transitioned into the NFPA 805 fire protection program as previously approved (NFPA 805, Section 2.2.7). These licensing actions are considered compliant under 10 CFR 50.48(c).
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| * None Page 22
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report The following licensing actions are no longer necessary and will not be transitioned into the NFPA 805 fire protection program (see Section 2.2):
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| " Exemption for lack of twenty foot separation between redundant Service Water Pumps in the Intake Structure.
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| This is no longer required for transition because a RI-PB analysis (NFPA 805, 4.2.4.2 -
| |
| Fire Risk Evaluation) was performed, and evaluated the condition as acceptable.
| |
| " Exemption for lack of twenty foot separation free of intervening combustibles or one-hour barriers between redundant trains in the Cable Spreading Room.
| |
| This exemption is no longer required for transition because a RI-PB analysis (NFPA 805, 4.2.4.2 - Fire Risk Evaluation) was performed, and evaluated the condition as acceptable.
| |
| " Exemption for lack of twenty foot separation or one-hour barriers between redundant trains in the Cable Expansion Room.
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| This exemption is no longer required for transition because a RI-PB analysis (NFPA 805, 4.2.4.2 - Fire Risk Evaluation) was performed, and evaluated the condition as acceptable.
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| * Exemption from the requirement for one-hour rated fire barriers for redundant conduits and area wide automatic suppression system in the Reactor Building northeast corner, 903'-6" Elevation.
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| This exemption is no longer required for transition because a RI-PB analysis (NFPA 805, 4.2.4.2 - Fire Risk Evaluation) was performed, and evaluated the condition as acceptable.
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| " Exemption from the requirement for an automatic suppression system in the Control Building Basement, 903'-6" Elevation.
| |
| This exemption is no longer required for transition because a RI-PB analysis (NFPA 805, 4.2.4.2 - Fire Risk Evaluation) was performed, and evaluated the condition as acceptable.
| |
| " Exemption from a fixed fire suppression system in the Auxiliary Relay Room.
| |
| This exemption is no longer required for transition because a RI-PB analysis (NFPA 805, 4.2.4.2 - Fire Risk Evaluation) was performed, and evaluated the condition as acceptable.
| |
| " Exemption from a fixed fire suppression system in the Control Room.
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| This exemption is no longer required for transition because a RI-PB analysis (NFPA 805, 4.2.4.2 - Fire Risk Evaluation) was performed, and evaluated the condition as acceptable.
| |
| " Exemption from the requirement of a three-hour fire barrier, or twenty feet of separation free of intervening combustibles combined with automatic suppression and detection in the 931' Elevation of the Reactor Building.
| |
| This exemption is no longer required for transition because a RI-PB analysis (NFPA 805, 4.2.4.2 - Fire Risk Evaluation) was performed, and evaluated the condition as acceptable.
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| Page 23
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| | |
| KlahrneL-n P"Wit- Pemmar Mcfrir-f ('KIQ KMDA %QA5 TrnncoifirnnD I ^rrf Il,-B F-J*- I\ . I L-.JIl*I *.JL %JIl%,JI*I I f* L JI,'J 1 I II I 0lJU Exemption from the requirement of a three-hour fire barrier, or twenty feet of separation free of intervening combustibles combined with automatic suppression and detection, and lack of alternate shutdown capability independent of the area in the 903'-6" Elevation of the Reactor Building (excluding the northeast corner).
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| This exemption is no longer required for transition because a RI-PB analysis (NFPA 805, 4.2.4.2 - Fire Risk Evaluation) was performed, and evaluated the condition as acceptable.
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| * Exemption from the requirement of a three-hour fire barrier, or twenty feet of separation free of intervening combustibles combined with automatic suppression and detection, and lack of alternate shutdown capability independent of the area in the 859' and 881' Elevations of the Reactor Building.
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| This exemption is no longer required for transition because a RI-PB analysis (NFPA 805, 4.2.4.2 - Fire Risk Evaluation) was performed, and evaluated the condition as acceptable.
| |
| Since the exemptions are no longer necessary, in accordance with the requirements of 10 CFR 50.48(c)(3)(i), NPPD requests that the exemptions listed in Attachment K be rescinded as part of the LAR process. It is NPPDs understanding that implicit in superseding the current license condition, all prior Fire Protection Program Safety Evaluation Reports and commitments will be superseded in their entirety. See Attachment 0, Orders and Exemptions.
| |
| 4.2.4 Fire Area Transition Overview of Evaluation Process The Fire Area Transition (NEI 04-02 Table B-3) was performed using the methodology contained in NEI 04-02 and FAQ 08-0054, Revision 1. The methodology for performing the Fire Area Transition, depicted in Figure 4-4, is outlined as follows:
| |
| Step 1 - Assembled documentation. Gathered industry and plant-specific fire area analyses and licensing basis documents.
| |
| Step 2 - Documented fulfillment of nuclear safety performance criteria.
| |
| " Assessed accomplishment of nuclear safety performance goals. Documented the method of accomplishment, in summary level form, for each fire area.
| |
| * Documented evaluation of effects of fire suppression activities. Documented the evaluation of the effects of fire suppression activities on the ability to achieve the nuclear safety performance criteria.
| |
| * Performed licensing action reviews. Performed a review of the licensing aspects of the selected fire area and document the results of the review. See Section 4.2.3.
| |
| * Performed existing engineering equivalency evaluation reviews. Performed a review of existing engineering equivalency evaluations (or create new evaluations) documenting the basis for acceptability. See Section 4.2.2.
| |
| " Pre-transition OMA reviews. Performed a review of pre-transition OMAs to determine those actions taking place outside of the Control Room or outside of the primary control station(s). See Section 4.2.1.3.
| |
| Step 3 - VFDR Identification and characterization and resolution considerations. Identified variances from the deterministic requirements of NFPA 805, Section 4.2.3. Documented Page 24
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| | |
| ('KICZ KIPDA POR Trnneifinn P= r%
| |
| KinkrneLro ID"Wit- Pnimmr Mc+rif-f kr~I~ Pih~~ ~fli~rir4 (kI~kIIA %AI T~nci~i~n nnK k variances as either a separation issue or a degraded fire protection system or feature.
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| Developed VFDR problem statements to support resolution.
| |
| Step 4 - Performance-Based evaluations (Fire Risk Evaluations). See Section 4.5.2 for additional information.
| |
| Step 5 - Final Disposition.
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| * Documented final disposition of the VFDR in Attachment C (NEI 04-02 Table B-3).
| |
| * For recovery action compliance strategies, ensured the manual action feasibility analysis of the required recovery actions was completed. Note: if a recovery action cannot meet the feasibility requirements established per NEI 04-02, then alternate means of compliance were considered.
| |
| * Documented the post transition NFPA 805 Chapter 4 compliance basis.
| |
| Step 6 - Documented required fire protection systems and features. Reviewed the NFPA 805 Section 4.2.3 compliance strategies (including fire area licensing actions and engineering evaluations) and the NFPA 805 Section 4.2.4 compliance strategies (including simplifying deterministic assumptions) to determine the scope of fire protection systems and features
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| 'required' by NFPA 805 Chapter 4. The 'required' fire protection systems and features are subject to the applicable requirements of NFPA 805 Chapter 3.
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| Page 25
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| | |
| Nebraska Public Power District ('Nq NFPA 809 Transition Trnn-dtinn Renort Rpnnrt Nebraska Public Power District CNS NFPA 805 (B-3 Table)
| |
| Figure 4 Summary of Fire Area Review
| |
| [Based on FAQ 08-0054 Revision 1]
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| Page 26
| |
| | |
| NohrnQk-n P"Wir Pnwor nictrinf rImJq KIPPA Rnfl' Trtanc~ifirn Pdanrfr Results of the Evaluation Process Attachment C contains the results of the Fire Area Transition review (NEI 04-02 Table B-3). On a fire area basis, Attachment C summarizes compliance with Chapter 4 of NFPA 805.
| |
| Attachment C, Table B-3 includes the following summary level information for each fire area:
| |
| " Regulatory Basis - NFPA 805 post-transition regulatory bases are included.
| |
| " Performance Goal Summary - An overview of the method of accomplishment of each of the performance criteria in NFPA 805 Section 1.5 is provided.
| |
| * Reference Documents - Specific references to Nuclear Safety Capability Assessment Documents are provided.
| |
| * Licensing Actions - Specific references to exemption requests that will remain part of the post-transition licensing basis are provided, when applicable. A brief description of the condition and the basis for acceptability of the licensing action is provided.
| |
| * EEEE - Specific references to EEEEs that rely on determinations of "adequate for the hazard" that will remain part of the post-transition licensing basis. A brief description of the condition and the basis for acceptability is provided.
| |
| " VFDR - Specific variances from the deterministic requirements of NFPA 805 Section 4.2.3 are provided, when applicable. Refer to Section 4.5.2 for a discussion of the performance-based approach.
| |
| 4.3 Non-Power Operational Modes 4.3.1 Overview of Evaluation Process CNS implemented the process outlined in NEI 04-02 and FAQ 07-0040, "Clarification on Non-Power Operations" (Ref. 58). The goal (as depicted in Figure 4-6) is to ensure that contingency plans are established when the plant is in an NPO mode where the risk is intrinsically high.
| |
| During low risk periods, normal risk management controls and fire prevention/protection processes and procedures will be utilized.
| |
| The process to demonstrate that the nuclear safety performance criteria are met during NPO modes involves the following steps:
| |
| * Review the existing Outage Management Processes.
| |
| * Identify Equipment/Cables:
| |
| o Review plant systems to determine success paths that support each of the defense-in-depth Key Safety Functions (KSFs), and
| |
| " Identify cables required for the selected components and determine their routing.
| |
| * Perform Fire Area Assessments (identify pinch points - plant locations where a single fire may damage all success paths of a KSF).
| |
| * Manage pinch-points associated with fire-induced vulnerabilities during the outage.
| |
| The process is depicted in Figures 4-5 and 4-6. The results are presented in Section 4.3.2.
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| Page 27
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| | |
| Nebraska Pubhlic Power flktrirf CrJ~q KFPA $AnqTr+/-nnczifinn Ppnnirt Figure 4-5 Review KSF, Equipment and Cables, and Identify Pinch Points Page 28
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| | |
| C'KMC KIC7A SRALZT ýncoifinn D KI
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| ~U.k Ic ýIen D"kli^ D^
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| na mlllI Jvu
| |
| ýr Mi f i +
| |
| UIL Q tl1/4'.. I r' fl. I l ci', ~JV ^nr+
| |
| Higher Risk Evolution as Defined by Plant Specific Outage Risk Criteria for example
| |
| : 1) Time to Boil
| |
| : 2) Reactor Coolant System and Fuel Pool Inventory
| |
| : 3) Decay Heat Removal Implement Contingency Plan for Specific KSF Figure 4-6 Manage Pinch Points Page 29
| |
| | |
| Klahrinckm P"hlir- PfuAmr niefrif-f t'KIQ KII=DA Af)r, Trnneifinn Pn ^
| |
| ~JId~Sda4fllJ~Vt*
| |
| M li~rr~
| |
| r!ek lPihi,.Pnic~
| |
| ,L,*L .S'M IMID II lfl'. fl Tac~ti~n II01I~tt.I Pr~
| |
| I*IJ.V 4.3.2 Results of the Evaluation Process Based on FAQ 07-0040 (Revision 4), the Plant Operating States (POS) considered for equipment and cable selection are defined in Calculation NEDC 11-003 "Non-Power Operation Modes Transition Review". Components were identified to support the KSFs of Inventory Control, Decay Heat Removal Capability, and associated support functions (process cooling and electrical power). A model was developed in the NFPA 805 Analysis Database (Genesis Solution Suite, SAFE Module). Equipment was logically tied to the supported KSF. Power supplies, interlocks, and supporting equipment were logically tied to their parent component.
| |
| For those components which had not been previously analyzed in support of the at-power analysis or whose functional requirements may have been different for the non-power analysis, cable selection was performed in accordance with approved project procedures. Cables necessary to support the selected function of a component were selected and analyzed for fire impact.
| |
| CNS Calculation NEDC 11-003 contains the fire area assessment, the identified pinch points, and general recommendations for administrative controls to reduce that fire risk as well as a proposed strategy for recovering the KSF should a fire occur. In accordance with FAQ 07-0040, any area experiencing fire damage which eliminates all success paths for a KSF (without recovery actions outside the Control Room) is considered a pinch point. Fire modeling was not used to eliminate any fire area from being a pinch point.
| |
| The list of generic recommendations specified in NEDC 11-003 considers the following actions from FAQ 07-0040:
| |
| * Prohibition or limitation of hot work in fire areas during periods of increased vulnerability
| |
| * Verification of operable detection and/or suppression in the vulnerable areas
| |
| * Prohibition or limitation of combustible materials in fire areas during periods of increased vulnerability
| |
| * Use of plant configuration changes (e.g., removing power from equipment once it is placed in its desired position)
| |
| " Provision of additional fire patrols at periodic intervals or other appropriate compensatory measures (such as surveillance cameras) during increased vulnerability
| |
| " Use of recovery actions to mitigate potential losses of key safety functions
| |
| " Identification and monitoring in-situ ignition sources for "fire precursors" (e.g., equipment temperatures)
| |
| * Rescheduling of work to a period with lower risk or higher defense-in-depth Refer to Attachment D for additional details. Based on consideration of the vulnerable areas and incorporation of generic recommendations from FAQ 07-0040 into appropriate plant procedures and practices, prior to implementation of NFPA 805 (See Implementation Item S-3.4 of Attachment S, Table S-3), the performance goals (KSFs) for Non-Power Operations will be fulfilled and the requirements of NFPA 805 will be met.
| |
| 4.4 Radioactive Release Performance Criteria 4.4.1 Overview of Evaluation Process The review of the FPP against NFPA 805 requirements for fire suppression related radioactive release was performed using the methodology contained in NEI 04-02 and subsequent Page 30
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| K1=hrncL-n P"hlit- DmAmr niefrL-+
| |
| kIhrcIa ihlp nu~rfictrr4(MQ tL'.i
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| ('KI(Z KIP7DA Af1r, Trnnýifinn Pn ^rf
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| ~.J*~
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| 'JtA*SA*fJ~lJJV NIID M*UMCI l ~
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| .fJCIIOTnn~+r~
| |
| IILLJ ~~~rr I*~'V guidance provided in NFPA 805 Task Force FAQ 09-0056 (Ref. 59). The methodology consisted of the following:
| |
| * A review to "screen-out" fire zones based on the lack of potential for contaminated materials during all plant operating modes, including full power and non-power conditions. The screening process considered input from Radiation Protection personnel and review of CNS pre-fire plans. The evaluation focused on radioactive release to any unrestricted area due to fire fighting activities only; radioactive release due to potential fuel cladding damage was not evaluated. The nuclear safety goal, nuclear safety objectives, and nuclear safety performance criteria specified in NFPA 805 require the prevention of fuel cladding damage. As such, radiological release due to fuel damage does not require a separate examination since no such damage is assumed to occur without violating the basic requirements of NFPA 805.
| |
| " A review of pre-fire plans and fire brigade training materials to identify FPP elements (e.g., systems / components / procedural control actions / flow paths, etc.) that are being credited to meet the radioactive release goals, objectives, and performance criteria during all plant operating modes, including full power and non-power conditions.
| |
| " A review of engineering controls to ensure containment of gaseous and liquid effluents (e.g., smoke and fire fighting agents). This review included all plant operating modes (including full power and non-power conditions). Otherwise, a bounding analysis, quantitative analysis, or other analysis that demonstrates that the limitations for instantaneous release of radioactive effluents specified in the CNS Technical Specifications are met was provided.
| |
| 4.4.2 Results of the Evaluation Process CNS Calculation NEDC 10-062, "NFPA 805 Radioactive Release Review," details the results of the screening process and review of pre-fire plans, fire brigade training materials, and engineering controls.
| |
| The radioactive release review determined the FPP will be compliant with the requirements of NFPA 805 and the guidance in NEI 04-02 and RG 1.205 upon completion of the implementation items identified in Attachment S.
| |
| The site specific review of the direct effects of fire suppression activities on radioactive release is summarized in Attachment E.
| |
| 4.5 Fire PRA and Performance-Based Approaches RI-PB evaluations are an integral element of an NFPA 805 fire protection program. Key parts of RI-PB evaluations include:
| |
| * A Fire PRA (discussed in Section 4.5.1 and Attachments V and W).
| |
| * NFPA 805 Performance-Based Approaches (discussed in Section 4.5.2).
| |
| 4.5.1 Fire PRA Development and Assessment In accordance with the guidance in RG 1.205, a Fire PRA model was developed for CNS in compliance with the requirements of Part 4 "Internal Fires at Power Probabilistic Risk Assessment Requirements," of the American Society of Mechanical Engineers (ASME) and American Nuclear Society (ANS) combined PRA Standard, ASME/ANS RA-Sa 2009, "Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Application" (Ref. 60), (hereafter referred to as Fire PRA Standard). CNS conducted a Page 31
| |
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| hJ=KrncL-n D"Kliý 1_)nAi=r Mcfriý+ ('KV_' KIPDA Af)J; Trnneifinn P,= rrf N IlrI La I ,,hlr.
| |
| II, t lV I trir ('kml~lPI M I * ,,DA I IT Ic IITInn i\ h peer review by independent industry analysts in accordance with RG 1.200 (Ref. 61), prior to a risk-informed submittal. The peer review validated the fire risk assessment model used as the analytical tool to perform Fire Risk Evaluations during the transition process.
| |
| Section 4.5.1.1 describes the Internal Events PRA model. Section 4.5.1.2 describes the Fire PRA model. Section 4.5.1.3 describes the results and resolution of the peer review of the Fire PRA, and Section 4.5.1.4 describes insights gained from the Fire PRA.
| |
| 4.5.1.1 Internal Events PRA The CNS base Internal Events PRA (CNS PRA Model 2007TM-R3) was the basis for the Fire PRA.
| |
| The CNS Internal Events PRA has undergone a self-assessment by a team of knowledgeable CNS PRA personnel and consultants. In addition, an independent peer review of the CNS Internal Events PRA was completed. The peer review was done in accordance with ASME Standard Capability Category II requirements. The peer review concluded that CNS PRA fully meets the Capability Category II requirements for 289 of the 301 applicable ASME PRA Standard Supporting Requirements (SRs), as modified by RG 1.200, Revision 1. Each of the remaining 12 open SRs, were addressed after completion of the peer review and none of these 12 are expected to impact the technical adequacy of the PRA for supporting NFPA 805.
| |
| Attachment U details the 12 open SRs, the actions taken to address them, and the impact on the NFPA 805 application.
| |
| 4.5.1.2 Fire PRA A Fire PRA model was developed for CNS using the guidance provided in NUREG/CR-6850/EPRI TR-1011989 (including supplement 1), EPRI TR-1016735 (Ref. 62), and draft NUREG-1921 (Ref. 63). Attachment H provides a listing of the approved FAQs that affect the overall license transition process for CNS. The resulting fire risk assessment model is used to support Fire Risk Evaluations during the transition process and to develop estimates of the potential change in fire related risk.
| |
| The Fire PRA was developed using the Internal Events PRA as a starting point. The Internal Events PRA was modified to model the effects of fire, both as an initiator and the subsequent potential failure modes for affected circuits or targets. The Fire PRA has been quantified using the CAFTA PRA software. The CNS Fire PRA is documented in a series of reports and calculations associated with each NUREG/CR-6850 Fire PRA task.
| |
| An independent peer review was conducted in April 2010 that included a review of the PRA model, data, and documentation in accordance with ASME Standard Capability Category II requirements as well as an assessment of the impacts on the NFPA 805 program. A follow on focused peer review was conducted in February 2011 to specifically address multi-compartment analyses and final results quantification.
| |
| Fire PRA quality and insights are discussed in subsequent sections and in Attachments V and W, respectively.
| |
| Fire Model Utilization in the Application Fire modeling was performed as part of the Fire PRA development (NFPA 805 Section 4.2.4.2).
| |
| RG 1.205, Regulatory Position 4.2 and Section 5.1.2 of NEI 04-02, provide guidance to identify fire models that are acceptable to the NRC for plants implementing a risk-informed, performance-based licensing basis.
| |
| The following fire models were used:
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| Page 32
| |
| | |
| M=KrncL-n P"Klif- Pnwnr niefrif-f
| |
| ~d*'dL M~r~~L lir.*C'I~kIPAfl Pruil, r~~wr .
| |
| r'KICZ KIPDA P09 Trnncifinn Pý ^
| |
| J U.,SU IflSIJJ T,~c~~i~
| |
| OSIO~fJ ~I'V II P~rr~+
| |
| " Flame Height (Method of Heskestad)
| |
| " Plume Centerline Temperature (Method of Heskestad)
| |
| * Radiant Heat Flux (Point Source Method)
| |
| " Plume Radius (Method of Heskestad)
| |
| * Hot Gas Layer (Method of McCaffrey, Quintiere, and Harkleroad)
| |
| * Hot Gas Layer (Method of Beyler)
| |
| " Hot Gas Layer (Method of Foote, Pagni, and Alvares)
| |
| * Hot Gas Layer (Method of Deal and Beyler)
| |
| " Ceiling Jet Temperature (Method of Alpert)
| |
| " Hot Gas Layer Calculations using Consolidated Model of Fire Growth and Smoke Transport (CFAST)
| |
| " Smoke Detection Actuation Correlation (Method of Heskestad and Delichatsios)
| |
| " Heat Detection Actuation Correlation
| |
| " Sprinkler Activation Correlation
| |
| * Control Room Abandonment Calculation using Fire Dynamics Simulator (FDS)
| |
| * Temperature Sensitive Equipment Hot Gas Layer Study using CFAST
| |
| * Temperature Sensitive Equipment Zone of Influence Study using FDS
| |
| * Plume/Hot Gas Layer Interaction Study using FDS
| |
| " Corner and Wall Heat Release Rate
| |
| " Correlation for Heat Release Rates of Cables (Method of Lee)
| |
| " Correlation for Flame Spread over Horizontal Cable Trays (FLASH-CAT)
| |
| The acceptability of the use of these fire models is included in Attachment J. Many of these correlations have been built into a Fire Modeling Workbook utilized for the Fire PRA fire modeling. The Fire Modeling Workbook was verified, by "black box" testing, to ensure that the results were identical to the verified and validated models. "Black box" testing (also called functional testing) is testing that ignores the internal mechanism of a system or component and focuses solely on the outputs generated in response to selected inputs and execution conditions.
| |
| The process compared results from the Fire Modeling Workbook to those produced by the NUREG-1805 Fire Dynamic Tools and Fire-Induced Vulnerability Evaluation when identical inputs were entered into both. Since the correlations from NUREG-1805 Fire Dynamic Tools and Fire-Induced Vulnerability Evaluation, Revision 1, were verified and validated in NUREG-1824, and the results match the results produced by the Fire Modeling Workbook, by the transitive property, the Fire Modeling Workbook is verified and validated with respect to NUREG-1824.
| |
| The results of this verification are documented in NEDC 10-020, "Verification and Validation of Fire Modeling Tools and Approaches for Use in NFPA 805 and Fire PRA Applications."
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| Page 33
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| | |
| Nebraska Pubhlic Power Distric~t CNSI NFPA 805!Transition Renort 4.5.1.3 Results of Fire PRA Peer Review The CNS Fire PRA was peer reviewed against the requirements of ASME/ANS RA-Sa-2009, Part 4. The BWR Owners Group issued the final report in March 2011 containing the results of the peer review. The identification and resolution of the findings are summarized in Attachment V.
| |
| All of the findings have either been formally addressed or evaluated to have no significant impact on the Fire PRA and fire risk evaluations. There were 49 SR identified that did not meet Capability Category II. These are summarized in Attachment V with a CNS resolution for this application.
| |
| 4.5.1.4 Risk Insights Risk insights were documented as part of the development of the Fire PRA. The total plant fire core damage frequency (CDF)/large early release frequency (LERF) was derived using the NUREG/CR-6850 methodology for Fire PRA development and is useful in identifying the areas of the plant where fire risk is greatest. A review of the fire scenarios that individually contribute more than 1% of the calculated fire risk is included as Attachment W.
| |
| 4.5.2 Performance-Based Approaches NFPA 805 outlines the approaches for performing performance-based analyses. As specified in Section 4.2.4, there are generally two types of analyses performed for the performance-based approach:
| |
| " Fire Modeling (NFPA 805 Section 4.2.4.1).
| |
| " Fire Risk Evaluation (NFPA 805 Section 4.2.4.2).
| |
| 4.5.2.1 Fire Modeling Approach In lieu of the fire modeling approach the fire risk evaluation approach was utilized for the transition.
| |
| 4.5.2.2 Fire Risk Approach Overview of Evaluation Process The Fire Risk Evaluations were completed as part of the CNS NFPA 805 transition. These Fire Risk Evaluations were developed using the process described below. This methodology is based upon the requirements of NFPA 805, industry guidance in NEI 04-02, and RG 1.205.
| |
| These requirements are summarized in Table 4-1.
| |
| Table 4-1 Fire Risk Evaluation Guidance Summary Table Document Section(s) Topic NFPA 805 2.2(h), 4.2.4, A.2.2(h), A.2.4.4, D.5 Change Evaluation (2.2(h), 2.2.9, 2.4.4 A.2.2(h), A.2.4.4, D.5)
| |
| Risk of Recovery Actions (4.2.4)
| |
| Use of Fire Risk Evaluation (4.2.4.2)
| |
| NEI 04-02 Revision 2 4.4, 5.3, Appendix B, Appendix I, Change Evaluation, Change Evaluation Appendix J Forms (App. I), No specific discussion of Fire Risk Evaluation Page 34
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report Table 4-1 Fire Risk Evaluation Guidance Summary Table Document Section(s) Topic RG 1.205 Revision 1 C.2.2.4, C.2.4, C.3.2 Risk Evaluations (C.2.2.4)
| |
| Recovery Actions (C.2.4)
| |
| During the transition to NFPA 805, variances from the deterministic approach in Section 4.2.3 of NFPA 805 were evaluated using a Fire Risk Evaluation per Section 4.2.4.2 of NFPA 805. A Fire Risk Evaluation was performed for each fire area containing variances from the deterministic requirements of Section 4.2.3 of NFPA 805 (VFDR).
| |
| If the Fire Risk Evaluation meets the acceptance criteria, this is confirmation that a success path effectively remains free of fire damage and that the performance-based approach is acceptable per Section 4.2.4.2 of NFPA 805.
| |
| The Fire Risk Evaluation process consists of the following steps (see Figure 4-7):
| |
| Step I - Preparation for the Fire Risk Evaluation
| |
| " Definition of the Variances from the Deterministic Requirements. The definition of the VFDR includes a description of problem statement and the section of NFPA 805 that is not met, type of VFDR (e.g., separation issue or degraded fire protection system), and proposed evaluation per applicable NFPA 805 section.
| |
| * Preparatory Evaluation - Fire Risk Evaluation Team Review. Using the information obtained during the development of the NEI 04-02 B-3 Table and the Fire PRA, a team review of the VFDR was performed. Depending on the scope and complexity of the VFDR, the team included a Safe Shutdown/NSCA Engineer, Fire Protection Engineer, and Fire PRA Engineer. The purpose and objective of this team review was to address the following:
| |
| " Review Fire PRA modeling treatment of VFDR o Ensure discrepancies were captured and resolved Step 2 - Performed the Fire Risk Evaluation
| |
| * The Evaluator coordinated as necessary with the Safe Shutdown/NSCA Engineer, Fire Protection Engineer and Fire PRA Engineer to assess the VFDR using the Fire Risk Evaluation process to perform the following:
| |
| " Change in Risk Calculation with consideration for additional risk of recovery actions and required fire protection systems and features due to fire risk.
| |
| o Fire area change in risk summary Step 3 - Reviewed the Acceptance Criteria The acceptance criteria for the Fire Risk Evaluation consist of two parts. One is quantitatively based and the other is qualitatively based. The quantitative figures of merit are ACDF and ALERF. The qualitative factors are defense-in-depth and safety margin.
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| o Risk Acceptance Criteria. The transition risk evaluation was measured quantitatively for acceptability using the ACDF and ALERF criteria from RG 1.174, as clarified in RG 1.205 Regulatory Position 2.2.4.
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| Page 35
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report o Defense-in-Depth. A review of the impact of the change on defense-in-depth was performed, using the guidance NEI 04-02. NFPA 805 defines defense-in-depth as:
| |
| - Preventing fires from starting.
| |
| - Rapidly detecting fires and controlling and extinguishing promptly those fires that do occur, thereby limiting damage.
| |
| - Providing adequate level of fire protection for structures, systems and components important to safety; so that a fire that is not promptly extinguished will not prevent essential plant safety functions from being performed.
| |
| In general, the defense-in-depth requirement was considered to be satisfied if the proposed change does not result in a substantial imbalance among these elements (or echelons).
| |
| The review of defense-in-depth was qualitative and addressed each of the elements with respect to the proposed change. Defense-in-depth was performed on a fire area basis.
| |
| Fire protection features and systems relied upon to ensure defense-in-depth were identified as a result of the assessment of defense-in-depth.
| |
| o Safety Margin Assessment. A review of the impact of the change on safety margin was performed. Guidelines for making that assessment are summarized below.
| |
| - Codes and standards or their alternatives accepted for use by the NRC are met, and
| |
| - Safety analysis acceptance criteria in the licensing basis are met, or provides sufficient margin to account for analysis and data uncertainty.
| |
| The requirements related to safety margins for the change analysis are described for each of the specific analysis types used in support of the FRE.
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| Page 36
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| | |
| KI K L,ý D k1i D r1l; 4 ;-+ fKIC KICDA Qnr. -r ;4; D ý+
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| %-UI' CIO~ UUI. %I UVVUIII 011. '.0I4'0 U"l I~J Vh!UJ, UOIOtlI Prepare for Fire Risk Evaluation Perform Fire Risk Evaluation Review of Acceptance Criteria Figure 4 Fire Risk Evaluation Process (NFPA 805 Transition)
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| [Based on FAQ 08-0054 Revision 1]
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| Page 37
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| K1=KrnQkn PHKlit- Pnimar Mefrirf M~hrc~I2 Pih~r~ A~Ac~rflkrir4CI\~
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| rm-q mr:PA MPA Am; Trnncifinn Pa fl'Tr~~itnn n
| |
| ~nnt! L Results of Evaluation Process Disposition of VFDR The ONS NSCA and the NFPA 805 transition project activities have identified a number of variances from the deterministic requirements of NFPA 805 Section 4.2.3. These variances were dispositioned using the fire risk evaluation process.
| |
| Each variance dispositioned using a Fire Risk Evaluation was assessed against the Fire Risk Evaluation acceptance criteria of ACDF and ALERF; and maintenance of defense-in-depth and safety margin criteria from Section 5.3.5 of NEI 04-02 and RG 1.205. The results of these calculations are summarized in Attachment C.
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| Following completion of transition activities and planned modifications and program changes, the plant will be compliant with 10 CFR 50.48(c).
| |
| Risk Change Due to NFPA 805 Transition In accordance with the guidance in RG 1.205, Section C.2.2.4, Risk Evaluations, risk increases or decreases for each fire area using Fire Risk Evaluations and the overall plant, are documented. Note that the risk increase due to the use of recovery actions was included in the risk change for transition for each fire area.
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| RG 1.205, Section C.2.2.4.2 states:
| |
| The total increase or decrease in risk associated with the implementation of NFPA 805 for the overall plant should be calculated by summing the risk increases and decreases for each fire area (including any risk increases resulting from previously approved recovery actions). The total risk increase should be consistent with the acceptance guidelines in Regulatory Guide 1.174. Note that the acceptance guidelines of Regulatory Guide 1.174 may require the total CDF, LERF, or both, to evaluate changes where the risk impact exceeds specific guidelines. If the additional risk associated with previously approved recovery actions is greater than the acceptance guidelines in Regulatory Guide 1.174, then the net change in total plant risk incurred by any proposed alternatives to the deterministic criteria in NFPA 805, Chapter 4 (other than the previously approved recovery actions), should be risk neutral or represent a risk decrease.
| |
| The risk increases and decreases are provided in Attachment W.
| |
| 4.6 Monitoring Program NFPA 805 Section 3.2.3(3) requires that procedures be established for reviews of the fire protection program related performance and trends. NFPA 805, Section 2.6 requires a monitoring program that in part is to establish acceptable performance levels and a method to monitor and assess the performance of the fire protection program. The NFPA 805 requirements for reviews of programs related to performance and trending is provided under the NFPA 805 Monitoring program.
| |
| The NFPA 805 Monitoring Program, as described in this Section, will be implemented within six months after issuance of the NFPA 805 Transition License Amendment (see Attachment S, Table S-3, Implementation Item S-3.23). In order to assess the impact of the transition to NFPA 805 on the current monitoring program, the CNS fire protection program documentation such as the maintenance program processes, FPP implementing procedures, and plant change processes will be reviewed. Sections 4.5.3 and 5.2 of the NEI 04-02, as modified by FAQ 10-Page 38
| |
| | |
| Nebraska Pubhlic Power District CNS NJPPA 805i Transition Renort 0059 (Ref. 64), will be used during the review process and that process is described in the following sections.
| |
| The following scope will be documented appropriately:
| |
| * The scope of SSCs and programmatic elements to monitor.
| |
| * The levels of availability, reliability, or other criteria for those elements that require monitoring.
| |
| 4.6.1 Overview of NFPA 805 Requirements for the NFPA 805 Monitoring Program Section 2.6 of NFPA 805 states:
| |
| A monitoring program shall be established to ensure that the availabilityand reliabilityof the fire protection systems and features are maintained and to assess the performance of the fire protection program in meeting the performance criteria. Monitoring shall ensure that the assumptions in the engineering analysis remain valid.
| |
| The intent of the monitoring review is to confirm the adequacy of the existing surveillance, inspection, testing, compensatory measures, and oversight processes for transition to NFPA 805. This review considers the following:
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| * The adequacy of the scope of structure, systems and components within existing plant programs,
| |
| " The performance criteria for the availability and reliability of the required structure, systems and components.
| |
| * The adequacy of the plant corrective action program in determining causes of equipment and programmatic failures and in minimizing their recurrence.
| |
| 4.6.2 Overview of Post-Transition NFPA 805 Monitoring Program This section provides an overview of the post-transition NFPA 805 Monitoring Program process.
| |
| The monitoring process will be comprised of four phases.
| |
| * Phase 1 - Scoping
| |
| * Phase 2 - Screening Using Risk Criteria
| |
| * Phase 3 - Risk Target Value Determination
| |
| * Phase 4 - Monitoring Implementation Figure 4-8 provides an overview of the Monitoring Process, while Figure 4-9 provides detail on a process for Phases 1 and 2.
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| Page 39
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| | |
| KI VNUI I, 10 ~Ln D LUI ~
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| QJV~
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| ('KICZ KIC:DA Onr T l f JJ IGUI"O
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| ;+;
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| %~JI 0ý
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| ~JJ^r+
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| H Phase I uerneProgrammatic scope oV ooT a Elements an Scoping to Monitor Establish risk significance See Figure E-2 fo Phase 2 criteria Detail Screening Using Risk Criteria Establish list of HSS Fire and NSCA SSCs (for each PMG) based on Criteria Establish Functional Failure criteria and Action Phase 3 Levels for each PMG Risk Target Value Determination Establish reliability and availability criteria for each PMG Yes monitoring program Address performance via corrective action process Perform appopriate maintenannce on, SSCs Is new SSC level goal required? NoIpefrac performance v Yes Nds Establish goals N Phase 4 MonitoringAdrspefracvi Implementation corrective action process Monitor performance goals Is goal met?
| |
| Yes No Address performance via corrective action process Is new SSC level goal required?
| |
| Yes No Figure 4 NFPA 805 Monitoring Process [Based on FAQ 10-0059 Rev.
| |
| 5, Table E-1]
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| Page 40
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| | |
| KI w~uIUIl C3 Llý D IIIII; D UIII. %0 JVVVIW r-A; ILoi
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| . j~ ~iIr r'KIQ KICDA DAR T I, IUII"1IQ W"
| |
| D U.J V4 Phase 1 - Scoping Fire Protection RaE Fire Protection Systems and eatresElements Programmatic Engine ant and Features Figure 4 NFPA 805 Monitoring - Scoping and Screening
| |
| [Based on FAQ 10-0059 Rev. 5, Table E-2]
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| Page 41
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| | |
| KI,=hracl'aDihn D^An~r nflirir4 r'K14Z KIPDA Qr)r, Trnne;+i^n D WVW r+
| |
| Phase I - Scoping In order to meet the NFPA 805 requirements for monitoring, the following categories of SSC and programmatic elements will be included in the NFPA 805 monitoring program:
| |
| " Structures, Systems, and Components required to comply with NFPA 805, specifically:
| |
| o Fire protection systems and features
| |
| - Required by the Nuclear Safety Capability Assessment
| |
| - Modeled in the Fire PRA
| |
| - Required by Chapter 3 of NFPA 805 6
| |
| o Nuclear Safety Capability Assessment equipment
| |
| - Nuclear safety equipment
| |
| - Fire PRA equipment
| |
| - NPO equipment o SSCs relied upon to meet radioactive release criteria
| |
| " Fire Protection Programmatic Elements Phase 2 - Screening Using Risk Criteria The equipment from Phase 1 scoping will be screened to determine the appropriate level of NFPA 805 monitoring. As a minimum, the SSC identified in Phase 1 will be part of an inspection and test program and system/program health program. If not in the current program, the SSC will be added in order to assure that the criteria can be met reliably.
| |
| The following screening process will be used to determine those SSCs that may require additional monitoring beyond normal surveillance activities.
| |
| : 1. Fire Protection Systems and Features Those fire protection systems and features identified in Phase 1 will be candidates for additional monitoring in the NFPA 805 program commensurate with risk significance.
| |
| Risk significance will be accomplished at the component, programmatic element, and/or functional level. Since risk will be evaluated at the compartment level or fire area level, criteria must be developed to determine those analysis units for which the fire protection SSCs contained within the area are considered risk significant. Screening compartments and fire areas will also include considerations for design/operation/maintenance limitations. For instance, fire detection will not subdivide systems beyond the system/train/channel level used in normal operation/maintenance.
| |
| The Fire PRA is the primary tool used to establish the risk significance criteria and performance bounding guidelines. Screening thresholds used to determine risk significant analysis units will be those that meet the following criteria:
| |
| Risk Achievement Worth (RAW) of the monitored parameter a 2.0 6 For the purposes of the NFPA 805 Monitoring, "NSCA equipment" is intended to include Nuclear Safety Equipment, Fire PRA equipment, and NPO equipment.
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| Page 42
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| | |
| KlnkrnýLn D I'IIJ I k1i 4JI D
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| .4'J4J ~UI, tIKIC KICDA Qnr, -Ir
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| ~ ;4; I~LUI D
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| IX hI'.I.4 (AND) either Core Damage Frequency (CDF) x (RAW) > 1.0E-7 per year (OR)
| |
| Large Early Release Frequency (LERF) x (RAW) > 1.OE-8 per year CDF, LERF, and RAW(monitored parameter) will be calculated for each fire area. The 'monitored parameter' will be established at a level commensurate with the amenability of the parameter to risk measurement (e.g., a fire barrier may be more conducive to risk measurement than an individual barrier penetration). If compartments are used that are smaller than fire areas, sufficient basis will be documented.
| |
| The monitoring program will include the appropriate Fire Protection Program SSC based on the criteria above. Additional Fire Protection Program SSC may also be screened in based on plant-specific considerations.
| |
| : 2. Nuclear Safety Capability Assessment Equipment NSCA equipment may already be appropriately monitored by the Maintenance Rule. A comparison of NSCA equipment to the SSCs that are monitored in the Maintenance Rule program will be performed to determine what equipment may require additional NFPA 805 Monitoring. For NSCA SSC not monitored by the Maintenance Rule, the basis for inclusion or exclusion of the SSC in the NFPA 805 monitoring program will be documented.
| |
| The Fire PRA will be used to identify high-safety-significant (HSS) NSCA SSC that require monitoring. The Maintenance Rule guidelines differentiating HSS from low-safety-significant (LSS) SSC will be used. HSS NSCA SSC not currently monitored in Maintenance Rule will be included in the Maintenance Rule program. NSCA SSC that are not HSS will be considered LSS, and need not be included in the monitoring program.
| |
| For fires originating during non-power operational modes, the qualitative use of fire prevention to manage fire risk during Higher Risk Evolutions does not lend itself to quantitative risk measurement. Therefore, fire risk management effectiveness is monitored programmatically similar to combustible material controls and other fire prevention programs. Additional monitoring beyond inspection and test programs and system/program health programs is not considered necessary.
| |
| : 3. SSCs Relied upon for Radioactive Release Criteria The evaluations performed to meet the radioactive release performance criteria are qualitative in nature. The SSC relied upon to meet the radioactive release performance criteria are not amenable to quantitative risk measurement. Additionally, since 10 CFR Part 20 limits (which are lower than releases due to core damage and containment breach) for radiological effluents are not being exceeded, equipment relied upon to meet the radioactive release performance criteria is considered inherently low risk. Therefore, additional monitoring beyond inspection and test programs and system/program health programs is not considered necessary.
| |
| : 4. Monitoring of Fire Protection Programmatic Elements Monitoring of programmatic elements is required in order to "assess the performance of the fire protection program in meeting the performance criteria". Programmatic aspects include:
| |
| " Transient Combustible Control; Transient Exclusion Zones
| |
| " Hot Work Control; Administrative Controls
| |
| * Fire Watch Programs; Program compliance and effectiveness Page 43
| |
| | |
| Nphr.q-,k.q Ptihlir PnwPrniqtrirt fN5S NFPA 805 Transition Renort Poer Dstrit Nebrska ubli
| |
| * Fire Brigade Effectiveness Fire protection health reports, self-assessments, regulator and insurance company reports provide inputs to the monitoring program. The monitoring of programmatic elements and program effectiveness will be performed as part of the management of engineering programs.
| |
| This monitoring is more qualitative in nature since the programs do not lend themselves to the numerical methods of reliability and availability. These programs form the bases for many of the analytical assumptions used to evaluate compliance with NFPA 805 requirements.
| |
| Phase 3 - Risk Target Value Determination Phase 3 consists of using the Fire PRA, or other processes as appropriate, to determine target values of reliability and availability for the HSS fire protection/NSCA SSC and programmatic elements established in Phase 2 as requiring additional monitoring beyond inspection and test programs and system/program health programs.
| |
| Failure criteria will be established by an expert panel or evaluation based on the required fire protection and nuclear safety capability SSC and programmatic elements assumed level of performance in the supporting analyses. Action levels will be established for the SSC at the component level, program level, or functionally through the use of the pseudo system or Iperformance monitoring group' concept. An action level will be developed for the NSCA SSC that are included in a monitoring program.
| |
| Since the HSS SSC will be identified using the Maintenance Rule guidelines, the associated SSC specific performance criteria will be established as in the Maintenance Rule, provided the criteria are consistent with Fire PRA assumptions. The actual action level is determined based on the number of component, program or functional failures within a sufficiently bounding time period (-2-3 operating cycles). Adverse trends and unacceptable levels of availability, reliability, and performance will be reviewed against established action levels. The Monitoring Program failure criteria and action level targets will be documented.
| |
| Phase 4 - Monitoring Implementation Phase 4 is the implementation of the monitoring program, once the monitoring scope and criteria are established. Monitoring consists of periodically gathering, trending, and evaluating information pertinent to the performance, and/or availability of the SSC and comparing the results with the established goals and performance criteria to verify that the goals are being met.
| |
| Results of monitoring activities will be analyzed in timely manner to assure that appropriate action is taken. The corrective action process will be used to address performance of fire protection and nuclear safety SSC that do not meet performance criteria.
| |
| For fire protection and NSCA SSC that are monitored, unacceptable levels of availability, reliability, and performance will be reviewed against the established action levels. If an action level is triggered, corrective action will be initiated to identify the negative trend. A corrective action plan will then be developed using the appropriate CNS process. Once the plan has been implemented, improved performance will return the SSC back to below the established action level.
| |
| A periodic assessment will be performed (e.g., at a frequency of approximately every two to three operating cycles), taking into account, where practical, industry wide operating experience. This may be conducted as part of other established assessment activities. Issues that will be addressed include:
| |
| * Review systems with performance criteria. Do performance criteria still effectively monitor the functions of the system? Do the criteria still monitor the effectiveness of the fire protection and nuclear safety capability assessment systems?
| |
| Page 44
| |
| | |
| Nebras~ka Pubichi Power Distric~t C'NJS NFPA 805~ Transcition Report
| |
| " Have the supporting analyses been revised such that the performance criteria are no longer applicable or new fire protection and nuclear safety capability assessment SSCs, programmatic elements and/or functions need to be in scope?
| |
| " Based on the performance during the assessment period, are there any trends in system performance that should be addressed that are not being addressed?
| |
| 4.7 Program Documentation, Configuration Control, and Quality Assurance 4.7.1 Compliance with Documentation Requirements in Section 2.7.1 of NFPA 805 In accordance with the requirements and guidance in NFPA 805 Section 2.7.1 and NEI 04-02, NPPD has documented analyses to support compliance with 10 CFR 50.48(c). The analyses are being performed in accordance with CNS processes for ensuring assumptions are clearly defined, that results are easily understood, that results are clearly and consistently described, and that sufficient detail is provided to allow future review of the entire analyses.
| |
| Analyses, as defined by NFPA 805 Section 2.4, performed to demonstrate compliance with 10 CFR 50.48(c) will be maintained for the life of the plant and organized to facilitate review for accuracy and adequacy. Note these analyses do not include items such as periodic tests, hot work permits, fire impairments, etc.
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| The Fire Protection Design Basis Document described in Section 2.7.1.2 of NFPA 805 and necessary supporting documentation described in Section 2.7.1.3 of NFPA 805 will be created as part of transition to 10 CFR 50.48(c) to ensure program implementation following receipt of the safety evaluation. (See Implementation Item S-3.5 of Attachment S, Table S-3).
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| Appropriate cross references will be established to supporting documents as required by CNS processes. Figure 4-10 depicts the planned post-transition documentation and relationships.
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| Page 45
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| ~i r'KIQ KII:DA QAIR T nnco+inn n ^r+
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| KI I1 k
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| al oL-n IO ILLIIJISJVIIIL D^%Ainr nio+r;^+
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| IISI % l~~% I OLIII ~'JVl NFPA 805 DOCUMENTS
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| , - NSCA Database I NSELComp Cables PRA Equipment Non-Power and Data Equipment and Revised License I ý Data Condition I----------------------
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| NSCA CALCULATION Comp&Cable 7FAAssessment Method/Results Method/Review Revised USAR MSO and OMA Treatments SSA Drawings NSCA SUPPORTING INFO Manual Action Tol Calculation Feasibility FIRE SAFETY ANALYSIS (DCD)
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| B-2 Table B-3 Table , On a Fire Area Basis
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| * Fire Area Description
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| * FHA Database Information Coordination Plant DCDs that
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| * Nuclear Safety Performance Criteria Compliance Summary (NEI 04-02 B-3 Table Calculations Support NSCA Results)
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| * Non-Power Evaluation Results Summary
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| * Radioactive Release Summary Non-Power Mode NSCA Treatment " On a Generic Basis
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| * B-1 Table Results I Non-Power Operations Calculations
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| * Radioactive Release (Training)
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| * Monitoring Program NFPA 805 FIRE RISK EVALUATIONS r Fire Risk Evaluation Calculation(s)
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| FHA DATABASE DATA Ignition Sources & FP Systems and Scenarios Features Data B Fire PRA ivnoyof BiTable Detaile Hazards Data FHA SUPPORT DOCUMENTATION FPSyatems Code Compliance FP Drawings Evaluations Bold text indicates new NFPA 80S documents FP System and Engineering Feature DCDs Equivalency Evalutions Radioactive Fire Pre-Plans Release Review Calculations I--------------
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| Figure 4 NFPA 805 Planned Post-Transition Documents and Relationships Page 46
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| KhohrocLen P"Wit- Pr%%Ai,=r r);c+riýf I-KICZ KIPDA ROR Trnnoif;^n Dn ^r4 4.7.2 Compliance with Configuration Control Requirements in Section 2.7.2 and 2.2.9 of NFPA 805 Program documentation established, revised, or utilized in support of compliance with 10 CFR 50.48(c) is subject to CNS configuration control processes that meet the requirements of Section 2.7.2 of NFPA 805. This includes the appropriate procedures and configuration control processes for ensuring that changes impacting the fire protection program are reviewed appropriately. The RI-PB post-transition change process methodology is based upon the requirements of NFPA 805, and industry guidance in NEI 04-02, and RG 1.205. These requirements are summarized in Table 4-2.
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| Table 4-2 Change Evaluation Guidance Summary Table Document Section(s) Topic NFPA 805 2.2(h), 2.2.9, 2.4.4, A.2.2(h), Change Evaluation A.2.4.4, D.5 NEI 04-02 5.3, Appendix B, Appendix I, Change Evaluation, Change Evaluation Appendix J Forms (Appendix I)
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| RG 1.205 C.2.2.4, C.3.1, C.3.2, C.4.3 Risk Evaluation, Standard License Condition, Change Evaluation Process, Fire PRA The Plant Change Evaluation Process required under the revised Fire Protection License Condition will consist of the following 4 steps and is depicted in Figure 4-1 1:
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| * Defining the Change
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| * Performing the Preliminary Risk Screening
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| * Performing the Risk Evaluation
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| " Evaluating the Acceptance Criteria Change Definition The Change Evaluation process begins by defining the change or altered condition to be examined and the baseline configuration as defined by the Design Basis and Licensing Basis (NFPA 805 Licensing Basis post-transition).
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| : 1) The baseline is defined as that plant condition or configuration that is consistent with the Design Basis and Licensing Basis (NFPA 805 Licensing Basis post-transition).
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| : 2) The changed or altered condition or configuration that is not consistent with the Design Basis and Licensing Basis is defined as the proposed alternative.
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| Preliminary Risk Review Once the definition of the change is established, a screening will then be performed to identify and resolve minor changes to the fire protection program. This screening will be consistent with fire protection regulatory review processes currently in place at CNS. This screening process will be modeled after the NEI 02-03 process. This process will address most administrative changes (e.g., changes to the combustible control program, organizational changes, etc.).
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| Page 47
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| Mahmck-m P"hfir PmAjor niefrit-f rCKNq KNiPPA Afl5 Trnnc~ifien Po nr*
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| The characteristics of an acceptable screening process that meets the "assessment of the acceptability of risk" requirement of Section 2.4.4 of NFPA 805 are:
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| " The quality of the screen is sufficient to ensure that potentially greater than minimal risk increases receive detailed risk assessments appropriate to the level of risk.
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| * The screening process must be documented and be available for inspection by the NRC.
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| * The screening process does not pose undue evaluation or maintenance burden.
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| If any of the above is not met, proceed to the Risk Evaluation step.
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| Risk Evaluation The screening will be followed by engineering evaluations that may include fire modeling and risk assessment techniques. The results of these evaluations will then be compared to the acceptance criteria. Changes that satisfy the acceptance criteria of NFPA 805 Section 2.4.4 and the license condition can be implemented within the framework provided by NFPA 805.
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| Changes that do not satisfy the acceptance criteria cannot be implemented within this framework. The acceptance criteria will require that the resultant change in CDF and LERF be consistent with the license condition. The acceptance criteria will also include consideration of defense-in-depth and safety margin, which would typically be qualitative in nature.
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| The risk evaluation will involve the application of fire modeling analyses and risk assessment techniques to obtain a measure of the changes in risk associated with the proposed change. In certain circumstances, an initial evaluation in the development of the risk assessment may be a simplified analysis using bounding assumptions provided the use of such assumptions does not unnecessarily challenge the acceptance criteria discussed below.
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| Acceptability Determination The Change Evaluations will be assessed for acceptability using the ACDF (change in core damage frequency) and ALERF (change in large early release frequency) criteria from the license condition. The proposed changes will also be assessed to ensure they are consistent with the defense-in-depth philosophy and that sufficient safety margins are maintained.
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| Page 48
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| Nebraska Public Power District CNS NFPA 805 Transition Renort Defining the Change (5.3.2)
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| License No wtChp3r Amendment Request vosyapve Y .es License Amendment r Request NOT Required Preliminary Risk Screening (5.3.3)
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| Risk Evaluation (5.3.4)
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| PRA Capability C4ftgory Assessment Fire PRA Capability Category Assessment Acceptance Criteria (5.3.5)
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| No Figure 4-11 Plant Change Evaluation [NEI 04-02 Figure 5-1]
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| Note references in Figure refer to NEI 04-02 Sections Page 49
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| Klýk ý le 0 kii D r1l; + ; + f'KIQ KICDA OnA T ;+; D r+
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| I /ic ci uLJil. I .JVV~l LJIOLII*L I.JlIlll I J- LDJ. I IlII~lLI*JII I IJUJIL The CNS Fire Protection Program configuration is defined by the program documentation. To the greatest extent possible, the existing configuration control processes for modifications, calculations and analyses, and Fire Protection Program License Basis Reviews will be utilized to maintain configuration control of the Fire Protection program documents. The configuration control procedures which govern the various CNS documents and databases that currently exist will be revised to reflect the new NFPA 805 licensing bases requirements. See Implementation Item S-3.27 of Attachment S, Table S-3.
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| Several NFPA 805 document types such as: NSCA supporting information, Non-Power Mode Review, Fire Modeling Calculations, Fire Safety Assessments, risk evaluations, etc., generally require new control procedures and processes to be developed since they are new documents and databases created as a result of the transition to NFPA 805. The new procedures will be modeled after the existing processes for similar types of documents and databases. See Implementation Item S-3.28 of Attachment S, Table S-3.
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| System level design basis documents will be revised to reflect the NFPA 805 role that the system components now play. The new procedures will be developed and existing documentation revised as part of LAR implementation. See Implementation Item S-3.29 of Attachment S, Table S-3.
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| The process for capturing the impact of proposed changes to the plant on the Fire Protection Program will continue to be a multiple step review. The first step of the review will be an initial screening for process users to determine if there is a potential to impact the Fire Protection Program as defined under NFPA 805 through a series of screening questions/checklists contained in one or more procedures depending upon the configuration control process being used. Reviews that identify potential program impacts will be sent to qualified individuals (Fire Protection, NSCA, Fire PRA) to ascertain the program impacts, if any. If Fire Protection Program impacts are determined to exist as a result of the proposed change, the issue would be resolved by one of the following:
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| * Deterministic Approach: Comply with NFPA 805 Chapter 3 and 4.2.3 requirements
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| * Performance-Based Approach: Utilize the NFPA 805 change process developed in accordance with NEI 04-02, RG 1.205, and the CNS NFPA 805 fire protection license condition to assess the acceptability of the proposed change. This process will be used to determine if the proposed change could be implemented "as-is" or whether prior NRC approval of the proposed change is required.
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| This process follows the requirements in NFPA 805 and the guidance outlined in RG 1.174 which requires the use of qualified individuals, procedures that require calculations be subject to independent review and verification, record retention, peer review, and a corrective action program that ensures appropriate actions are taken when errors are discovered.
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| 4.7.3 Compliance with Quality Requirements in Section 2.7.3 of NFPA 805 Fire Protection Program Quality NPPD will maintain the existing Fire Protection Quality Assurance program as outlined in the CNS Quality Assurance Program for Operation - Policy Document (QAPD) (Ref. 65), as implemented by CNS Quality Assurance procedures. The FPP procedures will be revised to specify application of the NFPA 805 Section 2.7.3 quality requirements (see Implementation Action S-3.8 of Attachment S, Table S-3).
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| During the transition to 10 CFR 50.48(c), NPPD performed work in accordance with the quality requirements of Section 2.7.3 of NFPA 805.
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| Page 50
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| Nebraska Public Power District CNS NFPA 805 Tmnsitinn Rpnort Fire PRA Quality Configuration control of the Fire PRA model will be maintained by integrating the Fire PRA model into the existing processes used to ensure configuration control of the internal events PRA model. This process conforms with Section 1-5 of the ASME Standard for PRA Quality and ensures that CNS maintains an as-built, as-operated PRA model of the plant. The process has been peer reviewed. Quality assurance of the Fire PRA is assured via the same processes applied to the internal events model.
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| Specific Requirements of NFPA 805 Section 2.7.3 NFPA 805 Section 2.7.3.1 - Review Analyses, calculations, and evaluations performed in support of compliance with 10 CFR 50.48(c) were performed in accordance with CNS procedures that require independent review.
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| NFPA 805 Section 2.7.3.2 - Verification and Validation Calculational models and numerical methods used in support of compliance with 10 CFR 50.48(c) were verified and validated as required by Section 2.7.3.2 of NFPA 805.
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| NFPA 805 Section 2.7.3.3 - Limitations of Use Engineering methods and numerical models used in support of compliance with 10 CFR 50.48(c) were used and were used appropriately as required by Section 2.7.3.3 of NFPA 805.
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| NFPA 805 Section 2.7.3.4 - Qualification of Users Cognizant personnel who use and apply engineering analysis and numerical methods in support of compliance with 10 CFR 50.48(c) are competent and experienced as required by Section 2.7.3.4 of NFPA 805.
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| During the transition to 10 CFR 50.48(c), work was performed in accordance with the quality requirements of Section 2.7.3 of NFPA 805. Personnel who used and applied engineering analysis and numerical methods (e.g. fire modeling) in support of compliance with 10 CFR 50.48(c) are competent and experienced as required by NFPA 805 Section 2.7.3.4.
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| For personnel performing fire modeling or Fire PRA development and evaluation, NPPD will develop and maintain qualification requirements for individuals assigned various tasks. Position Specific Guides will be developed to identify and document required training and mentoring to ensure individuals are appropriately qualified per the requirements of NFPA 805 Section 2.7.3.4 to perform assigned work (see Implementation Item S-3.15 of Attachment S, Table S-3).
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| NFPA 805 Section 2.7.3.5 - Uncertainty Analysis Uncertainty analyses were performed as required by 2.7.3.5 of NFPA 805 and the results were considered in the context of the application. This is of particular interest in fire modeling and Fire PRA development used to support performance-based approach. However, it is not required for deterministic approach calculations per 10 CFR 50.48(c)(2)(iv).
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| Page 51
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| Nebraska Public Power District CNS NFPA 805 Transition ReDort 4.8 Summary of Results 4.8.1 Results of the Fire Area Review A summary of the NFPA 805 compliance basis and the required fire protection systems and features is provided in Table 4-3. The table provides the following information from the NEI 04-02 Table B-3 (which is provided in Attachment C):
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| * Fire Area / Fire Zone: Fire Area/Zone Identifier.
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| == Description:==
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| Fire Area/Zone Description.
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| * NFPA 805 Regulatory Basis: Post-transition NFPA 805 Chapter 4 compliance basis (Note: Compliance is determined on a Fire Area basis therefore a compliance basis is not provided for individual fire zones.)
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| " Required Fire Protection System / Feature: Detection / suppression required in the Fire Area based on NFPA 805 Chapter 4 compliance. Other Required Features may include Electrical Raceway Fire Barrier Systems, fire barriers, etc. The documentation of required fire protection systems and features does not include the documentation of the fire area boundaries. Fire area boundaries are required and documentation of the fire area boundaries has been performed as part of reviews of engineering evaluations, licensing actions, or as part of the reviews of the NEI 04-02 Table B-1 process. The information is provided on a zone basis. The basis for the requirement of the fire protection system / feature is designated as follows:
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| " S - Separation Criteria: Systems required for Chapter 4 Separation Criteria in Section 4.2.3 o L - Licensing Action Criteria: Systems required for acceptability of NRC approved Licensing Action (i.e., Exemptions/Safety Evaluations) (Section 2.2.7) o E - EEEE Criteria: Systems required for acceptability of Existing Engineering Equivalency Evaluations (Section 2.2.7) o R - Risk Criteria: Systems required to meet the Risk Criteria for the Performance-Based Approach (Section 4.2.4) o D - Defense-In-Depth Criteria: Systems required to maintain adequate balance of Defense-in-Depth for a Performance-Based Approach (Section 4.2.4)
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| Attachment W contains the results of the Fire Risk Evaluations, additional risk of recovery actions, and the change in risk on a fire area basis.
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| 4.8.2 Plant Modifications and Items to be Completed During the Implementation Phase Planned modifications, training, programs, procedure changes, and evaluations to comply with NFPA 805 are described in Attachment S.
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| The Fire PRA model represents the as-built, as-operated and maintained plant as it will be configured at the completion of the transition to NFPA 805. The Fire PRA model includes credit for the implementation of the modifications identified in Attachment S. Following completion of the modifications and implementation items listed in Attachment S, additional refinements may need to be incorporated into the Fire PRA model. However, these changes are not expected to be significant and will likely result in additional risk improvement in areas where limited credit for the proposed modifications were taken. No other significant plant changes are outstanding with respect to their inclusion in the Fire PRA model.
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| Page 52
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| Nebraska Public Power District CNS NFPA 805 Transition Report 4.8.3 Supplemental Information - Other Licensee Specific Issues None Page 53
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| Nebraska Public Power District CNS NFPA 805 Transition Report Nebraska Public Power District ONS NFPA 805 Transition Report Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features Fire Fire NFPA 805 Regulatory Basis Required for? Required Fire Protection Area Zone Description Type of Feature or System S L E R D Feature and System Notes CB-A Control Building Basement, Control 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic Building 903 Corridor and RPS Room 1A assumptions CB-A 7A RHR Service Water Booster Pump and Detection Ionization N N Y Y N Service Air Compressor Areas CB-A 7A RHR Service Water Booster Pump and Feature Fire Barrier N N N Y N 1-hour concrete enclosure Service Air Compressor Areas CB-A 7B Emergency Condensate Storage Tank Area Detection Ionization N N N N N CB-A 8C RPS Room 1A Detection Ionization N N Y Y N CB-A 8D Seal Water Pump Area and Corridor Suppression Automatic Wet-Pipe N N N Y N CB-A 8D Seal Water Pump Area and Corridor Detection Ionization N N Y Y N CB-A-1 Control Building 903, DC Switchgear 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic Room 1A and Battery Room 1A: assumptions CB-A-1 8E Battery Room 1A Detection Ionization N N Y Y N CB-A-1 8H DC Switchgear Room 1A Detection Ionization N N Y Y N CB-B Control Building 903, DC Switchgear 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic Room 1B and Battery Room 1B assumptions CB-B 8F Battery Room 1B Detection Ionization N N Y Y N CB-B 8G DC Switchgear Room 1B Detection Ionization N N Y Y N CB-C RPS Room 1B 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions CB-C 8B RPS Room 1B Detection Ionization N N Y Y N CB-D Control Room, Computer Room, Cable 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with :simplifying deterministic Spreading Room, Cable Expansion assumptions Room, Auxiliary Relay Room CB-D 1OA Computer Room Suppression Auto Total Flooding N N Y N N Halon 1301 CB-D 10A Computer Room Detection Ionization N N Y N N Actuates Suppression CB-D 10B Control Room and SAS Corridor Detection Heat N N N Y N CB-D 10B Control Room and SAS Corridor Detection Ionization N N N Y N CB-D 8A Auxiliary Relay Room Detection Ionization N N Y Y N Page 54
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| Nebraska Public Power District CNS NFPA 805 Transition Report Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features Fire Fire NFPA 805 Regulatory Basis Required for? Required Fire Protection Area Zone Description Type of Feature or System , L E R D Fetr and Svte Notes*V...
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| vv CB-D 8A Auxiliary Relay Room Detection Incipient (in Panels 9- N N N Y N 32 and 9-33)
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| CB-D 9A Cable Spreading Room Detection Ionization N N Y Y N Actuates Suppression CB-D 9A Cable Spreading Room Detection Heat Actuated Devices N N Y Y N Actuates Suppression CB-D 9A Cable Spreading Room Suppression Preaction Sprinkler N N Y Y N System CB-D 9A Cable Spreading Room Feature Flame Impingement N N N Y N Protects conduit and cable Shield trays above PMIS-MUX-LNK6 CB-D 9A Cable Spreading Room Feature Flame Impingement N N N Y N Promat-H board protects Shield conduit from transient fires CB-D 9B Cable Expansion Room Detection Ionization N N Y Y N CB-D 9B Cable Expansion Room Suppression Automatic Wet-Pipe N N Y Y N CB-D 9B Cable Expansion Room Feature Flame Impingement N N N Y N Promat-H board protects Shield conduit from transient fires DG-A Diesel Generator Room 1A 4.2.3.2 - Deterministic Approach DG-A 14A Diesel Generator Room 1A Detection Heat N N Y Y N DG-A 14A Diesel Generator Room 1A Detection Ionization N N Y Y* N Actuates Suppression DG-A 14A Diesel Generator Room 1A Suppression Automatic Total N N Y Y* N *Risk Significance field Flooding Carbon credits a manual capability Dioxide of the suppression system only.
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| DG-A 14C DG1 Day Tank Room Suppression Automatic Total N N N N N Flooding Carbon Dioxide DG-A 14C DG1 Day Tank Room Detection Heat N N N N N Actuates Suppression DG-B Diesel Generator Room 1 B 4.2.3.2 - Deterministic Approach DG-B 14B Diesel Generator Room 1 B Suppression Automatic Total N N Y Y* N *Risk Significance field Flooding Carbon credits a manual capability Dioxide of the suppression system only.
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| DG-B 14B Diesel Generator Room 1B Detection Ionization N N Y Y* N Actuates Suppression DG-B 14B Diesel Generator Room 1B Detection Heat N N Y Y N Page 55
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| Nebraska Public Power District CNS NFPA 805 Transition Report Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features Fire Fire NFPA 805 Regulatory Basis Required for? Required Fire Protection Area Zone Description Type of Feature or System S L E R D Feature and System Notes DG-B 14D DG2 Day Tank Room Suppression Automatic Total N N N N N Flooding Carbon Dioxide DG-B 14D DG2 Day Tank Room Detection Heat N N N N N Actuates Suppression IS-A Intake Structure 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions IS-A 20A Service Water Pump Area Suppression Total Flooding Halon N N N Y N 1301 IS-A 20A Service Water Pump Area Detection Thermal Heat N N N Y N Actuates Suppression IS-A 20A Service Water Pump Area Detection Ionization N N N Y N Actuates Suppression IS-A 20A Service Water Pump Area Detection Flame N N N N N IS-A 20B Circulating Water Pump and Traveling None N/A - -
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| Screen Area RB-A RCIC and Core Spray Pump Room 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions RB-A 1A RCIC and Core Spray Pump Room Detection Heat N N N Y N RB-B Reactor Building South East Quad 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions RB-B 1B Core Spray Pump Room Detection Heat N N Y Y N RB-B 1G Control Rod Drive Pump Area Detection Heat N N Y Y N RB-CF Reactor Building Northwest Quad, 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic Reactor Building 903 North Area and assumptions South Corridor, RHR Heat Exchanger Room A RB-CF 1C RHR Pump Room lA and 1C Detection Heat N N Y Y N RB-CF 2A-2 CRD Units - North Detection Ionization N N N Y N RB-CF 2A-3 903' South Corridor None N/A - -
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| RB-CF 2B RHR Heat Exchanger Room A None N/A - -
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| RB-DI Reactor Building Southwest Quad, HPCI 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic Room, Reactor Building 903 South, RHR assumptions Heat Exchanger Room B Page 56
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| Nebraska Public Power District CNS NFPA 805 Transition Report Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features Fire Fire NFPA 805 Regulatory Basis Required for? Required Fire Protection Area Zone Description Type of Feature or System S L E R D Feature and System Notes RB-DI 1D RHR Pump Room 1B and 1D Detection Heat N N N Y N RB-DI 1E HPCI Pump Room Detection Heat N N N Y N RB-DI 2A-3 903' South Corridor None N/A . . ..
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| RB-DI 2C CRD Units - South Detection Heat N N N N N Actuates Suppression RB-DI 2C CRD Units - South Suppression Preaction Sprinkler N N N N N System RB-DI 2C CRD Units - South Detection Ionization N N N Y N RB-DI 2D RHR Heat Exchanger Room B None N/A - - -
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| RB-E Suppression Pool Area 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions RB-E 1F Suppression Pool Area None N/A - -
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| RB-FN Reactor Building 903' Northeast Corner 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions RB-FN 2A-1 Reactor Building 903' Northeast Corner Suppression Automatic Wet-Pipe N N Y Y N RB-FN 2A-1 Reactor Building 903' Northeast Corner Detection Ionization N N Y Y N RB-FN 2A-1 Reactor Building 903' Northeast Corner Detection Heat N N Y Y N RB-J Critical Switchgear Room 1F 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions RB-J 3A Critical Switchgear Room 1F Detection Ionization N N Y Y N RB-K Critical Switchgear Room 1G 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions RB-K 3B Critical Switchgear Room 1G Detection Ionization N N Y Y N RB-M Reactor Building North I East Side, RHR 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic Heat Exchanger Room A assumptions RB-M 2B RHR Heat Exchanger Room A None N/A RB-M 3C REC Heat Exchanger and Pump Area Feature Radiant Energy Shield N N N Y N Protects conduit and cable trays from transient fires RB-M 3C REC Heat Exchanger and Pump Area Detection Ionization N N N Y N RB-M 3D Reactor Recirculation Motor Generator Set Detection Ionization N N N Y N Lube Oil Cooler Area Page 57
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| Nebraska Public Power District CNS NFPA 805 Transition Report Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features Fire Fire NFPA 805 Regulatory Basis Required for? Required Fire Protection Area Zone Description Type of Feature or System S L E R D Feature and System Notes RB-M 3D Reactor Recirculation Motor Generator Set Suppression Automatic Wet-Pipe N N N N N Lube Oil Cooler Area RB-M 3E-2 RWCU Pump Area and Corridor None N/A - -
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| RB-N Reactor Building South West Corner, 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic RHR Heat Exchanger Room B and RWCU assumptions Heat Exchanger Room RB-N 2D RHR Heat Exchanger Room B None N/A RB-N 3E-1 RWCU Regenerative Heat Exchanger Detection Ionization N N N N Y Areas RB-N 3E-2 RWCU Pump Area and Corridor None N/A RB-P Reactor Building 958 Accessible Areas 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions RB-P 4A Reactor Building Elevator and Accessway Detection Ionization N N Y Y N Area RB-P 4B Reactor Building HVAC Area None N/A RB-P 4C Fuel Pool Heat Exchanger, CRD Repair Detection Ionization N N N Y N Room, and Raw Water Cleanup Areas RB-P 4D Reactor Recirculation Motor Generator Set Suppression Automatic Wet-Pipe N N N Y N Oil Pump Area RB-P 4D Reactor Recirculation Motor Generator Set Detection Ionization N N N Y N Oil Pump Area RB-T Reactor Building East Side and 4.2.3.2 - Deterministic Approach Refueling Floor RB-T 5A SLC Pump Tank and Accessway Detection Ionization N N Y N N RB-T 6 Refueling Floor Detection Heat N N Y N N RB-V Reactor Recirculation Motor Generator 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic Set Area assumptions RB-V 5B Reactor Recirculation Motor Generator Set Suppression Preaction Sprinkler N N Y Y N Area System RB-V 5B Reactor Recirculation Motor Generator Set Suppression (m Deluge Water Spray N N N N N Area RB-V 5B Reactor Recirculation Motor Generator Set Detection Flame N N N N N Area Page 58
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| Nebraska Public Power District CNS NFPA 805 Transition Report Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features Fire Fire NFPA 805 Regulatory Basis Required for? Required Fire Protection Area Zone Description Type of Feature or System S L E R D Feature and System Notes RB-V 5B Reactor Recirculation Motor Generator Set Detection Heat N N N N N Area RB-V 5B Reactor Recirculation Motor Generator Set Detection Ionization N N Y Y N Area RB-V 5B Reactor Recirculation Motor Generator Set Detection Heat Actuated Devices N N Y Y N Actuates Suppression Area TB-A Turbine Building, Non-Critical 4.14.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic Switchgear. Room, Office Building, assumptions Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility TB-A 11A Turbine Lube Oil Storage Tank Room Detection Heat Actuated Devices N N N Y N Actuates Suppression TB-A 11A Turbine Lube Oil Storage Tank Room Detection Ionization N N N N N TB-A 11A Turbine Lube Oil Storage Tank Room Suppression Automatic Water Spray N N N Y N TB-A 11B Turbine Building Basement - South Suppression Automatic Wet-Pipe N N N Y N TB-A 11B Turbine Building Basement - South Detection Ionization N N N Y N TB-A 11B Turbine Building Basement - South Detection Heat Actuated Devices N N N Y N Actuates Suppression TB-A 11C H2 Seal Oil Unit Area Suppression Automatic Water Spray N N N Y N TB-A 11C H2 Seal Oil Unit Area Detection Heat Actuated Devices N N N Y N Actuates Suppression TB-A 11C H2 Seal Oil Unit Area Detection Ionization N N N N N TB-A 11D Condenser Pit Area Detection Heat N N N N N TB-A 11D Condenser Pit Area Suppression Automatic Wet-Pipe N N N Y N TB-A 11E Reactor Feed Pumps Area Detection Heat N N N N N TB-A 11E Reactor Feed Pumps Area Detection Heat Activated Devices N N N Y N Actuates Suppression TB-A 11E Reactor Feed Pumps Area Suppression Automatic Water Spray N N N Y N TB-A 11F Turbine Building Controlled Corridor 882' Suppression Automatic Wet-Pipe N N N Y N Elevation TB-A 11F Turbine Building Controlled Corridor 882' Detection Ionization N N N Y N Elevation TB-A 11G Steam Jet Air Ejector Room Detection Heat N N N N N TB-A 11G Steam Jet Air Ejector Room Suppression Automatic Wet-Pipe N N N N N Page 59
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| Nebraska Public Power District CNS NFPA 805 Transition Report Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features Fire Fire NFPA 805 Regulatory Basis Required for? Required Fire Protection Area Zone Description Type of Feature or System S L E R D Feature and System Notes TB-A 11H Mechanical Vacuum Pumps Room Detection Heat N N N N N TB-A 11H Mechanical Vacuum Pumps Room Suppression Automatic Wet-Pipe N N N N N TB-A 11J Condensate, Condensate Booster and Suppression Automatic Wet-Pipe N N N Y N TEC Pumps Area" TB-A 11J Condensate, Condensate Booster and Detection Ionization N N N N N TEC Pumps Area TB-A 11K Turbine Oil Conditioner Room Detection Heat Actuated Devices N N N Y N Actuates Suppression TB-A 11K Turbine Oil Conditioner Room Detection Ionization N N N N N TB-A 11K Turbine Oil Conditioner Room Suppression Automatic Water Spray N N N Y N TB-A 11L Pipe Chase None N/A TB-A 12A ISO Phase Bus Duct Area Detection Heat N N N N N TB-A 12A ISO Phase Bus Duct Area Detection Heat Activated Devices N N N N N Actuates Suppression TB-A 12A ISO Phase Bus Duct Area Suppression Automatic Water Spray N N N N N TB-A 12B Turbine Building Controlled Corridor 903' None N/A Elevation TB-A 12C Condenser and Heater Bay Areas Detection Heat N N N N N TB-A 12C Condenser and Heater Bay Areas Suppression Automatic Water Spray N N N Y N TB-A 12C Condenser and Heater Bay Areas Detection Heat Activated Devices N N N Y N Actuates Suppression TB-A 12D Turbine Building Floor - North Detection Heat Actuated Devices N N Y Y N Actuates Suppression TB-A 12D Turbine Building Floor - North Suppression Automatic Wet-Pipe N N N Y N TB-A 12D Turbine Building Floor - North Detection Ionization N N Y Y N TB-A 12E Turbine Oil Reservoir Area Detection Ionization N N N N N TB-A 12E Turbine Oil Reservoir Area Suppression Automatic Water Spray N N N Y N TB-A 12E Turbine Oil Reservoir Area Detection Heat Actuated Devices N N N Y N Actuates Suppression TB-A 12F Turbine Building Document Storage Vault Suppression Automatic Wet-Pipe N N Y N N TB-A 12F Turbine Building Document Storage Vault Detection Ionization N N Y N N TB-A 13A Turbine Operating Floor Detection Flame N N N Y N TB-A 13A Turbine Operating Floor Suppression Automatic Water Spray N N N Y N TB-A 13A Turbine Operating Floor Detection Heat N N N Y N Actuates Suppression Page 60
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| Nebraska Public Power District Report CNS NFPA 805 Transition Report Nebraska Public Power District CNS NFPA 805 Transition Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features Fire Fire NFPA 805 Regulatory Basis Required for? Required Fire Protection Area Zone Description Type of Feature or System S L E R D Feature and System Notes TB-A 13A Turbine Operating Floor Suppression Automatic Carbon N N N Y N Dioxide TB-A 13B Non-Critical Switchgear Room Detection Ionization N N N Y N TB-A 13C Electrical Shop Detection Ionization N N N Y N TB-A 13D Instrument Shop, Instrument Records and Detection Ionization N N Y N N Chart Rooms TB-A 15 Heating Boiler Room Suppression Automatic Wet-Pipe N N N Y N TB-A 15 Heating Boiler Room Detection Heat N N N N N TB-A 16 Turbine Building Exhaust Fan Room Detection Ionization N N N N N TB-A 17 Water Treatment Building Detection Ionization N N N N N TB-A 18A Machine Shop Detection Ionization N N N N N TB-A 18A Machine Shop Suppression Automatic Wet-Pipe N N N N N TB-A 18A Machine Shop Detection Heat N N N N N TB-A 18B Machine Shop Clean Tool Room Suppression Automatic Wet-Pipe N N N N N TB-A 18C Machine Shop Oil Storage Room Detection Ionization N N N N N TB-A 18C Machine Shop Oil Storage Room Suppression Automatic Wet-Pipe N N N N N TB-A 18D Machine Shop Paint Storage Room Suppression Automatic Wet-Pipe N N N N N TB-A 18D Machine Shop Paint Storage Room Detection Ionization N N N N N TB-A 18E Machine Shop Lunch Room and Records Detection Ionization N N N N N Storage Room TB-A 18E Machine Shop Lunch Room and Records Suppression Automatic Wet-Pipe N N N N N Storage Room TB-A 19A Office Building Controlled Corridor 903' Suppression Automatic Wet-Pipe N N Y N N Elevation TB-A 19B Office Building Occupancies and Controlled Suppression Automatic Wet-Pipe N N N N N Corridors TB-A 19B Office Building Occupancies and Controlled Detection Ionization N N Y N N Corridors TB-A 19C Office Building Penthouse Detection Heat N N N N N TB-A 19C Office Building Penthouse Suppression (m Water Spray N N N N N TB-A 19C Office Building Penthouse Detection Ionization N N N N N Page 61
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| Nebraska Public Power District CNS NFPA 805 Transition Report Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features Fire Fire NFPA 805 Regulatory Basis Required for? Required Fire Protection Area Zone Description Type of Feature or System N L E R D Feature and System Notes TB-A 19C Office Building Penthouse Suppression Automatic Wet-Pipe N N N N N
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| TB-A 21A Radwaste Building Basement Detection Ionization N N N N N
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| TB-A 21B Radwaste Building First Floor Detection Heat N Y N N N
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| TB-A 21B Radwaste Building First Floor Detection Ionization N Y N N N
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| TB-A 21C Radwaste Building Second Floor Suppression Bottled Halon 1301 N N N N N
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| TB-A 21C Radwaste Building Second Floor Detection Heat N N N N N
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| TB-A 21C Radwaste Building Second Floor Suppression Automatic Wet-Pipe N N N N N
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| TB-A 21C Radwaste Building Second Floor Detection Ionization N N N N N
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| TB-A 21D Radwaste Building Third Floor Suppression Automatic Wet-Pipe N N N N N
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| TB-A 21D Radwaste Building Third Floor Detection Ionization N N N N N
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| TB-A 22A Augmented Radwaste Building Basem(ent Detection Heat N N N N N
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| TB-A 22A Augmented Radwaste Building BasemEent Detection Ionization N N N N N
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| TB-A 22B Augmented Radwaste Building First FI( )or Detection Heat N Y N N D N TB-A 22B Augmented Radwaste Building First FI( or Detection Flame N Y N N 0 N TB-A 22B Augmented Radwaste Building First FIc or Detection Ionization N Y N N N
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| TB-A 22C Augmented Radwaste Building Second Detection Ionization N N N N Floor TB-A 22C Augmented Radwaste Building Second Detection Flame N N N N N Floor TB-A 22C Augmented Radwaste Building Second Suppression Automatic Water Spray N N N N N Floor TB-A 22C Augmented Radwaste Building Second Detection Heat N N N N N Floor TB-A 24 Multi-Purpose Facility Suppression Preaction Sprinkler N N Y N N System TB-A 24 Multi-Purpose Facility Detection Heat N N Y N N Actuates Suppression YD Yard, Fire Pumphouse, Off-Gas Building, 4.2.3.2 - Deterministic Approach and Optimum Water Chemistry Building YD 23A Electric Motor Driven Fire Pump Room Detection Ionization N N N N N YD 23A Electric Motor Driven Fire Pump Room Detection Heat N N N N N YD 23B Diesel Driven Fire Pump Room Detection Ionization N N N N N Page 62
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| Nebraska Public Power District CNS NFPA 805 Transition Report Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features Fire Fire NFPA 805 Regulatory Basis Required for? Required Fire Protection Area Zone Description Type of Feature or System S L E R D Feature and System Notes YD 23B Diesel Driven Fire Pump Room Detection Heat N N N N N YD 23B Diesel Driven Fire Pump Room Detection Flame N N N N N YD 23B Diesel Driven Fire Pump Room Suppression Automatic Wet-Pipe Y N N N N Required for Chap. 3 for suppression over the diesel fire pump 3.9.4 YD 23C Diesel Oil Tank Room Suppression Automatic Wet-Pipe N N N N N YD 23C Diesel Oil Tank Room Detection Heat N N N N N YD 25 Off-Gas Building None N/A - -
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| YD 26 Optimum Water Chemistry Building None N/A - -
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| YD Yard Transformer Yard Detection Heat Actuated Devices N N Y Y N Actuates Suppression YD Yard Transformer Yard Suppression Deluge Water Spray N N Y Y N Legend:
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| Table Field: "Required?"
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| S - Required for Chapter 4 Separation Criteria L - Required for NRC Approved Licensing Action E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Page 63
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| NehrnQkn P"hlin Power Dicfrirf (,m.q mi=PA Rnf; Trnneifinn Pann
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| (~M5~ MFPA RA'~ Tr~n,~itiAn P~nA,-t
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| ~J~hr~k~ Piihlir PA~Mg~r flic~trirt L
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| | |
| ==5.0 REGULATORY EVALUATION==
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| | |
| 5.1 Introduction - 10 CFR 50.48 On July 16, 2004, the NRC amended 10 CFR 50.48, Fire Protection, to add a new subsection, 10 CFR 50.48(c), which establishes alternative fire protection requirements. 10 CFR 50.48 endorses, with exceptions, NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants - 2001 Edition (NFPA 805), as a voluntary alternative for demonstrating compliance with 10 CFR 50.48 Section (b), Appendix R, and Section (f), Decommissioning.
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| The voluntary adoption of 10 CFR 50.48(c) by CNS does not eliminate the need to comply with 10 CFR 50.48(a) and 10 CFR 50, Appendix A, General Design Criterion (GDC) 3, Fire Protection. The NRC addressed the overall adequacy of the regulations during the promulgation of 10 CFR 50.48(c) (Reference FR Notice 69 FR 33536 dated June 16, 2004, ML041340086).
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| NFPA 805 does not supersede the requirements of GDC 3, 10 CFR 50.48(a), or 10 CFR 50.48(o. Those regulatory requirements continue to apply to licensees that adopt NFPA 805. However, under NFPA 805, the means by which GDC 3 or 10 CFR 50.48(a) requirements may be met is different than under 10 CFR 50.48(b). Specifically, whereas GDC 3 refers to SSCs important to safety, NFPA 805 identifies fire protection systems and features required to meet the Chapter 1 performance criteria through the methodology in Chapter 4 of NFPA 805. Also, under NFPA 805, the 10 CFR 50.48(a)(2)(iii) requirement to limit fire damage to SSCs important to safety so that the capability to safely shut down the plant is ensured is satisfied by meeting the performance criteria in Section 1.5.1 of NFPA 805. The Section 1.5.1 criteria include provisions for ensuring that reactivity control, inventory and pressure control, decay heat removal, vital auxiliaries,and process monitoring are achieved and maintained.
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| This methodology specifies a process to identify the fire protection systems and features required to achieve the nuclear safety performance criteria in Section 1.5 of NFPA 805.
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| Once a determination has been made that a fire protection system or feature is required to achieve the performance criteria of Section 1.5, its design must meet any applicable requirements of NFPA 805, Chapter 3. Having identified the required fire protection systems and features, the licensee selects either a deterministic or performance-basedapproach to demonstrate that the performance criteria are satisfied. This process satisfies the GDC 3 requirement to design and locate SSCs important to safety to minimize the probability and effects of fires and explosions.
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| (Reference FR Notice 69 FR 33536 dated June 16, 2004, ML041340086)
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| The new rule provides actions that may be taken to establish compliance with 10 CFR 50.48(a),
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| which requires each operating nuclear power plant to have a fire protection program plan that satisfies GDC 3, as well as specific requirements in that section. The transition process described in 10 CFR 50.48(c)(3)(ii) provides, in pertinent parts, that a licensee intending to adopt the new rule must, among other things, "modify the fire protection plan required by paragraph (a) of that section to reflect the licensee's decision to comply with NFPA 805."
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| Therefore, to the extent that the contents of the existing fire protection program plan required by 10 CFR 50.48(a) are inconsistent with NFPA 805, the fire protection program plan must be modified to achieve compliance with the requirements in NFPA 805. All other requirements of 10 CFR 50.48 (a) and GDC 3 have corresponding requirements in NFPA 805.
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| Page 64
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| flI"J~ NFPA RO~ Tr2n~itinn Pg~nnrt Nebraska Public Power District ('KI.q KIFPA ROE; Trnn--ifirm Pimnrrt A comparison of the current requirements in Appendix R with the comparable requirements in Section 3 of NFPA 805 shows that the two sets of requirements are consistent in many respects. This was further clarified in FAQ 07-0032, "Clarification of 10 CFR 50.48(c),
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| 10 CFR 50.48(a) and GDC 3 clarification" (Ref. 66). The following tables provide a cross reference of fire protection regulations associated with the post-transition CNS Fire Protection Program and applicable industry and CNS documents that address the topic.
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| 10 CFR 50.48(a)
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| Table 5-1 10 CFR 50.48(a) - Applicability/Compliance Reference 10 CFR 50.48(a) Section(s) Applicability/Compliance Reference (1) Each holder of an operating license issued under this See below part or a combined license issued under part 52 of this chapter must have a fire protection plan that satisfies Criterion 3 of appendix A to this part. This fire protection plan must:
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| (i) Describe the overall fire protection program for the NFPA 805 Section 3.2 facility; LAR Attachment A NEI 04-02 Table B-1 (ii)Identify the various positions within the licensee's NFPA 805 Section 3.2.2 organization that are responsible for the program; LAR Attachment A NEI 04-02 Table B-1 (iii) State the authorities that are delegated to each of NFPA 805 Section 3.2.2 these positions to implement those responsibilities; LAR Attachment A NEI 04-02 Table B-1 and (iv)Outline the plans for fire protection, fire detection NFPA 805 Section 2.7 and Chapters 3 and 4 and suppression capability, and limitation of fire LAR Attachments A and C NEI 04-02 B-1 and B-3 damage. Tables (2) The plan must also describe specific features See below necessary to implement the program described in paragraph (a)(1) of this section such as:
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| (i)Administrative controls and personnel requirements NFPA 805 Sections 3.3.1 and 3.4 for fire prevention and manual fire suppression LAR Attachment A NEI 04-02 Table B-1 activities; (ii)Automatic and manually operated fire detection and NFPA 805 Sections 3.5 through 3.10 and suppression systems; and Chapter 4 LAR Attachments A and C NEI 04-02 B-1 and B-3 Tables (iii) The means to limit fire damage to structures, NFPA 805 Section 3.3 and Chapter 4 systems, or components important to safety so that the LAR Attachment C NEI 04-02 B-3 Table capability to shut down the plant safely is ensured.
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| (3) The licensee shall retain the fire protection plan and NFPA 805 Section 2.7.1.1 requires that each change to the plan as a record until the documentation (Analyses, as defined by NFPA 805 Commission terminates the reactor license. The 2.4, performed to demonstrate compliance with this licensee shall retain each superseded revision of the standard) be maintained for the life of the plant.
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| procedures for 3 years from the date it was The CNS FPP is maintained as a station superseded. procedure. The CNS QAPD and Procedure 1.9.
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| "Control and Retention of Records," provide station direction for the lifetime retention of procedures and procedure changes.
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| Page 65
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| Nebras~ka Pubichi Power District CN5S NFPA 805 Transcition Renor h Table 5-1 10 CFR 50.48(a) - Applicability/Compliance Reference 10 CFR 50.48(a) Section(s) Applicability/Compliance Reference (4) Each applicant for a design approval, design Not applicable. CNS is licensed under 10 CFR 50.
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| certification, or manufacturing license under part 52 of this chapter must have a description and analysis of the fire protection design features for the standard plant necessary to demonstrate compliance with Criterion 3 of Appendix A to this part.
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| General Design Criterion 3 Table 5-2 GDC 3 - Applicability/Compliance Reference GDC 3, Fire Protection, Statement Applicability/Compliance Reference Structures, systems, and components important to safety NFPA 805 Chapters 3 and 4 shall be designed and located to minimize, consistent with LAR Attachments A and C NEI 04-02 B-1 and B-3 other safety requirements, the probability and effect of fires Tables and explosions.
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| Noncombustible and heat resistant materials shall be used NFPA 805 Sections 3.3.2, 3.3.3, 3.3.4, 3.11.4 wherever practical throughout the unit, particularly in LAR Attachment A NEI 04-02 B-1 Table locations such as the containment and control room.
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| Fire detection and fighting systems of appropriate capacity NFPA 805 Chapters 3 and 4 and capability shall be provided and designed to minimize LAR Attachments A and C NEI 04-02 B-1 and B-3 the adverse effects of fires on structures, systems, and Tables components important to safety.
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| Firefighting systems shall be designed to assure that their NFPA 805 Sections 3.4 through 3.10 and 4.2.1 rupture or inadvertent operation does not significantly impair LAR Attachment C NEI 04-02 Table B-3 the safety capability of these structures, systems, and components.
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| 10 CFR 50.48(c)
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| Table 5-3 10 CFR 50.48(c) - Applicability/Compliance Reference 10 CFR 50.48(c) Section(s) Applicability/Compliance Reference (1) Approval of incorporationby reference. National Fire Protection General Information. NFPA Association (NFPA) Standard 805, "Performance-Based Standard for Fire 805 (2001 edition) is the Protection for Light Water Reactor Electric Generating Plants, 2001 edition used.
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| Edition" (NFPA 805), which is referenced in this section, was approved for incorporation by reference by the Director of the Federal Register pursuant to 5 U.S.C. 552(a) and 1 CFR part 51.
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| (2) Exceptions, modifications, and supplementation of NFPA 805. As used in General Information. NFPA this section, references to NFPA 805 are to the 2001 Edition, with the 805 (2001 edition) is the following exceptions, modifications, and supplementation: edition used.
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| (i) Life Safety Goal, Objectives, and Criteria.The Life Safety Goal, The Life Safety Goal, Objectives, and Criteria of Chapter 1 are not endorsed. Objectives, and Criteria of Chapter 1 of NFPA 805 are not part of the CNS LAR.
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| Page 66
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| KIýIýrneLn n
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| D ,hi.
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| U ~
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| kli^ D^-ýr JVILIL r)io+r;^#
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| firr tt ~Q PKIC KIC:DA Jl.JfUIf k~ A 95 ~t QOr Trnný;#;^n Trn~~rn~..,c uIIIJ Dý ^
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| be~'
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| Table 5-3 10 CFR 50.48(c) - Applicability/Compliance Reference 10 CFR 50.48(c) Section(s) Applicability/Compliance Reference (ii)PlantDamage/Business Interruption Goal, Objectives, and Criteria.The The Plant Damage/Business Plant Damage/Business Interruption Goal, Objectives, and Criteria of Interruption Goal, Objectives, Chapter 1 are not endorsed. and Criteria of Chapter 1 of NFPA 805 are not part of the CNS LAR.
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| (iii) Use of feed-and-bleed. In demonstrating compliance with the Not applicable. CNS is a performance criteria of Sections 1.5. 1(b) and (c), a high-pressure BWR.
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| charging/injection pump coupled with the pressurizer power-operated relief valves (PORVs) as the sole fire-protected safe shutdown path for maintaining reactor coolant inventory, pressure control, and decay heat removal capability (i.e., feed-and-bleed) for pressurized-water reactors (PWRs) is not permitted.
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| (iv) Uncertainty analysis. An uncertainty analysis performed in accordance Uncertainty analysis was not with Section 2.7.3.5 is not required to support deterministic approach performed for deterministic calculations. methodology.
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| (v) Existing cables. In lieu of installing cables meeting flame propagation Electrical cable construction tests as required by Section 3.3.5.3, a flame-retardant coating may be complies with a flame applied to the electric cables, or an automatic fixed fire suppression propagation test that was system may be installed to provide an equivalent level of protection. In found acceptable to the NRC addition, the italicized exception to Section 3.3.5.3 is not endorsed. as documented in Attachment A.
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| (vi) Water supply and distribution. The italicized exception to Section 3.6.4 See Attachment A.
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| is not endorsed. Licensees who wish to use the exception to Section 3.6.4 must submit a request for a license amendment in accordance with paragraph (c)(2)(vii) of this section.
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| (vii) Performance-based methods. Notwithstanding the prohibition in The use of performance-Section 3.1 against the use of performance-based methods, the fire based methods for NFPA 805 protection program elements and minimum design requirements of Chapter 3 is requested by Chapter 3 may be subject to the performance-based methods permitted NPPD. See Attachment L.
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| elsewhere in the standard. Licensees who wish to use performance-based methods for these fire protection program elements and minimum design requirements shall submit a request in the form of an application for license amendment under § 50.90. The Director of the Office of Nuclear Reactor Regulation, or a designee of the Director, may approve the application ifthe Director or designee determines that the performance-based approach; (A) Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release; (B) Maintains safety margins; and (C) Maintains fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).
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| Page 67
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| Njmhrn-_k-n P"Infir Prmiar niefrirf Ka=PA qnl; Trnnaifinn Pm ^rf Table 5-3 10 CFR 50.48(c) - Applicability/Compliance Reference 10 CFR 50.48(c) Section(s) Applicability/Compliance Reference (3) Compliance with NFPA 805. See below (i) A licensee may maintain a fire protection program that complies with The CNS LAR was submitted NFPA 805 as an alternative to complying with paragraph (b) of this section in accordance with for plants licensed to operate before January 1, 1979, or the fire protection 10 CFR 50.90. The CNS LAR license conditions for plants licensed to operate after January 1, 1979. The included applicable license licensee shall submit a request to comply with NFPA 805 in the form of an conditions, orders, technical application for license amendment under § 50.90. The application must specifications/bases that identify any orders and license conditions that must be revised or needed to be revised and/or superseded, and contain any necessary revisions to the plant's technical superseded.
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| specifications and the bases thereof. The Director of the Office of Nuclear Reactor Regulation, or a designee of the Director, may approve the application if the Director or designee determines that the licensee has identified orders, license conditions, and the technical specifications that must be revised or superseded, and that any necessary revisions are adequate. Any approval by the Director or the designee must be inthe form of a license amendment approving the use of NFPA 805 together with any necessary revisions to the technical specifications.
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| (ii)The licensee shall complete its implementation of the methodology in The CNS LAR and transition Chapter 2 of NFPA 805 (including all required evaluations and analyses) report summarize the and, upon completion, modify the fire protection plan required by evaluations and analyses paragraph (a) of this section to reflect the licensee's decision to comply performed in accordance with with NFPA 805, before changing its fire protection program or nuclear Chapter 2 of NFPA 805.
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| power plant as permitted by NFPA 805.
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| (4) Risk-informed or performance-based alternatives to compliance with NFPA 805. A licensee may submit a request to use risk-informed or performance- No risk-informed or based alternatives to compliance with NFPA 805. The request must be in performance-based the form of an application for license amendment under § 50.90 of this alternatives to compliance chapter. The Director of the Office of Nuclear Reactor Regulation, or with NFPA 805 (per designee of the Director, may approve the application ifthe Director or 10 CFR 50.48(c)(4)) were designee determines that the proposed alternatives: utilized by NPPD.
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| (i) Satisfy the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release; (ii)Maintain safety margins; and (iii) Maintain fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).
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| 5.2 Regulatory Topics 5.2.1 License Condition Changes The current CNS Fire Protection Operating License Condition 2.C(4) is being replaced with the standard license condition based upon Regulatory Position 3.1 of RG 1.205, as shown in Attachment M.
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| Page 68
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| Mahrnekn P"Win Pnwnr niefri M~hraQL fk~r,-*C~k~ Piihli- P1IA~r
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| ('K14Z KIPPA Af)r, Trnneifinn Pm r%
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| kIPA ~AiTr~ni~in PnnV L 5.2.2 Technical Specifications NPPD conducted a review of the Technical Specifications to determine which Technical Specifications are required to be revised, deleted, or superseded. NPPD determined that the changes to the Technical Specifications and applicable justification listed in Attachment N are adequate for the CNS adoption of the new fire protection licensing basis.
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| 5.2.3 Orders and Exemptions A review was conducted of the NPPD docketed correspondence to determine if there were any orders or exemptions that needed to be superseded or revised. A review was also performed to ensure that compliance with the physical protection requirements, security orders, and adherence to those commitments applicable to the plant are maintained. A discussion of affected orders and exemptions is included in Attachment 0.
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| 5.3 Regulatory Evaluations 5.3.1 No Significant Hazards Consideration A written evaluation of the significant hazards consideration of a proposed license amendment is required by 10 CFR 50.92. According to 10 CFR 50.92, a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:
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| * Involve a significant increase in the probability or consequences of an accident previously evaluated; or
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| " Create the possibility of a new or different kind of accident from any accident previously evaluated; or
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| * Involve a significant reduction in a margin of safety.
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| This evaluation is contained in Attachment Q.
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| Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. NPPD has evaluated the proposed amendment and determined that it involves no significant hazards consideration.
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| 5.3.2 Environmental Consideration Pursuant to 10 CFR 51.22(b), an evaluation of the proposed amendment has been performed to determine whether it meets the criteria for categorical exclusion set forth in 10 CFR 51.22(c).
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| That evaluation is discussed in Attachment R. The evaluation confirms that the proposed amendment meets the criteria set forth in 10 CFR 51.22(c)(9) for categorical exclusion from the need for an environmental impact assessment or statement.
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| 5.4 Revision to the Updated Safety Analysis Report After the approval of the LAR, in accordance with 10 CFR 50.71(e), the CNS USAR will be revised. The CNS Updated Safety Analysis Report is not formatted per RG 1.70, but will incorporate the applicable subject matter described in FAQ 12-0062, at a level of detail consistent with NEI 98-03, "Guidelines for Updating Final Safety Analysis Reports." See Implementation Item S-26 of Attachment S, Table S-3.
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| Page 69
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| Nebras~ka Public Power flktrit Ct'Jq NFiPA Aml; Trnnc~ifinn Pa nrf 5.5 Transition Implementation Schedule NPPD proposes a six-month implementation period for the transition of CNS to the new fire protection licensing basis. Pursuant to this, the following activities are planned:
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| * NPPD commits to the specific actions identified in Table S-3 of Attachment S to Enclosure 1, within six months after issuance of the NFPA 805 License Amendment.
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| * NPPD will complete implementation of the required modifications identified in Table S-2 of Attachment S to the Transition Report prior to startup from the first refueling outage greater than 12 months following the issuance of the NFPA 805 License Amendment.
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| Appropriate compensatory measures will be maintained until modifications are complete.
