Text

NFPA 805 Trip Report Handout References
	ML063310386
Person / Time
Site:	Harris
Issue date:	11/07/2006
From:	Ertman J, Gaffney P; Nuclear Generation Group, Progress Energy Co
To:	; Office of Nuclear Reactor Regulation
References
	Download: ML063310386 (392)
	v • d • e

NFPA 805 Pilot Observations Meeting Progress Energy Transition Status November 7, 2006 Jeff Ertman Paul Gaffney Page 1

PE NFPA 805 Transition Status Discussion Points O PE Objectives this meeting - Paul Gaffney O General project information O Harris transition plant status Page 2

PE NFPA 805 Transition Status Project Track Product Time Page 3

The Challenge Progress Energy Perspective O Open FAQs Z FAQ 4 - Clarification on Chapter 3 / 4 Linkage Z FAQ 8 - Evaluation Process Z FAQ 12 - Manual Action Clarification (free from fire damage)

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PE NFPA 805 Transition Status Pilot Meeting Objectives O Technical Presentations O Identify FAQs with near term Pilot impacts Z Review / establish schedule with NEI Task Force / NRC O Clear the Parking Lot Z Close items to FAQs where possible X Resolution schedule for the new FAQs Z Identify and schedule new items O Look ahead Z Next meeting specific date and scope Z Approximate meeting dates next 12 months X Dates and anticipated scopes Page 5

PE NFPA 805 Transition Status General Information - Overview Plan 2005 2006 2007 2008 2009 2010 2011 2012 Area Prepare Complete SSA Transition LAR Non-Power Submit Receive Receive Ops LAR RAIs LA FE & RR Upgrade PRA Implement Done Transition Report Amendment Harris Area Complete SSA Transition Prepare LAR Non-Power Submit Receive Receive Ops LAR RAIs LA FE & RR Upgrade PRA Implement Done Amendment Transition Report Crystal River Area Complete SSA Transition Prepare LAR Non-Power Submit Receive Receive Ops LAR RAIs LA FE & RR Upgrade PRA Implement Done Amendment Transition Report Robinson Area Complete SSA Transition Prepare LAR FE & RR Non-Power Submit Ops LAR Upgrade PRA Transition Report Brunswick Start Transition Page 6

PE NFPA 805 Transition Status General Information - Fleet Plan LARs O HNP LAR May 2008 O CR3 LAR August 2009 O RNP LAR August 2010 O BNP LAR August 2011 Page 7

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.d o .d o c u-tr a c k c u-tr a c k PE NFPA 805 Transition Status General Information -Organization

PE Fire Protection Initiatives Project with NFPA 805 Transition Classical Fire Protection/Program Transition (Typ)

Task 2.1.3 HNP Task 3.0 % Tasks 7.8 &

HNP Manual Radioactive 7.11 Fire Model Firefighting Release support C

Task 8.0 Start %Task 7.1/7.6 Task 2.1.1 Non Task 2.1.2 Tasl 2.2 HNP NFPA 805 Classical FP Support PRA FA Specific FA Specific Equivalency Change Work Data Gather Review Review Evaluations Evaluations Task 2.3.3 Task 2.3.1/2.3.2 Task 2.3.1/2.3.2 Task 10.0 Hemyc/ MT Hemyc/ MT Hemyc/ MT Transition GL response Test/Eval Test/Eval Report A

B Task 11.0/Task 12.0 NSPA (e.g. App R / SSA) and Circuit Analysis (Typ) LAR/RAIs Task 5.1 Task 5.2 Task 5.3 HNP BNP CR3 RNP Identify new Identify Input to Qualitative Components Pinch Points Outage Risk Review Task 13.0 NSPA/SSA/ Task 4.1.1 Task 4.1.6 Task 4.1.7 & Task 4.1.10 to Task 4.2 Task 4.3 Task 4.4 Task 4.5 NFPA 805 Circuit Analysis to 4.1.5 SSA Area 4.1.8 Manual 4.1.15 EC/ Fire Area Update SSA/ Update T-H Recovery Program Work Validation Analysis Actions Documentation Transtion App R Logic Analysis Actions Update Implementation

% Task 7.3 % Task 7.3 % Task Provide Provide 7.10 & 7. 4 Appendix R / SSA Input to PRA Input to PRA Support Validaiton per CLB D B

HNP Fire and Internal Events PRA (Typ) RNP Task 7.16 Fire PRA Documentation A Task 7.2 Task 7.10 Task 7.3 Task 7.10a CR3 Task 7.12 Component HNP Circuit Cable Selection Circuit Post-Fire Selection Analsys & Routing Analsys HRA Task 7.14 Task 7.14a Task 7.1 .Task 7.6 Task 7.4 Task 7.5 Task 7.8 Task 7.7 Task 7.11 Fire Risk Task 7.15 Start PRA Final Fire PRA Fire Ignit Qualitative Fire-Induced Scoping Fire Quanitative Detailed Quantification Uncertainty Work Fire Risk Partitioning Frequencies Screening PRA model HNP Modeling Screening Fire Models Evolving Sensitivity Model C Fire Model C

Task 6.1/6.2 Task 6.3 Task 6.3 Task 6.3 Internal events Gap Closure Gap Closure Gap Closure GAP Assessment Part 1 Part 2 Part 3 Task 6.x Updated Task 7.13 Internal Seismic-Fire Events model Interaction Data, Software, and Project Controls (Common Tasks for All Sites)

Task 6.4 Task 6.5 Update Start Establish Pre- Update Database Task 9.0 Project Peer Internal Events Common production to Receive Fire Stage Revision NGG and Site Closeout per Review Documentation Tasks Database Controls PRA data Post Transtion Documents PM-0018 Task 1 Task 14 D Gen Project CES Rolling Wave Initiation Project Planning CES Rev. 10/24/2006

Progress Energy NFPA 805 Transition Outlook 2007 Completion of Data Gathering Phase Initial Quantification / Change Evaluations Finalize LAR / Cleanup Program Implementation July/August 2007 Timeframe December 2007 Timeframe May 2008 May 2009 Task 2.1 & 2.2 / Chapter 3 Classical Task 10.0 / NFPA 805 Transition report Task 4.1 / Complete SSA Task 4.2 / Chapter 4 Fire Area Specific Final Iteration of Project Tasks Task 7.14 / Fire Scenario Quantification Task 4.2 / Chapter 4 non Fire Area Task 2.1 / Chapter 3 Fire Area specific Task 12 / RAI Responses Task 8.0 / NFPA 805 Change Evaluations Task 11.0 / LAR Task 7.3 & 7.10 / Circuit Analysis for Fire PRA Task 2.3 / Heymc & MT Wrap Task 9.0 / Post Transition Documentation Task 7.8, 7.11 / Scoping & Detailed Fire Modeling NRC Fire PRA Audit (Peer Review)

Tasks 7.12 / 4.5 HRA and Thermo - Hydraulics Task 7.5 / Fire Induced PRA Model / MSOs Task 7.16 Fire PRA Final Documentation Task 6 / Internal Events PRA HNP Task 13 / Program Implementation Task 7.6 / Fire Ignition Source Walkdowns (CR3) other early tasks CR3 Remaining Datagathering Tasks Robinson Fire Ignition Source Walkdowns and other early tasks Task 4.1 all Plants / Complete SSA Validation Brunswick Fire Ignition Source Walkdowns and other early tasks Harris Shown in Green Same General Approach all plants Rev Date November 3, Priority from NFPA 805 perspective is Harris 2006

Strawman Schedule 2007 NRC Harris Pilot Observation Reviews This is a Strawman to initiate discussion relative to 2007 observation meetings. Detail Review meeting under Type of Review is conceptually intended to be a small team from the NRC to focus on a narrow scope. There would be a minimal meeting preparation other than the products themselves. Results would be reported to the NEI task force at the next meeting/phone call. Duke representatives at the focused observation meetings are always welcome.

Pilot Meeting Date Topic Type of Review Plant Location Harris Harris Jan 15-17 Fire PRA Products Detail Review of Task 7.1 Plant Partitioning Products /

Task 7.6 Ignition Frequencies Calculations Task 7.2 Component Selection Harris Harris Jan 17-19 Classical Fire Protection Detail Review of Task 2.1.1 Chapter 3 Non Products /

Fire Area Transition Results Calculations Tasks 2.3.2 MT Wrap Barrier Worth Calculation Harris Harris Feb 26-28 Fire PRA Products Detail Review of Task 7.8 Scoping Products /

Task 7.11 Detailed Fire Calculations Modeling Harris Harris Feb 28- Classical Fire Protection Detail Review of March 2 Task 2.1.3 Manual Products /

Firefighting Calculations Tasks 3.0 Radioactive Release Task 2.2 Equivalency Evaluations Harris Harris April 9-10 Fire PRA Products Detail Review of Task 7.5 Fire Induced PRA Products /

model selected fire scenarios Results and Treatment of MSOs Harris Harris April 11- SSA / Electrical Detail Review of 13 Task 7.3/7.10 Circuit Products /

Analysis for PRA Calculations Task 5.3 Non-power operations review Task 4.2 Fire Area Transition selected results Harris Harris May 14-16 Fire PRA Products Detail Review of Task 7.12 Post Fire HRA Products /

Results Harris Harris May 16-18 SSA / Plant Systems Detail Review of Task 4.4 Update T-H Products /

Proposed Schedule 2007 NRC Harris Pilot a.doc Page 1 of 2

Strawman Schedule 2007 NRC Harris Pilot Observation Reviews Pilot Meeting Date Topic Type of Review Plant Location Analysis Calculations Task 4.5 Recovery Action Update Harris Harris July 9-11 Fire PRA Products Detail Review of Task 7.14 Fire Risk Products /

Quantification Selected Results Scenarios Harris Harris July 11-13 FP Program Detail Review of Task 8.0 Change Evaluations Products /

Selected Items / Scenarios Results Harris / Charlotte August 6-8 Combined meeting general Meeting Oconee / RII ? status, Additional review of Presentations Change Process, LAR content, etc.

Harris Harris Oct 15-19 NRC Fire PRA Audit Detail Review of Products /

Results Harris / Raleigh Nov 12-14 Combined meeting general Meeting Oconee /Charlotte status, methodologies, LAR Presentations

/ RII ? content, etc Proposed Schedule 2007 NRC Harris Pilot a.doc Page 2 of 2

Hemyc / MT Mike Fletcher Progress Energy

Hemyc / MT O MT 3 HR ERFBS Z HNP only user, 1250 ft installed Z Completed site specific fire testing Z Tested terminations, wall mounted configurations with site specific cable fills Z Working on a barrier worth calculation.

Z Based on testing appears all applications may be acceptable using performance based approach

Hemyc / MT Item Raceway / Fill % Rating (Minutes)

Configuration A 1-1/2 conduit free 21.5 134 air B 2-3 conduits free air 11.5 & 13.2 180 C 1-1/2 conduit free 21.5 115 air w/support (baseline)

D 1-1/2 conduit free 21.5 153 air w/support (upgrade)

E 2-1-1/2 conduits free 21.5 & 28.2 159 air F 2 Conduit wall 28.2 180 mounted G 18 X 18 X 13 J-Box n/a 163

Hemyc / MT O Hemyc 1 HR ERFBS Z 6500 ft installed Z Conducting 2 fire tests at Intertek Labs Z Multiple tray, multiple conduits, supports, terminations W/ plant specific cable fills Z Test 1- November 17th Z Test 2- December 14th

Item Raceway / Fill % Rating (Minutes)

Configuration A 1-1/2 conduit free 21.5 134 air B 2-3 conduits free air 11.5 & 13.2 180 C 1-1/2 conduit free 21.5 115 air w/support (baseline)

D 1-1/2 conduit free 21.5 153 air w/support (upgrade)

E 2-1-1/2 conduits free 21.5 & 28.2 159 air F 2 Conduit wall 28.2 180 mounted G 18 X 18 X 13 J-Box n/a 163

Duke Power NFPA-805 Transition Pilot Observation Project Status Oconee (ONS)

Harry Barrett November 7, 2006 1

Agenda Reconstitution Project Status NFPA-805 Project Status Fire PRA Status Duke 3-Site Transition Schedule Oconee Transition Schedule Near Term Tasks 2

Reconstitution Project Status ONS Units 2 & 3 /Common Reconstitution Analysis is complete Need to review Mods since analysis snapshot MNS is approximately 67% complete with expected completion date of April 2007 CNS is approximately 55% complete with expected completion date of June 2007 3

NFPA-805 Transition Status Fire Protection Program Fundamental Program Elements (Chapter 3)

Have completed Fire Hazards Analysis validation walkdowns Data currently under review Ignition Source walkdowns to be discussed later this week Chapter 3 element mapping into the NEI 04-02 Table B-1 is approximately 80% complete 4

NFPA-805 Transition Status Nuclear Safety Performance Criteria Transition (Chapter 4)

Have completed mapping Appendix R (NEI 00-01) methodology to NFPA-805 Alternate approach referenced in parking lot has been developed Information placed in Table B-2 is abbreviated for better clarity 5

NFPA-805 Transition Status - continued Nuclear Safety Performance Criteria Transition (Chapter 4) - continued Fire Area Assessment in progress for first fire area Working on Table B-3 for Fire Area BH12 Continuing to work on Recovery Action Feasibility Pilot of CAFTA EFW Logics completed Non-Power Operational Mode Transition Developed Philosophy and Methodology Finalized list of components for additional analysis Performed circuit analysis and cable routing on added components 6

Fire PRA Status Sub-Task 5.1 - Plant Boundary Definition and Partitioning In progress (incorporating lessons learned from Oct Pilot mtg)

Sub-Task 5.2 - Fire Ignition Frequencies In progress (incorporating lessons learned from Oct Pilot mtg)

Sub-Task 5.3 - Fire PRA Component Selection In progress Sub-Task 5.4 - Fire PRA Cable Selection In Progres Sub-Task 5.5 - Qualitative Screening Not going to perform Qualitative Screening (will quantify all Fire Compartments) 7

Fire PRA Status Sub-Task 5.6 - Fire-Induced Risk Model - to be discussed later this week Sub-Task 5.7 - Quantitative Screening Sub-Task 5.8 - Scoping Fire Modeling Sub-Task 5.9 - Detailed Circuit Failure Analysis (combined w/

5.10)

Sub-Task 5.10 - Circuit Failure Mode Likelihood Analysis Sub-Task 5.11 - Detailed Fire Modeling Sub-Task 5.12 - Post-Fire Human Reliability Analysis Sub-Task 5.13 - Seismic-Fire Interactions Assessment Sub-Task 5.14 - Fire Risk Quantification Sub-Task 5.15 - Uncertainty and Sensitivity Analysis Sub-Task 5.16 - Fire PRA Documentation 8

Armored Cable Fire Testing We have performed additional fire damage testing to more accurately determine spurious actuation probabilities for our armored cable Testing was performed at Intertek Testing Laboratories (Omega Point Labs) in Texas Test Plan was reviewed and commented on by NRC Testing was observed by NRC Testing Results 120V AC grounded control circuits are very robust - NO observed spurious actuations Ungrounded 120V AC and 125V DC control circuits exhibit hot short probabilities in the range of normal thermoset cables Unjacketed Armored Cable is not an effective approach to achieve no intervening combustibles 9

Duke 3-Site Transition Schedule ONS MNS CNS 2005 2006 2007 2008 2009 st nd rd st nd rd st nd rd st nd rd 1 2 3 4th 1 2 3 4th 1 2 3 4th 1 2 3 4th 1st 2nd 3rd ONS MNS CNS NRC NRC NRC Audit Audit Audit ONS Unit 0/2 ONS Unit 3 Reconstitution (Jun 05 - Oct 06)

ONS Transition to NFPA-805 (Mar 05 - Oct 07)

ONS Fire PRA (Jun 05 - May 07)

MNS Reconstitution (Feb 05 - Apr 07)

MNS Transition to NFPA-805 (Apr 06 - Dec 08)

MNS Fire PRA (Oct 06 - Mar 08)

CNS Reconstitution (Oct 05 - Jun 07)

CNS Transition to NFPA-805 (Jul 06 - Sept 09)

CNS Fire PRA (Jul 07 - Dec 08)

MNS and CNS Fire PRA Tasks have been extended by 6 months due to Peer Review MNS and CNS Transition have been extended 9 months beyond PRA to allow time for addressing major peer review issues and submittal of LAR 10

Oconee NFPA-805 Transition Schedule 11

Near Term Tasks (Next Six Months)

Chapter 4 Transition (Nuclear Safety Performance Criteria)

Chapter 3 Transition (Fundamental Fire Protection Program Elements)

Transient Analysis Manual Action Feasibility 12

FAQ 06-004, Clarifying the Relationship Between Chapter 3 & 4 of NFPA 805 and Defense-in-Depth Alan Holder, CES November 7, 2006 Page 1

FAQ 06-004, What it Asks z NEI 04-02 needs to be clearer on the relationship between NFPA 805 Chapter 3 and 4 requirements. There are a number of sections in Chapter 3 that are dependent upon the requirements for protection in Chapter 4 (e.g., Electrical Raceway Fire Barrier System (ERFBS), traditional fire barriers, suppression, and detection).

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FAQ 06-004, Where Were At z Concerns; If utilities could inadvertently remove Defense-in-Depth for systems under consideration based on risk alone.

Application of the determination process, (Flow charting the method of choice).

When/ Where does Defense-in-Depth and Safety Margin apply under NFPA 805?

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Protection Feature is Required for NFPA 805 Chapter 4 Compliance Page 4

Figure B-2, Process for Determining if an ERFBS is Required for NFPA 805 Chapter 4 Compliance Page 5

Figure B-3, Process for Determining if a Fire Barrier is Required for NFPA 805 Chapter 4 Compliance Page 6

Defense-in-Depth Strategy Applied via NFPA 805

The Defense-in-Depth requirement is satisfied when there is no substantial imbalance in:

Preventing fires from starting

Detecting fire quickly and extinguishing those that occur, thereby limiting damage

Providing adequate level of fire protection for structures, systems and components important to safety so that a fire that is not promptly extinguished will not prevent essential plant safety functions from being performed.

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Defense-in-Depth Strategy Applied via NFPA 805

For 805 plants, SSCs described in the third element of the DID trinity are equated to SSCs required to meet NFPA 805, Section 1.5.1, Nuclear Safety Performance Criteria.

In other words, Providing an adequate level of fire protection for SSCs which satisfy the Nuclear Safety Performance Criteria so that a fire that is not promptly extinguished, will not prevent essential plant safety functions from being performed.

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Defense-in-Depth Strategy Applied via NFPA 805 Further clarified in RIN 3150-AG48 (Statement of Considerations);

NFPA 805 does not supersede the requirements of GDC 3, 10CFR50.48(a), or 10CFR50.48(f). Those regulatory requirements continue to apply to licensees that adopt NFPA 805. However, under NFPA 805, the means by which GDC 3 or 10CFR50.48(a) requirements may be met is different than under 10CFR50.48(b).

Specifically, whereas GDC 3 refers to SSCs important to safety, NFPA 805 identifies fire protection systems and features required to meet the Chapter 1 performance criteria through the methodology in Chapter 4 of NFPA 805. Also, under NFPA 805, the 10CFR50.48(a)(2)(iii) requirement to limit fire damage to SSCs important to safety so that the capability to safely shut down the plant is ensured is satisfied by meeting the performance criteria in Section 1.5.1 of NFPA 805. The Section 1.5.1 criteria include provisions for ensuring that reactivity control, inventory and pressure control, decay heat removal, vital auxiliaries, and process monitoring are achieved and maintained.

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Defense-in-Depth Strategy Applied via NFPA 805 RIN 3150-AG48 continues; This methodology specifies a process to identify the fire protection systems and features required to achieve the nuclear safety performance criteria in Section 1.5.1 of NFPA 805. Once a determination has been made that a fire protection system or feature is required to achieve the performance criteria of Section 1.5.1, its design and qualification must meet any applicable requirements of NFPA 805, Chapter 3. Having identified the required fire protection systems and features, the licensee selects either a deterministic or performance-based approach to demonstrate that the performance criteria are satisfied. This process satisfies the GDC 3 requirement to design and locate SSCs important to safety to minimize the probability and effects of fires and explosions.

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Defense-in-Depth Strategy Applied via NFPA 805 Conversely; Once a determination has been made that a fire protection system or feature is not required to achieve the performance criteria of Section 1.5.1, its design and qualification is not required to meet any applicable requirements of NFPA 805, Chapter 3. As such those systems and features may be removed from further regulatory consideration.

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Defense-in-Depth Strategy Applied via NFPA 805 Examples of systems no longer applicable under NFPA 805;

Automatic Suppression Systems protecting SSCs (plant fire areas) with no redundant required equipment present.

Suppression Systems for existing non-safety HVAC charcoal filters, or Reactor Coolant Pumps.

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Defense-in-Depth Strategy Applied via NFPA 805 Considerations;

Some fire protection systems and features may become eligible for removal from further regulatory consideration.

Other standards may affect these systems, NEIL Insurance, state or local codes and regulations.

Any changes would be via the approved change process and applicable configuration management tools would be applied.

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Chapter 3 Transition Mike Fletcher, Shirelle Johnson Progress Energy

Chapter 3 Transition - Process O Completed First Pass through Chapter 3 Z Developed Project Instruction FPIP-0120 Z Used site experts Z Exposed the site team to the basic FP Program element requirements Z Used a Self Assessment type process

Chapter 3 Transition - Process O HNP started with well defined Fire Protection Program documentation including Z Fire Hazards Analysis Z FP Commitment database Z Design Basis Documents for fire barriers and FP systems Z NFPA Code comparison calculations for selected codes such as - 20, 24,13,15

Chapter 3 Transition - Process O Goal of first pass review to bin each of the requirements into one of the following categories Z Comply Z Complies with Clarification Z Complies via Previous Approval Z License Amendment Request Z Further Action Required

Chapter 3 Transition- Flow Chart Existing Fundamental Fire Protection Program and Design Element In the Compliance Basis In Basis Document column Enter Column provide: provide: Document any Open Complies* No additional Document References that Items found during in Compliance Statement clarification demonstrate compliance Review Column Meets the NFPA 805 Chapter 3 Requirement Yes Enter In the Compliance Basis In Basis Document column Complies with Column provide: provide: Document any Open Clarification Provide details on Document References that Items found during No in Compliance Statement clarification demonstrate compliance Review Column Enter In the Compliance Basis In Basis Document column NFPA 805 Yes Column provide verbatim provide:

Complies via Previous Document any Open Chapter 3 Requirement excerpt from: Licensing Document References Approval Items found during Has Submittal document Document References that in Compliance Statement Review Previous Approval Approval document demonstrate compliance Column No Can the Enter In Compliance Basis In Basis Document Requirement Yes Requirement evaluated column provide: column provide: Document any Open be evaluated as Adequate as Adequate Summary of bases for Document References Items found during via Engineering in Compliance Statement engineering evaluation that demonstrate Review Evaluation? Column compliance No In Compliance Basis In Basis Document Compliance Enter Column provide: column provide: Document any Open Indeterminate Further Action Required List of Actions to be Corrective Actions, as Items found during Further Action in Compliance Statement Taken appropriate Review required Column Document References Does Not Meet Chapter 3 nor is there Previous Approval Enter In Compliance Basis In Basis Document Choose License Amendment Column provide: column provide: Document any Open Is a License Amendment Summary of bases for Corrective Actions, as One Required Items found during Required? license amendment appropriate in Compliance Statement Review Column Document References

Chapter 3 Transition - Results O Spent approximately 200 man-hours O 82 paragraphs reviewed X Comply - 39 X Complies with clarification - 8 X Complies via previous approval - 11 X License Amendment Request - 3 X Further Action Required - 31 X N/A - Section 3.10 -Gaseous Systems O 17 paragraphs are new requirements O Used Table B-1 format from NEI 04-02

Chapter 3 Transition - Examples O Comply Z Verbatim compliance with program documentation with no other action required.

