ML080280567

January 2008 - Transition to National Fire Protection Association (NFPA) 805 - Example Table B-1, Shearon Harris Nuclear Power Plant, Unit 1, January 7, 2008

ML080280567
Person / Time
Site:	Harris
Issue date:	01/07/2008
From:	Ertman J Progress Energy Co
To:	Office of Nuclear Reactor Regulation
Oudinot D
References
Download: ML080280567 (33)

Text

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.1 General 3.1* General. N/A N/A - General statement; No technical Plant USA-M/BMRK-0011, All This chapter contains the fundamental elements of the fire requirements Code Compliance Evaluation protection program and specifies the minimum design NFPA 805,2003,, Rev. 000, requirements for fire protection systems and features.

These fire protection program elements and minimum design requirements shall not be subject to the performance-based methods permitted elsewhere in this standard. Previously approved alternatives from the fundamental protection program attributes of this chapter by the AHJ take precedence over the requirements contained herein.

3.2 Fire Protection Plan N/A N/A N/A - General statement; No technical , , Rev. ,

requirements 3.2.1 Intent 3.2.1 Intent. Complies No Additional Clarification , , Rev. ,

A site-wide fire protection plan shall be established. This plan shall document management policy and program direction and shall define the responsibilities of those individuals responsible for the plans implementation. This section establishes the criteria for an integrated combination of components, procedures, and personnel to implement all fire protection program activities 3.2.2 Management Policy 3.2.2* Management Policy Direction and Responsibility. Complies No Additional Clarification , , Rev. ,

Direction and A policy document shall be prepared that defines Responsibility. management authority and responsibilities and establishes the general policy for the site fire protection program.

3.2.2.1 [Management 3.2.2.1* Complies No Additional Clarification , , Rev. ,

Policy on Senior The policy document shall designate the senior Management] management position with immediate authority and responsibility for the fire protection program.

3.2.2.2 [Management 3.2.2.2* Complies No Additional Clarification , , Rev. ,

Policy on Daily The policy document shall designate a position Administration] responsible for the daily administration and coordination of the fire protection program and its implementation.

3.2.2.3 [Management 3.2.2.3* Complies No Additional Clarification , , Rev. ,

Policy on Interfaces] The policy document shall define the fire protection interfaces with other organizations and assign responsibilities for the coordination of activities. In addition, this policy document shall identify the various plant positions having the authority for implementing the various areas of the fire protection program.

3.2.2.4 [Management 3.2.2.4* Further Action , , Rev. ,

Policy on AHJ] The policy document shall identify the appropriate AHJ for Required the various areas of the fire protection program.

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.2.3 Procedures 3.2.3* Procedures. Complies No Additional Clarification , , Rev. ,

Procedures shall be established for implementation of the fire protection program. In addition to procedures that could be required by other sections of the standard, the procedures to accomplish the following shall be established:

(1)

• Inspection, testing, and maintenance for fire protection systems and features credited by the fire protection program (2)

• Compensatory actions implemented when fire protection systems and other systems credited by the fire protection program and this standard cannot perform their intended function and limits on impairment duration (3)

• Reviews of fire protection program related performance and trends (4) Reviews of physical plant modifications and procedure changes for impact on the fire protection program (5) Long-term maintenance and configuration of the fire protection program (6) Emergency response procedures for the plant industrial fire brigade.

3.3 Prevention 3.3 Prevention. N/A N/A - General statement; No technical , , Rev. ,

A fire prevention program with the goal of preventing a fire requirements from starting shall be established, documented, and implemented as part of the fire protection program. The two basic components of the fire prevention program shall consist of both of the following:

(1) Prevention of fires and fire spread by controls on operational activities (2) Design controls that restrict the use of combustible materials The design control requirements listed in the remainder of this section shall be provided as described.

3.3.1 Fire Prevention for 3.3.1 Fire Prevention for Operational Activities. Complies No Additional Clarification NLS-86-137, Point by Point Operational Activities. The fire prevention program activities shall consist of the Comparison of Plant USA to necessary elements to address the control of ignition Requirements of NUREG sources and the use of transient combustible materials 0800, Rev. , 5/7/1986 during all aspects of plant operations. The fire prevention program shall focus on the human and programmatic elements necessary to prevent fires from starting or, should a fire start, to keep the fire as small as possible.

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.3.1.1 General Fire 3.3.1.1 General Fire Prevention Activities. (1) Further Action FAQ 06-0028 Rev 0 , , Rev. ,

Prevention Activities. The fire prevention activities shall include but not be Required limited to the following program elements:

(1) Training on fire safety information for all employees and contractors including, as a minimum, familiarization with plant fire prevention procedures, fire reporting, and plant emergency alarms (2)

• Documented plant inspections including provisions for corrective actions for conditions where unanalyzed fire hazards are identified (3)

• Administrative controls addressing the review of plant modifications and maintenance to ensure that both fire hazards and the impact on plant fire protection systems and features are minimized.

(2) Complies No Additional Clarification OMM-001, Operations-Conduct of Operations, Rev. 067, AP-930, Plant Observation Program, Rev. 005, AP-003, General Plant Personnel Safety and Housekeeping, Rev. 026, (3) Complies No Additional Clarification EGR-NGGC-0005, Engineering Change, Rev.

026, ADM-NGGC-0104, Work Management Process, Rev.

030, Plant USA Page 3 of 33 1/3/2008 Test Plant USA for Transition Report Examples Jan. 2008.mdb Transition Tool Version 1.0.4

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.3.1.2 Control of 3.3.1.2* Control of Combustible Materials. (1) Complies FAQ 06-0019 Rev 0 , , Rev. ,

Combustible Materials Procedures for the control of general housekeeping practices and the control of transient combustibles shall be developed and implemented. These procedures shall include but not be limited to the following program elements:

(1)

• Wood used within the power block shall be listed pressure-impregnated or coated with a listed fire-retardant application.

Exception: Cribbing timbers 6 in. by 6 in. (15.2 cm by 15.2 cm) or larger shall not be required to be fire-retardant treated.

(2) Plastic sheeting materials used in the power block shall be fire-retardant types that have passed NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, large-scale tests, or equivalent.

(3) Waste, debris, scrap, packing materials, or other combustibles shall be removed from an area immediately following the completion of work or at the end of the shift, whichever comes first.

(4)

• Combustible storage or staging areas shall be designated, and limits shall be established on the types and quantities of stored materials.

(5)

• Controls on use and storage of flammable and combustible liquids shall be in accordance with NFPA 30, Flammable and Combustible Liquids Code, or other applicable NFPA standards.

(6)

• Controls on use and storage of flammable gases shall be in accordance with applicable NFPA standards.

(2) Complies FAQ 06-0019 Rev 0 , , Rev. ,

(3) LAR , , Rev. ,

(4) Complies No additional clarification , , Rev. ,

(5) Complies with FAQ 06-0020 Rev 0 , , Rev. ,

Clarification (6) Complies No additional clarification , , Rev. ,

3.3.1.3 Control of Ignition 3.3.1.3 Control of Ignition Sources N/A N/A - General statement no technical , , Rev. ,

Sources requirements 3.3.1.3.1 [Control of 3.3.1.3.1* Further Action FAQ 06-0020 Rev 0 FIR-NGGC-0003, Hot Work All Ignition Sources Code A hot work safety procedure shall be developed, Required Permit, Rev. 001, Requirements] implemented, and periodically updated as necessary in accordance with NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, and NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations.

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.3.1.3.2 [Control of 3.3.1.3.2 Complies with Smoking is prohibited inside all site structures, AP-003, General Plant Section 6.2.6.5 Ignition Sources on Smoking and other possible sources of ignition shall be Clarification and only allowed in specific designated outside Personnel Safety and Smoking Limitations] restricted to properly designated and supervised safe areas per procedure AP-003. Restrictions for Housekeeping, Rev. 026, areas of the plant. other possible ignition sources are addressed by section 3.3.1.3.1,3,4.

3.3.1.3.3 [Control of 3.3.1.3.3 Complies No Additional Clarification , , Rev. ,

Ignition Sources for Leak Open flames or combustion-generated smoke shall not be Testing] permitted for leak or air flow testing 3.3.1.3.4 [Control of 3.3.1.3.4* Further Action AP-003, General Plant Section 5.3 Ignition Sources on Plant administrative procedure shall control the use of Required Personnel Safety and Portable Heaters] portable electrical heaters in the plant. Portable fuel-fired Housekeeping, Rev. 026, heaters shall not be permitted in plant areas containing equipment important to nuclear safety or where there is a potential for radiological releases resulting from a fire.

