ML20058L366

Comparison of Existing Fire Protection Provisions to Guidelines Contained in SRP 9.5.1

ML20058L366
Person / Time
Site:	Monticello
Issue date:	12/10/1976
From:	NORTHERN STATES POWER CO.
To:
Shared Package
ML20058L365	List: ML20058L362 ML20058L366
References
NUDOCS 9105160399
Download: ML20058L366 (58)

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I Page I_ of E REVIEW OF GUIDE 1.INES CONTAINED IN STANDARD REVIEW FIAN 9.5.1 i

Action Feeded to Comply uith Guideline item No. Re fe rence NRC Guideline or Recommendation Present F1ent Statue or Practice i

l Overall Bettirements of Plant Program There is presently no document that Directives will be prepered to destenete 1 APGB 9 5 1 ' iwsponsibility for the overall fire protection responsibilittee for the nucteer plent

IV. A.1 program should be assigned to a designated designetes e person in management as having j person in the upper level of snnagement. overall responsibility for the nucteer' fire protection program.

plant fire protection program.

Person responsible for overall fire protection See item (1) above. This requirement will be settsfied

. 2 APCSB 9 5-1 in directives designating responsiblittles IV.A.1 pmgram should retain taltimate responsibility for the nucteer plant fire protection i

even though formulation and assurance of program implementation is delegated. program.

Delegation of autbarity by person responsible See item (1) above. This requirement will be setiefted 3 APGB 9.51 in directives desigusttog responethtlittee IV.A.1 for overall fi n protection program should be to staff personnel prepared by trsining and for the necteer plant fire protection i program.

experience in fire pmtection armi nuclear plant safety to provide a balanced approach in directing a nuclear plant fire protection program.

i 4 APGB 9 5-1 The PGAR should state the qualification this guideline is not applicable to en IV.A.1 requirements for the fire pmtection engineer operating nuclear power plent.

or consultant who will assist in the design and selection of equipment, inspect and test the completed physical aspects of the system, develop the fire protection progrna, and assist in the fire-fighting training for tha operating plant.

5 APGB 9 51 *lhe PSAR should dieeuse the trsining and the This guideline is not opplicable to en IV.A.1 upiating p mvisions such as fire drills provided eyersting nucteer power plant.

. for maintaining the competence of the station fir *. fighting and operating crew, inclaiing personnel responsible for maintaining and inspecti.ng the fire protection equiper>nt.

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REVIEW OF CtTIDE1,1NES CONTAINED IN STANDAPD REVIEW PtAN 9.5.1 l

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i Itom No. Re fe rence NRC Guideline or Recomendation Present Plant Statue or Practice Action Needed to Counply with Guideline 6 APCSB 9 5-1 he etsff to whom authority for fomuistion e) Fire detection and protection systeme IV.A.1 and assurvice of program inrplewntation were designed by Bechtel Corporation l

has been delegated should be responetble for: and NSF Engineering in close cooperation with the NSP safety and insurance groups

a. Coordination of building layout and and NELPIA. D e design required all systema design with fire requirements, ereen containing combustible meterial i

including consideration of potential to meet criteria contained in NFPA bazards associated with postulated etenderde in ef fect et the time of design basis fires. construction.

i I b) Heintensnce of protection end detection

b. Design and unintenance of fire detec.

tion, suppression, and extinguishing ett'pment is under the direction of the systems. pts..t steintenance st ef f.

l 'c. Fire pmvention activities. c) Fire prevention activities are under the direction of the plant Superintendent i

d. Plant personnel and fin brigade Operation and Maintenance.

l training and annual fin righting I activities. d) Fire training to under the direction of the plant Superintendent Operation and

, Maintenance and the plant Training l Supervisor.

i 7 APT 3B 9 5-1 he overnll fire ymtection pmgram should be ne fire protection program is beoed on A fire heterde snelyste using updated IV.A.2 based upon evaluation of potential fire appitceble stenderde end NEIPIA criterie will be done for the plant hazanie throughout the plant and the effect of reemunendations in ef fect when the plant to evoluete the ef fects of the postulated design basis fires relative to wee designed. design boats fitee.

maintaining ability to perfom safety shutdown functions and minimize radioactive mleases Revisions will be made in the fire protectic to the envinnment. progree where they are found to be regJited S APCSB 9 5-1 Total reliance should not be placed on a All automatic fire suppreceiou systees are IV. A. 3 single autonntic fire suppresator system. backed up by fire hose stations.

Appropriate backup fire suppreselon capability shodd be provided. (In each area containing safety related systems and equipment where automntic fire suppression equipment is installed, suitable backup suppmeston empebility abould be available. )

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REVIEW OF CUIDELINES CONTAf N rn IN STANDARD REVIEW PIAN 9.5.1 Present Plant Status or Practice Action Needed to Caply with C.tdeline Item No. Re fe rence NRC Cuideline or Recomendation A single failum in the fire suppression system llose stations are located throughout the 9 APCeB 9 5-1 reactor, turbine, and office buildings- They IV.A.4 should not impair both the primarf and backup were insta tted in accordance with the require-fire suppression capability (in any area containing safety related systems and equip- ments of the National Fire Code. Portable ment). Postulated fires or fire protection extinguishers have been located at various system failures need not be considered locations throughout the plant. The fire concurrent with other plant accidents or the Pumps have independent suppites and controle most severe natural phenomena. In the event (see response to Itee 101).

of a SSE, however, the fim suppression As permitted in Appendix A to APCSB 9.51, the nystem should be capable of delivering water to manual hose stations located within system has not been analysed to withstand the hose reach of arens containing equipsent SSE.

required for safe plant shutdown. The fire protection systems should, however, retain their original design capability for:

(1) natural phenomna of less severity and greater fraquency (approximtely once in ten y*ars) such as tornadoes, hurricanes, floods, ice stoms, or smil intensity earthquakes which are characteristic of the site g*ographic region.

(2) for potential mn-craated site related events such as oil barge collissions or aircraft crsshes which have a reasonable probaeility of occurring at a specific plent site.

10 The effects of lightning strikes should be The effects of itghtning strikes were con-APCGB 9 5-1 sidered in the overall plant fire protection IV.A.h included in the overall plant fire protection program. program. Lightsing protection has been in-stalled for the reactor building, the tur-bine butiding, the off-gas stock , and the cooling towers.

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9 Page 4 of 2 REVltV 0F GUIDELINtl5 CONTAINED IN STANDAPD REVIEW PIAN 9.3.1 Action Needed to C a ply with Guideline Re fe rence NRC Guideline or Recceseendation Present Plant Status or Practice Item No.

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Failure or inadvertent operation of the fire Refer to items 12, 42, and 118.

11 APC3B 9.}-1 I IV. A.$ suppression system should not incapacitate j enfety reinted systems or components.

l 12 APGB 9 31 Fire suppression systems that are pressurized Section B.4.d of APCSB Bronch Technical IV.A.5 during nonnal plant operstion should meet the Position 3-1 states that, l

guidelines contained in APCEB Brainch Technical Designs of plants for which operating

! Position 3-1, " Protection Against Postulated licenses are issutd before July 1, Piping 7%ilures in Fluid Gystemo Outside 1975 are considered acceptable with l

l Containment." 'Ihese guidelines include: regard to effects of piping failures s outside contaitunent on the bests of

.B.1 Protection of essential systems the analyses made and measures taken and ccuponents against pipir4 by applicants and licensees in re-failures through plant arrangemnt sponse to the December 72 letter-or protective enclosures if practical frois A Gisabusso, and the staf f re-view and acceptance of these analyses B.2 Protective structures or compartments and measures.

needed to implement (B.1) should be Staff review and acceptance of the analyses designed to seismic (htegory I performed and reasures taken in response to requirements. De protective structures the December,1972 letter f rom A Gisabusso is should be des 16ned to withstand the documented in the July 29, 1974 letter from effects of a postulated piping failum Karl R Goller to Northern States Power Co. ,

in combination with loading associ. A stannary of the analysis conducted on the sted with the operating basis earth- fire protection piping was included in a quake and SGE within the nspective letter from L 0 Mayer, NSP. to D L Ziemann, design load limits for structures

• USAEC, dated August 24, 1973.

Protective measures, structures, ard guard pipes should not prevent the sceess required to conduct inspections.

B.3 he effects of each postulated pipe f ailun- (BTP MED 3-1 ascumptione for moderate-energy fluid system) should be shown to result in offsite consequences within the guidelines of 10 CFR 100 under the conditions spacified in BTP AFCCB 3-1, Section B.3.b.

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RIVIEW OF CUIDEl.INES rrMTAINED IN STANDAPD R.EVIEW PIAN 9. 5.1 Present Plant Statue or Practice Action Needed to Comply with Guideline I t ect No. Reference NRC Guideline or Reccennendation 13 APGB 9 5-1 The fire pmtection program (plans, personnel, nis guideline is not applicable to an lY.A.6 and equipment) for buildings storing new operating nuclear power plant.

reactor fuel and for adjacent fire zones which could affect the fuel stomge zone should be fully operational before fuel is received at the site.

11. APGD 9 5-1 'Ihe fire protection pr06mm for an entire reactor nie guideline is not applicable to an IV. A.7 unit should be fully operational prior to initial operating nuclear power plant.

fuel londing in that reactor unit.

APGB 9 5-1 On multiple mactor unit sites where there are nie guideline is not applicable to a 15 single unit nuclear power plant.

IV. A.8 operating reactor units and construction of remaining unite is being completed, the fire protection program should pmvide continuing evaluation and include additional fire barriere, fire protection capability, and administrative contmle necessary to pmtect the operating units from construction fire hazards. He operating plant superintendent should have the lend responalblity for site fire protection.

Ger+rni Guidelines for Plant Protection A fire hemarde analysis wee not performed As requested in the September W.1976 letter Niid tre ineelgn during the initial plant design, from Karl R Coller to Northwa States Power 16 APGB 9 5-1 Flant 19youte should be arranged to Co. we have retained a qualified fire pro.

IV. B.1 ( a ) tection engineer (Bechtel Power Corp) to

&(b) (1) Isointe r.afety related systems from perform such en analysis. Decisione concern-unacceptable fire hazarus* ing modificatione required to settery this guideline will be made following completion (2) Separate redurulant safety related of the fire hasarde analyste.

systems frota each other so that both are not subject to damnge from a single fire hazarx1.

f In order to secomplish this, safety related systems and fire hazards should be identified throughout the plant. Berefore, a detailed 'l fire hnzard annlysis should be made during initial plant design.

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Page 6 of 57 FIVIEW OP GUIDELINES Cte4TAINED, IN STANDARD REVIE'J riAN 9.5.1 item No. R e f e renc e NRC Guideline or Recomendation Present Plant Status or Practice Action Needed to Casolv with Guideline 17 ApscB 9 5-1 For multiple reactor unit sites, cable spraadiry Monticello is a single reactor site. ne con- A fire hasards snelysis which will identify IV. D.1 ( c ) rooms shoald not t e shared between reactors, cept of defined fire aress surrounded by fire fire area barriers and provide an analysis Ench cable spreading room should be reparated ' barriers was not applied to the original plant of the consequences of design basis fires it f rom other arens of the plant by barriers design. each area is being performed.

(wsils and floors) having a minimum fire resistance of three hours. Cabling for radundant safety divisions should be reperated by walls having three hour fire barriers.

16 APGB 9.5-1 Interior vall and structu.rsl ece:ponents, themal All areas containing safety related systems Investigation of acceptability of toterior IV. D.1 ( d ) insulation ustterials, radiation shielding and equipment have interior walls of concrete finishes is continuing.

materials, and soundproofing shoald be and structural emponents of steel. Thermal noncombustible (in each area corstaining insutstion is used on piping and equipeent and safety related systems and equipmant). is composed of noncombustible material. Radt-Interior finishes should be noncombustible or ation shielding and soundproofing in the plant listei by a nationally recognized testing is provided by the concrete walls, ne con-laboratory, such as Factory Mutual or trol room has a suspended ceiling With is Undewriters Inbormtory, Incorpo r sted, fo r noncombustible (See Item 20).

finre sprend, snuke and fuel contribution of 25 or less in its use configuistion ( AGIM E-%

Test, " Surface Burnirg Omracteristics 3r Building Mnterials".

19 APGB Q. 5-1 Matal deck roof construction should be non- Built-up roofing and insulation material for IY . B.1 ( e ) emtustible (see Underwriters Imboratcry, the plant is Itsted by Underwriter's 1.aborn.

Incorporated building enteriale directory), tories, Inc., as acceptable for Class A roof or listed as Class I b, Factory Mutual construction.

System Approval Guide.

20 APc0B 9 5-1 Suspended ceiling and their supports (in each n e control room is the only area m ntaining IV. P.1 ( f) ares containing safety related systmo and safety related equipment nich has a suspen-equipm nt) should be of noncombustible ded ceiling. n is ceiling was chosen to construction. Concealed spaces should be qualify as a one-hour fire resistive ceiling devoid of combustibles. conforming to Underwriters' laboratories Retardant Report Series 4177, for non com-bustible materials, as listed under the t?nder writers' leboratories, Inc., Building Materia.e List. Concealed spaces in this ceiling are devoid of casbustibles. -

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REVIEW OF GUIDELINES CONTAINED IN STANDARD REVIEW PIAN 9.5.1 Action Needed to Cnunply with Guideline Itram No. Reference NRC Guideline or Recoweendation Present Plant Status or Practice High voltage - high amperage transformers High voltage-high current trans formers (spect-21 APGB 9 5-1 fically, the 4160/480 v load center trans-IV. B.1 (g) installed inside buildings containing safety related systems should be dry type or insulated formers) located in the turbine butiding at and cooled with noncestzustible 11guld. Monticello are insulated and cooled with Geners t Electric *Pyranol", a noncombustible liquid. No other high voltage-high current transformers are installed in buildings con-teining sa fety-related equipnent.

ne diesel generator building and the recom- A decision concer,ing any modiffestions will Du11 dings containing safety related systems 22 APCSB 9 5-1 should be protected from exposure or spill biner building have ventilation openings with. be made following conspletion of the fire IV. B.1 (h) in 50 feet of a transformer. hazards analysis.

fires involving oil filled tansformers by locating such tmnsformers at least 50 feet

listant or by assuring that such building wnlis within 50 feet of oil filled transformers are without openings and have a fire resirtance rating of at lenet three hours.

trloor drsins, sized to remove expected fire Adequately sized floor drains are provided in Adequately stred floor drains will beroom.in-23 APQB 9 5-1 those areas where fixed water fire suppressio i stalled in the recirculation M-G set IV. B.1 ( 1 ) fighting vster flow, abould be provided in systems are installed except for the recircul i-those areas where fixed vnter fire suppression systems nm inst %11ed. Drains should also be tion M-G set area and the tube oil dr'.as providad in other nrens where hand hose lines storage ares. Were is no safety related any be used if such fire fighting vnter equipment in the vicinity of the tube oil could enuse unacceptable dncnga to other drtas storsge area. Accumulation of water in (safety related) equipment in the araa. this area would not create an unacceptable consequence. All safety related equipment is installed such that it will not be affected by fire fighting veter buildup.