O Complies with Clarification Z Compliance meets the chapter 3 requirement but with minor clarification for items such as scope or to describe site specific condition

Chapter 3 Transition - Examples O Complies Via Previous Approval Z NRC approval for the existing plant condition is addressed by an SER.

O Further Action Required Z Used in cases where any other action is required such as revisions to site documents, NFPA Code comparisons, evaluation of existing 86-10 type documentation, and the sections that require Chapter 4 inputs.

Z These cases will be eventually be binned into one of the other categories

Chapter 3 Transition - Examples O LAR Z Used in cases where HNP does not comply with the requirement and the basis for acceptability will be documented and submitted for NRC approval as part of the LAR.

Chapter 3 Transition - Likely FAQ Items O Section 3.3.1.1- General Prevention Activities Z FAQ to clarify intent of the phrase familiarization with plant fire prevention procedures, fire reporting, and plant emergency alarms regarding scope of or depth of the training.

Z Clarify the intent is to provide training within the General Employee Orientation type process.

Chapter 3 Transition - Likely FAQ Items O In Chapter 3 various sections such as 3.3.1.2, define scope or applicability in terms such as plant or power block.

Z Clarify that when used the intent these terms is areas in which a fire could jeopardize the ability to meet the performance criteria described in section 1.5.1

Chapter 3 Transition - Likely FAQ Items O Section 3.3.1.2 Control of Combustible Materials part (6) Controls on use and storage of flammable gases shall be in accordance with applicable NFPA standards.

Z FAQ needed to specifically identify what the applicable codes are.

Chapter 3 Transition - Likely FAQ Items O Section 3.3.5.2 - Only metal tray and metal conduits shall be used for electrical raceways.

Thin wall metallic tubing shall not be used for power, instrumentation, or control cables.

Flexible metallic conduits shall only be used in short lengths to connect components.

Z FAQ needed to allow use of short cable drops.

Chapter 3 Transition - Likely FAQ Items O Section 3.3.5.3 - Electric Cable Construction Z FAQ to identify and approve typical cable testing methods used for non-IEEE cable.

Chapter 3 Transition - Likely FAQ Items O Section 3.3.8 Bulk Storage of Flammable and Combustible Liquids. 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.

Z FAQ needed to identify that DG Day tanks are acceptable.

Chapter 3 Transition - Likely FAQ Items O Section 3.3.11 - Electrical Equipment Z FAQ to define what is adequate clearance.

O Section 3.4.2.1- Fire Pre-plans.

Z FAQ needed to define the minimum acceptable pre-plan scope using existing guidance.

Chapter 3 Transition - Likely FAQ Items O Section 3.4.4 - Fire Fighting Equipment.

Z FAQ to clarify intent of this equipment shall conform with applicable NFPA codes statement.

X Fire fighting equipment shall be designed and purchased to NFPA code requirements. Care and maintenance does not have to be conducted per the applicable codes.

Chapter 3 Transition - Likely FAQ Items O Section 3.7 Fire Extinguishers.

Z FAQ to clarify intent of statement where provided.

Chapter 3 Transition - Code Evaluations O If NFPA Code compliance evaluations are conducted, if we are committed to specific code we will keep that code year of record.

Examples are X NFPA 30 - 1977, Flammable and Combustible Liquids X NFPA 20 - 1972, Centrifugal Fire Pumps X NFPA 24 - 1977, Outside Protection

Chapter 3 Transition - Code Evaluations O Where new codes are identified evaluations will use the latest code, examples include X NFPA 51- Oxygen-Fuel Gas Systems for Welding Cutting X NFPA 55 - Std for Storage Use and Handling Compressed Gasses.

X NFPA 51B - Std For Fire Prevention During Welding Cutting and Hot Work X NFPA 241 - Std for Safeguarding Construction, Alteration, and Demolition Operations appears to be NA.

Chapter 3 Transition - Fire Brigade O Transitioning to common NFPA 600 Compliant Fire Brigade / Training Program across PE fleet O Gap Analysis of applicable standards Z NFPA-805, Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants Z NFPA-600, Standard on Industrial Fire Brigades Z NFPA-1500, Standard on Fire Department Occupational Safety and Health Program Z NFPA-1403, Standard on Live Fire Training Evolutions

Chapter 3 Transition - Lessons Learned O Benefits Z Need for barriers on out side buildings is removed which allowed some deviations to be retired Z Clarify/simplify going forward licensing basis O Transitioning Existing Engineering Equivalency Evaluations Z Anticipate transitioning numerous engineering evaluations Z FAQ 06-0008 is the basis

I Information Use FIRE PROTECTION INITIATIVES PROJECT PROJECT INSTRUCTION FPIP-0120 NFPA 805 Chapter 3 Fundamental Transition REVISION 1A DRAFT Name Date Preparer:

Reviewer:

Project Manager:

FPIP-0120 Rev. 1A Page 1 of 98

TABLE OF CONTENTS SECTION PAGE TABLE OF CONTENTS ............................................................................................................. 2 1.0 PURPOSE ....................................................................................................................... 3

2.0 REFERENCES

................................................................................................................ 3 3.0 DEFINITIONS.................................................................................................................. 3 4.0 RESPONSIBILITIES........................................................................................................3 5.0 PREREQUISITES ........................................................................................................... 5 6.0 PRECAUTIONS AND LIMITATIONS............................................................................... 5 7.0 SPECIAL TOOLS AND EQUIPMENT ............................................................................. 5 8.0 ACCEPTANCE CRITERIA .............................................................................................. 5 9.0 INSTRUCTIONS.............................................................................................................. 5 9.1 General ................................................................................................................. 5 9.2 Documentation Requirements .............................................................................. 6 10.0 RECORDS....................................................................................................................... 8 ATTACHMENTS 1 Chapter 3 Compliance Review Flow Chart .............................................................1 Page 2 NFPA 805 Chapter 3 Fundamentals Transition Package ...................................77 Pages REVISION

SUMMARY

........................................................................................................... 118 FPIP-0120 Rev. 1A Page 2 of 98

1.0 PURPOSE The purpose of this project instruction is to provide instructions for site specific reviews associated with the Chapter 3 Fundamental Element / Minimum Design Requirement Transition Reviews, under the NGG Fire Protection Improvement Initiatives Project.

This project instruction is provided to ensure compliance with the requirements of NFPA 805, NEI 04-02 and Regulatory Guide 1.205.

This project instruction is intended for use under the Fire Protection Improvement Initiatives Project. When this project is complete, the calculation documentation developed as a result of the instruction will be included in the overall NGG Fire Protection Improvement Initiatives Project report and applicable licensing documentation.

2.0 REFERENCES

2.1 NGG Fire Protection Program Improvement Initiatives Project Plan 2.2 National Fire Protection Association (NFPA) Standard 805-2001, Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants 2.3 Nuclear Energy Institute (NEI) 04-02, Revision 1, Guidance for Implementing a Risk-Informed, Performance-Based Program Under 10CFR50.48(c) 2.4 Regulatory Guide 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants, May 2006 2.5 10CFR50, Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979 2.6 NUREG-0800, Standard Review Plan, Section 9.5.1 Fire Protection Program 2.7 EGR-NGGC-0017, Preparation and Control of Design Analysis and Calculations 2.8 FPIP-0100, Fire Protection Initiatives Project, Project Controls 3.0 DEFINITIONS 3.1 AHJ - Authority having jurisdiction. For the purposes of satisfying the nuclear safety requirements of NFPA 805, this is the NRC.

3.2 Other definitions shall be consistent with those found in section 1.6 of NFPA-805.

4.0 RESPONSIBILITIES FPIP-0120 Rev. 1A Page 3 of 98

4.1 CES Fire Protection Initiatives Project Manager 4.1.1 Review and approval of project procedures issued for use on the Fire Protection Initiatives Project.

4.1.2 Overall responsibility for ensuring that personnel assigned to prepare and review Project documents under their direct control have the required training and/or experience to perform the role to which they are assigned.

4.2 Site Fire Protection Initiative Project Manager 4.2.1 Ensuring that Fire Protection Program tasks and deliverables associated with their plant are performed in accordance with this procedure.

4.2.2 Participate in, or assign a designee, the review of fundamental fire protection program and design elements.

4.3 Assessment Panel Chairman 4.3.1 Preparing a review plan or agenda, and information package(s) that lists the potential fundamental fire protection program and design elements that will be reviewed. Distribute information to panel members.

4.3.2 Documenting (or assigning designee) review activities, to include recording of any meeting minutes as necessary, participants progress report and tie records for reviews, discussion of decisions reached, basis for decisions reached.

4.4 Assessment Panel Members 4.4.1 Reviews will be conducted in an assessment format, with individuals working on independent sections as best suited to their background (i.e.

FP, Training, OPS, Site Incident Commander (SIC), and RP) led by each sites Fire Protection Program Manager, with support from CES fire protection engineers.

4.4.2 Providing constructive input based on area of expertise, and maintaining objectivity to be able to challenge others (as necessary) so as to prevent group think.

4.4.3 Participate in the review of the fundamental fire protection program and design elements.

4.4.4 A punch-list, maintained by the Fire Protection Program Manager, will be used to update or revise procedures, documentation and provide ECs as required incorporating the results of the review.

5.0 PREREQUISITES N/A FPIP-0120 Rev. 1A Page 4 of 98

6.0 PRECAUTIONS AND LIMITATIONS N/A 7.0 SPECIAL TOOLS AND EQUIPMENT N/A 8.0 ACCEPTANCE CRITERIA N/A 9.0 INSTRUCTIONS 9.1 General The fire protection program elements listed in Chapter 3 of NFPA 805 are minimum design requirements and shall not be subject to the performance-based methods permitted elsewhere in the standard without submittal of a License Amendment Request.

Previously approved alternatives from the fundamental protection program attributes of this chapter by the AHJ take precedence over the requirements contained herein.

Using the Licensing Basis Documentation as it relates to the appropriate licensing documents, the transition team (reviewers) systematically steps through the requirements outlined in NFPA 805, Chapter 3. Each of the Chapter 3 Fundamental Elements is reviewed with the basis for compliance documented. Attachment 1 details the compliance review in flow chart format. The basis for compliance shall be either:

Literal Complies with the requirement as listed in NFPA 805, or;

Complies with Clarification, meets intent with simple clarifying statement or;

Complies via Previous Approval for an alternate means of compliance as documented in an NRC Safety Evaluation.

Fundamental elements that do not have one of these two methods of compliance demonstrated must either be brought into compliance or have NRC approval of the deviation as part of the NFPA 805 Transition approval.

Fire protection program features and systems associated with the pre-transitional licensing basis, although previously reviewed and approved by the NRC, may have been changed since initial NRC approval. Such changes are part of the Licensees approved Fire Protection Program if they have been made in accordance with the correct application of the guidelines of Generic Letter 86-10, and evaluated under the requirements of 10 CFR 50.59, or the fire protection standard license condition (Fire Protection Program Regulatory Reviews). The fire protection standard license condition allows changes to the approved fire protection program without prior approval of the Commission if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. Where the changes from the original NRC review and approval have been made appropriately using an approved change process, but do not meet NFPA 805 Chapter 3 requirements, the changes are FPIP-0120 Rev. 1A Page 5 of 98

considered an acceptable part of the Current License Basis (CLB). Licensees may rely on these changes to claim compliance but the NRC may inspect those changes and conclude that they do not comply with NFPA 805. However, they are not considered previously approved by the NRC for the purposes of superseding requirements in Chapter 3 and as such should be submitted to the NRC for approval as a license Comment [R/S1]: Jeff questioned amendment request. that this seems to be a conflict.

Pointed out that it is copied from NEI 04-02.

Comment [EK2]: This has always 9.2 Documentation Requirements been confusing - the way I understand this is.

If you had something that was The Chapter 3 Fundamental Transition Package should be documented using NEI previously approved. And you 02, Table B-1, as provided in template format (Attachment 2) as guidance. The changed that thing through the standard license condition review -

applicable document(s) which constitute the individual plants CLB (i.e. NUREG -0800, so it was no longer what the NRC 10CFR50, Appendix R) should be included in Attachment 2. This package will be in the approved. Then you cant claim previous approval - because form of data collected in calculation format using ENG-NGGC-0017 as a vehicle to technically it isnt what the NRC review and approve the data. If additional actions are identified during the reviews these approved - does that make sense?

should be put in punch-list fashion and tracked using an NTM. The completed calculation data and sign-off cover pages will become a portion of the final NFPA 805 Transition Report for each site.

The following types of information need to be documented to demonstrate the compliance status of the fundamental elements. If the plant is fully compliant, a general statement that the plant is compliant with the current requirement shall be provided.

Explicit NRC Approval These may be for items that are transitioning fully compliant as-is as well as those where the NRC has previously approved an alternative to meeting the requirement.

An excerpt of the previous plant commitment correspondence as well as the excerpt from the NRC Safety Evaluation Report that provided the formal approval.

Administrative Requirements These include such items as required procedures, control of combustibles and ignition sources, fire brigade requirements, etc.

Reference to the site or corporate procedure that provides the control required by the program. In general, the reference should be to the highest level document that satisfies the requirement. For example the requirement for ensuring the plant has procedures for inspection and maintenance of systems would reference the program procedure that establishes this requirement, rather than providing a list of all testing and inspection procedures.

System Related Requirements These include items such as water supply, automatic detection and suppression, manual suppression, fire extinguishers, and fire barriers. Note that only the suppression and FPIP-0120 Rev. 1A Page 6 of 98

detection systems required by Chapter 4 of NFPA 805 need to be transitioned in the new program.

For active systems (including extinguishers), a reference to the code compliance evaluation packages with a listing of evaluated deviations.

For passive systems, a reference to specifications, design documents or test reports that demonstrate compliance with the systems.

Note that specific care should be given to transitioning methodology and acceptance criteria, such that equivalency evaluations that are currently allowed continue to be allowed in the future.

NFPA Code Compliance Evaluations Each NFPA standard referenced by NFPA 805 shall be evaluated point by point and shall consider the following points.

Identify the applicable edition, code of record of the standard.

Identify the applicable sections of the standard Identify the deviations to the applicable sections and submit for NRC approval if required by the subject standard.

Note that NFPA standards not a part of the CLB, but contained in NFPA 805 may be disposition as guidance only, based on previous approval of the existing fundamental elements applicable to the standard. No code compliance evaluation would be necessary.

Evaluated Deviations These would include the various engineering equivalency evaluations (i.e. GL 86-10 evaluations).

A reference to the engineering equivalency evaluations that were used to evaluate the acceptability of the deviation.

For the purposes of the license amendment request, a copy of the evaluation will need to be provided to allow the NRC to determine the adequacy of the evaluation.

10.0 RECORDS N/A FPIP-0120 Rev. 1A Page 7 of 98 Page 1 of 1 Existing Fundamental Fire Protection Program and Design Element In the Compliance Basis In Basis Document column Enter Column provide: provide: Document any Open Complies* No additional Document References that Items found during in Compliance Statement clarification demonstrate compliance Review Column Meets the NFPA 805 Chapter 3 Requirement Yes Enter In the Compliance Basis In Basis Document column Complies with Column provide: provide: Document any Open Clarification Provide details on Document References that Items found during No in Compliance Statement clarification demonstrate compliance Review Column Enter In the Compliance Basis In Basis Document column NFPA 805 Yes Column provide verbatim provide:

Complies via Previous Document any Open Chapter 3 Requirement excerpt from: Licensing Document References Approval Items found during Has Submittal document Document References that in Compliance Statement Review Previous Approval Approval document demonstrate compliance Column No Can the Enter In Compliance Basis In Basis Document Requirement Yes Requirement evaluated column provide: column provide: Document any Open be evaluated as Adequate as Adequate Summary of bases for Document References Items found during via Engineering in Compliance Statement engineering evaluation that demonstrate Review Evaluation? Column compliance No In Compliance Basis In Basis Document Compliance Enter Column provide: column provide: Document any Open Indeterminate Further Action Required List of Actions to be Corrective Actions, as Items found during Further Action in Compliance Statement Taken appropriate Review required Column Document References Does Not Meet Chapter 3 nor is there Previous Approval Enter In Compliance Basis In Basis Document Choose License Amendment Column provide: column provide: Document any Open Is a License Amendment Summary of bases for Corrective Actions, as One Required Items found during Required? license amendment appropriate in Compliance Statement Review Column Document References FPIP-0120 Rev. 1A Page 8 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 3.1* General.

This chapter contains the fundamental elements of the fire protection program and specifies the minimum design requirements for fire protection systems and features. These fire protection program elements and minimum design requirements shall not be subject to the performance-based methods permitted elsewhere in this standard.

Previously approved alternatives from the fundamental protection program attributes of this chapter by the AHJ take precedence over the requirements contained herein.

3.2 Fire Protection Plan. I. AREAS OF REVIEW 3.2.1 Intent. The CMEB reviews the total fire A site-wide fire protection protection program described in plan shall be established. the applicant's Safety Analysis This plan shall document Report (SAR) with respect to the-management policy and criteria of Branch Technical program direction and shall Position CMEB 9.5-1 attached to define the responsibilities of this SRP section, specifically with those individuals responsible respect to the following:

FPIP-0120 Rev. 1A Page 9 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 for the plans 1. Overall fire protection program implementation. This section requirements, including the establishes the criteria for an degree of involvement and integrated combination of assigned responsibility of components, procedures, management; fire protection and personnel to implement administrative controls and quality all fire protection program assurance program; fire brigade activities. training activities and coordination with offsite fire fighting organizations, including their capability in assisting in the extinguishment of plant fires.

C.1.a Fire Protection Program (1) The fire protection program should be under the direction of an individual who has been delegated authority commensurate with the responsibilities of the position and who has available staff personnel knowledgeable in both fire protection and nuclear safety.

(2) The fire protection program should extend the concept of defense-in-depth to fire protection in fire areas important to safety, with the following objectives:

to prevent fires from starting;

to detect rapidly, control, and extinguish promptly those fires FPIP-0120 Rev. 1A Page 10 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 that do occur;

to provide protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by the fire suppression activities will not prevent the safe shutdown of the plant.

(3) Responsibility for the overall fire protection program should be assigned to a person who has management control over all organizations involved in fire protection activities. Formulation and assurance of program implementation may be delegated to a staff composed of personnel prepared by training and experience in fire protection and personnel prepared by training and experience in nuclear plant safety to provide a balanced approach in directing the fire protection program for the nuclear power plant.

The staff should be responsible for:

(a) Fire protection program requirements, including consideration of potential hazards FPIP-0120 Rev. 1A Page 11 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 associated with postulated fires, with knowledge of building layout and systems design.

(b) Post-fire shutdown capability.

(c) Design, maintenance, surveillance, and quality assurance of all fire protection features (e.g., detection systems, suppression systems, barriers, dampers, doors, penetration seals, and fire brigade equipment).

(d) Fire prevention activities (administrative controls and training).

(e) Fire brigade organization and training.

(f) Prefire planning.

3.2.2* Management Policy CMEB 9.5-1, NUREG 0800 does Direction and not specifically require the Responsibility. preparation of a policy document A policy document shall be to define management authority prepared that defines and responsibilities.

management authority and responsibilities and C.1.a Fire Protection Program establishes the general (3) Responsibility for the overall policy for the site fire fire protection program should be protection program.

assigned to a person who has management control over all FPIP-0120 Rev. 1A Page 12 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 organizations involved in fire protection activities. Formulation and assurance of program implementation may be delegated to a staff composed of personnel prepared by training and experience in fire protection and personnel prepared by training and experience in nuclear plant safety to provide a balanced approach in directing the fire protection program for the nuclear power plant.

The staff should be responsible for:

(a) Fire protection program requirements, including consideration of potential hazards associated with postulated fires, with knowledge of building layout and systems design.

(b) Post-fire shutdown capability.

(c) Design, maintenance, surveillance, and quality assurance of all fire protection features (e.g., detection systems, suppression systems, barriers, dampers, doors, penetration seals, and fire brigade equipment).

FPIP-0120 Rev. 1A Page 13 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 (d) Fire prevention activities (administrative controls and training).

(e) Fire brigade organization and training.

(f) Prefire planning.

3.2.2.1* C.1.a Fire Protection Program The policy document shall (1) The fire protection program designate the senior should be under the direction of management position with an individual who has been immediate authority and delegated authority responsibility for the fire commensurate with the protection program. responsibilities of the position and who has available staff personnel knowledgeable in both fire protection and nuclear safety.

(3) Responsibility for the overall fire protection program should be assigned to a person who has management control over all organizations involved in fire protection activities. Formulation and assurance of program implementation may be delegated to a staff composed of personnel prepared by training and experience in fire protection and personnel prepared by training and experience in nuclear plant safety to provide a balanced FPIP-0120 Rev. 1A Page 14 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 approach in directing the fire protection program for the nuclear power plant.

3.2.2.2* C.1.a Fire Protection Program The policy document shall (3) Formulation and assurance designate a position of program implementation may responsible for the daily be delegated to a staff composed administration and of personnel prepared by training coordination of the fire and experience in fire protection protection program and its and personnel prepared by implementation. training and experience in nuclear plant safety to provide a balanced approach in directing the fire protection program for the nuclear power plant.

The staff should be responsible for:

(a) Fire protection program requirements, including consideration of potential hazards associated with postulated fires, with knowledge of building layout and systems design.

(b) Post-fire shutdown capability.

(c) Design, maintenance, surveillance, and quality assurance of all fire protection features (e.g., detection systems, suppression systems, barriers, dampers, doors, penetration FPIP-0120 Rev. 1A Page 15 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 seals, and fire brigade equipment).

(d) Fire prevention activities (administrative controls and training).

(e) Fire brigade organization and training.

(f) Prefire planning.

3.2.2.3* No similar requirement in CMEB The policy document shall BTP 9.5-1, NUREG 0800.

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

3.2.2.4* No similar requirement in CMEB The policy document shall BTP 9.5-1, NUREG 0800.

identify the appropriate AHJ for the various areas of the fire protection program.

3.2.3* Procedures. 2. Administrative Controls Procedures shall be k. Successful fire protection FPIP-0120 Rev. 1A Page 16 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 established for requires testing and maintenance implementation of the fire of the fire protection equipment protection program. In and the emergency lighting and addition to procedures that communication. A test plan that could be required by other lists the individuals and their sections of the standard, the responsibilities in connection with procedures to accomplish routine tests and inspections of the following shall be the fire detection and protection established: systems should be developed.

(1)

Inspection, testing, and The test plan should contain the maintenance for fire types, frequency, and detailed protection systems and procedures for testing.

features credited by the fire Procedures should also contain protection program instructions on maintaining fire protection during those periods (2)

Compensatory actions when the fire protection system is implemented when fire impaired or during periods of plant protection systems and other maintenance, e.g., fire watches or systems credited by the fire temporary hose connections to protection program and this water systems.

standard cannot perform their intended function and j. Disarming of fire detection or limits on impairment duration fire suppression systems should be controlled by a permit system.

(3)

Reviews of fire Fire watches should be protection program established in areas where related performance and systems are so disarmed.

trends C.3 Fire Brigade (4) Reviews of physical plant modifications and procedure d. (7) Drills changes for impact on the (c) The drills should be fire protection program preplanned to establish the (5) Long-term maintenance training objectives of the drill and should be critiqued to determine FPIP-0120 Rev. 1A Page 17 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 and configuration of the fire how well the training objectives protection program have been met. Unannounced (6) Emergency response drills should be planned and procedures for the plant critiqued by members of the industrial fire brigade management staff responsible for plant safety and fire protection.

Performance deficiencies of a fire brigade or of individual fire brigade members should be remedied by scheduling additional training for the brigade or members.

C.2 Administrative Controls

o. Define the strategies for fighting fires in all safety-related areas and areas presenting a hazard to safety-related equipment.