3.3.2 Structural. 3.3.2 Structural. Complies Via Submittal Document NLS-86-137 Project NUREG-1038, Safety SER - SSER4 Walls, floors, and components required to maintain Previous Approval Conformance C.5.a(9) - "Interior walls and Evaluation Report Related to Section C.5.A(9) structural integrity shall be of noncombustible structural components, radiation shielding the Operation of the Plant construction, as defined in NFPA 220, Standard on Types materials, and soundproofing are USA Nuclear Power Plant, of Building Construction. noncombustible." Units 1 and 2 - Docket Nos.

STN-50-400 and STN 50-401, NUREG 1038 states in part "Interior walls and Rev. Original, 11/1/1983 structural components, are noncombustible or NLS-86-137, Point by Point are listed by a nationally recognized testing Comparison of Plant USA to laboratory, such as Factory Mutual (FM) or UL, Requirements of NUREG or have flame-spread, smoke, and fuel 0800, Rev. , 5/7/1986 contribution of 25 or less. The staff finds this in accordance with the guidelines of BTP CMEB 9.5-1 Section C.5.a, and, therefore acceptable."

3.3.3 Interior Finishes 3.3.3 Interior Finishes. Complies No Additional Clarification NUREG-1038, Safety Section 9.5.1.4 Interior wall or ceiling finish classification shall be in Evaluation Report Related to accordance with NFPA 101, Life Safety Code, the Operation of the Plant requirements for Class A materials. Interior floor finishes USA Nuclear Power Plant, shall be in accordance with NFPA 101 requirements for Units 1 and 2 - Docket Nos.

Class I interior floor finishes. STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 Plant USA Page 5 of 33 1/3/2008 Test Plant USA for Transition Report Examples Jan. 2008.mdb Transition Tool Version 1.0.4

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.3.4 Insulation Materials 3.3.4 Insulation Materials. Further Action LAR - HVAC DUCT , , Rev. ,

Thermal insulation materials, radiation shielding materials, Required SER - Approval for runner material in HVAC ventilation duct materials, and soundproofing materials duct shall be noncombustible or limited combustible. Section C.5.a of BTP CMEB 9.5-l states that flexible air duct coupling in ventilation and filter systems should be noncombustible. In Revision 3 to the comparison with BTP CMEB 9.5-1, the applicant informed the staff that combustible flexible air duct coupling is utilized in ventilation and filter systems at Harris. The applicant conservatively estimated that this combustible material constitutes less than 1.5% of the total ductwork footage and that there are no large concentrations of the material in any plant area. On the basis of its limited use, the staff concludes that the combustible flexible duct couplings will not contribute appreciably to the spread of fire.

This is, therefore, an acceptable deviation from Section C.5.a of BTP CMEB 9.5-l.

3.3.5 Electrical. N/A N/A N/A - General statement; No technical , , Rev. ,

requirements 3.3.5.1 [Electrical Wiring 3.3.5.1 Complies No Additional Clarification NLS-86-137, Point by Point Section C.5.a(11)

Above Suspended Ceiling Wiring above suspended ceiling shall be kept to a Comparison of Plant USA to Limitations] minimum. Where installed, electrical wiring shall be listed Requirements of NUREG for plenum use, routed in armored cable, routed in metallic 0800, Rev. , 5/7/1986 conduit, or routed in cable trays with solid metal top and bottom covers.

3.3.5.2 [Electrical 3.3.5.2 Further Action FAQ 06-0021 Rev 0 NUREG-1038, Safety Section 9.5.1.4 Raceway Construction Only metal tray and metal conduits shall be used for Required Evaluation Report Related to Limits] electrical raceways. Thin wall metallic tubing shall not be the Operation of the Plant used for power, instrumentation, or control cables. Flexible USA Nuclear Power Plant, metallic conduits shall only be used in short lengths to Units 1 and 2 - Docket Nos.

connect components. STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 3.3.5.3 [Electrical Cable 3.3.5.3* Complies FAQ 06-0022 Rev 0 NUREG-1038, Safety section 9.5.1, page Flame Propagation Electric cable construction shall comply with a flame Evaluation Report Related to 9-49 Limits] propagation test as acceptable to the AHJ. the Operation of the Plant USA Nuclear Power Plant, Exception: Existing cable in place prior to the adoption of Units 1 and 2 - Docket Nos.

this standard shall be permitted to remain as is. STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 Plant USA Page 6 of 33 1/3/2008 Test Plant USA for Transition Report Examples Jan. 2008.mdb Transition Tool Version 1.0.4

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.3.6 Roofs. 3.3.6 Roofs. Further Action Metal deck roofs are not used on safety-related NUREG-1038, Safety Pg 9-48 Metal roof deck construction shall be designed and Required structures. (Unremoved metal forms used for Evaluation Report Related to installed so the roofing system will not sustain a the casting of reinforced concrete floors or the Operation of the Plant self-propagating fire on the underside of the deck when walls do not constitute a metal deck roof or USA Nuclear Power Plant, the deck is heated by a fire inside the building. Roof partition.) Units 1 and 2 - Docket Nos.

coverings shall be Class A as determined by tests STN-50-400 and STN 50-401, described in NFPA 256, Standard Methods of Fire Tests Rev. Original, 11/1/1983 of Roof Coverings.

3.3.7 Bulk Flammable 3.3.7 Bulk Flammable Gas Storage. Complies via Previous SER Supplement 2 states "Safety-related NUREG-1038, Safety SSER 2 Gas Storage. Bulk compressed or cryogenic flammable gas storage Approval systems have been isolated or separated from Evaluation Report Related to shall not be permitted inside structures housing systems, combustible materials as much as possible. the Operation of the Plant equipment, or components important to nuclear safety. Compressed gases are stored outdoors. By USA Nuclear Power Plant, letter dated February 24, 1984, the applicants Units 1 and 2 - Docket Nos.

committed to provide hydrogen lines in STN-50-400 and STN 50-401, safety-related areas that are either seismically Rev. Original, 11/1/1983 designed, sleeved, or provided with excess flow valves. The staff finds this commitment acceptable. On the basis of its review, the staff concludes that the control of combustible materials meets its guidelines in Section C.5.d and is therefore, acceptable."

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.3.7.1 [Bulk Flammable 3.3.7.1 Complies via Previous Approval Document NUREG-1038 Section AR 206165, , Rev. ,

Gas Location Storage of flammable gas shall be located outdoors, or in Approval 9.5.1 states "Safety-related systems have 11/19/2007 Requirements] separate detached buildings, so that a fire or explosion will been isolated or separated from combustible AR 200493, , Rev. , 11/1/2007 not adversely impact systems, equipment, or components materials as much as possible. Compressed important to nuclear safety. NFPA 50A, Standard for gases are stored outdoors. By letter dated Gaseous Hydrogen Systems at Consumer Sites, shall be February 24, 1984, the applicants committed followed for hydrogen storage. to provide hydrogen lines in safety-related areas that are either seismically designed, sleeved, or provided with excess flow valves.

The staff finds this commitment acceptable.

On the basis of its review, the staff concludes that the control of combustible materials meets its guidelines in Section C.5.d and is therefore, acceptable."

NLS 137 states "C.5.d(2) Bulk storage of compressed or cryogenic-gases is not permitted within structures housing safety-related equipment. Flammable gases such as hydrogen are stored outdoors and will not adversely affect safety-related equipment, systems of structures. Care will be taken to locate high pressure gas storage containers with the long axis parallel to building walls, to minimize the possibility of wall penetration in the event of a container failure. Use of-compressed gases (especially flammable and fuel gases) inside buildings will be controlled."

3.3.7.2 [Bulk Flammable 3.3.7.2 Complies No Additional Clarification NLS-86-137, Point by Point C.5.d.(2)

Gas Container Outdoor high-pressure flammable gas storage containers Comparison of Plant USA to Restrictions] shall be located so that the long axis is not pointed at Requirements of NUREG buildings. 0800, Rev. , 5/7/1986 3.3.7.3 [Bulk Flammable 3.3.7.3 Complies No Additional Clarification , , Rev. ,

Gas Cylinder Limitations] Flammable gas storage cylinders not required for normal operation shall be isolated from the system.

3.3.8 Bulk Storage of 3.3.8 Bulk Storage of Flammable and Combustible Complies with FAQ 06-0023 Rev. 0 is applicable. LAP-83-306, , Rev. , page 266 SER Flammable and Liquids. Clarification open item 109 Combustible Liquids. Bulk storage of flammable and combustible liquids shall The two Emergency Diesel Generator Day not be permitted inside structures containing systems, Tanks are located in the safety related equipment, or components important to nuclear safety. As Emergency Diesel Generator Building. Each a minimum, storage and use shall comply with NFPA 30, tank is located within its own dedicated Fire Flammable and Combustible Liquids Code. Area separated from the remainder of the Emergency Diesel Generator Building by fire barriers.

