ML15316A009
| ML15316A009 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/15/2015 |
| From: | Allen B Pacific Gas & Electric Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Lingam S | |
| References | |
| DCL-15-119, TAC MF2333, TAC MF2334 | |
| Download: ML15316A009 (92) | |
Text
{{#Wiki_filter:Enclosure Attachment 3 PG&E Letter DCL-1 5-119 Updates to the License Amendment Request as a Result of Updated Analyses, Editorial Changes, and Reference Corrections 1
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~ nijanny non,, A ,-rnn,,rn fl~* ,J,, vat. I t~flCL Acronym List (Continued)
SC(O Senior Control Operator SD( C Shutdown Cooling SDF P Significance Determination Process SD*S Shutdown Seal SE Safety Evaluation SEF R Safety Evaluation Report SF Seismic / Fire Interaction 3FF ~Spent Fuel Pool 3FF *E Society of Fire Protection Engineers SG Steam Generator / Short to Ground SG]TR Steam Generator Tube Rupture SI Safety Injection SLE:)CA Small Loss of Coolant Accident SM Shift Manager SO\ V Solenoid Operated Valve SPc 3C Spill Prevention Control and Countermeasures SPLJR Spurious Operation SR Supporting Requirements SRCO Senior Reactor Operator S RN V Safety Relief Valve
*, Safe Shutdown Analysis 2* Systems, Structures, and Components
) Safe Shutdown SSE E Safe Shutdown Earthquake SSE SSE ELSafe Shutdown Equipment List fadd acronym: S FAd (senior SSE L*Supplemental Safety Evaluation ReportSes mic Hazard Analysis Committee)
Safe Shutdown Logic Diagram SSF PS Solid State Protection System STE) Standard STF ~Surveillance Test Procedure SW(GR Switchgear TB Turbine Building TCC DA Time Critical Operator Action TD/ \,FW Turbine Driven Auxiliary Feedwater TEE 3S Thermal Electric Design Standards T-.H Thermal-Hydraulic TI Temperature Indicator TM* S Temperature Monitoring System TR Transition Report (also Temperature Recorder) TS Technical Specifications U1 DCPP Unit 1 U2 DCPP Unit 2 UFS3AR Updated Final Safety Analysis Report UL Underwriters Laboratories UN( C Uncertainty and Sensitivity UPSS Uninterruptible Power Supply V&\/( Verification and Validation VAC 3 Volts Alternating Current Page xii
Pacific Gas and Electric Comoanv 4.0 Compliance with NFPA 805 Reauirements Paii a n lcrcCmoanv 4. Cooincewt NFPA.805 Reuee 4.1.2 Results of the Evaluation Process 4.1.2.1 NFPA 805, Chapter 3, Requirements Met or Previously Approved by the NRC Attachment A contains NEI 04-02, Revision 2, Table B-I, Transition of Fundamental Fire Protection Program and Design Elements. This table provides the compliance basis for the requirements in NFPA 805, Chapter 3. Except as identified in Section 4.1.2.3, Attachment A demonstrates that the FP program at DCPP either:
- Complies directly with the requirements of NFPA 805, Chapter 3,
- Complies with clarification with the requirements of NFPA 805, Chapter 3,
- Complies through the use of existing engineering equivalency evaluations which are valid and of appropriate quality,
- Complies with a previously NRC approved alternative to NFPA 805, Chapter 3, and therefore the specific requirement of NFPA 805, Chapter 3, is supplanted, or
- Complies with the completion of a required action. If DCPP will meet an NFPA 805 section and/or subsection after it completes a document revision or other action (e.g.,
procedure revision or program change), Attachment A lists one or more "Implementation Items" that DCPP is taking and that, once complete, will bring DCPP into compliance with that section and/or subsection (See Attachment S for details). Add bullet: .. . . . . . . . . . . . . . . . . . ,"Section 3.3.5.3 - NRC approval is requested for the existence
- of cables that do not comply with an acceptable flame from the fundamental ceOfover theNRC Prior requirements Approval Spropagation test." Chapter 3, program hir findina of orior approval for the following sections of NFPA 805 Chapter 3:
- None.
.1.2.3 NFPA 805, Chapter 3, Requirements Not Met and Not Previously Approved by NRC he following sections of NFPA 805 Chapter 3 are not specifically met nor do previous NRC a provals of alternatives exist:
*Section 3.2.3(1) - NRC approval is requested for the use of performance-based surveillance frequencies as described in Electric Power Research Institute (EPRI)
Technical Report TR-1006756, "Fire Protection Surveillance Optimization and Maintenance Guide for Fire Protection Systems and Features", July 2003 (Reference 6.27), for the inspection, testing, and maintenance of fire protection systems and features credited by the fire protection program. Section 3.3.5.1 - NRC approval is requested for the existence of wiring (cables) above suspended ceilings.
"* Section 3.3.5.2 - NRC approval is requested for the use of non-metallic conduit.
- Section 3.3.7.2 - NRC approval is requested for the outdoor high-pressure flammable gas storage container configuration.
*Section 3.3.8 - NRC approval is requested for the use of the existing EDG day tank withdrawal connections not having heat-actuated closure valves.
Page 15
P*rifir tr4.* *nrl I::l*rfrir *nmnaml N P.nmnli*nr* *lifh NFDA RN* P*niiir*m*nfe P rifir~ (~2c~ 2nrI Fic~r-trip (~nmn~,n~, A fl (~nmnIi~npn iaitl, MFPA Rfl~ Pg~niiramnnta Results The objective of the NSCA as documented in Report R2165-004-001, "Nuclear Safety Capability Assessment (NSCA)," Revision 0, June 2013 (Reference 6.22), is to demonstrate, using either deterministic or performance based methods of NFPA 805, that DCPP can achieve and maintain Hot Standby (i.e., safe and stable) conditions following a significant and challenging fire event using either det based methods of NFPA 805. The NSCA, including supporting calcu. R4eplace with* ssessment of fire impact on DCPP plant systems and features req "applicable" *ntain Hot Standby from at power conditions. The NSCA replaces the p mpliance assessment for each area that was previously assessed to determine c mpliance with 10 CFR 50, Rmv Appendix R, Section III.G. The NSCA for DCPP includes assessment of the fire impact upon the DCPP pJrfsystems an
- features that are required to achieve and maintai* Mode 3 (Hot Standby er1CPP TS Replace wit]
Table 1.1-1), from Mode 1 (Power Operation). '"l k~"^k-,'d
**%****T ~ow .... .s;÷,**,..,.*':~
"where" Mode 3 applicabilit' for thc NSCA is dcflncd-ae-being up to the point t':h5,the MOO Breakers for the RHR Pump Suction Valves, RHR-1 (2)-8701 and RHR-1 (2)-8702, are 4'-,eecked a÷d lose, at.*.v whc pon pro, prto f hc avs cu utohisrepot. g~
.... v'lw conrol circuitr';. This analysis is discussed in Section 4.2.4 ofthsep.
As part of the transition to NFPA 805, each Fire Area was evaluated forEaining-safe and stable Hot Standby conditions through either a "Deterministic Ap.g c "(NFPA 805,
*PA , ection 4.2.4). The necessary Add:"Whn arecloedthere tesebreker hei capbilty o ahiee asafe and NSC heapliabei n lngr nayss;th hn FP 85,Setins1. ad1.6.56.
NPO Modes Review is applicable.".' """
- 1. DCPP has design features and procedures to ensure that an adequate source of inventory is provided f . . . . . .' , o".. .
conditions (i e., supply d:Ti low o h eoal of decay heat from the Reservoir or Fire Wate eco oln ytm(O) through Atmospheric related tank and has a ta upVlvs(S )va the Steam Generators. volume, if required, wil system (MWS), which ma ealge to the AEWS. hsicudes the seisnlically qualified Fire Water Storg Tn and the Raw Water Reservoirs that have 5 million gallon capacity. These sources of water supply ensure suction capability f otor Driven Auxiliary Feedwater (MDAFWV) Pumps 2 and 3 and TDAFW Pump 1. This will support maintaining safe and stable operations for a sustained period of time.
- 2. DCPP has design features and procedures to ensure that an adequate source of inventory is provided for, ^Ro^,ctor,,C_,oo,,ant*
S^'*,yto*m°" (RCS)- Inventory Control in sustained Hot Standby conditions (i.e., RCS inventory makeup from the Refueling Water Storage Tank (RWST) and/or the Boric Acid Storage Tanks (BASTs) to maintain the RCS sub-cooled) utilizing the Chemical and Volume Control System.t This will support maintaining safe and stable operations for a sustained period of time.
- 3. In order to maintain extended Hot Standby conditions, add Iional negative reactivity must be added to the RCS. This is accomplished by borating th ;ROS while relying on natural circulation in the ROS to ensure adequate mixing of the inj *cted boric acid within the reactor coolant. Existing design features and procedures i¢ll ensure that an adequate
- Add: The RWST is a safety-related tank and has a total capacity /
- of approximately 450,000 gallons. The two BASTs (per unit) are safety-related tanks with a total usable volume of over 14,042 gallons. Additional pressure control capability is provided by the Page 19
- vital pressurizer heaters.
clddwt aculation File No. F.3.15,_Uncertainty and Sensitivity Analysis, Rcviscon 1, datod
.......... In..addition, sensitivitvy to uncertainty associated with specific FPRA parameters was quantitatively addressed in the same calculation.
While the removal of conservatism inherent in the FPRA is a long-term goal, the EPRA results were deemed sufficient for evaluating the risk associated with this application. While PG&E continues to strive toward a more "realistic" estimate of fire risk, use of mean values continues to be the best estimate of fire risk. During the FRE process, the uncertainty and sensitivity associated with specific FPRA parameters were considered in the evaluation of the change in risk relative to the applicable acceptance thresholds. Specific Requirements of NFPA 805 Section 2.7.3 The following discusses how the requirements of NEPA 805 Section 2.7.3 are met both for the NFPA 805 transition and for future revisions to or generation of NFPA 805 related analyses, calculations, or evaluations. NFPA 805 Section 2.7.3.1 - Review Analyses, calculations, and evaluations performed in support of compliance with 10 CFR 50.48(c) are performed in accordance with PG&E procedures that require independent review. These activities are controlled by program directive CF3 and other procedures that include appropriate review requirements. NFPA 805 Section 2.7.3.2 - Verification and Validation Calculational models and numerical methods used in support of compliance with 10 CFR 50.48(c) were verified and validated as required by Section 2.7.3.2 of NFPA 805. These activities are controlled by program directive CF3 and other procedures that include appropriate review requirements. NFPA 805 Section 2.7.3.3 - Limitations of Use Engineering methods and numerical models used in support of compliance with 10 CFR 50.48(c) were applied appropriately as required by Section 2.7.3.3 of NFPA 805. These activities are controlled by program directive CF3 and other procedures that include appropriate review requirements. NFPA 805 Section 2.7.3.4 - Qualification of Users Cognizant personnel who use and apply engineering analysis and numerical methods in support of compliance with 10 CFR 50.48(c) are competent and experienced as required by Section 2.7.3.4 of NFPA 805. During the transition to 10 CFR 50.48(c), work was and will be performed in accordance with the quality requirements of Section 2.7.3 of NFPA 805.'* Personnel who have and will use and apply engineering analysis and numerical methods (e.g., fire modeling) in support of compliance with 10 CFR 50.48(c) are competent and experienced as required by NFPA 805, Section 2.7.3.4. Post-transition, for personnel performing fire modeling or FPRA development and evaluation, PG&E will develop and maintain qualification requirements for individuals assigned various tasks. Position Specific Guides will be developed to identify and document required training and mentoring to ensure individuals are appropriately qualified per the requirements of NFPA 805, Section 2.7.3.4 to perform assigned work (see Attachment 5, Table S-3, Item S-3.23). Page 60
A I"1 *r*rnnl;ane.* I::)*r;fir. ('*.=* =nrl I:=l**'.frir (*_r*rnnn*, I U ifrl l acwVUGIIaU LEr rfnn I*, .a, ~n, II.Ma.lly "'i'S, SJ.I l m - fJIEC*IIItI ~ I*t;*h
.h MI:DA RN* D*nu;l.*m*nfc*
M YVVLflI **1 DA,--ItII.a,- r l U~JUtq,/I\I U II IllC*ILC NFPA 805 Section 2.7.3.5 - Uncertainty Analysis Uncertainty analyses were performed as required by Section 2.7.3.5 of NEPA 805 and the results were considered in the context of the application. This is of particular interest in fire modeling and FPRA development. Note: 10 CFR 50.48(c)(2)(iv) states that NFPA 805, Section 2.7.3.5 is not required for the deterministic approach because conservatism is included in the deterministic criteria. Uncertainty evaluations for the various tasks used to develop the FPRA model (specifically those outlined in NUREGICR-6850) were completed. The uncertainty analyses are contained in Calculation File No. F.3.15, Uncertainty and Sensitivity Analysis, Rc':i!ci 1, datcd
.Hc.,mcr30,20!,.Current and future FPRA model updates will also include uncertainty 4.8.1 Results of the Fire Area Review A summary of the NFPA 805 compliance basis and the required FP systems and features is provided in Table 4-3. The table provides the following information from the NEI 04-02, Revision 2, Table B-3:
- Fire Area / Fire Zone: Fire Area/Zone Identifier.
Description:
Fire Area/Zone Description.
- NFPA 805 Regulatory Basis: Post-transition NFPA 805 Chapter 4 compliance basis (Note: Compliance is determined on a Fire Area basis therefore a compliance basis is not provided for individual fire zones.)
*Required FP System I Feature: Detection / suppression required in the Fire Area based on NFPA 805 Chapter 4 compliance. Other Required Features may include Electrical Raceway Fire Barrier Systems, fire barriers, etc. The documentation of required FP systems and features does not include the documentation of the Fire Area boundaries.
Fire area boundaries are required and documentation of the Fire Area boundaries has been performed as part of reviews of engineering evaluations, licensing actions, or as part of the reviews of the NEI 04-02, Revision 2, Table B-i process. The basis for the requirement of the FP system / feature is designated as follows:
- S - Separation Criteria: Systems/Features required for Chapter 4 Separation Criteria in Section 4.2.3
*L -Licensing Action Criteria: Systems/Features required for acceptability of an NRC approved Licensing Action (i.e., Exemptions/Deviations/Safety Evaluations)
(Section 2.2.7)
*E - EEEE: Systems/Features required for acceptability of Existing Engineering Equivalency Evaluations (Section 2.2.7)
*R - Risk Criteria: Systems/Features required to meet the Risk Criteria for the PB Approach (Section 4.2.4)
*D - Defense-in-depth Criteria: Systems/Features required to maintain adequate balance of DID for a PB Approach (Section 4.2.4)
Attachment W contains the results of the FREs, additional risk of recovery actions, and the change in risk on a Fire Area basis. Page 61
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Recluirements Paii a adEeti Co *n 4. FA85Rqieet ,o~inewt 4.8.2 Plant Modifications and Items to be Completed During the Implementation Phase Planned modifications, studies, and evaluations to comply with NFPA 805 are described in Attachment S. Table S-1 summarizes plant modifications that have already been implemented. Table S-2 summarizes plant modifications that are committed for implementation. Table S-3 provides a list of those items (procedure changes, process updates, and training to affected plant personnel) that will be completed prior to the implementation of the new NFPA 805 FP Program at DCPP. PG&E did not identify any: (1) known outstanding plant changes that would require a change to the EPRA model, or (2) any planned plant changes that would significantly impact the PRA model, beyond those identified and scheduled to be implemented as part of the transition to the 10 CFR 50.48(c) FPP, as set forth in the license condition. The FPRA model represents the as-built, as-operated and maintained plant as it will be configured at the completion of the transition to NFPA 805. The FPRA model includes credit for the planned implementation of the modifications listed in Attachment S. Following completion of the modifications listed in Attachment S, additional refinements surrounding the modifications
- Add ¶J: Alert and alarm response procedure(s) will be developed for the incipient fire detection
- system-signals, and address alarm response for each alert, alarm level, and fault condition.
These procedures will conform to the guidance of FAQ 08-0046 (Incipient Fire Detection SSystems). Specifically, an incipient fire detection system Alert or Alarm will be annunciated in Sthe Main Control Room and investigated immediately by qualified Operations and/or Maintenance personnel. For fault conditions, appropriate compensatory measures will be 4mplee2te Inciien Dhe tecndtion cretem. ys IRasatondnpesnlwilhvsuicntraig Thisnwldgmodifictionewilly fimroefPghtn abtilityioetec incipentuiresind the Carebiae Spreadin Roiieoalom (Cor) andpSolridSate prepcrtion stem/o (espS)romse (obeformbthUitd.ad ) iresutingon, aeduciomnt voftg risatritosaas-esssowilsatghsmdfcto fire rovide anomproveents in Thi modifi~cation haspent montoudelied ands deigedvndinstled will be inacncossryodanefwiththe gudanet prov qidmedt, FaQ 08-0046. SpeCiFicD nII2ially, incipient fire detection i en ntle n reduitmednt win-c netinstallration intlocation that areAnot conitoinuouslyoccupie. Th Th PAcrrnl Ibeyistaledpe nopoae hsmodification reurmntgfNPA7,uaionalc the Fire Alarm004and Faiotie ,accptdmetscrib in8046 FAisused tee stignde5oftails wiLsAtifRthrFQ.804 Page 62
Pacific Gas and Electric Company4.Co linewtNFA85eurmns 4.0 Compliance with NFPA 805 Requirements This modification is not required to satisfy the deterministic requirements of 10 CFR 50, Appendix R. 4.8.2.2 Hot Shutdown Panel Modifications This modification will ensure that required hot shutdown panel (HSDP) functions are independent and electrically isolated from the Main Control Room (MCR) or Cable Spreading Room (CSR) (and the converse), which will allow for achievement of performance criteria in the case of a fire in the MCR or CSR areas for both Units. Connections/interconnections with safety-related plant systems will not cause a reduction in the capability, redundancy, diversity or design margin for those systems. This modification provides an improvement in ACDF and ALERE for both Units. To ensure Decay Heat Removal and Inventory and Pressure Control capabilities are available in the case of a fire in the MCR or CSR, the Hot Shutdown Panel for each Unit will be modified as necessary to provide the following functions:
- Control of *10 percent Steam Dump Valves MS-i (2)-PCV-21 and 22,
- Open/close control and position indications for Refueling Water Storage Tank (RWST) to Charging Pump Suction Header Valve SI-I1(2)-8805A,
- Open/close control and position indications for Cold Leg Loop Charging Valves CVCS-1 (2)-8107 and CVCS-1 (2)-8108 (valves are in series),
- Open/close control and position indications for charging to Cold Leg Loop Valve CVCS-1(2)-8146 to Loop 4,
- Steam Generator 3 and 4 level indication,
- Pressurizer level indication, and
- RCS hot and cold leg temperature indication.
The FPRA currently incorporates this modification by using accepted methods as discussed in Section 4.5 of this LAR. Because this modification is required to satisfy the requirements of both NFPA 805 and 10 CFR 50, Appendix R, compensato measures are in lace and will remain in place until this modification is" d:"ntle n prtoa. 4.8.2.3 RCP Seal Cooling Modification This modification will reduce the risk of a loss of coolant accident (LOCA) resulting from a loss of RCP seal cooling for both Units 1 and 2. This modification does not resolve any VFDRs and is therefore considered to be "beyond compliance". However, it provides an improvement in CDF and LERF for both Units. The FPRA currently incorporates this modification by using accepted methods as discussed in Section 4.5 of this LAR. This modification is required to satisfy the performance-based requirements of NEPA 805. Compensatory measures are currently in place under 10 CER 50, Appendix R to mitigate the potential for loss of RCP Seal Cooling as a result of a fire. For both of these reasons, compensatory measures will remain in place until this modificationadteNPA85Porm 6@ipeeted. Page 63
I::)*rifiP_ ('*.* *nrl I::l*PfriP_ P.nmn*nv *L N r.nmnli*nr* wlth NI=PA RN.q I:*nsJir*m*nt* P rifII, ~ (kl2n il lor*ip I( VVIII* ,iI fil Vnmnii illle e ~i ll i Mli IP R fli Ianirnmigli ti 4.8.2.4 Electrical Raceway Fire Barrier System (ERFBS) Installation This modification will eliminate the need for a Recovery Action associated with ensuring decay heat removal capability is maintained in the event of a fire in Fire Area 3-BB, 115 foot elevation. This modification provides an improvement in ACDF and ALERF for Unit 1. The FPRA currently incorporates this modification by using accepted methods as discussed in Section 4.5 of this LAR. This modification* is not required to satisfy the deterministic requirements of 10 CER 50, Appendix R, but is intended to reduce the additional risk associated with requiring a Recovery Action in the case of a fire in Fire Area 3-BB. Therefore, no compensatory measures are in place. 4.8.2.5 C;able-Re-Routct Ad:"RBEhneet This modification will eliminate the need for a Recovery Action associated with ensuring steam is available to the TDAFW pump, thus reducing the risk of a loss of decay heat removal capability. This modification provides an improvement in ACDF and ALERE for Unit 2. This modification is installed to eliminate VFDRs from Fire Areas 5-B-4 and 6-B-4 in Unit 2 that could result in a loss of steam to the TDAFW pump. The FPRA currently incorporates this modification by using accepted methods as discussed in Section 4.5 of this LAR. Because this modification is required to satisfy the requirements of both NFPA 805 and 10 CFR 50, Appendix R, compensat r i -I amn in place until this modification is r, , ,*,If* ~~q
*r Add "_
I=._insale an operat __1* 1ional." 4.8.3 Supplemental Information - Other Licensee Specific Issues None Page 64
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes I CotinmennB-";: Building 4.24.2. 2 ,:* "Cna 1 1-A Containment Annulus Area Detection -Smoke N N Y Y Y 1 1-A Containment Annulus Area Feature - Radiant Energy Shield N N Y N Y 1 1-A Containment Annulus Area Suppression - None 1 1-B Reactor Steam Generator Area Detection - Smoke N Y Y Y Y 1 1-B Reactor Steam Generator Area Feature - None 1 1-B Reactor Steam Generator Area Suppression - Wet Pipe N Y Y Y Y 1 1-C Reactor Cavity and Operating Deck Detection - Flame N N Y Y Y S1 1-C Reactor Cavity and Operating Deck Feature - None 1 1-C Reactor Cavity and Operating Deck Suppression - None 22 2 Auxr~ila r Detection - None -- .. 2 2 Auxiliary Boiler 3-B-i 3-6-1 RHR Pump 1-1 and Hx Room Detection - Smoke N N Y N Y 3-B-i 3-fl-i RHR Pump i-i and Hx Room Feature - None 3-B-i 3-B-i RHR Pump i-i and Hx Room Suppression - Water Spray N N Y N ¥*, Water spray in adjacent Fire t\ Zp**?,3 protects door to Page 66
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes 3-8-2 3-8-2 RHR Pump 1-2 and Hx Room Detection - Smoke N N* Y N* 3-8-2 3-B-2 RHR Pump 1-2 and Hx Room Feature - None 3-8-2 3-B-2 RHR Pump 1-2 and Hx Room Suppression - Water Spray N N Y N
- Water spray in adjacent Fire
/...*one 3-8-3 protects door to 3-BB Containment Penetration Area .4.2.4.2 *. . ..