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| Page 70
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| K1,mkrncL-n P"Win DrxAigmrniofrL-+
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| I'd~kraka f~c~rir+ mmhar n~A~r
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| ('KI(Z KIP713A AOR Trnnei+inn Pn n (MQ ~ID £~A Trnc~tirn ParU
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| ==6.0 REFERENCES==
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| The following references were used in the development of the Transition Report. Additional references are in the NEI 04-02 Tables in the various Attachments.
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| : 1. NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition.
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| : 2. NEI 04-02, Revision 2, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)," April 2008.
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| : 3. Regulatory Guide 1.205, Revision 1, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants," December 2009.
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| : 4. Letter from Randall K. Edington (NPPD) to U.S. NRC, dated December 22, 2005, "Letter of Intent to Adopt NFPA 805 - Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition" (NLS2005109), (Agency-wide Document Access and Management System (ADAMS) Accession Number ML053640280)
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| : 5. Letter from Catherine Haney (U.S. NRC) to Randall K. Edington (NPPD), dated March 7, 2006, "NRC Response to Nebraska Public Power District's Letter of Intent to Adopt 10 CFR 50.48(c) (NFPA 805 Rule) for Cooper Nuclear Station (CNS)." (ADAMS Accession Number ML060250510)
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| : 6. Letter from Catherine Haney (U.S. NRC) to Randall K. Edington (NPPD), dated October 30, 2006, "Period of Enforcement Discretion During Implementation of National Fire Protection Association Standard 805, Cooper Nuclear Station." (ADAMS Accession Number ML063050556)
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| : 7. Letter from Stewart B. Minahan (NPPD) to U.S. NRC, dated September 19, 2008, "Request for Extension of Enforcement Discretion and Revised Submittal Date for 10 CFR 50.48(c) License Amendment Request" (NLS2008079). (ADAMS Accession Number ML082700460)
| |
| : 8. Letter from Joseph G. Guitter (U.S. NRC) to Stewart B. Minahan (NPPD), dated December 19, 2008, "Evaluation of the Request for an Extension of Enforcement Discretion in Accordance with the Interim Enforcement Policy for Fire Protection Issues During Transition to National Fire Protection Standard NFPA 805 (TAC No. MD9823)."
| |
| (ADAMS Accession Number ML083510309)
| |
| : 9. Letter from John Stang (U.S. NRC) to T. Preston Gillespie (Duke Energy Carolinas, LLC),
| |
| dated December 29, 2010, "Oconee Nuclear Station, Units 1, 2, and 3, Issuance of Amendments Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program In Accordance With 10 CFR 50.48(c) (TAC Nos. ME3844, ME3845, and ME3846)." (ADAMS Accession Number ML103630612)
| |
| : 10. Letter from Brian J. O'Grady (NPPD) to U.S. NRC, dated June 27, 2011, "Revised Submittal Date for 10 CFR 50.48(c) License Amendment Request and Request for Extension of Enforcement Discretion" (NLS2011057).
| |
| : 11. Letter from Joseph G. Giitter (U.S. NRC) to Brian J. O'Grady (NPPD), dated July 28, 2011, "Cooper Nuclear Station - Commitment to Submit a License Amendment Request to Transition to 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805, and Request to Extend Enforcement Discretion (TAC No. ME6680)." (ADAMS Accession Number ML112030840)
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| Page 71
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| | |
| Mimhr-k-n PHhlir- Power DiQtrir-f rlN-q NFPA Rn-rF Transition Rcannrf
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| : 12. NUREG/CR-6850, "EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities,"
| |
| September 2005.
| |
| : 13. Letter from Roger S. Boyd (U.S. NRC), dated May 3, 1976.
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| : 14. Letter from Victor Stello (U.S. NRC) to J. M. Pilant (NPPD), dated May 11, 1976, "Cooper Nuclear Station."
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| : 15. Letter from Karl R. Goller (U.S. NRC) to J. M. Pilant (NPPD), dated September 30, 1976, "Cooper Nuclear Station."
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| : 16. Letter from Jay M. Pilant (NPPD) to D. L. Ziemann (U.S. NRC), dated December 17, 1976, "Response to Appendix A to Branch Technical Position APCB 9.5-1 Guidelines for Fire Protection for Nuclear Power Plants."
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| : 17. Letter from Jay M. Pilant (NPPD) to D. L. Ziemann (U.S. NRC), dated March 31, 1977, "Fire Hazard Analysis Response to Appendix A to Branch Technical Position APCSB 9.5-1 Guidelines for Fire Protection for Nuclear Power Plants."
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| : 18. Letter from Jay M. Pilant (NPPD) to D. L. Ziemann (U.S. NRC), dated April 6,1977, "Revisions and Additional Information Fire Protection Review."
| |
| : 19. Letter from Jay M. Pilant (NPPD) to D. L. Ziemann (U.S. NRC), dated February 4, 1977, "Proposed Change to the Radiological Technical Specifications."
| |
| : 20. Letter from Jay M. Pilant (NPPD) to Don K. Davis (U.S. NRC), dated July 20, 1977, "Proposed Change to the Radiological Technical Specifications."
| |
| : 21. Letter from Jay M. Pilant (NPPD) to Don K. Davis (U.S. NRC), dated December 19, 1977, "Proposed Changes to the Radiological Technical Specifications."
| |
| : 22. Letter from Jay M. Pilant (NPPD) to George E. Leer (U.S. NRC), dated May 11, 1978, "Fire Protection Program."
| |
| : 23. Letter from Jay M. Pilant (NPPD) to Victor Stello (U.S. NRC), dated June 21, 1978.
| |
| : 24. Letter from Jay M. Pilant (NPPD) to Thomas A. Ippolito (U.S. NRC), dated August 16, 1978, "Fire Protection/Request for Additional Information."
| |
| : 25. Letter from Jay M. Pilant (NPPD) to Thomas A. Ippolito (U.S. NRC), dated December 11, 1978, "Fire Inspection Review Response."
| |
| : 26. Letter from Jay M. Pilant (NPPD) to Thomas A. Ippolito (U.S. NRC), dated April 12, 1979, "Fire Protection Program/Fire Brigade Training."
| |
| : 27. Letter from Karl R. Goller (U.S. NRC) to J. M. Pilant (NPPD), dated November 29, 1977, "Cooper Nuclear Station."
| |
| : 28. Letter from Thomas A. Ippolito (U.S. NRC) to J. M. Pilant (NPPD), dated May 23, 1979.
| |
| : 29. Letter from Jay M. Pilant (NPPD) to Thomas A. Ippolito (U.S. NRC), dated October 22, 1979, "Fire Protection Technical Specification Changes."
| |
| : 30. Letter from Jay M. Pilant (NPPD) to Thomas A. Ippolito (U.S. NRC), dated January 16, 1980, "Fire Protection Modifications."
| |
| : 31. Letter from Thomas A. Ippolito (U.S. NRC) to J. M. Pilant (NPPD), dated November 21, 1980.
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| : 32. Letter from Jay M. Pilant (NPPD) to Domenic B. Vassallo (U.S. NRC), dated June 28, 1982, "Fire Protection Rule 10CFR50, Appendix R" (LQA8200158).
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| Page 72
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report
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| : 33. Letter from Jay M. Pilant (NPPD) to Domenic B. Vassallo (U.S. NRC), dated December 2, 1983, "Response to 10CFR50, Appendix R, 'Fire Protection of Safe Shutdown Capability - Volume IIl"' (LQA8300256).
| |
| : 34. Letter from Domenic B. Vassallo (U.S. NRC) to J. M. Pilant (NPPD), dated April 16, 1984, "Safety Evaluation for Appendix R to 10 CFR 50, Items II.G.3 and Ill.L, Alternate or Dedicated Shutdown Capability."
| |
| : 35. Letter from Michael T. Coyle (NPPD) to U.S. NRC, dated July 29, 2002, "Safety Evaluation For Appendix R to 10 CFR Part 50, Items II.G.3 and IlL, Alternate or Dedicated Shutdown Capability Clarification" (NLS2002085).
| |
| : 36. Letter from Jay M. Pilant (NPPD) to Domenic B. Vassallo (U.S. NRC), dated May 9, 1985, "Appendix R Analysis of Cooper Nuclear Station" (NLS8500085).
| |
| : 37. Letter from Jay M. Pilant (NPPD) to Domenic B. Vassallo (U.S. NRC), dated June 7, 1985, "Appendix R - Schedular Exemptions; Request for."
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| : 38. Letter from Hugh L. Thompson (U.S. NRC) to J. M. Pilant (NPPD), dated August 21, 1985, "Outstanding Fire Protection Modifications."
| |
| : 39. Letter from Domenic B. Vassallo (U.S. NRC) to J. M. Pilant (NPPD), dated April 29, 1983, "Cooper Nuclear Station."
| |
| : 40. Letter from Byron L. Siegel (U.S. NRC) to J. M. Pilant (NPPD), dated June 1, 1984.
| |
| : 41. Letter from Ernest D. Sylvester (U.S. NRC) to J. M. Pilant (NPPD), dated January 3, 1985.
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| : 42. Letter from William 0. Long (U.S. NRC) to J.M. Pilant (NPPD), dated April 10, 1986.
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| : 43. Letter from William 0. Long (U.S. NRC) to J. M. Pilant (NPPD), dated September 9, 1986.
| |
| : 44. Letter from Paul W. O'Connor (U.S. NRC) to George A. Trevors (NPPD), dated November 7, 1988, "Cooper Nuclear Station -Amendment No. 126 to Facility Operating License No. DPR-46 (TAC No. 67835)."
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| : 45. Letter from Paul W. O'Connor (U.S. NRC) to George A. Trevors (NPPD), dated February 3, 1989, "Cooper Nuclear Station -Amendment No. 127 to Facility Operating License No. DPR-46 (TAC No. 65623)."
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| : 46. Letter from Jack Donohew (U.S. NRC) to G. R. Horn (NPPD), dated July 31,1998, "Conversion to Improved Technical Specifications for the Cooper Nuclear Station -
| |
| Amendment No. 178 to Facility Operating License No. DPR-46 (TAC No. M98317)."
| |
| : 47. Letter from G. R. Horn (NPPD) to U.S. Nuclear Regulatory Commission, dated December 16, 1994, "Fire Protection Program Commitment Revision" (NLS940085).
| |
| : 48. Letter from James R. Hall (U.S. NRC) to Guy R. Horn (NPPD), dated August 15, 1995, "Revocation of Exemption From 10 CFR Part 50, Appendix R - Cooper Nuclear Station (TAC No. M91269)."
| |
| : 49. Letter from Domenic B. Vassallo (U.S. NRC) to L. G. Kuncl (NPPD), dated September 21, 1983, "Exemption Requests - 10 CFR 50.48 Fire Protection and Appendix R to 10 CFR Part 50."
| |
| : 50. Letter from Jay M. Pilant (NPPD) to Domenic B. Vassallo (U.S. NRC), dated March 18, 1983, "Fire Protection Rule 10 CFR 50, Appendix R, Preliminary Supplemental Response (Revised)" (LQA8300109).
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| Page 73
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report
| |
| : 51. Letter from Jay M. Pilant (NPPD) to Domenic B. Vassallo (U.S. NRC), dated June 2, 1983, "Fire Protection Rule 10 CFR 50, Appendix R, Preliminary Supplemental Response (Revision 2)."
| |
| : 52. Letter from Sunil Weerakkody (U.S. NRC) to Alexander Marion (NEI), dated July 12, 2006, "Process for Frequently Asked Questions For Title 10 of the Code of Federal Regulations, Part 50.48(c) Transitions." (ADAMS Accession Number ML061660105)
| |
| : 53. NRC Regulatory Issue Summary 2007-19, "Process For Communicating Clarifications of Staff Positions Provided In Regulatory Guide 1.205 Concerning Issues Identified During the Pilot Application of National Fire Protection Association Standard 805," dated August 20, 2007. (ADAMS Accession Number ML071590227)
| |
| : 54. NEI 00-01, Revision 1, "Guidance for Post-Fire Safe Shutdown Circuit Analysis," January 2005.
| |
| : 55. FAQ 07-0030. Revision 5, dated November 4, 2010, "Establishing Recovery Actions."
| |
| (ADAMS Accession Number ML103090602)
| |
| : 56. FAQ 07-0038, Revision 3, dated November 4, 2010, "Lessons Learned on Multiple Spurious Operations." (ADAMS Accession Number ML103090608)
| |
| : 57. FAQ 08-0054, Revision 1, dated December 17, 2010, "Demonstrating Compliance with Chapter 4 of NFPA 805." (ADAMS Accession Number ML103510379)
| |
| : 58. FAQ 07-0040, Revision 4, dated July 24, 2008, "Non-Power Operations Clarifications."
| |
| (ADAMS Accession Number ML082070249)
| |
| : 59. FAQ 09-0056, Revision 2, dated September 23, 2010, "Radioactive Release Transition."
| |
| (ADAMS Accession Number ML102810600)
| |
| : 60. ASME/ANS RA-Sa 2009, "Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications," American Society of Mechanical Engineers, New York, NY, and American Nuclear Society, La Grange Park, IL, 2009.
| |
| : 61. Regulatory Guide 1.200, Revision 2, "An Approach For Determining the Technical Adequacy of Probabilistic Risk Assessment Results For Risk-Informed Activities," March 2009.
| |
| : 62. EPRI 1016735, "Fire PRA Methods Enhancements-Additions, Clarifications, and Refinements to EPRI 1019189," Interim Report, December 2008.
| |
| : 63. NUREG-1921, "EPRI/NRC-RES Fire Human Reliability Analysis Guidelines," Draft Report for Comment, November 2009.
| |
| : 64. FAQ 10-0059, Revision 5, dated February 10, 2012, "NFPA 805 Monitoring." (ADAMS Accession Number ML120410589)
| |
| : 65. Cooper Nuclear Station Quality Assurance Program for Operation - Policy Document, Revision 21, dated April 16, 2010.
| |
| : 66. FAQ 07-0032, Revision 2, dated May 9, 2008, "Clarification of 10 CFR 50.48(c), 50.48(a),
| |
| and GDC 3." (ADAMS Accession Number ML081300697)
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| Page 74
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| Klnhrnelen D"Win PrmAidar r)ic+rif-f (CKQ KIPDA QnsL Trnno-ifie-n Pganrr+ - A**n-hrm~nt A ATTACHMENT A NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements 80 Pages Page A-1
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| | |
| Nebraska Public Power District NebrastCNS NFPA 805 Transition Reort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.1 General This chapter contains the N/A CNS compliance with the Fire None fundamental elements of the fire Protection Program elements protection program and specifies and minimum design the minimum design requirements requirements presented in for fire protection systems and NFPA 805 Chapter 3 is not features. These fire protection based on the performance-program elements and minimum based methods permitted design requirements shall not be elsewhere in the standard. The subject to the performance-based following discussion of Chapter methods permitted elsewhere in 3 requirements documents CNS this standard. Previously approved compliance or intended alternatives from the fundamental compliance with the individual protection program attributes of this code sections. In addition, chapter by the AHJ take documentation is provided precedence over the requirements where previous NRC approval contained herein. has been granted for a deviation to the code.
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| 3.2 Fire Protection Plan N/A N/A Section Heading - See None compliance bases below for compliance statements for specific subsections.
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| 3.2.1 Intent A site-wide fire protection plan shall Complies Procedure 0.23 establishes a Procedure 0.23, Rev. 64, CNS Fire be established. This plan shall Fire Protection Program for the Protection Plan document management policy and plant. This procedure describes program direction and shall define the functional responsibilities the responsibilities of those and administrative controls for individuals responsible for the implementing the CNS Fire plan's implementation. This section Protection Program.
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| establishes the criteria for an integrated combination of components, procedures, and personnel to implement all fire protection program activities.
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| 3.2.2 Management A policy document shall be Complies Procedure 0.23 establishes the Procedure 0.23, Rev. 64, CNS Fire Policy Direction and prepared that defines management general policy for the site Fire Protection Plan Responsibility authority and responsibilities and Protection Program, Attachment establishes the general policy for 6, Section 2, defines the the site fire protection program. administrative controls and departmental responsibilities.
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| 3.2.2.1 [Management The policy document shall Complies Procedure 0.23 establishes that Procedure 0.23, Rev. 64, CNS Fire Policy on Senior designate the senior management the Vice President-Nuclear and Protection Plan Page A-2
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Management] position with immediate authority Chief Nuclear Officer is and responsibility for the fire ultimately responsible for the FP protection program. Program including the implementation of functional elements of the program.
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| 3.2.2.2 [Management The policy document shall Complies Procedure 0.23, Attachment 6, Procedure 0.23, Rev. 64, CNS Fire Policy on Daily designate a position responsible for Paragraph 2.9 states that the FP Protection Plan Administration] the daily administration and Manager is responsible for the coordination of the fire protection daily administration and program and its implementation. coordination of the program.
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| Procedure 0.23, Attachment 6, Section 2.9.1, states that the FP Manager shall be, or have within his organization, a qualified FP Engineer. The FP Program Engineer is able to meet the requirements for TQD-0986 Fire Protection Program Engineer.
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| 3.2.2.3 [Management The policy document shall define Complies Procedure 0.23, Attachment 6, Procedure 0.23, Rev. 64, CNS Fire Policy on Interfaces] the fire protection interfaces with Section 2 outlines the Fire Protection Plan other organizations and assign Protection Program responsibilities for the coordination organization, which includes the of activities. In addition, this policy Vice President-Nuclear and document shall identify the various Chief Nuclear Officer, General plant positions having the authority Manager of Plant Operations, for implementing the various areas and Director of Engineering.
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| of the fire protection program. These positions have the authority for implementing the various areas of the Fire Protection Program. Procedure 0.23 also defines the fire protection interfaces with other organizations and the responsibilities for the coordination of activities.
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| 3.2.2.4 [Management The policy document shall identify Complies with Required The Authority Having Procedure 0.23, Rev. 64, CNS Fire Policy on AHJ] the appropriate AHJ for the various Action Jurisdiction (AHJ) (e.g. NRC, Protection Plan areas of the fire protection program. NEIL, etc.) is not identified in Procedure 0.23, CNS Fire Protection Plan.
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| Page A-3
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| Nebraska Public Power District Neb.NS NFPA 805 Transition Re.ort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Implementation Item S-3.9 -
| |
| Revise Procedure 0.23 to identify the AHJ for the various areas of the Fire Protection Program. See Attachment S, Table S-3.
| |
| 3.2.3 Procedures Procedures shall be established for Complies CNS Technical Specification CNS Technical Specifications, implementation of the fire protection (TS) 5.4.1 d requires that written through License Amendment 241 program. In addition to procedures procedures be established, that could be required by other implemented, and maintained sections of the standard, the for fire protection program procedures to accomplish the implementation.
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| following shall be established:
| |
| Note - This License Amendment Request deletes TS 5.4.1d. See Attachment N.
| |
| 3.2.3 Procedures (1) Inspection, testing, and Complies with Required Inspection, testing, and CNS Technical Requirements maintenance for fire protection Action maintenance requirements for Manual, Rev. 10/28/11 systems and features credited by credited fire protection systems the fire protection program and features are described in the Technical Requirements Manual (TRM), a document incorporated by reference into the CNS Updated Safety Analysis Report. This includes surveillances for the fire main, automatic suppression systems, high pressure carbon dioxide extinguishing system, Halon suppression system, fire detection systems, standpipe and hose systems, fire pumps, fire barriers, and penetration seals. The fire protection systems and features are inspected, tested, and maintained in accordance with the 6, 7, and 15 series of CNS Procedures.
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| Implementation Item S-3.1 -
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| Page A-4
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document During the implementation of the NFPA 805 licensing basis, performance-based surveillance frequencies will be established as described in Electric Power Research Institute (EPRI)
| |
| Technical Report (TR) 1006756, "Fire Protection Surveillance Optimization and Maintenance Guide for Fire Protection Systems and Features". The performance-based surveillance frequencies will be evaluated in the monitoring program in accordance with NFPA 805 FAQ 10-0059. See Attachment S, Table S-3.
| |
| 3.2.3 Procedures (2) Compensatory actions implemented Complies The TRM establishes the limits CNS Technical Requirements when fire protection systems and on impairment duration of the Manual, Rev. 10/28/11 other systems credited by the fire credited fire protection features.
| |
| protection program and this CNS Procedure 0.23 Procedure 0.23, Rev. 64, CNS Fire standard cannot perform their implements these TRM limits on Protection Plan intended function and limits on impairment duration and impairment duration establishes the required Procedure 0.39.1, Rev. 7, Fire compensatory actions. Watches and Fire Impairments Procedure 0.23, Section 6.1, requires that impairments to fire protection features be minimized to maintain the greatest level of readiness possible. When features are impaired, compensatory measures are commonly required to provide an acceptable level of protection. CNS license requirements dictate specific compensatory measures for specific impairments. The Impairments and Compensatory Measures Matrix, Attachment 1, Page A-5
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document describes conditions when fire impairments may be needed and the associated compensatory action. Section 6.2 requires that when a fire protection discrepancy is noted that causes an impairment, corrective actions are initiated to restore the impaired fire protection feature as soon as possible.
| |
| Procedure 0.39.1 provides criteria for issuing Fire Protection Impairment Permits for reporting, tracking, providing compensatory measures, and ensuring restoration of impaired features.
| |
| 3.2.3 Procedures (3) Reviews of fire protection Complies Per Procedure 0.23, the Fire EN-DC-329, Rev. 4C0, Engineering program - related performance Protection System Engineer is Programs Control and Oversight and trends responsible for equipment trends associated with the FP Procedure 0.23, Rev. 64, CNS Fire Systems. Protection Plan Procedure 0-CNS-64 identifies Procedure 0-CNS-64, Rev. 3, System the objective of the System Health Teams Health Teams to produce timely and effective solutions to current and future reliability performance problems.
| |
| Procedure EN-DC-329 provides direction for the use of Program Notebooks, Program Health Reports, self assessments, benchmarks, and similar Management oversight tools.
| |
| 3.2.3 Procedures (4) Reviews of physical plant Complies Procedure 3.4 provides the EDP-06, Rev. 45, Supporting modifications and procedure requirements for Configuration Requirements for Configuration changes for impact on the fire Changes at CNS, including Change Control Page A-6
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document protection program identifying applicable interdepartment/interdiscipline Procedure 0.4, Rev. 55, Procedure reviews per Procedure 3.4.8. Change Process Procedure EDP-06 provides criteria for when a fire protection Procedure 0.8, Rev. 24, 10CFR50.59 review is required to support and 10CFR72.48 Reviews configuration changes.
| |
| Procedure 0.4 provides Procedure 0.29.4, Rev. 17, Other administrative controls over the Regulatory Reviews procedure change process at CNS. Procedures 0.8 and Procedure 3.3SAFE, Rev. 16, Safety 3.3SAFE identify when a 0.29.4 Assessment fire protection review is required.
| |
| Procedure 3.4, Rev. 54, Configuration Change Control Procedure 3.4.8, Rev. 19, Design Verification 3.2.3 Procedures (5) Long-term maintenance and Complies Procedure 0.23, Section 1.1 Procedure 0.23, Rev. 64, CNS Fire configuration of the fire protection describes the purpose of the Protection Plan program procedure to establish functional responsibilities and administrative controls for implementing the CNS Fire Protection Program as part of its Long Term Compliance Program to 10CFR50.48 (Appendix R). This includes meeting the requirements of:
| |
| Technical Specifications Administrative Controls, the TRM, the Updated Safety Analysis Report (USAR),
| |
| Appendix A to Branch Technical Position 9.5-1, NFPA codes and standards, and Nuclear Electric Insurance Limited (NEIL) requirements.
| |
| Procedure 0.23, Section 4.1 invokes the Configuration Page A-7
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Control process which contains design input considerations that are utilized to ensure configuration changes do not adversely affect the Fire Protection Design Basis, and ensure updates are performed to maintain the Fire Protection Long Term Compliance Program.
| |
| 3.2.3 Procedures (6) Emergency response procedures Complies Procedure 5.1 INCIDENT Procedure 5.1 INCIDENT, Rev. 21, for the plant industrial fire brigade contains emergency response Site Emergency Incident guidelines for the industrial fire brigade.
| |
| 3.3 Prevention A fire prevention program with the Complies Procedure 0.23, Section 3 Procedure 0.23, Rev. 64, CNS Fire goal of preventing a fire from establishes specific Protection Plan starting shall be established, requirements for a fire documented, and implemented as prevention program.
| |
| part of the fire protection program.
| |
| The two basic components of the fire prevention program shall consist of both of the following:
| |
| 3.3 Prevention (1) Prevention of fires and fire spread Complies Procedure 0.23, Step 3.1 Procedure 0.23, Rev. 64, CNS Fire by controls on operational activities provides requirements for Protection Plan control of ignition sources.
| |
| Procedure 0.39, Rev. 45, Hot Work Procedures 0.39 and 7.7.1 establish controls on operational Procedure 7.7.1, Rev. 15, Special activities in order to prevent Process Control Maintenance fires. Procedure 3.3 Prevention (2) Design controls that restrict the use Complies Procedure 0.23, Step 3.2 Procedure 0.23, Rev. 64, CNS Fire of combustible materials provides requirements for Protection Plan control of combustibles.
| |
| The design control requirements Procedure 3.4, Rev. 54, Configuration listed in the remainder of this Procedure 3.4 provides design Change Control section shall be provided as controls on the use of described. combustible materials.
| |
| 3.3.1 Fire Prevention for The fire prevention program Complies Procedure 0.7.1 provides Procedure 0.39, Rev. 45, Hot Work Operational Activities activities shall consist of the requirements and controls for necessary elements to address the use and staging of estimated Procedure 0.39.1, Rev. 7, Fire control of ignition sources and the amounts of transient Watches and Fire Impairments Page A-8
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document use of transient combustible combustible materials within the materials during all aspects of plant power block and other plant Procedure 0.7, Rev. 32, Chemical operations. The fire prevention areas. Procedure 0.39 Material Control program shall focus on the human establishes requirements for hot and programmatic elements work procedures, including Procedure 0.7.1, Rev. 30, Control of necessary to prevent fires from training and supervision. Combustibles starting or, should a fire start, to Procedure 0.39.1 establishes keep the fire as small as possible. requirements for fire watches Procedure 0.7.1.1, Rev. 1, Control of during hot work activities. Flammable Materials Lockers Procedure 0.7.1.1 provides requirements for liquids not in Procedure 7.3.61, Rev. 6, Temporary use to be stored in approved Power lockers. Procedure 0.7 provides guidance to control storage, handling, and use of chemical materials at CNS.
| |
| Procedure 7.3.61 requires that temporary power installations be controlled to ensure the installation is per approved standards, and that any temporary power installation that is in place > 90 days shall be inspected to ensure the installation has not degraded.
| |
| 3.3.1.1 General Fire The fire prevention activities shall Complies Plant procedures for general fire None Prevention Activities include but not be limited to the prevention activities have been following program elements: developed and implemented.
| |
| The procedures address, at a minimum, the fire protection program elements identified in the sections below, but are not limited to these elements. Upon review of these procedures, NPPD concludes that the NFPA 805 code requirements in the following subsections are satisfied.
| |
| 3.3.1.1 General Fire Training on fire safety information Complies with Site-Specific Plant Access GEN001-02-04, Rev. 29, Site-Specific Prevention Activities (1) for all employees and contractors Clarification Training GEN001-02-04 Plant Access Training Page A-9
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document including, as a minimum, provides training information on familiarization with plant fire fire reporting, plant fire alarms, NEI 04-02, "Guidance for prevention procedures, fire and general plant fire Implementing a Risk-Informed, reporting, and plant emergency prevention. In accordance with Performance-Based Fire Protection alarms the guidance in Section K.3 of Program under 10 CFR 50.48(c),"
| |
| NEI 04-02, this training complies Rev. 2 with the interpreted meaning of "familiarization with plant fire prevention procedures, fire reporting, and plant emergency alarms."
| |
| 3.3.1.1 General Fire Documented plant inspections Complies Procedure 0.23, Attachment 6, Procedure 0.23, Rev. 64, CNS Fire Prevention Activities (2) including provisions for corrective Paragraph 2.12 describes that Protection Plan actions for conditions where the Station Fire Marshal unanalyzed fire hazards are implements, maintains, and identified updates the Fire Protection administrative portion of the Fire Protection Program. The Fire Marshal performs these duties through implementation of the Hot Work and transient combustible procedures, plant fire tours, and for assuring compliance with the Fire Protection Program. Procedure 0.23, Section 8 requires that records which demonstrate conformance with Fire Protection requirements be maintained and retrievable through the Records Management System. The record types include inspections and tests, non-conformances, and deficiencies. Procedure 0.23 Step 6.6.1.4 requires that deficiencies requiring Alternative Compensatory Measures are documented within the Corrective Action Program.
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| 3.3.1.1 General Fire Administrative controls addressing Complies Procedure 0.23, Attachment 6, EDP-06, Rev. 45, Supporting Page A-10
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Prevention Activities (3) the review of plant modifications Paragraph 2.10 describes the Requirements for Configuration and maintenance to ensure that Fire Protection Program Change Control both fire hazards and the impact on Engineer as being responsible plant fire protection systems and for reviews of Change Procedure 0.23, Rev. 64, CNS Fire features are minimized Evaluation Documents and Protection Plan ensures the appropriate Fire Protection Program Procedure 0.40, Rev. 82, Work documentation is updated as a Control Program result. Attachment 6, Paragraph 2.12 requires that the Station Fire Marshal implements, maintains, and updates the Fire Protection administrative portion of the Fire Protection Program.
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| As part of this responsibility, the Fire Marshal reviews implementation of the Hot Work and transient combustible procedures, performs plant fire tours assuring compliance with the Fire Protection Program, and performs the pre- and post-maintenance reviews of fire protection-related Work Orders.
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| EDP-06 provides controls for fire protection review of plant modifications. Procedure 0.40, Attachment 5, Section 4.18 describes the responsibilities of the Fire Protection Engineer to review the Fire Protection impact of maintenance activities.
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| 3.3.1.2 Control of Procedures for the control of Complies Procedure 0.23, Step 3.4 Procedure 0.23, Rev. 64, CNS Fire Combustible Materials general housekeeping practices requires that housekeeping Protection Plan and the control of transient inspections be periodically combustibles shall be developed performed by Plant Procedure 0.7.1, Rev. 30, Control of and implemented. These Management per Procedure 0- Combustibles procedures shall include but not be CNS-07-MGMT. Procedure limited to the following program 0.23, Step 3.2 provides Procedure 0-CNS-07-MGMT, Rev. 6, elements: requirements for control of Management Observation Program Page A-11
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document combustibles. Combustibles are controlled by Procedure 0.7.1.
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| Note: Plant procedures for the control of general housekeeping practices and the control of transient combustibles have been developed and implemented. The procedures address, at a minimum, the fire protection program elements identified in the sections below, but are not limited to these elements. Upon review of these procedures, NPPD concludes that the NFPA 805 code requirements in the following subsections are satisfied.
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| 3.3.1.2 Control of Wood used within the power block Submit for NRC Procedure 0.7.1, Section 4.3 Procedure 0.7.1, Rev. 30, Control of Combustible Materials shall be listed pressure- Approval provides guidelines for control of Combustibles (1) impregnated or coated with a listed Class A combustibles within the fire-retardant application. Power Block. The requirement for all wood to be treated with Exception: Cribbing timbers 6 in. by fire retardant is intended to 6 in. (15.2 cm by 15.2 cm) or larger apply to raw materials such as shall not be requiredto be fire- plywood and lumber products retardanttreated. and doesn't apply to commercially available products which utilize small quantities of wood as an integral part of a finished product (e.g., tools, janitorial supplies, special fixtures, M&TE, and office type furniture).
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| Per Section 4.3.4, bulk lumber at CNS is purchased through the procurement process, which requires lumber to be fire retardant pressure treated. If pressure impregnated wood is Page A-12
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document not available, Fire Protection personnel approval is required for using wood treated with surface applied chemicals. Per Section 4.3.6, heavy wood members with a cross-sectional area greater than 6" x 6" are not required to be treated with a fire retardant.
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| Refer to Attachment L for further details on the request for NRC approval of the use of commercially available products which utilize small quantities of non-treated wood as an integral part of a finished product (e.g.,
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| tools, janitorial supplies, special fixtures, M&TE, and office type furniture).
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| 3.3.1.2 Control of Plastic sheeting materials used in Complies Procedure 0.7.1, Section 4.3.7 Procedure 0.7.1, Rev. 30, Control of Combustible Materials the power block shall be fire- requires plastic film and fabrics Combustibles (2) retardant types that have passed used as sheeting material for NFPA 701, "Standard Methods of protective floor coatings, Fire Tests for Flame Propagation of contamination control, Textiles and Films", large-scale temporary enclosure, etc., shall tests, or equivalent be approved self-extinguishing fire retardant plastic sheeting (NFPA 701, UL Standard 214, or equivalent standard).
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| Attachment 5 of Procedure 0.7.1 details a list of acceptable plastics for use within the Power Block.
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| 3.3.1.2 Control of Waste, debris, scrap, packing Complies Procedure 0.7.1, Section 4.2.7 Procedure 0.7.1, Rev. 30, Control of Combustible Materials materials, or other combustibles requires waste, debris, scrap, oil Combustibles (3) shall be removed from an area spills, or other combustibles immediately following the resulting from the work activity, completion of work or at the end of should be removed promptly the shift, whichever comes first. following completion of the work or at the end of each shift, Page A-13
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| Nebraska Public Power District NebratCNS NFPA 805 Transition Re..ort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document whichever comes first. Per Section 4.4, when practical, equipment shipped in untreated combustible containers should be unpacked prior to plant entry.
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| When untreated combustible packing materials and shipping containers are unpacked in the plant. A Transient Combustible Evaluation is obtained for quantities of packing materials exceeding the threshold values for the associated plant area.
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| 3.3.1.2 Control of Combustible storage or staging Complies Procedure 0.7.1, Section 4.2.5 Procedure 0.7.1, Rev. 30, Control of Combustible Materials areas shall be designated, and requires that transient Combustibles (4) limits shall be established on the combustible materials should be types and quantities of stored located in designated storage Procedure 0.7.1.1, Rev. 1, Control of materials. areas or arranged so as to Flammable Materials Lockers minimize the fire hazard to cable trays and plant equipment.
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| Attachment 3 of Procedure 0.7.1 establishes the designated storage areas for combustibles.
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| Procedure 0.7.1.1, Attachment 2 establishes the maximum allowable size of flammable or combustible liquids in storage containers and portable tanks, as well as the maximum storage quantities for cabinets.
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| 3.3.1.2 Control of Controls on use and storage of Complies with use of Complies with use of EEEEs EE 10-071, Rev. 0, CNS Acceptance Combustible Materials flammable and combustible liquids Existing Engineering Plant procedures for the controls of EPM Report No: R1906-002-002, (5) shall be in accordance with NFPA Equivalency Evaluations on the use and storage of NFPA Code Conformance Review 30, "Flammable and Combustible (EEEEs) flammable and combustible Liquids Code, or other applicable liquids are in compliance with NEI 04-02, "Guidance for NFPA standards." Complies with the requirements of NFPA 30, Implementing a Risk-Informed, Clarification as documented in the NFPA Performance-Based Fire Protection 30-1973 code review checklist Program under 10 CFR 50.48(c),"
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| in Engineering Evaluation EE Rev. 2 10-071.
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| Page A-14
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Complies with Clarification No other NFPA Standards were determined to be applicable based on guidance in Nuclear Energy Institute (NEI) 04-02, Rev. 2, Section K.1 (FAQ 06-0020).
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| 3.3.1.2 Control of Controls on use and storage of Complies with use of Complies with use of EEEEs EE 10-071, Rev. 0, CNS Acceptance Combustible Materials flammable gases shall be in Existing Engineering Plant procedures for the controls of EPM Report No: R1906-002-002, (6) accordance with applicable NFPA Equivalency Evaluations on the use and storage of NFPA Code Conformance Review standards. (EEEEs) hydrogen are in compliance with the requirements of NFPA 50A, NEI 04-02, "Guidance for Complies with as documented in the NFPA Implementing a Risk-Informed, Clarification 50A-1973 code review checklist Performance-Based Fire Protection in Engineering Evaluation EE Program under 10 CFR 50.48(c),"
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| 10-071. Rev. 2 Complies with Clarification No other NFPA Standards were determined to be applicable based on guidance in Nuclear Energy Institute (NEI) 04-02, Rev. 2, Section K.1 (FAQ 06-0020).
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| 3.3.1.3 Control of Ignition N/A N/A Section Heading - See None Sources compliance bases below for compliance statements for specific subsections.
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| 3.3.1.3.1 [Control of A hot work safety procedure shall Complies with use of Hot work safety procedures are EE 10-071, Rev. 0, CNS Acceptance Ignition Sources - Code be developed, implemented, and Existing Engineering in compliance with the of EPM Report No: R1906-002-002, Requirements] periodically updated as necessary Equivalency Evaluations requirements of NFPA 51 B and NFPA Code Conformance Review in accordance with NFPA 51B, (EEEEs) NFPA 241, as documented in "Standard for Fire Prevention the NFPA 51 B-1 999 and NFPA During Welding, Cutting, and Other 241-2000 code review Hot Work", and NFPA 241, checklists in Engineering "Standard for Safeguarding Evaluation EE 10-071.
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| Construction, Alteration, and Demolition Operations."
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| 3.3.1.3.2 [Control of Smoking and other possible Complies Site-Specific Plant Access GEN001-02-04, Rev. 29, Site-Specific Ignition Sources - sources of ignition shall be Training GEN001-02-04 Plant Access Training Page A-15
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Smoking Limitations] restricted to properly designated requires that smoking is and supervised safe areas of the prohibited in all NPPD buildings, Procedure 0.23, Rev. 64, CNS Fire plant. facilities, vehicles, and aircraft. Protection Plan Smoking is permitted on NPPD property out-of-doors. Local management has the authority to designate areas for smoking out-of-doors. Procedure 0.23, Step 3.1 requires that ignition sources are controlled through Procedure 0.39, Hot Work.
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| 3.3.1.3.3 [Control of Open flames or combustion- Complies Procedure 0.23, Step 3.1 and Procedure 0.23, Rev. 64, CNS Fire Ignition Sources - Leak generated smoke shall not be Procedure 0.39, Step 3.2 state Protection Plan Testing] permitted for leak or air flow testing. that the use of ignition sources or combustion generated smoke Procedure 0.39, Rev. 45, Hot Work for leak testing is prohibited. A commercially approved aerosol technique shall be used for this purpose.
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| 3.3.1.3.4 [Control of Plant administrative procedure shall Complies with Required Administrative procedures do Procedure 0.39, Rev. 45, Hot Work Ignition Sources - control the use of portable electrical Action not establish controls on the use Portable Heaters] heaters in the plant. Portable fuel- of portable electrical heaters in fired heaters shall not be permitted the plant. Portable fuel-fired in plant areas containing equipment heaters are currently allowed important to nuclear safety or where inside buildings provided written there is a potential for radiological approval and guidance from releases resulting from a fire. FP/Designee is attained prior to commencing work per Procedure 0.39.
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| Implementation Item S-3.10 -
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| Administrative procedures will be revised to control the use of portable electric heaters, and revised to document that portable fuel-fired heaters are not permitted in plant areas containing equipment important to nuclear safety, or where there is a potential for radiological release resulting from a fire. See Page A-16
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Attachment S, Table S-3.
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| 3.3.2 Structural Walls, floors, and components Complies USAR Section XII-2.0 (Structural Cooper Nuclear Station Updated required to maintain structural Design) provides the Safety Analysis Report, loep xxv2 integrity shall be of noncombustible construction of the walls, floors, construction, as defined in NFPA and components required for 220, "Standard on Types of Building structural integrity. These Construction." material include concrete and steel which are noncombustible.
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| 3.3.3 Interior Finishes Interior wall or ceiling finish Complies Complies CNS Fire Hazards Analysis, Rev.
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| classification shall be in accordance CNS complies with NFPA 805, 9/26/2011 with NFPA 101, "Life Safety Code", Complies by Previous Section 3.3.3, except for NRC requirements for Class A materials. NRC Approval previous approval of plastic EE 12-009, Rev. 0, Acceptance of Interior floor finishes shall be in laminated particle board Unqualified Coatings within CNS accordance with NFPA 101 Submit for NRC installed within the Control requirements for Class I interior Approval Room and Computer Room. Letter dated 10/19/79, Fire Protection floor finishes. Modifications, from Pilant (NPPD) to The Fire Hazards Analysis Ippolito (NRC)
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| (FHA) requires all interior Letter dated 11/21/80, from Ippolito finishes to have a structural base of non-combustible (NRC) to Pilant (NPPD) material, with a surface not exceeding a thickness of 1/8" Plant Modification MDC 87-024 which has a flame spread rating of not >50 according to ASTM Procedure 0.7.1, Rev. 30, Control of E-84 testing procedures. This Combustibles definition meets the requirements of the NRC in Procedure 7.0.15, Rev. 14, Station NUREG-0800, CMEB 9.5-1, Painting Procedure Rev. 2, July 1981. Class A finishes as defined in NFPA 101 are those that have a flame spread index of less than or equal to 25 and a smoke developed index of less than or equal to 450.
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| Per Section 4.3.1 of Procedure 0.7.1, interior wall and structural components should be non-combustible or listed by a nationally recognized testing Page A-17
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Laboratory, such as Factory Mutual or Underwriters Laboratory, Inc., for flame spread of 25 or less and a smoke development of 50 or less.
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| Comolies by Previous NRC Approval CNS was originally constructed and licensed to the 1967 Draft General Design Criterion 3, and Branch Technical Position APCSB 9.5-1, Appendix A. The NRC approved this design based on the following:
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| The NPPD response to Branch Technical Position APCSB 9.5-1, Appendix A, dated 12/17/76, and a revised submittal dated 4/6/77 identified the use of a plastic laminate particle board used for the south, east, and north walls of the Control Room (Fire Zone 10B) and Computer Room (Fire Zone 1OA). Per letter dated 4/6/77, "Aplastic laminate is adhered to the particle board wall panels provided on the south, east, and north wall of the Control Room. This particle board is approximately 5/8" thick and is fastened to wood furring which is fastened to the concrete fire walls. As both rooms are provided with adequate manual back-up firefighting equipment, Automatic Fire Detection Systems (Products-of-Page A-18
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Combustion detectors), the Computer Room does not hose any safety related equipment, and the Control Room is constantly attended, no further action will be taken nor additional fire protection provided."
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| Section 3.15.2 of the CNS Fire Protection SER dated 5/23/79 stated "Certification will be obtained or tests performed to show that the particle board used in the control room has acceptable flame spread and smoke spread ratings."
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| Supplement 1 to the CNS Fire Protection SER dated 11/21/80 documented that this item was closed based on the flame spread rating test results per ANSI/ASTM E 84-77a provided by NPPD in a letter dated 10/19/79.
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| The plastic laminate particle board, as closed per Supplement 1 to the SER, is still installed at CNS. There have been no plant modifications or other changes that would invalidate the basis for approval.
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| The plastic laminate particle board features remain unchanged.
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| Submit for NRC Approval Attachment 3 of Procedure 7.0.15, Station Painting Procedure lists the Page A-19
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document paints/coatings that can be used. There are paints and coatings which do not have the necessary documentation to demonstrate testing under ASTM E-1 36 or an equivalent test method. EE 12-009 justifies the acceptability of these paints and coatings. Refer to Attachment L for further details on the request for NRC approval for the continued use of these unqualified paints and coatings.
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| 3.3.4 Insulation Materials Thermal insulation materials, Complies with Required Procedure 0.7.1, Section 4.3.1 DCD-40, Topical Reference radiation shielding materials, Action requires that interior wall and Information Manual, Thermal ventilation duct materials, and structural components, thermal Insulation, 2/2/09 soundproofing materials shall be insulation materials, radiation noncombustible or limited shielding materials, and Procedure 0.7.1, Rev. 30, Control of combustible. soundproofing should be non- Combustibles combustible or listed by a nationally recognized testing Procedure 7.0.13, Rev. 15, Control of Laboratory, such as Factory Insulation Removal and Installation Mutual or Underwriters Laboratory, Inc., for flame spread index of 25 or less and a smoke development index of 50 or less.
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| Procedure 7.0.13 states that insulation should be fabricated and installed per Topical Reference Information Manual DCD-40. DCD-40 states that all insulation installed should meet the minimum fire and smoke spread ratings.
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| Implementation Item S-3.21 -
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| Revise Procedure 0.7.1 to include the requirement for Page A-20
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document ventilation duct materials to be non-combustible or listed by a nationally recognized testing Laboratory, such as Factory Mutual or Underwriters Laboratory, Inc., for flame spread index of 25 or less and a smoke development index of 50 or less. See Attachment S, Table S-3.
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| 3.3.5 Electrical. Electrical N/A Section Heading - See None compliance bases below for compliance statements for specific subsections.
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| 3.3.5.1 [Electrical - Wiring above suspended ceiling Submit for NRC Procedure 0.7.1, Section 4.3.2 EDP-06, Rev. 45, Supporting Wiring Above shall be kept to a minimum. Where Approval requires that concealed spaces Requirements for Configuration Suspended Ceiling installed, electrical wiring shall be should be devoid of Change Control Limitations] listed for plenum use, routed in combustibles. Section 4.3.2.1 armored cable, routed in metallic states minor amounts of Procedure 0.7.1, Rev. 30, Control of conduit, or routed in cable trays with approved communications Combustibles solid metal top and bottom covers, cabling may be used within these concealed spaces. There are no significant amounts of wiring above suspended or dropped ceilings, and most of the wiring and cabling that is installed above the suspended or dropped ceiling is in conduit and/or meet one of the acceptable cable qualifications listed within FAQ 06-0022 Rev.
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| 3.
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| EDP-06, Attachment 1, Section F1 includes the requirements for electrical wiring above suspended ceilings and specifically references NFPA 805, Section 3.3.5.1 as part of the fire protection design considerations.
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| Page A-21
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| Nebraska Public Power District CNS NFPA 805 Transition ReDort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Some of the wiring installed above the suspended ceilings in the Power Block does not comply with the requirements of Section 3.3.5.1. The wiring in these locations that is not approved for plenum use and not installed in conduit includes lighting/power receptacle circuits, Gai-tronics cables, fire detection circuits and/or communication cables associated with computers, telephones, televisions, or projectors. Refer to Attachment L for further details on the request for NRC approval of the minimal amount of wiring located above suspended ceilings in the Power Block that are not approved for plenum use and not installed in conduit.
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| 3.3.5.2 [Electrical - Only metal tray and metal conduits Complies Complies Cooper Nuclear Station Updated Raceway Construction shall be used for electrical Procedure 7.3.55, Section 8.4 Safety Analysis Report, loep xxv2 Limits] raceways. Thin wall metallic tubing Submit for NRC requires that flexible conduit shall not be used for power, Approval runs shall be designed as short Procedure 7.3.55, Rev. 8, Raceway instrumentation, or control cables. as possible. Section VIII-4 Installation Flexible metallic conduits shall only (Auxiliary Power Distribution be used in short lengths to connect System) of the USAR requires components. the 4160 volt cables be installed in conduits and the 480 volt power cables and control cables be installed in conduit and metal trays. Section VIII-6 (125-250 Volt DC Power Systems) of the USAR requires the 125 and 250 Volt DC system cables be installed in conduits and metal trays.
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| Page A-22
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Submit for NRC Approval Refer to Attachment L for further details on the request for NRC approval of the use of plastic conduit for below grade and embedded conduit.
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| 3.3.5.3 [Electrical - Cable Electric cable construction shall Complies by Previous Complies by Previous NRC Letter dated 12/17/76, Response to Flame Propagation comply with a flame propagation NRC Approval Approval Appendix A to Branch Technical Limits] test as acceptable to the AHJ. The NPPD response to Branch Position APCB 9.5-1 Guidelines for Complies with Required Technical Position APCSB Fire Protection for Nuclear Power Note: the exception to this section is Action 9.5-1, Appendix A dated Plants, from Pilant (NPPD) to not endorsed by 10 CFR 50.48(c) 12/17/76, as revised on 4/6/77 Ziemann (NRC).
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| (2)(v) and has been removed. states, "Refer to Appendices A, B, C & D for the Cable Design Letter dated 4/6/77, Revisions and Specifications and Cable Fire Additional Information Fire Protection Tests performed on cable at Review, from Pilant (NPPD) to CNS. Refer to Appendix 'E' for Ziemann (NRC).
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| an item by item comparison of Cable Fire Tests performed on Letter dated 5/23/79, from Ippolito CNS cable vs. the IEEE No. 383 (NRC) to Pilant (NPPD).
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| Flame Test. Based on the results of the above attachments, the District feels that the fire-retardant characteristics of the cables at CNS far exceed the type of "fire-retardant" cable used in other plants of its vintage. Therefore, no additional action will be taken."
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| Section 4.8 of the CNS Fire Protection SER dated 5/23/79 states: "Flame tests conducted on the electrical cables used at Cooper Plant were comparable to the combustibility tests set forth in IEEE 383. The results show that, in the configurations and with the ignition sources used in the tests the cable Page A-23
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document insulation burns slowly.
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| Nevertheless, we consider all cable insulation made of organic material as combustible and, therefore, we find that retest to the IEEE 383 procedures and criteria would not provide information that would alter our conclusions. Accordingly, we find the electrical cables used at the Cooper Plant acceptable."
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| The electrical cables, as approved by the SER, are still installed at CNS. There have been no plant modifications or other changes that would invalidate the basis for approval.
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| These cables remain unchanged.
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| Complies with Required Action Implementation Item S-3.12 -
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| Procedures will be revised to require new cable installations to meet the requirements of IEEE-383 or similar. See Attachment S, Table S-3.
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| 3.3.6 Roofs Metal roof deck construction shall Complies Roofs comply with Factor Mutual CED 6013340, Reactor Building Roof be designed and installed so the Class I requirements per the Repair and Replacement roofing system will not sustain a associated references. A self-propagating fire on the Factory Mutual Class I roof is Contract No. 87-30, Re-roof Various underside of the deck when the equivalent to a NFPA 256 Class Plant Structures deck is heated by a fire inside the A roof classification.
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| building. Roof coverings shall be Drawing 4506, Rev. N09, Roof Plan Class A as determined by tests EDP-06, Attachment 1, Section and Details described in NFPA 256, "Standard F1 includes the requirements for Methods of Fire Tests of Roof roof construction, and Drawing CNS-BLDG-94, Rev. N05, Coverings." specifically references NFPA Re-Roofing Plan and Details 805, Section 3.3.6, as part of the fire protection design Drawing CNS-BLDG-353, Rev. N02, Page A-24
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| Nebraska Public Power District NebrasktCNS NFPA 805 Transition Re.ort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document considerations. CNS Re-Roofing Plan and Details Reactor Building EDP-06, Rev. 45, Supporting Requirements for Configuration Change Control MP 96-122, Steam Tunnel Roof Replacement MWR 97-1891, Maintenance Work Request - Turbine Building Roof MWR 98-4046, Maintenance Work Request Reactor Building Roof PO 351766, Purchase Order - 4160V Switchgear Roof Requisition No. 96-2231, Steam Tunnel Roof 3.3.7 Bulk Flammable Bulk compressed or cryogenic Complies Complies Procedure 0.7.1, Rev. 30, Control of Gas Storage flammable gas storage shall not be Bulk storage of hydrogen gas, in Combustibles permitted inside structures housing Complies with Required D.O.T.-approved high pressure systems, equipment, or Action cylinders, is located in a totally components important to nuclear separate building approximately safety. 80 feet east of the Water Treatment Plant.
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| There is no other bulk gas storage other than the hydrogen gas located outside.
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| Complies with Required Action Implementation Item S-3.13 -
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| Procedure 0.7.1 will be revised to include a requirement that bulk gas storage not be allowed inside structures housing systems, equipment, or components important to Page A-25
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| Nebraska Public Power District CNS NFPA 805 Transition Reoort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document nuclear safety. See Attachment S, Table S-3.
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| 3.3.7.1 [Bulk Flammable Storage of flammable gas shall be Complies Complies EE 10-071, Rev. 0, CNS Acceptance Gas Storage - Location located outdoors, or in separate Bulk storage of hydrogen gas, in of EPM Report No: R1906-002-002, Requirements] detached buildings, so that a fire or Complies with the use of D.O.T.-approved high pressure NFPA Code Conformance Review explosion will not adversely impact Existing Engineering cylinders, is located in a totally systems, equipment, or Equivalency Evaluations separate building approximately Drawing 4044, Rev. 1, Gas Bottle components important to nuclear (EEEEs) 80 feet east of the Water Storage Building safety. NFPA 50A, "Standard for Treatment Building. The long Gaseous Hydrogen Systems at axis of the hydrogen storage Drawing 4519, Rev. N01, Gas Bottle Consumer Sites," shall be followed containers is pointed towards Storage Building for hydrogen storage. the Intake Structure to the north.
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| However, the building is located approximately 100 feet south of the Intake Structure. In addition, the walls of the hydrogen storage structure are constructed of 1 foot reinforced poured concrete, and each hydrogen container is provided with two mounting frames that provide the necessary restraint in the event of failure.
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| Complies with use of EEEEs Hydrogen storage is in compliance with the requirements of NFPA 50A, as documented in the NFPA 50A-1 973 code review checklist in Engineering Evaluation EE 10-071.
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| 3.3.7.2 [Bulk Flammable Outdoor high-pressure flammable Submit for NRC Bulk storage of hydrogen gas, in Drawing 4003, Rev N39, Overall Site Gas Storage - Container gas storage containers shall be Approval D.O.T.-approved high pressure &Vicinity Plan Restrictions] located so that the long axis is not cylinders, is located in a totally pointed at buildings. separate building approximately Drawing 4044, Rev. 1, Gas Bottle 80 feet east of the Water Storage Building Treatment Building. The long axis of the hydrogen storage Drawing 4519, Rev. N01, Gas Bottle containers is pointed towards Storage Building the Intake Structure to the north.
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| Page A-26
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document However, the building is located approximately 100 feet south of the Intake Structure. In addition, the walls of the hydrogen storage structure are constructed of 1 foot reinforced poured concrete and each hydrogen container is provided with two mounting frames that provide the necessary restraint in the event of failure. Refer to Attachment L for further details on the request for NRC approval of the current configuration of the bulk hydrogen storage containers inside the hydrogen storage structure with long axis pointed towards the Intake Structure.
| |
| 3.3.7.3 [Bulk Flammable Flammable gas storage cylinders Complies Procedure 0.7.1, Section 4.8 Procedure 0.7.1, Rev. 30, Control of Gas Storage - Cylinder not required for normal operation provides for the segregation, Combustibles Limitations] shall be isolated from the system. storing, and transporting of flammable gases in accordance Procedure 0.36, Rev. 36, Industrial with site-specific procedures Safety Procedure and when flammable gases are used or staged for use in Level 1 Procedure 0.36.6, Rev. 10, Monitoring plant areas. In these cases, a for Industrial Gases Transient Combustible Evaluation is processed. The site-specific procedures which control the use and storage of gases include Procedures 0.36 and 0.36.6.
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| 3.3.8 Bulk Storage of Bulk storage of flammable and Complies by Previous Complies by Previous NRC EE 10-071, Rev. 0, CNS Acceptance Flammable and combustible liquids shall not be NRC Approval Approval of EPM Report No: R1906-002-002, Combustible Liquids permitted inside structures The storage areas inside NFPA Code Conformance Review containing systems, equipment, or Complies structures containing systems, components important to nuclear equipment, or components Letter dated 12/17/76, Response to safety. As a minimum, storage and Complies with use of important to nuclear safety have Appendix A to Branch Technical use shall comply with NFPA 30, Existing Engineering been previously approved by the Position APCB 9.5-1 Guidelines for "Flammable and Combustible Equivalency Evaluations NRC. The NPPD response to Fire Protection for Nuclear Power Page A-27
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Liquids Code." (EEEEs) Branch Technical Position Plants, from Pilant (NPPD) to APCSB 9.5-1, Appendix A, Ziemann (NRC).
| |
| dated 12/17/76 states:
| |
| Letter dated 5/23/79, from Ippolito "As shown in Fig. 4, both of the (NRC) to Pilant (NPPD).
| |
| 2,500 gallon Diesel Generator Fuel Oil Day tanks are cut off Procedure 0.7.1, Rev. 30, Control of from the remainder of the Diesel Combustibles Generator Room by a minimum 3 hour rated Fire Barrier, with a Procedure 0.7.1.1, Rev. 1, Control of Class A fire door. Each doorway Flammable Materials Lockers to the Day Tank Room has a 2' high curb to contain a total tank spill or rupture. As indicated in the paragraph above, the Day Tank Rooms are protected by C02, with detection and actuation by a thermal detector."
| |
| The NPPD response to Branch Technical Position APCSB 9.5-1, Appendix A, dated 12/17/76 also states:
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| "As shown in Fig. 3 & 4, rooms housing equipment and/or storage containers are cut off from the remainder of the Turbine Generator Building by minimum 3 hour fire-rated masonry Fire Barriers, and are provided with Class A fire doors and HVAC duct penetrations without fire-rated dampers. The Turbine Lube Oil Concentric Piping runs below the Turbine Operating Floor, at approximately the 920' elevation. Fig. 18, 19 & 20 show the Fire Zones which indicate Automatic Water Spray Fire Protection Systems, with Rate-Page A-28
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document of-Rise detection and actuation systems, are provided to protect these areas. Itshould be noted that none of these areas expose safety related systems and equipment. As indicated in Response to D.2(a), the E.H.
| |
| Governor Control Fluid is of a fire-resistant Quality."
| |
| Section 5.2.6 of the CNS Fire Protection SER dated 5/23/79 states:
| |
| "The licensee has proposed to electrically supervise the doors between diesel generator rooms.
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| "A curb will be provided at the entrance to the boiler room to prevent oil from entering the diesel generator room.
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| "The curb between the two diesel rooms will be modified to prevent an oil spill from affecting the adjacent room.
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| "The abort switch for the carbon dioxide systems will be electrically supervised to annunciate in the control room.
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| "We find that, subject to the implementation of the above described modifications, the fire protection of the diesel generator room satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable."
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| Page A-29
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Section 5.9.6 of the CNS Fire Protection SER dated 5/23/79 states:
| |
| "The licensee will provide a drainage system for the lube oil reservoir room at elevation 903'.
| |
| "Information will be provided by the licensee to assure satisfactory fire resistance capability of the penetration barriers.
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| "An automatic sprinkler system will be installed to provide coverage of the vertical electrical cable chase and penetrations in the north wall of the turbine building.
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| "We find that, subject to the implementation of the above modifications, the fire protection for the turbine building satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable."
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| These configurations, as approved by the SER, are still used at CNS. There have been no other plant modifications or other changes that would invalidate the basis for approval.
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| This feature remains unchanged.
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| Complies There is no bulk storage of flammable or combustible liquids Page A-30
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Revort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document inside structures containing systems, equipment, or components important to nuclear safety, with the exception of those previously approved. Procedure 0.7.1, Section 4.5 provides the guidelines for the staging, storage, and use of combustible and flammable liquids.
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| Procedure 0.7.1.1 provides administrative controls for flammable material storage at CNS.
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| Complies with use of EEEEs Bulk storage of flammable and combustible liquids is in accordance with the requirements of NFPA 30, as documented in the NFPA 30-1973 code review checklist in Engineering Evaluation EE 10-071.
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| 3.3.9 Transformers Where provided, transformer oil Complies with Required CNS does not utilize transformer None collection basins and drain paths Action oil drain paths.
| |
| shall be periodically inspected to ensure that they are free of debris Spill containment that could and capable of performing their accumulate debris are not design function. inspected to prohibit the proper collection of oil.
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| Implementation Item S-3.14 -
| |
| Procedures will be revised to include the requirement for the inspection of the transformer spill containment area. See Attachment S, Table S-3.
| |
| 3.3.10 Hot Pipes and Combustible liquids, including high Complies Procedure 0.7.1, Section 4.5.3.1 Procedure 0.7.1, Rev. 30, Control of Surfaces flashpoint lubricating oils, shall be requires that flammable liquids Combustibles kept from coming in contact with hot should not be used in close Page A-31
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document pipes and surfaces, including proximity to sources of ignition, Procedure 7.0.13, Rev. 15, Control of insulated pipes and surfaces. or in such a way that flammable Insulation Removal and Installation Administrative controls shall require vapors could come in contact the prompt cleanup of oil on with a source of ignition. Section insulation. 4.2.8 requires that combustible liquids, or Class A materials impregnated with combustible liquids, should be removed promptly and prevented from contacting hot pipes or other hot surfaces, including those which are insulated. Section 4.2.8.1 provides the requirement for prompt cleanup of oil on insulation. Procedure 7.0.13 provides the method and controls for removing piping, equipment, and HVAC Systems insulation.
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| 3.3.11 Electrical Adequate clearance, free of Complies Procedure 0.7.1, Section 4.2.3, Procedure 0.7.1, Rev. 30, Control of Equipment combustible material, shall be requires that transient Combustibles maintained around energized combustible materials should electrical equipment. not be stored within 3 feet of energized electrical equipment.
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| 3.3.12 Reactor Coolant For facilities with non-inerted N/A Not Applicable - CNS has an None Pumps containments, reactor coolant inerted containment.
| |
| pumps with an external lubrication system shall be provided with an oil collection system. The oil collection system shall be designed and installed such 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.
| |
| 3.3.12 Reactor Coolant The oil collection system for each N/A Not Applicable - CNS has an None Pumps (1) reactor coolant pump shall be inerted containment.
| |
| capable of collecting lubricating oil from all potential pressurized and nonpressurized leakage sites in each reactor coolant pump oil Page A-32
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document system.
| |
| 3.3.12 Reactor Coolant Leakage shall be collected and N/A Not Applicable - CNS has an None Pumps (2) drained to a vented closed inerted containment.
| |
| container that can hold the inventory of the reactor coolant pump lubricating oil system.
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| 3.3.12 Reactor Coolant A flame arrestor is required in the N/A Not Applicable - CNS has an None Pumps (3) vent if the flash point characteristics inerted containment.
| |
| of the oil present the hazard of a fire flashback.
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| 3.3.12 Reactor Coolant Leakage points on a reactor coolant N/A Not Applicable - CNS has an None Pumps (4) pump motor to be protected shall inerted containment.
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| 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 reactor coolant pumps.
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| 3.3.12 Reactor Coolant The collection basin drain line to the N/A Not Applicable - CNS has an None Pumps (5) collection tank shall be large inerted containment.
| |
| enough to accommodate the largest potential oil leak such that oil leakage does not overflow the basin.
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| 3.4 Industrial Fire N/A N/A Section Heading - See None Brigade compliance bases below for compliance statements for specific subsections.
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| 3.4.1 On-Site Fire- On-Site Fire-Fighting Capability. All N/A Introductory Statement - See None Fighting Capability of the following requirements shall compliance bases below for apply. compliance statements for specific subsections.
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| 3.4.1 On-Site Fire- A fully staffed, trained, and Complies by Previous Procedure 0.23, Section 1.1 and Cooper Nuclear Station Updated Fighting Capability (a) equipped fire-fighting force shall be NRC Approval USAR Section XIII-10.5.1 Safety Analysis Report, loep xxv2 available at all times to control and describe that a fire brigade of at extinguish all fires on site. This least five members is Letter dated 7/20/77, Proposed force shall have a minimum maintained at all times. The fire Change to the Radiological Technical complement of five persons on duty brigade composition may be Specifications Cooper Nuclear and shall conform with the following less than the minimum Station, from Pilant (NPPD) to Davis Page A-33
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition ReDort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document NFPA standards as applicable: requirements for a period of time not to exceed 2 hours in order to accommodate unexpected Letter dated 11/29/77, Cooper absence of fire brigade Nuclear Station, from Goller (NRC) to members, provided immediate Pilant (NPPD).
| |
| action is taken to restore the fire brigade to within the minimum Procedure 0.23, Rev. 64, CNS Fire requirements. Protection Plan This fire brigade staffing configuration, including this reduced composition allowance for a 2-hour time period, was previously approved by the NRC.
| |
| Letter dated 7/20/77 included the following statement in the proposed Fire Protection System Technical Specifications:
| |
| "In the event that any member of a minimum shift crew is absent or incapacitated due to illness or injury a qualified replacement shall be designated to report on-site within two hours."
| |
| Safety Evaluation Report, dated November 29, 1977, approved the Fire Protection System Technical Specifications which includes this reduced composition allowance for a 2-hour time period.
| |
| The fire brigade staffing, as approved by the NRC Safety Evaluation Report, is still intact at CNS. There have been no changes that would invalidate Page A-34
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document the basis for approval.
| |
| 3.4.1 On-Site Fire- NFPA 600, "Standard on Industrial Complies with use of The fire brigade is in compliance EE 10-071, Rev. 0, CNS Acceptance Fighting Capability (a)(1) Fire Brigades" (interior structural Existing Engineering with the requirements of NFPA of EPM Report No: R1906-002-002, fire fighting) Equivalency Evaluations 600, as documented in the NFPA Code Conformance Review (EEEEs) NFPA 600-2000 code review checklist in Engineering Evaluation EE 10-071.
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| 3.4.1 On-Site Fire- NFPA 1500, "Standard on Fire N/A Not Applicable - NFPA 1500 NEI 04-02, "Guidance for Fighting Capability (a)(2) Department Occupational Safety (2007) Chapter 1 Implementing a Risk-Informed, and Health Program" "Administration" Section 1.3.2 Performance-Based Fire Protection states that this standard does Program under 10 CFR 50.48(c),"
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| not apply to Industrial Fire Rev. 2 Brigades that might also be known as Emergency Brigades, NFPA 1500, Standard on Fire Emergency Response Teams, Department Occupational Safety and Response Teams, Fire Teams, Health Program, 2007 Edition Plant Emergency Organizations, or mine emergency response teams. Since CNS has an "Industrial Fire Brigade," this NFPA 805 Element is not applicable.
| |
| 3.4.1 On-Site Fire- NFPA 1582, "Standard on Medical N/A Not Applicable - NFPA 1582 is NEI 04-02, "Guidance for Fighting Capability (a)(3) Requirements for Fire Fighters and not applicable to CNS per the Implementing a Risk-Informed, Information for Fire Department scope statement below, and is Performance-Based Fire Protection Physicians" consistent with NEI 04-02, Rev. Program under 10 CFR 50.48(c),"
| |
| 2, Section K.6 (FAQ 06-0007). Rev. 2 NFPA 1582 (2007) Chapter 1 "Administration" Section 1.1.4 states that 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. Since CNS has an "Industrial Fire Brigade," this NFPA 805 Element is not Page A-35
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document applicable.
| |
| 3.4.1 On-Site Fire- Industrial fire brigade members Complies Per USAR Section XIII-10.5, a Cooper Nuclear Station Updated Fighting Capability (b) shall have no other assigned fire brigade of at least five Safety Analysis Report, loep xxv2 normal plant duties that would members is maintained at all prevent immediate response to a times. This excludes the four fire or other emergency as required. members of the minimum shift crew necessary for safe shutdown, and other personnel required for other essential functions during a fire emergency.
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| 3.4.1 On-Site Fire- During every shift, the brigade Complies Procedure 0.23, Attachment 6, Procedure 0.23, Rev. 64, CNS Fire Fighting Capability (c) leader and at least two brigade Section 1.2.12 requires that the Protection Plan members shall have sufficient fire brigade shall be a minimum training and knowledge of nuclear of five (5) individuals. A safety systems to understand the minimum of three (3) from effects of fire and fire suppressants Operations and two (2) from on nuclear safety performance another department trained in criteria, fire fighting techniques to control and extinguish fires. Qualified Exception to (c): Sufficient training station operators have a basic and knowledge shall be permittedto knowledge of nuclear safety be provided by an operations systems. Procedure 0.23, advisor dedicated to industrialfire Attachment 6 defines the brigade support. training and drills requirements for all fire brigade members to be considered qualified, which includes but is not limited to fire behavior, fire fighting tactics and strategies, radiological and electrical hazards, and damage control and salvage.
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| 3.4.1 On-Site Fire- The industrial fire brigade shall be Complies Site-Specific Plant Access Procedure 5.1 INCIDENT, Rev. 21, Fighting Capability (d) notified immediately upon Training GEN001-02-04 Site Emergency Incident verification of a fire. provides general training to plant employees, which includes GEN001-02-04, Site-Specific Plant notifying the Control Room via Access Training the telephone using 911 or gaitronics of a discovered fire.
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| Procedure 5.1 INCIDENT, Attachment 1, Section 1.2.1 Page A-36
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Revort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document requires that the Control Room is responsible to notify the fire brigade of any fire incident via a Gaitronics announcement.
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| 3.4.1 On-Site Fire- Each industrial fire brigade member Complies Procedure 0.23, Section 5.4.2 Procedure 0.23, Rev. 64, CNS Fire Fighting Capability (e) shall pass an annual physical states Fire Brigade physical Protection Plan examination to determine that he or examinations are provided she can perform the strenuous annually to Fire Brigade activity required during manual members and Section 5.4.3 firefighting operations. The physical states respiratory protection examination shall determine the training re-qualification is ability of each member to use completed annually.
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| respiratory protection equipment.
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| 3.4.2 Pre-Fire Plans Current and detailed pre-fire plans Complies CNS Pre-Fire Plans are Procedure 0.23, Rev. 64, CNS Fire shall be available to the industrial established as detailed drawings Protection Plan fire brigade for all areas in which a under the CNS Drawing Control fire could jeopardize the ability to Program. Procedure 6.FP.608, Rev. 23, meet the performance criteria License Required Fire Fighting described in Section 1.5. Procedure 0.23, Section 2.5 Equipment Monthly Examination requires that copies of these pre-fire plan drawings are Procedure 15.FP.650, Rev. 16, Fire retained at strategic locations Locker and Hazardous Material throughout the plant for use by Response Inventory the fire brigade during a fire event. Procedure 15.FP.650 identifies the inventory of the fire brigade lockers, which includes the pre-fire plans. Procedure 6.FP.608 documents the location of the fire brigade lockers.
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| 3.4.2.1 [Pre-Fire Plans - The plans shall detail the fire area Complies Per Section 2.5 of Procedure Procedure 0.23, Rev. 64, CNS Fire Contents] configuration and fire hazards to be 0.23, Pre-Fire Plans detail Protection Plan encountered in the fire area, along hazardous conditions and with any nuclear safety components firefighting recommendations in and fire protection systems and certain areas. The Pre-Fire features that are present. Plans detail an area drawing, potential hazards, cautions, fixed suppression, specialized fire fighting equipment, and the major shutdown equipment Page A-37
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| | |
| Nebraska Public Power District NebrasktCNS NPA 805 Transition Reort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document within various areas of the plant.
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| 3.4.2.2 [Pre-Fire Plans - Pre-fire plans shall be reviewed and Complies with Required Procedure 0.23, Section 2.5 Procedure 0.23, Rev. 64, CNS Fire Updates] updated as necessary. Action requires that Pre-Fire Plan Protection Plan drawings are controlled under the Configuration Change and Drawing Control processes.
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| Changes to these Pre-Fire Plans are distributed by the Fire Protection Staff, the Fire Brigade Training Instructor, or Operations personnel. However, there is no procedure for updating the pre-fire plans in each of the inventoried locations.
| |
| Implementation Item S-3.16 -
| |
| Revise procedures to inventory which pre-fire plans are in the fire lockers, and ensure that updates of the pre-fire plans include replacing the updated pages in each of the inventoried locations throughout the plant.
| |
| See Attachment S, Table S-3.
| |
| 3.4.2.3 [Pre-Fire Plans - Pre-fire plans shall be available in Complies with Required A copy of the Pre-Fire Plans is Procedure 0.23, Rev. 64, CNS Fire Locations] the control room and made Action contained within the Control Protection Plan available to the plant industrial fire Room. In addition, Procedure brigade. 0.23, Section 2.5 requires that Pre-Fire Plans are retained at strategic locations throughout the plant for use by the Fire Brigade during a fire event.
| |
| Implementation Item S-3.17 -
| |
| Revise procedures to ensure that Pre-Fire Plan drawings, are maintained in the Control Room and to ensure that the latest revisions are available. See Attachment 5, Table S-3.
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| Page A-38
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Reoort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.4.2.4 [Pre-Fire Plans - Pre-fire plans shall address Complies with Fire brigade coordination with Procedure 5.1 INCIDENT, Rev. 21, Coordination Needs] coordination with other plant groups Clarification other plant groups during fire Site Emergency Incident during fire emergencies. emergencies is not addressed in individual pre-fire plans.
| |
| However, the coordination between the fire brigade and other plant groups during a fire emergency is defined in Procedure 5.1 INCIDENT.
| |
| 3.4.3 Training and Drills Training and Drills. Industrial fire Complies Training Program Procedure TPP 101, Rev. 14, Emergency brigade members and other plant TPP 206 establishes the fire Response Organization personnel who would respond to a brigade training program such fire in conjunction with the brigade that training is commensurate TPP 206, Rev. 19, Fire Brigade shall be provided with training with their emergency commensurate with their responsibilities. Training emergency responsibilities. Program Procedure TPP 101 establishes the emergency response organization training program.
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| 3.4.3 Training and Drills Plant Industrial Fire Brigade N/A Section Heading - See None (a) Training. All of the following compliance bases below for requirements shall apply. compliance statements for specific subsections.
| |
| 3.4.3 Training and Drills Plant industrial fire brigade Complies with use of The fire brigade training EE 10-071, Rev. 0, CNS Acceptance (a)(1) members shall receive training Existing Engineering program is in compliance with of EPM Report No: R1906-002-002, consistent with the requirements Equivalency Evaluations the requirements of NFPA 600, NFPA Code Conformance Review contained in NFPA 600, "Standard (EEEEs) as documented in the NFPA on Industrial Fire Brigades," or 600-2000 code review checklist NFPA 1500, "Standard on Fire in Engineering Evaluation EE Department Occupational Safety 10-071. (NFPA 1500 does not and Health Program," as apply, as the plant operates a appropriate. fire brigade, not a fire department).
| |
| 3.4.3 Training and Drills Industrial fire brigade members Complies Per Section 5.4 of Procedure Procedure 0.23, Rev. 64, CNS Fire (a)(2) shall be given quarterly training and 0.23, brigade members are Protection Plan practice in fire fighting, including required to attend requalification radioactivity and health physics training on a quarterly basis. TPP 206, Rev. 19, Fire Brigade considerations, to ensure that each member is thoroughly familiar with the steps to be taken in the event of a fire.
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| Page A-39
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| | |
| Nebraska Public Power District Nebrask.NS NFPA 805 Transition Re-ort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Procedure 0.23, Reference Rev. 64, CNS Fire Document 3.4.3 Training and Drills A written program shall detail the Complies Procedure 0.23, Section 5 Procedure 0.23, Rev. 64, CNS Fire (a)(3) industrial fire brigade training details the fire brigade training Protection Plan program. program and requirements.
| |
| TPP 206, Rev. 19, Fire Brigade Procedure TPP 206, Section 1.1.2 states that this guide covers suggested training aids, strategies, and methods used to conduct the program. Section 2.2.1 details the training documents presented to all fire brigade members, which includes, but is not limited to, training on personal protective equipment, fires and extinguishing agents, pre-fire plans, and hazard identification.
| |
| 3.4.3 Training and Drills Written records that include but are Complies Procedure 0.23, Rev. 64, CNS Fire Per Section 2.2 of Training Procedure 0.23, Rev. 64, CNS Fire (a)(4) not limited to initial industrial fire Program Procedure TPP 206, Protection Plan brigade classroom and hands-on initial classroom training training, refresher training, special sessions, ongoing classroom TPP 206, Rev. 19, Fire Brigade training schools attended, drill training sessions, and fire drills attendance records, and leadership are recorded and maintained in training for industrial fire brigades the Training Records System.
| |
| shall be maintained for each industrial fire brigade member. Per Section 2.6 of Attachment 6 of Procedure 0.23, the Training Manager provides overall management of the Training Programs which support the Fire Protection Program. This includes maintenance of the fire brigade training records. The Operations Training Supervisor is responsible for ensuring all drills are scheduled and performed as required.
| |
| 3.4.3 Training and Drills Training for Non-Industrial Fire Complies Training Program Procedure TPP 101, Rev. 14, Emergency (b) Brigade Personnel. Plant personnel TPP 101 establishes the Response Organization who respond with the industrial fire emergency response brigade shall be trained as to their organization training program.
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| Page A-40
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document responsibilities, potential hazards to Plant personnel who respond be encountered, and interfacing with the fire brigade are included with the industrial fire brigade. in the fire brigade fire drills.
| |
| 3.4.3 Training and Drills Drills. All of the following N/A Introductory Statement - See None (c) requirements shall apply. compliance bases below for compliance statements for specific subsections.
| |
| 3.4.3 Training and Drills Drills shall be conducted quarterly Complies Procedure 0.23, Section 5.5 Procedure 0.23, Rev. 64, CNS Fire (c)(1) for each shift to test the response states fire drills shall be Protection Plan capability of the industrial fire performed at least once per brigade, calendar quarter per Operating Crew.
| |
| 3.4.3 Training and Drills Industrial fire brigade drills shall be Complies Procedure 0.23, Section 5.5.4 Procedure 0.23, Rev. 64, CNS Fire (c)(2) developed to test and challenge requires that the CNS Training Protection Plan industrial fire brigade response, Department shall develop drill including brigade performance as a scenarios with Fire Protection team, proper use of equipment, staff assistance to determine the effective use of pre-fire plans, and effectiveness of: Pre-Fire Plan coordination with other groups. strategies, Adequacy of These drills shall evaluate the equipment, Personal industrial fire brigade's abilities to understanding of react, respond, and demonstrate responsibilities, and Team Work proper fire-fighting techniques to and Communication. Per control and extinguish the fire and Attachment 3, a fire drill critique smoke conditions being simulated is performed after the drill to by the drill scenario, determine its effectiveness.
| |
| 3.4.3 Training and Drills Industrial fire brigade drills shall be Complies with Required Plant documents do not provide Procedure 0.23, Rev. 64, CNS Fire (c)(3) conducted in various plant areas, Action a description of fire drills that Protection Plan especially in those areas identified indicate the quarterly drills are to be essential to plant operation conducted in various areas of and to contain significant fire the plant.
| |
| hazards.
| |
| Implementation Item S-3.18 -
| |
| Station Fire Brigade Training Program will be updated to include guidance to ensure fire drills are conducted in various plant areas, especially in those areas identified to be essential to plant operation and to contain significant fire hazards. See Page A-41
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Attachment S, Table S-3.
| |
| 3.4.3 Training and Drills Drill records shall be maintained Complies Procedure 0.23, Section 5.5.4.4 Procedure 0.23, Rev. 64, CNS Fire (c)(4) detailing the drill scenario, industrial requires that fire drills be Protection Plan fire brigade member response, and tracked using the Fire Drill ability of the industrial fire brigade to Spreadsheet administered by perform as a team. Operations Training. The spreadsheet is entered into records documenting the completion of all required fire drills. Attachment 2 of this procedure is utilized to authorize and approve drills.
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| Procedure 0.23, Section 5.5 requires that a post-fire drill critique is recorded and maintained. This critique includes an assessment of individual and team performance of the fire brigade. Section 9 establishes plant records requirements. Attachment 3 provides the post-fire drill critique form.
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| 3.4.3 Training and Drills A critique shall be held and Complies Procedure 0.23, Section 5.5 Procedure 0.23, Rev. 64, CNS Fire (c)(5) documented after each drill, requires that a post-fire drill Protection Plan critique is recorded and maintained. Attachment 3 is utilized for post-fire drill critiques.
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| 3.4.4 Fire-Fighting Protective clothing, respiratory Complies Fire brigade equipment is Emergency Plan for Cooper Nuclear Equipment protective equipment, radiation purchased through qualified Station, Rev. 59 monitoring equipment, personal vendors and required to meet dosimeters, and fire suppression the latest NFPA Code. Procedure 6.FP.608, Rev. 23, equipment such as hoses, nozzles, License Required Fire Fighting fire extinguishers, and other needed Procedure 15.FP.650, Equipment Monthly Examination equipment shall be provided for the Attachment 1 provides the industrial fire brigade. This quantity and type of protective Procedure 15.FP.650, Rev. 16, Fire equipment shall conform with the equipment located in the fire Locker and Hazardous Material applicable NFPA standards. lockers and hazardous material Response Inventory carts.
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| Page A-42
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Per Section 6.6.1 of the Emergency Plan for Cooper Nuclear Station, emergency workers will wear dosimetry, as required by Radiological Protection personnel.
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| Emergency worker dosimetry will be provided on a 24-hour basis by Radiological Protection personnel.
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| Procedure 6.FP.608 ensures the operability and availability of Fire Brigade equipment.
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| 3.4.5 Off-Site Fire N/A N/A Section Heading - See None Department Interface compliance bases below for compliance statements for specific subsections.
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| 3.4.5.1 Mutual Aid Off-site fire authorities shall be Complies Per Section 5.5.9 of Procedure Emergency Plan for Cooper Nuclear Agreement offered a plan for their interface 0.23, local off-site responders Station, Rev. 59 during fires and related are offered site familiarization emergencies on site. training on a recurring basis to Procedure 0.23, Rev. 64, CNS Fire share information about the site Protection Plan layout and B.5.b event-related mitigation strategies and measures.
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| Per Section 8.1.3 of the CNS Emergency Plan, training for participating agencies is programmed by the individual agencies with aid from the State Governments in Nebraska, Missouri, Kansas, and Iowa.
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| NPPD personnel are available to describe the special conditions and constraints involved in dealing with the station emergencies and any radiological release situations.
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| Page A-43
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.4.5.2 Site-Specific Fire fighters from the off-site fire Complies Procedure 0.23, Section 5.5.8 Cooper Nuclear Station Updated Training authorities who are expected to requires that on an annual Safety Analysis Report, loep xxv2 respond to a fire at the plant shall basis, a station fire drill is be offered site-specific training and conducted where local fire Emergency Plan for Cooper Nuclear shall be invited to participate in a departments are invited to Station, Rev. 59 drill at least annually. participate. Per Section 5.5.9, local off-site responders are GEN005-10-12, Rev. 02, Offsite Fire offered site familiarization Department Training training on a recurring basis to share information about the site Procedure 0.23, Rev. 64, CNS Fire layout and B.5.b event-related Protection Plan mitigation strategies and measures.
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| Per Section 8.1.3 of the CNS Emergency Plan, NPPD offers training annually for members of the Volunteer Fire Departments of Brownville, Nemaha, Peru, and Auburn.
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| GEN005-10-12 provides training for familiarity with the expected process for and expectations/procedures for responding to CNS in the event of an emergency as a member of an offsite emergency response organization.
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| USAR Section X111-10.5.1 describes that frequent visits to CNS have been arranged for the outside fire fighting companies from the nearby communities, and that on an annual basis, a Station fire drill is conducted where local Fire Departments are afforded an opportunity to participate.
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| 3.4.5.3 Security and Plant security and radiation Complies Security Procedure 3.14 Security Procedure 3.14, Rev. 15, Page A-44
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| Nebraska Public Power District NebraskatCNS NPA 805 Transition Re..ort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Radiation Protection protection plans shall address off- provides instructions for Non-Security Emergencies site fire authority response. preparing for off-site emergency responders. Security Procedure Security Procedure 3.15, Rev. 10, 3.15 provides instructions for Emergency Entry/Exit expediting site access to off-site emergency responders. This includes the proper security and radiological protection controls to allow them to assist plant personnel.
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| 3.4.6 Communications An effective emergency Complies Per Section XII1-10.6.3 of the Cooper Nuclear Station Updated communications capability shall be USAR, the communication Safety Analysis Report, loep xxv2 provided for the industrial fire system consists of two-way brigade, radios and sound power Procedure 2.2.4, Rev. 43, telephones. System Operating Communications Systems Procedures define the operation of the Sound Power System.
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| Procedure 2.2.4, Attachment 2, Section 1.2.5 requires that the site 450 MHz (UHF) radio system uses three repeaters, Base 1, Base 2, and Base 4 with an 800 MHz as Base 3. Base 2 is the primary frequency used by CNS fire brigade.
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| 3.5 Water Supply N/A N/A Section Heading - See None compliance bases below for compliance statements for specific subsections.
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| 3.5.1 [Water Supply - A fire protection water supply of Complies CNS utilizes the method allowed Alarm Procedure 2.3_FP-PNL-4, Rev.
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| Flow Code adequate reliability, quantity, and in subsection (a) to comply with 3, Pump House Local Control Panel Requirements] duration shall be provided by one of Section 3.5.1.
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| the two following methods. Cooper Nuclear Station Updated Per Section X-9.3.2.1 of the Safety Analysis Report, loep xxv2 (a) Provide a fire protection water USAR, the fire water supply is supply of not less than two separate stored in two 500,000 gallon 300,000-gal (1,135,500-L) supplies, capacity fire water tanks. These tanks are vented to atmosphere (b) Calculate the fire flow rate for 2 and provide clean fire water to hours. This fire flow rate shall be the electric motor driven pump Page A-45
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document based on 500 gpm (1892.5 L/min) (FP-P-E) and a diesel driven for manual hose streams plus the pump (FP-P-D). Makeup water largest design demand of any to the fire water storage tanks is sprinkler or fixed water spray normally supplied by the Fresh system(s) in the power block as Well Water Pumping System or determined in accordance with the Makeup Water Treatment NFPA 13, Standard for the System. Fire water tank low Installation of Sprinkler Systems, or level annunciation in the Fire NFPA 15, "Standard for Water Pump House assures each tank Spray Fixed Systems for Fire will have a minimum level of Protection." The fire water supply greater than 26 feet per shall be capable of delivering this Procedure 2.3_FP-PNL-4. This design demand with the correlates to a minimum hydraulically least demanding capacity of 366,000 gallons per portion of fire main loop out of tank.
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| service.
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| 3.5.2 [Water Supply - The tanks shall be interconnected Complies Complies Drawing 2016, Sht. 2, Rev. N31, Fire Tank Code such that fire pumps can take Drawing 2016, Sht. 2 documents Protection System Flow Diagram for Requirements] suction from either or both. A failure Complies with use of that fire pumps can take suction Pumphouse and Storage Tanks in one tank or its piping shall not Existing Engineering from either or both storage tanks allow both tanks to drain. The tanks Equivalency Evaluations and that a failure in one tank or EE 01-006, Rev. 3, Disposition of shall be designed in accordance (EEEEs) piping will not allow both tanks NFPA Code Compliance Deviations with NFPA 22, "Standard for Water to drain. (Systems in Fire Zones Requiring an Tanks for Private Fire Protection." IPEEE Phase 2 Screening)
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| Complies with use of EEEEs Exception No. 1: Water storage The design and installation of tanks shall not be requiredwhen the water supply tanks is in fire pumps are able to take suction accordance with the from a large body of water (such as requirements of NFPA 22, as a lake), provided each fire pump documented in Engineering has its own suction and both Evaluation EE 01-006.
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| suctions and pumps are adequately separated.
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| 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.
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| Page A-46
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.5.3 [Water Supply - Fire pumps, designed and installed Complies with use of Complies with use of EEEEs Cooper Nuclear Station Updated Pump Code in accordance with NFPA 20, Existing Engineering The design and installation of Safety Analysis Report, loep xxv2 Requirements] "Standard for the Installation of Equivalency Evaluations the fire pumps is in accordance Stationary Pumps for Fire (EEEEs) with the requirements of NFPA EE 01-006, Rev. 3, Disposition of Protection," shall be provided to 20, as documented in NFPA Code Compliance Deviations ensure that 100 percent of the Complies Engineering Evaluation EE (Systems in Fire Zones Requiring an required flow rate and pressure are 01-006. IPEEE Phase 2 Screening) available assuming failure of the Submit for NRC largest pump or pump power Approval A detailed review of Fire Pump EE 10-071, Rev. 0, CNS Acceptance source. "E"Controller has been of EPM Report No: R1906-002-002, performed against the NFPA Code Conformance Review requirements of NFPA 20, as detailed in the NFPA 20-1999 MDC 81-114, Fire Protection Clean code review checklist in Water Supply Engineering Evaluation EE 10-071.
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| Complies Per Section X-9.3.2.1 of the USAR, fire pumps FP-P-E and FP-P-D are each rated for 3,000 gpm. They are sized to provide water for the largest fire suppression system demand plus the simultaneous flow of 1,000 gpm from manual hose stations. Per MDC 81-114, the diesel driven fire pump and the electric motor driven fire pump are rated for 3,000 gpm at a total head of 321 feet.
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| Submit for NRC Approval Refer to Attachment L for further details on the request for NRC approval for the remote stop of fire pump FP-P-E from the Control Room.
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| 3.5.4 [Water Supply - At least one diesel engine-driven Complies Per USAR Section X-9.3.2.1, the Cooper Nuclear Station Updated Pump Diversity and fire pump or two more seismic fire water supply is stored in two Safety Analysis Report, loep xxv2 Redundancy] Category I Class IE electric motor- 500,000 gallon capacity fire Page A-47
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document driven fire pumps connected to water tanks. These tanks are MDC 81-114, Fire Protection Clean redundant Class IE emergency vented to atmosphere and Water Supply power buses capable of providing provide clean fire water to the 100 percent of the required flow electric motor driven pump (FP-rate and pressure shall be provided. P-E) and a diesel driven pump (FP-P-D). Makeup water to the fire water storage tanks is normally supplied by the Fresh Well Water Pumping System or the Makeup Water Treatment System. Fire pumps FP-P-E and FP-P-D are each rated for 3,000 gpm. They are sized to provide water for the largest fire suppression system demand plus the simultaneous flow of 1,000 gpm from manual hose stations for two hours. Per MDC 81-114, the diesel driven fire pump and the electric motor driven fire pump are rated for 3,000 gpm at a total head of 321 feet.
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| 3.5.5 [Water Supply - Each pump and its driver and Complies Complies Drawing 4003, Rev. N35, Overall Site Pump Separation controls shall be separated from the Per Drawings 4571 and 4572 & Vicinity Plan Requirements] remaining fire pumps and from the Complies with use of the Electric Fire Pump Room rest of the plant by rated fire Existing Engineering (Fire Zone 23A) is separated Drawing 4571, Rev. N01, Fire barriers. Equivalency Evaluations from the Diesel Fire Pump Protection Pumphouse Plans and (EEEEs) Room (Fire Zone 23B) by a 3- Elevations hour rated wall.
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| Drawing 4572, Rev. 1, Fire Protection Per Drawings CNS-FP-182 and Pumphouse Sections, Details &
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| CNS-FP-285 Sheet 1 the Schedule penetrations within the wall separating the Electric Fire Drawing CNS-FP-285, Rev N04, Sht.
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| Pump Room from the Diesel 1, CNS Fire Barrier Penetration Seal Fire Pump Room are provided Details with 3-hour rated seals.
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| EE 94-8, Rev. 2, Block Wall Gap Site Plan Drawing 4003 Separation documents that the Fire Page A-48
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Protection Pumphouse Fire Protection Plan CNS-FP-182, containing the fire pumps is Rev N05, Fire Area Boundary spatially separated from the Drawing Diesel Driven Fire Pump remainder of the plant. Room West Wall 903'-6" Fire Pump House Complies with use of EEEEs Engineering Evaluation EE 94-8 justifies the adequacy of the hairline cracks in the Fire Protection Pumphouse barrier separating the diesel fire pump from the electric fire pump.
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| 3.5.6 [Water Supply - Fire pumps shall be provided with Complies Complies Drawing Al 0-308468 Sht. 1, Rev.
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| Pump Start/Stop automatic start and manual stop Per Drawings Al 0-308468 Sht. N03, Fire Pump Controller 1C Requirements] only. Submit for NRC I and Sht. 2, the electric motor Approval driven fire pump FP-P-E is Drawing Al 0-308468 Sht. 2, Rev.
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| provided with automatic start N06, Fire Pump Controller lC and manual stop.
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| Drawing A10-308583, Rev. 3, Engine Per Drawing Al 0-308583, the Driven Fire Pump Controller engine driven fire pump FP-P-D is provided with automatic start and manual stop.
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| Submit for NRC Approval Refer to Attachment L for further details on the request for NRC approval for the remote stop of fire pump FP-P-E from the Control Room.
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| 3.5.7 [Water Supply - Individual fire pump connections to Complies Drawing 2016, Sht. 2 documents Drawing 2016, Sht. 2, Rev. N31, Fire Pump Connection the yard fire main loop shall be the sectionalizing valves Protection System Flow Diagram for Requirements] provided and separated with adequately separating the Pumphouse and Storage Tanks sectionalizing valves between individual fire pump connections connections. to the yard fire main loop.
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| 3.5.8 [Water Supply - A method of automatic pressure Complies Per USAR Section X-9.3.2.1, a Cooper Nuclear Station Updated Pressure Maintenance maintenance of the fire protection 30 gpm jockey pump maintains Safety Analysis Report, loep xxv2 Limitations] water system shall be provided system header pressure by independent of the fire pumps. automatically starting on low system pressure and stopping when system pressure is Page A-49
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document restored. If pressure continues to drop (as from a system actuation) FP-P-E will automatically start. A continued drop in system pressure will automatically start FP-P-D.
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| 3.5.9 [Water Supply - Means shall be provided to Complies Drawing SK300, Sht. 2 Drawing SK300, Rev. N11, Sht. 2, Pump Operation immediately notify the control room, documents that pump Fire Alarm Panel Annunciator Notification] or other suitable constantly supervisory signals such as Elementary attended location, of operation of pump power and pump running fire pumps. are annunciated in the Control Room.
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| 3.5.10 [Water Supply - An underground yard fire main loop, Complies with use of The design and installation of EE 01-009, Rev. 3, Review of NFPA Yard Main Code designed and installed in Existing Engineering the underground fire loop is in 10 & 14 & 24 Code Conformance for Requirements] accordance with NFPA 24, Equivalency Evaluations accordance with the Power Block Buildings "Standard for the Installation of (EEEEs) requirements of NFPA 24-1973, Private Fire Service Mains and as documented in Engineering Their Appurtenances," shall be Evaluation EE 01-009.
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| installed to furnish anticipated water requirements.
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| 3.5.11 [Water Supply - Means shall be provided to isolate Complies The Fire Protection System Flow Drawing 2016, Sht. 1, Rev. N63, Flow Yard Main Maintenance portions of the yard fire main loop Drawings 2016 Sht. 1, 2, 3, 6, 7, Diagram Fire Protection Turbine Issues] for maintenance or repair without 1A, 1B, and IC document that Generator Bldg.
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| simultaneously shutting off the the system has sufficient supply to both fixed fire suppression sectionalizing valves for Drawing 2016, Sht. 1A, Rev. N08, systems and fire hose stations maintenance or repair without Flow Diagram Fire Protection Service provided for manual backup. simultaneously shutting off Bldg's &Yard Sprinkler systems and manual hose supply to both fixed suppression station standpipes shall be systems and fire hose stations. Drawing 2016, Sht. 1B, Rev. N02, connected to the plant fire Sprinkler systems and standpipe Flow Diagram Fire Protection Cont.
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| protection water main so that a systems are connected such RDW & ARDW Bldg.'s single active failure or a crack to the that the systems can be isolated water supply piping to these to prevent major impairments to Drawing 2016, Sht. 1C, Rev. N03, systems can be isolated so as not the systems. Flow Diagram Fire Protection Reactor to impair both the primary and Building backup fire suppression systems.
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| Drawing 2016, Sht. 2, Rev. N31, Fire Protection System Flow Diagram for Pumphouse and Storage Tanks Drawing 2016, Sht. 3, Rev. N25, Fire Page A-50
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Protection System Flow Diagram Drawing 2016, Sht. 6, Rev. N01, Flow Diagram Fire Protection System Multi Purpose Facility Drawing 2016, Sht. 7, Rev. N07, Fire Protection System Site Plan Flow Diagram 3.5.12 [Water Supply - Threads compatible with those Complies Per the original Response to Letter dated 12/17/76, Response to Compatible Thread used by local fire departments shall Appendix A to BTP 9.5-1 Appendix A to Branch Technical Connections] be provided on all hydrants, hose submittal dated December 17, Position APCB 9.5-1 Guidelines for couplings, and standpipe risers. 1976, the threads on hydrants, Fire Protection for Nuclear Power hose couplings, and standpipe Plants, from Pilant (NPPD) to Exception: Fire departments shall risers are compatible with those Ziemann (NRC) be permitted to be provided with used by the nearby local adaptersthat allow interconnection community fire departments.
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| between plant equipment and the fire department equipment if adequate trainingand procedures are provided.
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| 3.5.13 [Water Supply - Headers fed from each end shall be Complies E69-4 documents steel piping Contract E69-4, Mechanical Piping Header Options] permitted inside buildings to supply and fittings meet the Equipment & Erection both sprinkler and standpipe requirements ANSI B31.1.
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| systems, provided steel piping and Cooper Nuclear Station Updated fittings meeting the requirements of Per USAR Section X-9.5, the Safety Analysis Report, loep xxv2 ANSI B31.1, "Code for Power safety-related Class I systems Piping," are used for the headers and equipment necessary for Drawing 2016, Sht. 1, Rev. N63, Flow (up to and including the first valve) safe shutdown are located only Diagram Fire Protection Turbine supplying the sprinkler systems in the Reactor Building, the Generator Bldg.
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| where such headers are part of the Control Building, the Diesel seismically analyzed hose Generator Building, and in the Drawing 2016, Sht. 1A, Rev. N08, standpipe system. Where provided, Intake Structure. The Fire Flow Diagram Fire Protection Service such headers shall be considered Protection System piping is Bldg's &Yard an extension of the yard main Seismic Class IIS. However, the system. Each sprinkler and fire water piping and sprinklers Drawing 2016, Sht. 1B, Rev. N02, standpipe system shall be equipped in the Reactor Building and Flow Diagram Fire Protection Cont.
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| with an outside screw and yoke Control Building and the high RDW & ARDW Bldg.'s (OS&Y) gate valve or other pressure C02 system in the approved shutoff valve. Diesel Generator Building have Drawing 2016, Sht. 1C, Rev. N03, been supported and restrained Flow Diagram Fire Protection Reactor Page A-51
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document to Seismic Class IS criteria. The Building Intake Structure fire water piping in the SW Pump Room is Drawing 2016, Sht. 2, Rev. N31, Fire supported to the barge impact Protection System Flow Diagram for criteria. In this manner, when Pumphouse and Storage Tanks Fire Protection System piping passes over or near the Seismic Drawing 2016, Sht. 3, Rev. N25, Fire Class IS piping or Class I Protection System Flow Diagram equipment in the above buildings, it is supported and Drawing 2016, Sht. 6, Rev. N01, Flow restrained to withstand a Class I Diagram Fire Protection System Multi Seismic occurrence and Purpose Facility maintain structural and pressure integrity. Drawing 2016, Sht. 7, Rev. N07, Fire Protection System Site Plan Flow The Fire Protection System Flow Diagram Drawings 2016 Sht. 1, 2, 3, 6, 7, 1A, 1B, and lC document that each sprinkler and standpipe system is equipped with an outside screw and yoke (OS&Y) gate valve or other approved shutoff valve.
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| 3.5.14 [Water Supply - All fire protection water supply and Complies A program at the station Drawing 2016, Sht. 7, Rev. N07, Fire Control Valve fire suppression system control requires fire protection valves to Protection System Site Plan Flow Supervision] valves shall be under a periodic be sealed or locked in the Diagram inspection program and shall be normal open position. A periodic supervised by one of the following recorded surveillance is Procedure 6.FP.201, Rev. 15, methods. conducted to ensure that the Operations Cycling of Fire Main Fire Protection system valve Valves (a) Electrical supervision with positions are correct.
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| audible and visual signals in the Procedures 6.FP.201, 6.FP.301, Procedure 6.FP.301, Rev. 17, main control room or other suitable and 6.FP.302 provide Operations Power Block Sprinkler constantly attended location. verification of the status (locked System Testing or sealed) of each fire main and (b) Locking valves in their normal suppression system valve. The Procedure 6.FP.302, Rev. 22, position. Keys shall be made Fire Protection System Flow Automatic Deluge and Pre-Action available only to authorized Drawing 2016 Sht. 7 documents Systems Testing personnel. that each valve is located within the CNS Protected Area.