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.3.9 Transformers. 3.3.9* Transformers. Complies No Additional Clarification EC 48017, Xmer pit sizing, Where provided, transformer oil collection basins and Rev. , 9/8/2006 Section 5.3.10 drain paths shall be periodically inspected to ensure that OMM-016, Operators Rounds, they are free of debris and capable of performing their Rev. 062, design function.

3.3.10 Hot Pipes and 3.3.10* Hot Pipes and Surfaces. Complies No additional clarification , , Rev. ,

Surfaces. Combustible liquids, including high flashpoint lubricating oils, shall be kept from coming in contact with hot pipes and surfaces, including insulated pipes and surfaces.

Administrative controls shall require the prompt cleanup of oil on insulation.

3.3.11 Electrical 3.3.11 Electrical Equipment Complies FAQ 06-0024 Rev 0 , , Rev. ,

Equipment Adequate clearance, free of combustible material, shall be maintained around energized electrical equipment.

3.3.12 Reactor Coolant 3.3.12* Reactor Coolant Pumps. Complies No Additional Clarification LER 97-10, , Rev. ,

Pumps. For facilities with non-inerted containments, reactor 2165-S-0685, SFD -

coolant pumps with an external lubrication system shall be CONTM'T, TURBINE BLDG & sh 1-7 provided with an oil collection system. The oil collection TANK AREA & SEC. BLD, system shall be designed and installed such that leakage Rev. 027, from the oil system is safely contained for off normal 1364-053480, RCP-GEN conditions such as accident conditions or earthquakes. All ASSY OIL SPILL of the following shall apply. PROTESTON SYS, Rev. 001, (1) The oil collection system for each reactor coolant NLS-86-137, Point by Point pump shall be capable of collecting lubricating oil from all Comparison of Plant USA to potential pressurized and nonpressurized leakage sites in Requirements of NUREG each reactor coolant pump oil system. 0800, Rev. , 5/7/1986 (2) Leakage shall be collected and drained to a vented NUREG-1038, Safety closed container that can hold the inventory of the reactor Evaluation Report Related to coolant pump lubricating oil system. the Operation of the Plant (3) A flame arrestor is required in the vent if the flash point USA Nuclear Power Plant, characteristics of the oil present the hazard of a fire Units 1 and 2 - Docket Nos.

flashback. STN-50-400 and STN 50-401, (4) Leakage points on a reactor coolant pump motor to be Rev. Original, 11/1/1983 protected shall include but not be limited to the lift pump and piping, overflow lines, oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and the oil reservoirs, where such features exist on the reactor coolant pumps.

(5) The collection basin drain line to the collection tank shall be large enough to accommodate the largest potential oil leak such that oil leakage does not overflow the basin.

3.4 Industrial Fire N/A N/A N/A - General statement; No technical , , Rev. ,

Brigade. requirements Plant USA Page 9 of 33 1/3/2008 Test Plant USA for Transition Report Examples Jan. 2008.mdb Transition Tool Version 1.0.4

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.4.1 On-Site 3.4.1 On-Site Fire-Fighting Capability. Complies with FAQ 06-0007 Rev 0 is applicable. NFPA 1500 QCC FP FBBCERTH, INITIAL Fire-Fighting Capability. All of the following requirements shall apply. Clarification and NFPA 1582 are not applicable to Plant FIRE BRIGADE MEMBER (a) A fully staffed, trained, and equipped fire-fighting force USA as defined within their respective scope CERTIFICATION CARD shall be available at all times to control and extinguish all statements. FBBCERTH, Rev. 006, fires on site. This force shall have a minimum complement of five persons on duty and shall conform with the following NFPA standards as applicable:

(1) NFPA 600, Standard on Industrial Fire Brigades (interior structural fire fighting)

(2) NFPA 1500, Standard on Fire Department Occupational Safety and Health Program (3) NFPA 1582, Standard on Medical Requirements for Fire Fighters and Information for Fire Department Physicians (b)

• Industrial fire brigade members shall have no other assigned normal plant duties that would prevent immediate response to a fire or other emergency as required.

(c) During every shift, the brigade leader and at least two brigade members shall have sufficient training and knowledge of nuclear safety systems to understand the effects of fire and fire suppressants on nuclear safety performance Exception: Sufficient training and knowledge shall be permitted to be provided by an operations advisor dedicated to industrial fire brigade support criteria.

(d)

• The industrial fire brigade shall be notified immediately upon verification of a fire.

(e) Each industrial fire brigade member shall pass an annual physical examination to determine that he or she can perform the strenuous activity required during manual fire-fighting operations. The physical examination shall determine the ability of each member to use respiratory protection equipment.

3.4.2 Pre-Fire Plans. 3.4.2* Pre-Fire Plans. Further Action NLS-86-137, Point by Point Current and detailed pre-fire plans shall be available to the Required Comparison of Plant USA to industrial fire brigade for all areas in which a fire could Requirements of NUREG jeopardize the ability to meet the performance criteria 0800, Rev. , 5/7/1986 described in Section 1.5.

3.4.2.1 [Pre-Fire Plan 3.4.2.1* Further Action FAQ 06-0025 Rev 0 , , Rev. ,

Contents] The plans shall detail the fire area configuration and fire Required -

hazards to be encountered in the fire area, along with any FAQ/Clarification nuclear safety components and fire protection systems and features that are present.

3.4.2.2 [Pre-Fire Plan 3.4.2.2 Complies No Additional Clarification PRO-NGGC-0204, Procedure Updates] Pre-fire plans shall be reviewed and updated as Review and Approval, Rev.

necessary. 009, FP-002, Fire Emergency, Rev.

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.4.2.3 [Pre-Fire Plan 3.4.2.3* Complies No Additional Clarification , , Rev. ,

Locations] Pre-fire plans shall be available in the control room and made available to the plant industrial fire brigade.

3.4.2.4 [Pre-Fire Plan 3.4.2.4* Complies with Site procedure FPP-002, "Fire Emergency" is , , Rev. ,

Coordination Needs] Pre-fire plans shall address coordination with other plant Clarification not specifically a fire pre-plan however groups during fire emergencies. FPP-002 provides specific instructions for actions required from key groups at Plant USA supporting the fire brigade/fire emergency actions. There are detailed response coordination actions specified for Control Room personnel and the Security group. Any other coordination actions would be initiated by Control Room personnel as needed for any plant emergency.

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.4.3 Training and Drills. 3.4.3 Training and Drills. a) Complies with FAQ 06-0007 Rev 0 TPP-219, Emergency Industrial fire brigade members and other plant personnel Clarification Services Training Program, who would respond to a fire in conjunction with the brigade Rev. 011, shall be provided with training commensurate with their emergency responsibilities.

(a) Plant Industrial Fire Brigade Training. All of the following requirements shall apply.

(1) Plant industrial fire brigade members shall receive training consistent with the requirements contained in NFPA 600, Standard on Industrial Fire Brigades, or NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, as appropriate.

(2) Industrial fire brigade members shall be given quarterly training and practice in fire fighting, including radioactivity and health physics considerations, to ensure that each member is thoroughly familiar with the steps to be taken in the event of a fire.

(3) A written program shall detail the industrial fire brigade training program.

(4) Written records that include but are not limited to initial industrial fire brigade classroom and hands-on training, refresher training, special training schools attended, drill attendance records, and leadership training for industrial fire brigades shall be maintained for each industrial fire brigade member.

(b) Training for Non-Industrial Fire Brigade Personnel.

Plant personnel who respond with the industrial fire brigade shall be trained as to their responsibilities, potential hazards to be encountered, and interfacing with the industrial fire brigade.

(c)

• Drills. All of the following requirements shall apply.

(1) Drills shall be conducted quarterly for each shift to test the response capability of the industrial fire brigade.

(2) Industrial fire brigade drills shall be developed to test and challenge industrial fire brigade response, including brigade performance as a team, proper use of equipment, effective use of pre-fire plans, and coordination with other groups. These drills shall evaluate the industrial fire brigades abilities to react, respond, and demonstrate proper fire-fighting techniques to control and extinguish the fire and smoke conditions being simulated by the drill scenario.

(3) Industrial fire brigade drills shall be conducted in various plant areas, especially in those areas identified to be essential to plant operation and to contain significant fire hazards.

(4) Drill records shall be maintained detailing the drill scenario, industrial fire brigade member response, and ability of the industrial fire brigade to perform as a team.

