ML17354A202

Revision 19 to Updated Safety Analysis Report, Appendix E, Fire Protection Evaluation Report (Redacted)

ML17354A202
Person / Time
Site:	Clinton
Issue date:	12/20/2017
From:	Jennivine Rankin Plant Licensing Branch III
To:	Exelon Generation Co
Rankin J, NRR/DORL/LPLIIII, 415-1530
References
Download: ML17354A202 (310)

Text

APPENDIX E E4.1-1 REV. 19, OCTOBER 2017 4.0 COMPLIANCE WITH BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS A. OVERALL REQUIREMENTS OF NUCLEAR PLANT FIRE PROTECTION PROGRAM APPLICANT'S POSITION 1. Personnel Responsibility for the overall fire protection program should be assigned to a designated person in the upper level of management. This person should retain

ultimate responsibility even though formulation and assurance of program implementation is delegated. Such delegation of authority should be to staff personnel prepared by training and experience in fire protection and nuclear plant safety to provide a balanced approach in directing the fire protection programs for nuclear power plants. The qualification requirements for the fire protection engineer 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 program, and assist in the fire-fighting training for the operating plant should be stated.

Subsequently, the FSAR should discuss the training and the updating provisions such as fire drills provided for maintaining the competence of the station fire-fighting and operating crew, including personnel responsible for maintaining and inspecting the fire protection equipment. 1. Comply: A comprehensive fire protection program has been developed to train, organize, and guide personnel as an effective fire protection team.

Responsibilities, organization, and personnel qualifications have been

adequately provided for and document-ed in plant training and administrative procedures, and records. The fire protection system design is a coordinated effort between the Applicant and his consultants.

Comprehensive documentation of the system and plant design and coordina-tion are maintained and are retrievable for evaluation. The USAR discusses the training and provisions for maintaining the competence of the station fire-fighting and operating crew, including personnel responsible for maintaining and inspecting the fire protection

equipment. The fire protection staff should be responsible for: Comply: a. Coordination of building layout and systems design with fire area requirements, including consideration of potential hazards associated with postulated design basis fires, The building layout was coordinated between the applicant's engineering staff and his consultants with identifica-tion and consideration of fire hazards dictating portions of the design. b. Design and maintenance of fire detection, suppression, and extinguishing systems, A fire protection staff was established and its responsibilities include A.1 b, c, and d. c. Fire prevention activities,

APPENDIX E E4.1-2 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION d. Training and manual fire-fighting activities of plant personnel and the fire brigade.

(NOTE: NFPA 6 - Recommendations for Organization of Industrial Fire Loss Prevention contains useful guidance for organization and operation of the entire fire loss prevention program.)

2. Design Bases The overall fire protection program should be based upon evaluation of potential fire hazards throughout the plant and the effect of postulated design basis fires relative to maintaining ability to perform safety shutdown functions and minimize radioactive releases to the environment. 2. Comply: The overall fire protection program is based upon a fire hazards analysis, as documented in the Fire Protection Evaluation Report (FPER); the ability to withstand a design-basis fire and shut down the plant safely, as documented in the Safe Shutdown Analysis (SSA);

and the minimization of the release of radioactive material to the environment, as documented in the FPER. The FPER identifies and quantifies combustibles throughout the plant and provides details related to fire barriers, as well as fire detection and suppression.

The SSA documents the capability to safely shut down the plant using at least one safe shutdown method in the event of a design-basis fire in any single fire area of the plant. The FPER and SSA form the basis for the design of the fire protection systems. 3. Backup Total reliance should not be placed on a single automatic fire suppression system.

Appropriate backup fire suppression capability should be provided. 3. Comply with intent: All areas protected by automatic suppression systems are also protected by accessible hose stations with sufficient hose lengths and portable fire extinguishers as a backup means of fire suppression, with the exception of the partial suppression system in Fire Zone A-3f (see Figures FP-5a and b).

The partial fire suppression system in Fire Zone A-3f is not required for safe shutdown, but is provided because portions of this zone have poor APPENDIX E E4.1-3 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION accessibility for manual fire fighting. 4. Single Failure Criterion A single failure in the fire suppression system should not impair both the primary and backup fire suppression capability. For example, redundant fire water pumps with independent power supplies and controls should be provided.Postulated fires or fire protection system failures need not be considered concurrent with other plant accidents or the most severe natural

phenomena. 4. Comply: A single line break will not impair the primary and secondary suppression

capability in any fire zone in the RCA.

However, a manual fire fighting capability will be provided by hose stations in adjacent areas using additional hose length stored near the station (50 feet maximum additional length).

BTP APCSB 9.5-1 Section IV.A, Overall Requirements of Nuclear Plant Fire Protection Program, Item 4 describes the single failure requirement and states: "The fire protection system should, however, retain their original design capability for (1) natural phenomena of less severity and greater frequency (approximately once in 10 years)." At Clinton, there is no 10-year flood level stated in the USAR. However, the 100-year flood level at CPS is 697.0 ft (USAR 2.4.1.1.i.2). This is two feet below the fire pumps elevation of 699 ft (operating floor of the circulating water screen

house, USAR 2.4.1.1.h.3). Use of the 100-year flood is conservative, since it is more severe than the requirement in the BTP to consider natural phenomena with frequency of approximately once in 10

years. The effects of lightning strikes should be included in the overall plant fire protection program. Lightning protection is provided for the station buildings and the HVAC stack. The lightning protection system is bonded to the station ground mat to provide an adequate low impedance path to lightning surges to ensure that the potential rise during lightning strikes is limited to reasonable values that equipment and personnel can safely withstand. 5. Fire Suppression Systems Failure or inadvertent operation of the fire suppression system should not incapacitate safety-related systems or components. Fire suppression systems 5. Comply with intent: A detailed study of the fire protection system with respect to the guidelines of APCSB BTP 3-1 has been performed and compliance established.

APPENDIX E E4.1-4 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION that are pressurized during normal plant operation should meet the guidelines specified in APCSB Branch Technical Position 3-1, "Protection Against Postulated Piping Failures in Fluid Systems Outside Containment." Safe shutdown equipment will be protected from the effects of failure or inadvertent operation of the fire protec-tion system. Such failure or inadvertent operation would not compromise safe shutdown capability, as demonstrated in the Fire Suppression Effects Analysis. 6. Fuel Storage Areas The fire protection program (plans, personnel and equipment) for buildings storing new reactor fuel and for adjacent fire zones which could affect the fuel storage zones should be fully operational before fuel is received at the site. 6. Comply: Fire protection is provided by several fire hose stations and portable fire extinguishers in the vicinity of each storage and handling area. Partial automatic detection is installed in the fuel building. Detection is installed in those zones containing new fuel storage. Schedule for implementation of modifications, if any, will be established on a case-by-case basis. Station administrative procedures specify actions to be taken for control of combustibles, control of ignition sources, control action to be taken in the event of a fire, and fire protection impairment reporting. 7. Fuel Loading The fire protection program for an entire reactor unit should be fully operational prior to initial fuel loading in that reactor unit. Schedule for implementation of modifi-cations, if any, will be established on a case-by-case basis. 7. Comply: The fire protection program as approved by the NRC for the entire reactor unit will be implemented and fully operational prior to fuel load. 8. Multiple-Reactor Sites On multiple-reactor sites where there are operating reactors and construction of remaining units is being completed, the fire protection program should provide continuing evaluation and include additional fire barriers, fire protection capability, and administrative controls necessary to protect the operating units from construction fire hazards. The superintendent of the operating plant should have the lead responsibility for site fire protection.

8. Not applicable. 9. Simultaneous Fires 9. Not applicable.

APPENDIX E E4.1-5 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION Simultaneous fires in more than one reactor need not be postulated, where separation requirements are met. A fire involving more than one reactor unit need not be postulated except for facilities shared between units. B. ADMINISTRATIVE PROCEDURES, CONTROLS, AND FIRE BRIGADE

1. Administrative procedures consistent with the need for maintaining the performance of the fire protection system and personnel in nuclear power plants should be provided. Guidance is contained in the following publications: NFPA 4 - Organization for Fire Services NFPA 4A - Organization for Fire Department NFPA 6 - Industrial Fire Loss Prevention

NFPA 7 - Management of Fire Emergencies NFPA 8 - Management Responsibility for Effects of Fire on Operations 1. Comply with intent: Procedures are in place for maintaining the performance of the fire protection systems, and competence of plant personnel. 2. Effective administrative measures should be implemented to prohibit bulk storage of combustible materials inside or adjacent to safety-related buildings or systems during operation or maintenance periods.

Regulatory Guide 1.39 "Housekeeping Requirements for Water-Cooled Nuclear Power Plants," provides guidance on housekeeping, including the disposal of combustible materials. 2. Comply:

Effective administrative procedures have been developed to control bulk storage of combustible materials inside or adjacent to safety-related buildings or systems. Housekeeping procedures have been issued using Regulatory Guide 1.39 as a guideline. 3. Normal and abnormal conditions or other anticipated operations such as modifica-tions (e.g., breaking fire stops, impairment of fire detection and suppression systems) and refueling activities should be reviewed by appropriate levels of management and appropriate special actions and procedures such as fire watches or temporary fire barriers implemented to assure adequate fire protection and reactor safety. In particular: 3. Comply: Normal and abnormal conditions and other anticipated operations which would impair any fire detection or suppression system will be reviewed in accordance with written procedures

and approved by the appropriate level

of management.

APPENDIX E E4.1-6 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION a. Work involving ignition sources such as welding and flame cutting should be done under closely controlled conditions. Procedures governing

such work should be reviewed and

approved by persons trained and experienced in fire protection.

Persons performing and directly assisting in such work should be trained and equipped to prevent and combat fires. If this is not possible, a person qualified in fire protection should directly monitor the work and function as a fire watch. a. All work, such as welding and flame cutting, is accomplished under controlled conditions, using approved procedures. A trained fire watch will be established.

Procedures are reviewed and approved by qualified personnel. b. Leak testing, and similar procedures such as air flow determination, should use one of the commercially available aerosol techniques. Open flames or combustion generated smoke should

not be permitted. b. Testing will be accomplished under controlled conditions using approved procedures. Leak testing will not be done with open flame or combustion-generated smoke. c. Use of combustible material, e.g., HEPA and charcoal filters, dry ion exchange resins, or other combustible supplies, in safety-related areas should be controlled.

Use of wood inside buildings containing safety-related systems or equipment should be permitted only when suitable noncombustible substitutes are not available. If wood

must be used, only fire retardant treated wood (scaffolding, lay down blocks) should be permitted. Such materials should be allowed into safety-related areas only when they

are to be used immediately. Their possible and probable use should be considered in the fire hazard analysis to determine the adequacy of the installed fire protection system. c. Combustible material storage and use is controlled by administrative procedures. All work activities will be controlled using approved

procedures. 4. Nuclear power plants are frequently located in remote areas, at some distance from public fire departments. Also, first response fire departments are often volunteer. Public fire department response should be considered in the overall fire protection program. However, the plant should be designed to be self-4. Comply: The plant fire brigade is trained to adequately control the effects of a fire.

Offsite fire departments will be used only as a supplement to the plant fire brigade.