- 3-88 3-88 Containment Penetration Area Detection - Smoke N Y Y Y Y 3-8885 smoke detection not credited for risk 3-BB 3-88 Containment Penetration Area Feature - ERFBS N Y Y Y Y 3-88 3-88 Containment Penetration Area Suppression - Wet Pipe N Y Y Y Y 3-8885 auto suppression not provided 0CC* , Containment Penetraton Area 4. 2.4.2 .. ... ,'......., .. ..... ' ,,
3-cc 3-CC Containment Penetration Area Detection - Smoke N Y Y Y Y 3-CC85 smoke detection not credited for risk 3-CC 3-CC Containment Penetration Area Feature - ERFBS N Y Y Y Y 3-CC 3-CC Containment Penetration Area Suppression -Wet Pipe N Y Y Y Y 3-CC85 auto suppression not provided 3-D-1l: ...... RHR Pump 2-1 ,and Hx Roo~m:'* 4.2....3.....................2.. ........ 3-D-1 3-D-1 RHR Pump 2-1 and Hx Room Detection - Smoke N N Y N
- 3-D-1 3-D-1 RHR Pump 2-1 and Hx Room Feature - None 3-D-1 3-D-1 RHR Pump 2-1 and Hx Room Suppression - Water Spray N N Y N Water spray in adjacent Fire Page 67
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes I 3.- RHR:Pumnp 22 and JHx Room 4..........4.. 2....
.2* ...
3-D-2 3-D-2 RHR Pump 2-2 and Hx Room Detection - Smoke N N Y N Y 3-D-2 3-D-2 RHR Pump 2-2 and Hx Room Feature - None 3-D-2 3-D-2 RHR Pump 2-2 and Hx Room Suppression - Water Spray N N Y N J\¥ Water spray in adjacent Fire Zone 3-D-3 protects door to
/ Fire Zone 3-D-2.
i 3-H-I:: ... . ? e t f g-lCharging Pumps l1- 4.2.3.2: ... .. ..........- " *....*:.... ..- * .... '° and 1,-2 Room, . -, 3-H-i 3-H-i Centrifugal Charging Pumps i-i and 1-2 Room Detection - Smoke N N Y N N 3-H-i 3-H-i Centrifugal Charging Pumps 1-1 and 1-2 Room Feature- None 3-H-i 3-H-i Centrifugal Charging Pumps i-i and 1-2 Room Suppression -Water Spray N N Y N N 3-H-i 3-H-i Centrifugal Charging Pumps i-i and 1-2 Room Suppression -Wet Pipe N N Y N N S3-H-2 :Centrifugal Charging Pump 1-;3 , 4;.2.3.2" ' -i:" ,:*.. .. ,* :* * .. I ~~~-Room ..- :. .:*" 3-H-2 3-H-2 Centrifugal Charging Pump 1-3 Room Detection - Smoke N N Y N N 3-H-2 3-H-2 Centrifugal Charging Pump 1-3 Room Feature - None 3-H-2 3-H-2 Centrifugal Charging Pump 1-3 Room Suppression - Wet Pipe N N Y N N Page 68
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes 3-P-12. ,, HVAC,. Filters, 'Fans / ... * *4.2.3.2 +- ' ... . " *-! 3-P-12 3-P-12 HVAC, Filters, Fans Detection -None 3-P-12 3-P-12 HVAC, Filters, Fans Feature-None 3-P-12 3-P-12 HVAC, Filters, Fans Suppression -None 3-0-I. Aux~lar,,*' Feedto,÷r PumpRoo',*m. *:' .4".2 4.2 " "'
"3-0-1"
" 3-0-1 "Auxiliary Feodwator Pump -.Room**-......
*.... "+'Detection. - Smoke
. . " "N N Y N. .Y-3-0-1 3-Q-1 Auxiliary Feodwater Pump Room _.. Fature - None .. .
3-Q-1 3-0-1 Auxiliary Feed,;-atorPump Room "* * '=*"*'3 res - Wet PipeN N Y N Y 3T3-T - -T1 Aux!liary Feed,:ater Pump Room *---*--
- 3-T-i 3-T-i Auxiliary, Feedwator Pump Room Suppression - Wet PipeN N Y N Y 3-V-i 3-V-i HVAC, Filters, Fans Feature- None 3-V-i 3-V-i HVAC, Filters, Fans Suppression - None
_o Page 70
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements* Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes 3-V-5 3-V-5 HVAC, Filters, Fans D2etection,--Smoek N N N 14 N 3-V-5 3-V-5 HVAC, Filters, Fans Feature-None "" 3-V-5 3-V-5 HVAC, Filters, FansSupeso-Nn 3--3-V -V12 HVAC, Filters, Fans 4etet.3nNo2 3-V-12 3-V-12 HVAC, Filters, Fans Dupetecion - None Detection SmNone Page 71
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes 4-A (U1,) Counting, and:Chemical* 4.2,4.2. :; """ '
! ~~~Laboratory .- -
4-A (U1) 4-A Counting and Chemical Laboratory Detection - Smoke N Y Y Y Y 4-A-4J.44 4-A Countring and Chemical Laboratory Featu-re -Radiant Energy Shield 4 ¥ ¥ $4 ¥ 4-A (U1) 4-A Counting and Chemical Laboratory Feature- ERFBS N Y Y N Y 4-A (U1) 4-A Counting and Chemical Laboratory Suppression -Wet Pipe N Y Y Y YiI 4'.-A
.. (U2)
..... Counting
....... and Chemical:-:..
- * " - ...... : 4.2.:3.2:- ......... Feature does.......not..
i Laboratory, :: .exist: 4-A (U2) 4-A Counting and Chemical Laboratory Detection - Smoke N Y Y N N 4-A (U2) 4-A Counting and Chemical Laboratory Feature - ERFBS N Y Y N N 4-A-(Ul2- 4-A Cou-nting and Chemical Laboratory Featu-re -Radiant Energy Shield $4 *4 *4 $ N 4-A (U2) 4-A Counting and Chemical Laboratory Suppression - Wet Pipe N Y Y N N 4-B-i 4-B-I G Bus Compartment Detection - Smoke N N Y N Y 4-B-i 4-B-i G Bus Compartment Feature -None 4-B-i 4-B-i G Bus Compartment Suppression - None 4-,B-2 H Bus-Compartment '" 4.2.4*2': :-..,:,:, - :*: .. : 4-B-2 4-B-2 H Bus Compartment Detection -Smoke N N Y N Y 4-B-2 4-B-2 H Bus Compartment Feature*-None 4-B-2 4-B-2 H Bus Compartment Suppression - None Page 72
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes 6-A-3 Battery, Inverter, and DC " 4.2.4,2 :: S Switchgear, HBus " . . . . - , . . : * , .. ... ..
- 6-A-3 6-A-3 Battery, Inverter, and DC Switchgear, H Bus Detection - Smoke N N Y Y Y 6-A-3 6-A-3 Battery, Inverter, and DC Switchgear, H Bus Feature - None 6-A-3 6-A-3 Battery, Inverter, and DC Switchgear, H Bus Suppression - None
'6-A-4 . Reactor Trip Switch'gear 4.2,.42i" : .,,...." .... . '
6-A-4 6-A-4 Reactor Trip Switchgear Detection - Smoke N N Y Y Y 6-A-4 6-A-4 Reactor Trip Switchgear Feature - None 6-A-4 6-A-4 Reactor Trip Switchgear Suppression - None 6-A-5 6-A-5 e*t...-"Xe
- Detection -Smoke N N Y Y Y 6-A-5 6-A-5 *I~r~a-e <PPC Inverter Room: Feature- None 6-A-5 6-A-5 E~ectreaI-Arsa Suppression - None 6-B-I* , Battery, ,Inverter, and DC : . ... ..- 4.2.4.2 - :- - -- :-:-.... o--:* !
.. .switchgear,.F :Bus . .'"*:: ." ':. .
6-B-i 6-B-I Battery, Inverter, and DC Switchgear, F Bus Detection - Smoke N N Y Y Y 6-B-I 6-B-I Battery, Inverter, and DC Switchgear, F Bus Feature - None 6-B-i 6-B-i Battery, Inverter, and DC Switchgear, F Bus Suppression - None Page 76
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes 6-B-2 *+ Battery, Inverter, and DC4.2.4,2 -
. ..Switchgear,:G-Bus . : .. *..
6-B-2 6-B-2 Battery, Inverter, and DC Switchgear, G Bus Detection - Smoke N N Y Y Y 6-B-2 6-B-2 Battery, Inverter, and DC Switchgear, G Bus Feature - None 6-B-2 6-B-2 Battery, Inverter, and DC Switchgear, G Bus Suppression - None Switchgear, H-Bus + ' .. +++ + 6-B-3 6-B-3 Battery, Inverter, and DC Switchgear, H Bus Detection - Smoke N N Y Y Y 6-B-3 6-B-3 Battery, Inverter, and DC Switchgear, H Bus Feature - None 6-B-3 6-B-3 Battery, Inverter, and DC Switchgear, H Bus Suppression - None 6 -B-4 .. . +Reactor TriP sw itchgear-- .+ .... : 4.2.4.2, .... i - ..... -'+- - + -+ - ; ... : . .. - + + 6-B-4 6-B-4 Reactor Trip Switchgear Detection - Smoke N N Y Y Y 6-B-4 6-B-4 Reactor Trip Switchgear Feature - None 6-B-4 6-B-4 Reactor Trip Switchgear Suppression - None 6-B-5 6-B-5 * *c*aIA.e Detection - Smoke N N Y Y Y 6-B-5 6-B-5 *le~cIAe PP Ivete-Ro Feature- None 6-B3-5 6-B-5 get4aIA* Suppression.- None Page 77
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes 7-A Cable Spreading Room.*. 4.2.4.2.. . 7-A 7-A Cable Spreading Room Detection - Smoke N N Y Y Y 7-A 7-A Cable Spreading Room Detection - Heat N N Y Y Y 7-A 7-A Cable Spreading Room Detection - Incipient- Smoke N N N Y Y Incipient detection to be installed. See Attachment 5, Table S-2, item S-2.4. 7-A 7-A Cable Spreading Room Feature - None 7-A 7-A Cable Spreading Room Suppression - Automatic CO2 N N Y Y Y
!,7-B. :,"Cable SPreading Room ; 4
.42.4.2* ...- " - ...... ... ,
7-B 7-B Cable Spreading Room Detection - Heat N N Y Y Y 7-B 7-B Cable Spreading Room Detection - Smoke N N Y Y Y 7-B 7-B Cable Spreading Room Detection - Incipient - Smoke N N N Y Y Incipient detection to be installed. See Attachment 5, Table S-2, Item S-2.4. 7-B 7-B Cable Spreading Room Feature - None 7-B 7-B Cable Spreading Room Suppression - Automatic CO2 N N Y Y Y C ....... m ,. . s RRoom o.2.3.2.,
, , --- * . -m , ;
- .....4to?....... 7 ::,**- *
,-:-,T**::- . ..... *:,*, * .
7-C 7-C Communications Room Detection - None 7-C 7-C Communications Room Feature - None 7-C 7-C Communications Room Suppression - Automatic CO2 N N4 N N N Page 78
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes 7-0O Communica,..,tions"Room* -4.2.3.2* 7-D 7-D Communications Room Detection - None 7-D 7-D Communications Room Feature - None 7-D 7-D Communications Room Suppression - Automatic CO2 N N N N
'-G -G Sofegua'_rdeo Room.. Dtcin-IcpetSmkN N N Y YIcpetdtciotob 8-G 8-G Safegua'_rds Reem.*
- Feature -None 8-H 8-H & 4,- m Suppression - None Add Page 79
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes i 9 *.Containment Building 4.2.4.2 . . .. ,*
- 9 9-A Containment Annulus Area Detection - Smoke N N Y Y Y 9 9-A Containment Annulus Area Feature - Radiant Energy Shield N N Y N Y 9 9-A Containment Annulus Area Suppression - None rk 9 9-B Reactor Steam Generator Area Detection - Smoke N Y Y Y Y 9 9-B Reactor Steam Generator Area Feature - None 9 9-B Reactor Steam Generator Area Suppression - Wet Pipe N Y Y Y Y 9 9-C Reactor Cavity and Operating Deck Detection - Flame N N Y Y Y 9 9-C Reactor Cavity and Operating Deck Feature - None 9 9-C Reactor Cavity and Operating Deck Suppression - None t10 12kV Switchgear Room and "4.2.4.2 ... i i ~Cable Spreadin~g Room 10 10 12kV Switchgear Room and Cable Spreading Detection - Smoke N N Y Y Y Room 10 10 12kV Switchgear Room and Cable Spreading Feature - ERFBS N N Y Y Y Room 10 10 12kV Switchgear Room and Cable Spreading Suppression - None Room 9 9-A Containment Annulus Area Feature - ERFBS N N Y Y Y Page 80
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes I"27*-A - Boxedl-- Waste Zone 4.."
- 42.3.2 27-A 27-A Boxed Waste Zone Detection - None 27-A 27-A Boxed Waste Zone Feature -None 27-A 27-A Boxed Waste Zone Suppression -Wet Pipe N N N N N i27-B : *Drum: SoaeZone . 4.2.3.2 ' -
27-B 27-B Drum Storage Zone Detection - None 27-B 27-B Drum Storage Zone Feature -None 27-B 27-B Drum Storage Zone Suppression - Wet Pipe N N N N N
,27-C 0Contaminated Oil-Storage : .. " 4.2.3.2 ***, * , .. * *. . . * * :
27*C 27-C Contaminated Oil Storage Detection - None 27-C 27-C Contaminated Oil Storage Feature - None 27-C 27-C Contaminated Oil Storage Suppression - Wet Pipe N N N N N 28 Main Transformer Area 4.2.4.2.. ..... :*i: i'......... ::-- i--i : .... "*°...- 28 28 Main Transformer Area Detection - None 28 28 Main Transformer Area Feature - None 28 28 Main Transformer Area Suppression - Water-$t N N Y ¥ Y Deluge Nae8 Page 84
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes
'29 Main Transformer Area 4.2.4.2 29 29 Main Transformer Area Detection - None 29 29 Main Transformer Area Feature - None 29 29 Main Transformer Area Suppression - WNater-pr.ay N N Y ¥ Y 30-A-I Auxiliary. Saltwater Pump i-1 -4.2.4.2 Vault Deug 30-A-i 30-A-I Auxiliary Saltwater Pump 1-I Vault Detection - None 30-A-i 30-A-I Auxiliary Saltwater Pump I-I Vault Feature - None 30-A-i 30-A-I Auxiliary Saltwater Pump 1-1 Vault Suppression - None 30-A-2 ~ ' Auxiliary Saltwater Pump l.2. 4.2.4,2 ,
Vault : 30-A-2 30-A-2 Auxiliary Saltwater Pump 1-2 Vault Detection - None 30-A-2 30-A-2 Auxiliary Saltwater Pump 1-2 Vault Feature - None 30-A-2 30-A-2 Auxiliary Saltwater Pump 1-2 Vault Suppression - None 30-A-3 Auxiliary Saltwater Pump 2-1 4.2.4.2
- ~Vault i 30-A-3 30-A-3 Auxiliary Saltwater Pump 2-I Vault Detection - None 30-A-3 30-A-3 Auxiliary Saltwater Pump 2-1 Vault Feature - None 30-A-3 30-A-3 Auxiliary Saltwater Pump 2-I Vault Suppression - None Page 85
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes S30-A-4 Auxiliary. Saltwater Pump. 2-2 ,,4.2.4.2
" ~Vault.
30A43-- uiirySlwtrPm - VutDtcin-Nn 30-A-4 30-A-4 Auxiliary Saltwater Pump 2-2 Vault Featueto- None 30-A-4 30-A-4 Auxiliary Saltwater Pump 2-2 Vault Suppuresin-None
,33 SecurityDiesel Generator Room. 4'.2.3.2- *,
33 33 Security Diesel Generator Room Detection - Smoke N N N N N 33 33 Security Diesel Generator Room Feature - None 33 33 Security Diesel Generator Room Suppression -. Wet Pipe N N N N N .34(U1) Auxiliary'Building Roof . " '4.2.4.2 ". 34 (UI) 34 Auxiliary Building Roof Detection - None 34 (UI) 34 Auxiliary Building Roof Feature- None 34 (U1) 34 Auxiliary Building Roof Suppression -Wet Pipe N N Y ¥ Y ..34 ..... AuxiliaryBuilding Roof4.42 34 (U2) 34 Auxiliary Building Roof Detection - None 34 (U2) 34 Auxiliary Building Roof Feature - None 34 (U2) 34 Auxiliary Building Roof Suppression.- Wet Pipe N N Y Y Page 86
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes AB-1 (U1) Auxiliary Building 4.2.4.2 AB1Ul 3-A Liquid Holdup Tank Area Feature - None AB-1 (UI) 3-A, Liquid Holdup Tank Area Suppression - None AB-1 (Ul) 3-AA Auxiliary Building Elevation 115 Feet Detection - Smoke N N Y N Y AB-1 (U1) 3-AA Auxiliary Building Elevation 115 Feet Feature - None AB-1 (Ul) 3-AA Auxiliary Building Elevation 115 Feet Suppression - Wet Pipe N N Y N Y AB-1 (Ul) 3-B-A Boron Injection Tank Detection - None AB-1 (U1) 3-B-.3 Boron Injection Tank Feature - None AB-1 (U1) 3-8-3 Boron injection Tank Suppression - Water Spray N N Y N Y *Fire door exemption (3-B-i & 3-B-2) credits water spray. Water spray is present in Fire Zone 3-B-3. AB-1 (UI) 3-C Auxiliary Building Elevation 54, 64, and 73 Feet Detection - Smoke N Y Y N Y AB-1 (Ul) 3-C Auxiliary Building Elevation 54, 64, and 73 Feet Feature - ERFBS N Y- N N - 'N* AB-1 (UI) 3-C Auxiliary Building Elevation 54, 64, and 73 Feet Suppression - None _N AB-1 (Ul) 3-D-3 Boron Injection Tank Detection - None AB-1 (Ul) 3-D-3 Boron injection Tank Feature - None AB-1 (U1) 3-D-3 Boron injection Tank Suppression - Water Spray N N Y N Y *Fire door exemption (3-D-1 & 3-D-2) credits water spray. Water spray is present in Fire 88 Zone 3-D-3. Page Page 88
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes lAB-I"(UI) Auxiliary Building 4.2.4.2 AB-1 (UI) 3-K-2 Component Cooling Water Pump 2-2 Detection - Smoke N Y Y' N Y AB-1 (Ul) 3-K-2 Component Cooling Water Pump 2-2 Feature - Radiant Energy Shield N Y Y N Y AB-1 (Ul) 3-K-2 Component Cooling Water Pump 2-2 Suppression - Wet Pipe N Y Y N Y AB-1 (Ul) 3-K-3 Component Cooling Water Pump 2-3 Detection - Smoke N Y Y N Y AB-1 (U1) 3-K-3 Component Cooling Water Pump 2-3 Feature - Radiant Energy Shield N Y Y N Y AB-1 (UI) 3-K-3 Component Cooling Water Pump 2-3 Suppression - Wet Pipe N Y Y N Y AB-1 (U1) 3-L Auxiliary Building Elevation 85 and 100 Feet Detection - Smoke N N Y N Y AB-1 (U1) 3-L Auxiliary Building Elevation 85 and 100 Feet Feaue RB N N N N ¥ AB-1 (U1) 3-Q2MoSftor DivjecinAuxiirmeewtrpump Detection - Smoke\ AB-1 (Ul) 3-QN Motrarient uilay Fne edwaoe Pumps Feature - None . . . AB-1 (Ul) 3-Q-2 Motor Driven Auxiliary Feedwater Pumps Suppression -Wet Pipe \N N Y Y Y
~Page 90
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone -Description Basis Type S L E R D Notes 'AB-1 (UI) Auxiliary Building ,,4.2.4.2 - AB-1 (U1) 3-R Spent Fuel Pool .Detection - Smoke N N Y N Y AB-1 (U1) 3-R Spent Fuel Pool Feature- None AB-1 (U1) 3-R Spent Fuel Pool Suppression - None AB-1 (UI) 3-S Auxiliary Building Elevation 140 Feet Detection - Flame N N N N *-N AB-1 (U1) 3-S Auxiliary Building Elevation 140 Feet Feature - None AB-1 (U1) 3-S Auxiliary Building Elevation 140 Feet Suppression - None AB-1 (UI) 3-T-2 Motor Driven Auxiliary Feedwater Pumps Detection - Smoke N N Y Y Y AB-1 (U1) 3-T-2 Motor Driven Auxiliary Feedwater Pumps Feature - None AB-1 (U1) 3-T-2 Motor Driven Auxiliary Feedwater Pumps Suppression - Wet Pipe N N Y Y Y AB-1 (U1) 3-W Spent Fuel Pool Detection - Smoke N N Y N Y AB-1 (Ul) 3-W Spent Fuel Pool Feature- None AB-1 (U1) 3-W Spent Fuel Pool Suppression-Wet Pipe N N Y N Y AB-1 (U1) 3-X Auxiliary Building Elevation 100 Feet Detection - Smoke N N Y Y Y AB-1 (Ul) 3-X Auxiliary Building Elevation 100 Feet Feature - None AB-1 (U1) 3-X Auxiliary Building Elevation 100 Feet Suppression -Wet Pipe N N Y Y Y AB-1 (U1) 8-B-i Supply Fan Room Detection -Smoke N N N4 N Y AB-1 (U1) 8-B-i Supply Fan Room Feature- NoneY AB-I (U1) 8-B-I Supply Fan Room Suppression None. Page 91
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes AB-1 (UIt) *AuxiliaryBuilding - 4.2.4.2 AB-i (UI) 8-B-2 Supply Fan Room Detection- Smoke N N N N Y AS-i (U1) 8-B-2 Supply Fan Room Feature- None "_Y.* AB-1 (U1) 8-5-2 Supply Fan Room Suppression -Wet Pipe N N ,N N Y AS-i (U1) S-2 Stairwell S-2 Detection- None "Y"' AB-i (Ul) S-2 Stairwell S-2 Feature- None AS-i (U1) S-2 Stairwell S-2 Suppression - None AR-I (U1) S-3 Stairwell S-3 Detection - None AS-I (UI) S-3 Stairwell S-3 Feature- None AB-1 (UI) S-3 Stairwell S-3 Suppression - None AB-i (U1) S-4 Stairwell S-4 Detection - None AB-i (U1) S-4 Stairwell S-4 Feature- None AB-l (U1) S-4 Stairwell S-4 Suppression - None AB-I (U1) S-8 Stairwell S-8 Detection - None AB-i (U1) S-8 Stairwell S-8 Feature- None AS-i (U1) S-8 Stairwell S-8 Suppression-Wet Pipe N N N N *: AS-i (UI) S-9 Stairwell S-9 Detection - None AS-i (UI) S-9 Stairwell S-9 Feature-None \ AS-i (U1) S-9 .Stairwell S-9 "Su~pp.ressin-
.NoneM,,.,
Page 92
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire RegulatorY Required? Area Zone Description Basis Type S L E R D Notes
- B-1 (UL2,) Auxiliary ,Building 4:2.4.2 ...... **
AB-1 (U2) 3-A Liquid Holdup Tank Area Detection - None AB-1 (U2) 3-A Liquid Holdup Tank Area Feature - None AR-i (U2) 3-A Liquid Holdup Tank Area Suppression - None AR-i (U2) 3-AA Auxiliary Building Elevation 115 Feet Detection - Smoke N N Y N Y AB-1 (U2) 3-AA Auxiliary Building Elevation 115 Feet Feature - None AB-i (U2) 3-AA Auxiliary Building Elevation 115 Feet Suppression - Wet Pipe N N Y N Y AB-1 (U2) 3-B-3 Boron Injection Tank Detection - None AB-1 (U2) 3-R-3 Boron Injection Tank Feature - None AR-i (U2) 3-B-3 Boron Injection Tank. Suppression - Water Spray N N Y N Y AR-I (U2) 3-C Auxiliary Building Elevation 54, 64, and 73 Feet Detection - Smoke N Y Y N Y AR-I (U2) 3-C Auxiliary Building Elevation 54, 64, and 73 Feet Feature - ERFBS N ¥ N N ¥ AR-i (U2) 3-C Auxiliary Building Elevation 54, 64, and 73 Feet Suppression - None AR-I (U2) 3-D-3 Boron Injection Tank Detection - None AR-i (U2) 3-D-3 Boron Injection Tank Feature - None AR-i (U2) 3-D-3 Boron Injection Tank Suppression -Water Spray N N Y N Y AR-i (U2) 3-F Containment Spray Pumps Detection - Smoke N N Y N Y AR-i (U2) 3-F Containment Spray Pumps Feature - None AR-i (U2) 3-F Containment Spray Pumps Suppression - None 94 Page Page 94
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes
- ALB-. (U2): Auxiliary Building 4.2.4.2* ..
