RS-18-144, Amendment 28 to Fire Protection Report, Chapter 4, Fire Protection Program

Amendment 28 to Fire Protection Report, Chapter 4, Fire Protection Program

ML18355A558
Person / Time
Site:	Byron, Braidwood
Issue date:	12/17/2018
From:	Exelon Generation Co
To:	Office of Nuclear Reactor Regulation, Office of Nuclear Material Safety and Safeguards
Shared Package
ML18355A456	List: ML19168A119 ML19168A216 ML19169A023 ML19169A113 ML19170A007 ML19170A012 ML19170A311 ML19170A336 ML19170A347 ML19170A384 ML19170A387 RS-18-144, Amendment 28 to Fire Protection Report, Chapter 4, Fire Protection Program
References
RS-18-144
Download: ML18355A558 (2)

Text

B/BAMENDMENT 24 DECEMBER 2010 4.0-1 4.0 FIRE PROTECTION PROGRAM The fire protection program at Byron and Braidwood is implemented through station administrative procedures, which specifically address all aspects of the fire protection program, ranging from establishing and training of the

fire brigade, to surveillance and testing of fire protection systems, and

remedial actions for systems or equipment out of service.

The following fire protection features will be subjected to periodic tests and inspections:a.Fire alarm and detection systems b.Wet pipe sprinkler systems c.Deluge systems d.Halon 1301 system e.Carbon dioxide system f.Foam application system g.Fire pumps h.Fire barriers (walls, fire doors, penetration seals, fire dampers) i.Manual suppression (fire hoses, extinguishers, hydrants)

Equipment out of service including fire suppression, detection, and barriers will be controlled through the administrative program and appropriate remedial actions taken. The program requires all impairments to fire protection system

to be identified and appropriate notification given to the Fire Marshall for

evaluation. Based on the condition, engineering analysis may be required to determine the extent of the fire hazard to safe plant operations. As

conditions warrant remedial actions would include compensatory measures to

ensure equivalent level of fire protection in addition to timely efforts to

effect repairs and restore equipment to service.

Inspection, testing and maintenance surveillance/predefine activities for the fire protection systems are controlled by the Company's Predefine Program, as described by administrative procedure. This program utilizes an electronic predefine database designed to prompt the scheduling and performance of all predefine activities entered into the system.

B/BAMENDMENT 25 DECEMBER 2012 4.0-2 Fire protection surveillance/predefine activities conform to the following general requirements:

Crediting PredefinesUnplanned events may satisfy the testing requirement for a given

surveillance/predefine activity. In this case, the unplanned event may be

credited as fulfilling the performance of the surveillance/predefine activity, provided it meets all the requirements of the activity being credited.

Inoperable/Unavailable Equipment Surveillance/predefine activities do not have to be performed on

inoperable/unavailable equipment as long as the equipment is administratively

controlled, with compensatory measures implemented as appropriate. Applicable

surveillance/predefine activities have to be performed, with the specified

requirements of the surveillance/predefine activity being met, prior to

returning equipment to operable/available status.

Post Maintenance TestingUpon completion of maintenance appropriate post maintenance testing is

required to declare the equipment operable/available. This includes ensuring

applicable surveillance/predefine activities are current, with their most

recent performance meeting all the applicable requirements.

Grace period A 25% extension of the frequency interval specified for the

surveillance/predefine activity is permitted to facilitate scheduling of the

activity and to provide consideration for unit operating conditions that may not be suitable for conducting the surveillance/predefine activity (e.g.

transient conditions or other ongoing surveillance maintenance activities).

This 25% extension does not significantly degrade the reliability that results

from performing the surveillance/predefine activity at its specified

frequency. This is based on the recognition that the most probable result of

any particular surveillance/predefine activity being performed is the

verification of conformance with the requirements for the

surveillance/predefine activity.

The 25% surveillance/predefine activity frequency interval extension is not

intended to be used repeatedly merely as an operational convenience to extend

surveillance/predefine activity frequency intervals.The fire protection program is covered by Exelon Generation Company, LLC Quality Assurance Topical Report (QATR). Fire protection activities are thus subject to audit under the applicable portions of the QA program to ensure proper implementation and compliance with commitments.