APPENDIX E E4.1-7 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION sufficient with respect to fire-fighting activities and rely on the public response only for supplemental or backup capability. 5. The need for good organization, training, and equipping of fire brigades at nuclear power plant sites requires effective measures be implemented to assure proper discharge of these functions. The guidance in Regulatory Guide 1.101, "Emergency Planning for Nuclear Power Plants," should be followed as applicable. 5. Comply:

Regulatory Guide 1.101 is used for guidance in the development of plant emergency plans. a. Successful fire fighting requires testing and maintenance of the fire protection equipment, emergency lighting, and communication, as well as practice as brigades for the people who must utilize the equipment. A test plan that lists the individuals and their responsibilities in connection with routine tests and inspections of the fire detection and protection

systems should be developed. The test plan should contain the types, frequency, and detailed procedures for testing. a. The maintenance and testing of the fire detection and suppression equipment is accomplished in accordance with an approved test plan. The test plan identifies all phases of testing together with identification of the responsible personnel. Procedures should also contain instructions on maintaining fire protection during those periods when the fire protection system is impaired or during periods of plant maintenance, e.g., fire watches or temporary hose connections to water systems. Administrative procedures establish guidance for maintaining fire protection during those periods

when protection systems are impaired or during periods of plant

maintenance. b. Basic training is a necessary element in effective fire fighting operation. In order for a fire brigade to operate

effectively, it must operate as a team. All members must know what their individual duties are. They must be

familiar with the layout of the plant and equipment location and operation in order to permit effective fire-fighting operations during times when a particular area is filled with smoke or is insufficiently lighted. Such training can only be accomplished by b. The fire brigade members are to be trained to act effectively as a team, under the control of the fire brigade leader. All fire brigade members are to be familiar with the nuclear plant operations, plant layout, and equipment location. Fire drills are conducted at least quarterly to maintain fire brigade competence. Fire drills are conducted in a manner which APPENDIX E E4.1-8 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION conducting drills several times a year (at least quarterly) so that all mem-bers of the fire brigade have had the opportunity to train as a team, testing itself in the major areas of the plant.

The drills should include the simulated use of equipment in each area and should be preplanned and post-critiqued to establish the training objective of the drills and determine how well these objectives have been met. These drills should periodically (at least annually) include local fire department participation where possible. simulates all fire conditions, and provides the training objectives necessary to demonstrate the fire brigade's competency. Annually, the local fire department will be invited to participate in a fire drill. Such drills also permit supervising personnel to evaluate the effect-iveness of communications within the fire brigade and with the on-scene fire team leader, the reactor operator in the control room, and the off-site command post. c. To have proper coverage during all phases of operation, members of each shift crew should be trained in fire protection. Training of the plant fire brigade should be coordinated with the local fire department so that responsibilities and duties are deline-ated in advance. This coordination should be part of the training course and implemented into the training of the local fire department staff. Local fire departments should be educated in the operational precautions when fighting fires on nuclear power plant sites. Local fire departments should be made aware of the need for radio-active protection of personnel and the special hazards associated with a nuclear power plant site. c. Shift crew members are trained in fire protection requirements. The

plant fire brigade is fully trained in fire protection of the total plant.

This training is coordinated with offsite fire departments to assure a coordinated fire protection effort. Training of offsite fire departments includes operation precautions, and explains the need for radiation protection of department members. d. NFPA 27 - "Private Fire Brigade," should be followed in organization, training, and fire drills. This standard also is applicable for the inspection and maintenance of fire-fighting equipment. Among the standards referenced in this document, the d. NFPA 27 guidance was used in developing into the fire brigade training program.

APPENDIX E E4.1-9 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION following should be utilized. NFPA 194 Standard for Screw Threads and Gaskets for Fire Hose Couplings NFPA 196 Standard for Fire Hose NFPA 197 Training Standard on Initial Fire Attacks NFPA 601 Recommended manual of Instructions and Duties for the Plant Watchman

on Guard NFPA booklets and pamphlets listed on page 27-11 of Volume 8, 1971-72 are also applicable for good training references. In addition, courses in fire prevention and fire suppression which are recognized and/or spon-

sored by the fire protection industry should be utilized. C. QUALITY ASSURANCE PROGRAM Quality Assurance (QA) programs of applicants and contractors should be developed and implemented to assure that the requirements for design, procurement, installation, and testing and administrative controls for the fire protec-tion program for safety-related areas as defined in this Branch Position are satis-fied. The program should be under the management control of the QA organiza-tion. The QA program criteria that apply to the fire protection program should include the following: C. Comply with intent: Quality assurance for the fire protection system is applied using existing

programs. The program was not applied in the earlier stages of design and purchasing activities and cannot be retrofitted to them.

Sargent & Lundy Quality Assurance Program is applied to design control as necessary to meet specification requirements via a unique project instruction. Illinois Power Company and Baldwin Associates quality assurance programs applied to procurement, installation, testing, and administrative controls as appropriate during construction and plant operations until the AmerGen acquisition. Future activities will be conducted in accordance with the Exelon Quality Assurance Topical

Report. Portions of the Quality Assurance Program, as delineated in Appendix A of the Quality Assurance Topical

Report, apply to fire protection. This APPENDIX E E4.1-10 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION program includes the required provisions to ensure that the fire protection program is properly implemented, reviewed, and maintained throughout the life of the Clinton Power

Station. 1. Design Control and Procurement Document Control Measures should be established to assure that all design-related guidelines of the Branch Technical Position are included in design and procurement documents and that deviations therefrom are controlled. 1. Comply with intent: The design requirements of the Branch Technical Position appear in the specifications for equipment. Design and procurement document approved

procedures. 2. Instructions, Procedures, and Drawings Inspections, tests, administrative controls, fire drills, and training that govern the fire protection program should be prescribed by documented instructions, procedures, or drawings and should be accomplished in accordance with these documents. 2. Comply: Procedures to accomplish these provisions have been developed and

implemented. 3. Control of Purchased Material, Equipment, and Services Measures should be established to assure

that purchased material, equipment, and services conform to the procurement

documents. 3. Comply: Procedures established by Illinois Power Company and Baldwin Asso-ciates assured that purchased material, equipment, and services conformed to the procurement documents during construction and plant operations until the AmerGen acquisition. Future activi-ties will be conducted in accordance with the Exelon Quality Assurance Topical Report. 4. Inspection A program for independent inspection of activities affecting fire protection should be established and executed by, or for, the organization performing the activity to

verify conformance with documented installation drawings and test procedures for accomplishing the activities. 4. Comply: Specifications require documented inspection by the installer. Illinois Power Company and Baldwin Associates established programs for inspection of activities affecting fire protection during construction and plant operations until the AmerGen acquisi-tion. Future activities will be conducted in accordance with the Exelon Quality Assurance Topical Report.

APPENDIX E E4.1-11 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION 5. Test and Test Control A test program should be established and implemented to assure that testing is performed and verified by inspection and audit to demonstrate conformance with design and system readiness

requirements. The tests should be

performed in accordance with written test procedures; test results should be properly evaluated and acted on. 5. Comply: Clinton Power Station has established test and test control programs in its quality assurance program. 6. Inspection, Test, and Operating Status Measures should be established to provide for the identification of items that have satisfactorily passed required tests and inspections. 6. Comply:

Clinton Power Station procedures assure identification of items that have satisfactorily passed the required tests and inspections. 7. Nonconforming Items Measures should be established to control items that do not conform to specified

requirements to prevent inadvertent use of installation. 7. Comply: Clinton Power Station procedures have been established to govern identifica-tion and control of nonconforming

items. 8. Corrective Action Measures should be established to assure that conditions adverse to fire protection, such as failures malfunctions, deficiencies, deviations, defective components, uncontrolled combustible material, and nonconformance are promptly identified, reported, and corrected. 8. Comply: The Clinton Power Station Quality Assurance Program establishes measures for corrective action on conditions adverse to fire protection. 9. Records Records should be prepared and maintained to furnish evidence that the criteria enumerated above are being met for activities affecting the fire protection program. 9. Comply with intent: Records associated with CPS Fire Protection Program are prepared and

maintained in accordance with the CPS quality assurance programs. 10. Audits Audits should be conducted and documented to verify compliance with the fire protection program including design and procurement documents; instructions; procedures and drawings; and inspection and test activities.

10. Comply: The CPS quality assurance program established well defined auditing activities.

APPENDIX E E4.1-12 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION D. GENERAL GUIDELINES FOR PLANT PROTECTION

1. Building Design a. Comply: a. Plant layouts should be arranged to: 1. Isolate safety-related systems from unacceptable fire hazards. Safety-related equipment is either isolated protected as identified in

the Fire Protection Evaluation

Report and Safe Shutdown

Analysis. 2. Alternatives: a. redundant safety-related systems that are subject to damage from a single fire hazard should be protected by a combination of fire retardant coatings and fire detection and suppression system, or b. a separate system to perform the safety function should be

provided. The fire protection general arrangement drawings depict the plant layout and general location of

equipment. The equipment of redundant safe shutdown systems are adequately protected from a single fire hazard as documented by the Safe Shutdown Analysis. b. In order to accomplish 1.a. above, safety-related systems and fire hazards should be identified through-out the plant. Therefore, a detailed fire hazard analysis should be made.

The fire hazards analysis should be reviewed and updated as necessary.

Additional fire hazards analyses should be done after any plant modifications. b. Comply: A fire hazard analysis is contained in the CPS FPER. Procedures have been developed to update the FPER and to ensure that all design changes will be reflected in the FPER. For multiple reactor sites cable spreading rooms should not be

shared between reactors. Each cable spreading room should be separated from other areas of the plant by barriers (walls and floors) having a minimum fire resistance of three hours. Cabling for redundant safety divisions should be separated by walls having three hour fire barriers. Not applicable. c. Alternative guidance for constructed plants is shown in Section F.3, "Cable Spreading Room."

c. Not applicable.

APPENDIX E E4.1-13 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION d. Interior wall and structural components, thermal insulation aterials and radiation shielding materials and sound-proofing should be non-combustible. Interior finishes should be non-combustible or listed by a nationally recognized testing laboratory, such as Factory Mutual or Underwriters' Laboratory, Inc. for flame spread, smoke, and fuel contribution of 25 or less in its use configuration (ASTM E-84 Test),

"Surface Burning Characteristics of Building Materials." d. Comply with intent: Interior wall and structural components are noncombustible. Minor amounts of combustibles are

used. Examples of these are nailers, seals, caulking, and joint fillers. These materials do not present a hazard to safety-related equipment. The thermal insulation, radiation shielding and

soundproofing materials are either noncombustible or their fire resistance properties are evaluated with the intent to minimize the fire hazard. Most of the materials used in the original construction were within the limits of 25 when tested in accordance with the ASTM E-84 protocol. When replacement or new materials are selected, the fire hazard characteristics are reviewed using the results of appropriate testing. The fire test may be other than ASTM E-84, depending on the intended form and application of

the material at CPS. For example, floor coverings will be evaluated and accepted if the critical radiant

flux, tested in accordance with NFPA 253/ASTM E-648, is

0.45 watts/sq.cm. or greater and the maximum specific optical smoke density, tested in accordance with NFPA 258, is less than 450.