2k APCSB 9 5-1 (Gnfety related) equipment should be either All safety related equipment is installed on IV. B.1 ( 1) Installed on pedeetals, or curbs should be pedestals, or mounted high enought above the provided as requir*d to contain water and floor to not be affected by water, or pro-direct it to floor drains ( NFPA 92, " Water- tected by curbs.

proofinsand Draining of Floors.")

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e Page 8 of g REVIEW OF CUIDELINES CONTAINED IN STANDARD REVIEW PLAN 9.5.1 Present Plant Status or Practice Action Needed to Cteply with Guideline Item No. Reference NRC Guideline or Recommendation 25 APCGB 9 5 1 Drains in areas containing combustible 11gulds All drains are discharged to sumps below the IV. B.1 (1) should have provisions for p nventing the sump water levels except the tube oil storage spread of the fire throughout the drain system. tank area drain. This drain discharges to the emergency dump tank. These drain provisions prevent the spread of fire.

26 APCGB 9 5 1 Water drainage from areas which may contain All drainage from areas Wich may contain IV. B.1 ( 1 ) radioactivity should be sampled and analyzed radioactivity is directed to the liquid red-before discharge to the environment, vaste systen Were it is either reclaimed or would be sampled and analysed before dis.

charge to the environment.

APCGB 9 51 Goers, walls, and ceilings enclosin6 separnte See response to Ites 17.

27 IV.B.1 ( j) fire areas should have minieram three-hour fire ratings.

26 APCSB 9 51 Penettstions in fin area barriers, including See response to Item 17.

IV. B.1 ( j ) conduits and piping, should be sealed or closed to provide a fin noistance rating at least equal to that of the barrier itself.

29 APCSB 9 5 1 Door openings in fin area barriers should be See response to item 17.

IV. D.1 ( k ) protected with equivalent rated doors, frames, and hardware that have been tested and approved by a nationally recognized laboratory. Such door should be normally closed and locked or provided with an alars and annunciation in the control room.

APCGB 9 51 Penetrations in fire area barriers for ventila. See response to item 17.

30 IV. B.1 (1) tion systems should be protected by a starderd

" fire door damper" where requind (ff?TA 80,

" Fire Doors and Windows.")

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RZVIEW OF CUIDELINES CONTAINED e IN STANDARD REVIEW PLAN 9.5.1 Re fe rence NRC Cuideline or Recco u ndation Present Plant Status or tractice Action Needed to Comply with Guideline Item No.

Control or Ombustibles in generst there is very little combustible The fire hasards analysis will identify any 31 APGB 9 5-1 Safety related systems should be isolated or material in the vicinity of safety related need for additional special protection IV.B.2 (a) separated from ecubustible materials. When systems. Control of storage of combustible measures, this is not possible due to the nature of the material is addressed in Item 73.

I safety system or the combustible material, l special protection will be required to prevent With respect to the specific examplest a fire defeating the safety system function.

Such protection may involve a combination of 1) See response to item 186.

autoontic fire suppression, and construction capable or withstanding and containing a fire 2) Turbine generator tube att piping

. that consumee all combustibles present. and storage areas are protected by

{ Examples or euch combustible anterials which automatic sprinkler systems, may not be separable from the remainder or its system aret 3) Reactor rectreulation ptmps are located inside primary contain-i (1)Deerrency diesel generator fuel oil ment which is inerted during

' day tanks. operation (See Itsen 138).

(2) Turbine-generator oil and hydraulic control fluid systems.

(3) Beactor coolant pump lube oil system.

32 APCSB 9 51 Bulk gas storsge (either compressed or cryo- Bulk gas storage is located outside struct-1 IV. B.2 ( b ) gente), should not be pemitted inside struc* ures housing safety related equipment.

tures housing safety related equipment.

33 APCSB 9 5-1 F1summatle gas stomge such as hydrogen should Fleansable gases are stored in the hydrogen IV.B.2 (b) be located outdoors or in separste detached storage building and the hot machine shop.

buildings to that a fire or explosion will These are both separate, but attached not adversely arrect any safety related systems buildings. It is extrememly unlikely that or equipment (NFPA Son, " caseous Rydrogen ' a fire or explosten would adversely affect Systems.") safety related equipment.

3h APdSB 9 5-1 a re should be taken to locate high pressure All gas storage containers located in IV. B.2 (b) gas stoms e containers with the long axis buildings housing safety related equipment pars 11e1 to building walls. This will minimize are oriented such that the long sais le the possibility or wall penetration'in the parallel to the building walls.

• wnt or a centsiner failure. - - - . _ . - _ __ _ _ _ _ .

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fage 10 of y PUltv 0F Cli1DELINES CONTAINE3 IN STANMP2 PSIEV PIAN 9.5.1 Action Needed to Cm ply with Guidelin Reference NRC Guideltne or Recomendation Present Plant Status or Practice tte= so.

in aw>st instances use of compressed gases is The use of compressed gases will be revieve, APcB 9 5-1 Use of centr *esed gnees (especially rimmable 35 and fuel gsces) inside balldirss shed 3 te governed by the existing work control process, to deterntne if additional eastnistrative IV. B. 2 ( b ) controle are required (See also response to controlled (NTTA 6, " Industrial Fire loss Items 73 and 223).

Pre ve nt ion. ")

APIB 9.5-1 The use of pinstic mterisis should be mini- Pla stic materials a re used for radia tion pro-36 mired. Haloginated plsetics espacially, tection purposes, however, the use of this IV. B.O ( ) material is minimited to the extent practical.

such as TVC and neepr*ne, should be ured only where Fubstitute DCDCCeibustible BRtertRIS See elettriral Cables are constructed with sT not sysilable. e PVC outer jacket (See response to Item 46).

Fln=rmble liquids stenge should, as a miMaum, Flassmable liquido storage at Monticello cep- lovestigation of energency relief venting f.

37 AP.r B 9 5-1 lies with all applicable requirements of MITA fire esposure of above-ground tanks is con-IV. S ? ( d) eceply with the requirevnts of NTPA 30, tinuing. The fill line for the underground "Flansble ani cmbustible Liquids Cbie." 30 with minor exceptions. The linen frm each diesel ergine day tank to the l'esel fuel oil storage tank is not properly ident engines do not have shutof f valves located as fled, tais line will be iden ti fied. Th e specified in paragraph '342. It is felt that steel supports for the heating boiler and installation of such valves, is undesireable diesel fire psamp day tanks are not protect because transfer of oil to the diesel depende as outlined in paragraph 2430 Ndi fi c a t t o on a syphoning action dich could be a ffected v111 be made to comply with this requirceen by the additional valves. There are isolattoi valves on these lines located near the diesel generator.

thble Trmys, 4 Penetrations Cables are routed in steel trays.

Otble constructit n,

% APCSB 9.5-1 Only nonetsabastil'.e enterials abould be used for IV. B. 3 ( a ) cable tmy construction.

I There are no autmatic sprinkler systees pro- A decteten concerning installation of such F APCSB 9.5-1 Autoentic vster sprinkler systems should be eyetens will be made following cc g lettee o pmvided for esble trve outside the cable vided for cable trays cutside the cable IV. B. 3 ( c ) spreading room.

the fire homards analysts.

spreed1Nr f m e.

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cables should be destra.d to allow wetting down Electrical cables et the Monticelto facility l' 00 ANSB 9. 5 1 are ineuteted with veterproof synthetic IV.B.3 (c) with deluge water tcithout electrical faulting.

l esterials such as butyl rubber, neoprene, or polyethylene. By design, splices are not j peruttted in trays, conduite, or raceways.

I Thus electrical faulting would not be l espected to occur tf the cables were wetted i with deluge water, l

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9 Page 11 of 57 REVIEW OF CUIDEllNES CONTAINED IN STANDARD RIVIEW PIM 9.5.1 Item No. Re fe rence NRC Cuideline or Rectwanendation Present Plant Status or Practice Action Needed to Ctoply with Guideline u APcGB 9 5-1 Manual hose stations and portable band Manual hose stations and portable hand ex-IV. B. 3 ( c ) estinguishere should be provided as a backup tinguishers are provided for fighting cable means of wetting down cable tmys outside the tray fires outside the cable spreading room.

cable spreading rme.

42 ArcGB 9 5-1 Safety related equipment in the vicinity of cable khile some exceptions have been identified, Additional protection may be needed for the IV. B. 3 ( c ) trnys. which does not itself require water safety related equipnent is generally not the following equipment to coerely with this fire pmtection, but is subject to unneceptable subject to water damage. i tre:

damnge if wetted by eprinkler (or hoca or 1. Yarway reactor level switches extinguisher) water discharge, should be 2. Scram discha rge voltsee level se ltch, prutected from sprinkler system (or bose or 3. Secondary containement isols tion extinguisher) operation or malfunetton. damper actuators Appropriate protection will be provided.

43 APCSB 9 5-1 Cable and cable tray penetrwtion of fire barriere see response to item 17.

IV. B. 3 (d) (vertical and horizontal) should be senled to give pmtection at least equivalent to tha ___ _

fire barrier. The design of fire barriers for horizontal and vertical csble trwys should, as a minimum, maet the requirements of ASTM E-119, "Fim Test of Pu11 ding Construction and Materials," including tha hose stream test.

u Fire breaks should be installed at every 10 feet Cable runs at Mmticello were not installed decision concerning installation of such APCSB 9 5-1 with fire breaks in the cable trays. breaks will be made follevt g co,,pg,gg,, ,g IV. P. 3 ( e) along horizontal and vertical emble routings to pr* vent the propagation of a fire. Ylruse or the fire hasards analysis, fire retardant coatings any be used as a firs break for gmuped electrical cables to limit sprend of a fire in cable routings.

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APGB 9 5-1 Electric cable constmettons should at leert pnee Me electrical cables at Nonticello were menu !ovestigationio detemine' the status of our 45 factured and installed prior to issuance of cables with respect to the IEEE-383 standard ty. p. g ( f ) the current lEEE No. 383 flame test. '

the IEEE-383 Standard. The cables do, how- is continuing.

ever, meet the arplicable Insulated Power Cable maineers Association (IPCEA) standards in effect et the time of manufacture; specifi.

cally, S-19-81 for rubber insulated cable and S-61-402 for thermoplastic insulated cable, nese standards include flame testa of single cables in horizontal or vertical configure-

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Page 3 f SI REVIEW OF GV1DEt,1NES CNIAINED IN STANDARD REVIEW PIAN 9.5.1 Action heeded to Comply with Guidellre Present Plant Status or Practice NRC Cuideline or Recocumendation _

Item No. Re f e rence in accordance with Appendix A to Branch Techni To the extent practical, cable construction cal Position APC55 9.5-1, this guldettne h6 that does not give off corrosive gases while is applicable to new cable installations.

APCOB r!. B. 3 (g 9.5-)1 burning shou.ld be used.

Miscellaneous storage in these areas will Cable trays, receveys, conduits, trenches or be prohibited by s&ministrative directives.

AFCB 9 5-1 Cable traye, Tsceways, conduit, trenches, or culverts are used only for cables. Diesel 47 IV.B. 3 (b) culverts should be used only for cables. oil, turb"ne oil, and hydrogen gas piping Miscellaneous storsge should not be pemitted. is not installed in these areas.

Piping for flamable or combustible 11gulds or gases should not be installed in these areas.

All plant ventilation units are capable of Areas containing significant concentrstions being manually controlled to attow smoke L8 APCSB 9.5-1 IV.B. 3 (1) of plaistic insulated electric cables steh as venting as required, cable tunnels, culverte, and spreading rooms should be pmvided i:ith automatic or manual smoke venting as required to facilitate ranual fire fighting capability.

All cables entering the control room arehe for Cables in the control mom should be kept to the control rocia use and terminate there, re 49 APCSB 9 5-1 minimum necesssry for o;erstion of the control IV. P. 3 ( j ) are no concealed floor and ceiling spaces room. All cables entering tre control room CD,bles should not be used for cable routing except for control should terminate there. room lighting power cables which are run in installed in floor trenchas or culverts *n the conduite above the ceiling tile.

control room.

his evaluation will be made in coejunction Ventilatitm Ventilation frees areas with potential for d APCSB 9 5-1 Products or combustion which need to be removed release of radioactive materi11 is monitored. with the fire hasards analysis now un erw 50 from a specific fire area should be evaluated to IV. B.4 (s ) deterinine how they will be controlled. anoke and corrosive gases should generally be auto-metically discharged directly outside to a safe location. Smoke and Bases containing radio-setive materials should be monitored in the fire area to determine if release to the environment is within the pemissible limits of the plant Technical Epecifications.

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Fuga 13 of 57 REY!EW OF GUIDEt1?tEs CCNTAINED IN STANDARD REVIEW PIAN 9.5.1 NRC Cuideline or Recommendation Present Plant Statue or Practice Action Needed to Comply with Guldettne Item 18o. Re fe rence 51 AFCSB 9 5-1 Any ventilation system designed to exhaust ne isolation systems for primary and IV.B.h (b) smoke or cormstve gases should be evaluated secondary containment are designed to meet to assure that inadvertent opemtion of single failure criteria. The ventilation single railures will not violate the controlled system for the control room is designed areas of the plant design. 21e vaquirement to allow recirculation to maintain includes containment functions for prvtection habitability. No special neoke or gas of the public and maintaining habitability for exhausting systmo are required or installed.

opsrstions personnel.

APCSB 9 5-1 he power supply and contals for mechanical ne plant was not designed with specific fire A decision concerning Ony required modifica.

52 IV. B.4 ( c) ventilation systems should be run outside the areas. We have reviewed the locations of the tions will be made following completion of fire area served by the system. ventilation system power supplies and controli .the fire hasards analysis.

We have identified several plant areas where power supplice and controle are located with-in the ventilated a rea, nis includes diesel generator area, reactor building ventilation power supply and control areae , and intake structure psump rom area.

Fixed automatic sprinkler systema should be nere are no fized automatic sprinkler sys. A decision concerning the installation of

$3 APCEB 9 5-1 tes installed to protect charcoal filters, such systems will be made following com-IV.B.6 (d) installed to protect charcoal filters.

pletion of the fire hasarde analysis.

APCSB 9.$-1 he fresh air supply intakes to areas containin6 The fresh air intakes are located remote from 54 safety related equipment or systems should be the exhaust air outlete except for the switch IV. B.h (e) gear area. Modifications are unnecessary se located remote fmm the exhaust air outlete and smoke vents of other fire areas. B is is to gravity venting of this area is adequate minimise the roselbility of contamination of the (See response to Itm 60).

intaka air with the products of combustion.

APCSB 9 51 stairvelle cheuld be designed to minimise suoke ne aministrative building stairw - la are 55 IV.B.k ( f) infiltration during a fin. designed to minimise sacke infilt " ion.

ne stairvelle in the reactor en/ Aine buildings are of open metal const. _.an.