AB-1 (U2) 3-K-3 Component Cooling Water Pump 2-3 Detection - Smoke N Y Y N Y AB-1 (U2) 3-K-3 Component Cooling Water Pump 2-3 Feature - Radiant Energy Shield N Y Y N Y AB-1 (U2) 3-K-3 Component Cooling Water Pump 2-3 Suppression - Wet Pipe N Y Y N Y AB-1 (U2) 3-L Auxiliary Building Elevation 85 and 100 Feet Detection - Smoke N N Y N Y AB-1 (U2) 3-L Auxiliary Building Elevation 85 and 100 Feet FetueERB N N. N N ¥ AB-1 (U2) 3-L Auxiliary Building Elevation 85 and 100 Feet Suppression - Non* .. AB-1 (U2) 3-M Safety Injection Pumps Deeto SoeN N Y N Y AB-1 (U2) 3-M Safety Injection Pumps Feature - None \... AB-1 (U2) 3-M Safety Injection Pumps Supeso None. AB-1 (U2) 3-R Spfenty FujeltoPool s Feature-Non AB-1 (U2) 3-R Spent Fuel Pool Suppuresin-None\
~Page 96
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes
- B-1 *(U2) Auxiliary. Building ' ,4.-2.4.2 ". .
AB-1 (U2) 3-S Auxiliary Building Elevation 140 Feet Detection - Flame N N N N Y AB-1 (U2) 3-S Auxiliary Building Elevation 140 Feet Feature - None AB-1 (U2) 3-S Auxiliary Building Elevation 140 Feet Suppression - None AB-1 (U2) 3-T-2 Motor Driven Auxiliary Feedwater Pumps Detection - Smoke N N Y Y Y AB-1 (U2) 3-T-2 Motor Driven Auxiliary Feedwater Pumps Feature - None AB-1 (U2) 3-T-2 Motor Driven Auxiliary Feedwater Pumps Suppression - Wet Pipe N N Y Y Y AB-1 (U2) 3-W Spent Fuel Pool *"Detection - Smoke N N Y N Y AB-1 (U2) 3-W Spent Fuel Pool Feature- None AB-1 (U2) 3-W Spent Fuel Pool Suppression -Wet Pipe N N Y N Y AB-1 (U2) 3-X Auxiliary Building Elevation 100 Feet Detection - Smoke N N Y Y Y AB-1 (U2) 3-X Auxiliary Building Elevation 100 Feet Feature - None AB-1 (U2) 3-X Auxiliary Building Elevation 100 Feet Suppression -Wet Pipe N N Y Y Y AB-1 (U2) 8-B-i Supply Fan Room Detection -Smoke N N N *4 . Y*,' AB-1 (U2) 8-B-I Supply Fan Room Feature- None AB-1 (U2) 8-B-i AB-1 (U2) 8-B-2 Supply Fan Room Supply Fan Room Supro" onNon Detection -Smoke
\~ N N N*,,
AB-1 (U2) 8-B-2 Supply Fan Room Feature - None ... AB-1 (U2) 8-B-2 Supply Fan Room *Suppression - Wet Pipe N N N4 N . Suppression -Wet Pipe N N Y N Y .. Page 97
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes AB- (U. Auxilia.....Building 4.2.4.2: AR-i (U2) S-2 Stairwell S-2 Detection - None AR-1 (U2) S-2 Stairwell S-2 Feature- None AB-1 (U2) S-2 Stairwell 5-2 Suppression - None AB-i (U2) S-3 Stairwell S-3 Detection - None AB-1 (U2) S-3 Stairwell S-3 Feature- None AR-i (U2) S-3 Stairwell S-3 Suppression - None AB-i (U2) S-4 Stairwell S-4 Detection - None AB-1 (U2) S-4 Stairwell S-4 Feature- None AR-I (U2) S-4 Stairwell S-4 Suppression - None AB-i (U2) S-8 Stairwell S-8 Detection -None AR-I (U2) S-8 Stairwell S-8 Feature- None AR-i (U2) S-8 Stairwell S-8 Suppression *Wet Pipe N N N N AR-i (U2) S-9 Stairwell S-9 Detection - None AB-1 (U2) S-9 Stairwell S-9 Feature- None AR-i (U2) S-9 Stairwell S-9 Suppression - None AR-i (U2) S-10 Stairwell S-10 Detection - None AR-i (U2) S-10 Stairwell S-10 Feature- None AR-i (U2) S-i0 Stairwell S-i0 Suppression - None Page 98
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes AB-1 (U2) S-il Stairwell S-li Detection - None AB-i (U2) S-Il Stairwell S-li Feature- None AB-i (U2) S-il Stairwell S-li Suppression - None AB-2 8-5 ElectricalAreaNentilation Room 4etc2in- on AB-2 8-B-5 Electrical AreaNentilation Room Deatueto - None AB-2 8-B-5 Electrical AreaNentilation Room Features-sNon-Noe AB-2 8-B-6 Electrical]Area/Ventilation Room Supesscion - None AB-2 8-B-6 Electrical Area/Ventilation Room Deatueto - None AB-2 8-8-6 Electrical Area/Ventilation Room FeaturessiNon-Noe AB-2 S-5 Stairwell S-5 Detection - None AB-2 S-5 Stairwell S-5 Feature -None
- AB-2 S-5 Stairwell S-5 Suppr~o_.o_!n -Wet Pipe Su ress o ;'No e...... "--'"--:-:"'
Page 99
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes pR-i. (U2).... Control Room Complex 4..2.4.2. .... , , *.. . CR-I (U2) 8-F Office Detection - Smoke N N Y N Y CR-i (U2) 8-F Office Feature- None CR-I (U2) 8-F Office Suppression - None !FB-I* (UI,). Fuel.Handling'Building 4.2.4.2 ....... :" ' FB-1 (U1) 3-0 Spent Fuel Pool Heat Exchanger Room Detection - Smoke N N Y N Y FB-1 (U1) 3-0 Spent Fuel Pool Heat Exchanger Room Feature- None FB-1 (U1) 3-0 Spent Fuel Pool Heat Exchanger Room Suppression - None FB-1 (U1) 31 Fuel Handling Building Corridor Detection - None FB-1 (U1) 31 Fuel Handling Building Corridor Feature - None FB-1 (U1) 31 Fuel Handling Building Corridor Suppression-Wet Pipe N N Y 2¥ Y B-(U) Fuel Handling Buildingr . *..'4,2;4.2. .. .:- N.. .... ..: FB-1 (U2) 3-0 Spent Fuel Pool Heat Exchanger Room Detection - Smoke N N Y N Y FB-1 (U2) 3-0 Spent Fuel Pool Heat Exchanger Room Feature - None FB-1 (U2) 3-0 Spent Fuel Pool Heat Exchanger Room Suppression - None FB-1 (U2) 31 Fuel Handling Building Corridor Detection - None FB-1 (U2) 31 Fuel Handling Building Corridor Feature - None FB-1 (U2) 31 Fuel Handling Building Corridor Suppression :- Wet Pipe N N Y N Y Page 104
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes iTB-I. Emergency Diesel. Generator 1-1 4.2.3.2 ,..i TB-i 11-A-I Emergency Diesel Generator 1-1 Detection - Heat N N Y N N TB-I 11-A-I Emergency Diesel Generator 1-1 Feature - None TB-i 11-A-I Emergency Diesel Generator 1-1 Suppression - Automatic CO2 N N Y N N TB-I I11-A-2 Emergency Diesel Generator 1-1 Intake and De~tection Heat
-4 11 A 2 Emcrmncy Dicscl Gncnrator 11!intako. an~d Fcat'-ro .Nno eeton-Nn Exhausct Room TB-2 11-B-I Emergency Diesel Generator 1-2 nak n Suppression - Automatic CO2 N N Y N N TTB- 1B-2 Emergency Diesel Generator 1 Intake2and I-2 Detection H-t nn4 .. . ----
TB2 11-B-1 Emergency Dicsel Genorator 1-2 SnacadFauprossion-AuomaicCO2 NO N------Y----N-----N TB-2 11-B-2 Emergency Diesel Generator 1-2 Intake and Supe*o AutomaticNC Exhaust Room {=L 11E* G."*rccr
*mg,'*y!*s!
2 ."t~k *,,d
- Dupe sscion - None ..................
*B-*
l--2 merenc Feseeeature Fu Oi 1-2 tael aan k FillValess~ ~ NAt.rq3~ Y CN N N N Page 106
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes TB-3 Emergency Diesel Generator 1-3 4.2.3.2 .. TB-3 11-C-i Emergency Diesel Generator 1-3 Detection - Heat N N Y N N TB-3 11-C-i Emergency Diesel Generator 1-3 Feature- None TB-3 11-C-i Emergency Diesel Generator 1-3 Suppression - Automatic C02 N N Y N N TB-3 1 1-C-2 Emergency Diesel Generator 1-3 Intake and DeetonHa N N *Y N N* Exhaust Room
/,Exhaust Room TB-3 11-0 2 Emergency Diesel Generator 1-3 Intake and Suppression -Auto.matic C02 N N
- N N
. * --Exh~au~stRoom ..................... .. .... ....... . . . .. .. . . . . .. . . .
iTB-4 , 4kV Switchigear Room and Cable . 4.2.4.2 " - ' *Suppression - None. . . . .. : i \~Spreading Room, F Bus : TB-4 12-A *kV Cable Spreading Room, F Bus Detection - SmokeN N Y Y Y TB-4 13-A 4kV blSprchearinRoom, F Bus Feature - None. . . TB-4 13-A 4kV abwitSgearinRoom, F Bus Suppression - None. . . TB43- 4V 4 Fhea tuReom,FBuel OiDa akilVlesetin-YmNkN N N Y Y Y Page 107
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes iTB-7 (UI) Turbine Deck and Main. 4,2.4,2
! ~ ~~Condenser Area ,i TB-7 (U1) 14-E Component Cooling Water Heat Exchanger Room Feature - None TB-7 (U1) 14-E Component Cooling Water Heat Exchanger Room Suppression - Wet Pipe N N Y N Y TB-7 (U1) 16 Machine Shop Detection -None TB-7 (U1) 16 Machine Shop Feature- None TB-7 (U1) 16 Machine Shop Suppression -Wet Pipe N N N N * '
TB-7 (U1) 19-A Main Condenser, Feedwater, and Condensate Detection - None Equipment Area TB-7 (UI) 19-A Main Condenser, Feedwater, and Condensate Feature - None Equipment Area TB-7 (Ul1) 19-A Main Condenser, Feedwater, and Condensate Suppression - Water Spray N N Y Y Y Equipment Area TB-7 (UI) 19-A Main Condenser, Feedwater, and Condensate Suppression -Wet Pipe N N Y Y Y Equipment Area TB-7 (U1) 19-B Electrical Load Center Detection - Smoke N N Y N Y TB-7 (U1) 19-B Electrical Load Center Feature- None TB-7 (U1) 19-B Electrical Load Center Suppression - None TB-7 (U1) 19-C Oil Reclamation and $* e- m Detection - None TB-7 (U1) 19-C Oil Reclamation and -- Storage Room" None TB-7 (U1) 19-C Oil Reclamation and Suppression - Wet Pipe N N N N
- N TB-7 (U1) 19-D Turbine Deck Detection- Heat N N Y Y Y Page 110
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis ,Type S L E R D Notes fTB-7 (U2) Turbine'Beck and ,Main* 4'.2.4.'2 ..
! Condenser Area, TB7(2 14E CmoetCoigWtrHaExhneRomFaue-on TB-7 (U2) 14-E Component Cooling Water Heat Exchanger Room Suppureson- WoetPpN N Y N Y TB-7 (U2) 16 Machine Shop Detection - None TB-7 (U2) 16 Machine Shop Feature -None TB-7 (U2) 16 Machine Shop Suppression -Wet Pipe N N N N
- N*
TB-7 (U2) 19-A Main Condenser, Feedwater, and Condensate Detection - None Equipment Area TB-7 (U2) 19-A Main Condenser, Feedwater, and Condensate Feature - None Equipment Area TB-7 (U2) 19-A Main Condenser, Feedwater, and Condensate Suppression - Water Spray N N Y Y Y Equipment Area TB-7 (U2) 19-A Main Condenser, Feedwater, and Condensate Suppression - Wet Pipe N N Y Y Y Equipment Area TB-7 (U2) 19-B Electrical Load Center Detection - Smoke N N Y N Y TB-7 (U2) 19-B Electrical Load Center Feature- None TB-7 (U2) 19-B Electrical Load Center Suppression - None TB-7 (U2) 19-C Oil Reclamation and Detection-.None TB-7 (U2) 19-C Oil Reclamation and h#ae£4a<--Storage Room *None TB-7 (U2) 19-C Oil Reclamation and *Pae-4 Suppression - Wet Pipe -N N N N ¥ TB-7 (U2) 19-D Turbine Deck Detection- Heat N N Y Y Y Page 113
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes T1B-B Emergency Diesel Generator 2-1 4.2.3.2; TB-8 22-A-i Emergency Diesel Generator 2-1 Detection - Heat N N Y N N TB-8 22-A-i Emergency Diesel Generator 2-1 Feature - None TB-8 22-A-I Emergency Diesel Generator 2-1 Suppression - Automatic CO2 N N Y N N TB-8 22-A-2 Emergency Diesel Generator 2-1 Intake and DetNctionNHeat
- -- rI e -Suppression -Auto~matic 002 N N Ž- N N TB-9 22-B-I Emergency Diesel Generator 2-2 Detection - Heat TB-9 22-B-I Emergency Diesel Generator 2-2 Feature - None TB-9 22-B-i Emergency Diesel Generator 2-2 Suppression - Automatic C02 N N Y N N TB-9 22-B-2 Emergency Diesel Generator 2-2 Intake and Dtcin Ha _ .N N
- NN Exhaust Room A
*tion - None-------------....
OO I~zOEmergency*n-., Diesel Gene*ratorJr 202 Intake* ,andl l TB-9 B-2 Emege Disel Generator 2-2 Intake and Suppression -Automatic 002 N N ¥ N N 115 Page Page 115
Pacific Gas and Electric Company 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire Fire Regulatory Required? Area Zone Description Basis Type S L E R D Notes I TB-16 - Unit 2Buttress Area/Technicai, ,4.2.3.2* .-. , ,,.. .. .. .. .. ... ° ,, ... *. . .. . . . . . i, "' ~supportcenter' ".. .- TB-16 TB-16 Unit 2 Buttress Area/Technical Support Center Detection - Smoke N N N N N TB-16 TB-16 Unit 2 Buttress Area/Technical Support Center Feature- None TB-16 TB-16 Unit 2 Buttress Area/Technical Support Center Suppression-Wet Pipe N N N N N TB---717 Emergency Diesel2es i Generator en rto -3 4....................... 2.3.2*, ...3 ...... * .,*. ....T........ 7 - -: TB-17 22-C-i Emergency Diesel Generator 2-3 Detection - Heat N N Y N N TB-17 22-C-i Emergency Diesel Generator 2-3 Feature - None TB-17 22-C-I Emergency Diesel Generator 2-3 Suppression-Automatic C02 N N Y N N TB-17 22-C-2 Emergency Diesel Generator 2-3 Intake and DtcinHa TB-17 22-C-2 Emergency Diesel Generator 2-3 Intake and Suppure-sioneAtmtcC0 Exhaust Room Page 119
based methods is requested a at,..
! tltoll* *[i3 fit, 00 II4*
an at. E.IauqrIn
.*~tt*
I 'nnO4EI*not~ fit, SSsJflfi nuan ~ 1 fo om xisting cables. See
*Attachment L, Approval
*;Request 6. For the remainder Table 5-3 10 CFR 50.48(c) - Applicability/Compliance Rel e! of existing cables, Selectrical..'" . . .....
10 CFR 50.48(c) Section(s) A e erence
/
(v) Existing cables. In lieu of installing cables meeting flame propagation Eleetf~eal cable construction tests as required by Section 3.3.5.3, a flame-retardant coating may be complies with a flame applied to the electric cables, or an automatic fixed fire suppression system propagation test that was may be installed to provide an equivalent level of protection. In addition, the found acceptable to the NRC italicized exception to Section 3.3.5.3 is not endorsed. as documented in NEI 04-02, Revision 2, Table B-I. (vi) Water supply and distribution. The italicized exception to Section 3.6.4 is DCPP complies with not endorsed. Licensees who wish to use the exception to Section 3.6.4 NFPA 3.6.4 (without the use must submit a request for a license amendment in accordance with of the exception) as paragraph (c)(2)(vii) of this section. documented in NEI 04-02, Revision 2, Table B-i. (vii) Performance-based methods. Notwithstanding the prohibition in The use of performance-Section 3.1 against the use of performance-based methods, the fire based methods for NFPA 805 protection program elements and minimum design requirements of Chapter 3 is requested. See Chapter 3 may be subject to the performance-based methods permitted Attachment L. elsewhere in the standard. Licensees who ~vish to use performance-based methods for these fire protection program elements and minimum design requirements shall submit a request in the form of an application for license amendment under § 50.90. The Director of the Office of Nuclear Reactor Regulation, or a designee of the Director, may approve the application if the Director or designee determines that the performance-based approach; (A) Satisfies the performance goals, performance objectives,.and performance criteria specified in NFPA 805 related to nu*;lear safety and radiological release; (B) Maintains safety margins; and (C) Maintains fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability). (3) Compliance with NFPA 805. See below (i) A licensee may maintain a fire protection program that complies with The LAR was submitted in NFPA 805 as an alternative to complying with paragraph (b) of this section accordance with for plants licensed to operate before January 1, 1979, or the fire protection 10 CFR 50.90. The LAR license conditions for plants licensed to operate after January 1, 1979. The included applicable license licensee shall submit a request to comply with NFPA 805 in the form of an conditions, orders, technical application for license amendment under § 50.90. The application must specifications/bases that identify any orders and license conditions that must be revised or needed to be revised and/or superseded, and contain any necessary revisions to the plant's technical superseded. specifications and the bases thereof. The Director of the Office of Nuclear Reactor Regulation, or a designee of the Director, may approve the application if the Director or designee determines that the licensee has identified orders, license conditions, and the technical specifications that must be revised or superseded, and that any necessary revisions are adequate. Any approval by the Director or the designee must be in the form of a license amendment approving the use of NFPA 805 together with any necessary revisions to the technical specifications. (ii) The licensee shall complete its implementation of the methodology in The LAR and transition report Chapter 2 of NFPA 805 (including all required evaluations and analyses) summarize the evaluations and, upon completion, modify the fire protection plan required by~paragraph and analyses performed in (a) of this section to reflect the licensee's decision to comply with NFPA 805, accordance with Chapter 2 of before changing its fire protection program or nuclear power plant as NFPA 805. permitted by NFPA 805. Page 127
P*rifir P.* *nH I::l*rfrir P.*mn*nw P2~~fi,(~2Q2ndI~Iafri (~hmn~~, l pa, ,o~nn ~ ohn
- Involve a significant reduction in a margin of safety.