3.3 Prevention. C.1.a Fire Protection Program A fire prevention program (2) The fire protection program with the goal of preventing a should extend the concept of fire from starting shall be defense-in-depth to fire protection established, documented, in fire areas important to safety, and implemented as part of with the following objectives:

the fire protection program.

to prevent fires from starting; The two basic components of the fire prevention

to detect rapidly, control, and program shall consist of both extinguish promptly those fires of the following: that do occur; (1) Prevention of fires and

to provide protection for fire spread by controls on structures, systems, and components important to safety FPIP-0120 Rev. 1A Page 18 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 operational activities so that a fire that is not promptly (2) Design controls that extinguished by the fire restrict the use of suppression activities will not combustible materials prevent the safe shutdown of the plant.

The design control requirements listed in the (3) Responsibility for the overall remainder of this section fire protection program should be shall be provided as assigned to a person who has described. management control over all organizations involved in fire protection activities.

Formulation and assurance of program implementation may be delegated to a staff composed of personnel prepared by training and experience in fire protection and personnel prepared by training and experience in nuclear plant safety to provide a balanced approach in directing the fire protection program for the nuclear power plant.

The staff should be responsible for:

(d) Fire prevention activities (administrative controls and training).

(4) The organizational responsibilities and lines of communication pertaining to fire FPIP-0120 Rev. 1A Page 19 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 protection should be defined between the various positions through the use of organizational charts and functional descriptions of each position's responsibilities.

The following positions/organizations should be designated:

(d) The onsite position(s) which:

i. Implements periodic inspections to: minimize the amount of combustibles in safety-related areas; determine the effectiveness of housekeeping practices; assure the availability and acceptable condition of all fire protection systems/equipment, emergency breathing apparatus, emergency lighting, communication equipment, fire stops, penetration seals, and fire retardant coatings; and assures the prompt and effective corrective actions are taken to correct conditions adverse to fire protection and preclude their recurrence.

iv. Reviews and evaluates proposed work activities to identify potential transient fire loads.

FPIP-0120 Rev. 1A Page 20 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 3.3.1 Fire Prevention for Operational Activities.

The fire prevention program activities shall consist of the necessary elements to address the control of ignition sources and the use of transient combustible materials during all aspects of plant operations. The fire prevention program shall focus on the human and programmatic elements necessary to prevent fires from starting or, should a fire start, to keep the fire as small as possible.

3.3.1.1 General Fire 1. Fire Protection Program Prevention Activities. Requirements The fire prevention activities C.1.a Fire Protection Program shall include but not be 4) (d) The onsite position(s) limited to the following which:

program elements:

i. Implements periodic inspections (1) Training on fire safety to: minimize the amount of information for all employees combustibles in safety-related and contractors including, as areas; determine the a minimum, familiarization effectiveness of housekeeping with plant fire prevention practices; assure the availability procedures, fire reporting, and acceptable condition of all fire and plant emergency alarms protection systems/equipment, (2)

Documented plant emergency breathing apparatus, FPIP-0120 Rev. 1A Page 21 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 inspections including emergency lighting, provisions for corrective communication equipment, fire actions for conditions where stops, penetration seals, and fire unanalyzed fire hazards are retardant coatings; and assures identified the prompt and effective (3)

Administrative controls corrective actions are taken to addressing the review of correct conditions adverse to fire plant modifications and protection and preclude their maintenance to ensure that recurrence.

both fire hazards and the iv. Reviews and evaluates impact on plant fire proposed work activities to identify protection systems and potential transient fire loads.

features are minimized. v. Implements a program for indoctrination of all plant contractor personnel in appropriate administrative procedures which implement the fire protection program, and the emergency procedures relative to fire protection.

3.3.1.2* Control of C.1.a Fire Protection Program Combustible Materials. 4) (d) The onsite position(s)

Procedures for the control of which:

general housekeeping i. Implements periodic inspections practices and the control of to: minimize the amount of transient combustibles shall combustibles in safety-related be developed and areas; determine the implemented. These effectiveness of housekeeping procedures shall include but practices; assure the availability not be limited to the following and acceptable condition of all fire program elements: protection systems/equipment, FPIP-0120 Rev. 1A Page 22 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 (1)

Wood used within the emergency breathing apparatus, power block shall be listed emergency lighting, pressure-impregnated or communication equipment, fire coated with a listed fire- stops, penetration seals, and fire retardant application. retardant coatings; and assures Exception: Cribbing timbers the prompt and effective 6 in. by 6 in. (15.2 cm by corrective actions are taken to 15.2 cm) or larger shall not correct conditions adverse to fire be required to be fire- protection and preclude their retardant treated. recurrence.

(2) Plastic sheeting materials C.2 Administrative Controls used in the power block shall Administrative controls should be be fire-retardant types that used to maintain the performance have passed NFPA 701, of the fire protection system and Standard Methods of Fire personnel. These controls should Tests for Flame Propagation establish procedures to:

of Textiles and Films, large- a. Prohibit bulk storage of scale tests, or equivalent. combustible materials inside or (3) Waste, debris, scrap, adjacent to safety-related packing materials, or other buildings or systems during combustibles shall be operation or maintenance periods.

removed from an area Regulatory Guide 1.39 provides immediately following the guidance on housekeeping, completion of work or at the including the disposal of end of the shift, whichever combustible materials.

comes first. b. Govern the handling and (4)

Combustible storage or limitation of the use of ordinary staging areas shall be combustible materials, designated, and limits shall combustible and flammable gases be established on the types and liquids, high efficiency and quantities of stored particulate air and charcoal filters, dry ion exchange resins, or other FPIP-0120 Rev. 1A Page 23 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 materials. combustible supplies in safety-(5)

Controls on use and related areas.

storage of flammable and c. Govern the handling of and limit combustible liquids shall be transient fire loads such as in accordance with NFPA 30, combustible and flammable Flammable and Combustible liquids, wood and plastic products, Liquids Code, or other or other combustible materials in applicable NFPA standards. buildings containing safety-related (6)

Controls on use and systems or equipment during all storage of flammable gases phases of operating, and shall be in accordance with especially during maintenance, applicable NFPA standards. modification, or refueling operations.

d. Designate the onsite staff member responsible for the in plant fire protection review of proposed work activities to identify potential transient fire hazards and specify required additional fire protection in the work activity procedure.

f. Control the removal from the area of all waste, debris, scrap, oil spills, or other combustibles resulting from the work activity immediately following completion of the activity, or at the end of each work shift, whichever comes first.

h. Maintain the periodic housekeeping inspections to ensure continued compliance with FPIP-0120 Rev. 1A Page 24 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 these administrative controls.

i. Control the use of specific combustibles in safety-related areas. All wood used in safety-related areas during maintenance, modification, or refueling operation (such as lay-down blocks or scaffolding) should be treated with a flame retardant.

Equipment or supplies (such as new fuel) shipped in untreated combustible packing containers may be unpacked in safety-related areas if required for valid operating reasons. However, all combustible materials should be removed from the area immediately following unpacking.

Such transient combustible material, unless stored in approved containers, should not be left unattended during lunch breaks, shift changes, or other similar periods. Loose combustible packing material such as wood or paper excelsior, or polyethylene sheeting should be placed in metal containers with tight-fitting self-closing metal covers.

C.5.d. Control of Combustibles (3) The use of plastic materials FPIP-0120 Rev. 1A Page 25 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 should be minimized. In particular, halogenated plastics such as polyvinyl chloride (PVC) and neoprene should be used only when substitute noncombustible materials are not available. All plastic materials, including flame and fire retardant materials, will burn with an intensity and BTU production in a range similar to that of ordinary hydrocarbons.

When burning, they produce heavy smoke that obscures visibility and can plug air filters, especially charcoal and HEPA.

The halogenated plastics also release free chlorine and hydrogen chloride when burning which are toxic to humans and corrosive to equipment.

(4) Storage of flammable liquids should, as a minimum, comply with the requirements of NFPA 30, "Flammable and Combustible Liquids Code.

REFERENCES Regulatory Guide 1.39, "Housekeeping Requirements for Water-Cooled Nuclear Power Plants.

FPIP-0120 Rev. 1A Page 26 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 3.3.1.3 Control of Ignition 2. Administrative Controls Sources. e. Govern the use of ignition 3.3.1.3.1* sources by use of a flame permit A hot work safety procedure system to control welding, flame shall be developed, cutting, brazing, or soldering implemented, and operations. A separate permit periodically updated as should be issued for each area necessary in accordance where work is to be done. If work with NFPA 51B, Standard for continues over more than one Fire Prevention During shift, the permit should be valid for Welding, Cutting, and Other not more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the Hot Work, and NFPA 241, plant is operating or for the Standard for Safeguarding duration of a particular job during Construction, Alteration, and plant shutdown.

Demolition Operations.

3.3.1.3.2 2. Administrative Controls Smoking and other possible e. Govern the use of ignition sources of ignition shall be sources by use of a flame permit restricted to properly system to control welding, flame designated and supervised cutting, brazing, or soldering safe areas of the plant. operations. A separate permit should be issued for each area where work is to be done. If work continues over more than one shift, the permit should be valid for not more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the plant is operating or for the duration of a particular job during plant shutdown.

FPIP-0120 Rev. 1A Page 27 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 3.3.1.3.3 2. Administrative Controls Open flames or combustion- g. Govern leak testing; similar generated smoke shall not procedures such as airflow be permitted for leak or air determination should use one of flow testing. the commercially available techniques. Open flames or combustion-generated smoke should not be permitted.

3.3.1.3.4* No similar requirement in CMEB Plant administrative BTP 9.5-1, NUREG 0800.

procedure shall control the use of portable electrical heaters in the plant. Portable fuel-fired heaters shall not be permitted in plant areas containing equipment important to nuclear safety or where there is a potential for radiological releases resulting from a fire.

3.3.2 Structural. 5.a Building Design Walls, floors, and (9) Interior wall and structural components required to components, thermal insulation maintain structural integrity materials, radiation shielding shall be of noncombustible materials, and soundproofing construction, as defined in should be noncombustible.

NFPA 220, Standard on Types of Building Construction.

3.3.3 Interior Finishes. 5.a Building Design FPIP-0120 Rev. 1A Page 28 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 Interior wall or ceiling finish (9) Interior wall and structural classification shall be in components, thermal insulation accordance with NFPA materials, radiation shielding 101, Life Safety Code, materials, and soundproofing requirements for Class A should be noncombustible.

materials. Interior floor Interior finishes should be non-finishes shall be in combustible.

accordance with NFPA 101 Materials that are acceptable for requirements for Class I use as interior finish without interior floor finishes. evidence of test and listing by a nationally recognized laboratory are the following:

Plaster, acoustic plaster, gypsum plasterboard (gypsum wallboard), either plain, wallpapered, or painted with oil- or water-base paint;

Ceramic tile, ceramic panels;

Glass, glass blocks;

Brick, stone, concrete blocks, plain or painted;

Steel and aluminum panels, plain, painted, or enameled;

Vinyl tile, vinyl-asbestos tile, linoleum, or asphalt tile on concrete floors.

3.3.4 Insulation Materials. 5.a Building Design Thermal insulation materials, (9) Interior wall and structural radiation shielding materials, components, thermal insulation FPIP-0120 Rev. 1A Page 29 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 ventilation duct materials, materials, radiation shielding and soundproofing materials materials, and soundproofing shall be noncombustible or should be noncombustible.

limited combustible. Interior finishes should be non-combustible.

Materials that are acceptable for use as interior finish without evidence of test and listing by a nationally recognized laboratory are the following:

Plaster, acoustic plaster, gypsum plasterboard (gypsum wallboard), either plain, wallpapered, or painted with oil- or water-base paint;

Ceramic tile, ceramic panels;

Glass, glass blocks;

Brick, stone, concrete blocks, plain or painted;

Steel and aluminum panels, plain, painted, or enameled;

Vinyl tile, vinyl-asbestos tile, linoleum, or asphalt tile on concrete floors.

3.3.5 Electrical. 5.a Building Design 3.3.5.1 (11) Suspended ceiling and their Wiring above suspended supports should be of ceiling shall be kept to a noncombustible construction.

Concealed spaces should be FPIP-0120 Rev. 1A Page 30 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 minimum. Where installed, devoid of combustibles except as electrical wiring shall be noted in Position C.6.b.

listed for plenum use, routed 7.b Control Room Complex in armored cable, routed in All cables that enter the control metallic conduit, or routed in room should terminate in the cable trays with solid metal control room. That is, no cabling top and bottom covers.

should be routed through the control room from one area to another. Cables in underfloor and ceiling spaces should meet the separation criteria necessary for fire protection.

Air-handling functions should be ducted separately from cable runs in such spaces; i.e., if cables are routed in underfloor or ceiling spaces, theses spaces should not be used as air plenums for ventilation of the control room.

Fully enclosed electrical raceways located in such underfloor and ceiling spaces, if over 1 square foot in cross-sectional area, should have automatic fire suppression inside. Area automatic fire suppression should be provided for underfloor and ceiling spaces if used for cable runs unless all cable is run in 4-inch or smaller steel conduit or the cables are in fully enclosed FPIP-0120 Rev. 1A Page 31 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 raceways internally protected by automatic fire suppression.

3.3.5.2 5.e Electrical Cable Only metal tray and metal Construction, Cable Trays, and conduits shall be used for Cable Penetrations electrical raceways. Thin wall (1) Only metal should be used for metallic tubing shall not be cable trays. Only metallic tubing used for power, should be used for conduit. Thin-instrumentation, or control wall metallic tubing should not be cables. Flexible metallic used. Flexible metallic tubing conduits shall only be used should only be used in short in short lengths to connect lengths to connect components to components. equipment. Other raceways should be made of noncombustible material.

3.3.5.3* 5.e Electrical Cable Electric cable construction Construction, Cable Trays, and shall comply with a flame Cable Penetrations propagation test as (3) Electric cable construction acceptable to the AHJ. should, as a minimum, pass the flame test in the current IEEE Std 383. (This does not imply that cables passing this test will not require fire protection.)

3.3.6 Roofs. 5.a Building Design Metal roof deck construction (10) Metal deck roof construction shall be designed and should be noncombustible and installed so the roofing listed as "acceptable for fire" in system will not sustain a self- the UL Building Materials FPIP-0120 Rev. 1A Page 32 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 propagating fire on the Directory, or listed as Class I in underside of the deck when the Factory Mutual System the deck is heated by a fire Approval Guide.

inside the building. Roof coverings shall be Class A as determined by tests described in NFPA 256, Standard Methods of Fire Tests of Roof Coverings.

3.3.7 Bulk Flammable Gas 5.d Control of Combustibles Storage. (2) Bulk gas storage (either Bulk compressed or compressed or cryogenic), should cryogenic flammable gas not be permitted inside structures storage shall not be housing safety-related equipment.

permitted inside structures housing systems, equipment, or components important to nuclear safety.

3.3.7.1 5.d Control of Combustibles Storage of flammable gas (2) Storage of flammable gas shall be located outdoors, or such as hydrogen should be in separate detached located outdoors or in separate buildings, so that a fire or detached buildings so that a fire explosion will not adversely or explosion will not adversely impact systems, equipment, affect any safety-related systems or components important to or equipment. (Refer to NFPA nuclear safety. NFPA 50A, 50A, "Gaseous Hydrogen Standard for Gaseous Systems.")

Hydrogen Systems at Consumer Sites, shall be followed for hydrogen FPIP-0120 Rev. 1A Page 33 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 storage.

3.3.7.2 5.d Control of Combustibles Outdoor high-pressure (2) Care should be taken to locate flammable gas storage high pressure gas storage containers shall be located containers with the long axis so that the long axis is not parallel to building walls. This will pointed at buildings. minimize the possibility of wall penetration in the event of a container failure. Use of compressed gases (especially flammable and fuel gases) inside buildings should be controlled.

(Refer to NFPA 6, "Industrial Fire Loss Prevention.")

3.3.7.3 No similar requirement in CMEB Flammable gas storage BTP 9.5-1, NUREG 0800.

cylinders not required for normal operation shall be isolated from the system.

3.3.8 Bulk Storage of 2. Administrative Controls Flammable and Administrative controls should be Combustible Liquids. used to maintain the performance Bulk storage of flammable of the fire protection system and and combustible liquids shall personnel. These controls should not be permitted inside establish procedures to:

structures containing a. Prohibit bulk storage of systems, equipment, or combustible materials inside or components important to adjacent to safety-related nuclear safety. As a buildings or systems during minimum, storage and use operation or maintenance periods.

FPIP-0120 Rev. 1A Page 34 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 shall comply with NFPA 30, Regulatory Guide 1.39 provides Flammable and Combustible guidance on housekeeping, Liquids Code. including the disposal of combustible materials.

5.d Control of Combustibles (4) Storage of flammable liquids should, as a minimum, comply with the requirements of NFPA 30, "Flammable and Combustible Liquids Code.

7.j Diesel Fuel Oil Storage Areas Diesel fuel oil tanks with a capacity greater than 1,100 gallons should not be located inside buildings containing safety-related equipment. If above-ground tanks are used, they should be located at least 50 feet from any building containing safety-related equipment or, if located within 50 feet, they should be housed in a separate building with construction having a minimum fire resistance rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . Potential oil spills should be confined or directed away from buildings containing safety-related equipment. Totally buried tanks are acceptable outside or under buildings (see NFPA 30, "Flammable and Combustible FPIP-0120 Rev. 1A Page 35 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 Liquids Code," for additional guidance).

3.3.9* Transformers. No similar requirement in CMEB Where provided, transformer BTP 9.5-1, NUREG 0800.

oil collection basins and drain paths shall be periodically inspected to ensure that they are free of debris and capable of performing their design function.

3.3.10* Hot Pipes and 2. Administrative Controls Surfaces. f. Control the removal from the Combustible liquids, area of all waste, debris, scrap, oil including high flashpoint spills, or other combustibles lubricating oils, shall be kept resulting from the work activity from coming in contact with immediately following completion hot pipes and surfaces, of the activity, or at the end of including insulated pipes and each work shift, whichever comes surfaces. Administrative first.

controls shall require the prompt cleanup of oil on insulation.

3.3.11 Electrical Equipment No similar requirement in CMEB Adequate clearance, free of BTP 9.5-1, NUREG 0800.

combustible material, shall be maintained around energized electrical equipment.

FPIP-0120 Rev. 1A Page 36 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 3.3.12* Reactor Coolant 5.d Control of Combustibles Pumps. (1) Safety-related systems should For facilities with non-inerted be isolated or separated from containments, reactor combustible materials. When this coolant pumps with an is not possible because of the external lubrication system nature of the safety system or the shall be provided with an oil combustible material, special collection system. The oil protection should be provided to collection system shall be prevent a fire from defeating the designed and installed such safety system function. Such that leakage from the oil protection may involve a system is safely contained combination of automatic fire for off normal conditions suppression, and construction such as accident conditions capable of withstanding and or earthquakes. All of the containing a fire that consumes all following shall apply. combustibles present. Examples (1) The oil collection system of such combustible materials that for each reactor coolant may not be separable from the pump shall be capable of remainder of its system are:

collecting lubricating oil from (a) Emergency diesel generator all potential pressurized and fuel oil day tanks.

nonpressurized leakage sites (b) Turbine-generator oil and in each reactor coolant pump hydraulic control fluid systems.

oil system.

(c) Reactor coolant pump lube oil (2) Leakage shall be system.

collected and drained to a 7.a Primary and Secondary vented closed container that Containment can hold the inventory of the reactor coolant pump 1. (e) The reactor coolant pumps lubricating oil system. should be equipped with an oil collection system if the (3) A flame arrestor is containment is not inerted during FPIP-0120 Rev. 1A Page 37 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 required in the vent if the normal operation. The oil flash point characteristics of collection system should be so the oil present the hazard of designed, engineered, and a fire flashback. installed that failure will not lead to (4) Leakage points on a fire during normal or design basis reactor coolant pump motor accident conditions and that there to be protected shall include is reasonable assurance that the but not be limited to the lift system will withstand the safe pump and piping, overflow shutdown earthquake.

lines, oil cooler, oil fill and drain lines and plugs, Such collection systems should flanged connections on oil be capable of collecting lube oil lines, and the oil reservoirs, from all potential pressurized and where such features exist on unpressurized leakage sites in the the reactor coolant pumps. reactor coolant pump lube oil (5) The collection basin drain systems. Leakage should be line to the collection tank collected and drained to a vented shall be large enough to closed container that can hold the accommodate the largest entire lube oil system inventory. A potential oil leak such that oil flame arrester is required in the leakage does not overflow vent if the flash point the basin. characteristics of the oil present the hazard of fire flashback.

Leakage points to be protected should include lift pump and piping overflow lines, lube oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and lube oil reservoirs where such features exist on the reactor coolant pumps. The drain line should be large enough to FPIP-0120 Rev. 1A Page 38 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 accommodate the largest potential oil leak.

3.4 Industrial Fire Brigade. No similar requirement in CMEB 3.4.1 On-Site Fire-Fighting BTP 9.5-1, NUREG 0800.

Capability.

All of the following requirements shall apply.

(a) A fully staffed, trained, and equipped fire-fighting force shall be available at all times to control and extinguish all fires on site.

This force shall have a minimum complement of five persons on duty and shall conform with the following NFPA standards as applicable:

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

(2) NFPA 1500, Standard on Fire Department Occupational Safety and Health Program (3) NFPA 1582, Standard on Medical Requirements for Fire Fighters and Information FPIP-0120 Rev. 1A Page 39 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 for Fire Department Physicians (b)

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

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

(d)

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

(e) Each industrial fire brigade member shall pass an annual physical FPIP-0120 Rev. 1A Page 40 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 examination to determine that he or she can perform the strenuous activity required during manual fire-fighting operations. The physical examination shall determine the ability of each member to use respiratory protection equipment.

3.4.2* Pre-Fire Plans. C.1.a Fire Protection Program Current and detailed pre-fire (6) The following NFPA plans shall be available to publications should be used for the industrial fire brigade for guidance to develop the fire all areas in which a fire could protection program:

jeopardize the ability to meet No. 4 - "Organization for Fire the performance criteria Services

described in Section 1.5.

No. 4A - "Organization of a Fire Department

No. 6 - Industrial Fire Loss Prevention

No. 7 - Management of Fire Emergencies

No. 8 - Management Responsibilities for Effects of Fire on Operations

No. 27 - "Private Fire Brigades

C.2 Administrative Controls

n. Control actions to be taken by the fire brigade after notification by the control room operator of a FPIP-0120 Rev. 1A Page 41 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 fire, for example, assembling in a designated location, receiving directions from the fire brigade leader, and discharging specific fire fighting responsibilities, including selection and transportation of fire fighting equipment to fire location, selection of protective equipment, operating instructions for use of fire suppression systems, and use of preplanned strategies for fighting fires in specific areas.

3.4.2.1* C.2 Administrative Controls The plans shall detail the fire o. Define the strategies for area configuration and fire fighting fires in all safety-related hazards to be encountered in areas and areas presenting a the fire area, along with any hazard to safety-related nuclear safety components equipment. These strategies and fire protection systems should designate:

and features that are (1) Fire hazards in each area present. covered by the specific prefire plans.

(2) Fire extinguishants best suited for controlling the fires associated with the fire hazards in that area and the nearest location of these extinguishants.

(3) Most favorable direction from which to attack a fire in each area in view of the ventilation direction, FPIP-0120 Rev. 1A Page 42 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 access hallways, stairs, and doors that are most likely to be free of fire, and the best station or elevation for fighting the fire. All access and egress routes that involve locked doors should be specifically identified in the procedure with the appropriate precautions and methods for access specified.

(4) Plant systems that should be managed to reduce the damage potential during a local fire and the location of local and remote controls for such management (e.g., any hydraulic or electrical systems in the zone covered by the specific fire fighting procedure that could increase the hazards in the area because of overpressurization or electrical hazards).