(5) A critique shall be held and documented after each Plant USA Page 12 of 33 1/3/2008 Test Plant USA for Transition Report Examples Jan. 2008.mdb Transition Tool Version 1.0.4

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail drill.

b) Complies No Additional Clarification , , Rev. ,

c) Complies No Additional Clarification TPP-219, Emergency Services Training Program, Rev. 011, 3.4.4 Fire-Fighting 3.4.4 Fire-Fighting Equipment. Complies with Fire Brigade turnout gear is purchased to meet HPP-630, Respitory Equipment. Protective clothing, respiratory protective equipment, Clarification applicable NFPA codes. Care and Protection Program, Rev. 020, radiation monitoring equipment, personal dosimeters, and maintenance is based on actual field usage fire suppression equipment such as hoses, nozzles, fire and sufficient to ensure the gear is capable of extinguishers, and other needed equipment shall be performing its design functions. Radiation provided for the industrial fire brigade. This equipment monitoring equipment and personal dosimeters shall conform with the applicable NFPA standards. are provided to the fire brigade, and they are maintained in accordance with the site procedures consistent with other radiation monitoring equipment and personal dosimeters in use at Plant USA. Fire suppression equipment such as hose and nozzles are available to the fire brigade in the staging area or are staged in the plant for the fire brigade use. The fire suppression equipment such as hose and nozzles comply with applicable NFPA codes. Fire Extinguishers are located as necessary throughout the areas of the plant as described in the response to Section 3.7.

3.4.5 Off-Site Fire N/A N/A N/A - General statement; No technical , , Rev. ,

Department Interface. requirements 3.4.5.1 Mutual Aid 3.4.5.1 Mutual Aid Agreement. Complies No Additional Clarification TPP-219, Emergency Agreement. Off-site fire authorities shall be offered a plan for their Services Training Program, interface during fires and related emergencies on site. Rev. 011, 3.4.5.2 Site-Specific 3.4.5.2* Site-Specific Training. Complies No Additional Clarification TPP-219, Emergency Training. Fire fighters from the off-site fire authorities who are Services Training Program, expected to respond to a fire at the plant shall be offered Rev. 011, site-specific training and shall be invited to participate in a drill at least annually.

3.4.5.3 Security and 3.4.5.3* Security and Radiation Protection. Complies No Additional Clarification PLP-201, Emergency Plan, Radiation Protection. Plant security and radiation protection plans shall address Rev. 052, off-site fire authority response.

3.4.6 Communications. 3.4.6* Communications. Complies No Additional Clarification FSAR Section 9.5.2, An effective emergency communications capability shall Communication System, Rev.

be provided for the industrial fire brigade. ,

3.5 Water Supply N/A N/A N/A - General statement; No technical , , Rev. ,

requirements Plant USA Page 13 of 33 1/3/2008 Test Plant USA for Transition Report Examples Jan. 2008.mdb Transition Tool Version 1.0.4

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.5.1 [Water Supply Flow 3.5.1 Complies with FAQ 06-0019 Rev. 0 is applicable. The , , Rev. ,

Code Requirements] A fire protection water supply of adequate reliability, Clarification available Plant USA water supply meets the quantity, and duration shall be provided by one of the two criteria of section 3.5.1(b) for sprinkler systems following methods. which meet the Nuclear Safety Performance (a) Provide a fire protection water supply of not less than Criteria.

two separate 300,000-gal (1,135,500-L) supplies.

(b) Calculate the fire flow rate for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This fire flow rate shall be based on 500 gpm (1892.5 L/min) for manual hose streams plus the largest design demand of any sprinkler or fixed water spray system(s) in the power block as determined in accordance with NFPA 13, Standard for the Installation of Sprinkler Systems, or NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection. The fire water supply shall be capable of delivering this design demand with the hydraulically least demanding portion of fire main loop out of service.

3.5.2 [Water Supply Tank 3.5.2* Complies with Plant USA utilizes exception No. 1. The fire NUREG 1083, NUREG 1083, Code Requirements] The tanks shall be interconnected such that fire pumps Clarification protection pumps take suction from the Rev. ,

can take suction from either or both. A failure in one tank Auxiliary Reservoir.

or its piping shall not allow both tanks to drain. The tanks shall be designed in accordance with NFPA 22, Standard for Water Tanks for Private Fire Protection.

Exception No. 1: Water storage tanks shall not be required when fire pumps are able to take suction from a large body of water (such as a lake), provided each fire pump has its own suction and both suctions and pumps are adequately separated.

Exception No. 2: Cooling tower basins shall be an acceptable water source for fire pumps when the volume is sufficient for both purposes and water quality is consistent with the demands of the fire service.

3.5.3 [Water Supply 3.5.3* Complies No Additional Clarifications Plant USA-M/BMRK-0007, Pump Code Fire pumps, designed and installed in accordance with Code Compliance Evaluation Requirements] NFPA 20, Standard for the Installation of Stationary NFPA 20 - Centrifugal Fire Pumps for Fire Protection, shall be provided to ensure that Pumps, Rev. 001, 100 percent of the required flow rate and pressure are available assuming failure of the largest pump or pump power source.

3.5.4 [Water Supply 3.5.4 Complies with , , Rev. ,

Pump Diversity and At least one diesel engine-driven fire pump or two more Clarification Redundancy] seismic Category I Class IE electric motor-driven fire pumps connected to redundant Class IE emergency power buses capable of providing 100 percent of the required flow rate and pressure shall be provided.

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.5.5 [Water Supply 3.5.5 Complies via Previous Submittal Document NLS-86-137 Section NUREG 1083, NUREG 1083, Pump Separation Each pump and its driver and controls shall be separated Approval C.6.b(6) Project Conformance "As shown in Rev. ,

Requirements] from the remaining fire pumps and from the rest of the FSAR Figure 9.5.1-1 two 100% capacity fire plant by rated fire barriers. pumps, one electric and one diesel driven, installed in accordance with NFPA 20, are provided. The pumps are installed at opposite ends of the emergency service water intake structure which provides spatial separation in lieu of a fire wall."

SER section 9.5.1 pg 9-51 states in part "The fire pumps are located in the emergency service-water screening structure. The fire pumps are separated by the intake water structure. A single fire is, therefore, unlikely to cause damage to both pumps. Based on its review, the staff concludes that the fire protection water supply system meets Section C.6.c of BTP CMEB 9.5-l and is, therefore, acceptable."

3.5.6 [Water Supply 3.5.6 Complies No Additional Clarification , , Rev. ,

Pump Start/Stop Fire pumps shall be provided with automatic start and Requirements] manual stop only.

3.5.7 [Water Supply 3.5.7 Complies No Additional Clarification 2165-S-0556, , Rev. 13, Pump Connection Individual fire pump connections to the yard fire main loop 2165-S-0555, , Rev. 18, Requirements] shall be provided and separated with sectionalizing valves 2165-S-0557, , Rev. 7, between connections.

3.5.8 [Water Supply 3.5.8 Complies No Additional Clarification NUREG 1083, NUREG 1083, Pressure Maintenance A method of automatic pressure maintenance of the fire Rev. ,

Limitations] protection water system shall be provided independent of the fire pumps.

3.5.9 [Water Supply 3.5.9 Complies No Additional Clarification , , Rev. ,

Pump Operation Means shall be provided to immediately notify the control Notification] room, or other suitable constantly attended location, of operation of fire pumps.

3.5.10 [Water Supply 3.5.10 Complies No Additional Clarification Plant USA-M/BMRK-0008, Yard Main Code An underground yard fire main loop, designed and Code Compliance Evaluation Requirements] installed in accordance with NFPA 24, Standard for the NFPA 24 - Standard for Installation of Private Fire Service Mains and Their Outside Protection, Rev. 001, Appurtenances, shall be installed to furnish anticipated water requirements.

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.5.11 [Water Supply 3.5.11 Complies via Previous SER Section 9.5.1 pg 9-51 states in part , , Rev. ,

Yard Main Maintenance Means shall be provided to isolate portions of the yard fire Approval "Approved post-indicator sectional control Issues] main loop for maintenance or repair without valves are provided to isolate portions of the simultaneously shutting off the supply to both fixed fire underground main for maintenance or repair suppression systems and fire hose stations provided for without shutting off the supply to primary and manual backup. Sprinkler systems and manual hose backup fire suppression systems that serve station standpipes shall be connected to the plant fire areas containing or exposing safety-related protection water main so that a single active failure or a systems. Based on its review, the staff crack to the water supply piping to these systems can be concludes that the fire protection water supply isolated so as not to impair both the primary and backup system meets Section C.6.c of BTP CMEB fire suppression systems. 9.5-l and is, therefore, acceptable."