This evaluation is contained in Attachment Q. Based on the considerations discussed above; (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. PG&E has evaluated the proposed amendment and determined that it involves no significant hazards consideration. 5.3.2 Environmental Consideration Pursuant to 10 CFR 51.22(b), an evaluation of the LAR has been performed to determine whether it meets the criteria for categorical exclusion set forth in 10 CER 51.22(c). That evaluation is discussed in Attachment R. The evaluation confirms that this LAR meets the criteria set forth in 10 CFR 51.22(c)(9) for categorical exclusion from the need for an environmental impact assessment or statement. 5.4 Revision to the UFSAR After the approval of the LAR, in accordance with 10 CFR 50.71(e), the DCPP UFSAR will be revised. The format and content will be consistent with NEI 04-02, Revision 2, FAQ 12-0062. 5.5 Transition Implementation Schedule The following schedule for transitioning DCPP to the new FP licensing basis requires NRC approval of the LAR in accordance with the following schedule: Implementation of the new NFPA 805 EP Program to include procedure changes, process updates, and training to affected plant personnel will occur 1.--,ftrissuance of the license amendment (see Attachment S, Table S-3). PG&E will complete modifications necessary to support the n
- basis for transitioning to NFPA 805 by the end of the Units 1 and 2 Refueling Outages, currently scheduled for April/May 2017 (1R20) and February/March 2018 (2R20), respectively. All modifications have been planned and are in the site's long term budget. Appropriate compensatory measures will be established per OM8.1D2, "Fire System Impairment," and maintained until modifications are complete (see Attachment S, Table S-2).
Page 129
Pacific Gas and Electric Company Paciic Gs an Elctri ComanyAttachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element NFPA 805 Reauirement Compliance Statement Compliance Basis Reference Document STP M-80A, Outdoor Fire Hose Operability Test STP M-80B, Indoor Fire Hose Operability Test STP M-800, Long Term Cooliqg Water Pump Hose Annual Operability and Hydrostatic Test STP M-80D, Fire Hose Hydrostatic Testing STP P 21, Testing of the Portable Long Term Cooling Pumps STP P-FPP-A01, Fire Pump 0-1 Performance Test STP P-FPP-A02, Fire Pump 0-2 Performance Test Remove from LAR. STP P-FPP-A03, Fire Pump 0-3 Equipment referenced in Performance Test procedure is not credited for the NFPA 805 fire STP P-FPP-A04, Fire Pump 0-4 Performance Test protection program. STP P-FPP-B01 Fire Pump 0-1 Routine Surveillance STP P-FPP-B02, Fire Pump 0-2 Routine Surveillance STP P-FPP-B03, Fire Pump 0-3 Routine Surveillance STP P-FPP-B04, Fire Pump 0-4 PageA-II
Pacific Gas and Electric Company Paciic Gs an Elctri ComanyAttachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element NFPA 805 Requirement; ,Compliance Statement; Compliance Basis Reference Document 3.3.5.3 [Electrical Electric cable construction shall ° Complies with Plant requirements comply DCM S-18, "Fire Protection System," Cable Flame comply with a flame propagation test Clarification with the acceptable electrical Revision 19, Section 4.3.5.4 Propagation Limitsl as acceptable to the AHJ. cable construction tests acceptable to the AHJ (NRC) DCM T-22, "ElectriCal Cable, Note: As stated in 10 CFR as documented in FAQ 06- Termination and Raceway," 50.48(c)(2)(v), In lieu of installing 0022 and as clarified below. Revision 10D, Section 4.3.3.10 cables meeting flame propagation tests as required by Section 3.3.5.3, CF3.1D9, "Design Change Electrical cables at DCPP a flame-retardant coating may be meet the intent of IEEE 383- Development," Revision 43 applied to the electric cables, or an 1974 flame test requirements automatic fixed fire suppression as stated in FAQ 06-0022 or ABB Impell Corporation Document system may be installed to provide ABB Impell Corporation No. 0170-219-001, "PG&E Electrical an equivalent level of protection. In Document No. 0170-219-001, Cable Acceptability Analysis," addition, the italicized exception to Revision 1, (PG&E Electrical Revision 2 Section 3.3.5.3 is not endorsed. Cable Acceptability Analysis). Cables installed at DCPP fall Specification 0702, "HighVoltage into on fo--categories: Power Cables," Revision I (Inactive), dated July 22, 1994 *
*..(dCables tested to the flame "five" test requirements of IEEE 383- Specification 0703, "Low Voltage
~1974. These cables meet the Power Cables," Revision I (Inactive),
requirement without further dated July 22, 1994
- clarification.
Drawing 663359, Sheet 91, (2) Cables tested to the flame pages 5-7, "Flame Test Report," test requirements in UL 1666,_ Revision 1 or UL 1581. The flame tests in these UL Standards meet or exceed the requirements of IEEE 383-1974 per the guidance of NEI 02-04, Revision 1, as supplemented by FAQ 06-0022, Revision 3. (3) Cables tested to the flame test requirements in UL 910. The flame tests in this UL Standards meet or exceed the Page A-25
Pacific Gas and Electric Company Paciic Gs an Elctri ComanyAttachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element NFPA 805 Reauirement; Compliance Statement Compliance Basis Reference Document requirements of IEEE 383-1974 as evaluated and-documented in ABB Impell Corporation Document No. 0170-219-001, Revision 1, (PG&E Electrical Cable Acceptability Analysis). Specifically, the UL 910 standard represents a much more severe test condition than IEEE 383 and the acceptance criteria are more conservative. (4) Cables that were not originally required to meet the flame tests of IEEE 383 since they are used in small quantities, and/or are generally routed in conduit or used inside panels and equipment, including: Wire and cables supplied by the vendor as part of the equipment; Specialty cables, such as communications, te4eph~on~e,
"(5) Cables that have a flame-retardant coating and instr-menbtiton cables; Wire or cable used only within applied or an automatic fixed fire suppression panels or equipment; system installed to provide an equivalent level of Lighting and receptacle cables protection in lieu of meeting the flame propagation. that are installed entirely within tests discussed above, as permitted by 10 CFR fully enclosed raceway (conduit, solid tray with solid 50.48(c)(2)(v). covers).
Submit for NRC Approval: NRC approval isa
- Additionally, all cab!es installed requested in Attachment L for the use of Category 4 at DCPP in anal,;zed fire areas cables that do not comply with a flame propagation test as acceptable to the AHJ."
Page A-26
Pacific Gas and Electric Company Paciic Gs an Elctri ComanyAttachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element NFPA 805 Requirement Comp liance Statement Compliance Basis Reference Document subsequent.to'Jun... ,1991, meet the requirements of IEEE 158 (Ctegotr 2..),or UL 910 (Categor, 3). Therefore, tperm'tted toema..n as is per.. the excertion to this section. 3.3.6 Roofs Metal roof deck construction shall be *Complies No Additional Clarification Turbine Building: Drawings 59601 - designed and installed so the roofing system will not sustain a self-50606 and 6018227 Sheets I 77, - propagating fire on the underside of Various Revisions the deck when the deck is heated by Auxiliary Building: Drawings 59579, a fire inside the building. Roof coverings shall be Class A as 59583, 59590, 59593, and 59662, determined by tests described in Various Revisions NFPA 256, Standard Methods of Fire Tests of Roof Coverings. Fuel Handling Building: Drawings 501252, 501253, 59581 ,.59582, 59591, 59607, 59608, 6013118 Sheets 1-5, 439505 439508, 443498, 4002044, and 59641, Various Revisions Containment: Drawings 57729, 57731, 438464, 438231 and 438234, Various Revisions Intake Structure: Drawings 495080 - 49586, 495476 49586, and 4017056, Various Revisions Buttress Building: Drawings 512471 - 512476, 6018227 Sheets 1 -77, and 663524 Sheets 1 12, Various Revisions Page A-27
Pacific Gas and Electric Company Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.4.1(b) On-Site Fire- Industrial fire brigade members shall
- Complies No Additional Clarification Casualty Procedure (CP) M-6, "Fire,"
Fighting Capability (b) have no other assigned normal plant Revision 33A, Section 2.1.1 duties that would prevent immediate response to a fire or other emergency as required.
- LuIII[pII*=b, WIL[1 Fighting Capability (c) and at least two brigade members Required Action Revision 33A, Section 2.1.1 shall have sufficient training and knowledge of nuclear safety systems Re,-ision 33A, that allo,;.s the "Complies with the Exception.
to understand the effects of fire and Incident Commander to be an Casuality Procedure M-6, Section fire suppressants on nuclear safety operations responder. This is performance criteria. .2.1.1, specifies that "an operations not...ctual pln .tice... r responder will accompany the Exception: Sufficient training and [Incident Commander] in all knowledge shall be permitted to be Implementation Item S-3.13 is provided by an operations advisor emergency responses inside the compIeted~ protected area." The operations dedicated to industrial fire brigade support. responder as discussed above is
- equivalent to the operations advisor IMPLEMENTATION ITEMS:
S-3.13 SAP Notification #50294777-32 was issued to track the revision of Casualty Procedure M-6 to remove the phrase 'unless the IC is as permitted by the exception. Casualty Procedure M-6 allows the 3.4.1(d) On-Site Fire- The industrial fire brigade shall be
- Complies No Additional Clarification Fighting Capability (d) notified immediately upon verification Incident Commander to be an of a fire. - operations responder. This is not actual plant practice, and 3.4.1(e) On-Site Fire- Each industrial fire brigade member ° Complies No Additional Clarification Implementation Item 5-3.13 was Fighting Capability (e) shall pass an annual physical examination to determine that he or
- established to revise the procedure.
she can perform the strenuous ;Therefore, the Compliance Basis will activity required during manual be 'Complies' once Implementation firefighting operations. The physical :ltem 5-3.13 is completed." examination shall determine the ability of each member to use respiratory protection equipment. Page A-42
Pacific Gas and Electric Company Paciic Gs an Elctri ComanyAttachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element*_ NFPA 805 Requirement Comeliance Statement Comoliance Basis Reference Document Engineering evaluations (FHAREs) were developed to analyze the acceptability of various configurations at DCPP. A list of applicable engineering evaluations is provided under "Reference Documents." 3.9.1 (2) [Fire NFPA 15, Standard for Water Spray
- Complies with Complies with Use of EEEEs: DCM S-18, "Fire Protection System,"
Suppression System Fixed Systems for Fire Protection Use of EEEEs Automatic or manual water Revision 19, Section 4.3.3.1.k Code Requirements] based suppression systems (2) credited to meet the Report P1890-002-004, "Fire requirements of Chapter 4 are Protection Code Conformance identified in Section 4.8 of the Review Report," Revision 1, dated Transition Report. For the March 2013 credited systems, DCPP complies with NFPA 15-1 969 .FHARE NoJ.' 159, "Unrated and 1990, Water Spray Fixed 'doors Protected by Local Systems for Fire Protection, as :Automatic Sprinklers," dated documented in Report P1890-002-004, "Fire Protection Code March 21, 2013 Conformance Review Report, Revision 1, dated March 2013. Engineering evaluations (FHAREs). were developed to analyze the acceptability of various configurations at DCPP. A list of applicable engineering evaluations is provided under "Reference Documents." Page A-87
Pacific Gas and Electric Company Paciic Gs an Elctri ComanyAttachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element NFPA 805 Requirement Compliance Statement; .Compliance Basis Reference Document 3.11.5 Electrical ERFBS required by Chapter 4 shall
- Complies with Complies with Use of EEEEs: FHARE No. 138, "Drain Holes in Raceway Fire Barrier be capable of resisting the fire effects Use of EEEEs Engineering evaluations Pyrocrete Panels in Fire Areas 10 Systems (ERFBS) of the hazards in the area. ERFBS (FHAREs) were developed to and 20," Revision 0, dated shall be tested in accordance with analyze the acceptability of November 4, 1998 and shall meet the acceptance various configurations at criteria of NRC GL 86-10, DCPP. A list of applicable FHARE No. 145, 'Pyrocrete Supplement 1, "Fire Endurance Test engineering evaluations is Enclosure Thickness," Revision 1, Acceptance Criteria for Fire Barrier provided under "Reference dated May 9, 2001 Systems Used to Separate Safe Documents."
Shutdown Trains Within the Same 1 Fire Area." The ERFBS needs to (D. . ..07 ," R...i.i.n.. adequately address the design requirements and limitations of MIP C-!3_0 '3M Interam Firn supports and intervening items and w=wI A t f*A* .... I* Protect!on *vstem *' .........
*r.u_.),l.J*.,
their impact on the fire barrier system rating. The fire barrier system's ability to maintain the required nuclear safety circuits free of fire damage for a specific thermal Add: exposure, barrier design, raceway
- Calculation C-FP-1 04, "Evaluation of 3M Series size and type, cable size, fill, and E-50 Raceway Fire Barrier Wrap Configurations at type shall be demonstrated. DCPP", Revision 001/01
- Replacement Part Evaluation C-7222, "Pyrocrete Exception No. 1: When the temperatures inside the fire barrier 241 to Replace Pyrocrete 201", Revision 0 system exceed the maximum temperature allowed by the acceptance criteria of GL 86-10, "Fire Endurance Acceptance Test Criteria for Fire Barrier Systems Used to Separate Redundant Safe Shutdown Training Within the Same Fire Area,"
Supplement 1, functionality of the cable at these elevated temperatures shall be demonstrated. Qualification demonstration of these cables shall be performed in accordance with the electrical testing requirements of Page A-123
D*r;fir *.* *nrl I:=lnrfrir t*_*mn*nw l u-,fllr* VCI UllV,J I--I,. rhL IV V larJnOli /--*.L V,..hmII*I I.P -- II1.. f----.A") i .I;.1; I.J--/ .. ,I~g1l,.l g~l L V rl k;llla, A'* ,e),*,mIIInnI IVtIIV SI~ I\; lt Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Re~f NEI 00-01 Guidance 3.1.1.3 Criteria/Assumptions [PWR] Generic Letter 86-10, Enclosure 2, Section 5.3.5 specifies that hot shutdown can be maintained without the use of pressurizer heaters (i.e., pressure control is provided by controlling the makeup/charging pumps). Hot shutdown conditions can be maintained via natural circulation of the Reactor Coolant System (RCS) through the steam generators. The cooldown rate must be controlled to prevent the formation of a bubble in the reactor head. Therefore, feedwater (either auxiliary or emergency) flow rates as well as steam release must be controlled. Agnlicabilitv Comments Applicable None Alianment Statement Aligns Alianment oasis RCS pressure control capabilities required to achieve and maintain a "safe and stable" plant condition post-fire are identified in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection. The DCPP NSCA model includes pressurizer heater capability for RCS pressure control for defense-in-depth (DID). The vital pressurizer heater groups are analyzed to remain available from the Main Control Room (MCR) (or locally) for RCS pressure control. The non-vital pressurizer heater groups are only analyzed for loss of MCR trip capability. The DCPP NSCA model also allows for RCS pressure control to be achieved utilizing the Chemical and Volume Control System (CVCS) to add RCS inventory (and increase RCS pressure) and the Auxiliary Feedwater (AFW) System (to remove decay heat, and decrease RCS pressure). RCS inventory is supplied with the CVCS utilizing one of three centrifugal charging pumps, with pump suction taken from the borated Refueling Water Storage Tank (RWST) or Boric Acid Storage Tanks (BASTs), and pump discharge injected into the RCS through the normal charging, alternate charging, RCP seal injection, or charging injection flowpaths. The noncredited charging pump(s) are analyzed for loss of MCR trip capability. Feedwater for decay heat removal is supplied from either the Turbine Driven Auxiliary Feedwater (TDAFW) Pump (supplies .... team.... generto
..... (
rs,__ 1 2~, o)(2 2) and.. 1_ 3-(2 3,) or the two Motor Driven Auxiliary Feedwater Pumps (MDAFW). AFW-1(2)-AFWP1-RUN supplies SGs 1-1 (2-1) and 1-2 (2-2), AFV (2)-AFWP2-RUN supplies SGs 1-3 (2-3) and 1-4 (2-4). 10 percent atmospheric steam dump valves (ASDVs) are modeled to be operable as required for the credited S5 (1 of 4). The noncredited AFW pump(s) are analyzed for loss of MCR trip capability. CommentsalforSemGnrtradioprtdbsta drw ofofSemGnrtr1-an/r13(-an/r2) None Reference Documents Document Details Report R21 65-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013 Section 10.0 Page B-IO
Pacific Gas and Electric Company Paciic as nd lecricComanyAttachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodoloqyv Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref NEI 00-01 Guidance 3.1.2.2 Pressure Control [PWR] Makeup/Charging Systems RCS pressure is controlled by controlling the rate of charging/makeup to the RCS. Although utilization of the pressurizer heaters and/or auxiliary spray reduces operator burden, neither component is required to provide adequate pressure control. Pressure reductions are made by allowing the RCS to cool/shrink, thus reducing pressurizer level/pressure. Pressure increases are made by initiating charging/makeup to maintain pressurizer level/pressure. Manual control of the related pumps is acceptable. Aoolicability Comments Applicable None Alignment Statement Aligns Alignment Basis RCS pressure control capabilities required to achieve and maintain a "safe and stable" plant condition post-fire are identified in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection. The DCPP NSCA model includes pressurizer heater capability for RCS pressure control for DID. The vital pressurizer heater groups are analyzed to remain available from the MCR (or locally) for RCS pressure control. The non-vital l~ressurizer heater groups are only analyzed for loss of MCR trip capability. The DCPP NSCA model also allows for RCS pressure control to be achieved utilizing the CVCS to add RCS inventory (and increase RCS pressure) and the AFW System (to remove decay heat, and decrease RCS pressure). Addition of RCS inventory is accomplished with the CVCS utilizing one of three CCPs, with pump suction taken from the borated RWST or BASTs, and pump discharge injected into the RCS through the normal charging, alternate charging, RCP seal injection, or charging injection flowpaths. The noncredited charging pump(s) are analyzed for loss of MCR trip capability. Feedwater for decay heat removal is supplied from either the TDAFW Pump (supplies *G .2(-)*d!3(-*) or the two MDAFW. AFW-1I(2)-AFWPI-RUN supplies SGs 1-1 (2-1) and 1-2 (2-2), AFW-I(2)-AFWP2-RUN supplies SGs 1-3 (2-3) and 1-4 (2-4). 10 Ircent ASDVs are modeled to be operable as required for the credited SG (1 of 4). The noncredited AFW pumpsaranlzdfrlsofMRticpblty CommentsalforSemGnrtradioprtdbSta drw ofofSemGnrtr1-an/r13(-an/r2) None Reference Documents Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013 Section 10.0 Page B-24
Pacific Gas and Electric Company Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodoloav Review Paifc a ad leticCopay Attachment B - NEI 04-02 Table B-2 Nuclear Safety CapabilityAssessment MethodologyReview NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection Add: " Battery, Inverter and DC Switchgear and 480V Vital Switchgear Rooms (Fire HVAC systems are required for the following plant res.Areas 6-A-I, 6-A-2, 6-A-3, 6-B-I, 6-B-2, 6-B-3, 5-A-i, 5-A-2, 5-A-3, 5-B-I, 5-B-2, and 5-
- S upRosB-3), the Auxiliary Saltwater (ASW) pump vaults (Fire Areas 30-A-I, 30-A-2, 30-A-3, and
- 1kV S,;"tchgear Rooms 3-4)and the Control Room Complex (satisfied bythe CRVS in Fire Areas CR-I U1
- DC and '180V Swi:tchgear RoomsanCRI[2)
In the event of fire induced failure of required HVAC system. , Comments None Reference Documents Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013 Section 10.0; Attachment 14 Page B-38
Pacific Gas and Electric Company Attachment E - Radioactive Release Transition Table E-1 - NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Screened Engineering Controls Training and Pre-Fire Unit Area Zone Description Plan Rev. In'? Water Smoke Plan Review Results Conclusions DC Switchgear, _ H Bus 2 6-B-4 6-B-4 Reactor Trip RA-1 0 03/08 No N/A N/A N/A N/A - Screened Out Switchgear 2 6-B-5 6-8-5 Electrical RA-1 0 03/08 No N/A N/A N/A N/A - Screened Out Area 1 7-A 7-A Cable RA-22 05/03 No N/A N/A N/A N/A - Screened Out Spreading Room
- 2. 7-B 7-B Cable RA-22 05/03 No N/A N/A N/A N/A - Screened Out Spreading Room 1 7-C 7-C Communi- RA-22 05/03 No N/A N/A N/A N/A - Screened Out cations Room 2 7-D 7-D Communi- RA-22 05/03 No N/A N/A N/A N/A - Screened Out cations Room 1 8-G 8-G l-,
ooa,?guar,* RA-12 03/08 No N/AA /AN/A - Screened Out 2 9 9-A Containment RA-31 05/03 Yes During Plant Operation: Containment ventilation Training materials reinforce Based on the availability of Annulus Area RA-32 05/03 Floor drains are routed to systems include use of PFPs and Casualty engineering controls for RA-33 05/03 the monitored LRS. Units Containment fan coolers, Procedure CP M-6, "Fire" both smoke and fire 1 and 2 share a common Iodine removal units, and for containment and suppression water runoff LRS, except for Containment Purge Supply monitoring of potential and use of revised PFPs equipment located inside and Exhaust System. All radioactive effluents. PFP and training materials, containment. The wastes radioactive atmospheres revisions will identify DCPP's approach will be are collected in the are monitored for potentially contaminated considered acceptable to Containment sump and radioactivity concentration areas, provide instruction meet NFPA 805 are released to the during normal operations, for communication with radioactive release environment at either of anticipated transients, and Radiation Protection and performance criteria. the units circulating water accident conditions by the describe precautions to be system discharge RMS. High radiation in any undertaken for the The results documenting structures via the ASW of these areas in monitored containment and safe conformance to NFPA 805 System. The ASW System in the Control Room, removal of contaminated radioactive release criteria and Main Circulating Accidental releases from smoke and water runoff in will be maintained as part Water System dilute the Containment are monitored these potentially of DCPP's Configuration collected waste. The by the process and effluent contaminated areas. Control Program. This effluents are continuously radiological monitoring Training material and. PFP program will ensure that Page E-57
Pacific Gas and Electric Company Attachment E - Radioactive Release Transition Table E-1 - NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Screened Engineering Controls Training and Pre-Fire Unit Area Zone Description Plan Rev. In? Water Smoke Plan Review Results Conclusions 0 17 17 Warehouse TB-9 05/03 No N/A N/A N/A N/A - Screened Out 2 18 18 Turbine Lube TB-l8 05/03 No N/A N/A N/A N/A - Screened Out Oil Reservoir 2 20 20 12kV TB-5 05/03 No N/A N/A N/A N/A - Screened Out Switchgear Room and Cable Spreading Room 2 22-C 22-C Corridor TB-I6 05/03 No N/A N/A N/A N/A - Screened Out Outside Diesel Generator Rooms 2 24-D 24-D Excitation TB-20 05/03 No N/A N/A N/A N/A - Screened Out Switchgear Room 0 26 26 "*uildingJ RA-23 05/03 Yes DCPP Calculation No. DCPP Calculation No. Training materials reinforce Based on the results of I11BZ RA-24 05/03 9000041373 9000041374 demonstrates use of PFPs and Casualty DCPP Calculation No's. Ra te RA-25 05/03 demonstrates that the that the gaseous effluent Procedure CP M-6, "Fire" 9000041373 and Lau* and liquid effluent radioactive radioactive dose limits of for containment and 9000041 374 regarding St aea; dose limits of 10 CFR 20 10 CFR 20 and plant TS monitoring of potential liquid and gaseous uilding \and plant TS will not be will not be exceeded due to radioactive effluents. PEP radioactive release, and
/ \exceeded due to the the effects of complete revisions will identify the use of revised PFPs effects of complete combustion of the worst- potentially contaminated and training materials, combustion of the worst- case "bounding" single dry areas, provide instruction DCPP's approach will be case "bounding" single dry active waste container, and for communication with considered acceptable to Chmia and '*active waste container, subsequent fire Radiation Protection and meet NFPA 805 and subsequent fire suppression activities describe precautions to be radioactive release GsosSoaesuppression activities within the Owner Protected undertaken for the performance criteria.