(5) Vital heat-sensitive system components that need to be kept cool while fighting a local fire.

Particularly hazardous combustibles that need cooling should be designated.

(6) Organization of fire fighting brigades and the assignment of special duties according to job title so that all fire fighting functions FPIP-0120 Rev. 1A Page 43 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 are covered by any complete shift personnel complement. These duties include command control of the brigade, transporting fire suppression and support equipment to the fire scenes, applying the extinguishant to the fire, communication with the control room, and coordination with outside fire departments.

(7) Potential radiological and toxic hazards in fire zones.

(8) Ventilation system operation that ensures desired plant air distribution when the ventilation flow is modified for fire containment or smoke clearing operation.

(9) Operations requiring control room and shift engineer coordination or authorization.

(10) Instructions for plant operators and general plant personnel during fire.

3.4.2.2 No similar requirement in CMEB Pre-fire plans shall be BTP 9.5-1, NUREG 0800.

reviewed and updated as necessary.

3.4.2.3* No similar requirement in CMEB Pre-fire plans shall be BTP 9.5-1, NUREG 0800.

FPIP-0120 Rev. 1A Page 44 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 available in the control room and made available to the plant industrial fire brigade.

3.4.2.4* No similar requirement in CMEB Pre-fire plans shall address BTP 9.5-1, NUREG 0800.

coordination with other plant groups during fire emergencies.

3.4.3 Training and Drills. C.3 Fire Brigade Industrial fire brigade a. The need for good members and other plant organization, training, and personnel who would equipping of fire brigades at respond to a fire in nuclear power plant sites requires conjunction with the brigade that effective measures be shall be provided with implemented to ensure proper training commensurate with discharge of these functions. The their emergency guidance in Regulatory Guide responsibilities. 1.101, "Emergency Planning for (a) Plant Industrial Fire Nuclear Power Plants," should be Brigade Training. All of followed as applicable.

the following requirements shall apply.

(1) Plant industrial fire brigade members shall receive training consistent with the requirements contained in NFPA 600, Standard on Industrial Fire Brigades, or NFPA 1500, Standard on Fire Department Occupational Safety and FPIP-0120 Rev. 1A Page 45 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 Health Program, as appropriate.

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

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

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

(b) Training for Non-Industrial Fire Brigade Personnel. Plant personnel who respond with the FPIP-0120 Rev. 1A Page 46 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 industrial fire brigade shall be trained as to their responsibilities, potential hazards to be encountered, and interfacing with the industrial fire brigade.

(c)

Drills. All of the following requirements shall apply.

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

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

FPIP-0120 Rev. 1A Page 47 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 (3) Industrial fire brigade drills shall be conducted in various plant areas, especially in those areas identified to be essential to plant operation and to contain significant fire hazards.

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

(5) A critique shall be held and documented after each drill.

3.4.4 Fire-Fighting C.3 Fire Brigade Equipment. a. The need for good Protective clothing, organization, training, and respiratory protective equipping of fire brigades at equipment, radiation nuclear power plant sites requires monitoring equipment, that effective measures be personal dosimeters, and fire implemented to ensure proper suppression equipment such discharge of these functions. The as hoses, nozzles, fire guidance in Regulatory Guide extinguishers, and other 1.101, "Emergency Planning for needed equipment shall be Nuclear Power Plants," should be provided for the industrial fire followed as applicable.

brigade. This equipment b. A site fire brigade trained and FPIP-0120 Rev. 1A Page 48 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 shall conform with the equipped for fire fighting should applicable NFPA standards. be established to ensure adequate manual fire fighting capability for all areas of the plant containing structures, systems, or components important to safety.

The fire brigade should be at least five members on each shift. The brigade leader and at least two brigade members should have sufficient training in or knowledge of plant safety-related systems to understand the effects of fire and fire suppressants on safe shutdown capability. The qualification of fire brigade members should include an annual physical examination to determine their ability to perform strenuous fire fighting activities.

The shift supervisor should not be a member of the fire brigade. The brigade leader shall be competent to assess the potential safety consequences of a fire and advise control room personnel. Such competence by the brigade leader may be evidenced by possession of an operator's license or equivalent knowledge of plant safety-related systems.

c. The minimum equipment FPIP-0120 Rev. 1A Page 49 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 provided for the brigade should consist of personal protective equipment such as turnout coats, boots, gloves, hard hats, emergency communications equipment, portable lights, portable ventilation equipment, and portable extinguishers.

Self-contained breathing apparatus using full-face positive-pressure masks approved by NIOSH (National Institute for Occupational Safety and Health--

approval formerly given by the U.S. Bureau of Mines) should be provided for fire brigade, damage control, and control room personnel. At least 10 masks shall be available for fire brigade personnel. Control room personnel may be furnished breathing air by a manifold system piped from a storage reservoir if practical. Service or rated operating life shall be a minimum of one-half hour for the self-contained units.

At least two extra air bottles should be located onsite for each self-contained breathing unit. In addition, an onsite 6-hour supply of reserve air should be provided FPIP-0120 Rev. 1A Page 50 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 and arranged to permit quick and complete replenishment of exhausted supply air bottles as they are returned. If compressors are used as a source of breathing air, only units approved for breathing air shall be used; compressors shall be operable assuming a loss of offsite power.

Special care must be taken to locate the compressor in areas free of dust and contaminants.

C.3.d. (9) Guidance Documents NFPA 27, "Private Fire Brigade,"

should be followed in organization, training, and fire drills. This standard also is applicable for the inspection and maintenance of fire fighting equipment. Among the standards referenced in this document, NFPA 197, "Training Standard on Initial Fire Attacks," should be utilized as applicable. NFPA booklets and pamphlets listed in NFPA 27 may be used as applicable for training references.

In addition, courses in fire prevention and fire suppression that are recognized or sponsored by the fire protection industry should be utilized.

FPIP-0120 Rev. 1A Page 51 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 3.4.5 Off-Site Fire No similar requirement in CMEB Department Interface. BTP 9.5-1, NUREG 0800.

3.4.5.1 Mutual Aid Agreement.

Off-site fire authorities shall be offered a plan for their interface during fires and related emergencies on site.

3.4.5.2* Site-Specific C.2 Administrative Controls Training. o. Define the strategies for Fire fighters from the off-site fighting fires in all safety-related fire authorities who are areas and areas presenting a expected to respond to a fire hazard to safety-related at the plant shall be offered equipment. These strategies site-specific training and should designate:

shall be invited to participate (6) Organization of fire fighting in a drill at least annually. brigades and the assignment of special duties according to job title so that all fire fighting functions are covered by any complete shift personnel complement. These duties include command control of the brigade, transporting fire suppression and support equipment to the fire scenes, applying the extinguishant to the fire, communication with the control room, and coordination with outside fire departments.

FPIP-0120 Rev. 1A Page 52 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 3.4.5.3* Security and No similar requirement in CMEB Radiation Protection. BTP 9.5-1, NUREG 0800.

Plant security and radiation protection plans shall address off-site fire authority response.

3.4.6* Communications. C.3 Fire Brigade An effective emergency c. The minimum equipment communications capability provided for the brigade should shall be provided for the consist of personal protective industrial fire brigade. equipment such as turnout coats, boots, gloves, hard hats, emergency communications equipment, portable lights, portable ventilation equipment, and portable extinguishers.

Self-contained breathing apparatus using full-face positive-pressure masks approved by NIOSH (National Institute for Occupational Safety and Health--

approval formerly given by the U.S. Bureau of Mines) should be provided for fire brigade, damage control, and control room personnel. At least 10 masks shall be available for fire brigade personnel. Control room personnel may be furnished breathing air by a manifold system piped from a storage reservoir if FPIP-0120 Rev. 1A Page 53 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 practical. Service or rated operating life shall be a minimum of one-half hour for the self-contained units.

C.3.d.7 Drills (f) Drills should as a minimum include the following:

ii. Assessment of each brigade member's knowledge of his or her role in the fire fighting strategy for the area assumed to contain the fire. Assessment of the brigade members' conformance with established plant fire fighting procedures and use of fire fighting equipment, including self-contained emergency breathing apparatus, communication equipment, and ventilation equipment, to the extent practicable.

3.5 Water Supply. C.6.b Fire Protection Water 3.5.1 Supply A fire protection water supply (9) Two separate, reliable of adequate reliability, freshwater supplies should be quantity, and duration shall provided. Saltwater or brackish be provided by one of the water should not be used unless two following methods. all freshwater supplies have been exhausted. If tanks are used, two (a) Provide a fire protection 100% (minimum of 300,000 FPIP-0120 Rev. 1A Page 54 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 water supply of not less than gallons each) system capacity two separate 300,000-gal tanks should be installed. They (1,135,500-L) supplies. should be so interconnected that (b) Calculate the fire flow pumps can take suction from rate for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This fire flow either or both. However, a failure rate shall be based on 500 in one tank or its piping should not gpm (1892.5 L/min) for cause both tanks to drain. Water manual hose streams plus supply capacity should be capable the largest design demand of of refilling either tank in 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or any sprinkler or fixed water less.

spray system(s) in the power (11) The fire water supply should block as determined in be calculated on the basis of the accordance with NFPA 13, largest expected flow rate for a Standard for the Installation period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , but not less of Sprinkler Systems, or than 300,000 gallons. This flow NFPA 15, Standard for rate should be based Water Spray Fixed Systems (conservatively) on 500 gpm for for Fire Protection. The fire manual hose streams plus the water supply shall be largest design demand of any capable of delivering this sprinkler or deluge system as design demand with the determined in accordance with hydraulically least NFPA 13 or NFPA 15. The fire demanding portion of fire water supply should be capable of main loop out of service. delivering this design demand over the longest route of the water supply system.

3.5.2* C.6.b Fire Protection Water The tanks shall be Supply interconnected such that fire (9) Two separate, reliable FPIP-0120 Rev. 1A Page 55 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 pumps can take suction from freshwater supplies should be either or both. A failure in provided. Saltwater or brackish one tank or its piping shall water should not be used unless not allow both tanks to drain. all freshwater supplies have been The tanks shall be designed exhausted. If tanks are used, two in accordance with NFPA 22, 100% (minimum of 300,000 Standard for Water Tanks for gallons each) system capacity Private Fire Protection. tanks should be installed. They should be so interconnected that pumps can take suction from Exception No. 1: Water either or both. However, a failure storage tanks shall not be in one tank or its piping should not required when fire pumps cause both tanks to drain. Water are able to take suction from supply capacity should be capable a large body of water (such of refilling either tank in 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or as a lake), provided each fire less.

pump has its own suction and both suctions and (12) Freshwater lakes or ponds of pumps are adequately sufficient size may qualify as sole separated. source of water for fire protection but require separate redundant suctions in one or more intake Exception No. 2: Cooling structures. These supplies should tower basins shall be an be separated so that a failure of acceptable water source for one supply will not result in a fire pumps when the volume failure of the other supply.

is sufficient for both (13) When a common water purposes and water quality is supply is permitted for fire consistent with the demands protection and the ultimate heat of the fire service.

sink, the following conditions should also be satisfied:

(a) The additional fire protection water requirements are designed FPIP-0120 Rev. 1A Page 56 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 into the total storage capacity, and (b) Failure of the fire protection system should not degrade the function of the ultimate heat sink.

3.5.3* C.6.b Fire Protection Water Fire pumps, designed and Supply installed in accordance with (6) If pumps are required to meet NFPA 20, Standard for the system pressure or flow Installation of Stationary requirements, a sufficient number Pumps for Fire Protection, of pumps should be provided to shall be provided to ensure ensure that 100% capacity will be that 100 percent of the available assuming failure of the required flow rate and largest pump or loss of offsite pressure are available power (e.g., three 50% pumps or assuming failure of the two 100% pumps). This can be largest pump or pump power accomplished, for example, by source. providing either:

(a) Electric motor-driven fire pump(s) and diesel-driven fire pump(s); or (b) Two or more seismic Category I Class 1E electric motor-driven fire pumps connected to redundant Class 1E emergency power buses (see Regulatory Guides 1.6, 1.32, and 1.75).

Individual fire pump connections to the yard fire main loop should be separated with sectionalizing valves between connections.

FPIP-0120 Rev. 1A Page 57 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 Each pump and its driver and controls should be located in a room separated from the remaining fire pumps by a fire wall with a minimum rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

The fuel for the diesel fire pump(s) should be separated so that it does not provide a fire source exposing safety-related equipment. Alarms indicating pump running, driver availability, failure to start, and low fire-main pressure should be provided in the control room.

The fire pump installation should conform to NFPA 20, "Standard for the Installation of Centrifugal Fire Pumps."

3.5.4 C.6.b Fire Protection Water At least one diesel engine- Supply driven fire pump or two more (6) If pumps are required to meet seismic Category I Class IE system pressure or flow electric motor-driven fire requirements, a sufficient number pumps connected to of pumps should be provided to redundant Class IE ensure that 100% capacity will be emergency power buses available assuming failure of the capable of providing 100 largest pump or loss of offsite percent of the required flow power (e.g., three 50% pumps or rate and pressure shall be two 100% pumps). This can be FPIP-0120 Rev. 1A Page 58 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 provided. accomplished, for example, by providing either:

(a) Electric motor-driven fire pump(s) and diesel-driven fire pump(s); or (b) Two or more seismic Category I Class 1E electric motor-driven fire pumps connected to redundant Class 1E emergency power buses (see Regulatory Guides 1.6, 1.32, and 1.75).

Individual fire pump connections to the yard fire main loop should be separated with sectionalizing valves between connections.

Each pump and its driver and controls should be located in a room separated from the remaining fire pumps by a fire wall with a minimum rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

The fuel for the diesel fire pump(s) should be separated so that it does not provide a fire source exposing safety-related equipment. Alarms indicating pump running, driver availability, failure to start, and low fire-main pressure should be provided in the control room.

FPIP-0120 Rev. 1A Page 59 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 The fire pump installation should conform to NFPA 20, "Standard for the Installation of Centrifugal Fire Pumps."

3.5.5 C.6.b Fire Protection Water Each pump and its driver Supply and controls shall be (6) If pumps are required to meet separated from the system pressure or flow remaining fire pumps and requirements, a sufficient number from the rest of the plant by of pumps should be provided to rated fire barriers. ensure that 100% capacity will be available assuming failure of the largest pump or loss of offsite power (e.g., three 50% pumps or two 100% pumps). This can be accomplished, for example, by providing either:

(a) Electric motor-driven fire pump(s) and diesel-driven fire pump(s); or (b) Two or more seismic Category I Class 1E electric motor-driven fire pumps connected to redundant Class 1E emergency power buses (see Regulatory Guides 1.6, 1.32, and 1.75).

Individual fire pump connections to the yard fire main loop should be separated with sectionalizing valves between connections.

FPIP-0120 Rev. 1A Page 60 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 Each pump and its driver and controls should be located in a room separated from the remaining fire pumps by a fire wall with a minimum rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

The fuel for the diesel fire pump(s) should be separated so that it does not provide a fire source exposing safety-related equipment. Alarms indicating pump running, driver availability, failure to start, and low fire-main pressure should be provided in the control room.

The fire pump installation should conform to NFPA 20, "Standard for the Installation of Centrifugal Fire Pumps."

3.5.6 No similar requirement in CMEB Fire pumps shall be provided BTP 9.5-1, NUREG 0800. May with automatic start and be tacitly covered by the following manual stop only. statement.

C.6.b Fire Protection Water Supply Systems (6) The fire pump installation should conform to NFPA 20, "Standard for the Installation of Centrifugal Fire Pumps."

FPIP-0120 Rev. 1A Page 61 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 3.5.7 C.6.b Fire Protection Water Individual fire pump Supply connections to the yard fire (6) If pumps are required to meet main loop shall be provided system pressure or flow and separated with requirements, a sufficient number sectionalizing valves of pumps should be provided to between connections. ensure that 100% capacity will be available assuming failure of the largest pump or loss of offsite power (e.g., three 50% pumps or two 100% pumps). This can be accomplished, for example, by providing either:

(a) Electric motor-driven fire pump(s) and diesel-driven fire pump(s); or (b) Two or more seismic Category I Class 1E electric motor-driven fire pumps connected to redundant Class 1E emergency power buses (see Regulatory Guides 1.6, 1.32, and 1.75).

Individual fire pump connections to the yard fire main loop should be separated with sectionalizing valves between connections.

Each pump and its driver and controls should be located in a room separated from the remaining fire pumps by a fire wall FPIP-0120 Rev. 1A Page 62 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 with a minimum rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

The fuel for the diesel fire pump(s) should be separated so that it does not provide a fire source exposing safety-related equipment. Alarms indicating pump running, driver availability, failure to start, and low fire-main pressure should be provided in the control room.

The fire pump installation should conform to NFPA 20, "Standard for the Installation of Centrifugal Fire Pumps."

3.5.8 No similar requirement in CMEB A method of automatic BTP 9.5-1, NUREG 0800. May pressure maintenance of the be tacitly covered by the following fire protection water system statement.

shall be provided independent of the fire C.6.b Fire Protection Water pumps. Supply Systems (6) The fire pump installation should conform to NFPA 20, "Standard for the Installation of Centrifugal Fire Pumps."

3.5.9 C.6.b Fire Protection Water Means shall be provided to Supply immediately notify the control (6) If pumps are required to meet room, or other suitable system pressure or flow FPIP-0120 Rev. 1A Page 63 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 constantly attended location, requirements, a sufficient number of operation of fire pumps. of pumps should be provided to ensure that 100% capacity will be available assuming failure of the largest pump or loss of offsite power (e.g., three 50% pumps or two 100% pumps). This can be accomplished, for example, by providing either:

(a) Electric motor-driven fire pump(s) and diesel-driven fire pump(s); or (b) Two or more seismic Category I Class 1E electric motor-driven fire pumps connected to redundant Class 1E emergency power buses (see Regulatory Guides 1.6, 1.32, and 1.75).

Individual fire pump connections to the yard fire main loop should be separated with sectionalizing valves between connections.

Each pump and its driver and controls should be located in a room separated from the remaining fire pumps by a fire wall with a minimum rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

The fuel for the diesel fire pump(s) should be separated so that it does not provide a fire source exposing safety-related FPIP-0120 Rev. 1A Page 64 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 equipment. Alarms indicating pump running, driver availability, failure to start, and low fire-main pressure should be provided in the control room.

The fire pump installation should conform to NFPA 20, "Standard for the Installation of Centrifugal Fire Pumps."

3.5.10 C.6.b Fire Protection Water An underground yard fire Supply main loop, designed and (1) An underground yard fire main installed in accordance with loop should be installed to furnish NFPA 24, Standard for the anticipated water requirements.

Installation of Private Fire NFPA 24, "Standard for Outside Service Mains and Their Protection," gives necessary Appurtenances, shall be guidance for such installation. It installed to furnish references other design codes anticipated water and standards developed by such requirements. organizations as the American National Standards Institute (ANSI) and the American Water Works Association (AWWA). Type of pipe and water treatment should be design considerations with tuberculation as one of the parameters. Means for inspecting and flushing the systems should be provided.

3.5.11 C.6.b Fire Protection Water FPIP-0120 Rev. 1A Page 65 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 Means shall be provided to Supply isolate portions of the yard (3) Valves should be installed to fire main loop for permit isolation of outside maintenance or repair hydrants from the fire main for without simultaneously maintenance or repair without shutting off the supply to interrupting the water supply to both fixed fire suppression automatic or manual fire systems and fire hose suppression systems in any area stations provided for manual containing or presenting a fire backup. Sprinkler systems hazard to safety-related or safe and manual hose station shutdown equipment.

standpipes shall be connected to the plant fire protection water main so that a single active failure or a crack to the water supply piping to these systems can be isolated so as not to impair both the primary and backup fire suppression systems.

3.5.12 C.6.b Fire Protection Water Threads compatible with Supply those used by local fire (3) Threads compatible with those departments shall be used by local fire departments provided on all hydrants, should be provided on all hose couplings, and hydrants, hose couplings, and standpipe risers. standpipe risers.

Exception: Fire departments shall be permitted to be provided with adapters that allow interconnection FPIP-0120 Rev. 1A Page 66 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 between plant equipment and the fire department equipment if adequate training and procedures are provided.

3.5.13 C.6.c Water Sprinkler and Hose Headers fed from each end Standpipe Systems shall be permitted inside (1) Sprinkler systems and manual buildings to supply both hose station standpipes should sprinkler and standpipe have connections to the plant systems, provided steel underground water main so that a piping and fittings meeting single active failure or a crack in a the requirements of ANSI moderate-energy line cannot B31.1, Code for Power impair both the primary and Piping, are used for the backup fire suppression systems.

headers (up to and including Alternatively, headers fed from the first valve) supplying the each end are permitted inside sprinkler systems where buildings to supply both sprinkler such headers are part of the and standpipe systems, provided seismically analyzed hose steel piping and fittings meeting standpipe system. Where the requirements of ANSI B31.1, provided, such headers shall "Power Piping, are used for the be considered an extension headers up to and including the of the yard main system. first valve supplying the sprinkler Each sprinkler and standpipe systems where such headers are system shall be equipped part of the seismically analyzed with an outside screw and hose standpipe system. When yoke (OS&Y) gate valve or provided, such headers are other approved shutoff valve. considered an extension of the yard main system. Each sprinkler and standpipe system should be equipped with OS&Y (outside FPIP-0120 Rev. 1A Page 67 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 screw and yoke) gate valve or other approved shutoff valve and waterflow alarm. Safety-related equipment that does not itself require sprinkler water fire protection but is subject to unacceptable damage if wet by sprinkler water discharge should be protected by water shields or baffles.

3.5.14* C.6.c Water Sprinkler and Hose All fire protection water Standpipe Systems supply and fire suppression (2) Control and sectionalizing system control valves shall valves in the fire water systems be under a periodic should be electrically supervised inspection program and shall or administratively controlled. The be supervised by one of the electrical supervision signal following methods. should indicate in the control (a) Electrical supervision room. All valves in the fire with audible and visual protection system should be signals in the main control periodically checked to verify room or other suitable position (see NFPA 26, constantly attended location. "Supervision of Valves").

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

(c) Sealing valves in their normal positions. This option shall be utilized only where FPIP-0120 Rev. 1A Page 68 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 valves are located within fenced areas or under the direct control of the owner/operator.

3.5.15 C.6.b Fire Protection Water Hydrants shall be installed Supply approximately every 250 ft (7) Outside manual hose (76 m) apart on the yard installation should be sufficient to main system. A hose house provide an effective hose stream equipped with hose and to any onsite location where fixed combination nozzle and or transient combustibles could other auxiliary equipment jeopardize safety-related specified in NFPA 24, equipment. Hydrants should be Standard for the Installation installed approximately every 250 of Private Fire Service Mains ft on the yard main system. A and Their Appurtenances, hose house equipped with hose shall be provided at intervals and combination nozzle and other of not more than 1000 ft (305 auxiliary equipment m) along the yard main recommended in NFPA 24, system. "Outside Protection," should be Exception: Mobile means of provided as needed, but at least providing hose and every 1,000 ft. Alternatively, associated equipment, such mobile means of providing hose as hose carts or trucks, shall and associated equipment, such be permitted in lieu of hose as hose carts or trucks, may be houses. Where provided, used. When provided, such such mobile equipment shall mobile equipment should be be equivalent to the equivalent to the equipment equipment supplied by three supplied by three hose houses.

hose houses.

3.5.16* C.6.b Fire Protection Water FPIP-0120 Rev. 1A Page 69 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 The fire protection water Supply supply system shall be (4) fire main system piping should dedicated for fire protection be separate from service or use only. sanitary water system piping, except as described in Position Exception No. 1: Fire C.5.c.(4).

protection water supply (10) Common tanks are permitted systems shall be permitted to for fire and sanitary or service be used to provide backup to water storage. When this is done, nuclear safety systems, however, minimum fire water provided the fire protection storage requirements should be water supply systems are dedicated by passive means, for designed and maintained to example, use of a vertical deliver the combined fire and standpipe for other water nuclear safety flow demands services. Administrative controls, for the duration specified by including locks for tank outlet the applicable analysis. valves, are unacceptable as the only means to ensure minimum water volume.