W ey need not be redesigned to minimise smoke infiltration because:

1. anch level of these buildings casamunicate freely via open equipment hatches and other openings. Therefore encioeure ,

of the stairwelle will not prevent the spread of smoke

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,V Pt.AN 9.3.1 REVIEW OF GtTIDELINES crHTAINED IN STANDARD "

Action Needed to Comply with Guideline NRC Cuideline or Recomumendation Present Plant Status or Practice item No. Reference

2. The heating and ventitating systems for the reactor and turbine buildings were designed with consideratione given to the commemiesting levete.

Isolation of these levels would degrade the ventilation and smoke renoval capacity of these sytems.

3. All commamicating floor levels are sufficiently open and un-obstructed so that it may be assumed that a fire or other dangerous condition in any part will be immediately ob-tous to the occupants of all camounicating levels and areas. Esit stairways are well separated and sufficient to provide simultaneous evacum-tion for all the occupants of all the casesunicating levels and areas.

Stairesses should serve as escapa mutes and Staircases are provided throughout the plant

$6 APGB 9 5-3 and serve se escape routes and access routes IV.B.h (f) secess routes for fim fighting.

for fire fighting.

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Page 15 og y REVIEW 07 GUIDELINES CONTAINED IN STANMRD REVIEW PIAN 9.5.1 Item No. Re f e rence NltC Guideline or Reconnendation Present Plant Status or Practice Action Needed to Comply with Guideline 57 APCSB k.5-1 Fim exit mutes should be clearly marked. Sane fire exit routes are not clearly marked. Appropriate areas of the plant will be sup-IV.B.k ( f) Plant employees are familiar with exit routes, plied with fire exit signs.

Plant visitors not familiar with the plant layout and exit routes are escorted.

APCGB 9 5-1 statrvells, elevators, and chutes should be Stairvelts, elevators, and chutes are not en-58 IV.B.4 ( f) enclosed in ensonry towers with minimmn thrae closed in masonry towers with a ministan three hour fire rating and automatic fire doors at hour fire rating. Fire exit routes will be least equal to the enclosure construction, at appropriately marked (see response to item 57:

each opening into the building. Practice evacuation and re-entry are included in the semi-annual emergency drill.

59 APTB 9 5-1 13evators should not be used during fire It is general plant practice not to use Signs will be inetslied at each elevator IV. B. 4 ( f ) enva rgencies. elevators in a fire emergency. entrance to mesure that the elevator is not used during a fire emergency.

60 APCSB 9 5-1 Smoke and heat vents may be useful in specific n e cable spreading room ventilation meets Investigation of other plant areas with re-IV. B.h (g) areas si ch as cable spreading rooms and diesel the power venting criteria, h e switchgear spect to this criteria is continuing. Any fuel oil storage areas and switchgear rooms. area ventilation meets the power venting and deficiencies revested by this investigation When used, they should be installed at a Bravity venting criteria. The diesel fuel will be reported.

minimum ratio of I square foot of venting arer oil day tank areas do not meet this criteria per 200 squam feet of floor area (the We feel that smoke and heat venting of the conversion factor for power venting is 300 Cm day tank areas is not required or desireable equals 1 square foot cf grnvity venting ares)* because these areas are small and could not Befer to NTPA No. 204 for additional guidance be entered during a fire. Venting would tend on smoke control. to increase the fire intensity by providing oxygen.

61 APCSB 9 5-1 Self-cor tnined breathing apparatus, using full We presently have alz Scott Presur-Pak 11 Additional Scott Presur-Pak units will face positive pressure masks, approved by units and two Scott Rescue-Pak units, ne be obtained to assure en adequate supply.

IV. B. 4 ( h )

NIOGH, should be pmvided for fire br1 6ade, Scot. S asur-Pak is approved by NIOSH.

damage cmtrol, and control room personnel. .

Control mom personnel vry be furTaished breathing air by a ennifold syntan piped from a storage reservoir if practical.

62 APG B 9 5-1 Service or operating life for self-contained ne Presur-Pak 11 is rated at 30 minutes IV. B.4 (h) t resthing appamtus should te a minimum of duration (Bureau of Mines approv.1 #13E-08).

1/2 hour. no Scott Rescue-Pak is rated at 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> duration (Bureau of Mines approval #13E-15).

"m ,i Pese of REVIEW OF CITIDELINES CONTAINED N STANDARD PEVIEW PLAN 9.3.1 NRC Guideline or Recoussendation Present Plant Status or Practice Action Needed to Cc=eply with Guideline Itos No. Reference 63 APCDB 9 5-1 At least two extra air bottles should be located the number of extra bottles does not meet (hte .re vill obtain additional air botties such IV.B.h (h) onsite for each self-contained breathir:g unit. criteria. that there are two extra bottles for each welf-contained breathing unit.

Na APCSR 9 5-1 An onsite reserve air supply should be We have a recharge system constating of three toditional spare cyttaders will be obtained IV. B. h ( b ) provided and so arranged to quickly and fully cascaded 300-cubic foot cylinders plus e- to meet this requirement.

replenleh exhausted supply air bottles as they spare cylindere.

are returned ( 6-hours per breathing unit).

i 65 APCSB 9 51 If coepressore are used as a source of breathing All self-contained breathing unite are supplied IV.B.h (b) air, only unite approved for breathing air should by reserve cylinde rs obtained from a ccannercial be used. Also, epecial care must be taken to recharge source.

locate the compressor in areas free of dust and cont aminants.

66 APGB 9 5-1 Where total flooding gas extinguishing systems there are no total see extingutehtng systems IV.B.k (1) are used, area intake and exhaust ventilation installed. Any eyeteos ubich may be dampero should close upon initiation of gas installed in the future will meet this riov to unintain neccesary gas concentration requiremen t.

(See NFPA Mo.12, "Omrbon Dioxide Systeme,"

and NFPA No. 12A, "Balon 1301 Systeme.")

67 APCSB 9 5-1 imed me n I l IV.B.5 (a) bould be proeided consisting of sealed beam unite with individust one on( e I suo a(e path fr the administration building and the other eye-8-hour minimum battery power supplies.

tes ilitaminates the control roce and pathways to the diesel generator and 4 KV evitchgear areas. The probability of a complete loss of essential AC power is extremely low. In the reaute chance that AC power is lost, the emnergency DC lighting systems provide adequate time for the evacuation 6nhe adm161-stration building and restoration of AC power.

68 APTB 9.$-3 Portable emergency lighting should be provide Two portable sealed beam battery powered hand.

IV.B.3 (b) consisting of suitable sealed beau battery lights are maintained in the control room powered portable hand lights, emergency locker, and one to meintained is ,

shift supervisors locker. In addition, portabl. !

hand lights are maintained in the 115 KV and 345 KV control houses at the substation. ,

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FDIEW OF GUIDE 1. DES C(ETABED IN STANDARD DDIEW FtAN 9.5d Ites No. Reference NRC Cuideline or Recommendation Present Plant Status or Practice Action Needed to Comply with Guideline j 69 APCGB 9 5-1 Fixed emergency communication should be Primary emergency communications at the IV.B.5 (c) installed using votee powered head sets et Monticello facility are provided by a fixed pre-selected staticus. public address systeen with stations located throughout the plant and a PABX telepbone sys<

a tem with estenstens throughout the plant. The public a4 dress system is powered by the unin-terruptible AC system while the PA3X system is powered by a separate battery. Secondary emergency communications are provided by a voice powered phone system with jacks in-

' stalled throughout the plant. Handsets y be connected at any location.

' .TO APCSB 9.F 1 Fixed repeaters installed to permit use of No itmed radio causesnication repeaters are t IV.B.$ (d) portable radio c-lestion units should be reptred at the Monticello facility. [

pmtected fmm exposure to fire daange.

)

Administrative Procedures, Administrative the plant emergency plan currently specifies Procedural modifications to incorporate the controls, aml Fire Brirsde the makeup and directs the actions of specific guidance contained in the NFPA publi [

71 APC5B 9 31 Administrative procedur*s consistent with the emergency teams. catione are currently under review. ,

I IV.B.6 (a) need for maintaining the performame of the I fire protection system and personnel in nuclear l pouer plants should be provided. Ouidance is contained in the following NFPA publications:

2. k Organitation for fire Services ,

No. kA Organitation of a Fire Department t No. 6 Industrial Fire loss Prevention ,

No. 7 Mmagement of Fire Boergencies t

2. 8 Manegement keponsibility for Effects of Fire on Operstions No. 27 Private Fire Drigades 72 APTB 9.5-1 I:rfective =4=inistrutive measures should be see response to Item 73.

( IV.B.6 (b) implemented to pmbibit bulk storage of combustible estterials inside or adjacent to safety related buildings or systems during operstion or maintenance periods. ,

, _ _ _ _ - _ _ _ _ . _ ___.__ - _ _ , _ - - . . . _ . - , . _ _ - - . _ _ _ . . _ . - _ _ _ _ . - _ . . . . ~ . _ . _ _ _ _ _ . . - . _ . - - - _ . . . . _ . - . _ , - ~ _ - . . - - . - _ . _ . _ _ ~ . . . . - _ - - -

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REVICW OF GUIDE 1.INES CONTAINED IN STANDARD REVIEW PtAN Y. 3.1 Present Plant status or Practice Action Needed to Comply with Guideline Itce No. Re fe rence NRC Cuideline or Recommendation Etisting work control processes include con-73 APC5B 9.51 Normal and abnormal conditions or otber sideration of the need for special action and IV.B.6 (c) anticipsted oparations such as modifications (e.g., b making fire stops, inrpaiment of fire Procedures, such as fire watches. Almost =11 detection and suppression systems) and refueling work involving ignition sources, such se activities should be aviewed by appropriate welding and cutting, is governed by the entst-levels of snnagement snd appropriate special ing work control processes. The NSP Safety Practices Manual establishes general house-action and procedures roch as ff re watches keeping practices. Existing work control or temporary fire barrten inplemented to processes include consideration of control assure adequate fire protection and reactor safety. In particular: of combustible material.

A parait system which will ene mpass all (1) Woril involving ignition sources such Maintenance personnel involved in such work welding or torch use in the plant is being as welding and fisme cutting should be have received fire protection training and developed to prevent unauthorised use of done under closely controlled condi- s11 NSP personnel participate in periodic welding or flame cutting equipment and tions. Procedures governing such work safety meetings which include training in fvrt'aer assure that special precautions, should be reviewed and approved by fire prevention and fire fighting. Personnel such as fire watches, or temporary fire persons trained and experienced in fire f rtaa offsite organizations are required to barriers, are implemented den necessary.

protection. Persons perforining and attend an indoctrination which includes fire directly assisting in such work should protection training, be trained and equipped to prevent and combat fires. A person trained in Equipment necessary to prevent of combat fire protection should directly monitor fires, such as asbestos blankets and fire the work and function as a fire watch. extinguishers, is provided.

Use of open fismes will be prohibited by (2) leak testing, and similar procedures administrative directive. tJoe of combustion such as air flow dete'ininstion, should generated smoke (except use with an approved use one of the conenercielly available procedure) will be prohibited by admini-ser= sol techniques. Open flames or strative directive, combustion genernted smoke should not be perinitted.

All wood presently used in the plant will be (3) Use of combustible material (e.g., treated with fire retardant. Only fire re-REPA and charcoal filters, dry ion tardant treated wood will be used in the exchange resins, or other combustible fu tu re. Requirements related to storege of supplies) in safety related areas combustible materials and restrictions on shod d be controlled. Use of wood in. the use et caobustible material in safety side baildtruts containing safety related areas will be included in assint-related systems or equipus nt should be strative directives.

permitted only when suitatle non.

combustible substitutes are not avail- The fire hasards analysis will consider the able. If wood must be used, only fire Possible and probable use of combustible retardant treated wood (seaffolding, materials to determine adequesy of installet lay down blocks) should be perinltted. fire protection systema.

such materials should be allowed into safety related areas only when they are to be used inse-diately. Their possible and probable use should be considered in the fire hazard analysis to deter-mine adaquacy of the installed fire

_ __. _ - pro _ t_ect_ ion systems.. _ -. _ ,_ _, _ _ _ . ,. _ ._. _ _ _ .

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REVIEW OF GUIDE 1,1NES CONTAINED IN STANDARD RIVIEW PIAN 9.3.1 Itee No. Reference NRC Guideline or Recommend *_ tion Present Plant Status or Practice Action Needed to Cceply with Guideline 71 APCSB 9.$-1 Public fire department response should be ne plant is designed to be self-sufficient IV.B.6 (d) in the overall fire protection with respect to fire fighting activittee, p rogrsa. 110 wever, the plant should be designed The Plant Dnergency Plan provideo for response to be self sufficient with respect to fire by the local fire department if requested by fighting activities and rely on the public the Emergency Director.

response only for supplemental or backup capability.

75 APCCB 9 5-1 The site Duergency Plan and specific emergency h e Monticello Emergency Plan and specific IV.B.6 (e) procedures should follow the guidance contained emergency procedures follw the guidance in ikgulatory Guide 1.101 Deergency Planning contained in Regulatory Guide 1.101.

for Nuclear Ibwer Plante,gw"here applicable.

76 APCSB 9.$-1 A test plan should be developed which lists the here is no test plan specifically for fire IV.B.6 (e)(1) individuals and their responsiblities in detection and protection system teste and connection with routine teste and inspections of inspections, however all of the desired the fire detection and protection systems. De elemments of a fire detection and protection test plan should contain the types, frequency, systes test plan are provided.

and detailed procedures for testing. Proceduree n e schedule for all surveillance require-should also contain instructions on maintaining ments identifies the type, frequency, and fire protection during those periods of fin group responsible. Detatted procedures for protection system impairinent or maintenance such testing and other record doetments are kept as fire watches or temporsry hose connections to in controlled files. Recorde Management Pro-water systems. cedures, Doctament Control Procedures, and a Surveillance Program doctament specify individ ual responsibilitice and adisinistrative pro-cedures for surveillance. All types of our-ve111ance are scheduled, seeigned, performed, reviewed and doctamented by the same method.

Preparation of a separate test plan for fire detection and p+otection systems would be totally redundant to existing documente and procedures. Emperience hee shown thet it is impractical to include detatted test proced-ures, which may require frequent and individ-ual revision, se part of a plan document.

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< ^% j' Page _2_0 er 37 REVIEW OF CITIDELINES CTAINED, IN STANDARD REVIEW PtAN 9.5.1 item No. Reference NRC Culdeline or Recouemendation Present Plant Statue or Practice Action Needed to Comply with Guidelin a

i l

TI APT,B 9 5-1 Drille for the rire brigade should be conducted no femal prosram existe that requires peri- sent-annual dritte for the emersency team IV. B.6 ( e )( 2) at least quarterly so that all members of the odie drille for the emergency team assigned seeigned fire fighting responetbilittee wil brigade have had the opportunity to train as, fire fighting responsibilities. On June 4, be conducted. Drill guides will be preparee '

a team, testing itself in the major areas of 1975 a semi-annual mergency Procedures Test to estabitsh the training objectives and the plant. De drille should include the was conducted. This test simulated a fire in anticipated response, including simulated u simulated use of equipment in each area and the recombiner butiding which required a re- of equipment, for the drille. Drill perfon should be preplanned and post-critiqued to sponse by the plant emergency teams and the ence wilf be monitored and poet critiqued.

establish the trainir4 objective of the drille Monticello Fire Department. Die Semi-annual This detti frequency is consistent with that and detemine how well these objectives have Energency Procedures Test conducted establiebed for emergency procedures drille.

been met. October 27, 1976 included a simulated tire 1 in the deisel generator day tank room.

neee drille involved almuisted use of ,

equipment and performance during the drille was post-critiqued.