within the Owner Area. As such, this containment and safe Protected Area. As such, calculation is "bounding" removal of contaminated The results documenting this calculation is for this location and can be smoke and water runoff in conformance to NFPA 805 "bounding" for this location applied to demonstrate that these potentially radioactive release criteria and can be applied to any potential contaminated contaminated areas. will be maintained as part demonstrate that any gaseous effluent release Training material and PEP of DCPP's Configuration potential contaminated resulting from complete revisions will describe the Control Program. This liquid effluent release combustion of the single presence and potential use program will ensure that resulting from complete "worst-case" radioactive of monitored ventilation the radioactive release combustion of the single source container and and drainage systems, if goals, objective and "worst-case" radioactive subsequent fire such systems are deemed performance criteria will source container and suppression activities in operational and capable of continue to be satisfied Page E-68
Pacific Gas and Electric Company Attachment E - Radioactive Release Transition Table E-1 - NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Screened Engineering Controls Training and Pre-Fire Unit Area Zone Description Plan Rev. In? Water Smoke Plan Review Results Conclusions subsequent fire this building is expected to supporting manual removal when considering the suppression activities in be below 10 CFR 20 and efforts. The level of detail possibility that areas that this building is expected to plant technical provided in the revised were not contaminated at be below 10 CFR 20 and specification limits, training materials and the time of NFPA 805 plant technical PFPs will meet NFPA 805 transition, and were specification limits. Provisions are in place to radioactive release consequently screened-commence communication performance criteria, out, may become Provisions are in place to between the Fire Brigade contaminated in the future commence and Radiation Protection Implementation Item S- due to plant operational communication between and provide precautions for 3.19 - PFPs and training events. the Fire Brigade and containing, monitoring, and materials will be revised to Radiation Protection and safely releasing address radioactive Implementation Item S-to contain/monitor liquid contaminated gaseous release requirements of 3.20 - The NFPA 805 effluents prior to safe effluents. NFPA 805. See NFPA 805 radioactive release review removal. Transition Report will be incorporated into Attachment S, Table S-3. DCPP's Configuration Control Program. See NFPA 805 Transition Report Attachment S, Table S-3. 0 27-A 27-A Boxed Waste RA-2-4. 05/03 Yes DCPP Calculation No. DCPP Calculation No. Training materials reinforce Based on the results of Zone RA-2--2 05/03 Aliquid 9000041373 9000041374 demonstrates use of PFPs and Casualty DCPP Calculation No's.
*/demonstrates that the that the gaseous effluent Procedure CP M-6, "Fire" 9000041373 and effluent radioactive radioactive dose limits of for containment and 9000041374 regarding dose limits of 10 CFR 20 10 CFR 20 and plant TS monitoring of potential liquid and gaseous
~and plant TS will not be will not be exceeded due to radioactive effluents. PFP radioactive release, and RA-23 exceeded due to the the effects of complete revisions will identify the use of revised PFPs RA-24 effects of complete combustion of the worst- potentially contaminated and training materials, RA-25 combustion of the worst- case "bounding' single dry areas, provide instruction DCPP's approach will be case 'bounding" single dry active waste container, and for communication with considered acceptable to active waste container, subsequent fire Radiation Protection and meet NFPA 805 and subsequent fire suppression activities describe precautions to be radioactive release suppression activities within the Owner Protected undertaken for the performance criteria.
within the Owner Area. As such, this containment and safe Protected Area. As such, calculation is "bounding" removal of contaminated The results documenting this calculation is for this location and can be smoke and water runoff in conformance to NFPA 805 "bounding" for this location applied to demonstrate that these potentially radioactive release criteria and can be applied to any potential contaminated contaminated areas, will be maintained as part demonstrate that any gaseous effluent release Training material and PFP of IDCPP's Configuration potential contaminated resulting from complete revisions will describe the Control Program. This liquid effluent release combustion of the single presence and potential use program will ensure that resulting from complete "worst-case" radioactive of monitored ventilation the radioactive release combustion of the single source container and and drainage systems, if goals, objective and "worst-case" radioactive subsequent fire such systems are deemed performance criteria will source container and suppression activities in operational and capable of continue to be satisfied Page E-69
Pacific Gas and Electric Company Attachment E - Radioactive Release Transition Table E-1 - NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone -Pre-Fire Screened Engineering Controls Training and Pre-Fire Unit Area Zone Description Plan Rev. In? Water Smoke Plan Review Results Conclusions subsequent fire this building is expected to supporting manual removal when considering the suppression activities in be below 10 CFR 20 and efforts. The level of detail possibility that areas that this building is expected to plant technical provided in the revised were not contaminated at be below 10 CFR 20 and specification limits, training materials and the time of NFPA 805 plant technical PFPs will meet NFPA 805 transition, and were specification limits. Provisions are in place to radioactive release consequently screened-commence communication performance criteria, out, may become Provisions are in place to between the Fire Brigade contaminated in the future commence and Radiation Protection Implementation Item S- due to plant operational communication between and provide precautions for 3.19 - PFPs and training events. the Fire Brigade and containing, monitoring, and materials will be revised to Radiation Protection and to contain/monitor liquid effluents prior to safe safely releasing contaminated gaseous effluents. address radioactive release requirements of NFPA 805. See NFPA 805 3.20 - Implementation Item S-The NFPA 805 radioactive release review removal. Transition Report will be incorporated into Attachment S, Table S-3. DCPP's Configuration Control Program. See NFPA 805 Transition Report Attachment S, Table S-3. 0 27-B 27-B Drum 1A-k-24 05/03 Yes DCPP Calculation No. DCPP Calculation No. Training materials reinforce Based on the results of Storage Zone ,eA-2- 05/03 9000041373 9000041374 demonstrates use of PFPs and Casualty DCPP Calculation No's.
*/demonstrates that the that the gaseous effluent Procedure CP M-6, "Fire" 9000041373 and i/dose liquid effluent radioactive radioactive dose limits of for containment and 9000041374 regarding r
limits of 10 CFR 20 10 CFR 20 and plant TS monitoring of potential liquid and gaseous and plant TS will not be will not be exceeded due to radioactive effluents. PFP radioactive release, and R-3exceeded due to the the effects of complete revisions will identify the use of revised PFPs R 24effects of complete combustion of the worst- potentially contaminated and training materials, combustion of the worst- case "bounding" single dry areas, provide instruction DCPP's approach will be R-5case "bounding" single dry active waste container, and for communication with considered acceptable to active waste container, subsequent fire Radiation Protection and meet NFPA 805 and subsequent fire suppression activities describe precautions to be radioactive release suppression activities within the Owner Protected undertaken for the performance criteria. within the Owner Area. As such, this containment and safe Protected Area. As such, calculation is "bounding" removal of contaminated The results documenting-this calculation is for this location and can be smoke and water runoff in conformance to NFPA 805 "bounding" for this location applied to demonstrate that these potentially radioactive release criteria and can be applied to any potential contaminated contaminated areas. will be maintained as part demonstrate that any gaseous effluent release Training material and PEP of DCPP's Configuration potential contaminated resulting from complete revisions will describe the Control Program. This liquid effluent release combustion of the single presence and potential use program will ensure that resulting from complete "worst-case" radioactive of monitored ventilation the radioactive release combustion of the single source container and and drainage systems, if goals, objective and "worst-case" radioactive subsequent fire such systems are deemed performance criteria will source container and suppression activities in operational and capable of continue to be satisfied Page E-70
Pacific Gas and Electric Company Attachment E - Radioactive Release Transition Table E-1 - NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Screened Engineering Controls Training and Pre-Fire Unit Area Zone Description Plan Rev. In? Water Smoke Plan Review Results Conclusions subsequent fire this building is expected to supporting manual removal when considering the suppression activities in be below 10 CFR 20 and efforts. The level of detail possibility that areas that this building is expected to plant technical provided in the revised were not contaminated at be below 10 CFR 20 and specification limits, training materials and the time of NFPA 805 plant technical PFPs will meet NFPA 805 transition, and were specification limits. Provisions are in place to radioactive release consequently screened-commence communication performance criteria, out, may become Provisions are in place to between the Fire Brigade contaminated in the future commence and Radiation Protection Implementation Item S- due to plant operational communication between and provide precautions for 3.19 - PFPs and training events. the Fire Brigade and containing, monitoring, and materials will be revised to Radiation Protection and safely releasing address radioactive Implementation Item 5-to contain/monitor liquid contaminated gaseous release requirements of 3.20 - The NFPA 805 effluents prior to safe effluents. NFPA 805. See NFPA 805 radioactive release review removal. Transition Report will be incorporated into Attachment S, Table S-3. DCPP's Configuration Control Program. See NFPA 805 Transition Report Attachment 5, Table S-3. 0 27-C 27-C Contaminated RA24 05/03 Yes DCPP Calculation No. DCPP Calculation No. Training materials reinforce Based on the results of Oil Storage RA22 05/03 9000041373 9000041374 demonstrates use of PFPs and Casualty DCPP Calculation No's.
/demonstrates that the that the gaseous effluent Procedure CP M-6, "Fire" 9000041373 and i/dose liquid effluent radioactive limits of 10 CFR 20 radioactive dose limits of 10 CFR 20 and plant TS for containment and monitoring of potential 9000041374 regarding liquid and gaseous L
and plant TS will not be will not be exceeded due to radioactive effluents. PEP radioactive release, and RA-23 exceeded due to the the effects of complete revisions will identify the use of revised PFPs SRA-24 effects of complete combustion of the worst- potentially contaminated and training materials, combustion of the worst- case "bounding" single dry areas, provide instruction DCPP's approach will be SRA-25 case 'bounding" single dry active waste container, and for communication with considered acceptable to active waste container, subsequent fire Radiation Protection and meet NFPA 805 and subsequent fire suppression activities describe precautions to be radioactive release suppression activities within the Owner Protected undertaken for the performance criteria. within the Owner Area. As such, this containment and safe Protected Area. As such, calculation is "bounding" removal of contaminated The results documenting this calculation is for this location and can be smoke and water runoff in conformance to NFPA 805 "bounding" for this location applied to demonstrate that these potentially radioactive release criteria and can be applied to any potential contaminated contaminated areas, will be maintained as part demonstrate that any gaseous effluent release Training material and PEP of DCPP's Configuration potential contaminated resulting from complete revisions will describe the Control Program. This liquid effluent release combustion of the single presence and potential use program will ensure that resulting from complete "worst-case" radioactive of monitored ventilation the radioactive release combustion of the single source container and and drainage systems, if goals, objective and "worst-case radioactive subsequent fire such systems are deemed performance criteria will source container and suppression activities in operational and capable of continue to be satisfied Page E-71
Pacific Gas and Electric Company Attachment E - Radioactive Release Transition Table E-1 - NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Screened Engineering Controls Training and Pre-Fire Unit Area Zone Description Plan Rev. In? Water Smoke Plan Review Results Conclusions precautions for containing, monitoring, and safely releasing contaminated gaseous effluents. 1AB-1 AR-i (U1) (U2) 3-R Spn ul RA-111 05/03 Yes Floor drains areLRS. routed to Each served by apntFel.Training Pool R-1 03108 the monitored Each similarunit butisseparate use of PFPsmaterials reinforce and Casualty Based on thecontrols engineering availability for of floor drain flows into the FHBVS. The FHBVS can Procedure CP M-6, "Fire' both smoke and fire AB sump. The collected operate in either of two for containment and suppression water runoff Ad:wastes are released to the configurations, a normal monitoring of potential and use of revised PFPs RA9environ~ment at either of configuration or an iodine radioactive effluents. PFP and training materials, RA1~the units circulating water removal configuration. The revisions will identify DCPP's approach will be system discharge difference between the potentially contaminated considered acceptable to structures via the ASW configurations is the a~reas, provide instruction meet NFPA 805 System. The ASW System treatment of exhaust air. for communication with radioactive release and Main Circulating Each FHBVS contains two Radiation Protection and performance criteria. Water System dilute the full-capacity supply fans describe precautions to be collected waste. The that collect air from along undertaken for the The results documenting effluents are continuously one side of the fuel pool, containment and safe conformance to NFPA 805 monitored and require and discharge into duct removal of contaminated radioactive release criteria positive operator action to work in the corridors and smoke and water runoff in will be maintained as part be released into the equipment compartments these potentially of DCPP's Configuration environment, below the SFP. contaminated areas. Control Program. This Training material and PFP program will ensure that During NPO: Floor drains During normal operation, revisions will describe the the radioactive release as described above one non-vital exhaust fan presence and potential use goals, objective and remain present. is in operation and the air of monitored ventilation performance criteria will is passed through a and drainage systems, if continue to be satisfied Provisions are in place to roughing and HEPA filter such systems are deemed when considering the commence before being discharged to operational and capable of possibility that areas that communication between the plant vent. In the iodine supporting manual removal were not contaminated at the Fire Brigade and removal configuration, efforts. The level of detail the time of NFPA 805 Radiation Protection and exhaust air passes through provided in the revised transition, and were to contain/monitor liquid charcoal adsorbers in training materials and consequently screened-effluents prior to safe addition to roughing and PFPs will meet NFPA 805 out, may become removal. HEPA filters. Automatic radioactive release contaminated in the future initiation of the iodine performance criteria, due to plant operational removal configuration events. occurs in response to high Implementation Item 5-radiation, as measured by 3.19 - PFPs and training Implementation Item 5-radiation monitors in the materials will be revised to 3.20 - The NFPA 805 FHB, or upon failure of the address radioactive radioactive release review normal operating exhaust release requirements of will be incorporated into fan. Ventilation air from NFPA 805. See NFPA 805 .DCPP's Configuration areas containing Transition Report Control Program. See radioactive materials is Attachment 5, Table S-3. NFPA 805 Transition Page E-107
Pacific Gas and Electric Company Attachment E - Radioactive Release Transition Table E-1 - NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Screened Engineering Controls Training and Pre-Fire Unit Area Zone Description Plan Rev. In? Water Smoke Plan Review Results Conclusions slight negative pressure. If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and RP personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents. 1 AB-1 05/03 Yes Due to its location within Due to its location within Training materials reinforce Based on the availability of AB-1 (U1) S-8 Stairwell S-8 RA-7 (U2) RA-8 03/08 the RCA, the stairwell is the RCA, the stairwell is use of PFPs and Casualty engineering controls for RA-11 05/03 screened-in. However per screened-in. However per Procedure CP M-6, "Fire" both smoke and fire
~RA-12 03/08 Procedure OMa.ID4, there Procedure OM8.1D4, there for containment and suppression water runoff is no storage of is no storage of permanent monitoring of potential and 'use of revised PEPs permanent and transient and transient combustibles radioactive effluents. PEP and training materials, combustibles located located within the stairwell. revisions will identify DCPP's approach will be within the stairwell. As As such, the stairwell can potentially contaminated considered acceptable to such, the stairwell can be be dispositioned as being areas, provide instruction meet NFPA 805 dispositioned as being of of negligible radioactive for communication with radioactive release negligible radi'oactive release consequence. Radiation Protection and performance criteria.
release consequence. describe precautions to be In the unlikely event of a undertaken for the The results documenting In the unlikely event of a fire in the stairwell, each containment and safe conformance to NFPA 805 fire in the stairwell, floor unit is served by a similar removal of contaminated radioactive release criteria drains, routed to the but separate FHBVS. The smoke and water runoff in will be maintained as part monitored LRS, are FHBVS can operate in these potentially of DC PP's Configuration provided in adjacent fire either of two contaminated areas. Control Program. This zones. The AB is divided configurations, a normal Training material and PEP program will ensure that into several drainage configuration or an iodine revisions will describe the the radioactive release zones and each area removal configuration. The presence and potential use goals, objective and within a zone is drained by difference between the "* of monitored ventilation performance criteria will several screen outlets. configurations is the and drainage systems, if continue to be satisfied Page E-125
Pacific Gas and Electric Company Attachment E - Radioactive Release Transition Table E-1 - NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Screened Engineering Controls Training and Pre-Fire Unit Area Zone Description Plan Rev. In? Water Smoke Plan Review Results Conclusions lation Room _-- -- Add:* o AB-2 S-5 Stairwell S-5 RA-8 03/08 No N/A *.RA-6 N/A N/A N/A - Screened Out RA-12 03/08 R-0 AB-3 8-B-7 Electrical RA-22 05/03 No N/A N/A N/A N/A - Screened Out AreaNenti-lation Room 0 AB-3 8-B-8 Electrical RA-22 05/03 No N/A N/A N/A N/A - Screened Out Area/Venti-1 CR-i (U1) 8-A Computer RA-12 03/08 No N/A NA/AN/A - Screened Out CR-i (U2) Room 1 CR-i (U1) 8-B-3 CR RA-21 05/03 Yes Floor drains are routed to The AB ventilation system Training materials reinforce - Based on the availability of CR-i (U2) Ventilation RA-22 05/03 the monitored LRS. The contains two full-capacity use of PFPs and Casualty engineering controls for Equipment AB is divided into several supply fans that draw air Procedure CP M-6, "Fire" both smoke and fire Room drainage zones and each from the atmosphere for containment and suppression water runoff area within a zone is above the AB and then monitoring of potential and use of revised PFPs drained by several screen discharge it to the radioactive effluents. PFP and training materials, outlets. Each floor drain occupied areas of the revisions will identify DCPP's approach will be flows into the AB sump. building and to the potentially contaminated considered acceptable to The collected wastes are engineered safety feature areas, provide instruction meet NFPA 805 released to the (ESF) pump compartments for communication with radioactive release environment at either of whenever they are in Radiation Protection and performance criteria. the units circulating water operation. During normal describe precautions to be system discharge operating conditions, undertaken for the The results documenting structures via the ASW *exhaust air is passed containment and safe conformance to NFPA 805 System. The ASW System through a roughing filter removal of contaminated radioactive release criteria and Main Circulating and HEPA filter before smoke and water runoff in will be maintained as part Water System dilute the entering the vent, these potentially of DCPP's Configuration collected waste. The contaminated areas. Control Program. This effluents are continuously Under accident conditions, Training material and PFP program will ensure that monitored and require the air is exhausted from revisions will describe the the radioactive release positive operator action to the ESF pump presence and potential use goals, objective and be released into the compartments and is of monitored ventilation performance criteria will environment, passed through a charcoal and drainage systems, if continue to be satisfied filter in addition to the such systems are deemed when considering the During NPO: Floor drains roughing and HEPA filters, operational and capable of possibility that areas that as described above Exhaust air from other supporting manual removal were not contaminated at remain present. portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed provided in the revised transition, and were Provisions are in place to through roughing and training materials and consequently screened-Page E-133
Pacific Gas and Electric Company Attachment E - Radioactive Release Transition Table E-1 - NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Screened Engineering Controls Training and Pre-Fire Unit Area Zone Description Plan Rev. In? Water Smoke Plan Review Results Conclusions techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents. 0 IS-1 30-A-5 Circulating PA-2 03/08 No N/A N/A N/A N/A - Screened Out Water Pump Room 0 IS-I 30-B Intake PA-2 03/08 No N/A N/A N/A N/A - Screened Out Structure Control Room 1 TB-i 11-A-i Emergency TB-5 05/03 No N/A N/A N/A N/A - Screened Out 11i-A-2 Diesel TB-7 05/03 Generator 1-1 / Intake and Exhaust Room TB-2 li-B-i Emergency TB-5 05/03 No N/A N/A N/A N/A - Screened Out i1-B-2 Diesel
- Generator 1-2 /Intake and Ad ExhaustTB Room TB-3 il-C-i Emergency TB-5 05/03 No N/A N/A N/A N/A - Screened Out 11i-C-2 Diesel TB-7 05/03 Generator 1-3 /Intake and Exhaust Room 1 TB-4 12-A 4kV Cable TB-7 05/03 No N/A N/A N/A N/A - Screened Out Spreading Page E-143
Pacific Gas and Electric Company Attachment E--, Radioactive Release Transition Table E-1 - NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Screened Engineering Controls Training and Pre-Fire Unit Area Zone Description Plan Rev. In? Water Smoke Plan Review Results Conclusions Feedwater and Condensate Equipment Area 2 TB-7 (U1) 19-B Electrical TB-20 05/03 No N/A N/A N/A N/A - Screened Out TB-7 (U2) Load Center 2 TB-7 (Ul) 19-C Oil lB4. 05/03 No N/A N/A N/A N/A - Screened Out TB-7 (U2) Reclamation and Shetage _ TB14*-'- Room ' *Ct~g 2 TB-7 (UI) 19-D Turbine Deck TB-22 05/03 No N/A N/A N/A N/A - Screened Out TB-7 (U2) 2 TB-7 (UI) 19-E Component :[-1--1 05/03 No N/A N/A N/A N/A - Screened Out TB-7 (U2) Cooling * . Water Heat Exchanger Room 2 TB-7 (U1) 23-E Iso-Phase TB-18 05/03 No N/A N/A N/A N/A - Screened Out TB-7 (U2) Bus Duct Room 2 TB-7 (U1) 5-6 Stairwell S-6 TB-20 05/03 No N/A JN/A N/A N/A - Screened Out TB-7 (U2) 2 TB-8 22-A-i Emergency TB-16 05/03 No N/A N/A N/A N/A - Screened Out 22-A-2 Diesel TB-l8 05/03-Generator 2-I / Intake and Exhaust Room 2 TB-9 22-B-i Emergency TB-I6s 05/03 No N/A N/A N/A N/A - Screened Out, 22-B-2 Diesel TB-18 05/03 Generator 2-2 / Intake and Exhaust Room 2 TB-10 23-A 4kV Cable *TB-18 05/03 No N/A "N/A N/A N/A - Screened Out Spreading Room, F Bus 2 TB-10 24-A 4kV TB-20 05/03 No N/A N/A N/A N/A - Screened Out Switchgear Page E-145
Pacific Gas and Electric Company Attachment E - Radioactive Release Transition Table E-1 - NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Screened Engineering Controls Training and Pre-Fire Unit Area Zone Description Plan Rev. In? Water Smoke Plan Review Results Conclusions and/or charcoal filters. Table S-3. During NPO: The ventilation and mornitoring systems as described above remain present. If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents. V-2 3-P-6 HVAC Room RA-1 1 05/03 Yes Floor drains are routed to Each unit is served by a Training materials reinforce Based on the availability of 3-P-7 RA-12 03/08 the monitored LRS. Each similar but separate use of PFPs and Casualty engineering controls for 3-P-8 RA--1-1 05/03 floor drain flows into the FHBVS. The FHBVS can Procedure CP M-6, "Fire" both smoke and fire 3-P-i10 RA 03/08 AB sump. The collected operate in either of two for containment and suppression water runoff 3-P-I11 *,-44 05/03 wastes are released to the configurations, a normal monitoring of potential and use of revised PFPs 3-P-13
- A-12 03/08 environment at either of configuration or an iodine radioactive effluents. PFP and training materials, the units circulating water removal configuration. The revisions will identify DCPP's approach will be system discharge difference between the potentially contaminated considered acceptable to Deeedpiaestructures via the ASW configurations is the areas, provide instruction meet NFPA 805 System. The ASW System treatment of exhaust air. for communication with radioactive release and Main Circulating Each FHBVS contains two Radiation Protection and performance criteria.