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

3.6 Standpipe and Hose Stations. C.6.c Water Sprinkler and Hose 3.6.1 Standpipe Systems FPIP-0120 Rev. 1A Page 70 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 For all power block buildings, (4) Interior manual hose Class III standpipe and hose installation should be able to systems shall be installed in reach any location that contains, accordance with NFPA 14, or could present a fire exposure Standard for the Installation hazard to, safety-related of Standpipe, Private equipment with at least one Hydrant, and Hose Systems. effective hose stream. To accomplish this, standpipes with hose connections equipped with a maximum of 100 feet of 1-1/2-inch woven-jacket, lined fire hose and suitable nozzles should be provided in all buildings on all floors. Individual standpipes should be at least 4 inches in diameter for multiple hose connections and 2-1/2 inches in diameter for single hose connections. These systems should follow the requirements of NFPA 14, "Standpipe and Hose Systems," for sizing, spacing, and pipe support requirements.

Hose stations should be located as dictated by the fire hazard analysis to facilitate access and use for fire fighting operations.

Alternative hose stations should be provided for an area if the fire hazard could block access to a single hose station serving that FPIP-0120 Rev. 1A Page 71 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 area.

Provisions should be made to supply water at least to standpipes and hose connections for manual fire fighting in areas containing equipment required for safe plant shutdown in the event of a safe shutdown earthquake.

The piping system serving such hose stations should be analyzed for SSE loading and should be provided with supports to ensure system pressure integrity. The piping and valves for the portion of hose standpipe system affected by this functional requirement should, as a minimum, satisfy ANSI B31.1, "Power Piping." The water supply for this condition may be obtained by manual operator actuation of valves in a connection to the hose standpipe header from a normal seismic Category I water system such as the essential service water system. The cross connection should be (a) capable of providing flow to at least two hose stations (approximately 75 gpm per hose station), and (b) designed to the same standards as the seismic FPIP-0120 Rev. 1A Page 72 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 Category I water system; it should not degrade the performance of the seismic Category I water system.

3.6.2 No similar requirement in CMEB A capability shall be provided BTP 9.5-1, NUREG 0800. May to ensure an adequate water be tacitly covered by the following flow rate and nozzle statement.

pressure for all hose stations. This capability C.6.c Water Sprinkler and Hose includes the provision of Standpipe Systems hose station pressure (4) These systems should reducers where necessary follow the requirements of NFPA for the safety of plant 14, "Standpipe and Hose industrial fire brigade Systems," for sizing, spacing, and members and off-site fire pipe support requirements.

department personnel.

3.6.3 C.6.c Water Sprinkler and Hose The proper type of hose Standpipe Systems nozzle to be supplied to each (5) The proper type of hose power block area shall be nozzle to be supplied to each area based on the area fire should be based on the fire hazards. The usual hazard analysis. The usual combination spray/straight combination spray/straight-stream stream nozzle shall not be nozzle should not be used in used in areas where the areas where the straight stream straight stream can cause can cause unacceptable unacceptable damage or mechanical damage. Fixed fog present an electrical hazard nozzles should be provided at to fire-fighting personnel. locations where high-voltage FPIP-0120 Rev. 1A Page 73 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 Listed electrically safe fixed shock hazards exist. All hose fog nozzles shall be provided nozzles should have shutoff at locations where high- capability. (Guidance on safe voltage shock hazards exist. distances for water application to All hose nozzles shall have live electrical equipment may be shutoff capability and be able found in the "NFPA Fire to control water flow from full Protection Handbook.")

open to full closed.

3.6.4 C.6.c Water Sprinkler and Hose Provisions shall be made to Standpipe Systems supply water at least to (4) Provisions should be made to standpipes and hose stations supply water at least to for manual fire suppression standpipes and hose connections in all areas containing for manual fire fighting in areas systems and components containing equipment required for needed to perform the safe plant shutdown in the event nuclear safety functions in of a safe shutdown earthquake.

the event of a safe shutdown The piping system serving such earthquake (SSE). hose stations should be analyzed for SSE loading and should be provided with supports to ensure system pressure integrity. The piping and valves for the portion of hose standpipe system affected by this functional requirement should, as a minimum, satisfy ANSI B31.1, "Power Piping." The water supply for this condition may be obtained by manual operator actuation of valves in a connection to the hose standpipe header from a normal seismic FPIP-0120 Rev. 1A Page 74 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 Category I water system such as the essential service water system. The cross connection should be (a) capable of providing flow to at least two hose stations (approximately 75 gpm per hose station), and (b) designed to the same standards as the seismic Category I water system; it should not degrade the performance of the seismic Category I water system.

3.6.5 C.6.c Water Sprinkler and Hose Where the seismic required Standpipe Systems hose stations are cross- (4) Provisions should be made to connected to essential supply water at least to seismic non-fire protection standpipes and hose connections water supply systems, the for manual fire fighting in areas fire flow shall not degrade containing equipment required for the essential water system safe plant shutdown in the event requirement. of a safe shutdown earthquake.

The piping system serving such hose stations should be analyzed for SSE loading and should be provided with supports to ensure system pressure integrity. The piping and valves for the portion of hose standpipe system affected by this functional requirement should, as a minimum, satisfy ANSI B31.1, "Power Piping." The water supply for this condition FPIP-0120 Rev. 1A Page 75 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 may be obtained by manual operator actuation of valves in a connection to the hose standpipe header from a normal seismic Category I water system such as the essential service water system. The cross connection should be (a) capable of providing flow to at least two hose stations (approximately 75 gpm per hose station), and (b) designed to the same standards as the seismic Category I water system; it should not degrade the performance of the seismic Category I water system.

3.7 Fire Extinguishers. C.6 Portable Extinguishers Where provided, fire (f) Fire extinguishers should be extinguishers of the provided in areas that contain, or appropriate number, size, could present a fire exposure and type shall be provided in hazard to, safety-related accordance with NFPA 10, equipment in accordance with Standard for Portable Fire guidelines of NFPA 10, "Portable Extinguishers. Extinguishers Fire Extinguishers, Installation, shall be permitted to be Maintenance and Use." Dry positioned outside of fire chemical extinguishers should be areas due to radiological installed with due consideration conditions. given to possible adverse effects on safety-related equipment installed in the area.

3.8 Fire Alarm and C.6.b Fire Detection FPIP-0120 Rev. 1A Page 76 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 Detection Systems. (1) Detection systems should be 3.8.1 Fire Alarm. provided for all areas that contain or present a fire exposure to Alarm initiating devices shall safety-related equipment.

be installed in accordance with NFPA 72, National Fire (2) Fire detection systems should Alarm Code. Alarm comply with the requirements of annunciation shall allow the Class A systems as defined in proprietary alarm system to NFPA 72D, "Standard for the transmit fire-related alarms, Installation, Maintenance, and supervisory signals, and Use of Proprietary Protective trouble signals to the control Signaling Systems," and Class I room or other constantly circuits as defined in NFPA 70, attended location from which "National Electrical Code."

required notifications and (3) Fire detectors should be response can be initiated. selected and installed in Personnel assigned to the accordance with NFPA 72E, proprietary alarm station "Automatic Fire Detectors."

shall be permitted to have Preoperational and periodic other duties. The following testing of pulsed line-type heat fire-related signals shall be detectors should demonstrate that transmitted: the frequencies used will not (1) Actuation of any fire affect the actuation of protective detection device relays in other plant systems.

(2) Actuation of any fixed (4) Fire detection systems should fire suppression system give audible and visual alarm and annunciation in the control room.

(3) Actuation of any Where zoned detection systems manual fire alarm are used in a given fire area, local station means should be provided to (4) Starting of any fire identify which detector zone has pump actuated. Local audible alarms (5) Actuation of any fire should sound in the fire area.

FPIP-0120 Rev. 1A Page 77 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 protection supervisory (5) Fire alarms should be device distinctive and unique so they will (6) Indication of alarm not be confused with any other system trouble plant system alarms.

condition (6) Primary and secondary power supplies should be provided for the fire detection system and for electrically operated control valves for automatic suppression systems. Such primary and secondary power supplies should satisfy provisions of Section 2220 of NFPA 72D. This can be accomplished by using normal offsite power as the primary supply with a 4-hour battery supply as secondary supply; and by providing capability for manual connection to the Class 1E emergency power bus within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of loss of offsite power.

Such connection should follow the applicable guidelines in Regulatory Guides 1.6, 1.32, and 1.75.

3.8.1.1 No similar requirement in CMEB Means shall be provided to BTP 9.5-1, NUREG 0800.

allow a person observing a fire at any location in the plant to quickly and reliably communicate to the control room or other suitable FPIP-0120 Rev. 1A Page 78 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 constantly attended location.

3.8.1.2 No similar requirement in CMEB Means shall be provided to BTP 9.5-1, NUREG 0800.

promptly notify the following of any fire emergency in such a way as to allow them to determine an appropriate course of action:

(1) General site population in all occupied areas (2) Members of the industrial fire brigade and other groups supporting fire emergency response (3) Off-site fire emergency response agencies. Two independent means shall be available (e.g.,

telephone and radio) for notification of off-site emergency services 3.8.2 Detection. C.6.b Fire Detection FPIP-0120 Rev. 1A Page 79 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 If automatic fire detection is (2) Fire detection systems should required to meet the comply with the requirements of performance or deterministic Class A systems as defined in requirements of Chapter 4, NFPA 72D, "Standard for the then these devices shall be Installation, Maintenance, and installed in accordance with Use of Proprietary Protective NFPA 72, National Fire Signaling Systems," and Class I Alarm Code, and its circuits as defined in NFPA 70, applicable appendixes. "National Electrical Code."

(3) Fire detectors should be selected and installed in accordance with NFPA 72E, "Automatic Fire Detectors."

Preoperational and periodic testing of pulsed line-type heat detectors should demonstrate that the frequencies used will not affect the actuation of protective relays in other plant systems.

3.9 Automatic and Manual C.6.c Water Sprinklers and Water-Based Fire Hose Standpipe Systems Suppression Systems. (3) Fixed water extinguishing 3.9.1* systems should conform to If an automatic or manual requirements of appropriate water-based fire suppression standards such as NFPA 13, system is required to meet "Standard for the Installation of the performance or Sprinkler Systems," and NFPA 15, deterministic requirements of "Standard for Water Spray Fixed Chapter 4, then the system Systems."

shall be installed in (7) Certain fires, such as those FPIP-0120 Rev. 1A Page 80 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 accordance with the involving flammable liquids, appropriate NFPA standards respond well to foam suppression.

including the following: Consideration should be given to (1) NFPA 13, Standard use of mechanical low-expansion for the Installation foam systems, high-expansion of Sprinkler foam generators, or aqueous film-Systems forming foam (AFFF) systems, including the AFFF deluge (2) NFPA 15, Standard system. These systems should for Water Spray comply with the requirements of Fixed Systems for NFPA 11, NFPA 11A, NFPA 11B, Fire Protection and NFPA 16, as applicable.

(3) NFPA 750, Standard on Water Mist Fire Protection Systems (4) NFPA 16, Standard for the Installation of Foam-Water Sprinkler and Foam-Water Spray Systems 3.9.2 C.6.c Water Sprinklers and Each system shall be Hose Standpipe Systems equipped with a water flow (1) Each sprinkler and alarm. standpipe system should be equipped with OS&Y (outside screw and yoke) gate valve or other approved shutoff valve and water flow alarm.

3.9.3 B.4 Definitions FPIP-0120 Rev. 1A Page 81 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 All alarms from fire Sprinkler System - a network of suppression systems shall piping connected to a reliable annunciate in the control water supply that will distribute the room or other suitable water throughout the area constantly attended location. protected and will discharge the water through sprinklers in sufficient quantity either to extinguish the fire entirely or to prevent its spread. The system, usually activated by heat, includes a controlling valve and a device for actuating an alarm when the system is in operation. The following categories of sprinkler systems are defined in NFPA 13, "Standard for the Installation of Sprinkler Systems":

Wet-Pipe System

Dry-Pipe System

Pre-action System

Deluge System

Combined Dry-Pipe and Pre-action System

On-Off System C.2 Administrative Controls (m) Control actions to be taken by the control room operator to determine the need for brigade assistance upon report of a fire or receipt of alarm on control room FPIP-0120 Rev. 1A Page 82 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 annunciator panel, for example, announcing location of fire over PA system, sounding fire alarms, and notifying the shift supervisor and the fire brigade leader of the type, size, and location of the fire.

C. 7. Guidelines for Specific Plant Areas This section of NUREG 0800 only requires that fire detection systems alarm locally and in the control room. There is no specific reference that automatic and manual water-based fire suppression systems alarm locally and in the control room.

3.9.4 No similar requirement in CMEB Diesel-driven fire pumps BTP 9.5-1, NUREG 0800.

shall be protected by automatic sprinklers.

3.9.5 C.6.c Water Sprinklers and Each system shall be Hose Standpipe Systems equipped with an OS&Y gate (1) Each sprinkler and valve or other approved standpipe system should be shutoff valve. equipped with OS&Y (outside screw and yoke) gate valve or other approved shutoff valve and water flow alarm.

3.9.6 C.6.c Water Sprinklers and All valves controlling water- Hose Standpipe Systems FPIP-0120 Rev. 1A Page 83 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 based fire suppression (2) Control and sectionalizing systems required to meet the valves in the fire water systems performance or deterministic should be electrically supervised requirements of Chapter 4 or administratively controlled. The shall be supervised as electrical supervision signal described in 3.5.14. should indicate in the control room. All valves in the fire protection system should be periodically checked to verify position(see NFPA 26, "Supervision of Valves").

3.10 Gaseous Fire C.6.d Halon Suppression Suppression Systems. Systems 3.10.1 Halon fire extinguishing systems If an automatic total flooding should comply with the and local application requirements of NFPA 12A and gaseous fire suppression NFPA 12B, Halogenated Fire system is required to meet Extinguishing Agent Systems the performance or Halon 1301 and Halon 1211.

deterministic requirements of C.6.e Carbon Dioxide Chapter 4, then the system Suppression Systems shall be designed and Carbon dioxide extinguishing installed in accordance with systems should comply with the the following applicable requirements of NFPA 12, NFPA codes: "Carbon Dioxide Extinguishing (1) NFPA 12, Standard on Systems."

Carbon Dioxide Extinguishing Systems (2) NFPA 12A, Standard on Halon 1301 Fire FPIP-0120 Rev. 1A Page 84 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 Extinguishing Systems (3) NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems 3.10.2 No similar requirement in CMEB Operation of gaseous fire BTP 9.5-1, NUREG 0800.

suppression systems shall annunciate and alarm in the control room or other constantly attended location identified.

3.10.3 C.5.f Ventilation Ventilation system design Where total flooding gas shall take into account extinguishing systems are used, prevention from over- area intake and exhaust pressurization during agent ventilation dampers should be injection, adequate sealing to controlled in accordance with prevent loss of agent, and NFPA 12, "Carbon Dioxide confinement of radioactive Systems," and NFPA 12A, "Halon contaminants. 1301 Systems," to maintain the necessary gas concentration.

C.6.d Halon Suppression Systems Particular consideration should also be given to:

(1) Minimum required Halon concentration, distribution, soak time, and ventilation control.

Particular consideration should also be given to:

FPIP-0120 Rev. 1A Page 85 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 C.6.e Carbon Dioxide Suppression Systems (1) Minimum required CO2 concentration, distribution, soak time, and ventilation control; (4) Conflicting requirements for venting during CO2 injection to prevent overpressurization versus sealing to prevent loss of agent.

7.b Control Room Complex If a halon flooding system is used for fire suppression, these dampers should be strong enough to support the pressure rise accompanying halon discharge and seal tightly against infiltration of halon into the control room.

3.10.4* III. REVIEW PROCEDURES In any area required to be CMEB reviews the results of an protected by both primary FPP failure modes and effect and backup gaseous fire analysis (impairment) to assure suppression systems, a that the entire fire protection single active failure or a system for one safety-related area crack in any pipe in the fire cannot be impaired by a single suppression system shall not failure.

impair both the primary and C.1.c. Fire Suppression System backup fire suppression Design Basis capability.

(2) A single active failure or a crack in a moderate-energy line (pipe) in the fire suppression FPIP-0120 Rev. 1A Page 86 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 system should not impair both the primary and backup fire suppression capability. For example, neither the failure of a fire pump, its power supply or controls, nor a crack in a moderate-energy line in the fire suppression system, should result in loss of function of both sprinkler and hose standpipe systems in an area protected by such primary and backup systems.

3.10.5 C.6.d Halon Suppression Provisions for locally Systems disarming automatic Provisions for locally disarming gaseous suppression automatic Halon systems should systems shall be secured be key locked and under strict and under strict administrative control. Automatic administrative control. Halon extinguishing systems should not be disarmed unless controls as described in Position C.2.j. are provided.

C.6.e Carbon Dioxide Suppression Systems Provisions for locally disarming automatic carbon dioxide systems should be key locked and under strict administrative control.

Automatic carbon dioxide extinguishing systems should not be disarmed unless controls as FPIP-0120 Rev. 1A Page 87 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 described in Position C.2.j. are provided.

3.10.6* C.7.b Control Room Complex Total flooding carbon dioxide Carbon dioxide flooding systems systems shall not be used in are not acceptable for these normally occupied areas. areas.

3.10.7 C.6.e Carbon Dioxide Automatic total flooding Suppression Systems carbon dioxide systems shall Where automatic carbon dioxide be equipped with an audible systems are used, they should be pre-discharge alarm and equipped with a pre-discharge discharge delay sufficient to alarm system and a discharge permit egress of personnel. delay to permit personnel egress.

No similar requirement in CMEB The carbon dioxide system BTP 9.5-1, NUREG 0800 for an shall be provided with an odorizer.

odorizer.

3.10.8 No similar requirement in CMEB Positive mechanical means BTP 9.5-1, NUREG 0800 for shall be provided to lock out positive mechanical lockout.

total flooding carbon dioxide systems during work in the protected space.

3.10.9 C.6.e Carbon Dioxide The possibility of secondary Suppression Systems thermal shock (cooling) Particular consideration should damage shall be considered also be given to:

during the design of any (3) Possibility of secondary gaseous fire suppression thermal shock (cooling) damage.

FPIP-0120 Rev. 1A Page 88 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 system, but particularly with carbon dioxide.

3.10.10 C.6.d Halon Suppression Particular attention shall be Systems given to corrosive Particular consideration should characteristics of agent also be given to:

decomposition products on (3) Toxicity and corrosive safety systems. characteristics of the thermal decomposition products of Halon.

3.11 Passive Fire Protection Features.

This section shall be used to determine the design and installation requirements for passive protection features.

Passive fire protection features include wall, ceiling, and floor assemblies, fire doors, fire dampers, and through fire barrier penetration seals. Passive fire protection features also include electrical raceway fire barrier systems (ERFBS) that are provided to protect cables and electrical components and equipment from the effects of fire.

3.11.1 Building Separation. C. 5.a Building Design Each major building within (1) Fire barriers with a minimum FPIP-0120 Rev. 1A Page 89 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 the power block shall be fire resistance rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months separated from the others by should be provided to:

barriers having a designated (c) Separate individual units on a fire resistance rating of 3 multiple-unit site unless the hours or by open space of at requirements of General Design least 50 ft (15.2 m) or space Criterion 5 are met with respect to that meets the requirements fires.

of NFPA 80A, (8) Cable spreading rooms should Recommended Practice for be separated from each other and Protection of Buildings from from other areas of the plant by Exterior Fire Exposures.

barriers having a minimum fire Exception: Where a resistance of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

performance-based analysis (13) Outdoor oil-filled transformers determines the adequacy of should have oil spill confinement building separation, the features or drainage away from requirements of 3.11.1 shall the buildings. Such transformers not apply.

should be located at least 50 feet distant from the building, or by ensuring that such building walls within 50 feet of oil-filled transformers are without openings and have a fire resistance rating of at least 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

7.h Turbine Building The turbine building should be separated from adjacent structures containing safety-related equipment by a fire barrier with a minimum rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

The fire barriers should be designed so as to maintain FPIP-0120 Rev. 1A Page 90 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 structural integrity even in the event of a complete collapse of the turbine structure.

3.11.2 Fire Barriers. A.4 Definitions Fire barriers required by Fire Resistance Rating - The time Chapter 4 shall include a that materials or assemblies have specific fire-resistance rating. withstood a fire exposure as Fire barriers shall be established in accordance with designed and installed to the test procedures of "Standard meet the specific fire Methods of Fire Tests of Building resistance rating using Construction and Materials" assemblies qualified by fire (NFPA 251).

tests. The qualification fire tests shall be in accordance with NFPA 251, Standard Methods of Tests of Fire Endurance of Building Construction and Materials, or ASTM E 119, Standard Test Methods for Fire Tests of Building Construction and Materials.

3.11.3* Fire Barrier C.5.a Building Design Penetrations. (4) Penetration openings for Penetrations in fire barriers ventilation systems should be shall be provided with listed protected by fire dampers having fire-rated door assemblies or a rating equivalent to that required listed rated fire dampers of the barrier (see NFPA-90A, "Air having a fire resistance Conditioning and Ventilating rating consistent with the Systems"). Flexible air duct designated fire resistance coupling in ventilation and filter FPIP-0120 Rev. 1A Page 91 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 rating of the barrier as systems should be determined by the noncombustible.

performance requirements (5) Door openings in fire barriers established by Chapter 4. should be protected with (See 3.11.3.4 for penetration equivalently rated doors, frames, seals for through penetration and hardware that have been fire stops.) Passive fire tested and approved by a protection devices such as nationally recognized laboratory.

doors and dampers shall Such doors should be self-closing conform with the following or provided with closing NFPA standards, as mechanisms and should be applicable: inspected semiannually to verify that automatic hold-open, release, (1) NFPA 80, Standard for and closing mechanisms and Fire Doors and Fire Windows latches are operable. (See NFPA 80, "Fire Doors and Windows.")

(2) NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems (3) NFPA 101, Life Safety Code Exception: Where fire area boundaries are not wall-to-wall, floor-to-ceiling boundaries with all penetrations sealed to the fire rating required of the boundaries, a performance-based analysis shall be required to assess the FPIP-0120 Rev. 1A Page 92 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 adequacy of fire barrier forming the fire boundary to determine if the barrier will withstand the fire effects of the hazards in the area.

Openings in fire barriers shall be permitted to be protected by other means as acceptable to the AHJ.

3.11.4* Through C.5.a Building Design Penetration Fire Stops. (3) Openings through fire barriers Through penetration fire for pipe, conduit, and cable trays stops for penetrations such which separate fire areas should as pipes, conduits, bus be sealed or closed to provide a ducts, cables, wires, fire resistance rating at least equal pneumatic tubes and ducts, to that required of the barrier and similar building service itself. Openings inside conduit equipment that pass through larger than 4 inches in diameter fire barriers shall be should be sealed at the fire barrier protected as follows. penetration. Openings inside (a) The annular space conduit 4 inches or less in between the diameter should be sealed at the penetrating item and fire barrier unless the conduit the through opening extends at least 5 feet on each in the fire barrier shall side of the fire barrier and is be filled with a sealed either at both ends or at qualified fire-resistive the fire barrier with penetration seal noncombustible material to assembly capable of prevent the passage of smoke maintaining the fire and hot gases. Fire barrier resistance of the fire penetrations that must maintain barrier. The assembly environmental isolation or FPIP-0120 Rev. 1A Page 93 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 shall be qualified by pressure differentials should be tests in accordance qualified by test to maintain the with a fire test barrier integrity under such protocol acceptable conditions.

to the AHJ or be protected by a listed Penetration designs should utilize fire-rated device for only noncombustible materials the specified fire-and should be qualified by tests.

resistive period.