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5 Pe se II- of $7 REVIEW OF GUIDELINES ' CONTAINED IN STANDARD REVIEW PIAN 1.3.1 Present Plant Status or Practice Action Keeded to Comply with Guideline Item No. Re fe rence NRC Cuideline or Recoennendation Drills should periodically (at least annually) A drill has been conducted with the local Plant fire dritte will be formalised to i 78 APCSB 9 5-1 fire department (See Itesa 77). include annual participation of the local IV.B.6 (e)(2) include local fire departnent participation fire department.

where possible. t 79 ArcsB 9 5-1 Members of each shift crew should be treined in Members doctasent of the operating shif ts conduct and monthly safety group meetings. The IV.B.6 (e)(3) fire protection.

safety Croup chairman acquaints new members with standard safety practices, conducts re-

' fresher training 1p standard safety practices for group memebers, and reports instances of unsafe practices or conditions. D e safety practices that are discussed include fire prevention measures and fire fighting tech-niques. W e discussions are supplemented with review of relevant published material.

Additionally, manbers of the operating shifts receive annual training in fire prevention and fire fighting techniques. His training includes a review of the facility fire pro-tection systeen and its function. n e train-ing is supplemented by films and review of g relevant published material.

80 APCSB 9.5-1 Training of the plant fire brigade should be See response to item 814 IV.B.6(e)(3) coordinated with the local fire department so that responsibilities and duties are delinasted in advance.

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C Page 1 of E REVIEW OF CUIDELINES CONTAINED IN STANDARD REVIEW PIAN 9.5.1 Action Needed to Comply with Guidettne Reference NRC Guideline or Recommendation Present Plant Status or Practice Iton No.

the orgsnisation and actions concerning site %ual training of the local fire departmen 81 APCSB 9.5-1 Coordination with the plant fire brigade should will be provided to include:

and offsite activities during an emergency IV.B.6(e)(3) be part of the training course end implemented are delir.ested in the emergency procedures, into the training of the local fire department 1) designation of responsibilities s ta f f.

During fire emergencies the Monticello volunteer fire department may be requested and authority to provide assistance, however their actions will be directed by site personnel. 1.oca l 2) tour of the plant with emphasis on fire department personnel have been given fire fighting capsbilities and tours of the plant and have received training potential fire basards in the special hazards and precautions associated with a nuclear power plant site, ' 3) appropriate radiation protection however it has not been on a regularly training scheduled basis. 4) discussion of operational precautions 82 APCSB 9 5-1 local fire depcrtments should be educated in the See response to item 81.

IV.B.6 (e)(31 operstier.nl pracautions wben fighting fins on nuclear power plant sites.

APGB 9.5-1 local fire depar+mnts should be ende aware'of See response to item 81.

83 IV.B.6 (e)( 3l the need for radioactive protection of person-nel and the special hazards associated with a nuclear power plant site.

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REVIEW OF CUIDELINES CONTAINED IN STANDARD REVIEW FtAN 9.5 1 Present Plant Statue or Practice Action Needed to Comply with Guideline Item No. Reference NRC Guideline or Recommendattr's NFPA No. 27, " Private Fire Brigsde," should be NFPA No. 27 and references have been reviewed. The following actions will be taken to assure Sh APCSB 9 5-1 Plant procedures depart frogn recomenended conformance IV.B.6 (e)(k) folleved in organization, training, and fire practice in a number of areas. 1. Fire brigade chiefe and aestetant t

drille. This standard also is applicable for chiefs will be oppointed to provide the inspection and enintenance of fire fighting 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coversge.

equipment. Standards mferenced from this document which should be utilized are 2. A training program will be fornutoted. ,

NETA 1% Drille will be performed on a periodic 3.

NFPA 196 beste.

NFPA 197 NPTA 601 4 A survey will be -wnd,cted to detemine NFPA booklete and pamphlete listed on page equipment adequag.

27-11 of Volume 8, 1971 - 72 are also applicable for, good training refennees. 5. Special fire fighting equipment will be listed in the emergency procedures.

i 8} APCSB 9 5-1 Courses in fire prevention and fi m supp m eelon The Power Production Department safety coordi- "

IV.B.6 (e)(h) which are recognized and/or sponsored by the nator has attended fire prevention and fire fire protection industry should be utilized. euppreselon courses sponsored by the fire ,

protection industry. The services of this individual have been utilleed in conducting training for the platt emergency teams. nie training will continue on en annual baste to update emergency teams with respect to current practice.

Quality Assumnee Program the present directive; on design changes pro-86 APCSB 9 5-1 QA Progrum should be developed amt isplemented - vide for the design of all em>difications to IV . B.7 to assure that the requineente for design, applicable standards which include fire pro-procurement, installation, and testing and tection standards. These directives address administrative controle for the fire protection design, procurement, installation and testing program for safety-related amas are satisfied. of all changes and additions to the original plant design.

j 87 APCSB 9 5-1 The QA Program (related to fire protection) obould The QA program related to fire protection is IV. B.7 be under the enna6ement contml of the QA under the management control of the NSP ,

organization. Operational QA organtastion.

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Page 24 og y REVIEW OF CUIDELINES cfETATNrn IN STANDARD REVIEW PIAN 9.3.1 Item No. Re fe rence NRC Cuideline or iteccammendation Present Plant Status or Practice Action Needed to Comply with Guideline 88 APCSB 9 5-1 he @ Prosma criteria that apply to the fire See response to Item 86. Design Change directives will be revised to IV.B.7 (a) protection program abould include design control include reference to BTP APCss 9.5-1.

and procurement document control. Measures should be establiabed to assure that all design-related guidelines of BTP APC5B 9 5-1 are j included in design and procurement documents and that deviations therefrom are controlled.

89 APCSB 9 5-1 The @ Program criteria that apply to the fire Plant a&sinistrative controle and procedures A review of documents will be performed IV.B.7 (b) prutection program should include instructions, address testing, maintenance, training and to insure tAat fire protection procedures and procedures, and drawings. Inspections, tests, inspections in all safety related areas. controle are adequate.

administrative controle, fire drills, and train-ing which govern the fire protection progma should be prescribed by documented instructions, pmcedures, or dmwin6s ac4 should be accom-pitsbed in accordance with these documents.

90 APCUB 9 5-1 De @ Program criteria that apply to the fire Not1ent procedures and directives insure IV.B.7 (c) protection progrium should include control of that purchase order specificatione are com-purchased material, equipment, and services. plied with when material is received.

Measures should be established to assure that purchased eterial, equipment, and services conform to the procurement documents.

91 APCEB 9 5-1 he @ Progrem criteria that apply to the fire Periodically, representatives from NELP1A, IV.B.7 (d) protection program abould include provision for NSP insurance carriers, and NSP insurence inspection. A prog ma for independent inspec- department representatives inspect the plant, tion of activities affecting fire protection Rose inspections insure that the fire pro-should be established and executed by, or for, tection program is adhered to.

the organization performin6 the activity to verify conformance with documented installation drsvings and test procedures for secomplishing the activities.

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Fage 25 ef $1 RIVIEW OF GUIDELINES CONTAINED IN STANDARD REVIEW PLAN 9. 5.1 Present Plant Status or Practice Action Needed to Comply with Guideline 1 rom No. Reference NRC Guideline or Reconusendation APCSB 9.5-1 The GA Program criteria that apply to the fire Present plant written surveillance procedures 92 ensure adequate testing of the plants fire IV.B.7 (e) protection pmgram should include provision for test and control. A test progrna should be protection provisions, establiebed and implemented to assure that testing is performed and verified by inspection and audit to demonstrate conformnee with design and system readiness requirements. Be teste should be performed in accordance with written test procedures and test results properly evaluated armi acted on.

ne QA Program criteria that apply to the fire Plant surveillance procedures normally con-93 APCSB 9 5-1 IV.B.7 ( f) protection program should include provision for tain acceptance criteria and instructions on identification of items which have entisfactorili what to do if the criteria are not met.

passed mquir*d tests and inspections.

The QA Program criteria trat apply to the fire Purchasing and receiving procedures provide 96 APCSB 9 5-1 for identification of non-conforming material IV.B.7 (g) protection program should include maasures to control items which do not ecnform to and subsequent disposal of such material.

specified requirements to prevent inadvertent use or installation.

APCSB 9. 5-1 The GA Program criteria that apply to the fire Inspections and plant surve111soce testing 95 identify conditions adverse to fire protec-TV. B. 7 ( h ) pmtect:on progma should include measures to assure that conditions adverse to fire protec- tion. Work requests are issued and acted tion, such es failures, malfunctions, deri. upon to correct these deficiencies, ciencies, deviations, defective components, uncontrolled ecebustible anterial, and non-conformances, are promptly identified, reported, and corrected.

9 Page 26 of 57 REV1EW OF GUIDELINES Cf taA m m IN STANDARD REVIEW PLAN 9. 5.1 Present Plant Status or Fractice Action Needed to C aply with Guidettne Item No. Reference NRC Guideline or Recomendation ne GA Proarna criteria that apply to the fin All testing procedures and inspection reports

% APT B 9 5-1 are retained for the required length of time.

IV. B. T ( 1) prvtection program shou.ld include provision for Corrective action reports are retained.

reco nis . Ncords should be prepared and main-tained to furnish evidence that the criteris contained in the program are being net.

he QA Prcgma criteria that apply to the rire Audits are performed by NELPIA NSP insurance 97 APCOB 9 5-1 IY.B.7 (j ) protection prbgram should include pmvis Lon for underwriters, and NSP insurance department a2dits. Audits should be conducted and docu- representatives. These audits cover all e nted to verify coc:pliance with the fire espects of fire protection.

prctection program, including design and procurement doeurents, instructions, procedures, drawings, and inspection and test activities.

The fire detection systems installed at Monti-Fira retection 96 AP_TB 9 5-1 Fira detection systems should as a minimum ecsuply cello comply with the requirements of NFPA with NFPA No. 72D, "Starvierd for the Installa. standard 72D with one exception. We trouble IV . C.1 ( a )

tion , Maintenance, and Use of Preprietary signal from the smoke detector devices is not Proteettre Signaling Systems." connected to an annunciator separste frcus the alarm signal: instead, the two signals share a co mon annuncistor. This conditions does not, however, detract frons the effectiveness of the alare systen since any alam would be treated se a fire alam until the condition is verified locally. Each local smoke de-tector control unit has separate indications for alam or trouble conditions which would be used for detemining the cause of the control ro<m alam.

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RIVIEW OF CUIDE1.INES CONTAINED IN STAEDARD PEVIEW FIAN 9 5.1 Action Needed to Comply with Guidelin NRC Cuideline or Recowenendation Present Plant Status or Practice Item No. Reference All fire detection systems give audible and Control room audible and visual alors and Fire detection systems should give audible and annunciatic, will be provided for the re-

4) APCSB 9 5-1 visual alarm and annunciate in the control circulation M-G set room and the cooling IV.C.1 (b) visual alarm and annunciation in the control roots except for the detection systems for the room. Incal audible alarms should also sound recirculation M-G set room and the cooling towe rs .

at the location of the fire. towers. 1.ocal audible alarms sound near the location of all detectors.

Fire alarins should be distinctive and unique. The local audible alarms initiated by the 100 APCSE 9 5-1 ney should not be capable of being confused fire protection systen are bells which are IV.C.1 (c) easily distinguishable from the sounds of with any other plant working system.

other plant systems. Alarms in the control room are unique by their grouping and loca-tion.

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Page U cf E REVIEW OP (,UIDEl.L<tS CCETAINED IN STANDARD REVIEW PLAN 9,5.1 r

Present Plant Status or Practice Action Needed to Comply with Guideline Reference NRC Guideline or Recoespendation item No.

Fina detection and actuation systems shouli be The fire detection and deluge actuation sys-101 APCB 9 5-1 tems at Monticello are powered from sources IV.C.1 (d) connected to the plant esergency power supply.

connected to the plant emergency AC power supply or from the station batteries.

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• Pmtection Water Supply Tystems The installed underground yar a fire main loop 102 APIB 9 5-1 An undergnau:mi yani fire main loep should be is capable of furnishing an'.icipated water IV.C.2 (a) installed to furnish anticipated fire water requirements to all potential fire locations, requin -ents.

APG B 9 5-1 1.1ned steel or cast iren pipe should be used The installed vard fire main loop is cast 103 IV. C. 2 ( a ) in the yani fire enin loep to redace interr.a1 tron. The yard fire main is periodicstty tube rculation. Means for treating and flushic4 flushed through the installed hydrants.

should be provided.

1 04 APGB 9.5-1 Be ynni fire min loep should use approve <t The yard system is fitted with post indicator visually indiesting sectional control va)<es, valves for isolation of any portion of the IV. C. 2 ( a )

such as Pest Indicator Valves, to isolete loop, branches, or hydrants for maintenance portions of the unin for saintenance or repair or repair without shutting off the entire without shutting off the entire system. system.

ne fin min system piping should be separste n ere is no connection between the fire sys-105 APG B 9 5-1 tem and the sanitary water system. The only IV.C.2 (a ) from service or sanitan water system pipir.g.

connection between the fire main and the service water system is through a Jockey Ptnap This pump uses service water as the source fo

maintaining the fire system pressurized durin1; standby operation. This pump and service water connection are auteenatically isolated upon startup of the fire system ptmaps by mean:t of a check valve. Also, the ptump and service water connection can be isolated by closure of two isolation valves installed in the connection line. This installation and espacity to isolate is seceptable according to Appendix A to Branch Technical Position AK SB 9.5-1. .

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• of SL REVIEW OF GtTIDE1,INES C0tf7AINED DI STANDARD REVIEW FIAN 9.5.1 Action Needed to Consply with Guideline '

Reference NRC Guideline or Recommendation Present Plant Status or Practice Item No.

4 Monticello is a single unit nuclear power 106 AFC3B 9 5-1 A cosanon yard fire main lonp any serve multi-unit nuclear power plant sites, ir cross- plant site and this guideline does not apply.

IV.C.2 (b) l connected between units. Sectional control valves should permit maintaining independence of the individual loop around each unit. For such installations, common water supplies any also be utilized. he water supply should be sited for the largest single expected flow.

i Simultaneous fires in more than one reactor unit need not be considered. Due to separation requirements, s fire involving unre than one t

reactor unit need not be considered except for facilities shared between units.