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| (c) Sealing valves in their normal Page A-52
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document positions. This option shall be utilized only where valves are located within fenced areas or under the direct control of the owner/operator.
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| 3.5.15 [Water Supply - Hydrants shall be installed Complies with use of Complies with use of EEEEs Cooper Nuclear Station Updated Hydrant Code approximately every 250 ft (76 m) Existing Engineering Hose house equipment is in Safety Analysis Report, loep xxv2 Requirements] apart on the yard main system. A Equivalency Evaluations accordance with the hose house equipped with hose (EEEEs) requirements of NFPA 24-1973, EE 01-009, Rev. 3, Review of NFPA and combination nozzle and other as documented in Engineering 10 & 14 & 24 Code Conformance for auxiliary equipment specified in Complies Evaluation EE 01-009. Power Block Buildings NFPA 24, "Standard for the Installation of Private Fire Service Complies Letter dated 5/23/79, from Ippolito Mains and Their Appurtenances," Per USAR Section X-9.3.2.1, an (NRC) to Pilant (NPPD).
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| shall be provided at intervals of not outside, 12-inch, underground more than 1000 ft (305 m) along the yard loop surrounds the Station Procedure 6.FP.608, Rev. 23, yard main system. and provides water to hydrants, License Required Fire Fighting wet standpipes, hose stations, Equipment Monthly Examination Exception: Mobile means of deluge spray systems, and providing hose and associated sprinkler systems. Hydrants with equipment, such as hose carts or two gated discharge ports are trucks, shall be permitted in lieu of provided on the yard main at hose houses. Where provided, such approximately 250-foot mobile equipment shall be intervals. Fire hydrants are equivalent to the equipment provided with an isolation valve supplied by three hose houses. in order to isolate the hydrant in the event of physical damage or mechanical malfunction.
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| Procedure 6.FP.608, Attachment 2 documents the location and equipment provided in each outside hose cabinet.
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| Per Section 4.3.1.3 of the CNS Fire Protection SER dated 5/23/79, hose houses have been provided at, as a minimum, every other hydrant.
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| 3.5.16 [Water Supply - The fire protection water supply Complies Complies Drawing 2016, Sht. 1, Rev. N63, Flow Dedicated Limits] system shall be dedicated for fire The Fire Protection System Flow Diagram Fire Protection Turbine protection use only. Complies with Required Drawings 2016 Sht. 1, 2, 3, 6, 7, Generator Bldg.
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| Page A-53
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Action 1A, lB, and lC document that Exception No. 1: Fire protection the water tanks, fire pumps, and Drawing 2016, Sht. 2, Rev. N31, Fire water supply systems shall be piping network are dedicated for Protection System Flow Diagram for permitted to be used to provide fire protection use only. Pumphouse and Storage Tanks backup to nuclear safety systems, provided the fire protection water Complies with Required Action Drawing 2016, Sht. 3, Rev. N25, Fire supply systems are designed and Implementation Item S-3.22 - Protection System Flow Diagram maintainedto deliver the combined Procedures will be revised to fire and nuclear safety flow ensure that the fire protection Drawing 2016, Sht. 6, Rev. N01, Flow demands for the duration specified system is not to be used for non- Diagram Fire Protection System Multi by the applicable analysis. emergency usage. See Purpose Facility Attachment S, Table S-3.
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| Exception No. 2: Fire protection Drawing 2016, Sht. 7, Rev. N07, Fire water storage can be provided by Protection System Site Plan Flow plant systems serving other Diagram functions, provided the storage has a dedicated capacity capable of Drawing 2016, Sht. 1A, Rev. N08, providing the maximum fire Flow Diagram Fire Protection Service protection demand for the specified Bldg's &Yard duration as determined in this section. Drawing 2016, Sht. 1B, Rev. N02, Flow Diagram Fire Protection Cont.
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| RDW &ARDW Bldg.'s Drawing 2016, Sht. 1C, Rev. N03, Flow Diagram Fire Protection Reactor Building 3.6 Standpipe and Hose N/A N/A Section Heading - See None Stations compliance bases below for compliance statements for specific subsections.
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| 3.6.1 [Standpipe and For all power block buildings, Class Complies by Previous Complies by Previous NRC EE 01-009, Rev. 3, Review of NFPA Hose Stations - Code III standpipe and hose systems NRC Approval Approval 10 & 14 & 24 Code Conformance for Requirements] shall be installed in accordance with CNS utilizes a Class II standpipe Power Block Buildings NFPA 14, "Standard for the Complies with use of service, not Class III as required Installation of Standpipe, Private Existing Engineering by this section. The system was Letter dated 12/17/76, Response to Hydrant, and Hose Systems." Equivalency Evaluations previously approved by the Appendix A to Branch Technical (EEEEs) NRC. The NPPD response to Position APCB 9.5-1 Guidelines for Branch Technical Position Fire Protection for Nuclear Power Submit for NRC APCSB 9.5-1, Appendix A, Plants, from Pilant (NPPD) to Approval dated 12/17/76, states: Ziemann (NRC).
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| Page A-54
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document "As a result of the October 1976 Letter dated 5/23/79, from Ippolito site inspection, it was found that (NRC) to Pilant (NPPD).
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| a minimum of five additional 1 1/2" fire hose connections are MDC 77-015, Fire Protection needed to provide application of Modifications at least one effective hose stream to all areas of the Main Plant. At present, a survey is underway to determine which areas of the Main Plant are not provided with manual back-up fire hose coverage. As a result of this survey, consideration will be given to providing an additional 25' length of 1 1/2" woven jacket lined fire hose to the existing 75' length of fire hose and replacement of the existing hose racks with hose reels...
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| "...All existing inside 1 1/2" fire hose connections are provided with combination spray nozzles suitable for Class A & B fires.
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| These nozzles will be replaced with nozzles suitable for use on Class A, B & C type fires..."
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| Section 4.3.14 of the CNS Fire Protection SER dated 5/23/79 states:
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| "Fifty-four interior hose stations are strategically located throughout the plant. Each hose station is equipped with 75 feet of 1-1/2 inch woven jacketed rubber lined hose with adjustable fog nozzles...
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| Page A-55
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document "Four additional fire hose stations will be provided in the reactor building to adequately protect the area.
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| "Additional hose (25 feet) will be provided for the computer room and 903' elevation of the control building. With the addition of these lengths of hose, all safety related areas can be reached by at least one hose stream. Some interior nozzles will be replaced by spray only types.
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| "We find, that subject to the above described modifications, the hose stations satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable."
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| Modification MDC 77-015 installed the additional four hose stations in the Reactor Building and installed the additional 25 feet of hose. The hose station and standpipe configuration, as approved by the SER, is still used at CNS. There have been no additional plant modifications or other changes that would invalidate the basis for approval.
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| This feature remains unchanged.
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| Complies with use of EEEEs Installation of the Class II standpipe and hose systems is in accordance with the requirements of NFPA 14-1974, as documented in Engineering Page A-56
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Evaluation EE 01-009.
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| Submit for NRC Approval Refer to Attachment L for further details on the request for NRC approval for the deviation against Sections 322, 442, 625, and 671 of NFPA 14-1974 for the standpipe and hose station installations.
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| 3.6.2 [Standpipe and A capability shall be provided to Complies Hydraulic calculation 9.41-001 Calculation 9.41-001, Fire Flow, Hose Stations - ensure an adequate water flow rate demonstrates adequate water Pressure Required, and Storage Capability Limitations] and nozzle pressure for all hose flow rate and nozzle pressure Requirements, Rev. 0 stations. This capability includes the for all hose stations.
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| provision of hose station pressure reducers where necessary for the safety of plant industrial fire brigade members and off-site fire department personnel.
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| 3.6.3 [Standpipe and The proper type of hose nozzle to Complies Per USAR Section X-9.3.2.2, Cooper Nuclear Station Updated Hose Stations - Nozzle be supplied to each power block wet standpipe hose stations are Safety Analysis Report, loep xxv2 Restrictions] area shall be based on the area fire located throughout the plant in hazards. The usual combination strategic locations to assure spray/straight stream nozzle shall hose stream coverage and to not be used in areas where the serve as backup for fixed straight stream can cause suppression systems. Hose unacceptable damage or present stations have either 75 or 100 an electrical hazard to fire-fighting feet of 1 1/2-inch lined hose, as personnel. Listed electrically safe deemed necessary. Where fixed fog nozzles shall be provided appropriate, hoses are supplied at locations where high-voltage with a nozzle suitable for use on shock hazards exist. All hose Class A, B, and C type fires.
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| nozzles shall have shutoff capability and be able to control water flow from full open to full closed.
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| 3.6.4 [Standpipe and Provisions shall be made to supply Complies by Previous The licensing of CNS preceded Letter dated 12/4/1972, Amendment Hose Stations - water at least to standpipes and NRC Approval the issuance of NUREG-75/087, No. 15 to License Application Filed on Earthquake Provisions] hose stations for manual fire Section 9.5-1, Rev. 1, which July 27, 1967, from Reder (NPPD) to suppression in all areas containing required the fire suppression Muntzing (U.S. Atomic Energy systems and components needed system to be capable of Commission) to perform the nuclear safety delivering water to manual hose Page A-57
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| Nebraska Public Power District NtCNS NPA 805 Transition Reort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document functions in the event of a safe stations located within hose NUREG-75/087, Standard Review shutdown earthquake (SSE). reach of areas containing Plan, Section 9.5-1, Fire Protection equipment required for safe Program, Rev. 1, dated May 1976 Note: The exception to this section plant shutdown following the is not endorsed by 10CFR50.48(c) safe shutdown earthquake Report dated 2/14/1973, Safety (2)(vi) and has been removed. (SSE). However, in response to Evaluation of the Cooper Nuclear Final Safety Analysis Report Station, U.S. Atomic Energy (FSAR) Question and Answer Commission.
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| 10.15, NPPD committed in FSAR Amendment 15 that whenever fire protection piping passes over or near the Class IS piping or equipment in the Reactor Building, Control Building, or Intake Structure (the building containing Essential Class IS equipment necessary for safe shutdown serviced by the Fire Water System), it will be supported and restrained to withstand a Class IS seismic occurrence and maintain structural and pressure integrity.
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| This was partially acknowledged in Section 9.3.4, "The applicant agreed to modify Fire Protection System piping to Class I (seismic) standards in all areas where it passed over or near the Class I (seismic) systems."
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| Furthermore, USAR Section X-9.5 describes that the entire Fire Protection System piping and sprinklers in the Reactor Building and Control Building as being supported and restrained to Seismic Class IS criteria. The Fire Protection System piping in the SW Pump Room is supported to the barge impact criteria, which is bounding over SSE.
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| Page A-58
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.6.5 [Standpipe and Where the seismic required hose N/A Not Applicable. The fire None Hose Stations - Seismic stations are cross-connected to protection system seismically-Connection Limitations] essential seismic non-fire protection restrained piping is not cross-water supply systems, the fire flow connected to any essential non-shall not degrade the essential fire systems.
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| water system requirement.
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| 3.7 Fire Extinguishers Where provided, fire extinguishers Complies with use of Complies with use of EEEEs Engineering Evaluation EE 01-009, of the appropriate number, size, Existing Engineering Portable fire extinguishers are in Rev. 3, Review of NFPA 10 & 14 & 24 and type shall be provided in Equivalency Evaluations accordance with the Code Conformance for Power Block accordance with NFPA 10, (EEEEs) requirements of NFPA 10-1975, Buildings "Standard for Portable Fire as documented in Engineering Extinguishers." Extinguishers shall Submit for NRC Evaluation EE 01-009.
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| be permitted to be positioned Approval outside of fire areas due to Submit for NRC Approval radiological conditions. Refer to Attachment L for further details on the request for NRC approval for the deviation against Section 3-3 of NFPA 10-1975 for fire extinguisher size and placement for Class B fires.
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| 3.8 Fire Alarm and N/A N/A Section Heading - See None Detection Systems compliance bases below for compliance statements for specific subsections.
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| 3.8.1 Fire Alarm Alarm initiating devices shall be Complies with use of Complies with use of EEEEs Drawing SK300, Sht. 1, Rev. N10, installed in accordance with NFPA Existing Engineering The fire alarm system is in Fire Alarm Panel Annunciator 72, "National Fire Alarm Code." Equivalency Evaluations accordance with the Elementary Alarm annunciation shall allow the (EEEEs) requirements of NFPA 72A-1 975 proprietary alarm system to transmit and NFPA 72D-1975, as Drawing SK300, Sht. 2, Rev. N11, fire-related alarms, supervisory Complies documented in Engineering Fire Alarm Panel Annunciator signals, and trouble signals to the Evaluations EE 01-006, EE Elementary control room or other constantly 01-013, and EE 01-014.
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| attended location from which Drawing SK300, Sht. 3, Rev. N05, required notifications and response Complies Fire Panel Alarm Window #5 can be initiated. Personnel Schematic drawings SK300, Annunciator Elementary assigned to the proprietary alarm Sht. 1, 2, and 3 document alarm station shall be permitted to have annunciation of transmit fire- EE 01-006, Rev. 3, Disposition of other duties. The following fire- related alarms, supervisory NFPA Code Compliance Deviations related signals shall be transmitted: signals, and trouble signals in (Systems in Fire Zones Requiring an the Control Room. IPEEE Phase 2 Screening)
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| Page A-59
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document EE 01-013, Rev. 2, Disposition of NFPA Code Deviations (Non Phase 2 IPEEE Power Block Systems)
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| EE 01-014, Rev. 0, Disposition of NFPA Code Compliance Deviations (Non-Power Block Systems) 3.8.1 Fire Alarm (1) Actuation of any fire detection Complies Schematic drawings SK300, Drawing SK300, Sht. 1, Rev. N10, device Sht. 1, 2, and 3 document the Fire Alarm Panel Annunciator Control Room fire panel alarm Elementary annunciation for fire detection devices. Drawing SK300, Sht. 2, Rev. N1 1, Fire Alarm Panel Annunciator Elementary Drawing SK300, Sht. 3, Rev. N05, Fire Panel Alarm Window #5 Annunciator Elementary 3.8.1 Fire Alarm (2) Actuation of any fixed fire Complies Schematic drawings SK300, Drawing SK300, Sht. 1, Rev. N10, suppression system Sht. 1, 2, and 3 document the Fire Alarm Panel Annunciator Control Room fire panel alarm Elementary annunciation for fixed fire suppression systems. Drawing SK300, Sht. 2, Rev. N11, Fire Alarm Panel Annunciator Elementary Drawing SK300, Sht. 3, Rev. N05, Fire Panel Alarm Window #5 Annunciator Elementary 3.8.1 Fire Alarm (3) Actuation of any manual fire alarm Complies Schematic drawing SK300, Sht. Drawing SK300, Sht. 1, Rev. N10, station 1 documents the Control Room Fire Alarm Panel Annunciator fire panel alarm annunciation for Elementary manual pull stations.
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| 3.8.1 Fire Alarm (4) Starting of any fire pump Complies Schematic drawing SK300, Sht. Drawing SK300, Sht. 2, Rev. Nil, 2 documents the Control Room Fire Alarm Panel Annunciator fire panel alarm annunciation for Elementary the starting of the fire pumps.
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| 3.8.1 Fire Alarm (5) Actuation of any fire protection Complies Schematic drawings SK300, Drawing SK300, Sht. 1, Rev. N10, supervisory device Sht. 1, 2, and 3 document the Fire Alarm Panel Annunciator Control Room fire panel alarm Elementary Page A-60
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document annunciation for fire protection supervisory devices. Drawing SK300, Sht. 2, Rev. N11, Fire Alarm Panel Annunciator Elementary Drawing SK300, Sht. 3, Rev. N05, Fire Panel Alarm Window #5 Annunciator Elementary 3.8.1 Fire Alarm (6) Indication of alarm system trouble Complies Schematic drawings SK300, Drawing SK300, Sht. 1, Rev. N10, condition Sht. 1, 2, and 3 document the Fire Alarm Panel Annunciator Control Room fire panel alarm Elementary annunciation for alarm system trouble conditions. Drawing SK300, Sht. 2, Rev. N11, Fire Alarm Panel Annunciator Elementary Drawing SK300, Sht. 3, Rev. N05, Fire Panel Alarm Window #5 Annunciator Elementary 3.8.1.1 [Fire Alarm - Means shall be provided to allow a Complies USAR Section X-16 documents Cooper Nuclear Station Updated Communications person observing a fire at any the communication systems are Safety Analysis Report, loep xxv2 Requirements] location in the plant to quickly and available to allow a person reliably communicate to the control observing a fire to effectively Procedure 5.7COMMUN, Rev. 16, room or other suitable constantly communicate to the Control Communications attended location. Room.
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| Procedure 5.7COMMUN, Attachment 1 details the communications systems which are installed at the plant and basic instructions for their operation, which includes portable radios, plant phones, and gaitronics.
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| 3.8.1.2 [Fire Alarm - Means shall be provided to N/A Introductory Statement - See None Prompt Notification promptly notify the following of any compliance bases below for Limits] fire emergency in such a way as to compliance statements for allow them to determine an specific subsections.
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| appropriate course of action:
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| 3.8.1.2 [Fire Alarm - General site population in all Complies USAR Section X-16 describes Cooper Nuclear Station Updated Prompt Notification occupied areas that emergency signals (fire, Safety Analysis Report, loep xxv2 Page A-61
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Limits] (1) evacuation, all clear) are generated by a tone generator located in the Control Room.
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| The emergency signals are carried over the paging channel and all of the speakers.
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| 3.8.1.2 [Fire Alarm - Members of the industrial fire Complies USAR Section X-16 describes Cooper Nuclear Station Updated Prompt Notification brigade and other groups that emergency signals (fire, Safety Analysis Report, loep xxv2 Limits] (2) supporting fire emergency response evacuation, all clear) are generated by a tone generator located in the Control Room.
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| The emergency signals are carried over the paging channel and all of the speakers.
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| 3.8.1.2 [Fire Alarm - Off-site fire emergency response Complies Per Procedure 5.1 INCIDENT, Procedure 5.1 INCIDENT, Rev. 21, Prompt Notification agencies. Two independent means Attachment 2 requires that the Site Emergency Incident Limits] (3) shall be available (e.g., telephone Shift Manager is responsible for and radio) for notification of off-site contacting the Nebraska Procedure 5.7COMMUN, Rev. 16, emergency services. Emergency Management Communications Agency NEMA for additional fire response assistance. The Nebraska Emergency Management Agency NEMA is available by two different telephone numbers.
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| Procedure 5.7COMMUN, Section 12.1 requires that a cross-band, two-way radio communications system exists between CNS and the Nemaha County Sheriffs Office as an additional source of communication between the plant and the off-site emergency response teams.
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| 3.8.2 Detection If automatic fire detection is Complies with use of The fire detection devices are EE 01-007, Rev. 2, Fire Detector required to meet the performance Existing Engineering installed in accordance with the Location and Spacing or deterministic requirements of Equivalency Evaluations requirements of NFPA Chapter 4, then these devices shall (EEEEs) 72E-1974, as documented in EE 01-013, Rev. 2, Disposition of be installed in accordance with Engineering Evaluations EE NFPA Code Deviations (Non Phase 2 Page A-62
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document NFPA 72, "National Fire Alarm 01-007, EE 01-013, and EE IPEEE Power Block Systems)
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| Code," and its applicable 01-014. The systems credited to appendixes. meet the requirements of EE 01-014, Rev. 0, Disposition of Chapter 4 are identified in Table NFPA Code Compliance Deviations 4-3 of the Transition Report. (Non-Power Block Systems) 3.9 Automatic and N/A N/A Section Heading - See None Manual Water-Based compliance bases below for Fire Suppression compliance statements for Systems specific subsections.
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| 3.9.1 [Automatic and If an automatic or manual water- N/A Introductory Statement - See None Manual Water-Based based fire suppression system is compliance bases below for Fire Suppression required to meet the performance compliance statements for Systems - Code or deterministic requirements of specific subsections.
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| Requirements] Chapter 4, then the system shall be installed in accordance with the appropriate NFPA standards including the following:
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| 3.9.1 [Automatic and NFPA 13, "Standard for the Complies with use of The automatic sprinkler systems EE 01-006, Rev. 3, Disposition of Manual Water-Based Installation of Sprinkler Systems" Existing Engineering are installed in accordance with NFPA Code Compliance Deviations Fire Suppression Equivalency Evaluations the requirements of the (Systems in Fire Zones Requiring an Systems - Code (EEEEs) applicable code of record as IPEEE Phase 2 Screening)
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| Requirements] (1) documented in Engineering Evaluations EE 01-006, EE EE 01-013, Rev. 2, Disposition of 01-013, and EE 01-014. The NFPA Code Deviations (Non Phase 2 systems credited to meet the IPEEE Power Block Systems) requirements of Chapter 4 are identified in Table 4-3 of the EE 01-014, Rev. 0, Disposition of Transition Report. NFPA Code Compliance Deviations (Non-Power Block Systems) 3.9.1 [Automatic and NFPA 15, "Standard for Water Complies with use of The automatic water spray EE 01-006, Rev. 3, Disposition of Manual Water-Based Spray Fixed Systems for Fire Existing Engineering systems are installed in NFPA Code Compliance Deviations Fire Suppression Protection" Equivalency Evaluations accordance with the (Systems in Fire Zones Requiring an Systems - Code (EEEEs) requirements of the applicable IPEEE Phase 2 Screening)
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| Requirements] (2) code of record as documented in Engineering Evaluations EE EE 01-013, Rev. 2, Disposition of 01-006 and EE 01-013. The NFPA Code Deviations (Non Phase 2 systems credited to meet the IPEEE Power Block Systems) requirements of Chapter 4 are identified in Table 4-3 of the Transition Report.
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| Page A-63
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.9.1 [Automatic and NFPA 750, "Standard on Water N/A Not Applicable. There are no None Manual Water-Based Mist Fire Protection Systems" water mist systems at CNS.
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| Fire Suppression Systems - Code Requirements] (3) 3.9.1 [Automatic and NFPA 16, "Standard for the N/A Not Applicable. There are no None Manual Water-Based Installation of Foam-Water Sprinkler foam-water sprinkler or foam-Fire Suppression and Foam-Water Spray Systems" water spray systems at CNS.
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| Systems - Code Requirements] (4) 3.9.2 [Automatic and Each system shall be equipped with Complies Water flow alarms are installed Drawing 2016, Sht. 1, Rev. N62, Flow Manual Water-Based a water flow alarm. on all systems per review of Diagram Fire Protection Turbine Fire Suppression associated references. Generator Bldg.
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| Systems - Flow Alarm]
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| Drawing 2016, Sht. 1A, Rev. N08, Flow Diagram Fire Protection Service Bldg's & Yard Drawing 2016, Sht. 1B, Rev. N02, Flow Diagram Fire Protection Cont.
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| RDW &ARDW Bldg.'s Drawing 2016, Sht. 1C, Rev. N03, Flow Diagram Fire Protection Reactor Building Procedure 6.FP.301, Rev. 17, Operations Power Block Sprinkler System Testing Procedure 6.FP.302, Rev. 22, Automatic Deluge and Pre-Action Systems Testing Procedure 6.FP.307, Rev. 19, Operations Out-Building Sprinkler System Testing Procedure 15.FP.648, Rev. 5, Outside Transformer Deluge System Flow Test Page A-64
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.9.3 [Automatic and All alarms from fire suppression Complies Schematic drawings SK300, Drawing SK300, Sht. 1, Rev. N10, Manual Water-Based systems shall annunciate in the Sht. 1, 2, and 3 document the Fire Alarm Panel Annunciator Fire Suppression control room or other suitable Control Room fire panel alarm Elementary Systems - Alarm constantly attended location, annunciation for fire suppression Locations] system alarms. Drawing SK300, Sht. 2, Rev. N11, Fire Alarm Panel Annunciator Elementary Drawing SK300, Sht. 3, Rev. N05, Fire Panel Alarm Window #5 Annunciator Elementary 3.9.4 [Automatic and Diesel-driven fire pumps shall be Complies Drawing 2016, Sht. 2 documents Drawing 2016, Sht. 2, Rev. N31, Fire Manual Water-Based protected by automatic sprinklers, that the Diesel Driven Fire Pump Protection System Flow Diagram for Fire Suppression Room is provided with an Pumphouse and Storage Tanks Systems - Diesel Pump automatic wet pipe sprinkler Sprinkler Protection] system.
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| 3.9.5 [Automatic and Each system shall be equipped with Complies The referenced flow diagrams Drawing 2016, Sht. 1, Rev. N63, Flow Manual Water-Based an OS&Y gate valve or other show valves for each Diagram Fire Protection Turbine Fire Suppression approved shutoff valve, suppression system. Generator Bldg.
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| Systems - Shutoff Controls] Drawing 2016, Sht. 2, Rev. N31, Fire Protection System Flow Diagram for Pumphouse and Storage Tanks Drawing 2016, Sht. 3, Rev. N25, Fire Protection System Flow Diagram Drawing 2016, Sht. 6, Rev. N01, Flow Diagram Fire Protection System Multi Purpose Facility Drawing 2016, Sht. 7, Rev. N07, Fire Protection System Site Plan Flow Diagram Drawing 2016, Sht. 1A, Rev. N08, Flow Diagram Fire Protection Service Bldg's & Yard Drawing 2016, Sht. 1B, Rev. N02, Flow Diagram Fire Protection Cont.
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| Page A-65
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document RDW & ARDW Bldg.'s Drawing 2016, Sht. 1C, Rev. N03, Flow Diagram Fire Protection Reactor Building 3.9.6 [Automatic and All valves controlling water-based Complies A program at the station Drawing 2016, Sht. 7, Rev. N07, Fire Manual Water-Based fire suppression systems required requires fire protection valves to Protection System Site Plan Flow Fire Suppression to meet the performance or be sealed or locked in the Diagram Systems - Valve deterministic requirements of normal open position. A periodic Supervision] Chapter 4 shall be supervised as recorded surveillance is Procedure 6.FP.201, Rev. 15, described in 3.5.14. conducted to ensure that the Operations Cycling of Fire Main Fire Protection system valve Valves positions are correct.
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| Procedures 6.FP.201, 6.FP.301, Procedure 6.FP.301, Rev. 17, and 6.FP.302 provide Operations Power Block Sprinkler verification of the status (locked System Testing or sealed) of each fire main and suppression system valve. The Procedure 6.FP.302, Rev. 22, Fire Protection System Flow Automatic Deluge and Pre-Action Drawing 2016 Sht. 7 documents Systems Testing that each valve is located within the CNS Protected Area.
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| 3.10 Gaseous Fire N/A N/A Section Heading - See None Suppression Systems compliance bases below for compliance statements for specific subsections.
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| 3.10.1 [Gaseous Fire If an automatic total flooding and N/A Introductory Statement - See None Suppression Systems - local application gaseous fire compliance bases below for Code Requirements] suppression system is required to compliance statements for meet the performance or specific subsections.
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| deterministic requirements of Chapter 4, then the system shall be designed and installed in accordance with the following applicable NFPA codes:
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| 3.10.1 [Gaseous Fire NFPA 12, "Standard on Carbon Complies with use of The carbon dioxide systems are EE 01-006, Rev. 3, Disposition of Suppression Systems - Dioxide Extinguishing Systems" Existing Engineering installed in accordance with the NFPA Code Compliance Deviations Code Requirements] (1) Equivalency Evaluations requirements of NFPA 12-1972 (Systems in Fire Zones Requiring an (EEEEs) as documented in Engineering IPEEE Phase 2 Screening)
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| Evaluation EE 01-006. The systems credited to meet the Page A-66
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document requirements of Chapter 4 are identified in Table 4-3 of the Transition Report.
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| 3.10.1 [Gaseous Fire NFPA 12A, "Standard on Halon Complies with use of The Halon systems in the EE 01-006, Rev. 3, Disposition of Suppression Systems - 1301 Fire Extinguishing Systems" Existing Engineering Computer Room and SW Pump NFPA Code Compliance Deviations Code Requirements] (2) Equivalency Evaluations Room are installed in (Systems in Fire Zones Requiring an (EEEEs) accordance with the IPEEE Phase 2 Screening) requirements of NFPA 12A-1 980 as documented in Engineering EE 01-013, Rev. 2, Disposition of Evaluations EE 01-006 and EE NFPA Code Deviations (Non Phase 2 01-013. The systems credited to IPEEE Power Block Systems) meet the requirements of Chapter 4 are identified in Table 4-3 of the Transition Report.
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| 3.10.1 [Gaseous Fire NFPA 2001, "Standard on Clean N/A Not Applicable. There are no None Suppression Systems - Agent Fire Extinguishing Systems" clean agent fire extinguishing Code Requirements] (3) systems installed.
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| 3.10.2 [Gaseous Fire Operation of gaseous fire Complies Carbon dioxide system Drawing FH-16282, Sht. 3, Rev. N07, Suppression Systems - suppression systems shall connection diagrams document Cardox High Press Fire Extinguishing Alarm Location] annunciate and alarm in the control annunciation and alarm of the System Elementary Line Connection room or other constantly attended operation of the C02 systems in Diagram location identified. the Control Room. Schematic drawings SK300, Sht. 2 and 3 Drawing FL-16551, Sht. 6, Rev. N05, document the Control Room fire Cardox Fire Extinguishing System panel alarm annunciation for Elementary Line &Connection C02 and Halon suppression Diagram system alarms. Drawing SK300, Sht.
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| 2, Rev. Nil, Fire Alarm Panel Annunciator Elementary Drawing SK300, Sht. 3, Rev. N05, Fire Panel Alarm Window #5 Annunciator Elementary 3.10.3 [Gaseous Fire Ventilation system design shall take Complies Complies Drawing 2221, Rev. N03, H.V.A.C-Suppression Systems - into account prevention from over- Drawing 2221 indicates that Plan & Sections Diesel Generator Ventilation Limitations] pressurization during agent Complies with pressure relief dampers are Bldg. Heating Boiler Room injection, adequate sealing to Clarification provided for the DG Room C02 prevent loss of agent, and systems. System Pre- System Pre-Operational Test BR-67, confinement of radioactive Operational Test BR-67 dated 04/04/1973 contaminants. documents that concentration Page A-67
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| Nebraska Public Power District CNS NFPA 805 Transition ReDort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
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| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document and hold time requirements were met showing that adequate sealing is provided.
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| Complies with Clarification Halon activation does result in an over-pressurization in Halon concentrations of 10% or greater per NFPA 12A-2009 Annex B. Halon systems installed at CNS are designed to maintain concentrations below 10% during system activation.
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| The SW Pump Room concentration is 8% and the Computer Room is 6%. These systems are designed with safety margins of 20% and 40%,
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| respectively.
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| There are no radioactive contaminants in the areas provided with Halon or C02 system protection.
| |
| 3.10.4 [Gaseous Fire In any area required to be protected N/A Not Applicable. No areas are None Suppression Systems - by both primary and backup protected by both primary and Single Failure Limits] gaseous fire suppression systems, backup gaseous suppression a single active failure or a crack in systems.
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| any pipe in the fire suppression system shall not impair both the primary and backup fire suppression capability.
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| 3.10.5 [Gaseous Fire Provisions for locally disarming Complies Complies DC 85-01, Halon 1301 Fire Suppression Systems - automatic gaseous suppression The SW Pump Room and Suppression System for Service Disarming Controls] systems shall be secured and Submit for NRC Computer Room Halon systems Water Pump Room under strict administrative control. Approval are provided with keyed abort switches. Operation of the abort Drawing FH-16282, Sht. 3, Rev. N07, switch will annunciate in the Cardox High Press Fire Extinguishing Control Room. System Elementary Line Connection Diagram Submit for NRC Approval Page A-68
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document The Diesel Generator High Procedure 6.FP.305, Rev. 11, Halon Pressure Cardox System, 1301 Service Water Pump Room Fire although not provided with Suppression Surveillance Checks keyed abort switches, is provided with abort switches that Procedure 15.FP.307, Rev. 6, Halon will annunciate in the Control 1301 Computer Room Fire Room upon operation. Refer to Suppression Surveillance Checks Attachment L for further details on the request for NRC approval of the lack of local keyed abort switches.
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| 3.10.6 Total flooding carbon dioxide Complies The Diesel Generator Rooms CNS Fire Hazards Analysis, Rev.
| |
| [Gaseous Fire systems shall not be used in are not normally occupied 9/26/2011 Suppression Systems - normally occupied areas. areas.
| |
| C02 Limitations]
| |
| 3.10.7 Automatic total flooding carbon Complies Complies Drawing FH-16282, Sht. 3, Rev. N07,
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| [Gaseous Fire dioxide systems shall be equipped Carbon dioxide system Cardox High Press Fire Extinguishing Suppression Systems - with an audible pre-discharge alarm Submit for NRC connection diagrams document System Elementary Line Connection C02 Warnings] and discharge delay sufficient to Approval an audible alarm of the Diagram permit egress of personnel. The operation of the C02 systems in carbon dioxide system shall be the Control Room. Drawing FL-16551, Sht. 6, Rev. N05, provided with an odorizer. Cardox Fire Extinguishing System Submit for NRC Approval Elementary Line &Connection The DG High Pressure C02 Diagram System is not provided with an odorizer. Refer to Attachment L for further details on the request for NRC approval of the lack of an odorizer on the DG High Pressure C02 System.
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| 3.10.8 Positive mechanical means shall be Complies The referenced drawings and Drawing FH-16282, Sht. 3, Rev. N07,
| |
| [Gaseous Fire provided to lock out total flooding procedures document the Cardox High Press Fire Extinguishing Suppression Systems - carbon dioxide systems during work mechanical lock out capability System Elementary Line Connection C02 Required in the protected space. via transfer selector switch for Diagram Disarming] the DG Room High Pressure C02 System. Drawing FL-16551, Sht. 6, Rev. N05, Cardox Fire Extinguishing System Elementary Line &Connection Diagram Procedure 2.2.2, Rev. 35, Carbon Page A-69
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Dioxide Systems 3.10.9 [Gaseous Fire The possibility of secondary thermal Complies Halon does not have a potential CNS Fire Hazards Analysis, Rev.
| |
| Suppression Systems - shock (cooling) damage shall be for thermal shock damage. 9/26/2011 Cooling Considerations] considered during the design of any gaseous fire suppression system, Appendix B of the Fire Hazards but particularly with carbon dioxide. Analysis (FHA) assesses the possibility of secondary thermal shock (cooling) damage due to discharge of the turbine bearing and DG Room C02 systems.
| |
| 3.10.10 [Gaseous Fire Particular attention shall be given to Complies CNS has Halon and C02 NFPA Fire Protection Handbook, 20th Suppression Systems - corrosive characteristics of agent systems which do not have any edition Decomposition Issues] decomposition products on safety corrosive characteristics of systems. agent decomposition products on safety systems.
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| 3.11 Passive Fire This section shall be used to N/A Introductory Statement - See None Protection Features determine the design and compliance bases below for installation requirements for passive compliance statements for protection features. Passive fire specific subsections.
| |
| protection features include wall, ceiling, and floor assemblies, fire doors, fire dampers, and through fire barrier penetration seals.
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| Passive fire protection features also include electrical raceway fire barrier systems (ERFBS) that are provided to protect cables and electrical components and equipment from the effects of fire.
| |
| 3.11.1 Building Each major building within the Complies Complies CNS Fire Hazards Analysis, Rev.
| |
| Separation power block shall be separated Table 3 of the Fire Hazards 9/26/2011 from the others by barriers having a Complies with use of Analysis (FHA) provides a listing designated fire resistance rating of Existing Engineering of required fire barriers, with Drawing 4003, Rev. N39, Overall Site 3 hours or by open space of at least Equivalency Evaluations their plant orientation, adjacent & Vicinity Plan 50 ft (15.2 m) or space that meets (EEEEs) zones and associated barrier the requirements of NFPA 80A, type (Appendix A, Appendix R or Drawing 4058, Rev. N02, Structural "Recommended Practice for Common to both Appendix A Turbine Generator Building Protection of Buildings from Exterior and Appendix R). In addition, Foundation Walls and Sections Fire Exposures." the individual FHA Fire Zone Matrix Tables, which are located Drawing 4059, Rev. 13, Structural Exception: Where a performance- in Section 9 of the FHA, provide Turbine Generator Building Concrete Page A-70
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document based analysis determines the a detailed fire barrier listing for Walls Sht. No.1 adequacy of building separation, the applicable Fire Zone. This the requirements of 3.11.1 shall not matrix identifies fire barrier Drawing 4123, Rev. N03, Structural apply. orientation, adjacent Fire Zone, Diesel Generator Building Plan at applicable CNS-FP drawing, Elev. 903'-6" & 917'-6" construction features, fire rating, and associated barrier type Drawing 4173, Rev. N01, Structural (Appendix A, Appendix R or Control Building Cable Room - Plans Common). Fire barrier ratings & Sections are assigned based on the construction features associated Drawing 4174, Rev. N05, Structural with the barrier. Construction Control Building Basement Plan &
| |
| features such as barrier Sections material, barrier thickness, fire damper design, fire door design, Drawing 4175, Rev. N02, Structural and penetration seal assemblies Control Building Operating Floor -
| |
| were reviewed as part of Plan and Sections assigning a rating to an individual fire barrier. Drawing 4180, Rev. N05, Structural Control Building Corridor Sh 1 The Reactor Building, Turbine Building, Control Building, Diesel Drawing 4219, Rev. N05, Structural Generator Building, Radwaste Reactor Bldg. EL. 903'-6" Plan, Building, Augmented Radwaste Sects., & Dets. SH #1 Building, Multi-Purpose Facility, and other buildings of the Power Drawing 4221, Rev. N03, Structural Block are separated from the Reactor Building EL 931'-6" Plan &
| |
| Intake Structure, Hydrogen Schedules Storage area, Off-Gas Building, ISFSI, flammable liquid storage Drawing 4222, Rev. N02, Structural trailer, warehouses, and Reactor Building EL. 958'-3" Plan and Security Building by open space Schedule greater than 50 feet where facing such buildings. Drawing 4223, Rev. N02, Structural Reactor Building EL. 976'-0" Plan &
| |
| All outdoor oil-filled transformers Schedule are more than 50 feet away from any opening in the exterior wall Drawing 4226, Rev. N01, Structural of the buildings containing safety Miscellaneous Concrete Details related equipment, with the exception of the spare Main Drawing 4306, Rev. N03, Structural Transformer. Radwaste Building Plan at Elev.
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| Page A-71
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 903'-6" Complies with use of EEEEs Structural drawings for the Drawing 4307, Rev. N04, Structural Turbine Building, Control Radwaste Building Plan at Elev.
| |
| Building, Reactor Building, 918'-0" Diesel Generator Building, Multi-Purpose Facility, Office Building, Drawing 4308, Rev. N03, Structural Radwaste Building and Radwaste Building Plan at Elev.
| |
| Augmented Radwaste Building 934'-0" indicate that the walls separating adjacent buildings are Drawing 4342, Rev. N03, Structural constructed of poured concrete Office Building Plan - Elev. 918'-0" with 3-hour fire rating. Doors within these barriers that do not Drawing 4403, Rev. 11, Structural meet the 3-hour fire rating have Augmented Radwaste Building been evaluated as adequate in Basement Plan Engineering Evaluation EE 09-047. Engineering Evaluation Drawing 4406, Rev. N02, Structural EE 09-035 evaluates the Augmented Radwaste Building Plans adequacy of the metal plate at Elev. 903'-6" covered door located less than 50 feet from the spare Main Drawing 4408, Rev. N01, Structural Transformer. Augmented Radwaste Building Floor El. 918'-6" Plan, Sect. & Dets.
| |
| The Fire Pump House is located less than 50 feet from the Multi- EE 09-035, Rev. 1, Evaluation of Fire Purpose Facility. The exposed Doors faces of the Fire Pump House and Multi-Purpose Facility are EE 09-047, Rev. 0, Doors Required solid poured concrete for NFPA 805 Building Separation construction, with only door opening in each exposed NFPA 80A-1996, Recommended building wall. The distance Practice for Protection of Buildings between the two buildings is 45 from Exterior Fire Exposures feet, and based on the reductions in separation distance allowed for in Chapter 4 for automatic suppression installed in the Fire Pump House, this configuration meets the requirements of NFPA 80A-1 996.
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| Page A-72
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.11.2 Fire Barriers Fire barriers required by Chapter 4 Complies Complies CNS Fire Hazards Analysis, Rev.
| |
| shall include a specific fire- Per Section 5.1.7(6) of the Fire 9/26/2011 resistance rating. Fire barriers shall Complies with use of Hazards Analysis (FHA), fire be designed and installed to meet Existing Engineering barrier ratings are assigned Drawing 4058, Rev. N02, Structural the specific fire resistance rating Equivalency Evaluations based on the construction Turbine Generator Building using assemblies qualified by fire (EEEEs) features associated with the Foundation Walls and Sections tests. The qualification fire tests barrier. In addition, the individual shall be in accordance with NFPA FHA Fire Zone Matrix Tables, Drawing 4059, Rev. 13, Structural 251, "Standard Methods of Tests of which are located in the FHA, Turbine Generator Building Concrete Fire Endurance of Building provide a detailed fire barrier Walls Sht. No. 1 Construction and Materials," or listing for the applicable fire ASTM E 119, "Standard Test zone. This matrix identifies fire Drawing 4123, Rev. N03, Structural Methods for Fire Tests of Building barrier orientation, adjacent Diesel Generator Building Plan at Construction and Materials." zone, applicable CNS-FP Elev. 903'-6" & 917'-6" drawing, construction features, fire rating and associated barrier Drawing 4173, Rev. N01, Structural type. Control Building Cable Room - Plans
| |
| & Sections The referenced structural drawings for required fire Drawing 4174, Rev. N05, Structural barriers indicate that the barriers Control Building Basement Plan &
| |
| are typically constructed of Sections poured concrete with 3-hour fire rating. Drawing 4175, Rev. N02, Structural Control Building Operating Floor -
| |
| Complies with use of EEEEs Plan and Sections Fire barrier features within these barriers that do not meet the 3- Drawing 4180, Rev. N05, Structural hour fire rating have been Control Building Corridor Sh 1 determined to be equivalent in the referenced evaluations. Drawing 4219, Rev. N05, Structural Reactor Bldg. EL. 903'-6" Plan, Sects., & Dets. SH #1 Drawing 4221, Rev. N03, Structural Reactor Building EL 931'-6" Plan &
| |
| Schedules Drawing 4222, Rev. N02, Structural Reactor Building EL. 958'-3" Plan and Schedule Page A-73
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Drawing 4223, Rev. N02, Structural Reactor Building EL. 976'-0" Plan &
| |
| Schedule Drawing 4226, Rev. N01, Structural Miscellaneous Concrete Details Drawing 4306, Rev. N03, Structural Radwaste Building Plan at Elev.
| |
| 903'-6" Drawing 4307, Rev. N04, Structural Radwaste Building Plan at Elev.
| |
| 918'-0" Drawing 4308, Rev. N03, Structural Radwaste Building Plan at Elev.
| |
| 934'-0" Drawing 4342, Rev. N03, Structural Office Building Plan - Elev. 918'-0" Drawing 4403, Rev. 11, Structural Augmented Radwaste Building Basement Plan Drawing 4406, Rev. N02, Structural Augmented Radwaste Building Plans at Elev. 903'-6" Drawing 4408, Rev. N01, Structural Augmented Radwaste Building Floor El. 918'-6" Plan, Sect. & Dets.
| |
| EE 05-034, Rev. 0, Evaluation of the Reclassification of Door R104 Under the FHA EE 09-031, Rev. 0, Evaluation of Critical Switchgear Rooms 1F and 1G Fire Barrier Separation Page A-74
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document EE 09-036, Rev. 0, Evaluation of Cable Expansion Room Penetration Seals EE 09-040, Rev. 0, Evaluation of Auxiliary Relay Room and RPS Room 1B Appendix R Fire Barriers EE 09-042, Rev. 0, Evaluation of 1-Hour Marinite Wall in Battery Room 1B EE 12-013, Rev. 0, Evaluation of the SLC Pump Tank and Accessway (Fire Zone 5A) and Refueling Floor (Fire Zone 6) Fire Barrier Separation EE 86-2, Rev. 1, Evaluation of a Ventilation Opening Through the Cable Spreading Room Floor Appendix R Fire Barrier EE 86-5, Rev. 1, Evaluation of HVAC Ducts and Fire Door Between the Control Room and Controlled Corridor EE 97-121, Rev. 1, Appendix R Fire Protection Evaluation of Control Building 882' Underground Cable Manholes EE 97-124, Rev. 1, Evaluation of Steam Tunnel East Wall Fire Barrier LBDCR 2004-023, Rev. 0, Evaluation of a FHA Revision to Relocate the Fire Barrier Between Fire Area IV/Fire Zone 8D and Fire Area VII/Fire Zone 24 3.11.3 Fire Barrier Penetrations in fire barriers shall be Complies with use of Complies with use of EEEEs CNS Fire Hazards Analysis, Rev.
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| Penetrations provided with listed fire-rated door Existing Engineering In some cases the doors and 9/26/2011 Page A-75
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Reoort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document assemblies or listed rated fire Equivalency Evaluations dampers do not have the same dampers having a fire resistance (EEEEs) rating. If the fire barrier could not rating consistent with the be assigned a rating or could designated fire resistance rating of Complies not achieve a rating of the barrier as determined by the approximately 50% greater than performance requirements the equivalent fire severity to established by Chapter 4. (See which it could be exposed, then 3.11.3.4 for penetration seals for engineering evaluations were through penetration fire stops.) developed to justify the adequacy of the barrier Exception: Where fire area configuration. Fire barriers boundariesare not wall-to-wall, which required these floor-to-ceiling boundarieswith all evaluations are annotated in the penetrationssealed to the fire rating FHA Fire Zone Matrix Table fire requiredof the boundaries,a barrier listings.
| |
| performance-basedanalysis shall be requiredto assess the adequacy Doors and fire dampers within of fire barrierforming the fire required fire barriers that do not boundary to determine if the barrier meet the 3-hour fire rating have will withstand the fire effects of the been evaluated as equivalent in hazards in the area. Openings in the engineering evaluations fire barriersshall be permitted to be referenced in Sections 3.11.3(1) protected by other means as and 3.11.3(2).
| |
| acceptable to the AHJ.
| |
| Complies Fire barrier openings (doors and dampers) typically have the same fire resistance as the fire barrier in which they are installed.
| |
| 3.11.3 [Fire Barrier Passive fire protection devices such Complies with use of A detailed review of CNS fire EE 05-034, Rev. 0, Evaluation of the Penetrations - NFPA 80] as doors and dampers shall Existing Engineering doors has been performed Reclassification of Door R104 Under (1) conform with the following NFPA Equivalency Evaluations against the requirements of the FHA standards, as applicable: (EEEEs) NFPA 80, as detailed in the NFPA 80-1975 code review EE 09-031, Rev. 0, Evaluation of NFPA 80, "Standard for Fire Doors checklist in Engineering Critical Switchgear Rooms 1F and 1G and Fire Windows" Evaluation EE 10-071. Fire Barrier Separation Doors within required fire EE 09-032, Rev. 0, Evaluation of DC barriers that do not meet the 3- SWGR Rooms 1A and 1B and Battery hour fire rating have been Rooms 1A and 1B Fire Barrier Page A-76
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition ReDort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document evaluated as equivalent in the Separation referenced engineering evaluations. EE 09-035, Rev. 1, Evaluation of Fire Doors EE 09-040, Rev. 0, Evaluation of Auxiliary Relay Room and RPS Room 1B Appendix R Fire Barriers EE 10-071, Rev. 0, CNS Acceptance of EPM Report No: R1906-002-002, NFPA Code Conformance Review EE 86-5, Rev. 1, Evaluation of HVAC Ducts and Fire Door Between the Control Room and Controlled Corridor 3.11.3 [Fire Barrier Passive fire protection devices such Complies with use of A detailed review of CNS fire EE 09-031, Rev. 0, Evaluation of Penetrations - NFPA as doors and dampers shall Existing Engineering dampers has been performed Critical Switchgear Rooms 1F and 1G 90A] (2) conform with the following NFPA Equivalency Evaluations against the requirements of Fire Barrier Separation standards, as applicable: (EEEEs) NFPA 90A, as detailed in the NFPA 90A-1985 code review EE 09-032, Rev. 0, Evaluation of DC NFPA 90A, "Standard for the checklist in Engineering SWGR Rooms 1A and 1B and Battery Installation of Air-Conditioning and Evaluation EE 10-071. Rooms 1A and 1B Fire Barrier Ventilating Systems" Separation Fire dampers within required fire barriers that do not meet the 3- EE 10-071, Rev. 0, CNS Acceptance hour fire rating have been of EPM Report No: R1906-002-002, evaluated as equivalent in NFPA Code Conformance Review Engineering Evaluation EE 09-031 and EE 09-032.
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| 3.11.3 [Fire Barrier Passive fire protection devices such Complies As described in Engineering EE 10-071, Rev. 0, CNS Acceptance Penetrations - NFPA as doors and dampers shall Evaluation EE 10-071, the of EPM Report No: R1906-002-002, 101] (3) conform with the following NFPA requirements of NFPA 101 NFPA Code Conformance Review standards, as applicable: applicable to fire doors and fire dampers are bound by NFPA 80 NFPA 101, "Life Safety Code" and NFPA 90A. NFPA 101 Section 8.2.3.2.1 refers to NFPA 80, and NFPA 101 Section 9.2.1 refers to NFPA 90A.
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| 3.11.4 Through Through penetration fire stops for N/A Introductory Statement - See None Penetration Fire Stops penetrations such as pipes, compliance bases below for Page A-77
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document conduits, bus ducts, cables, wires, compliance statements for pneumatic tubes and ducts, and specific subsections.
| |
| similar building service equipment that pass through fire barriers shall be protected as follows.
| |
| 3.11.4 [Through The annular space between the Complies Complies EE 09-031, Evaluation of Critical Penetration Fire Stops] penetrating item and the through Per Section 2.1 of Procedure Switchgear Rooms 1IF and 1IG Fire (a) opening in the fire barrier shall be Complies with use of 3.6.1, openings in or Barrier Separation, Rev. 0 filled with a qualified fire-resistive Existing Engineering penetrations of required fire penetration seal assembly capable Equivalency Evaluations barriers shall be sealed with an EE 09-032, Evaluation of DC SWGR of maintaining the fire resistance of (EEEEs) approved seal design with a fire Rooms 1lA and 1B and Battery the fire barrier. The assembly shall rating commensurate with the Rooms 1lA and 1lB Fire Barrier be qualified by tests in accordance rating of the fire barrier. The Separation, Rev. 0 with a fire test protocol acceptable CNS-FP-285 Fire Protection to the AHJ or be protected by a Plan drawings depict approved EE 09-036, Evaluation of Cable listed fire-rated device for the seal design details. Expansion Room Penetration Seals, specified fire-resistive period. Rev. 0 Per Section 2.3 of Procedure 3.6.1, all objects penetrating fire EE 97-124, Evaluation of Steam barriers (penetrants) shall be Tunnel East Wall Fire Barrier, Rev. 1 externally sealed using an approved fire rated seal design. Fire Protection Plan CNS-FP-285, Various designs of external Sht. 1, Rev. N06, CNS Fire Barrier seals are provided on the CNS- Penetration Seal Details FP-285 Fire Protection Plan drawings. Fire Protection Plan CNS-FP-285, Sht. 2, Rev. N04, CNS Fire Barrier Calculation NEDC 91-3, Penetration Seal Details Qualification of Fire Barrier Penetration Seal Details, Fire Protection Plan CNS-FP-285, provides technical justification Sht. 3, Rev. N06, CNS Fire Barrier for the penetration seal details Penetration Details utilized at CNS.
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| NEDC 91-3, Qualification of Fire Complies with use of EEEEs Barrier Penetration Seal Details Penetrations within required fire barriers that do not meet the 3- Procedure 3.6.1, Rev. 20, Fire Barrier hour fire rating have been Control evaluated as equivalent in the referenced engineering evaluations.
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| Page A-78
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.11.4 [Through Conduits shall be provided with an Complies Complies EE 10-055, Rev. 0, Fire Protection Penetration Fire Stops] internal fire seal that has an Section 2.4.1.3 of Procedure Evaluation of Internal Conduit Seals (b) equivalent fire-resistive rating to Complies with use of 3.6.1 provides the requirements that of the fire barrier through Existing Engineering for fire rated, smoke, and hot Procedure 3.6.1, Rev. 20, Fire Barrier opening fire stop and shall be Equivalency Evaluations gas internal seals. Control permitted to be installed on either (EEEEs) side of the barrier in a location that Complies with use of EEEEs is as close to the barrier as EE 10-055, Fire Protection possible. Evaluation of Internal Conduit Seals, provides a technical Exception: Openings inside conduit evaluation of the internal conduit 4 in. (10.2 cm) or less in diameter seal program, specifies the shall be sealed at the fire barrier specific criteria for providing with a fire-ratedinternal seal unless internal seals for conduits the conduit extends greaterthan 5 ft penetrating fire barriers, and (1.5 m) on each side of the fire evaluates the impact of these barrier.In this case the conduit criteria on existing internal opening shall be provided with conduit seals.
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| noncombustible materialto prevent the passage of smoke and hot gases. The fill depth of the material packed to a depth of 2 in. (5.1 cm) shall constitute an acceptable smoke and hot gas seal in this application.
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| 3.11.5 Electrical ERFBS required by Chapter 4 shall N/A There are no ERFBS installed at None Raceway Fire Barrier be capable of resisting the fire CNS.
| |
| Systems (ERFBS) effects of the hazards in the area.
| |
| ERFBS shall be tested in accordance with and shall meet the acceptance criteria of NRC Generic Letter 86-10, Supplement 1, "Fire Endurance Test Acceptance Criteria for Fire Barrier Systems Used to Separate Safe Shutdown Trains Within the Same Fire Area."
| |
| The ERFBS needs to adequately address the design requirements and limitations of supports and intervening items and their impact on the fire barrier system rating.
| |
| The fire barrier system's ability to Page A-79
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment A Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)
| |
| NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document maintain the required nuclear safety circuits 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 temperatures inside the fire barrier system exceed the maximum temperature allowed by the acceptance criteriaof Generic Letter 86-10, "FireEndurance Acceptance 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 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 DemonstratingFunctionalityof Cables Protected by 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 acceptableproviding that the system successfully met the limiting end point temperaturerequirements as specified by the AHJ at the time of acceptance.
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| Page A-80
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B ATTACHMENT B NEI 04-02 Table B Nuclear Safety Capability Assessment - Methodology Review 109 Pages Page B-1
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| | |
| Nebraska Public Power District NebrskaPublc istictCNS Pwer NFPA 805 Transition Re ort - Attac'hment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection A comprehensive list of systems and equipment and their interrelationships to be analyzed for a fire event shall be developed. The equipment list shall contain an inventory of those critical components required to achieve the nuclear safety performance criteria of Section 1.5. Components required to achieve and maintain the nuclear safety functions and components whose fire-induced failure could prevent the operation or result in the maloperation of those components needed to meet the nuclear safety criteria shall be included. Availability and reliability of equipment selected shall be evaluated.
| |
| NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3 Deterministic This section discusses a generic deterministic methodology and criteria that licensees can use to perform a post-fire safe Methodology shutdown analysis to address regulatory requirements. The plant-specific analysis approved by NRC is reflected in the plant's licensing basis. The methodology described in this section is also an acceptable method of performing a post-fire safe shutdown analysis. This methodology is indicated in Figure 3-1. Other methods acceptable to NRC may also be used. Regardless of the method selected by an individual licensee, the criteria and assumptions provided in this guidance document may apply. The methodology described in Section 3 is based on a computer database oriented approach, which is utilized by several licensees to model Appendix R data relationships. This guidance document, however, does not require the use of a computer database oriented approach.
| |
| The requirements of Appendix R Sections Ill.G.1, III.G.2 and III.G.3 apply to equipment and cables required for achieving and maintaining safe shutdown in any fire area. Although equipment and cables for fire detection and suppression systems, communications systems and 8-hour emergency lighting systems are important features, this guidance document does not address them.
| |
| [Refer to hardcopy of NEI 00-01 for Figure]
| |
| ADDlicability Comments Applicable None Alicqnment Statement Aligns Alignment Basis A deterministic methodology was used to assess conformance with the Nuclear Safety Performance Criteria (NSPC) from Section 1.5.1 of NFPA 805 for the CNS.
| |
| The CNS NFPA 805 Nuclear Safety Capability Assessment (NSCA) deterministic methodology has been reviewed in detail against the guidance, criteria, and assumptions contained within NEI 00-01, Chapter 3, as documented in the subsequent sections of this table (i.e., Table B-2 from NEI 04-02).
| |
| The results of this review conclude that the CNS NSCA has been performed consistent with (i.e., aligns with) the deterministic methodology guidance, criteria, and Page B-2
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection assumptions from Chapter 3 of NEI 00-01 except as noted within this document.
| |
| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 Page B-3
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1 Safe Shutdown Systems This section discusses the identification of systems available and necessary to perform the required safe shutdown and Path Development functions. It also provides information on the process for combining these systems into safe shutdown paths. Appendix R Section III.G.1 .a requires that the capability to achieve and maintain hot shutdown be free of fire damage. It is expected that the term "free of fire damage" will be further clarified in a forthcoming Regulatory Issue Summary. Appendix R Section Ill.G.1 .b requires that repairs to systems and equipment necessary to achieve and maintain cold shutdown be completed within 72 hours. It is the intent of the NRC that requirements related to the use of manual operator actions will be addressed in a forthcoming rulemaking.
| |
| The goal of post-fire safe shutdown is to assure that a one train of shutdown systems, structures, and components remains free of fire damage for a single fire in any single plant fire area. This goal is accomplished by determining those functions important to achieve and maintain hot shutdown. Safe shutdown systems are selected so that the capability to perform these required functions is a part of each safe shutdown path. The functions important to post-fire safe shutdown generally include, but are not limited to the following:
| |
| - Reactivity Control
| |
| - Pressure Control Systems
| |
| - Inventory Control Systems
| |
| - Decay Heat Removal Systems
| |
| - Process Monitoring
| |
| - Support Systems
| |
| * Electrical systems
| |
| * Cooling systems These functions are of importance because they have a direct bearing on the safe shutdown goal of being able to achieve and maintain hot shutdown which ensures the integrity of the fuel, the reactor pressure vessel, and the primary containment. If these functions are preserved, then the plant will be safe because the fuel, the reactor and the primary containment will not be damaged. By assuring that this equipment is not damaged and remains functional, the protection of the health and safety of the public is assured.
| |
| In addition to the above listed functions, Generic Letter 81-12 specifies consideration of associated circuits with the potential for spurious equipment operation and/or loss of power source, and the common enclosure failures. Spurious operations/actuations can affect the accomplishment of the post-fire safe shutdown functions listed above. Typical examples of the effects of the spurious operations of concern are the following:
| |
| - A loss of reactor pressure vessel/reactor coolant inventory in excess of the safe shutdown makeup capability Page B-4
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection
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| - A flow loss or blockage in the inventory makeup or decay heat removal systems being used for the required safe shutdown path.
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| Spurious operations are of concern because they have the potential to directly affect the ability to achieve and maintain hot shutdown, which could affect the fuel and cause damage to the reactor pressure vessel or the primary containment.
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| Common power source and common enclosure concerns could also affect these and must be addressed.
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| Aoolicabilitv Comments Applicable None Alignment Statement Aligns Alignment Basis CNS systems / functions components required to achieve and maintain "safe and stable" plant conditions post-fire per the Nuclear Safety Performance Criteria of NFPA 805 are identified in CNS Calculation NEDC 11-019, Section 9.0, Nuclear Safety Capability Assessment Analysis Model Development.
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| NFPA 805 allows more flexibility than the previous deterministic programs based on 10 CFR 50 Appendix R (and NEI 00-01, Chapter 3) since NFPA 805 only requires the licensee to maintain the fuel in a safe and stable condition. NFPA 805, Section 1.6.56 defines safe and stable condition. For CNS to be in a safe and stable condition, it will not be necessary to perform a transition to cold shutdown as currently required under 10 CFR 50, Appendix R.
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| The identification and analysis of these systems / functions / components includes addressing associated circuit issues for spurious operations, high/low pressure interfaces, common power supplies, and common enclosures.
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| A computer database tool, EDISON/SAFE, is utilized to demonstrate that the Nuclear Safety Performance Criteria of NFPA 805 are met for each fire area of the plant.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 7.5, 9.0, 10.0 and 11.0)
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| Page B-5
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.1 Criteria/Assumptions The following criteria and assumptions may be considered when identifying systems available and necessary to perform the required safe shutdown functions and combining these systems into safe shutdown paths.
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| Applicability Comments Not Applicable None Alignment Statement Not Applicable Alignment Basis Introductory Section. Refer to following sub-sections for detailed guidance and bases.
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| Reference Documents None Page B-6
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.1.1 Criteria/Assumptions [BWR] GE Report GE-NE-T43-00002-00-01-RO1 entitled "Original Safe Shutdown Paths For The BWR" addresses the systems and equipment originally designed into the GE boiling water reactors (BWRs) in the 1960s and 1970s, that can be used to achieve and maintain safe shutdown per Section III.G.1 of 10CFR 50, Appendix R. Any of the shutdown paths (methods) described in this report are considered to be acceptable methods for achieving redundant safe shutdown.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 9.0, Nuclear Safety Capability Assessment Analysis Model Development, identifies the performance criteria, systems, equipment and logic development in order to achieve a safe and stable condition. Calculation NEDC 11-019, Section 12.0 describes the analysis results with the individual fire area assessments contained within Appendix F of Calculation NEDC 11-019. The shutdown paths and methods described in these sections of this calculation along with those depicted in the analysis model contained in EDISON/SAFE are consistent with the information provided in the referenced GE Report.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 9.0, 12.0 and Appendix F)
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| Page B-7
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.1.2 Criteria/Assumptions [BWR] GE Report GE-NE-T43-00002-00-03-RO1 provides a discussion on the BWR Owners' Group (BWROG) position regarding the use of Safety Relief Valves (SRVs) and low pressure systems (LPCI/CS) for safe shutdown. The BWROG position is that the use of SRVs and low pressure systems is an acceptable methodology for achieving redundant safe shutdown in accordance with the requirements of 10CFR50 Appendix R Sections II.G.1 and II.G.2. The NRC has accepted the BWROG position and issued an SER dated Dec. 12, 2000.
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| Applicability Comments Applicable None Aliqnment Statement Aligns Alignment Basis ADS is used to reduce plant pressure for the use of the low pressure CS system to achieve a safe and stable condition. Calculation NEDC 11-019 details the CS, LPCI and ADS systems. The safety relief valves within ADS are credited to rapidly depressurize the reactor to allow for the use of the low pressure systems in lieu of the high pressure systems for reactor makeup. LPCI is modeled within the analysis but is not the preferred method of low pressure makeup.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 9.1.2, 9.4.2.3, 9.4.2.4 and 9.4.2.7)
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| Page B-8
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.1.3 Criteria/Assumptions [PWR] Generic Letter 86-10, Enclosure 2, Section 5.3.5 specifies that hot shutdown can be maintained without the use of pressurizer heaters (i.e., pressure control is provided by controlling the makeup/charging pumps). Hot shutdown conditions can be maintained via natural circulation of the RCS through the steam generators. The cool down rate must be controlled to prevent the formation of a bubble in the reactor head. Therefore, feedwater (either auxiliary or emergency) flow rates as well as steam release must be controlled.
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| Apolicability Comments Not Applicable None Aliqnment Statement Not Applicable Alignment Basis CNS is a BWR.
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| Reference Documents None Page B-9
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| Nebraska Public Power District NtCNS NPA 805 Transition Renort - Attachment R Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.1.4 Criteria/Assumptions The classification of shutdown capability as alternative shutdown is made independent of the selection of systems used for shutdown. Alternative shutdown capability is determined based on an inability to assure the availability of a redundant safe shutdown path. Compliance to the separation requirements of Sections III.G.1 and III.G.2 may be supplemented by the use of manual actions to the extent allowed by the regulations and the licensing basis of the plant, repairs (cold shutdown only), exemptions, deviations, GL 86-10 fire hazards analyses or fire protection design change evaluations, as appropriate. These may also be used in conjunction with alternative shutdown capability.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Alternate shutdown capability is provided at CNS as a redundant path exterior to the Main Control Room. Alternative shutdown capability is comprised of 3 control panels in the Alternate Shutdown Room. These control panels provide isolation, control and indication for ADS, HPCI, RHR and REC. CNS Operations Emergency Procedure 5.4FIRE-S/D, "Fire Induced Shutdown From Outside the Control Room," governs the use of the Alternate Shutdown Panels.
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| Unlike 10 CFR 50 Appendix R, NFPA 805 makes no distinction for alternate and dedicated shutdown. Alternate Shutdown Panels are the primary control stations for implementation of the 10 CFR 50 Appendix R alternate shutdown strategy in the event of a fire that requires the evacuation of the Main Control Room. Based on the definition provided in RG 1.205, and the additional guidance provided in FAQ 07-0030 Revision 5 (ML110070485), Alternate Shutdown Panels are also considered to be the Primary Control Station for NFPA 805.
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| The use of Alternate Shutdown Panels have been transitioned to NFPA 805 as the Primary Control Stations for meeting the NSPC in the event of a fire that requires evacuation of the Main Control Room.
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| Reference Documents CNS Operations Emergency Procedure 5.4 FIRE-S/D, "Fire Induced Shutdown From Outside the Control Room," Revision 44 Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 Page B-10
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| Nebraska Public Power District NFPA 805 Transition ReDort.NS - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.1.5 Criteria/Assumptions At the onset of the postulated fire, all safe shutdown systems (including applicable redundant trains) are assumed operable and available for post-fire safe shutdown. Systems are assumed to be operational with no repairs, maintenance, testing, Limiting Conditions for Operation, etc. in progress. The units are assumed to be operating at full power under normal conditions and normal lineups.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 5.1, NSCA Criteria / Assumptions for NEI 00-01, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria / assumption listed in Section 3.1.1.5 of NEI 00-01 is explicitly stated in Section 5.1.1 of Calculation NEDC 11-019.
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| All systems credited to achieve a safe and stable condition are assumed to be operational at the onset of a postulated fire with the unit operating at full power.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 5.1.1)
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| Page B-11
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| Nebraska Public Power District NFPA 805 Transition Reort - Attac.hment B NebrtCNS Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.1.6 Criteria/Assumptions No Final Safety Analysis Report accidents or other design basis events (e.g. loss of coolant accident, earthquake), single failures or non-fire induced transients need be considered in conjunction with the fire.
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| ApDlicability Comments Applicable None Alignment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 5.1, NSCA Criteria / Assumptions for NEI 00-01, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria / assumption listed in Section 3.1.1.6 of NEI 00-01 is explicitly stated in Section 5.1.1 of Calculation NEDC 11-019.
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| No additional design basis accidents need to be considered in conjunction with the postulated fire analysis.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 5.1.1)
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| Page B-12
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| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.1.7 Criteria/Assumptions For the case of redundant shutdown, offsite power may be credited if demonstrated to be free of fire damage. Offsite power should be assumed to remain available for those cases where its availability may adversely impact safety (i.e.,
| |
| reliance cannot be placed on fire causing a loss of offsite power if the consequences of offsite power availability are more severe than its presumed loss). No credit should be taken for a fire causing a loss of offsite power. For areas where train separation cannot be achieved and alternative shutdown capability is necessary, shutdown must be demonstrated both where offsite power is available and where offsite power is not available for 72 hours.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 5.1, NSCA Criteria / Assumptions for NEI 00-01, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria / assumption listed in Section 3.1.1.7 of NEI 00-01 is explicitly stated in Section 5.1.1 of Calculation NEDC 11-019.
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| Offsite power can be used as a source of power for the NSCA, if desired. All equipment required to support the portion of offsite power relied upon to achieve the NSPC has been included in the NSCA model.
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| The electrical distribution systems in the CNS NSCA, inclusive of offsite power capability, is addressed in Section 9.1 of this calculation and is intertwined at the component level and not modeled as a stand-alone system.
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| Per Section 1.3.1 of NFPA 805, given a fire, a plant is not required to transition to cold shutdown within 72 hours but instead provides reasonable assurance to achieve and maintain the fuel in a safe and stable condition. For CNS, the required end state of "safe and stable" under NFPA 805 will be met when the plant is in a stable hot shutdown configuration.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 5.1.1 and 5.2.1)
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| Page B-13
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.1.8 Criteria/Assumptions Post-fire safe shutdown systems and components are not required to be safety-related.
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| Apolicability Comments Applicable None Aliqnment Statement Aligns Alignment Basis Both safety-related and non-safety related equipment are credited to achieve a safe and stable condition. Calculation NEDC 11-019 does not restrict the use of only safety-related systems and components to achieve the nuclear safety performance criteria.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0- (Section 5.1.1)
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| Page B-14
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| Nebraska Public Power District CNS NFPA 805 Transition ReDort - Attach ent B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.1.9 Criteria/Assumptions The post-fire safe shutdown analysis assumes a 72-hour coping period starting with a reactor scram/trip. Fire-induced impacts that provide no adverse consequences to hot shutdown within this 72-hour period need not be included in the post-fire safe shutdown analysis. At least one train can be repaired or made operable within 72 hours using onsite capability to achieve cold shutdown.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Per Section 1.3.1 of NFPA 805, given a fire, a plant is not required to transition to cold shutdown within 72 hours, but instead provides reasonable assurance to achieve and maintain the fuel in a safe and stable condition. For CNS, the required end state of "safe and stable" under NFPA 805 will be met when the plant is in a stable hot shutdown configuration.
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| The nuclear safety goals, objectives and performance criteria of NFPA 805, as discussed above, allow more flexibility than the previous deterministic programs based on 10 CFR 50 Appendix R (and NEI 00-01, Chapter 3) since NFPA 805 only requires the licensee to maintain the fuel in a safe and stable condition rather than achieve and maintain cold shutdown.
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| NFPA 805, Section 1.6.56, defines Safe and Stable Conditions as follows:
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| "For fuel in the reactor vessel, head on and tensioned, safe and stable conditions are defined as the ability to maintain K<0.99, with a reactor coolant temperature at or below the requirements for hot shutdown for a boiling water reactor and hot standby for a pressurized water reactor. For all other configurations, safe and stable conditions are defined as maintaining K <0.99 and fuel coolant temperature below boiling."
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| The nuclear safety goal of NFPA 805 requires "...reasonable assurance that a fire during any operational mode and plant configuration will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition," without a specific reference to a mission time or event coping duration.
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| For CNS to be in a safe and stable condition, it will not be necessary to perform a transition to cold shutdown as currently required under 10 CFR 50, Appendix R.
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| Therefore, the unit will remain at or below the temperature defined by a hot shutdown plant operating state for the event.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 7.5)
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| Page B-15
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.1.10 Criteria/Assumptions Manual initiation from the main control room or emergency control stations of systems required to achieve and maintain safe shutdown is acceptable where permitted by current regulations or approved by NRC; automatic initiation of systems selected for safe shutdown is not required but may be included as an option.
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| ADDlicability Comments Applicable None Alignment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 5.1, NSCA Criteria / Assumptions for NEI 00-01, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criterion / assumption listed in Section 3.1.1.10 of NEI 00-01 is explicitly stated in Section 5.1.1 of Calculation NEDC 11-019.
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| The CNS NSCA credits Main Control Room operator actions to align NSCA systems / functions / components. The CNS NSCA does not credit automatic initiation of NSCA systems / functions / components unless specifically modeled and analyzed.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 5.1.1)
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| Page B-16
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.1.11 Criteria/Assumptions Where a single fire can impact more than one unit of a multi-unit plant, the ability to achieve and maintain safe shutdown for each affected unit must be demonstrated.
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| Applicability Comments Not Applicable None Alignment Statement Not Applicable Alicqnment Basis CNS is a single unit facility.
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| Reference Documents None Page B-17
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.2 Shutdown Functions The following discussion on each of these shutdown functions provides guidance for selecting the systems and equipment required for safe shutdown. For additional information on BWR system selection, refer to GE Report GENE-T43-00002 01-ROl entitled "Original Safe Shutdown Paths for the BWR."
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| Applicability Comments Not Applicable None Alignment Statement Not Applicable Alignment Basis Introductory Section. Refer to following sub-sections for detailed guidance and bases.
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| Reference Documents None Page B-18
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| Nebraska Public Power District CNS NFPA 805 Transition Re.ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.2.1 Reactivity Control [BWR] Control Rod Drive System The safe shutdown performance and design requirements for the reactivity control function can be met without automatic scram/trip capability. Manual scram/reactor trip is credited. The post-fire safe shutdown analysis must only provide the capability to manually scram/trip the reactor.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Reactivity control will be accomplished by insertion of the control rods and will result from an automatic RPS trip or from operator initiation of a manual trip. This action will de-energize the RPS to actuate a reactor scram. The CNS NSCA does not credit automatic initiation of NSCA systems / functions / components unless specifically modeled and analyzed.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 5.1.1 and 9.1.1)
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| Page B-19
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.2.1 Reactivity Control [PWR] Makeup/Charging There must be a method for ensuring that adequate shutdown margin is maintained by ensuring borated water is utilized for RCS makeup/charging.
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| Applicabilitv Comments Not Applicable None Alignment Statement Not Applicable Alignment Basis CNS is a BWR.
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| Reference Documents None Page B-20
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| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.2.2 Pressure Control Systems [BWR] Safety Relief Valves (SRVs)
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| The SRVs are opened to maintain hot shutdown conditions or to depressurize the vessel to allow injection using low pressure systems. These are operated manually. Automatic initiation of the Automatic Depressurization System is not a required function.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Overpressure protection is provided by the SRVs in the self-activated spring lift mode. This mode of operation is not susceptible to fire damage. The SRVs are also actuated by the operator or ADS to reduce plant pressure for the use of low pressure CS system. The ADS system is only credited in manual mode for depressurization. Use of the ADS Inhibit switch blocks spurious ADS auto-initiation signal.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 9.1.2 and 9.4.2.7.3)
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| Page B-21
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.2.2 Pressure Control Systems [PWR] Makeup/Charging RCS pressure is controlled by controlling the rate of charging/makeup to the RCS. Although utilization of the pressurizer heaters and/or auxiliary spray reduces operator burden, neither component is required to provide adequate pressure control. Pressure reductions are made by allowing the RCS to cool/shrink, thus reducing pressurizer level/pressure.
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| Pressure increases are made by initiating charging/makeup to maintain pressurizer level/pressure. Manual control of the related pumps is acceptable.
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| ADDlicability Comments Not Applicable None Alignment Statement Not Applicable Alignment Basis CNS is a BWR.
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| Reference Documents None Page B-22
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| Nebraska Public Power District NebrskaPublc istictCNS Pwer NFPA 805 Transition Renort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.2.3 Inventory Control [BWR] Systems selected for the inventory control function should be capable of supplying sufficient reactor coolant to achieve and maintain hot shutdown. Manual initiation of these systems is acceptable. Automatic initiation functions are not required.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Reactor coolant make-up can be achieved by isolation of the Reactor Coolant System and control of the vessel coolant level by injecting water into the isolated reactor vessel. The RCS pressure boundary is necessary to achieve inventory and pressure control. The required components to limit coolant loss are contained within the analysis. Reactor make-up is provided by the operation of the CS system, the HPCI system or the RCIC system. Note that depressurization is required to reduce plant pressure for the use of the low pressure CS system. Only manual operation of the HPCI, RCIC and CS systems are credited to achieve a safe and stable condition.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 9.1.2, 9.4.2.1.1, 9.4.2.2.1 and 9.4.2.3.1)
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| Page B-23
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.2.3 Inventory Control [PWR] Systems selected for the inventory control function should be capable of maintaining level to achieve and maintain hot shutdown. Typically, the same components providing inventory control are capable of providing pressure control.
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| Manual initiation of these systems is acceptable. Automatic initiation functions are not required.
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| Applicability Comments Not Applicable None Aliqnment Statement Not Applicable Alignment Basis CNS is a BWR.
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| Reference Documents None Page B-24
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.2.4 Decay Heat Removal [BWR] Systems selected for the decay heat removal function(s) should be capable of:
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| - Removing sufficient decay heat from primary containment, to prevent containment over-pressurization and failure.
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| - Satisfying the net positive suction head requirements of any safe shutdown systems taking suction from the containment (suppression pool).
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| - Removing sufficient decay heat from the reactor to achieve cold shutdown.
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| This does not restrict the use of other systems.
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| Applicability Comments Applicable None Alicqnment Statement Aligns Alignment Basis Decay Heat is removed initially by natural circulation within the reactor pressure vessel and automatic mechanical operation of the SRVs. The SRVs discharge steam from the reactor vessel to the suppression pool. The emerging steam is condensed in this pool, and the heat absorbed by the suppression pool is removed by the RHR System operating in the Suppression Pool Cooling (SPC) mode and ultimately transferred to the river via the Service Water (SW) System. The required system logics for suppression pool cooling include satisfying net positive suction head requirements.
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| As pointed out in Section 1.3.1 of NFPA 805, given a fire, a plant is not required to transition to cold shutdown within 72 hours, but instead provide reasonable assurance to achieve and maintain the fuel in a safe and stable condition. For CNS, the required end state of "safe and stable" under NFPA 805 will be met when the plant is in a stable hot shutdown configuration.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 9.1.3)
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| Page B-25
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| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.2.4 Decay Heat Removal [PWR] Systems selected for the decay heat removal function(s)) should be capable of:
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| - Removing sufficient decay heat from the reactor to reach hot shutdown conditions. Typically, this entails utilizing natural circulation in lieu of forced circulation via the reactor coolant pumps and controlling steam release via the Atmospheric Dump valves.
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| - Removing sufficient decay heat from the reactor to reach cold shutdown conditions.
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| This does not restrict the use of other systems.
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| Aiplicability Comments Not Applicable None Alignment Statement Not Applicable Alignment Basis CNS is a BWR.
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| Reference Documents None Page B-26
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.2.5 Process Monitoring The process monitoring function is provided for all safe shutdown paths. IN 84-09, Attachment 1, Section IX "Lessons Learned from NRC Inspections of Fire Protection Safe Shutdown Systems (10CFR50 Appendix R)" provides guidance on the instrumentation acceptable to and preferred by the NRC for meeting the process monitoring function. This instrumentation is that which monitors the process variables necessary to perform and control the functions specified in Appendix R Section III.L.1. Such instrumentation must be demonstrated to remain unaffected by the fire. The IN 84-09 list of process monitoring is applied to alternative shutdown (III.G.3). IN 84-09 did not identify specific instruments for process monitoring to be applied to redundant shutdown (III.G.1 and III.G.2). In general, process monitoring instruments similar to those listed below are needed to successfully use existing operating procedures (including Abnormal Operating Procedures).
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| BWR
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| - Reactor coolant level and pressure
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| - Suppression pool level and temperature
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| - Emergency or isolation condenser level
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| - Diagnostic instrumentation for safe shutdown systems
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| - Level indication for tanks needed for safe shutdown PWR
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| - Reactor coolant temperature (hot leg / cold leg)
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| - Pressurizer pressure and level
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| - Neutron flux monitoring (source range)
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| - Level indication for tanks needed for safe shutdown
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| - Steam generator level and pressure
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| - Diagnostic instrumentation for safe shutdown systems The specific instruments required may be based on operator preference, safe shutdown procedural guidance strategy (symptomatic vs. prescriptive), and systems and paths selected for safe shutdown.
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| Applicability Comments Applicable None Alignment Statement Aligns Page B-27
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection Alignment Basis The following instruments are modeled in the Nuclear Boiler Instrumentation (NBI) system, based on existing operating procedures:
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| Reactor coolant level and pressure Suppression chamber temperature and level The indicating ranges of these instruments cover the normal operating bands and will operate throughout the scenario. Other tank levels and diagnostic instrumentation such as flow or system pressures are modeled directly in the logics for the system or component that requires the indication and are not included in this performance goal.
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| Other diagnostic instrumentation contained within the model includes the follow:
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| HPCI Pump Discharge Pressure Indication HPCI Turbine Inlet and Outlet Pressure Indication HPCI Turbine Speed Indication ECST Level Indication RCIC Turbine Speed Indication CS Pump A and B Discharge Flow Indication RHR System Loop A and B Flow Indication When shutting down from outside the Main Control Room, the following instruments are available at the Primary Control Station in the Alternate Shutdown Room:
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| RPV Level Reactor Pressure (at HPCI Turbine Steam Inlet)
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| Suppression Chamber Temperature and Level ECST Level Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 9.1.5)
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| Page B-28
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.2.6.1 Electrical Systems AC Distribution System Power for the Appendix R safe shutdown equipment is typically provided by a medium voltage system such as 4.16 KV Class 1E busses either directly from the busses or through step down transformers/load centers/distribution panels for 600, 480 or 120 VAC loads. For redundant safe shutdown performed in accordance with the requirements of Appendix R Section III.G.1 and 2, power may be supplied from either offsite power sources or the emergency diesel generator depending on which has been demonstrated to be free of fire damage. No credit should be taken for a fire causing a loss of offsite power. Refer to Section 3.1.1.7.
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| DC Distribution System Typically, the 125VDC distribution system supplies DC control power to various 125VDC control panels including switchgear breaker controls. The 125VDC distribution panels may also supply power to the 120VAC distribution panels via static inverters. These distribution panels typically supply power for instrumentation necessary to complete the process monitoring functions. For fire events that result in an interruption of power to the AC electrical bus, the station batteries are necessary to supply any required control power during the interim time period required for the diesel generators to become operational. Once the diesels are operational, the 125 VDC distribution system can be powered from the diesels through the battery chargers.
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| [BWR] Certain plants are also designed with a 250VDC Distribution System that supplies power to Reactor Core Isolation Cooling and/or High Pressure Coolant Injection equipment.
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| The DC control centers may also supply power to various small horsepower Appendix R safe shutdown system valves and pumps. If the DC system is relied upon to support safe shutdown without battery chargers being available, it must be verified that sufficient battery capacity exists to support the necessary loads for sufficient time (either until power is restored, or the loads are no longer required to operate).
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| Apolicability Comments Applicable None Alignment Statement Aligns Aliqnment Basis The power distribution system is contained within the NSCA model as equipment-to-equipment logics. 4.16 KV power is provided from offsite sources or diesel generators. This power is stepped down through transformers for the necessary VAC levels. 250V and 125V DC power is provided with batteries that are supported with battery chargers.
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| Page B-29
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Appendix C)
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| Page B-30
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| Nebraska Public Power District CNS NFPA 805 Transition Reoort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.2.6.2 Cooling Systems Various cooling water systems may be required to support safe shutdown system operation, based on plant-specific considerations. Typical uses include:
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| - RHR/SDC/DH Heat Exchanger cooling water
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| - Safe shutdown pump cooling (seal coolers, oil coolers)
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| - Diesel generator cooling
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| - HVAC system cooling water.
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| HVAC Systems may be required to assure that safe shutdown equipment remains within its operating temperature range, as specified in manufacturer's literature or demonstrated by suitable test methods, and to assure protection for plant operations staff from the effects of fire (smoke, heat, toxic gases, and gaseous fire suppression agents).
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| HVAC systems may be required to support safe shutdown system operation, based on plant-specific configurations.
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| Typical uses include:
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| - Main control room, cable spreading room, relay room
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| - ECCS pump compartments
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| - Diesel generator rooms
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| - Switchgear rooms Plant-specific evaluations are necessary to determine which HVAC systems are essential to safe shutdown equipment operation.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Various plant systems are required to support the systems and components selected to accomplish the previously defined safety functions.
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| The following are modeled as Systems in the SUPPORT Performance Goal:
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| Reactor Equipment Cooling (REC): This system supplies cooling to critical heat exchangers and coolers. Ifboth pumps are inoperable, emergency operation is Page B-31
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| Nebraska Public Power District CNS NFPA 805 Transition Reoort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection possible by cross-connecting to the Service Water system. This allows modeling Train A and Train B of both the normal and the emergency lineup as four different systems and at least one of the four are required to survive.
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| Service Water: This system cools the diesel generator coolers and the REC and RHR heat exchangers. EDISON/SAFE models Train A and Train B as two systems, and requires the same-train Service Water to cool the REC and RHR systems. Both diesel coolers can be supplied from either Train A and Train B Service Water. Components of the Service Water system that are specific to individual cooling loads are modeled as support components for the cooled system.
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| Other critical support functions are modeled in as equipment logics:
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| HVAC Systems. HVAC cooling is required and modeled for the battery rooms, diesel generators, critical switchgear rooms, Core Spray Pump Rooms (including the RCIC turbine) and the HPCI Room. Plant evaluations have confirmed that other areas of the plant do not require HVAC cooling in order to protect credited equipment from overheating or to ensure habitability.
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| Diesel Generator Support Auxiliaries. Provides direct support in equipment logics for the corresponding Diesel Generator. This includes cooling water valves, ventilation, starting air, fuel oil transfer pumps and jacket water pumps.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 9.1.4, 9.4.4.5 and 9.4.4.6)
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| Page B-32
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.3 Methodology for Refer to hardcopy of NEI 00-01 Rev 1 Figure 3-2 for a flowchart illustrating the various steps involved in selecting safe Shutdown System shutdown systems and developing the shutdown paths.
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| Selection The following methodology may be used to define the safe shutdown systems and paths for an Appendix R analysis:
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| Applicability Comments Not Applicable None Alignment Statement Not Applicable Alignment Basis Introductory section. Refer to following subsection detailed guidance and bases.
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| Reference Documents None Page B-33
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.3.1 Identify Safe Shutdown Review available documentation to obtain an understanding of the available plant systems and the functions required to Functions achieve and maintain safe shutdown. Documents such as the following may be reviewed:
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| - Operating Procedures (Normal, Emergency, Abnormal)
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| - System descriptions
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| - Fire Hazard Analysis
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| - Single-line electrical diagrams
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| - Piping and Instrumentation Diagrams (P&IDs)
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| - [BWR] GE Report GE-NE-T43-00002-00-01 -R02 entitled "Original Shutdown Paths for the BWR" Aoolicabilitv Comments Applicable None Alignment Statement Aligns Alignment Basis The necessary documentation was reviewed in support of the development of the NSCA model to achieve and maintain a safe and stable condition.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 6.0)
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| Page B-34
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.3.2 Identify Combinations of Given the criteria/assumptions defined in Section 3.1.1, identify the available combinations of systems capable of Systems That Satisfy achieving the safe shutdown functions of reactivity control, pressure control, inventory control, decay heat removal, Each Safe Shutdown process monitoring and support systems such as electrical and cooling systems (refer to Section 3.1.2). This selection Function process does not restrict the use of other systems. In addition to achieving the required safe shutdown functions, consider spurious operations and power supply issues that could impact the required safe shutdown function.
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| Applicability Comments Applicable None Aliqnment Statement Aligns Aliqnment Basis The method to achieve a safe and stable condition and system path relationships used to analyze post-fire safe shutdown are maintained in EDISON/SAFE as described in Calculation NEDC 11-019, Section 11.0. Each safe shutdown function (methods) and credited system is included in logic diagrams. The supporting systems are illustrated as logical paths necessary to satisfy each function through AND/OR statements.
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| Components whose spurious operation could adversely affect safe shutdown functions are included in the system level logics as applicable. Associated Circuits by Common Power Supply have been addressed as described in Calculation NEDC 11-019, Section 10.3 as applicable. There are no coordination issues that required the inclusion of circuits to the analysis model.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 10.3 and 11.0)
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| Page B-35
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.3.3 Define Combination of Select combinations of systems with the capability of performing all of the required safe shutdown functions and designate Systems for Each Safe this set of systems as a safe shutdown path. In many cases, paths may be defined on a divisional basis since the Shutdown Path availability of electrical power and other support systems must be demonstrated for each path. During the equipment selection phase, identify any additional support systems and list them for the appropriate path.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Different combinations of systems that successfully achieve the nuclear safety functions criteria are illustrated on logic diagrams. The NSCA Model relationships are maintained in the EDISON/SAFE database as described in Calculation NEDC 11-019, Section 11.0.
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| Additional supplementary information is provided for each of the credited systems in Section 9.1 of Calculation NEDC 11-019.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 9.1 and 11.0)
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| Page B-36
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| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.1.3.4 Assign Shutdown Paths Assign a path designation to each combination of systems. The path will serve to document the combination of systems to Each Combination of relied upon for safe shutdown in each fire area. Refer to Attachment 1 to this document for an example of a table Systems illustrating how to document the various combinations of systems for selected shutdown paths.
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| ApDlicability Comments Applicable None Alicqnment Statement Aligns Aliqnment Basis Path designations are assigned to each specific system using Train A or B designation where applicable. Each path is a specific combination of systems and components supporting the success of a method, as illustrated in logic diagrams. The analysis of each fire area ensures that at least one success path exists for each fire area.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Appendix F)
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| Page B-37
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| Nebraska Public Power District NetCNS NFPA 805 Transition Reort - Atta.ent R Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.2 Safe Shutdown The previous section described the methodology for selecting the systems and paths necessary to achieve and maintain Equipment Selection safe shutdown for an exposure fire event (see Section 5.0 DEFINITIONS for "Exposure Fire"). This section describes the criteria/assumptions and selection methodology for identifying the specific safe shutdown equipment necessary for the systems to perform their Appendix R function. The selected equipment should be related back to the safe shutdown systems that they support and be assigned to the same safe shutdown path as that system. The list of safe shutdown equipment will then form the basis for identifying the cables necessary for the operation or that can cause the maloperation of the safe shutdown systems.
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| ADplicability Comments Applicable None Aliqnment Statement Aligns Alignment Basis All selected equipment in support of a system required to achieve a safe and stable condition is appropriately designated as such in Appendix A of Calculation NEDC 11-019. The equipment list relates back to the systems. The specific equipment that support each system path are documented within Calculation NEDC 11-019, Tables 9.4.2-1 through 9.4.4-8 and are illustrated in the logic diagrams within Appendix E of Calculation NEDC 11-019.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Appendix A, Appendix E and Tables 9.4.2-1 through 9.4.4-8)
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| Page B-38
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| Nebraska Public Power District CNS NFPA 805 Transition ReDort - Attach ent B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.2.1 Criteria/Assumptions Consider the following criteria and assumptions when identifying equipment necessary to perform the required safe shutdown functions:
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| Applicability Comments Not Applicable None Alignment Statement Not Applicable Alignment Basis Introductory Section. Refer to following sub-sections for detailed guidance and bases.
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| Reference Documents None Page B-39
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.2.1.1 Criteria/Assumptions Safe shutdown equipment can be divided into two categories. Equipment may be categorized as (1) primary components or (2) secondary components. Typically, the following types of equipment are considered to be primary components:
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| - Pumps, motor operated valves, solenoid valves, fans, gas bottles, dampers, unit coolers, etc.
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| - All necessary process indicators and recorders (i.e., flow indicator, temperature indicator, turbine speed indicator, pressure indicator, level recorder)
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| - Power supplies or other electrical components that support operation of primary components (i.e., diesel generators, switchgear, motor control centers, load centers, power supplies, distribution panels, etc.).
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| Secondary components are typically items found within the circuitry for a primary component. These provide a supporting role to the overall circuit function. Some secondary components may provide an isolation function or a signal to a primary component via either an interlock or input signal processor. Examples of secondary components include flow switches, pressure switches, temperature switches, level switches, temperature elements, speed elements, transmitters, converters, controllers, transducers, signal conditioners, hand switches, relays, fuses and various instrumentation devices.
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| Determine which equipment should be included on the Safe Shutdown Equipment List (SSEL). As an option, include secondary components with a primary component(s) that would be affected by fire damage to the secondary component.
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| By doing this, the SSEL can be kept to a manageable size and the equipment included on the SSEL can be readily related to required post-fire safe shutdown systems and functions.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Appendix A of Calculation NEDC 11-019 contains the required equipment list. While the list does not specifically list equipment with primary or secondary designations, it does list the equipment as to what system it is a part of. The equipment list combined with the system and equipment logics implicitly show primary and secondary relationships and designations.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Appendix A)
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| Page B-40
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| Nebraska Public Power District CNS NFPA 805 Transition ReDort - Attach ent B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.2.1.2 Criteria/Assumptions Assume that exposure fire damage to manual valves and piping does not adversely impact their ability to perform their pressure boundary or safe shutdown function (heat sensitive piping materials, including tubing with brazed or soldered joints, are not included in this assumption). Fire damage should be evaluated with respect to the ability to manually open or close the valve should this be necessary as a part of the post-fire safe shutdown scenario.
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| Applicability Comments Applicable None Alignment Statement Aligns Aliqnment Basis Calculation NEDC 11-019, Section 5.1, NSCA Criteria / Assumptions for NEI 00-01, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criterion / assumption listed in Section 3.2.1.2 of NEI 00-01 is explicitly stated in Section 5.1.2 of Calculation NEDC 11-019.
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| Fire damage is evaluated with respect to the ability to manually open or close the valve should it be necessary to do so as a part of the post-fire safe shutdown scenario.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 5.1.2 & 5.2.3)
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| Page B-41
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| Nebraska
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| .NS Public Power District NFPA 805 Transition Renort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.2.1.3 Criteria/Assumptions Assume that manual valves are in their normal position as shown on P&IDs or in the plant operating procedures.
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| ADDlicability Comments Applicable None Alignment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 5.1, NSCA Criteria / Assumptions for NEI 00-01, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criterion / assumption listed in Section 3.2.1.3 of NEI 00-01 is explicitly stated in Section 5.1.2 of Calculation NEDC 11-019.
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| Manual valves are assumed to be in their normal operating position for the analysis.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 5.1.2)
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| Page B-42
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.2.1.4 Criteria/Assumptions Assume that a check valve closes in the direction of potential flow diversion and seats properly with sufficient leak tightness to prevent flow diversion. Therefore, check valves do not adversely affect the flow rate capability of the safe shutdown systems being used for inventory control, decay heat removal, equipment cooling or other related safe shutdown functions.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 5.1, NSCA Criteria / Assumptions for NEI 00-01, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criterion / assumption listed in Section 3.2.1.4 of NEI 00-01 is explicitly stated in Section 5.1.2 of Calculation NEDC 11-019.
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| Check valves are assumed to operate properly for the analysis.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 5.1.2)
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| Page B-43
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.2.1.5 Criteria/Assumptions Instruments (e.g., resistance temperature detectors, thermocouples, pressure transmitters, and flow transmitters) are assumed to fail upscale, midscale, or downscale as a result of fire damage, whichever is worse. An instrument performing a control function is assumed to provide an undesired signal to the control circuit.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 5.1, NSCA Criteria / Assumptions for NEI 00-01, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criterion / assumption listed in Section 3.2.1.5 of NEI 00-01 is explicitly stated in Section 5.1.2 of Calculation NEDC 11-019.
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| Instruments are assumed to fail upscale, midscale, or downscale as a result of fire damage, whichever is worse. An instrument performing a control function is assumed to provide an undesired signal to the control circuit.
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| In addition, the analysis includes instruments which provide permissive or controlling signals to safe shutdown components, or which can cause spurious operation. These instruments are modeled in direct support of the affected component using equipment logics, cable logics, or a combination of both.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 5.1.2 and 9.1.5)
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| Page B-44
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.2.1.6 Criteria/Assumptions Identify equipment that could spuriously operate or mal-operate and impact the performance of equipment on a required safe shutdown path during the equipment selection phase. Consider Bin 1 of RIS 2004-03 during the equipment identification process.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Support components were identified where credit was taken for proper control and/or operation of other main or support components (e.g., solenoid valve supporting air-operated valve). In addition, components that could cause spurious actuation of another component, loss of control of another component, or another component adopting an unwanted position/status were analyzed for cable selection (e.g., transmitter supporting process control loop or relay supporting control circuit). Spurious components were divided into the following two categories:
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| a) Components that could cause spurious operations when energized or de-energized; and b) Components that could transmit spurious signals.
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| The components of Category a) were analyzed for cable selection based on receipt of an unwanted signal resulting in spurious operation of the main component to an undesirable position. The components of Category b) were considered "permissive" and analyzed accordingly. For the purpose of spurious signal analysis, the selected cables included all cables that could transmit a spurious signal as a result of a fire-induced cable failure. This included conductors that could operate a relay having a contact(s) in the control circuit being analyzed.
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| RIS 2004-03, Bin 1 circuit configurations (i.e., those most likely to fail under fire scenarios) were considered. This included conductor-to-conductor shorts within a multi-conductor cable, and cable-to-cable interactions. The analysis did not limit the number of cables that may be damaged by fire.
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| During the NFPA 805 transition, NPPD performed a series of MSO Expert Panel systems reviews. Results were fed back into the NSCA and Fire PRA, as necessary. The treatment of MSOs is provided in the applicable section of the LAR Transition Report.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 10.2.1.2)
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| Page B-45
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| Nebraska Public Power District NebrskaPublc istictCNS Pwer NFPA 805 Transition Re ort - Attac'hment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.2.1.7 Criteria/Assumptions Identify instrument tubing that may cause subsequent effects on instrument readings or signals as a result of fire.
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| Determine and consider the fire area location of the instrument tubing when evaluating the effects of fire damage to circuits and equipment in the fire area.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis As part of the NFPA 805 Transition, the impact of fire on instrument tubing sensing lines was evaluated considering the fire area location of the instrument sensing lines. The sensing lines for the applicable process monitoring instruments are included in the NSCA model, and evaluated similar to a cable, such that the instrument is assumed to fail in areas containing its associated tubing unless an evaluation notes otherwise. The sensing lines for applicable process monitoring instruments are welded steel therefore the pressure boundary will not be breached as a result of fire damage. For instruments that are credited as active or for instruments whose failure could be detrimental, the fire zone location of the instrument, together with the fire zone(s) where the instrument's sensing line is located, ifdifferent than that of the instrument, are associated in EDISON/SAFE with the instrument. In this manner, a fire would fail the instrument in the fire zone containing the instrument and in any fire zone containing the sensing line.
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| The effects of exposure fire damage on instrumentation tubing is not an issue as original construction requirements only allowed socket weld, butt weld, or screwed joints. CNS does not use brazed or soldered joints. Copper tubing may be used in limited pneumatic applications however it is not used in instrument lines.
| |
| Reference Documents Contract E70-3, "Piping Tubing and Fittings for IC," Revision 2 GE Specification 22A1427AE, "Process Instrument Piping and Tubing," Revision 1 Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 9.5)
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| Page B-46
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.2.2 Methodology for Refer to NEI 00-01 Rev 1 Figure 3-3 for a flowchart illustrating the various steps involved in selecting safe shutdown Equipment Selection equipment.
| |
| Use the following methodology to select the safe shutdown equipment for a post-fire safe shutdown analysis:
| |
| [Refer to hardcopy of NEI 00-01 for Figure]
| |
| ApDlicability Comments Not Applicable None Alignment Statement Not Applicable Aliqnment Basis Introductory section. Refer to following subsection detailed guidance and bases.
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| Reference Documents None Page B-47
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.2.2.1 Identify the System Flow Mark up and annotate a P&ID to highlight the specific flow paths for each system in support of each shutdown path. Refer Path for Each Shutdown to Attachment 2 for an example of an annotated P&ID illustrating this concept.
| |
| Path
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| [Refer to hardcopy of NEI 00-01 for Attachment 2]
| |
| Applicabilite Comments Applicable None Alignment Statement Aligns Alignment Basis Marked up and annotated P&ID drawings were primarily used as an aide in reviewing the credited system flow paths during the development of system and equipment logics that reside in the NSCA model and database.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 9.4)
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| Page B-48
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| Nebraska Public Power District CNS NFPA 805 Transition ReDort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.2.2.2 Identify the Equipment in Review the applicable documentation (e.g. P&IDs, electrical drawings, instrument loop diagrams) to assure that all Each Safe Shutdown equipment in each system's flow path has been identified. Assure that any equipment that could spuriously operate and System Flow Path adversely affect the desired system function(s) is also identified. If additional systems are identified which are necessary Including Equipment That for the operation of the safe shutdown system under review, include these as systems required for safe shutdown.