The penetration qualification tests (b) Conduits shall be should use the time-temperature provided with an exposure curve specified by internal fire seal that ASTM E-119, "Fire Test of has an equivalent Building Construction and fire-resistive rating to Materials." The acceptance that of the fire barrier criteria for the test should require through opening fire that:

stop and shall be (a) The fire barrier penetration has permitted to be withstood the fire endurance test installed on either without passage of flame or side of the barrier in a ignition of cables on the location that is as unexposed side for a period of close to the barrier as time equivalent to the fire possible.

resistance rating required of the Exception: Openings barrier.

inside conduit 4 in. (10.2 (b) The temperature levels cm) or less in diameter recorded for the unexposed side shall be sealed at the fire are analyzed and demonstrate barrier with a fire-rated that the maximum temperature internal seal unless the does not exceed 325o F.

conduit extends greater than 5 ft (1.5 m) on each (c) The fire barrier penetration side of the fire barrier. In remains intact and does not allow FPIP-0120 Rev. 1A Page 94 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 this case the conduit projection of water beyond the opening shall be unexposed surface during the provided with hose stream test. The stream noncombustible material shall be delivered through a 1-1/2 to prevent the passage of inch nozzle set at a discharge smoke and hot gases. angle of 30% with a nozzle The fill depth of the pressure of 75 psi and a minimum material packed to a discharge of 75 gpm with the tip of depth of 2 in. (5.1 cm) the nozzle a maximum of 5 ft from shall constitute an the exposed face; or the-stream acceptable smoke and shall be delivered through a 1-1/2-hot gas seal in this inch nozzle set at a discharge application. angle of 15% with a nozzle pressure of 75 psi and a minimum discharge of 75 gpm with the tip of the nozzle a maximum of 10 ft from the exposed face; or the stream shall be delivered through a 2-1/2-inch national standard playpipe equipped with 1-1/8 inch tip, nozzle pressure of 30 psi, located 20 ft from the exposed face.

3.11.5* Electrical Raceway No similar requirement in CMEB Fire Barrier Systems BTP 9.5-1, NUREG 0800.

(ERFBS).

ERFBS required by Chapter 4 shall be capable of resisting the fire effects of the hazards in the area.

ERFBS shall be tested in accordance with and shall FPIP-0120 Rev. 1A Page 95 of 98 Page 1 of 89 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 meet the acceptance criteria of NRC Generic Letter 86-10, Supplement 1, Fire Endurance Test Acceptance Criteria for Fire Barrier Systems Used to Separate Safe Shutdown Trains Within the Same Fire Area. The ERFBS needs to adequately address the design requirements and limitations of supports and intervening items and their impact on the fire barrier system rating.

The fire barrier systems ability to maintain the required nuclear safety circuits free of fire damage for a specific thermal exposure, barrier design, raceway size and type, cable size, fill, and type shall be demonstrated.

Exception No. 1: When the temperatures inside the fire barrier system exceed the maximum temperature allowed by the acceptance criteria of Generic Letter 86-10, Fire Endurance Acceptance Test Criteria for FPIP-0120 Rev. 1A Page 96 of 98 Page 1 of 88 Chapter 3 Fundamental Mapped to CMEB BTP 9.5-1, Basis Statement Basis Document Fire Protection Program NUREG 0800 References and Design Elements July 1981 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 Generic Letter 86-10, Supplement 1, Attachment 1, Attachment Methods for Demonstrating Functionality of Cables Protected by Raceway Fire Barrier Systems During and After Fire Endurance Test Exposure.

Exception No. 2: ERFBS systems employed prior to the issuance of Generic Letter 86-10, Supplement 1, are acceptable providing that the system successfully met the limiting end point temperature requirements as specified by the AHJ at the time of acceptance. Deleted: ¶

¶ FPIP-0120 Rev. 1A Page 97 of 98

1 REVISION

SUMMARY

TBD FPIP-0120 Rev. 1A Page 98 of 98

EXAMPLE 1- Comply Chapter 3 Fundamental Compliance Basis Document Fire Protection Program Basis Statement Statement References and Design Elements 3.2.2.4 Comply The policy document procedure FPP-001, Fire FPP-001, Rev The policy document shall Protection Program Manual identifies the 29, Fire identify the appropriate appropriate AHJ for the various areas of the fire Protection AHJ for the various areas protection program Program Manual of the fire protection

NSPC area-NRC Section 3.2 program.

Non-NSPC areas NEIL / Local Authorities /

Site FP Engineer

EXAMPLE 2- Complies With Clarification (Simple)

Chapter 3 Fundamental Compliance Basis Document Fire Protection Program Basis Statement Statement References and Design Elements 3.4.2.4 Complies with FPP-002, Fire Emergency provides the specific FPP-002, Rev Pre-fire plans shall Clarification instructions for actions required from key groups at 31, Fire address coordination with HNP supporting the fire brigade/fire emergency Emergency other plant groups during actions. There are detailed response coordination fire emergencies. actions specified for Control Room personnel and FPP-001, Rev the Security group. Any other coordination actions 29, Fire would be initiated by Control Room personnel as Protection needed for any plant emergency.

Program Manual, Section The Fire Pre-plans contain guidance to be used by 8.6.5-Fire the Site Incident Commander for coordination of Response control room, security and radiation control personnel activities.

Key Points- FPP-002 is not by definition a pre-plan it is the control room procedure for fire response

EXAMPLE 3- Complies With Clarification (Detailed)

Chapter 3 Fundamental Compliance Basis Document Fire Protection Program Basis Statement Statement References and Design Elements 3.4.4 Fire-Fighting Complies with Protective clothing, respiratory protective SHNPP FSAR, Equipment. Clarification equipment, radiation monitoring equipment, Section 9.5.1, Protective clothing, personal dosimeters, and fire suppression page 9.5.1-26, respiratory protective equipment such as hoses, nozzles, and other Amendement 50 equipment, radiation needed equipment are provided for the fire brigade.

monitoring equipment, SHNPP FSAR, personal dosimeters, and Protective clothing is designed and purchased to Section 9.5.1, fire suppression applicable NFPA codes. Respiratory protective page 9.5.1-25, equipment such as hoses, equipment is purchased and maintained per Amendement 37 nozzles, fire extinguishers, applicable industry codes. Fire suppression and other needed equipment such as hoses and nozzles are equipment shall be HPP-630, Rev designed and purchased per the applicable NFPA provided for the industrial 20, Respiratory codes.

fire brigade. This Protection equipment shall conform Program.

with the applicable NFPA standards.

Key Points- Fire Extinguishers are excluded from the response as they are installed in the plant. The requirement is not clear on expectations on maintenance therefore the response excludes applicable NFPA standards regarding maintenance of the clothing and equipment.

EXAMPLE 4- Complies via Previous Approval (Specific Approval)

Chapter 3 Fundamental Compliance Basis Document Fire Protection Program Basis Statement Statement References and Design Elements 3.3.2 Structural. Complies Via NUREG 1038 states in part Interior walls and HNP SER structural components, are noncombustible NUREG -1038 Walls, floors, and Previous or are listed by a nationally recognized testing components required to Approval laboratory, such as Factory Mutual (FM) or UL, or maintain structural have flame-spread, Smoke, and fuel contribution of integrity shall be of 25 or less. The staff finds this in accordance with noncombustible the guidelines of BTP CMEB 9.5-1 Section C.5.a, construction, as defined in and, therefore acceptable.

NFPA 220, Standard on Types of Building Construction.

Key Points - HNP did not look at NFPA 220 and we will rely on the existing plant construction and licensing basis.

EXAMPLE 5- Complies via Previous Approval (Non-Specific Approval)

Chapter 3 Fundamental Compliance Basis Document Fire Protection Program Basis Statement Statement References and Design Elements 3.9.4 Complies via SER section 9.5.1 pg 9-51 states in part The fire HNP SER Previous pumps are located in the emergency service-water NUREG-1038 Diesel-driven fire pumps Approval screening structure. The fire pumps are separated shall be protected by by the intake water structure. A single fire is, automatic sprinklers.

therefore, unlikely to cause damage to both pumps.

Based on its review, the staff concludes that the fire protection water supply system meets Section C.6.c of BTP CMEB 9.5-l and is, therefore, acceptable.

Key Points - The original SER identifies that A single fire is unlikely to cause damage to both pumps therefore we believe this bounds the current design and the new requirement for sprinklers is not applicable.

EXAMPLE 6- Further Action Required (Pending FAQ 06-008)

Chapter 3 Fundamental Compliance Basis Document Fire Protection Program Basis Statement Statement References and Design Elements 3.5.3 Complies The Centrifugal Fire Pumps installed at SHNPP SHNPP FSAR w/Engineering conform to the applicable requirements of NFPA 20 Amendment 53, Fire pumps, designed and Equivalency - 1972. section 9.5.1, page installed in accordance Evaluation (FAQ 9.5.1-21 with NFPA 20, Standard 06-008) for the Installation of FSAR states Fire pumps are installed in Stationary Pumps for Fire accordance with NFPA-20. Water is supplied from Protection, shall be the Auxiliary Reservoir by two 100 percent capacity HNP-M/BMRK-provided to ensure that 0007, Rev 2, Code fire pumps. Each fire pump provides the total fire Compliance 100 percent of the protection water supply requirements to the fire Evaluation NFPA required flow rate and main loop, thus required fire pump discharge 20 - Centrifugal pressure are available capacity and pressure are available with either Fire Pumps assuming failure of the pump out of service.

largest pump or pump power source.

Key Points- NFPA 20 Code Evaluation has sections that were evaluated as acceptable and flagged as JC. These are considered acceptable engineering equivalency evaluations.

EXAMPLE 7- License Amendment Request (LAR)

Chapter 3 Fundamental Compliance Basis Document Fire Protection Program Basis Statement Statement References and Design Elements 3.5.16 LAR The fire protection system water will not be used SHNPP FSAR The fire protection water for any non-fire-related purposes, except to provide Amendment 53, supply system shall be makeup to the Non-Essential Services Chilled section 9.5.1, dedicated for fire Water Expansion Tank. However, under normal page 9.5.1-20 protection use only. conditions there would be no water going into this system as makeup. Other uses are as approved by the Superintendent - Shift Operations.

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

Key Points- Need to do formal justification for alternate use of water in non-safety related system.

Chapter 3 Sections with no Similar NUREG 0800 Requirement Chapter 3 Chapter 3 Requirement NRC Reference NRC Requirement Reference 3.2.2.3 3.2.2.3* NUREG 0800 No similar requirement in CMEB BTP 9.5-1, The policy document shall define the fire protection interfaces NUREG 0800.

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

3.2.2.4 3.2.2.4* NUREG 0800 No similar requirement in CMEB BTP 9.5-1, The policy document shall identify the appropriate AHJ for the NUREG 0800.

various areas of the fire protection program.

3.3.1.3.4 3.3.1.3.4* NUREG 0800 No similar requirement in CMEB BTP 9.5-1, Plant administrative procedure shall control the use of portable NUREG 0800.

electrical heaters in the plant. Portable fuel-fired heaters shall not be permitted in plant areas containing equipment important to nuclear safety or where there is a potential for radiological releases resulting from a fire.

3.3.7.3 3.3.7.3 NUREG 0800 No similar requirement in CMEB BTP 9.5-1, Flammable gas storage cylinders not required for normal NUREG 0800.

operation shall be isolated from the system.

3.3.9 3.3.9* Transformers. NUREG 0800 No similar requirement in CMEB BTP 9.5-1, Transformers. Where provided, transformer oil collection basins and drain paths NUREG 0800.

shall be periodically inspected to ensure that they are free of debris and capable of performing their design function.

3.3.11 3.3.11 Electrical Equipment NUREG 0800 No similar requirement in CMEB BTP 9.5-1, Electrical Adequate clearance, free of combustible material, shall be NUREG 0800.

Equipment maintained around energized electrical equipment.

Page 1 of 5

Chapter 3 Sections with no Similar NUREG 0800 Requirement Chapter 3 Chapter 3 Requirement NRC Reference NRC Requirement Reference 3.4.1 On-Site 3.4.1 On-Site Fire-Fighting Capability. NUREG 0800 No similar requirement in CMEB BTP 9.5-1, Fire-Fighting All of the following requirements shall apply. NUREG 0800.

Capability. (a) A fully staffed, trained, and equipped fire-fighting force shall be available at all times to control and extinguish all fires on site.

This force shall have a minimum complement of five persons on duty and shall conform with the following NFPA standards as applicable:

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

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

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

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

(d)

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

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

The physical examination shall determine the ability of each member to use respiratory protection equipment.

3.4.2.2 3.4.2.2 NUREG 0800 No similar requirement in CMEB BTP 9.5-1, Pre-fire plans shall be reviewed and updated as necessary. NUREG 0800.

Page 2 of 5

Chapter 3 Sections with no Similar NUREG 0800 Requirement Chapter 3 Chapter 3 Requirement NRC Reference NRC Requirement Reference 3.4.2.3 3.4.2.3* NUREG 0800 No similar requirement in CMEB BTP 9.5-1, Pre-fire plans shall be available in the control room and made NUREG 0800.

available to the plant industrial fire brigade.

3.4.2.4 3.4.2.4* NUREG 0800 No similar requirement in CMEB BTP 9.5-1, Pre-fire plans shall address coordination with other plant groups NUREG 0800.

during fire emergencies.

3.4.5.1 Mutual 3.4.5.1 Mutual Aid Agreement. NUREG 0800 No similar requirement in CMEB BTP 9.5-1, Aid Off-site fire authorities shall be offered a plan for their interface NUREG 0800.

Agreement. during fires and related emergencies on site.

3.4.5.3 3.4.5.3* Security and Radiation Protection. NUREG 0800 No similar requirement in CMEB BTP 9.5-1, Security and Plant security and radiation protection plans shall address off-site NUREG 0800.

Radiation fire authority response.

Protection.

3.8.1.1 3.8.1.1 NUREG 0800 No similar requirement in CMEB BTP 9.5-1, Means shall be provided to allow a person observing a fire at any NUREG 0800.

location in the plant to quickly and reliably communicate to the control room or other suitable constantly attended location.

3.8.1.2 3.8.1.2 NUREG 0800 No similar requirement in CMEB BTP 9.5-1, Means shall be provided to promptly notify the following of any NUREG 0800.

fire emergency in such a way as to allow them to determine an appropriate course of action:

(1) General site population in all occupied areas (2) Members of the industrial fire brigade and other groups supporting fire emergency response (3) Off-site fire emergency response agencies. Two independent means shall be available (e.g., telephone and radio) for notification of off-site emergency services Page 3 of 5

Chapter 3 Sections with no Similar NUREG 0800 Requirement Chapter 3 Chapter 3 Requirement NRC Reference NRC Requirement Reference 3.9.4 3.9.4 NUREG 0800 No similar requirement in CMEB BTP 9.5-1, Diesel-driven fire pumps shall be protected by automatic NUREG 0800.

sprinklers.

3.10.2 3.10.2 NUREG 0800 No similar requirement in CMEB BTP 9.5-1, Operation of gaseous fire suppression systems shall annunciate NUREG 0800.

and alarm in the control room or other constantly attended location identified.

3.11.5 3.11.5* Electrical Raceway Fire Barrier Systems (ERFBS). NUREG 0800 No similar requirement in CMEB BTP 9.5-1, Electrical ERFBS required by Chapter 4 shall be capable of resisting the NUREG 0800.

Raceway Fire fire effects of the hazards in the area. ERFBS shall be tested in Barrier accordance with and shall meet the acceptance criteria of NRC Systems Generic Letter 86-10, Supplement 1, Fire Endurance Test (ERFBS). Acceptance Criteria for Fire Barrier Systems Used to Separate Safe Shutdown Trains Within the Same Fire Area. The ERFBS needs to adequately address the design requirements and limitations of supports and intervening items and their impact on the fire barrier system rating. The fire barrier systems ability to maintain the required nuclear safety circuits free of fire damage for a specific thermal exposure, barrier design, raceway size and type, cable size, fill, and type shall be demonstrated.

Exception No. 1: When the temperatures inside the fire barrier system exceed the maximum temperature allowed by the acceptance criteria of Generic Letter 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 Generic Letter 86-10, Supplement 1, Attachment 1, Attachment Methods for Demonstrating Functionality of Cables Protected by Raceway Page 4 of 5

Chapter 3 Sections with no Similar NUREG 0800 Requirement Chapter 3 Chapter 3 Requirement NRC Reference NRC Requirement Reference Fire Barrier Systems During and After Fire Endurance Test Exposure.

Exception No. 2: ERFBS systems employed prior to the issuance of Generic Letter 86-10, Supplement 1, are acceptable providing that the system successfully met the limiting end point temperature requirements as specified by the AHJ at the time of acceptance.

Page 5 of 5

HNP CHAPTER 3 FURTHER ACTIONS REQUIRED Chapter 3 Section Summary Action Required 3.3.1.1 General Fire Prevention Activities FAQ to clarify intent of familiarization with plant fire (1) Training on fire safety information for all employees and prevention procedures, fire reporting, and plant emergency contractors including, as a minimum, familiarization with alarms regarding scope of or depth of the training.

plant fire prevention procedures, fire reporting, and plant emergency alarms 3.3.1.2 Control of Combustible Materials FAQ to define where used in Chapter 3, power block and (1)Wood used within the power block shall be listed plant are intended to mean areas in which a fire could pressure-impregnated or coated with a listed fire-retardant jeopardize the ability to meet the performance criteria described application. in section 1.5.

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

3.3.1.2 Control of Combustible Materials Response will provide a methodology to evaluate a storage area.

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

(6) Controls on use and storage of flammable gases shall be FAQ to identify what applicable is.

in accordance with applicable NFPA standards.

3.3.5.2 FAQ required clarifying that air drops are acceptable. HNP has Only metal tray and metal conduits shall be used for exposed cable drops ~ 3 in length.

electrical raceways. Thin wall metallic tubing shall not be used for power, instrumentation, or control cables. Flexible Page 1 of 3

HNP CHAPTER 3 FURTHER ACTIONS REQUIRED metallic conduits shall only be used in short lengths to connect components.

3.3.5.3 FAQ to identify a list of typical flame propagation tests which are Electric cable construction shall comply with a flame considered acceptable.

propagation test as acceptable to the AHJ.

3.3.8 Bulk Storage of Flammable and Combustible FAQ to grant exception for Diesel Generator Day Tanks located Liquids. within Diesel Generator Buildings.

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.

3.3.11 Electrical Equipment FAQ to define what adequate clearance is. Could be based on Adequate clearance, free of combustible material, shall be OSHA 3ft requirement.

maintained around energized electrical equipment.

3.4 Industrial Fire Brigade. FAQ to define minimum acceptable pre-plan scope. Suggest use 3.4.2.1 of existing guidance.

The plans shall detail the fire area configuration and fire hazards to be encountered in the fire area, along with any nuclear safety components and fire protection systems and features that are present.

3.4.4 Fire-Fighting Equipment. FAQ to clarify that intent is for design and purchase of Protective clothing, respiratory protective equipment, equipment. NFPA code requirements for gear maintenance is not radiation monitoring equipment, personal dosimeters, and applicable.

fire suppression equipment such as hoses, nozzles, fire extinguishers, and other needed equipment shall be provided Page 2 of 3

HNP CHAPTER 3 FURTHER ACTIONS REQUIRED for the industrial fire brigade. This equipment shall conform with the applicable NFPA standards.

3.5.3 Need to screen the NFPA 20 calc for deviations that were Fire pumps, designed and installed in accordance with evaluated as acceptable to ensure they meet any criteria of 805.

NFPA 20, Standard for the Installation of Stationary Pumps for Fire Protection, shall be provided to ensure that 100 percent of the required flow rate and pressure are available assuming failure of the largest pump or pump power source.

3.7 Fire Extinguishers. FAQ to clarify the where provided statement.

Where provided, fire extinguishers of the appropriate number, size, and type shall be provided in accordance with NFPA 10, Standard for Portable Fire Extinguishers.

Extinguishers shall be permitted to be positioned outside of fire areas due to radiological conditions.

Page 3 of 3

SYSTEM FILE NO.# 6175 CALC. TYPE DH CATEGORY CODE B CAROLINA POWER & LIGHT COMPANY HNP-M/BMRK-0007 (CALCULATION #)

Code Compliance Evaluation NFPA 20 - Centrifugal Fire Pumps (TITLE INCLUDING STRUCTURE/SYSTEM/COMPONENT)

FOR SHEARON HARRIS NUCLEAR POWER PLANT NUCLEAR ENGINEERING DEPARTMENT QUALITY CLASS: A B C D E REV RESPONSIBLE DESIGN VERIFIED BY APPROVED BY NO ENGINEER ENGINEERING REVIEW BY RESPONSIBLE SUPERVISORY DATE DATE DATE 0 Ross E. Park John G. Crowther REASON FOR CHANGE:

REASON FOR CHANGE:

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CALCULATION NO. HNP-M/BMRK-0007 PAGE NO. 2 REVISION 1 LIST OF EFFECTIVE PAGES PAGE REV PAGE REV PAGE REV 1 1 2 1 3 1 4 1 5 1 6 1 7 1 8 1 ATTACHMENTS 1 1 2 0 3 1 4 0 5 0 6 1 7 1 ENP-011

CALCULATION NO. HNP-M/BMRK-0007 PAGE NO. 3 REVISION 1 TABLE OF CONTENTS LIST OF EFFECTIVE PAGES .........................................................................................................2 TABLE OF CONTENTS...................................................................................................................3 PURPOSE ..........................................................................................................................................4 SCOPE ...............................................................................................................................................4 REFERENCES ..................................................................................................................................4

SUMMARY

.......................................................................................................................................7 CONCLUSIONS................................................................................................................................8 CALCULATION INDEXING TABLE IMPACT.............................................................................8 Attachment 1 - Code of Record Determination - NFPA 20 Attachment 2 - Applicability Matrix - NFPA 20, 1972 Edition Attachment 3 - Code Compliance Verification Checklist - NFPA 20 - 1972 Attachment 4 - Owner Review Comments Attachment 5 - DE&S Design Review Record Attachment 6 - Resolution of Apparent Code Deviations Attachment 7 - Rev. 1 Design Verification Record ENP-011

CALCULATION NO. HNP-M/BMRK-0007 PAGE NO. 4 REVISION 1 PURPOSE The purpose of this analysis is to assess the NFPA 20 - 1972 compliance level of the Centrifugal Fire Pumps installed at the Shearon Harris Nuclear Power Plant (SHNPP). Centrifugal Fire Pumps are required by FSAR (Reference 1.1) Section 9.5.1.2.1 to conform to NFPA 20 - 1972.

SCOPE System walkdown, design review, and development of this analysis were conducted in accordance with SHNPP Task Scoping Document WA-00011H, HNP NFPA Code Evaluations. Minor identified code deviations (items that do not require a design change, procedure change, and/or complex evaluation) are dispositioned within this analysis; others Within Attachment 6. These items are identified by a JC (Justified Compliance) entry in the Compliance column of Attachment 3 to this calculation, the Code Compliance Verification Checklist.

Rev. 1: This revision resolves the deviations that were noted in Rev. 0 of this calculation. The resolutions were taken from AR 25060, action item #5, and EC 50147.