"Each automatic sprinkler system and interior hose standpipe is supplied through separate connections from the yard main or from the internal cross connections through buildings to ensure that no single failure in the water supply system will impair both the primary and backup fire protection in building areas. Each sprinkler and standpipe system connection to the distribution system is equipped with an indicating gate valve, so that groups of sprinkler systems and/or manual hose stations can be isolated without interrupting the supply to other sprinkler systems and manual hose stations connected to the same header Based on its evaluation, the staff finds that sprinkler and standpipe systems have been provided in accordance with Section C.6.(C) of BTP CMEB 9.5-l and are, therefore, acceptable. "

Submittal Document NLS-86-137 Sections C.6.b(2) and C.6.c(1) Project Conformance "Post indicator valves are provided in the distribution system for adequate sectionalization of loops and isolation of branch lines to facilitate system maintenance.

Isolation valves are located in branch lines connecting fire suppression systems in the buildings to avoid closing sectional valves in the main loop. Sectional isolation valves are provided in the yard loop piping to minimize the impairment of fire protection water supply if maintenance on the loop or yard hydrants becomes necessary. Sprinkler systems and manual hose station standpipes have connections to the plant underground water main so that a single active failure or a crack in a moderate-energy line cannot impair both the primary and backup fire suppression systems."

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.5.12 [Water Supply 3.5.12 Complies No Additional Clarification , , Rev. ,

Compatible Thread Threads compatible with those used by local fire Connections] departments shall be provided on all hydrants, hose couplings, and standpipe risers.

Exception: Fire departments shall be permitted to be provided with adapters that allow interconnection between plant equipment and the fire department equipment if adequate training and procedures are provided.

3.5.13 [Water Supply 3.5.13 Complies No Additional Clarification , , Rev. ,

Header Options] Headers fed from each end shall be permitted inside buildings to supply both sprinkler and standpipe systems, provided steel piping and fittings meeting the requirements of ANSI B31.1, Code for Power Piping, are used for the headers (up to and including the first valve) supplying the sprinkler systems where such headers are part of the seismically analyzed hose standpipe system. Where provided, such headers shall be considered an extension of the yard main system. Each sprinkler and standpipe system shall be equipped with an outside screw and yoke (OS&Y) gate valve or other approved shutoff valve.

3.5.14 [Water Supply 3.5.14* Complies No Additional Clarification , , Rev. ,

Control Valve All fire protection water supply and fire suppression Supervision] system control valves shall be under a periodic inspection program and shall be supervised by one of the following methods.

(a) Electrical supervision with audible and visual signals in the main control room or other suitable constantly attended location.

(b) Locking valves in their normal position. Keys shall be made available only to authorized personnel.

(c) Sealing valves in their normal positions. This option shall be utilized only where valves are located within fenced areas or under the direct control of the owner/operator.

3.5.15 [Water Supply 3.5.15 Complies with , , Rev. ,

Hydrant Code Hydrants shall be installed approximately every 250 ft (76 Clarification Requirements] m) apart on the yard main system. A hose house equipped with hose and combination nozzle and other auxiliary equipment specified in NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances, shall be provided at intervals of not more than 1000 ft (305 m) along the yard main system.

Exception: Mobile means of providing hose and associated equipment, such as hose carts or trucks, shall be permitted in lieu of hose houses. Where provided, such mobile equipment shall be equivalent to the equipment supplied by three hose houses.

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.5.16 [Water Supply 3.5.16* Complies with , , Rev. ,

Dedicated Limits] The fire protection water supply system shall be dedicated Clarification for fire protection use only.

Exception No. 1: Fire protection water supply systems shall be permitted to be used to provide backup to nuclear safety systems, provided the fire protection water supply systems are designed and maintained to deliver the combined fire and nuclear safety flow demands for the duration specified by the applicable analysis.

Exception No. 2: Fire protection water storage can be provided by plant systems serving other functions, provided the storage has a dedicated capacity capable of providing the maximum fire protection demand for the specified duration as determined in this section.

3.6 Standpipe and Hose N/A N/A N/A - General statement; No technical , , Rev. ,

Stations. requirements Plant USA Page 18 of 33 1/3/2008 Test Plant USA for Transition Report Examples Jan. 2008.mdb Transition Tool Version 1.0.4

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.6.1 [Standpipe and 3.6.1 Complies Via Approval Document NUREG-1038 Section NLS-86-137, Point by Point Hose Station Code For all power block buildings, Class III standpipe and hose Previous Approval 9.5.1.5 Sprinkler and Standpipe System states Comparison of Plant USA to Requirements] systems shall be installed in accordance with NFPA 14, "Each sprinkler and standpipe system Requirements of NUREG Standard for the Installation of Standpipe, Private Hydrant, connection to the distribution system is 0800, Rev. , 5/7/1986 Section 9.5.1 and Hose Systems. equipped with an indicating gate valve, so that Plant USA SER initial and groups of sprinkler systems and/or manual Supplement 4, , Rev. ,

hose stations can be isolated without Plant USA-M/BMRK-0006, interrupting the supply to other sprinkler Code Compliance Evaluation systems and manual hose stations connected NFPA 14-1976, Standpipe to the same heat' Based on its evaluation, the and Hose Stations, Rev. 001, staff finds that sprinkler and standpipe systems SPlant USAP FSAR 9.5.1, ,

have been provided in accordance with Rev. ,

Section C.6.(C) of BTP CMEB 9.5-l and are, therefore, acceptable. Manual hose stations are located throughout the plant in accordance with NFPA 14. Standpipe system piping for hose stations protecting safe shutdown equipment has been analyzed for SSE loading and is provided with seismic supports. The staff concludes that the design of the standpipe system piping meets Section C.6.c of BTP CMEB 9.5-l and is, therefore, acceptable."

Approval Document NUREG-1038 Supplement No. 4 Section 9.5.1 states "In SER Supplement 3, the staff indicated that its review of the applicant's fire protection program for Harris was complete. By letters dated May 7, June 4, June 18, June 20, July 22, and August 6, 1986, the applicant provided additional information (including Revision 3 to its point-by-point comparison with BTP CMEB 9.5-l), requests for additional deviations from BTP CMEB 9.5-1, and FSAR Amendment 27.

The information provided contained changes resulting from continued program development, and incorporated information previously provided via docketed correspondence, editorial changes, and clarifications. Only those changes that affect the staff's previous safety evaluations are addressed in this supplement.

The Plant USA response NLS-86-137 to section C.6.c(4) states in part "Interior manual hose stations are provided in each plant area so that all portions of the plant are protected with at least one effective hose stream, except the tank area: Diesel Fuel Oil Storage Tank Plant USA Page 19 of 33 1/3/2008 Test Plant USA for Transition Report Examples Jan. 2008.mdb Transition Tool Version 1.0.4

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail and Transfer Pumps area and ESW intake and screen-structure, which are protected by yard hydrants." "Individual standpipes are 4 inches in diameter for multiple hose stations and 2-1/2 inches for single hose stations. These systems follow the requirements of NFPA 14 "Standpipe and Hose Systems" Class II, for sizing, spaces, and pipe support requirements.

Hose stations are located as dictated by the fire hazard analysis to facilitate access and use for firefighting operations. Alternative hose stations are provided for an area if the fire hazard could block access to a single hose station serving that area."

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.6.2 [Standpipe and 3.6.2 Complies Via Submittal Document NLS-86-137 Section Plant USA SER initial and Hose Station Capability A capability shall be provided to ensure an adequate water Previous Approval C.6.c(4) Project Conformance "Interior manual Supplement 4, , Rev. ,

Limitations] flow rate and nozzle pressure for all hose stations. This hose stations are provided in each plant area AR 76621, Evaluate Electrical capability includes the provision of hose station pressure so that all portions of the plant are protected Nozzles, Rev. , 11/12/2003 reducers where necessary for the safety of plant industrial with at least one effective hose stream, except AR 25032, Evaluation of fire brigade members and off-site fire department the tank area: Diesel Fuel Oil Storage Tank NFPA 14 Deviations, Rev. ,

personnel. and Transfer Pumps area and ESW intake and 4/15/2002 screen-structure, which are protected by yard Plant USA-M/BMRK-0006, hydrants. Each interior hose station is provided Code Compliance Evaluation with 100 feet of 1 1/2 inches Angus "Red Chief" NFPA 14-1976, Standpipe rubber-lined, rubber coated hose and and Hose Stations, Rev. 001, adjustable nozzles suitable for use on NLS-86-137, Point by Point electrical equipment. Individual standpipes are Comparison of Plant USA to 4 inches in diameter for multiple hose stations Requirements of NUREG and 2-1/2 inches for single hose stations. 0800, Rev. , 5/7/1986 These systems follow the requirements of SPlant USAP FSAR 9.5.1, ,

NFPA 14 Standpipe and Hose Systems Class Rev. ,

II, for rising, spaces, and pipe support requirements. Hose stations are located as dictated by the fire hazard analysis to facilitate access and use for firefighting operations.