Water System dilute the full-capacity supply fans describe precautions to be collected waste. The that collect air from along undertaken for the The results documenting effluents are continuously one side of the fuel pool, containment and safe conformance to NFPA 805 monitored and require and discharge into duct removal of contaminated radioactive release criteria positive operator action to work in the corridors and smoke and water runoff in will be maintained as part be released into the equipment compartments these potentially of DCPP's Configuration environment, below the SFP. contaminated areas. Control Program. This Page E-148
Pacific Gas and Electric Company Attachment E - Radioactive Release Transition Table E-1 - NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Screened Engineering Controls Training and Pre-Fire Unit Area Zone Description Plan Rev. In? Water Smoke Plan Review Results Conclusions and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents. 2 V-3 3-V-2 HVAC Room RA--1-.~ 05/03 Yes Floor drains are routed to Each unit is served by a Training materials reinforce Based on the availability of RA-.4- 05/03 the monitored LRS. Each .similar but separate use of PFPs and Casualty engineering controls for floor drain flows into the FHBVS. The FHBVS can Procedure CP M-6, "Fire" both smoke and fire 3-V-3 *A4. 05/03 AB sump. The collected operate in either of two for containment and suppression water runoff RA-44. 03/08 wastes are released to the configurations, a normal monitoring of potential and use of revised PFPs RA-15 05/03 environment at either of configuration or an iodine radioactive effluents. PFP and training materials, RA-16 03/08 the units circulating water removal configuration. The revisions will identify DCPP's approach will be RA-17 05/03 system discharge difference between the potentially contaminated considered acceptable to RA-18 05/03 structures via the ASW configurations is the areas, provide instruction meet NFPA 805 System. The ASW System treatment of exhaust air. for communication with radioactive release 3-V-4 R.A-4 05/03 and Main Circulating Each FHBVS contains two Radiation Protection and performance criteria. R---- 05/03 Water System dilute the full-capacity supply fans describe precautions to be collected waste. The that collect air from along undertaken for the The results documenting 3-V-9 RA--1.- 05/03 effluents are continuously one side of the fuel pool, containment and safe conformance to NFPA 805 RA-4.* 05/03 monitored and require and discharge into duct removal of contaminated radioactive release criteria positive operator action to work in the corridors and smoke and water runoff in will be maintained as part be released into the equipment compartments these potentially of DCPP's Configuration environment, below the SFP. contaminated areas. Control Program. This Training material and PFP program will ensure that During NPO: Floor drains During normal operation, revisions will describe the the radioactive release as described above one non-vital exhaust fan presence and potential use goals, objective and remain present. is in operation and the air of monitored ventilation performance criteria will is passed through a and drainage systems, if continue to be satisfied Provisions are in place to roughing and HEPA filter such systems are deemed when considering the commence before being discharged to operational and capable of possibility that areas that communication between the plant vent. In the iodine supporting manual removal were not contaminated at the Fire Brigade and removal configuration, efforts. The level of detail the time of NFPA 805 Radiation Protection and exhaust air passes through provided in the revised transition, and were to contain/monitor liquid charcoal adsorbers in training materials and consequently screened-effluents prior to safe addition to roughing and PFPs will meet NFPA 805 out, may become removal. HEPA filters. Automatic radioactive release contaminated in the future initiation of the iodine performance criteria, due to plant operational removal configuration events. occurs in response to high Implementation Item S-radiation, as measured by 3.19 - PFPs and training Implementation Item 5-radiation monitors in the materials will be revised to 3.20 -" The NFPA 805 FHB, or upon failure of the address radioactive radioactive release review normal operating exhaust release requirements of will be incorporated into fan. Ventilation air from NFPA 805. See NFPA 805 DCPP's Configuration Page E-150
Pacific Gas and Electric Company Attachment E - Radioactive Release Transition Table E-1 - NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Screened Engineering Controls Training and Pre-Fire Unit Area Zone Description Plan Rev. In? Water Smoke Plan Review Results Conclusions areas containing Transition Report Control Program. See radioactive materials is Attachment S, Table S-3. NFPA 805 Transition exhausted through HEPA Report Attachment S, and/or charcoal filters. Table S-3. During NPO: The ventilation and monitoring systems as described above remain present. If normal ventilation is
./ unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2 V-4 3-V-6 HVAC Room RA-19 05/03 Yes Floor drains are routed to Each unit is served by a Training materials reinforce Based on the availability of 3-V-7 RA-20 05/03 the monitored LRS. Each similar but separate use of PF~s and Casualty engineering controls for 3-V-8 RA--1-9 05/03 floor drain flows into the FHBVS. The FHBVS can Procedure CR M-6, "Fire" both smoke and fire 3-V-10 ,eA 05/03 AB sump. The collected operate in either of two for containment and suppression water runoff 3-V-il *f A- 05/03 wastes are released to the configurations, a normal monitoring of potential and use of revised PFPs 3-V-13 J' A-2-O 05/03 environment at either of configuration or an iodine radioactive effluents. PFP and training materials, the units circulating water removal configuration. The revisions will identify DCPP's approach will be Deeedpiaesystem discharge difference between the potentially contaminated considered acceptable to structures via the ASW configurations is the areas, provide instruction meet NFPA 805 System. The ASW System treatment of exhaust air. for communication with radioactive release and Main Circulating Each FHBVS contains two Radiation Protection and performance criteria. Water System dilute the full-capacity supply fans describe precautions to be collected waste. The that collect air from along undertaken for the The results documenting effluents are continuously one side of the fuel pool, containment and safe conformance to NFRA 805 monitored and require and discharge into duct removal of contaminated radioactive release criteria Page E-151
Pacific Gas and Electric Company Attachment E - Radioactive Release Transition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone Pre-Fire Screened Engineering Controls Training and Pre-Fire Unit Area Zone Description Plan Rev. In? Water Smoke Plan Review Results Conclusions However, per discussion is screened-in. However, conformance to NFPA 805 with site Radiation per discussion with site radioactive release criteria Protection, there is no Radiation Protection (RP), will be maintained as part radioactive waste or other there is no radioactive of DCPP's Configuration storage of permanent and waste or other storage of Control Program. This transient combustibles permanent and transient program will ensure that within the SG Storage combustibles within the the radioactive release Building. The contents are Steam Generator Storage goals, objective and non-combustible, there Building. The contents are performance criteria will are no work processes non-combustible, there are continue to be satisfied which occur in the no work processes which when considering the building, and therefore a occur in the building, and possibility that areas that credible fire scenario is therefore a credible fire were not contaminated at not anticipated. As such, scenario is not anticipated, the time of NFPA 805 this facility can be As such, this facility can be transition, and were dispositioned as being of dispositioned as being of consequently screened-negligible radioactive negligible radioactive out, may become release consequence and release consequence and contaminated in the future the radioactive dose limits the radioactive dose limits due to plant operational of 10 CFR 20 will not be of 10 CFR 20 will not be *events. exceeded due to the exceeded due to the S 2O~ effects of fire suppression effects of fire suppression Implementation . - activities, activities. The NEPA 805 radioactive release review will be incorporated into DCPP's Configuration Control Program. See NFPA 805 Transition Report Attachment 5, Table S-3. N/A N/A N/A Unit 2 Cold PA-i19 03/08 No N/A N/A N/A N/A - Screened Out Machine Shop - Building 116 N/A N/A N/A Vehicle OC-32 03/08 No N/A N/A N/A N/A - Screened Out Maintenance Shop /Parts Office - Building 526 N/A N/A N/A Warehouse PA-34 03/08 No N/A N/A N/A N/A - Screened Out "A"Building 528 and Surrounding Area Page E-158
Pnrifi* ('*n¢ nnd I=l*rfrir ('*.nmnnnv Aff*rhm*nf I -- *flniflnn *f Pr*ntc*r RIr*rk P~iife ~+/-u 2rIFtrtrr~(~mn~~,A~~ahm~t f~fmitr~ jf D~urV nI, k The term "power block" is clarified in Section K.2 (Frequently Asked Question (FAQ) 06-0019) of NEI 04-02, Revision 2, as "structures that have equipment required for nuclear plant operations, such as containment, auxiliary building, fuel handling building, turbine building, and intake structure, or structures that are identified in the facility's current license basis." The structures in the Owner Controlled Area were evaluated in Report P1890-002-001, Revision 4, to determine those structures that contain equipment that is required to meet the nuclear safety performance criteria and radioactive release performance criteria described in Section 1 .5 of NFPA 805. For the purpose of establishing the structures included in the Diablo Canyon Power Plant (DCPP) Fire Protection (FP) program in accordance with 10 CFR 50.48(c) and NFPA 805, plant structures listed in the following table are considered to be part of the power block: Table I-1 - Power Block Definition Power Block Structures Fire Area(s) AB-i (UI), AB-i (U2), AB-2, AB-3, 3-B-i, 3-B-2, 3-D-1, 3-0-2, 3-H-i, 3-H-2, 3-I-i, 3-1-2, 4-A (U1), Auxiliary Building (Unit 1, Unit 2 and 4-A (U-2), 4-A-i, 4-A-2, 4-B (U 1), 4-B (U2), 4-B-Como)1, Common)2, 4-B-2, 5-B-3, 5-A-i, 5-B-4, 5-A-2, 6-A-i, 5-A-3, 6-A-2, 5-A-4, 6-A-3, 5-B-i, 6-A-4, 5-B-6-A-5, 6-B-i, 6-B-2, 6-B-3, 6-B-4, 6-B-5, 7-A, 7-B, 7-C, 7-D, 8-C, 8-H, 34 (U1), and 34 (U2) Auxiliary Building (Control Room Complex) CR-i (U1) and CR-i (U2) Containment Building (Unit i, Unit 2 and 1 ,3Bad3C Penetration Areas) 1 ,3Bad3C Fuel Handling Building (Unit i1 Unit 2 and AB-i (Ui), AB-1 (U2), FB-i (Ui), FB-1 (U2), FB-Common) '2, V-i, V-2, V-3, V-4, 2, 3-P-i, 3-P-5, 3-P-i2, 3-Q-l, 3-T-i, 3-V-i, 3-V-5, 3-V-i2, and 33 Intake Structure (Unit i, Unit 2 and I-,3--,3--,3--,3-- Common) I-,3 -- ,3 -- ,3 -- ,3 -- TB-i, TB-2, TB-3, TB-4, TB-5, TB-6, TB-7 (Ui), Turbine Building (Unit 1, Unit 2 and TB-7 (U2), TB-8, TB-9, TB-i0, TB-1i, TB-12, Common) TB-13, TB-i4, TB-i7, i0, i1-D, i3-D, i3-E, 13-F, i4-B, is, 17, 18, 20, 22-C, 24-D, 35-A, and 35-B Buttress Building TB-i5 and TB-16 Transformer Yard Areas (Unit i and Unit 2, including Main Bank, Auxiliary and Startup 28 and 29 Transformers)
~[Power Block Structures] Radwaste Laundry Facility and Yard Vault
[Fire Area(s)] 26, 27-A, 27-B, and 27-C Page I-2
P*rifir I I
*=* *nrl I::l*rfrir I
*.nrnn=nv Aff',r-hment" I -- Iira Mrularlinn \Ik.\I lib *H* Hll* b bbLI Ib VVIll*gll* /'IILLU*I/IlllISIII, !,/ l 115 lllVU!*'IIII*,I V*l,*,V Table J-1 - Verification and Validation (V &V) Basis for Fire Models / Model Correlations Used Calculation Application -V& V Basis Discussion HGL Calculations using Calculates the upper and
- NIST Special Publication 1086,
- V&V of the CFAST code is documented in the NIST Consolidated Model of Fire lower gas layer 2008 Special Publication 1086.
Growth and Smoke temperature and interface Transport (CFAST) height for various
- CFAST Version 6 *The V&V of CFAST specifically for Nuclear Power compartments.
- NUREG-1824, Volume 5, 2007 Plant applications is documented in NUREG-1824.
*It is concluded in NUREG-1 824, Volume 5, Chapter 6,
- NUREG-1 934, Chapter 2, 2012 "Model Validation", that CFAST models the Hot Gas
- R2044-311-001, "Verification and Layer (HGL) height, temperature and smoke
- Validation of Fire Modeling Tools concentration in an appropriate manner.
..- *..n A proa,"e fr evisin 2,P
- The model has been applied within its limits of 8 .* ," evison , "applicability and within the validated range reported in SSections F.1 an . NUREG-184o.i ~~e utside the validated -,------
- Add items:
[Calculation] Structural Steel Temperature Calculations for a Catastrophic T/G fire using FDS [Application] Calculate HGL and target temperatures at critical locations such as ceilings and walls [iV&V Basis]
- NIST Special Publication 1018, 2010
- FDS Version 5
- NUREG-1 824, Volume 7, 2007
- NUREG-1934, Chapter 2, 2012
- R2044-31 1-001, "Verification and Validation of Fire Modeling Tools and Approaches for Use in NFPA 805 and Fire PRA"
- SFPE Handbook of Fire Protection Engineering, 4th Edition, Chapter 1-10, Kodur V.K.R., and Harmanthy T.Z., 2008
[Discussion]
- V&V of the EDS code is documented in the NIST Special Publication 1018
- The V&V of EDS specifically for Nuclear Power Plant applications is documented in NUREG-1 824.
- It is concluded in NUREG-1 824, Volume 7, Chapter 6, "Model Validation," that FOS is suitable for predicting HGL height and temperature, with no specific caveats.
- The model has been applied within its limits of applicability and within the validated range reported in NUREG-1 824 or, if applied outside the validated range, the model has been justified as acceptable, either by qualitative analysis or by quantitative sensitivity analysis. The methodology for justifying application of the fire model outside the range is in accordance with methods documented in NUREG-1 934.
- Structural Steel damage criteria is documented in authoritative publication of the "SFPE Handbook of Fire Protection EngineeringY' r'age j-/
Attachment L - NFPA 805 Pacific Gas and Electric Company Chapter 3 Requirements for Approval Approval Request 3 net adP& eindaings require" NFPA 805, Sectio .3.hng 6 set1 NFPA 805, Sectio ... tts "Only metal traynmea nsr:"nPGEdsgdrwgseqi" tubing shallnt en se shall only be u edin s orefrnetrwn 502 hne6,set1 PG&E requesNCapoafothusofnnealccduInet"otoraesadidraes from the reirm sofFA80,Catr3f I S sujctowtocorsvenrnets DCM T-22 ta ii o net rgdio" di uha h naesrcue diinly applications i tcodnt onlcae ea lxbecnuti sdi
*PG&E/ olicy is to u PVC outdoors, either embedded shr egh ocnetcmoet.
- PV coated Ri.gid-4re~i conduit is used above ground in the intao ctruct'.uro. .......
DCM T-22 req.'.ires-that Acrylonitrile-Butadiene-Styrene (ABS) conduit be embedded in concrete or in earth beneath a protective concrete slab in indoor and outdoor applications. DCM T-22 req*ires-that Transite be only used when buried directly in the ground or encased in cemen,,
- Since Transite is an asbestos product, its manufacture has been discontinued. As ar replacement for Transite Type I1,* 051879 allows the use of ABS, high density polyethylene (HDPE), or PVC for (rect burial use, provided they meet the requirem{ nts of the, ,Western Underground Corn.3-.e DCM T-22 !'vthat Electrical Metallic Tubi* Thermal Electric. luit may not be use* for Finally, no , ,and low-voltage video, communication, and data cabling.
Basis for Request: The basis for the approval request of this deviation for embedded nonmetallic conduit is:
- Access points to embedded conduit are required by DCM T-22 to be rigid steel. The nonmetallic conduit in question is used in concrete embedded pplications, thus providing physical protection and separation for the conduit.
- The plastic conduit embedded in concrete is not subject to flar e/heat impingement from an external source which would result in structural failure, cot ribution to fire load, and/or damage to the circuits contained within, where the conduit is :mbedded in concrete.
Isr:"nPGEdsgdrwnsrwould not result in damage Reeec:daig002 hne6,set8exposed to the effects of
- NFPA 70 (National Electric Code (NEC)), Article 352, allows use of Rigid Nonmetallic Conduit for underground and embedded applications.
Page L-11
AtcmnL-NPA805 Pacific Gas and Electric Comn Chapter 3 Requirements for Approval The basis for the approval request of this deviation for EMT (thin wall) conduit is:
- EMT is used only for non-Class 1E applications. Accordingly, potentially affected equipment is only that which is not essential to achieve safe and stable plant conditions
--/"G"M-/IT 49"*
- EMT is used extensively throughout the plant in non-Class 1E applications. Replacing
*~ch conduit would be extremely burdensome and cost ineffective, with little Add "(DCM T-22 ional enhancement of the fire protection program.
dawnd gEdsign IEC states, in Article 358.10, that "the use of EMT shall be permitted for both drawigs)."sed and concealed work." According to the NFPA Report on Proposals for Revision
Reference:
drawing =PA 805-2001, Section 3.3.5.2 of NFPA 805, was revised for consistency with 050030 revision 42, A70 to remove the sentence regarding thin-wall metallic tubing. The current sheet 18 *n, NFPA 805-2010, retains this change. The revised section (which is Section 5.3.7.2 in the 2010 edition) states:
"Only metal tray and metal conduits shall be used for exposed electrical raceways." The addition of the word "exposed" indicates that plastic conduits are permitted for electrical raceways that are not exposed (i.e., embedded or underground).
The basis for the approval request for this deviation for nonsheathed, metallic, flexible conduit for fiber optic and low-voltage video, communication, and data cables is:
- The video, communication, and data cables in question are not power, control, or instrumentation circuits and are not essential to achieve safe and stable plant conditions.
- Fiber optic and low-voltage cables are not generally susceptible to self-ignition and electrical shorts that could result in fire and potential damage to external targets.
Acceptance Criteria Evaluation: Nuclear Safety and Radiological Release Performance Criteria: The use of nonmetallic conduit for raceways embedded in concrete is allowed by NFPA 70, National Electric Code (NEC), and provides adequate physical and electrical protection for cables. The use of plastic conduit in embedded locations does not affect nuclear safety, as the material in which conduits are run within an embedded location are not subject to the failure Th sfnonmCas Etaircuis chreondui inhembedeinstaimactionsthenc,*,Ad."teuseo wi ,onPV-class__, cruTsanthe use of nonsheathed, metallic, flexible conduit for fiber op tic° aondut low-voltage viecommunication, and data cables doe not havfeayipct n- ohto thelradiologicalcreleas performance criteria. The radiological release review was performed based on the manual fire suppression activities in areas containing, or potentially containing, radioactive materials and is Page L-12
Pacific Gas and Electric Company Appended Page The following text is to be added where identified in the callout on Page L-12: The basis for the approval request of this deviation for PVC-coated rigqid iron conduit used above ground is as follows:
- PVC-coated rigqid iron conduit provides equivalent physical and electrical protection to standard rigid iron conduit, because the characteristics of the metallic body of the conduit are not affected by the coating.