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APCSB 9 5-1 If pumps are aquired to provide pressure and/or There are three 1007. capacity ptmps; a 1500 flow requirements (for a fire protection water gym electrie, motor-driven vertical centrifugal 107 IV.C.2 (c) fire pump, a 1500 gpm diesel driven vertical supply system), redundant 100% capacity pumps centrifugal fire pump, and an additional back-should be provided. Each pump should have its own independent water supply. The connection up 1500 gym electric motor driven vertical to the yard fire main loop fmm each fire pump centrifugal pump normally assigned as a screer should be videly sepamted, prefembly located wash pump. W e diesel driven pump takes its on opposite side of the plant. Ihch pump should suction from a different intake bay than the electrically driven ptumps. The connections tc have its own driver with independent power supplies and cont ml, At least one pump should the yard fire main loop for the diesel fire be driven by non-electrical means, prefembly ptmap and the electrically driven ptumps are diesel engine. Pumps and drivers should be separated by approxtmately 50 feet. Each ptog located in rooms, separated fmm the remaining has its own driver with independent power pumps and equipment by a minimum three-hour supplies and controls. The diesel fire ptmp fire wall. Alams indicating pump running, and driver are located in structures which era driver availability, or failure to start should separated from the remaining ptmaps and equip-be provided in the control room. Details of the ment by a ministan three-hour fire well. Both fire pump installation should as a miniman fire ptmps have* alarms in the control room conform to NFPA No. 20, " Standard for the ' Lndicating ptump running and loss of power Installation of O=ntrifugal Fire 1%nps." (driver availability). Details of the fire i ptmp installation conform to NFPA No. 20

" Standard for the Installation of Centrifugal Fire Pteps".

f The fire system utiltres one source of water 106 APCSB 9 5-1 Two sepante reliable water supplies should be provided (for the fire protection water (the Mississippi River) for its supply, IV.C.2 (d) There are two paths by which water can be supply system). taken from the river; the normal plant intake and the cooling tower return line to the pleet.

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REVi!N OF CUIDELINES CONTAINED IN STANDARD REVIEV PLAN 9.5.1 Present Plant Status or Practice Action Needed to Comply with Guideline Item ho. Re fe rence NRC Guideline or Recournendation The fire water supply (total capacity and flow the fire water supply is the Mississippi River .

lo) APCSB 9 5-1 IV.C.2 (e ) rate) should be calculated on the basis of largest expected flow rate for a period of two hours, but not lees than 300,000 6allons. This flow rate should be based (conservatively) on 1000 gpm for manual bose streams plus the greater of:

(1) all sprinkler heads opened and flowing in the largest des 16ned fim area; or (2) the largest open bead deluge system (s) oparating.

lakes or fresh water ponds of sufficient No takes or ponds are ut111:ed as the source 110 APCSB 9 5-1 of water for fire protection. There are two IV.C.2 (f) sir.e may qualify as sole source of water for methods of supplying river water for fire fire protection, but requite at least two protection. Refer to item 108.

intakes to the pump supply, When a ccanon water supply is pemitted for The water supply for fire protection and the 111 APCSB 9 5-1 ultimate heat sink is the Mississippi River.

i IV.C.2 ( f) fire protection and the ultimate heat sink, the The additional fire protection veter require-following conditions should also be satisfied: ments do not affect tin capacity of the vetet l

(1) the additional fire protection water supply. Failure of the fire protection sys-requirements are designed into the tem will not degrade the function of the total storage capacity; and ultimate heat sink.

(2) failure of the fire protection system abould not degrade the function of the ultimate heat sink.

112 APCSB 9.$-1 Outside manual hose installation should be Outside manual hose stations are sufficient IV.C.2 (g) sufficient to reach any location with an effec- to reach any location with an effective hose tive hose stream. Ib accomplish this, hydranta stream. The hydrants are installed at ap-should be installed approximately every 250 proximately 220 feet intervals along our feet on the yard main system. yard main system.

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Page M i of f REVIEW OF GUIDELINES CONTAINED IN STANDARD REVIEW FIAN 9.5.1 Action Needed to Comply with Guideline Reference NRC Guideline or Recommendation Present Plant Status or Practice Item No.

The later1L1 to each hydrant on the yard main The laterale from our yard main are controlled 113 APCSB 9 51 by visually indicating valves.

IV.C.2 (g) system should be controlled by a visually indicating or key operated (curb) valve.

APGP 9.5-1 A hose house, equipped with hose and combination The hose houses are built around hydrants nottle and other auxiliary equipment recomended which are spaced at 220' intervals. The equip-lik 1Y.C.2 (g) in NFPA No. 24, "Outside Protection," should be ment furnished with each hose house does not correspond to the list suggested by NFPA 24, provided as needed, but at least every 1000 feet. however, the equipment provided meets NEl. PIA requirements.

115 APCSB 9 5-1 'Ihreads compatible with those used by local fire All threads are compatible with those used by IV.C.2 (g) departments should be pmvided on all hydmnts, the local fire department.

hoee couplings, and standpipe risers.

Water Sprinkler and Ilose Stnndpipe Systeres The automatic sprinkler systems and manual Any decisions made concerning modifications t-hose stations inside the plant do not meet the sprinkler systems, hose stations, or 116 APCSB 9 5-1 Phch automatic sprinkler system and manual hose these requiremente. supply piping will be made following ecample-IV.C. 3 (a) station should have an independent connection tion of the fire hazards analysis, to the plant underground water main. llenders fed from each end arte permitted inside buildings to supply multiple sprinkler and standpipe systems. When provided, such headers are considered an extension of the yer11 main system.

Such headers should be located in seperate valve rooms with three-hour fire rated walls and with interior and exterior access.

lhch sprinkler and standpipe system should be All shutoff vstves for our sprinkler system 117 APTB 9 5-1 are OS&Y gate valves. Also, all of our IV.C. 3 (a) equippad with OC&Y (outside screw and yoke) gate valve, or other approved shut off valve, sprinkler systems have a water gong with the and water flow alarm. exception of ther M-C set room dich has an alarm bell operated by the trip weight in the clapper valve.

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REVIEW OF GU1071.INES CONTAING IN STANDARD pIVIEW PLAN 9.5.1 Action Needed to Couply with Guideline NRC Guldstine or Recouemendation Present Plant Status or Practice ItCa No. Re fe rence Safety related equipernt which does not itself here is no safety related equipment which is 118 APCSB 9 5 1 IV.C. 3 (a ) require sprieller vster fire pmtection, but is subject to unacceptable damage if wetted by subject to unneceptable damnge if wetted by sprinkler water discharge. We equienent sprinkler water discharge, abould be protected listed in response to item 42 is subject only by water shields or baffles. to bose or extinguisher water discharge.

All valves in the fire water systems should be The isolation valves for each sprinkler sys. Electrical supervision of the remaining 119 APCSB 9 5-1 valves in the fire water system is not IV.C.3 (b) electrically eupervised. We electrical super- tesa in the plant (except for the Rectre M-G vision signal should indicate in the control set sprinklers and the tube oil piping practical due to the large ntamber of valves room and other appropriate commnna locations in sprinkler system under the turbine floor) are involved. As an alternative, the present the plant. Hefer to NFTA No. 26, " supervision electrically supervised in the control room. management supervision program of the valves o f ' Valve s. " The Recirc M-G set sprinkler system isolation will be upgraded with the addition of the valves are electrically supervised locally, following:

The tube oil piping sprinkler systes isolatiori 1) Where not presently provided, tasper valve is maintained locked open and the key proof seats will be installed on fire

- --- is controlled by the shift supervisor. The water system valves.

deluge header to the main transformer,1R startup transformer, fit aux 111ary transformer. 2) Every valve in the fire water system and turbine building siding delugee contains will be inspected on a note frequent en isolation valve that is also electrically basis.

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supervised and indicates in the control room.

No other valves in the fire water system are This will provide a reliable, appropriate, I

electrically supervised. and practical alternative method of supervision, n is is consistent with i

Appendiz A to Branch Technical Fosition l

APCSB 9.5-1.

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REVIEW OF CUIDELINES CONTAINED IN STANDARD REVIEW PIAN 9.5.1 Present Plant Statue or Practice Action Needed to Comply with Cuideline Item No. Re fe rence NRC Cuideltoe or Recommendation 120 APCSB 9 5-1 Auttasitie errinkler systems abould as a minimm The original design specificatione required conform to the requirements of appropriate NFPA that systems comply with the requirements of IV.C.3 (c) Standants such as NPTA No.13, "Gtandard for the NFPA No. 13 and NFPA No. 15. The oprinklers Installation of Sprinkler Systems," and NFPA in the recirculation ptung M-C set room were No.15. " Standard for water Sprsy rixed systeme." not involved in the original plant deetsn, however, they also counply with these standa rds.

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Additional hose stations will be installed 121 APCSB 9 5-1 Interior manual boee installatico shotild be able our hose connections are equipped with 75' of in the torus area.

IV.C.3 (d) to reach any location with at least one effective 1%" unlined linen hose. All hoses are in-hose stream. To accomplish this, standpipes with spected for servicability on an annual basis.

hose connectione, equipped with a nutximum of 75 Roses showing signs of deterioration will be feet of 1-1/2 inch voven . jacket-lined fire hose replaced. All nossles are designed for and outtable nostles should be provided in all fighting electrical fires. In some cases the buildings, including containment. on all floors hose statione are opsced at elightly more and should be spaced at not more than 100 feet than 100' intervals, however effective booe i

I intervals. Individual standpipes should be of at strema coverage is available at all locatione least 4-inch diameter for multiple hose connec- se required by NFPA No. 14, with the excep-tions and 2-1/2 inch diameter for single hoes tion of the torus area. In some cases we do connections. 1hese systems should follow the not meet 4" diameter multiple connection and requirements of IUTA No.14, ' standpipe and Rose 2%" diameter eingle connection standpipe Systems," for sizing, spacing, and pipe support requirements. Bowever, the system was requirements. designed to meet National Fire Code require-mente and we believe the standpipe etsing is adequate.

Rose stations are not provided in primary contatteent. Refer to itemas 138 and 139.

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rage % of 1 REVIEW OF GUIDE 1.D'ES CONTAINED IN STANDARD EVIEW F1AN 9.5.1 Action Needed to Comply with Guideline Ites No. Reference NRC Cuideline or Recceanendation Present Plant Status or Practice We meet this requirement with the exception of 122 APWB 9 5-1 Hose stations should be located outside entrances the control room. Refer to Item No. 142.

IV.C. 3 (d) to nonnally unoccupied areas and inside normily occupied areas.

APCSB 9,5-1 Standpipes serving bose stations in areas houstry We do not use pressure reducing devices since

.123 they are not required if the system pressure IV. C. 3 (d ) safety related equipment abould have shut-off valves and pressure reducing devices (if doesn't exceed 100 poi (NFPA #14). There are applicable) outside the area. shut-off valves located at each of the hose s ta tions. All supply headers off the yard ring header have post indication valves loca-ted outside the areas being served.

12ta APCSB 9 5-1 Iwvisions should be mde to supply water at See response to Item 121.

IV.C.3 (d) least to standpipes and bose connections for m nual fire fighting in areas within hose reach of equipment required for safe plant shutdown in the event of a SSE.

The standpipe system serving bose stations AppendLu A to Branch Technical Position 125 APG B 9 5-1 APCSB 9.5-1 indicates that this item is not IV.C.3 (d) in areas within hose reach of equipment required for safe plant shutdown should be analyzed applicable for operating plants, for SSE loading and be provided with supports to assure system pressure integrity. Assoelated piping and valves should at least satisfy MIGI B31.1, " Power Piping." The vster supply for this condition my be obtained by manual operster actuation of valve (s) in a connection to the hose standpipe header from a norwil seismic Category I veter mystem such as the rasential Service Wster System. In this cose, '

the cross connection should be (a) capable of providtrut flow to at least two hose stations (approxistely 150 gpa per hose station).

(b) designed to the same standards as the seismic Categrey I vater system and should not degrude the perforvance of the seismic Category I veter system.

Pa ge 33 of 1 REVIEW OF GUIDELINES CONTAINED IN STANDARD REVIEW PIAN 9.5.1 Action Needed to C m ply with Guideline Reference NRC Guideline or Recommendation Present Plant Statue or Practice

'Itos No.

lit, APG B 9 5-1 'Ibe proper type of bose nozzle to be supplied in We use electrically safe noastes throughout the plant.

IV. C. 3 ( e ) each ana should be based on the fim bazard analysis. The usual combination spray straight stream mny enuse unneceptable mechanical damnge, (for instance deliente electronic equipment in the control room) and be unsuitable. Electri-cally safe nozzles should be provided at locations where electrien1 equipment or cabling is located.

The use of evettable foams to being con-Considerution should be given to the use of Foame are not currently used.

127 APCSB 9 5-1 eldered.

IV.C.3 ( f) any 'of the available fonme for specialized protection application (flasnable liquids).

tinion Duppression Dystems Not applicable. No Halon systems or extingut<

123 AP C B 9 5-1 The use of Balon fire extinguishing agents should ehere are installed.

IV. C. h ne a minimum comply with the requirements of NFPA No.12.A and No. 12B, "finlegenated Fire Extinguishing Agent Systems - Halon 1301 and finion 1211."

APGB 9 5 1 only UL or D4 approved Halon fire extinguishing Not applicable. No Halon systees or estingui.

129 IV . C. k agents abould be used, ehere are instatted.

130 APG B 9 5-1 Preventive maintenance and testing of ihlon fire Not appitcable. No Relon systese or entingui IV. C. h extinguishing systems, including check veighing shere are instatted, of the Balon cylinders, should be done at lenst quarterly. Consideration should be given to:

(n) minimum r* quired Halon concentrstion and soak time.

(b) toxicity of Halon.

(c) toxicity and corrosive charneteristics of thammi deccerposition products of IIslon.

re ge M of 57 FIVIEV 0F CU1DELINES CONTAINED IN STANIARD PEVIEW f1AN 9.5.1 Action Needed to Creply with Guideline Re f e rence NRC Guideline or Recomendation Present Plant Status or Practice Item No.

carbon Picxida Duppression Dystems Not applicable. No CO2 systems are installed.

APGB 9 31 ne use of carbon dioxide extinguishing sytems Systems which may be instetted in the future 131 IN.C.5 should as a minimum creply with the requirements will comply with NFPA 12.

of NFPA No. 12, " Carbon Dioxide Extinsulching Gystems." 1%rticular considerwtion should also be given to:

(a) minimum raquired CO2 concentration arx1 ecek time.

(b) toxicity of CO 2-(c) possibility of secondary themal shock (cooling) damnge.

(d) offsetting requirements for venting during C02 irQection to prevent over-pressurization versus sealing to prevent loss of agent.

(e) design requirmants from cverpressur-1 ration.

(f) possibility and probability of CO2 eystems being out of service due to personnel enfety consideration (CO2 systems are dieamad whenever paople are present in an aren so protected).

Portable extinguishers were originally to- We will evaluate att areas of the plant to Portable Extinguishers determine that the proper type of estinguishe APT,B 9 5-1 Por+ nble extinguishers should be providad in cated in accordance with NFPA No 10.

1 32 is still being utilized in each ares, IV.C.6 accortlance with guidelines of NFPA No.10 and No. 10%, " Portable Fire Extinguishers, Installation" and " Portable Fire Extinguishers, N intenanea and Use." Dry chemical extinguisheri should be installed with due considetstion given to cleanup problems after use and possible adverse effects on equilmant installed in the area.