Alternative hose stations are provided for an area if the fire hazard could block access to a single hose station serving that area."

Approval Document NUREG-1038 Section 9.5.1.5 Sprinkler and Standpipe Systems states "Each sprinkler and standpipe system connection to the distribution system is equipped with an indicating gate valve, so that groups of sprinkler systems and/or manual hose stations can be isolated without interrupting the supply to other sprinkler systems and manual hose stations connected to the same heat' Based on its evaluation, the staff finds that sprinkler and standpipe systems have been provided in accordance with Section C.6.(C) of BTP CMEB 9.5-l and are, therefore, acceptable. Manual hose stations are located throughout the plant in accordance with NFPA 14."

FSAR section 9.5.1 states, "The guidelines of NFPA 14 were followed in the design of the standpipe. Individual standpipes are a minimum of 4 inches diameter for multiple hose connections and 2-1/2 inch for single hose connections. The stand pipe system is designed and sized to provide to the most remote hose station the flow rate and pressure Plant USA Page 21 of 33 1/3/2008 Test Plant USA for Transition Report Examples Jan. 2008.mdb Transition Tool Version 1.0.4

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail required for effective hose streams."

3.6.3 [Standpipe and 3.6.3 Complies No Additional Clarification AR 25032, Evaluation of Hose Station Nozzle The proper type of hose nozzle to be supplied to each NFPA 14 Deviations, Rev. ,

Restrictions] power block area shall be based on the area fire hazards. 4/15/2002 The usual combination spray/straight stream nozzle shall NFPA 14-1976, Standpipes not be used in areas where the straight stream can cause and Hose Stations, Rev. ,

unacceptable damage or present an electrical hazard to Plant USA SER initial and fire-fighting personnel. Listed electrically safe fixed fog Supplement 4, , Rev. ,

nozzles shall be provided at locations where high-voltage NLS-86-137, Point by Point shock hazards exist. All hose nozzles shall have shutoff Comparison of Plant USA to capability and be able to control water flow from full open Requirements of NUREG to full closed. 0800, Rev. , 5/7/1986 Plant USA Page 22 of 33 1/3/2008 Test Plant USA for Transition Report Examples Jan. 2008.mdb Transition Tool Version 1.0.4

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.6.4 [Standpipe and 3.6.4 Complies via Previous Deviation Request- Plant USA SER initial and Hose Station Earthquake Provisions shall be made to supply water at least to Approval Supplement 4, , Rev. ,

Provisions] standpipes and hose stations for manual fire suppression From NLS-86-315 NLS-86-137, Point by Point in all areas containing systems and components needed Comparison of Plant USA to to perform the nuclear safety functions in the event of a

SUMMARY

Requirements of NUREG safe shutdown earthquake (SSE). Carolina Power & Light Company (CP&L) 0800, Rev. , 5/7/1986 would lie to identify a deviation from BTP Plant USA-M/BMRK-0006, Exception: For existing plants that are not capable of 9.5-1, Section C.6.c (4) of NUREG-0800 from Code Compliance Evaluation meeting this requirement, provisions to restore a water having to provide manual Safe Shutdown NFPA 14-1976, Standpipe supply and distribution system for manual fire-fighting Earthquake (SSE) hose stations in three areas and Hose Stations, Rev. 001, purposes shall be made. This provisional manual of the plant identified below.

fire-fighting standpipe/hose station system shall be BACKGROUND capable of providing manual fire-fighting protection to the Section 9.5.15 of the November 1983 Harris various plant locations important to supporting and Safety Evaluation Report (SER) stated that:

maintaining the nuclear safety function. The provisions for "Based on its evaluation, the Staff finds that establishing this provisional system shall be preplanned sprinkler and standpipe systems have been and be capable of being implemented in a timely manner provided in accordance with Section C.6.( c )

following an SSE. of BTP CMEB 9.5-l and are, therefore, acceptable."

"Standpipe system piping for hose stations protecting safe shutdown equipment has been analyzed for SSE loading and is provided with seismic supports. The Staff concludes the design of the standpipe system piping, meets Section C.6.c of BTP CMEB 9:5-I and is, therefore, acceptable."

The above SER statements were based on CP&.L's Qctober 1983 response to NRC Question 280.1. However, the SER did not address the deviations identified in CP&L's response (specifically, that SSE hose stations were not provided for the diesel generator and fuel oil storage buildings). Amendment No. 20 of the Harris Final Safety Analysis Report, dated May 10,1985, identified the Emergency Service Water Intake structure as an additional area where SSE hose stations are not provided. Following recent conversations with your Staff, CP&L was requested to provide justification for not providing SSE hose stations for the below three areas.

DISCUSSION The Company requests approval of a deviation from the requirements to provide-SSE hose stations in the following plant areas:

Plant Location:

a) Diesel Generator Building b) Diesel Fuel Oil Storage Building c) Emergency Service Water Intake Structure Fire Area:

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail a) I-D-DGA, I-D-DCB, I-D-DTA, I-D-DTB b) 12-O-TA, 12-O-TB, I-O-PA, l-O-PB, 5-O-BAL c) I2-I-ESWPA, I2-I-ESWPB SSA Area:

a) FADDGA, FADDGB, FADDTA, FADDTB b) FCOTKA. FCOTKB, FAOPA, FAOPB, FPOBAL c) FCIESA. FCIESB Other safe shutdown equipment within the SSA area:

a) Diesel Generator, Diesel Generator Day Tanks, and Diesel Control Panels b) Diesel Generator Fuel Oil Transfer Pumps, Diesel Generator Storage Tanks c) Emergency Service Water Pumps and Controls The Company considers this deviation justified because:

1-the above redundant safe shutdown equipment is separated from each other by three-hour rated barriers, which are Seismic Class I structures, 2-these areas are provided with non-seismic fire protection systems, and 3-the combustible loading in these areas is considered low, except in the case of the diesel day tank and storage tank area where the enclosures are Seismic Class I or ASME Section III.

CONCLUSION Based on the fire protection provided and described above, CP&L believes that a commensurate level of protection has been provided in lieu of additional SSE hose stations as described in Section C.6,c (4) of NUREG-0800.

Plant USA initial SER states "Each sprinkler and standpipe system connection to the distribution system is equipped with an indicating gate valve, so that groups of sprinkler systems and/or manual hose stations can be isolated without interrupting the supply to other sprinkler systems and manual hose stations connected to the same heat' Based on its evaluation, the staff finds that sprinkler and standpipe systems have been provided in accordance with Section C.6.(C) of BTP CMEB 9.5-l and are, therefore, acceptable. Manual Plant USA Page 24 of 33 1/3/2008 Test Plant USA for Transition Report Examples Jan. 2008.mdb Transition Tool Version 1.0.4

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail hose stations are located throughout the plant in accordance with NFPA 14. Standpipe system piping for hose stations protecting safe shutdown equipment has been analyzed for SSE loading and is provided with seismic supports. The staff concludes that the design of the standpipe system piping meets Section C.6.c of BTP CMEB 9.5-l and is, therefore, acceptable."

SER 4 -

In the SER, the staff stated that standpipe system piping for hose stations protecting safe shutdown equipment has been analyzed for safe-shutdown earthquake (SSE) loading and is provided with seismic supports in accordance with Section C.6.c of BTP CMEB 9.5-l. In fact, this is not the case for the diesel generator building, the diesel fuel oil storage building, and the emergency service water intake structures. By letter dated August 25, 1986, the applicant justified this deviation from staff guidelines. On the basis of its review of the applicant's justification, which is based on the separation of the redundant safe-shutdown equipment located in the diesel generator building, the diesel fuel oil storage building, and the emergency service water (ESW) intake structure by seismic Category I 3-hour fire rated barriers, and the provision of alternative means of manual firefighting, the staff concludes that the standpipe system is acceptable. The lack of seismically qualified hose stations in the diesel generator and fuel oil storage buildings and the emergency service water (ESW) intake structure is an acceptable deviation from Section C.6.c of BTP CMEB 9.5-l. 9.5.1.6.