Floor coverings in areas containing systems or equipment required for safe shutdown of the plant are generally Class I material as defined in NFPA 101, or generally a flame spread rating of 25 or less as defined in ASTM E-84. For fire

hazard analysis purposes, floor coatings are considered non-combustible if the material has a structural base of non-combustible

material, with a nominal depth not APPENDIX E E4.1-14 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION over 1/8 inch thick, and has a flame spread rating not higher than 50 as defined in ASTM E-84. Exceptions to these guidelines are evaluated for acceptability by Engineering on a case-by-case basis. Consistent with the guidelines of NUREG 0800, Revision 2, Section 9.5.1, the following materials are acceptable for use as interior finish without evidence of

test and listing by a nationally

recognized laboratory. Plaster, acoustic plaster, gypsum plasterboard (gypsum; wallboard) either plain, wall-papered, orpainted with oil-or water-based paint; Ceramic tile, ceramic panels: Glass, glass blocks; Brick, stone, concrete blocks, plain or painted; Steel and aluminum panels, plain, or enameled; Vinyl tile, vinyl-asbestos tile, linoleum, or asphalt on concrete floors. The noncombustible materials used at CPS are concrete and steel structural and radiation shielding materials, and the reflective metallic installation installed inside the drywell. The following are examples of com-bustible materials utilized at CPS.

Silicone foam sealant is used for sealing penetrations through walls and floors. Fiberglass insulation with metal lagging or fiberglass blanket insulation is used for hot piping. Fiberglass insulation with white craft paper and foil reinforced with glass yarns is used for cold piping. HVAC ductwork is insulated with fiberglass insulation with white craft paper and foil reinforced vapor barrier. Foam plastic insulation is used for cold pipe insulation inside the containment and drywell and for insulating cold equipment. Phenolic foam insulation is used for piping APPENDIX E E4.1-15 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION and ductwork subjected to low temperatures. Materials installed to improve building comfort are carpeting and the fiberglass and melamine acoustical panels. The combustible components in the radiation shielding materials are the vinyl cover for the lead blanket and the rubber bladder for the water shield. Acceptable alternate tests for floor coverings include NFPA-253 "Standard Method of Test for

Critical Radiant Flux of Floor Covering Systems Using a Radiant Heat Energy Source" and

NFPA-258 "Standard Research

Test Method for Determining Smoke Generation of Solid

Materials". e. Metal deck roof construction should be noncombustible (see the building materials directory of the Under-writer's Laboratory, Inc.) or listed as Class 1 by Factory Mutual System Approval Guide. Where combustible material is used in metal deck roofing design, acceptable alternatives are (i) replace combustibles with non-combustible materials, (ii) provide an automatic sprinkler system, or (iii) provide ability to cover roof exterior and interior with adequate water volume and pressure. e. Comply: The materials used in metal deck roofing design are non-combustible and meet the criteria of Factory Mutual Class 1 design and UL Class "A" construction. f. Suspended ceilings and their supports should be of noncombustible construction. Concealed spaces should be devoid of combustibles.

Adequate fire detection and suppres-sion systems should be provided where full implementation is not practicable. f. Comply with intent: Suspended ceilings and supports are constructed of non-combustible materials (non-combustible

acoustical tiles or metal eggcrate). The fire classification for acoustical tile is: flame spread 15 and smoke developed 0; and for the plaster ceilings: flame spread 10, fuel contribution 0, and smoke devel-oped 0. Fire detection and manual extinguishing capabilities are pro-vided as detailed in Chapter 3.0 of the FPER.

APPENDIX E E4.1-16 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION g. High voltage-high amperage transformers installed inside buildings containing safety-related systems should be of the dry type or insulated and cooled with noncombustible liquid. Safety-related systems that

are exposed to flammable oil filled transformers should be protected from the effects of a fire by: i. Replacing with dry transformers that are insulated and cooled with noncombustible liquid; or ii. Enclosing the transformer with a three-hour fire barrier and installing automatic water spray protection.

g. Comply: All transformers located inside buildings are of the dry type. The oil filled main (MPTs), unit auxiliary (UATs), and reserve

auxiliary power (RAT B) transformers are located outdoors

and are equipped with automatic deluge systems. Portions of Category 1 buildings within 50 feet of an oil filled

transformer are 3-hour fire barriers, except for the main bus duct feeds to the unit auxiliary transformers. Oil filled transformers located farther than 50 feet from Category 1 buildings (RAT A and RATC) are equipped with fire detection systems. h. Buildings containing safety-related systems having openings in exterior walls closer than 50 feet to flammable oil filled transformers should be protected from the effects of a fire by: i. Closing of the opening to have fire resistance equal to three hours; ii. Constructing a three-hour fire barrier between the

transformers and the wall openings; or iii. Closing the opening and grade providing the capability to maintain a water curtain in case of fire. h. Comply with intent: Portions of Category 1 buildings within 50 feet of an oil filled

transformer are 3-hour fire barriers, except for the main bus duct feeds

from the unit auxiliary transformers. The turbine building also contains safety-related cables and instru-ments, but these are not required for safe shutdown. Portions of the turbine building within 50 feet of an oil filled transformer are 3-hour fire barriers up to approximately 60 feet above grade elevation, except for the main bus duct feeds to the main and unit auxiliary transformers. The transformers (except Main Power Transformers and RATs A &

C) and associated bus ducts are

protected by an automatic deluge system initiated by heat detectors that annunciate in the main control room. Main Power Transformers A, B, & C are protected by deluge

systems initiated automatically by sudden pressure and differential relay actuation, and manually by APPENDIX E E4.1-17 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION Operator after receiving the MPT fire detection alarm in the main control room. RAT A and RAT C utilitize heat detectors that annunciate in the main control room. In addition, oil retention berms and barrier walls between

transformers are provided to prevent the spread of a fire.

As evaluated by a fire protection engineer, the construction of the

bus duct assembly for the unit

auxiliary transformer, as well as the

bolted attachment of the duct to both sides of the wall, provides protection equivalent to that of a fire

door or damper. i. Floor drains, sized to remove expected fire-fighting water flow, should be provided in those areas where fixed water fire suppression systems are installed. Drains should also be provided in other areas where hand hose lines may be used if such fire-fighting water could cause unacceptable damage to equipment in the area. Equipment should be installed on pedestals, or curbs should be provided as required to contain water and direct it to floor drains. (See NFPA 92M, "Water-proofing and Draining of Floors.")

Drains in areas containing combustible liquids should have provisions for preventing the spread of fire throughout the drain system.

Water drainage from areas which

may contain radioactivity should be

sampled and analyzed before discharge to the environment. In operating plants or plants under construction, if accumulation of water from the operation of new fire suppression systems does not create unacceptable consequences, drains need not be installed. i. Comply with intent: Floor drains are provided in areas where fixed water fire suppression systems are installed. Water for controlling a fire can be introduced virtually anywhere in the plant and a floor drain system has been provided to reduce accumula-

tion of water from fire suppression systems. Provisions, such as pedestals for equipment and curbs around openings, have been pro-

vided, as required, to assure that excess water is directed away from equipment, particularly safety-related equipment, and will run off into areas where it will not impair the safe shut down of the plant. It is not possible to mount some electrical equipment, such as switchgear, on pedestals. (See Section A.5 in this chapter.) A fire suppression effects analysis was performed to determine the conse-quences of spraying safe shutdown

equipment with water, either from a sprinkler system or a fire hose.

The analysis resulted in several required modifications in order to protect such equipment from the effects of initiation of fire suppres-APPENDIX E E4.1-18 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION sion measures and subsequent flooding. With the installation of the required modifications, it is concluded that initiation of either

automatic or manual fire suppres-sion measures along with any associated buildup of fire protection water will not preclude safe shut-down of the plant. Drains have provisions for preventing the spread of fire through the drainage

system. Drainage which is poten-tially radioactive goes to the liquid

radwaste area where it is analyzed and processed. j. Floors, walls, and ceilings enclosing separate fire areas should have minimum fire rating of three hours.

Penetrations in these fire barriers, including conduits and piping, should be sealed or closed to provide a fire-resistance rating at least equal to that of the fire barrier itself. Door openings should be protected with equivalent rated doors, frames and hardware that have been tested and approved by a nationally recognized laboratory. Such doors should be normally closed and locked or alarmed with alarm and annunciation in the control room. Penetrations for

ventilation system should be protected by a standard "fire door damper" where required. (Refer to NFPA 80, "Fire Doors and Windows")

The fire hazard in each area should

be evaluated to determine barrier requirements. If barrier fire resistance cannot be made adequate, fire detection and suppression should be provided, such as: i. Water curtain in case of fire,

ii. Flame retardant coatings,

iii. Additional fire barriers. j. Comply with intent: Fire areas are enclosed by barriers commensurate with the fire hazards and protection within each area, as defined in the FPER. Openings in these rated barriers are described in the FPER. Doors to vital areas are closed and locked in accordance with the station security requirements.

These doors will alarm and annunciate in the security control room if they are used for unauthorized entry, exit, or set ajar. The locking of many doors would interfere with the normal and safe operation of the plant. Doors that should not be locked are provided with self-closing devices. Rolling steel fire doors, which do not have self-closing devices, are monitored every twenty-four hours or, if open

for extended periods of time, then appropriate compensatory mea-sures will be taken in accordance with applicable CPS procedures.

Door openings are protected with equivalent doors, frames and hardware tested and approved by a nationally recognized laboratory.

Deviations have been provided in the Safe Shutdown Analysis.

APPENDIX E E4.1-19 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION 2. Control of Combustibles

a. Safety-related systems should be isolated or separated from combustible materials. When this is not possible because of thenature of the safety system or the combustible material, special protection should be

provided to prevent a fire from defeating the safety system function.

Such protection may involve a com-bination of automatic fire suppression, and construction capable of withstanding and containing a fire that consumes all combustibles present. Examples of such combustible materials that may not be separable

from the remainder of its system are: a. Comply with intent:

Safety-related systems are isolated or separated from combustibles.

When this is not possible, protec-

tion is provided to prevent a fire from defeating the ability to safely shut down the plant. 1. Emergency diesel generator fuel oil day tanks 1. The diesel day tank rooms are separated from the diesel

generator rooms by 1.9-hour barriers. An automatic wet-pipe suppression system is

provided in each day tank

room. Curbing is provided in the day tank rooms that will contain 110% of the oil inventory. In addition, drain capacity allows for a 20-minute sprinkler system accumulation. 2. Turbine generator oil and hydraulic control fluid systems. 2. The turbine generator oil system is located in a non-

safety-related building. Portions of the system are provided with automatic sprinkler fire suppression. The hydraulic control fluid is a synthetic fire resistive fluid.

Some equipment in the turbine building is designated as safety-related in the Clinton design; however, none of this

equipment has a safe shutdown-related function.

APPENDIX E E4.1-20 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION 3. Reactor coolant pump lube oil system. 3. The reactor recirculation pumps nonpressurized lube oil systems are integral with the reactor recirculation pump motors except for 1 gallon

automatic oilers which may be added to the lower bearing reservoir fill line. Infrared flame detectors are provided in the area of the reactor recirculation pumps. b. Bulk gas storage (either compressed or cryogenic) should not be permitted inside structures housing safety-related equipment. Storage of flammable gas such as hydrogen should be located outdoors or in separate detached buildings so that a fire or explosion will not adversely

affect any safety-related systems or equipment. (Refer to NFPA 50A, "Gaseous Hydrogen Systems.") Care should be taken to locate high pressure gas storage containers with the long axis parallel to building walls.

This will minimize the possibility of wall penetration in the event of a container failure. Use of compressed gases (especially flammable and fuel gases) inside buildings should be controlled. (Refer to NFPA 6, "Industrial Fire Loss Prevention.") b. Comply with intent: Bulk gas storage facilities are provided remote from any safety-related structures. Bulk storage of flammable gas is located outdoors in separate facilities and away from any safety-related structures.