Eziating fire protection provistens for the A decision concerning instattation of addi-Guidelines for Specifie Plant Aress Primnar and 0*condary Containmant primary and secondary contairusent are dis- tional provisions will be made following cussed in Items 138 and 13?. completion of the fire hasards analysis.

Mrmt Orarstion 133 APGB 9 5-1 Fire protection requirements for the primary and IV.D.1 (a) secondary containment areas should be pmvided on tha bases of spacific identified hnzards.

For example:

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' (n) lubrienting oil or hydrwalic fluid (b) cable trsy arrsngetnents and cable penetts-tions l (c) charcoal filters

Page of RIVIEW OF CtrIDE1. DIES CONTAINED IN STANDARD PEVIEW PIAN 9.S.1 Action Needed to Cceply with Guideline

~1 tem No. Reference NRC Guideline or Reccessendation Present riant Status or Practice Primary containment and secondary containment Primary containment is inerted during normat The fire bazards analysis now in progress 1 34 APCSB 9 5-1 operation. and therefore automatic fire sup- will determine if fire protection systems IV.D.1 (a) (if normally inaccessable) chould be provided with fire protection from automatic fi ed pression capability is not required. installed in the reactor building (secondary contairement) are adequate.

systema. Automatic sprinklers should be installed for those hazards identified as requiring fixed suppassion.

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APaB 9 5-1 operution of the fire p mtection systems should operation of fire protection systems vitt not l 135 IV.D.1 (a) not cocrprumise containent integrity and/or compromise containment integrity. Operation l other safety related systems. Fin pmtection of fire protection equigment near safety I

activities in the containment ar=as should related systems is discussed in item 11.

function in conjunctir a with total containment Control of ventitation and geseous retenses requireents such as ventLiztion, control of . is not degraded by fire protection activities, contaminated liquid, and gaseous release. All liquido entering drains in containment are controlled.

Fire detection systems (installed in containment l Thers are currently no fire alares located A decision concerning installation of such 136 APC B 9 5-1 etares will be made following completion of IV.D.1 (a) should alarm and annunciate in the control room. within the primary contairusent. the fire hasards analysis, These systemn should utilize detection and loca-tion most suitable to the particular type of fire expected from the identified hazard.

A primary contairant genersi area fire detec. See item No. 136.

137 APCSB 9 5-1 IV.D.1 ( a ) tion capability should be provided as backup for specific hazard detection alame. 'Ib accomplish this, suitable smoke detectors should be installed in the air recirculation system ahead of any filters.

.m Page of PEVIEW OF Gt4DELINES CRj]A1 BED IN STANMPD RIVIEW FiAN 9. 5.1 Present P.ent Status or Practice Action Needed to Comply with Guideline Item No. Reference NRC Guideline of Recomunenda tion Auteentic fire suppmenion capability need not Containment is inerted durina normal opera-1 33 APCGB 9 5-1 IV . D.1 ( a ) be provided in the primry containment atmo- tion. Special fire protection requirements speres that are inerted during normal oparstion. during refueling and maintenance operations Howeve r, spacial fire protection mquimmants are considered in our work control processes during rafaeling and maintenance operations (See response to lten f73).

must be satisfied.

Perueltrat and Wirtanance Standpipes with hose a stions and portable lp APCB 9 5-1 m nual fire fig.hting capability should be fire extinguishers are estalled at strategic rt.D.1 (b) permanently ihotalled in containment. Ctand- locations throughout secondary contairunent.

pipes with bose statione, and p2rtabla fire There is no fire fighting equipment ins ta lled extinguishers, should be installed at strategic inside prisie ry conteinment. A hose station locations throughout containment for any is located near the primary containemt ret 11 red manual fin fighting oparations. equipment batch, n ich is normally open dur-ing refueling. Portable fire extinguishers are available for use inside conteirunent during outages. Due to the primary contain-ment environmental conditions and inacces.

sibility for inspectim during normal opera-tion, it is felt that parmanent instahation of hose stations and portable extinguishers is imprudent.

160 AP C B 9 5-1 Adequate self-containad breathing aparatus No self-contained breathing apparatus is Adequate self-contained breathing unite IV.D.1 (b ) should be provided for fire fightin6 ar t dann6e currently located near the containment will be located in the access control area control personnel and located naar the contain- entrance. to the reactor building. Dese units will ment entrances. %*se unite should be indepen. ; not be used for general plant activities.

dent of any breathing apparstus or air supply systems provided for general plant activities.

Control Bom The control room to located in a building A fire hassrds snalysis is betrg performed The control room must be protectad aginst separate from the turbine and reactor to determine the sdequacy of the barriers 161 APCB 9 5-1 buildings. Die affords a high degree of protecting the control room.

TI.D.2 disabling fire damage and should be separated protection, however a specific analysis has from other arans of tha plant by floors, val.ls, and mor having stinteum fire motstance retings not been done.

of three bours.

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l Page 39 of 57 REVIEV 0F GUIDELINES CONTAINED IN STANDARD DEVIEW PIAN 9.5.1 Action Needed to Comply with Guideline NRC Guideline or Recoursendation Present Plant Status or Practice Item No. Reference Phnual fire fighting capability abould ba Two portable fire extinguishere (CO2 ) are 1k2 APCSB 9 5-1 located inside the control room. A hose sta-IV . D. 2 provided in the control room to combat:

tion is located outside the control room (a) fire originating within a cabinet or opproximately 15 feet from the door. This console canplies with Appendix A to Brsuch Technical (b) exposure fires involving combustibles Position APCSB 9.5-1.

in the general room area Bose stations and portable extinguishere should be located in the control room to eliminate the need for operstors to leave the centrol room.

An additional bose piping shut-off valve and This item to not applicable. (See response Ik3 APCSB 9 5-1 to item 142).

IV.D.2 p res eart reducing device should be installed outside the control room.

Nozzles which are compatible with the hasardo See response to Item 126.

Ikk APC3B 9 5-1 IV. D. 2 and equipurnt in tha control room abould be provided for the nennual hose station (s).

The nossleo chosen should satisfy actual fire fighting needs and satisfy electrical safety and miniritze physical damse to electrical equipeent frem bone stream impingement.

A decielon concerning installation of Fire detection in the control room, cabinete, There are no smoke or heat detectors in the 1k5 APCSB 9 5-1 control room. Alerus in other parts of the smoke or heet detectors in the control IV . D.2 and consoles should be provided by smoke and room will be made following completion of beat detectore in each fire area. Alam and plant are discussed in item 99. the fire heterde analyste, annunciation should be provided in the control room. Fire alams in other parts of the plant shosid also be alsmed and annunciated in the conrol room.

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9.EVIEW 07 GUIDC.INES CWTAINED IN STANDARD FIVIEW FIRt 1.5.1 Action Needed to Cteply with Guideline Re fe r ence N1tC Cuideline or Recomunendation Present Plant Status or Practice Item No.

Bresthing sp;erstus for control roem operators There are two self-contained breathing unite 146 APGB 9 5-1 located in the control ro m .

IV . D. 2 should be readily available.

Control room floors, floor-ceiling structuras, See response to Itess 141.

147 APIB 9 5-1 IV . D. 2 a.nd vslls incita11r4 penetrations and doors, should be designad to a minimum three-hour fire retir4 All, penetration seals should be air tight.

h control room ventilation intake is not Modifications to meet detection. alarm ard 148 APIB 9 5 1 3e control room ventilation intake should be provided with smoke detection, isolation requirements will be mode. A IV . D. 2 provided with etsoke detection empnbility to manual override will be included in this nutcestically alam locally and isolate the modification.

control mom ventilation eyetem to protect operstors by preventire smoke from entering the control roce. Mmun11y operated venting of the cont rol room should be available so that oparstors have the option of ventir4 for visibility, lia) APcB 95 1 Cables should not te loested in concealed floor See item 49.

IV . D. 2 and ceiling s;eces in the control room. All cables which enter the conrol room should teminate in the control room. h t is, no cabling should be simply routed throueth the control r9can from one area to another.

Ssfety ralated equignent should be mountad According to Appendix A to Branch Technical 150 AP I B 9 5-1 Position APCSS 9.5-1, this item is not appli-IV . D.2 on pedestals or the control room should have curbs and dmins to direct water avsy frce cable to operating plants. It is noted that such equipewnt. Such drsins should be providad there are no terminal boards or other safety with resne for clostra to maintain integrity of related equipment within 6" of the control the control room in event of other necidents room floor. A hose would have to came mquiring control room isolmtion, through the control room door which would provide a method of drainage.

L-Page 41' of 57 REVIEW OF GUIDELINES CONTAINED IN STANDARD 3(EVIEW PIAN 9. 3.1 i

(

l Present Plant Status or Practice Action Needed to Comply with Guideline

! Item No. Reference NRC Guideline or Recomendation There is no automatic veter system installed We will install a fixed system utill:1ng onbje Upreading Fbom

'lhe primary fire suppression in the cable spread- in the cable spreading roan. either CO2 or Halon. A decision concerning 151 APCGB 9 5-1 instat tation of a water spray system will IV . D. 3 ing room should tw an automatic vnter system suct as closed head sprinklers, open head deluge, or be made following ccepletion of the fire hazards analysis, open directional spray nozzles. IelNe and open sprq systems should have provisions for manual operation at a remote stations however,

' there should be provision to preclude iradverten'.

ope ration. Iocation of sprinkler heads or spray nozzles should consider cable tray sizing armi arrangements to assum adequate water coverage.

(see item No. 155) 152 APCUB 9 5-1 Cables (in the spreading room) should be designed See response to Item 40.

IV .D. 3 to allow wettirg dow i with deluge water without electrical faulting.

Open head deluge and open directional spmy See response to Item 151.

153 APC83 9 5-1 IV. D. 3 systems should be zened so that a single failum i

vill not deprive autoentic fire suppression

' capability to the entire area.

APGB 9 5-1 The automtic water supprension system should See response to items 151 and 155.

1 516 b= backed up. 14anual hoses and portable Dr. D. 3 extinguishing equipsent is acceptable for this pmvided:

(a) at least two remote and separate entrances are provided to the room for access by fire brigade personnel; and l

I (b) aisle separation pmvided tetween tray stacks should be at least three feet wide and eight feet high.

. ~ .

Pa ge 42 ,g N REVIEW OF CUIDELINES CONTAINE2) IF STANDAR.D REVIEW F1AN 9.5.1 Action Needed to Cennpty with Guideline NRC Cuidelice or Recommendation Present Plant Status or Practice Ites No. Reference Alterrately, ges systees (Halon or LV 2) may be nere are two resmote and separate entrances 15$ APT >3 9 5-1 to the cable spreading room. The cable IV.D.3 used for primary fire suppression in the cable spreading room Isyout does not lend itself spreading mom if they are backed up by an to an analysis of eccessibility based on installed water spray system and bose stations "sistes" and " tray stacks." However, the arsi portable extirgliebers imediately outside room layout is open end all cable tray the room. Se access provisions noted in areas are accessible for fire fighting.

(Item 154) should also de satisfied, Two portable extinguishers are located inside the cable spreading room. Two hose ,

stations are located imunediately outside the twem (one by each remmote entrance). hets ,

are portable extinguishers located tammediatel r outside the cable spreading room. All of this equipment can be effectively used in the room.

See response to item 45.

156 APCSB 9 5-1 Electric cable construction in the cable l

IV. D. 3 spreading room should as a minimm tass the IEEB 383 finae test.

here are no drains in the cable spreading Additional draintge will be constdered if a Drains to remove fire fightin6 water should be 157 APGB 9 5-1 room. However drainage through doorveys used water sprinkler systems is installed. (See provided in the cable spreadir4 room with response to Item 151.)

adequate seeling provided vben Ems extinguishins for manual fire fighting with hoses is adequ-IV. D. 3 systems are also installed. ate for that purpose.

t I

There is divisional cable separation. Ibe fire hawards analysis will investigste i

158 APCSB 9 5-1 Bedundant safety emble divisions should be the adequacy of the cable spreading roce separsted by three-hour firs rsted walls. Concrete wells with sealed penetrations

• IV.D.3 surround the cable spreading room. If these walls.

walls are fo.:nd to have a sufficient fire rating on completion to the fire hasards i analysig, separation will acet requirements.

F, APCUB 9 5-1 fbr multiple reector unit sites, cable spreadin Not to appsicable to a single unit site. Refer item 158 for discussion of divisional IV.D.3 rooms should not be shared between reactors. separation.

thch cable apreading room of each unit should have divisional cable separation and be separs-ted from the other and the rest of the plant by a minisrm three-hour rated fire wall (refer to NFPA No. 251, " Fire hets, kilding Construction, and mterials" or A51M E-119, " Fire het of A11 ding (bnetruction end femterials" for

~

fire test resistance rstir4).

- - - - - - - - - - - - - - - - - - _ __ , _ _ _ # ~ ' " ' ' ' '??- p,

FMs vge Fage 43 , of 57 REVIEV 0F CL'1DE1,I3t3 CONTAINED IF STANDARD REVIEV FIAN 9.5.1 MlN Cuideline or Reconomendation Fresent Float tstus or Fractice Action ideeded to Comply with Guideline Iton No. Refereoca D e ventilation system to the cable spreading n ere is preneutly no gas extinguishing sys- This requirassent will be considered when the 160 APCB 9.5-1 tem for the cable spreading room. gas extinguishing system is installed.(See IV.D.3 room should be designed to isolate the area upon actuation of any gae extinnishing response to Itee 151.)

system in the area.

f Smoke senting of the cable spreadirg room The ventilation system for the cable spreadici. Autcastic control of the ventitation system 161 APIB 9 5-1 roca can be sianually operated from a remote vill be coesidered in conbnction with the IV. D. 3 say be desirsble. Sem>ke venting systems should ges extinguish 1cg system installation.(See be controlle3 automatically 7 the fire detee- location for smoke venting.

tion and/or suppression eystem as appr3riate. response to item 151.)

Capability for remote manual control should a390 be- provided.

Cceputer Room The computer rocus is not separated free. other Computer rcoms should be separated from other areas of the plant by berriers having a mini-162 APCDB 9 5-1 IV.D.e areas of the plant by barriers havin6 etinimum num 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire resistance rating. The pro-three-hour fire resistance sv.tirug. cess computer is not safety reisted. De rod worth minimuser computer to not required for safe plant shutdown. Therefore no modifica-tions are considered necesesty.

Autoentic fire detection should be provided in hermocouples are inetslied in all camputer 163 APIB 9 5-1 IL D. . the computer room to alam and annunciate in cabinets and alarm in tue control roces on the -ontrol room and alam locally. high temperature. The high temperature alarms are considered adequate for early fire detection.

I i

1M APCEB 9.5-1 Manual bcee si.atier.s and pertable water and Dere are no home stations or portable ex-TV. D. 4 balon fire extinguisbers abould be provided in tinguishers located in the computer room.

I the eceputer rotu. Dere is a hose station and portable extingut-sher located isWistely outside the cceputer l room. The process computer is not safety-related. We Rod Worth Minimiser computer is not required for safe shutdown of the plant. Considering the above and the semit size of the computer roce, it is felt that the existing fire suppression provisions are appropriate and adequate.