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| May Spuriously Operate Designate these new systems with the same safe shutdown path as the primary safe shutdown system under review and Affect System (Refer to Figure 3-1).
| |
| Operation
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| [Refer to hardcopy of NEI 00-01 for Figure]
| |
| Applicability Comments Applicable None Aliqnment Statement Aligns Aliflnment Basis Nuclear Safety Capability Assessment Analysis Model Development detailed within NEDC 11-019, identifies the overall process utilized to identify the combinations of plant components for each plant system that is identified as being required to satisfy each of the Nuclear Safety Performance Criteria (NSPC) from Section 1.5.1 of NFPA 805.
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| A review of P&IDs, electrical drawings, etc. was performed to identify the NSCA systems, and to identify and develop the NSCA system-to equipment logic relationships (i.e., Boolean logic / success paths) and the NSCA equipment-to-equipment logic success path relationships (i.e., success paths).
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| Mechanical and electrical system components such as pumps, air-operated valves, motor-operated valves, and solenoid-operated valves, fans, heaters, electrically controlled circuit breakers, transformers, switchgear, motor control centers, batteries, battery chargers, inverters, distribution panels, automatic transfer switches, diesel generators and engines, strainers, instrumentation, and dampers, etc., which have an active function in achieving a safe and stable condition are included in the NSCA.
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| Mechanical and electrical system passive components such as pumps, air-operated valves, motor-operated valves, and solenoid-operated valves, fans, heaters, electrically controlled circuit breakers, instrumentation, and dampers, etc., are included in the NSCA if they maintain a system pressure boundary, or if the spurious operation(s) of the passive component(s) has an adverse impact on NSCA capabilities.
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| Control panels and discrete electrical and instrumentation components such as hand switches, relays, starters, fuses, indicating lights, molded case and other non-electrically operated circuit breakers, electrical disconnects, pull boxes, junction boxes, terminal boxes, signal converters, amplifiers, bistables, relay cards, instrument power supplies, etc. (excluding the transmitting devices and indicating devices), are not explicitly identified or included in the NFPA 805 Nuclear Safety Page B-49
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| | |
| Nebraska Public Power District Nebr.ska.Public.CNS NFPA 805 Transition ReDort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection Equipment List, Appendix A of NEDC 11-019. These secondary components or sub-components are represented in the NSCA by virtue of the circuit conductors and cables that interconnect them to the primary component.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 9.0)
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| Page B-50
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| Nebraska Public Power District CNS NFPA 805 Transition ReDort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.2.2.3 Develop a List of Safe Prepare a table listing the equipment identified for each system and the shutdown path that it supports. Identify any valves Shutdown Equipment or other equipment that could spuriously operate and impact the operation of that safe shutdown system. Assign the safe and Assign the shutdown path for the affected system to this equipment. During the cable selection phase, identify additional equipment Corresponding System required to support the safe shutdown function of the path (e.g., electrical distribution system equipment). Include this and Safe Shutdown additional equipment in the safe shutdown equipment list. Attachment 3 to this document provides an example of a Path(s) Designation to (SSEL). The SSEL identifies the list of equipment within the plant considered for safe shutdown and it documents various Each equipment-related attributes used in the analysis.
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| [Refer to hardcopy of NEI 00-01 for Attachment 3]
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis All selected equipment in support of a system required to achieve a safe and stable condition is appropriately designated as such in Appendix A of Calculation NEDC 11-019. The equipment list relates back to the systems. The specific equipment that support each system path are documented within Calculation NEDC 11-019, Tables 9.4.2-1 through 9.4.4-8 and are illustrated in the logic diagrams within Appendix E of Calculation NEDC 11-019.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Appendix A, Appendix E and Tables 9.4.2-1 through 9.4.4-8)
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| Page B-51
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.2.2.4 Identify Equipment Collect additional equipment-related information necessary for performing the post-fire safe shutdown analysis for the Information Required for equipment. In order to facilitate the analysis, tabulate this data for each piece of equipment on the SSEL. Refer to the Safe Shutdown Attachment 3 to this document for an example of a SSEL. Examples of related equipment data should include the Analysis equipment type, equipment description, safe shutdown system, safe shutdown path, drawing reference, fire area, fire zone, and room location of equipment. Other information such as the following may be useful in performing the safe shutdown analysis: normal position, hot shutdown position, cold shutdown position, failed air position, failed electrical position, high/low pressure interface concern, and spurious operation concern.
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| [Refer to hardcopy of NEI 00-01 for Attachment 3]
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis The Nuclear Safety Equipment List identifies the credited equipment for the NSCA. Calculation NEDC 11-019, Appendix A, specifies the data included on the NFPA 805 Nuclear Safety Equipment List for each piece of equipment:
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| - Equipment Designation
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| - Description
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| - Fire Zone
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| - System
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| - Normal Position
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| - Failed Position
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| - HSD Position
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| - Remarks While some of the suggested information to be included on the table has been excluded from the NFPA 805 Nuclear Safety Equipment List, the necessary information is captured in the NSCA database (EDISON/SAFE) in order to successfully perform the post-fire separation analysis.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Appendix A)
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| Page B-52
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| Nebraska Public Power District CNS NFPA 805 Transition ReDort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.2.2.5 Identify Dependencies In the process of defining equipment and cables for safe shutdown, identify additional supporting equipment such as Between Equipment, electrical power and interlocked equipment. As an aid in assessing identified impacts to safe shutdown, consider Supporting Equipment, modeling the dependency between equipment within each safe shutdown path either in a relational database or in the Safe Shutdown Systems form of a Safe Shutdown Logic Diagram (SSLD). Attachment 4 provides an example of a SSLD that may be developed to and Safe Shutdown Paths document these relationships.
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| [Refer to hardcopy of NEI 00-01 for Attachment 4]
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis The NSCA database (EDISON/SAFE) provides the tool to establish relational ties between selected methods, systems, components and cable that are credited to achieve a safe and stable condition.
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| Different combinations of equipment that successfully support the NSCA performance goal paths are illustrated on the logic diagrams in Calculation NEDC 11-019, Appendix E. The various equipment combinations can be achieved by choosing different logical branches that satisfy a particular system path. Support systems may not be included in the system logic diagrams. These relationships may instead be applied at the equipment logic level within the database.
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| Equipment logics are defined in textual format in Section 9.4. Boolean logics associating each Equipment with their supporting cables were developed and logic statements entered into EDISON/SAFE. Equipment credited in support of the NSCA model and equipment logics are tabulated in Appendix C of Calculation NEDC 11-019.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 9.2, Appendix C and Appendix E)
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| Page B-53
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis 2.4.2.2.1 Circuits Required in Nuclear Safety Functions. Circuits required for the nuclear safety functions shall be identified. This includes circuits that are required for operation, that could prevent the operation, or that result in the maloperation of the equipment identified in 2.4.2.1. This evaluation shall consider fire-induced failure modes such as hot shorts (external and internal), open circuits, and shorts to ground, to identify circuits that are required to support the proper operation of components required to achieve the nuclear safety performance criteria, including spurious operation and signals. This will ensure that a comprehensive population of circuitry is evaluated.
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| 2.4.2.2.2 Other Required Circuits. Other circuits that share common power supply and/or common enclosure with circuits required to achieve nuclear safety performance criteria shall be evaluated for their impact on the ability to achieve nuclear safety performance criteria.
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| (a) Common Power Supply Circuits. Those circuits whose fire-induced failure could cause the loss of a power supply required to achieve the nuclear safety performance criteria shall be identified. This situation could occur ifthe upstream protection device (i.e., breaker or fuse) is not properly coordinated with the downstream protection device.
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| (b) Common Enclosure Circuits. Those circuits that share enclosures with circuits required to achieve the nuclear safety performance criteria and whose fire-induced failure could cause the loss of the required components shall be identified. The concern is that the effects of a fire can extend outside of the immediate fire area due to fire-induced electrical faults on inadequately protected cables or via inadequately sealed fire area boundaries.
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| NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.3 Safe Shutdown Cable This section provides industry guidance on the recommended methodology and criteria for selecting safe shutdown Selection and Location cables and determining their potential impact on equipment required for achieving and maintaining safe shutdown of an operating nuclear power plant for the condition of an exposure fire. The Appendix R safe shutdown cable selection criteria are developed to ensure that all cables that could affect the proper operation or that could cause the maloperation of safe shutdown equipment are identified and that these cables are properly related to the safe shutdown equipment whose functionality they could affect. Through this cable-to-equipment relationship, cables become part of the safe shutdown path assigned to the equipment affected by the cable.
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| Applicability Comments Applicable None Aliqnment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 10.0 describes the circuit analysis methodology used to meet the NFPA 805 requirements. Cables that are required to support the NFPA 805 equipment are maintained in the EDISON/SAFE database. The database provides cable data and circuit analysis data for each component and cable credited to achieve a safe and stable condition.
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| Page B-54
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 10.0)
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| Page B-55
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.3.1 Criteria/Assumptions To identify an impact to safe shutdown equipment based on cable routing, the equipment must have cables that affect it identified. Carefully consider how cables are related to safe shutdown equipment so that impacts from these cables can be properly assessed in terms of their ultimate impact on safe shutdown system equipment.
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| Consider the following criteria when selecting cables that impact safe shutdown equipment:
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| Applicability Comments Not Applicable None Alignment Statement Not Applicable Alignment Basis Introductory section. refer to following subsection for detailed guidance and bases.
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| Reference Documents None Page B-56
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.3.1.1 Criteria/Assumptions The list of cables whose failure could impact the operation of a piece of safe shutdown equipment includes more than those cables connected to the equipment. The relationship between cable and affected equipment is based on a review of the electrical or elementary wiring diagrams. To assure that all cables that could affect the operation of the safe shutdown equipment are identified, investigate the power, control, instrumentation, interlock, and equipment status indication cables related to the equipment. Consider reviewing additional schematic diagrams to identify additional cables for interlocked circuits that also need to be considered for their impact on the ability of the equipment to operate as required in support of postfire safe shutdown. As an option, consider applying the screening criteria from Section 3.5 as a part of this section.
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| For an example of this see Section 3.3.1.4.
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| Applicability Comments Applicable None Aligqnment Statement Aligns Aliqnment Basis The circuit analysis methodology is described in Calculation NEDC 11-019, Section 10.0, Circuit Identification and Analysis. This methodology includes consideration of hot shorts (external and internal), open circuits, shorts to ground, and spurious signals (including interlock and permissive circuits).
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| The EDISON/SAFE database provides circuit analysis data and relational tie between each component and cable credited in the analysis model.
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| Development of the safe shutdown separation analysis for CNS required that circuit identification and analysis be performed for each electrically controlled and/or operated NSCA component. This task was performed through a detailed engineering review of circuit schematics, connection diagrams, cable block diagrams, and/or other relevant controlled plant documentation. The purpose of circuit identification and analysis was to identify and classify all cables supporting a given safe shutdown component such that a component/cable logic could be developed in preparation for computerized separation analysis.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 10.0)
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| Page B-57
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.3.1.2 Criteria/Assumptions In cases where the failure (including spurious actuations) of a single cable could impact more than one piece of safe shutdown equipment, include the cable with each piece of safe shutdown equipment.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 10.0 identifies the types of cables considered and selection criteria including control, permissive/interlock, indication/signal and annunciation circuits that could result in the spurious actuation of NSCA Equipment.
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| The EDISON/SAFE database provides relational tie between each component and cable credited to achieve a safe and stable condition.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 10.0)
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| Page B-58
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| Nebraska Public Power District NtNS NFPA 805 Transition Re.ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.3.1.3 Criteria/Assumptions Electrical devices such as relays, switches and signal resistor units are considered to be acceptable isolation devices. In the case of instrument loops, review the isolation capabilities of the devices in the loop to determine that an acceptable isolation device has been installed at each point where the loop must be isolated so that a fault would not impact the performance of the safe shutdown instrument function.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 5.1, NSCA Criteria / Assumptions for NEI 00-01, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criterion / assumption listed in Section 3.3.1.3 of NEI 00-01 is explicitly stated in Section 5.1.3 of the Calculation NEDC 11-019.
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| Cables containing circuit conductors required for post-fire operations, including circuits that could cause spurious operation are included within equipment cable logics for each of the NSCA Equipment. These cables are classified as "required." Cables that functioned as a portion of the control circuit, but that could not disable the control circuit required for safe and stable hot shutdown, were classified as "not required," and were not included in the cable logic.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 5.1.3, 10.2.2.1 and 10.2.3.2)
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| Page B-59
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.3.1.4 Criteria/Assumptions Screen out cables for circuits that do not impact the safe shutdown function of a component (i.e., annunciator circuits, space heater circuits and computer input circuits) unless some reliance on these circuits is necessary. However, they must be isolated from the component's control scheme in such a way that a cable fault would not impact the performance of the circuit.
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| AiDlicability Comments Applicable None Alicqnment Statement Aligns Alignment Basis Cable selection was performed for each electrically controlled and/or operated NSCA component per the guidance outlined in NEI-00-01 "Guidance for Post-Fire Circuit Analysis," and insights provided in NUREG/CR-6850 "EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities."
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| Cables associated with an NSCA component were classified as "required" or "not required" depending upon the possible effects that fire-induced cable failure could have upon the function(s) of the respective component.
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| Not required cables are generally only identified in the database for primary scheme (i.e., "on-scheme") cables that are determined not to be required for the NSCA, NPO, or Fire PRA. These cables are identified in the EDISON/SAFE database at the discretion of the preparer and reviewer of the circuit identification and analysis for each NSCA component to document that the primary scheme cables were indeed included and addressed in the circuit identification and analysis activity.
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| Cables that functioned as a portion of the control circuit, but that could not disable the control circuit required for safe and stable hot shutdown, were classified as "not required," and were not included in the cable logic.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 10.2.1 and 10.2.2.1)
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| Page B-60
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| Nebraska Public Power District CNS NFPA 805 Transition ReDort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.3.1.5 Criteria/Assumptions For each circuit requiring power to perform its safe shutdown function, identify the cable supplying power to each safe shutdown and/or required interlock component. Initially, identify only the power cables from the immediate upstream power source for these interlocked circuits and components (i.e., the closest power supply, load center or motor control center). Review further the electrical distribution system to capture the remaining equipment from the electrical power distribution system necessary to support delivery of power from either the offsite power source or the emergency diesel generators (i.e., onsite power source) to the safe shutdown equipment. Add this equipment to the safe shutdown equipment list. Evaluate the power cables for this additional equipment for associated circuits concerns.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Electrical power sources (e.g., AC/DC bus, MCC or distribution panel) providing motive power and/or control power for active components were identified and tabulated for each NSCA component. These electrical power sources were considered "active" components and subject to circuit analysis and cable selection.
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| Electrical power sources (e.g., AC/DC bus, MCC or distribution panel) providing motive power and/or control power for passive components were identified and tabulated for each NSCA component. These electrical power sources were considered as "active" safe shutdown components and subject to additional circuit analysis and cable selection if their failure (e.g., power supply de-energization or energization resulting from a fire-induced cable failure) could result in the spurious operation of the host passive component. If power supply failure could not result in spurious operation of the host passive component, the power supply was considered "passive," and not subject to circuit analysis and/or cable selection.
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| Calculation NEDC 11-019, Section 10.3, Associated Circuits of Concern Study, identifies the approach to address circuits of concerns by common power supply.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 10.2.2.2, 10.2.3 and 10.3)
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| Page B-61
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| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.3.1.6 Criteria/Assumptions The automatic initiation logics for the credited post-fire safe shutdown systems are not required to support safe shutdown.
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| Each system can be controlled manually by operator actuation in the main control room or emergency control station. If operator actions outside the MCR are necessary, those actions must conform to the regulatory requirements on manual actions. However, if not protected from the effects of fire, the fire-induced failure of automatic initiation logic circuits must not adversely affect any post-fire safe shutdown system function.
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| ADDlicability Comments Applicable None Alignment Statement Aligns Alignment Basis The cable selection process outlined in Calculation NEDC 11-019, Section 10.0 considers the affects of automatic, spurious and permissive signals.
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| Cables required to ensure positive remote manual control capability of a component were selected to provide the intended post-fire function. Credit was not taken for receipt of automatic/process signals initiating or assisting in initiation or operation of a system. Automatic signals that provided an automatic start (or trip) signal to components, however, were considered in the cable selection process as potential spurious concerns.
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| CNS takes credit for Operator Manual Actions (hot shutdown) that are not currently approved nor allowed by the NRC. These OMAs are currently characterized as compensatory actions and considered variances from deterministic requirements (VFDRs) that are being addressed / analyzed in accordance NFPA 805 FAQ 07-0030 and FAQ 08-0054 through the Fire Risk Evaluation process as part of transition to the new NFPA 805 licensing basis.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 10.0 and 10.2.1.1)
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| Page B-62
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| Nebraska Public Power District CNS NFPA 805 Transition ReDort - Attach ent B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.3.1.7 Criteria/Assumptions Cabling for the electrical distribution system is a concern for those breakers that feed associated circuits and are not fully coordinated with upstream breakers. With respect to electrical distribution cabling, two types of cable associations exist.
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| For safe shutdown considerations, the direct power feed to a primary safe shutdown component is associated with the primary component. For example, the power feed to a pump is necessary to support the pump. Similarly, the power feed from the load center to an MCC supports the MCC. However, for cases where sufficient branch-circuit coordination is not provided, the same cables discussed above would also support the power supply. For example, the power feed to the pump discussed above would support the bus from which it is fed because, for the case of a common power source analysis, the concern is the loss of the upstream power source and not the connected load. Similarly, the cable feeding the MCC from the load center would also be necessary to support the load center.
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| Applicabilitv Comments Applicable None Alignment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 10.3 identifies the approach taken to address associated circuits concerns by common power supply.
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| Coordination of circuit protective devices has been evaluated and demonstrated via the performance and maintenance of several Breaker/Fuse Coordination Studies. As such, there was not a need for inclusion of associated circuits of this kind into the separation analysis.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 10.3)
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| Page B-63
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.3.2 Associated Circuit Cables Appendix R, Section III.G.2, requires that separation features be provided for equipment and cables, including associated nonsafety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve hot shutdown. The three types of associated circuits were identified in Reference 6.1.5 and further clarified in a NRC memorandum dated March 22, 1982 from R. Mattson to D. Eisenhut, Reference 6.1.6. They are as follows:
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| - Spurious actuations
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| - Common power source
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| - Common enclosure Cables Whose Failure May Cause Spurious Actuations Safe shutdown system spurious actuation concerns can result from fire damage to a cable whose failure could cause the spurious actuation/mal-operation of equipment whose operation could affect safe shutdown. These cables are identified in Section 3.3.3 together with the remaining safe shutdown cables required to support control and operation of the equipment.
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| Common Power Source Cables The concern for the common power source associated circuits is the loss of a safe shutdown power source due to inadequate breaker/fuse coordination. In the case of a fire-induced cable failure on a non-safe shutdown load circuit supplied from the safe shutdown power source, a lack of coordination between the upstream supply breaker/fuse feeding the safe shutdown power source and the load breaker/fuse supplying the non-safe shutdown faulted circuit can result in loss of the safe shutdown bus. This would result in the loss of power to the safe shutdown equipment supplied from that power source preventing the safe shutdown equipment from performing its required safe shutdown function. Identify these cables together with the remaining safe shutdown cables required to support control and operation of the equipment.
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| Refer to Section 3.5.2.4 for an acceptable methodology for analyzing the impact of these cables on post-fire safe shutdown.
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| Common Enclosure Cables The concern with common enclosure associated circuits is fire damage to a cable whose failure could propagate to other safe shutdown cables in the same enclosure either because the circuit is not properly protected by an isolation device (breaker/fuse) such that a fire-induced fault could result in ignition along its length, or by the fire propagating along the cable and into an adjacent fire area. This fire spread to an adjacent fire area could impact safe shutdown equipment in that fire area, thereby resulting in a condition that exceeds the criteria and assumptions of this methodology (i.e., multiple fires). Refer to Section 3.5.2.5 for an acceptable methodology for analyzing the impact of these cables on post-fire safe shutdown.
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| Page B-64
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis The circuit analysis methodology is described in Calculation NEDC 11-019, Section 10.0. This methodology addresses spurious operation and includes consideration of hot shorts (external and internal), open circuits, shorts to ground, and spurious signals (including interlock and permissive circuits).
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| Associated circuits by common power supply are discussed in Calculation NEDC 11-019, Section 10.3. Associated Circuit by Common Enclosure is presented in Calculation NEDC 11-019, Section 10.3.4.
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| Refer to subsequent sections (3.5.2.4 & 3.5.2.5) for alignment details.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 10.0, 10.3.3 and 10.3.4)
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| Page B-65
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| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.3.3 Methodology for Cable Refer to Figure 3-4 for a flowchart illustrating the various steps involved in selecting the cables necessary for performing a Selection and Location post-fire safe shutdown analysis.
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| Use the following methodology to define the cables required for safe shutdown including cables that may cause associated circuits concerns for a post-fire safe shutdown analysis:
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| [Refer to hardcopy of NEI 00-01 for Figure]
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| Avolicabilitv Comments Not Applicable None Alignment Statement Not Applicable Alignment Basis Introductory section. Refer to subsequent sections for evaluation of specific criteria/guidance.
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| Reference Documents None Page B-66
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.3.3.1 Identify Circuits Required For each piece of safe shutdown equipment defined in section 3.2, review the appropriate electrical diagrams including for the Operation of the the following documentation to identify the circuits (power, control, instrumentation) required for operation or whose failure Safe Shutdown may impact the operation of each piece of equipment:
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| Equipment
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| - Single-line electrical diagrams
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| - Elementary wiring diagrams
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| - Electrical connection diagrams
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| - Instrument loop diagrams.
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| For electrical power distribution equipment such as power supplies, identify any circuits whose failure may cause a coordination concern for the bus under evaluation.
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| If power is required for the equipment, include the closest upstream power distribution source on the safe shutdown equipment list. Through the iterative process described in Figures 3-2 and 3-3, include the additional upstream power sources up to either the offsite or the emergency power source.
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| [Refer to hardcopy of NEI 00-01 for Figure]
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| ADplicability Comments Applicable None Alignment Statement Aligns Alignment Basis Appropriate drawings for applicable electrical equipment listed in the NFPA 805 Nuclear Safety Equipment List, Appendix A of NEDC 11-019 were reviewed during the cable selection process. Component work sheets and cable block diagrams have been created as appropriate. Any Input drawings used during the cable selection process have been identified on the worksheets/block diagrams. Power supplies have been identified for all active equipment.
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| Refer to Section 3.5.2.4 for alignment details related to coordination studies.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 Page B-67
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| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.3.3.2 Identify Interlocked In reviewing each control circuit, investigate interlocks that may lead to additional circuit schemes, cables and equipment.
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| Circuits and Cables Assign to the equipment any cables for interlocked circuits that can affect the equipment.
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| Whose Spurious Operation or Mal- While investigating the interlocked circuits, additional equipment or power sources may be discovered. Include these operation Could Affect interlocked equipment or power sources in the safe shutdown equipment list (refer to NEI 00-01 Rev 1 Figure 3-3) if they Shutdown can impact the operation of the equipment under consideration.
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| [Refer to hardcopy of NEI 00-01 for Figure]
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis The circuit analysis methodology is described in Calculation NEDC 11-019, Section 10.0. This methodology includes consideration of interlock and permissive circuits.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 10.0)
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| Page B-68
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| Nebraska Public Power District CNS N.PA 805 Transition Reoort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.3.3.3 Assign Cables to the Given the criteria/assumptions defined in Section 3.3.1, identify the cables required to operate or that may result in mal-Safe Shutdown operation of each piece of safe shutdown equipment.
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| Equipment Tabulate the list of cables potentially affecting each piece of equipment in a relational database including the respective drawing numbers, their revision and any interlocks that are investigated to determine their impact on the operation of the equipment. In certain cases, the same cable may support multiple pieces of equipment. Relate the cables to each piece of equipment, but not necessarily to each supporting secondary component.
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| Ifadequate coordination does not exist for a particular circuit, relate the power cable to the power source. This will ensure that the power source is identified as affected equipment in the fire areas where the cable may be damaged.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Circuit analysis data for each component and cable credited to achieve a safe and stable condition are contained in a relational database (EDISON/SAFE).
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| Section 11.0 of Calculation NEDC 11-019 describes the development of the model in the analysis database.
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| There were no cases of inadequate coordination identified for a particular circuit. Refer to Section 3.5.2.4 for alignment details related to coordination studies.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 11.0)
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| Page B-69
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.5 Circuit Analysis and This section on circuit analysis provides information on the potential impact of fire on circuits used to monitor, control and Evaluation power safe shutdown equipment. Applying the circuit analysis criteria will lead to an understanding of how fire damage to the cables may affect the ability to achieve and maintain post-fire safe shutdown in a particular fire area. This section should be used in conjunction with Section 3.4, to evaluate the potential fire-induced impacts that require mitigation.
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| Appendix R Section II.G.2 identifies the fire-induced circuit failure types that are to be evaluated for impact from exposure fires on safe shutdown equipment. Section III.G.2 of Appendix R requires consideration of hot shorts, shorts-to-ground and open circuits.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Section 10.0 of Calculation NEDC 11-019 describes the circuit analysis methodology used to meet the NFPA 805 requirements.
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| The fire induced cable damage postulated to occur within the NSCA includes hot shorts, shorts to ground, and open circuits.
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| Cables that are required to support the NFPA 805 equipment are maintained in the analysis database EDISON/SAFE. The database provides cable and circuit analysis data for each component and cable credited to achieve a safe and stable condition.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 10.0 and 10.3.2.1)
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| Page B-70
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.5.1 Criteria/Assumptions Apply the following criteria/assumptions when performing fire-induced circuit failure evaluations.
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| Applicability Comments Not Applicable None Alignment Statement Not Applicable Alignment Basis Introductory Section. Refer to subsequent sections for evaluation of specific criteria/assumptions.
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| Reference Documents None Page B-71
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| Nebraska Public Power District CNS NFPA 805 Transition ReDort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.5.1.1 Criteria/Assumptions Consider the following circuit failure types on each conductor of each unprotected safe shutdown cable to determine the potential impact of a fire on the safe shutdown equipment associated with that conductor.
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| - A hot short may result from a fire-induced insulation breakdown between conductors of the same cable, a different cable or from some other external source resulting in a compatible but undesired impressed voltage or signal on a specific conductor. A hot short may cause a spurious operation of safe shutdown equipment.
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| - An open circuit may result from a fire-induced break in a conductor resulting in the loss of circuit continuity. An open circuit may prevent the ability to control or power the affected equipment. An open circuit may also result in a change of state for normally energized equipment. (e.g. [for BWRs] loss of power to the Main Steam Isolation Valve (MSIV) solenoid valves due to an open circuit will result in the closure of the MSIVs). Note that RIS 2004-03 indicates that open circuits, as an initial mode of cable failures, are considered to be of very low likelihood. The risk-informed inspection process will focus on failures with relatively high probabilities.
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| - A short-to-ground may result from a fire-induced breakdown of a cable insulation system, resulting in the potential on the conductor being applied to ground potential. A short-to-ground may have all of the same effects as an open circuit and, in addition, a short-to-ground may also cause an impact to the control circuit or power train of which it is a part.
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| Consider the three types of circuit failures identified above to occur individually on each conductor of each safe shutdown cable on the required safe shutdown path in the fire area.
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| ApDlicability Comments Applicable None Aliqnment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 5.1, NSCA Criteria / Assumptions from NEI 00-01 Chapter 3, lists criteria / assumptions pertaining to the NSCA fire area assessment. The criteria / assumptions listed in Section 3.5.1.1 of NEI 00-01 are explicitly stated in the Section 5.1.5 of Calculation NEDC 11-019.
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| The three circuit failure types have all been identified and considered within the NSCA. Calculation NEDC 11-019 describes these circuit failure types within Section 10.3, Associated Circuits of Concern Study.
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| Page B-72
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 5.1.5 and 10.3)
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| Page B-73
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.5.1.2 Criteria/Assumptions Assume that circuit contacts are positioned (i.e., open or closed) consistent with the normal mode/position of the safe shutdown equipment as shown on the schematic drawings. The analyst must consider the position of the safe shutdown equipment for each specific shutdown scenario when determining the impact that fire damage to a particular circuit may have on the operation of the safe shutdown equipment.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 5.1, NSCA Criteria / Assumptions from NEI 00-01 Chapter 3, lists criteria / assumptions pertaining to the NSCA fire area assessment. The criteria / assumptions listed in Section 3.5.1.2 of NEI 00-01 are explicitly stated in Section 5.1.5 of Calculation NEDC 11-019.
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| All relay, position switch, and control switch contacts in the control circuits are in the position or status .that corresponds to the normal condition of the device. Test and transfer switches in control circuits are in their normal positions. This assumption is reasonable and is consistent with the single fire assumption identified above.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 5.1.5 and 5.2.1)
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| Page B-74
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.5.1.3 Criteria/Assumptions Assume that circuit failure types resulting in spurious operations exist until action has been taken to isolate the given circuit from the fire area, or other actions have been taken to negate the effects of circuit failure that is causing the spurious actuation. The fire is not assumed to eventually clear the circuit fault. Note that RIS 2004-03 indicates that fire-induced hot shorts typically self-mitigate after a limited period of time.
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| Applicability Comments Applicable None Aliqgnment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 5.1, NSCA Criteria / Assumptions from NEI 00-01 Chapter 3, lists criteria / assumptions pertaining to the NSCA fire area assessment. The criteria / assumptions listed in Section 3.5.1.3 of NEI 00-01 are explicitly stated in Section 5.1.5 of Calculation NEDC 11-019.
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| Fire induced damage that causes spurious operation exists until action has been taken to isolate the given circuit. The fire is not assumed to clear the circuit fault. The analysis utilizes the following mitigating methods to resolve spurious operation; plant modification, pre-fire de-energization and recovery action.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 5.1.5 and 10.3.2.5)
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| Page B-75
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| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment B NebrskaPubic owerDisric CN NFA 80 TrnsiionRe~ot -Attchmnt Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.5.1.4 Criteria/Assumptions When both trains are in the same fire area outside of primary containment, all cables that do not meet the separation requirements of Section III.G.2 are assumed to fail in their worst case configuration.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 5.1, NSCA Criteria / Assumptions for NEI 00-01, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria / assumption listed in Section 3.5.1.4 of NEI 00-01 is explicitly stated in Section 5.1.5 of Calculation NEDC 11-019.
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| The deterministic separation requirements of NFPA 805 Section 4.2.3 are similar and assume the same failure criteria of Section III.G.2. Additionally, NFPA 805 allows for a performance based analysis of fire areas that do not meet the deterministic requirements. NFPA 805 Section 4.2.4 details the requirements of the performance based analysis.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 5.1.5)
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| Page B-76
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| Nebraska Public Power District CNS NFPA 805 Transition ReDort - Attachment B Nebrask....Public. PoeIititCSNP 0 rasto eot-Atcmn Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.5.1.5 Criteria/Assumptions The following guidance provides the NRC inspection focus from Bin 1 of RIS 2004-03 in order to identify any potential combinations of spurious operations with higher risk significance. Bin 1 failures should also be the focus of the analysis; however, NRC has indicated that other types of failures required by the regulations for analysis should not be disregarded even ifin Bin 2 or 3. If Bin I changes in subsequent revisions of RIS 2004-03, the guidelines in the revised RIS should be followed.
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| Cable Failure Modes. For multiconductor cables testing has demonstrated that conductor-to-conductor shorting within the same cable is the most common mode of failure. This is often referred to as "intra-cable shorting." It is reasonable to assume that given damage, more than one conductor-to-conductor short will occur in a given cable. A second primary mode of cable failure is conductor-to-conductor shorting between separate cables, commonly referred to as "inter-cable shorting." Inter-cable shorting is less likely than intra-cable shorting. Consistent with the current knowledge of fire-induced cable failures, the following configurations should be considered:
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| A. For any individual multiconductor cable (thermoset or thermoplastic), any and all potential spurious actuations that may result from intra-cable shorting, including any possible combination of conductors within the cable, may be postulated to occur concurrently regardless of number. However, as a practical matter, the number of combinations of potential hot shorts increases rapidly with the number of conductors within a given cable. For example, a multiconductor cable with three conductors (3C) has 3 possible combinations of two (including desired combinations), while a five conductor cable (5C) has 10 possible combinations of two (including desired combinations), and a seven conductor cable (7C) has 21 possible combinations of two (including desired combinations). To facilitate an inspection that considers most of the risk presented by postulated hot shorts within a multiconductor cable, inspectors should consider only a few (three or four) of the most critical postulated combinations.
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| B. For any thermoplastic cable, any and all potential spurious actuations that may result from intra-cable and inter-cable shorting with other thermoplastic cables, including any possible combination of conductors within or between the cables, may be postulated to occur concurrently regardless of number. (The consideration of thermoset cable inter-cable shorts is deferred pending additional research.)
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| C. For cases involving the potential damage of more than one multiconductor cable, a maximum of two cables should be assumed to be damaged concurrently. The spurious actuations should be evaluated as previously described. The consideration of more than two cables being damaged (and subsequent spurious actuations) is deferred pending additional research.
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| D. For cases involving direct current (DC) circuits, the potential spurious operation due to failures of the associated control cables (even ifthe spurious operation requires two concurrent hot shorts of the proper polarity, e.g., plus-to-plus and Page B-77
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| Nebraska Public Power District CNS NFPA 805 Transition Rei)ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis minus-to-minus) should be considered when the required source and target conductors are each located within the same multiconductor cable.
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| E. Instrumentation Circuits. Required instrumentation circuits are beyond the scope of this associated circuit approach and must meet the same requirements as required power and control circuits. There is one case where an instrument circuit could potentially be considered an associated circuit. Iffire-induced damage of an instrument circuit could prevent operation (e.g., lockout permissive signal) or cause maloperation (e.g., unwanted start/stop/reposition signal) of systems necessary to achieve and maintain hot shutdown, then the instrument circuit may be considered an associated circuit and handled accordingly.
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| Likelihood of Undesired Consequences Determination of the potential consequence of the damaged associated circuits is based on the examination of specific NPP piping and instrumentation diagrams (P&IDs) and review of components that could prevent operation or cause maloperation such as flow diversions, loss of coolant, or other scenarios that could significantly impair the NPP's ability to achieve and maintain hot shutdown. When considering the potential consequence of such failures, the [analyst] should also consider the time at which the prevented operation or maloperation occurs. Failures that impede hot shutdown within the first hour of the fire tend to be most risk significant in a first-order evaluation. Consideration of cold-shutdown circuits is deferred pending additional research.
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| Applicability Comments Applicable None Alignment Statement Aligns Alicqnment Basis CNS performed a Fire Protection self assessment (April 2005) to review the existing Appendix R Safe Shutdown Analysis with respect to NRC RIS 2004-03, Bin 1 issues for various cable failure modes.
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| The procedure for NFPA 805 / FPRA cable selection and circuit analysis (EPM-DP-EP-004) references the RIS mention above. However, understanding that RIS applies primarily for the Reactor Oversight Process (ROP), itdoes not place the same limitations or restrictions on circuit failure modes analysis performed under the self assessment as part of the new licensing basis proposed under NFPA 805. Specifically no limitations have been placed on cable type (thermoplastic/thermoset) or short failure modes (intra-/inter-cable). In addition, as part of the NFPA 805 transition, NPPD performed a series of expert panel systems reviews to address the potential for multiple spurious operations (MSOs). Results were fed back into the NSCA and Fire PRA as necessary. The treatment of MSOs is to be documented in the applicable section of the LAR Transition Report.
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| Page B-78
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| Nebraska Public Power District CNS NFPA 805 Transition Re.ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis Reference Documents P1731-RPT-001, "CNS Associated Circuits Assessment for RIS 2004-03," Revision 0 Page B-79
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| Nebraska Public Power District NFPA 805 Transition Reort - Atta.h.,nt NebrtCNS R Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.5.2 Types of Circuit Failures Appendix R requires that nuclear power plants must be designed to prevent exposure fires from defeating the ability to achieve and maintain post-fire safe shutdown. Fire damage to circuits that provide control and power to equipment on the required safe shutdown path and any other equipment whose spurious operation/mal-operation could affect shutdown in each fire area must be evaluated for the effects of a fire in that fire area. Only one fire at a time is assumed to occur. The extent of fire damage is assumed to be limited by the boundaries of the fire area. Given this set of conditions, it must be assured that one redundant train of equipment capable of achieving hot shutdown is free of fire damage for fires in every plant location. To provide this assurance, Appendix R requires that equipment and circuits required for safe shutdown be free of fire damage and that these circuits be designed for the fire-induced effects of a hot short, short-to-ground, and open circuit. With respect to the electrical distribution system, the issue of breaker coordination must also be addressed.
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| This section will discuss specific examples of each of the following types of circuit failures:
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| - Open circuit
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| - Short-to-ground
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| - Hot short.
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| Applicability Comments Not Applicable None Alignment Statement Not Applicable Alignment Basis Introductory Section. Refer to subsequent sections for evaluation of specific circuit failure types.
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| Reference Documents None Page B-80
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| Nebraska Public Power District CNS NFPA 805 Transition Renort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.5.2.1 Circuit Failures Due to an This section provides guidance for addressing the effects of an open circuit for safe shutdown equipment. An open circuit Open Circuit is a fire-induced break in a conductor resulting in the loss of circuit continuity. An open circuit will typically prevent the ability to control or power the affected equipment. An open circuit can also result in a change of state for normally energized equipment. For example, a loss of power to the main steam isolation valve (MSIV) solenoid valves [for BWRs]
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| due to an open circuit will result in the closure of the MSIV.
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| NOTE: The EPRI circuit failure testing indicated that open circuits are not likely to be the initial fire-induced circuit failure mode. Consideration of this may be helpful within the safe shutdown analysis. Consider the following consequences in the safe shutdown circuit analysis when determining the effects of open circuits:
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| - Loss of electrical continuity may occur within a conductor resulting in deenergizing the circuit and causing a loss of power to, or control of, the required safe shutdown equipment.
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| - In selected cases, a loss of electrical continuity may result in loss of power to an interlocked relay or other device. This loss of power may change the state of the equipment. Evaluate this to determine ifequipment fails safe.
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| - Open circuit on a high voltage (e.g., 4.16 kV) ammeter current transformer (CT) circuit may result in secondary damage.
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| [Refer to hardcopy of NEI 00-01 for Figure 3.5.2-1 that shows example of open circuits]
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| ADDlicability Comments Applicable None Alicinment Statement Aligns Alignment Basis The fire induced cable damage postulated to occur includes hot shorts, shorts to ground, and open circuits. Multiple simultaneous circuit failures are postulated in the circuit identification and analysis (affecting multiple cables, affecting multiple conductors within cables). No limit is prescribed to the number or type circuit failures that are postulated to occur except as modified by the following: In consideration of spurious actuations, all possible functional failure states must be evaluated as a result of one or more of the above failure modes. For three-phase AC electrical circuits, the probability of getting a hot short on all three phases in the proper sequence to cause spurious operation of a motor is considered sufficiently low as to not require evaluation except for any cases involving high/low pressure interfaces. For ungrounded DC circuits, ifit would require that two shorts of the proper polarity without grounding cause the spurious operation, then no further evaluation is necessary except for cases involving high/low pressure interfaces.
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| Page B-81
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis Calculation NEDC 11-071, Evaluation of Current Transformer Open Secondary, during a Fire, concludes the following: a Current Transformer (CT) secondary open circuit will produce very short duration high voltage pulses when the circuit cable has high cable insulation resistance (IR). However, based on cable fire data, high cable IRduring a fire event is indicative of an intact cable, not one with an open conductor. More likely, an open conductor exists when the cable is damaged by the fire and the cable IR is 100 ohms or less. At this degraded level the CT voltage pulses are much lower. The possibility of the much lower voltages causing a secondary fire at the CT location is unlikely.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 5.2.3)
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| Calculation NEDC 11-071, "Evaluation of Current Transformer Open Secondary during a Fire," Revision 0 Page B-82
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.5.2.2 Circuit Failures Due to a This section provides guidance for addressing the effects of a short-to-ground on circuits for safe shutdown equipment. A Short-to-Ground short-to-ground is a fire-induced breakdown of a cable insulation system resulting in the potential on the conductor being applied to ground potential. A short-to-ground can cause a loss of power to or control of required safe shutdown equipment. In addition, a short-to-ground may affect other equipment in the electrical power distribution system in the cases where proper coordination does not exist. Consider the following consequences in the post-fire safe shutdown analysis when determining the effects of circuit failures related to shorts-to-ground:
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| - A short to ground in a power or a control circuit may result in tripping one or more isolation devices (i.e. breaker/fuse) and causing a loss of power to or control of required safe shutdown equipment.
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| - In the case of certain energized equipment such as HVAC dampers, a loss of control power may result in loss of power to an interlocked relay or other device that may cause one or more spurious operations.
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| [Refer to hardcopy of NEI 00-01 for Figures 3.5.2-2 and 3.5.2-3 that shows example of short-to-ground on ungrounded and grounded circuits]
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| Applicability Comments Applicable None Aliqnment Statement Aligns Aliqnment Basis The fire-induced cable damage postulated to occur includes hot shorts, shorts-to-ground, and open circuits. Multiple simultaneous circuit failures are postulated in the circuit identification and analysis (affecting multiple cables, affecting multiple conductors within cables). No limit is prescribed to the number or type of circuit failures that are postulated to occur, except as modified by the following: In consideration of spurious actuations, all possible functional failure states must be evaluated as a result of one or more of the above failure modes. For three-phase AC electrical circuits, the probability of getting a hot short on all three phases in the proper sequence to cause spurious operation of a motor is considered sufficiently low as to not require evaluation, except for any cases involving high/low pressure interfaces. For ungrounded DC circuits, if it would require that two shorts of the proper polarity without grounding cause the spurious operation, then no further evaluation is necessary except for cases involving high/low pressure interfaces.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 5.2.3)
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| Page B-83
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| Nebraska Public Power District Nebraska..CNS NFPA 805 Transition ReDort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.5.2.3 Circuit Failures Due to a This section provides guidance for analyzing the effects of a hot short on circuits for required safe shutdown equipment. A Hot Short hot short is defined as a fire induced insulation breakdown between conductors of the same cable, a different cable or some other external source resulting in an undesired impressed voltage on a specific conductor. The potential effect of the undesired impressed voltage would be to cause equipment to operate or fail to operate in an undesired manner.
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| Consider the following specific circuit failures related to hot shorts as part of the post-fire safe shutdown analysis:
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| - A hot short between an energized conductor and a de-energized conductor within the same cable may cause a spurious actuation of equipment. The spuriously actuated device (e.g., relay) may be interlocked with another circuit that causes the spurious actuation of other equipment. This type of hot short is called a conductor-to-conductor hot short or an internal hot short.
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| - A hot short between any external energized source such as an energized conductor from another cable (thermoplastic cables only) and a de-energized conductor may also cause a spurious actuation of equipment. This is called a cable-to-cable hot short or an external hot short. Cable-to-cable hot shorts between thermoset cables are not postulated to occur pending additional research.
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| [Refer to hardcopy of NEI 00-01 for Figures 3.5.2-4 and 3.5.2-5 that shows example of hot shorts on ungrounded and grounded circuits]
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Consider the following circuit failure types on each conductor of each unprotected safe shutdown cable to determine the potential impact of a fire on the safe shutdown equipment associated with that conductor. A hot short may result from a fire-induced insulation breakdown between conductors of the same cable, a different cable, or from some other external source resulting in a compatible but undesired impressed voltage or signal on a specific conductor. A hot short may cause a spurious operation of safe shutdown equipment.
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| Circuit identification and analysis for the CNS NSCA includes consideration for multiple concurrent hot shorts, open circuits, and shorts-to-ground.
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| The fire induced cable damage postulated to occur includes hot shorts, shorts-to-ground, and open circuits. In consideration of spurious actuations, all possible Page B-84
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis functional failure states must be evaluated as a result of one or more of the above failure modes.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 5.1.5, 10.0 and 10.3.2.1)
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| Page B-85
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.5.2.4 Circuit Failures Due to The evaluation of associated circuits of a common power source consists of verifying proper coordination between the Inadequate Circuit supply breaker/fuse and the load breakers/fuses for power sources that are required for safe shutdown. The concern is Coordination that, for fire damage to a single power cable, lack of coordination between the supply breaker/fuse and the load breakers/fuses can result in the loss of power to a safe shutdown power source that is required to provide power to safe shutdown equipment.
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| A coordination study should demonstrate the coordination status for each required common power source. For coordination to exist, the time-current curves for the breakers, fuses and/or protective relaying must demonstrate that a fault on the load circuits is isolated before tripping the upstream breaker that supplies the bus. Furthermore, the available short circuit current on the load circuit must be considered to ensure that coordination is demonstrated at the maximum fault level.
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| The methodology for identifying potential associated circuits of a common power source and evaluating circuit coordination cases of associated circuits on a single circuit fault basis is as follows:
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| - Identify the power sources required to supply power to safe shutdown equipment.
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| - For each power source, identify the breaker/fuse ratings, types, trip settings and coordination characteristics for the incoming source breaker supplying the bus and the breakers/fuses feeding the loads supplied by the bus.
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| - For each power source, demonstrate proper circuit coordination using acceptable industry methods.
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| - For power sources not properly coordinated, tabulate by fire area the routing of cables whose breaker/fuse is not properly coordinated with the supply breaker/fuse. Evaluate the potential for disabling power to the bus in each of the fire areas in which the associated circuit cables of concern are routed and the power source is required for safe shutdown.
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| Prepare a list of the following information for each fire area:
| |
| - Cables of concern.
| |
| - Affected common power source and its path.
| |
| - Raceway in which the cable is enclosed.
| |
| - Sequence of the raceway in the cable route.
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| - Fire zone/area in which the raceway is located.
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| For fire zones/areas in which the power source is disabled, the effects are mitigated by appropriate methods.
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| Page B-86
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis
| |
| - Develop analyzed safe shutdown circuit dispositions for the associated circuit of concern cables routed in an area of the same path as required by the power source. Evaluate adequate separation based upon the criteria in Appendix R, NRC staff guidance, and plant licensing bases.
| |
| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Circuit coordination has been evaluated by NPPD under Breaker/Fuse Coordination Studies NEDC 86-105B, "Critical AC Coordination", NEDC 86-1 05D, "Critical DC Coordination", NEDC 86-105F, "Non-critical AC Coordination" and NEDC 09-028, "120V Fuse Coordination". The results of these calculations are summarized within Section 10.3.3 of Calculation NEDC 11-019.
| |
| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 10.3.3)
| |
| Calculation NEDC 86-105B, "Critical AC Coordination, " Revision 8 Calculation NEDC 86-105D, "Critical DC Coordination" Calculation NEDC 86-105F, "Non-critical AC Coordination" Revision 6 Calculation NEDC 09-028, "120V Fuse Coordination," Revision 0 Page B-87
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.5.2.5 Circuit Failures Due to The common enclosure associated circuit concern deals with the possibility of causing secondary failures due to fire Common Enclosure damage to a circuit either whose isolation device fails to isolate the cable fault or protect the faulted cable from reaching Concerns its ignition temperature, or the fire somehow propagates along the cable into adjoining fire areas.
| |
| The electrical circuit design for most plants provides proper circuit protection in the form of circuit breakers, fuses and other devices that are designed to isolate cable faults before ignition temperature is reached. Adequate electrical circuit protection and cable sizing are included as part of the original plant electrical design maintained as part of the design change process. Proper protection can be verified by review of as-built drawings and change documentation. Review the fire rated barrier and penetration designs that preclude the propagation of fire from one fire area to the next to demonstrate that adequate measures are in place to alleviate fire propagation concerns.
| |
| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Review of applicable documentation determined that the application and sizing of cable and circuit protection devices along with breaker/fuse coordination has been implemented into plant design to eliminate the requirement to postulate circuit failures due to common enclosures.
| |
| Electrical penetrations are fire-sealed at their boundary penetrations with fire stops installed equivalent to those required for the boundary. Exceptions are required to be addressed and justified through engineering evaluations.
| |
| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 3.0, 10.3.4 and 10.3.4.1)
| |
| Burns & Roe, "Engineering Criteria Document for Cooper Nuclear Station," Dated 6/3/70 CNS Design Criteria Document DCD-5, "DC Electrical Distribution System," Revision 0 CNS Design Criteria Document DCD-4, "AC Electrical Distribution System," Revision 0 Calculation NEDC 09-028, "120V Fuse Coordination," Revision 0 Page B-88
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition ReDort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis Calculation NEDC 86-105D, "Critical DC Coordination" Calculation NEDC 86-105F, "Non-critical AC Coordination," Revision 6 Page B-89
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.3 Nuclear Safety Equipment and Cable Location Physical location of equipment and cables shall be identified.
| |
| NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.3.3.4 Identify Routing of Cables Identify the routing for each cable including all raceway and cable endpoints. Typically, this information is obtained from joining the list of safe shutdown cables with an existing cable and raceway database.
| |
| Applicability Comments Applicable None Alicqnment Statement Aligns Alignment Basis The routing information for each cable required for the NSCA has been entered into EDISON/SAFE for use in the analysis. The routing information will be used to determine cable fire zones to support the NSCA analysis.
| |
| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 10.3.5)
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| Page B-90
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.3 Nuclear Safety Equipment and Cable Location NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.3.3.5 Identify Location of Identify the fire area location of each raceway and cable endpoint identified in the previous step and join this information Raceway and Cables by with the cable routing data. In addition, identify the location of field-routed cable by fire area. This produces a database Fire Area containing all of the cables requiring fire area analysis, their locations by fire area, and their raceway.
| |
| Applicability Comments Applicable None Alignment Statement Aligns Aliqnment Basis The methodology for the identification of locating credited equipment and cables is described in Section 10.3.5 of Calculation NEDC 11-019. Location information is provided on a fire zone basis for each equipment and cable credited in the analysis.
| |
| The routing information (tray, conduit, etc.) of each required cable was reviewed to determine the fire zone locations. Cable fire zones were determined by a review of the plant equipment and cable and conduit layout drawings. This information was entered into EDISON/SAFE for use in the NSCA model.
| |
| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 10.3.5)
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| Page B-91
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition ReDort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment An engineering analysis shall be performed in accordance with the requirements of Section 2.3 for each fire area to determine the effects of fire or fire suppression activities on the ability to achieve the nuclear safety performance criteria of Section 1.5. See Chapter 4 for methods of achieving these performance criteria (performance-based or deterministic).
| |
| NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.4 Fire Area Assessment By determining the location of each component and cable by fire area and using the cable to equipment relationships and Compliance described above, the affected safe shutdown equipment in each fire area can be determined. Using the list of affected Strategies equipment in each fire area, the impacts to safe shutdown systems, paths and functions can be determined. Based on an assessment of the number and types of these impacts, the required safe shutdown path for each fire area can be determined. The specific impacts to the selected safe shutdown path can be evaluated using the circuit analysis and evaluation criteria contained in Section 3.5 of this document. Having identified all impacts to the required safe shutdown path in a particular fire area, this section provides guidance on the techniques available for individually mitigating the effects of each of the potential impacts.
| |
| ApDlicability Comments Applicable None Alignment Statement Aligns Alignment Basis The EDISON/SAFE module provides the capability to perform an automated analysis utilizing a model composed of plant systems, equipment, cables, and their physical locations. The analysis uses a Boolean logic evaluation method that supports success path relationships enabling analysis and graphic display capability of each fire zone/fire area. Consequently, EDISON/SAFE contains the complete Cooper Nuclear Station (CNS) Nuclear Safety Capability Assessment (NSCA) analysis including the equipment, cable, fire zone/area, logic, analysis results and compliance strategy information necessary to support the NSCA.
| |
| Refer to subsequent sections for evaluation of specific criteria/assumptions.
| |
| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 12.1)
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| Page B-92
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| | |
| Nebraska Public Power District NFPA 805 Transition
| |
| .NS Renort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.4.1 Criteria/Assumptions The following criteria and assumptions apply when performing fire area compliance assessment to mitigate the consequences of the circuit failures identified in the previous sections for the required safe shutdown path in each fire area.
| |
| Applicability Comments Not Applicable None Alignment Statement Not Applicable Alignment Basis Introductory section. Refer to subsequent sections for evaluation of specific criteria/guidance.
| |
| Reference Documents None Page B-93
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.4.1.1 Criteria/Assumptions Assume only one fire in any single fire area at a time.
| |
| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 5.1, NSCA Criteria / Assumptions for NEI 00-01, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria / assumption listed in Section 3.4.1.1 of NEI 00-01 is explicitly stated in Section 5.1.4 of Calculation NEDC 11-019.
| |
| The NSCA assumes only one fire in a single fire area at a time.
| |
| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 5.1.4)
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| Page B-94
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition ReDort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.4.1.2 Criteria/Assumptions Assume that the fire may affect all unprotected cables and equipment within the fire area. This assumes that neither the fire size nor the fire intensity is known. This is conservative and bounds the exposure fire that is required by the regulation.
| |
| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 5.1, NSCA Criteria / Assumptions for NEI 00-01, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria /assumption listed in Section 3.4.1.2 of NEI 00-01 is explicitly stated in Section 5.1.4 of Calculation NEDC 11-019.
| |
| All unprotected equipment and cables are fire-affected within a fire area for the NSCA deterministic analysis that is required to determine the VFDRs. Additional performance-based analysis may be utilized per NFPA 805.
| |
| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 5.1.4)
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| Page B-95
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.4.1.3 Criteria/Assumptions Address all cable and equipment impacts affecting the required safe shutdown path in the fire area. All potential impacts within the fire area must be addressed. The focus of this section is to determine and assess the potential impacts to the required safe shutdown path selected for achieving post-fire safe shutdown and to assure that the required safe shutdown path for a given fire area is properly protected.
| |
| Applicability Comments Applicable None Aliqnment Statement Aligns Alignment Basis Calculation NEDC 11-019, Section 5.1, NSCA Criteria / Assumptions for NEI 00-01, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria / assumption listed in Section 3.4.1.3 of NEI 00-01 is explicitly stated in Section 5.1.4 of Calculation NEDC 11-019.
| |
| The NSCA requires one success path for each performance goal be available to achieve a safe and stable condition. This compliance strategy is determined by performing a deterministic analysis and resolving any fire-affected equipment and/or cables within that success path. Any failures within the success path that require OMA are further investigated with the use of performance-based methods. All failures within the credited compliance strategies are analyzed and resolved to ensure the credited strategy is properly protected and available.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 5.1.4)
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| Page B-96
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.4.1.4 Criteria/Assumptions Use manual actions where appropriate to achieve and maintain post-fire safe shutdown conditions in accordance with NRC requirements.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Operator manual actions are considered variances from deterministic requirements (VFDRs) that are being addressed / analyzed in accordance FAQ 30 / 54 through the Fire Risk Evaluation process as part of transition to the new NFPA 805 licensing basis.
| |
| Recovery actions can be performed as part of a performance-based, risk-informed approach subject to the limitations of Chapter 4 of NFPA 805 to mitigate a spurious actuation or achieve and maintain a Nuclear Safety Performance Criterion. The NFPA 805 recovery action assessment documented in CNS Calculation NEDC 11-020 "Recovery Action Transition," documents the results of an evaluation and documentation of recovery actions used as resolutions to VFDRs at the Cooper Nuclear Station.
| |
| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 12.3)
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| NEDC 11-020, "Recovery Action Transition", Rev 0 Page B-97
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.4.1.5 Criteria/Assumptions Where appropriate to achieve and maintain cold shutdown within 72 hours, use repairs to equipment required in support of post-fire shutdown.
| |
| Applicability Comments Applicable None Aligqnment Statement Aligns Alignment Basis The 72-hour requirement from NEI 00-01 is only applicable to the 10 CFR 50 Appendix R licensing basis. Per Section 1.3.1 of NFPA 805, given a fire, a plant is not required to transition to cold shutdown within 72 hours but instead provide reasonable assurance to achieve and maintain the fuel in a safe and stable condition. For CNS, the required end state of "safe and stable" under NFPA 805 will be met when the plant is in a stable hot shutdown configuration.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 7.5)
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| Page B-98
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| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.4.1.6 Criteria/Assumptions Appendix R compliance requires that one train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) is free of fire damage (III.G.1 .a). When cables or equipment, including associated circuits, are within the same fire area outside primary containment and separation does not already exist, provide one of the following means of separation for the required safe shutdown path(s):
| |
| - Separation of cables and equipment and associated nonsafety circuits of redundant trains within the same fire area by a fire barrier having a 3-hour rating (lll.G.2.a)
| |
| - Separation of cables and equipment and associated nonsafety circuits of redundant trains within the same fire area by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area (llI.G.2.b).
| |
| - Enclosure of cable and equipment and associated non-safety circuits of one redundant train within a fire area in a fire barrier having a one-hour rating. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area (lll.G.2.c).
| |
| For fire areas inside noninerted containments, the following additional options are also available:
| |
| - Separation of cables and equipment and associated nonsafety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards (lll.G.2.d);
| |
| - Installation of fire detectors and an automatic fire suppression system in the fire area (lll.G.2.e); or
| |
| - Separation of cables and equipment and associated non-safety circuits of redundant trains by a noncombustible radiant energy shield (llI.G.2.f).
| |
| Use exemptions, deviations and licensing change processes to satisfy the requirements mentioned above and to demonstrate equivalency depending upon the plant's license requirements.
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| Applicability Comments Applicable None Alignment Statement Aligns Page B-99
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment Alignment Basis As part of Transition to NFPA 805, similar deterministic approaches (NFPA 805, Section 4.2.3) or performance-based approaches (NFPA 805 Section 4.2.4) will be used to achieve compliance with the new regulation. If performance-based methods are used then variances from deterministic requirements (VFDRs) will be identified and addressed using the fire risk evaluation process.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 12.1.2)
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| Page B-100
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.4.1.7 Criteria/Assumptions Consider selecting other equipment that can perform the same safe shutdown function as the impacted equipment. In addressing this situation, each equipment impact, including spurious operations, is to be addressed in accordance with regulatory requirements and the NPP's current licensing basis.
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| Applicability Comments Applicable None Alignment Statement Aligns Alignment Basis Numerous systems are used to accomplish the NFPA 805 Performance Goals. This includes a list of equipment comprising the system and the logical relationship between the system and the equipment. The system function may be accomplished by more than one set of equipment and this is shown by an "OR" logic relationship. The system-equipment logical relationship is shown in both a tabular and graphic format.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 5.1.4 and 9.4)
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| Page B-101
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.4.1.8 Criteria/Assumptions Consider the effects of the fire on the density of the fluid in instrument tubing and any subsequent effects on instrument readings or signals associated with the protected safe shutdown path in evaluating post-fire safe shutdown capability. This can be done systematically or via procedures such as Emergency Operating Procedures.
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| ADDlicability Comments Applicable None Aliqnment Statement Aligns Alignment Basis As part of the NFPA 805 Transition, the impact of fire on instrument tubing sensing lines was evaluated considering the fire area location of the instrument sensing lines. The sensing lines for the applicable process monitoring instruments are included in the NSCA model, and evaluated similar to a cable, such that the instrument is assumed to fail in areas containing its associated tubing unless an evaluation notes otherwise. The sensing lines for applicable process monitoring instruments are welded steel; therefore, the pressure boundary will not be breached as a result of fire damage. For instruments that are credited as active or for instruments whose failure could be detrimental, the fire zone location of the instrument, together with the fire zone(s) where the instrument's sensing line is located, ifdifferent than that of the instrument, are associated in EDISON/SAFE with the instrument. In this manner, a fire would fail the instrument in the fire zone containing the instrument and in any fire zone containing the sensing line.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 9.5)
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| Page B-102
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| Nebraska Public Power District CNS NFPA 805 Transition Reoort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.4.2 Methodology for Fire Refer to Figure 3-5 for a flowchart illustrating the various steps involved in performing a fire area assessment.
| |
| Area Assessment Use the following methodology to assess the impact to safe shutdown and demonstrate Appendix R compliance:
| |
| [Refer to hardcopy of NEI 00-01 for Figure]
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| Applicability Comments Not Applicable None Aliqnment Statement Not Applicable Alignment Basis Introductory Section. Refer to subsequent sections for evaluation of specific guidance.
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| Reference Documents None Page B-103
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| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.4.2.1 Identify the Affected Identify the safe shutdown cables, equipment and systems located in each fire area that may be potentially damaged by Equipment by Fire Area the fire. Provide this information in a report format. The report may be sorted by fire area and by system in order to understand the impact to each safe shutdown path within each fire area (see Attachment 5 for an example of an Affected Equipment Report).
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| [Refer to hardcopy of NEI 00-01 for Attachment]
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| ADDlicability Comments Applicable None Alignment Statement Aligns Alicqnment Basis An automated analysis is completed within EDISON/SAFE to determine the fire affected equipment and cables for each fire area. The analysis steps through the logic statements (system logic statements, performance goal success paths, equipment-equipment success paths, equipment-cable success paths, and equipment-system success paths) beginning with the initially failed items list (systems, equipment, and cables). Initially failed items list are located in the fire zone being analyzed, or specified at the beginning of the analysis, or have a resolution type of initially failed for the fire zone or zones being analyzed.
| |
| The analysis structure and results are displayed as a tree structure beginning with performance goals on the left leading to system logic. The system logic display shows all equipment in every success path. This tree structure diagram of the EDISON/SAFE model shows the results of the analysis in the following way:
| |
| Failed equipment, cables, systems, and performance goals (displayed in red text)
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| Resolved equipment, cables, systems (displayed in blue text, with check mark)
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| Design Change (ACP) logics, ifapplicable (displayed in bold text)
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| All items that show with black text are unaffected by the initial failures used in this analysis.
| |
| The failed equipment and cables can be listed in report format for each fire area from EDISON/SAFE.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 11.1.3)
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| Page B-104
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.4.2.2 Determine the Shutdown Based on a review of the systems, equipment and cables within each fire area, determine which shutdown paths are Paths Least Impacted By either unaffected or least impacted by a postulated fire within the fire area. Typically, the safe shutdown path with the least a Fire in Each Fire Area number of cables and equipment in the fire area would be selected as the required safe shutdown path. Consider the circuit failure criteria and the possible mitigating strategies, however, in selecting the required safe shutdown path in a particular fire area. Review support systems as a part of this assessment since their availability will be important to the ability to achieve and maintain safe shutdown. For example, impacts to the electric power distribution system for a particular safe shutdown path could present a major impediment to using a particular path for safe shutdown. By identifying this early in the assessment process, an unnecessary amount of time is not spent assessing impacts to the frontline systems that will require this power to support their operation.
| |
| Based on an assessment as described above, designate the required safe shutdown path(s) for the fire area. Identify all equipment not in the safe shutdown path whose spurious operation or mal-operation could affect the shutdown function.
| |
| Include these cables in the shutdown function list. For each of the safe shutdown cables (located in the fire area) that are part of the required safe shutdown path in the fire area, perform an evaluation to determine the impact of a fire-induced cable failure on the corresponding safe shutdown equipment and, ultimately, on the required safe shutdown path.
| |
| When evaluating the safe shutdown mode for a particular piece of equipment, it is important to consider the equipment's position for the specific safe shutdown scenario for the full duration of the shutdown scenario. It is possible for a piece of equipment to be in two different states depending on the shutdown scenario or the stage of shutdown within a particular shutdown scenario. Document information related to the normal and shutdown positions of equipment on the safe shutdown equipment list.
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| ApDlicability Comments Applicable None Alignment Statement Aligns Alignment Basis EDISON/SAFE provides a demonstration that at least one post-fire success path is established including the documentation of any engineering justification, recovery actions, etc., needed to ensure the path is available. EDISON/SAFE resolutions (masks) are provided in the form of a protection remark, or compliance strategy, used to disposition the failure of a specific component or cable during the performance of the separation analysis for a specific fire area. Resolutions are only applied to components and cables associated with the systems selected to be utilized to achieve a safe and stable condition. The NFPA 805 systems selected to achieve this condition are those least affected (if at all) by the fire thus minimizing the number of variances that require resolution.
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| Page B-105
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| Nebraska Public Power District CNS NFPA 805 Transition ReDort - Attach ent B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment Fire Area compliance strategies for each fire area are contained within Appendix F of Calculation NEDC 11-019. The compliance strategies include resolutions, recovery actions and credited system success paths for each fire area.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 11.1, 12.1.2 and Appendix F)
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| Page B-106
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.4.2.3 Determine Safe Using the circuit analysis and evaluation criteria contained in Section 3.5 of this document, determine the equipment that Shutdown Equipment can impact safe shutdown and that can potentially be impacted by a fire in the fire area, and what those possible impacts Impacts are.
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| ADDlicability Comments Applicable None Alignment Statement Aligns Aliqnment Basis The EDISON/SAFE database electronically identifies the equipment that is affected by a fire within a specified fire area. This is completed through logical relationships that have been created within the database. NSCA model development is detailed within Section 9.0 of Calculation NEDC 11-019.
| |
| The NSCA analysis is run in EDISON/SAFE, which indicates possible instances where the performance goals are not met. Each of these instances is reviewed. If there is a design reason that the instance is not a problem, e.g. the battery charger fails but the capacity of the battery is sufficient to perform the required action, the explanation(s) are entered into EDISON/SAFE as resolutions and the analysis rerun.
| |
| Remaining instances where performance goals are not met once EDISON/SAFE is rerun are considered "Variances from Deterministic Requirements" (VFDRs).
| |
| During the NFPA 805 transition process, instances of logic failure were handled using Fire Risk Evaluations (FREs).
| |
| During the FRE process, the logic failure is reviewed using risk-informed, performance-based methodologies with the possible results including:
| |
| -No impact, risk insignificant;
| |
| -Procedure change, preemptive action;
| |
| -Physical plant modification; and
| |
| -Recovery action (RA).
| |
| The results of the Fire Risk Evaluation are reflected in EDISON/SAFE as resolutions. This process is repeated until all the performance goals in EDISON/SAFE are shown to be successful.
| |
| Fire Area compliance strategies for each fire area are contained within Appendix F of Calculation NEDC 11-019. The compliance strategies include resolutions, recovery actions and credited system success paths for each fire area.
| |
| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Sections 9.0, 12.1.2 and Appendix F)
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| Page B-107
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.4.2.4 Develop a Compliance The available deterministic methods for mitigating the effects of circuit failures are summarized as follows (see Figure 1-Strategy or Disposition to 2):
| |
| Mitigate the Effects Due to Fire Damage to Each - Provide a qualified 3-fire rated barrier.
| |
| Required Component or - Provide a 1-hour fire rated barrier with automatic suppression and detection.
| |
| Cable - Provide separation of 20 feet or greater with automatic suppression and detection and demonstrate that there are no intervening combustibles within the 20 foot separation distance.
| |
| - Reroute or relocate the circuit/equipment, or perform other modifications to resolve vulnerability.
| |
| - Provide a procedural action in accordance with regulatory requirements.
| |
| - Perform a cold shutdown repair in accordance with regulatory requirements.
| |
| - Identify other equipment not affected by the fire capable of performing the same safe shutdown function.
| |
| - Develop exemptions, deviations, Generic Letter 86-10 evaluation or fire protection design change evaluations with a licensing change process.
| |
| Additional options are available for non-inerted containments as described in 10 CFR 50 Appendix R section IIl.G.2.d, e and f.
| |
| [Refer to hardcopy of NEI 00-01 for Figure]
| |
| ADDlicability Comments Applicable None Alignment Statement Aligns Aliqnment Basis The NSCA methodology is contained within Section 1.3 of Calculation NEDC 11-019. The NFPA 805 analysis is completed using a deterministic or performance based approach in each fire area at CNS. Circuit failures are analyzed to determine if any mitigating factors can resolve the identified cable failures. Failures that cannot be resolved without the use of a recovery action (i.e. separation issues) are evaluated as a VFDR. VFDRs are analyzed within the PRA analysis to determine acceptability. If not acceptable, alternate means of compliance are pursued.
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| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 1.3)
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| Page B-108
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Rer)ort - Attachment B Attachment B - NEI 04-02 TABLE B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref NEI 00-01 Section 3 Guidance 3.4.2.5 Document the Assign compliance strategy statements or codes to components or cables to identify the justification or mitigating actions Compliance Strategy or proposed for achieving safe shutdown. The justification should address the cumulative effect of the actions relied upon by Disposition Determined the licensee to mitigate a fire in the area. Provide each piece of safe shutdown equipment, equipment not in the path to Mitigate the Effects whose spurious operation or mal-operation could affect safe shutdown, and/or cable for the required safe shutdown path Due to Fire Damage to with a specific compliance strategy or disposition. Refer to Attachment 6 for an example of a Fire Area Assessment Each Required Report documenting each cable disposition.
| |
| Component or Cable
| |
| [Refer to hardcopy of NEI 00-01 for Attachment]
| |
| ApDlicability Comments Applicable None Aliqnment Statement Aligns Alignment Basis Per Calculation NEDC 11-019, Section 12.0, the analysis is performed to determine the ability to achieve a safe and stable condition given a fire in any area of the plant. The EDISON/SAFE module provides the capability to perform an automated analysis utilizing a model composed of plant systems, equipment, cables, and their physical locations. The analysis uses a Boolean logic evaluation method that supports success path relationships enabling analysis and graphic display capability of each fire zone/fire area. Consequently, EDISON/SAFE contains the complete CNS NSCA analysis including the equipment, cable, fire zone/area, logic, analysis results and strategy information necessary to support NFPA 805 compliance.
| |
| The compliance strategy to achieve a safe and stable condition for each fire area is contained within Appendix F of Calculation NEDC 11-019.
| |
| Reference Documents Calculation NEDC 11-019, "Nuclear Safety Capability Assessment," Revision 0 - (Section 12.0 and Appendix F)
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| Page B-109
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C ATTACHMENT C NEI 04-02 Table B Fire Area Transition 236 Pages Page C-1
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C The nuclear safety goal of NFPA 805 is to provide reasonable assurance that a fire during any operational mode and plant configuration will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition. A safe and stable condition is defined as the ability to maintain Keff <0.99, with a reactor coolant temperature at or below the requirements for hot shutdown. The B-3 table documents this for 'at-power' modes of operation.
| |
| To meet this nuclear safety goal, fire protection features shall be capable of providing reasonable assurance that, in the event of a fire, the plant is not placed in an unrecoverable condition and the licensee must demonstrate the ability to maintain one success path of required equipment effectively free of fire damage. This was accomplished at CNS by developing and analyzing a comprehensive list of systems and equipment to identify those critical components required to achieve and maintain the fuel in a safe and stable hot shutdown state following a fire from at power conditions. Key assumptions associated with the Table B-3 selected equipment and systems are detailed within CNS Calculation NEDC 11-019.
| |
| In general, the fire area analyses consider control of the unit from the Control Room or from the Alternate Shutdown (ASD) Room (i.e., Primary Control Station).
| |
| The strategies documented in Table B-3 are the assured strategy for each fire area. The location and severity of the fire dictates whether the bounding (i.e., worst case full area involved in the fire) compliance strategy will be implemented for a fire.
| |
| Evaluation of Nuclear Safety Performance Criteria NFPA 805 Section 1.5.1 states, "Fire protection features shall be capable of providing reasonable assurance that, in the event of a fire, the plant is not placed in an unrecoverable condition. To demonstrate this, the following performance criteria shall be met." The sections below provide a description of how the performance criteria are assured at CNS.
| |
| Reactivity Control NFPA 805 Section 1.5.1 (a) states for the Reactivity Control performance criteria:
| |
| Reactivity control shall be capable of inserting negative reactivity to achieve and maintain subcritical conditions. Negative reactivity inserting shall occur rapidly enough such that fuel design limits are not exceeded.
| |
| Reactivity control will be accomplished by insertion of the control rods and will result from an automatic RPS trip or from operator initiation of a manual trip. This action will de-energize the RPS to actuate a reactor scram. For boiling water reactors (BWRs), adequate shutdown margin is assured without the need for borated charging water and source range monitoring is not required.
| |
| Inventory and Pressure Control NFPA 805 Section 1.5.1(b) states for the Inventory and Pressure Control performance criteria:
| |
| With fuel in the reactor vessel, head on and tensioned, inventory and pressure control shall be capable of controlling coolant level such that subcooling is maintained for a PWR and shall be capable of maintaining or rapidly restoring reactor water level above top of active fuel for a BWR such that fuel clad damage as a result of a fire is prevented.
| |
| Reactor coolant make-up can be achieved by isolation of the Reactor Coolant System and control of vessel coolant level by injecting water into the isolated Reactor Pressure Vessel (RPV). Systems for which the primary purpose is to inject water into the RPV are grouped under this Performance Goal, even if they also assist in removing decay heat.
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| Page C-2
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| | |
| KinKrneln D kli^ D^
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| ,.~., . VV
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| 0u 1 LIMU ýJv~
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| A+'k+r 0%~a.,I mu11w"L,*
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| Maintaining the RCS pressure boundary integrity is necessary to achieve inventory and pressure control. Coolant loss is limited by modeling the ability to isolate the following pressure boundaries:
| |
| * Control Rod Drive (CRD) vents
| |
| * High Pressure Coolant Injection (HPCI) System
| |
| " Main Steam to the Main Turbine and other paths
| |
| " Safety Relief Valves (SRVs - spurious concern)
| |
| " Steam Supply to Reactor Core Isolation Cooling (RCIC) Turbine
| |
| * Residual Heat Removal (RHR) System
| |
| * Reactor Water Cleanup (RWCU) System Initially, reactor makeup is provided by operation of the Core Spray (CS) system, the HPCI system or the RCIC system. The Operator or the Automatic Depressurization System (ADS) is utilized to reduce plant pressure for use of the low pressure CS System. The HPCI and RCIC systems consist of a steam driven centrifugal pump capable of injecting high pressure water into the RPV. This also aids in removing decay heat.
| |
| Overpressure protection is provided by the SRVs in the self-activated spring lift mode. This mode of operation is not susceptible to fire damage.
| |
| Instrumentation required for Reactor Inventory and Pressure Control (Reactor Coolant Level and Pressure) is modeled in the Process Monitoring Performance Goal.
| |
| When shutting down from outside the Control Room, Inventory and Pressure control is accomplished by maintaining the RCS pressure boundary integrity and by operating HPCI from the Alternate Shutdown (ASD) Room.
| |
| Decay Heat Removal NFPA 805 Section 1.5.1(c) states for the Decay Heat Removal performance criteria:
| |
| Decay heat removal shall be capable of removing sufficient heat from the reactor core or spent fuel such that fuel is maintainedin a safe and stable condition.
| |
| Decay Heat is removed initially by natural circulation within the RPV and automatic (mechanical) operation of the SRVs. The SRVs discharge steam from the RPV to the Suppression Pool. The emerging steam is condensed in this pool, and the heat absorbed by the Suppression Pool is removed by the RHR system operating in the Suppression Pool Cooling (SPC) mode and ultimately transferred to the river via the Service Water (SW) system. The required system logics for SPC include satisfying net positive suction head requirements.
| |
| When HPCI or RCIC is used for makeup, steam is also vented to the suppression chamber via the operating turbine. These systems are modeled under the Inventory and Pressure Performance Goal since their primary purpose is makeup, and they are not included in this Performance Goal.
| |
| Instrumentation required for decay heat removal (suppression chamber level and temperature) are modeled in the Process Monitoring Performance Goal.
| |
| When steam pressure is reduced such that HPCI and/or RCIC turbine operation cannot be sustained, the SRVs are manually opened to further reduce RPV pressure such that the CS system can be used to provide core cooling and maintain RPV inventory.
| |
| When shutting down from outside the Control Room, decay heat removal is accomplished by operating the RHR system in Low Pressure Coolant Injection (LPCI) mode from the ASD Room.
| |
| Three SRVs are available to be operated from the ASD Room to depressurize the RPV.
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| Page C-3
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| | |
| Mahroclen P"Hin Pe%%Ai=r r)ic+rit-+ ('K14Z KIPDA Qnz; Trnnoifinn Pý ^r+- A++ý^ký + I' ki a hr~~L'~ PiihIir PIflAIar ~*OL*
| |
| flia+r14 ItIL S.fl ~'.J NI~DA C'M~ I fl ~1V flJJ Tr,,ncitirn I IOU IOILISJI I I~nr~r+
| |
| ,~U~Ji t - A44a,'Hm~n+
| |
| fl110t1 C' III I~I IL '..J Fuel pool cooling is required in order to prevent boiling and the resulting loss of inventory, which can cause damage to the stored fuel cells when they are uncovered. However, per CNS Updated Safety Analysis Report Section X-3, Spent Fuel Storage:
| |
| Since the spent fuel pool temperature will initially be less than 150°/F, the decay heat will take at least 4 hours to heat the spent fuel pool water to 212°F. Four hours is sufficient time to establish adequate makeup to the spent fuel pool prior to the onset of bulk boiling. Also, under bulk boiling conditions, the temperature of the fuel will not exceed 350 0F. This is an acceptable temperature from the standpoint of fuel rod integrity and surface corrosion.
| |
| Plant procedures require logging the temperature every four hours in the event that cooling is lost. A number of options are available for replenishing the water to prevent uncovering the fuel, including the use of fire hoses or cross-ties to the RHR system. It is, therefore, unnecessary to model the Fuel Pool Cooling system.
| |
| Vital Auxiliaries NFPA 805 Section 1.5.1(d) states for the Vital Auxiliaries performance criteria:
| |
| Vital auxiliaries shall be capable of providing the necessary auxiliary support equipment and systems to assure that the systems required under (a), (b), (c), and (e) are capable of performing their required nuclearsafety function.
| |
| Various plant systems are required to support the systems and components selected to accomplish the previously defined safety functions. Not all of these plant systems are modeled as system logics but are instead modeled in component logics for the supported component.
| |
| The following are modeled as Systems in the SUPPORT Performance Goal:
| |
| * Reactor Equipment Cooling (REC): This system supplies cooling to critical heat exchangers and coolers. If both pumps are inoperable, emergency operation is possible by cross-connecting to the SW system. This allows modeling Train A and Train B of both the normal and the emergency lineup as four different systems and at least one of the four are required to survive.
| |
| * Service Water: This system cools the diesel generator coolers and the REC and RHR Heat Exchangers. SAFE models Train A and Train B as two systems, and requires the same-train SW to cool the REC and RHR systems. Both Diesel Generator coolers can be supplied from either SW Train A or Train B. Components of the SW system that are specific to individual cooling loads are modeled as support components for the cooled system.
| |
| Other critical support functions are modeled in as component logics:
| |
| * HVAC Systems. HVAC cooling is required and modeled for the Battery Rooms, Diesel Generators, Critical Switchgear Rooms, Core Spray Pump Rooms (including the RCIC turbine) and the HPCI Room using component logics. Plant evaluations have confirmed that other areas of the plant do not require HVAC cooling in order to protect credited equipment from overheating or to ensure habitability.
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| * Diesel Generator Support Auxiliaries. Provides direct support in component logics for the corresponding Diesel Generator. This includes cooling water valves, ventilation, starting air, fuel oil transfer pumps and jacket water pumps.
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| * Electrical Supply. Each bus, breaker, motor control center, panel, etc., is modeled in direct support of the specific load.
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| Page C4
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| KJohm-den P"hfir Pnwar niefrin+ rm-q mppA Anr, Trinneifi^n Pga rrf - A+fn,-hr-ngmnf ('
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| When shutting down from outside the Control Room, REC Pumps C and D can be operated from the ASD Room to provide cooling, or isolated to allow for the REC emergency mode.
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| Process Monitoring NFPA 805 Section 1.5.1(e) states for the Process Monitoring performance criteria:
| |
| Process monitoring shall be capable of providing the necessary indication to assure the criteriaaddressed in (a) through (d) have been achieved and are being maintained.
| |
| NEI 00-01 contains guidance in Section 3.1.2.5 for choosing appropriate instrumentation for process monitoring. The following instruments are modeled in the Reactor Vessel Instrumentation (RVI) system, based on existing operating procedures:
| |
| " Reactor coolant level and pressure
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| " Suppression chamber temperature and level The indicating ranges of these instruments cover the normal operating bands and will operate throughout the scenario. Other tank levels and diagnostic instrumentation such as flow or system pressures are modeled directly in the logics for the system or component that requires the indication and are not included in this performance goal.
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| In addition to instruments required for indication, the analysis includes instruments which provide permissive or controlling signals to safe shutdown components or which can cause spurious operation. These instruments are modeled in direct support of the affected component using component logics, cable logics, or a combination of both.
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| When shutting down from outside the Control Room, the following instruments are available in the ASD Room:
| |
| " Reactor coolant level
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| " Reactor Pressure (at HPCI Turbine Steam Inlet)
| |
| * Suppression chamber temperature and level
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| * Emergency Condensate Storage Tank level
| |
| * Diagnostic instrumentation for alternate shutdown systems
| |
| * Level indication for tanks needed for alternate shutdown Page C-5
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire AreaDecito CB-A Control Building Basement, Control Building 903 Corridor and RPS Room 1A Fire Zone Description 7A RHR Service Water Booster Pump and Service Air Compressor Areas 7B Emergency Condensate Storage Tank Area 8C RPS Room 1A 8D Seal Water Pump Area and Corridor Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomolishment Comments / VFDR Decay Heat Removal SPC Train B will be operated to maintain Suppression Pool temperature. CBA-02 CBA-05 Process Monitoring The following indications will be used to support the Process Monitoring function: None
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| - RPV water level and pressure [from Control Room]
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| - Suppression Pool level and temperature [from Control Room]
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| - CS, RHR, and SW flow indication [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, CBA-02 other discharge paths inboard of the MSIVs, and other system pressure CBA-05 boundaries. RPV over-pressure protection will be provided by SRVs. Only the self-activated spring lift mode is credited for over-pressure protection. ADS will be used to reduce RPV pressure for operation of Core Spray Train B to maintain RPV level.
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| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
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| Page C-6
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area DnI2u CB-A Control Building Basement, Control Building 903 Corridor and RPS Room 1A Vital Auxiliaries Mechanical: CBA-01
| |
| -REC will be supplied by SW Train B to provide the cooling supply to the ECCS. CBA-03
| |
| -SW Train B will be operated to provide the cooling supply to the REC system CBA-04 and RHR Heat Exchangers. CBA-06 Electrical (AC/DC):
| |
| - Offsite Emergency Transformer aligned to 4160V Bus 1G
| |
| - 125/250 VDC Train B is available HVAC:
| |
| - CS Train B - Quad area cooling
| |
| - AC Switchgear Room 1G - Essential Control Building HVAC system
| |
| - DC Switchgear Room 1 B - Essential Control Building HVAC system
| |
| - Battery Rooms 1B - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Room 1 B - Essential Control Building HVAC system Reference Document / Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensina Actions None Page C-7
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area DescriLoton CB-A Control Building Basement, Control Building 903 Corridor and RPS Room 1A Existina Enaineerina Eauivalency Evaluations (EEEE)
| |
| EEEETitle EE 09-032 - Evaluation of DC SWGR Rooms 1A and 1B and Battery Rooms 1A and 1B Fire Barrier Separation Purpose This evaluation was written to justify fire dampers provided in supply ventilation ductwork routed through the barrier between each Switchgear Room and the adjacent Seal Water Pump Area and Corridor that have not been installed in the plane of the barrier, as required by the manufacturers installation guidelines. Also, the dampers at the wall boundary where the ventilation ductwork penetrates the barriers from Battery Rooms 1A and 1B to the Seal Water Pump Area and Corridor have been blocked open to ensure exhaust system operability. In addition, the fire doors in these barriers have NFPA 80 code deviations.
| |
| Conclusion Based on the lack of significant combustible loading and fire hazards in the areas, the presence of 3-hour rated dampers that will provide significant fire separation regardless of the mounting position, and installed fire protection features including detection system coverage and manual suppression capabilities, the fire damper configurations are adequate for the fire hazards of the adjacent areas. The fire door code deviations include excessive door-to-door gap clearances and modifications made to ensure proper door operation.
| |
| Considering the lack of significant combustible loading and fire hazards in the area and administrative procedures controlling door operation, these deviations do not represent a significant decrease in fire safety.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| e The combustible loading classification for Switchgear Rooms 1A and 1B are "LOW" and is mainly attributed to miscellaneous plastics and transient loading allowances. There are few fixed combustibles in any of the zones and the equivalent fire severities are minimal. The combustible loading classification in the Corridor is also "LOW" and consists of miscellaneous cable, hose and plastic, and transient allowances.
| |
| * The lack of significant combustible materials in the zones and the lack of intervening combustibles significantly reduce the chance of fire propagation between zones. Transient combustibles are controlled by plant procedures, effectively reducing the possibility of a fire involving transient materials.
| |
| * Each fire zone is provided with detection system coverage. In the event of a fire in the Switchgear Rooms or Corridor, detection system actuation will result in rapid fire brigade response and subsequent manual extinguishment utilizing hose stations and portable extinguishers strategically located in adjacent fire zones.
| |
| e Based on the material and installation of the ventilation ducts, they are considered to prevent fire propagation for up to 1 hour.
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| Page C-8
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area echto CB-A Control Building Basement, Control Building 903 Corridor and RPS Room 1A EEEE Title EE 09-035 - Evaluation of Fire Doors Purpose Fire door assemblies provided in fire-rated barriers may vary slightly from listed configurations, and may or may not provide the same fire rating as that required of the fire barrier. The evaluation documents the adequacy of the configurations that have been provided for fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and R115, and justifies the continued use of the configurations, as they have been determined to provide a level of protection that is adequate for the fire hazards in the areas.
| |
| " Door D202 separates the Cable Expansion Room (Fire Area CB-D) from Stair A-9 (Fire Area TB-A)
| |
| " Door H105 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Turbine Building Floor North (Fire Area TB-A)
| |
| * Doors H200 and H201 separate the Cable Spreading Room (Fire Area CB-D) from Stair A-10 (Fire Area CB-A) e Door H202 separates the Cable Spreading Room (Fire Area CB-D) from the Office Building Controlled Corridor (Fire Area TB-A) e Door H306 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Computer Room (Fire Area CB-D)
| |
| " Door H307 separates the Computer Room (Fire Area CB-D) from the I and C Shop (Fire Area TB-A)
| |
| " Door N103 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Turbine Building Mezzanine North (Fire Area TB-A)
| |
| * Door N104 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Diesel Generator Room 1B (Fire Area DG-B)
| |
| * Door R6 separates the Reactor Building Southeast Quad (Fire Area RB-CF) from the Suppression Pool Area (Fire Area RB-E) o Door R7 separates the Reactor Building Northwest Quad (Fire Area RB-B) from the Suppression Pool Area (Fire Area RB-E) o Doors R101 and R102 separate the Reactor Building 903' Northeast Corner (Fire Area RB-FN) from the Office Building Controlled Corridor (Fire Area TB-A) o Door R1 15 separates Reactor Building 903'-6" CRD Units - South (Fire Area RB-DI) from the Exterior Transformer Yard (Fire Area YD)
| |
| Conclusion The fire door configurations (i.e., fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and R115) have been determined to provide a level of protection commensurate with the fire hazards of the areas, and adequate separation has been provided. In general, minor variations to the configurations, such as conduit penetrations through the door frames, slightly larger gaps between doors and Page C-9
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Dsdto CB-A Control Building Basement, Control Building 903 Corridor and RPS Room 1A frames, and doors rated for less than that required of the barrier, have been evaluated as acceptable based on the fire hazards on either side of the barrier.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| * Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
| |
| * Fire hoses and portable extinguishers are strategically located throughout the plant for use by the responding fire brigade.
| |
| " Ventilation systems can typically be used for smoke and heat removal.
| |
| " Due to control of transient combustibles and ignition sources, door proximity to permanent combustibles, and fire area combustible loading, the majority of these doors will not be challenged by a credible fire. This effectively reduces the risk of the identified deviations.
| |
| o The automatic sprinkler system and smoke detection provided in the Cable Expansion Room (Fire Area CB-D) are credited for the acceptability of door D202.
| |
| e The automatic smoke detection systems provided in the Seal Water Pump Area and Corridor (Fire Area CB-A) and in the Turbine Building Floor North (Fire Area TB-A) are credited for the acceptability of door H105.
| |
| e The pre-action sprinkler system and automatic smoke detection provided in the Cable Spreading Room (Fire Area CB-D) are credited for the acceptability of doors H200 and H201.
| |
| 9 The automatic total flooding Halon 1301 suppression system and automatic smoke detection provided in the Computer Room (Fire Area CB-D) are credited for the acceptability of doors H306 and H307.
| |
| * The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1A (Fire Area DG-A) and the heat detection installed are credited for the acceptability of doors N103 and N104.
| |
| * The smoke and heat actuated devices provided in the Turbine Building Mezzanine (Fire Area TB-A) are credited for the acceptability of doors N103.
| |
| * The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1B (Fire Area DG-B) and the heat detection installed are credited for the acceptability of door N104.
| |
| e The automatic heat detection provided in the Reactor Building Northwest Quad (Fire Area RB-CF) is credited for the acceptability of door R6.
| |
| e The automatic heat detection provided in the Reactor Building Southeast Quad (Fire Area RB-B) is credited for the acceptability of door R7.
| |
| 9 The automatic suppression system provided in the Office Building Corridor (Fire Area TB-A) is credited for the acceptability of doors R101 and R102.
| |
| * The automatic sprinkler system and smoke detection provided in the Reactor Building 903' Northeast Page C-10
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area CB-A Control Building Basement, Control Building 903 Corridor and RPS Room 1A Corner (Fire Area RB-FN) is credited for the acceptability of doors R101 and R102.
| |
| * The automatic deluge suppression system actuated by heat actuated devices provided for the yard transformers (Fire Area YD) are credited for the acceptability of door R1 15.
| |
| e Actuation of the detection systems will prompt rapid fire brigade response and subsequent manual extinguishment.
| |
| Page C-11
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Nebraska Public Power District ONS NFPA 805 Transition Report Attachment C Table B-3 Fire Area Transition Fire Area CB-A Control Building Basement, Control Building 903 Corridor and RPS Room 1A EEEE Title EE 09-040 - Evaluation of Auxiliary Relay Room and RPS Room 1 B Appendix R Fire Barriers Purpose This evaluation justifies the adequacy of ventilation duct penetrations, without fire-rated dampers, routed through the barriers that separate the Auxiliary Relay Room, RPS Room 1B, and RPS Room 1A on the 903'-
| |
| 6" Elevation of the Control Building. Additionally, a fire rating cannot be assigned to the barriers due to miscellaneous door discrepancies concerning doors H102, H103, and H104.
| |
| e Door H102 separates RPS Room 1B (Fire Area CB-C) from the Seal Water Pump Area and Corridor (Fire Area CB-A)
| |
| * Doors H103 and H104 separate the Auxiliary Relay Room (Fire Area CB-D) from the Seal Water Pump Area and Corridor (Fire Area CB-A)
| |
| Conclusion Based on the installed fire protection features, including detection system coverage and manual fire suppression capabilities, and the lack of significant fire hazards, and the types of combustible materials, the ventilation ductwork is sufficient to provide protection from spread of fire prior to fire brigade response and subsequent manual extinguishment, if necessary. Discrepancies concerning doors H102, H103, and H104 are relatively minor, and include door clearances, and minor modification for proper operation. These discrepancies are therefore not considered to affect fire safety. The separation that has been provided is considered to be adequate for the fire hazards of the areas.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| 9 There are typically few fixed combustibles in any of the zones, and the equivalent fire severities are minimal. The exception is the Auxiliary Relay Room, which contains a significant amount of cable insulation in open cable trays routed at the ceiling elevation. The content of the RPS Room consists mainly of batteries.
| |
| The combustibles in the Corridor mainly consist of miscellaneous cable, hose and plastic, and transient allowances. Cables in the Corridor are routed in conduit, and potential ignition sources in the zones are limited to energized electrical equipment, typically in cabinets, and potential transient sources.
| |
| e A cable tray fire in the Auxiliary Relay Room would be characterized as a slow propagating fire that has the potential to produce significant amounts of smoke. Based on the installed detection system coverage, fire brigade response and manual extinguishment would occur prior to the fire being able to breach the barrier via the ductwork.
| |
| * The lack of significant combustible materials in the remaining zones and the lack of intervening combustibles significantly reduce the chance of fire propagation between zones.
| |
| e Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of a fire.
| |
| Page C-12
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Descrin~tion CB-A Control Building Basement, Control Building 903 Corridor and RPS Room 1A
| |
| * The supply registers in the Auxiliary Relay Room are provided with 3-hour rated fire dampers (HV-AD-AD1434 and HV-AD-AD1435). A 3-hour fire-rated damper has been provided in the Auxiliary Relay Room at the exhaust register (HV-AD-AD1436).
| |
| 9 Sheet metal ductwork is recognized by the NFPA to provide up to 1-hour fire separation when properly hung, and the fire is stopped.
| |
| * Each fire zone is provided with detection system coverage. In the event of a fire in the RPS Room, Auxiliary Relay Room, or Corridor, detection system actuation will result in rapid fire brigade response and subsequent manual extinguishment utilizing hose stations and portable extinguishers strategically located in adjacent fire zones.
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| EEEE Title EE 09-042 - Evaluation of 1-Hour Marinite Wall in Battery Room lB Purpose This evaluation is written to address the fire protection adequacy of the 1-hour fire-rated wall enclosure located in Battery Room 1B.
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| Conclusion Based on a review of the potential fire hazards located in Battery Room 1 B, with the 1-hour fire-rated wall enclosure and the existing fire detection system, the existing barrier provided is adequate to prevent the fire spreading from Battery Room 1B to the 1-hour fire-rated enclosure.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| a The combustible loading classification for Battery Room 1B is "LOW" and is mainly attributed to plastics and transient loading allowances. Battery Room 1B has an equivalent fire severity of 30 minutes. The combustible loading consists of cables routed in conduit riser. The lack of significant combustible materials in the zones and the lack of intervening combustibles significantly reduce the chance of fire propagation between zones.
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| 9 Based on the low combustible loading in Battery Room 1B, a fire will not be able to develop to such intensity as to challenge the as-installed configuration.
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| 9 Battery Room 1 B is provided with smoke detection system coverage. Detection system actuation will prompt rapid fire brigade response and manual extinguishment via portable extinguishers and manual hose stations strategically located in adjacent zones. Pre-fire plans are available for Battery Room 1B.
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| e Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of a fire.
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| e Safe shutdown can be accomplished independent of Battery Room 1B.
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| Page C-13
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area De.cr.otLo CB-A Control Building Basement, Control Building 903 Corridor and RPS Room 1A EEEE Title LBDCR 2004-023 - Evaluation of a FHA Revision to Relocate the Fire Barrier Between Fire Area IV/Fire Zone 8D and Fire Area VII/Fire Zone 24 Purpose The purpose of this evaluation is to demonstrate the relocated fire barrier between Fire Area IV/Fire Zone 8D and Fire Area VIII/Fire Zone 24 is adequate. The section of the barrier that is being changed is the wall area adjacent to, and including, door H 100. The barrier is being moved to the vestibule walls and ceiling on the north side of H100. Door H100 will no longer be considered part of the fire barrier. Door H114 on the east side of the vestibule will be evaluated to show it is adequate for the fire hazards that are present. Door H1 14 is located on the east side of the vestibule. The door is a single leaf unrated metal door. The door has been barricaded with a 1/2 in. thick carbon steel plate plug welded to the frame of the door. The west side of door H1 14 has been barricaded with concrete blocks stacked approximately 6 ft high and 3 ft deep.
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| Conclusion The walls and ceiling of the vestibule can be credited as a 3-hour fire rating. Based on the fire hazard analysis, fire door H1 14 is adequate for the hazards associated with the area.
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| Basis The bases that justify this conclusion are summarized as follows:
| |
| o The automatic smoke detection system that alarms in the Control Room will result in prompt fire brigade response and manual fire brigade extinguishment. Based on low combustible loading and detection in the area, the fire zone boundaries are adequate to prevent fire spread to adjacent fire areas and fire zones. Pre-fire plans are available for fire brigade use in responding to fire events in the fires zones.
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| o An automatic wet pipe sprinkler system has been provided in the Swing Charger Room adjacent to the west wall of Fire Zone 8C.
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| o Given a fire in this zone, safe shutdown can be accomplished as verified by the Appendix R Safe Shutdown Analysis Report.
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| * Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
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| * The construction features associated with door H1 14 and the vestibule are similar to door R1 15. Door R1 15 was evaluated under EE 09-035.
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| e Based on the construction of the barrier and door H1 14 with welded steel plate and the fire severity present in Fire Area VIII/Fire Zone 24 side of the barrier, the Fire Area VIII/Fire Zone 24 fire would not be expected to breach the barrier. Also, a fire starting in Fire Area VIII/Fire Zone 24 would be mitigated by the automatic suppression system so that it would not provide a significant challenge to barrier. A fire starting in Fire Area IV/Fire Zone 8D would not be expected to spread to Fire Area VIII/Fire Zone 24 due to lack of combustibles in the area, lack of combustibles inside the vestibule, and the construction features of door H1 14.
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| * The walls and ceiling of the vestibule can be credited as a 3-hour fire rating. Based on the fire hazard analysis, fire door H1 14 is adequate for the hazards associated with the area.
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| Page C-14
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare AreaDecito CB-A Control Building Basement, Control Building 903 Corridor and RPS Room 1A JTile EE 97-121 - Appendix R Fire Protection Evaluation of Control Building 882' Underground Cable Manholes Purpose This analysis is written to address the adequacy of cable manhole barriers located on the basement level of the Control Building, 882'-6" Elevation (Fire Area IV/Fire Zone 7A). Non-rated fire barriers separate the Control Building Basement Area from the individual cable manholes located below the basement, which function as a connection point for cables routed in underground ducts from the Intake Structure or the Diesel Generator Building to the Control Building. Due to the presence of safe shutdown cables in the manholes, the adequacy of the manhole barriers must be assessed to ensure that fire spread is precluded to the Control Building Basement at the 882' Elevation and to the opposite division manholes.
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| Conclusion Based on a review of the potential fire hazards located in the Control Building Basement and in the manholes, adequate fire protection is provided to prevent fire spread to and from the manholes located below the Control Building Basement.-
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| Basis The bases that justify this conclusion are summarized as follows:
| |
| e Each manhole contains a limited amount of fire resistant cable insulation and no ignition sources. As a result, fire potential in the manhole is limited, a significant fire could not be sustained, and due to the lack of intervening combustibles and the metal plates, propagation to either the Control Building Basement Area or to the redundant division manholes is not possible.
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| * A review of the Control Building Basement Area also indicates limited potential for fire spread into the manholes. Combustible loading in the basement area is low and consists mainly of lube oil associated with the RHR Service Water (RHRSW) Booster Pumps and Station Air Compressors.
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| * A 4" steel I-beam floor dike is also provided on the floor in the basement area to separate the main basement floor area from the floor area of the manholes. This floor dike will prevent combustible liquid spills from impacting the manholes.
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| " Smoke detection, portable extinguishers, and a manual fire hose are provided in the area.
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| " Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
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| e Each manhole is approximately 8' apart on center. A substantial metal plate (approximately 1/4" thick and approximately 3' x 3') covers the access opening to each manhole. Cables routed through the manhole do not penetrate or cross over to the redundant division manholes. Cables exiting manholes are typically routed in 4" steel conduits and the conduits are routed in the soil fill below the basement slab.
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| Page C-15
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area CB-A Control Building Basement, Control Building 903 Corridor and RPS Room 1A Variances from Deterministic Reauirements (VFDRI CBA-01 Description Establish vital auxiliaries by powering the credited 4160G Bus from Emergency Transformer (EE-CB-4160G-IGE).