APPENDIX E E4.1-21 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION c. The use of plastic materials should be minimized. In particular, halognated plastics such as polyvinyl chloride (PVC) and neoprene should be used only when substitute non-combustible materials are not available. All plastic materials, including flame and fire retardant materials, will burn with an intensity and Btu production in a range similar to that of ordinary hydrocarbons. When burning, they produce heavy smoke that obscures visibility and can plug air filters, especially charcoal and HEPA. The haloginated plastics also release free chlorine and hydrogen chloride when burning which are toxic to humans and corrosive to equipment. c. Comply: The use of plastic materials is minimized. d. Storage of flammable liquids should, as a minimum, comply with the requirements of NFPA 30, "Flammable and Combustible Liquids

Code." d. Comply:

Administrative procedures covering the storage and handling of flammable liquids have been

developed. 3. Electric Cable Construction,Cable Trays, and Cable Penetrations

a. Only noncombustible materials should be used for cable tray construction. a. Comply: All cable trays are constructed of steel. b. See Section F.3 for fire protection guidelines for cable spreading rooms. b. See Section F.3 for responses.

APPENDIX E E4.1-22 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION

c. Automatic water sprinkler systems should be provided for cable trays outside the cable spreading room. Cables should be designed to allow wetting down with deluge water without electrical faulting. Manual hose stations and portable hand extinguishers should be provided as backup. Safety-related equipment in the vicinity of such cable trays, that does not itself require water fire protection, but is subject to unacceptable damage from sprinkler water discharge, should be protected from sprinkler system operation or malfunction. When safety-related cables do not satisfy the provisions of

Regulatory Guide 1.75, all exposed cables should be covered with an approved fire retardant coating and a fixed automatic water fire suppression system should be provided. c. Partial compliance: Automatic suppression systems will be installed as required by the Fire Protection Evaluation Report

and the Safe Shutdown Analysis.

Automatic sprinkler systems are not provided for cable trays outside the cable spreading room, based on a detailed review of heavy cable tray concentration areas in Category 1 buildings. Cables are designed to withstand wetting without electrical failure. The justification for not providing sprinkler systems for cable trays in areas outside the cable spreading

rooms is: 1. Fire detection is provided in areas of high cable concen-tration associated with safe shutdown cables. 2. Cable tray loadings are low. 3. Use of solid bottom cable trays with all instrumentation cable trays totally enclosed. 4. Low fire loading in the fire zone. 5. Cables are generally flame retardant and nonpropagating per IEEE-383. 6. Conservative separation per IEEE-384. Conformance with Regulatory Guide 1.75 is covered in Subsections 7.1.2.6.19 and 8.1.6.1.14 of the USAR. Manual hose stations and portable hand extinguishers are provided throughout the plant. Their locations are shown on the "b" APPENDIX E E4.1-23 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION series figures in the Fire Protection Evaluation Report. Safe shutdown equipment that can be subjected to unacceptable damage from sprinkler water discharge is protected from sprinkler system operation or malfunction, as documented in the Fire Suppression Effects Analysis, calculation 01FP14. d. Cable and cable tray penetration of fire barriers (vertical and horizontal) should be sealed to give protection at least equivalent to that fire barrier. The design of fire barriers for horizontal and vertical cable trays should, as a minimum, meet the requirements of ASTM E-119, "Fire Test of Building Construction and Materials," including the hose stream test. Where installed penetration seals are deficient with respect to fire resistance, these seals may be protected by covering both sides with an approved fire retardant material.

The adequacy of using such material should be demonstrated by suitable testing. d. Comply with intent: Conduit and cable tray penetrations of fire barriers are sealed with fire stops of a rating equivalent with that of the fire barrier, except as noted in Appendix F, Section 4.2.2.22. A deviation has been requested from the NRC such that the 325

°F temperature end point limitation on the unexposed side of cable

insulation may be exceeded. e. Fire breaks should be provided as deemed necessary by the fire hazards analysis. Flame or flame retardant coatings may be used as a fire break for grouped electrical cables to limit spread of fire in cable ventings. (Possible cable derating owing to use of such considered during design.) e. Comply: Fire breaks are provided as required by the Fire Protection

Evaluation Report and the Safe Shutdown Analysis. All vertical cable tray risers are provided with fire breaks where they penetrate a floor/ceiling. Fire breaks are also

provided within the PGCC in the

control room as deemed necessary by GE Licensing Topical Report NED0-10466-A.

APPENDIX E E4.1-24 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION f. Electrical cable constructions should, as a minimum, pass the current IEEE No. 383 flame test. (This does not imply that cables passing this test will not require additional fire protection.)

For cable installation in operating plants under construction that do not

meet the IEEE No. 383 flame test requirements, all cables must be covered with an approved flame retardant coating and properly

derated. f. Comply: Cables used are of EPR/hypalon or tefzel construction, which is certified as having passed the

IEEE-383 flame test, and is flame retardant with self-extinguishing characteristics. A small amount of cables furnished by manufacturers for their equipment (e.g., turbine control cables) do not meet IEEE-383 requirements. Also, fire detection, lighting, and communi-cation cabling does not meet IEEE-383 requirements. However, these cables are a small quantity compared to the total quantity of cables installed; they will have a negligible impact. g. To the extent practical, cable construction that does not give off corrosive gases while burning should be used. g. Comply. h. Cable trays, raceways, conduit, trenches, or culverts should be used only for cables. Miscellaneous storage should not be permitted, nor should piping for flammable or com-bustible liquids or gases be installed to these areas. Installed equipment in cable tunnels or culverts need not be removed if they present no hazard to the cable runs as determined by the fire hazards analysis. h. Comply:

Only cables occupy cable trays and conduits. Piping is not routed through cable trenches or culverts.

Piping associated with flammable or combustible liquids or gases is not routed in the vicinity of safety-

related cables. i. The design of cable tunnels, culverts, and spreading rooms should provide

for automatic or manual smoke venting as required to facilitate manual fire fighting capability. i. Comply with intent: Venting is described in the CPS Smoke Removal Plan.

APPENDIX E E4.1-25 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION j. Cables in the control room should be kept to a minimum necessary for operation of the control room. All cables entering the control room should terminate there. Cables should not be installed in floor trenches or culverts in the control room. Existing cabling installed in concealed floor and ceiling spaces should be protected with an automatic total flooding Halon system. j. Comply with intent: Cables in the control room are kept to the minimum necessary for operation of the control room.

Generally, cables entering the

control room terminate there. The control room is part of the Power

Generation Control Complex (PGCC) designed by General Electric. The design of the PGCC is addressed in Licensing Topical Report NEDO-10466-A. A Halon

fire suppression system

automatically initiated by thermal detectors is provided as part of the PGCC. 4. Ventilation

a. The products of combustion that need to be removed from a specific fire area should be evaluated to determine how they will be controlled. Smoke and corrosive gases should generally be automatically discharged directly outside to a safe location.

Smoke and gases containing radioactive materials should be monitored in the fire area to determine if release to the environment is within the permissible limits of the plant Technical Specifications. The products of combustion which need to be removed from a specific fire area should be evaluated to determine how they will be controlled. a. Comply: In the event of a fire, the situation will be thoroughly evaluated before venting the area, and venting will take place under the direction and control of cognizant personnel.

The CPS Smoke Removal Plan identifies acceptable methods of

smoke removal. In most cases throughout the plant, ventilation systems were not specifically designed for smoke/heat removal, but for the ventilation requirements of the areas that they serve. However, these systems may aid in smoke removal once a fire is extinguished.

Effluent from areas that contain radioactive or potentially radio-

active materials that are discharged to the outdoors through ventilation are constantly monitored.

APPENDIX E E4.1-26 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION b. Any ventilation system designed to exhaust smoke or corrosive gases should be evaluated to ensure that inadvertent operation or single failures will not violate the controlled areas of the plant design. This requirement includes containment functions for protection of the public and maintaining habitability for operations personnel. b. Comply:

A single failure or inadvertent operation of any ventilation system will not affect habitability or present a hazard to the public. Ventilation systems which are related to habitability of personnel are under the control of the cognizant personnel. c. The power supply and controls for mechanical ventilation systems should be run outside the fire area served by the system. c. Comply:

The power supply and controls for mechanical ventilation systems are run outside the area served by the system. Some ventilation systems, such as area recirculation cooling systems, are located inside the fire

area. These systems are not used for smoke removal. d. Fire suppression systems should be installed to protect charcoal filters in accordance with Regulatory

Guide 1.52, "Design Testing and Maintenance Criteria for Atmospheric Cleanup Air Filtration." d. Comply with intent: To protect the charcoal filters against the effects of iodine decay heat after a postulated accident, the control room (VC), the standby gas treatment (VG), and the

drywell purge (VQ) filter units are

equipped with heat sensors that auto-matically annunciate in the control room, as well as manually operated water spray systems. In addition the VG filter units are

protected with low-flow charcoal adsorbent cooling fans.

The temperature detection panels are not in full compliance with the NFPA Code for fire detection systems, as the primary function is for adsorbent cooling with a secondary function of fire detection.

These panels are not UL listed. NFPA Code conformance is documented in the CPS NFPA Code Conformance Evaluation.

APPENDIX E E4.1-27 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION e. The fresh air supply intakes to areas containing safety-related equipment or systems should be located remote from the exhaust air outlets and smoke vents of other fire areas to minimize the possibility of contaminating the intake air with the products of combustion. e. Comply: The intake and exhaust of each area are physically remote to prevent recirculation. f. Stairwells should be designed to minimize smoke infiltration during a fire. Staircases should serve as escape routes and access routes for fire fighting. Fire exit routes should be clearly marked. Stairwells, elevators, and chutes should be enclosed in masonry towers with a minimum fire rating of three hours and automatic fire doors at least equal to the enclosure construction, at each opening into the building. Elevators should not be used during fire emergencies. Where stairwells or elevators cannot be enclosed in

three-hour fire rated barriers with

equivalent fire doors, escape and access routes should be established by prefire plan and practiced in drills by operating and fire brigade personnel. f. Comply with intent: Stairwells are designed to minimize smoke infiltration during a fire. There is at least one enclosed

stairway located in or within quick access to each building, except the containment building. Elevators are enclosed in 1.9-hour rated masonry towers and have

1-1/2-hour fire rated hoistway doors. Enclosed stairways have minimum 1.9-hour fire rated walls and 1-1/2-hour automatic closing fire rated doors. Some unprotected steel is located inside

the stairwells. Three fire dampers installed in ducts penetrating Radwaste Building Stairwell walls may not completely close under designed airflow due to their respective airflow velocities. The ducts containing these fire dampers have no openings in the stairwell. Since the sheet metal duct can withstand a one-hour fire, the ability of the stairway to provide access and egress for approximately one hour during a fire is not jeopardized. Where stairwells or elevators are not enclosed in 1.9-hour fire rated barriers, access and egress routes are established and included in fire brigade procedures and practiced in drills by operating and fire brigade personnel.

APPENDIX E E4.1-28 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION g. Smoke and heat vents may be useful in specific areas such as cable spreading rooms and diesel fuel oil storage areas and switchgear rooms.

When natural-convection ventilation is used, a minimum ratio of 1 sq. ft. of venting area per 200 sq. ft. of floor area should be provided. If forced-convection ventilation is used, 300 cfm should be provided for every 200 sq. ft. of floor area. See NFPA No.