Page M 'of 2 REVIEW Or GUIDELINES CONTAINED IN STANDAPD PIVIEV PIRI 9.5.1 Present Plant Status or Practice Action Needed to Comply with Guideltre

. Ae f e rer.*

• NRC Guideline or Recosamendation i A decision concerning the need and practical.

Swit-War hvus Switchgear is not located in distinct roces.

AMB951 Evitchgear roces simuld be separated fraa the Fire protection for these areas is described ity of providing fire barriers will be made 165 remainder of the plant by mininre th:3e-hour in Itesas 167 and 170. following completion of the fire hasards DI. D. 5 ana lys is.

rated fire barri2rs.

e u

Pese '3'o f 57 FIVIEW OF CUIDELINES CON TAINED IN STANDARD R MIEV PLAN 9.5.1 Action Needcj to Comply with Guideline NRC Guideline or Reccamendation Present Plant Status or Practice Item No. Reference The redundant svitebgear safety divisions are A decision concerning the need and prac tica t -

APTB 9"5-1 Bedundant switchgear safety divisions should not separated by 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barriers. De ity of providing additional fire barriers M'

Iy* p" 2 be separated by three-hour firt rated barriers two divisions are located on separate levels will be ande following completion of the fire of the turbine building. hazards analysis.

Automatic fire detectors should be installed Switchgear is not contained in distinct roms .

167 APGB 9 5 1 The switchgear areas are provided with fire IV. D. 5 in switchgear reoras. They thould alam ani detectors which alam locally and annunciate annunciate in the control r xim an1 alarin in the control room.

locally.

All cables W ich enter the switchgest rooms Bere are no switchgear rooms but ra the r 168 APCB 4 5-1 should teminate there. switchgest areas in the north-west corner of IV. D. 5 the turbine building on elevations 911' and 931' We majority of cables that enter these areas are terminated in the switchgeer. Ca ble runs through the switchgear areas are held to the minimum practical. D e probability of these cables becoming an ignition source is extremely low since their energy sources are fused or monitored by protectelve aWying.

The cables do not account for an appreciable amount of additional fismable material in the lower switchgea r a rea. Destruc tion of these cables by fire will not result in loss of essential power f rom the upper switchgear area. It is felt that the cable routing through the switchgear a reas is satis f actory.

169 APCGB 9 5-1 Switchg*ar rooms should not be used for any ne switchgear in the plant is not contained other purpose. in distinct rocens. The evitchgear areas are IV. D. 5 not used for any other purpose.

l Fire hope stations and portable fire The 4160 V Switchgear is not located in rooms 170 APCSB 9 5-] but in two distinct areas. A fire hose sta-IV. D. 5 extinguisbers should be readily aratlable tion and portable extinguishers are located in switchgest rooms.

in each area.

171 APCSB 9 54 Equi;eent in switchgear rooms should be Equipasent in switchgear areas is not located IV. P. 5 located on padestals or curbs and dmins on pedesta' and no curbs are provided. An abould be provided to direct water away accv ulation of 4" of water would be required fras safety related equi;msent (refer to to a f fect breaker operation. Drainage is FU'PA No. 92M, " Waterproofing arri Draining adequate to preclude the accumulation of this amount of water. _

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y-Page 46' of J REVIEW OF GlflDELINES CONTAINED IN STANIMRD REVIEW PIA'; 9.5.1 Reference NRC Guideline or Recomunendation Present Plant Status or Practice Action Needed to Comply with Cutdeline Item No.

172 APCSB 9 5-1 Benx2te manual actuated ventilation should be Bere is adequate gravity venting of this area IV. D. 5 provided for venting emoke from switchgest for smoke removal (see response to Item 60).

rooms when annual fire suppression effort is naeded.

Twmote Darety Related Panels The 4 KV switchgear area and the standby gas A decision concerning installation of such 173 APCSB 9 5-1 The general area housing remote safety related treatment system area are provided with auto- detectors will be made following cceptetton

IV. D. 6 panels should be provided with autumatic fire instic fire detectors chat alarm tocally and of the fire hasseds analysis.

' detectors that alaris locally and alarit and annunciate in the control roce. Other remote annunciate in the control room. safety related penets do not have automatic fire detectors.

f

( 1 71s APC3B 9 51 combustible materials in tw genersl area or see response to Item 73.

IV.D.6 remote safety related panels should be l

, controlled and limited to those required for l operation.

l Portable extinguishers and manual hose sta. Fire hose stations and portable fire extingut-175 APT >B 9 5-1 IV. D.6 tions should be p mvided in the general area shers provide adequate coverage for all the of remote safety related panels. remote safety related panels.

l

_ Station Pattery Rooms the battery roas barriers do not meet the The fire bazards analysis will determine the 176 APCiB 9 5-1 Battery rooms should be separated frcus each minimum 3-hour fire rating. adequacy of the estating barriers.

IV. D. 7 other and from other areas of the plant by barriers having a mininr.no three-hour fire rating incluelve of all penettstions and openings. Refer to NFPA No. 69, " Standard, on Explosion Prevention Systems."

'I

• Fase oi 1 eDIEV OF GUIDELUtES CCNTAI!tED 118 $TAGR.D PW1EV FtAN 9. 5.I N1tC Cuideline or secosasendatice Present Plant status or Practice Action Iteeded to Ceeply with Guideltre tten No. R e f e rence e 177 A.PGB 9 5-1 Battery moms should be providei with hydrogen Bere are no hydrogen concentration detectore IV. D. 7 eeneentration detectore which should alarm ani located in the lattery roces. It is felt that accunciate in the contml rece ani alara such detectors are not necessary as the venti-locally. ac detector alans set point ebould lation system for this area includes redundant be no greater than 2 v/o hydregen concentratioth exhaust fans supplied with essential power.

(See response to item 178.)

ITS APIB 9 5-1 ventilation systems in battery n=e e.wald t+ The veetitation system for the battery room ,

le capable of preventing hydrogen buildup.  !

1 IV. D. 7 espable of maintainir4 the hyd mgen concen.

tration well' belev the detector alarm set point.

179 APGB 9 5-1 Standpipe and home and portable extinguisbere standpipes, hoses, and portable extinguishers IV.D.7 ebould be pmvided in the battery rooms. are not located teoide the battery rooms.

Item 122 reccessends that home stations abould be located oundle .ntrances to normally unoccupied areas. Battery roosts are not i normally occupied. A fire hose station to located in the hallway eutside the three battery rooms with enough booe to reach all areas of these rooms. Portable dry chest-r41 and CO2 extinguishers are located in the ballway outside these rooms. Considering I the above, and the small stee of the battery .

i rooms, it to felt that the existing fire protection provisions are appropriate and [

adequate.

"Nrbine lubrteetion ard Cbntml 011 Stong. See response to item 17.

180 AP3B 9.3-1 A blema fire wall beving a utn1mm resistanee IV. D.6 rstin6 of three hours abould separate all areas containir4 safety related systems and equipment from the turbine oil systems.

Diesel Genentor Ar*as Se diesel generator fire barriere do not he fire basarde analysis will determine the 181 AP"$P 9 5-1 Diesel generstore abould be separated from each meet the minieman 3-hour fire resistance adequacy of the existing barriere.

IV.19 other and from c*ber anas of the plant by reting.

fire barriere havin6 a minisrJen thne-bour .

fire r*sistance reting. l 132 APC B 9.5-1 Aatematic fire suppreselon each me AFyF, foam, nere are no automatic fire suppression eye. A decision conceming installation of evch a IY. D.9 or oprinAlere atuould be installed to ecubut tems installed in the diesel gecerator rome. system will be made following completion of arty diesel generster mat /or lubriceting oil the fire hasarde anstysts.

- _ _ _ _ _ _ _ _ . _ _ _ _ _ f trast _ . _ _ _ _ _ _ , , _ _ ___, _ _ _ , _ _ _. , _ _ _ _ _ _ _ . _ _ _ ., _ _ _ _ , _ _ _ _ _ __,

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REVIEW OF CITIDELDIES CONTAINED IF STANDARD RIVIEW PIAN 9.5.1 ItGm No. Reference NRC Guideline or Recosamendation Present Plant Stetus or Practice Action Needed to Comply with Guideline Automatic fire detection should be provided There are no automatic fire detection devices A deciolon concerning the installation of 183 APGB 9 5-1 auch devices will be made fo11oving l IV. D.9 in the diesel generator areas to alarm and in the diesel generator area.

completion of the fire hasards analysis.  ;

annunciate in the control room and alam locall,y. ,

[

t 18k APCSB 9 5-1 Drainage for rire righting water should be There ie adequate drainese in the eunersency t IV .D.9 provided in the diesel generator areas. diesel generator rooms to remove espected fire fighting water flow. r 185 APCS 3 9 5-1 .Neans for local manual venting or smoke enould Diesel senerator room ventilation has local IV. D.9 be. provided in the diesel generator areas, manual controle. i

! L 186 APG B 9 5-1 Day tsnke should not be permitted in the The diesel day tanks are located in the diesel A decision concerning modifications associa. i IV.D.9 diesel generator areas unlese: generator area in separate enclosures. The ted with the diesel generator day tank arese doors to the day tank rooms have a three hour will be made following ccmpletion of the (a) the day tank to located in a separate fire rating. The walle are not three hour fire hasarde analyste.

enclosure with mininra fire resistance fire rated. The enclosures are capable of of thne hours, including doors or containing the entire contents of the day penetrations. These enclosures should tanks. The enclosures do not have an instal-be capable of containing the c'1 tire led ventilation system and there is no auto-contents of the day tanks. The matic fire suppreeston systeem installed for enclosure should be ventilated to protection. Rose statione and portable avoid accuralation or oil fumes. extinguishere are located near these areas.

(b) the enclosure should be protected by automatic fire suppression systems i

auch as AFFF or sprinklere.

Diceel Fuel _011 Storage Areas There are 3 diesel oil fuel tanks greater A decision concernin6 modificatione sesocta-ted with the diesel generator day tank 187 APCSB 9 5-1 Diesel oil ruel tanks greater than 1100 gallone than 11QO gallon capacity. A storage tank of 60,000 gallon capacity is buried. Each areas will be made fo11owing completion of IV.D.10 capacity should not be located inside buildings the fire hazards analysis.

containing earety re W.ed equipment. 1 hey diesel generator day tank has a 1500 gallon ebould be at least 50 feet distant from any capacity and to located in separate enclosure l buildin6 containing earety related equipment. - which are within 50 feet of the diesel genera-or if located within 50 reet, they should be tors. (see response to item 186.) l housed in a sepa mte building with construction (

baving minimum fire resistance rating of three hours. kried tanks are considered to meet the three-hour requirement (refer to NFPA Ik). 30).

e- e * -t- e*'+ qui 9 *ames --'ur e-r--' m- 1w-ei-+m-uiu--y--e >  % m- 9e wm e- eamw w-s equ v er ere -r'-we=* es-ex--t~ - =ummnur 1-vg --e ---w.e e r- en  %. -- w s- . W -----r-- p. -i --1m---+ -, *-m--e- --a-

Pese N

• of REVIEW OF CUIDELINES cmTUMm IN STANDARD REVIEW FIAN 9.5.1 Present Plant Status or Practice Action Needed to Comply with Guideline Itom No. Reference NRC Cuideline or Recommendstion Wen loested in a separate building, diesel See response to Item 186. l 188 APCSB 9 5-1  !

IV.D.10 fuel oil storage tanks should be protected by an automatic fire suppression system such as AFFF or sprinklers.  !

T' Diesel fuel oil storage tanks should not be None of the diesel fuel oil storage tanks are 189 APGB 9 5-1 IV.D.10 located directly atore or below safety related located directly above or below safety-related systems or equipment regarsiless of the fire systems or equipunent.

rating of separating floors or ceilings.

Safety klated Pws. See response to Item 17.

. 190 APG3 9 5-1 Pump bouses and mcas housing safety related 17.D.ll pumps should be sept rated from other areas of the plant by fire barriers having at least a three-hour rating.

There is no automatic sprinkler protection A decistou concerning installation of such 191 APCSB 9 5-1 lboms housing safety related pumps should be protected by autonatic sprinkler protection provided for rooms housing safety related protection will be made foslowing completion IV.D.11 of the fire hasards analysis.

unless a fire hazards analysis can demonstrate pumps.

that a fire will not endanger other safety related equiresent required for safe plant shutdown.

s APCSB 9 5-1 Ihrly warning fire detection should be in. Most areas housing safety-related pumps do not A decistou concerning installation of sah 192 devices will be made following completion IV.D.ll stalled in each area housing safety related have fire detection devices.

of the fire hasards analysis.

pumps with alars and annuciation locally arid in the control room.

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Page M ,of 1 REVIEW OF CUIDELINES CONTADED IN STANDARD REVIEW PIAN 9.5.1 I

Action Needed to Comply with Cutdeline NRC Cuideline or Recosamendation Present Plant Status or Practice Item No. Reference APGB 9 5-1 Incal hose stations and portable extinguist.m 1.ocal hose stations and portable extinguishers should be provided in each area bousin6 safety are previded for each area housing safety 193 IV. D.11 related ptsaps.

related pumps.

Equipment pedestals or curbs and drains should There is no safety-related equipment in

.194 APGB 9 5-1 safety-celated pump areas that would be IV.D.11 be provided to remove and direct water away from safety related equipment in safety damaged or made inoperable by the accumula- ,

related pump areas.

tion of fire fighting water. All safety-rotated pump areas are provided with drains that will remove the expected fire fighting water flow. The safety related ptemps are either on pedestals or are the vertical type r

which an arctanulation of water would not harm i * ..

' 195 APGB 9 51 Provisions should be made for manual control

• The ventilation systema serving safety-rela-of the ventilation system in safety related ted ptmap areas have manual controls.

. IV. D.ll Pump areas to facilitate smoke renoval if required for manual fire fightin6 operation. .

There are .our hand portable extinguishers New Puel Arwe located on the refueling floor.

196 APCSB 9.5-1 Band portable extinguishers should be toeeted IV.D.12 within the new fuel area.

Iocal hose stations should be located outside hre are two hose stations located within 197 APGB 9 5-1 40 feet of the new fuel vault.

IV.D.12 but within bose reach of the new fuel area.

A decision concerning installation of sudi APGB 9 51 Automatic fire detection should alam and

• There are r) fire detection devices in the devices will be made following completion 108 oew fuel area.

IV.D.12 annunciate in the control room ani alam of the fire hasards scalysis, locally on indication of fire in the new fuel area.

N i

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_ ___

• _ - - _ _ - - - _ * - _ * * - - * - _ _ _

• _ _ _ _ *_>-.'----.r __ -- *+=__w- + _-'_*+-w*__r_w.m- h _-s__- * *p__ h-__------ - -- . _ _ _ . _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ - - -

Fase 51, og y REVIEW OF CUIDELINES CONTAINED IN STANDAPD DEVIEW PIAN 9.$.1 Present Plant Status or Practice Action Needed to Comaply with Guideline Iton No. Re f e rence NRC Guideline or Reco usendation see response to Item 73.