3.6.5 [Standpipe and 3.6.5 Complies No Additional Clarification NLS-86-137, Point by Point Hose Station Seismic Where the seismic required hose stations are Comparison of Plant USA to Connection Limitations] cross-connected to essential seismic non-fire protection Requirements of NUREG water supply systems, the fire flow shall not degrade the 0800, Rev. , 5/7/1986 essential water system requirement. Plant USA SER initial and Supplement 4, , Rev. ,

Plant USA-M/BMRK-0006, Code Compliance Evaluation NFPA 14-1976, Standpipe and Hose Stations, Rev. 001, Plant USA Page 25 of 33 1/3/2008 Test Plant USA for Transition Report Examples Jan. 2008.mdb Transition Tool Version 1.0.4

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.7 Fire Extinguishers. 3.7 Fire Extinguishers. LAR Plant USA-M/BMRK-0005, Where provided, fire extinguishers of the appropriate CODE COMPLIANCE number, size, and type shall be provided in accordance EVALUATION NFPA 10, with NFPA 10, Standard for Portable Fire Extinguishers. PORTABLE FIRE Extinguishers shall be permitted to be positioned outside EXTINGUISHERS, Rev. 001, of fire areas due to radiological conditions. AR 25033, , Rev. , 4/15/2002 3.8 Fire Alarm and N/A N/A N/A - General statement; No technical , , Rev. ,

Detection Systems. requirements 3.8.1 Fire Alarm. 3.8.1 Fire Alarm. Further Action Plant USA-M/BMRK-0001, Alarm initiating devices shall be installed in accordance Required CODE COMPLIANCE with NFPA 72, National Fire Alarm Code. Alarm EVALUATION NFPA 72E, annunciation shall allow the proprietary alarm system to AUTOMATIC FIRE transmit fire-related alarms, supervisory signals, and DETECTORS, Rev. 001, trouble signals to the control room or other constantly attended location from which required notifications and response can be initiated. Personnel assigned to the proprietary alarm station shall be permitted to have other duties. The following fire-related signals shall be transmitted:

(1) Actuation of any fire detection device (2) Actuation of any fixed fire suppression system (3) Actuation of any manual fire alarm station (4) Starting of any fire pump (5) Actuation of any fire protection supervisory device (6) Indication of alarm system trouble condition 3.8.1.1 [Fire Alarm 3.8.1.1 Complies FAQ 06-0019 Rev 0 is applicable. , , Rev. ,

Communication Means shall be provided to allow a person observing a fire Requirements] at any location in the plant to quickly and reliably communicate to the control room or other suitable constantly attended location.

3.8.1.2 [Fire Alarm 3.8.1.2 Complies No Additional Clarification , , Rev. ,

Prompt Notification Means shall be provided to promptly notify the following of Limits] any fire emergency in such a way as to allow them to determine an appropriate course of action:

(1) General site population in all occupied areas (2) Members of the industrial fire brigade and other groups supporting fire emergency response (3) Off-site fire emergency response agencies. Two independent means shall be available (e.g., telephone and radio) for notification of off-site emergency services 3.8.2 Detection. 3.8.2 Detection. Further Action Plant USA-M/BMRK-0001, If automatic fire detection is required to meet the Required CODE COMPLIANCE performance or deterministic requirements of Chapter 4, EVALUATION NFPA 72E, then these devices shall be installed in accordance with AUTOMATIC FIRE NFPA 72, National Fire Alarm Code, and its applicable DETECTORS, Rev. 001, appendixes.

3.9 Automatic and N/A N/A N/A - General statement; No technical , , Rev. ,

Manual Water-Based Fire requirements Suppression Systems.

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.9.1 [Fire Suppression 3.9.1* Further Action , , Rev. ,

System Code If an automatic or manual water-based fire suppression Required Requirements] system is required to meet the performance or deterministic requirements of Chapter 4, then the system shall be installed in accordance with the appropriate NFPA standards including the following:

(1) NFPA 13, Standard for the Installation of Sprinkler Systems (2) NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection (3) NFPA 750, Standard on Water Mist Fire Protection Systems (4) NFPA 16, Standard for the Installation of Foam-Water Sprinkler and Foam-Water Spray Systems 3.9.2 [Fire Suppression 3.9.2 Complies No Additional Clarification SPlant USAP FSAR 9.5.1 Section 9.5.1, page System Flow Alarm] Each system shall be equipped with a water flow alarm. Amendment 48, , Rev. , 9.5.1-23 3.9.3 [Fire Suppression 3.9.3 Complies No Additional Clarification SPlant USAP FSAR 9.5.1 Section 9.5.1, page System Alarm Locations] All alarms from fire suppression systems shall annunciate Amendment 48, , Rev. , 9.5.1-25 in the control room or other suitable constantly attended location.

3.9.4 [Fire Suppression 3.9.4 LAR , , Rev. ,

System Diesel Pump Diesel-driven fire pumps shall be protected by automatic Sprinkler Protection] sprinklers.

3.9.5 [Fire Suppression 3.9.5 Complies No Additional Clarification , , Rev. ,

System Shutoff Controls] Each system shall be equipped with an OS&Y gate valve or other approved shutoff valve.

3.9.6 [Fire Suppression 3.9.6 Complies No Additional Clarification OP-149, Fire Protection, Rev.

System Valve All valves controlling water-based fire suppression 037, Supervision] systems required to meet the performance or deterministic requirements of Chapter 4 shall be supervised as described in 3.5.14.

3.10 Gaseous Fire N/A N/A N/A - General statement; No technical , , Rev. ,

Suppression Systems. requirements 3.10.1 [Gaseous 3.10.1 N/A Gaseous suppression not used at Plant USA. , , Rev. ,

Suppression System If an automatic total flooding and local application Code Requirements] gaseous fire suppression system is required to meet the performance or deterministic requirements of Chapter 4, then the system shall be designed and installed in accordance with the following applicable NFPA codes:

(1) NFPA 12, Standard on Carbon Dioxide Extinguishing Systems (2) NFPA 12A, Standard on Halon 1301 Fire Extinguishing Systems (3) NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems Plant USA Page 27 of 33 1/3/2008 Test Plant USA for Transition Report Examples Jan. 2008.mdb Transition Tool Version 1.0.4

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.10.2 [Gaseous 3.10.2 N/A Gaseous suppression not used at Plant USA. , , Rev. ,

Suppression System Operation of gaseous fire suppression systems shall Alarm Location] annunciate and alarm in the control room or other constantly attended location identified.

3.10.3 [Gaseous 3.10.3 N/A Gaseous suppression not used at Plant USA. , , Rev. ,

Suppression System Ventilation system design shall take into account Ventilation Limitations] prevention from over-pressurization during agent injection, adequate sealing to prevent loss of agent, and confinement of radioactive contaminants.

3.10.4 [Gaseous 3.10.4* N/A Gaseous suppression not used at Plant USA. , , Rev. ,

Suppression System In any area required to be protected by both primary and Single Failure Limits] backup gaseous fire suppression systems, a single active failure or a crack in any pipe in the fire suppression system shall not impair both the primary and backup fire suppression capability.

3.10.5 [Gaseous 3.10.5 N/A Gaseous suppression not used at Plant USA. , , Rev. ,

Suppression System Provisions for locally disarming automatic gaseous Disarming Controls] suppression systems shall be secured and under strict administrative control.

3.10.6 [Gaseous 3.10.6* N/A Gaseous suppression not used at Plant USA. , , Rev. ,

Suppression System CO2 Total flooding carbon dioxide systems shall not be used in Limitations] normally occupied areas.

3.10.7 [Gaseous 3.10.7 N/A Gaseous suppression not used at Plant USA. , , Rev. ,

Suppression System CO2 Automatic total flooding carbon dioxide systems shall be Warnings] equipped with an audible pre-discharge alarm and discharge delay sufficient to permit egress of personnel.

The carbon dioxide system shall be provided with an odorizer.

3.10.8 [Gaseous 3.10.8 N/A Gaseous suppression not used at Plant USA. , , Rev. ,

Suppression System CO2 Positive mechanical means shall be provided to lock out Required Disarming] total flooding carbon dioxide systems during work in the protected space.

3.10.9 [Gaseous 3.10.9 N/A Gaseous suppression not used at Plant USA. , , Rev. ,

Suppression System The possibility of secondary thermal shock (cooling)

Cooling Considerations] damage shall be considered during the design of any gaseous fire suppression system, but particularly with carbon dioxide.

3.10.10 [Gaseous 3.10.10 N/A Gaseous suppression not used at Plant USA. , , Rev. ,

Suppression System Particular attention shall be given to corrosive Decomposition Issues] characteristics of agent decomposition products on safety systems.