204 for additional guidance on smoke control. g. Comply with intent: Smoke vents are used for the turbine building only. Smoke and heat vents will not be used for the areas identified due to building security and missile protection. In

addition, many of these areas are located in the lower levels of the plant, making gravity venting unfeasible. These areas are

provided with mechanical ventilation. The flow rates are

based on HVAC requirements and in most cases are less than 300 cfm per 200 ft

2. The ventilation systems will be used for post-fire purging as required, for which they are adequate. The CPS Smoke Removal Plan provides acceptable methods for removing products of combustion from fire areas. h. Self-contained breathing apparatus, using full face positive pressure masks, approved by NIOSH (National Institute for Occupational

Safety and Health-approval formerly given by the U.S. Bureau of Mines) should be provided for fire brigade, damage control, and control room personnel. Control room personnel may be furnished breathing air by a

manifold system piped from a storage reservoir if practical. Service or operating life should be a minimum of one-half hour for the self-contained units. At least two extra air bottles should be located onsite for each self-contained breathing unit. In addition, an onsite six-hour supply of reserve air should be provided and arranged to permit quick and complete replenishment of exhausted supply air bottles as they are returned. If compressors are used as a source of breathing air, only units approved for h. Comply: Self-contained breathing apparatus (SCBA) with approved full-face positive pressure masks approved by NIOSH with a minimum I-hour operating life have been supplied for fire brigade personnel. The Radiation Protection Department controls and provides full-face masks SCBA for fire brigade use and controls all spare bottles. A minimum 6-hour reserve supply of control room breathing air is

furnished by a manifold breathing system. Two extra air bottles are maintained on the site for each fire brigade SCBA. A 6-hour air supply is maintained for the reserve air

requirement.

APPENDIX E E4.1-29 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION breathing air should be used. Special care must be taken to locate the compressor in areas free of dust and contaminants. i. Where total flooding gas extinguish-ing systems are used, area intake and exhaust ventilation dampers should close upon initiation of gas flow to maintain necessary gas con-centration. (See NFPA 12, "Carbon Dioxide Systems," and 12A, "Halon

1301 Systems.") i. Comply: The ventilation air intake and exhaust dampers located in the fan rooms above the diesel generator close upon initiation of the CO 2 system. The can be opened manually for post-fire purging. In addition, the ventilation systems in areas served by Halon systems are isolated upon initiation to achieve and maintain Halon concentration. 5. Lighting and Communication 5. Comply: See USAR Sections 9.5.1 and 9.5.3. Lighting and two-way voice communi-cation are vital to safe shutdown and emergency response in the event of fire.

Suitable fixed and portable emergency lighting and communication devices should be provided to satisfy the following

requirements: Communication and emergency lighting are provided throughout the station as noted below: a. Fixed emergency lighting should consist of sealed beam units with individual eight hour minimum battery power supplies. a. Comply with intent: Fixed sealed-beam lighting units with 8-hour minimum battery supplies are provided for manned

workstations and remote manual action locations needed for safe shutdown and the credited access and egress paths thereto. Emergency lighting consisting of 1.5-hour minimum battery supplies units and 125-Vdc incandescent

light fixtures are provided in other areas of the plant for evacuation of personnel, which is consistent with NUREG-0800 and NFPA-101.

APPENDIX E E4.1-30 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION b. Suitable sealed beam battery powered portable hand lights should be provided for emergency use. b. Comply: Suitable 8-hour sealed beam battery powered portable hand lights are provided for one-time remote manual actions and access and egress paths thereto. c. Fixed emergency communication should use voice powered headsets at preselected stations. c. Comply: Sound-powered phone jacks are installed at selected locations throughout the plant for voice

powered communication. d. Fixed repeaters installed to permit use of portable radio communication units should be protected from exposure to fire damage. d. Comply with intent: Fixed repeaters are not protected from fire damage but are backed up by the three independent systems: PA, telephone, and sound powered phones. E. FIRE DETECTION AND SUPPRESSION

1. Fire Detection

a. Fire detection systems should, as a minimum, comply with NFPA 72D, "Standard for the Installation, Maintenance and Use of Proprietary Protective Signaling Systems."

Deviations from the requirements of NFPA 72D should be identified and justified. a. Comply with intent: The fire detection system for the station complies with NFPA 72D with deviation as documented in the CPS NFPA Code Conformance

Evaluation. b. Fire detection systems should give audible and visual alarm and annunciation in the control room.

Local audible alarms should also sound at the location of the fire. b. Comply with intent: The fire detection system for the station gives audible and visual alarm and annunciation in the control room. Local audible alarms

are only provided for fire suppression systems excluding the filter train deluge and the FLEX diesel generator systems. c. Fire alarms should be distinctive and unique. They should not be capable of being confused with any

other plant system alarms. c. Comply with exception: Audible fire alarms are distinctive and unique except for some panel alarms in the fuel and turbine buildings, as documented in the CPS NFPA Code Conformance

Evaluation.

APPENDIX E E4.1-31 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION d. Fire detection and actuation systems should be connected to the plant emergency power supply. d. Comply with intent: The fire detection system for the station is connected to the station Class 1E power system. The fire suppression systems in safety related buildings are connected to the station Class 1E power system.

The non-safety-related filter train deluge systems, with the exception of those for drywell purge, are connected to the station Class 1E

power system. For those exceptions, the deluge valves may be operated manually as well as via electric operator.

2. Fire Protection Water Supply Systems

a. An underground yard fire main loop should be installed to furnish anticipated fire water requirements.

NFPA 24, "Standard for Outside Protection," gives necessary guidance for such installation. It references other design codes and standards developed by such organi-zations as the American National

Standards Institute (ANSI) and the American Water Works Association (AWWA). Lined steel or cast iron pipe should be used to reduce internal tuberculation. Such tuber-culation deposits in an unlined pipe over a period of years can signifi-cantly reduce water flow through the combination of increased friction and reduced pipe diameter. Means for treating and flushing the systems should be provided. a. Comply with intent:

The underground yard fire main loop is designed and installed in compliance with applicable NFPA 24 requirements. NFPA code conformance is documented in the CPS NFPA Code

Conformance Evaluation. Unlined carbon steel pipe is provided in the underground yard loop. Possible tuberculation of pipe is accounted for in the hydraulic calculations by using a

conservative C-factor of 75. The calculations demonstrate adequate fire protection water supply during the life of the plant.

APPENDIX E E4.1-32 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION Approved visually indicating sectional control valves, such as Post Indicator Valves, should be provided to isolate portions of the main for maintenance or repair without shutting off the entire system.

Visible location marking signs for underground valves are acceptable. Alternative valve position indicators should also be provided. For operating plants, fire main system piping that can be isolated

from service or sanitary water system piping is acceptable. Comply: Sectional control valves with post indicators allow the isolation of any one section without affecting the balance of the system. b. A common yard fire main loop may serve multiunit nuclear power plant sites, if cross-connected between units. Sectional control valves should permit maintaining independence of the individual loop around each unit. For such installa-tions, common water supplies may

also be utilized. The water supply should be sized for the largest single expected flow. For multiple reactor sites with widely separated plants (approaching one mile or more), separate yard fire main loops should be used.

Sectionalized systems are acceptable. b. Not applicable: The Clinton Power Station utilizes a single fire main loop with section isolation valves. c. If pumps are required to meet system pressure or flow requirements, a sufficient number of pumps should be provided so that

100% capacity will be available with

one pump inactive (e.g., three 50%

pumps or two 100% pumps). The connection to the yard fire main loop from each fire pump should be widely separated, preferably located on opposite sides of the plant. Each pump should have its own driver with independent power supplies and control. At least one pump (if not powered from the emergency diesels) should be driven by non- c. Comply with intent: Normally the fire protection system is pressurized by a jockey pump fed from the filtered water system. Fire protection is provided by two 100% capacity (2500 gpm each) diesel driven fire pumps. The connections to the yard main loop from each fire pump are widely separated, located on opposite sides of the screen house, and diverge as they connect to the underground yard main.

Pumps and drivers are located in APPENDIX E E4.1-33 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION electrical means, preferably diesel engine. Pumps and drivers should be located in rooms separated from the remaining pumps and equipment by a minimum three-hour fire wall. separate rooms. The fire pump located at the north end of the screen house is enclosed in a 3-hour fire rated wall on three sides. The exterior wall is not rated. The ceiling in this zone is

rated; however, the floor is not.

The walls surrounding the fire pump at the south end of the screen house are not rated; however, a separation distance of approximately 140 feet exists

between the two fire pump rooms.

Approximately half of this distance was intended for Unit 2 use and now contains minimal combustibles. Alarms indicating pump running, driver availability, or failure to start should be provided in the control room. Details of the fire pump installation should, as a minimum, conform to

NFPA 20, "Standard for the Installation of Centrifugal Fire Pumps." The recommended alarms are provided in the control room. An automatic water suppression system is provided in each fire pump room. The fire pump installation is in accordance with applicable NFPA 20 requirements. NFPA code conformance is documented in the CPS NFPA Code Conformance Evaluation. d. Two separate reliable water supplies should be provided. If tanks are

used, two 100% (minimum of

300,000 gallons each) system capacity tanks should be installed.

They should be so interconnected that pumps can take suction from either or both. However, a leak in one tank or its piping should not cause both tanks to drain. The main plant fire water supply capacity should be capable of refilling either tank in a minimum of eight hours. Common tanks are permitted for fire and sanitary or service water storage. When this is done, however, minimum fire water storage requirements should be dedicated by means of a vertical standpipe for d. Not applicable. See Section 2.f.

APPENDIX E E4.1-34 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION other water services. e. The fire water supply (total capacity and flow rate) should be calculated on the basis of the largest expected flow rate for a period of two hours, but not less than 300,000 gallons. This flow rate should be based (conservatively) on 1,000 gpm for manual hose streams plus the greater of: e. Comply with intent:

The inventory of water in the ultimate heat sink allocated to fire protection is 900,000 gallons. For safety-related buildings, the fire pump flow rate is based on the sprinkler flow requirements of NFPA 13 and 15 plus 500 gpm for manual hose streams. 1. All sprinkler heads opened and flowing in the largest designed fire area; or 2. The largest open head deluge system(s) operating. f. Lakes or fresh water ponds of sufficient size may qualify as sole source of water for fire protection, but require at least two intakes to the

pump supply. When a common water supply is permitted for fire protection and the ultimate heat sink, the following conditions should also be satisfied: f. Comply: A common water supply is used for fire protection and the ultimate heat sink, but the size is adequate for both. Each pump has its own supply tunnel and screens. Under no circumstances is the safety function of the ultimate heat sink compromised. 1. The additional fire protection water requirements are designed into the total storage capacity; and 1. Comply:

Fire protection requirements were designed into the storage capacity of the ultimate heat sink. 2. Failure of the fire protection system should not degrade the function of the ultimate heat sink. 2. Comply: Failure of the fire protection system does not degrade the function of the ultimate heat sink. g. Outside manual hose installation should be sufficient to reach any location with an effective hose stream. To accomplish this, hydrants should be installed approxi-mately every 250 feet on the yard main system. The lateral to each hydrant from the yard main

should be controlled by a visually indicating or key operated (curb) g. Comply with intent:

Hydrants are provided in the area of the power block at a spacing of approximately 325 feet. In other areas of the plant (Unit 2 excava-tion area) distances approach 400 feet. Sufficient hose lengths are provided in hose houses to permit fire fighters to reach all

areas between hydrants. Hydrants APPENDIX E E4.1-35 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION valve. A hose house, equipped with hose and combination nozzle, and other auxiliary equipment recommended in NFPA 24, "Outside Protection," should be provided as needed but at least every 1,000 feet.are controlled by individual curb box valves. Hose houses are provided for all hydrants in the power block area. Additional hose houses are provided for the

majority of hydrants outside the power block area. Distances never

exceed 1000 feet between hose houses. All hose houses are equipped in accordance with applicable NFPA 24 requirements. Threads compatible with those used by local fire departments should be provided on all hydrants, hose couplings, and standpipe risers. Threads compatible with those used by local fire departments are

provided for hydrants, hose couplings, and standpipe risers, or adapters are available. 3. Water Sprinklers and Hose Standpipe Systems a. Each automatic sprinkler system and manual hose station standpipe should have an independent connection to the plant underground water main. Headers fed from each end are permitted inside buildings to supply multiple sprinkler and standpipe systems. When provided, such headers are considered an extension of the yard main system. The header arrangement should be such that no single failure can impair both the primary and backup fire protection systems. a. Comply with intent: All sprinkler systems, with the exception of those in the diesel generator storage tank rooms, are supplied by ring headers that are supplied from redundant connections to the yard main.