Irf) APGB 9 5-1 combustibles should be limited to a minimu:n in IV. D.12 the new fuel an a.

he new fuel area should be provided with a Adequate drainage is provided for the new 200 APCSB 9 5-1 fuel area, IV. D.12 drainage system to preclude accumulation of water.

Storage configurstion of new fuel should always Available fire fighting equipment in new 201 APGB 9 5-1 fuel storage eress will not produce water IV.D.12 be maintained to preclude criticality for any water density that might occur during fire densities in range to produce criticality.

Maxianan reactivity occurs at water densities water application. in range of 0.1 to 0.2 g/cc. Fog nestles produce densities less than 0.01 g/cc.

W+nt Fhel Pool Aran De spent fuel pool is within reach of three Protection for the span.t fuel pool area should different base stations. A dry chemical 202 AP T B 9 5-1 extinguisher is located within 20' of the IV.D.13 be provided by local bose stations and pertable extinguisbers. spent fuel pool. Three other extinguishers are located on the refueling floor.

Automatic fire detection should be provided in There are no fire detection devices located A decision concerning installation of such 203 AP 3 8 9 5-1 devices will be inade followies completion IV. D.13 the spent fuel pool area to alarn and annun- in the spent fuel pool area, l

ciate in the control room and to alarin locally. of the fire hasards analysis.

I Badweste !bilding The radveste building is separated from the A decision concerning installation of fire he radwaste building should be seprated frcus reactor building by walls and doors beving a dampers will be made following completion of 2Ola APCSB 9 5-1 the fire hasards analysis.

IV. D.lls other areas of the plant by fire barriers haviry 3. hour fire rating. However, the ventilation at least three-hour ratings, ducts penetrating this barrier are not pro-vided with fire dampers. There is no equip-ment located in the redveste building that is required for safe plant shutdown.

m

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Page '52 ,,g g t

REVIEW OP CITIDELINES CONT 41NED IN $TANDARD REVIEW PIAN 9.5.1 Present Plant Status or Practice Action Needed to Comply with Guideline Item No. Re fe rence NRC Cuideline or Recomunendation Automatic sprinklers should be used in all here are no autcastic sprinklers in the rad. A decision concerning the installation of 205 APCB 9 5-1 such systems d 11 be made following the IV.D.14 areas of the radvaste building vbem vaste building.

ecompletion of the fire hasards analysis.

combustible materials are located.

206 APGB 9 5-1 Automatic flee detection should be provided Automatic fire detection devices do not exist A decision concerning installation of such devices will be made following campletion of IV.D.lb in the radvaste building to annunciate and in the radvaste building.

alans in the control room and alarin locally. the fire hasards analysis.

APGB 9 5-1 -During a fire in the radvaste building, the ne radvaste building ventilation systems 207 are capable of being isolated. Isolation is IV.D.lb ' ventilation system should be capable of being isolated. accomplished by shutdown of the supply and exhaust fans. The fans can be shutdovu from the redweste control room or from their respective breakers located in the reactor building.

i'

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Water fmm fire fighting in the radvaste All drains in the radvaste building are part 2C6 APGB 9 51 of the open redveste system, IV.D.lb building should drain to the 11guld rad.

vaste building susqps.

Dreentaminstion Areas The decontamination area is not separated frtu APCSB 9 5-1 The decontamination areas should be separated other areas of the plant by fire barriers 209 IV.D.15 from other areas of the plant by fire barriere having 3-hour ratings. It is felt that such having at least three bour ratings. barriers are not needed for the reasons stated in the response to Iten 210.

Decontamination areas should be protected by The decoutsumination area is not protected by 210 APCSB 9 5-1 automatic sprinklers. .

automatic sprinklers. It is felt that auto-IV. D.15 matic sprinklers are not needed because there are few combustibles stored it this area.

There are two hose stations and two portable extinguishers located near this area. There is no safety related equipment located nearby, 211 APCSB 9 5-3 Se ventilation systems serving the decontem- The decontamination area is located in an IV.D.15 instion areas should be capable of being open area of the reactor building. The re-isolated.

actor ventilation system is capable of being isolated.

1----___-_ ____ __f . _ _ _ _ _ _ , _ _ _ _ _ _ _ _ , _ _

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. s rege 'S3 ,of 1 REVIEW OF CUIDELINES CONTAIF'D IN STANDARD REVIEW PIM 9.5.1 Itos No. Re fe rence NRC Guideline or Recourssodation Present P'ent Status or Practice Action Needed to Ccumply with Guideline 212 APCCB 9 5-1 Iocal hose stations and hand portable extin- See response to Item No. 210.

IV. D.15 guishere should be provided as a backup to the spricAler system in the decontamination arves.

Safety Related Vater 'I%nks Eere are two hose static,s in the immediate We will Provide a portable extinguisher for 213 APCGB 9 5-1 Storage tanks which supply water for safe vicinity of the condensets storage tanks. esch of these hose stations.

IV. D.16 shutdown should be protected from the effects of fire. Iotal hose stations and portable extinguisbers should be provided. Portable extinguishers should be located is nearby hose '

houses.

214 APCSB 9 5-1 Cbebustible materials should not be stored next Tt4ere are no corabustible materials stored IV. D.16 to outdoor safety related water tarAs. A within 50' of the outdoor safety reisted separstion of 50 feet between outdoor tanks tanks (condensate storage tanks).

and combustible s terials should be provided.

Neords Sto m Arams OJr existing records storage areas are not A records storage area ohich meets the guide-215 APG B 9 5-1 secords storage areas should be pmtected with protected with auteenstic sprinkler systems. lines of Regulatory Guide 1.88 will be IV. D.17 automatic reaction sprinkler systems. constructed.

216 APCB 9 5-1 Dirly varning fire detectors should be prvvided There are no early warning fire detectors A records storage area shich aseets the guide-II.D.17 in records storsge areas to alarm and annun- provided in records storage eress, lines of Regulatory Guide 1.88 will be ciste in the control room and to alam constructed.

locally.

217 APCSB 9 5-1 local hose stations and portable extinguishers Fire hose stations ard port ele " ntngs,'shers IV.D.17 should serve as backup in records storage areas. are provided for re ords stuste areas, g Berer to NFPA No. 232AM, " Manual for Fire I Protection for Archives ard Record Centers, "

• l Pnulatory Guide 1.88, and Alt 3I $5 2 9.

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l REVIEW OF CITIDELINES q0NTAINED IN STANDARD REVIEW F1M 9.5.1

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r NRC Guideline or Reconnendation Present Plant Status or Practice Action Needed to Comply with Guideline item No. Re f e rence

! Cooling 'Itners The cooling towers are of combustible con-l 218 APGB 9.$-1 cooling towers should be of non-combustible struction, but are located so that a fire IV.D.17 construction or so located that a fin will would not adversely affect any safety related

(, not adversely affect any safety ralated systems or equi pent. The cooling tower systems er equipment. Cboling towers should basins are not used for the ultimate heat sinn.

I be of non-combustible construction when the The towers may be used as a backup water sup-basins are used for the ultimate heat sink ply for the fire protection system. Fire pro-or for the fin protection water supply. taction is provided for the towers by auto-matic sprinkler systems and hose stations i strategically located. Since no single fire I in conjunction with a single impairment of tbs fire protection system would disable the fire protection water supply, the existing design is considered to be adequate.

Niseellaneous Arans All miscellaneous areas such as shops, were.

219 APCSB 9 5-1 Miscellaneous anas such as shops, warehouses, houses, and the auxiliary boiler room are IV.D.18 and auxiliary boiler rooms should be so loca- either located in separate structures, attach-ted that a fire or effects of a fire, includin8 ed to the turbine building or in separate smoke, will not adversely affect any safety structures remotely located fra the reactor related systents or equipment. and turbine buildings. All of these areas ari located so that a fire or effects of a fire, including smoke, will not adversely affect an:

safety related systems or equipent.

220 APCSB 9 5-1 Fuel oil tanks for auxiliary boilers should A dike is provided below the heating boiler IV.D.18 be buried or provided with dikes to contain the day tank tis t has the capacity to contain the i entire tank contents. entire contents of the tank.

No fixed piping systems for cutting and weld- In addition to current measures, a portable Sp?eial Protection Guidelines extinguisher will be mounted on each Welding nrvi ';uttina, Acetylene-Oxygen Fuel ing operations utilizing oxygen and acetylene Storage locations for Acetylene-Oxygen fuel are installed in the plant. There is a perm- welding ca rt.

l 221 APCSB 9.$-1 IV.E.1 systema should be chosen to permit fire nnent welding station in the hot machine shop 4

protection by automatic sprinkler systems. consisting of two bottles and a manifold. A hose station and portable fire extinguisher are loc.ated within the shop. There are four portable carts which are moved to work areas se necessary. Bose stations and portable ex-tinguishers are located throughout the plant. ,

l'o general stoarge area is maintained within the plant. Spare bottles are_ stored in a warehouse which is protected by automatic sprinklers.

222 APCSB 9 5-1 Local bone stations and portable equipment See responee to item 221.

IV . E.1 should be provided as backup in areas wherg

. Acetylene-Oxygen fuel systems are located.

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' Pa ge 55* of _57 i PEVIEW OF GUIDE 1.INES CONTAINED IN STANDARD PIVIEW PLAN 9.5.1 It em No. Reference NRC Guideline or Recommendation Present Plant Status or Practice Action Needed to Comply with Guideline The requirnments of NFPA 51 and SIB should NFPA 51 223 APCSB 9.5-1 There are no f Lxed installations involving IV. E.1 be satisfied with respect to acetylene-oxygen '

fuel gas systems, manifolds, piping systems, acetylene gen-erators or bulk storage. The requirements associated with connections, regulators, and cyclinder handling and storage are redundant to OSHA reguistions with ditch we comply.

NFPA 51B Our welder apprenticeship and supplemental Control of votk areas for cutting and training satisfies many of the requirements welding is discussed in item 73. The of NFPA 51B. The remaining training control processes will be in conformance requirements will be satisfied by additional with the requirnments of NFPA-518.

seminare.

A permit system should be required to utilise The only Acetylene-Oxygen fuel systems used A permit system for their use in the main 224 APCSB 9.5-1 plant structure is being established.

IV.E.1 Acetylene-Oxygen fuel systema, in the plant are cutting / welding torches.

225 APCSB 9.5-1 Storate Areas for Dry Ion Exchange Resins Dry ion exchange resins are not stored near IV.E.2 The storage of dry ion exchange resins should essential safety related systems l be kept away from essential safety related systems.

Our resin storage areas are not protected A decision concerning installation of such 226 APCSB 9.5-1 Dry unused resins should be protected by protection will be made following complettos .

IV.E.2 automatic wet pipe sprinkler installations. by automatic sprinkler systems, of the fire hazards snelysis.

Detection by smoke and heat detectors should There are no fire detectors provided in the A decision concerning installation of such 227 APCSB 9.5-1 detectors will be made following completion IV.E.2 be provided in dry ion exchange resin storage dry ion exchange resin storage areas.

, of the fire hazards analysis.

i areas. They should clana and annunciate in the control room and alare locally, 228 APCSB 9.5-1 Local hose stations and portable extinguishers All areas where resins are stored have hase i

IV.E.2 should previde backup protection for dry ton stations and portable fire extinguishers.

exchange resin storage areas.

A deetsien concerning the need for curbs or 229 APCSB 9.5-1 Storage areas for dry resin should have curbs There are drains located in the areas of additional drains will be made followtog IV.E.2 and drains (refer to NFTA No. 92N, "Weter- dry resin storage.

completion of the fire basards analysis.

proofing and Draining of Floors"),

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Page b of 1 PEVIEW OP GUIDELINES CONTAINED TN STANDARD REVIEW PLAN 9.3.1 Action Needed to Comply with Guideline Re fe rence NRC Guideline or Recomendation Present Plant Status nr Practice Item No.

Hazardous chemicata are stored and protected 230 APCSB 9.5-1 Haterdous Chemicals in accordance with the reconsnendations of 1Y. E. 3 Hasardous chemicale should be stored and pro-NFPA No. 49.

tected in accordance with the recoennendations of NTPA No. 49, " Hazardous Chemicals Data".

Chemical storage areas should be vett ventiln- ne chemical storage area for all opened 231 APCSB 9.5-1 and unopened plant laboratory chmicals is IV.E.3 ted and protected against fleoding conditions the hot lab. De hot lab is a cool, dry, since some chemicals may react with water to well ventilated, fully-enclosed room produce ignition, completely surrounded by cement block. ne rocsa has an accese door under lock and key.

The chemicals are stored on fire resistant shelves. Each chemical group is labeled and is separated from other groups. No chemicals are stored on the floor. A floor drain is provided to prevent flooding. Chemicals are opened, handled, mixed, and transferred only in the hot lab.

Materials Containing Radioactivity Spent ton enchange resins are stored in 232 APCSB 9.5-1 slurry form in steel tanks. Af ter decay, IV.E.4 Materials which collect and contain radio- the spent ion exchange resins are partially activity such as spent ion exchange resins, dewatered, placed in steel containers and charcoal filters, and HEPA filters should be shipped off site. Contaminated HEPA filters stored in closed metal tanks or containers which are placed in steel containers and shipped are located in areas free from ignition sources or combustibles. W ese materials should be off site. Used charcoal filters are either protected from esposure to fires in adjacent placed in steel containers and shipped of f areas as well, site, or the charcoal is removed from the filters and disposed of as required by their level of contamination. We spent ton ex-change resin tanks and sludge processing system are located in the turbine building, reactor building and radweste building in areas maintained f ree from ignition sources or combustibles.

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REVIEW OF GtTIDE1,INES CONTAINED IN STANDARD RIVIEW Pt.AN 9.5.1 Present Plant Status or Practice Action Needed to Comply with Guideline Item No. Re fe rence NRC Guideline or HecJamendation Materials which collect and contain radio- Provisions have been made for cooling the 233 APCSB 9.5-1 activity should have consideration given to charcoal and HEPA filters that are part of IV.E.4 requirements for removal of isotopic decay heat the standby gas treatment system, and could from entrained radioactive material. arcumulate considerable fission products during a design basis accident. No other materials accumulate sufficient quantities of fission products such that cooling is required.

2 34 RG 1.78 If chemical agents are used in fire suppression. The capability exists to isolate the control the habitability of the control room should be room ventilation from the surrounding

• evaluated using the guidelines contained in environment thereby protecting it from Regulatory Guide 1.78. June, 1974. " Assumptions hasardous releases outside the room. Carbon for Evaluating the Habitability of a Nuclear dioxide extinguishers are installed for fire Power Plant Control Room During a Postulated protection inside the control room and use Hazardous Chemical Release". of these would generate a volume of carbon dioxide that would remain below the toxicity 10mit given in Table C-1 of Regulatory Guide 1.78. If additional carbon dioxide was used and released into the room, the t9xicity 10mit could be exceeded and use af the available breathing apparatus may be re-quired.

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! 235 RC 1.101 The plant emergency plan should include fire see response to Item 75.

protection emergency planning as outlined in

Regulatory Guide 1.101, November,1975, "Amergency Planning for Nuclear Power /lents".

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