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.11 Passive Fire 3.11 Passive Fire Protection Features. N/A N/A - General statement; No technical Plant USA-M/BMRK-0011, 3.11 Protection Features This section shall be used to determine the design and requirements Code Compliance Evaluation installation requirements for passive protection features. NFPA 805,2003,, Rev. 000, Passive fire protection features include wall, ceiling, and floor assemblies, fire doors, fire dampers, and through fire barrier penetration seals. Passive fire protection features also include electrical raceway fire barrier systems (ERFBS) that are provided to protect cables and electrical components and equipment from the effects of fire.

3.11.1 Building 3.11.1 Building Separation. Further Action FAQ 06-0008 Rev 0 is applicable. 2165-G-0003, SITE PLAN, Separation. Each major building within the power block shall be Required- Rev. 018, separated from the others by barriers having a designated 2165-G-0002, PLOT PLAN, 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 /> or by open space of at Rev. 023, least 50 ft (15.2 m) or space that meets the requirements E-5525, Safe Shutdown of NFPA 80A, Recommended Practice for Protection of Analysis in Case of Fire, Rev.

Buildings from Exterior Fire Exposures. 015, Exception: Where a performance-based analysis determines the adequacy of building separation, the requirements of 3.11.1 shall not apply.

3.11.2 Fire Barriers. 3.11.2 Fire Barriers. Further Action , , Rev. ,

Fire barriers required by Chapter 4 shall include a specific Required fire-resistance rating. Fire barriers shall be designed and installed to meet the specific fire resistance rating using assemblies qualified by fire tests. The qualification fire tests shall be in accordance with NFPA 251, Standard Methods of Tests of Fire Endurance of Building Construction and Materials, or ASTM E 119, Standard Test Methods for Fire Tests of Building Construction and Materials.

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.11.3 Fire Barrier 3.11.3* Fire Barrier Penetrations. Further Action Plant USA-M/BMRK-0003, Penetrations. Penetrations in fire barriers shall be provided with listed Required Code Compliance Evaluation fire-rated door assemblies or listed rated fire dampers NFPA 80, Standard for Fire having a fire resistance rating consistent with the Doors and Windows, Rev.

designated fire resistance rating of the barrier as 001, determined by the performance requirements established Plant USA-M/BMRK-0004, by Chapter 4. (See 3.11.3.4 for penetration seals for Code Compliance Evaluation through penetration fire stops.) Passive fire protection NFPA 90A, Air Conditioning devices such as doors and dampers shall conform with and Ventilating Systems the following NFPA standards, as applicable: (1981), Rev. 001, (1) NFPA 80, Standard for Fire Doors and Fire Windows (2) NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems (3) NFPA 101, Life Safety Code Exception: Where fire area boundaries are not wall-to-wall, floor-to-ceiling boundaries with all penetrations sealed to the fire rating required of the boundaries, a performance-based analysis shall be required to assess the adequacy of fire barrier forming the fire boundary to determine if the barrier will withstand the fire effects of the hazards in the area. Openings in fire barriers shall be permitted to be protected by other means as acceptable to the AHJ.

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.11.4 Through 3.11.4* Through Penetration Fire Stops. Further Action , , Rev. ,

Penetration Fire Stops. Through penetration fire stops for penetrations such as Required pipes, conduits, bus ducts, cables, wires, pneumatic tubes and ducts, and similar building service equipment that pass through fire barriers shall be protected as follows.

(a) The annular space between the penetrating item and the through opening in the fire barrier shall be filled with a qualified fire-resistive penetration seal assembly capable of maintaining the fire resistance of the fire barrier. The assembly shall be qualified by tests in accordance with a fire test protocol acceptable to the AHJ or be protected by a listed fire-rated device for the specified fire-resistive period.

(b) Conduits shall be provided with an internal fire seal that has an equivalent fire-resistive rating to that of the fire barrier through opening fire stop and shall be permitted to be installed on either side of the barrier in a location that is as close to the barrier as possible.

Exception: Openings inside conduit 4 in. (10.2 cm) or less in diameter shall be sealed at the fire barrier with a fire-rated internal seal unless the conduit extends greater than 5 ft (1.5 m) on each side of the fire barrier. In this case the conduit opening shall be provided with noncombustible material to prevent the passage of smoke and hot gases. The fill depth of the material packed to a depth of 2 in. (5.1 cm) shall constitute an acceptable smoke and hot gas seal in this application.

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail 3.11.5 Electrical Raceway 3.11.5* Electrical Raceway Fire Barrier Systems (ERFBS). Complies with AT Plant USA there are five different ERFBS , , Rev. ,

Fire Barrier Systems ERFBS required by Chapter 4 shall be capable of resisting Clarification installed which are credited in Chapter 4, (ERFBS). the fire effects of the hazards in the area. ERFBS shall be Hemyc, MT, Thermo-lag, Interam, and Meggitt tested in accordance with and shall meet the acceptance Cable.

criteria of NRC Generic Letter 86-10, Supplement 1, "Fire Endurance Test Acceptance Criteria for Fire Barrier HEMYC Systems Used to Separate Safe Shutdown Trains Within The fire resistive rating of the Hemyc ERFBS the Same Fire Area." The ERFBS needs to adequately is established by testing conducted in address the design requirements and limitations of accordance with the guidance and acceptance supports and intervening items and their impact on the fire criteria of GL 86-10 Supp 1. The rating varies barrier system rating. The fire barrier systems ability to from 28 minutes to 56 minutes. The Hemyc maintain the required nuclear safety circuits free of fire testing addressed the design requirements and damage for a specific thermal exposure, barrier design, limitations of supports and intervening items raceway size and type, cable size, fill, and type shall be and their impact on the fire barrier system demonstrated. rating. The testing also established the fire barrier system's bounding barrier design, Exception No. 1: When the temperatures inside the fire raceway size and type, cable size, fill, and barrier system exceed the maximum temperature allowed type's. Specific applications credited by by the acceptance criteria of Generic Letter 86-10, "Fire Chapter 4 are evaluated as acceptable based Endurance Acceptance Test Criteria for Fire Barrier on the rating via the change evaluation Systems Used to Separate Redundant Safe Shutdown process and included within the LAR.

Training Within the Same Fire Area," Supplement 1, functionality of the cable at these elevated temperatures MT shall be demonstrated. Qualification demonstration of The fire resistive rating of the MT ERFBS is these cables shall be performed in accordance with the established by testing conducted in electrical testing requirements of Generic Letter 86-10, accordance with the guidance and acceptance Supplement 1, Attachment 1, "Attachment Methods for criteria of GL 86-10 Supp 1. The rating varies Demonstrating Functionality of Cables Protected by from 116 minutes to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The MT testing Raceway Fire Barrier Systems During and After Fire addressed the design requirements and Endurance Test Exposure." limitations of supports and intervening items and their impact on the fire barrier system Exception No. 2: ERFBS systems employed prior to the rating. The testing also established the fire issuance of Generic Letter 86-10, Supplement 1, are barrier system's bounding barrier design, acceptable providing that the system successfully met the raceway size and type, cable size, fill, and limiting end point temperature requirements as specified type's. Specific applications credited by by the AHJ at the time of acceptance. Chapter 4 are evaluated as acceptable based on the rating via the change evaluation process and included within the LAR.

Thermo-lag The fire resistive rating of the Thermo-lag ERFBS is established by testing conducted in accordance with the guidance and acceptance criteria of GL 86-10 Supp 1. The Thermo-lag as installed at Plant USA is a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated ERFBS. The Thermo-lag testing addressed the design requirements and limitations of supports and intervening items and their impact on the fire barrier system rating. The testing also established the fire barrier Plant USA Page 32 of 33 1/3/2008 Test Plant USA for Transition Report Examples Jan. 2008.mdb Transition Tool Version 1.0.4

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail system's bounding barrier design, raceway size and type, cable size, fill, and type's.

Interam The fire resistive rating of the Interam ERFBS is established by testing conducted in accordance with the guidance and acceptance criteria of GL 86-10 Supp 1. The Interam as installed at Plant USA is installed in both 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated and 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated ERFBS configurations. The Interam testing addressed the design requirements and limitations of supports and intervening items and their impact on the fire barrier system rating. The testing also established the fire barrier system's bounding barrier design, raceway size and type, cable size, fill, and types.

Meggitt Safety Systems Cable The Meggitt Safety Systems Cable is not specifically an ERFBS but it will be addressed under this section due to its design function and qualification testing equivalent to an ERFBS. The Meggitt Safety Systems Cable was tested to establish that it is capable of performing its design function during and after a fire exposure.

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