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| The Nuclear Safety Performance Criteria (NSPC) require at least one train of electrical power available post-fire. There is cable fire damage to the DG Fuel Oil (DGDO) Pumps, EE-CB-4160DG2-EG2 (DG48, DG53, DG54, DG57, H574), EE-CB-4160F-1FS, EE-CB-4160G-1GE (H572, H573), EE-CB-4160G-1GS (H555), EE-SWGR-4160DG2 and Isolate-DG2 (A54, DG45, DG48, DG50, DG51, DG63, DG87, DG88, DG89, H470, H485, H573, H574). The 4160F-1FS, even with the potential cable damage, will trip to protect the Emergency Transformer from potential faults on the 4160F Bus and allow the Emergency Transformer to be used in this area. Cable damage to the EE-CB-4160DG2-EG2, EESWGR- 4160DG2, and Isolate-DG2 would allow for the DG to place itself on the 4160G Bus, potentially out-of-phase with offsite power that may be present on the bus. Based on cable damage, even in "isolate" the failure mode is possible to place the DG on the bus until control power fuses are pulled in the DG2 area and the breaker controlled locally (specifically DG53 and DG57 with an external hot short).
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| During the normal transfer sequence when 4160B is removed from the 4160G Bus (EE-CB-4160G-1GB and/or EE-CB-4160B-1BG open), DG2 would start automatically and the EE-CB-4160G-1GS would close.
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| Once DG2 is up to speed, it checks the status of the 4160G Bus and closes its output breaker if power is still required to the bus. The operator can open EE-CB-4160G-1GS and/or EE-CB-4160G-1GE from the Control Room, but based on normal operations for the GS breaker (if there is no power on the bus) and/or cable damage on the GE breaker (H572 and H573), either breaker may re-close on its own once the operator has opened it from the Control Room.
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| Action to open EE-CB-4160G-IGE locally may not be able to be accomplished in time to preclude paralleling the DG out-of-phase onto the credited 4160G Bus. The four cables in question are all affected in fire scenarios: 7A-TS1 1, CPSR-A.FD4, CPSR-B.FD4, CPSR-C.FD4, SW-P-A.FD4, SW-P-B.FD4, SW-P-C.FD4, and SW-P-D.FD4.
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| Fire damage to interlock cables (H572 and H573) between 1GE and EG2/GEN EG2 CONTROL and RELAY PANEL may also cause automatic tripping of the 4160G-1 GE breaker and inability to close it from the Control Room, or allow for auto-closure of breaker. EE-CB-4160G-1GE is normally closed and is desired open to isolate the DG from the 4160G Bus ifthe Emergency Transformer is used. The Page C-16
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area CB-A Control Building Basement, Control Building 903 Corridor and RPS Room 1A Emergency Transformer is available. The ability to open from the Control Room is still available, but based on potential cable damage the 4160-1GE breaker may re-close on its own.
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| This is a separation issue for Vital Auxiliaries.
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| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
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| Risk: Acceptable with Recovery Action.
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| See LAR Attachment G, Table G-1 for Recovery Action details.
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| Modification: None Page C-17
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Des.cription CB-A Control Building Basement, Control Building 903 Corridor and RPS Room 1A CBA-02 Description Preventing a full or partial loss of Service Water for supporting Decay Heat Removal and Inventory and Pressure Control. (EE-CB-4160G-SWPIB, SW-MOV-37MV, and SW-MOV-MO89B).
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| SW Train B is required to support various functions (SPC, HPCI and CS Quad cooling, REC, DGs, etc) for NSPC. CS Train B is credited for Inventory Control, SPC Train B is credited for Decay Heat Removal, REC Train B provides cooling for RHR Pump 1D and the RHR and CS Pump Rooms (Quads), and SW Train B provides the cooling for REC and RHR Heat Exchangers (DGs not credited). The complete loss of Service Water or its diversion could challenge these NSPC.
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| Fire in the area could result in damage to the 4KV Bus 1G UV circuit which would cause a trip signal to the SW Pump 1B breaker. Inability to keep the SW Pump 1 B breaker closed would result in loss of all Service Water.
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| Damage to SW-MOV-37MV cables (MY348 and MY350) could remove the ability to close the valve if already open. This would divert flow to non-critical loads and the non-credited SW loop with only a single Service Water Pump available. This reduction in flow may not allow sufficient cooling to the REC and RHR Heat Exchangers.
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| NOTE: Even though SW-MOV-37MV is a potential NRC Information Notice 92-18 concern, the only location with an affected cable is in Fire Zone 7A, where the cable that causes the concern is protected via the duct bank.
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| Cable damage to both RHRSW Booster Pump breakers would result in the inability to close either breaker, causing SW-MOV-MO89B to fail closed without the ability to open from the Control Room. This would result in the loss of SW flow to the RHR Heat Exchanger for SPC Train B.
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| This is a separation issue for Decay Heat Removal and Inventory and Pressure Control.
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| Page C-18
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Dsrlto CB-A Control Building Basement, Control Building 903 Corridor and RPS Room 1A Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
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| Risk: Acceptable - Recovery Action carried forward as Defense-in-Depth.
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| See LAR Attachment G, Table G-1 for Recovery Action details.
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| Modification: None CBA-03 Description Loss of Critical Switchgear cooling due to cable damage to damper AD-1408 (HV-FAN-SF-SWGR-1G and HV-FAN-EF-SWGR-1G).
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| Fire damage to cables will not preclude operation of the HV-FAN-EF-SWGR-1G and HV-FAN-SFSWGR-1G fans from the 1 G AC Switchgear Room. Cable damage will affect the operation of ventilation damper AD-1408 by energizing its solenoid and keeping the damper open. Damper AD-1407 has its cable routed in dedicated conduit in area CB-A. The NSCA model requires that either train of Switchgear Room cooling fans be available to ensure both AC and DC Switchgear remain available post-fire.
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| This is a separation issue for Vital Auxiliaries, Electrical Power Distribution.
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| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
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| Risk: Acceptable Modification: None Page C-19
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Descriotion CB-A Control Building Basement, Control Building 903 Corridor and RPS Room 1A CBA-04 Description 4160G UV Circuit cable damage affects automatic / remote operation from the Control Room of Critical Pumps for Safe Shutdown (CS Pump 1B and RHR Pump 1 D).
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| Fire in the area could result in damage to the 4KV Bus 1G UV circuit that will cause a trip signal to the CS Pump 1 B, RHR Pump ID, and SW Pump 1B breakers. SW Pump 1B is covered separately under CBA-2 for ensuring SW flow. NSPC requires the ability to maintain level within the core. CS Train B is the credited train for inventory control in this area. RHR Train B is credited to support SPC mode of RHR following a fire in this area. NSPC requires a means of Decay Heat Removal post-fire. SPC Train B is credited for Decay Heat Removal.
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| Inability to keep the Core Spray Pump 1 B breaker closed would result in loss of ability to add makeup water via the CS system.
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| Inability to keep the RHR Pump 1D breaker closed would result in loss of RHR flow to the RHR Heat Exchanger, resulting in the loss of SPC Train B.
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| This is a separation issue for Vital Auxiliaries, Electrical Power Distribution, in support of Inventory and Pressure Control, and Decay Heat Removal.
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| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
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| Risk: Acceptable with Recovery Action.
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| See LAR Attachment G, Table G-1 for Recovery Action details.
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| Modification: None Page C-20
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Nebraska Public Power District CNS NFPA 805 Transition Report Attachment C Table B-3 Fire Area Transition Fire P,rea D[escrition CB-A Control Building Basement, Control Building 903 Corridor and RPS Room 1A CBA-l06 Description Preventing a full or partial loss of Service Water due to clogging of SW-STNR-B.
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| SW Train B is required to support various functions (SPC, HPCI and CS Quad cooling, REC, DGs, etc) for NSPC. CS Train B is credited for Inventory Control and SPC Train B is credited for Decay Heat Removal. REC Train B provides cooling for RHR Pump 1 D and the RHR and CS Pump Rooms (Quads),
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| and SW Train B provides the cooling for REC and RHR Heat Exchangers (DGs not credited). The complete loss of Service Water or its diversion could challenge these NSPC.
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| Cable damage to MTX1 results in a loss of the automatic features of the SW Train B strainer. The loss of the automatic features could result in the clogging of the strainer, resulting is a complete loss of SW flow.
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| This is a separation issue for Inventory and Pressure Control and Decay Heat Removal.
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| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
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| Risk: Acceptable - Recovery Action carried forward as Defense-in-Depth.
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| See LAR Attachment G, Table G-1 for Recovery Action details.
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| Modification: None CBA-06 Description Loss of both A and B Train Battery Chargers due to Cable damage (EE-CHG-1 25-1 B).
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| Fire damage to cable MTX1 0 causes a loss of Main Supply Power to the B Train Battery Charger. The NSPC require at least one train of DC power be available post-fire and both A and B Train Battery Chargers are affected. The B Train batteries are the credited train post-fire.
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| This is a separation issue for Vital Auxiliaries.
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| Page C-21
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area ecifo CB-A Control Building Basement, Control Building 903 Corridor and RPS Room 1A Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
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| Risk: Acceptable with Modification.
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| Modification: Item S-2.3 of LAR Attachment S, Table S-2.
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| Reauired Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
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| Full (F) Suppression?
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| Partial (P) S IL E R D 7A Detection Ionization R N N N Y Y N 7A Feature Fire Barrier N/A N/A N N N Y N 7B Detection Ionization R N N N N N N 8C Detection Ionization R N N N Y Y N 8D Detection Ionization R N N N Y Y N 8D Suppression Automatic Wet-Pipe P N/A N N N Y N Legend:
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| Table Field: "Required System?"
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| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Page C-22
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descriotion CB-A Control Building Basement, Control Building 903 Corridor and RPS Room 1A Fire Suooression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. Per MWR 91-1264, electrical cabinets and conduit have been sealed to mitigate the effects of suppression activities. In the event of normal operation, the wet-pipe system in the Swing Charger Room will not have an adverse effect, as the chargers and the disconnect switch cabinets are spray tight and the conduits are sealed. A pipe rupture from within Fire Zone 7A could spray several of the RHRSW Booster Pumps and may also spray EE-MCC-T. However, the equipment is spray-tight and would not be adversely affected. A pipe rupture of the supply pipe in the corridor of Fire Zone 8D could discharge water through the steel equipment access hatch and down the stairwell to Fire Zone 7A. There is no direct effect due to floor drains, equipment pedestals, and the physical distance to equipment. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
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| Fire Area Comments A 1-hour rated concrete enclosure containing Division II control and motive power feeds is located along the south wall of Fire Zone 7A.
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| Page C-23
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition CB-A-1 Control Building 903, DC Switchgear Room 1A and Battery Room 1A Fire Zone eci!o 8E Battery Room 1A 8H DC Switchgear Room 1IA Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments I VFDR Decay Heat Removal SPC Train B will be operated to maintain Suppression Pool temperature. None Process Monitoring The following indications will be used to support the Process Monitoring function: None
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| - RPV level and pressure [from Control Room]
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| - Suppression Pool level and temperature [from Control Room]
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| - CS, SW, RHR flow indications, and REC pressure indication [from Control Room]
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| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, CBAlP-02 other discharge paths inboard of the MSIVs, and other system pressure boundaries. RPV over-pressure protection will be provided by SRVs. Only the self-activated spring lift mode is credited for over-pressure protection. ADS will be used to reduce RPV pressure for operation of Core Spray Train B to maintain RPV level.
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| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
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| Page C-24
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Nebraska Public Power District CNS NFPA 805 Transition Report Attachment C Table B-3 Fire Area Transition Fore Area CB-A-1 Control Building 903, DC Switchgear Room 1A and Battery Room 1A Vital Auxiliaries Mechanical: CBAl-01
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| -REC Train B will be operated to provide the cooling supply to the ECCS. CBA1-03
| |
| -SW Train B will be operated to provide the cooling supply to the REC system and RHR Train B Heat Exchanger.
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| Electrical (AC/DC):
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| - Offsite Emergency Transformer aligned to 4160V Bus 1G
| |
| - 125/250 VDC Train B is available HVAC:
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| - HPCI/CS Train B - Quad area cooling
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| - AC Switchgear Room 1G - Essential Control Building HVAC system.
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| - DC Switchgear Room 1B
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| - Battery Room 1B
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| - Auxiliary Relay Room and RPS MG Set Room 1B Reference Document / Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensing Actions None Page C-25
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area QeacLo1Lan CB-A-1 Control Building 903, DC Switchgear Room 1A and Battery Room 1A Existinq Enqineering Eguivalency Evaluations IEEEE)
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| EEEETitle EE 09-032 - Evaluation of DC SWGR Rooms 1A and 1 B and Battery Rooms 1A and 1 B Fire Barrier Separation Purpose This evaluation was written to justify fire dampers provided in supply ventilation ductwork routed through the barrier between each Switchgear Room and the adjacent Seal Water Pump Area and Corridor that have not been installed in the plane of the barrier, as required by the manufacturers installation guidelines. Also, the dampers at the wall boundary where the ventilation ductwork penetrates the barriers from Battery Rooms 1A and 1B to the Seal Water Pump Area and Corridor have been blocked open to ensure exhaust system operability. In addition, the fire doors in these barriers have NFPA 80 code deviations.
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| Conclusion Based on the lack of significant combustible loading and fire hazards in the areas, the presence of 3-hour rated dampers that will provide significant fire separation regardless of the mounting position, and installed fire protection features including detection system coverage and manual suppression capabilities, the fire damper configurations are adequate for the fire hazards of the adjacent areas. The fire door code deviations include excessive door-to-door gap clearances and modifications made to ensure proper door operation.
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| Considering the lack of significant combustible loading and fire hazards in the area and administrative procedures controlling door operation, these deviations do not represent a significant decrease in fire safety.
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| Basis The bases that justify this conclusion are summarized as follows:
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| e The combustible loading classification for Switchgear Rooms 1A and 1B are "LOW" and is mainly attributed to miscellaneous plastics and transient loading allowances. There are few fixed combustibles in any of the zones and the equivalent fire severities are minimal. The combustible loading classification in the Corridor is also "LOW" and consists of miscellaneous cable, hose and plastic, and transient allowances.
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| * The lack of significant combustible materials in the zones and the lack of intervening combustibles significantly reduce the chance of fire propagation between zones. Transient combustibles are controlled by plant procedures, effectively reducing the possibility of a fire involving transient materials.
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| e Each fire zone is provided with detection system coverage. In the event of a fire in the Switchgear Rooms or Corridor, detection system actuation will result in rapid fire brigade response and subsequent manual extinguishment utilizing hose stations and portable extinguishers strategically located in adjacent fire zones.
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| e Based on the material and installation of the ventilation ducts, they are considered to prevent fire propagation for up to 1 hour.
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| Page C-26
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Description CB-A-1 Control Building 903, DC Switchgear Room 1A and Battery Room 1A EEEE Title EE 86 Evaluation of a Ventilation Opening Through the Cable Spreading Room Floor Appendix R Fire Barrier Purpose The purpose of this engineering evaluation is to document the acceptability of fire damper HV-AD-AD1556 located in the floor/ceiling boundary where the ventilation ductwork penetrates from Battery Room 1A to the Cable Spreading Room. The damper has been blocked open to ensure exhaust system operability, as accidental closure would render the exhaust system inoperable. In addition, steel pipe has been used as ventilation ductwork in the Cable Spreading Room, which is not typical for ventilation.
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| Conclusion Based on the significant construction of the assembly, the lack of significant fire hazards and combustible loading, and the presence of installed fire protection features including fire detection and fixed fire suppression, the configuration that has been provided is adequate for the fire hazards of the areas.
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| Basis The bases that justify this conclusion are summarized as follows:
| |
| e The duct assembly in the Cable Spreading Room is of significant steel construction. There is reasonable assurance that if a fire in the Cable Spreading Room was to occur, it would not breach the ductwork (i.e., the pipe) based on the significant pipe construction, and be able to propagate down into the Battery Room.
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| e Although the combustible loading classification in the Cable Spreading Room is "HIGH," due to the large quantity of cable insulation in the area, installed fire protection features are provided to mitigate the effects of a fire.
| |
| e The combustible loading classification in the Battery Room is "LOW" and consists mainly of plastic associated with battery cases. The lack of significant fire hazards and combustible loading in Battery Room 1A precludes the possibility of a fire developing to such intensity as to breach the ventilation ductwork in the Battery Room and then breach the significant pipe construction provided in the Cable Spreading Room.
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| e Automatic detection system coverage will alert the fire brigade of fire conditions and automatic suppression system coverage will limit the intensity of a fire in the Cable Spreading Room.
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| e Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
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| Page C-27
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area CB-A-1 Control Building 903, DC Switchgear Room 1A and Battery Room 1A Variances from Deterministic Reauirements (VFDR)
| |
| Description Loss of critical electrical components due to loss of Control Building HVAC/Switchgear Cooling (HV-FAN-SF-SWGR-1G, HV-FAN-EF-SWGR-1G, EE-MCC-TX, EE-PNL-CDP1B, EE-SWGR-125B, and EE-BAT-125B).
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| The NSCA model requires that either train of Switchgear Room cooling fans be available to ensure the Switchgear remains available post-fire. The NSCA model also requires that either train of Battery power be available post-fire.
| |
| Fire damage to cables will not preclude operation of the EF-SWGR-1G and SF-SWGR-1G fans from the 1G AC Switchgear Room. Cable damage will affect the operation of ventilation damper AD-1408 by energizing its solenoid and keeping the damper open. Damper AD-1407 has its cable routed in dedicated conduit in area CB-A.
| |
| Fire-induced failure of cables for Control Building HVAC and/or a fire in the Train A DC Switchgear and/or Battery Room will result in loss of cooling to EE-SWGR-1 25B/EE-BAT-1 25B/EE-PNL-CDP1 B/EE-MCC-TX. This would result in a loss of all DC panels. With temperatures affecting operations, cooling via open compartments is effective to ensure operation of the panels.
| |
| This is a separation issue for Vital Auxiliaries, Electrical Power Distribution.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-28
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Description CB-A-1 Control Building 903, DC Switchgear Room 1A and Battery Room 1A CBA1 -02 Description Preventing a Reactor Recirculation (RR) Pump Seal LOCA due to inability to secure the RR Pumps from the Control Room with the REC Non-Critical Header secured (RR Pump Breaker for 4160C-1CS).
| |
| Breaker F/FDR to the 4160V Bus from the Startup Transformer: This is a normally available, required open breaker that provides motive power to RR Pump A. The RR Pumps are required to trip to prevent a potential seal LOCA when REC is not available to provide cooling. This would challenge the NSPC for Inventory Control. Remote operation of the breaker from the Control Room is lost due to EE-PNL-AA1 cable DC311 being potentially damaged, and therefore a loss of control power to the breaker.
| |
| NOTE: REC Non-Critical Header is secured in this fire area to address potential containment over-pressure.
| |
| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Description Establish vital auxiliaries by ensuring power to the credited 4160G Bus from Emergency Transformer (EE-CB-4160F-1FS).
| |
| The NSPC require at least one train of electrical power available post-fire. Fire damage to control power panels and supply cables on the 4160F Bus would not allow breakers to open automatically if required, and therefore, cause a loss of the credited 4160G Bus. EE-CB-4160F-1FS would normally close during the transfer process to the Emergency Transformer to power the 4160F Bus.
| |
| This is a separation issue for Vital Auxiliaries.
| |
| Page C-29
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descriotion CB-A-1 Control Building 903, DC Switchgear Room 1A and Battery Room 1A Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Reauired Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?
| |
| ,_Partial (P) S L E R D 8E Detection Ionization R N N N Y Y N 8H Detection Ionization R N N N Y Y N Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Fire Suporession Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. There are no fixed suppression systems in the area and the Battery Rooms and DC Switchgear Rooms on the 903'-6" Elevation of the Control Building are not subject to any adverse effects by water intrusion from fire suppression systems. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments None Page C-30
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area 1ecato CB-B Control Building 903, DC Switchgear Room lB and Battery Room 1B Fire Zone Descrition 8F Battery Room 1B 8G DC Switchgear Room 1B Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Perfnrmance Goal Method of Accomnlishment Comments / VFDR Decay Heat Removal SPC Train A will be operated to maintain Suppression Pool temperature. None Process Monitoring The following indications will be used to support the Process Monitoring function: None
| |
| - RPV level and pressure [from Control Room]
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - Flow indications for CS, RHR, and SW [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, CBB-03 other discharge paths inboard of the MSIVs, and other system pressure boundaries. RPV over-pressure protection will be provided by SRVs. Only the self-activated spring lift mode is credited for over-pressure protection. ADS will be used to reduce RPV pressure for operation of Core Spray Train A to maintain RPV level.
| |
| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
| |
| Page C-31
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area ecotn CB-B Control Building 903, DC Switchgear Room 1B and Battery Room 1B Vital Auxiliaries Mechanical: CBB-01
| |
| -REC will be supplied by SW Train A to provide the cooling supply to the ECCS. CBB-02
| |
| -SW Train A will be operated to provide the cooling supply to the REC system and RHR Train A Heat Exchanger.
| |
| Electrical (AC/DC):
| |
| - Offsite Emergency Transformer aligned to 4160V Bus 1 F
| |
| - 125/250 VDC Train A is available HVAC:
| |
| - RCIC/CS Train A - Quad area cooling
| |
| - AC Switchgear Room 1F - Essential Control Building HVAC system
| |
| - DC Switchgear Room 1A - Essential Control Building HVAC system
| |
| - Battery Room 1A - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Room 1A Reference Document / Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensino Actions None Page C-32
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area Deifl*Jt.on CB-B Control Building 903, DC Switchgear Room 1 B and Battery Room 1B Existinq Enaineerina Eauivalency Evaluations (EEEEI EEEE Titl EE 09-032 - Evaluation of DC SWGR Rooms 1A and 1B and Battery Rooms 1A and 1B Fire Barrier Separation Purpose This evaluation was written to justify fire dampers provided in supply ventilation ductwork routed through the barrier between each Switchgear Room and the adjacent Seal Water Pump Area and Corridor that have not been installed in the plane of the barrier, as required by the manufacturers installation guidelines. Also, the dampers at the wall boundary where the ventilation ductwork penetrates the barriers from Battery Rooms 1A and 1B to the Seal Water Pump Area and Corridor have been blocked open to ensure exhaust system operability. In addition, the fire doors in these barriers have NFPA 80 code deviations.
| |
| Conclusion Based on the lack of significant combustible loading and fire hazards in the areas, the presence of 3-hour rated dampers that will provide significant fire separation regardless of the mounting position, and installed fire protection features including detection system coverage and manual suppression capabilities, the fire damper configurations are adequate for the fire hazards of the adjacent areas. The fire door code deviations include excessive door-to-door gap clearances and modifications made to ensure proper door operation.
| |
| Considering the lack of significant combustible loading and fire hazards in the area and administrative procedures controlling door operation, these deviations do not represent a significant decrease in fire safety.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| e The combustible loading classification for Switchgear Rooms 1A and 1 B are "LOW" and is mainly attributed to miscellaneous plastics and transient loading allowances. There are few fixed combustibles in any of the zones and the equivalent fire severities are minimal. The combustible loading classification in the Corridor is also "LOW" and consists of miscellaneous cable, hose and plastic, and transient allowances.
| |
| 9 The lack of significant combustible materials in the zones and the lack of intervening combustibles significantly reduce the chance of fire propagation between zones. Transient combustibles are controlled by plant procedures, effectively reducing the possibility of a fire involving transient materials.
| |
| e Each fire zone is provided with detection system coverage. In the event of a fire in the Switchgear Rooms or Corridor, detection system actuation will result in rapid fire brigade response and subsequent manual extinguishment utilizing hose stations and portable extinguishers strategically located in adjacent fire zones.
| |
| 9 Based on the material and installation of the ventilation ducts, they are considered to prevent fire propagation for up to 1 hour.
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| Page C-33
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Nebraska Public Power District CNS NFPA 805 Transition Report Attachment C Table B-3 Fire Area Transition Fore Area CB-B Control Building 903, DC Switchgear Room 1B and Battery Room 1B EEEE Title EE 09-042 - Evaluation of 1-Hour Marinite Wall in Battery Room 1B Purpose This evaluation is written to address the fire protection adequacy of the 1-hour fire-rated wall enclosure located in Battery Room 1B.
| |
| Conclusion Based on a review of the potential fire hazards located in Battery Room 1B, with the 1-hour fire-rated wall enclosure and the existing fire detection system, the existing barrier provided is adequate to prevent the fire spreading from Battery Room 1 B to the 1-hour fire-rated enclosure.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| e The combustible loading classification for Battery Room 1 B is "LOW" and is mainly attributed to plastics and transient loading allowances. Battery Room 1B has an equivalent fire severity of 30 minutes. The combustible loading consists of cables routed in conduit riser. The lack of significant combustible materials in the zones and the lack of intervening combustibles significantly reduce the chance of fire propagation between zones.
| |
| e Based on the low combustible loading in Battery Room 1B, a fire will not be able to develop to such intensity as to challenge the as-installed configuration.
| |
| 9 Battery Room 1B is provided with smoke detection system coverage. Detection system actuation will prompt rapid fire brigade response and manual extinguishment via portable extinguishers and manual hose stations strategically located in adjacent zones. Pre-fire plans are available for Battery Room 1B.
| |
| 9 Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of a fire.
| |
| * Safe shutdown can be accomplished independent of Battery Room I B.
| |
| Page C-34
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion CB-B Control Building 903, DC Switchgear Room 1B and Battery Room 1 B Variances from Deterministic Reauirements (VFDR)
| |
| CBB-01 Description Loss of critical electrical components due to loss of Control Building HVAC/Switchgear Cooling (HV-FAN-SF-SWGR-1F, HV-FAN-EF-SWGR-1F, EE-MCC-LX, and EE-PNL-CDPIA).
| |
| The NSCA model requires that either train of Switchgear Room cooling fans be available to ensure the Switchgear remains available post-fire. The NSCA model also requires that either train of Battery power be available post-fire.
| |
| Fire damage to cables will not preclude operation of the EF-SWGR-1 F and SF-SWGR-1 F fans from the 1F AC Switchgear Room. Cable damage will affect the operation of ventilation damper AD-1405 by energizing its solenoid and keeping the damper open.
| |
| Fire-induced failure of cables for Control Building HVAC and/or a fire in the Train B DC Switchgear and/or Battery room will result in loss of cooling to EE-PNL-CDPIA/EE-MCC-LX. This would result in a loss of all DC panels. With temperatures affecting operations, cooling via open compartments is effective to ensure operation of the panels.
| |
| This is a separation issue for Vital Auxiliaries.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-35
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Descrotion CB-B Control Building 903, DC Switchgear Room 1B and Battery Room 1 B Description Establish vital auxiliaries by ensuring power to the credited 4160F Bus from Emergency Transformer (EE-CB-4160G-1GS).
| |
| The NSPC require at least one train of electrical power available post-fire.
| |
| Fire damage to control power panels and supply cables on the 4160G Bus would not allow breakers to open automatically, if required, and therefore cause a loss of the credited 4160F Bus. EE-CB-4160G-1GS would normally close during the transfer process to the Emergency Transformer to power the 4160G Bus.
| |
| This is a separation issue for Vital Auxiliaries.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Description Preventing a RR Pump Seal LOCA due to inability to secure the RR Pumps from the Control Room with the REC Non-Critical Header secured (RR Pump Breakers for 4160D-1 DS).
| |
| Breaker F/FDR to the 4160V Bus from the Startup Transformer: This is a normally available, required open breaker that provides motive power to the RR Pump B. The RR Pump is required to trip to prevent a potential RR Seal LOCA when REC is not available to provide cooling. This would challenge the NSPC for Inventory and Pressure Control. Remote operation of the breaker(s) from the Control Room is lost due to EE-PNL-BB1 1 cable DC331 being potentially damaged, and therefore, a loss of control power to the breaker.
| |
| NOTE: REC Non-Critical Header is secured in this fire area to address potential Containment over-pressure.
| |
| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
| |
| Page C-36
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descriotion CB-B Control Building 903, DC Switchgear Room 1B and Battery Room 1B Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Required Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?
| |
| ,_Partial (P) S L E R D 8F Detection Ionization R N N N Y Y N 8G Detection Ionization R N N N Y Y N Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Page C-37
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrip~tion CB-B Control Building 903, DC Switchgear Room 1B and Battery Room 1B Fire Suppression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. There are no fixed suppression systems in the area, and the Battery Rooms and DC Switchgear Rooms on the 903'-6" Elevation of the Control Building are not subject to any adverse effects by water intrusion from fire suppression systems. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments None Page C-38
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area 2escriLtion CB-C RPS Room 1B Fire Zone Description 8B RPS Room 1B Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomnlishment Comments / VFDR Decay Heat Removal SPC Train A will be operated to maintain Suppression Pool temperature. CBC-02 Process Monitoring The following indications will be used to support the Process Monitoring function: None
| |
| - RPV level and pressure [from Control Room]
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - RHR, SW, and CS flow indication, and REC pressure indication [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, CBC-01 other discharge paths inboard of the MSIVs, and other system pressure boundaries. RPV over-pressure protection will be provided by SRVs. Only the self-activated spring lift mode is credited for over-pressure protection. ADS will be used to reduce RPV pressure for operation of Core Spray Train A to maintain RPV level.
| |
| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip, or from operator initiation of a manual trip.
| |
| Page C-39
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Descriotion CB-C RPS Room 1B Vital Auxiliaries Mechanical: None
| |
| -REC Train A will be operated to provide the cooling supply to the ECCS.
| |
| -SW Train A will be operated to provide the cooling supply to the REC system and RHR Train A Heat Exchanger.
| |
| Electrical (AC/DC):
| |
| - Offsite Emergency Transformer aligned to 4160V Bus 1F
| |
| - 125/250 VDC Train A and B are available HVAC:
| |
| - HPCI/CS Train A - Quad area cooling
| |
| - AC Switchgear Rooms - Essential Control Building HVAC system
| |
| - DC Switchgear Rooms - Essential Control Building HVAC system
| |
| - Battery Rooms - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Room 1A - Essential Control Building HVAC system Reference Document / Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensing Actions None Page C-40
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area Description CB-C RPS Room 1B Existina Enaineering Eguivalency Evaluations (EEEE)
| |
| EEEE EE 09-040 - Evaluation of Auxiliary Relay Room and RPS Room 1B Appendix R Fire Barriers Purpose This evaluation justifies the adequacy of ventilation duct penetrations, without fire-rated dampers, routed through the barriers that separate the Auxiliary Relay Room, RPS Room 1B, and RPS Room 1A on the 903'-
| |
| 6" Elevation of the Control Building. Additionally, a fire rating cannot be assigned to the barriers due to miscellaneous door discrepancies concerning doors H 102, H103, and H104.
| |
| 9 Door H102 separates RPS Room 1B (Fire Area CB-C) from the Seal Water Pump Area and Corridor (Fire Area CB-A)
| |
| * Doors H103 and H104 separate the Auxiliary Relay Room (Fire Area CB-D) from the Seal Water Pump Area and Corridor (Fire Area CB-A)
| |
| Conclusion Based on the installed fire protection features, including detection system coverage and manual fire suppression capabilities, and the lack of significant fire hazards, and the types of combustible materials, the ventilation ductwork is sufficient to provide protection from spread of fire prior to fire brigade response and subsequent manual extinguishment, if necessary. Discrepancies concerning doors H102, H103, and H104 are relatively minor, and include door clearances, and minor modification for proper operation. These discrepancies are therefore not considered to affect fire safety. The separation that has been provided is considered to be adequate for the fire hazards of the areas.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| e There are typically few fixed combustibles in any of the zones, and the equivalent fire severities are minimal. The exception is the Auxiliary Relay Room, which contains a significant amount of cable insulation in open cable trays routed at the ceiling elevation. The content of the RPS Room consists mainly of batteries.
| |
| The combustibles in the Corridor mainly consist of miscellaneous cable, hose and plastic, and transient allowances. Cables in the Corridor are routed in conduit, and potential ignition sources in the zones are limited to energized electrical equipment, typically in cabinets, and potential transient sources.
| |
| 9 A cable tray fire in the Auxiliary Relay Room would be characterized as a slow propagating fire that has the potential to produce significant amounts of smoke. Based on the installed detection system coverage, fire brigade response and manual extinguishment would occur prior to the fire being able to breach the barrier via the ductwork.
| |
| o The lack of significant combustible materials in the remaining zones and the lack of intervening combustibles significantly reduce the chance of fire propagation between zones.
| |
| Page C-41
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area D.scraoJgteo CB-C RPS Room 1B e Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of a fire.
| |
| * The supply registers in the Auxiliary Relay Room are provided with 3-hour rated fire dampers (HV-AD-AD1434 and HV-AD-AD1435). A 3-hour fire-rated damper has been provided in the Auxiliary Relay Room at the exhaust register (HV-AD-AD1436).
| |
| e Sheet metal ductwork is recognized by the NFPA to provide up to 1-hour fire separation when properly hung, and the fire is stopped.
| |
| * Each fire zone is provided with detection system coverage. In the event of a fire in the RPS Room, Auxiliary Relay Room, or Corridor, detection system actuation will result in rapid fire brigade response and subsequent manual extinguishment utilizing hose stations and portable extinguishers strategically located in adjacent fire zones.
| |
| Page C-42
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area CB-C RPS Room 1B Variances from Deterministic Reauirements (VFDR)
| |
| Description Ability to operate SRV's automatically/remotely from the Control Room is lost due to cable fire damage (Pilot Valves SPV71 E, SPV71G, and SPV71 H).
| |
| The NSPC require the ability to reduce pressure in the RPV to maintain water inventory above the active fuel using low pressure injection systems. Automatic control of these valves is lost, to support operation of the CS Pumps for Inventory Control.
| |
| This is a separation issue for Inventory and Pressure Control.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None CBC-02 Description Preventing a loss of SW cooling flow to credited RHR Heat Exchanger (SW-MOV-MO89A).
| |
| SW Train A is required to support various functions (SPC, HPCI and CS Quad cooling, REC, DGs, etc) for NSPC.
| |
| SPC Train A is the credited train of Decay Heat Removal. SW-MOV-MO89A is normally closed and with the loss of RHR-LOGIC-A power, the valve will not spuriously open. However, the loss of RHR logic will lock in the closed signal on the valve, securing SW flow to the RHR Heat Exchanger, and therefore result in a loss of SPC Train A.
| |
| This is a separation issue for Decay Heat Removal.
| |
| Page C-43
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area CB-C RPS Room 1B Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Reauired Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?
| |
| Partial (P) S 8B Detection Ionization R N N N Y Y N Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Fire SuoDression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. There are no fixed suppression systems in the area and the RPS MG Set Room on the 903'-6" Elevation of the Control Building is not subject to any adverse effects by water intrusion from fire suppression systems. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments None Page C-44
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Foe Area CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room Fire Zone Description 1OA Computer Room 10B Control Room and SAS Corridor 8A Auxiliary Relay Room 9A Cable Spreading Room 9B Cable Expansion Room Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments / VFDR Decay Heat Removal RHR system will use the alternate lineup to maintain temperature. CBD-01 CBD-02 CBD-09 CBD-10 CBD-12 Process Monitoring The following indications will be used to support the Process Monitoring function: None
| |
| - RPV level and pressure [from Primary Control Station]
| |
| - Suppression Pool level and temperature [from Primary Control Station]
| |
| - Emergency Condensate Storage Tank level [from Primary Control Station]
| |
| -HPCI flow, pressure, and turbine speed [from Primary Control Station]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, CBD-01 other discharge paths inboard of the MSIVs, and other system pressure CBD-02 boundaries. RPV over-pressure protection will be provided by SRVs. Only the CBD-04 self-activated spring lift mode is credited for over-pressure protection. HPCI CBD-06 system will use alternate lineup to control RPV pressure and to maintain RPV CBD-08 level. CBD-ll1 CBD-13 CBD-14 Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control CBD-1 2 rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
| |
| Page C-45
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Dsrlto CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room Vital Auxiliaries Mechanical: CBD-03
| |
| -REC will be supplied by SW Train B to provide the cooling supply to the ECCS CBD-05 in the alternate lineup. CBD-07
| |
| -SW Train B will be operated to provide the cooling supply to the REC system CBD-15 and RHR Heat Exchangers in the alternate lineup.
| |
| Electrical (AC/DC):
| |
| - Offsite Emergency Transformer aligned to 4160V Bus 1G
| |
| - 125/250 VDC Train B is available HVAC:
| |
| - HPCI/CS Train B - Quad area cooling
| |
| - AC Switchgear Room IG - Essential Control Building HVAC system
| |
| - DC Switchgear Room 1 B
| |
| - Battery Room 1B
| |
| - Auxiliary Relay Room and RPS MG Set Room 1B Reference Document / Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensing Actions None Page C-46
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area ecotn CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room Existina Enaineerina Eauivalency Evaluations (EEEE)
| |
| EE.I itl EE 09-035 - Evaluation of Fire Doors Purpose Fire door assemblies provided in fire-rated barriers may vary slightly from listed configurations, and may or may not provide the same fire rating as that required of the fire barrier. The evaluation documents the adequacy of the configurations that have been provided for fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and R115, and justifies the continued use of the configurations, as they have been determined to provide a level of protection that is adequate for the fire hazards in the areas.
| |
| " Door D202 separates the Cable Expansion Room (Fire Area CB-D) from Stair A-9 (Fire Area TB-A)
| |
| " Door H105 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Turbine Building Floor North (Fire Area TB-A) e Doors H200 and H201 separate the Cable Spreading Room (Fire Area CB-D) from Stair A-1 0 (Fire Area CB-A)
| |
| * Door H202 separates the Cable Spreading Room (Fire Area CB-D) from the Office Building Controlled Corridor (Fire Area TB-A)
| |
| * Door H306 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Computer Room (Fire Area CB-D)
| |
| " Door H307 separates the Computer Room (Fire Area CB-D) from the I and C Shop (Fire Area TB-A)
| |
| " Door N103 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Turbine Building Mezzanine North (Fire Area TB-A)
| |
| * Door N104 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Diesel Generator Room 1 B (Fire Area DG-B)
| |
| * Door R6 separates the Reactor Building Southeast Quad (Fire Area RB-CF) from the Suppression Pool Area (Fire Area RB-E) e Door R7 separates the Reactor Building Northwest Quad (Fire Area RB-B) from the Suppression Pool Area (Fire Area RB-E) e Doors R101 and R102 separate the Reactor Building 903' Northeast Corner (Fire Area RB-FN) from the Office Building Controlled Corridor (Fire Area TB-A) e Door R1 15 separates Reactor Building 903'-6" CRD Units - South (Fire Area RB-DI) from the Exterior Transformer Yard (Fire Area YD)
| |
| Conclusion The fire door configurations (i.e., fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and R115) have been determined to provide a level of protection commensurate with the fire Page C-47
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area ecotn CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room hazards of the areas, and adequate separation has been provided. In general, minor variations to the configurations, such as conduit penetrations through the door frames, slightly larger gaps between doors and frames, and doors rated for less than that required of the barrier, have been evaluated as acceptable based on the fire hazards on either side of the barrier.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| 9 Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
| |
| e Fire hoses and portable extinguishers are strategically located throughout the plant for use by the responding fire brigade.
| |
| " Ventilation systems can typically be used for smoke and heat removal.
| |
| " Due to control of transient combustibles and ignition sources, door proximity to permanent combustibles, and fire area combustible loading, the majority of these doors will not be challenged by a credible fire. This effectively reduces the risk of the identified deviations.
| |
| * The automatic sprinkler system and smoke detection provided in the Cable Expansion Room (Fire Area CB-D) are credited for the acceptability of door D202.
| |
| * The automatic smoke detection systems provided in the Seal Water Pump Area and Corridor (Fire Area CB-A) and in the Turbine Building Floor North (Fire Area TB-A) are credited for the acceptability of door H105.
| |
| e The pre-action sprinkler system and automatic smoke detection provided in the Cable Spreading Room (Fire Area CB-D) are credited for the acceptability of doors H200 and H201.
| |
| * The automatic total flooding Halon 1301 suppression system and automatic smoke detection provided in the Computer Room (Fire Area CB-D) are credited for the acceptability of doors H306 and H307.
| |
| e The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1A (Fire Area DG-A) and the heat detection installed are credited for the acceptability of doors N103 and N104.
| |
| 9 The smoke and heat actuated devices provided in the Turbine Building Mezzanine (Fire Area TB-A) are credited for the acceptability of doors N103.
| |
| 9 The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1 B (Fire Area DG-B) and the heat detection installed are credited for the acceptability of door N104.
| |
| * The automatic heat detection provided in the Reactor Building Northwest Quad (Fire Area RB-CF) is credited for the acceptability of.door R6.
| |
| e The automatic heat detection provided in the Reactor Building Southeast Quad (Fire Area RB-B) is credited for the acceptability of door R7.
| |
| * The automatic suppression system provided in the Office Building Corridor (Fire Area TB-A) is credited for Page C-48
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room the acceptability of doors R101 and R102.
| |
| e The automatic sprinkler system and smoke detection provided in the Reactor Building 903' Northeast Corner (Fire Area RB-FN) is credited for the acceptability of doors R101 and R102.
| |
| 9 The automatic deluge suppression system actuated by heat actuated devices provided for the yard transformers (Fire Area YD) are credited for the acceptability of door R1 15.
| |
| o Actuation of the detection systems will prompt rapid fire brigade response and subsequent manual extinguishment.
| |
| EEEE Title EE 09-036 - Evaluation of Cable Expansion Room Penetration Seals Purpose This evaluation documents the adequacy of the non-fire rated expansion joints in the Cable Expansion Room Appendix R fire barriers. In addition, conduit penetrations exist in the floor/ceiling assembly penetrating to the Office Building Corridor below that are not sealed with grout to the depth specified in the design details.
| |
| Conclusion Based on the fire protection features provided in the Cable Expansion Room, including automatic suppression and detection system coverage, the ability to achieve safe shutdown independent of the area, and the lack of safe shutdown equipment/cables and combustible materials in the fire zone adjacent to the Cable Expansion Room, the configurations, as provided, are considered adequate.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| * The expansion joints are provided with 14 gauge metal covers. The metal covers will provide some degree of fire protection to impede the spread of fire, smoke, and hot gases to the adjacent fire zones.
| |
| e An automatic sprinkler system and smoke detectors are provided in the Cable Expansion Room. In the event of a fire in the area, detection system actuation will result in alarm in the Control Room, fire brigade response, and subsequent manual extinguishment utilizing hose stations and portable extinguishers.
| |
| e The presence of automatic detection and suppression ensures that a fire will be limited by automatic or manual suppression, such that breaching of the barriers via the expansion joints or conduit penetrations will be limited.
| |
| e Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of a fire.
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| Page C-49
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Nebraska Public Power District CNS NFPA 805 Transition Report Attachment C Table B-3 Fire Area Transition Fire Area Desription CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room EEEE Title EE 09-040 - Evaluation of Auxiliary Relay Room and RPS Room 1 B Appendix R Fire Barriers Purpose This evaluation justifies the adequacy of ventilation duct penetrations, without fire-rated dampers, routed through the barriers that separate the Auxiliary Relay Room, RPS Room 1B, and RPS Room 1A on the 903'-
| |
| 6" Elevation of the Control Building. Additionally, a fire rating cannot be assigned to the barriers due to miscellaneous door discrepancies concerning doors H102, H103, and H104.
| |
| 9 Door H102 separates RPS Room 1B (Fire Area CB-C) from the Seal Water Pump Area and Corridor (Fire Area CB-A)
| |
| * Doors H103 and H104 separate the Auxiliary Relay Room (Fire Area CB-D) from the Seal Water Pump Area and Corridor (Fire Area CB-A)
| |
| Conclusion Based on the installed fire protection features, including detection system coverage and manual fire suppression capabilities, and the lack of significant fire hazards, and the types of combustible materials, the ventilation ductwork is sufficient to provide protection from spread of fire prior to fire brigade response and subsequent manual extinguishment, if necessary. Discrepancies concerning doors H102, H103, and H104 are relatively minor, and include door clearances, and minor modification for proper operation. These discrepancies are therefore not considered to affect fire safety. The separation that has been provided is considered to be adequate for the fire hazards of the areas.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| * There are typically few fixed combustibles in any of the zones, and the equivalent fire severities are minimal. The exception is the Auxiliary Relay Room, which contains a significant amount of cable insulation in open cable trays routed at the ceiling elevation. The content of the RPS Room consists mainly of batteries.
| |
| The combustibles in the Corridor mainly consist of miscellaneous cable, hose and plastic, and transient allowances. Cables in the Corridor are routed in conduit, and potential ignition sources in the zones are limited to energized electrical equipment, typically in cabinets, and potential transient sources.
| |
| * A cable tray fire in the Auxiliary Relay Room would be characterized as a slow propagating fire that has the potential to produce significant amounts of smoke. Based on the installed detection system coverage, fire brigade response and manual extinguishment would occur prior to the fire being able to breach the barrier via the ductwork.
| |
| * The lack of significant combustible materials in the remaining zones and the lack of intervening combustibles significantly reduce the chance of fire propagation between zones.
| |
| * Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of a fire.
| |
| Page C-50
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Qsdnfn CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room e The supply registers in the Auxiliary Relay Room are provided with 3-hour rated fire dampers (HV-AD-AD 1434 and HV-AD-AD1435). A 3-hour fire-rated damper has been provided in the Auxiliary Relay Room at the exhaust register (HV-AD-AD1436).
| |
| e Sheet metal ductwork is recognized by the NFPA to provide up to 1-hour fire separation when properly hung, and the fire is stopped.
| |
| e Each fire zone is provided with detection system coverage. In the event of a fire in the RPS Room, Auxiliary Relay Room, or Corridor, detection system actuation will result in rapid fire brigade response and subsequent manual extinguishment utilizing hose stations and portable extinguishers strategically located in adjacent fire zones.
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| Page C-51
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Dl~ZoU CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room EEEE Title EE 86 Evaluation of a Ventilation Opening Through the Cable Spreading Room Floor Appendix R Fire Barrier Purpose The purpose of this engineering evaluation is to document the acceptability of fire damper HV-AD-AD1 556 located in the floor/ceiling boundary where the ventilation ductwork penetrates from Battery Room 1A to the Cable Spreading Room. The damper has been blocked open to ensure exhaust system operability, as accidental closure would render the exhaust system inoperable. In addition, steel pipe has been used as ventilation ductwork in the Cable Spreading Room, which is not typical for ventilation.
| |
| Conclusion Based on the significant construction of the assembly, the lack of significant fire hazards and combustible loading, and the presence of installed fire protection features including fire detection and fixed fire suppression, the configuration that has been provided is adequate for the fire hazards of the areas.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| e The duct assembly in the Cable Spreading Room is of significant steel construction. There is reasonable assurance that if a fire in the Cable Spreading Room was to occur, it would not breach the ductwork (i.e., the pipe) based on the significant pipe construction, and be able to propagate down into the Battery Room.
| |
| e Although the combustible loading classification in the Cable Spreading Room is "HIGH," due to the large quantity of cable insulation in the area, installed fire protection features are provided to mitigate the effects of a fire.
| |
| e The combustible loading classification in the Battery Room is "LOW" and consists mainly of plastic associated with battery cases. The lack of significant fire hazards and combustible loading in Battery Room 1A precludes the possibility of a fire developing to such intensity as to breach the ventilation ductwork in the Battery Room and then breach the significant pipe construction provided in the Cable Spreading Room.
| |
| 9 Automatic detection system coverage will alert the fire brigade of fire conditions and automatic suppression system coverage will limit the intensity of a fire in the Cable Spreading Room.
| |
| * Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
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| Page C-52
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room EEE EE 86 Evaluation of HVAC Ducts and Fire Door Between the Control Room and Controlled Corridor Purpose This engineering evaluation is being prepared to document the acceptability of the three ventilation duct penetrations that are not provided with fire dampers located in the Control Room south wall, which provides Appendix R fire barrier separation between the Control Room and the Controlled Corridor.
| |
| Conclusion Based on the construction of the assembly, the lack of significant fire hazards and combustible loading and the presence of installed fire protection features including fire detection, the configuration that has been provided is adequate for the fire hazards of the areas.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| e The Control Room is constantly attended. Any anticipated fire would be quickly discovered and extinguished in its incipient stage.
| |
| * The two larger vent ducts are at an elevation approximately 12 feet above the floor, which is above the suspended ceilings in the corridor. It is, therefore, unlikely that a fire would cause direct flame exposure to the duct in the corridor.
| |
| 9 The corridor area is essentially void of any significant combustible loading with the exception of miscellaneous combustibles stored in closed metal lockers. There are essentially no combustibles normally located in the corridor near the duct penetrations. It is extremely unlikely that the penetrations would ever be exposed to a significant fire.
| |
| e Fire propagation from the Control Room to the corridor is considered inconsequential from a safe shutdown standpoint since the office corridor does not contain any safe shutdown cables or equipment.
| |
| 9 Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
| |
| * There are no openings, such as ventilation grills, on either side of the wall in the large ducts to allow flame propagation to enter the ductwork.
| |
| * The Battery Room exhaust duct is a Schedule 80 pipe. Fire propagation into or through this pipe is not considered a credible event, as it is of significant construction so as to prevent fire spread.
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| Page C-53
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room Variances from Deterministic Reauirements MVFDRI CBD-01 Description Preventing a full or partial loss of SW for supporting Decay Heat Removal and Inventory and Pressure Control from the starter racks and ASD Room with SW supplying REC (EE-CB-4160G-SWP1B, REC-FIS-24-ASD, REC-MOV-695MV-ASD, REC-MOV-714MV-ASD, SW-AOV-TCV451B-ASD, SW-MOV-37MV, SW-MOV-651 MV-ASD, SW-MOV-887MV-ASD, SW-MOV-889MV-ASD, and SW-STNR-B).
| |
| SW Train B is required to support various functions (SPC, HPCI and CS Quad cooling, REC, DGs, etc) for NSPC. HPCI is credited for Inventory Control, SPC Train B is credited for Decay Heat Removal, REC Train B provides cooling for RHR Pump 1D and the RHR and HPCI Rooms (Quads), and SW Train B provides the cooling for REC and RHR Heat Exchangers (DGs not credited). The complete loss or diversion of SW to REC could challenge these NSPC.
| |
| (1) Based on cable failures, EE-CB-4160G-SWP1B may trip open.
| |
| (2) HPCI Room cooling flow may not be available due to cable failures to FIS indication.
| |
| (3) REC-MOV-695MV is not controlled from the ASD Room, and cable failure removes the ability to remotely close the valve prior to leaving the Control Room.
| |
| (4) REC-MOV-714MV is not controlled from ASD Room, and cable failure removes the ability to remotely close the valve prior to leaving the Control Room.
| |
| (5) Cable damage may cause SW-AOV-TCV451 B to fail closed, securing the Reactor Building SW flow returning from the REC system, removing cooling flow to the HPCI and RHR Pumps.
| |
| (6) SW-MOV-37MV is not controlled from the ASD Room, and may need to be closed to isolate the diversion of SW flow from the critical SW and REC loads to the non-critical SW loads.
| |
| (7) SW-MOV-651 MV is not controlled from the ASD Room, and needs to be closed to prevent flow diversion from the SW system to the REC Heat Exchanger, which is bypassed in ASD lineup.
| |
| (8) SW-MOV-887 is not controlled from the ASD Room, and needs to be open to supply SW to the REC Critical Header.
| |
| (9) SW-MOV-889 is not controlled from the ASD Room, and needs to be open to supply SW to the REC Critical Header.
| |
| (10) SW-STNR-B based on cable failures may lose its automatic features, resulting in clogging of the strainer and reducing/securing SW flow.
| |
| This is a separation issue for Inventory and Pressure Control and Decay Heat Removal.
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| Page C-54
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore AreaDecito CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Description Ability to close MSIVs automatically/remotely from the Control Room is lost due to cable fire damage and Control Room abandonment.
| |
| MSIVs (MS-AOV-AO80A, MS-AOV-AO80B, MS-AOV-AO80C, and MS-AOV-AO80D) may not go closed from the Control Room due to cable damage. The NSPC requires a means of isolating the RPV to ensure sufficient water inventory for Decay Heat Removal.
| |
| This is a separation issue for Inventory and Pressure Control and Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-55
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Dsrlto CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room CBD-03 Description Establish Vital Auxiliaries and control by powering the credited 4160G Bus from the Emergency Transformer, and MCC-R from its alternate power supply (EE-CB-4160F-1 FS, EE-CB-4160G-1 GB, EE-CB-4160G-1 GE, EE-CB-4160G-1 GS, EE-CB-4160G-RSWP1 B-OCT, EE-CB-4160G-RSWP1 D-OCT, and EE-CB-4160G-SS1G).
| |
| The NSCA require at least one source of AC power be available. Offsite power from the Emergency Transformer is unavailable using the normal transfer mode due to fire damage to supply breakers feeding the 4160G Bus.
| |
| There are multiple breaker and cables affected on the 4160F Bus. Multiple cables that support EE-CB-4160F-1 FS are also damaged due to fire, and may close the breaker.
| |
| The EE-CB-4160G-1GB breaker is normally closed, and should open as part of the transfer process due to loss of the Start-Up Transformer, but cable damage to H561 may not allow it to open. The DG and Emergency Transformer are not rated to normally carry both the Vital and Non-Vital buses. Additionally, the DG2/1GS breakers are interlocked with the BG/GB breakers, and will not close if the breaker is not opened.
| |
| Cable damage (C730, H571, H572, H573) due to fire could close EE-CB-4160G-1GE, or blow its control power fuses. The breaker is normally closed, and needs to be open to allow for control of the DG and not allow damage to the DG or the bus if the DG came onto the bus out-of-phase.
| |
| Based on cable failure (C730, H551, H552, H553, H555, X10) due to fire damage, breaker EE-CB-4160G-1GS may trip open or blow control power fuses, and not close.
| |
| EE-CB-4160G-RSWP1 B-OCT may not trip due to potential fire damage to the control and load cables, resulting in loss of the credited 4160G Bus.
| |
| EE-CB-4160G-RSWP1 D-OCT may not trip due to potential. fire damage to the control and load cables, resulting in loss of the credited 4160G Bus.
| |
| Cable damage to H542 and H543 may cause EE-CB-4160G-SS1G to trip open. Opening this breaker causes a loss of power to the 480V G Bus. The breaker is normally closed, and desired closed to support NSPC requirements for Process Monitoring and Decay Heat Removal.
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| Page C-56
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room This is a separation issue for Vital Auxiliaries.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDRs meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Description Ability to Close SRVs automatically/remotely from the Control Room is lost due to cable fire damage (Pilot Valves SPV71A, SPV71B, SPV71C, SPV71D, SPV71E, SPV71F, SPV71G, and SPV71H).
| |
| The NSCA require the ability to isolate the RPV to maintain water inventory above the top of active fuel.
| |
| Spurious operations could result in the opening of up to eight ADS (SRV) valves. The NSPC could be challanged if the affected ADS valves are not returned to their fail-safe closed position within 18 minutes for single spurious operation, and a shorter time if more than one ADS valve spuriously opens.
| |
| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-57
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room CBD-05 Description Loss of Battery/DC Switchgear Room/Critical Switchgear cooling due to cable damage to cooling fans and dampers (EE-BAT-1 25-1 B, EE-BAT-250-1 B, EE-SWGR-1 25B, EE-SWGR-250B, HV-FAN-EF-SWGR-1 G, and HV-FAN-SF-SWGR-1G).
| |
| Fire-induced failure of cables for Control Building HVAC will result in loss of cooling to Battery Room 1B.
| |
| The NSCA model requires that either train of battery power be available post-fire. With temperatures affecting operation, cooling via open compartment is effective to ensure operation of the batteries.
| |
| Fire damage to cables will not preclude operation of the EF-SWGR-1 G and SF-SWGR-1 G fans from the 1G AC Switchgear Room. Cable damage will affect the operation of ventilation damper AD-1408 by energizing its solenoid and keeping the damper open. Damper AD-1407 has its cable routed in dedicated conduit in area CB-A. The NSCA model requires that either train of Switchgear Room cooling fans be available to ensure the Switchgear remains available post-fire.
| |
| This is a separation issue for Vital Auxiliaries.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-58
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire AreaControl Roo CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room Description Preventing a RR Pump Seal LOCA due to inability to secure the RR Pumps from the Control Room with the REC Non-Critical header secured (RR Pump Breakers for 4160C-1CS and 4160D-1 DS).
| |
| Breakers F/FDR to the 4160V Buses from the Startup Transformer: These are normally available, required open breakers that provide motive power to the RR Pumps. The RR Pumps are required to trip to prevent potential RR Pump Seal LOCA when REC is not available to provide cooling. This would challenge the NSPC for Inventory and Pressure Control. Remote operation of the breaker(s) from the Control Room is lost due to cables H248, H261 and M1 (1C Bus) and H288, H301 and M1 (1D Bus) fire-induced damage.
| |
| NOTE: REC Non-Critical Header is secured in this fire area to address potential containment over-pressure.
| |
| This is a separation issue for Inventory and Pressure Control.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-59
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area ecotn CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room CBD-07 Description Loss of both A and B Train 125V and 250V Battery Chargers due to cable damage (EE-CHG-125-1B and EE-CHG-250-1 B).
| |
| Fire damage to cable MTX10 causes a loss of Main Supply Power to the B Train 125V Battery Charger.
| |
| The NSCA require at least one train of DC power be available post-fire, and both A and B Train Battery Chargers are affected. The B Train batteries are the credited train post-fire. Battery Charger repair is required commencing within 1.5 hours and completed within 4.5 hours from the time the Battery Charger is lost.
| |
| Fire damage to cable MTX9 causes a loss of Main Supply Power to the B Train 250V Battery Charger.
| |
| The NSCA require at least one train of DC power be available post-fire, and both A and B Train Battery Chargers are affected. The B Train batteries are the credited train post-fire. Battery Charger repair is required commencing within 1.5 hours and completed within 4.5 hours from the time the Battery Charger is lost.
| |
| This is a separation issue for Vital Auxiliaries.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-60
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Dsrlto CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room CBD-08 Description Loss of RPV water inventory to Reactor Building Sumps and Radwaste (CRD-SOV-SO31A and CRD-SOV-SO31 B).
| |
| Cable damage may result in the spurious opening of CRD-SOV-SO31A and CRD-SOV-SO31 B. This opening of the CRD Scram Discharge Volume Vent and Drain Valve SOVs would result in loss of RPV Inventory to the Reactor Building Sumps and then Radwaste. The NSCA require a means of isolating the RPV post-fire to ensure sufficient water inventory. Based on CNS-PSA-007, the flow rate from CRD seal leakage is assumed to be 450 to 600 gpm initially, reducing to 73 gpm after 70 minutes, and down to 40 gpm after 4 hours, based on all CRD seals leaking at the same time at the maximum amount prior to repair.
| |
| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable - Recovery Action carried forward as Defense-in-Depth.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-61
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare AreaDecito CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room CBD-09 Description Loss of Decay Heat Removal, due to flow diversion or loss of a pump in the RHR system or loss of cooling from the SW system due to cable damage (RHR-MOV-MO20-ASD, RHR-MOV-MO26B-ASD, RHR-MOV-MO57-ASD, EE-CB-RHRP1 D, and SW-MOV-MO89B-ASD).
| |
| SPC Train B is the credited train for Decay Heat Removal. The complete loss of RHR flow, or the diversion of flow, would challenge this NSPC.
| |
| Based on cable failure, valve RHR-MOV-MO20 may spuriously open, resulting in a 20-inch flow diversion through the bypass line, resulting in a loss or reduction of flow during the SPC Train B mode of operation.
| |
| The normal method of operation of RHR-MOV-MO26B during ASD would be to remove control power fuses (3C), and operate from the MCC starter or local handwheel. Control cable damage may spuriously operate this valve prior to removing the control power fuses. The feeder cable is undamaged. RHR-MOV-M026B presents a 10-inch diversion path to establishing SPC Train B.
| |
| The normal method of operation of RHR-MOV-MO57 during ASD would be to remove control power fuses and operate from the MCC starter or local handwheel. Control cable damage may spuriously operate this valve prior to removing the control power fuses. The feeder cable is undamaged. RHR-MOV-MO57 presents a 4-inch diversion path to establishing SPC Train B.
| |
| Due to multiple damaged cables, the RHR Pump breaker may fail to close automatically or remotely. This would result in a loss of Decay Heat Removal for SPC Train B.
| |
| Based on cable damage to RHRSW Booster Pump breakers, neither breaker can be closed removing remote operability of SW-MOV-MO89B. The valve is normally closed, and is required to be open to establish SW flow through the RHR Heat Exchanger.
| |
| This is a separation issue for Decay Heat Removal.
| |
| Page C-62
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area Descrintion CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None CBD-10 Description Preventing the loss of containment over-pressure in support of RHR Pump operation for SPC operation (RW-AOV-AO82 and RW-AOV-AO94, REC-MOV-712MV, REC-MOV-713MV, PC-AOV-245AV, and PC-AOV-246AV)
| |
| The NSPC require a means to provide Decay Heat Removal post-fire. SPC Train B is credited for Decay Heat Removal. The loss of containment over-pressure could result in the loss of Net Positive Suction Head (NPSH) for the credited RHR Pump during the SPC mode of operation.
| |
| Cable damage to the SOVs associated with RW-AOV-AO82, RW-AOV-AO83, RW-AOV-AO94, and RW-AOV-AO95 may result in spurious opening. These valves isolate the drywell equipment and floor drain sump discharge paths, and their opening would result in a loss of containment over-pressure.
| |
| REC-MOV-712MV and REC-MOV-713MV isolate the REC Critical and Non-Critical Headers. The valves are normally open, and are required to be closed to secure flow to the Drywell Coolers. Based on cable damage and Control Room abandonment, remote operation of these valves is not possible.
| |
| Cable damage to M355 (PC-AOV-245AV) and M358 (PC-AOV-246AV) may cause the valves to fail open.
| |
| These valves are normally closed and desired closed. Spurious opening of these valves results in Containment and Suppression Chamber vent/purge lines opening, resulting in loss of containment over-pressure.
| |
| This is a separation issue for Decay Heat Removal.
| |
| Page C-63
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Dsrlto CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None CBD-1 1 Description Prevent loss of RPV water inventory and/or high pressure in the low pressure portion of the RWCU system from the Control Room due to cable fire damage (RWCU-MOV-MO15).
| |
| The NSPC requires a means of isolating the RPV and low pressure systems from the RPV post-fire.
| |
| Cable damage (MR122 and PC86) may cause spurious opening of RWCU-MOV-MO15, and the inability to close RWCU-MOV-MO15 would result in loss of RPV inventory to the RWCU system, or cause high pressure in the low pressure portion of RWCU piping downstream.
| |
| This is a separation issue for Inventory and Pressure Control.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-64
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire AreaDecito CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room CBD-12 Description Inability to control power or ensure positive reactor shutdown due to fire damage (RPS-ELECT).
| |
| The NSCA require a means of ensuring the reactor is shutdown post-fire. Cable damage may result in the inability of a manual scram to occur from the Control Room.
| |
| EE 10-064 shows that a fire in the Control Room will not totally disable the ability to close the MSIVs from the Control Room. Control Room operation to close the MSIVs will be successful if performed.
| |
| This is a separation issue for Reactivity Control and Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Description Preventing an RPV overfill condition with spurious RCIC startup and loss of control due to cable damage (RCIC-MOV-MO15).
| |
| The NSCA require a means of maintaining RPV water level post-fire. RCIC normally maintains level during transient conditions, but with the cables damaged due to fire in this area for RCIC-MOV-MO15, RCIC-MOV-MO16, and RCIC-MOV-131MV, system status is not assured, and may result in a startup of the RCIC system without control, and cause an overfill condition. RPV water level can still be maintained by the HPCI system if required.
| |
| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-65
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Dct£toJn CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room CBD-14 Description Preventing loss of remote valve control for essential systems from the ASD Room (EE-MCC-R-1A).
| |
| The NSCA require a mean of RPV pressure and inventory control post-fire. The feeder cable from MCC-K (MK1 34) is affected by the fire and MCC-R is the power supply to HPCI-MOV-M015-ASD, MS-MOV-M074, REC-MOV-695MV, RHR-MOV-MO20, RHR-MOV-MO57-ASD, and RWCU-MOV-MO15. The normal position of HPCI-MOV-MO15 is open and the desired position is open, with HPCI as the credited train of RPV inventory control. HPCI-MOV-MO1 5 may spuriously close prior to shifting to the ASD Room.
| |
| Shift of power will provide both indication of valve position, and allow for control power from the ASD panel.
| |
| This is a separation issue for Inventory and Pressure Control.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None CBD-15 Description Loss of power to critical equipment for plant operation (SW Pump B and SW Pump D).
| |
| The NSCA require a means of powering the critical pieces of equipment SW Pump B feeder cable H521, and SW Pump D feeder cable H531. Failure of these cables will result in loss of the credited Service Water function.
| |
| This is a separation issue for Vital Auxiliaries.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-66
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area Description CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room Required Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?
| |
| Partial (P) S L E R D 10A Detection Ionization R Y N N Y N N 10A Suppression Auto Total Flooding Halon 1301 F N/A N N Y N N 10B Detection Heat R N N N N Y N 10B Detection Ionization R N N N N Y N 8A Detection Incipient (in Panels 9-32 and 9-33) R N N N N Y N 8A Detection Ionization R N N N Y Y N 9A Detection Heat Actuated Devices R Y N N Y Y N 9A Detection Ionization R Y N N Y Y N 9A Feature Flame Impingement Shield N/A N/A N N N Y N 9A Feature Flame Impingement Shield N/A N/A N N N Y N 9A Suppression Preaction Sprinkler System F N/A N N Y Y N 9B Detection Ionization R N N N Y Y N 9B Feature Flame Impingement Shield N/A N/A N N N Y N 9B Suppression Automatic Wet-Pipe F N/A N N Y Y N Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Page C-67
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Descriotion CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room Fire Suppression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. Per MWR 91-1264, electrical cabinets and conduit have been sealed to mitigate the effects of suppression activities. In the event of normal operation, the pre-action and automatic wet pipe suppression systems will not adversely effect the other equipment operating within the Fire Zone. The possibility of inadvertent actuation of the pre-action suppression system in the Cable Spreading Room is not assumed since the suppression lines are not under constant pressure. The drainage features and equipment pedestals mitigate the potential for flooding damage due to fire suppression, such that the standing water would not affect safety-related equipment. In the event of normal operation, the Halon system will not adversely effect the other equipment operating within the Fire Zone, as potential corrosion developing on equipment is a long term issue that would be significantly reduced by extensive post-discharge clean up. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments In Fire Zone 9A, fire insulated board has been installed to around Division II power feeds near the floor. Cable trays C209, C212, C213, C232 and C233 in Fire Zone 9A are provided with solid bottom 1/4" asbestos boards, and the trays below are provided with solid metal covers.
| |
| In Fire Zone 9A, flame impingement shielding is being installed for cable trays and conduit to prevent damage from fires involving panels PMIS-MUX-LNK6 and PMIS-MUX-LNK7. See LAR Attachment S, Table S-2, Item S-2.7.
| |
| In Fire Zone 9B a flame impingement shield has been installed beneath the Division II conduit bank.
| |
| Page C-68
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Description DG-A Diesel Generator Room 1A Fire Zone Description 14A Diesel Generator Room 1A 14C DG1 Day Tank Room Reaulatorv Basis 4.2.3.2 - Deterministic Approach Performance Goal Method of Accomplishment Comments / VFDR Decay Heat Removal SPC Train B will be operated to maintain Suppression Pool temperature. None Process Monitoring The following indications will be used to support the Process Monitoring None function:
| |
| - RPV water level and pressure [from Control Room]
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - Emergency Condensate Storage Tank level [from Control Room]
| |
| - RHR and SW flow indications [from Control Room]
| |
| - HPCI flow, pressures, and turbine speed indication [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, None other discharge paths inboard of the MSIVs, and other system pressure boundaries. RPV over-pressure protection is provided by SRVs. Only the self-activated spring lift mode is credited for over-pressure protection. The HPCI system will be used to control RPV pressure and to maintain RPV level.
| |
| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
| |
| Page C-69
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descr~i[tion DG-A Diesel Generator Room 1A Vital Auxiliaries Mechanical: None
| |
| -REC will be supplied by Train B to provide the cooling supply to the ECCS.
| |
| -SW Train B will be operated to provide the cooling supply to the REC system and RHR Train B Heat Exchanger.
| |
| Electrical (AC/DC):
| |
| - Offsite Startup Transformer aligned to 4160V Bus 1G
| |
| - 125/250 VDC Train B is available HVAC:
| |
| - HPCI/CS Train B - Quad area cooling
| |
| - AC Switchgear Room 1G - Essential Control Building HVAC system
| |
| - DC Switchgear Room 1 B - Essential Control Building HVAC system
| |
| - Battery Room 1 B - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Room 1B - Essential Control Building HVAC system Reference Document I Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensing Actions None Page C-70
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion DG-A Diesel Generator Room 1A Existina Engineerina Eauivalency Evaluations (EEEE)
| |
| EEEE EE 09-035 - Evaluation of Fire Doors Purpose Fire door assemblies provided in fire-rated barriers may vary slightly from listed configurations, and may or may not provide the same fire rating as that required of the fire barrier. The evaluation documents the adequacy of the configurations that have been provided for fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and Rl15, and justifies the continued use of the configurations, as they have been determined to provide a level of protection that is adequate for the fire hazards in the areas.
| |
| " Door D202 separates the Cable Expansion Room (Fire Area CB-D) from Stair A-9 (Fire Area TB-A)
| |
| * Door H105 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Turbine Building Floor North (Fire Area TB-A) e Doors H200 and H201 separate the Cable Spreading Room (Fire Area CB-D) from Stair A-1 0 (Fire Area CB-A)
| |
| * Door H202 separates the Cable Spreading Room (Fire Area CB-D) from the Office Building Controlled Corridor (Fire Area TB-A) 9 Door H306 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Computer Room (Fire Area CB-D)
| |
| " Door H307 separates the Computer Room (Fire Area CB-D) from the I and C Shop (Fire Area TB-A)
| |
| " Door N103 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Turbine Building Mezzanine North (Fire Area TB-A) e Door N104 separates the Diesel Generator Room IA (Fire Area DG-A) from the Diesel Generator Room 1B (Fire Area DG-B) e Door R6 separates the Reactor Building Southeast Quad (Fire Area RB-CF) from the Suppression Pool Area (Fire Area RB-E) e Door R7 separates the Reactor Building Northwest Quad (Fire Area RB-B) from the Suppression Pool Area (Fire Area RB-E) e Doors R101 and R102 separate the Reactor Building 903' Northeast Corner (Fire Area RB-FN) from the Office Building Controlled Corridor (Fire Area TB-A)
| |
| * Door R1 15 separates Reactor Building 903'-6" CRD Units - South (Fire Area RB-DI) from the Exterior Transformer Yard (Fire Area YD)
| |
| Conclusion The fire door configurations (i.e., fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and R115) have been determined to provide a level of protection commensurate with the fire Page C-71
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area ecito DG-A Diesel Generator Room 1A hazards of the areas, and adequate separation has been provided. In general, minor variations to the configurations, such as conduit penetrations through the door frames, slightly larger gaps between doors and frames, and doors rated for less than that required of the barrier, have been evaluated as acceptable based on the fire hazards on either side of the barrier.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| e Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
| |
| * Fire hoses and portable extinguishers are strategically located throughout the plant for use by the responding fire brigade.
| |
| " Ventilation systems can typically be used for smoke and heat removal.
| |
| " Due to control of transient combustibles and ignition sources, door proximity to permanent combustibles, and fire area combustible loading, the majority of these doors will not be challenged by a credible fire. This effectively reduces the risk of the identified deviations.
| |
| e The automatic sprinkler system and smoke detection provided in the Cable Expansion Room (Fire Area CB-D) are credited for the acceptability of door D202.
| |
| * The automatic smoke detection systems provided in the Seal Water Pump Area and Corridor (Fire Area CB-A) and in the Turbine Building Floor North (Fire Area TB-A) are credited for the acceptability of door H105.
| |
| 9 The pre-action sprinkler system and automatic smoke detection provided in the Cable Spreading Room (Fire Area CB-D) are credited for the acceptability of doors H200 and H201.
| |
| e The automatic total flooding Halon 1301 suppression system and automatic smoke detection provided in the Computer Room (Fire Area CB-D) are credited for the acceptability of doors H306 and H307.
| |
| * The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1A (Fire Area DG-A) and the heat detection installed are credited for the acceptability of doors N103 and N104.
| |
| * The smoke and heat actuated devices provided in the Turbine Building Mezzanine (Fire Area TB-A) are credited for the acceptability of doors N103.
| |
| e The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1B (Fire Area DG-B) and the heat detection installed are credited for the acceptability of door N104.
| |
| 9 The automatic heat detection provided in the Reactor Building Northwest Quad (Fire Area RB-CF) is credited for the acceptability of door R6.
| |
| e The automatic heat detection provided in the Reactor Building Southeast Quad (Fire Area RB-B) is credited for the acceptability of door R7.
| |
| * The automatic suppression system provided in the Office Building Corridor (Fire Area TB-A) is credited for Page C-72
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area Descrintion DG-A Diesel Generator Room 1A the acceptability of doors R101 and R102.
| |
| * The automatic sprinkler system and smoke detection provided in the Reactor Building 903' Northeast Corner (Fire Area RB-FN) is credited for the acceptability of doors R101 and R102.
| |
| e The automatic deluge suppression system actuated by heat actuated devices provided for the yard transformers (Fire Area YD) are credited for the acceptability of door R1 15.
| |
| * Actuation of the detection systems will prompt rapid fire brigade response and subsequent manual extinguishment.
| |
| Variances from Deterministic Requirements (VFDR)
| |
| None Required Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression? L E R D Partial (P) SLERD 14A Detection Heat R N N N Y Y N 14A Detection Ionization R Y* N N Y Y* N 14A Suppression Automatic Total Flooding Carbon Dioxide F N/A N N Y Y* N 14C Detection Heat R Y N N N N N 14C Suppression Automatic Total Flooding Carbon Dioxide F N/A N N N N N Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Page C-73
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area DG-A Diesel Generator Room 1A Fire Suppression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. Per MWR 91-1264, electrical cabinets and conduit have been sealed to mitigate the effects of suppression activities. The drainage features and equipment pedestals mitigate the potential for flooding damage due to fire suppression, such that the standing water would not affect safety-related equipment.
| |
| In the event of normal operation, the carbon dioxide system will not adversely effect the other equipment operating within the Fire Zone as potential condensation developing on electrical components is a long term issue that would be eliminated by ventilating the compartment after actuation. Per drawing FH-16282, all carbon dioxide nozzles are located greater than five feet away from any equipment included in the PRA analysis, and therefore, the possibility of thermal shock due to carbon dioxide actuation has been deemed to be a non-issue in this Fire Area.
| |
| Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments
| |
| *Note: The total flooding carbon dioxide system in the Diesel Generator Room is automatic, however, the Risk Significance field in the "Required Fire Protection Systems and Features" Table for the total flooding carbon dioxide system credits a manual capability of the suppression system only.
| |
| Page C-74
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area DG-B Diesel Generator Room 1B Fire Zone Description 14B Diesel Generator Room 1B 14D DG2 Day Tank Room Reaulatorv Basis 4.2.3.2 - Deterministic Approach Performance Goal Method of Accomplishment Comments I VFDR Decay Heat Removal SPC Train A will be operated to maintain Suppression Pool temperature. None Process Monitoring The following indications will be used to support the Process Monitoring None function:
| |
| - RPV water level and pressure [from Control Room]
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - CS, SW, RHR flow indications, and REC pressure indication [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, None other discharge paths inboard of the MSIVs, and other system pressure boundaries. RPV over-pressure protection will be provided by SRVs. Only the self-activated spring lift mode is credited for over-pressure protection. ADS will be used to reduce RPV pressure for operation of Core Spray Train A to maintain RPV level.
| |
| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
| |
| Page C-75
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Nebraska Public Power District CNS NFPA 805 Transition Report Attachment C Table B-3 Fire Area Transition Fire Area DG-B Diesel Generator Room 1B Vital Auxiliaries Mechanical: None
| |
| -REC will be supplied by Train A to provide the cooling supply to the ECCS.
| |
| -SW Train A will be operated to provide the cooling supply to the REC system and the RHR Train A Heat Exchanger.
| |
| Electrical (AC/DC):
| |
| - Offsite Startup Transformer is aligned to 4160V Bus 1F
| |
| - 125/250 VDC Train A is available HVAC:
| |
| - RCIC/CS Train A - Quad area cooling
| |
| - AC Switchgear Room 1F - Essential Control Building HVAC system
| |
| - DC Switchgear Room 1A - Essential Control Building HVAC system
| |
| - Battery Rooms 1A - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Room IA - Essential Control Building HVAC system Reference Document / Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensina Actions None Page C-76
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Dsrito DG-B Diesel Generator Room 1 B Existina Enaineering Eguivalency Evaluations (EEEF)
| |
| EEE Tit EE 09-035 - Evaluation of Fire Doors Purpose Fire door assemblies provided in fire-rated barriers may vary slightly from listed configurations, and may or may not provide the same fire rating as that required of the fire barrier. The evaluation documents the adequacy of the configurations that have been provided for fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and R115, and justifies the continued use of the configurations, as they have been determined to provide a level of protection that is adequate for the fire hazards in the areas.
| |
| * Door D202 separates the Cable Expansion Room (Fire Area CB-D) from Stair A-9 (Fire Area TB-A)
| |
| " Door H105 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Turbine Building Floor North (Fire Area TB-A) 9 Doors H200 and H201 separate the Cable Spreading Room (Fire Area CB-D) from Stair A-10 (Fire Area CB-A)
| |
| * Door H202 separates the Cable Spreading Room (Fire Area CB-D) from the Office Building Controlled Corridor (Fire Area TB-A)
| |
| * Door H306 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Computer Room (Fire Area CB-D)
| |
| " Door H307 separates the Computer Room (Fire Area CB-D) from the I and C Shop (Fire Area TB-A)
| |
| " Door N103 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Turbine Building Mezzanine North (Fire Area TB-A) e Door N104 separates the Diesel Generator Room IA (Fire Area DG-A) from the Diesel Generator Room 1 B (Fire Area DG-B)
| |
| * Door R6 separates the Reactor Building Southeast Quad (Fire Area RB-CF) from the Suppression Pool Area (Fire Area RB-E) a Door R7 separates the Reactor Building Northwest Quad (Fire Area RB-B) from the Suppression Pool Area (Fire Area RB-E) 9 Doors R101 and R102 separate the Reactor Building 903' Northeast Corner (Fire Area RB-FN) from the Office Building Controlled Corridor (Fire Area TB-A)
| |
| * Door R1 15 separates Reactor Building 903'-6" CRD Units - South (Fire Area RB-DI) from the Exterior Transformer Yard (Fire Area YD)
| |
| Conclusion The fire door configurations (i.e., fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and R1 15) have been determined to provide a level of protection commensurate with the fire Page C-77
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Description DG-B Diesel Generator Room 1 B hazards of the areas, and adequate separation has been provided. In general, minor variations to the configurations, such as conduit penetrations through the door frames, slightly larger gaps between doors and frames, and doors rated for less than that required of the barrier, have been evaluated as acceptable based on the fire hazards on either side of the barrier.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| e Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
| |
| e Fire hoses and portable extinguishers are strategically located throughout the plant for use by the responding fire brigade.
| |
| " Ventilation systems can typically be used for smoke and heat removal.
| |
| " Due to control of transient combustibles and ignition sources, door proximity to permanent combustibles, and fire area combustible loading, the majority of these doors will not be challenged by a credible fire. This effectively reduces the risk of the identified deviations.
| |
| e The automatic sprinkler system and smoke detection provided in the Cable Expansion Room (Fire Area CB-D) are credited for the acceptability of door D202.
| |
| * The automatic smoke detection systems provided in the Seal Water Pump Area and Corridor (Fire Area CB-A) and in the Turbine Building Floor North (Fire Area TB-A) are credited for the acceptability of door H105.
| |
| * The pre-action sprinkler system and automatic smoke detection provided in the Cable Spreading Room (Fire Area CB-D) are credited for the acceptability of doors H200 and H201.
| |
| * The automatic total flooding Halon 1301 suppression system and automatic smoke detection provided in the Computer Room (Fire Area CB-D) are credited for the acceptability of doors H306 and H307.
| |
| * The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1A (Fire Area DG-A) and the heat detection installed are credited for the acceptability of doors N103 and N104.
| |
| e The smoke and heat actuated devices provided in the Turbine Building Mezzanine (Fire Area TB-A) are credited for the acceptability of doors N103.
| |
| 9 The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1 B (Fire Area DG-B) and the heat detection installed are credited for the acceptability of door N104.
| |
| 9 The automatic heat detection provided in the Reactor Building Northwest Quad (Fire Area RB-CF) is credited for the acceptability of door R6.
| |
| e The automatic heat detection provided in the Reactor Building Southeast Quad (Fire Area RB-B) is credited for the acceptability of door R7.
| |
| * The automatic suppression system provided in the Office Building Corridor (Fire Area TB-A) is credited for Page C-78
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area DG-B Diesel Generator Room 1 B the acceptability of doors R101 and R102.
| |
| o The automatic sprinkler system and smoke detection provided in the Reactor Building 903' Northeast Corner (Fire Area RB-FN) is credited for the acceptability of doors R101 and R102.
| |
| o The automatic deluge suppression system actuated by heat actuated devices provided for the yard transformers (Fire Area YD) are credited for the acceptability of door R1 15.
| |
| o Actuation of the detection systems will prompt rapid fire brigade response and subsequent manual extinguishment.
| |
| Variances from Deterministic Reauirements (VFDR)
| |
| None Required Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?
| |
| ,_Partial (P) _ _L S E R ID 14B Detection Heat R N N N Y Y N 14B Detection Ionization R Y* N N Y Y* N 14B Suppression Automatic Total Flooding Carbon Dioxide F N/A N N Y Y* N 14D Detection Heat R Y N N N N N 14D Suppression Automatic Total Flooding Carbon Dioxide F N/A N N N N N Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Page C-79
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion DG-B Diesel Generator Room 1 B Fire Suppression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. Per MWR 91-1264, electrical cabinets and conduit have been sealed to mitigate the effects of suppression activities. The drainage features and equipment pedestals mitigate the potential for flooding damage due to fire suppression, such that the standing water would not affect safety-related equipment.
| |
| In the event of normal operation, the carbon dioxide system will not adversely effect the other equipment operating within the Fire Zone as potential condensation developing on electrical components is a long term issue that would be eliminated by ventilating the compartment after actuation. Per drawing FH-16282, all carbon dioxide nozzles are located greater than five feet away from any equipment included in the PRA analysis and therefore, the possibility of thermal shock due to carbon dioxide actuation has been deemed to be a non-issue in this Fire Area. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments
| |
| *Note: The total flooding carbon dioxide system in the Diesel Generator Room is automatic, however, the Risk Significance field in the "Required Fire Protection Systems and Features" Table for the total flooding carbon dioxide system credits a manual capability of the suppression system only.
| |
| Page C-80
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Descrintfion IS-A Intake Structure Fire Zone Description 20A Service Water Pump Area 20B Circulating Water Pump and Traveling Screen Area Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments / VFDR Decay Heat Removal SPC Train A or B will be operated to maintain Suppression Pool temperature. ISA-01 ISA-02 ISA-03 Process Monitoring The following indications will be used to support the Process Monitoring None function:
| |
| - RPV water level and pressure [from Control Room]
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - CS, SW, RHR flow indications, and REC pressure indication [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, ISA-01 other discharge paths inboard of the MSIVs, and other system pressure ISA-02 boundaries. RPV over-pressure protection will be provided by SRVs. Only the ISA-03 self-activated spring lift mode is credited for over-pressure protection. ADS will be used to reduce RPV pressure for operation of either Core Spray Train A or Train B to maintain RPV level.
| |
| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
| |
| Page C-81
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire AreaDecito IS-A Intake Structure Vital Auxiliaries Mechanical: ISA-01
| |
| -REC Train A or Bwill be operated to provide the cooling supply to ECCS. ISA-02
| |
| -SW Train A or B will be operated to provide the cooling supply to REC and the ISA-03 RHR Train A or B Heat Exchanger based on available SW pumps.
| |
| Electrical (AC/DC):
| |
| - Offsite Emergency Transformer is aligned to 4160V Bus 1IF and 1G
| |
| - 125/250 VDC Train A and B is available HVAC:
| |
| - HPCI/RCIC/CS Trains A and B - Quad area cooling
| |
| - AC Switchgear Rooms - Essential Control Building HVAC system
| |
| - DC Switchgear Rooms - Essential Control Building HVAC system
| |
| - Battery Rooms - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Rooms - Essential Control Building HVAC system Reference Document / Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensing Actions None Existing Engineering Eguivalency Evaluations (EEEE)
| |
| None Page C-82
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area Description IS-A Intake Structure Variances from Deterministic Reauirements (VFDRI Description Preventing flow diversion from reducing the effectiveness of SW for cooling plants loads with only one SW pump operating (SW-MOV-36MV and SW-MOV-37MV).
| |
| SW Train A and B are required to support various functions (SPC, HPCI and CS Quad cooling, REC, DGs, etc) for NSPC. CS is credited for Inventory Control, SPC is credited for Decay Heat Removal, REC provides cooling for RHR Pumps and the HPCI, RCIC, RHR and CS Pump Rooms (Quads), and SW provides the cooling for REC and RHR Heat Exchangers (DGs not credited). The diversion could challenge these NSPCs during single SW pump operation.
| |
| Fire in the area could result in physical damage to component cabling and result in the spurious opening without the ability to remotely close either or both valves. These valves support the SW system supply side cross connection and non-vital load isolation.
| |
| This is a separation issue for Inventory and Pressure Control, Vital Auxiliaries, and Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-83
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area ecotn IS-A Intake Structure ISA-02 Description Preventing a full or partial loss of SW for supporting Decay Heat Removal and Inventory and Pressure Control (SW-STNR-A and SW-STNR-B).
| |
| SW Train A and B are required to support various functions (SPC, HPCI and CS Quad cooling, REC, DGs, etc) for NSPC. CS is credited for Inventory Control, SPC is credited for Decay Heat Removal, REC provides cooling for RHR Pumps and the HPCI, RCIC, RHR, and CS Pump Rooms (Quads), and SW provides the cooling for REC and RHR Heat Exchangers (DGs not credited). The complete loss or diversion of SW could challenge these NSPCs.
| |
| Fire in the area could result in physical damage to component cabling. Based on size of the structure and physical location within the structure, at least one Train would be available.
| |
| All SW Pumps and Strainers are located in Fire Zone 20A and at least one pump and strainer is required to achieve the NSPC function.
| |
| Quad cooling via REC is required to support CS. Quad heat up due to fire location in Fire Area IS-A is not credible. However, even if cooling is not required to the Quad, cooling to the RHR Heat Exchanger is still required for supporting SPC mode of operation. SW Train A and B may be credited to support various functions for NSPC depending on location of fire.
| |
| Cable damage to MTX1 (SW Strainer B) or MLX29 (SW Strainer A) results in a loss of the automatic features of the SW Train B and A Strainer. The loss of the automatic features could result in the clogging of the strainer resulting in a complete loss of SW flow.
| |
| This is a separation issue for Inventory and Pressure Control, Vital Auxiliaries, and Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-84
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area Dfl+/-QU IS-A Intake Structure ISA-03 Description Preventing a full or partial loss of SW for supporting Decay Heat Removal and Inventory and Pressure Control. (SW Pump A and SW Pump D).
| |
| SW Trains A and B are required to support various functions (SPC, HPCI and CS Quad cooling, REC, DGs, etc) for NSPC. CS is credited for Inventory Control, SPC is credited for Decay Heat Removal, REC provides cooling for RHR Pumps and the HPCI, RCIC, RHR, and CS Pump Rooms (Quads), and SW provides the cooling for REC and RHR Heat Exchangers (DGs not credited). The complete loss or diversion of SW could challenge these NSPC. Fire in the area could result in physical damage to component cabling. Based on size of the structure and physical location within the structure at least one Train would be available.
| |
| All SW Pumps and Strainers are located in Fire Zone 20A and at least one pump and strainer is required to achieve the NSPC function. Quad cooling via REC is required to support CS. Quad heat up due to fire location in Fire Area IS-A is not credible. However, even if cooling not required to the Quad, cooling to the RHR Heat Exchanger is still required for supporting SPC mode of operation. SW Train A and B may be credited to support various functions for NSPC depending on location of fire.
| |
| Cable damage to H401 (SW Pump A) or H531 (SW Pump D) results in a loss of power to the SW Pumps A or D. The loss of power to both would result in a complete loss of SW flow.
| |
| This is an issue for Inventory and Pressure Control and Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-85
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area IS-A Intake Structure Required Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?
| |
| Partial (P) _D S !L E R 20A Detection Thermal Heat R Y N N N Y N 20A Detection Ionization R Y N N N Y N 20A Detection Flame R N N N N N N 20A Suppression Total Flooding Halon 1301 F N/A N N N Y N 20B None N/A N/A N/A N/A N/A N/A N/A N/A Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Fire Sunoression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. Per MWR 91-1264, electrical cabinets and conduit have been sealed to mitigate the effects of suppression activities. In the event of normal operation, the Halon system will not adversely effect the other equipment operating within the Fire Zone as potential corrosion developing on equipment is a long term issue that would be significantly reduced by extensive post-discharge clean up. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments None Page C-86
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion RB-A RCIC and Core Spray Pump Room Fire Zone Description 1A RCIC and Core Spray Pump Room Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments / VFDR Decay Heat Removal SPC Train B will be operated to maintain Suppression Pool temperature. RBA-03 Process Monitoring The following indications will be used to support the Process Monitoring RBA-01 function:
| |
| - RPV water level and pressure [from Control Room]
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - CS, SW, RHR flow indications, and REC pressure indication [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, None other discharge paths inboard of the MSIVs, and other system pressure boundaries. RPV over-pressure protection will be provided by SRVs. Only the self-activated spring lift mode is credited for over-pressure protection. ADS will be used to reduce RPV pressure for operation of Core Spray Train B to maintain RPV level.
| |
| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
| |
| Page C-87
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Nebraska Public Power District CNS NFPA 805 Transition Report Attachment C Table B-3 Fire Area Transition Fore Area RB-A RCIC and Core Spray Pump Room Vital Auxiliaries Mechanical: RBA-02
| |
| -REC will be supplied by Train B to provide the cooling supply to the ECCS.
| |
| -SW Train B will be operated to provide the cooling supply to the REC system and RHR Heat Exchangers.
| |
| Electrical (AC/DC):
| |
| - Offsite Emergency Transformer aligned to 4160V Bus 1G
| |
| - 125/250 VDC Train B is available HVAC:
| |
| - CS Train B - Quad area cooling
| |
| - AC Switchgear Room 1G - Essential Control Building HVAC system
| |
| - DC Switchgear Room 1 B - Essential Control Building HVAC system
| |
| - Battery Rooms 1 B - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Room 1B - Essential Control Building HVAC system Reference Document / Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensina Actions None Existina Enaineerina Eauivalency Evaluations (EEEE)
| |
| None Page C-88
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area RB-A RCIC and Core Spray Pump Room Variances from Deterministic Reauirements IVFDR)
| |
| Description Ability to monitor temperatures (Torus water) for SPC mode of operation of Decay Heat Removal (PC-TR-24).
| |
| The indication cable from Junction Box 307 to the Foxboro rack is damaged for all temperature indicators (1A-1H and 2A-2F), resulting in a loss of Torus water temperature indication in the Control Room. Loss of indication would result in the loss of ability to monitor Suppression Pool temperature for monitoring containment pressure as well as NPSH for the RHR pumps which take suction off the Suppression Pool.
| |
| This is a separation issue related to Process Monitoring.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-89
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area RB-A RCIC and Core Spray Pump Room Description Preventing a loss of SW cooling flow to the credited REC Heat Exchanger (SW-AOV-TCV451 B).
| |
| SW Train B is required to support various functions (SPC, HPCI and CS Quad cooling, REC, DGs, etc) for NSPC.
| |
| The NSPC require a means of maintaining and controlling RPV water inventory post-fire. CS Train B is the credited train. SW-AOV-TCV451 B controls the outlet flow from REC Heat Exchanger B. REC Train B is the credited train for supporting RHR Pump cooling, the credited RHR Pump for SPC, and Quad cooling for the RHR Pump and CS Pump Rooms. Cable damage to M923 could result in SW-AOV-TCV451B remaining energized, essentially locking the valve in the closed position, securing flow through the Heat Exchanger. Cable M923 is routed in a dedicated conduit in this area. If the valve fails to open, this causes a no-flow condition for SW through the credited REC Heat Exchanger, removing the REC ability to cool the credited RHR Pump for SPC and Quad cooling for the RHR and CS Pumps.
| |
| This is a separation issue for Vital Auxiliaries.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable - Recovery Action carried forward as Defense-in-Depth.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-90
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Description RB-A RCIC and Core Spray Pump Room RBA-03 Description Preventing a loss of SW cooling flow to credited RHR Heat Exchanger or damage to RHRSW Booster Pumps due to run out (SW-MOV-MO89B).
| |
| SW Train B is required to support various functions (SPC, HPCI and CS Quad cooling, REC, DGs, etc) for NSPC. SPC Train B is the credited train of Decay Heat Removal. The valve is normally closed and cable damage to M923 may cause the valve to spuriously open, or not allow it to open electrically. If the valve fully opens with the RHRSW Booster Pump operating, this may cause the pump to run out, damaging the pump. Ifthe valve fails to open, this causes a no-flow condition for SW through the credited RHR Heat Exchanger, removing the ability to cool the credited SPC Train B for Decay Heat Removal.
| |
| This is a separation issue for Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable - Recovery Action carried forward as Defense-in-Depth.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-91
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrioon RB-A RCIC and Core Spray Pump Room Req*uired Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?-
| |
| Partial (P) S L E R D 1A Detection Heat R N N N N Y N Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Fire Suporession Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. Per MWR 91-1264, electrical cabinets and conduit have been sealed to mitigate the effects of suppression activities. The drainage features and equipment pedestals mitigate the potential for flooding damage due to fire suppression, such that the standing water would not affect safety-related equipment. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments None Page C-92
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Nebraska Public Power District CNS NFPA 805 Transition Report Attachment C Table B-3 Fire Area Transition Fire Area RB-B Reactor Building South East Quad Fire Zone Descriotion 1B Core Spray Pump Room 1G Control Rod Drive Pump Area Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomolishment Comments / VFDR Decay Heat Removal SPC Train A or B will be operated to maintain Suppression Pool temperature. RBB-0 1 Process Monitoring The following indications will be used to support the Process Monitoring None function:
| |
| - RPV water level and pressure [from Control Room]
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - CS, SW, RHR flow indications, and REC pressure indication [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, None other discharge paths inboard of the MSIVs, and other system pressure boundaries. RPV over-pressure protection will be provided by SRVs. Only the self-activated spring lift mode is credited for over-pressure protection. ADS will be used to reduce RPV pressure for operation of Core Spray Train A to maintain RPV level.
| |
| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
| |
| Page C-93
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Nebraska Public Power District CNS NFPA 805 Transition Report Attachment C Table B-3 Fire Area Transition Fore Area Descrition RB-B Reactor Building South East Quad Vital Auxiliaries Mechanical: None
| |
| -REC Train A or B will be operated to provide the cooling supply to the ECCS.
| |
| -SW Train A or B will be operated to provide the cooling supply to the REC system and RHR Train A or B Heat Exchanger based on available SW Pump.
| |
| Electrical (AC/DC):
| |
| - Offsite Emergency Transformer aligned to 4160V Bus 1F or 1 G
| |
| - 125/250 VDC Train A and B is available HVAC:
| |
| - RCIC/CS Trains A and B - Quad area cooling
| |
| - AC Switchgear Rooms - Essential Control Building HVAC system
| |
| - DC Switchgear Rooms - Essential Control Building HVAC system
| |
| - Battery Rooms - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Rooms - Essential Control Building HVAC system Reference Document / Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensing Actions None Page C-94
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion RB-B Reactor Building South East Quad Existinr Enaineering Eguivalency Evaluations (EEEE)
| |
| EEEE Tile EE 09-035 - Evaluation of Fire Doors Purpose Fire door assemblies provided in fire-rated barriers may vary slightly from listed configurations, and may or may not provide the same fire rating as that required of the fire barrier. The evaluation documents the adequacy of the configurations that have been provided for fire doors D202, H105, H200, H201, H202, H306, H307, N1 03, N1 04, R6, R7, R1 01, R1 02, and R1 15, and justifies the continued use of the configurations, as they have been determined to provide a level of protection that is adequate for the fire hazards in the areas.
| |
| " Door D202 separates the Cable Expansion Room (Fire Area CB-D) from Stair A-9 (Fire Area TB-A)
| |
| " Door H105 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Turbine Building Floor North (Fire Area TB-A) e Doors H200 and H201 separate the Cable Spreading Room (Fire Area CB-D) from Stair A-10 (Fire Area CB-A)
| |
| * Door H202 separates the Cable Spreading Room (Fire Area CB-D) from the Office Building Controlled Corridor (Fire Area TB-A) 9 Door H306 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Computer Room (Fire Area CB-D)
| |
| " Door H307 separates the Computer Room (Fire Area CB-D) from the I and C Shop (Fire Area TB-A)
| |
| " Door N103 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Turbine Building Mezzanine North (Fire Area TB-A)
| |
| * Door N104 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Diesel Generator Room 1B (Fire Area DG-B) e Door R6 separates the Reactor Building Southeast Quad (Fire Area RB-CF) from the Suppression Pool Area (Fire Area RB-E)
| |
| * Door R7 separates the Reactor Building Northwest Quad (Fire Area RB-B) from the Suppression Pool Area (Fire Area RB-E)
| |
| * Doors R101 and R102 separate the Reactor Building 903' Northeast Corner (Fire Area RB-FN) from the Office Building Controlled Corridor (Fire Area TB-A)
| |
| * Door R1 15 separates Reactor Building 903'-6" CRD Units - South (Fire Area RB-DI) from the Exterior Transformer Yard (Fire Area YD)
| |
| Conclusion The fire door configurations (i.e., fire.doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and R1 15) have been determined to provide a level of protection commensurate with the fire Page C-95
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area De n RB-B Reactor Building South East Quad hazards of the areas, and adequate separation has been provided. In general, minor variations to the configurations, such as conduit penetrations through the door frames, slightly larger gaps between doors and frames, and doors rated for less than that required of the barrier, have been evaluated as acceptable based on the fire hazards on either side of the barrier.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| 9 Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
| |
| 9 Fire hoses and portable extinguishers are strategically located throughout the plant for use by the responding fire brigade.
| |
| * Ventilation systems can typically be used for smoke and heat removal.
| |
| " Due to control of transient combustibles and ignition sources, door proximity to permanent combustibles, and fire area combustible loading, the majority of these doors will not be challenged by a credible fire. This effectively reduces the risk of the identified deviations.
| |
| e The automatic sprinkler system and smoke detection provided in the Cable Expansion Room (Fire Area CB-D) are credited for the acceptability of door D202.
| |
| o The automatic smoke detection systems provided in the Seal Water Pump Area and Corridor (Fire Area CB-A) and in the Turbine Building Floor North (Fire Area TB-A) are credited for the acceptability of door H105.
| |
| 9 The pre-action sprinkler system and automatic smoke detection provided in the Cable Spreading Room (Fire Area CB-D) are credited for the acceptability of doors H200 and H201.
| |
| * The automatic total flooding Halon 1301 suppression system and automatic smoke detection provided in the Computer Room (Fire Area CB-D) are credited for the acceptability of doors H306 and H307.
| |
| * The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1A (Fire Area DG-A) and the heat detection installed are credited for the acceptability of doors N103 and N104.
| |
| e The smoke and heat actuated devices provided in the Turbine Building Mezzanine (Fire Area TB-A) are credited for the acceptability of doors N103.
| |
| e The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1 B (Fire Area DG-B) and the heat detection installed are credited for the acceptability of door N104.
| |
| * The automatic heat detection provided in the Reactor Building Northwest Quad (Fire Area RB-CF) is credited for the acceptability of door R6.