REFERENCES

1. Licensing Documents 1.1 SHNPP FSAR, Section 9.5.1, Fire Protection System.

1.2 SHNPP FSAR, Appendix 9.5A, Fire Protection Hazards Analysis.

1.3 NUREG-1038, including Supplements 1-4, Safety Evaluation Report Related to the Operation of SHNPP.

1.4 DBD-202, Rev. 6, Plant Electrical Distribution System.

1.5 DBD-317, Rev. 0, Water-Based Fire Suppression System.

2. Fire Protection Procedures 2.1 FPP-001, Rev. 20, Fire Protection Program Manual.

2.2 FPP-013, Rev. 33, Fire Protection - Minimum Requirements, Mitigating Actions and Surveillance Requirements.

3. Miscellaneous Procedures 3.1 CM-M0032, Rev. 5, Johnston Vertical Turbine Pumps (Disassembly and Repair) 3.2 FPT-3001, Rev. 9, Motor Driven Main Fire Pump Operability Test (Monthly)(All Modes).

3.3 FPT-3004, Rev. 11, Main Fire Pump Flow Test (Annual)(All Modes).

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CALCULATION NO. HNP-M/BMRK-0007 PAGE NO. 5 REVISION 1 3.4 FPT-3010, Rev. 9, Engine Driven Main Fire Pump Operability Test (Monthly)(All Modes).

3.5 MPT-E0019, Rev. 4, Diesel Fire Pump Battery Weekly Test.

3.6 MPT-E0020, Rev. 3, Diesel Fire Pump Battery Specific Gravity Verification.

3.7 MPT-E0021, Rev. 4, Diesel Fire Pump Battery 18 Month Inspection.

3.8 MPT-M0036, Rev. 8, Fire Protection Emergency Diesel Engine Operational Inspection (18 Months)(All Modes).

3.9 PIC-I305, Rev. 3, Diesel Driven Fire Pump Over-Speed Switch Calibration.

4. Specifications 4.1 CAR-SH-E-12, Rev. 6, Motors for Station Auxiliary Service Furnished With Driven Equipment Rated up to 460V and 250 HP.

4.2 CAR-SH-M-20, Rev. 2, Firewater Pumps.

4.3 CAR-SH-M-62, Rev. 3, Fire Hose and Accessories.

5. Vendor Manuals 5.1 VM-BCF, Rev. 7, Relief Valves (JE Lonergan).

5.2 VM-BJY, Rev. 6, Valves and Accessories (Crane, Inc.).

5.3 VM-EIZ, Rev. 5, Pumps (Johnston Pump Co.)

5.4 VM-IJX, Rev. 16, Motors (General Electric) 5.5 VM-MJD, Rev. 6, Diesel Engine (Cummins Engine Co.)

5.6 VM-UJL, Rev. 0, Pump Drive, Right Angle (Randolph Mfg. Co.)

6. Plant Drawings and Flow Diagrams 6.1 1364-1675, Rev. 1, Fire Water Pump - Diesel Driven 6.2 1364-1676, Rev. 1, Fire Water Pump - Motor Driven 6.3 1364-1691, Rev. 1, Fire Water Pump - Diesel Driven Right Angle Gear Drive 6.4 1364-1693, Rev. 1, Fire Water Pump - Diesel Driven Engine Detail 6.5 1364-1697, Rev. 3, Fire Water Pump - Diesel Driven 550 Gallon Fuel Tank and Rack 6.6 1364-1698, Rev. 1, Fire Water Pump - Diesel Driven Engine Wiring Diagram 6.7 1364-1719, Rev. 1, Fire Water Jockey Pump 6.8 1364-1741, Rev. 1, Fire Water Jockey Pump Motor 6.9 1364-1742, Rev. 1, Fire Water Pump - Motor Driven Motor O/L 6.10 1364-1812, Rev. 2, Diesel Engine Controller Outline 6.11 1364-1813, Rev. 3, Diesel Engine Controller Wiring Diagram 6.12 1364-1814, Rev. 1, Diesel Engine Controller Data Sheet 6.13 1364-1815, Rev. 1, Diesel Engine Controller Schematic Diagram ENP-011

CALCULATION NO. HNP-M/BMRK-0007 PAGE NO. 6 REVISION 1 6.14 1364-1816, Rev. 4, Diesel Engine Controller External Connections and Selection of Operating Features 6.15 1364-2141, Rev. 3, Fire W Pump - Diesel Driven Disch Fittings 6.16 1364-2142, Rev. 3, Fire W Pump - Motor Driven Disch Fittings 6.17 1364-2156, Rev. 0, Fire Water Pump - Diesel Driven Test Curve.

6.18 1364-2157, Rev. 0, Fire Water Pump - Motor Driven Test Curve.

6.19 SD/C-C-1007, Rev. 0, Site P.O.H - 37838 Jockey Pump Controller Outline And Wiring Diagram.

6.20 SD/C-C-1010, Rev. 0, Site P.O.H - 38698 Motor Control Panel, Wiring And Schem.

Diag, Cab Outline.

6.21 CAR-2166-B-041, Sheet 79, Rev. 6, Unit No. 1 Power Distribution & Motor Data 480V General Services Bus 1-4A101.

6.22 CAR-2166-B-041, Sheet 253S01, Rev. 9, Unit No. 1 Power Distribution & Motor Data 480V MCC 1-4A1012.

6.23 CAR-2166-B-401, Sheet 2581, Rev. 9, Unit No. 1 Control Wiring Diagram Motor Driven Fire Pump1-4B-NNS.

6.24 CAR-2166-B-401, Sheet 2582, Rev. 7, Unit No. 1 Control Wiring Diagram Jockey Fire Pump1-4X-NNS.

6.25 CAR-2166-B-401, Sheet 2583, Rev. 6, Unit No. 1 Control Wiring Diagram Diesel Driven Emergency Fire Pump 1-4A-NNS 6.26 CAR-2166-S-0301, Sheet 31, Rev. 3, Low Voltage Relay Settings 480V Power Center 1-4A101 6.27 CAR-2166-G-037S01, Rev. 11, General Service Auxiliary One Line Wiring Diagram Bus 1-4A 6.28 CAR-2165-G-209, Rev. 13, Emergency Service Water Intake Screening Structure Piping.

7. Fire Protection Valve Drawings 7.1 1364-21774, Rev. 0.

7.2 1364-44080, Rev. 4

8. Codes and Standards 8.1 NFPA 20, 1972 Edition, Standard for the Installation of Centrifugal Fire Pumps.

9. Calculations 9.1 E1-001.19, Rev. 0, Analysis for Overcurrent Protection for 460V Motor, Motor Driven Fire Pump 1-4B.

10. Engineering Service Requests ENP-011

CALCULATION NO. HNP-M/BMRK-0007 PAGE NO. 7 REVISION 1 10.1 ESR-94-00257, Rev. 0, 2166-B-401 Sht. 2582 Corrections.

10.2 ESR-95-00467, Rev. 0, NAD Assess. Issue H-FP-95-01-I1 (Eval Fire Pump Performance).

10.3 ESR-96-00128, Rev. 0, Revise Instrument Tags on 2166-B-401 Sht. 2582.

10.4 ESR-95-00532, Rev. 0, Fire Pump Seal Ring Material Evaluation.

10.5 ESR-99-00130, Rev. 0, Fire Protection Jockey Pump Line Leak.

10.6 EC 50147, Rev 0,

11. Miscellaneous / Other Documents 11.1 SD-149, Rev. 12, System Description, Fire Protection / Detection Systems.

11.2 OP-149, Rev. 17, Fire Protection.

11.3 Cummins Diesel Engine NT-380-IF Data Sheets 11.4 Purchase Order NY-435007, including Supplements 1-5, Firewater Pumps and Jockey Pumps 11.5 Line As-Built Master List, Rev. 50, dated 7/23/96.

11.6 FCR-FP-583, Rev. 1, Yard Piping: ESW Screening Structure Valve 8FP-R2-1-4 11.7 FCR-SP-121, Rev. 0, Fire Pump Relief Valve Discharge 11.8 AR 25060

SUMMARY

As part of the fire protection code compliance review for SHNPP, the Centrifugal Fire Pumps were reviewed against the code of record edition of NFPA 20, Standard for the Installation of Centrifugal Fire Pumps. This activity was conducted to identify the present level of compliance with the requirements of the consensus standard.

The methodology applied to the NFPA 20 code compliance review was a three-step process as follows:

Identify the code of record for the Centrifugal Fire Pumps within the scope of this review.

Identify the applicable sections of the code requiring verification.

Perform the verification of the applicable code sections.

First, an NFPA Code of Record Determination was performed. This included a review of the installation documents for the Centrifugal Fire Pumps and modification work associated with system hardware. The code of record determination also included the review of the design and purchase specifications, engineering evaluations and design data on record. The results of this review determined that the code of record for the centrifugal fire pumps is NFPA 20 - 1972. The Code of Record Determination is documented in Attachment 1 to this calculation.

ENP-011

CALCULATION NO. HNP-M/BMRK-0007 PAGE NO. 8 REVISION 1 Second, an Applicability Matrix was developed which documents a section-by-section review of NFPA 20 - 1972. The review of each section determined whether a formal verification of compliance with that section would be performed. Where sections were determined not applicable for formal verification, a justification for this position was provided. The Applicability Matrix is contained in Attachment 2 to this calculation.

Third, system walkdowns and a documentation review were conducted in order to verify compliance with code sections deemed applicable based on the section-by-section code review.

The results of this review are documented in the Code Compliance Verification Checklist, which is included as Attachment 3 to this calculation.

CONCLUSIONS The Centrifugal Fire Pumps installed at SHNPP conform to the applicable requirements of NFPA 20 - 1972. Refer to the corresponding section in Attachment 3 for the exact NFPA code requirement and a detailed discussion of the SHNPP compliance scenario.

CALCULATION INDEXING TABLE IMPACT The calculation indexing table is not used in this calculation. There are no impacts to equipment, design documents, licensing documents or plant documents as a result of this calculation.

ENP-011

CALCULATION NO. HNP-M/BMRK-0007 PAGE NO. 1 REVISION 1 Attachment 1 - Code of Record Determination - NFPA 20

CALCULATION NO. HNP-M/BMRK-0007 PAGE NO. 2 REVISION 1 Attachment 1 CODE OF RECORD DETERMINATION NFPA Code: 20, Centrifugal Fire Pumps SHNPP System: Centrifugal Fire Pumps Documents Reviewed:

The documents reviewed in the effort to determine the NFPA 20 code of record were items 1 through 6 and 9-11 identified in the References section of this document. Pertinent code of record information obtained from this review is as follows:

Design/Installation:

Section 9.5.1.2.1 of the SHNPP FSAR (Reference 1.1) identifies the NFPA 20 code of record as 1972.

CAR-SH-M-20, the Firewater Pump purchase specification, was originally issued in 1972.

Purchase Order NY-435007, the Fire Pump purchase contract, specified delivery of all Fire Pumps, controllers, and associated equipment no later than January 1, 1974. NFPA 20 was revised in 1974, but the 1972 edition was still in effect on January 1.

Each of the following drawings (from Reference Item 6) which include various fire pump, pump driver, and controller components and information, were issued by the vendor in either 1972 or 1973. Since NFPA 20 was revised in 1974, the 1972 edition was still in effect at the time or their issue.

1364-1675, Rev. 1, Fire Water Pump - Diesel Driven 1364-1676, Rev. 1, Fire Water Pump - Motor Driven 1364-1691, Rev. 1, Fire Water Pump - Diesel Driven Right Angle Gear Drive 1364-1693, Rev. 1, Fire Water Pump - Diesel Driven Engine Detail 1364-1697, Rev. 3, Fire Water Pump - Diesel Driven 550 Gallon Fuel Tank and Rack 1364-1698, Rev. 1, Fire Water Pump - Diesel Driven Engine Wiring Diagram 1364-1719, Rev. 1, Fire Water Jockey Pump 1364-1741, Rev. 1, Fire Water Jockey Pump Motor 1364-1742, Rev. 1, Fire Water Pump - Motor Driven Motor O/L 1364-1813, Rev. 3, Diesel Engine Controller Wiring Diagram 1364-1816, Rev. 4, Diesel Engine Controller External Connections and Selection of Operating Features SD/C-C-1007, Rev. 0, Site P.O.H - 37838 Jockey Pump Controller Outline And Wiring Diagram.

SD/C-C-1010, Rev. 0, Site P.O.H - 38698 Motor Control Panel, Wiring And Schem.

Diag, Cab Outline.

CALCULATION NO. HNP-M/BMRK-0007 PAGE NO. 3 REVISION 1 Attachment 1 Results Based on the documents reviewed, the code of record for SHNPP Centrifugal Fire Pump design and installation is NPFA 20 - 1972.

CALCULATION NO. HNP-M/BMRK-0007 PAGE NO. 1 REVISION 0 Attachment 2 - Applicability Matrix - NFPA 20, 1972 Edition

NFPA Code Review - Applicability Matrix NFPA 20 - Standard for the Installation of Centrifugal Fire Pumps, 1972 Edition Code Section Title Applicability Basis for Non-Applicability

--- General

--- Purpose No General information not pertaining to fire pump design, installation, operation or maintenance.

--- Approval Prior to Purchase No General information not pertaining to fire pump design, installation, operation or maintenance.

--- Unit Assembly Required No General information regarding pump purchasing and field acceptance tests that do not pertain to fire pump design, installation, operation or maintenance.

--- Complete Plans and Data Required No Pre-installation documentation requirements not pertaining to fire pump design, installation, operation or maintenance.

Part I Pump Arrangement, Test, and Installation Chapter 1 Basic Information 10 General Yes 20 Water Supplies Yes 30 Pumps Yes 40 Installation Yes 50 Power Supply Yes 60 Tests No Pre-installation shop test requirements not pertaining to fire pump design, installation, operation or maintenance.

70 Alarms No Recommendations, not requirements Chapter 100 Horizontal Split-case Pumps 110 General No Both main fire pumps are vertical shaft turbine-type pumps 120 Water Supplies No See above 130 Pump No See above 140 Installation No See above Chapter 200 Vertical Shaft Turbine-Type Pumps 210 General Yes 220 Water Supply Yes 230 Pump Yes HNP-M/BMRK-0007 Page 2 Rev. 0 Attachment 2

NFPA Code Review - Applicability Matrix NFPA 20 - Standard for the Installation of Centrifugal Fire Pumps, 1972 Edition 240 Installation Yes 250 Driver Yes 260 Tests Yes 270 Operation and Maintenance Yes Chapter 300 Special Fire Service Pumps 310 General No HNP does not use special fire service pumps.

320 Water Supplies No See above.

330 Pump No See above.

340 Installation No See above.

350 Driver No See above.

360 Tests No See above.

370 Contracts No See above.

Part II Drive and Driver Controllers for Pump Chapter 400 Electrical Drive 410 General Yes 420 Power Station Yes 430 Power Supply Lines Yes 440 Transformers Yes 450 Motors Yes Chapter 500 Electric Driver Controllers 510 Requirements for all Controllers Yes 520 Controllers in Excess of 600 Volts No Electric motors are 460 volts. This section is therefore not applicable.

530 Limited Service Controllers No The motor of the electric fire pump is in excess of 30 horsepower, which is outside the applicability of this section.

Chapter 600 Internal Combustion Engine Drive 610 General No General information not pertaining to fire pump design, installation, operation or maintenance.

620 Engines Yes 630 Location Yes 640 Fuel Supply Arrangement Yes 650 Exhaust Piping Yes HNP-M/BMRK-0007 Page 3 Rev. 0 Attachment 2

NFPA Code Review - Applicability Matrix NFPA 20 - Standard for the Installation of Centrifugal Fire Pumps, 1972 Edition 660 Maintenance Yes Chapter 700 Engine Drive Controllers 710 Requirements for all Controllers Yes Chapter 800 Steam Turbine Drive 810 General Features No SHNPP does not use steam turbine drives for their fire pumps.

820 Turbine No See above.

830 Installation No See above.

Part III Acceptance, Operation, and Maintenance Chapter 900 Tests and Instructions 910 Field Acceptance Tests No Field acceptance test requirements to be followed after installation; the fire pumps have been installed and acceptance tested.

920 Operating Instructions for Centrifugal Fire Pumps Yes 930 Care of Pump Yes This Appendix is not part of NFPA Standard 20. It is Appendix A Glossary No included for information purposes only.

This Appendix is not part of NFPA Standard 20. It is Appendix B Guide for Diagnosing Defects No included for information purposes only.

This Appendix is not part of NFPA Standard 20. It is Appendix C Figures and Diagrams No included for information purposes only.

HNP-M/BMRK-0007 Page 4 Rev. 0 Attachment 2

CALCULATION NO. HNP-M/BMRK-0007 PAGE NO. 1 REVISION 1 Attachment 3 - Code Compliance Verification Checklist -

NFPA 20 - 1972

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Systems Reviewed: Centrifugal Fire Pumps HNP-M/BMRK-0007 Page 2 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps General Notes applicable to the Code Compliance Verification Checklist:

Verification Method

DR = Documentation Review

WD = Walkdown Inspection Compliance

Y = Yes

N = No*

JC = Justified Compliance. This designates an item deemed acceptable based on an engineering or other type of evaluation.

N/A = Not Applicable Abbreviations / Acronyms AHJ : Authority Having Jurisdiction gpm : gallons per minute psi : pounds per square inch

For Non-compliant items, refer to Table 1 in the Conclusions section of this calculation for recommended solutions.

HNP-M/BMRK-0007 Page 3 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A)

Part I Pump Arrangement, Test, and Installation Chapter Basic Information 1

10 General 11 Approved Pumps Required - Centrifugal fire DR Y

FSAR Sec. 9.5.1, p. 21 Two fire pumps are provided: A diesel driven pumps shall be specifically approved for fire fire pump (1-4A-NNS) which is FM approved pump service. for fire service, and an electric motor driven fire pump (1-4B-NNS) which is UL listed for fire service.

20 Water Supplies 21 Requirements - Fire pumps should be provided DR Y

FSAR Sec. 9.5.1, p. 20 Fire protection water for the plant is taken from with as large and reliable a supply of water as

SD-149, Rev. 12, Sec. the fresh water supply impounded in the possible. The adequacy and the dependability of 3.1 Auxiliary Reservoir, which has an area of 317 the source of water are of primary importance

OP-149, 17, Sec 3.3 acres at an approximate depth of 14 feet. The and must be fully determined at the time of

CAR-2165-G-209, storage capacity greatly exceeds the calculated 2 installation, also the prospects for its reliability Rev. 13 hour fire protection water supply requirement in the future. The minimum water level with (including system demand, hose stream, reserve maximum discharge from the pump must be supply, and makeup re-supply) which totals determined. Where a stored supply is the only 1,440,000 gallons. The reservoir has been one available, a reliable method of replenishing designed with seismic considerations to assure the supply should be provided. Representatives availability of the safety related water supplies of the pump manufacturer shall assist in (which it provides in addition to fire protection establishing these facts to the satisfaction of the water). The quality of water in the reservoir is authority having jurisdiction. Water supplies suitable for use in fire protection systems.

containing salt and other materials deleterious to Traveling screens are provided at the intake the fire protection systems should be avoided structure for the removal of larger impurities whenever possible. which may be present in the water. The Auxiliary Reservoir water level is required to be at least 248 (centerline of fire pump discharge pipes is at 257-81/2).

HNP-M/BMRK-0007 Page 4 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 30 Pumps 31 Types and Rated Capacities of Pumps 31.a Positive suction fire pumps of horizontal split- DR N/A

CAR-SH-M-20, Rev. The two main fire pumps are of the vertical shaft case design for horizontal or vertical mounting 2, Sec. 5 turbine, single suction type and are rated for having rated capacities of 250, 500, 750, 1,000,

FSAR Sec. 9.5.1, p. 21 2500 gpm at 125 psi. The requirements of this 1,500, 2,000 or 2,500 gallons per minute, or

SD-149, Rev. 12, Sec. code section are therefore not applicable.

larger, and rated at net pressure of 40 pounds per 3.2 square inch, or more.

31.b Negative suction fire pumps (these can be used DR N/A

CAR-SH-M-20, Rev. The two main fire pumps are of the vertical shaft with positive suction) of horizontal split-case 2, Sec. 5 turbine, single suction type and are rated for design for horizontal or vertical mounting

FSAR Sec. 9.5.1, p. 21 2500 gpm at 125 psi. The requirements of this having rated capacities of 500, 750, 1,000,

SD-149, Rev. 12, Sec. code section are therefore not applicable.

1,500, 2,000, or 2,500 gallons per minute, or 3.2 larger, and rated at net pressures of 100 pounds per square inch, or more.

31.c Vertical shaft turbine type fire pumps intended DR Y

CAR-SH-M-20, Rev. The two main fire pumps are of the vertical shaft for submerged installation having rated 2, Sec. 5 turbine, single suction type and are rated for capacities of 500, 750, 1,000, 1,500, 2,000 or

FSAR Sec. 9.5.1, p. 21 2500 gpm at 125 psi.

2,500 gallons per minute, or larger, and rated at

SD-149, Rev. 12, Sec.

net pressures of 100 pounds per square inch, or 3.2 more.

31.d Special fire service pumps rated at 200, 300, or DR N/A

CAR-SH-M-20, Rev. The two main fire pumps are of the vertical shaft 450 gallons per minute limited to 130% capacity 2, Sec. 5 turbine, single suction type and are rated for maximum, and for various pressures. The

FSAR Sec. 9.5.1, p. 21 2500 gpm at 125 psi. Special fire service pumps maximum power required shall not exceed the

SD-149, Rev. 12, Sec. are not used. The requirements of this code limitations of a 30 horsepower electric motor. 3.2 section are therefore not applicable.

31.e Pressure maintenance pumps (jockey or make- DR Y

CAR-SH-M-20, Rev. A centrifugal vertical turbine, single suction up pumps) are to be used when it is desirable to 2, Sec. 5 type jockey pump (1-4X-NNS, rated for 125 psi maintain a uniform or relatively high pressure

FSAR Sec. 9.5.1, p. 22 at 50 gpm) is used to maintain a uniform on the fire protection system. The capacity and

SD-149, Rev. 12, Sec. pressure on the fire protection system. The pressure rating of the pump shall be sufficient to 3.2 jockey pump maintains system pressure at HNP-M/BMRK-0007 Page 5 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) maintain the desired pressure against the leakage

NUREG-1038, p. 9-51 approximately 115-143 psi. The fire protection in the system as approved by the authority

EC 50147 water supply system has been approved by the having jurisdiction. A centrifugal type pump is NRC, and has been in continuous service and preferable. Where the discharge pressure at subjected to ongoing testing and maintenance pump shut off of a centrifugal type pump for over 25 years.

exceeds the working pressure rating of the fire protection equipment, or a turbine vane (peripheral) or a positive displacement type pump is used, a suitable relief valve shall be installed on the pump discharge to prevent damage to the fire system.

32 Standards on Capacity and Pressure - For DR Y

CAR-SH-M-20, Rev. The main fire pumps are sized such that they can requirements on capacity and pressure refer to 2, Sec. 5 meet the largest firewater flow and pressure Standard for the Installation of Sprinkler

FSAR Sec. 9.5.1, p. 21 demand at SHNPP, which is 2750 gpm at 72 psi Systems (NFPA No. 13) and Standard for the

1364-2156, Rev. 0 at the Turbine Building mezzanine 286 Installation of Standpipe and Hose Systems

1364-2157, Rev. 0 elevation South sprinkler system. Each fire (NFPA No. 14) and for hydrants, Standard for pump is capable of providing the total fire Outside Protection (NFPA No. 24). protection water supply to the fire main loop, thus required pump discharge capacity and pressure are available with either pump out of service.

33 Name and Capacity Plate - Pumps shall be WD Y

WD SHNPP fire pumps feature name and capacity provided with a Name and Capacity Plate. plates.

40 Installation 41 The Pump Room 41.a The fire pump shall be protected against WD & DR Y

WD Both main fire pumps and the jockey pump are possible interruption of service through damage

NUREG-1038, p. 9-51 located at the Emergency Service Water Intake caused by fire or water, in a manner satisfactory

FSAR Sec. 9.5.1, p. 21 Screening Structure (ESWISS) which is a to the authority having jurisdiction.