- The use of PVC-coated rigqid iron conduit is limited to outdoor areas and indoor areas subiect to wet or corrosive environments, such as the intake structure.
- NFPA 70 (NEC). Article 344. allows rigqid metal conduit to be used in wet areas and areas subiect to severe corrosive influences, provided that it is equipped with corrosion protection.
- Because the PVC coating is thin, it is not expected to sustain fire on the conduit exterior for any credible lengqth of time. Specifically, the plastic coating is approximately 0.060" thick or less, and is not expected to provide any credible influence on fire propagqation behavior.
- If a fire were to occur in a fire area containingq these conduits, existing controls such as fire-rated barriers, electrical raceway fire barrier systems. spatial separation. etc. would ensure that redundant cabling and circuitry would not be affected by the fire.
The basis for the approval request of this deviation for coated flexible metallic conduit used in short lengths to connect components is as follows:
- Coated flexible metallic conduit provides equivalent physical and electrical protection to uncoated flexible metallic conduit, because the characteristics of the metallic body of the conduit are not affected by the coating..
- The use of such conduit complies with the requirements of NFPA 805, 2001 edition, with the exception that the metallic flexible conduit is coated with thermoplastic material.
*Because the thermoplastic coatingq is thin, it is not expected to sustain fire on the conduit exterior for any credible length of time. Specifically, the plastic coatingq is approximately 0.060" thick or less, and is not expected to provide any credible influence on fire propagqation behavior.
- If a fire were to occur in a fire area containing these conduits, existingq controls such as fire-rated barriers, electrical raceway fire barrier systems. spatial separation. etc. would ensure that redundant cablingq and circuitry would not be affected by the fire.
Page L-12A
Pacific Gas and Electric Company Appended Page The following text is to be added where identified in the callout on Page L-12: The use of PVC-coated rigqid iron conduit is provided for in NFPA 70 (NEC) and provides equivalent physical and electrical protection for cables as uncoated rigid iron. The use of PVC-coated rigid iron conduit in areas subiect to corrosive influences does not affect nuclear safety. as the characteristics of this PVC-coated conduit do not lend themselves to credible fire propagation that would cause safe shutdown circuits or equipment to be affected. If a fire were to occur in a fire area containing these conduits, existing controls such as fire-rated barriers. electrical raceway fire barrier systems. spatial separation. etc. would ensure that redundant cabling and circuitry would not be affected by the fire. The use of coated metal flexible conduit is used in short lengqths to connect components does not affect nuclear safety, as the conduit will provide eguivalent protection to uncoated flexible metallic conduit, and the characteristics of this plastic-coated conduit do not lend themselves to credible fire propagation that would cause safe shutdown circuits or equipment to be affected. If a fire were to occur in a fire area containing these conduits, existingq controls such as fire-rated barriers, electrical raceway fire barrier systems, spatial separation. etc. would ensure that redundant cabling and circuitry would not be affected by the fire. Page L-12B
radiological release evaluation peffor..id that potentially contaminated water is contained and smok. monitored. The conduits do not add additional radiological materials to the area or F.* .. * .cha flge/system s boundaries that contain plastic conduits. / - *T P - n - L -"'R 1 Af r Ad:"i" fty Margin and, Defense-i~n-Depth: updated par...r.ph. The three echelons of DID are: (1) to prevent fires from starting (combustible/hot work controls); (2) rapidly detect, control and extinguish fires that do occur, thereby limiting damage (fire detection systems, automatic fire suppression, manual fire suppression, PFPs); and (3) provide adequate level of FP for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers, fire-rated cable, success path remains free of fire damage, RAs). The use of embedded/underground plastic conduit, EMT, and nonsheathed, metallic, ' "" _ eno affect echelons 1, 2, an .Add: PCcae igdiocaed flexible metallic manual fire suppression functie onutishrlegstocnctom nns, capability.
Conclusion:
NRC approval is requested for the use of nonmetallic,/ MT, and flexible conduit at DCPP as described above. The performance-based approach satisfies the following criteria: (A) Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release (B) Maintains safety margins; and (C) Maintains fire protection DID (fire prevention, fire detection, fire suppression, mitigation, and post-fire nuclear safety capability). Page L-13
Attachment L - NFPA 805 Pacific Gas and Electric Company Chapter 3 Requirements for Approval Approval Request 4 NFPA 805, Section 3.3.7.2 NFPA 805, Section 3.3.7.2 states: .y Add "ifeen"'
"Outdoorhigh-pressure fla blI gas storage containers shall be located so that the long axis is not pointed at bitds."/
PG&E requests NRC *tpro AI of si 'hydrogen tanks whose long axes point at power block structures. Per IJ.AR, to ... 2, the existing configuration of the six hydrogen tanks, along with thr-ee-nitrog~e tanks, ar at sa sufficient distance from power block structures such that a fire or explosi at the tank /cation would not impact the power block structures. Basis for Re qst:/ The basisfth proval requ ,st of this deviation is as flos* The si 2ydrogen tanks and three nitrogen tanks are in a b*d~ that is approximately 88 feet fro e east side of the fuel handling building (column line V)./ Fhe six hydrogen tanks and three nitrogen tanks are at a sufficient distance from power bloc structures such that a fire or explosion at a tank would not impact the power block structures. Per Section 3.5.1.2 of the UFSAR, "Thrust loads resulting from a ostulated failure of the largest connected pipe or manifold have been calculated to produce stre ;ses no larger than yield in the container hold-down structure, therefore, no significant missiles ae postulated from any of these containers." An implementation item will ensure revision to applicable design gd idance to apply the requirements of this section to future chan es to the lant (See NF A 805 LAR Attachment S Table S-3, Item S-3.11). Add: "The structure (known as the "Yard Vault") is open Accetanc Crteri Evluaton:to the outdoors on the side facing the power block. In other words, the building does not have a western wall. Nuclear Safety and Radiological As such, the storage arrangement is considered to be Thehydoge an ntroen ank a"outdoors", as considered in NFPA 805 Section 3.3.7.2" that the existing configuration does not affect nuclear safety. Therefore, there is no impact on nuclear safety performance criteria. These tanks are at a sufficient distance from power block structures such that there is no impact on the radiological release performance criteria. Safety Margin and Defense-in-Depth: The hydrogen and nitrogen tanks are at a sufficient distance from power block structures such that there would be minimal impact on power block structures and equipment and, therefore, the safety margin inherent in the analysis for the fire event has been preserved. The existing configuration of the hydrogen and nitrogen tanks are at a sufficient distance from power block structures that it does not impact fire protection DID.
== Conclusion:== Ad ffen NRC approval is requested for approval of six hydrogen Lks whose long axes point at power block structures. The six hydrogen tanks, along with t=4enitrogen tanks, are at a sufficient distance from power block structures that it satisfies the intent of NFPA 805, Section "44.2*4"* Add: "3.3.7.2" Page L-14
Pacific Gas and Electric Company Appended Page The following text is to be added where identified in the callout on Page L-13: Embedded nonmetallic conduit is protected from mechanical damage and from damage resulting from either and exposure fire or from a fire within the conduit impacting other targets. The areas with plastic conduit have been analyzed in their current configuration. Precautions and limitations on use ensure that these materials do not impact the analysis of the fire event. Therefore, the inherent safety margin and conservatisms in these analysis methods remain unchanged. PVC-coated rigid iron conduit does not lend itself to credible fire propagation that would cause safe shutdown circuits or equipment to be affected. If a fire were to occur in a fire area containing these conduits, existing controls such as fire-rated barriers, electrical raceway fire barrier systems, spatial separation, etc. would ensure that redundant cabling and circuitry would not be affected by the fire. Additionally. because the conduit is rigid iron, it will provide eguivalent physical and electrical protection to standard rigid iron conduit, and will therefore not result in additional risk of damage to circuits. Precautions and limitations on use ensure that these materials do not impact the analysis of the fire event. Therefore, the inherent safety margin and conservatisms in these analysis methods remain unchanged. Coated flexible metallic conduit in short lengths to connect components does not lend itself to credible fire propagation that would cause safe shutdown circuits or equipment to be affected. If a fire were to occur in a fire area containingq these conduits, existing controls such as fire-rated barriers, electrical raceway fire barrier systems, spatial separation. etc. would ensure that redundant cabling and circuitry would not be affected by the fire. Additionally, because the conduit is metallic, it will provide eguivalent physical and electrical protection to standard flexible metallic conduit, and will therefore not result in additional risk of damage to circuits. Precautions and limitations on use ensure that these materials do not impact the analysis of the fire event. Therefore, the inherent safety margin and conservatisms in these analysis methods remain unchanged. EMT (thin wall) conduit is not used for Class 1 E applications after 6/1/82. and the analysis of Class 1E circuits is not affected. The circuits enclosed in EMT conduit are not essential to achieve safe and stable plant conditions. Additionally, the circuits are fully enclosed by conduit and therefore are not susceptible to in-conduit self-ignition. Precautions and limitations on use ensure that these materials do not impact the analysis of the fire event. Therefore. the inherent safety margin and conservatisms in these analysis methods remain unchanged. Nonsheathed. metallic, flexible conduit is used only for fiber optic and low-voltage video, communication, and data cables. They are not power, control, or instrumentation circuits and are not essential to achieve safe and stable plant conditions. Additionally, fiber optic and low-voltage cables are not susceptible to self-ignition and electrical shorts that could result in fire and potential damage to external conduits. Precautions and limitations on use ensure that these materials do not impact the analysis of the fire event. Therefore, the inherent safety margin and conservatisms in these analysis methods remain unchanged. Page L-13A
Attachment L - NFPA 805 Pacific Gas and Electric Company Chapter 3 Requirements for Approval Approval Request 5 NFPA 805, Section 3.3.8 NFPA 805, Section 3.3.8 states:
"Bulk storage of flammable and combustible liquids shall not be permitted inside structures containing systems, equipment, or components important to nuclear safety. As a minimum, storage and use shall comply with NFPA 30, Flammable and Combustible Liquids Code."
The Emergency Diesel Generator (EDG) day tanks supply fuel oil to the EDGs located in the Turbine Building (TB) (Fire Areas 1i-A-i, Il-B-I, il-C-i; 22-A-i, 22-B-I, and 22-C-i). As such, the EDG day tanks were re-reviewed against NFPA 30, 1969 Edition, as documented in P1890-002-004, 'Fire Protection Code Conformance Review". Specifically for this approval request, Section 2343 of NFPA 30 states: "Flammable or combustible liquid tanks located inside of buildings, except in one-story buildings designed and protected for flammable or combustible liquid storage, shall be provided with an automatic-closing, heat-actuated valve on each withdrawal connection below the liquid level, except for connections used for emergency disposal, to prevent continued flow in the event of fire in the vicinity of the tank. This function may be incorporated in the valve required in 2342 and, if separate valve, shall be located adjacent to the valve required in 2342." Contrary to the requirements of NFPA 30, Section 2343, the EDG day tanks do not have an automatic-closing, heat-actuated valve on each withdrawal connection below the liquid level. Additional details are provided below. NRC approval is requested for the use of the existing EDG day tank withdrawal connections not having heat-actuated closure valves. Basis for Request: The intent of the NFPA 30, Section 2343, requirement is to stop the flow of liquid in the evento a fire. The use of the existing EDG day tank withdrawal connections not having heat-actjae closure valves is requested based on the following information:
*The EDG day tank openings are provided with normally-close es and caps.
Therefore the only open withdrawal connection is th f jPpply lines to the EDG engines. The fuel supply lines to the EDG e~giee *e provided with-Re*-uy-epe"" valves in this safety-related EDG system. The addition of heat actuated, automatic closing shut-off valves in the fuel supply lilies would introduce additional single failure possibilities that could have an adverse eff ct on EDG equipment reliability and availability. *
,Add: "These valves aein the saefire ae
- The EDG day tanks maintain a local invento* as their respective EDGs and EDG day tank has a nominal capacity of 550 gallons. _e :tanks, but are separated from them by 3-alarm and control automatic make-up from th* hour fire rated roll-up doors that are fuel oil storage tanks and fuel oil transfer pum*, equipped with fusible links to cause them to safety-related monitoring instrumentation to pro close in the event of a fire. Also, the valves operating conditions are annunciated locally at aeacsil fro a adaetfr *rai Level control system with safety reltaed instrum the evnto.afiean.cnbeshtmaual prevention in this safety-related EDG system./ neen[oanran]cnesu m ual day tank fill valve is detected, operators are ab sigloclY staged wrenches-_.....
manual operation to limit oil spillage. To ensure and with minimal effort, T-wrenches are supplied in each EDG room. These wrenches have been fabricated to fit the actuator shafts and allow easy operation of the valves Page L-16
Pacific Gas and Electric Company Attachment L - NFPA 805 Chapter 3 Requirements for Approval from above. Modified grating is provided over the fill valves to allow for insertion of T-wrenches onto the fill valves. Manual isolation valves are also provided in each fuel oil transfer line supplying the EDG day tanks. These manual valves are located upstream of their respective EDG day tank level control valve. The manual valves are normally open and provide the capability to isolate the fuel oil branch piping serving a particular EDG day tank.
- A credible fire scenario of sufficient size and intensity to damage the EDG day tanks and corresponding EDG set is not anticipated for the following reasons:
- The EDG rooms are constructed of fire barriers and normally closed fire doors that are either 3-hour rated or evaluated to be adequate for the hazards;
-The access aisles around the perimeter of the EDGs are maintained free of combustible materials. DCPP uses transient combustible and hot work procedures throughout plant areas. Large steel I-beams form the north and south sides of the EDG day tanks. Due to the location of the EDG day tanks within the overall EDO steel I-beam frame assembly and the lack of combustibles in the vicinity of the tanks, the EDG day tanks are not anticipated to be subject to direct flame exposure;
- The EDG day tanks are provided with floor drains in each EDG room. A common 4 inch pitched header, which is a minimum of 3-1/2 feet below the drain openings, connects the drains from each room with the TB sump. The drainage system will drain the quantity of an EDG day tank fuel oil spill to the TB sump.
Drainage of fuel oil spills reduces the likelihood of a potential fire scenario
- An automati carbon dioxideiression system, actuated by a heat detection
- Add:
"'... tanks. The drainage system will not lead to a spread of fire to other fire areas for the following reasons: *. Each floor drain is covered by a circular grating and a supporting steel catch basin in the throat
'of the drain. This prevents debris that could lead to or sustain combustion from entering the drain system.
*Drainage of an oil spill in a compartment would not result in a flame pathway down the drain line
- since flame passage would be inhibited by the floor drain covers, oxygen depletion in the drain line, and the distance downward and laterally that the flame would have to traverse to propagate to the turbine building sump.
- Each EDG room is equipped with heat detectors that activate the total flooding 002 system for the fire area in the event of a fire, and close the roll-up doors on the west side of the space.
- In the worst case scenario, the entire supply of fuel oil has spilled from the EDG day tank in one EDO room and transient combustibles are located in the area of the drains. In this scenario, the Ifire would result in the activation of the C02 fire suppression system, which would prevent the fuel
- oil trapped in the drains from becoming heated to the auto-ignition temperature, by suppressing the fire in the affected area, thereby preventing propagation of fire through the drain.
Page L-17
Attachment L - NFPA 805 Pacific Gas and Electric Company Chapter 3 Requirements for Approval and precautionary measures, in addition to the presence of redundant and adequately-separated EDG systems, result in no impact on nuclear safety performance criteria. The use of the existing noncompliant EDG day tank withdrawal connections has no impact on the radiological release performance criteria. The radiological release review was performed based on the automatic and manual fire suppression activities in locations containing radioactive materials and is not dependent on the withdrawal connection configuration of the EDO day tanks. These tanks are not located in areas containing radioactive materials and, therefore, do not impact the radiological release evaluation performed at DCPP. Safety Margin and Defense-in-Depth: The use of the existing noncompliant EDG day tank withdrawal connections will not impact the ability of the plant to achieve and maintain fire SSD.-r'Duo to.. tho,,pr.......
, ofw* rcdund.,,,,
,.,. t nd ,,",
adouatl'; coparatcd EDG cyctcmc,* th, inh, n cafot' margi and concrlatcm inhc The three echelons of DID are: (1 rvent fires from starting (combustible/hot work controls); (2) rapidly detect, control an xt.inguish fires that do occur thereby limiting damage (fire detection systems, automatic fire sup sesion, manual fire suppression, PFPs); and (3) provide adequate level of FP for systems and u~ctures so that a fire will not prevent essential safety functions from being performed (fire barriefi're-rated cable, success path remains free of fire damage, RAs). The use the existing non-coin n~t EDG day tank withdrawal connections does not affect Echelons 1, 2, and 3; and do ~not directly result in compromising automatic fire suppression functions, manual fire suppressio hfunctions, or post-fire SSD capability.!
== Conclusion:==
- sets and offsite power, a fire-induced failure involving one EDG will not NRC approval is reque cause a failure of the EDG system to either mitigate the consequences having heat-actuated of an accident, or bring the Units to a SSD condition. Therefore, the equivalent level of fire :Safety Margin inherent in the analyses for the plant design basis Pacific Gas and Electri events has been preserved in the analysis for the fire event."
criteria: (A) Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release (B) Maintains safety margins; and (C) Maintains fire protection DID (fire prevention, fire detection, fire suppression, mitigation, and post-fire nuclear safety capability). Page L-18
Attachment L - NFPA 805 Pacific Gas and Electric Company Chapter 3 Requirements for Approval Approval Request 6_ _ _ _ _ _ _ _ _ NFPA 805, Section 3.3.5.3 NR FE A I*aaa= epnet NFPA 805, Section 3.3.5.3 states:
"Electric cable construction shall comply with a flame propagationtest as acceptable to the AHJ."
Diablo Canyon Power Plant (DCPP) has cables that were not originally required to meet the flame tests of IEEE 383. PG&E requests NRC approval for cables that do not meet the flame tests of IEEE 383 as an acceptable variance from the requirements of NFPA 805, Chapter 3 requirements. A review of cables installed at DCPP reveals the existence of cables that do not meet the criteria of NFPA 805, Section 3.3.5.3. These cables are used in small quantities in most fire areas, andlor are generally routed in conduit or used inside panels and equipment. Specifically, subject cables can be characterized as being in one of the following categories:
- Wire or cable used only within panels or equipment.
- Lighting and receptacle cables that are installed entirely within fully enclosed raceway (i.e., conduit, solid tray with solid covers).
- Specialty cables, such as video, communication, and data cables.
Basis for Request: The basis for the approval request of this deviation is:
- Cables that are internal to panels and equipment or installed entirely within fully enclosed raceway:
o Do not contribute to the fire growth and spread in any fire area, as assessed in accordance with the methodologies of NUREGICR-6850. o Do not present a credible risk of ignition, as assessed in accordance with the methodologies of NUREGICR-6850.
*Specialty cables, such as video, communication, and data cables that are not installed entirely within fully enclosed raceway:
Page L-19
Attachment L - NFPA 805 Pacific Gas and Electric Company Chapter 3 Requirements for Approval o Are not associated with NSCA equipment. Therefore, damage to these cables would not result in inability to achieve and maintain the fuel in a safe and stable condition. o With the exception of the Unit I and Unit 2 Communications Rooms (Fire Areas 7-C and 7-D) and the Main Control Room (Fire Area CR-I), fire areas contain a quantity of these cables that does not contribute to fire growth and spread.
*The Unit I and Unit 2 Communications Rooms (Fire Areas 7-C and 7-D) are protected by an automatic CO2 suppression system. Hose stations and portable fire extinguishers are also available in the vicinity. A fire in one of these rooms would be readily detected and extinguished by the automatic actuation of the CO2 suppression system.
*The Main Control Room (Fire Area CR-I) is constantly manned, and is protected by automatic in-cabinet detection systems. Hose stations and portable fire extinguishers are available in the vicinity. A fire in the Main Control Room would be readily detected because it is constantly manned, and quickly extinguished.
o Video, communication, and data cables are typically fiber optic or low-voltage cables that are not generally susceptible to self-ignition and electrical shorts that could result in fire and potential damage to external targets. Acceptance Criteria Evaluation: Nuclear Safety and Radiological Release Performance Criteria: The use of cables that are internal to panels and equipment or installed entirely within fully enclosed raceway does not contribute to fire growth and spread or ignition frequency in any fire area, since they are internal to panels and equipment or fully enclosed raceway. Therefore, their use does not result in a challenge to the plant's ability to achieve and maintain the fuel in a safe and stable condition. Therefore, there is no impact on the nuclear safety performance criteria. The use of specialty cables, such as video, communication, and data cables that are not installed entirely within fully enclosed raceway does not contribute to fire growth and spread or ignition frequency in any fire area, since such cables are Page L-20
Attachment L - NFPA 805 Pacific Gas and Electric Company Chapter 3 Requirements for Approval low voltage and therefore not generally susceptible to self-ignition. For those areas where the quantity of such cables is sufficient to contribute to fire growth and spread, adequate fire detection or automatic suppression, and manual fire suppression equipment are provided to ensure rapid detection and suppression in the event of a fire. Such cables are not associated with NSCA equipment, and their use does not result in a challenge to the plant's ability to achieve and maintain the fuel in a safe and stable condition. Therefore, there is no impact on the nuclear safety performance criteria. The use of cables internal to panels and equipment or installed entirely within fully enclosed raceways and the use of specialty cables do not have any impact on the radiological release performance criteria. The radiological release review was performed based on the manual fire suppression activities in areas containing, or potentially containing, radioactive materials and is not depended on the types of cables. The cables do not change the radiological release evaluation performed that potentially contaminated water is contained and smoke monitored. The cables do not add additional radiological materials to the area or challenge systems boundaries. Therefore, there is no impact on the radiological release performance criteria. Safety Margin and Defense-in-Depth: The use of cables that are internal to panels and equipment or installed entirely within fully enclosed raceway does not contribute to fire growth and spread or ignition frequency in any fire area, since they are internal to panels and equipment or fully enclosed raceway. Precautions and limitations on use ensure that these materials do not impact the analysis of the fire event. Therefore, the inherent safety margin and conservatisms in these analysis methods remain unchanged. The use of specialty cables, such as video, communication, and data cables that are not installed entirely within fully enclosed raceway does not contribute to fire growth and spread or ignition frequency in any fire area, since such cables are low voltage and therefore not generally susceptible to self-ignition. For those areas where the quantity of such cables cannot be characterized as "insignificant," adequate fire detection, and automatic and/or manual fire suppression equipment are provided to ensure rapid detection and suppression in the event of a fire. Also, such cables are not associated with NSCA equipment. Precautions and limitations on use ensure that these materials do not impact the analysis of the fire event. Therefore, the inherent safety margin and conservatisms in these analysis methods remain unchanged. The three echelons of DID are: (1) to prevent fires from starting (combustiblelhot work controls); (2) rapidly detect, control and extinguish fires that do occur, thereby limiting damage (fire detection systems, automatic fire suppression, manual fire suppression, PFPs); and (3) provide adequate level of FP for systems Page L-21
Pacific Gas and Electric Company Attachment L - NFPA 805 Chapter 3 Requirements for Approval and structures so that a fire will not prevent essential safety functions from being performed (fire barriers, fire-rated cable, success path remains free of fire damage, RAs). The use of cables that were not originally required to meet the flame tests of IEEE-383 does not affect echelons 1, 2, and 3, as discussed above. They do not directly result in compromising automatic or manual fire suppression functions, fire protection for systems and structures, or post-fire SSD capability.