The diesel generator storage

tank rooms and day tank rooms are not supplied by redundant connections; however, adequate hose lengths installed at nearby hose stations can be coupled together to attain a 150 foot maximum length, and permit secondary suppression capability in the event of a pipe break.

Those systems connected directly to the yard main are independent. Multiple sprinkler

and standpipe systems are supplied from independent connections to the building ring headers. OS&Y valves are provided for each sprinkler and standpipe system. A water flow alarm is also provided for each sprinkler and standpipe with the two APPENDIX E E4.1-36 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION exceptions. An alarm is not provided for the standpipe feeding two hose stations in the gate house, which is not part of the power block, and flow switch

IFS FP054, which is located on one of the three standpipes feeding containment hose stations, will alarm at a water flow of approximately 250 gpm.

This is acceptable for the following reasons: The piping is primarily of welded construction, which minimizes leakage. Access to the containment is normally restricted and inadvertent operation of the hoses is not likely. The flow switch will identify a pipe break in the hose station with a flow of approximately

250 gpm. If there is significant flow in the system, the main fire pumps will initiate, thereby annunciating in the control room. Each sprinkler and standpipe system should be equipped with OS&Y (outside screw and yoke) gate valve, or other approved shutoff valve, and

water flow alarm. Safety-related equipment that does not itself require sprinkler water fire protection, but is subject to unacceptable damage if wetted by sprinkler water discharge should be protected by water shields or baffles. Safe shutdown-related equipment that does not itself require sprinkler water fire protection, but is subject to unacceptable damage if wetted by sprinkler water discharge, will be

protected by water shields or baffles.

APPENDIX E E4.1-37 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION

b. All valves in the fire water systems should be electrically supervised. The electrical supervision signal should indicate in the control room and other appropriate command locations in the plant. (See

NFPA 26, "Supervision of Valves.")

When electrical supervision of fire protection valves is not practical, an adequate management supervision

program should be provided. Such a program should include locking valves open with strict key control; tamper-proof seals; and periodic visual check of all valves. b. Comply with intent: All main isolation valves will be electrically supervised or adminis-tratively controlled. The isolation valves for sprinkler systems, except for the filter train deluge systems, will be electrically supervised. The isolation valve for the FLEX diesel generator system is not electrically supervised but is locked open and

monitored by administrative procedures. The interior loop isolation valves and those for standpipes will not be electrically supervised, but will be monitored by administrative procedures. c. Automatic sprinkler systems should, as a minimum, conform to require-ments of appropriate standards such

as NFPA 13, "Standard for the Installation of Sprinkler Systems," and NFPA 15, "Standard for Water Spray Fixed Systems." c. Comply with intent: The automatic sprinkler systems conforms, with deviations, to all applicable NFPA codes, including NFPA 13 and 15, and include com-ponents approved by a nationally recognized laboratory such as UL, where practical. NFPA code conformance including deviations is documented in the CPS NFPA Code

Conformance Evaluation. d. Interior manual hose installation should be able to reach any location with at least one effective hose stream. To accomplish this, standpipes with hose connections equipped with a maximum of 75 feet of 1-1/2 inch woven jacket lined fire hose and suitable nozzles should be provided in all buildings, including containment, on all floors and should be spaced at not more than 100 foot intervals. Individual standpipes should be of at least 4 inch diameter for multiple hose connections and 2-1/2 inch diameter for single hose connections. These systems should follow the

requirements of NFPA No. 14 for sizing, spacing, and pipe support requirements. d. Comply with intent: The standpipe system will conform to the appropriate requirements of NFPA 14. All areas in the plant can be reached by at least one hose stream. Hose stations have a maximum of 100 feet of 1-1/2-inch hose with suitable spray nozzles.

Two hose stations (located outside

the main steam tunnel and outside the control room) have an additional 50 feet of hose stored nearby to provide adequate coverage. NFPA code conformance is documented in the CPS NFPA Code Conformance

Evaluation. Standpipes are a minimum of 4 inches in diameter for multiple-hose connections and a minimum of 2.5 inches in diameter for a single-hose connection.

APPENDIX E E4.1-38 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION Hose stations should be located outside entrances to normally unoccupied areas and inside normally occupied areas. Stand-pipes serving hose stations in areas housing safety-related equipment should have shutoff valves and pressure reducing devices (if applicable) outside the area. Hose stations are located to provide accessibility and coverage to all areas of the plant with the exception of the manually inaccessible pipe tunnel in Fire Zone A-3f, which is inaccessible for manual fire fighting and is provided with automatic suppression. A second exception exists for drywell Zone C-1, where coverage is provided only for the two recirculation water pumps. One hose station is located inside the drywell wall. An isolation valve is provided to fully isolate this station. All hose standpipes have shutoff valves. e. The proper type of hose nozzle to be supplied to each area should be based on the fire hazard analysis.

The usual combination spray/straight stream nozzle may cause unacceptable mechanical damage (for example, the delicate electronic equipment in the control room) and be unsuitable. e. Comply:

Consideration was given to the type of fire hazard and the safety of equipment in the selection of hose nozzles. Electrically safe hose nozzles provided at locations where electrical equipment or cabling is located. f. Certain fires such as those involving flammable liquids respond well to foam suppression. Consideration should be given to use of any of the available foams for such specialized protection application. These include the more common chemical and mechanical low expansion foams, high expansion foam, and the relatively new aqueous film forming foam (AFFF). f. Not applicable. Clinton design does not utilize foam systems, but instead utilizes water, CO 2 , and Halon systems. 4. Halon Suppression Systems The use of Halon fire extinguishing agents should, as a minimum, comply with the requirements of NFPA 12A and 12B, "Halogenated Fire Extinguishing

Agent Systems - Halon 1301 and Halon 1211." Only UL or FM approved agents should be used. 4. Comply with intent:

The Halon 1301 systems provided in the plant are designed and installed to the applicable requirements of NFPA 12A. NFPA code conformance is documented in the CPS NFPA Code Conformance

Evaluation. In addition to the guidelines of NFPA 12A and 12B, preventative maintenance Inspection and maintenance procedures will be conducted by authorized plant APPENDIX E E4.1-39 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION and testing of the systems, including check weighing of the Halon cylinders, should be done at least quarterly. Particular consideration should also be given to: personnel. Halon storage tank weight and pressure checks are performed periodically to ensure adequate system supply The Halon 1301 system for the Auxiliary Electric Equipment Room Panel (781' Control) is designed for total flooding and meets a Halon concentration of not less than 10% maintained for 10 minutes.

The Halon 1301 system for the Main Control Room Panels (800' Control) is designed for total flooding under floor of each protected MCR panel with a minimum Halon concentration of 6% by volume with 10 seconds of bottle initiation and sustained concentration of greater than or equal to 6% by volume after ten minutes.

This system is set to discharge a second bottle with similar concentration and soak time within a few minutes of the first bottle. a. Minimum required Halon concentration and soak time; b. Toxicity of Halon; and c. Toxicity and corrosive characteristics of thermal decomposition products of Halon. 5. Carbon Dioxide Suppression Systems The use of carbon dioxide extinguishing systems should, as a minimum, comply with the requirements of NFPA 12, "Carbon Dioxide Extinguishing Systems."Particular consideration should also be given to: 5. Comply:

All CO 2 systems will conform to the applicable requirements of NFPA 12. NFPA code conformance is documented in the CPS NFPA Code Conformance

Evaluation. a. Minimum required CO 2 concentration and soak time; The CPS CO 2 system was designed to comply minimum NFPA 12 requirements for CO 2 concentration and soak time. Provisions (horns, lights, signage) for personnel safety were installed. Thermal shock and overpressurization versus sealing have been accounted for.

The CO 2 System for each Diesel Generator (Division 1, 2, and 3) room is designed for b. Toxicity of CO 2; c. Possibility of secondary thermal shock (cooling) damage;

d. Offsetting requirements for venting during CO 2 injection to prevent over-pressurization versus sealing to prevent loss of agent;

APPENDIX E E4.1-40 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION e. Design requirements from over-pressurization; and total flooding and was tested to verify the design concentration minimum of 34% CO 2 was obtained within 1 minue and

maintained for 10 minutes.

The CO 2 System for the Main Turbine Exciter Enclosures is designed for local application with liquid CO 2 discharged at the nozzles for a minimum of 30 seconds, with the CO 2 discharge blanketing the protected hazard. f. Possibility and probability of CO 2 systems being out-of-service because of personnel safety consideration. CO 2 systems are disarmed whenever people are present in an area so protected.

Areas entered frequently (even though duration time for any visit is short) have often been found with

CO 2 systems shut off. Procedures have been written to caution personnel who will be working in areas

protected by CO 2 systems. 6. Portable Extinguishers Fire extinguishers should be provided in accordance with guidelines of NFPA 10 and 10A, "Portable Fire Extinguishers Installation, Maintenance and Use." Dry chemical extinguishers should be installed with due consideration given to cleanup problems after use and possible adverse effects on equipment installed in

the area. 6. Comply: Portable fire extinguishers are provided and will conform to the applicable

requirements of NFPA 10. NFPA code conformance is documented in the CPS NFPA Code Conformance Evaluation. F. GUIDELINES FOR SPECIFIC PLANT AREAS 1. Primary and Secondary Containment a Normal Operation Fire protection requirements for the primary and secondary containment areas should be provided on the basis of specific identified hazards.

For example: a. Comply with intent: Fire protection is provided based on the Fire Protection Evaluation Report.

APPENDIX E E4.1-41 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION i. Lubricating oil or hydraulic fluid system for the primary coolant pumps; i. Each reactor recirculation pump motor utilizes self-lubricating bearings with the lubricating oil cooled by cooling coils installed within the reservoirs. A pressurized

oil system is not used.

Infrared fire detection is provided for each pump with alarm and annunciation in the control room. All cables except those attached beneath the reactor or those for RR

pump vibration instrumentation are in raceways. ii. Cable tray arrangements and cable penetrations; and ii. Linear thermal detectors with alarm and annunciation in the

control room are provided for all cable trays containing safe shutdown cables in primary containment outside the drywell. In the same area all

safety related cable trays greater than approximately 40% full are provided with linear thermal detectors. iii. Charcoal filters. iii. Not applicable. No charcoal filters are located in the primary or secondary

containment. Fire suppression systems should be provided based on the fire hazard analysis. Fixed fire suppression capability should be provided for hazards that could jeopardize safe plant

shutdown. Automatic sprinklers are preferred. An acceptable alternate is automatic gas (Halon or CO

2) for hazards identified as requiring fixed suppression protection. An enclosure may be required to confine the agent if a gas

system is used. Such enclosures should Fire suppression systems have been provided based on the FPER. Portable fire extinguishers and hose stations are provided for manual firefighting in both primary and secondary

containment. The atmosphere of the reactor containment is not inerted during plant operation.