| |
| 9 The automatic heat detection provided in the Reactor Building Southeast Quad (Fire Area RB-B) is credited for the acceptability of door R7.
| |
| * The automatic suppression system provided in the Office Building Corridor (Fire Area TB-A) is credited for Page C-96
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area D RB-B Reactor Building South East Quad the acceptability of doors R101 and R102.
| |
| e The automatic sprinkler system and smoke detection provided in the Reactor Building 903' Northeast Corner (Fire Area RB-FN) is credited for the acceptability of doors R1 01 and R1 02.
| |
| 9 The automatic deluge suppression system actuated by heat actuated devices provided for the yard transformers (Fire Area YD) are credited for the acceptability of door R1 15.
| |
| e Actuation of the detection systems will prompt rapid fire brigade response and subsequent manual extinguishment.
| |
| Variances from Deterministic Reguirements WVFDR)
| |
| RBB-01 Description Preventing loss of containment over-pressure in support of RHR Pump operation for SPC operation (PC-AOV-245AV).
| |
| The NSPC require a means of Decay Heat Removal (SPC Train A) post-fire. Both PC-AOV-245AV and PC-MOV-230MV cables are affected by the fire and may spuriously open. These valves isolate the Vent and Purge path from the Suppression Chamber and would result in a loss of containment over-pressure.
| |
| SPC Train A is credited for Decay Heat Removal. The loss of containment over-pressure could result in the loss of NPSH for the credited RHR Pump during the SPC mode of operation.
| |
| This is a separation issue for Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable - Recovery Action carried forward as Defense-in-Depth.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-97
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Descrip~tion RB-B Reactor Building South East Quad Reguired Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?
| |
| ,_Partial (P) S L E R D 1B Detection Heat R N N N Y Y N 1G Detection Heat R N N N Y Y N Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Fire SuDnression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. Per MWR 91-1264, electrical cabinets and conduit have been sealed to mitigate the effects of suppression activities. The drainage features and equipment pedestals mitigate the potential for flooding damage due to fire suppression, such that the standing water would not affect safety-related equipment. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments None Page C-98
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area ecato RB-CF Reactor Building Northwest Quad, Reactor Building 903 North Area and South Corridor, RHR Heat Exchanger Room A Fire Zone Descrioltion 1C RHR Pump Room 1A and 1C 2A-2 CRD Units - North 2A-3 903' South Corridor 2B RHR Heat Exchanger Room A Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments / VFDR Decay Heat Removal SPC Train B will be operated to maintain Suppression Pool temperature. RBCF-05 RBCF-06 RBCF-07 RBCF-09 RBCF-10 Process Monitoring The following indications will be used to support the Process Monitoring function: None
| |
| - RPV water level and pressure [from Control Room]
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - CS, RHR, and SW flow indications [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, RBCF-01 other discharge paths inboard of the MSIVs, and other system pressure RBCF-02 boundaries. RPV over-pressure protection will be provided by SRVs. Only the RBCF-03 self-activated spring lift mode is credited for over-pressure protection. ADS will RBCF-04 be used to reduce RPV pressure for operation of Core Spray Train B to RBCF-08 maintain RPV level. RBCF-09 Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
| |
| Page C-99
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire AreaDecito RB-CF Reactor Building Northwest Quad, Reactor Building 903 North Area and South Corridor, RHR Heat Exchanger Room A Vital Auxiliaries Mechanical: RBCF-1 1
| |
| - REC will be supplied by SW Train B to provide the cooling supply to the ECCS.
| |
| - SW Train B will be operated to provide the cooling supply to the REC system and RHR Heat Exchangers.
| |
| Electrical (AC/DC):
| |
| - Offsite Emergency Transformer aligned to 4160G Bus
| |
| - 125/250 VDC Train B is available HVAC:
| |
| - DG/CS Train B - Quad area cooling
| |
| - DG 2 HVAC system
| |
| - AC Switchgear Room 1 G - Essential Control Building HVAC system
| |
| - DC Switchgear Room 1 B - Essential Control Building HVAC system
| |
| - Battery Room 1B - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Room 1 B - Essential Control Building HVAC system Reference Document / Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensina Actions None Page C-100
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore AreaDecito RB-CF Reactor Building Northwest Quad, Reactor Building 903 North Area and South Corridor, RHR Heat Exchanger Room A Existinq Enaineering Eguivalency Evaluations (EEEE)
| |
| EEEE EE 09-035 - Evaluation of Fire Doors Purpose Fire door assemblies provided in fire-rated barriers may vary slightly from listed configurations, and may or may not provide the same fire rating as that required of the fire barrier. The evaluation documents the adequacy of the configurations that have been provided for fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and R115, and justifies the continued use of the configurations, as they have been determined to provide a level of protection that is adequate for the fire hazards in the areas.
| |
| " Door D202 separates the Cable Expansion Room (Fire Area CB-D) from Stair A-9 (Fire Area TB-A)
| |
| " Door H105 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Turbine Building Floor North (Fire Area TB-A) e Doors H200 and H201 separate the Cable Spreading Room (Fire Area CB-D) from Stair A-10 (Fire Area CB-A)
| |
| * Door H202 separates the Cable Spreading Room (Fire Area CB-D) from the Office Building Controlled Corridor (Fire Area TB-A)
| |
| * Door H306 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Computer Room (Fire Area CB-D)
| |
| " Door H307 separates the Computer Room (Fire Area CB-D) from the I and C Shop (Fire Area TB-A)
| |
| " Door N103 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Turbine Building Mezzanine North (Fire Area TB-A)
| |
| * Door N104 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Diesel Generator Room 1B (Fire Area DG-B)
| |
| * Door R6 separates the Reactor Building Southeast Quad (Fire Area RB-CF) from the Suppression Pool Area (Fire Area RB-E) e Door R7 separates the Reactor Building Northwest Quad (Fire Area RB-B) from the Suppression Pool Area (Fire Area RB-E) 9 Doors R101 and R102 separate the Reactor Building 903' Northeast Corner (Fire Area RB-FN) from the Office Building Controlled Corridor (Fire Area TB-A)
| |
| * Door R1 15 separates Reactor Building 903'-6" CRD Units - South (Fire Area RB-DI) from the Exterior Transformer Yard (Fire Area YD)
| |
| Conclusion The fire door configurations (i.e., fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, Page C-101
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area ecito RB-CF Reactor Building Northwest Quad, Reactor Building 903 North Area and South Corridor, RHR Heat Exchanger Room A R7, R101, R102, and R115) have been determined to provide a level of protection commensurate with the fire hazards of the areas, and adequate separation has been provided. In general, minor variations to the configurations, such as conduit penetrations through the door frames, slightly larger gaps between doors and frames, and doors rated for less than that required of the barrier, have been evaluated as acceptable based on the fire hazards on either side of the barrier.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| o Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
| |
| * Fire hoses and portable extinguishers are strategically located throughout the plant for use by the responding fire brigade.
| |
| " Ventilation systems can typically be used for smoke and heat removal.
| |
| * Due to control of transient combustibles and ignition sources, door proximity to permanent combustibles, and fire area combustible loading, the majority of these doors will not be challenged by a credible fire. This effectively reduces the risk of the identified deviations.
| |
| 9 The automatic sprinkler system and smoke detection provided in the Cable Expansion Room (Fire Area CB-D) are credited for the acceptability of door D202.
| |
| o The automatic smoke detection systems provided in the Seal Water Pump Area and Corridor (Fire Area CB-A) and in the Turbine Building Floor North (Fire Area TB-A) are credited for the acceptability of door H105.
| |
| 9 The pre-action sprinkler system and automatic smoke detection provided in the Cable Spreading Room (Fire Area CB-D) are credited for the acceptability of doors H200 and H201.
| |
| e The automatic total flooding Halon 1301 suppression system and automatic smoke detection provided in the Computer Room (Fire Area CB-D) are credited for the acceptability of doors H306 and H307.
| |
| o The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1A (Fire Area DG-A) and the heat detection installed are credited for the acceptability of doors N103 and N104.
| |
| 9 The smoke and heat actuated devices provided in the Turbine Building Mezzanine (Fire Area TB-A) are credited for the acceptability of doors N103.
| |
| e The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1 B (Fire Area DG-B) and the heat detection installed are credited for the acceptability of door N104.
| |
| * The automatic heat detection provided in the Reactor Building Northwest Quad (Fire Area RB-CF) is credited for the acceptability of door R6.
| |
| o The automatic heat detection provided in the Reactor Building Southeast Quad (Fire Area RB-B) is credited Page C-102
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area ecmfo RB-CF Reactor Building Northwest Quad, Reactor Building 903 North Area and South Corridor, RHR Heat Exchanger Room A for the acceptability of door R7.
| |
| e The automatic suppression system provided in the Office Building Corridor (Fire Area TB-A) is credited for the acceptability of doors R101 and R102.
| |
| * The automatic sprinkler system and smoke detection provided in the Reactor Building 903' Northeast Corner (Fire Area RB-FN) is credited for the acceptability of doors R101 and R102.
| |
| e The automatic deluge suppression system actuated by heat actuated devices provided for the yard transformers (Fire Area YD) are credited for the acceptability of door R1 15.
| |
| * Actuation of the detection systems will prompt rapid fire brigade response and subsequent manual extinguishment.
| |
| Page C-103
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area Dul2n RB-CF Reactor Building Northwest Quad, Reactor Building 903 North Area and South Corridor, RHR Heat Exchanger Room A Variances from Deterministic Reauirements (VFDR)
| |
| Description Loss of RPV water inventory to Reactor Building Sumps and Radwaste (CRD-SOV-SO31A and CRD-SOV-SO31 B).
| |
| The NSCA require a means of isolating the RPV post-fire to ensure sufficient water inventory. Cable damage may result in the spurious opening of CRD-SOV-SO31A and CRD-SOV-SO31 B. This opening of the CRD Scram Discharge Volume Vent and Drain Valve SOVs would result in loss of RPV Inventory to the Reactor Building Sumps and then to Radwaste. Based on CNS-PSA-007, the CRD seal leakage flow rate is assumed to be 450 to 600 gpm initially, reducing to 73 gpm after 70 minutes, and down to 40 gpm after 4 hours, based on all CRD seals leaking at the same time at the maximum amount prior to repair.
| |
| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-104
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area RB-CF Reactor Building Northwest Quad, Reactor Building 903 North Area and South Corridor, RHR Heat Exchanger Room A RBCF-02 Description Preventing a RR Pump Seal LOCA due to inability to secure the RR Pump from the Control Room with the REC Non-Critical Header secured (RR Pump Breaker for 4160C-1 CS).
| |
| Breaker F/FDR to the 4160V Bus from the Startup Transformer: This is a normally available, required open breaker that provides motive power to the RR Pump A. The RR Pumps are required to trip to prevent a potential RR Pump Seal LOCA when REC is not available to provide cooling. This would challenge the NSPC for Inventory Control. Remote operation of the breaker from the Control Room is lost due to cable, H254 (1C Bus) having fire-induced damage.
| |
| NOTE: REC Non-Critical Header is secured in this fire area to address potential containment over-pressure.
| |
| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-105
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area 2 ron RB-CF Reactor Building Northwest Quad, Reactor Building 903 North Area and South Corridor, RHR Heat Exchanger Room A Description Preventing an RPV Overfill due to the inability to close the inboard or outboard steam supply valves to the HPCI Turbine (HPCI-MOV-MO14-Passive and HPCI-MOV-MO16).
| |
| HPCI-MOV-MO14, M015, and M016 are all impacted by fire in this area.
| |
| Spurious opening of the HPCI-MOV-MO16 (HPCI Steam Admission Valve) due to cable damage on HP185 would result in rapid RPV overfill condition. This VFDR concern is limited to fires occurring at RB 903' Elevation. HPCI is not credited in this area for NSCA success. Core Spray Train B is available automatically.
| |
| Cable damage to DC190 and DC191 can cause HPCI-MOV-MO16 to not be able to be closed from the Control Room. This failure would result in the rapid RPV overfill condition if HPCI-MOV-MOV14 spuriously opens. This VFDR concern is limited to fires occurring at Reactor Building 859' and 881' Elevations. HPCI is not credited in this area for NSCA success. Core Spray Train B is available automatically.
| |
| This is a separation issue in isolating the RPV for Inventory and Pressure Control.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-106
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area RB-CF Reactor Building Northwest Quad, Reactor Building 903 North Area and South Corridor, RHR Heat Exchanger Room A RBCF-04 Description Ability to close SRVs automatically/remotely from the Control Room could be lost due to cable fire damage (Pilot Valves SPV71A, SPV71B, SPV71C, and SPV71D).
| |
| The NSPC require the ability to isolate the RPV to maintain water inventory above the active fuel.
| |
| Spurious operations could result in the opening of up to four ADS valves. The NSPC could be challanged if the affected ADS valves are not returned to their fail-safe closed position within 18 minutes for single spurious operation.
| |
| NOTE: Cables causing spurious operations are only impacted during Fire Zones 2A-2 and 2A-3 full zone burn out.
| |
| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-107
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area Dsrlto RB-CF Reactor Building Northwest Quad, Reactor Building 903 North Area and South Corridor, RHR Heat Exchanger Room A RBCF-05 Description Preventing loss of containment over-pressure in support of RHR Pump operation for SPC operation (PC-MOV-231 MV, RW-AOV-AO82, and RW-AOV-AO94).
| |
| NSPC require a means of Decay Heat Removal post-fire. SPC Train B is credited for Decay Heat Removal. The loss of containment over-pressure could result in the loss of NPSH for the credited RHR pump during SPC mode of operation.
| |
| Both PC-AOV-AO246 and PC-MOV-231 MV cables are affected by the fire and may spuriously open.
| |
| These valves isolate the Vent and Purge path from the Drywell, and would result in a loss of containment over-pressure.
| |
| RW-AOV-AO82, RW-AOV-AO83, RW-AOV-AO94, and RW-AOV-AO95 cables are all affected by the fire, and may spuriously open. These valves isolate the Drywell Equipment and Floor Drain Sump discharge paths and would result in a loss of containment over-pressure.
| |
| This is a separation issue for Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable - Recovery Action carried forward as Defense-in-Depth.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-108
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descriotion RB-CF Reactor Building Northwest Quad, Reactor Building 903 North Area and South Corridor, RHR Heat Exchanger Room A R1BCF-06 Description Preventing damage to credited RHR pump / loss of Decay Heat Removal due to spurious closure of the minimum flow recirculation line for RHR Train B (RHR-MOV-MO16B).
| |
| RHR-MOV-MO16B could spuriously close based on equipment and cable failures. The NSPC require a means of Decay Heat Removal post-fire. RHR Train B is credited to support SPC mode of RHR following a fire in this area. Failures associated with RHR-Logic-B may result in spurious starting of RHR Pump 1 D.
| |
| Spurious closure of RHR-MOV-MO16 concurrent with a running RHR Pump (1D) would result in potential pump damage due to overheating, and loss of SPC Train B.
| |
| This is a separation issue for Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable - Recovery Action carried forward as Defense-in-Depth.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None RBCF-07 Description Preventing flow diversion during SPC mode of RHR for Decay Heat Removal (RHR-MOV-M020-Passive and RHR-MOV-MO27B).
| |
| The NSPC require a means of Decay Heat Removal post-fire. SPC Train B is the credited train of Decay Heat Removal. RHR-MOV-MO20 is normally closed, and is desired closed during SPC mode of operation.
| |
| Based on cable failure, the valve may spuriously open, resulting in a 20-inch flow diversion through the bypass line. This results in a loss or reduction of flow during the SPC Train B mode of operation.
| |
| Spurious opening of RHR-MOV-MO25B, and inability to close normally open RHR-MOV-MO27B (20-inch flow diversion path) would result in loss of SPC Train B. An IN 92-18 concern (MBR2) may prevent ability to close RHR-MOV-MO25B and isolate the flow diversion.
| |
| This is a separation issue for Decay Heat Removal.
| |
| Page C-109
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Dsr[to RB-CF Reactor Building Northwest Quad, Reactor Building 903 North Area and South Corridor, RHR Heat Exchanger Room A Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None RBCF-08 Description Prevent loss of RPV water inventory and, or high temperature and pressure in the low pressure portion of the RWCU system from the Control Room due to cable fire damage (RWCU-MOV-MO18).
| |
| The NSPC require a means of isolating the RPV and low pressure systems from the RCPB post-fire. The inability to close RWCU-MOV-MO18 or RWCU-MOV-MO15 may result in loss of RPV water inventory to the RWCU system or cause high temperatures and pressures in the low pressure portion of piping downstream.
| |
| NOTE: Fire modeling indicates a fixed ignition source could potentially disable RWCU-MOV-MO18 due to cable failure and also affect normal power to MCC R, resulting in inability to close RWCU-MOV-MO15 from the Control Room. For all other fire scenarios RWCU-MOV-MO18 will be available to close from the Control Room.
| |
| This is a separation issue for Inventory and Pressure Control.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Modification.
| |
| Modification: Item S-1.1 of LAR Attachment S, Table S-1.
| |
| Page C-1 10
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area ecotn RB-CF Reactor Building Northwest Quad, Reactor Building 903 North Area and South Corridor, RHR Heat Exchanger Room A Description Preventing a full or partial loss of SW for supporting Decay Heat Removal and Inventory and Pressure Control from the Control Room with SW supplying REC (REC-MOV-694MV, REC-MOV-695MV, REC-MOV-697MV, REC-MOV-698MV, REC-MOV-71 1MV-Passive, SW-MOV-37MV, SW-MOV-886MV-Passive, SW-MOV-887MV, SW-MOV-888MV-Passive, and SW-MOV-889MV).
| |
| SW Train B is required to support various functions (SPC, HPCI and CS Quad cooling, REC, DGs, etc) for NSPC. CS Train B is credited for Inventory Control, SPC Train B is credited for Decay Heat Removal, REC Train B provides cooling for RHR Pump 1 D and the RHR and CS Pump Rooms (Quads), and SW Train B provides the cooling for REC and RHR Heat Exchangers (DGs not credited). The complete loss or diversion of SW to REC could challenge these NSPC.
| |
| Based on fire location on the 903' Elevation, heat up of the Quads is not expected due to the fire location.
| |
| Based on cable failures, the REC and SW systems need to be manually aligned for SW Train B to supply REC Train B (Critical Header only), and keep pressure on the REC Train A Header.
| |
| Cable damage (MY344) for SW-MOV-37MV could remove the ability to close the valve if already open.
| |
| This would divert flow to non-critical loads and the non-credited SW Train with only a single SW Pump available. This reduction in flow may not allow sufficient cooling to REC and RHR Heat Exchangers. The valve splits the SW Train B from SW Train A and the non-essential loads.
| |
| This is a separation issue for Inventory and Pressure Control and Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-111
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Dsrlto RB-CF Reactor Building Northwest Quad, Reactor Building 903 North Area and South Corridor, RHR Heat Exchanger Room A RBCF-10 Description Preventing a loss of SW cooling flow to credited RHR Heat Exchanger or damage to RHRSW Booster Pumps due to run-out (SW-MOV-MO89B).
| |
| SW Train B is required to support various functions (SPC, HPCI and CS Quad cooling, REC, DGs, etc) for the NSPC.
| |
| SPC Train B is the credited train of Decay Heat Removal. SW-MOV-MO89B is normally closed, and with damage to RHR-Logic B, control from the Control Room or automatic operation would not be available.
| |
| The failure of this valve to open results in a no-flow condition for SW through the credited RHR Heat Exchanger. This removes the ability to cool the credited SPC Train B for Decay Heat Removal.
| |
| This is a separation issue for Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable - Recovery Action carried forward as Defense-in-Depth.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Description Loss of G Bus powered Switchgear Cooling Fans due to cable damage (EE-CB-4160F-1 FS and EE-CB-4160F-SS1 F).
| |
| The Essential Control Building HVAC is required to support the credited train of electrical power. Division II fans (SF and EF) are unavailable due to potential cable damage (MRB7). Division I fans are unavailable due to cable failures opening EE-CB-4160F-SS1F and EE-CB-4160F-1FS.
| |
| This is a separation issue related to Vital Auxiliaries, Essential Control Building HVAC.
| |
| Page C-1 12
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Decr.to RB-CF Reactor Building Northwest Quad, Reactor Building 903 North Area and South Corridor, RHR Heat Exchanger Room A Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Required Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression? ,
| |
| Partial(P) S : L E R D IC Detection Heat R N N N Y Y N 2A-2 Detection Ionization R N N N N Y N 2A-3 None N/A N/A N/A N/A -N/A N/A N/A N/A 2B None N/A N/A N/A N/A N/A N/A N/A N/A Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Page C-113
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area RB-CF Reactor Building Northwest Quad, Reactor Building 903 North Area and South Corridor, RHR Heat Exchanger Room A Fire Suporession Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. Per MWR 91-1264, electrical cabinets and conduit have been sealed to mitigate the effects of suppression activities. The drainage features and equipment pedestals mitigate the potential for flooding damage due to fire suppression, such that the standing water would not affect safety-related equipment. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
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| Fire Area Comments None Page C-1 14
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Dsdto RB-DI Reactor Building Southwest Quad, HPCI Room, Reactor Building 903 South, RHR Heat Exchanger Room B Fire Zone Description 1D RHR Pump Room 1B and 1D 1E HPCI Pump Room 2A-3 903' South Corridor 2C CRD Units - South 2D RHR Heat Exchanger Room B Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments / VFDR Decay Heat Removal SPC Train A will be operated to maintain Suppression Pool temperature RBDI-06 RBDI-07 RBDI-08 Process Monitoring The following indications will be used to support the Process Monitoring function: RBDI-05
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| - RPV water level and pressure [from Control Room with OMA]
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| - Suppression Pool level and temperature [from Control Room]
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| - CS, RHR, and SW flow indications [from Control Room]
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| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, RBDI-0 1 other discharge paths inboard of the MSIVs, and other system pressure RBDI-02 boundaries. RPV over-pressure protection will be provided by SRVs. Only the RBDI-03 self-activated spring lift mode is credited for over-pressure protection. ADS will RBDI-04 be used to reduce RPV pressure for operation of Core Spray Train A to RBDI-06 maintain RPV level.
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| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
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| Page C-1 1
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion RB-Dl Reactor Building Southwest Quad, HPCI Room, Reactor Building 903 South, RHR Heat Exchanger Room B Vital Auxiliaries Mechanical: None
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| - REC will be supplied by SW Train A to provide the cooling supply to the ECCS.
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| - SW Train A will be operated to provide the cooling supply to the REC system and RHR Heat Exchangers.
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| Electrical (AC/DC):
| |
| -Offsite Emergency Transformer aligned to 4160F Bus
| |
| -125/250 VDC Train A is available HVAC:
| |
| - RCIC/CS Train A - Quad area cooling
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| - DG 1 HVAC system
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| - AC Switchgear Room 1G - Essential Control Building HVAC system
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| - DC Switchgear Room 1A - Essential Control Building HVAC system
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| - Battery Room 1A - Essential Control Building HVAC system
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| - Auxiliary Relay Room and RPS MG Set Room 1A - Essential Control Building HVAC system Reference Document I Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensina Actions None Page C-1 16
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area Des.reot Ln RB-DI Reactor Building Southwest Quad, HPCI Room, Reactor Building 903 South, RHR Heat Exchanger Room B Existina Enaineering Eauivalency Evaluations (EEEE)
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| EEEE Titl EE 09-035 - Evaluation of Fire Doors Purpose Fire door assemblies provided in fire-rated barriers may vary slightly from listed configurations, and may or may not provide the same fire rating as that required of the fire barrier. The evaluation documents the adequacy of the configurations that have been provided for fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and R115, and justifies the continued use of the configurations, as they have been determined to provide a level of protection that is adequate for the fire hazards in the areas.
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| " Door D202 separates the Cable Expansion Room (Fire Area CB-D) from Stair A-9 (Fire Area TB-A)
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| " Door H105 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Turbine Building Floor North (Fire Area TB-A) e Doors H200 and H201 separate the Cable Spreading Room (Fire Area CB-D) from Stair A-10 (Fire Area CB-A) e Door H202 separates the Cable Spreading Room (Fire Area CB-D) from the Office Building Controlled Corridor (Fire Area TB-A) e Door H306 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Computer Room (Fire Area CB-D)
| |
| " Door H307 separates the Computer Room (Fire Area CB-D) from the I and C Shop (Fire Area TB-A)
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| " Door N103 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Turbine Building Mezzanine North (Fire Area TB-A) e Door N104 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Diesel Generator Room 1B (Fire Area DG-B)
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| * Door R6 separates the Reactor Building Southeast Quad (Fire Area RB-CF) from the Suppression Pool Area (Fire Area RB-E)
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| * Door R7 separates the Reactor Building Northwest Quad (Fire Area RB-B) from the Suppression Pool Area (Fire Area RB-E)
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| * Doors R101 and R102 separate the Reactor Building 903' Northeast Corner (Fire Area RB-FN) from the Office Building Controlled Corridor (Fire Area TB-A) e Door R1 15 separates Reactor Building 903'-6" CRD Units - South (Fire Area RB-DI) from the Exterior Transformer Yard (Fire Area YD)
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| Conclusion The fire door configurations (i.e., fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and R1 15) have been determined to provide a level of protection commensurate with the fire Page C-1 17
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area RB-DI Reactor Building Southwest Quad, HPCI Room, Reactor Building 903 South, RHR Heat Exchanger Room B hazards of the areas, and adequate separation has been provided. In general, minor variations to the configurations, such as conduit penetrations through the door frames, slightly larger gaps between doors and frames, and doors rated for less than that required of the barrier, have been evaluated as acceptable based on the fire hazards on either side of the barrier.
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| Basis The bases that justify this conclusion are summarized as follows:
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| * Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
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| e Fire hoses and portable extinguishers are strategically located throughout the plant for use by the responding fire brigade.
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| * Ventilation systems can typically be used for smoke and heat removal.
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| " Due to control of transient combustibles and ignition sources, door proximity to permanent combustibles, and fire area combustible loading, the majority of these doors will not be challenged by a credible fire. This effectively reduces the risk of the identified deviations.
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| e The automatic sprinkler system and smoke detection provided in the Cable Expansion Room (Fire Area CB-D) are credited for the acceptability of door D202.
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| o The automatic smoke detection systems provided in the Seal Water Pump Area and Corridor (Fire Area CB-A) and in the Turbine Building Floor North (Fire Area TB-A) are credited for the acceptability of door H105.
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| e The pre-action sprinkler system and automatic smoke detection provided in the Cable Spreading Room (Fire Area CB-D) are credited for the acceptability of doors H200 and H201.
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| * The automatic total flooding Halon 1301 suppression system and automatic smoke detection provided in the Computer Room (Fire Area CB-D) are credited for the acceptability of doors H306 and H307.
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| * The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1A (Fire Area DG-A) and the heat detection installed are credited for the acceptability of doors N103 and N104.
| |
| * The smoke and heat actuated devices provided in the Turbine Building Mezzanine (Fire Area TB-A) are credited for the acceptability of doors N103.
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| * The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1 B (Fire Area DG-B) and the heat detection installed are credited for the acceptability of door N104.
| |
| * The automatic heat detection provided in the Reactor Building Northwest Quad (Fire Area RB-CF) is credited for the acceptability of door R6.
| |
| * The automatic heat detection provided in the Reactor Building Southeast Quad (Fire Area RB-B) is credited for the acceptability of door R7.
| |
| * The automatic suppression system provided in the Office Building Corridor (Fire Area TB-A) is credited for Page C-1 18
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area Description RB-DI Reactor Building Southwest Quad, HPCI Room, Reactor Building 903 South, RHR Heat Exchanger Room B the acceptability of doors R101 and R102.
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| * The automatic sprinkler system and smoke detection provided in the Reactor Building 903' Northeast Corner (Fire Area RB-FN) is credited for the acceptability of doors R101 and R102.
| |
| * The automatic deluge suppression system actuated by heat actuated devices provided for the yard transformers (Fire Area YD) are credited for the acceptability of door R1 15.
| |
| e Actuation of the detection systems will prompt rapid fire brigade response and subsequent manual extinguishment.
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| Page C-119
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area D toon RB-DI Reactor Building Southwest Quad, HPCI Room, Reactor Building 903 South, RHR Heat Exchanger Room B Variances from Deterministic Reauirements (VFDR)
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| RBDI-01 Description Loss of RPV water inventory to Reactor Building Sumps and Radwaste (CRD-SOV-SO31A and CRD-SOV-SO31 B).
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| Cable damage may result in the spurious opening of CRD-SOV-SO31A and CRD-SOV-SO31 B. This opening of the CRD Scram Discharge Volume Vent and Drain Valve SOVs would result in loss of RPV Inventory to the Reactor Building Sumps and then Radwaste. The NSCA require a means of isolating the RPV post-fire to ensure sufficient water inventory. Based on CNS-PSA-007, the CRD seal leakage flow rate is assumed to be 450 to 600 gpm initially, reducing to 73 gpm after 70 minutes, and down to 40 gpm after 4 hours, based on all CRD seals leaking at the same time at the maximum amount prior to repair.
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| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
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| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
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| Risk: Acceptable with Recovery Action.
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| See LAR Attachment G, Table G-1 for Recovery Action details.
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| Modification: None RBDI-02 Description Preventing a RR Pump Seal LOCA due to inability to secure the RR Pumps from the Control Room with the REC Non-Critical header secured (RR Pump Breakers for 4160C-1CS and 4160D-1DS).
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| Breakers F/FDR to the 4160V Bus from the Startup Transformer: These are normally available, required open breakers that provides motive power to the RR Pumps. The RR Pumps are required to trip to prevent a potential seal LOCA when REC is not available to provide cooling. This would challenge the NSPC for Inventory Control. REC is secured in this fire area to address a potential loss of containment over-pressure. Remote operation of the breaker(s) from the Control Room is lost due to cables H254 (1 C bus) and H294 (1 D bus) fire-induced damage.
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| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
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| Page C-120
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Des.L2U RB-Dl Reactor Building Southwest Quad, HPCI Room, Reactor Building 903 South, RHR Heat Exchanger Room B Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None RBDI-03 Description Preventing an RPV Overfill due to the inability to close the inboard or outboard steam supply valves to the HPCI Turbine (HPCI-MOV-MO14-Passive and HPCI-MOV-MO15). HPCI-MOV-MO14, HPCI-MOV-MO15, and HPCI-MOV-MO16 are all impacted in this area.
| |
| Spurious opening of HPCI-MOV-MO15 (HPCI Steam Admission Valve) due to cable damage on HP185, would result in a rapid RPV overfill condition. This VFDR concern is limited to fires occurring at RB 903' Elevation. HPCI is not credited in this area for NSCA success. Core Spray Train A is available.
| |
| Cable damage can cause HPCI-MOV-MO15 to not be able to be closed from the Control Room. This failure would result in the rapid RPV overfill condition if HPCI-MOV-MO14 spuriously opens. This VFDR concern is limited to fires occurring at the Reactor Building 859' and 881' Elevations. HPCI is not credited in this area for NSCA success. Core Spray Train A is available.
| |
| This is a separation issue in isolating the RPV for Inventory and Pressure Control.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
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| Risk: Acceptable Modification: None Page C-121
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area ecuto RB-DI Reactor Building Southwest Quad, HPCI Room, Reactor Building 903 South, RHR Heat Exchanger Room B RBDI-04 Description Ability to close SRV's automatically / remotely from the Control Room is lost due to cable fire damage (Pilot Valves SPV71A, SPV71 B, SPV71C, SPV71 D, SPV71 E, SPV71 F, SPV71 G, and SPV71H).
| |
| The NSPC require the ability to isolate the RPV to maintain water inventory above the active fuel.
| |
| Spurious operations could result in the opening of up to four ADS valves. SPV71A, SPV71 B, SPV71 C, and SPV71D utilize penetration X-100-G and SPV71E, SPV71F, SPV71G, and SPV71H utilize penetration X-100-A. Based on physical separation of these penetrators, at least one should survive limiting the total number of valves affected at any one time to 4 of the 8. The NSPC could be challanged if the affected ADS valves are not returned to their fail-safe closed position within 18 minutes for single spurious operation.
| |
| NOTE: SPV71A, SPV71B, SPV71C, and SPV71D spurious cables are only impacted by a full zone burn out of Fire Zone 2A-3 in this area. SPV71E, SPV71 F, SPV71G, and SPV71H are impacted in Fire Zone 2C scenarios and within full zone burnout in this area.
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| This is a separation issue related to Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable - Recovery Action carried forward as Defense-in-Depth.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-122
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| | |
| Nebrask.a Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area RB-DI Reactor Building Southwest Quad, HPCI Room, Reactor Building 903 South, RHR Heat Exchanger Room B RBDI-05 Description Loss of RPV water level and pressure along with Torus level due to the fire affects on sensing line piping (NBI-LT-52A, NBI-LT-52C, NBI-LT-59A, NBI-LT-59C, NBI-LT-91A, NBI-LT-91C, NBI-PT-53A, and NBI-PT-53C).
| |
| The NSPC require a means of monitoring plant conditions post-fire. While instruments are not located within this fire area, their sensing lines are affected by the fire, making indication unreliable. Unaffected instruments need to be isolated from the common cold reference leg continuous backfill supply.
| |
| This is a separation issue for Process Monitoring.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable - Recovery Action carried forward as Defense-in-Depth.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-123
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Nebraska Public Power District CNS NFPA 805 Transition Report Attachment C Table B-3 Fire Area Transition EJLLArea RB-DI Reactor Building Southwest Quad, HPCI Room, Reactor Building 903 South, RHR Heat Exchanger Room B R1301- 06 Description Preventing a full or partial loss of SW for supporting Decay Heat Removal and RPV Inventory Control from the Control Room with SW supplying REC (REC-MOV-714MV-Passive, SW-MOV-887MV, and SW-MOV-889MV).
| |
| SW Train A is required to support various functions (SPC, RCIC and CS Quad cooling, REC, DGs, etc) for the NSPC. CS Train A is credited for RPV Inventory Control, SPC Train A is credited for Decay Heat Removal, REC-A provides cooling for RHR Pump 1A and the RHR and CS Pump Rooms (Quads), and SW Train A provides the cooling for REC and RHR Heat Exchangers (DGs not credited). The complete loss or diversion of SW to REC could challenge these NSPC.
| |
| Current requirements indicate 1 hour to establish room cooling.
| |
| NOTE: Based on fire location on the 903' Elevation, additional heat up of the Quad due to contribution of the fire is not expected due to the fire location.
| |
| Based on cable failures, the REC and SW systems need to be aligned for SW Train A to supply the REC Train A Critical Header only, and keep pressure on the REC Train B Critical Header.
| |
| This is a separation issue for Inventory and Pressure Control and Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-124
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area Descrotion RB-DI Reactor Building Southwest Quad, HPCI Room, Reactor Building 903 South, RHR Heat Exchanger Room B RBDI-07 Description Preventing a loss of Decay Heat Removal for credited SPC Train A by loss of SW cooling flow to the credited RHR Heat Exchanger or Diversion of RHR flow in SPC mode of operation (SW-MOV-MO89A and RHR-MOV-MO27A).
| |
| The NSPC require a means of Decay Heat Removal post-fire. SPC Train A is the credited source of Decay Heat Removal for this area. SW-MOV-MO89A is normally closed, and damage to RHR-Logic A automatic operations or control from the Control Room would not be available. This valve failing to open results in a no-flow condition for SW through the credited RHR Heat Exchanger. This removes the ability to cool the credited SPC Train A for Decay Heat Removal.
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| RHR-MOV-MO27A is a normally open valve, and the injection line is isolated by RHR-MOV-MO25A. RHR-MOV-MO25A fails open in this area, and based on cable damage, neither RHR-MOV-MO25A nor RHR-MOV-MO27A can be closed remotely to isolate the injection line. The spurious opening of RHR-MOV-M025A, along with inability to close either valve, results in a 20-inch diversion to the SPC Train A flow path. An IN 92-18 concern may prevent ability to close RHR-MOV-MO25A and isolate the flow diversion.
| |
| This is a separation issue for Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-125
| |
| | |
| Nebrask a Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area RB-DI Reactor Building Southwest Quad, HPCI Room, Reactor Building 903 South, RHR Heat Exchanger Room B RBDI-08 Description Preventing loss of containment over-pressure in support of RHR pump operation for SPC operation (PC-AOV-245AV).
| |
| The NSPC require a means of Decay Heat Removal post-fire. SPC Train A is credited for Decay Heat Removal. The loss of containment over-pressure could result in the loss of NPSH for the credited RHR pump during SPC mode of operation.
| |
| Both PC-AOV-245AV and PC-MOV-230MV cables are affected by the fire, and may spuriously open.
| |
| These valves isolate the Vent and Purge path from the Suppression Chamber, and would result in a loss of containment over-pressure.
| |
| This is a separation issue for Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-126
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Description RB-DI Reactor Building Southwest Quad, HPCI Room, Reactor Building 903 South, RHR Heat Exchanger Room B Reauired Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?
| |
| Partial (P) _D S IL E R 1D Detection Heat R N N N N Y N 1E Detection Heat R N N N N Y N 2A-3 None N/A N/A N/A N/A N/A N/A N/A N/A 2C Detection Ionization R N N N N Y N 2C Detection Heat R Y N N N N N 2C Suppression Preaction Sprinkler System P N/A N N N N N 2D None N/A N/A N/A N/A N/A N/A N/A N/A Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Page C-127
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area ecotn RB-DI Reactor Building Southwest Quad, HPCI Room, Reactor Building 903 South, RHR Heat Exchanger Room B Fire SuDoression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. Per MWR 91-1264, electrical cabinets and conduit have been sealed to mitigate the effects of suppression activities. In the event of normal operation, the pre-action system will not adversely effect the other equipment operating within the Fire Zone. The drainage features and equipment pedestals mitigate the potential for flooding damage due to fire suppression, such that the standing water would not affect safety-related equipment. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments None Page C-128
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fie Area RB-E Suppression Pool Area Fie ZoneD Description 1IF Suppression Pool Area Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomnlishment Comments / VFDR Decay Heat Removal SPC Train A will be operated to maintain Suppression Pool temperature RBE-01 RBE-03 Process Monitoring The following indications will be used to support the Process Monitoring function: RBE-02
| |
| - RPV water level and pressure [from Control Room]
| |
| - Suppression Pool level [from Control Room]
| |
| - Suppression Pool temperature [locally]
| |
| - CS, RHR, and SW flow indications [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, RBE-03 other discharge paths inboard of the MSIVs, and other system pressure boundaries. RPV over-pressure protection will be provided by SRVs. Only the self-activated spring lift mode is credited for over-pressure protection. ADS will be used to reduce RPV pressure for operation of Core Spray Train A to maintain RPV level.
| |
| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
| |
| Page C-129
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area RB-E Suppression Pool Area Vital Auxiliaries Mechanical: None
| |
| - REC will be supplied by Train A to provide the cooling supply to the ECCS.
| |
| - SW Train A will be operated to provide the cooling supply to the REC system and RHR Heat Exchangers.
| |
| Electrical (AC/DC):
| |
| - Offsite Emergency Transformer aligned to 4160F Bus
| |
| - 125/250 VDC Train A is available HVAC:
| |
| - DG /CS Train A - Quad area cooling
| |
| - DG 1 HVAC system
| |
| - AC Switchgear Room 1G - Essential Control Building HVAC system
| |
| - DC Switchgear Room IA - Essential Control Building HVAC system
| |
| - Battery Room 1A - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Room 1A - Essential Control Building HVAC system Reference Document / Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensina Actions None Page C-130
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Description RB-E Suppression Pool Area Existinq Enaineerina Eouivalency Evaluations (EEEE)
| |
| E.Fle EE 09-035 - Evaluation of Fire Doors Purpose Fire door assemblies provided in fire-rated barriers may vary slightly from listed configurations, and may or may not provide the same fire rating as that required of the fire barrier. The evaluation documents the adequacy of the configurations that have been provided for fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and RI 15, and justifies the continued use of the configurations, as they have been determined to provide a level of protection that is adequate for the fire hazards in the areas.
| |
| " Door D202 separates the Cable Expansion Room (Fire Area CB-D) from Stair A-9 (Fire Area TB-A)
| |
| " Door H105 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Turbine Building Floor North (Fire Area TB-A) e Doors H200 and H201 separate the Cable Spreading Room (Fire Area CB-D) from Stair A-10 (Fire Area CB-A) e Door H202 separates the Cable Spreading Room (Fire Area CB-D) from the Office Building Controlled Corridor (Fire Area TB-A) e Door H306 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Computer Room (Fire Area CB-D)
| |
| " Door H307 separates the Computer Room (Fire Area CB-D) from the I and C Shop (Fire Area TB-A)
| |
| * Door N103 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Turbine Building Mezzanine North (Fire Area TB-A)
| |
| * Door N104 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Diesel Generator Room 1B (Fire Area DG-B)
| |
| * Door R6 separates the Reactor Building Southeast Quad (Fire Area RB-CF) from the Suppression Pool Area (Fire Area RB-E) 9 Door R7 separates the Reactor Building Northwest Quad (Fire Area RB-B) from the Suppression Pool Area (Fire Area RB-E) o Doors R101 and R102 separate the Reactor Building 903' Northeast Corner (Fire Area RB-FN) from the Office Building Controlled Corridor (Fire Area TB-A) o Door R1 15 separates Reactor Building 903'-6" CRD Units - South (Fire Area RB-DI) from the Exterior Transformer Yard (Fire Area YD)
| |
| Conclusion The fire door configurations (i.e., fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and Rl15) have been determined to provide a level of protection commensurate with the fire Page C-131
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area Dsrlto RB-E Suppression Pool Area hazards of the areas, and adequate separation has been provided. In general, minor variations to the configurations, such as conduit penetrations through the door frames, slightly larger gaps between doors and frames, and doors rated for less than that required of the barrier, have been evaluated as acceptable based on the fire hazards on either side of the barrier.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| * Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
| |
| e Fire hoses and portable extinguishers are strategically located throughout the plant for use by the responding fire brigade.
| |
| " Ventilation systems can typically be used for smoke and heat removal.
| |
| " Due to control of transient combustibles and ignition sources, door proximity to permanent combustibles, and fire area combustible loading, the majority of these doors will not be challenged by a credible fire. This effectively reduces the risk of the identified deviations.
| |
| * The automatic sprinkler system and smoke detection provided in the Cable Expansion Room (Fire Area CB-D) are credited for the acceptability of door D202.
| |
| e The automatic smoke detection systems provided in the Seal Water Pump Area and Corridor (Fire Area CB-A) and in the Turbine Building Floor North (Fire Area TB-A) are credited for the acceptability of door H105.
| |
| e The pre-action sprinkler system and automatic smoke detection provided in the Cable Spreading Room (Fire Area CB-D) are credited for the acceptability of doors H200 and H201.
| |
| * The automatic total flooding Halon 1301 suppression system and automatic smoke detection provided in the Computer Room (Fire Area CB-D) are credited for the acceptability of doors H306 and H307.
| |
| e The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1A (Fire Area DG-A) and the heat detection installed are credited for the acceptability of doors N103 and N104.
| |
| e The smoke and heat actuated devices provided in the Turbine Building Mezzanine (Fire Area TB-A) are credited for the acceptability of doors N103.
| |
| * The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1B (Fire Area DG-B) and the heat detection installed are credited for the acceptability of door N104.
| |
| * The automatic heat detection provided in the Reactor Building Northwest Quad (Fire Area RB-CF) is credited for the acceptability of door R6.
| |
| e The automatic heat detection provided in the Reactor Building Southeast Quad (Fire Area RB-B) is credited for the acceptability of door R7.
| |
| * The automatic suppression system provided in the Office Building Corridor (Fire Area TB-A) is credited for Page C-132
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area D,.cr.*ntoon RB-E Suppression Pool Area the acceptability of doors R101 and R102.
| |
| e The automatic sprinkler system and smoke detection provided in the Reactor Building 903' Northeast Corner (Fire Area RB-FN) is credited for the acceptability of doors R101 and R102.
| |
| e The automatic deluge suppression system actuated by heat actuated devices provided for the yard transformers (Fire Area YD) are credited for the acceptability of door R1 15.
| |
| * Actuation of the detection systems will prompt rapid fire brigade response and subsequent manual extinguishment.
| |
| Page C-133
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Description RB-E Suppression Pool Area Variances from Deterministic Reauirements (VFDR)
| |
| Description Preventing loss of containment over-pressure in support of RHR pump operation for SPC operation (PC-AOV-245AV, RW-AOV-AO82, and RW-AOV-AO94).
| |
| The NSPC requires a means of Decay Heat Removal post-fire. SPC Train A is credited for Decay Heat Removal. The loss of containment over-pressure could result in the loss of NPSH for the credited RHR pump during the SPC mode of operation.
| |
| RW-AOV-AO82, RW-AOV-AO83, RW-AOV-AO94, and RW-AOV-AO95 cables are all affected by the fire and may spuriously open. These valves isolate the Drywell Equipment and Floor Drain Sump discharge path and would result in a loss of containment over-pressure.
| |
| Both PC-AOV-245AV and PC-MOV-230MV cables are affected by the fire and may spuriously open.
| |
| These valves isolate the Vent and Purge path from the Suppression Chamber, and would result in a loss of containment over-pressure.
| |
| This is a separation issue for Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-134
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore AreaDecito RB-E Suppression Pool Area RBE-02 Description Preventing the loss of Torus level and temperature due to the fire affects on sensing line piping and temperature element signal cable damage (PC-LR-1A and PC-TR-24).
| |
| The NSCA require a means of monitoring Torus level. PCDPT-3A1 and PC-DPT-3B2 are affected, due to sensing lines located in the Torus fire area. The PCDPT-3A1 sensing line is located in the Northeast quadrant of the Torus. The PC-DPT-3B2 sensing line is located in the Southeast quadrant of the Torus. A separation of approximately 75 feet exists between the redundant sensing lines.
| |
| NOTE: Fire scenarios in RB-E consist of a non-ventilated electrical panel and transient fires. Based on NEDC 09-101, "EPM Report R1906-71 1-RB - Detailed Fire Modeling Report Fire Compartment RB," there are no secondary combustibles that would be involved in the fires postulated in this fire compartment.
| |
| Therefore, the zone of influence of the fire scenarios in RB-E are not large enough to result in damage to targets located 75 feet apart.
| |
| The NSCA require a means of monitoring Torus temperature. PC-TR-24 provides Torus temperature indication for Primary Containment.
| |
| This is a separation issue for Process Monitoring.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-135
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area ecato RB-E Suppression Pool Area RBE-03 Description Preventing a full or partial loss of SW for the Reactor Building in support of Decay Heat Removal (RHR Heat Exchanger) and Inventory and Pressure Control (REC Heat Exchanger) from the Control Room or automatically due to cable and equipment damage (SW-AOV-TCV451A and SW-MOV-89A).
| |
| SW Train A is required to support various functions (SPC, RCIC and CS Quad cooling, REC, DGs, etc) for NSPC. CS Train A is credited for Inventory and Pressure Control, SPC Train A is credited for Decay Heat Removal, REC Train A provides cooling for RHR Pump 1A and the RHR and CS Pump Rooms (Quads) and SW Train A provides the cooling for REC and RHR Heat Exchangers (DGs not credited).
| |
| The complete loss of SW to the Reactor Building could challenge these NSPC.
| |
| SW-MOV-MO89A is normally closed, and cable damage (M920 and M921) to this valve may cause spurious operation to open, with automatic operation or control from the Control Room would not be available. This valve failing to open results in a no-flow condition for SW through the credited RHR Heat Exchanger. This removes the ability to cool the credited SPC Train A for Decay Heat Removal.
| |
| CS Train A is the credited train. SW-AOV-TCV451A controls the outlet flow from the REC Heat Exchanger A. REC Train A is the credited train for supporting RHR Pump cooling, and the credited RHR Pump for SPC and Quad cooling for the RHR Pump and CS Pump Rooms. Cable damage to M920, M921, and REC-TIC- 451A could result in SW-AOV-TCV451A remaining energized, essentially locking the valve in the closed position, securing flow through the Heat Exchanger. Cable M920, M921, and M923 are routed in a dedicated conduit in this area. If the valve fails to open, this causes a no-flow condition for SW through the credited REC Heat Exchanger removing the REC ability to cool the credited RHR Pump for SPC and Quad cooling for the RHR Pump and CS Pump Rooms.
| |
| This is a separation issue for Inventory and Pressure Control and Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable - Recovery Action carried forward as Defense-in-Depth.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-136
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion RB-E Suppression Pool Area Required Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?
| |
| Partial (P) S L E R D 1F None N/A N/A N/A N/A N/A N/A N/A N/A Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Fire Sunoression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. The Suppression Pool area of the Reactor Building on the 859' and 881' Elevations are not subject to adverse effects to equipment by water intrusion from fire suppression systems. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments None Page C-137
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area 1ecafo RB-FN Reactor Building 903' Northeast Corner Fire Zone Descriotion 2A-1 Reactor Building 903' Northeast Corner Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomnlishment Comments / VFDR Decay Heat Removal SPC Train B will be operated to maintain Suppression Pool temperature. RBFN-01 RBFN-08 RBFN-09 Process Monitoring The following indications will be used to support the Process Monitoring function: RBFN-12
| |
| - RPV water level and pressure [from Control Room] RBFN-13
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - Emergency Condensate Storage Tank level [from Alternate Shutdown Panel]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, RBFN-01 other discharge paths inboard of the MSIVs, and other system pressure RBFN-02 boundaries. RPV over-pressure protection is provided by SRVs. Only the self- RBFN-04 activated spring lift mode is credited for over-pressure protection. The HPCI RBFN-05 system will be used to control RPV pressure and to maintain RPV level. RBFN-06 RBFN-07 RBFN-1 0 RBFN-1 1 Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
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| Page C-1 38
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Nebraska Public Power District CNS NFPA 805 Transition Report Attachment C Table B-3 Fire Area Transition Fire Area Reacr utldn RB-FN Reactor Building 903' Northeast Corner Vital Auxiliaries Mechanical: RBFN-01
| |
| - REC will be supplied by SW Train B to provide the cooling supply to the ECCS RBFN-03 in the alternate shutdown lineup. RBFN-13
| |
| - SW Train B will be operated to provide the cooling supply to the REC system and RHR Heat Exchangers in the alternate shutdown lineup.
| |
| Electrical (AC/DC):
| |
| - Offsite Emergency Transformer aligned to 4160G Bus
| |
| - 125/250 VDC Train B is available HVAC:
| |
| - HPCI/CS Train B - Quad area cooling
| |
| - AC Switchgear Room 1G - Essential Control Building HVAC system
| |
| - DC Switchgear Room 1B - Essential Control Building HVAC system
| |
| - Battery Room 1B - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Room 1 B - Essential Control Building HVAC system Reference Document / Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensing Actions None Page C-139
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore AreaDecito RB-FN Reactor Building 903' Northeast Corner Existina Enaineering Eguivalency Evaluations (EEEE)
| |
| TEE 05-034 - Evaluation of the Reclassification of Door R1 04 Under the FHA Purpose The purpose of this evaluation is to permanently reclassify door R104 from a 3-hour fire door to a 1-hour fire door required to separate Fire Area RB-FN/Fire Zone 2A-1 (Reactor Building 903'-6" Northeast Corner) and Fire Area TB-C/Fire Zone 2E (Steam Tunnel).
| |
| Conclusion It is acceptable to revise the fire barrier between Fire Area RB-FN/Fire Zone 2A-1, and Fire Area TB-C/Fire Zone 2E from a 3-hour rated barrier to a 1-hour fire rated barrier.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| * Ignition sources near door R104 include, but are not limited to: MCC-K, RCIC Rack, and Condensate Pumps CP-R-A1 and A2. Each of these ignition sources is spatially separated from door R104 by approximately 5 feet or more. In the case of MCC-K, as much as approximately 15 feet. A postulated fire at each of these ignition sources would propagate upward into the cable raceways. Horizontal propagation will not occur due to the scarcity and discontinuity of combustibles in the zone. Without horizontal propagation of the postulated fire, no challenge can be made to door R104.
| |
| e The combustible loading calculation, NEDC 93-161, shows that the primary contributor of combustibles in Reactor Building Elev. 903'-6" are located 20 feet above the floor in the overhead cable raceways. These cables are fire retardant and are equivalent to IEEE-383 rated cable. Fire in the cable raceways would not present a fire severity of greater than 1 hour to door R1 04 due to a spatial separation of 10 feet or more.
| |
| 9 This area is also equipped with fire and smoke detection as well as fire suppression. The smoke and fire detections systems would ensure immediate fire brigade response. The fire suppression system alone will mitigate any postulated fire at the floor level, well before the fire reaches a severity of greater than 1 hour.
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| Page C-140
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion RB-FN Reactor Building 903' Northeast Corner EEEE Tit EE 09-035 - Evaluation of Fire Doors Purpose Fire door assemblies provided in fire-rated barriers may vary slightly from listed configurations, and may or may not provide the same fire rating as that required of the fire barrier. The evaluation documents the adequacy of the configurations that have been provided for fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and R1 15, and justifies the continued use of the configurations, as they have been determined to provide a level of protection that is adequate for the fire hazards in the areas.
| |
| " Door D202 separates the Cable Expansion Room (Fire Area CB-D) from Stair A-9 (Fire Area TB-A)
| |
| " Door H105 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Turbine Building Floor North (Fire Area TB-A)
| |
| * Doors H200 and H201 separate the Cable Spreading Room (Fire Area CB-D) from Stair A-10 (Fire Area CB-A) e Door H202 separates the Cable Spreading Room (Fire Area CB-D) from the Office Building Controlled Corridor (Fire Area TB-A) 9 Door H306 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Computer Room (Fire Area CB-D)
| |
| " Door H307 separates the Computer Room (Fire Area CB-D) from the I and C Shop (Fire Area TB-A)
| |
| " Door N103 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Turbine Building Mezzanine North (Fire Area TB-A)
| |
| * Door N104 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Diesel Generator Room 1B (Fire Area DG-B) 9 Door R6 separates the Reactor Building Southeast Quad (Fire Area RB-CF) from the Suppression Pool Area (Fire Area RB-E) e Door R7 separates the Reactor Building Northwest Quad (Fire Area RB-B) from the Suppression Pool Area (Fire Area RB-E)
| |
| &Doors R101 and R102 separate the Reactor Building 903' Northeast Corner (Fire Area RB-FN) from the Office Building Controlled Corridor (Fire Area TB-A)
| |
| * Door R115 separates Reactor Building 903'-6" CRD Units - South (Fire Area RB-DI) from the Exterior Transformer Yard (Fire Area YD)
| |
| Conclusion The fire door configurations (i.e., fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and R115) have been determined to provide a level of protection commensurate with the fire hazards of the areas, and adequate separation has been provided. In general, minor variations to the configurations, such as conduit penetrations through the door frames, slightly larger gaps between doors and Page C-141
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area Descriotion RB-FN Reactor Building 903' Northeast Corner frames, and doors rated for less than that required of the barrier, have been evaluated as acceptable based on the fire hazards on either side of the barrier.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| * Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
| |
| * Fire hoses and portable extinguishers are strategically located throughout the plant for use by the responding fire brigade.
| |
| " Ventilation systems can typically be used for smoke and heat removal.
| |
| " Due to control of transient combustibles and ignition sources, door proximity to permanent combustibles, and fire area combustible loading, the majority of these doors will not be challenged by a credible fire. This effectively reduces the risk of the identified deviations.
| |
| * The automatic sprinkler system and smoke detection provided in the Cable Expansion Room (Fire Area CB-D) are credited for the acceptability of door D202.
| |
| e The automatic smoke detection systems provided in the Seal Water Pump Area and Corridor (Fire Area CB-A) and in the Turbine Building Floor North (Fire Area TB-A) are credited for the acceptability of door H105.
| |
| * The pre-action sprinkler system and automatic smoke detection provided in the Cable Spreading Room (Fire Area CB-D) are credited for the acceptability of doors H200 and H201.
| |
| e The automatic total flooding Halon 1301 suppression system and automatic smoke detection provided in the Computer Room (Fire Area CB-D) are credited for the acceptability of doors H306 and H307.
| |
| * The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1A (Fire Area DG-A) and the heat detection installed are credited for the acceptability of doors N103 and N104.
| |
| e The smoke and heat actuated devices provided in the Turbine Building Mezzanine (Fire Area TB-A) are credited for the acceptability of doors N103.
| |
| * The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1B (Fire Area DG-B) and the heat detection installed are credited for the acceptability of door N104.
| |
| * The automatic heat detection provided in the Reactor Building Northwest Quad (Fire Area RB-CF) is credited for the acceptability of door R6.
| |
| o The automatic heat detection provided in the Reactor Building Southeast Quad (Fire Area RB-B) is credited for the acceptability of door R7.
| |
| e The automatic suppression system provided in the Office Building Corridor (Fire Area TB-A) is credited for the acceptability of doors R101 and R102.
| |
| * The automatic sprinkler system and smoke detection provided in the Reactor Building 903' Northeast Page C-142
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descriotion RB-FN Reactor Building 903' Northeast Corner Corner (Fire Area RB-FN) is credited for the acceptability of doors R101 and R102.
| |
| * The automatic deluge suppression system actuated by heat actuated devices provided for the yard transformers (Fire Area YD) are credited for the acceptability of door R1 15.
| |
| e Actuation of the detection systems will prompt rapid fire brigade response and subsequent manual extinguishment.
| |
| Page C-143
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area RB-FN Reactor Building 903' Northeast Corner Variances from Deterministic Reauirements MVFDR)
| |
| RBFN-01 Description Preventing a full or partial loss of SW for supporting Decay Heat Removal and RPV Inventory and Pressure Control with SW supplying REC (EE-CB-4160GSWP1D, REC-MOV-695MV, REC-MOV-694MV, REC-MOV-698MV, SW-AOV-TCV451B, SW-FI-132B, SW-MOV-37MV, SW-MOV-651MV, SW-MOV-887MV, and SW-MOV-889MV).
| |
| SW Train B is required to support various functions (SPC, HPCI and CS Quad cooling, REC, DGs, etc) for NSPC. HPCI is credited for RPV Inventory Control, SPC Train B is credited for Decay Heat Removal, REC Train B provides cooling for RHR Pump 1B and the RHR Room (Quads) and SW Train B provides the cooling for REC and RHR Heat Exchangers (DGs not credited). The complete loss or diversion of SW to REC could challenge these NSPC.
| |
| Based on cable failures, the REC and SW systems are aligned to SW Train B to supply the REC Train B Critical Header. This is a separation issue for Vital Auxiliaries for which:
| |
| -Based on cable failures, EE-CB-4160G-SWP1D may trip open.
| |
| *REC-MOV-694MV is normally open and presents a flow diversion during REC operation supplied from SW. Cable damage removes the ability to remotely close the valve from the Control Room.
| |
| *REC-MOV-698MV is normally open and presents a flow diversion from the REC Train B Critical Header.
| |
| Cable damage removes the ability to remotely close the valve from the Control Room.
| |
| *REC-MOV-695MV cable failure removes the ability to remotely close the valve from the Control Room.
| |
| -Cable damage may cause SW-AOV-TCV451 B to fail closed, securing the SW Train B discharge back to the river and removing cooling flow to the HPCI and RHR Pumps.
| |
| -Cable damage may cause SW-FI-1 32B to result in SW flow indication not being available in the Control Room. However, indication remains available at the ASD Panel.
| |
| *SW-MOV-37MV may need to be closed to isolate the diversion of SW flow from the critical SW and REC loads to the non-critical SW loads with only a single operating SW Pump.
| |
| *SW-MOV-651 MV needs to be closed to prevent flow diversion from the SW system to the REC Heat Exchanger, which is bypassed in ASD lineup.
| |
| *SW-MOV-887MV needs to be open to supply SW to the REC Critical Header.
| |
| *SW-MOV-889MV needs to be open to supply SW to the REC Critical Header.
| |
| This is a separation issue for Vital Auxiliaries, Inventory and Pressure Control, and Decay Heat Removal.
| |
| Page C-144
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area DescriBtion RB-FN Reactor Building 903' Northeast Corner Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None RBFN-02 Description Ability to close MSIVs automatically / remotely from the Control Room is lost due to cable fire damage.
| |
| MSIVs (MS-AOV-AO80A, MS-AOV-AO80B, MS-AOV-AO80C, and MS-AOV-AO80D) may not go closed from the Control Room due to cable damage. The NSPC requires a means of isolating the RPV to ensure sufficient water inventory for Decay Heat Removal.
| |
| This is a separation issue related to Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-145
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area D.escroJtio RB-FN Reactor Building 903' Northeast Corner RBFN-03 Description Establish vital auxiliaries and control by powering the credited 4160G Bus from the Emergency Transformer (EE-CB-4160F-1 FS, UNDERVOLTAGE-BUS-G, EE-CB-4160G-1 GB, EE-CB-4160G-1 GE, EE-CB-4160G-1 GS, EE-CB-4160G-SS1 G, EE-CB-4160G-RSWP1 B-OCT, and EE-CB-4160G-SWP1 B-OCT).
| |
| The NSCA require at least one source of AC power available. Offsite power from the Emergency Transformer is unavailable using the normal transfer mode due to fire damage to supply breakers feeding the 4160G Bus.
| |
| There are multiple breaker and cables affected on the 4160F Bus. Multiple cables that support EE-CB-4160F-1FS are also damaged due to fire and may close the breaker.
| |
| Due to cable damage on the UV circuit for the 4160G Bus, in addition to cable damage listed below, all breakers need to be operated.
| |
| - The EE-CB-4160G-1GB breaker is normally closed, and should open as part of the transfer process due to loss of Startup Transformer, but cable damage to H561 may not allow it to open. The DG and Emergency Transformer are not rated to normally carry both the vital and non-vital buses. Additionally, the DG2/1 GS breakers are interlocked with the BG/GB breakers, and will not close if the breaker is not opened.
| |
| -Cable damage (H572, H573) due to fire could close EE-CB-4160G-1GE or blow its control power fuses.
| |
| The breaker is normally closed and needs to be open to allow for control of the DG, and not allow damage to the DG or the bus if the DG came onto the bus out-of-phase.
| |
| -Based on cable failure (H551, H552, H553, H555) due to fire damage, the 4160G-1GS Breaker may trip open or blow control power fuses and not close.
| |
| -Cable damage to H542 and H543 may cause EE-CB-4160G-SS1G to trip open. Opening this breaker causes a loss of power to the 480V G Bus. The breaker is normally closed and is desired closed to support NSPC requirements for Process Monitoring and Decay Heat Removal.
| |
| *EE-CB-4160G-RSWPI B-OCT may not trip due to potential fire damage to the control and load cables, resulting in loss of the credited 4160G Bus.
| |
| Page C-146
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Bescriltinon RB-FN Reactor Building 903' Northeast Corner
| |
| *EE-CB-4160G-RSWP1 D-OCT may not trip due to potential fire damage to the control and load cables, resulting in loss of the credited 4160G Bus.
| |
| *EE-CB-4160G-SWP1 B-OCT may not trip due to potential fire damage to the control and load cables, resulting in loss of the credited 4160G Bus.
| |
| Therefore, the above OCT circuits are needed to ensure that the credited critical train of power (4160G) can remain free of damage based on cable protection or modification to re-route impacted cables to the load or control circuitry.
| |
| This is a separation issue for Vital Auxiliaries.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None RBFN-04 Description Ability to close SRV's automatically / remotely from the Control Room is lost due to cable fire damage (Pilot Valves SPV71A, SPV71B, SPV71C, SPV71D, SPV71E, SPV71F, SPV71G, and SPV71H).
| |
| The NSCA require the ability to isolate the RPV to maintain water inventory above the top of active fuel.
| |
| Spurious operations could result in the opening of up to eight (8) ADS valves. The NSPC could be challanged if the affected ADS valves are not returned to their fail-safe closed position within 18 minutes for single spurious operation.
| |
| This is a separation issue related to Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-147
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Descriotion RB-FN Reactor Building 903' Northeast Corner RBFN-05 Description Preventing a loss of Inventory and Pressure Control by losing remote operation of the HPCI system (HPCI-ECCS, HPCI-FAN-GSE, HPCI-FIC-108, HPCI-MOV-MO14, HPCI-MOV-MO15, HPCI-MOV-MO15-PASSIVE, HPCI-MOV-MO16-PASSIVE, HPCI-MOV-MO17, HPCI-MOV-MO19, HPCI-MOV-MO20, HPCI-MOV-MO21, HPCI-MOV-MO24, HPCI-MOV-MO25, HPCI-MOV-MO58, HPCI-P-ALOP, HPCI-P-CP, HPCI-P1-109, HPCI-PI-1 11, HPCI-PI-1 12, HPCI-PI-1 16, HPCI-SI-2792, and HPCI-TU-TURB).
| |
| Based on cable damage to valves, valve control, indication, and the HPCI Turbine, the system may fail to initiate automatically from the Control Room or not be able to be controlled if it does initiate. The ASD portion of the system is unaffected by a fire in this area.
| |
| This is a separation issue related to Inventory and Pressure Control.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable - Recovery Action carried forward as Defense-in-Depth.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Description Preventing loss of remote valve control for essential systems from the ASD Room (EE-MCC-R-1A).
| |
| The NSPC require a mean of RPV inventory and pressure control post-fire. Feeder cable from MCC K (MK1 34) is affected by the fire, and MCC-R is the power supply to HPCI-MOV-MO15-ASD, MS-MOV-M074, REC-MOV-695MV, RHR-MOV-MO20, RHR-MOV-MO57-ASD, and RWCU-MOV-MO15. The normal position for HPCI-MOV-MO15 is open and the desired position is open, with HPCI as the credited train of inventory control. HPCI-MOV-MO15 may spuriously close prior to shifting to the ASD Room.
| |
| This is a separation issue for Inventory and Pressure Control.
| |
| Page C-148
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Description RB-FN Reactor Building 903' Northeast Corner Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable - Recovery Action carried forward as Defense-in-Depth See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None RBFN-07 Description Loss of RPV water inventory to Reactor Building Sumps and Radwaste (CRD-SOV-SO31A and CRD-SOV-SO31 B).
| |
| Cable damage may result in the spurious opening of CRD-SOV-SO31A and CRD-SOV-SO31B. This opening of the CRD Scram Discharge Volume Vent and Drain Valve SOVs would result in loss of RPV Inventory to the Reactor Building Sumps and then Radwaste. The NSCA require a means of isolating the RPV post-fire to ensure sufficient water inventory. Based on CNS-PSA-007, the CRD seal leakage flow rate is assumed to be 450 to 600 gpm initially, reducing to 73 gpm after 70 minutes, and down to 40 gpm after 4 hours, based on all CRD seals leaking at the same time at the maximum amount prior to repair.
| |
| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-149
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descr~intion RB-FN Reactor Building 903' Northeast Corner RBFN-08 Description Loss of Decay Heat Removal, due to flow diversion, loss of flow path, loss of pump in the RHR system or loss of cooling from the SW system due to cable damage (RHR-FI-133B, RHR-MOV-MO12B-PASSIVE, RHR-MOV-MO13D-PASSIVE, RHR-MOV-MO16B, RHR-MOV-MO20-PASSIVE, RHR-MOV-MO26B, RHR-MOV-27B, RHR-MOV-MO34B, RHR-MOV-MO38B, RHR-MOV-39B, RHR-MOV-MO57-PASSIVE, RHR-MOV-MO65B, RHR-MOV-MO66B, EE-CB-4160G-RHRP1D, and SW-MOV-MO89B). SPC Train B is the credited train for Decay Heat Removal. The complete loss of RHR flow, or the diversion of flow, would challenge this NSPC.
| |
| Cable damage to the Control Room indication RHR-FI-133B requires monitoring flow at the unaffected ASD Room indication.
| |
| Cable damage to RHR-MOV-MO12B may cause the valve to spuriously close securing discharge from the RHR Heat Exchanger. Control is shifted to the ASD Panel.
| |
| Based on cable damage, RHR-MOV-MO13D may spuriously close, therefore, not allowing for a suction path from the Suppression Pool to establish SPC flow. Control is shifted to the ASD Panel.
| |
| RHR-MOV-MO16B is normally open to ensure a discharge flow path to prevent damage to the RHR Pumps. Based on cable damage, the valve will not be able to close from the Control Room, therefore, resulting in a 4-inch flow diversion from SPC mode of operation.
| |
| Based on cable failure, RHR-MOV-MO20 may spuriously open, resulting in a 20-inch flow diversion through the bypass line, resulting in a loss or reduction of flow during SPC Train B mode of operation.
| |
| Control cable damage may spuriously operate RHR-MOV-MO26B. Thefeeder cable is undamaged. RHR-MOV-MO26B represents a 10-inch diversion path to establishing SPC Train B.
| |
| Both RHR-MOV-MO27B and RHR-MOV-MO25B have cable damage which would allow 24-inch flow diversion from SPC flow.
| |
| Based on cable failures to RHR-MOV-34B, RHR-MOV-MO38B, and RHR-MOV-MO39B, a return path to the Suppression Pool for SPC Train B may not be available.
| |
| RHR-MOV-MO57 damage to cable MR33 could result in spurious opening of the valve without a means to Page C-150
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area ecotn RB-FN Reactor Building 903' Northeast Corner remotely close the valve from the Control Room, resulting in a 4-inch flow diversion.
| |
| RHR-MOV-MO65B cable damage may result in spurious closure isolating flow to the RHR Heat Exchanger in SPC Train B mode.
| |
| RHR-MOV-MO66B, while normally open, is desired to be closed for SPC Train B operation. Cable damage will not allow for closure of the valve from the Control Room, resulting in the bypass of the RHR Heat Exchanger.
| |
| Due to multiple damaged cables, the RHR Pump breaker may fail to close automatically or remotely. This would result in a loss of Decay Heat Removal for SPC Train B.
| |
| Based on cable damage to the RHRSW Booster Pump breakers, they cannot be closed. This removes electrical control of RHR-MOV-MO89B and secures SW flow to the RHR Heat Exchanger.
| |
| This is a separation issue for Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-151
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area RB-FN Reactor Building 903' Northeast Corner Description Preventing loss of containment over-pressure in support of RHR pump operation for SPC operation (RW-AOV-AO82 and RW-AOV-AO94, REC-MOV-712MV, REC-MOV-713MV, PC-AOV-245AV, and PC-AOV-246AV).
| |
| The NSPC require a means of Decay Heat Removal post-fire. SPC Train B is credited for Decay Heat Removal. The loss of containment over-pressure could result in the loss of NPSH for the credited RHR pump during SPC mode of operation.
| |
| Cable damage to the SOVs associated with RW-AOV-AO82, RW-AOV-AO83, RW-AOV-AO93, and RW-AOV-AO94 may result in spurious opening. These valves isolate the Drywell Equipment and Floor Drain Sump discharge paths, and their opening would result in a loss of containment over-pressure.
| |
| REC-MOV-712MV and REC-MOV-713MV isolate the REC Critical and Non-Critical Headers. The valves are normally open, and are required to close to secure flow to the Drywell coolers. Based on cable damage and Control Room abandonment, remote operation of these valves is not possible.
| |
| Cable damage to M355 (PC-AOV-245AV) and M358 (PC-AOV-246AV) may cause the valves to fail open.
| |
| These valves are normally closed and desired closed. Spurious opening of these valves results in Drywell and Suppression Chamber vent and purge lines opening, resulting in loss of containment over-pressure.
| |
| This is a separation issue for Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-152
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire AreaDecito RB-FN Reactor Building 903' Northeast Corner RBFN-10 Description Prevent loss of RPV inventory and high pressure in the low pressure portion of the RWCU system from the Control Room due to cable fire damage (RWCU-MOV-MO1 5).
| |
| The NSPC require a means of isolating the RPV and low pressure systems from the RPV post-fire. Cable damage (MR122) may cause spurious opening and the inability to close RWCU-MOV-MO15, resulting in loss of RPV Inventory to the RWCU system, or cause high pressure in the low pressure portion of RWCU piping downstream.
| |
| This is a separation issue for Inventory and Pressure Control.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None RBEN-1I Description Preventing an RPV overfill condition with spurious RCIC startup and loss of control due to cable damage (RCIC-MOV-MO15).
| |
| The NSPC require a means of maintaining water level in the RPV post-fire. HPCI maintains level in this area, but with the cables damaged due to fire in this area for RCIC-MOV-MO15, RCIC-MOV-MO16, and RCIC-MOV-131MV, system status is not assured, and may result in a startup of the RCIC system without control and cause an RPV overfill condition.
| |
| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-153
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Nebraska Public Power District CNS NFPA 805 Transition Report Attachment C Table B-3 Fire Area Transition Fire Ar,ea Description RB-FN Reactor Building 903' Northeast Corner RBFN- 12 Description Loss of RPV water level and pressure along with Suppression Chamber level and temperature indications in the Control Room (NBI-LT-59B, NBI-LT-91B, NBI-PT-53B, PC-LT-10, and PC-TR-25).
| |
| The NSPC require a means of monitoring plant conditions post-fire. While instrument cables to the Control Room are impacted by the fire, these indications are available at the ASD Panel.
| |
| This is a separation issue for Process Monitoring.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Description Loss of power to critical equipment for plant operation (EE-MCC-TX and SW Pump D).
| |
| The NSCA require a means of powering critical pieces of equipment. EE-MCC-TX feeder cables SG-27A and 27B, along with SW Pump D feeder cable H521. Failure of these cables will result in loss of credited process monitoring instrumentation and the SW function.
| |
| This is a separation issue for Process Monitoring and Vital Auxiliaries.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-154
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrin2tion RB-FN Reactor Building 903' Northeast Corner Required Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?
| |
| ,_Partial (P) S L E R D 2A-1 Detection Ionization R N N N YY N 2A-1 Detection Heat R N N N YY N 2A-1 Suppression Automatic Wet-Pipe P N/A N N Y Y N Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Fire Suppression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. The CRD solenoid-operated valves and the Scram Discharge Volume level instruments will be impacted by actuation of the suppression system. Motor Control Center EE-MCC-K is provided with horizontal spray shields to prevent direct spray on the MCC and the conduit ends are sealed to prevent water from entering the MCCs. The conduit ends entering starter racks EE-STR-125 RCIC, EE-STR (RHR-MOV-MO67), EE-STR-125 RCIC (RCIC-MOV-M0131), and disconnect switches EE-DSC-125 RCIC and EE-SW-125 RCIC and Distribution Panels EE-PNL-AA3, EE-PNL-BB3, EE-PNL-CA, and EE-PNL-CB are provided with seals to prevent water from entering the equipment. In the event of normal operation, the wet-pipe sprinkler system will not adversely effect the other equipment operating within the Fire Zone. The drainage features and equipment pedestals mitigate the potential for flooding damage due to fire suppression, such that the standing water would not affect safety-related equipment. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments None Page C-155
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area RB-J Critical Switchgear Room 1F Fire Zone Descrittion 3A Critical Switchgear Room 1 F Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments / VFDR Decay Heat Removal SPC Train B will be operated to maintain Suppression Pool temperature. RBJ-03 Process Monitoring The following indications will be used to support the Process Monitoring function: None
| |
| - RPV water level and pressure [from Control Room]
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - Emergency Condensate Storage Tank level [from Control Room]
| |
| - RHR and SW flow indications [from Control Room]
| |
| - HPCI flow, pressures, and turbine speed indication [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, RBJ-01 other discharge paths inboard of the MSIVs, and other system pressure boundaries. RPV over-pressure protection is provided by SRVs. Only the self-activated spring lift mode is credited for over-pressure protection. The HPCI system will be used to control RPV pressure and to maintain RPV level.
| |
| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
| |
| Page C-156
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare AreaDecito RB-J Critical Switchgear Room 1F Vital Auxiliaries Mechanical: RBJ-02
| |
| - REC will be supplied by Train B to provide the cooling supply to the ECCS. RBJ-03
| |
| - SW Train B will be operated to provide the cooling supply to the REC system, RHR Heat Exchangers and DG 2.
| |
| Electrical (AC/DC):
| |
| - DG 2 aligned to 4160G Bus
| |
| - 125/250 VDC Train B is available HVAC:
| |
| - DG 2 HVAC system
| |
| - AC Switchgear Room 1G - Essential Control Building HVAC system
| |
| - DC Switchgear Room 1 B - Essential Control Building HVAC system
| |
| - Battery Room 1B - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Room 1B - Essential Control Building HVAC system Reference Document / Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensinn Actions None Page C-157
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descriotion RB-J Critical Switchgear Room 1F Existina Enaineerina Eauivalency Evaluations (EEEEI EEEE EE 09-031 - Evaluation of Critical Switchgear Rooms 1F and 1 G Fire Barrier Separation Purpose The purpose of this evaluation is to document the acceptability of the fire barrier separation that has been provided for Critical Switchgear Rooms 1F and 1G. A fire rating cannot be assigned to the barriers due to miscellaneous door discrepancies, ventilation ducts that do not contain fire dampers at the barriers, and unsealed bus duct penetrations.
| |
| Conclusion Based on the expected fire hazards and the existing fire protection features associated with the Critical Switchgear Rooms, the installation of additional fire seals within the bus duct enclosure, fire dampers in the ventilation ductwork, or penetration seal material in the conduits, will not significantly improve fire protection required to ensure redundant safe shutdown capability. The existing fire barrier configurations are adequate for the fire hazards in the areas, and to prevent propagation of fire between adjacent areas.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| " The wall separating the two Switchgear Room Fire Zones is approximately 12 inches of reinforced concrete.
| |
| " On the Switchgear Room side of the wall, the ducts are coated with a 1.5-hour rated fire retardant material.
| |
| " The outlet of the supply duct and the inlet of the exhaust duct in the Critical Switchgear Room are provided with 1.5-hour rated fire dampers.
| |
| * The exhaust ductwork in the Critical Switchgear Room has a smoke detection system interlock that is arranged to shutdown the operating supply fan.
| |
| * Plant procedures effectively reduce the possibility of a fire involving transient ignition sources and combustibles.
| |
| 9 Equivalent fire severity in both Switchgear Rooms is less than 1-minute and consists of an assumed transient combustible load and small quantities of miscellaneous plastic.
| |
| e The Corridor side of wall near the ventilation openings is essentially void of any significant combustible loading with the exception of miscellaneous combustibles stored in closed metal lockers.
| |
| 9 A smoke detection system has been provided in both Critical Switchgear Rooms which will result in an alarm to the constantly attended Control Room upon activation.
| |
| * Manual fire suppression means has been provided for this area in the form of fire hoses and extinguishers.
| |
| Page C-158
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Dfciit.[ n RB-J Critical Switchgear Room 1F Variances from Deterministic Reauirements (VFDR)
| |
| Description Preventing a RR Pump Seal LOCA due to inability to secure the RR Pump from the Control Room with the REC Non-Critical Header secured (RR Pump Breaker for 4160C-1 CS).
| |
| Breaker F/FDR to the 4160V Bus from the Startup Transformer: This is a normally available, required open breaker that provides motive power to RR Pump A. The RR Pump is required to trip to prevent potential RR Pump Seal LOCA when REC is not available to provide cooling. This would challenge the NSPC for Inventory Control. REC is secured in this fire area to address potential containment over-pressure. Remote operation of the breaker from the Control Room is lost due to cables H251 and H254 (1C bus) fire-induced damage.
| |
| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-159
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion RB-J Critical Switchgear Room 1F Description Loss of Critical Switchgear cooling due to cable damage to damper AD-1408 (HV-FAN-SF-SWGR-1 G and HV-FAN-EF-SWGR-1G).
| |
| Fire damage to cables will not preclude operation of the EF-SWGR-1 G and SF-SWGR-1 G fans from the 1G AC Switchgear Room. Cable damage will affect the operation of ventilation damper AD-1408 by energizing its solenoid and keeping the damper open. The NSCA model requires that either train of Switchgear Room cooling fans be available to ensure Switchgear remains available post-fire.
| |
| Based on damage to damper AD-1408, fans HV-FAN-SF-SWGR-1G and HV-FAN-EF-SWGR-1G will not provide adequate ventilation.
| |
| This is a separation issue for Vital Auxiliaries, Electrical Power Distribution.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Description Preventing a loss of SW for supporting Decay Heat Removal (SW-MOV-MO89B).
| |
| SW Train B is required to support various functions (SPC, HPCI and CS Quad cooling, REC, DGs, etc) for the NSPC. SPC Train B is credited for Decay Heat Removal; REC Train B provides cooling for RHR Pump 1 D and the HPCI Room. The complete loss of SW to the RHR Heat Exchanger could challenge this NSPC.
| |
| Cable damage to both RHRSW Booster Pump breakers would result in the inability to close either breaker, causing SW-MOV-MO89B to fail closed without the ability to open from the Control Room. This would result in the loss of SW flow to the RHR Heat Exchanger for SPC Train B.
| |
| This is a separation issue for Vital Auxiliaries and Decay Heat Removal.
| |
| Page C-160
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area ecotn RB-J Critical Switchgear Room 1 F Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Reluired Fire protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?
| |
| Partial (P) S L E R D 3A Detection Ionization R N N N Y Y N Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Fire Sutrnression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. Per MWR 91-1264, electrical cabinets and conduit have been sealed to mitigate the effects of suppression activities. There are no fixed suppression systems in the area. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments None Page C-161
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Nebraska Public Power District CNS NFPA 805 Transition Report Attachment C Table B-3 Fire Area Transition Fire Area RB-K Critical Switchgear Room 1G Fire Zone Descrittion 3B Critical Switchgear Room 1G Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomolishment Comments I VFDR Decay Heat Removal SPC Train A will be operated to maintain Suppression Pool temperature. RBK-03 RBK-05 Process Monitoring The following indications will be used to support the Process Monitoring function: None
| |
| - RPV water level and pressure [from Control Room]
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - CS, RHR, and SW flow indications [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, RBK-01 other discharge paths inboard of the MSIVs, and other system pressure RBK-03 boundaries. RPV over-pressure protection will be provided by SRVs. Only the self-activated spring lift mode is credited for over-pressure protection. ADS will be used to reduce RPV pressure for operation of Core Spray Train A to maintain RPV level.
| |
| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
| |
| Page C-162
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area D n RB-K Critical Switchgear Room 1G Vital Auxiliaries Mechanical: RBK-02
| |
| - REC will be supplied by SW Train A to provide the cooling supply to the ECCS. RBK-03
| |
| - SW Train A will be operated to provide the cooling supply to the REC system, RBK-04 RHR Heat Exchangers, and DG 1.
| |
| Electrical (AC/DC):
| |
| - DG 1 aligned to 4160F Bus
| |
| - 125/250 VDC Train A is available HVAC:
| |
| - DG/CS Train A - Quad area cooling
| |
| - DG 1 HVAC system
| |
| - AC Switchgear Room 1F - Essential Control Building HVAC system
| |
| - DC Switchgear Room 1A - Essential Control Building HVAC system
| |
| - Battery Room 1A - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Room 1A - Essential Control Building HVAC system Reference Document I Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensina Actions None Page C-163
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition RB-K Critical Switchgear Room 1G Existinq Engineerinq Eauivalency Evaluations (EEEE)
| |
| TEE 09-031 - Evaluation of Critical Switchgear Rooms 1F and 1 G Fire Barrier Separation Purpose The purpose of this evaluation is to document the acceptability of the fire barrier separation that has been provided for Critical Switchgear Rooms 1 F and 1G. A fire rating cannot be assigned to the barriers due to miscellaneous door discrepancies, ventilation ducts that do not contain fire dampers at the barriers, and unsealed bus duct penetrations.
| |
| Conclusion Based on the expected fire hazards and the existing fire protection features associated with the Critical Switchgear Rooms, the installation of additional fire seals within the bus duct enclosure, fire dampers in the ventilation ductwork, or penetration seal material in the conduits, will not significantly improve fire protection required to ensure redundant safe shutdown capability. The existing fire barrier configurations are adequate for the fire hazards in the areas, and to prevent propagation of fire between adjacent areas.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| " The wall separating the two Switchgear Room Fire Zones is approximately 12 inches of reinforced concrete.
| |
| " On the Switchgear Room side of the wall, the ducts are coated with a 1.5-hour rated fire retardant material.
| |
| " The outlet of the supply duct and the inlet of the exhaust duct in the Critical Switchgear Room are provided with 1.5-hour rated fire dampers.
| |
| 9 The exhaust ductwork in the Critical Switchgear Room has a smoke detection system interlock that is arranged to shutdown the operating supply fan.
| |
| 9 Plant procedures effectively reduce the possibility of a fire involving transient ignition sources and combustibles.
| |
| e Equivalent fire severity in both Switchgear Rooms is less than 1-minute and consists of an assumed transient combustible load and small quantities of miscellaneous plastic.
| |
| e The Corridor side of wall near the ventilation openings is essentially void of any significant combustible loading with the exception of miscellaneous combustibles stored in closed metal lockers.
| |
| * A smoke detection system has been provided in both Critical Switchgear Rooms which will result in an alarm to the constantly attended Control Room upon activation.
| |
| e Manual fire suppression means has been provided for this area in the form of fire hoses and extinguishers.
| |
| Page C-164
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area 1ec~to RB-K Critical Switchgear Room 1G Variances from Deterministic Reauirements (VFDR)
| |
| Description Preventing a RR Pump Seal LOCA due to inability to secure the RR Pumps from the Control Room with the REC Non-Critical header secured (RR Pump Breakers for 4160C-1CS and 4160D-1 DS).
| |
| Breakers F/FDR to the 4160V Buses from the Startup Transformer: These are normally available, required open breakers that provide motive power to the RR Pumps. The RR Pumps are required to trip to prevent potential RR Pump Seal LOCA when REC is not available to provide cooling. This would challenge the NSPC for Inventory Control. REC is secured in this fire area to address the potential containment over-pressure. Remote operation of the breaker(s) from the Control Room is lost due to cables H251 and H254 (1C bus) and H291 and H294 (1D bus) fire-induced damage.
| |
| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Recovery Action carried forward as Defense-in-Depth.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-165
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area Descriotion RB-K Critical Switchgear Room IG RBK-02 Description Establish vital auxiliaries by powering the credited 4160F Bus from DG1 (EE-CB-4160F-1FA and EE-CB-4160F-1 FS).
| |
| The NSCA require at least one source of AC power be available. Offsite power from the Emergency Transformer is unavailable due to fire damage. Cable damage (H432 and H433) could result in loss of breaker control, or spurious actuation of normally closed EE-CB-4160F-1FA. Breaker 1FA may not open as part of the transfer process due to loss of the Startup Transformer. Cable damage to H443 in the 1 FS breaker may cause it to spuriously close, placing the 4160F Bus on the damaged bus duct from the Emergency Transformer.
| |
| The FA and FS breaker cables discussed above are different than the cables that relay actual breaker position to the DG breaker to close. Therefore, the potential for out-of-phase paralleling is not a concern based on the following: The DG will start normally as part of the electrical power transfer process. With cable damage to the 1 FA and 1FS breakers, either the 1 FA breaker may stay closed or the 1 FS breaker may close on its own. The 1FS breaker closing is a result of the normal transfer process, or cable damage, even though the Emergency Transformer cabling is damaged by fire. Either of the above situations will result in the DG output breaker not closing on its own. While this ensures the DG and offsite power will not be paralleled out-of-phase, there may be no source of AC power to the credited 4160F Bus.
| |
| This is a separation issue for Vital Auxiliaries, Electrical Power Distribution.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Modification Modification: Item S-2.1 of LAR Attachment S, Table S-2.
| |
| Page C-166
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area RB-K Critical Switchgear Room 1G Description 4160F UV Circuit cable damage affects automatic/remote operation from the Control Room of Critical Pumps for Safe Shutdown (EE-CB-4160F-CSP1A, EE-CB-4160F-RHRP1A, and EE-CB-4160F-RSWP1A).
| |
| Fire in the area could result in damage to the 4KV Bus 1F UV circuit, which will cause a trip signal to the CS Pump 1A, RHR Pump 1A, RHRSW Booster Pump 1A and SW Pump 1A breakers. The SW Pump 1A breaker is covered separately, VFDR RBK-04, due to the time requirements to ensure the DG remains available for powering the 4160F Bus.
| |
| The NSCA requires the ability to maintain RPV level. CS Train A is credited for Inventory Control in this area. RHR Train A is credited to support SPC mode of RHR following a fire in this area. The NSPC require a means of Decay Heat Removal post-fire be available. SPC Train A is credited for Decay Heat Removal. Inability to keep the RHR Pump 1A breaker closed would result in loss of RHR flow to the RHR Heat Exchanger resulting in loss of SPC Train A. Inability to close the RHRSW Booster Pump 1A breaker results in SW-MOV-MO89A closing and staying closed, securing SW flow to the RHR Heat Exchanger A (see VFDR RBK-05). SW provides cooling to REC, DGs, and RHR systems.
| |
| REC is required to provide both Quad cooling in support of Pump operation and cooling for the RHR Pump and Pump Room. Additional Quad heat up due to fire in this area is not credible.
| |
| This is a separation issue for Vital Auxiliaries, Inventory and Pressure Control, and Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Modification and Recovery Action carried forward as Defense-in-Depth for EE-CB-4160F-RSWPIA.
| |
| Modification: Item S-2.1 of LAR Attachment S, Table S-2.
| |
| Modification: Item S-2.1 of LAR Attachment S, Table S-2.
| |
| Page C-167
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area RB-K Critical Switchgear Room 1G Description DG1 is the credited source of power. Damage to SW Pump 1A (4160F UV circuit) results in the requirement for tripping the DG.
| |
| Cable damage to the 4KV Bus 1F UV circuit will cause a trip signal to the SW Pump 1A breaker. Loss of the SW Pump would result in a loss of SW cooling to the RHR Heat Exchangers, DGs, and REC system cooling to critical loads.
| |
| This is a separation issue for Vital Auxiliaries, Inventory and Pressure Control, and Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Modification Modification: Item S-2.1 of LAR Attachment S, Table S-2.
| |
| Description Preventing a loss of SW for supporting Decay Heat Removal (SW-MOV-MO89A).
| |
| SW Train A is required to support various functions (SPC, HPCI and CS Quad cooling, REC, DGs, etc) for the NSPC. SPC Train A is credited for Decay Heat Removal, REC Train A provides cooling for RHR Pump 1A and the CS Quad. The complete loss of SW to the RHR Heat Exchanger could challenge the NSPC. Cable damage to both RHRSW Booster Pump breakers would result in the inability to close either breaker, causing SW-MOV-MO89A to fail closed without the ability to open from the Control Room. This would result in the loss of SW flow to the RHR Heat Exchanger for SPC Train A.
| |
| Note: EE-CB-4160F-SS1F is the feeder breaker, and while it has an overcurrent trip it is not part of the UV circuit, and therefore, this breaker will not open when power is restored to the critical MCCs on the 480F Bus (MCC-Q is one of these that will remain closed - there are several 480 Bus breakers that will trip open on the loss-of-power to the 480V bus). Therefore, once power is restored to the bus (to get the pumps running), SW-MOV-MO89A will be operable from its starter.
| |
| This is a separation issue for Decay Heat Removal.
| |
| Page C-168
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area RB-K Critical Switchgear Room 1G Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Recovery Action carried forward as Defense-in-Depth.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Reauired Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression? L E R D Partial (P) S LE R D 3B Detection Ionization R N N N Y Y N Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Fire Suppression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. Per MWR 91-1264, electrical cabinets and conduit have been sealed to mitigate the effects of suppression activities. There are no fixed suppression systems in the area. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments None Page C-169
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Nebraska Public Power District CNS NFPA 805 Transition Report Attachment C Table B-3 Fire Area Transition Fire Area Dsc.r.Uztion RB-M Reactor Building North / East Side, RHR Heat Exchanger Room A Fire Zone Description 2B RHR Heat Exchanger Room A 3C REC Heat Exchanger and Pump Area 3D Reactor Recirculation Motor Generator Set Lube Oil Cooler Area 3E-2 RWCU Pump Area and Corridor Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomolishment Comments / VFDR Decay Heat Removal SPC Train B will be operated to maintain Suppression Pool temperature. RBM-05 RBM-07 Process Monitoring The following indications will be used to support the Process Monitoring function: RBM-04
| |
| - RPV water level [from Control Room]
| |
| - RPV pressure [from NBI-PI-61 at Rack 25-51]
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - RHR and SW flow indications [from Control Room]
| |
| - Emergency Condensate Storage Tank level [from Control Room]
| |
| - RCIC system flow, pressures, and turbine speed indication [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, RBM-01 other discharge paths inboard of the MSIVs, and other system pressure RBM-03 boundaries. RPV over-pressure protection is provided by SRVs. Only the self- RBM-06 activated spring lift mode is credited for over-pressure protection. The RCIC RBM-08 system will be used to control RPV pressure and to maintain RPV level.
| |
| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
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| Page C-1 70
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fr riDescrin~tion RB-M Reactor Building North / East Side, RHR Heat Exchanger Room A Vital Auxiliaries Mechanical: RBM-02
| |
| - REC will be supplied by SW Train B to provide the cooling supply to the ECCS. RBM-06
| |
| - SW Train B will be operated to provide the cooling supply to the REC system RBM-07 and RHR Heat Exchangers.
| |
| Electrical (AC/DC):
| |
| - Offsite Emergency Transformer aligned to 4160G Bus
| |
| - 125/250 VDC Train B is available HVAC:
| |
| - DG/CS Train A - Quad area cooling
| |
| - AC Switchgear Room 1G - Essential Control Building HVAC system
| |
| - DC Switchgear Room 1B - Essential Control Building HVAC system
| |
| - Battery Rooms 1B - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Room 1 B - Essential Control Building HVAC system Reference Document I Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensing Actions None Existina Engineering Eguivalency Evaluations (EEEE)
| |
| None Page C-171
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire AreaDecito RB-M Reactor Building North / East Side, RHR Heat Exchanger Room A Variances from Deterministic Reauirements (VFDR)
| |
| RBM-01 Description Preventing a RR Pump Seal LOCA due to inability to secure the RR Pumps from the Control Room with the REC Non-Critical Header secured (RR Pump Breakers for 416OC-lCS and 4160D-1DS).
| |
| Breakers F/FDR to the 4160V Buses from the Startup Transformer: These are normally available, required open breakers that provide motive power to the RR Pumps. The RR Pumps are required to trip to prevent a potential RR Pump Seal LOCA when REC is not available to provide cooling. This would challenge the NSPC for Inventory Control.
| |
| REC is secured in this fire area to address potential containment over-pressure. Remote operation of the breaker(s) from the Control Room is lost due to cables H251 and H254 (1C bus), and H291 and H294 (1D bus) fire-induced damage.
| |
| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-172
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion RB-M Reactor Building North / East Side, RHR Heat Exchanger Room A Description Establish vital auxiliaries by powering the credited 4160F and G Bus from Offsite Power (EE-CB-4160F-SS1F, EE-CB-4160F-1FS, EE-CB-4160G-1GS, EE-CB-4160FRHRP1B, and EE-CB-4160G-SS1G)
| |
| The NSCA require at least one source of AC power be available. Both 4160F and G UV circuits have cable damage and DC control power cables are damaged.
| |
| EE-CB-4160F-SS1F breaker cable damage (H422 and H423) may cause it to spuriously trip, causing a loss-of-power to the 480F Bus.
| |
| Cable damage (DC control power and UV Circuit) could result in the breaker (EE-CB-4160F-1 FS) not closing automatically during the normal transfer process due to loss of the Startup Transformer.
| |
| Cable damage (H551, H552, H553, H555 and UV Circuit) could result in the breaker (EE-CB-4160G-1GS) not closing automatically during the normal transfer process due to loss of the Startup Transformer.
| |
| Fire in the area could result in damage to the 4KV Bus 1 F UV circuit which will cause a trip signal to EE-CB-4160F-RHRP1B. The NSCA require the ability to remove Decay Heat post-fire. RHR Train B is credited to support the SPC mode of RHR following a fire in this area. Inability to keep RHR Pump 1 B breaker closed would result in the loss of RHR flow to the RHR Heat Exchanger, resulting in loss of SPC Train B.
| |
| Cable damage (H542, H543, DC control power, and UV circuit) could result in the breaker (EECB-4140G-SS1 G) tripping, securing power to the 480G Bus.
| |
| This is a separation issue for Vital Auxiliaries.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-173
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire AreaDecito RB-M Reactor Building North I East Side, RHR Heat Exchanger Room A RBM-03 Description Ability to close SRV's automatically/remotely from the Control Room is lost due to cable fire damage (Pilot Valves SPV71 D and SPV71 F).
| |
| The NSPC require the ability to isolate the RPV to maintain water inventory above the active fuel.
| |
| Spurious operations could result in the opening of up to two ADS valves. Affected ADS valves need to be returned to their fail-safe closed position within 18 minutes for single spurious operation.
| |
| SRV's D and F are impacted as a result of fire in this area. Cables RP517 and RP518 are impacted for SPV71D, and RP519 and RP520 for SPV71F. In Fire Area RB-M, RP517 and 518 are impacted in the following scenarios: 3C-TS03, 3D-TS02, 3C zone failure and 3D zone failure. In Fire Area RB-M, RP519 and 520 are impacted in the following scenarios: 3C-TS02, 3C-TS12, and 3C zone failure. Therefore, two SRVs would only be impacted at the same time in RB-M for a full zone burnout of Fire Zone 3C.
| |
| This is a separation issue for isolating the RPV for Inventory and Pressure Control.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable - Recovery Action carried forward as Defense-in-Depth.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-174
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fie Ara Descipion RB-M Reactor Building North / East Side, RHR Heat Exchanger Room A RBM-04 Description Preventing the loss of RPV level and pressure indication due to the fire affects on sensing line piping and pressure transmitter signal cable damage (NBI-LI-91A and RFC-PI-90A).
| |
| The NSCA require a means of monitoring RPV water level. NBI-LT-91A, NBI-LT-91B, and NBI-LT- 91C are affected due to sensing lines located in the Fire Area. The NBI-LT-91A and NBI-LT-91C sensing line is located in the west side of the Reactor Building. The NBI-LT-91 B sensing line is located in the east side of the Reactor Building. A separation of approximately 80 feet exists between the redundant sensing lines.
| |
| The NSCA require a means of RPV pressure indication, and all three channels are affected in this area.
| |
| RFC-PI-90A provides the Control Room with RPV pressure indication.
| |
| Note: Fire scenarios in Fire Area RB-M consist of REC Pump motor fires, a ventilated electrical panel fire, non-ventilated electrical panel and MCC fires, and transient fires. The REC Pump motors are not oil lubricated, and there are no secondary combustibles that would be involved in the pump fire or the ventilated electrical panel fire. Therefore, the zone of influence of the fire scenarios in Fire Area RB-M is not large enough to result in damage to targets located 80 feet apart.
| |
| This is a separation issue for Process Monitoring.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-175
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area RB-M Reactor Building North / East Side, RHR Heat Exchanger Room A Description Preventing loss of containment over-pressure in support of RHR pump operation for SPC operation (PC-MOV-231 MV).
| |
| The NSPC require a means of Decay Heat Removal post-fire be available. SPC Train B is credited for Decay Heat Removal. The loss of containment over-pressure could result in the loss of NPSH for the credited RHR pump during the SPC mode of operation.
| |
| Both PC-AOV-246AV and PC-MOV-231 MV cables could be affected by the fire and may spuriously open.
| |
| These valves isolate the Vent and Purge path from the Drywell, and would result in a loss of containment over-pressure.
| |
| This is a separation issue for Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable - Recovery Action carried forward as Defense-in-Depth.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-176
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area 2cLion RB-M Reactor Building North / East Side, RHR Heat Exchanger Room A Description Preventing a full or partial loss of SW for supporting Decay Heat Removal and Inventory and Pressure Control from the Control Room with SW supplying REC (REC-MOV-694MV, REC-MOV- 695MV, REC-MOV-697MV, REC-MOV-698MV, REC-MOV-71 1MV-Passive, REC-MOV-714MV-Passive, SW-MOV-651 MV, SW-MOV-886MV-Passive, SW-MOV-887MV, and EE-CB-4160G-SWP1 B).
| |
| SW Train B is required to support various functions (SPC, HPCI and CS Quad cooling, REC, DGs, etc) for NSPC. RCIC is credited for Inventory and Pressure Control, SPC Train B is credited for Decay Heat Removal, REC Train B provides cooling for RHR Pump 1D and the RHR and CS Pump Rooms (Quads) and SW Train B provides the cooling for REC and RHR Heat Exchangers (DGs not credited). The complete loss or diversion of SW to REC could challenge these NSPCs.
| |
| Current requirements indicate for RCIC that REC flow is required within 4 hours of the start of RCIC Turbine. Based on fire location, heat up of the Quad is not expected.
| |
| NOTE: Cross-ties between REC Train A and REC Train B are opened to support RCIC Room cooling with the credited REC Train B.
| |
| Cable damage to 4160G UV Circuit may cause SW Pump 1 B breaker to spuriously trip. The breaker tripping will cause a complete loss of SW flow.
| |
| This is a separation issue for Inventory and Pressure Control and Vital Auxiliaries.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-177
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descriotion RB-M Reactor Building North / East Side, RHR Heat Exchanger Room A RBM-07 Description Preventing a complete or partial loss of Suppression Pool Cooling due to flow diversion or loss of SW cooling (RHR-MOV-MO20-Passive, RHR-MOV-MO27B, and SW-MOV-MO89B).
| |
| SW Train B is required to support various functions (SPC, HPCI and CS Quad cooling, REC, DGs, etc) for NSPC. SPC Train B is credited for Decay Heat Removal, REC Train B provides cooling for RHR Pump 1B, and REC Train A cools the RCIC Quad. The flow diversion of RHR and/or the complete loss of SW to the RHR Heat Exchanger could challenge this NSPC.
| |
| RHR-MOV-MO20 is normally closed, and desired closed during SPC mode of operation. Based on cable failure (MR22), the valve may spuriously open, resulting in a 20-inch flow diversion through the bypass line. This diversion would result in a loss or reduction of flow during SPC Train B mode of operation.
| |
| RHR-MOV-MO27B is normally open, with RHR-MOV-MO25B normally closed during the SPC mode of operation. Based on cable failure, RHR-MOV-MO25B may spuriously open, resulting in a 20-inch flow diversion without the ability to close either RHR-MOV-MO25B or RHR-MOV-MO27B from the Control Room. This diversion would result in a loss or reduction of flow during SPC Train B mode of operation.
| |
| Cable damage to both RHRSW Booster Pump breakers results in the inability to close either breaker, causing SW-MOV-MO89B to fail closed without the ability to open from the Control Room. This would result in the loss of SW flow to the RHR Heat Exchanger for SPC Train B.
| |
| This is a separation issue for Vital Auxiliaries and Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-178
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area RB-M Reactor Building North / East Side, RHR Heat Exchanger Room A RBM-08 Description Loss of RCIC operation due to cable damage providing erroneous RPV low water level and RPV high water level signals, resulting in RCIC not starting (RCIC ECCS, RCIC-MOV-MO131, and RCIC-MOV-M018).
| |
| Cable damage could cause a spurious RPV high and low water level signal to the RCIC ECCS logic.
| |
| These erroneous signals will not allow RCIC to start up automatically as required. Isolating the damaged cables will allow for RCIC operation.
| |
| This is a separation issue for Inventory and Pressure Control.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-179
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area ecmto RB-M Reactor Building North / East Side, RHR Heat Exchanger Room A Required Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?
| |
| Partial (P) S L E R D 2B None N/A N/A N/A N/A N/A N/A N/A N/A 30 Detection Ionization R N N N N Y N 3C Feature Radiant Energy Shield N/A N/A N N N Y N 3D Detection Ionization R N N N N Y N 3D Suppression Automatic Wet-Pipe P N/A N N N N N 3E-2 None N/A N/A N/A N/A N/A N/A N/A N/A Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Page C-180
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Descrtil RB-M Reactor Building North / East Side, RHR Heat Exchanger Room A Fire Suppression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. Per MWR 91-1264, electrical cabinets and conduit have been sealed to mitigate the effects of suppression activities. In the event of normal operation of the wet-pipe sprinkler system in Fire Zone 3D, there is a limited potential for effects from the system, as water discharge would be contained within the diked area around the RR MG Set Heat Exchangers, which has sealed penetrations. A limited amount of overspray will occur to adjacent areas next to the heat exchangers. This area has no direct flow path to the 903'-6" Elevation below, and there are no identified direct paths from Fire Zone 4D above. The drainage features and equipment pedestals mitigate the potential for flooding damage due to fire suppression, such that the standing water would not affect safety-related equipment. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments In Fire Zone 3C, radiant shielding is being installed for the conduit bank located along the west wall of the Critical Switchgear Rooms to prevent damage from transient fires. See Attachment S, Table S-2, Item S-2.5.
| |
| Cable tray risers west of the elevator, in Fire Zone 3C, are being provided with radiant shielding to prevent damage from transient fires. See Attachment S, Table S-2, Item S-2.6.