== Conclusion:==
NRC approval is requested for the use of cables that do not meet the flame tests of IEEE-383 (or equivalent) in accordance with the requirements of NFPA 805, Section 3.3.5.3. The performance-based approach satisfies the following criteria: (A) Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release (B) Maintains safety margins; and (C) Maintains fire protection DID (fire prevention, fire detection, fire suppression, mitigation, and post-fire nuclear safety capability Page L-22
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Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed In Comp Rs nomdCaatrzto Modification FPRA Measure Rs nomdCaatrzto S-2.5 Medium 2 Rc r-tc cf-cable Ga *--e~t Yes Yes This modification will eliminate the associated with
- need for a Recovery Action MS-2-FCV-95 is Ad:"R Sassociated with ensuring steam is necessary to reduce available to the turbine-driven the risk associated Auxiliary Feedwater pump, thus with a fire in Fire reducing the risk of a loss of decay Area 5-B-4. This heat removal capability. This modification will also modification provides an resolve a VFDR in improvement in ACDF and ALERF.
Fire Area 6-B-4. Cmestr esr o Additional detail is NFmpenator805:reo provided inNFA85 Section 4.8.2 of the Appropriate compensatory measures Transition Report. will be established per OM8.1D2, as required, until the modification is implemented. enhanementfor"Compensatory Measure for 10 CFR 50 Appendix R: Appropriate compensatory measures have been established per OM8.1D2, and will remain in place until the modification is implemented. Page S-7
Pacific Gas and Electric Company tahetS-MdfctosadIpeetto Attachment tm S.- Modifications and Implementation Items Table S-3, Implementation Items, provided below are those items (procedure changes, process updates, and training to affected plant personnel) that will be completed prior to the implementation of new NFPA 805 Fire Protection Program (FPP), as defined in Section 5.5 of this LAR. ofteflwigimsiTal -wilbimlm tewiin65dyafr all modifications for the respective unit are operable (as listed in Table S-2). IL*I II i~fHIlL
~ectonIource S-3.1 . 1, 2 SAP Notification 50399288 was issued to track the development and 4.6 implementation of the NFPA 805 monitoring program for DCPP.
S-3.2 1, 2 SAP Notification 50294777-27 was issued to track the revision of 0M8.1D4 to 4.1.2 and incorporate the requirements of NFPA 805, Section 3.3.1 .2.(1), which discusses Attachment A wood used within the power block. S-3.3 1, 2 SAP Notification 50294777-3 was issued to track the revision of 0M8.1D4, 4.1.2 and Section 5.1.1 .f, to address basis of flame retardant plastic sheeting material. Attachment A S-3.4 1, 2 SAP Notification 50294777-15 was issued to track the revision of OM8.1D4 to 4.1.2 and comply with the requirements of NFPA 805, Section 3.3.1.2(3), for removal of Attachment A incident combustible materials at the end of the shift or when work is complete, whichever comes first. Also, OM8.1D4 will be revised to specify labeling and limits on combustible storage areas per NFPA 805, Section 3.3.1.2(4). S-3.5 1, 2 SAP Notification 50294777-6 was issued to track the revision of Plant Procedure 4.1.2 and MA1 .ID9 to include requirements that management ensure that only approved Attachment A apparatus, such as torches, manifolds, regulators or pressure reducing valves, and acetylene generators, be used in accordance with NFPA 51 B requirements. S-3.6 1, 2 SAP Notification 50294777-13 was issued to track the revision of applicable 4.1.2 and procedure(s) to indicate the operational requirements for cutting/welding equipment Attachment A with more than one cylinder as required by NFPA 241. Page S-8
PacficGasandEletri Co an At "Add: "... , and of other implementation items listed in Table S-3, if determined to impact the post-transition PRA models. If the actual Table S Implementation It* change-in-risk and/or total risk exceeds the acceptance guidelines of Regulatory Guide Item Unit Description 1.174, the model will be reassessed and new 99538 has been issued to addre* modifications or refinements will be S-3.23 Add: "... and total lents and Task Qualification Gui4 implemented, as necessary, to meet the risk..." mLl *ihy~ el performing acceptance guidelines prior to its use in the
~ m~n+ ~ ~ -' , -
S-.4 1, 2 SAP 1*tification 5054160 was issued to verify the validity of the r'eported chang - Attachment S in-risk'upon completion of I.1 Table S-2 modifications, which are credited in the PI A currently and are therefor ~stimates based on current plans.</ S-3.25 1, 2 SAP Notification 50294777-23 was issued to revise applicable plant procedures to Attachment V address seismic fire brigade training as necessary as required by the EPRA to support compliance with Supporting Requirement SF-A5. 5-.SPNotification create new plant administrative wr 4.5.1.1 and proce-8todfne 50541was isudto the process for implementing regularly scheduled Attachment V and interim PRA model up ae, king issues identified as potentially affecting Add items: ,[Item] S-3.27 [Unit] 1, 2 [Description] PG&E will create a "No Combustible Storage" area within 5 feet of the north wall of Fire Compartment 6-A-3. This will include the addition of localized visual warnings in accordance with OM8.1D4 and the addition of Fire Compartment 6-A-3 to Section 5.5.4 of 0M8.1D4 [LAR Section/Source] PRA RAI 05 [Item] S-3.28 [Unit] 1, 2 [Description] PG&E will monitor small and infrequent gaps in credited cable tray covers to ensure they do not exceed one 'inch wide, spaced three or more feet apart as part of the DCPP NEPA 805 monitoring program. [LAR Section/Source] FM RAI 02.b [Item] S-3.29 [Unit] 1, 2 [Description] PG&E will use NRC accepted SDS failure models as these become available to confirm, as a minimum, that-the transition change-in-risk estimates will not exceed the RG 1.205 acceptance guidelines. The DCPP NFPA 805 Change Evaluation process will include provisions to ensure that self-approved changes that rely on the SDS failure model will not be undertaken before acceptable models have been developed. [LAR Section/Source] PRA RAI 01 .f [Item] S-3.30 [Unit] 1, 2 [Description] PG&E will update radioactive storage procedures to incorporate a monitoring program to ensure that radioactive materials are not stored in a given area in excess of values determined by related calculations that are part of the NEPA 805 fire protection program. [LAR Section/Source] RR RAI 04 [Item] S-3.31 [Unit] 1, 2 [Description] Verification of the condition of electrical cabinet doors to meet fire modeling assumptions will be included in the monitoring program. [LAR Section/Source] FM RAI 01 .d Page S-12
Pacific Gas and Electric Company Attachment V - Fire PRA Quality Table V-2 FPRA Peer Review - Facts and Observations - SR Topic F&O Level Status Finding Disposition known. These systems are also not A set of sensitivity analyses were included since they are not important provided in Calculation F.3.15 to the internal events risk model. R*-'4sieR4 to further su p ort the Documentation for meeting the justification.,_ Cha nge to" " requirement is not clear. However, review of model results show system *"Revision 2" importance is low. Provide clarification in documentation. ES-B1 ES-B1-02 (2008), CC Finding Closed The intent of ES-B 1 per Discussion 2 When the DCPP FPRA was first I, need to verify the is that it is iterative. The analysis developed, the exclusion of basis of excluding does not demonstrate that excluded equipment from the FPRA was low importance SS0 components are revisited to determine not justified during the valid ifthe system/component should be component selection process in added due to importance of risk, terms of its risk significance Reference Section 7.7.1.c and considering fire initiators. This Section 3.2 for systems and can only be performed once the components considered. Discussion* detailed FPRA quantification has 2 of ES-B1 reviews the importance of been completed in Task 14. using an iterative approach to validate Now that the FPRA model is the assumptions made in the initial complete the risk significance of review of components to include, excluded systems and Even though systems such as Main equipment has been addressed Feed / Condensate are not important in the uncertainty and sensitivity to the internal events model, they may analysis performed in Section 3 be important to specific Fire Areas of PRA Calculation F.3.15. once initial results are re-reviewed. Reference Section 7.7.1 .c and Section 3.2 for systems and During the 2010 peer review, the components considered. ES-B 1-02 (2008) was review and Add step to process to review the judged to meet at CC-Il, but assumptions and determine if systems replaced with the 2010 F&O
/components originally excluded due ES-BI-01 on the similar topic.
Page V-6
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d, .Iui . Ili f~lt~I, ,,,C.*llllL V -- ,I *fl r *fl* a i,cy cua,l Table V-2 FPRA Peer Review - Facts and Observations SR Topic F&O Level Status Finding Disposition Evaluate significance of not including recovery actions and equipment and include where appropriate. (Note: This F&O was generated during the January 2008 review). ES-Bi ES-B1-01 (2010), CC Finding Closed Calculation F.3.2 does not explicitly A sensitivity analysis was II, need to verify the include a step to review the performed and is documented in basis of excluding assumptions used to exclude Calculation F.3.15. Calculation low importance SSC components or systems that were F.3.2 provides a pointer to valid excluded to verify that these calculation F.3.15 for sensitivi * * - components can remain excluded studies.Chnet based on risk significance. The Calculation F.3.15 R 'eei- "evson2 DCPP response indicates that the uncertainty of excluded components now includes the results of a and systems is addressed in F.3.15. sensitivity study in which all systems which were assumed to A review of Calculation F.3.15 does be guaranteed failed and form not indicate any discussion of the part of the FPRA model, were uncertainty of the exclusion of restored to their random failure components or systems based on risk status. The overall fire Core significance under Section 3.3.2 of the Damage Frequency (CDF) calculation. reduced by 12% and the impact Basis for Significance: The iteration on Large Early Release to validate that the assumption to Frequency (LERF) was exclude components or systems insignificant. needs to be performed to ensure that the model is not excessively conservative to meet a Capability Category II. Possible Resolution: Perform a sensitivity analysis of components or systems that were excluded during Page V-B
Pacific Ga*and I*l*ctritz Comnanv AttRP.hm*_nt V -- Fir*_ PRA QuAlity Table V-2 FPRA Peer Review - Facts and Observations SR Topic F&O Level Status Finding Disposition wouid be preserved for 1(2)- 8804A/B and 0-FCV-601 after a stall event caused by the postulated fire scenario. CS-A6 CS-A6-01 (2008), Suggestion Closed A concern related to EDG availability - Scation 7.,.2 of Dccign Associated Circuit
'Common Enclosure DCP T), cumma;ize the-,commo daagether l a ffcted trans orme atr onclosuro analycic documented in Appendix I. Tho cummary of secondary-fire concern wsil.Thfe di nAssmoci Ci ated~n n~rjcAt levihew cacec analyzed. For the cace of the non cafety relatod bucce D &
E (both Unitc), the acceptance -Revise: criteria are nct met and thuc Section 7,4.2 of Design Calculation 90000041048 Revision 1 (Legacy No. 134ADC-T), conctituto common enclocuro -summarizes the common enclosure analysis documented in Appendix I. The summary of results accociated circuite. In Appendix found adequate cable protection for the credited electrical power system lineups with the Y of PRA. Calculation F.3.5, thc baco FPR'\ modeling impacte for -exception of two locations for unit 1. The analysis shows that two (2) unit 1 load cables for non- thic caco wcrc rc rcvicwcd and 2safety 4.16 kV bus D and two (2) unit 1 load cables for non-safety 4.16 kV bus E could pose ) documented. The review c*ommon enclosure concerns in Fire Areas 4-A and 5-A-4. Further scenario development for the concluded that nono of potontial common enclocuro aecociatod 2four (4)*potential common enclosure cables in unit 1 Fire Areas 4-A and 5-A-4 indicates that no circuite roculted in rick cignificant -credible fire in these locations will cause a secondary fire with the potential to damage Fire PRA econarioc. Thcroforc they were cables or equipment beyond that included in the Fire PRA circuit analysis and Fire PRA model. not modeled in the bace FPRA. secondary fire does not result in damage to credited SSD equipment. Page V-15
Pnr.ifir. G;A.q And E:l*_r.trir. C*nmnAnv Att~cehm*.nf V - Firn PRA Ou~ifvit Table V-2 FPRA Peer Review - Facts and Observations SR Topic F&O Level Status Finding Disposition FSS-C8 FSS-C8-01 (2008), Finding Closed Fire Wrap is not discussed in the Fire Fire Wrap information is NOT MET, treatment Area analysis performed for the PRA, available from the DCPP's of fire wrap and the technical justification for Cable/Raceway database (i.e., credited wrap is not provided as SetRoute Data) and PG&E required by FSSC8. Design Calculation 9000041072 Provide a description of when fire (Legacy No 134-DC-T) wrapwicrdtdalitoFieAas (Attachment Gieditia9 fire randi cmoenitsd w ist inFie eac Fire* Ara/ir scenrio s doumented in its risk enceto he tchncalmodeling workbook (AppendbcR justification for the fire wrap of Calculation F.3.5). The qualifications in the FPRA. surveillance test procedure, STP Additionally, provide documentation of M7D rvdsrqieet o and 2-EA-48568. Credited..." the wrap effectiveness, including the M7D rvdsrqieet o maintenance of the wrap (no visual inspection of wraps. mechanical damage) and the review The technical element FSS was of the wrap against direct flame reviewed completely during 2010 impingement from a high hazard review and no finding was ignition source. identified related FSS-C8. The (Note: This F&O was generated during the January 2008 review). aprevriewteam sumaraceized iitse f latr frepr rcegardingtheouFhScaseu "The DCPP FPRA has folowsidrto; appropriately characterized the fire scenarios through careful consideration of all factors related to fire scenario development and modeling. The scenarios provide a realistic measure of fire development and resultant fire damage. The resulting fire modeling provide for the ability to quantify risk-relevant fire scenarios. Fire Page V-44
AttF*t,,hmzsn{- Xl -- r";Pn DDA A.IQl;tI* I-{1.IIII f.coe alIU C-I~l Ian lJIrl
*...r. na ll f"lLtCIL.III,,CI V -- rllC r I--(,/' aL~dC*IILV Table V-2 FPRA Peer Review - Facts and Observations SR Topic F&O Level Status Finding Disposition UNC-AI UNC-A1 -01 (2008), Finding Closed The FPRA shall identify key sources NOT MET, of CDF and LERF uncertainties, have now been addressed in uncertainty analysis including key assumptions and not done, Associated modeling approximations. These SRs: UNC-A2, UNC- F.3.15 Rcision, 3 3 1 j uncertainties shall be characterized A3 such that their impacts on the results are understood. Uncertainty and sensitivity analysis have not completed yet. Items could not be verified for SRs UNC-AI, UNC-A2, and UNC-A3, therefore, assumed as not met.
Once the FPRA model becomes stable, perform the CDF and LERF uncertainties, including key assumptions and modeling approximations. (Note: This F&O was generated during the January 2008 review). UNC-Al UNC-A1-01 (2010), Suggestion Closed F&O: Section QU-E4 of Part 2 of the Specific impacts of uncertainties editorial changes to Combined Standard requires that for on modeling assumptions are Calculation F,3,15 each source of model uncertainty and identified in calculation file F.3.15, related assumption identified, Section 3.3.5, Items (i)thru (xix). IDENTIFY how the PRA model is affected (e.g., introduction of a new For example, basic event, changes to basic event
- 1) For 1D2.06 (Certain top events probabilities, change in success are assumed to fail) the top criterion, introduction of a new events assumed to fail are listed initiating event).
in calculation F.3.15, Section Basis for Significance: Required by 3.3.5 Items (v), vi, x etc.
- 2) For 1D5.06 (MSIVs will be Page V-I 00
Pacific Ga* nnd I*l*_r.frir_ CnmnRnv Affnrhm*=nt V Par~ifir~ c~And EIActrir~ CnmnRnv Aff~,i-hm~n* V -- I=irp PRA Firg~ PRA C31nnlltv
~
Table V-3 FPRA- Not Met, Not Reviewed, and Category I Summary SR Topic Status FQ-F1 Documentation of the CDF and LERF analyses has not Documentation of the fire-induced risk model is now Not Met(2008) documented consistent with thie applicable SRs. The complete, and provided in PG&E calculation F.3.5 (with quantification is in an early state, and meaningful associated appendices). Met(201 0) documentation cannot yet be accomplished. At the time of 2010 Peer Review, the final quantification was complete. EQ-Fl was re-reviewed in the 2010 peer review and was judged to be met with suggestion that has been closed. UNC-AI The FPRA shall identify key sources of CDF and LERE Uncertainty and Sensitivity issues have now been NtMt20) uncertainties, including key assumptions and modeling addressed in F.3.1 5 *eAie-. Ntet20) approximations. These uncertainties shall be ' Met(2010) characterized such that their impacts on the results areChnet understood. Uncertainty and sensitivity analysis have not "eiin2 completed yet. Items could not be verified for SRsUNC-Al, UNC-A2 and UNC-A3, therefore, assumed as not met. Once the FPRA model becomes stable, perform the ODE and LERE uncertainties, including key assumptions and modeling approximations. (Note: This F&O was generated during the January 2008 review). UNC-A2 The EPRA shall identify key sources of ODE and LERE Uncertainty and Sensitivity issues have now been NotMe(208) uncertainties, including key assumptions and modeling addressed in F.3.15Re4iR4vsc" . Ntet20) approximations. These uncertainties shall be \** hn*=t* " Met(2010) characterized such that their impacts on the results are "eiin2 understood. Uncertainty and sensitivity analysis have not completed yet. Items could not be verified for SRs UNC-Al, UNC-A2 and UNC-A3, therefore, assumed as not met. Page V-I134
PRr.ifir:. *_* :*nri I::l#rfri* (*.nmn:*nv A~ff~phmnt '\1 -- I:ira D:PA n=*it
- *v.,,v v*v *,,* =.*v*..v vv,,n* ,,l[ rtLLUVUIUII*,,nlt, V -- n nn** u u*u=t *l,*uunnLy Table V-3 FPRA- Not Met, Not Reviewed, and Category I Summary SR Topic Status Once the FPRA model becomes stable, perform the CDF and LERF uncertainties, including key assumptions and modeling approximations.
(Note: This F&O was generated during the January 2008 review). UNC-A3 The FPRA shall identify key sources of CDF and LERF Uncertainty and Sensitivity issues have now been Not Me(2008) uncertainties, including key assumptions and modeling addressed in F.3.15, Re'.'eiecn !. NtMt20) approximations. These uncertainties shall be
- Deleted from the characterized such that their impacts on the results are "eiin2 2009 Standard understood. Uncertainty and sensitivity analysis have not completed yet. Items could not be verified for SRs UNC-Al, UNC-A2 and UNC-A3, therefore, assumed as not met.
Once the FPRA model becomes stable, perform the CDF and LERF uncertainties, including key assumptions and modeling approximations. (Note: This F&O was generated during the January 2008 review). MU-A2 DCPP has an Administrative Procedure for Control of the PRA element MU and its SRs were re-reviewed in the 2010 No e(20) PRA, TS3.NRI. This procedure does not explicitly Peer Review and were judged to be met. Based on this, Noe(20) require monitoring changes in PRA technology and the 2008 finding MU-A1-01 is considered closed.. Met(2010) industry experience. DCPP Procedures AWP E-028 and TS3.NR1 will provide Update Section 5.1.3 of TS3.NRI to explicitly require the overall program of PRA model maintenance and monitoring/reviewing changes in PRA techrnology and upgrade: industry experience on an every other Unit 2 outage
*basis.
(Note: This F&O was generated during the January 2008 review).
~Page V-135
Enclosure 5 PG&E Letter DCL-13-065 List of Regulatory Commitments Commitment 1: (Section 5.4 of Transition Report) After the approval of the LAR, in accordance with 10 CFR 50.71(e), the DCPP UFSAR will be revised. The format and content will be consistent with NEI 04-02,* Revision 2, FAQ 12-0062. Commitment 2: (Section 5.5 of Transition Report) Implementation of the new NFPA 805 FP Program to include procedure changes, process updates, and training to affected plant personnel will occur 140-days after issuance of the license amendment (see Attachment S, TableS-) J Commitment 3: (Section 5.5 of Transition Report) day PG&E will complete modifications necessary to support the new FP licensing basis for transitioning to NFPA 805 by the end of the Units I and 2 Refueling Outages, currently scheduled for April/May 2017 (1R20) and February/March 2018 (2R20), respectively. Commitment 4: (Section 5.5 of Transition Report) Appropriate compensatory measures will be established per 0M8.1D2, "Fire System Impairment," and maintained until modifications are complete (see attachment S, Table S-2). Commitment 5: (Attachment S of Transition Report, Table S-3) Table S-3, Implementation Items, provided below are those items (procedure changes, process updates, and training to affected plant personnel)' that will be completed prior to the implementation of new NFPA 805 Fire Protection Program (FPP), as defined in Section 5.5 of this LAR.}}