APPENDIX E E4.1-42 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION not adversely affect safe shutdown, or other operating equipment in containment.Automatic fire suppression capability need not

be provided in the primary

containment atmospheres that are inerted during normal operation. However, special fire protection requirements

during refueling and

maintenance operations should be satisfied as provided below. b. Refueling and Maintenance Refueling and maintenance operations in containment may introduce additional hazards such as

contamination control materials, decontamination supplies, wood planking, temporary wiring, welding, and flame cutting (with portable compressed fuel gas supply).

Possible fires would not necessarily

be in the vicinity of fixed detection

and suppression systems. Management procedures and con-trols necessary to assure adequate fire protection are discussed in Section 3a. b. Comply with intent: Procedures are in place which establish the controls to ensure adequate fire protection during

maintenance and refueling operations. Equivalent protection for portable systems should be provided if it is impractical to install standpipes with hose stations. Hose stations and portable extinguishers are provided as shown on the fire protection drawings. Adequate self-contained breathing apparatus should be provided near the containment entrances for fire fighting and damage control personnel. These units should be independent of any breathing apparatus or air supply systems provided for general plant activities. Adequate self-contained breathing apparatus will be provided for emergency teams. This equipment will be maintained in emergency kits in strategic locations throughout the plant. 2. Control Room The control room is essential to safe reactor operation. It must be protected against disabling fire damage and should be separated from other areas of the 2. Comply with intent: The control room complex (including computers) is separated from other areas of the plant by floors and ceilings having a fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The APPENDIX E E4.1-43 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION plant by floors, walls, and roofs having minimum fire resistance ratings of three hours. supporting steel has a 3-hour protective covering. The control room is protected from a fire in the peri-pheral rooms by a 1.9-hour fire rated barrier (see Figures FP-14a and b). Control room cabinets and consoles are subject to damage from two distinct fire hazards: Comply: Ionization detection is provided in the control room area and in cabinets and consoles. The control room is part of the PGCC designed by GE. The PGCC is provided with a Halon fire suppression system. The design of the PGCC is addressed in GE Licensing Topical

Report NED0-10466-A. a. Fire originating within a cabinet or console; and

b. Exposure fire involving combustibles in the general room area.

Hose stations adjacent to the control room with portable extinguishers in the control room are acceptable. Comply: Hose stations and portable fire extinguishers are adjacent to, and portable fire extinguishers are located in, the control room. Nozzles that are compatible with the hazards and equipment in the control

room should be provided for the manual hose station. The nozzles chosen should satisfy actual fire-fighting needs, satisfy electrical safety, and minimize physical damage to electrical equipment

from hose stream impingement. Comply. Fire protection in the control room cabinets and consoles should be provided by smoke and heat detectors in each fire area. Alarm and annunciation should be provided in the control room.

Fire alarms in other parts of the plant should also be alarmed and annunciated in the control room. Comply: The PGCC Halon fire suppression system provides ionization fire detection in control room cabinets and consoles, and alarms and annunciators in the control room.

Fire alarms in other parts of the station are also alarmed and annunciated in the

control room. Breathing apparatus for control room operators should be readily available.

Control room floors, ceilings, supporting structures, and walls, including penetra-tions and doors, should be designed to a minimum fire rating of three hours. All Comply with intent: A manifold breathing air system is provided for control room operators.

Control room floors, ceilings, and supporting structures, including pene-APPENDIX E E4.1-44 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION penetration seals should be airtight. trations and doors, are designed to a minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The north and west walls are 3-hour rated. The south and east walls are 1.9-hour rated.

All fire rated penetration seals are airtight. Manually operated ventilation systems are acceptable. Manually operated ventilation systems are provided. Cables should not be located in concealed floor and ceiling spaces. All cables that enter the control room should terminate in the control room. That is, no cabling should be simply routed through the control room from one area to another. If such concealed spaces are used, however, they should have fixed automatic total flooding Halon protection. Comply with intent: Generally, all cables that enter the control room terminate there. Fire detection is provided above the non-combustible suspended ceiling in the control room.

The PGCC Halon fire suppression system provides fire detection and automatically initiated suppression for the PGCC floor sections. 3. Cable Spreading Room

a. The preferred acceptable methods are: 1. Automatic water system such as closed head sprinklers, open head deluge, or open directional spray nozzles. Deluge and

open spray systems should

have provisions for manual operation at a remote station; however, there should also be provisions to reclude inadvertent operation. Location of sprinkler heads or spray nozzles should consider cable tray sizing and arrangements to assure adequate water coverage. Cables should be designed to allow wetting down with deluge water without electrical faulting. Open head deluge and open directional spray systems should be zoned so that a single failure will not deprive the entire area of auto-matic fire suppression capability. The use of foam is acceptable provided it is of a type capable of being delivered by a sprinkler or deluge system, such as an Aqueous Film 1. Comply:

An automatic wet pipe system is provided for the Division 1 and Division 2 cable spreading rooms. Locations of sprinkler heads consider cable tray sizing, arrangement, and obstructions to ensure adequate water coverage. All cables and their installation are designed to be wetted without electrical failure.

APPENDIX E E4.1-45 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION Forming Foam (AFFF). 2. Manual hoses and portable extinguishers should be provided as backup. 2. Comply: Hose stations are readily accessible from both entrances to each cable spreading room. In addition, hose stations and portable fire extinguishers are provided inside each cable spreading room. 3. Each cable spreading room of each unit should have divisional cable separation, and be separated from the other and the rest of the plant by a minimum three hour rated fire wall (refer to NFPA 251 or ASTM E-119 for fire test resistance rating). 3. Comply with intent: Each cable spreading room is separated from the other by

two 1.9-hour fire rated walls that contain the auxiliary electric room, except for a small portion of a 1.9-hour fire

rated wall where they abut

together. The auxiliary electrical equipment room is also protected by an automatic preaction sprinkler system.

The floor and ceiling of each cable spreading room is 3-hour fire rated. The north and west walls are 3-hour fire rated, and the south and east walls are 1.9-hour fire rated. For details of the separation of cable spreading areas of the plant, refer to Section 3.0 and the SSA. 4. At least two remote and separate entrances are provided to the room for access by fire brigade personnel. 4. Comply: Each cable spreading room has at least two remote and separate entrances for access by the plant fire brigade. 5. Aisle separations provided between tray stacks should be at least three feet wide and eight feet high. 5. Comply:

Main aisle separations provided between tray stacks are at least 3 feet wide and 8 feet high.

APPENDIX E E4.1-46 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION b. For cable spreading rooms that do not provide divisional cable separa-tion of a.3., in addition to meeting a.1., 2., 4., and 5. above, the following should also be provided: b. Not applicable based on Section F.3.a. and the Safe Shutdown Analysis. 1. Divisional cable separation should meet the guidelines of

Regulatory Guide 1.75, "Physical Independence of Electric Systems." 2. All cabling should be covered with a suitable fire-retardant coating. 3. As an alternate to a.1. above, automatically initiated gas systems (Halon or CO

2) may be used for primary fire suppres-sion, provided a fixed water system is used as a backup. 4. Plants that cannot meet the guidelines of Regulatory Guide 1.75, in addition to meet-ing a.1., 2., 4., and 5. above, an

auxiliary shutdown system with all cabling independent of the cable spreading room should be

provided. 4. Plant Computer Room Safety-related computers should be separated from other areas of the plant by barriers having a minimum three hour fire resistant rating. Automatic fire detection should be provided to alarm and annunciate in the control room and alarm locally. Manual hose stations and

portable water and Halon fire extinguishers should be provided. 4. Not applicable: The computer is not safety-related, but is an integral part of the GE PGCC control room complex and cannot be separated from the control room. Automatic fire detection, as well as manual hose stations and portable fire extinguishers, are provided. 5. Switchgear Rooms Switchgear rooms should be separated from the remainder of the plant by mini-mum three hour rated fire barriers to the extent practicable. Automatic fire detec-tion should alarm and annunciate in the

control room and alarm locally. Fire hose stations and portable extinguishers 5. Comply (except as noted): Division 1 and 2 switchgear areas are separated from each other and other plant areas by 3-hour fire rated barriers.

The Division 3 switchgear area is enclosed by 1.9-hour fire-rated barriers. The switchgear rooms do not have automatic suppression systems but do APPENDIX E E4.1-47 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION should be readily available. Acceptable protection for cables that pass through the switchgear room is automatic water or gas agent suppres-sion. Such automatic suppression must consider preventing unacceptable damage to electrical equipment and possible necessary containment of agent following discharge. have automatic detection that alarms and annunciates in the control room. Hose stations and portable fire extinguishers are readily accessible to the areas.

Detectors do not alarm locally. 6. Remote Safety-Related Panels The general area housing remote safety-related panels should be provided with automatic fire detectors that alarm locally and alarm and annunciate in the control room. Combustible materials should be controlled and limited to those required for operation. Portable extinguishers and manual hose stations should be

provided. 6. Comply with intent: Detection is provided throughout the zone containing the remote shutdown panel that alarms and annunciates in the control

room. As required by the Safe Shutdown Analysis, other general areas have detection that alarms in the main control

room to protect any required safe shutdown components. Detectors do not

alarm locally. Combustible materials are controlled and limited to those required for operation. Portable extinguishers and manual hose stations are provided. 7. Station Battery Rooms Battery rooms should be protected against fire explosions. Battery rooms should be separated from each other and other areas of the plant by barriers having a minimum fire rating of three hours inclusive of all penetrations and openings. (See NFPA 69, "Standard on

Explosion Prevention Systems.") 7. Comply: Battery rooms are protected against fire and explosions. Safe shutdown battery rooms are enclosed by 3-hour fire

barriers. Other battery rooms have 1.9-hour fire rated barrier enclosures. Ventilation systems in the battery rooms should be capable of maintaining the hydrogen concentration well below 2 vol.

% hydrogen concentration. Standpipe and hose and portable extinguishers should be provided.

Alternatives: Ventilation is designed to maintain hydrogen concentrations below 2% for the maximum postulated rate of hydrogen release. Fire hose stations and portable extinguishers are accessible to the battery rooms. Loss of ventilation is alarmed in the control room. a. Provide a total fire rated barrier enclosure of the battery room complex that exceeds the fire load contained in the room, a. Comply.

APPENDIX E E4.1-48 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION b. Reduce the fire load to be within the fire barrier capability of 1-1/2 hours, or b. Not applicable. c. Provide a remote manual actuated sprinkler system in each room and

provide the 1-1/2 hour fire barrier separation. c. Not applicable. 8. Turbine Lubrication and Control Oil Storage and Use Areas A blank fire wall having a minimum resistance rating of three hours should separate all areas containing safety-related systems and equipment from the turbine oil system. When a blank wall is not present, open head deluge protection should be provided for the turbine oil hazards, and automatic open head water curtain protection should be provided for wall openings. 8. Comply: The turbine oil area is separated from all safety-related equipment by walls having

a 3-hour rating, except the main steam tunnel on elevation 755 feet of the turbine building (see Subsection .2.2.2 of the Safe Shutdown Analysis). In general, tubine oil hazards are protected by wet-pipe automatic sprinkler systems. There are safety-related cables and instruments located in the turbine oil area; however, they are not required for safe shutdown. 9. Diesel Generator Areas Diesel generators should be separated from each other and other areas of the

plant by fire barriers having a minimum fire resistance rating of three hours.