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| Page C-181
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Dsrlto RB-N Reactor Building South West Corner, RHR Heat Exchanger Room B and RWCU Heat Exchanger Room Fire Zone Description 2D RHR Heat Exchanger Room B 3E-1 RWCU Regenerative Heat Exchanger Areas 3E-2 RWCU Pump Area and Corridor Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments / VFDR Decay Heat Removal SPC Train A will be operated to maintain Suppression Pool temperature. RBN-01 RBN-02 Process Monitoring The following indications will be used to support the Process Monitoring function: None
| |
| - RPV water level and pressure [from Control Room]
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - CS, RHR, and SW flow indications [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, RBN-01 other discharge paths inboard of the MSIVs, and other system pressure boundaries. RPV over-pressure protection will be provided by SRVs. Only the self-activated spring lift mode is credited for over-pressure protection. ADS will be used to reduce RPV pressure for operation of Core Spray Train A to maintain RPV level.
| |
| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
| |
| Page C-182
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Nebraska Public Power District CNS NFPA 805 Transition Report Attachment C Table B-3 Fire Area Transition Fire Area RB-N Reactor Building South West Corner, RHR Heat Exchanger Room B and RWCU Heat Exchanger Room Vital Auxiliaries Mechanical: None
| |
| - REC will be supplied by Train A to provide the cooling supply to the ECCS.
| |
| - SW Train A will be operated to provide the cooling supply to the REC system and RHR Heat Exchangers.
| |
| Electrical (AC/DC):
| |
| - Offsite Emergency Transformer aligned to 4160F Bus
| |
| - 125/250 VDC Train A is available HVAC:
| |
| - DG/CS Train A - Quad area cooling
| |
| - DG 1 HVAC system
| |
| - AC Switchgear Room 1F - Essential Control Building HVAC system
| |
| - DC Switchgear Room 1A - Essential Control Building HVAC system
| |
| - Battery Room 1A - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Room 1A - Essential Control Building HVAC system Reference Document / Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensina Actions None Existing Engineering Eguivalency Evaluations (EEEE)
| |
| None Page C-183
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Description RB-N Reactor Building South West Corner, RHR Heat Exchanger Room B and RWCU Heat Exchanger Room Variances from Deterministic Reauirements (VFDR)
| |
| RBN-01 Description Preventing loss of containment over-pressure in support of RHR pump operation for SPC operation while not allowing flow diversion from credited REC Train A for cooling to CS Quad and RHR pump (REC-MOV-712MV and REC-MOV-714 MV-Passive).
| |
| The NSPC require a means of RPV Inventory and Pressure Control and Decay Heat Removal post-fire.
| |
| CS Train A is credited for Inventory and Pressure Control and SPC Train A is credited for Decay Heat Removal. The flow diversion through REC-MOV-712MV and REC-MOV-714MV would result in a reduction of cooling flow to the credited RHR Pump and the CS Pump Quads. The loss of containment over-pressure could result in the loss of NPSH for the credited RHR pump during the SPC mode of operation.
| |
| REC-MOV-712MV isolates the REC Non-Critical Header from the outlet of the REC Train A Heat Exchanger. REC is required to provide Quad cooling in support of Core Spray pump operation for NSCA.
| |
| CS Train A is the credited success path following a fire in this area. Current requirements indicate 1 hour is needed to establish Quad cooling. REC-MOV-712VN represents a 12-inch flow diversion from the REC Critical Header to ensure adequate Quad cooling.
| |
| REC-MOV-714MV isolates the REC Train B Heat Exchanger. REC is required to provide Quad cooling in support of CS Pump operation for NSCA. CS Train A is the credited success path following a fire in this area. Current requirements indicate 1 hour is needed to establish Quad cooling. REC-MOV-714MV represents a 6-inch flow diversion from the REC Train A Critical Header to ensure adequate Quad cooling.
| |
| This is a separation issue for Inventory and Pressure Control and Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-184
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area Descriotion RB-N Reactor Building South West Corner, RHR Heat Exchanger Room B and RWCU Heat Exchanger Room RBN-02 Description Preventing a complete or partial loss of Suppression Pool Cooling due to flow diversion (RHR-MOV-M027A).
| |
| SPC Train A is credited for Decay Heat Removal post-fire in support of the NSPC. RHR-MOV-MO27A is normally open with RHR-MOV-MO25A normally closed during the SPC mode of operation. Based on cable failure, RHR-MOV-MO25A may spuriously open, resulting in a 20-inch flow diversion, without the ability to close either RHR-MOV-MO25A or RHR-MOV-MO27A from the Control Room due to cable failures. This diversion would result in a loss or reduction of flow during SPC Train A mode of operation.
| |
| This is a separation issue for Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-185
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition RB-N Reactor Building South West Corner, RHR Heat Exchanger Room B and RWCU Heat Exchanger Room Required Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?
| |
| Partial (P'i S L IE R D Partial ("P 2D None N/A N/A N/A N/A N/A N/A N/A N/A 3E-1 Detection Ionization R N N N N N Y 3E-2 None N/A N/A N/A N/A N/A N/A N/A N/A Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Fire SuoDression Activities Effect on Nuclear Safetv Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. Per MWR 91-1264, electrical cabinets and conduit have been sealed to mitigate the effects of suppression activities. The drainage features and equipment pedestals mitigate the potential for flooding damage due to fire suppression, such that the standing water would not affect safety-related equipment. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments None Page C-186
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descriotion RB-P Reactor Building 958 Accessible Areas Fire Zone Description 4A Reactor Building Elevator and Accessway Area 4B Reactor Building HVAC Area 4C Fuel Pool Heat Exchanger, CRD Repair Room, and Raw Water Cleanup Areas 4D Reactor Recirculation Motor Generator Set Oil Pump Area Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments I VFDR Decay Heat Removal SPC Train A or B will be operated to maintain Suppression Pool temperature. RBP-01 Process Monitoring The following indications will be used to support the Process Monitoring function: None
| |
| - RPV water level and pressure [from Control Room]
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - CS, RHR, and SW flow indications [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, RBP-02 other discharge paths inboard of the MSIVs, and other system pressure boundaries. RPV over-pressure protection will be provided by SRVs. Only the self-activated spring lift mode is credited for over-pressure protection. ADS will be used to reduce RPV pressure for operation of either Core Spray Train A or Train B to maintain RPV level.
| |
| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
| |
| Page C-187
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Nebraska Public Power District CNS NFPA 805 Transition Report Attachment C Table B-3 Fire Area Transition Fare Area Description RB-P Reactor Building 958 Accessible Areas Vital Auxiliaries Mechanical: None
| |
| - REC will be supplied by Train A or B to provide the cooling supply to the ECCS.
| |
| - SW Train A or B will be operated to provide the cooling supply to the REC system and RHR Heat Exchangers.
| |
| Electrical (AC/DC):
| |
| - Offsite Emergency Transformer aligned to 4160F or 4160G Bus
| |
| - 125/250 VDC Trains A and B are available [from Control Room]
| |
| HVAC:
| |
| - RCIC/CS Trains A and B - Quad area cooling
| |
| - AC Switchgear Rooms - Essential Control Building HVAC system
| |
| - DC Switchgear Rooms - Essential Control Building HVAC system
| |
| - Battery Rooms - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Rooms - Essential Control Building HVAC system Reference Document / Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensing Actions None Page C-188
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Nebraska Public Power District ONS NFPA 805 Transition Report Attachment C Table B-3 Fire Area Transition Fire Area Rescr uiltion RB-P Reactor Building 958 Accessible Areas ncv Evaluations fEEEE*
| |
| I=Xiqtinn Frinineering Enuivalenrv Evaluations (EEEEI EEEE Title EE 12-013 - Evaluation of the SLC Pump Tank and Accessway (Fire Zone 5A) and Refueling Floor (Fire Zone
| |
| : 6) Fire Barrier Separation Purpose This evaluation is written to justify several unrated and open penetrations in the Fire Area RB-T floor boundaries to the adjacent fire area, including an open equipment hatchway, an open stairwell, and fire doors having a fire resistance rating less than 3 hours. The evaluation documents that the separation between Fire Area RB-T and adjacent fire areas is adequate to demonstrate compliance NFPA 805 section 4.2.3.2.
| |
| Conclusion The existing fire area boundary configurations and automatic and manual fire protection features provide a level of protection that are adequate to prevent damage to safe shutdown systems in adjacent fire areas. The' performance-based analysis has assessed the adequacy of the fire barrier forming the fire boundary to withstand the fire effects of the hazards in the area.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| * The combustible loading classification for Fire Zone 5A is "LOW" and is mainly attributed to cable insulation, lube oil, miscellaneous plastic, fiberglass, and PVC.
| |
| 9 The SLC equipment is located within a concrete curbed area which will prevent any spill of oil down to Fire Zone 4A via floor openings.
| |
| * The combustible loading classification for Fire Zone 4A is "LOW" and is mainly attributed to cable insulation, miscellaneous fiberglass, and plastic.
| |
| * Fixed ignition sources in Fire Zone 4A are limited to small electrical panels, instrument racks, and MCCs.
| |
| The MCCs are well-sealed, robustly secured panels and are not located adjacent to the open Stair S-3.
| |
| o The lack of significant combustible materials in either fire zone and the lack of intervening combustibles in the open Stair S-3 significantly reduce the chance of fire propagation between zones.
| |
| 9 The combustible loading classification for Fire Zone 5B is "MEDIUM" and is mainly attributed to cable insulation, lube oil, charcoal, miscellaneous plastic, and fiberglass.
| |
| " The combustible loading classification for Fire Zone 6 is "LOW" and is mainly attributed to lube oil.
| |
| " All fire zones are provided with automatic detection system coverage. In the event of a fire, detection system actuation will result in rapid fire brigade response and subsequent manual extinguishment utilizing hose stations and portable extinguishers strategically located in adjacent fire zones.
| |
| * Transient combustibles are administratively controlled by CNS procedure 0.7.1, "Control of Combustibles,"
| |
| effectively reducing the possibility of a fire involving transient materials.
| |
| e Fire Zone 5B is provided with I-beams at the floor to contain the oil to the area around the MG Sets. The location of the I-beams prevents oil entering the area near the fire doors.
| |
| Page C-189
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area RB-P Reactor Building 958 Accessible Areas e The Stud Tensioner in Fire Zone 6 is only used when manned, therefore, a fire involving the oil would be immediately detected. Additionally, the equipment hatchway is provided with steel curbing to prevent oil leakage down to lower elevations.
| |
| * A carbon dioxide hose reel is provided along the west wall near MG Set A in Fire Zone 5B. A portable foam hose cart is located near the southwest stairwell in Fire Zone 5B.
| |
| e Fixed automatic preaction sprinkler system coverage is provided for the Reactor MG Sets in Fire Zone 5B.
| |
| Page C-190
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Description RB-P Reactor Building 958 Accessible Areas Variances from Deterministic Reauirements (VFDR)
| |
| RBP-01 Description Preventing the loss of Decay Heat Removal function during Suppression Pool Cooling operations due to loss of NPSH.
| |
| Both valves (PC-AOV-246AV and PC-MOV-231 MV) in the Drywell vent path could be affected by fire in this area. The spurious opening of PC-MOV-231MV resulting from cable damage to any single cable or combination of MRA13, MRA14, and MRA16 may challenge the NSPC for Decay Heat Removal. When this containment vent/purge line valve opens and stays open, it results in the loss of containment over-pressure, and therefore,.the possible loss of NPSH for the RHR pump in supporting SPC Trains A and B.
| |
| Normally open PC-V-51 0 and normally closed PC-MOV-306MV are in series and provide for equalizing around PC-MOV-231 MV. Neither valve is modeled, based on 2-inch bypass line using a conservative assumption, since both PC-MOV-306MV and PC-MOV-231 MV are located physically in close proximity, fire damage to PC-MOV-231 MV will cause PC-MOV-306MV to fail as-is, which would leave a 2-inch vent path around PC-MOV-231MV.
| |
| This is a separation issue for Decay Heat Removal.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-191
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area RB-P Reactor Building 958 Accessible Areas Description Preventing a RR Pump Seal LOCA due to inability to secure the RR Pumps from the Control Room with the REC Non-Critical header secured (RR Pump Breakers for 4160C-1CS and 4160D-1DS).
| |
| Breakers F/FDR to the 4160V Buses from the Startup Transformer: These are normally available, required open breakers that provide motive power to the RR Pumps. The RR Pumps are required to trip to prevent a potential seal LOCA when REC is not available to provide cooling. This would challenge the NSPC for Inventory and Pressure Control. REC is secured in this fire area to address potential containment over-pressure. Remote operation of the breaker(s) from the Control Room is lost due to cables H251 (1C bus) and H291 (1D bus) fire-induced damage.
| |
| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-192
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition FieAaDescriotion RB-P Reactor Building 958 Accessible Areas Required Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?
| |
| Partial (P) S L E R D 4A Detection Ionization R N N N Y Y N 4B None N/A N/A N/A N/A N/A N/A N/A N/A 4C Detection Ionization R N N N N Y N 4D Detection Ionization R N N N N Y N 4D Suppression Automatic Wet-Pipe F N/A N N N Y N Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Fire Suloression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. Per MWR 91-1264, electrical cabinets and conduit have been sealed to mitigate the effects of suppression activities. In the event of normal operation of the wet-pipe sprinkler system in Fire Zone 4D, water would be dispersed at approximately the 8 ft level and below throughout the zone. The zone is provided with containment dikes and sealed pipe shafts and an enclosed stairwell. Additionally, the door to the stairwell is equipped with a dike to prevent flow of suppression water and oil into the stairwell. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments None Page C-193
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion RB-T Reactor Building East Side and Refueling Floor Fire Zone Descriotion 5A SLC Pump Tank and Accessway 6 Refueling Floor Reaulatorv Basis 4.2.3.2 - Deterministic Approach Performance Goal Method of Accomolishment Comments / VFDR Decay Heat Removal SPC Train A or B will be operated to maintain Suppression Pool temperature. None Process Monitoring The following indications will be used to support the Process Monitoring function: None
| |
| - RPV water level and pressure [from Control Room]
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - CS, RHR, and SW flow indications [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, None other discharge paths inboard of the MSIVs, and other system pressure boundaries. RPV over-pressure protection will be provided by SRVs. Only the self-activated spring lift mode is credited for over-pressure protection. ADS will be used to reduce RPV pressure for operation of either Core Spray Train A or Train B to maintain RPV level.
| |
| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
| |
| Page C-194
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire AreaDecito RB-T Reactor Building East Side and Refueling Floor Vital Auxiliaries Mechanical: None
| |
| - REC will be supplied by Train A or B to provide the cooling supply to the ECCS.
| |
| - SW Train A or B will be operated to provide the cooling supply to the REC system and RHR Heat Exchangers.
| |
| Electrical (AC/DC):
| |
| - Offsite Emergency Transformer aligned to 4160F or 4160G Bus
| |
| - 125/250 VDC Trains A and B are available [from Control Room]
| |
| HVAC:
| |
| - RCIC/CS Trains A and B - Quad area cooling
| |
| - AC Switchgear Rooms - Essential Control Building HVAC system
| |
| - DC Switchgear Rooms - Essential Control Building HVAC system
| |
| - Battery Rooms - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Rooms - Essential Control Building HVAC system Reference Document / Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensing Actions None Page C-195
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descr~iotion RB-T Reactor Building East Side and Refueling Floor Existina Enaineerina Eguivalency Evaluations (EEEE)
| |
| EEE Title EE 12-013 - Evaluation of the SLC Pump Tank and Accessway (Fire Zone 5A) and Refueling Floor (Fire Zone
| |
| : 6) Fire Barrier Separation Purpose This evaluation is written to justify several unrated and open penetrations in the Fire Area RB-T floor boundaries to the adjacent fire area, including an open equipment hatchway, an open stairwell, and fire doors having a fire resistance rating less than 3 hours. The evaluation documents that the separation between Fire Area RB-T and adjacent fire areas is adequate to demonstrate compliance NFPA 805 section 4.2.3.2.
| |
| Conclusion The existing fire area boundary configurations and automatic and manual fire protection features provide a level of protection that are adequate to prevent damage to safe shutdown systems in adjacent fire areas. The performance-based analysis has assessed the adequacy of the fire barrier forming the fire boundary to withstand the fire effects of the hazards in the area.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| e The combustible loading classification for Fire Zone 5A is "LOW" and is mainly attributed to cable insulation, lube oil, miscellaneous plastic, fiberglass, and PVC.
| |
| e The SLC equipment is located within a concrete curbed area which will prevent any spill of oil down to Fire Zone 4A via floor openings.
| |
| * The combustible loading classification for Fire Zone 4A is "LOW" and is mainly attributed to cable insulation, miscellaneous fiberglass, and plastic.
| |
| e Fixed ignition sources in Fire Zone 4A are limited to small electrical panels, instrument racks, and MCCs.
| |
| The MCCs are well-sealed, robustly secured panels and are not located adjacent to the open Stair S-3.
| |
| 9 The lack of significant combustible materials in either fire zone and the lack of intervening combustibles in the open Stair S-3 significantly reduce the chance of fire propagation between zones.
| |
| e The combustible loading classification for Fire Zone 5B is "MEDIUM" and is mainly attributed to cable insulation, lube oil, charcoal, miscellaneous plastic, and fiberglass.
| |
| " The combustible loading classification for Fire Zone 6 is "LOW" and is mainly attributed to lube oil.
| |
| " All fire zones are provided with automatic detection system coverage. In the event of a fire, detection system actuation will result in rapid fire brigade response and subsequent manual extinguishment utilizing hose stations and portable extinguishers strategically located in adjacent fire zones.
| |
| e Transient combustibles are administratively controlled by CNS procedure 0.7.1, "Control of Combustibles,"
| |
| effectively reducing the possibility of a fire involving transient materials.
| |
| e Fire Zone 5B is provided with I-beams at the floor to contain the oil to the area around the MG Sets. The location of the I-beams prevents oil entering the area near the fire doors.
| |
| Page &*196
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition RB-T Reactor Building East Side and Refueling Floor e The Stud Tensioner in Fire Zone 6 is only used when manned, therefore, a fire involving the oil would be immediately detected. Additionally, the equipment hatchway is provided with steel curbing to prevent oil leakage down to lower elevations.
| |
| e A carbon dioxide hose reel is provided along the west wall near MG Set A in Fire Zone 5B. A portable foam hose cart is located near the southwest stairwell in Fire Zone 5B.
| |
| * Fixed automatic preaction sprinkler system coverage is provided for the Reactor MG Sets in Fire Zone 5B.
| |
| Variances from Deterministic Reauirements IVFDR)
| |
| None Required Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?
| |
| Partial (P) S L E R D 5A Detection Ionization R N N N Y N N 6 Detection Heat R N N N Y N N Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Page C-197
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area 1ecito RB-T Reactor Building East Side and Refueling Floor Fire Suppression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario, It has been concluded that water impingement on cables is not a concern. The standpipe system riser in this area, if inadvertently ruptured, could result in water down the pipe chase in which it is located. A minimal amount of water would spill in this area and the standpipe system is equipped with a water flow alarm. The containment H2/02 analyzer panels (PC AN H2/02) are more than 50 feet from the standpipe. Therefore, pipe rupture will not affect these panels. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments None Page C-198
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area r n RB-V Reactor Recirculation Motor Generator Set Area Fire Zone Description 5B Reactor Recirculation Motor Generator Set Area Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomolishment Comments / VFDR Decay Heat Removal SPC Train A or B will be operated to maintain Suppression Pool temperature None Process Monitoring The following indications will be used to support the Process Monitoring function: None
| |
| - RPV water level and pressure [from Control Room]
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - CS, RHR, and SW flow indications [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, RBV-01 other discharge paths inboard of the MSIVs, and other system pressure boundaries. RPV over-pressure protection will be provided by SRVs. Only the self-activated spring lift mode is credited for over-pressure protection. ADS will be used to reduce RPV pressure for operation of either Core Spray Train A or Train B to maintain RPV level.
| |
| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
| |
| Page C-199
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion RB-V Reactor Recirculation Motor Generator Set Area Vital Auxiliaries Mechanical: None
| |
| - REC will be supplied by Train A or B to provide the cooling supply to the ECCS.
| |
| - SW Train A or B will be operated to provide the cooling supply to the REC system and RHR Heat Exchangers.
| |
| Electrical (AC/DC):
| |
| - Offsite Emergency Transformer aligned to 4160F or 4160G Bus
| |
| - 125/250 VDC Trains A and B are available [from Control Room]
| |
| HVAC:
| |
| - RCIC/CS Trains A and B - Quad area cooling
| |
| - AC Switchgear Rooms - Essential Control Building HVAC system
| |
| - DC Switchgear Rooms - Essential Control Building HVAC system
| |
| - Battery Rooms - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Rooms - Essential Control Building HVAC system Reference Document I Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensing Actions None Page C-200
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion RB-V Reactor Recirculation Motor Generator Set Area Existina Enaineerina Eauivalency Evaluations (EEEE EEEE Title EE 12-013 - Evaluation of the SLC Pump Tank and Accessway (Fire Zone 5A) and Refueling Floor (Fire Zone
| |
| : 6) Fire Barrier Separation Purpose This evaluation is written to justify several unrated and open penetrations in the Fire Area RB-T floor boundaries to the adjacent fire area, including an open equipment hatchway, an open stairwell, and fire doors having a fire resistance rating less than 3 hours. The evaluation documents that the separation between Fire Area RB-T and adjacent fire areas is adequate to demonstrate compliance NFPA 805 section 4.2.3.2.
| |
| Conclusion The existing fire area boundary configurations and automatic and manual fire protection features provide a level of protection that are adequate to prevent damage to safe shutdown systems in adjacent fire areas. The performance-based analysis has assessed the adequacy of the fire barrier forming the fire boundary to withstand the fire effects of the hazards in the area.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| e The combustible loading classification for Fire Zone 5A is "LOW" and is mainly attributed to cable insulation, lube oil, miscellaneous plastic, fiberglass, and PVC.
| |
| e The SLC equipment is located within a concrete curbed area which will prevent any spill of oil down to Fire Zone 4A via floor openings.
| |
| * The combustible loading classification for Fire Zone 4A is "LOW" and is mainly attributed to cable insulation, miscellaneous fiberglass, and plastic.
| |
| e Fixed ignition sources in Fire Zone 4A are limited to small electrical panels, instrument racks, and MCCs.
| |
| The MCCs are well-sealed, robustly secured panels and are not located adjacent to the open Stair S-3.
| |
| 9 The lack of significant combustible materials in either fire zone and the lack of intervening combustibles in the open Stair S-3 significantly reduce the chance of fire propagation between zones.
| |
| * The combustible loading classification for Fire Zone 5B is "MEDIUM" and is mainly attributed to cable insulation, lube oil, charcoal, miscellaneous plastic, and fiberglass.
| |
| " The combustible loading classification for Fire Zone 6 is "LOW" and is mainly attributed to lube oil.
| |
| " All fire zones are provided with automatic detection system coverage. In the event of a fire, detection system actuation will result in rapid fire brigade response and subsequent manual extinguishment utilizing hose stations and portable extinguishers strategically located in adjacent fire zones.
| |
| e Transient combustibles are administratively controlled by CNS procedure 0.7.1, "Control of Combustibles,"
| |
| effectively reducing the possibility of a fire involving transient materials.
| |
| e Fire Zone 5B is provided with I-beams at the floor to contain the oil to the area around the MG Sets. The location of the I-beams prevents oil entering the area near the fire doors.
| |
| Page C-201
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion RB-V Reactor Recirculation Motor Generator Set Area e The Stud Tensioner in Fire Zone 6 is only used when manned, therefore, a fire involving the oil would be immediately detected. Additionally, the equipment hatchway is provided with steel curbing to prevent oil leakage down to lower elevations.
| |
| e A carbon dioxide hose reel is provided along the west wall near MG Set A in Fire Zone 5B. A portable foam hose cart is located near the southwest stairwell in Fire Zone 5B.
| |
| 9 Fixed automatic preaction sprinkler system coverage is provided for the Reactor MG Sets in Fire Zone 5B.
| |
| Variances from Deterministic Reauirements (VFDR)
| |
| RBV-01 Description Preventing a RR Pump Seal LOCA due to inability to secure the RR Pumps from the Control Room with the REC Non-Critical Header secured (RR Pump Breakers for 4160C-1CS and 4160D-1 DS).
| |
| Breakers F/FDR to the 4160V Buses from the Startup Transformer: These are normally available, required open breakers provide motive power to the RR Pumps. The RR Pumps are required to trip to prevent a potential seal LOCA when REC is not available to provide cooling. This would challenge the NSCA for Inventory and Pressure Control. REC is secured in this fire area to address potential containment over-pressure. Remote operation of the breaker(s) from the Control Room is lost due to cables H251 and H725 (1C bus), and H291 and H726 (1D bus) fire-induced damage.
| |
| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-202
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Descrintion RB-V Reactor Recirculation Motor Generator Set Area Reauired Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?
| |
| Partial (P) S L E R D 5B Detection Ionization R N N N Y Y N SB Detection Heat R N N N N N N 5B Detection Flame R N N N N N N 5B Detection Heat Actuated Devices R Y N N Y Y N 5B Suppression Preaction Sprinkler System P N/A N N Y Y N 5B Suppression (manual) Deluge Water Spray P N/A N N N N N Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Page C-203
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrin~tion RB-V Reactor Recirculation Motor Generator Set Area Fire Sutpression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. Per MWR 91-1264, electrical cabinets and conduit have been sealed to mitigate the effects of suppression activities. In the event of normal operation of the preaction sprinkler system in the Fire Area there is a limited potential for effects from the system. A preaction system is not pressurized with water throughout its piping system and can only discharge water through a sprinkler head that has operated by fusing the heat sensitive link or by inadvertent rupture of the pipe or head. The preaction system has a predischarge alarm by heat actuating devices (HADS) and a water flow alarm that would notify the Control Room of both occurrences. The suppression system for the SBGT Room was modified (DC-86-012) to a manual actuation system. The SBGT filter water spray systems are located in the filter housing assemblies, and the nozzles would discharge within the entire enclosure upon manual actuation. The enclosure is watertight and resultant water would be channeled into a floor drain within the room.
| |
| Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments None Page C-204
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descriotioon TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility Fire Zone DescriDtion 1 1A Turbine Lube Oil Storage Tank Room 11 B Turbine Building Basement - South 11C H2 Seal Oil Unit Area 11D Condenser Pit Area 11E Reactor Feed Pumps Area 11F Turbine Building Controlled Corridor 882' Elevation 11G Steam Jet Air Ejector Room 11H Mechanical Vacuum Pumps Room 11J Condensate, Condensate Booster and TEC Pumps Area 11K Turbine Oil Conditioner Room 11L Pipe Chase 12A ISO Phase Bus Duct Area 12B Turbine Building Controlled Corridor 903' Elevation 12C Condenser and Heater Bay Areas 12D Turbine Building Floor - North 12E Turbine Oil Reservoir Area 12F Turbine Building Document Storage Vault 13A Turbine Operating Floor 13B Non-Critical Switchgear Room 13C Electrical Shop 13D Instrument Shop, Instrument Records and Chart Rooms 15 Heating Boiler Room 16 Turbine Building Exhaust Fan Room 17 Water Treatment Building 18A Machine Shop 18B Machine Shop Clean Tool Room 18C Machine Shop Oil Storage Room 18D Machine Shop Paint Storage Room Page C-205
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descriotmon TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility 18E Machine Shop Lunch Room and Records Storage Room 19A Office Building Controlled Corridor 903' Elevation 19B Office Building Occupancies and Controlled Corridors 19C Office Building Penthouse 21A Radwaste Building Basement 21B Radwaste Building First Floor 21C Radwaste Building Second Floor 21 D Radwaste Building Third Floor 22A Augmented Radwaste Building Basement 22B Augmented Radwaste Building First Floor 22C Augmented Radwaste Building Second Floor 24 Multi-Purpose Facility Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments / VFDR Decay Heat Removal SPC Train A will be operated to maintain Suppression Pool temperature None Process Monitoring The following indications will be used to support the Process Monitoring function: None
| |
| - RPV water level and pressure [from Control Room]
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - CS, RHR, and SW flow indications [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, TBA-01 other discharge paths inboard of the MSIVs, and other system pressure boundaries. RPV over-pressure protection will be provided by SRVs. Only the self-activated spring lift mode is credited for over-pressure protection. ADS will be used to reduce RPV pressure for operation of Core Spray Train A to maintain RPV level.
| |
| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
| |
| Page C-206
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Description TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility Vital Auxiliaries Mechanical: TBA-02
| |
| - REC will be supplied by SW Train A to provide the cooling supply to the ECCS. TBA-03
| |
| - SW Train A will be operated to provide the cooling supply to the REC system, TBA-04 RHR Heat Exchangers, and DG 1. TBA-05 Electrical (AC/DC):
| |
| - Diesel Generator 1 aligned to 4160F Bus
| |
| - 125/250 VDC Train A is available [from Control Room]
| |
| HVAC:
| |
| - RCIC/CS Train A - Quad area cooling
| |
| - DG 1 HVAC system
| |
| - AC Switchgear Rooms - Essential Control Building HVAC system
| |
| - DC Switchgear Rooms - Essential Control Building HVAC system
| |
| - Battery Rooms - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Rooms - Essential Control Building HVAC system Reference Document I Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensing Actions None Page C-207
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area D in TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility Existing Enaineering Eguivalency Evaluations (EEEE)
| |
| EEEE Tit EE 09-031 - Evaluation of Critical Switchgear Rooms 1F and 1G Fire Barrier Separation Purpose The purpose of this evaluation is to document the acceptability of the fire barrier separation that has been provided for Critical Switchgear Rooms 1F and 1G. A fire rating cannot be assigned to the barriers due to miscellaneous door discrepancies, ventilation ducts that do not contain fire dampers at the barriers, and unsealed bus duct penetrations.
| |
| Conclusion Based on the expected fire hazards and the existing fire protection features associated with the Critical Switchgear Rooms, the installation of additional fire seals within the bus duct enclosure, fire dampers in the ventilation ductwork, or penetration seal material in the conduits, will not significantly improve fire protection required to ensure redundant safe shutdown capability. The existing fire barrier configurations are adequate for the fire hazards in the areas, and to prevent propagation of fire between adjacent areas.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| " The wall separating the two Switchgear Room Fire Zones is approximately 12 inches of reinforced concrete.
| |
| " On the Switchgear Room side of the wall, the ducts are coated with a 1.5-hour rated fire retardant material.
| |
| " The outlet of the supply duct and the inlet of the exhaust duct in the Critical Switchgear Room are provided with 1.5-hour rated fire dampers.
| |
| * The exhaust ductwork in the Critical Switchgear Room has a smoke detection system interlock that is arranged to shutdown the operating supply fan.
| |
| * Plant procedures effectively reduce the possibility of a fire involving transient ignition sources and combustibles.
| |
| e Equivalent fire severity in both Switchgear Rooms is less than 1-minute and consists of an assumed transient combustible load and small quantities of miscellaneous plastic.
| |
| * The Corridor side of wall near the ventilation openings is essentially void of any significant combustible loading with the exception of miscellaneous combustibles stored in closed metal lockers.
| |
| 9 A smoke detection system has been provided in both Critical Switchgear Rooms which will result in an alarm to the constantly attended Control Room upon activation.
| |
| e Manual fire suppression means has been provided for this area in the form of fire hoses and extinguishers.
| |
| Page C-208
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility EEEE Title EE 09-035 - Evaluation of Fire Doors Purpose Fire door assemblies provided in fire-rated barriers may vary slightly from listed configurations, and may or may not provide the same fire rating as that required of the fire barrier. The evaluation documents the adequacy of the configurations that have been provided for fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and R115, and justifies the continued use of the configurations, as they have been determined to provide a level of protection that is adequate for the fire hazards in the areas.
| |
| " Door D202 separates the Cable Expansion Room (Fire Area CB-D) from Stair A-9 (Fire Area TB-A)
| |
| " Door H105 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Turbine Building Floor North (Fire Area TB-A) 9 Doors H200 and H201 separate the Cable Spreading Room (Fire Area CB-D) from Stair A-10 (Fire Area CB-A) 9 Door H202 separates the Cable Spreading Room (Fire Area CB-D) from the Office Building Controlled Corridor (Fire Area TB-A)
| |
| * Door H306 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Computer Room (Fire Area CB-D)
| |
| * Door H307 separates the Computer Room (Fire Area CB-D) from the I and C Shop (Fire Area TB-A)
| |
| " Door N103 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Turbine Building Mezzanine North (Fire Area TB-A) e Door N104 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Diesel Generator Room 1B (Fire Area DG-B) e Door R6 separates the Reactor Building Southeast Quad (Fire Area RB-CF) from the Suppression Pool Area (Fire Area RB-E) e Door R7 separates the Reactor Building Northwest Quad (Fire Area RB-B) from the Suppression Pool Area (Fire Area RB-E) 9 Doors R101 and R102 separate the Reactor Building 903' Northeast Corner (Fire Area RB-FN) from the Office Building Controlled Corridor (Fire Area TB-A) e Door R1 15 separates Reactor Building 903'-6" CRD Units - South (Fire Area RB-DI) from the Exterior Transformer Yard (Fire Area YD)
| |
| Conclusion The fire door configurations (i.e., fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and R1 15) have been determined to provide a level of protection commensurate with the fire hazards of the areas, and adequate separation has been provided. In general, minor variations to the Page C-209
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility configurations, such as conduit penetrations through the door frames, slightly larger gaps between doors and frames, and doors rated for less than that required of the barrier, have been evaluated as acceptable based on the fire hazards on either side of the barrier.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| 9 Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
| |
| e Fire hoses and portable extinguishers are strategically located throughout the plant for use by the responding fire brigade.
| |
| " Ventilation systems can typically be used for smoke and heat removal.
| |
| * Due to control of transient combustibles and ignition sources, door proximity to permanent combustibles, and fire area combustible loading, the majority of these doors will not be challenged by a credible fire. This effectively reduces the risk of the identified deviations.
| |
| * The automatic sprinkler system and smoke detection provided in the Cable Expansion Room (Fire Area CB-D) are credited for the acceptability of door D202.
| |
| * The automatic smoke detection systems provided in the Seal Water Pump Area and Corridor (Fire Area CB-A) and in the Turbine Building Floor North (Fire Area TB-A) are credited for the acceptability of door H105.
| |
| 9 The pre-action sprinkler system and automatic smoke detection provided in the Cable Spreading Room (Fire Area CB-D) are credited for the acceptability of doors H200 and H201.
| |
| 9 The automatic total flooding Halon 1301 suppression system and automatic smoke detection provided in the Computer Room (Fire Area CB-D) are credited for the acceptability of doors H306 and H307.
| |
| o The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1A (Fire Area DG-A) and the heat detection installed are credited for the acceptability of doors N103 and N104.
| |
| * The smoke and heat actuated devices provided in the Turbine Building Mezzanine (Fire Area TB-A) are credited for the acceptability of doors N103.
| |
| e The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1B (Fire Area DG-B) and the heat detection installed are credited for the acceptability of door N104.
| |
| a The automatic heat detection provided in the Reactor Building Northwest Quad (Fire Area RB-CF) is credited for the acceptability of door R6.
| |
| 9 The automatic heat detection provided in the Reactor Building Southeast Quad (Fire Area RB-B) is credited for the acceptability of door R7.
| |
| * The automatic suppression system provided in the Office Building Corridor (Fire Area TB-A) is credited for Page C-210
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Description TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility the acceptability of doors R101 and R102.
| |
| * The automatic sprinkler system and smoke detection provided in the Reactor Building 903' Northeast Corner (Fire Area RB-FN) is credited for the acceptability of doors R101 and R102.
| |
| * The automatic deluge suppression system actuated by heat actuated devices provided for the yard transformers (Fire Area YD) are credited for the acceptability of door R1 15.
| |
| * Actuation of the detection systems will prompt rapid fire brigade response and subsequent manual extinguishment.
| |
| EEEE Title EE 09-036 - Evaluation of Cable Expansion Room Penetration Seals Purpose This evaluation documents the adequacy of the non-fire rated expansion joints in the Cable Expansion Room Appendix R fire barriers. In addition, conduit penetrations exist in the floor/ceiling assembly penetrating to the Office Building Corridor below that are not sealed with grout to the depth specified in the design details.
| |
| Conclusion Based on the fire protection features provided in the Cable Expansion Room, including automatic suppression and detection system coverage, the ability to achieve safe shutdown independent of the area, and the lack of safe shutdown equipment/cables and combustible materials in the fire zone adjacent to the Cable Expansion Room, the configurations, as provided, are considered adequate.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| * The expansion joints are provided with 14 gauge metal covers. The metal covers will provide some degree of fire protection to impede the spread of fire, smoke, and hot gases to the adjacent fire zones.
| |
| * An automatic sprinkler system and smoke detectors are provided in the Cable Expansion Room. In the event of a fire in the area, detection system actuation will result in alarm in the Control Room, fire brigade response, and subsequent manual extinguishment utilizing hose stations and portable extinguishers.
| |
| 9 The presence of automatic detection and suppression ensures that a fire will be limited by automatic or manual suppression, such that breaching of the barriers via the expansion joints or conduit penetrations will be limited.
| |
| e Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of a fire.
| |
| Page C-211
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility EEEE Title EE 09-047 - Doors Required for NFPA 805 Building Separation Purpose This evaluation was written to justify fire door assemblies provided in fire-rated barriers that may vary slightly from listed configurations, and may or may not provide the same fire rating as that required of the fire barrier.
| |
| This evaluation documents the adequacy of the configurations that have been provided for fire doors B100, B101, B1 14A, and D301, and justifies the continued use of the configurations, as they have been determined to provide a level of protection that is adequate for the fire hazards in the areas.
| |
| Conclusion The fire door configurations have been evaluated (i.e., fire doors B100, B101, B114A, and D301) to provide a level of protection commensurate with the fire hazards of the areas, and adequate separation has been determined to be provided. In general, minor variations to the configurations such as conduit penetrations through the door frames, slightly larger gaps between doors and frames, and doors rated for less than that required of the barrier have been evaluated as acceptable.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| " Fire severities do not exceed the fire-rated integrity of the doors.
| |
| " Detection and/or suppression systems are present in certain zones discussed. Actuation of the detection systems will prompt rapid fire brigade response, and subsequent manual extinguishment using fire hoses and portable extinguishers strategically located throughout the plant.
| |
| e Due to control of transient combustibles and ignition sources, door proximity to permanent combustibles, and fire area combustible loading, the majority of these doors will not be challenged by a credible fire. This effectively reduces the risk of the identified deviations.
| |
| * Certain doors discussed are normally closed with card reader access that is monitored by Security personnel.
| |
| Page C-212
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire AreaDecito TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility EEEE Title LBDCR 2004-023 - Evaluation of a FHA Revision to Relocate the Fire Barrier Between Fire Area IV/Fire Zone 8D and Fire Area VII/Fire Zone 24 Purpose The purpose of this evaluation is to demonstrate the relocated fire barrier between Fire Area IV/Fire Zone 8D and Fire Area VIII/Fire Zone 24 is adequate. The section of the barrier that is being changed is the wall area adjacent to, and including, door H100. The barrier is being moved to the vestibule walls and ceiling on the north side of H100. Door H100 will no longer be considered part of the fire barrier. Door H114 on the east side of the vestibule will be evaluated to show it is adequate for the fire hazards that are present. Door H1 14 is located on the east side of the vestibule. The door is a single leaf unrated metal door. The door has been barricaded with a 1/2 in. thick carbon steel plate plug welded to the frame of the door. The west side of door H1 14 has been barricaded with concrete blocks stacked approximately 6 ft high and 3 ft deep.
| |
| Conclusion The walls and ceiling of the vestibule can be credited as a 3-hour fire rating. Based on the fire hazard analysis, fire door H1 14 is adequate for the hazards associated with the area.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| * The automatic smoke detection system that alarms in the Control Room will result in prompt fire brigade response and manual fire brigade extinguishment. Based on low combustible loading and detection in the area, the fire zone boundaries are adequate to prevent fire spread to adjacent fire areas and fire zones. Pre-fire plans are available for fire brigade use in responding to fire events in the fires zones.
| |
| * An automatic wet pipe sprinkler system has been provided in the Swing Charger Room adjacent to the west wall of Fire Zone 8C.
| |
| e Given a fire in this zone, safe shutdown can be accomplished as verified by the Appendix R Safe Shutdown Analysis Report.
| |
| e Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
| |
| * The construction features associated with door H1 14 and the vestibule are similar to door R1 15. Door R1 15 was evaluated under EE 09-035.
| |
| e Based on the construction of the barrier and door H1 14 with welded steel plate and the fire severity present in Fire Area VIII/Fire Zone 24 side of the barrier, the Fire Area VIII/Fire Zone 24 fire would not be expected to breach the barrier. Also, a fire starting in Fire Area VIII/Fire Zone 24 would be mitigated by the automatic suppression system so that it would not provide a significant challenge to barrier. A fire starting in Fire Area IV/Fire Zone 8D would not be expected to spread to Fire Area VIII/Fire Zone 24 due to lack of combustibles in the area, lack of combustibles inside the vestibule, and the construction features of door H1 14.
| |
| * The walls and ceiling of the vestibule can be credited as a 3-hour fire rating. Based on the fire hazard Page C-213
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area ecotn TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility analysis, fire door H1 14 is adequate for the hazards associated with the area.
| |
| EEEE Title EE 86 Evaluation of HVAC Ducts and Fire Door Between the Control Room and Controlled Corridor Purpose This engineering evaluation is being prepared to document the acceptability of the three ventilation duct penetrations that are not provided with fire dampers located in the Control Room south wall, which provides Appendix R fire barrier separation between the Control Room and the Controlled Corridor.
| |
| Conclusion Based on the construction of the assembly, the lack of significant fire hazards and combustible loading and the presence of installed fire protection features including fire detection, the configuration that has been provided is adequate for the fire hazards of the areas.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| e The Control Room is constantly attended. Any anticipated fire would be quickly discovered and extinguished in its incipient stage.
| |
| 9 The two larger vent ducts are at an elevation approximately 12 feet above the floor, which is above the suspended ceilings in the corridor. It is, therefore, unlikely that a fire would cause direct flame exposure to the duct in the corridor.
| |
| e The corridor area is essentially void of any significant combustible loading with the exception of miscellaneous combustibles stored in closed metal lockers. There are essentially no combustibles normally located in the corridor near the duct penetrations. It is extremely unlikely that the penetrations would ever be exposed to a significant fire.
| |
| * Fire propagation from the Control Room to the corridor is considered inconsequential from a safe shutdown standpoint since the office corridor does not contain any safe shutdown cables or equipment.
| |
| * Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
| |
| * There are no openings, such as ventilation grills, on either side of the wall in the large ducts to allow flame propagation to enter the ductwork.
| |
| * The Battery Room exhaust duct is a Schedule 80 pipe. Fire propagation into or through this pipe is not considered a credible event, as it is of significant construction so as to prevent fire spread.
| |
| Page C-214
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area ecotn TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility jEEE Title EE 97-124 - Evaluation of Steam Tunnel East Wall Fire Barrier Purpose The purpose of this evaluation is to document the adequacy of the fire barrier separating the Steam Tunnel and the Heater Bay on the 909'-6" Elevation of the Turbine Building. This evaluation was prepared to address the adequacy of the entire barrier separation that has been provided, and to justify the lack of fire-rated penetration seal configurations in the barrier.
| |
| Conclusion The barrier between Zones 2E and 12C is an acceptable configuration with respect to limiting fire spread potential between adjacent areas. Safe shutdown capability is assured for both Fire Zones, as documented in the Safe Shutdown Analysis Report. Therefore, this barrier configuration is adequate for CNS Fire Protection Program purposes.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| e The fire hazards and combustible loading in the vicinity of the barrier on the Heater Bay side consists primarily of potential transient combustibles. There are negligible quantities of fixed combustible materials near the barrier. The lack of significant fire hazards and combustible loading precludes the possibility of a fire developing to such an extent as to breach and propagate into the Steam Tunnel.
| |
| e There are negligible fire hazards and combustible loading in the vicinity of the barrier on the Steam Tunnel side. The lack of significant fire hazards and combustible loading precludes the possibility of a fire developing to such an extent as to breach the barrier and propagate into the Heater Bay.
| |
| " Access to these areas is controlled during power operations.
| |
| " Safe shutdown capability is assured for both Fire Zones, as documented in the Safe Shutdown Analysis Report.
| |
| * Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
| |
| Page C-215
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Description TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility Variances from Deterministic Reauirements 1VFDR1 TBA-01 Description Preventing a RR Pump Seal LOCA due to inability to secure the RR Pumps from the Control Room with the REC Non-Critical Header secured (RR Pump Breakers for 4160C-1CS and 4160D-1DS).
| |
| Breakers F/FDR to the 4160V Buses from the Startup Transformer: These are normally available, required open breakers that provide motive power to the RR Pumps. The RR Pumps are required to trip to prevent a potential seal LOCA when REC is not available to provide cooling. This would challenge the NSPC for Inventory and Pressure Control. REC is secured in this fire area to address potential containment over-pressure. Remote operation of the breaker(s) from the Control Room is lost due to cables H251 and H725 (1C bus), and H291 and H726 (1D bus) fire-induced damage.
| |
| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with Recovery Action.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: None Page C-216
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fie Ar Qsrato TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility TBA-Q2 Description Establish vital auxiliaries by powering the credited 4160F Bus from DG1 (EE-CB-4160F-1FA, EE-CB-4160F-1FS, and EE-CB-4160DG1-EG1).
| |
| The NSCA require at least one source of AC power be available. Offsite power from the Emergency Transformer is unavailable due to fire damage. Cable damage (H432 and H433) could result in loss of breaker control or spurious actuation of normally closed EE-CB-4160F-1FA. Breaker 1FA may not open as part of the transfer process due to loss of the Startup Transformer. Cable damage to H443 in the 1 FS Breaker may cause it to spuriously close, placing the 4160F Bus on the damaged Emergency Transformer. Cable damage to DG20 could blow the "close breaker" circuit control fuses if the DG selector switch is in "Auto," not allowing the DG1 breaker to close, therefore, not placing the DGI on the bus. The DG is not rated to normally carry both the Vital and Non-Vital buses. Additionally the DG1 breaker is interlocked with the AF/FA breakers, and will not close if the breaker is not opened. Therefore, cbreakers 1FS, 1FA, DG1-EG1 need to be operated to ensure that the credited critical train of power (4160F) can be energized from the DG1. Operation of DG1 is covered in TBA-05.
| |
| This is a separation issue for Vital Auxiliaries, Electrical Power Distribution.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable - Recovery Action carried forward as Defense-in-Depth with modification.
| |
| See LAR Attachment G, Table G-1 for Recovery Action details.
| |
| Modification: Item S-2.2 of of LAR Attachment S, Table S-2.
| |
| Page C-217
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Description TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility Description Loss of Critical Switchgear cooling due cable damage to Cooling Fan (HV-'FAN-EF-SWGR-1 F).
| |
| Fire damage to cable M1368 will not preclude operation of the EF-SWGR-1 F fan from the 1F AC Switchgear Room. Cable damage will affect the operation of ventilation dampers AD-1405 and/or AD-1407 by energizing their solenoids and keeping the dampers open. The NSCA model requires that either train of the IF AC Switchgear Room Cooling Fans be available to ensure the Switchgear remains available post-fire.
| |
| This is a separation issue for Vital Auxiliaries, Electrical Power Distribution.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Page C-218
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Description TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility TBA-04 Description 4160F UV Circuit cable damage affects automatic/remote operation from the Control Room of Critical Pumps for Safe Shutdown (EE-CB-4160F-CSPIA, EE-CB-4160F-RHRP1A, and EE-CB-4160F-RWSP1A).
| |
| Fire in the area could result in damage to the 4KV Bus 1F UV circuit, which will cause a trip signal to the CS Pump 1A, RHR Pump 1A, RHRSW Booster Pump 1A breakers. The NSCA require the ability to maintain RPV water level. CS Train A is the credited train for Inventory and Pressure Control in this area.
| |
| RHR Train A is credited to support the SPC mode of RHR following a fire in this area. The NSPC require a means of Decay Heat Removal post-fire. SPC Train A is credited for Decay Heat Removal. Inability to keep the RHR Pump 1A breaker closed would result in loss of RHR flow to the RHR Heat Exchanger, resulting in loss of SPC Train A. Inability to close the RHRSW Booster Pump 1A breaker results in SW-MOV-MO89A closing, and staying closed, isolating SW flow to the RHR Heat Exchanger. SW provides cooling to the REC, DGs, and RHR systems. REC is required to provide both Quad cooling in support of CS Pump operation, and cooling for the RHR pump and RHR Quad. Additional Quad heat-up due to fire in the TB is not credible.
| |
| This is a separation issue for Vital Auxiliaries, Electrical Power Distribution.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with modification.
| |
| Modification: Item S-2.2 of of LAR Attachment S, Table S-2.
| |
| Page C-219
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Description TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility TBA-05 Description DG1 is the credited source of power for a fire in Fire Area TB-A. Damage to SW Pump 1A (4160F UV circuit), results in the requirement for tripping the DG, or inability to start the DG and place it on the bus.
| |
| Cable damage to the 4KV Bus 1F UV circuit will cause a trip signal to the SW Pump 1A Breaker. Loss of the SW pump would result in a loss of SW cooling to the RHR Heat Exchangers, DGs, and REC system cooling to critical loads.
| |
| This is a separation issue for Vital Auxiliaries, Electrical Power Distribution.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable with modification.
| |
| Modification: Item S-2.2 of of LAR Attachment S, Table S-2.
| |
| Page C-220
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area Descrintion TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility Reauired Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?
| |
| Partial (P) S L E R D 11A Detection Ionization R N N N N N N 11A Detection Heat Actuated Devices R Y N N N Y N 11A Suppression Automatic Water Spray F N/A N N N Y N 11B Detection Ionization R N N N N Y N 11 B Detection Heat Actuated Devices R Y N N N Y N 11B Suppression Automatic Wet-Pipe F N/A N N N Y N 11C Detection Ionization R N N N N N N 11C Detection Heat Actuated Devices R Y N N N Y N 11C Suppression Automatic Water Spray F N/A N N N Y N 11D Detection Heat R N N N N N N 11D Suppression Automatic Wet-Pipe F N/A N N N Y N 11 E Detection Heat Activated Devices R Y N N N Y N 11E Detection Heat R N N N N N N 11E Suppression Automatic Water Spray F N/A N N N Y N 11F Detection Ionization R N N N N Y N 11F Suppression Automatic Wet-Pipe F N/A N N N Y N 11G Detection Heat R N N N N N N 11G Suppression Automatic Wet-Pipe F N/A N N N N N 11H Detection Heat R N N N N N N 11H Suppression Automatic Wet-Pipe F N/A N N N N N 11J Detection Ionization R N N N N N N 11J Suppression Automatic Wet-Pipe P N/A N N N Y N 11K Detection Ionization R N N N N N N 11 K Detection Heat Actuated Devices R Y N N N Y N Page C-221
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition FireAr ecmlg TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility 11K Suppression Automatic Water Spray F N/A N F N +IN IYI N
| |
| -+ I F I 4 4-11L None N/A N/A N/A N/A N/A N/A N/A N/A 12A Detection Heat R N N N N N N 12A Detection Heat Activated Devices R Y N N N N N 12A Suppression Automatic Water Spray P N/A N N N N N 12B None N/A N/A N/A N/A N/A N/A N/A N/A 12C Detection Heat Activated Devices R Y N N N Y N 12C Detection Heat R N N N N N N 12C Suppression Automatic Water Spray P N/A N N N Y N 12D Detection Ionization R N N N Y Y N 12D Detection Heat Actuated Devices R Y N N Y Y N 12D Suppression Automatic Wet-Pipe P N/A N N N Y N 12E Detection Heat Actuated Devices R Y N N N Y N 12E Detection Ionization R N N N N N N 12E Suppression Automatic Water Spray F N/A N N N Y N 12F Detection Ionization R N N N Y N N 12F Suppression Automatic Wet-Pipe F N/A N N Y N N 13A Detection Heat R Y N N N Y N 13A Detection Flame R N N N N Y N 13A Suppression Automatic Carbon Dioxide P N/A N N N Y N 13A Suppression Automatic Water Spray P N/A N N N Y N 13B Detection Ionization R N N N N Y N 13C Detection Ionization R N N N N Y N 13D Detection Ionization R N N N Y N N 15 Detection Heat R N N N N N N 15 Suppression Automatic Wet-Pipe F N/A N N N Y N 16 Detection Ionization R N N N N N N 17 Detection Ionization R N N N N N N 18A Detection Heat R N N N N N N Page C-222
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area ecofn TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility 18A Detection Ionization R N N + N t N IN + N
| |
| -I- 1 18A Suppression Automatic Wet-Pipe P N/A N N N IN N 18B Suppression Automatic Wet-Pipe F N/A N N N N N 18C Detection Ionization R N N N N N N 18C Suppression Automatic Wet-Pipe F N/A N N N N N 18D Detection Ionization R N N N N N N 18D Suppression Automatic Wet-Pipe F N/A N N N N N 18E Detection Ionization R N N N N N N 18E Suppression Automatic Wet-Pipe F N/A N N N N N 19A Suppression Automatic Wet-Pipe P N/A N N Y N N 19B Detection Ionization R N N N Y N N 19B Suppression Automatic Wet-Pipe F N/A N N N N N 19C Detection Ionization R N N N N N N 19C Detection Heat R N N N N N N 19C Suppression Automatic Wet-Pipe P N/A N N N N N 19C Suppression (manual) Water Spray P N/A N N N N N 21A Detection Ionization R N N N N N N 21B Detection Ionization R N N N Y N N 21B Detection Heat R N N N Y N N 21C Detection Heat R N N N N N N 21C Detection Ionization R N N N N N N 21C Suppression Bottled Halon 1301 P N/A N N N N N 21C Suppression Automatic Wet-Pipe P N/A N N N N N 21 D Detection Ionization R N N N N N N 21D Suppression Automatic Wet-Pipe P N/A N N N N N 22A Detection Ionization R N N N N N N 22A Detection Heat R N N N N N N 22B Detection Ionization R N N N Y N N 22B Detection Flame R N N N Y N N Page C-223
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area Description TB-A Turbine Building, Non-Critical Switchgear Room, Office Building, Radwaste Building, Augmented Radwaste Building, and Multi-Purpose Facility 22B Detection
| |
| * Heat R N N N Y N N 22C Detection Ionization R N N N N N N 22C Detection Heat R N N N N N N 22C Detection Flame R N N N N N N 22C Suppression Automatic Water Spray P N/A N N N N N 24 Detection Heat R Y N N Y N N 24 Suppression Preaction Sprinkler System P N/A N N Y N N Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Fire SuDoression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. Per MWR 91-1264, electrical cabinets and conduit have been sealed to mitigate the effects of suppression activities. In the event of normal operation, the automatic suppression systems will not adversely effect the other equipment operating within the Fire Zone. The drainage features and equipment pedestals mitigate the potential for flooding damage due to fire suppression, such that the standing water would not affect safety-related equipment. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
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| Fire Area Comments None Page C-224
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area D~escrintion TB-C Steam Tunnel Fire Zone Description 2E Steam Tunnel Reaulatorv Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments I VFDR Decay Heat Removal SPC Train A or B will be operated to maintain Suppression Pool temperature None Process Monitoring The following indications will be used to support the Process Monitoring function: None
| |
| - RPV water level and pressure [from Control Room]
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - CS, RHR, and SW flow indications [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, TBC-01 other discharge paths inboard of the MSIVs, and other system pressure boundaries. RPV over-pressure protection will be provided by SRVs. Only the self-activated spring lift mode is credited for over-pressure protection. ADS will be used to reduce RPV pressure for operation of either Core Spray Train A or Train B to maintain RPV level.
| |
| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
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| Page C-225
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area Descrintion TB-C Steam Tunnel Vital Auxiliaries Mechanical: None
| |
| - REC will be supplied by SW Train A or B and operated to provide the cooling supply to the ECCS.
| |
| - SW Train A or B will be operated to provide the cooling supply to the REC system and RHR Heat Exchangers.
| |
| Electrical (AC/DC):
| |
| - Offsite Emergency Transformer aligned to 4160F or 4160G Bus
| |
| - 125/250 VDC Trains A and B are available [from Control Room]
| |
| HVAC:
| |
| - CS Trains A and B - Quad area cooling
| |
| - DG 1 and 2 HVAC system
| |
| - AC Switchgear Rooms - Essential Control Building HVAC system
| |
| - DC Switchgear Rooms - Essential Control Building HVAC system
| |
| - Battery Rooms - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Rooms - Essential Control Building HVAC system Reference Document I Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensing Actions None Page C-226
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area ecamo TB-C Steam Tunnel Existina Enqineerinq Eguivalency Evaluations (EEEE)
| |
| TEE 05-034 - Evaluation of the Reclassification of Door R1 04 Under the FHA Purpose The purpose of this evaluation is to permanently reclassify door R1 04 from a 3-hour fire door to a 1-hour fire door required to separate Fire Area RB-FN/Fire Zone 2A-1 (Reactor Building 903'-6" Northeast Corner) and Fire Area TB-C/Fire Zone 2E (Steam Tunnel).
| |
| Conclusion It is acceptable to revise the fire barrier between Fire Area RB-FN/Fire Zone 2A-1, and Fire Area TB-C/Fire Zone 2E from a 3-hour rated barrier to a 1-hour fire rated barrier.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| e Ignition sources near door R104 include, but are not limited to: MCC-K, RCIC Rack, and Condensate Pumps CP-R-A1 and A2. Each of these ignition sources is spatially separated from door R104 by approximately 5 feet or more. In the case of MCC-K, as much as approximately 15 feet. A postulated fire at each of these ignition sources would propagate upward into the cable raceways. Horizontal propagation will not occur due to the scarcity and discontinuity of combustibles in the zone. Without horizontal propagation of the postulated fire, no challenge can be made to door R104.
| |
| e The combustible loading calculation, NEDC 93-161, shows that the primary contributor of combustibles in Reactor Building Elev. 903'-6" are located 20 feet above the floor in the overhead cable raceways. These cables are fire retardant and are equivalent to IEEE-383 rated cable. Fire in the cable raceways would not present a fire severity of greater than 1 hour to door R104 due to a spatial separation of 10 feet or more.
| |
| * This area is also equipped with fire and smoke detection as well as fire suppression. The smoke and fire detections systems would ensure immediate fire brigade response. The fire suppression system alone will mitigate any postulated fire at the floor level, well before the fire reaches a severity of greater than 1 hour.
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| Page C-227
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Nebraska Public Power District CNS NFPA 805 Transition Report Attachment C Table B-3 Fire Area Transition Fire Area TB-C Steam Tunnel
| |
| ~EEEE le~ EE 97-124 - Evaluation of Steam Tunnel East Wall Fire Barrier Purpose The purpose of this evaluation is to document the adequacy of the fire barrier separating the Steam Tunnel and the Heater Bay on the 909'-6" Elevation of the Turbine Building. This evaluation was prepared to address the adequacy of the entire barrier separation that has been provided, and to justify the lack of fire-rated penetration seal configurations in the barrier.
| |
| Conclusion The barrier between Zones 2E and 12C is an acceptable configuration with respect to limiting fire spread potential between adjacent areas. Safe shutdown capability is assured for both Fire Zones, as documented in the Safe Shutdown Analysis Report. Therefore, this barrier configuration is adequate for CNS Fire Protection Program purposes.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| * The fire hazards and combustible loading in the vicinity of the barrier on the Heater Bay side consists primarily of potential transient combustibles. There are negligible quantities of fixed combustible materials near the barrier. The lack of significant fire hazards and combustible loading precludes the possibility of a fire developing to such an extent as to breach and propagate into the Steam Tunnel.
| |
| * There are negligible fire hazards and combustible loading in the vicinity of the barrier on the Steam Tunnel side. The lack of significant fire hazards and combustible loading precludes the possibility of a fire developing to such an extent as to breach the barrier and propagate into the Heater Bay.
| |
| " Access to these areas is controlled during power operations.
| |
| " Safe shutdown capability is assured for both Fire Zones, as documented in the Safe Shutdown Analysis Report.
| |
| * Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
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| Page C-228
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire AreaDecito TB-C Steam Tunnel Variances from Deterministic Reauirements (VFDR)
| |
| TBC-01 Description Ability to close SRV's automatically/remotely from the Control Room could be lost due to cable fire damage (Pilot Valves SPV71E, SPV71 F, SPV71G, and SPV71 H).
| |
| The NSPC require the ability to isolate the RPV to maintain water inventory above the active fuel.
| |
| Spurious operations could result in the opening of up to four ADS valves. Affected ADS SRVs need to be returned to their fail-safe closed position within 18 minutes for single spurious operation.
| |
| This is a separation issue for Inventory and Pressure Control, RPV Isolation.
| |
| Disposition A fire risk evaluation was performed using the guidelines of NFPA 805 Section 4.2.4 that determined that this VFDR meets the risk acceptance criteria.
| |
| Risk: Acceptable Modification: None Reouired Fire protection Systems and Features None Fire Suppression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. The steam tunnel is not subject to an adverse effects to equipment by water intrusion from fire suppression systems. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments None Page C-229
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area *Des, gfio YD Yard, Fire Pumphouse, Off-Gas Building, and Optimum Water Chemistry Building Fire Zone Descrintion 23A Electric Motor Driven Fire Pump Room 23B Diesel Driven Fire Pump Room 23C Diesel Oil Tank Room 25 Off-Gas Building 26 Optimum Water Chemistry Building Yard Transformer Yard Reaulatorv Basis 4.2.3.2 - Deterministic Approach Performance Goal Method of Accomplishment Comments I VFDR Decay Heat Removal SPC Train A or B will be operated to maintain Suppression Pool temperature None Process Monitoring The following indications will be used to support the Process Monitoring function: None
| |
| - RPV water level and pressure [from Control Room]
| |
| - Suppression Pool level and temperature [from Control Room]
| |
| - CS, RHR, and SW flow indications [from Control Room]
| |
| Inventory and Pressure Control RPV isolation will be accomplished by manual isolation of main steam lines, None other discharge paths inboard of the MSIVs, and other system pressure boundaries. RPV over-pressure protection will be provided by SRVs. Only the self-activated spring lift mode is credited for over-pressure protection. ADS will be used to reduce RPV pressure for operation of either Core Spray Train A or Train B to maintain RPV level.
| |
| Reactivity Control Subcritical conditions will be achieved and maintained by insertion of the control None rods caused by de-energizing RPS. The reactor scram will be the result of an automatic RPS trip or from operator initiation of a manual trip.
| |
| Page C-230
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area YD Yard, Fire Pumphouse, Off-Gas Building, and Optimum Water Chemistry Building Vital Auxiliaries Mechanical: None
| |
| - REC will be supplied by Train A or B and operated to provide the cooling supply to the ECCS.
| |
| - SW Train A or B will be operated to provide the cooling supply to the REC system, RHR Heat Exchangers and DGs.
| |
| Electrical (AC/DC):
| |
| - DG 1 or 2 aligned to 4160F or 4160G Bus
| |
| - 125/250 VDC Trains A and B are available [from Control Room]
| |
| HVAC:
| |
| - CS Trains A and B - Quad area cooling
| |
| - DG 1 and 2 HVAC system
| |
| - AC Switchgear Rooms - Essential Control Building HVAC system
| |
| - DC Switchgear Rooms - Essential Control Building HVAC system
| |
| - Battery Rooms - Essential Control Building HVAC system
| |
| - Auxiliary Relay Room and RPS MG Set Rooms - Essential Control Building HVAC system Reference Document I Document Detail CNS Calculation NEDC 11-019 "Nuclear Safety Capability Assessment" Licensina Actions None Page C-231
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area DescaJ~t~o.B YD Yard, Fire Pumphouse, Off-Gas Building, and Optimum Water Chemistry Building Existina Enaineerina Eauivalency Evaluations (EEEE)
| |
| ETitle EE 09-035 - Evaluation of Fire Doors Purpose Fire door assemblies provided in fire-rated barriers may vary slightly from listed configurations, and may or may not provide the same fire rating as that required of the fire barrier. The evaluation documents the adequacy of the configurations that have been provided for fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and R115, and justifies the continued use of the configurations, as they have been determined to provide a level of protection that is adequate for the fire hazards in the areas.
| |
| " Door D202 separates the Cable Expansion Room (Fire Area CB-D) from Stair A-9 (Fire Area TB-A)
| |
| " Door H105 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Turbine Building Floor North (Fire Area TB-A) e Doors H200 and H201 separate the Cable Spreading Room (Fire Area CB-D) from Stair A-10 (Fire Area CB-A) e Door H202 separates the Cable Spreading Room (Fire Area CB-D) from the Office Building Controlled Corridor (Fire Area TB-A) e Door H306 separates the Seal Water Pump Area and Corridor (Fire Area CB-A) from the Computer Room (Fire Area CB-D)
| |
| " Door H307 separates the Computer Room (Fire Area CB-D) from the I and C Shop (Fire Area TB-A)
| |
| " Door N103 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Turbine Building Mezzanine North (Fire Area TB-A)
| |
| * Door N104 separates the Diesel Generator Room 1A (Fire Area DG-A) from the Diesel Generator Room 1B (Fire Area DG-B)
| |
| * Door R6 separates the Reactor Building Southeast Quad (Fire Area RB-CF) from the Suppression Pool Area (Fire Area RB-E)
| |
| * Door R7 separates the Reactor Building Northwest Quad (Fire Area RB-B) from the Suppression Pool Area (Fire Area RB-E)
| |
| * Doors R101 and R102 separate the Reactor Building 903' Northeast Corner (Fire Area RB-FN) from the Office Building Controlled Corridor (Fire Area TB-A) e Door R115 separates Reactor Building 903'-6" CRD Units - South (Fire Area RB-DI) from the Exterior Transformer Yard (Fire Area YD)
| |
| Conclusion The fire door configurations (i.e., fire doors D202, H105, H200, H201, H202, H306, H307, N103, N104, R6, R7, R101, R102, and R115) have been determined to provide a level of protection commensurate with the fire Page C-232
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area ecotn YD Yard, Fire Pumphouse, Off-Gas Building, and Optimum Water Chemistry Building hazards of the areas, and adequate separation has been provided. In general, minor variations to the configurations, such as conduit penetrations through the door frames, slightly larger gaps between doors and frames, and doors rated for less than that required of the barrier, have been evaluated as acceptable based on the fire hazards on either side of the barrier.
| |
| Basis The bases that justify this conclusion are summarized as follows:
| |
| 9 Transient combustibles, hot work, and ignition sources are controlled by administrative procedures that effectively reduce the possibility of fires in these areas.
| |
| e Fire hoses and portable extinguishers are strategically located throughout the plant for use by the responding fire brigade.
| |
| " Ventilation systems can typically be used for smoke and heat removal.
| |
| " Due to control of transient combustibles and ignition sources, door proximity to permanent combustibles, and fire area combustible loading, the majority of these doors will not be challenged by a credible fire. This effectively reduces the risk of the identified deviations.
| |
| e The automatic sprinkler system and smoke detection provided in the Cable Expansion Room (Fire Area CB-D) are credited for the acceptability of door D202.
| |
| 9 The automatic smoke detection systems provided in the Seal Water Pump Area and Corridor (Fire Area CB-A) and in the Turbine Building Floor North (Fire Area TB-A) are credited for the acceptability of door H 105.
| |
| e The pre-action sprinkler system and automatic smoke detection provided in the Cable Spreading Room (Fire Area CB-D) are credited for the acceptability of doors H200 and H201.
| |
| e The automatic total flooding Halon 1301 suppression system and automatic smoke detection provided in the Computer Room (Fire Area CB-D) are credited for the acceptability of doors H306 and H307.
| |
| e The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1A (Fire Area DG-A) and the heat detection installed are credited for the acceptability of doors N103 and N104.
| |
| e The smoke and heat actuated devices provided in the Turbine Building Mezzanine (Fire Area TB-A) are credited for the acceptability of doors N103.
| |
| * The automatic total flooding carbon dioxide system actuated by smoke detectors provided in Diesel Generator Room 1B (Fire Area DG-B) and the heat detection installed are credited for the acceptability of door N104.
| |
| * The automatic heat detection provided in the Reactor Building Northwest Quad (Fire Area RB-CF) is credited for the acceptability of door R6.
| |
| e The automatic heat detection provided in the Reactor Building Southeast Quad (Fire Area RB-B) is credited for the acceptability of door R7.
| |
| * The automatic suppression system provided in the Office Building Corridor (Fire Area TB-A) is credited for Page C-233
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fare Area YD Yard, Fire Pumphouse, Off-Gas Building, and Optimum Water Chemistry Building the acceptability of doors R101 and R102.
| |
| e The automatic sprinkler system and smoke detection provided in the Reactor Building 903' Northeast Corner (Fire Area RB-FN) is credited for the acceptability of doors R101 and R102.
| |
| 9 The automatic deluge suppression system actuated by heat actuated devices provided for the yard transformers (Fire Area YD) are credited for the acceptability of door R1 15.
| |
| * Actuation of the detection systems will prompt rapid fire brigade response and subsequent manual extinguishment.
| |
| Variances from Deterministic Reauirements (VFDR)
| |
| None Page C-234
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fire Area D~escriotion YD Yard, Fire Pumphouse, Off-Gas Building, and Optimum Water Chemistry Building Required Fire Protection Systems and Features Fire Local (L) Detection Zone Type of System Specific Type of System Remote (R) Actuates Required System?
| |
| Full (F) Suppression?
| |
| Partial (P) S L E R D 23A Detection Heat R N N N N N N 23A Detection Ionization R N N N N N N 23B Detection Ionization R N N N N N N 23B Detection Flame R N N N N N N 23B Detection Heat R N N N N N N 23B Suppression Automatic Wet-Pipe F N/A Y N N N N 23C Detection Heat R N N N N N N 23C Suppression Automatic Wet-Pipe F N/A N N N N N 25 None N/A N/A N/A N/A N/A N/A N/A N/A 26 None N/A N/A N/A N/A N/A N/A N/A N/A Yard Detection Heat Actuated Devices R Y N N Y Y N Yard Suppression Deluge Water Spray P N/A N N Y Y N Legend:
| |
| Table Field: "Required System?"
| |
| S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Exemption E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to maintain adequate balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Page C-235
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment C Table B-3 Fire Area Transition Fore Area YD Yard, Fire Pumphouse, Off-Gas Building, and Optimum Water Chemistry Building Fire Suppression Activities Effect on Nuclear Safety Performance Criteria The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate Fire Zone. For this reason, fire brigade activities are not expected to fail components not immediately involved in the fire scenario. It has been concluded that water impingement on cables is not a concern. In the event of normal operation, the transformer deluge systems will not adversely effect the other equipment operating within the yard. The drainage features mitigate the potential for flooding damage due to fire suppression, such that the standing water would not affect safety-related equipment. Since it is shown that suppression effects will not impact the NSPC, the Fire Area configuration is deemed acceptable.
| |
| Fire Area Comments The automatic wet-pipe sprinkler system provided over the diesel fire pump is required for compliance with Section 3.9.4 of NFPA 805.
| |
| Page C-236
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment D ATTACHMENT D NEI 04-02 Non-Power Operational Modes Transition 8 Pages Page D-1
| |
| | |
| Kld:,hrnýL-n D"kliý NI ~hracL'a Dm.hli,- D,,iju~r DniAtinr rliefriM I ',JVV~l fliciri,-4
| |
| ('KICZ IKir:DA C'NIQ M~DA Q09 TI 101
| |
| ý 4i QA~ T,,~,nIOlLl~JI D ^r+ L -- Affn^ký +nfl 1 si+i,~n Di~nrr+ - A++,!.,.km~m4 I ~~L'I 0CI'.0 I IAUII'.J LilOti l'..,L '.JI ~SJ ~I I fl 'J'JJ I I ~~LflJI flhIOI.OI III l~I IL Li NFPA 805 Section 1.3.1 Nuclear Safety Goal The nuclear safety goal is to provide reasonable assurance that a fire during any operational mode and plant configuration will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition.
| |
| FAQ 07-0040, Rev. 4, Implementing Guidance F.A Review existing Outage Management Processes.
| |
| Define Higher Risk Evolutions (HREs), if not already defined in plant outage management procedures. The HRE definition should consider the following:
| |
| * Time to boil
| |
| " Reactor coolant system and fuel pool inventory
| |
| * Decay heat removal capability Review Cooper Nuclear Station (CNS) Procedure 0.50.5 provides the definition for Higher Risk Evolutions (HRE) used during plant outages:
| |
| Outage activities,plant configurations,or conditions during shutdown where the plant is more susceptible to an event causing loss of a key safety function.
| |
| Procedure 0.50.5 provides the following as examples of HRE and/or elevated risk time periods:
| |
| * Transfer of RPS power supplies with SDC in service
| |
| * Performance of Procedures 6.1 DG.302 or 6.2DG.302
| |
| * Lowered inventory operation
| |
| * Plant in electrical backfeed lineup Procedure 0.50.5 uses time to boil and decay heat removal system availability in defining actions associated with HRE. Procedure 0.50.5 does not specify all conditions considered HRE, but the examples above are consistent with the FAQ 07-0040, Revision 4, guidance. A Shutdown Safety Contingency Plan is required when entering any HRE. Time to boil is a specified condition to be considered in developing a Contingency Plan.
| |
| Procedure 0.50.5 directs that risk management actions should be developed and implemented to include the fire risk of outage activities.
| |
| Reference Documents
| |
| : 1. CNS Procedure 0.50.5, Revision 23, "Outage Shutdown Safety"
| |
| : 2. CNS Procedure 6.1DG.302, Revision 65, "Undervoltage Logic Functional, Load Shedding, and Sequential Loading Test (DIV 1)"
| |
| : 3. CNS Procedure 6.2DG.302, Revision 56, "Undervoltage Logic Functional, Load Shedding, and Sequential Loading Test (DIV 2)"
| |
| : 4. FAQ 07-0040, Revision 4, "Non-Power Operations Clarifications" (ADAMS Accession No. ML082070249), as approved by the NRC (ADAMS Accession No.: ML082200528)
| |
| Page D-2
| |
| | |
| CNS NFPA 805 Transition Report - Attachment D Nebraska Public Power Distri NFPA 805 Section 1.3.1 Nuclear Safety Goal The nuclear safety goal is to provide reasonable assurance that a fire during any operational mode and plant configuration will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition.
| |
| FAQ 07-0040, Rev. 4, Implementing Guidance F.2 Identify Components and Cables.
| |
| The identification of systems and components to be included in this Non-Power Operations (NPO) Review begins with the identification of the Plant Operational States (POS) that need to be considered.
| |
| Review CNS Procedure 0.50.5, Attachment 1, defines the following Key Safety Functions (KSFs):
| |
| * Decay Heat Removal
| |
| " Fuel Pool Cooling
| |
| * Inventory Control
| |
| * Containment
| |
| * Power Supplies
| |
| " Reactivity Control Based on FAQ 07-0040, Revision 4, the POS considered for equipment and cable selection in CNS Calculation NEDC 11-003 are:
| |
| POS 1 This POS starts when the RHR system is put into service. The RPV head is on and the RCS is closed such that an extended loss of the decay heat removal function without operator intervention could result in a RCS re-pressurization above the shutoff head for the RHR pumps.
| |
| POS 2 This POS represents the shutdown condition when: (1) the RPV head is removed and RPV water level is less than the minimum level required for movement of irradiated fuel assemblies within the RPV, as defined by Technical Specifications, or (2) a sufficient RCS vent path exists for decay heat removal.
| |
| POS 3 This POS represents the shutdown condition when the RPV water level is equal to, or greater than, the minimum level required for movement of irradiated fuel assemblies within the RPV as define by Technical Specifications. This POS occurs during Mode 5.
| |
| The evaluation of these POS resulted in the exclusion of Fuel Pool Cooling, Containment, and Reactivity Control KSF from further consideration based on the following justifications:
| |
| Fuel Pool Cooling is required in order to prevent boiling and the resulting loss of inventory, which can cause damage to the stored fuel cells when they are uncovered.
| |
| However, per USAR Section X-3.6.3, there is sufficient time to establish adequate makeup to the Spent Fuel Pool prior to the onset of bulk boiling. Plant procedures require logging the temperature starting at every four hours in the event that cooling is lost. A number of options are available for replenishing the water to prevent uncovering Page D-3
| |
| | |
| Ne ra k Pu ..li Power...
| |
| ..... ..... CNS NFPA 805 Transition ReDort - Attachment D the fuel, including the use of fire hoses, or cross-ties to the RHR system. Therefore, it is unnecessary to model the Fuel Pool Cooling system.
| |
| * The Containment KSF specifies the Secondary Containment as the equipment/volume of concern during NPO modes. No specific equipment has been modeled to satisfy this KSF since administrative and procedural controls are credited. The requirements for containment closure capability are contained in CNS Procedure 0.50.5, "Outage Shutdown Safety". Maintenance of decay heat removal and inventory KSF will preclude the need for establishing containment during the times when containment may be relaxed. When containment must be intact, the equipment used is covered by the CNS Technical Specifications, plant design, and procedural or administrative controls.
| |
| * The NPO analysis excludes the Reactor Protection System since the plant is already in a shutdown state with all control rods inserted (or reactivity controls are in place per the CNS Technical Specifications to ensure the reactor stays shutdown). No additional equipment is required for the reactivity KSF as the control rods are designed such that sufficient negative reactivity is inserted to ensure Keff <0.99 even with the most reactive rod stuck in the fully withdrawn position.
| |
| In CNS Calculation NEDC 11-003, the components relied upon to provide the remaining KSF including support functions were identified. The selection of equipment was further broken down and related by KSF success paths. Power supplies and other supporting components such as interlocks were identified, listed, and tied with their component and KSF success paths in the SAFE fire protection safe shutdown analysis software. For those components not already in SAFE, cable selection and routing were performed in accordance with the Nuclear Safety Capability Assessment (NSCA) methodology, CNS Calculation NEDC 11-019. The NSCA methodology identified all required cables associated with a component and this information was added to SAFE. The SAFE software was run and the resulting analysis by fire area identified "pinch points," that is, fire areas where a KSF success path was not available.
| |
| Reference Documents
| |
| : 1. CNS Procedure 0.50.5, Revision 23, "Outage Shutdown Safety"
| |
| : 2. FAQ 07-0040, Revision 4, "Non-Power Operations Clarifications" (ADAMS Accession No. ML082070249), as approved by the NRC (ADAMS Accession No.: ML082200528)
| |
| : 3. CNS Calculation NEDC 11-019, Revision 0, "EPM Report: R1906-004-002, Nuclear Safety Capability Assessment"
| |
| : 4. CNS Calculation NEDC 11-003, Revision 0, "Non-Power Operation Modes Transition Review of EPM Report R1906-006-001" Page D-4
| |
| | |
| Klnkrnolen D KH^ *~LI D^%Ajýr IIJV~ILuIL~
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| |
| ('KIQ KIC'DA Qnr, T fl~.JIi~I f Lt~t I10"a i4i I
| |
| D UOLIJI V~UI r+
| |
| A 44 k flLOU *I Iq 4 n Iu L NFPA 805 Section 1.3.1 Nuclear Safety Goal The nuclear safety goal is to provide reasonable assurance that a fire during any operational mode and plant configuration will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition.
| |
| FAQ 07-0040, Rev. 4. Implementing Guidance F.3 Perform Fire Area Assessments (identify pinch points).
| |
| Identify locations where:
| |
| * Fires may cause damage to the equipment (and cabling) credited above, or
| |
| " KSF are achieved solely by crediting recovery actions, e.g., alignment of gravity feed.
| |
| Fire modeling may be used to determine if postulated fires in a compartment are expected to damage equipment (and cabling) thereby eliminating a pinch point.
| |
| Review The NPO fire area reviews conservatively assumed that the entire contents of a fire area would be lost. These reviews identified that there are fire areas where a single fire could result in a loss of all credited paths for a given KSF (i.e., a pinch point). The review also identified that there are certain fire areas that are vulnerable to a loss of a KSF if certain system trains or components are taken out of service during a non-power operational mode and a fire were to occur (i.e. fire area where only a single path is recovered). Fire areas where a fire might cause damage to equipment required to support a KSF path are identified in CNS Calculation NEDC 11-003.
| |
| Twenty-one (21) generic fire area pinch points (i.e. a fire area which contains at least one KSF with a pinch point) were identified during the performance of the NPO reviews of the twenty-five (25) fire areas analyzed. Details of the pinch points and fire areas containing the pinch points are contained in CNS Calculation NEDC 11-003.
| |
| The assessments that were performed as part of the NPO review conservatively assumed that all NPO components or component cables in the fire area may be lost due to a fire. Using the review methodology outlined in CNS Calculation NEDC 11-003 and the recovery approaches that were developed to alleviate the identified "pinch points," which are also presented in the calculation, precluded the need to utilize fire modeling in order to achieve a KSF.
| |
| Reference Document
| |
| : 1. CNS Calculation NEDC 11-003, Revision 0, "Non-Power Operation Modes Transition Review of EPM Report R1 906-006-001" Page D-5
| |
| | |
| k1gaKrnolen D_ "klii- DmAiimr ki~rc~'
| |
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| |
| JV~i~I, r)iofriM firi4CRI JCI L ~ r'KICZ KMDA RI)r, T I~lIO~l
| |
| / % lfl IDA QL no;+;^n Dý Taci~r.
| |
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| |
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| |
| +~rH lflIII~ en+f LL n
| |
| NFPA 805 Section 1.3.1 Nuclear Safety Goal The nuclear safety goal is to provide reasonable assurance that a fire during any operational mode and plant configuration will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition.
| |
| FAQ 07-0040, Rev. 4. Implementing Guidance F.4 Manage risks associated with fire-induced vulnerabilities during the outage.
| |
| During those NPO evolutions where risk is relatively low:
| |
| The normal fire protection program defense-in-depth actions are credited for addressing the risk impact of those fires that would cause equipment damage but would not be expected to cause the total loss of that KSF. The following actions are considered to be adequate to address minor losses of system capability or redundancy:
| |
| " Control of Ignition Sources o Hot Work (cutting, welding and/or grinding) o Temporary Electrical Installations o Electric portable space heaters
| |
| * Control of Combustibles o Transient fire hazards o Modifications o Flammable and Combustible liquids and gases
| |
| " Compensatory Actions for fire protection system impairments o Openings in fire barriers o Inoperable fire detectors or detection systems o Inoperable fire suppression systems
| |
| * Housekeeping Ensure that the normal fire protection defense-in-depth features are applicable during NPO modes.
| |
| During those NPO evolutions that are defined as HRE:
| |
| Additional fire protection defense in depth measures will be taken during HRE by:
| |
| * Managing risk in fire areas that contain known pinch points.
| |
| " Managing risk in fire areas where pinch points may arise because of equipment taken out of service NUMARC 91-06 discusses the development of outage plans and schedules. A key element of that process is to ensure the KSF perform as needed during the various outage evolutions.
| |
| During outage planning, the NPO compartment assessment should be reviewed to identify areas of single-point KSF vulnerability during higher risk evolutions to develop any needed contingency plans/actions. For those areas consider combinations of the following options to reduce fire risk depending upon the significance of the potential damage.
| |
| * Prohibition or limitation of hot work in fire areas during periods of increased vulnerability
| |
| * Verification of operable detection and/or suppression in the vulnerable areas.
| |
| Page D-6
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Renort - Attachment D Nebr.ska.Public.Power .District......FPA.805 eort
| |
| .Transitio .. .At.achment...
| |
| * Prohibition or limitation of combustible materials in fire areas during periods of increased vulnerability
| |
| * Plant configuration changes (e.g., removing power from equipment once it is placed in its desired position)
| |
| * Provision of additional fire patrols at periodic intervals or other appropriate compensatory measures (such as surveillance cameras) during increased vulnerability
| |
| * Use of recovery actions to mitigate potential losses of key safety functions.
| |
| * Identification and monitoring in-situ ignition sources for "fire precursors" (e.g.,
| |
| equipment temperatures)
| |
| * Reschedule the work to a period with lower risk or higher defense-in-depth In addition, for KSF Equipment removed from service during the HRE the impact should be evaluated based on KSF equipment status and the NPO Compartment Assessment to develop needed contingency plans/actions.
| |
| Review To preclude or mitigate the KSF failures, a number of strategies have been developed. These strategies include revisions to plant shutdown and abnormal operating procedures. These procedural revisions will make changes to plant equipment and electrical system line-ups as the plant is brought to cold shutdown conditions. Plant operational procedures will also be revised to include protective strategies, preemptive actions, and recovery actions for those instances where operator actions would be necessary to ensure that a specific KSF can be maintained.
| |
| (See Implementation Item S-3.4 of Attachment S, Table S-3). The pinch points that were identified are documented in CNS Calculation NEDC 11-003.
| |
| CNS Procedure 0.50.5, "Outage Shutdown Safety," requires the effect of outage work scope on the KSFs to be qualitatively assessed. When entering an HRE, a Shutdown Safety Contingency Plan is required. Risk management actions are recommended when any of the following occur:
| |
| * Performance of maintenance activities with potential to cause a fire.
| |
| " Removal of fire detection or suppression equipment from service.
| |
| " Removal or impairment of fire barriers.
| |
| " Removal of KSF equipment from service.
| |
| Risk management actions include:
| |
| " Compensatory measures for the temporary removal of fire barriers.
| |
| " Increased fire watches.
| |
| " Re-scheduling activities that involve increased fire likelihood in fire areas where the inservice KSF equipment would be relied upon in the event of a fire.
| |
| To address concerns associated with equipment being taken out of service during NPO modes, and the potential for a concurrent fire, CNS procedures will be reviewed and revised, as necessary, to provide instructions that will assist in mitigating the effects of a fire if one were to occur. The procedure revisions will provide guidelines for actions to be taken in specific fire areas when components or system trains are taken out of service. (See Implementation Item S-3.4 of Attachment S, Table S-3). For those fire areas where the credited KSF system or equipment may be been taken out of service by a fire in that area, the following guidelines may be included in the outage management procedure:
| |
| Page D-7
| |
| | |
| Mahroclen P"hlit- PmAidar niefrit-f (,Kiq Kir:pA Anr, Trinneifinn Pda Xnrf - Affnt-h onf n IJhr~L'lItrrfPihir~Pr~A~r ~ MZ~KI~A ~A'Trne~ir.nP~nrt- t~~hm~n
| |
| * Prohibition or limitation of hot work,
| |
| * Prohibition or limitation of combustible materials, and/or
| |
| * Establishment of additional fire watches as appropriate.
| |
| Reference Documents
| |
| : 1. NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," dated December 1991
| |
| : 2. CNS Calculation NEDC 11-003, Revision 0, "Non-Power Operation Modes Transition Review of EPM Report R1906-006-001"
| |
| : 3. CNS Procedure 0.50.5, Revision 23, "Outage Shutdown Safety" Page D-8
| |
| | |
| Unkr-molen D"Win Dr%%Aii=r Mefrir-f ('KI(Z KMDA Anr, Trnný;fi 0 ^rf - Affn k nf P:
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| INk. hrac~L'a
| |
| ~LflJI Hip IDv~,e~r OCIXO IDiIALS**~J %JVV~I LJIOLI flic,+ript I'.1 ('NIQ M~DA
| |
| ~Jl ~%J iii I fl QA~ Tranc,,4i,~n UUJ I Hal iCILI',JI I D~r~,,i4 I ~aP'J, I -- A*4~ph.,,~n+
| |
| flLtOtII III I~I IL 1 L
| |
| ATTACHMENT E NEI 04-02 Radioactive Release Transition 96 Pages Page E-1
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions RB-A 1A RCIC and CNS-FP-211 N03 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of Core Spray A monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Pump Room Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Sump B receives drainage movement of air from lesser identify potentially suppression water runoff, flow from the northeast to progressively greater contaminated areas, and use of revised pre-fire Reactor Building Quad areas of radioactive provide instructions for plans and training and from upper levels of contamination potential communication with materials, the NPPD the Reactor Building. The prior to final exhaust from Radiation Protection, and approach will meet NFPA sump is provided with the building. Two systems describe precautions to be 805 radioactive release pumps which transfer the monitor the air flow for undertaken for the performance criteria.
| |
| collected drainage from radioactivity: (1) The RB containment and safe the sump to the Radwaste Ventilation Radiation removal of contaminated System Floor Drain Monitoring System smoke and water runoff in Collector Tank. The continuously monitors and these potentially collected wastes are records the radiation level contaminated areas.
| |
| analyzed, filtered, and at a sample point located in Training material and pre-treated prior to either safe the RB ventilation exhaust fire plan revisions will disposal or re-use in the vent just prior to the release describe the presence and station. point. The RB Ventilation potential use of monitored Radiation Monitoring HVAC and drainage During NPO: Floor drains System alerts the Control systems, if such systems as described above Room when the radiation are deemed operational remain present. Provisions level is abnormal. (2) The and capable of supporting are also in place to RB Isolation Ventilation manual removal efforts.
| |
| commence Monitoring System monitors The level of detail provided communication between the flow of air through the in the revised training the Fire Brigade and RB plenum and will isolate materials and pre-fire plans Radiation Protection and the RB and initiate the will meet NFPA 805 to contain/monitor liquid Standby Gas Treatment radioactive release effluents prior to safe (SGT) System on high performance criteria.
| |
| removal. radiation levels. Initiation of the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the Page E-2
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions contamination contained in the smoke. Ventilation supply air is provided to the Quad room and flows through wall penetrations to the Suppression Chamber area where it enters exhaust ducts to the main exhaust system.
| |
| During NPO: The ventilation and monitoring systems as described above remain present.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-B 1B Core Spray B CNS-FP-212 N04 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of Pump Room monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Sump D receives drainage movement of air from lesser identify potentially suppression water runoff, flow from the southeast to progressively greater contaminated areas, and use of revised pre-fire Reactor Building Quad areas of radioactive provide instructions for plans and training and from upper levels of contamination potential communication with materials, the NPPD the Reactor Building. The prior to final exhaust from Radiation Protection, and approach will meet NFPA sump is provided with the building. Two systems describe precautions to be 805 radioactive release Page E-3
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions pumps which transfer the monitor the air flow for undertaken for the performance criteria.
| |
| collected drainage from radioactivity: (1) The RB containment and safe the sump to the Radwaste Ventilation Radiation removal of contaminated System Floor Drain Monitoring System smoke and water runoff in Collector Tank. The continuously monitors and these potentially collected wastes are records the radiation level contaminated areas.
| |
| analyzed, filtered, and at a sample point located in Training material and pre-treated prior to either safe the RB ventilation exhaust fire plan revisions will disposal or re-use in the vent just prior to the release describe the presence and station. point. The RB Ventilation potential use of monitored Radiation Monitoring HVAC and drainage During NPO: Floor drains System alerts the Control systems, if such systems as described above Room when the radiation are deemed operational remain present. Provisions level is abnormal. (2) The and capable of supporting are also in place to RB Isolation Ventilation manual removal efforts.
| |
| commence Monitoring System monitors The level of detail provided communication between the flow of air through the in the revised training the Fire Brigade and RB plenum and will isolate materials and pre-fire plans Radiation Protection and the RB and initiate the will meet NFPA 805 to contain/monitor liquid Standby Gas Treatment radioactive release effluents prior to safe (SGT) System on high performance criteria.
| |
| removal. radiation levels. Initiation of the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air is provided to the Quad room and flows through wall penetrations to the Suppression Chamber area where it enters exhaust ducts to the main exhaust system.
| |
| Page E-4
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions During NPO: The ventilation and monitoring systems as described above remain present.
| |
| Ifnormal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-CF 1C RHR Pump CNS-FP-213 N04 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of Room 1A and monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for 1C Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Sump A receives drainage movement of air from lesser identify potentially suppression water runoff, flow from the northwest to progressively greater contaminated areas, and use of revised pre-fire Reactor Building Quad areas of radioactive provide instructions for plans and training and from upper levels of contamination potential communication with materials, the NPPD the Reactor Building. The prior to final exhaust from Radiation Protection, and approach will meet NFPA sump is provided with the building. Two systems describe precautions to be 805 radioactive release pumps which transfer the monitor the air flow for undertaken for the performance criteria.
| |
| collected drainage from radioactivity: (1) The RB containment and safe the sump to the Radwaste Ventilation Radiation removal of contaminated System Floor Drain Monitoring System smoke and water runoff in Collector Tank. The continuously monitors and these potentially collected wastes are records the radiation level contaminated areas.
| |
| analyzed, filtered, and at a sample point located in Training material and pre-treated prior to either safe the RB ventilation exhaust fire plan revisions will disposal or re-use in the vent just prior to the release describe the presence and station. point. The RB Ventilation potential use of monitored Page E-5
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions Radiation Monitoring HVAC and drainage During NPO: Floor drains System alerts the Control systems, if such systems as described above Room when the radiation are deemed operational remain present. Provisions level is abnormal. (2) The and capable of supporting are also in place to RB Isolation Ventilation manual removal efforts.
| |
| commence Monitoring System monitors The level of detail provided communication between the flow of air through the in the revised training the Fire Brigade and RB plenum and will isolate materials and pre-fire plans Radiation Protection and the RB and initiate the will meet NFPA 805 to contain/monitor liquid Standby Gas Treatment radioactive release effluents prior to safe (SGT) System on high performance criteria.
| |
| removal. radiation levels. Initiation of the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air is provided to the Quad room and flows through wall penetrations to the Suppression Chamber area where it enters exhaust ducts to the main exhaust system. In addition, Quad communication with the 903-6" Elevation is provided via grated openings.
| |
| During NPO: The ventilation and monitoring systems as described above remain present.
| |
| If normal ventilation is not Page E-6
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-DI 1D RHR Pump CNS-FP-214 N03 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of Room 1B and monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for 1D Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Sump C receives drainage movement of air from lesser identify potentially suppression water runoff, flow from the southwest to progressively greater contaminated areas, and use of revised pre-fire Reactor Building Quad areas of radioactive provide instructions for plans and training and from upper levels of contamination potential communication with materials, the NPPD the Reactor Building. The prior to final exhaust from Radiation Protection, and approach will meet NFPA sump is provided with the building. Two systems describe precautions to be 805 radioactive release pumps which transfer the monitor the air flow for undertaken for the performance criteria.
| |
| collected drainage from radioactivity: (1) The RB containment and safe the sump to the Radwaste Ventilation Radiation removal of contaminated System Floor Drain Monitoring System smoke and water runoff in Collector Tank. The continuously monitors and these potentially collected wastes are records the radiation level contaminated areas.
| |
| analyzed, filtered, and at a sample point located in Training material and pre-treated prior to either safe the RB ventilation exhaust fire plan revisions will disposal or re-use in the vent just prior to the release describe the presence and station. point. The RB Ventilation potential use of monitored Radiation Monitoring HVAC and drainage During NPO: Floor drains System alerts the Control systems, if such systems as described above Room when the radiation are deemed operational remain present. Provisions level is abnormal. (2) The and capable of supporting are also in place to RB Isolation Ventilation manual removal efforts.
| |
| commence Monitoring System monitors The level of detail provided Page E-7
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions communication between the flow of air through the in the revised training the Fire Brigade and RB plenum and will isolate materials and pre-fire plans Radiation Protection and the RB and initiate the will meet NFPA 805 to contain/monitor liquid Standby Gas Treatment radioactive release effluents prior to safe (SGT) System on high performance criteria.