Automatic fire suppression such as AFFF foam, or sprinklers, should be installed to combat any diesel generator or lubricating oil fires. Automatic fire detection should be provided to alarm and annunciate in the control room and alarm locally. Drainage for fire fighting

water and means for local manual

venting of smoke should be provided. 9. Comply:

The three safety-related standby, emergency diesel generators are separated from each other and all other plant equipment by 3-hour rated enclosures. An automatic total flooding

CO 2 system is provided for each diesel generator room. The automatic fire detection provided alarms and annunciates in the control room and

alarms locally. Drainage for fire-fighting water is provided. Means for local manual venting of smoke is provided as described in the CPS Smoke Removal Plan. When day tanks cannot be separated from the diesel generator, one of the following should be provided for the diesel generator area:

The day tanks are separated from the diesel generator by a 1.9-hour fire rated enclosure. An automatic wet-pipe sprinkler system is provided for the day tanks. Ionization fire detection will be provided for each day tank room that alarms and annunciates in the control room. a. Automatic open head deluge or open head spray nozzle system(s), b. Automatic closed head sprinklers, APPENDIX E E4.1-49 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION c. Automatic AFFF that is delivered by a sprinkler deluge or spray system, or d. Automatic gas system (Halon or CO 2) may be used in lieu of foam or sprinklers to combat diesel generator and/or lubricating oil fires.

10. Diesel Fuel Oil Storage Areas Diesel fuel oil tanks with a capacity greater than 1,100 gallons should not be located inside the buildings containing

safety-related equipment. They should be located at least 50 feet from any building containing safety-related equipment, or if located within 50 feet, they should be housed in a separate building with construction having a minimum fire resistance rating of three hours. Buried tanks are considered as meeting the three hour fire resistance requirements. See NFPA 30, "Flammable and Combustible Liquids Code," for additional guidance. 10. Comply with intent: The diesel generator oil day tanks (600 gallons) are totally enclosed in 1.9-hour rated structures, and are

protected by an automatic wet-pipe sprinkler system. The diesel generator oil storage tanks (nominally 35,000/50,000 gallons) are located directly below the diesel generators and are not buried. They are totally enclosed in a 3-hour rated

structure. Fire suppression capability consists of automatic wet-pipe sprinkler with hose stations and portable fire extinguishers as backups. An ionization fire detection system that alarms and annunciates in the control room will be provided for each oil storage room. When located in a separate building, the tank should be protected by an automatic fire suppression system such as AFFF or sprinklers. Not applicable: Diesel tanks are located in the same building. In operating plants where tanks are located directly above or below the diesel generators and cannot reasonably be moved, separating floors and main structural members should, as a minimum, have a fire resistance rating of three hours. Floors should be liquid tight to prevent leaking of possible oil spills from one level to another. Drains should be provided to remove possible oil spills and fire-fighting water to a safe location.

Structural members are concrete encased to provide a 3-hour fire rating. Doors are located 7 feet 6 inches above the finish floor to prevent oil from spreading to other zones in the unlikely event of an oil spill. Drains are provided to remove possible oil spills and fire-fighting water to a local sump. One of the following acceptable methods of fire protection should also be

provided:

APPENDIX E E4.1-50 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION a. Automatic open head deluge or open head spray nozzle system(s); a. Not applicable. b. Automatic closed head sprinklers; or b. Comply. c. Automatic AFFF that is delivered by a sprinkler system or spray c. Not applicable. 11. Safety-Related Pumps Pump houses and rooms housing safety-related pumps should be protected by automatic sprinkler protection unless a fire hazards analysis can demonstrate that a fire will not endanger other safety-related equipment required for safe plant

shutdown. Early warning fire detection should be installed with alarm and annunciation locally and in the control room. Local hose stations and portable extinguishers should also be provided. 11. Comply with intent: Fire protection and detection are provided in accordance with the FPER and SSA. The SSA demonstrates that the plant will maintain the ability to perform safe shutdown functions. Fire hose stations and portable fire extinguishers are located in the area 12. New Fuel Area Hand portable extinguishers should be located within this area. Also, local hose stations should be located outside but within hose reach of this area.

Automatic fire detection should alarm and annunciate in the control room and alarm locally. Combustibles should be limited to a minimum in the new fuel area. The storage area should be provided with a drainage system to preclude accumulation of water. 12. Comply (except as noted below): An ionization type smoke detection system is provided which annunciates and alarms in the control room. Detectors do not alarm locally. Fire hose stations and portable extinguishers are located within the area. Combustibles are limited

to a minimum in the new fuel area. The storage area is provided with a drainage system to preclude accumulation of water. The storage configuration of new fuel should always be so maintained as to preclude criticality for any water density that might occur during fire water application. The storage configuration of new fuel will always be maintained so as to preclude criticality. 13. Spent Fuel Pool Area Protection for the spent fuel pool area should be provided by local fire hose stations and portable extinguishers.

Automatic fire detection should be provided to alarm and annunciate in the control room and to alarm locally. 13. Comply (except as noted below): An ionization type smoke detection system is provided which annunciates and alarms in the control room. Detectors do not alarm locally. Fire hose stations and portable fire extinguishers are located in the area. 14. Radwaste Building The radwaste building should be separated from other areas of the plant 14. Comply: The radwaste building is separated from safety-related areas of the plant APPENDIX E E4.1-51 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION by fire barriers having at least three hour ratings. Automatic sprinklers should be used in all areas where combustible materials are located. by 3-hour fire barriers. Automatic preaction sprinklers are provided for the radwaste building paint/oil storage room and baler areas. Automatic fire detection should be provided to annunciate and alarm in the

control room and alarm locally. During a fire, the ventilation systems in these areas should be capable of being isolated. Water should drain to liquid

radwaste building sumps. The sprinkler systems alarm and annunciate in the control room and alarm

locally. Automatic fire detection is provided in selected areas which annunciates and alarms in the control room. The ventilation systems are capable of being isolated. Adequate drainage has been provided to the liquid radwaste building sumps. Acceptable alternative fire protection is automatic fire detection to alarm and annunciate in the control room, in addition to manual hose stations and portable extinguishers consisting of handheld and large wheeled units. Fire hose stations and portable fire extinguishers are located throughout the building with the exception of high-radiation areas. Extinguishers located outside of these areas can be brought in for manual fire fighting. 15. Decontamination Areas The decontamination areas should be protected by automatic sprinklers if flammable liquids are stored. Automatic fire detection should be provided to annunciate and alarm in the control room

and alarm locally. The ventilation system should be capable of being isolated. Local hose stations and hand portable extinguishers should be provided as backup to the sprinkler system. 15. Comply:

Manual fire fighting equipment is provided, consisting of fire hose stations and portable fire extinguishers. Automatic suppression and detection is not provided in this area since flammable materials will not be stored there. The ventilation systems are capable of being isolated.

APPENDIX E E4.1-52 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION 16. Safety-Related Water Tanks Storage tanks that supply water for safe shutdown should be protected from the effects of fire. Local hose stations and portable extinguishers should be provided. Portable extinguishers should be located in nearby hose houses.

Combustible materials should not be stored next to outdoor tanks. A minimum of 50 feet of separation should be provided between outdoor tanks and combustible materials where feasible. 16. Not applicable: Storage tanks that supply water for safe shutdown are not employed in the Clinton Power Station design. 17. Cooling Towers Cooling towers should be of noncombus-tible construction or so located that a fire will not adversely affect any safety-related systems or equipment. Cooling towers should be of noncombustible construction when the basins are used for the ultimate heat sink or for the fire protection water supply. Cooling towers of combustible construction, so located that a fire in them could adversely affect

safety-related systems or equipment, should be protected with an open head deluge system installation with hydrants and hose houses strategically located. 17. Not applicable: Cooling towers are not employed in the Clinton Power Station design. 18. Miscellaneous Areas Miscellaneous areas such as records storage areas, shops, warehouses, and auxiliary boiler rooms should be so located that a fire or effects of a fire, including smoke, will not adversely affect any safety-related systems or equipment. Fuel oil tanks for auxiliary boilers should be buried or provided with dikes to contain the entire tank contents. 18. Comply: The records storage area, machine shop, and storerooms are located in the radwaste and service buildings and are

remote from safety-related equipment.

The storeroom in the radwaste building has an overhead sprinkler system. The auxiliary boiler system employs an electrode boiler and steam reboiler, and is located in non-safety-related buildings.

No oil-fired equipment is present.

APPENDIX E E4.1-53 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION G. SPECIAL PROTECTION GUIDELINES 1. Welding and Cutting Acetylene-Oxygen Fuel Gas Systems This equipment is used in various areas throughout the plant. Storage locations should be chosen to permit fire protection by automatic sprinkler systems. Local hose stations and portable equipment should be provided as backup. The requirements of NFPA 51 and 51B are applicable to these hazards. A permit system should be required to utilize this equipment. (Also refer to 2f herein. 1. Comply: Combustible gas tanks are stored in the radwaste building storeroom and are protected by an automatic preaction system. Use of combustible gases will be controlled in accordance with approved procedures. Local hose stations andportable extinguishers will be utilized for additional fire protection as required. 2. Storage Areas for Dry Ion Exchange Resins Dry ion exchange resins should not be stored near essential safety-related systems. Dry unused resins should be protected by automatic wet pipe sprinkler installations. Detection by smoke and heat detectors should alarm and annunciate in the control room and alarm locally. Local hose stations and portable extinguishers should provide backup for these areas. Storage areas of dry resin should have curbs and drains. (Refer to NFPA 92M, "Waterproofing and Draining of Floors." 2. Partial compliance: New resins (greater than or equal to 70% moisture) will be stored in an area remote from safety-related equipment or stored in a fire retardant container. Local hose stations and portable extinguishers provide the primary means of protection. 3. Hazardous Chemicals Hazardous chemicals should be stored and protected in accordance with the recommendations of NFPA 49, "Hazardous Chemicals Data."

Chemicals storage areas should be well ventilated and protected against flooding conditions since some chemicals may react with water to produce ignition. 3. Comply: Permanent storage of hazardous chemicals is in accordance with NFPA 49.

Chemical storage areas are well ventilated and protected against flooding conditions. NFPA code conformance is documented in the CPS NFPA Code Conformance Evaluation.

APPENDIX E E4.1-54 REV. 19, OCTOBER 2017 BTP APCSB 9.5-1, APPENDIX A, PLANTS UNDER CONSTRUCTION AND OPERATING PLANTS APPLICANT'S POSITION 4. Materials Containing Radioactivity Materials that collect and contain radioactivity such as spent ion exchange resins, charcoal filters, and HEPA filters should be stored in closed metal tanks or containers that are located in areas free

from ignition sources or combustibles. These materials should be protected from exposure to fires in adjacent areas as well. Consideration should be given to requirements for removal of isotopic

decay heat from entrained radioactive materials. 4. Comply: Materials that could collect radioactivity will be stored in closed metal containers and will be protected from other fire areas. Consideration has been given to decay heat which wouldcome from any entrained radioactive materials

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