| |
| removal. radiation levels. Initiation of the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air is provided to the Quad room and flows through wall penetrations to the Suppression Chamber area where it enters exhaust ducts to the main exhaust system. In addition, Quad communication with the 903'-6" Elevation is provided via grated openings.
| |
| During NPO: The ventilation and monitoring systems as described above remain present.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to Page E-8
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-DI lE HPCI Pump CNS-FP-214 N03 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of Room monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Sump C receives drainage movement of air from lesser identify potentially suppression water runoff, flow from the southwest to progressively greater contaminated areas, and use of revised pre-fire Reactor Building Quad areas of radioactive provide instructions for plans and training and from upper levels of contamination potential communication with materials, the NPPD the Reactor Building. The prior to final exhaust from Radiation Protection, and approach will meet NFPA sump is provided with the building. Two systems describe precautions to be 805 radioactive release pumps which transfer the monitor the air flow for undertaken for the performance criteria.
| |
| collected drainage from radioactivity: (1) The RB containment and safe the sump to the Radwaste Ventilation Radiation removal of contaminated System Floor Drain Monitoring System smoke and water runoff in Collector Tank. The continuously monitors and these potentially collected wastes are records the radiation level contaminated areas.
| |
| analyzed, filtered, and at a sample point located in Training material and pre-treated prior to either safe the RB ventilation exhaust fire plan revisions will disposal or re-use in the vent just prior to the release describe the presence and station. point. The RB Ventilation potential use of monitored Radiation Monitoring HVAC and drainage During NPO: Floor drains System alerts the Control systems, if such systems as described above Room when the radiation are deemed operational remain present. Provisions level is abnormal. (2) The and capable of supporting are also in place to RB Isolation Ventilation manual removal efforts.
| |
| commence Monitoring System monitors The level of detail provided communication between the flow of air through the in the revised training the Fire Brigade and RB plenum and will isolate materials and pre-fire plans Radiation Protection and the RB and initiate the will meet NFPA 805 to contain/monitor liquid Standby Gas Treatment radioactive release effluents prior to safe (SGT) System on high performance criteria.
| |
| removal. radiation levels. Initiation of Page E-9
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev ' Out? Water Smoke Plan Review Results Conclusions the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air is provided to the HPCI Room and flows through wall penetrations to the RHR Pump 1B and 1D Room (Fire Zone 1D) and then through to the Suppression Chamber area and then to the exhaust plenum.
| |
| During NPO: The ventilation and monitoring systems as described above remain present.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also Page E-10
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-B 1G Hydraulic CNS-FP-212 N04 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of Drive Pump monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Area Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Sump D receives drainage movement of air from lesser identify potentially suppression water runoff, flow from the southeast to progressively greater contaminated areas, and use of revised pre-fire Reactor Building Quad areas of radioactive provide instructions for plans and training and from upper levels of contamination potential communication with materials, the NPPD the Reactor Building. The prior to final exhaust from Radiation Protection, and approach will meet NFPA sump is provided with the building. Two systems describe precautions to be 805 radioactive release pumps which transfer the monitor the air flow for undertaken for the performance criteria.
| |
| collected drainage from radioactivity: (1) The RB containment and safe the sump to the Radwaste Ventilation Radiation removal of contaminated System Floor Drain Monitoring System smoke and water runoff in Collector Tank. The continuously monitors and these potentially collected wastes are records the radiation level contaminated areas.
| |
| analyzed, filtered, and at a sample point located in Training material and pre-treated prior to either safe the RB ventilation exhaust fire plan revisions will disposal or re-use in the vent just prior to the release describe the presence and station. point. The RB Ventilation potential use of monitored Radiation Monitoring HVAC and drainage During NPO: Floor drains System alerts the Control systems, if such systems as described above Room when the radiation are deemed operational remain present. Provisions level is abnormal. (2) The and capable of supporting are also in place to RB Isolation Ventilation manual removal efforts.
| |
| commence Monitoring System monitors The level of detail provided communication between the flow of air through the in therevised training the Fire Brigade and RB plenum and will isolate materials and pre-fire plans Radiation Protection and the RB and initiate the will meet NFPA 805 to contain/monitor liquid Standby Gas Treatment radioactive release effluents prior to safe (SGT) System on high performance criteria.
| |
| removal. radiation levels. Initiation of the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| Page E-11
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air is provided to the Quad room and flows through wall penetrations to the Suppression Chamber area where it enters exhaust ducts to the main exhaust system.
| |
| During NPO: The ventilation and monitoring systems as described above remain present.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-E 1F Suppression N/A N/A Yes N/A N/A N/A N/A - Screened Out Pool Area RB-FN 2A-1 903'-6" CNS-FP-215 N04 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of Northeast monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Page E-12
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions Corner Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Sumps A, B, C, and D movement of air from lesser identify potentially suppression water runoff, receive drainage flow from to progressively greater contaminated areas, and use of revised pre-fire the Reactor Building areas of radioactive provide instructions for plans and training Quads and from upper contamination potential communication with materials, the NPPD levels of the Reactor prior to final exhaust from Radiation Protection, and approach will meet NFPA Building. The sumps are the building. Two systems describe precautions to be 805 radioactive release provided with pumps monitor the air flow for undertaken for the performance criteria.
| |
| which transfer the radioactivity: (1) The RB containment and safe collected drainage from Ventilation Radiation removal of contaminated the sump to the Radwaste Monitoring System smoke and water runoff in System Floor Drain continuously monitors and these potentially Collector Tank. The records the radiation level contaminated areas.
| |
| collected wastes are at a sample point located in Training material and pre-analyzed, filtered, and the RB ventilation exhaust fire plan revisions will treated prior to either safe vent just prior to the release describe the presence and disposal or re-use in the point. The RB Ventilation potential use of monitored station. Radiation Monitoring HVAC and drainage System alerts the Control systems, if such systems During NPO: Floor drains Room when the radiation are deemed operational as described above level is abnormal. (2) The and capable of supporting remain present. Provisions RB Isolation Ventilation manual removal efforts.
| |
| are also in place to Monitoring System monitors The level of detail provided commence the flow of air through the in the revised training communication between RB plenum and will isolate materials and pre-fire plans the Fire Brigade and the RB and initiate the will meet NFPA 805 Radiation Protection and Standby Gas Treatment radioactive release to contain/monitor liquid (SGT) System on high performance criteria.
| |
| effluents for fires where radiation levels. Initiation of NPO openings may exist. the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air is provided to the Page E-13
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions general 903'-6" Elevation area. Exhaust is through areas fed from the general area.
| |
| During NPO (Refueling Activities): Per CNS Technical Specifications, there are periods when Secondary Containment and/or the Control Room Emergency Filter System (CREFS) and SGT System are off-line. During these periods of potential radioactive release, procedures are in place to address fire risk associated with maintenance activities and to close the Reactor Building in a short period of time, which will mitigate consequences of a radioactive release.
| |
| Therefore, contaminated smoke migration from the Reactor Building is anticipated to be insignificant.
| |
| During NPO (Remaining outage activities): Per CNS Technical Specifications, the Secondary Containment may be relaxed and the CREFS and SGT System may be offline during this period. As such, procedures are in place to monitor transient combustibles entering the Reactor Building. A credible worst case fire was postulated in NEDC 11-148. The calculation concluded that Page E-14
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions the maximum exposure dose limits of 10 CFR 20 would not be exceeded, even when conservatively assuming non-operability of the filtration system and 100% instantaneous airborne dose release from the Reactor Building. For any fires inside the Reactor Building, it is reasonably anticipated that the dose impact would be less than a Fuel Handling Accident, which is a design basis event.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-CF 2A-2 CRD Units - CNS-FP-215 N04 No Floor drains are routed to The-Reactor Building (RB) Training materials reinforce Based on the availability of North monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Sumps A, B, C, and D movement of air from lesser identify potentially suppression water runoff, receive drainage flow from to progressively greater contaminated areas, and use of revised pre-fire the Reactor Building areasof radioactive provide instructions for plans and training Quads and from upper contamination potential communication with materials, the NPPD Page E-15
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions levels of the Reactor prior to final exhaust from Radiation Protection, and approach will meet NFPA Building. The sumps are the building. Two systems describe precautions to be 805 radioactive release provided with pumps monitor the air flow for undertaken for the performance criteria.
| |
| which transfer the radioactivity: (1) The RB containment and safe collected drainage from Ventilation Radiation removal of contaminated the sump to the Radwaste Monitoring System smoke and water runoff in System Floor Drain continuously monitors and these potentially Collector Tank. The records the radiation level contaminated areas.
| |
| collected wastes are at a sample point located in Training material and pre-analyzed, filtered, and the RB ventilation exhaust fire plan revisions will treated prior to either safe vent just prior to the release describe the presence and disposal or re-use in the point. The RB Ventilation potential use of monitored station. Radiation Monitoring HVAC and drainage System alerts the Control systems, if such systems During NPO: Floor drains Room when the radiation are deemed operational as described above level is abnormal. (2) The and capable of supporting remain present. Provisions RB Isolation Ventilation manual removal efforts.
| |
| are also in place to Monitoring System monitors The level of detail provided commence the flow of air through the in the revised training communication between RB plenum and will isolate materials and pre-fire plans the Fire Brigade and the RB and initiate the will meet NFPA 805 Radiation Protection and Standby Gas Treatment radioactive release to contain/monitor liquid (SGT) System on high performance criteria.
| |
| effluents for fires where radiation levels. Initiation of NPO openings may exist. the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air is provided.to the general 903'-6'.' Elevation area. Exhaustis through areas fed from the general area.
| |
| Page E-16
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions During NPO (Refueling Activities): Per CNS Technical Specifications, there are periods when Secondary Containment and/or the Control Room Emergency Filter System (CREFS) and SGT System are off-line. During these periods of potential radioactive release, procedures are in place to address fire risk associated with maintenance activities and to close the Reactor Building in a short period of time, which will mitigate consequences of a radioactive release.
| |
| Therefore, contaminated smoke migration from the Reactor Building is anticipated to be insignificant.
| |
| During NPO (Remaining outage activities): Per CNS Technical Specifications, the Secondary Containment may be relaxed and the CREFS and SGT System may be offline during this period. As such, procedures are in place to monitor transient combustibles entering the Reactor Building. A credible worst case fire was postulated in NEDC 11-148. The calculation concluded that the maximum exposure dose limits of 10 CFR 20 would not be exceeded, even when conservatively assuming non-operability of Page E-17
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions the filtration system and 100% instantaneous airborne dose release from the Reactor Building. For any fires inside the Reactor Building, it is reasonably anticipated that the dose impact would be less than a Fuel Handling Accident, which is a design basis event.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-DI 2A-3 903'-6" South CNS-FP-215 N04 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of Corridor monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Sumps A,B, C, and D movement of air from lesser identify potentially suppression water runoff, receive drainage flow from to progressively greater contaminated areas, and use of revised pre-fire the Reactor Building areas of radioactive provide instructions for plans and training Quads and from upper contamination potential communication with materials, the NPPD levels of the Reactor prior to final exhaust from Radiation Protection, and approach will meet NFPA Building. The sumps are the building. Two systems describe precautions to be 805 radioactive release provided with pumps monitor the air flow for undertaken for the performance criteria.
| |
| which transfer the radioactivity: (1) The RB containment and safe collected drainage from Ventilation Radiation removal of contaminated Page E-18
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions the sump to the Radwaste Monitoring System smoke and water runoff in System Floor Drain continuously monitors and these potentially Collector Tank. The records the radiation level contaminated areas.
| |
| collected wastes are at a sample point located in Training material and pre-analyzed, filtered, and the RB ventilation exhaust fire plan revisions will treated prior to either safe vent just prior to the release describe the presence and disposal or re-use in the point. The RB Ventilation potential use of monitored station. Radiation Monitoring HVAC and drainage System alerts the Control systems, if such systems During NPO: Floor drains Room when the radiation are deemed operational as described above level is abnormal. (2) The and capable of supporting remain present. Provisions RB Isolation Ventilation manual removal efforts.
| |
| are also in place to Monitoring System monitors The level of detail provided commence the flow of air through the in the revised training communication between RB plenum and will isolate materials and pre-fire plans the Fire Brigade and the RB and initiate the will meet NFPA 805 Radiation Protection and Standby Gas Treatment radioactive release to contain/monitor liquid (SGT) System on high performance criteria.
| |
| effluents for fires where radiation levels. Initiation of NPO openings may exist. the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air is provided to the general 903'-6" Elevation area. Exhaust is through areas fed from the general area.
| |
| During NPO (Refueling Activities): Per CNS Technical Specifications, there are periods when Secondary Containment Page E-19
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions and/or the Control Room Emergency Filter System (CREFS) and SGT System are off-line. During these periods of potential radioactive release, procedures are in place to address fire risk associated with maintenance activities and to dose the Reactor Building in a short period of time, which will mitigate consequences of a radioactive release.
| |
| Therefore, contaminated smoke migration from the Reactor Building is anticipated to be insignificant.
| |
| During NPO (Remaining outage activities): Per CNS Technical Specifications, the Secondary Containment may be relaxed and the CREFS and SGT System may be offline during this period. As such, procedures are in place to monitor transient combustibles entering the Reactor Building. A credible worst case fire was postulated in NEDC 11-148. The calculation concluded that the maximum exposure dose limits of 10 CFR 20 would not be exceeded, even when conservatively assuming non-operability of the filtration system and 100% instantaneous airborne dose release from the Reactor Building. For any fires inside the Reactor Page E-20
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions Building, it is reasonably anticipated that the dose impact would be less than a Fuel Handling Accident, which is a design basis event.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-CF 2B RHR HX-1A CNS-FP-215 N04 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of CNS-FP-218 N10 monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Sumps A, B, C, and D movement of air from lesser identify potentially suppression water runoff, receive drainage flow from to progressively greater contaminated areas, and use of revised pre-fire the Reactor Building areas of radioactive provide instructions for plans and training Quads and from upper contamination potential communication with materials, the NPPD levels of the Reactor prior to final exhaust from Radiation Protection, and approach will meet NFPA Building. The sumps are the building. Two systems describe precautions to be 805 radioactive release provided with pumps monitor the air flow for undertaken for the performance criteria.
| |
| which transfer the radioactivity: (1) The RB containment and safe collected drainage from Ventilation Radiation removal of contaminated the sump to the Radwaste Monitoring System smoke and water runoff in System Floor Drain continuously monitors and these potentially Collector Tank. The records the radiation level contaminated areas.
| |
| collected wastes are at a sample point located in Training material and pre-analyzed, filtered, and the RB ventilation exhaust fire plan revisions will Page E-21
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions treated prior to either safe vent just prior to the release describe the presence and disposal or re-use in the point. The RB Ventilation potential use of monitored station. Radiation Monitoring HVAC and drainage System alerts the Control systems, if such systems During NPO: Floor drains Room when the radiation are deemed operational as described above level is abnormal, (2) The and capable of supporting remain present. Provisions RB Isolation Ventilation manual removal efforts.
| |
| are also in place to Monitoring System monitors The level of detail provided commence the flow of air through the in the revised training communication between RB plenum and will isolate materials and pre-fire plans the Fire Brigade and the RB and initiate the will meet NFPA 805 Radiation Protection and Standby Gas Treatment radioactive release to contain/monitor liquid (SGT) System on high performance criteria.
| |
| effluents prior to safe radiation levels. Initiation of removal. the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air to the RHR Heat Exchanger Room is from the 903'-6" and 931'-6" Elevation general areas.
| |
| Exhaust from the RHR Heat Exchanger Room is to the exhaust plenum.
| |
| During NPO: The ventilation and monitoring systems as described above remain present.
| |
| if normal ventilation is not available, smoke will be removed using standard Page E-22
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-DI 2C CRD Units- CNS-FP-215 N04 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of South monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Sumps A, B, C, and D movement of air from lesser identify potentially suppression water runoff, receive drainage flow from to progressively greater contaminated areas, and use of revised pre-fire the Reactor Building areas of radioactive provide instructions for plans and training Quads and from upper contamination potential communication with materials, the NPPD levels of the Reactor prior to final exhaust from Radiation Protection, and approach will meet NFPA Building. The sumps are the building. Two systems describe precautions to be 805 radioactive release provided with pumps monitor the air flow for undertaken for the performance criteria.
| |
| which transfer the radioactivity: (1) The RB containment and safe collected drainage from Ventilation Radiation removal of contaminated the sump to the Radwaste Monitoring System smoke and water runoff in System Floor Drain continuously monitors and these potentially Collector Tank. The records the radiation level contaminated areas.
| |
| collected wastes are at a sample point located in Training material and pre-analyzed, filtered, and the RB ventilation exhaust fire plan revisions will treated prior to either safe vent just prior to the release describe the presence and disposal or re-use in the point. The RB Ventilation potential use of monitored station. Radiation Monitoring HVAC and drainage System alerts the Control systems, if such systems During NPO: Floor drains Room when the radiation are deemed operational as described above level-is abnormal. (2) The and capable of supporting remain present. Provisions RB Isolation Ventilation manual removal efforts.
| |
| are also in place to Monitoring System monitors The level of detail provided commence the flow of air through the in the revised training communication between RB plenum and will isolate materials and pre-fire plans Page E-23
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions the Fire Brigade and the RB and initiate the will meet NFPA 805 Radiation Protection and Standby Gas Treatment radioactive release to contain/monitor liquid (SGT) System on high performance criteria.
| |
| effluents for fires where radiation levels. Initiation of NPO openings may exist. the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air is provided to the 903'-6" Elevation general area. Exhaust is through areas fed from the general area.
| |
| During NPO (Refueling Activities): Per CNS Technical Specifications, there are periods when Secondary Containment and/or the Control Room Emergency Filter System (CREFS) and SGT System are off-line. During these periods of potential radioactive release, procedures are in place to address fire risk associated with maintenance activities and to close the Reactor Building in a short period of time, which will mitigate consequences of a radioactive release.
| |
| Therefore, contaminated Page E-24
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions smoke migration from the Reactor Building is anticipated to be insignificant.
| |
| During NPO (Remaining outage activities): Per CNS Technical Specifications, the Secondary Containment may be relaxed and the CREFS and SGT System may be offline during this period. As such, procedures are in place to monitor transient combustibles entering the Reactor Building. A credible worst case fire was postulated in NEDC 11-148. The calculation concluded that the maximum exposure dose limits of 10 CFR 20 would not be exceeded, even when conservatively assuming non-operability of the filtration system and 100% instantaneous airborne dose release from the Reactor Building. For any fires inside the Reactor Building, it is reasonably anticipated that the dose impact would be less than a Fuel Handling Accident, which is a design basis event.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside orto an area where normal Page E-25
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-DI 2D RHR HX-1B CNS-FP-215 N04 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of CNS-FP-218 N10 monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Sumps A, B, C, and D movement of air from lesser identify potentially suppression water runoff, receive drainage flow from to progressively greater contaminated areas, and use of revised pre-fire the Reactor Building areas of radioactive provide instructions for plans and training Quads and from upper contamination potential communication with materials, the NPPD levels of the Reactor prior to final exhaust from Radiation Protection, and approach will meet NFPA Building. The sumps are the building. Two systems describe precautions to be 805 radioactive release provided with pumps monitor the air flow for undertaken for the performance criteria.
| |
| which transfer the radioactivity: (1) The RB containment and safe collected drainage from Ventilation Radiation removal of contaminated the sump to the Radwaste Monitoring System smoke and water runoff in System Floor Drain continuously monitors and these potentially Collector Tank. The records the radiation level contaminated areas.
| |
| collected wastes are at a sample point located in Training material and pre-analyzed, filtered, and the RB ventilation exhaust fire plan revisions will treated prior to either safe vent just prior to the release describe the presence and disposal or re-use in the point. The RB Ventilation potential use of monitored station. Radiation Monitoring HVAC and drainage System alerts the Control systems, if such systems During NPO: Floor drains Room when the radiation are deemed operational as described above level is abnormal. (2) The and capable of supporting remain present. Provisions RB Isolation Ventilation manual removal efforts.
| |
| are also in place to Monitoring System monitors The level of detail provided commence the flow of air through the in the revised training communication between RB plenum and will isolate materials and pre-fire plans the Fire Brigade and the RB and initiate the will meet NFPA 805 Radiation Protection and Standby Gas Treatment radioactive release to contain/monitor liquid (SGT) System on high performance criteria.
| |
| effluents prior to safe radiation levels. Initiation of removal. the SGT System will Implementation S-3.20 -
| |
| Page E-26
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air to the RHR Heat Exchanger Room is from the 903'-6" and 931'-6" Elevation general areas.
| |
| Exhaust from the RHR Heat Exchanger Room is to the exhaust plenum.
| |
| During NPO: The ventilation and monitoring systems as described above remain present.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing.
| |
| Page E-27
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions contaminated gaseous effluents.
| |
| TB-C 2E Steam Tunnel CNS-FP-215 N04 No Floor drains are routed to There is no individual Training materials reinforce Based on the availability of monitored Liquid supply or exhaust air for the the use of pre-fire plans. engineered controls for Radwaste System (LRW). steam tunnel. Smoke will be Pre-fire plan revisions will both smoke and fire Sumps A, B, C, and D removed using standard identify potentially suppression water runoff, receive drainage flow from industry manual ventilation contaminated areas, and use of revised pre-fire the Reactor Building techniques (i.e. portable provide instructions for plans and training Quads and from upper smoke ejectors and flexible communication with materials, the NPPD levels of the Reactor ducts) to the outside or to Radiation Protection, and approach will meet NFPA Building. The sumps are an area where normal describe precautions to be 805 radioactive release provided with pumps ventilation will remove undertaken for safe performance criteria.
| |
| which transfer the smoke. Prior to any release, removal of contaminated collected drainage from plant pre-fire plans provide smoke and water runoff in the sump to the Radwaste instructions to establish these potentially System Floor Drain communications with contaminated areas. The Collector Tank. The Radiation Protection level of detail provided in collected wastes are personnel, and to also the revised training analyzed, filtered, and provide precautions for materials and pre-fire plans treated prior to either safe containing, monitoring, and will meet NFPA 805 disposal or re-use inthe safely releasing radioactive release station. contaminated gaseous performance criteria.
| |
| effluents.
| |
| During NPO: Floor drains Implementation S-3.20 -
| |
| as described above Pre-fire plans and training remain present. Provisions materials will be revised to are also in place to address radioactive commence release requirements of communication between NFPA 805. See the Fire Brigade and Attachment S, Table S-3.
| |
| Radiation Protection and to contain/monitor liquid effluents prior to safe removal.
| |
| RB-J 3A SWGR Room CNS-FP-216 N03 Yes N/A N/A N/A N/A - Screened Out 1F RB-K 3B SWGR Room CNS-FP-217 N03 Yes N/A N/A N/A N/A - Screened Out 1G RB-M 3C REC HX and CNS-FP-218 N10 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of Pump Area monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Sumps A, B, C, and D movement of air from lesser identify potentially suppression water runoff, receive drainage flow from to progressively. greater contaminated areas, and use of revised pre-fire Page E-28
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions the upper levels of the areas of radioactive provide instructions for plans and training Reactor Building. The contamination potential communication with materials, the NPPD sumps are provided with prior to final exhaust from Radiation Protection, and approach will meet NFPA pumps which transfer the the building. Two systems describe precautions to be 805 radioactive release collected drainage from monitor the air flow for undertaken for the performance criteria.
| |
| the sump to the Radwaste radioactivity: (1) The RB containment and safe System Floor Drain Ventilation Radiation. removal of contaminated Collector Tank. The Monitoring System smoke and water runoff in collected wastes are continuously monitors and these potentially analyzed, filtered, and records the radiation level contaminated areas.
| |
| treated prior to either safe at a sample point located in Training material and pre-disposal or re-use in the the RB ventilation exhaust fire plan revisions will station. vent just prior to the release describe the presence and point. The RB Ventilation potential use of monitored During NPO: Floor drains Radiation Monitoring HVAC and drainage as described above System alerts the Control systems, if such systems remain present. Provisions Room when the radiation are deemed operational are also in place to level is abnormal. (2) The and capable of supporting commence RB Isolation Ventilation manual removal efforts.
| |
| communication between Monitoring System monitors The level of detail provided the Fire Brigade and the flow of air through the in the revised training Radiation Protection and RB plenum and will isolate materials and pre-fire plans to contain/monitor liquid the RB and initiate the will meet NFPA 805 effluents prior to safe Standby Gas Treatment radioactive release removal. (SGT) System on high performance criteria.
| |
| radiation levels. Initiation of the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air provided to the 931'-6" Elevation general area. Exhaust is through areas fed from the general Page E-29
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions area.
| |
| During NPO: The ventilation and monitoring systems as described above remain present.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-M 3D Reactor MG CNS-FP-218 N10 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of Set Lube Oil monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Cooler Area Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Sumps A, B, C, and D movement of air from lesser identify potentially suppression water runoff, receive drainage flow from to progressively greater contaminated areas, and use of revised pre-fire the upper levels of the areas of radioactive provide instructions for plans and training Reactor Building. The contamination potential communication with materials, the NPPD sumps are provided with prior to final exhaust from Radiation Protection, and approach will meet NFPA pumps which transfer the the building. Two systems describe precautions to be 805 radioactive release collected drainage from monitor the air flow for undertaken for the performance criteria.
| |
| the sump to the Radwaste radioactivity: (1) The RB containment and safe System Floor Drain Ventilation Radiation removal of contaminated Collector Tank. The Monitoring System smoke and water runoff in collected wastes are continuously monitors and these potentially analyzed, filtered, and records the radiation level contaminated areas.
| |
| treated prior to either safe at a sample point located in Training material and pre-disposal or re-use in the the RB ventilation exhaust fire plan revisions will Page E-30
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions station. vent just prior to the release describe the presence and point. The RB Ventilation potential use of monitored During NPO: Floor drains Radiation Monitoring HVAC and drainage as described above System alerts the Control systems, if such systems remain present. Provisions Room when the radiation are deemed operational are also in place to level is abnormal. (2) The and capable of supporting commence RB Isolation Ventilation manual removal efforts.
| |
| communication between Monitoring System monitors The level of detail provided the Fire Brigade and the flow of air through the in the revised training Radiation Protection and RB plenum and will isolate materials and pre-fire plans to contain/monitor liquid the RB and initiate the will meet NFPA 805 effluents prior to safe Standby Gas Treatment radioactive release removal. (SGT) System on high performance criteria.
| |
| radiation levels. Initiation of the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air provided to the 931'-6" Elevation general area. Exhaust is through areas fed from the general area.
| |
| During NPO: The ventilation and monitoring systems as described above remain present.
| |
| If normal ventilation is .not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable Page E-31
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-N 3E-1 Regenerative CNS-FP-218 N10 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of HX Areas monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Sumps A, B, C, and D movement of air from lesser identify potentially suppression water runoff, receive drainage flow from to progressively greater contaminated areas, and use of revised pre-fire the upper levels of the areas of radioactive provide instructions for plans and training Reactor Building. The contamination potential communication with materials, the NPPD sumps are provided with prior to final exhaust from Radiation Protection, and approach will meet NFPA pumps which transfer the the building. Two systems describe precautions to be 805 radioactive release collected drainage from monitor the air flow for undertaken for the performance criteria.
| |
| the sump to the Radwaste radioactivity: (1) The RB containment and safe System Floor Drain Ventilation Radiation removal of contaminated Collector Tank. The Monitoring System smoke and water runoff in collected wastes are continuously monitors and these potentially analyzed, filtered, and records the radiation level contaminated areas.
| |
| treated prior to either safe at a sample point located in Training material and pre-disposal or re-use in the the RB ventilation exhaust fire plan revisions will station. vent just prior to the release describe the presence and point. The RB Ventilation potential use of monitored During NPO: Floor drains Radiation Monitoring HVAC and drainage as described above System alerts the Control systems, if such systems remain present. Provisions Room when the radiation are deemed operational are also in place to level is abnormal. (2) The and capable of supporting commence RB Isolation Ventilation manual removal efforts.
| |
| communication between Monitoring System monitors The level of detail provided the Fire Brigade and the flow of air through the in the revised training Radiation Protection and RB plenum and will isolate materials and pre-fire plans to contain/monitor liquid the RB and initiate the will meet NFPA 805 effluents prior to safe Standby Gas Treatment radioactive release Page E-32
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions removal. (SGT) System on high performance criteria.
| |
| radiation levels. Initiation of the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. This area has a high potential for contamination and the exhaust air is first passed through banks of prefilters and HEPA filters before discharging into the main exhaust system.
| |
| During NPO: The ventilation and monitoring systems as described above remain present.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also Page E-33
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-N 3E-2 RWCU CNS-FP-218 N10 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of Recirc monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Pumps and Radwaste System (LRWA). System provides for the Pre-fire plan revisions will both smoke and fire Corridor Sumps A, B, C, and D movement of air from lesser identify potentially suppression water runoff, receive drainage flow from to progressively greater contaminated areas, and use of revised pre-fire the upper levels of the areas of radioactive provide instructions for plans and training Reactor Building. The contamination potential communication with materials, the NPPD sumps are provided with prior to final exhaust from Radiation Protection, and approach will meet NFPA pumps which transfer the the building. Two systems describe precautions to be 805 radioactive release collected drainage from monitor the air flow for undertaken for the performance criteria.
| |
| the sump to the Radwaste radioactivity: (1) The RB containment and safe System Floor Drain Ventilation Radiation removal of contaminated Collector Tank. The Monitoring System smoke and water runoff in collected wastes are continuously monitors and these potentially analyzed, filtered, and records the radiation level contaminated areas.
| |
| treated prior to either safe at a sample point located in Training material and pre-disposal or re-use in the the RB ventilation exhaust fire plan revisions will station. vent just prior to the release describe the presence and point. The RB Ventilation potential use of monitored During NPO: Floor drains Radiation Monitoring HVAC and drainage as described above System alerts the Control systems, if such systems remain present. Provisions Room when the radiation are deemed operational are also in place to level is abnormal. (2) The and capable of supporting commence RB Isolation Ventilation manual removal efforts.
| |
| communication between Monitoring System monitors The level of detail provided the Fire Brigade and the flow of air through the in the revised training Radiation Protection and RB plenum and will isolate. materials and pre-fire plans to contain/monitor liquid the RB and initiate the will meet NFPA 805 effluents prior to safe Standby Gas Treatment radioactive release removal. (SGT) System on high performance criteria.
| |
| radiation levels. Initiation of the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA; and materials will be revised to carbon absorbers prior to address radioactive safely discharging. it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| Page E-34
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. This area has a high potential for contamination and the exhaust air is first passed through banks of prefilters and HEPA filters before discharging into the main exhaust system.
| |
| During NPO: The ventilation and monitoring systems as described above remain present.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-P 4A RB Elevator CNS-FP-219 N10 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of and monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Accessway Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Area Sumps A, B, C, and D movement of air from lesser identify potentially suppression water runoff, Page E-35
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions receive drainage flow from to progressively greater contaminated areas, and use of revised pre-fire the upper levels of the areas of radioactive provide instructions for plans and training Reactor Building. The contamination potential communication with materials, the NPPD sumps are provided with prior to final exhaust from Radiation Protection, and approach will meet NFPA pumps which transfer the the building. Two systems describe precautions to be 805 radioactive release collected drainage from monitor the air flow for undertaken for the performance criteria.
| |
| the sump to the Radwaste radioactivity: (1) The RB containment and safe System Floor Drain Ventilation Radiation removal of contaminated Collector Tank. The Monitoring System smoke and water runoff in collected wastes are continuously monitors and these potentially analyzed, filtered, and records the radiation level contaminated areas.
| |
| treated prior to either safe at a sample point located in Training material and pre-disposal or re-use in the the RB ventilation exhaust fire plan revisions will station. vent just prior to the release describe the presence and point. The RB Ventilation potential use of monitored During NPO: Floor drains Radiation Monitoring HVAC and drainage as described above System alerts the Control systems, if such systems remain present. Provisions Room when the radiation are deemed operational are also in place to level is abnormal. (2) The and capable of supporting commence RB Isolation Ventilation manual removal efforts.
| |
| communication between Monitoring System monitors The level of detail provided the Fire Brigade and the flow of air through the in the revised training Radiation Protection and RB plenum and will isolate materials and pre-fire plans to contain/monitor liquid the RB and initiate the will meet NFPA 805 effluents prior to safe Standby Gas Treatment radioactive release removal. (SGT) System on high performance criteria.
| |
| radiation levels. Initiation of the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air is provided to the 958'-3" Elevation general area. Exhaust is through Page E-36
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions areas fed from the general area and through to the exhaust plenum.
| |
| During NPO: The ventilation and monitoring systems as described above remain present.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-P 4B RB HVAC CNS-FP-219 N10 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of Area monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Sumps A, B, C, and D movement of air from lesser identify potentially suppression water runoff, receive drainage flow from to progressively greater contaminated areas, and use of revised pre-fire the upper levels of the areas of radioactive provide instructions for plans and training Reactor Building. The contamination potential communication with materials, the NPPD sumps are provided with prior to final exhaust from Radiation Protection, and approach will meet NFPA pumps which transfer the the building. Two systems describe precautions to be 805 radioactive release collected drainage from monitor the air flow for undertaken for the performance criteria.
| |
| the sump to the Radwaste radioactivity: (1) The RB containment and safe System Floor Drain Ventilation Radiation removal of contaminated Collector Tank. The Monitoring System smoke and water runoff in collected wastes are continuously monitors and these potentially analyzed, filtered, and records the radiation level contaminated areas.
| |
| Page E-37
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions treated prior to either safe at a sample point located in Training material and pre-disposal or re-use in the the RB ventilation exhaust fire plan revisions will station. vent just prior to the release describe the presence and point. The RB Ventilation potential use of monitored During NPO: Floor drains Radiation Monitoring HVAC and drainage as described above System alerts the Control systems, if such systems remain present. Provisions Room when the radiation are deemed operational are also in place to level is abnormal. (2) The and capable of supporting commence RB Isolation Ventilation manual removal efforts.
| |
| communication between Monitoring System monitors The level of detail provided the Fire Brigade and the flow of air through the in the revised training Radiation Protection and RB plenum and will isolate materials and pre-fire plans to contain/monitor liquid the RB and initiate the will meet NFPA 805 effluents prior to safe Standby Gas Treatment radioactive release removal. (SGT) System on high performance criteria.
| |
| radiation levels. Initiation of the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air is provided to the 958'-3" Elevation general area. Exhaust is through areas fed from the general area and through to the exhaust plenum.
| |
| During NPO: The ventilation and monitoring systems as described above remain present.
| |
| If normal ventilation is not available, smoke will be Page E-38
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-P 4C Fuel Pool HX, CNS-FP-219 N10 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of CRD Repair monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Room and Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Raw Water Sumps A, B, C, and D movement of air from lesser identify potentially suppression water runoff, Cleanup receive drainage flow from to progressively greater contaminated areas, and use of revised pre-fire Areas the upper levels of the areas of radioactive provide instructions for plans and training Reactor Building. The contamination potential communication with materials, the NPPD sumps are provided with prior to final exhaust from Radiation Protection, and approach will meet NFPA pumps which transfer the the building. Two systems describe precautions to be 805 radioactive release collected drainage from monitor the air flow for undertaken for the performance criteria.
| |
| the sump to the Radwaste radioactivity: (1) The RB containment and safe System Floor Drain Ventilation Radiation removal of contaminated Collector Tank. The Monitoring System smoke and water runoff in collected wastes are continuously monitors and these potentially analyzed, filtered, and records the radiation level contaminated areas.
| |
| treated prior to either safe at a sample point located in Training material and pre-disposal or re-use in the the RB ventilation exhaust fire plan revisions will station. vent just prior to the release describe the presence and point. The RB Ventilation. potential use of monitored During NPO: Floor drains Radiation Monitoring HVAC anddrainage as described above System alerts the Control systems, if such systems remain present. Provisions Room when the radiation are deemed operational are also in place to level is abnormal.. (2) The and capable of supporting commence RB Isolation Ventilation manual removal efforts.
| |
| communication between Monitoring System monitors The level of detail provided the Fire Brigade and the flow of air through the in the revised training Page E-39
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions Radiation Protection and RB plenum and wi11 isolate materials and pre-tire plans to contain/monitor liquid the RB and initiate the will meet NFPA 805 effluents prior to safe Standby Gas Treatment radioactive release removal. (SGT) System on high performance criteria.
| |
| radiation levels. Initiation of the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air is provided to the 958'-3" Elevation general area. Exhaust is through areas fed from the general area and through to the exhaust plenum.
| |
| During NPO: The ventilation and monitoring systems as described above remain present.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Page E-40
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-P 4D Reactor MG CNS-FP-219 N10 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of Set Oil Pump monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Area Radwaste System (LRVV). System provides for the Pre-fire plan revisions will both smoke and fire Sumps A, B, C, and D movement of air from lesser identify potentially suppression water runoff, receive drainage flow from to progressively greater contaminated areas, and use of revised pre-fire the upper levels of the areas of radioactive provide instructions for plans and training Reactor Building. The contamination potential communication with materials, the NPPD sumps are provided with prior to final exhaust from Radiation Protection, and approach will meet NFPA pumps which transfer the the building. Two systems describe precautions to be 805 radioactive release collected drainage from monitor the air flow for undertaken for the performance criteria.
| |
| the sump to the Radwaste radioactivity: (1) The RB containment and safe System Floor Drain Ventilation Radiation removal of contaminated Collector Tank. The Monitoring System smoke and water runoff in collected wastes are continuously monitors and these potentially analyzed, filtered, and records the radiation level contaminated areas.
| |
| treated prior to either safe at a sample point located in Training material and pre-disposal or re-use in the the RB ventilation exhaust fire plan revisions will station. vent just prior to the release describe the presence and point. The RB Ventilation potential use of monitored During NPO: Floor drains Radiation Monitoring HVAC and drainage as described above System alerts the Control systems, if such systems remain present. Provisions Room when the radiation are deemed operational are also in place to level is abnormal. (2) The and capable of supporting commence RB Isolation Ventilation manual removal efforts.
| |
| communication between Monitoring System monitors The level of detail provided the Fire Brigade and the flow of air through the in the revised training Radiation Protection and RB plenum and will isolate materials and pre-fire plans to contain/monitor liquid the RB and initiate the will meet NFPA 805 effluents prior to safe Standby Gas Treatment radioactive release removal. (SGT) System on high performance criteria.
| |
| radiation levels. Initiation of the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See Page E-41
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air is provided to the 958'-3" Elevation general area. Exhaust is through areas fed from the general area and through to the exhaust plenum.
| |
| During NPO: The ventilation and monitoring systems as described above remain present.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-T 5A SBLC Pump CNS-FP-220 N05 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of Tank and monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Accessway Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Page E-42
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions Sumps A, B, C, and D movement of air from lesser identify potentially suppression water runoff, receive drainage flow from to progressively greater contaminated areas, and use of revised pre-fire the upper levels of the areas of radioactive provide instructions for plans and training Reactor Building. The contamination potential communication with materials, the NPPD sumps are provided with prior to final exhaust from Radiation Protection, and approach will meet NFPA pumps which transfer the the building. Two systems describe precautions to be 805 radioactive release collected drainage from monitor the air flow for undertaken for the performance criteria.
| |
| the sump to the Radwaste radioactivity: (1) The RB containment and safe System Floor Drain Ventilation Radiation removal of contaminated Collector Tank. The Monitoring System smoke and water runoff in collected wastes are continuously monitors and these potentially analyzed, filtered, and records the radiation level contaminated areas.
| |
| treated prior to either safe at a sample point located in Training material and pre-disposal or re-use in the the RB ventilation exhaust fire plan revisions will station. vent just prior to the release describe the presence and point. The RB Ventilation potential use of monitored During NPO: Floor drains Radiation Monitoring HVAC and drainage as described above System alerts the Control systems, if such systems remain present. Provisions Room when the radiation are deemed operational are also in place to level is abnormal. (2) The and capable of supporting commence RB Isolation Ventilation manual removal efforts.
| |
| communication between Monitoring System monitors The level of detail provided the Fire Brigade and the flow of air through the in the revised training Radiation Protection and RB plenum and will isolate materials and pre-fire plans to contain/monitor liquid the RB and initiate the will meet NFPA 805 effluents prior to safe Standby Gas Treatment radioactive release removal. (SGT) System on high performance criteria.
| |
| radiation levels. Initiation of the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air is provided to the Standby Liquid Control Page E-43
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions System area. Exhaust from this area is through areas it feeds and eventually through to the exhaust plenum.
| |
| During NPO: The ventilation and monitoring systems as described above remain present.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-V 5B Reactor MG CNS-FP-221 N05 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of Set Area CNS-FP-222 N03 monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Sumps A, B, C, and D movement of air from lesser identify potentially suppression water runoff, receive drainage flow from to progressively greater contaminated areas, and use of revised pre-fire the upper levels of the areas of radioactive provide instructions for plans and training Reactor Building. The contamination potential communication with materials, the NPPD sumps are provided with prior to final exhaust from Radiation Protection, and approach will meet NFPA pumps which transfer the the building. Two systems describe precautions to be 805 radioactive release collected drainage from monitor the air flow for undertaken for the performance criteria.
| |
| the sump to the Radwaste radioactivity: (1) The RB containment and safe System Floor Drain Ventilation Radiation removal of contaminated Collector Tank. The Monitoring System smoke and water runoff in Page E-44
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions collected wastes are continuously monitors and these potentially analyzed, filtered, and records the radiation level contaminated areas.
| |
| treated prior to either safe at a sample point located in Training material and pre-disposal or re-use in the the RB ventilation exhaust fire plan revisions will station. vent just prior to the release describe the presence and point. The RB Ventilation potential use of monitored During NPO: Floor drains Radiation Monitoring HVAC and drainage as described above System alerts the Control systems, if such systems remain present. Provisions Room when the radiation are deemed operational are also in place to level is abnormal. (2) The and capable of supporting commence RB Isolation Ventilation manual removal efforts.
| |
| communication between Monitoring System monitors The level of detail provided the Fire Brigade and the flow of air through the in the revised training Radiation Protection and RB plenum and will isolate materials and pre-fire plans to contain/monitor liquid the RB and initiate the will meet NFPA 805 effluents prior to safe Standby Gas Treatment radioactive release removal. (SGT) System on high performance criteria.
| |
| radiation levels. Initiation of the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. The two Reactor Recirculation Motor Generator sets have their own common ventilation system. High radiation level at the RB Isolation Ventilation Radiation Monitoring System will isolate this system.
| |
| During NPO: The ventilation and monitoring systems as described above remain Page E-45
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions present.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| RB-T 6 Refueling CNS-FP-223 N04 No Floor drains are routed to The Reactor Building (RB) Training materials reinforce Based on the availability of Floor monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Radwaste System (LRW). System provides for the Pre-fire plan revisions will both smoke and fire Sumps A, B, C, and D movement of air from lesser identify potentially suppression water runoff, receive drainage flow from to progressively greater contaminated areas, and use of revised pre-fire the upper levels of the areas of radioactive provide instructions for plans and training Reactor Building. The contamination potential communication with materials, the NPPD sumps are provided with prior to final exhaust from Radiation Protection, and approach will meet NFPA pumps which transfer the the building. Two systems describe precautions to be 805 radioactive release collected drainage from monitor the air flow for undertaken for the performance criteria.
| |
| the sump to the Radwaste radioactivity: (1) The RB containment and safe System Floor Drain Ventilation Radiation removal of contaminated Collector Tank. The Monitoring System smoke and water runoff in collected wastes are continuously monitors and these potentially analyzed, filtered, and records the radiation level contaminated areas.
| |
| treated prior to either safe at a sample point located in Training material and pre-disposal or re-use in the the RB ventilation exhaust fire plan revisions will station. vent just prior to the release describe the presence and point. The RB Ventilation potential use of monitored During NPO: Floor drains Radiation Monitoring HVAC and drainage as described above System alerts the Control systems, if such systems remain present. Provisions Room when the radiation are deemed operational Page E-46
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions are also in place to level is abnormal. (2) The and capable of supporting commence RB Isolation Ventilation manual removal efforts.
| |
| communication between Monitoring System monitors The level of detail provided the Fire Brigade and the flow of air through the in the revised training Radiation Protection and RB plenum and will isolate materials and pre-fire plans to contain/monitor liquid the RB and initiate the will meet NFPA 805 effluents prior to safe Standby Gas Treatment radioactive release removal. (SGT) System on high performance criteria.
| |
| radiation levels. Initiation of the SGT System will Implementation S-3.20 -
| |
| process the RB air via its Pre-fire plans and training banks of filters, HEPA, and materials will be revised to carbon absorbers prior to address radioactive safely discharging it from release requirements of the Elevated Release Point NFPA 805. See (ERP). Attachment S, Table S-3.
| |
| The ventilation of smoke is accomplished by the RB Heating and Ventilating System governed by the level of radioactivity of the contamination contained in the smoke. Ventilation supply air is provided to the refueling floor, 1001'-0" Elevation general area.
| |
| Exhaust is through areas fed from the general area and through to the exhaust plenum.
| |
| During NPO: The ventilation and monitoring systems as described above remain present.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal Page E-47
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| CB-A 7A RHR Service CNS-FP-224 N04 No Fire Zone 7A is not part of Fire Zone 7A is not part of Training materials reinforce As the fire zone has been Water the RCA, however, there the RCA, however, there is use of the pre-fire plans. deemed to be of negligible Booster is a small section in the a small section in the Pre-fire plan revisions will consequence, the NPPD Pump and southwest corner that is southwest corner that is identify potentially approach will meet NFPA Service Air taped off as a taped off as a contaminated contaminated areas, 805 radioactive release Compressor contaminated area. Based area. Based on RP provide instructions for performance criteria.
| |
| Areas on RP radiation survey, radiation survey, the level of communication with the level of surface surface contamination, as Radiation Protection, and contamination, as well as well as radiation levels for describe precautions to be radiation levels for the the taped-off area, was very undertaken for the taped-off area, was very slight. containment and safe slight. removal of contaminated The potential quantity of smoke and water runoff in Control Building non- contaminated smoke these potentially radioactive floor drains resulting from fire fighting contaminated areas.
| |
| discharge to the "L"sump. activities in the taped off Training material and pre-Sump pumps Li and L2 area is deemed to be very fire plan revisions will are normally lined up to insignificant. The Control describe the presence and discharge to the radwaste Building Heating and potential use of monitored drain collector tank. If Ventilating system or HVAC and drainage Sump Pumps L1 and L2 manual smoke removal systems, if such systems are lined up to discharge techniques can be used to are deemed operational to the river, Radiation remove the smoke. and capable of supporting Protection (RP) analyzes However, prior to any manual removal efforts.
| |
| the contaminated liquid release, the radiological The level of detail provided effluents prior to placing in hazards associated with in the revised training operation. releasing contaminated materials and pre-fire plans smoke from the building will will meet NFPA 805 The potential be considered, and direct radioactive release contaminated water runoff communication between the performance criteria.
| |
| resulting from fire fighting Fire Brigade and Radiation activities in the taped-off Protection will be initiated. Implementation S-3.20 -
| |
| Page E-48
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions area is deemed to be very The quantity of Pre-fire plans and training insignificant. In addition, contaminated smoke materials will be revised to provisions are in place to released to the atmosphere address radioactive commence is reasonably anticipated to release requirements of communication between be well below the maximum NFPA 805. See the Fire Brigade and exposure dose limits of 10 Attachment S, Table S-3.
| |
| Radiation Protection and CFR 20.
| |
| to contain/monitor liquid effluents for a fire event.
| |
| CB-A 7B Emergency CNS-FP-224 N04 No Fire Zone 7B is not part of Fire Zone 7B is not part of Training materials reinforce As the fire zone has been Condensate the RCA, however, the the RCA, however, the area use of the pre-fire plans. deemed to be of negligible Storage TK. area has contamination has contamination potential Pre-fire plan revisions will consequence, the NPPD Area potential due to the due to the presence of the identify potentially approach will meet NFPA presence of the Emergency Condensate contaminated areas, 805 radioactive release Emergency Condensate Storage Tanks (ECST). provide instructions for performance criteria.
| |
| Storage Tanks (ECST). communication with The potential quantity of Radiation Protection, and Control Building non- contaminated smoke describe precautions to be radioactive floor drains resulting from fire fighting undertaken for the discharge to the "L"sump. activities is deemed to be containment and safe Sump pumps Li and L2 very insignificant based on removal of contaminated are normally lined up to the low contamination level, smoke and water runoff in discharge to the radwaste The Control Building these potentially drain collector tank. If Heating and Ventilating contaminated areas.
| |
| Sump Pumps Li and L2 system or manual smoke Training material and pre-are lined up to discharge removal techniques can be fire plan revisions will to the river, Radiation used to remove the smoke. describe the presence and Protection (RP) analyzes However, prior to any potential use of monitored the contaminated liquid release, the radiological HVAC and drainage effluents prior to placing in hazards associated with systems, if such systems operation. releasing contaminated are deemed operational smoke from the building will and capable of supporting The potential be considered and direct manual removal efforts.
| |
| contaminated water runoff communication between the The level of detail provided resulting from fire fighting Fire Brigade and Radiation inthe revised training activities is deemed to be Protection will be initiated, materials and pre-fire plans very insignificant based on The quantity of will meet NFPA 805 the contamination level. In contaminated smoke radioactive release addition, provisions are in released to the atmosphere performance criteria.
| |
| place to commence is reasonably anticipated to communication between be well below the maximum Implementation S-3.20 -
| |
| the Fire Brigade and exposure dose limits of 10 Pre-fire plans and training Radiation Protection and CFR 20. materials will be revised to to contain/monitor liquid address radioactive Page E-49
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions effluents for a fire event, release requirements of NFPA 805. See Attachment S, Table S-3.
| |
| CB-D 8A Aux Relay CNS-FP-225 N05 Yes N/A N/A N/A N/A - Screened Out Room CB-C 8B RPS Room CNS-FP-226 N05 Yes N/A N/A N/A N/A - Screened Out 1B CB-A 8C RPS Room CNS-FP-227 N05 Yes N/A N/A N/A N/A - Screened Out 1A CB-A 8D Seal Water CNS-FP-227 N05 Yes N/A N/A N/A N/A - Screened Out Pump Area and Corridor CB-A-1 8E Battery Room CNS-FP-227 N05 Yes N/A N/A N/A N/A - Screened Out 1A CB-B 8F Battery Room CNS-FP-228 N05 Yes N/A N/A N/A N/A - Screened Out 1B CB-B 8G DC SWGR CNS-FP-228 N05 Yes N/A N/A N/A N/A - Screened Out Room 1B CB-A-1 8H DC SWGR CNS-FP-227 N05 Yes N/A N/A N/A N/A - Screened Out Room 1A CB-D 9A Cable CNS-FP-229 N04 Yes N/A N/A N/A N/A - Screened Out Spreading Room CB-D 9B Cable CNS-FP-234 N03 Yes N/A N/A N/A N/A - Screened Out Expansion Room CB-D 10A Computer CNS-FP-230 N06 Yes N/A N/A N/A N/A - Screened Out Room CB-D 10B Control Room CNS-FP-230 N06 Yes N/A N/A N/A N/A - Screened Out and SAS Corridor TB-A 11A Turbine Lube CNS-FP-242 N04 No Floor drains are routed to The Turbine Building Training materials reinforce Based on the availability of Oil Storage monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for TK Room Radwaste System (LRW). system supplies 100% Pre-fire plan revisions will both smoke and fire Turbine Building filtered outside air to all identify potentially suppression water runoff, radioactive floor drain areas of the Turbine contaminated areas, and use of revised pre-fire sumps receive drainage Building. Air movement is provide instructions for plans and training flow. The sumps are from clean areas to areas communication with materials, the NPPD Page E-50
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions provided with pumps with progressively greater Radiation Protection, and approach will meet NFPA which transfer the contamination potential. describe precautions to be 805 radioactive release collected drainage from Exhaust air is discharged to undertaken for the performance criteria.
| |
| the sump to the Radwaste the atmosphere above the containment and safe System Floor Drain roof of the Fan Room via removal of contaminated Collector Tank or to four exhaust fans. The smoke and water runoff in disposal. The collected exhaust system does not these potentially wastes are analyzed, contain filtration equipment. contaminated areas.
| |
| filtered, and treated prior The fans are interlocked Training material and pre-to either safe disposal or and are provided with fire plan revisions will re-use in the station. alarms that annunciate in describe the presence and the Control Room. Control potential use of monitored Provisions are also in Room operators control the HVAC and drainage place to commence operation of the exhaust systems, if such systems communication between fans. are deemed operational the Fire Brigade and and capable of supporting Radiation Protection and The Turbine Building manual removal efforts.
| |
| to contain/monitor liquid Ventilation Radiation The level of detail provided effluents prior to safe Monitoring system is in the revised training removal. installed to provide a materials and pre-fire plans continuous record of will meet NFPA 805 exhaust air flow and radioactive release contamination activity, and performance criteria.
| |
| to alert the Control Room of such abnormal air activity. Implementation S-3.20 -
| |
| The monitoring system Pre-fire plans and training does not perform any materials will be revised to control functions (e.g. address radioactive exhaust fan shutdown). release requirements of NFPA 805. See Due to the configuration of Attachment S, Table S-3.
| |
| the Turbine Building Heating and Ventilating system (air movement from clean areas to areas with greater contamination) and the ability of the Control Room to monitor potentially contaminated smoke and shut down exhaust fans, contaminated smoke migration from Turbine Building areas is anticipated to be insignificant. If normal ventilation is not available, Page E-51
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| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| TB-A 11B Turbine Bldg CNS-FP-242 N04 No Floor drains are routed to The Turbine Building Training materials reinforce Based on the availability of Basement - monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for South Radwaste System (LRW). system supplies 100% Pre-fire plan revisions will both smoke and fire Turbine Building filtered outside air to all identify potentially suppression water runoff, radioactive floor drain areas of the Turbine contaminated areas, and use of revised pre-fire sumps receive drainage Building. Air movement is provide instructions for plans and training flow..The sumps are from clean areas to areas communication With materials, the NPPD provided with pumps with progressively greater Radiation Protection, and approach will meet NFPA which transfer the contamination potential. describe precautions to be 805 radioactive release collected drainage from Exhaust air is discharged to undertaken for the performance criteria.
| |
| the sump to the Radwaste the atmosphere above the containment and safe System Floor Drain roof of the Fan Room via removal of contaminated Collector Tank or to four exhaust fans. The smoke and water runoff in disposal. The collected exhaust system does not these potentially wastes are analyzed, contain filtration equipment. contaminated areas.
| |
| filtered, and treated prior The fans are interlocked Training material and pre-to either safe disposal or and are provided with fire plan revisions will re-use in the station. alarms that annunciate in describe the presence and the Control Room. Control potential use of monitored Provisions are also in Room operators control the HVAC and drainage place to commence operation of the exhaust systems, if such systems communication between fans. are deemed operational the Fire Brigade and and capable of supporting Radiation Protection and The Turbine Building manual removal efforts.
| |
| to contain/monitor liquid Ventilation Radiation The level of detail provided Page E-52
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions effluents prior to safe Monitoring system is in the revised training removal. installed to provide a materials and pre-fire plans continuous record of will meet NFPA 805 exhaust air flow and radioactive release contamination activity, and performance criteria.
| |
| to alert the Control Room of such abnormal air activity. Implementation S-3.20 -
| |
| The monitoring system Pre-fire plans and training does not perform any materials will be revised to control functions (e.g. address radioactive exhaust fan shutdown). release requirements of NFPA 805. See Due to the configuration of Attachment S, Table S-3.
| |
| the Turbine Building Heating and Ventilating system (air movement from clean areas to areas with greater contamination) and the ability of the Control Room to monitor potentially contaminated smoke and shut down exhaust fans, contaminated smoke migration from Turbine Building areas is anticipated to be insignificant. If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous Page E-53
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions effluents.
| |
| TB-A 11C H2 Seal Oil CNS-FP-242 N04 No Floor drains are routed to The Turbine Building Training materials reinforce Based on the availability of Unit Area monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Radwaste System (LRW). system supplies 100% Pre-fire plan revisions will both smoke and fire Turbine Building filtered outside air to all identify potentially suppression water runoff, radioactive floor drain areas of the Turbine contaminated areas, and use of revised pre-fire sumps receive drainage Building. Air movement is provide instructions for plans and training flow. The sumps are from clean areas to areas communication with materials, the NPPD provided with pumps with progressively greater Radiation Protection, and approach will meet NFPA which transfer the contamination potential. describe precautions to be 805 radioactive release collected drainage from Exhaust air is discharged to undertaken for the performance criteria.
| |
| the sump to the Radwaste the atmosphere above the containment and safe System Floor Drain roof of the Fan Room via removal of contaminated Collector Tank or to four exhaust fans. The smoke and water runoff in disposal. The collected exhaust system does not these potentially wastes are analyzed, contain filtration equipment. contaminated areas.
| |
| filtered, and treated prior The fans are interlocked Training material and pre-to either safe disposal or and are provided with fire plan revisions will re-use in the station. alarms that annunciate in describe the presence and the Control Room. Control potential use of monitored Provisions are also in Room operators control the HVAC and drainage place to commence operation of the exhaust systems, if such systems communication between fans. are deemed operational the Fire Brigade and and capable of supporting Radiation Protection and The Turbine Building manual removal efforts.
| |
| to contain/monitor liquid Ventilation Radiation The level of detail provided effluents prior to safe Monitoring system is in the revised training removal. installed to provide a materials and pre-fire plans continuous record of will meet NFPA 805 exhaust air flow and radioactive release contamination activity, and performance criteria.
| |
| to alert the Control Room of such abnormal air activity. Implementation S-3.20 -
| |
| The monitoring system Pre-fire plans and training does not perform any materials will be revised to control functions (e.g. address radioactive exhaust fan shutdown). release requirements of NFPA 805. See Due to the configuration of Attachment S, Table S-3.
| |
| the Turbine Building Heating and Ventilating system (air movement from clean areas to areas with greater contamination) and Page E-54
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions the ability of the Control Room to monitor potentially contaminated smoke and shut down exhaust fans, contaminated smoke migration from Turbine Building areas is anticipated to be insignificant. If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| TB-A 11D Condenser CNS-FP-246 N03 No Floor drains are routed to The Turbine Building Training materials reinforce Based on the availability of Pit Area monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Radwaste System (LRW). system supplies 100% Pre-fire plan revisions will both smoke and fire Turbine Building filtered outside air to all identify potentially suppression water runoff, radioactive floor drain areas of the Turbine contaminated areas, and use of revised pre-fire sumps receive drainage Building. Air movement is provide instructions for plans and training flow. The sumps are from clean areas to areas communication with materials, the NPPD provided with pumps with progressively greater Radiation Protection, and approach will meet NFPA which transfer the contamination potential. describe precautions to be 805 radioactive release collected drainage from Exhaust air-is discharged to undertaken for the performance criteria.
| |
| the sump to the Radwaste the atmosphere above the containment and safe System Floor Drain roof of the Fan Room via removal of contaminated Collector Tank or to four exhaust fans. The smoke and water runoff in disposal. The collected exhaust system does not these potentially wastes are analyzed, contain filtration equipment. contaminated areas.
| |
| filtered, and treated prior The fans are interlocked Training material and pre-Page E-55
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions to either safe disposal or and are provided with fire plan revisions will re-use in the station. alarms that annunciate in describe the presence and the Control Room. Control potential use of monitored Provisions are also in Room operators control the HVAC and drainage place to commence operation of the exhaust systems, if such systems communication between fans. are deemed operational the Fire Brigade and and capable of supporting Radiation Protection and The Turbine Building manual removal efforts.
| |
| to contain/monitor liquid Ventilation Radiation The level of detail provided effluents prior to safe Monitoring system is in the revised training removal. installed to provide a materials and pre-fire plans continuous record of will meet NFPA 805 exhaust air flow and radioactive release contamination activity, and performance criteria.
| |
| to alert the Control Room of such abnormal air activity. Implementation S-3.20 -
| |
| The monitoring system Pre-fire plans and training does not perform any materials will be revised to control functions (e.g. address radioactive exhaust fan shutdown). release requirements of NFPA 805. See Due to the configuration of Attachment S, Table S-3.
| |
| the Turbine Building Heating and Ventilating system (air movement from clean areas to areas with greater contamination) and the ability of the Control Room to monitor potentially contaminated smoke and shut down exhaust fans, contaminated smoke migration from Turbine Building areas is anticipated to be insignificant. If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, Page E-56
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| TB-A 11E Reactor Feed CNS-FP-243 N04 No Floor drains are routed to The Turbine Building Training materials reinforce Based on the availability of Pumps Area monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Radwaste System (LRW). system supplies 100% Pre-fire plan revisions will both smoke and fire Turbine Building filtered outside air to all identify potentially suppression water runoff, radioactive floor drain areas of the Turbine contaminated areas, and use of revised pre-fire sumps receive drainage Building. Air movement is provide instructions for plans and training flow. The sumps are from clean areas to areas communication with materials, the NPPD provided with pumps with progressively greater Radiation Protection, and approach will meet NFPA which transfer the contamination potential. describe precautions to be 805 radioactive release collected drainage from Exhaust air is discharged to undertaken for the performance criteria.
| |
| the sump to the Radwaste the atmosphere above the containment and safe System Floor Drain roof of the Fan Room via removal of contaminated Collector Tank or to four exhaust fans. The smoke and water runoff in disposal. The collected exhaust system does not these potentially wastes are analyzed, contain filtration equipment. contaminated areas.
| |
| filtered, and treated prior The fans are interlocked Training material and pre-to either safe disposal or and are provided with fire plan revisions will re-use in the station. alarms that annunciate in describe the presence and the Control Room. Control potential use of monitored Provisions are also in Room operators control the HVAC and drainage place to commence operation of the exhaust systems, ifsuch systems communication between fans. are deemed operational the Fire Brigade and and capable of supporting Radiation Protection and The Turbine Building manual removal efforts.
| |
| to contain/monitor liquid Ventilation Radiation The level of detail provided effluents prior to safe Monitoring system is inthe revised training removal, installed to provide a materials and pre-fire plans continuous record of will meet NFPA 805 exhaust air flow and radioactive release contamination activity, and performance criteria.
| |
| to alert the Control Room of such abnormal air activity. Implementation S-3.20 -
| |
| The monitoring system Pre-fire plans and training does not perform any materials will be revised to Page E-57
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions control functions (e.g. address radioactive exhaust fan shutdown). release requirements of NFPA 805. See Due to the configuration of Attachment S, Table S-3.
| |
| the Turbine Building Heating and Ventilating system (air movement from clean areas to areas with greater contamination) and the ability of the Control Room to monitor potentially contaminated smoke and shut down exhaust fans, contaminated smoke migration from Turbine Building areas is anticipated to be insignificant. If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| TB-A 11F TB Controlled CNS-FP-243 N04 No Floor drains are routed to The Turbine Building Training materials reinforce Based on the availability of Corridor 882 CNS-FP-244 N04 monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Elev Radwaste System (LRW). system supplies 100% Pre-fire plan revisions will both smoke and fire Turbine Building filtered outside air to all identify potentially suppression water runoff, radioactive floor drain areas of the Turbine contaminated areas, and use of revised pre-fire sumps receive drainage Building. Air movement is provide instructions for plans and training flow. The sumps are from clean areas to areas communication with materials, the NPPD Page E-58
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions provided with pumps with progressively greater Radiation Protection, and approach will meet NFPA which transfer the contamination potential. describe precautions to be 805 radioactive release collected drainage from Exhaust air is discharged to undertaken for the performance criteria.
| |
| the sump to the Radwaste the atmosphere above the containment and safe System Floor Drain roof of the Fan Room via removal of contaminated Collector Tank or to four exhaust fans. The smoke and water runoff in disposal. The collected exhaust system does not these potentially wastes are analyzed, contain filtration equipment. contaminated areas.
| |
| filtered, and treated prior The fans are interlocked Training material and pre-to either safe disposal or and are provided with fire plan revisions will re-use in the station. alarms that annunciate in describe the presence and the Control Room. Control potential use of monitored Provisions are also in Room operators control the HVAC and drainage place to commence operation of the exhaust systems, if such systems communication between fans. are deemed operational the Fire Brigade and and capable of supporting Radiation Protection and The Turbine Building manual removal efforts.
| |
| to contain/monitor liquid Ventilation Radiation The level of detail provided effluents prior to safe Monitoring system is in the revised training removal. installed to provide a materials and pre-fire plans continuous record of will meet NFPA 805 exhaust air flow and radioactive release contamination activity, and performance criteria.
| |
| to alert the Control Room of such abnormal air activity. Implementation S-3.20 -
| |
| The monitoring system Pre-fire plans and training does not perform any materials will be revised to control functions (e.g. address radioactive exhaust fan shutdown). release requirements of NFPA 805. See Due to the configuration of Attachment S, Table S-3.
| |
| the Turbine Building Heating and Ventilating system (air movement from clean areas to areas with greater contamination) and the ability of the Control Room to monitor potentially contaminated smoke and shut down exhaust fans, contaminated smoke migration from Turbine Building areas is anticipated to be insignificant. If normal ventilation is not available, Page E-59
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| TB-A 11G Steam Jet Air CNS-FP-243 N04 No Floor drains are routed to The Turbine Building Training materials reinforce Based on the availability of Ejector Room CNS-FP-244 N04 monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Radwaste System (LRW). system supplies 100% Pre-fire plan revisions will both smoke and fire Turbine Building filtered outside air to all identify potentially suppression water runoff, radioactive floor drain areas of the Turbine contaminated areas, and use of revised pre-fire sumps receive drainage Building. Air movement is provide instructions for plans and training flow. The sumps are from clean areas to areas communication with materials, the NPPD provided with pumps with progressively greater Radiation Protection, and approach will meet NFPA which transfer the contamination potential. describe precautions to be 805 radioactive release collected drainage from Exhaust air is discharged to undertaken for the performance criteria.
| |
| the sump to the Radwaste the atmosphere above the containment and safe System Floor Drain roof of the Fan Room via removal of contaminated Collector Tank or to four exhaust fans. The smoke and water runoff in disposal. The collected exhaust system does not these potentially wastes are analyzed, contain filtration equipment. contaminated areas.
| |
| filtered, and treated prior The fans are interlocked Training material and pre-to either safe disposal or and are provided with fire plan revisions will re-use in the station. alarms that annunciate in describe the presence and the Control Room. Control potential use of monitored Provisions are also in Room operators control the HVAC and drainage place to commence operation of the exhaust systems, if such systems communication between fans. are deemed operational the Fire Brigade and and capable of supporting Radiation Protection and The Turbine Building manual removal efforts.
| |
| to contain/monitor liquid Ventilation Radiation The level of detail provided Page E-60
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions effluents prior to safe Monitoring system is in the revised training removal. installed to provide a materials and pre-fire plans continuous record of will meet NFPA 805 exhaust air flow and radioactive release contamination activity, and performance criteria.
| |
| to alert the Control Room of such abnormal air activity. Implementation S-3.20 -
| |
| The monitoring system Pre-fire plans and training does not perform any materials will be revised to control functions (e.g. address radioactive exhaust fan shutdown). release requirements of NFPA 805. See Due to the configuration of Attachment S, Table S-3.
| |
| the Turbine Building Heating and Ventilating system (air movement from clean areas to areas with greater contamination) and the ability of the Control Room to monitor potentially contaminated smoke and shut down exhaust fans, contaminated smoke migration from Turbine Building areas is anticipated to be insignificant. If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous Page E-61
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions effluents.
| |
| TB-A 11H Mechanical CNS-FP-244 N04 No Floor drains are routed to The Turbine Building Training materials reinforce Based on the availability of Vacuum CNS-FP-245 N04 monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Pumps Room Radwaste System (LRW). system supplies 100% Pre-fire plan revisions will both smoke and fire Turbine Building filtered outside air to all identify potentially suppression water runoff, radioactive floor drain areas of the Turbine contaminated areas, and use of revised pre-fire sumps receive drainage Building. Air movement is provide instructions for plans and training flow. The sumps are from clean areas to areas communication with materials, the NPPD provided with pumps with progressively greater Radiation Protection, and approach will meet NFPA which transfer the contamination potential. describe precautions to be 805 radioactive release collected drainage from Exhaust air is discharged to undertaken for the performance criteria.
| |
| the sump to the Radwaste the atmosphere above the containment and safe System Floor Drain roof of the Fan Room via removal of contaminated Collector Tank or to four exhaust fans. The smoke and water runoff in disposal. The collected exhaust system does not these potentially wastes are analyzed, contain filtration equipment. contaminated areas.
| |
| filtered, and treated prior The fans are interlocked Training material and pre-to either safe disposal or and are provided with fire plan revisions will re-use in the station. alarms that annunciate in describe the presence and the Control Room. Control potential use of monitored Provisions are also in Room operators control the HVAC and drainage place to commence operation of the exhaust systems, if such systems communication between fans. are deemed operational the Fire Brigade and and capable of supporting Radiation Protection and The Turbine Building manual removal efforts.
| |
| to contain/monitor liquid Ventilation Radiation The level of detail provided effluents prior to safe Monitoring system is in the revised training removal. installed to provide a materials and pre-fire plans continuous record of will meet NFPA 805 exhaust air flow and radioactive release contamination activity, and performance criteria.
| |
| to alert the Control Room of such abnormal air activity. Implementation S-3.20 -
| |
| The monitoring system Pre-fire plans and training does not perform any materials will be revised to control functions (e.g. address radioactive exhaust fan shutdown). release requirements of NFPA 805. See Due to the configuration of Attachment S, Table S-3.
| |
| the Turbine Building Heating and Ventilating system (air movement from clean areas to areas with greater contamination) and Page E-62
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions the ability of the Control Room to monitor potentially contaminated smoke and shut down exhaust fans, contaminated smoke migration from Turbine Building areas is anticipated to be insignificant. If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| TB-A 11J Condensate, CNS-FP-245 N04 No Floor drains are routed to The Turbine Building Training materials reinforce Based on the availability of Condensate monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Booster and Radwaste System (LRW). system supplies 100% Pre-fire plan revisions will both smoke and fire TEC Pumps Turbine Building filtered outside air to all identify potentially suppression water runoff, Area radioactive floor drain areas of the Turbine contaminated areas, and use of revised pre-fire sumps receive drainage Building. Air movement is provide instructions for plans and training flow. The sumps are from clean areas to areas communication with materials, the NPPID provided with pumps with progressively greater Radiation Protection, and approach will meet NFPA which transfer the contamination potential. describe precautions to be 805 radioactive release collected drainage from Exhaust air is discharged to undertaken for the performance criteria.
| |
| the sump to the Radwaste the atmosphere above the containment and safe System Floor Drain roof of the Fan Room via removal of contaminated Collector Tank or to four exhaust fans. The smoke and water runoff in disposal. The collected exhaust system does not these potentially wastes are analyzed, contain filtration equipment. contaminated areas.
| |
| filtered, and treated prior The fans are interlocked Training material and pre-Page E-63
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions to either safe disposal or and are provided with fire plan revisions will re-use in the station. alarms that annunciate in describe the presence and the Control Room. Control potential use of monitored Provisions are also in Room operators control the HVAC and drainage place to commence operation of the exhaust systems, if such systems communication between fans. are deemed operational the Fire Brigade and and capable of supporting Radiation Protection and The Turbine Building manual removal efforts.
| |
| to contain/monitor liquid Ventilation Radiation The level of detail provided effluents prior to safe Monitoring system is in the revised training removal. installed to provide a materials and pre-fire plans continuous record of will meet NFPA 805 exhaust air flow and radioactive release contamination activity, and performance criteria.
| |
| to alert the Control Room of such abnormal air activity. Implementation S-3.20 -
| |
| The monitoring system Pre-fire plans and training does not perform any materials will be revised to control functions (e.g. address radioactive exhaust fan shutdown). release requirements of NFPA 805. See Due to the configuration of Attachment S, Table S-3.
| |
| the Turbine Building Heating and Ventilating system (air movement from clean areas to areas with greater contamination) and the ability of the Control Room to monitor potentially contaminated smoke and shut down exhaust fans, contaminated smoke migration from Turbine Building areas is anticipated to be insignificant. If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, Page E-64
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| TB-A 11K Turbine Oil CNS-FP-245 N04 No Floor drains are routed to The Turbine Building Training materials reinforce Based on the availability of Conditioner monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Room Radwaste System (LRW). system supplies 100% Pre-fire plan revisions will both smoke and fire Turbine Building filtered outside air to all identify potentially suppression water runoff, radioactive floor drain areas of the Turbine contaminated areas, and use of revised pre-fire sumps receive drainage Building. Air movement is provide instructions for plans and training flow. The sumps are from clean areas to areas communication with materials, the NPPD provided with pumps with progressively greater Radiation Protection, and approach will meet NFPA which transfer the contamination potential. describe precautions to be 805 radioactive release collected drainage from Exhaust air is discharged to undertaken for the performance criteria.
| |
| the sump to the Radwaste the atmosphere above the containment and safe System Floor Drain roof of the Fan Room via removal of contaminated Collector Tank or to four exhaust fans. The smoke and water runoff in disposal. The collected exhaust system does not these potentially wastes are analyzed, contain filtration equipment. contaminated areas.
| |
| filtered, and treated prior The fans are interlocked Training material and pre-to either safe disposal or and are provided with fire plan revisions will re-use in the station. alarms that annunciate in describe the presence and the Control Room. Control potential use of monitored Provisions are also in Room operators control the HVAC and drainage place to commence operation of the exhaust systems, if such systems communication between fans. are deemed operational the Fire Brigade and and capable of supporting Radiation Protection and The Turbine Building manual removal efforts.
| |
| to contain/monitor liquid Ventilation Radiation The level of detail provided effluents prior to safe Monitoring system is in the revised training removal, installed to provide a materials and pre-fire plans continuous record of will meet NFPA 805 exhaust air flow and radioactive release contamination activity, and performance criteria.
| |
| to alert the Control Room of such abnormal air activity. Implementation S-3.20 -
| |
| The monitoring system Pre-fire plans and training does not perform any materials will be revised to Page E-65
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions control functions (e.g. address radioactive exhaust fan shutdown). release requirements of NFPA 805. See Due to the configuration of Attachment S, Table S-3.
| |
| the Turbine Building Heating and Ventilating system (air movement from clean areas to areas with greater contamination) and the ability of the Control Room to monitor potentially contaminated smoke and shut down exhaust fans, contaminated smoke migration from Turbine Building areas is anticipated to be insignificant. If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| TB-A 11L Pipe Chase CNS-FP-243 N04 Yes N/A N/A N/A N/A - Screened Out TB-A 12A ISO Phase CNS-FP-247 N06 Yes N/A N/A N/A N/A - Screened Out Bus Duct Area TB-A 12B TB Controlled CNS-FP-248 N07 No Floor drains are routed to The Turbine Building Training materials reinforce Based on the availability of Corridor 903 monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Elev Radwaste System (LRW). system supplies 100% Pre-fire plan revisions will both smoke and fire Page E-66
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions Turbine Building filtered outside air to all identify potentially suppression water runoff, radioactive floor drain areas of the Turbine contaminated areas, and use of revised pre-fire sumps receive drainage Building. Air movement is provide instructions for plans and training flow. The sumps are from clean areas to areas communication with materials, the NPPD provided with pumps with progressively greater Radiation Protection, and approach will meet NFPA which transfer the contamination potential. describe precautions to be 805 radioactive release collected drainage from Exhaust air is discharged to undertaken for the performance criteria.
| |
| the sump to the Radwaste the atmosphere above the containment and safe System Floor Drain roof of the Fan Room via removal of contaminated Collector Tank or to four exhaust fans. The smoke and water runoff in disposal. The collected exhaust system does not these potentially wastes are analyzed, contain filtration equipment. contaminated areas.
| |
| filtered, and treated prior The fans are interlocked Training material and pre-to either safe disposal or and are provided with fire plan revisions will re-use in the station. alarms that annunciate in describe the presence and the Control Room. Control potential use of monitored Provisions are also in Room operators control the HVAC and drainage place to commence operation of the exhaust systems, if such systems communication between fans. are deemed operational the Fire Brigade and and capable of supporting Radiation Protection and The Turbine Building manual removal efforts.
| |
| to contain/monitor liquid Ventilation Radiation The level of detail provided effluents prior to safe Monitoring system is in the revised training removal. installed to provide a materials and pre-fire plans continuous record of will meet NFPA 805 exhaust air flow and radioactive release contamination activity, and performance criteria.
| |
| to alert the Control Room of such abnormal air activity. Implementation S-3.20 -
| |
| The monitoring system Pre-fire plans and training does not perform any materials will be revised to control functions (e.g. address radioactive exhaust fan shutdown). release requirements of NFPA 805. See Due to the configuration of Attachment S, Table S-3.
| |
| the Turbine Building Heating and Ventilating system (air movement from clean areas to areas with greater contamination) and the ability of the Control Room to monitor potentially contaminated smoke and shut down exhaust fans, contaminated smoke Page E-67
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions migration from Turbine Building areas is anticipated to be insignificant. If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| TB-A 12C Condenser CNS-FP-248 N07 No Floor drains are routed to The Turbine Building Training materials reinforce Based on the availability of and Heater monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Bay Areas Radwaste System (LRW). system supplies 100% Pre-fire plan revisions will both smoke and fire Turbine Building filtered outside air to all identify potentially suppression water runoff, radioactive floor drain areas of the Turbine contaminated areas, and use of revised pre-fire sumps receive drainage Building. Air movement is provide instructions for plans and training flow. The sumps are from clean areas to areas communication with materials, the NPPD provided with pumps with progressively greater Radiation Protection, and approach will meet NFPA which transfer the contamination potential. describe precautions to be 805 radioactive release collected drainage from Exhaust air is discharged to undertaken for the performance criteria.
| |
| the sump to the Radwaste the atmosphere above the containment and safe System Floor Drain roof of the Fan Room via removal of contaminated Collector Tank or to four exhaust fans. The smoke and water runoff in disposal. The collected exhaust system does not these potentially wastes are analyzed, contain filtration equipment. contaminated areas.
| |
| filtered, and treated prior The fans are interlocked Training material and pre-to either safe disposal or and are provided with fire plan revisions will re-use in the station. alarms that annunciate in describe the presence and the Control Room. Control potential use of monitored Provisions are also in Room operators control the HVAC and drainage place to commence operation of the exhaust systems, if such systems Page E-68
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions communication between fans. are deemed onerational the Fire Brigade and and capable of supporting Radiation Protection and The Turbine Building manual removal efforts.
| |
| to contain/monitor liquid Ventilation Radiation The level of detail provided effluents prior to safe Monitoring system is in the revised training removal. installed to provide a materials and pre-fire plans continuous record of will meet NFPA 805 exhaust air flow and radioactive release contamination activity, and performance criteria.
| |
| to alert the Control Room of such abnormal air activity. Implementation S-3.20 -
| |
| The monitoring system Pre-fire plans and training does not perform any materials will be revised to control functions (e.g. address radioactive exhaust fan shutdown). release requirements of NFPA 805. See Due to the configuration of Attachment S, Table S-3.
| |
| the Turbine Building Heating and Ventilating system (air movement from clean areas to areas with greater contamination) and the ability of the Control Room to monitor potentially contaminated smoke and shut down exhaust fans, contaminated smoke migration from Turbine Building areas is anticipated to be insignificant. If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communicationswith Radiation Protection personnel, and to also Page E-69
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| TB-A 12D Turbine Bldg CNS-FP-249 N06 Yes N/A N/A N/A N/A - Screened Out Floor-North TB-A 12E Turbine Oil CNS-FP-249 N06 Yes N/A N/A N/A N/A - Screened Out Reservoir Area TB-A 12F Turbine Bldg CNS-FP-250 N04 Yes N/A N/A N/A N/A - Screened Out Document Storage Vault TB-A 13A Turbine CNS-FP-251 N08 No Floor drains are routed to The Turbine Building Training materials reinforce Based on the availability of Operating monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Floor Radwaste System (LRW). system supplies 100% Pre-fire plan revisions will both smoke and fire Turbine Building filtered outside air to all identify potentially suppression water runoff, radioactive floor drain areas of the Turbine contaminated areas, and use of revised pre-fire sumps receive drainage Building. Air movement is provide instructions for plans and training flow. The sumps are from clean areas to areas communication with materials, the NPPD provided with pumps with progressively greater Radiation Protection, and approach will meet NFPA which transfer the contamination potential. describe precautions to be 805 radioactive release collected drainage from Exhaust air is discharged to undertaken for the performance criteria.
| |
| the sump to the Radwaste the atmosphere above the containment and safe System Floor Drain roof of the Fan Room via removal of contaminated Collector Tank or to four exhaust fans. The smoke and water runoff in disposal. The collected exhaust system does not these potentially wastes are analyzed, contain filtration equipment. contaminated areas.
| |
| filtered, and treated prior The fans are interlocked Training material and pre-to either safe disposal or and are provided with fire plan revisions will re-use in the station. alarms that annunciate in describe the presence and the Control Room. Control potential use of monitored Provisions are also in Room operators control the HVAC and drainage place to commence operation of the exhaust systems, ifsuch systems communication between fans. are deemed operational the. Fire Brigade and and capable of supporting Radiation Protection and The Turbine Building manual removal efforts.
| |
| to contain/monitor liquid Ventilation Radiation The level of detail provided effluents prior to safe Monitoring system is inthe revised training removal. installed to provide a materials and pre-fire plans continuous record of will meet NFPA 805 exhaust air flow and radioactive release contamination activity, and performance criteria.
| |
| Page E-70
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions to alert the Control Room of such abnormal air activity. Implementation S-3.20 -
| |
| The monitoring system Pre-fire plans and training does not perform any materials will be revised to control functions (e.g. address radioactive exhaust fan shutdown). release requirements of NFPA 805. See Due to the configuration of Attachment S, Table S-3.
| |
| the Turbine Building Heating and Ventilating system (air movement from clean areas to areas with greater contamination) and the ability of the Control Room to monitor potentially contaminated smoke and shut down exhaust fans, contaminated smoke migration from Turbine Building areas is anticipated to be insignificant. If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| TB-A 13B Non-Critical CNS-FP-252 N03 Yes N/A N/A N/A N/A - Screened Out SWGR Room Page E-71
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions TB-A 13C Electrical CNS-FP-253 N06 Yes N/A N/A N/A N/A - Screened Out Shop TB-A 13D Instrument CNS-FP-253 N06 Yes N/A N/A N/A N/A - Screened Out Shop, Instrument Records and Chart Rooms DG-A 14A Emergency CNS-FP-236 N05 Yes N/A N/A N/A N/A - Screened Out Diesel Generator 1A Room DG-B 14B Emergency CNS-FP-237 N03 Yes N/A N/A N/A N/A - Screened Out Diesel Generator 1B Room DG-A 14C DG 1A Diesel CNS-FP-236 N05 Yes N/A N/A N/A N/A - Screened Out Oil Day TK.
| |
| Room DG-B 14D DG 1B Diesel CNS-FP-237 N03 Yes N/A N/A N/A N/A - Screened Out Oil Day TK.
| |
| Room TB-A 15 Heating CNS-FP-238 N05 Yes N/A N/A N/A N/A - Screened Out Boiler Room TB-A 16 Turbine Bldg CNS-FP-239 N03 No Floor drains are routed to The Turbine Building Training materials reinforce Based on the availability of Exhaust Fan monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Room Radwaste System (LRW). system supplies 100% Pre-fire plan revisions will both smoke and fire Turbine Building filtered outside air to all identify potentially suppression water runoff, radioactive floor drain areas of the Turbine contaminated areas, and use of revised pre-fire sumps receive drainage Building. Air movement is provide instructions for plans and training flow. The sumps are from clean areas to areas communication with materials, the NPPD provided with pumps with progressively greater Radiation Protection, and approach will meet NFPA which transfer the contamination potential. describe precautions to be 805 radioactive release collected drainage from Exhaust air is discharged to undertaken for the performance criteria.
| |
| the sump to the Radwaste the atmosphere above the containment and safe System Floor Drain roof of the Fan Room via removal of contaminated Collector Tank or to four exhaust fans. The smoke and water runoff in disposal. The collected exhaust system does not these potentially wastes are analyzed, contain filtration equipment. contaminated areas.
| |
| filtered, and treated prior The fans are interlocked Training material and pre-to either safe disposal or and are provided with fire plan revisions will re-use in the station. alarms that annunciate in describe the presence and Page E-72
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions the Control Room. Control potential use of monitored Provisions are also in Room operators control the HVAC and drainage place to commence operation of the exhaust systems, if such systems communication between fans. are deemed operational the Fire Brigade and and capable of supporting Radiation Protection and The Turbine Building manual removal efforts.
| |
| to contain/monitor liquid Ventilation Radiation The level of detail provided effluents prior to safe Monitoring system is in the revised training removal. installed to provide a materials and pre-fire plans continuous record of will meet NFPA 805 exhaust air flow and radioactive release contamination activity, and performance criteria.
| |
| to alert the Control Room of such abnormal air activity. Implementation S-3.20 -
| |
| The monitoring system Pre-fire plans and training does not perform any materials will be revised to control functions (e.g. address radioactive exhaust fan shutdown). release requirements of NFPA 805. See Due to the configuration of Attachment S, Table S-3.
| |
| the Turbine Building Heating and Ventilating system (air movement from clean areas to areas with greater contamination) and the ability of the Control Room to monitor potentially contaminated smoke and shut down exhaust fans, contaminated smoke migration from Turbine Building areas is anticipated to be insignificant. If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish Page E-73
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| TB-A 17 Water CNS-FP-240 N06 Yes N/A N/A N/A N/A - Screened Out Treatment CNS-FP-241 N05 Bldg TB-A 18A Machine Shop CNS-FP-254 N06 No Floor drains are routed to The Turbine Building Training materials reinforce Based on the availability of CNS-FP-255 N05 monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Radwaste System (LRW). system supplies 100% Pre-fire plan revisions will both smoke and fire Turbine Building filtered outside air to all identify potentially suppression water runoff, radioactive floor drain areas of the Turbine contaminated areas, and use of revised pre-fire sumps receive drainage Building. Air movement is provide instructions for plans and training flow. The sumps are from clean areas to areas communication with materials, the NPPD provided with pumps with progressively greater Radiation Protection, and approach will meet NFPA which transfer the contamination potential. describe precautions to be 805 radioactive release collected drainage from Exhaust air is discharged to undertaken for the performance criteria.
| |
| the sump to the Radwaste the atmosphere above the containment and safe System Floor Drain roof of the Fan Room via removal of contaminated Collector Tank or to four exhaust fans. The smoke and water runoff in disposal. The collected exhaust system does not these potentially wastes are analyzed, contain filtration equipment. contaminated areas.
| |
| filtered, and treated prior The fans are interlocked Training material and pre-to either safe disposal or and are provided with fire plan revisions will re-use in the station. alarms that annunciate in describe the presence and the Control Room. Control. potential use of monitored Provisions are also in Room operators control the HVAC and drainage place to commence operation of the exhaust systems, if such systems communication between fans. are deemed operational the Fire Brigade and and capable of supporting Radiation Protection and The Turbine Building manual removal efforts.
| |
| to contain/monitor liquid Ventilation Radiation The level of detail provided effluents prior to safe Monitoring system is inthe revised training removal, installed to provide a materials and pre-fire plans continuous record of will meet NFPA 805 exhaust air flow and radioactive release contamination activity, and performance criteria.
| |
| to alert the Control Room of such abnormal air activity. Implementation S-3.20 -
| |
| The monitoring system Pre-fire plans and training Page E-74
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions does not perform any materials will be revised to control functions (e.g. address radioactive exhaust fan shutdown). release requirements of NFPA 805. See Due to the configuration of Attachment S, Table S-3.
| |
| the Turbine Building Heating and Ventilating system (air movement from clean areas to areas with greater contamination) and the ability of the Control Room to monitor potentially contaminated smoke and shut down exhaust fans, contaminated smoke migration from Turbine Building areas is anticipated to be insignificant. If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| TB-A 18B Machine CNS-FP-254 N06 Yes N/A N/A N/A N/A - Screened Out Shop Clean Tool Room TB-A 18C Machine CNS-FP-254 N06 Yes N/A N/A N/A N/A - Screened Out Shop Oil Storage Room Page E-75
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions TB-A 18D Machine CNS-FP-254 N06 Yes N/A N/A N/A N/A - Screened Out Shop Paint Storage Room TB-A 18E Machine CNS-FP-255 N05 No Floor drains are routed to The Turbine Building Training materials reinforce Based on the availability of Shop Lunch monitored Liquid Heating and Ventilating use of the pre-fire plans. engineered controls for Room and Radwaste System (LRW). system supplies 100% Pre-fire plan revisions will both smoke and fire Records Turbine Building filtered outside air to all identify potentially suppression water runoff, Storage Room radioactive floor drain areas of the Turbine contaminated areas, and use of revised pre-fire sumps receive drainage Building. Air movement is provide instructions for plans and training flow. The sumps are from clean areas to areas communication with materials, the NPPD provided with pumps with progressively greater Radiation Protection, and approach will meet NFPA which transfer the contamination potential. describe precautions to be 805 radioactive release collected drainage from Exhaust air is discharged to undertaken for the performance criteria.
| |
| the sump to the Radwaste the atmosphere above the containment and safe System Floor Drain roof of the Fan Room via removal of contaminated Collector Tank or to four exhaust fans. The smoke and water runoff in disposal. The collected exhaust system does not these potentially wastes are analyzed, contain filtration equipment. contaminated areas.
| |
| filtered, and treated prior The fans are interlocked Training material and pre-to either safe disposal or and are provided with fire plan revisions will re-use in the station. alarms that annunciate in describe the presence and the Control Room. Control potential use of monitored Provisions are also in Room operators control the HVAC and drainage place to commence operation of the exhaust systems, if such systems communication between fans. are deemed operational the Fire Brigade and and capable of supporting Radiation Protection and The Turbine Building manual removal efforts.
| |
| to contain/monitor liquid Ventilation Radiation The level of detail provided effluents prior to safe Monitoring system is in the revised training removal. installed to provide a materials and pre-fire plans continuous record of will meet NFPA 805 exhaust air flow and radioactive release contamination activity, and performance criteria.
| |
| to alert the Control Room of such abnormal air activity. Implementation S-3.20 -
| |
| The monitoring system Pre-fire plans and training does not perform any materials will be revised to control functions (e.g. address radioactive exhaust fan shutdown). release requirements of NFPA 805. See Due to the configuration of Attachment S, Table S-3.
| |
| the Turbine Building Heating and Ventilating system (air'movement from Page E-76
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions clean areas to areas with greater contamination) and the ability of the Control Room to monitor potentially contaminated smoke and shut down exhaust fans, contaminated smoke migration from Turbine Building areas is anticipated to be insignificant. If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| TB-A 19A Office Bldg CNS-FP-231 N06 Yes N/A N/A N/A N/A - Screened Out Controlled Corridor 903 Elev TB-A 19B Office Bldg CNS-FP-232 N08 Yes N/A N/A N/A N/A - Screened Out Occupancies CNS-FP-233 N09 and CNS-FP-235 N07 Controlled Corridors TB-A 19C Office CNS-FP-269 N05 Yes N/A N/A N/A N/A - Screened Out Building Penthouse Page E-77
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions IS-A 20A Service CNS-FP-256 N04 Yes N/A N/A N/A N/A - Screened Out Water Pump Area IS-A 20B Circ Water CNS-FP-256 N04 Yes N/A N/A N/A N/A - Screened Out Pump and Traveling Screen Area TB-A 21A Radwaste CNS-FP-257 N07 No Floor drains are routed to Ventilation air from areas Training materials reinforce Based on the availability of Bldg monitored Liquid containing radioactive use of the pre-fire plans. engineered controls for Basement Radwaste System (LRWA'). materials and equipment Pre-fire plan revisions will both smoke and fire Radwaste Building floor are monitored by the identify potentially suppression water runoff, drain sumps H and K Radwaste/Augmented contaminated areas, and use of revised pre-fire receive drainage flow. The Radwaste Building provide instructions for plans and training sumps are provided with Ventilation Radiation communication with materials, the NPPD pumps which transfer the Monitoring System and is Radiation Protection, and approach will meet NFPA collected drainage from discharged to a common describe precautions to be 805 radioactive release the sump to the Radwaste exhaust vent for both the undertaken for the performance criteria.
| |
| System Floor Drain Radwaste Building and containment and safe Collector Tank. The Augmented Radwaste removal of contaminated collected wastes are Building HVAC systems. smoke and water runoff in analyzed, filtered, and For the potentially these potentially treated prior to either safe contaminated exhaust, two contaminated areas.
| |
| disposal or re-use in the separate full capacity filter Training material and pre-station. assemblies are installed fire plan revisions will upstream of the exhaust describe the presence and Provisions are also in vent. Each filter assembly is potential use of monitored place to commence isolated automatically with HVAC and drainage communication between fan operation. Prefilter and systems, if such systems the Fire Brigade and HEPA filter differential are deemed operational Radiation Protection and pressures are indicated and capable of supporting to contain/monitor liquid outside each filter assembly manual removal efforts.
| |
| effluents prior to safe compartment. The level of detail provided removal. in the revised training Ifnormal ventilation is not materials and pre-fire plans available, smoke will be will meet NFPA 805 removed using standard radioactive release industry manual ventilation performance criteria.
| |
| techniques (i.e. portable smoke ejectors and flexible Implementation S-3.20 -
| |
| ducts) to the outside or to Pre-fire plans and training an area where normal materials will be revised to ventilation will remove address radioactive smoke. Prior to any release, release requirements of plant pre-fire plans provide NFPA 805. See Page E-78
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions instructions to establish Attachment S, Table S-3.
| |
| communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| TB-A 21B Radwaste CNS-FP-258 N03 No Floor drains are routed to Ventilation air from areas Training materials reinforce Based on the availability of Bldg First CNS-FP-259 N03 monitored Liquid containing radioactive use of the pre-fire plans. engineered controls for Floor Radwaste System (LRW). materials and equipment Pre-fire plan revisions will both smoke and fire Radwaste Building floor are monitored by the identify potentially suppression water runoff, drain sumps H and K Radwaste/Augmented contaminated areas, and use of revised pre-fire receive drainage flow. The Radwaste Building provide instructions for plans and training sumps are provided with Ventilation Radiation communication with materials, the NPPD pumps which transfer the Monitoring System and is Radiation Protection, and approach will meet NFPA collected drainage from discharged to a common describe precautions to be 805 radioactive release the sump to the Radwaste exhaust vent for both the undertaken for the performance criteria.
| |
| System Floor Drain Radwaste Building and containment and safe Collector Tank. The Augmented Radwaste removal of contaminated collected wastes are Building HVAC systems. smoke and water runoff in analyzed, filtered, and For the potentially these potentially treated prior to either safe contaminated exhaust, two contaminated areas.
| |
| disposal or re-use in the separate full capacity filter Training material and pre-station. assemblies are installed fire plan revisions will upstream of the exhaust describe the presence and Provisions are also in vent. Each filter assembly is potential use of monitored place to commence isolated automatically with HVAC and drainage communication between fan operation. Prefilter and systems, if such systems the Fire Brigade and HEPA filter differential are deemed operational Radiation Protection and pressures are indicated and capable of supporting to contain/monitor liquid outside each filter assembly manual removal efforts.
| |
| effluents prior to safe compartment. The level of detail provided removal. in the revised training This area contains solids, materials and pre-fire plans liquids, and gaseous waste will meet NFPA 805 that ranges from highly radioactive release radioactive to low level performance criteria.
| |
| activity. For the highly radioactive waste (e.g. Implementation S-3.20 -
| |
| RWCU-related), these Pre-fire plans and training wastes are addressed with materials will be revised to thick concrete shielding, address radioactive Page E-79
| |
| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions storage drums, etc., where release requirements of a fire is unlikely. However, NFPA 805. See the pre-fire plans identify Attachment S, Table S-3.
| |
| that for fires involving radioactive materials, the Control Room and Radiation Protection personnel be notified.
| |
| If normal ventilation is not available, smoke will be removed using standard industry manual ventilation techniques (i.e. portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove smoke. Prior to any release, plant pre-fire plans provide instructions to establish communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| TB-A 21C Radwaste CNS-FP-260 N06 No Floor drains are routed to Ventilation air from areas Training materials reinforce Based on the availability of Bldg Second monitored Liquid containing radioactive use of the pre-fire plans. engineered controls for Floor Radwaste System (LRW). materials and equipment Pre-fire plan revisions will both smoke and fire Radwaste Building floor are monitored by the identify potentially suppression water runoff, drain sumps H and K Radwaste/Augmented contaminated areas, and use of revised pre-fire receive drainage flow. The Radwaste Building provide instructions for plans and training sumps are provided with Ventilation Radiation communication with materials, the NPPD pumps which transfer the Monitoring System and is Radiation Protection, and approach will meet NFPA collected drainage from discharged to a common describe precautions to be 805 radioactive release the sump to the Radwaste exhaust vent for both the undertaken for the performance criteria.
| |
| System Floor Drain Radwaste Building and containment and safe Collector Tank. The Augmented Radwaste removal of contaminated collected wastes are Building HVAC systems. smoke and water runoff in analyzed, filtered, and For the potentially these potentially treated prior to either safe contaminated exhaust, two contaminated areas.
| |
| Page E-80
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions disposal or re-use in the separate full capacity filter Training material and pre-station. assemblies are installed fire plan revisions will upstream of the exhaust describe the presence and Provisions are also in vent. Each filter assembly is potential use of monitored place to commence isolated automatically with HVAC and drainage communication between fan operation. Prefilter and systems, if such systems the Fire Brigade and HEPA filter differential are deemed operational Radiation Protection and pressures are indicated and capable of supporting to contain/monitor liquid outside each filter assembly manual removal efforts.
| |
| effluents prior to safe compartment. The level of detail provided removal. inthe revised training If normal ventilation is not materials and pre-fire plans available, smoke will be will meet NFPA 805 removed using standard radioactive release industry manual ventilation performance criteria.
| |
| techniques (i.e. portable smoke ejectors and flexible Implementation S-3.20 -
| |
| ducts) to the outside or to Pre-fire plans and training an area where normal materials will be revised to ventilation will remove address radioactive smoke. Prior to any release, release requirements of plant pre-fire plans provide NFPA 805. See instructions to establish Attachment S, Table S-3.
| |
| communications with Radiation Protection personnel, and to also provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
| |
| TB-A 21 D Radwaste CNS-FP-261 N05 No Floor drains are routed to Ventilation air from areas Training materials reinforce Based on the availability of Bldg Third monitored Liquid containing radioactive use of the pre-fire plans. engineered controls for Floor Radwaste System (LRW). materials and equipment Pre-fire plan revisions will both smoke and fire Radwaste Building floor are monitored by the identify potentially suppression water runoff, drain sumps H and K Radwaste/Augmented contaminated areas, and use of revised pre-fire receive drainage flow. The Radwaste Building provide instructions for plans and training sumps are provided with Ventilation Radiation communication with materials, the NPPD pumps which transfer the Monitoring System and is Radiation Protection, and approach will meet NFPA collected drainage from discharged to a common describe precautions to be 805 radioactive release the sump to the Radwaste exhaust vent for both the undertaken for the performance criteria.
| |
| System Floor Drain Radwaste Building and containment and safe Collector Tank. The Augmented Radwaste removal of contaminated collected wastes are Building HVAC systems. smoke and water runoff in Page E-81
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| | |
| Nebraska Public Power District CNS NFPA 805 Transition Report - Attachment E Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Pre-Fire Screened Engineering Controls Training and Pre-Fire Area Zone Description Plan Plan Rev Out? Water Smoke Plan Review Results Conclusions analyzed, filtered, and For the potentially these potentially treated prior to either safe contaminated exhaust, two contaminated areas.
| |
| disposal or re-use in the separate full capacity filter Training material and pre-station. assemblies are installed fire plan revisions will}}
| |