CAR-2165-G-209, concrete building. The pumps are actually Rev. 13 installed just outside the building, with the motor driven fire pump and the jockey pump at HNP-M/BMRK-0007 Page 6 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) the North wall and the diesel driven fire pump at the South wall (approx. 104 distance between pumps). As such, the pumps are somewhat protected by the adjacent building on one side.

The pumps are mounted on the concrete deck which supports the ESWISS enclosure.

Although not fully enclosed, the pumps are not subject to interruption of service caused by fire or water or from damage from falling floors or machinery. A weatherproof motor is provided for the motor driven pump, and the engine for the diesel driven pump is installed in a weatherproof enclosure.

The installed fire pump configuration, as part of the fire protection water supply system, was approved by the NRC.

41.b Except where there are several pumps on the WD & DR Y

WD The pumps are located outside the ESWISS same system, located in buildings which are not

NUREG-1038, p. 9-51 building, as described in item 41.a above.

all subject to one fire, or where the pump is

FSAR Sec. 9.5.1, p. 21 The installed fire pump configuration, as part of automatically controlled and supplies automatic

CAR-2165-G-209, the fire protection water supply system, was sprinklers only, the pump should be in a room so Rev. 13 approved by the NRC.

located and constructed as to protect it from falling floors or machinery and from fire which might drive away the operator or damage the pump or driving equipment.

NOTE: Where the use of brick or reinforced concrete is not feasible, metal lath and cement plaster is recommended for the construction of the pump room.

41.c The pump room should be of ample size, and the WD & DR Y

WD The pumps are located outside the ESWISS HNP-M/BMRK-0007 Page 7 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) piping and equipment should be so arranged as

NUREG-1038, p. 9-51 building, as described in item 41.a above.

to make them readily accessible for operation or Although there is not a pump room, the piping repair. The pump room should not be used for and equipment are so arranged that they are storage purposes. readily accessible for operation or repair.

The installed fire pump configuration, as part of NOTE: With vertical type pumps it may be the fire protection water supply system, was necessary to provide a removable panel in the approved by the NRC.

pump house roof to permit the pump to be lifted out for repairs.

41.d The location of the pump room should be such WD & DR Y

WD The pumps are located outside the ESWISS as to permit installation of short and direct pipe

1364-1675, Rev. 1 building, as described in item 41.a above.

connections, the suction pipe receiving first

1364-1676, Rev. 1 Although there is not a pump room, the pumps consideration.

NUREG-1038, p. 9-51 are located directly adjacent to the Auxiliary Reservoir to permit short and direct pipe connections. The suction pipes are routed vertically straight down into the supply water, with an overall column assembly length of 18-6 from concrete grade elevation.

The installed fire pump configuration, as part of the fire protection water supply system, was approved by the NRC.

41.e Suitable means shall be provided for WD & DR JC

WD The pumps are located outside the ESWISS maintaining the temperature of the pump room

NUREG-1038, p. 9-51 building, as described in item 41.a above. There above 40oF.

FSAR Sec. 9.5.1, p. 21 is no specific means provided to maintain

CAR-SH-M-20, Rev. temperature above 40oF. However, SHNPP 2, Sec. 5.05, 5.06 winter average temperature is 41.3 oF, the

CAR-SH-M-62, Rev. installed fire pumps and associated equipment 3, Sec. 2.0 are specified for outdoor use (operating range -2 to 105 oF), and piping and components subject to freezing are insulated and heat traced.

HNP-M/BMRK-0007 Page 8 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A)

The installed fire pump configuration, as part of the fire protection water supply system, was approved by the NRC.

41.f Artificial light shall be provided, and provision WD & DR Y

WD The ESWISS building has fixed external lights made for drainage and ventilation of the pump

NUREG-1038, p. 9-51 which provide artificial illumination to the pump room. A suitable lamp or lantern should be areas. Ample ventilation is provided, and the provided for emergency use. Emergency floor adjacent to the pump areas is constructed lighting may be provided from the battery circuit of steel grating which drains directly to the of an internal combustion engine. Auxiliary Reservoir below.

The installed fire pump configuration, as part of the fire protection water supply system, was approved by the NRC.

41.g Pump rooms housing electric and engine driven WD & DR Y

WD The pumps are located outside the ESWISS pumps should be dry and free from condensate.

FSAR Sec. 9.5.1, p. 21 building, as described in item 41.a above. There Some heat may be required to accomplish this.

CAR-SH-M-20, Rev. is no specific means provided to maintain the 2, Sec. 5.05, 5.06 area dry and free from condensate, however,

NUREG-1038, p. 9-51 there is ample ventilation and the installed fire pumps and associated equipment are specified for outdoor use.

The installed fire pump configuration, as part of the fire protection water supply system, was approved by the NRC.

42 Discharge Pipe 42.a The size of discharge pipe shall be as given in DR Y

CAR-2165-G-209, Discharge piping from each main fire pump is of the following table unless otherwise specified by Rev. 13 12-inch diameter, which meets the code the authority having jurisdiction. (See Table in requirement for 2500 gpm pumps as installed at Code - for 2500 gpm Pumps, a 12-inch SHNPP.

discharge pipe is required).

HNP-M/BMRK-0007 Page 9 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 42.b An approved check valve shall be installed in WD & DR Y

WD An approved 12 check valve (Crane Fig. 1471/2 the discharged pipe. Large fire protection

CAR-2165-G-209, XU) is installed in each main fire pump systems sometimes experience severe water Rev. 13 discharge pipe. Observed conditions and hammer caused by back flow when the

1364-21774, Rev. 0 reviewed documents did not indicate that the use automatic control shuts down the fire pump. An

VM-BJY, Rev. 6, pp. of an anti-water hammer check valve was approved anti-water hammer check valve should 5, 14 warranted.

be installed in the discharge line of a fire pump where conditions may be expected to cause objectionable water hammer with the usual swing type check valve.

42.c Approved indicating gate valves shall be WD & DR JC

WD An approved Crane Fig. 471/2 OS&Y gate valve installed in such places as needed to make the

CAR-2165-G-209, (with Limitorque operator) is installed pump and check valve accessible for repair. Rev. 13 immediately on the system side of the check

FSAR Sec. 9.5.1, p. 23 valve in each main fire pump discharge outlet.

NOTE: This requires a valve on the system side

1364-44080, Rev. 4 Although not of the indicating type, the gate of the check valve and on the supply side of the

VM-BJY, Rev. 6, p. 7 valves are considered acceptable because in pump if the supply may at any time be under a addition to being normally locked open they are head. also electrically supervised via limit switches (Namco) installed on the valves. As such, a valve out of position will provide indication at the LFDCP and the MFDIC, as well as in the Control Room. This set of safety features adequately compensates for the non-indicating configuration of the gate valves.

No gate is required on the supply side of the pump, since the Auxiliary Reservoir water supply will not be under a head.

43 Relief Valve 43.a Pumps connected to adjustable-speed drivers WD & DR Y

WD Both the adjustable-speed engine driven fire shall be equipped with an approved relief valve.

CAR-2165-G-209, pump and the constant-speed motor driven fire Where pumps are driven by constant-speed pump are provided with approved relief valves.

HNP-M/BMRK-0007 Page 10 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) motors and the shut-off pressure plus the static Rev. 13 suction pressure exceeds the pressure for which

1364-2141, Rev. 3 the system is designed to operate, relief valves

1364-2142, Rev. 3 are required.

43.b The relief valve should ordinarily be set to DR Y

SD-149, Rev. 12, Sec. The relief valves for the two main fire pumps prevent pressure on the fire protection system in 3.2 are set at 150 psi. The fire protection system excess of that pressure at which the system was

1364-2141, Rev. 3 design working pressure is 125 psig and the designed to operate.

1364-2142, Rev. 3 maximum design pressure rating is 175 psig.

Line Master List EC 50147 evaluated the impact of the 150 psi

AR 25060 setpoint on system design.

EC 50147 43.c Where provided, relief valves shall be of the size WD & DR Y

WD Relief valves are 6-inch size, which meets the given in the following table. (See Table in Code

CAR-2165-G-209, code requirement for 2500 gpm pumps as

- For 2500 gpm Pumps, a 6-inch relief valve is Rev. 13 installed at SHNPP.

required).

1364-2141, Rev. 3

1364-2142, Rev. 3

FCR-FP-583, Rev. 1

FCR-SP-121, Rev. 0 43.d The relief valves should be located between the WD & DR Y

WD Relief valves are installed between the pump pump and the pump discharge valve.

CAR-2165-G-209, and the discharge gate valve on both main fire Rev. 13 pumps.

FCR-FP-583, Rev. 1

FCR-SP-121, Rev. 0 43.e The relief valve should discharge into an open WD JC

WD Relief valves discharge into cones which are of pipe in plain sight near the pump or into a cone

CAR-2165-G-209, the open port type which can allow the operator or funnel secured to the outlet of the valve. This Rev. 13 to see water wasting through the relief valve.

cone should be so constructed that the pump

1364-2141, Rev. 3 Although the relief valve assemblies are located operator can easily see any water wasting

1364-2142, Rev. 3 below grade elevation in concrete pits and are through the relief valve, and it should be so

FCR-SP-121, Rev. 0 covered by insulation such that relief flow made as to avoid splashing water into the pump

AR 25060 cannot be visibly detected, water flow can be room. If a closed type cone is used, it should be HNP-M/BMRK-0007 Page 11 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) provided with means for detecting motion of observed in the pit areas for the excess flow in water through the cone. The cone should be the discharge cone. This flow provides the piped to a point where water can be freely operator with sufficient knowledge to verify that wasted, preferably outside the building. the pumps are operating in a normal fashion.

Relief valves discharge through fixed 10 piping directly back into the Auxiliary Reservoir. The relief valve discharge-piping configuration is designed per NFPA 13. Insulation is installed on the piping and cone due to freeze protection concerns. Wastewater can be observed in the pits when the pump is running.

43.f If the relief valve waste pipe is connected to an WD & DR N/A

WD Relief valves discharge through fixed 10 piping underground drain, care should be taken that no

CAR-2165-G-209, directly back into the Auxiliary Reservoir. The steam drains enter near enough to work back Rev. 13 requirements of this code section are therefore through the cone and into the pump room.

1364-2141, Rev. 3 not applicable.

Discharge from the relief valves should not be

1364-2142, Rev. 3 piped into the suction connection, except with

FCR-SP-121, Rev. 0 the permission of the authority having jurisdiction.

43.g When the supply of water is taken from a DR Y

FSAR Sec 9.5.1, p. 21 Relief valve waste piping from both main fire suction reservoir of limited capacity, the waste

CAR-2165-G-209, pumps discharges through fixed 10 piping pipe shall drain into such reservoir, entering as Rev. 13 directly back into the Auxiliary Reservoir, and is far from the pump suction as is necessary to

1364-2141, Rev. 3 arranged such that it does not affect pump prevent the pump from drafting air which may

1364-2142, Rev. 3 suction.

be carried down by the discharge from the waste

FCR-SP-121, Rev. 0 pipe.

43.h The relief valve waste pipe from an open cone DR JC

CAR-2165-G-209, The installed 10-inch diameter waste piping, should not be smaller than specified below; if Rev. 13 which features 2 elbows, does not meet the code more than one elbow is employed the next size

FCR-SP-121, Rev. 0 requirement for an open cone configuration for larger pipe should be used to complete the 2500 gpm pumps where more than one elbow as connection. (See Table in Code - for Pumps installed at SHNPP. However, the configuration HNP-M/BMRK-0007 Page 12 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 2000-2500 gpm, a 10-inch pipe is required, or a is considered acceptable based on the 12-inch pipe if more than one elbow is used). modifications per FCR-SP-121, which added deflector shields to the relief cones and bored drainage holes in the bottom of the pits to promote drainage.

43.i The relief valve waste pipe from a closed cone DR N/A

CAR-2165-G-209, Relief valve waste piping is to an open cone.

shall be sized to prevent back pressure in excess Rev. 13 The requirements of this code section are of 8 psi.

FCR-SP-121, Rev. 0 therefore not applicable.

43.j The relief valve shall be so attached as to permit WD & DR Y

WD Relief valves are attached to the piping with of its ready removal for repairs without

1364-2141, Rev. 3 standard bolted flanged fittings, and are located disturbing the waste piping.

1364-2142, Rev. 3 such that they may be readily removed.

FCR-SP-121, Rev. 0 However, the entire relief valve assemblies are covered with insulation which would require removal prior to disassembly of the valves.

Since removal of the insulation is possible to enable removal / repair of the relief valves, the intent of the code is met.

44 Hose Valves 44.a Approved 21/2-inch hose valves of the number WD & DR Y

WD A test manifold featuring eight approved 21/2-specified in Paragraph 44b shall be provided for

CAR-2165-G-209, inch hose valves is located at the ESWISS use in testing the pumps. The hose valves Rev. 13 facility, and is installed in a metal enclosure should ordinarily be attached to a header or adjacent to the main motor driven fire pump (the manifold; they shall be connected by suitable enclosure is situated over the pit which contains piping to the pump discharge piping, preferably the main fire pump discharge piping and valves).

at a point between the discharge check valve and The test manifold is connected to both main fire the discharge gate valve. The hose valves pumps, by suitable 12 piping, at a point should be so located as to avoid any possible between the discharge check valve and the water damage to the driving motor or engine or discharge gate valve. The hose valves, since their controllers, and should preferably be they are in an enclosure separate from the pumps outside the pump room. Where located outside, and their controllers, are unlikely to cause water or at a distance from the pump, and there is any damage upon their discharge. The manifold and HNP-M/BMRK-0007 Page 13 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) danger of freezing, an approved indicating gate supply piping is insulated and supplied with an valve and drain valve shall be located in the line approved drain valve. The metal enclosure is to the hose valves at a point close to the pump. also provided with a heating unit.

44.b Unless otherwise specified by the authority WD & DR Y

WD Eight hose valves are provided as described in having jurisdiction, the number of hose valves

CAR-2165-G-209, Section 44.a, meeting the code requirement for shall be as given in the following table, except Rev. 13 2500 gpm fire pumps as installed at SHNPP.

that for special service fire pumps and for booster pumps, only one hose valve is required for five hundred gallon or smaller pumps. (See Table in Code - For 2500 gpm pumps, 8 hose valves are required) 44.c Where water disposal may be a problem, there DR N/A

CAR-2165-G-209, Water can be readily discharged into the should be installed a fixed nozzle(s) or pipe Rev. 13 Auxiliary Reservoir, which is located outlet arranged to discharge at an appropriate immediately adjacent to the hose valve place, or an approved metering device in a pipe manifold. The requirements of this code section line discharging back into the suction supply, for are therefore not applicable.

use in making a flow test to the full capacity of the pump or pumps. (See Section 912.) With such test arrangements, the authority having jurisdiction may permit a reduction in the number of hose valves to the number needed for hose stream use.

44.d Hose valves shall be threaded to conform to the DR Y

CAR-2165-G-209, Hose valves installed in the fire pump test American (National) Standard B26-1925 for Rev. 13 manifold feature National Standard threads.

Fire Hose Coupling Screw Threads. Adapter couplings securely attached to each outlet shall be provided if local couplings are not American Standard.

44.e When 2 hose valves are required, use 4-inch DR Y

CAR-2165-G-209, Discharge pipe for the test manifold is of 12-pipe between the header and the connection to Rev. 13 inch diameter, which exceeds the 8-inch discharge piping; when 3 or 4 are required use minimum pipe size required for an eight-valve 6-inch piping; when 6 or 8 are required use 8- manifold (the pipe is less than 15 feet long).

HNP-M/BMRK-0007 Page 14 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) inch pipe. When this pipe is over 15 feet long increase one pipe size.

45 Pressure Gages 45.a A pressure gage having a dial not less than 31/2 WD Y

WD Pressure gages having a diameter of at least 31/2 in. in diameter shall be connected near the inches in size are installed on the discharge of discharge casting by a 1/4-in. cock with lever each pump. The gage dials read to 300 psi handle. The dial shall indicate pressure to at which is more than twice the 125 psi working least twice the rated working pressure of the pressure of the pumps. The dials read in units of pump but not less than 200 psi. The face of the psi, and are graduated at 10 psi intervals.

dial shall read in pounds per square inch with the manufacturers standard graduations.

45.b A compound pressure and vacuum gage having WD N/A

WD SHNPP fire pumps are of the vertical shaft a dial not less than 31/2 in. in diameter shall be turbine type. The requirements of this code connected to the suction pipe near the pump section are therefore not applicable.

(except in the case of vertical shaft turbine type pumps). The face of the dial shall read in pounds per square inch for the suction range and have a maximum pressure range not less than twice the rated working pressure of the pump, or a lower pressure range may be furnished if the gage is protected from damage by a gage protector.

46 Circulation Relief Valve to Prevent Overheating WD & DR N/A

WD The main fire pumps are automatic vertical shaft

- Pumps which are automatically controlled

CAR-SH-M-20, Rev. turbine pumps, and are classified as submerged shall be provided with a 3/4-inch relief valve set 2, Sec. 5 type pumps. The diesel engine for the engine slightly below the shut-off pressure and arranged

VM-MJD, Rev. 6, p. driven fire pump is cooled by raw water which to permit circulation of sufficient water to 0-20 is supplied from the fire pump prior to the pump prevent the pump from overheating when discharge flange. The requirements of this code operating with no discharge. A 3/4 inch relief section are therefore not applicable.

valve shall be used for pumps with a rated capacity of 500 to 2500 gpm; a one-inch relief valve shall be use for pumps with a rated HNP-M/BMRK-0007 Page 15 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) capacity of 3000 to 4500 gpm. This is not needed for submerged type pumps nor for engine driven pumps for which engine cooling water is taken from the pump discharge. Pumps which are manually controlled shall be equipped with either such a relief valve or with a test valve as specified in Section 133. Provision should be made for discharge to a drain.

47 Summary of Pump Data N/A This section summarizes information from preceding sections designating pump capacities and corresponding required discharge piping sizes, relief valve sizes, relief waste line sizes, and numbers of hose valves.

50 Power Supply 51 Dependability of Power Supply - Careful DR Y

FSAR Sec. 9.5.1, p. 22 Power for the electric motor driven fire pump is consideration must be given in each case to the

SD-149, Rev. 12, Sec. supplied from 480V General Services Bus 1-dependability of the power supply not 5.1 4A101 (compartment 5A) power center, which overlooking the possible effect on transmission

CAR-2166-B-041, Sh. is fed from a 6.9kV switchgear that has an lines of fire in the property or in adjoining 79, Rev. 6 alternate feed through a bus tie with another buildings which might threaten the property. 6.9kV switchgear.

Chapter Vertical Shaft Turbine-Type Pumps 200 210 General 211 Suitability. The deep well turbine-type pump is DR N/A FSAR Sec. 9.5.1, p. 22 This section describes vertical-type fire pumps particularly suitable for fire pump service when and states that either oil-lubricated or water-the source of water is located below the surface lubricated vertical pumps are acceptable. No of the ground and it would be difficult to install verification is required. SHNPP uses vertical any other type of pump below the minimum shaft turbine centrifugal fire pumps.

water level. It is a vertical shaft centrifugal pump with rotating impellers suspended from the pump head by a column or eduction pipe HNP-M/BMRK-0007 Page 16 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) which also serves as a support for the shaft and bearings. It was originally designed for installation in bored wells, but may also be used to lift water from lakes, streams, open sumps and other sub-surface sources. Oil-lubricated enclosed line shaft or water-lubricated open line shaft pumps will be acceptable.

212 Maximum Depth. Wells should not be DR N/A

FSAR Sec. 9.5.1, p. 22 SHNPP fire protection water is supplied from considered as a source of supply for fire pump the Auxiliary Reservoir rather than from a well.

service where the water level when pumping at The requirements of this code section are 150 per cent capacity exceeds 200 feet from the therefore not applicable.

surface of the ground. In all applications where the water level is expected to exceed 50 feet the authority having jurisdiction shall be supplied with data on the draw-down characteristics of the well and the pump performance to determine the available discharge pressure at the discharge flange of the vertical pump.

213 Acceptable Drive. These pumps may be WD & DR Y

WD There are two vertical shaft turbine fire pumps operated by vertical shaft electric motor or,

FSAR Sec. 9.5.1, p. 22 installed at SHNPP. One is operated by a when equipped with a suitable right angle gear

CAR-SH-M-20, Rev. vertical shaft electric motor, and the other is drive, they may be operated by an internal 2, Sec. 5 equipped with a right angle gear drive and combustion engine or a steam turbine. Careful operated by a diesel engine. The electric motor consideration must be given in each case to the power supply is as discussed in Section 51. The dependability of the source of power. diesel engine fuel is supplied by a 550 gallon No. 2 diesel oil tank located adjacent to the ESWISS.

214 Supervision of Installation. Satisfactory DR JC

CAR-SH-M-20, Rev. The referenced specification required the pump operation of vertical turbine-type pumps is 2, Sec. 13.5 and 15 seller to be responsible for the proper dependent to a large extent upon careful and

VM-EIZ, Rev. 5, specification of installation and operating correct installation of the unit; therefore, it is Sections 1 and 5 procedures for the complete drive equipment recommended that this work be done under and engine assembly, as well all motor and HNP-M/BMRK-0007 Page 17 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) direction of a representative of the pump engine requirements. It also required submittal manufacturer. by the seller of schedules for fabrication of items, tests, etc. The referenced vendor manual sections contain an installation, operation and maintenance manual which includes detailed step-by-step instructions for installation of the provided fire pumps. Although actual supervision of the installation by the seller was not specified, the reviewed documentation provides reasonable assurance that an adequate level of guidance was provided by the pump supplier. Also, the pump has been in service and subjected to ongoing testing and maintenance for over 25 years.

215 Performance. Pumps shall furnish not less than DR Y

CAR-SH-M-20, Rev. The main fire pumps are rated at 2500 gpm at 150 percent of rated capacity at a total head of 2, Sec. 6.01 and 6.02 294 feet of water (125 psi). At initial tests, the not less than 65 per cent of the total rated head.

1364-2156, Rev. 0 pumps delivered the following:

The shut-off total head shall not exceed 140 per

1364-2157, Rev. 0 cent of total rated head. GPM Head (ft.) Head (psi) % of Rated 2500 (100%) 294 127 100 3750 (150%) 253 110 881 0 (Shutoff) 387 167 1312 1

Greater than or equal to 65 - per code.

2 Less than or equal to 140 - per code.

Pump test results demonstrated that the two main fire pumps are capable of the performance required by this code section.

220 Water Supply 221 Source HNP-M/BMRK-0007 Page 18 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 221.a The water supply shall be acceptable to the DR Y

NUREG-1038, p. 9-51 The fire protection water supply system was authority having jurisdiction. Stored water

FSAR Sec. 9.5.1, p. 20 approved by the NRC.

supplies from reservoirs or tanks supplying wet

SD-149, Rev. 12, Sec. Fire protection water for the plant is taken from pits are preferable. Lakes, streams and ground 3.1 the fresh water supply impounded in the water supply may be acceptable where

OP-149, 17, Sec 3.3 Auxiliary Reservoir, which has an area of 317 investigation shows that they can be expected to

CAR-2165-G-209, acres at an approximate depth of 14 feet. The provide a suitable and reliable supply. Rev. 13 storage capacity greatly exceeds the calculated 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months fire protection water supply requirement (including system demand, hose stream, reserve supply, and makeup re-supply) which totals 1,440,000 gallons. The reservoir has been designed with seismic considerations to assure availability of the safety related water supplies (which it provides in addition to fire protection water). The quality of water in the reservoir is suitable for use in fire protection systems.

Traveling screens are provided at the intake structure for the removal of larger impurities which may be present in the water. The Auxiliary Reservoir water level is required to be at least 248 (centerline of fire pump discharge pipes is at 257-81/2).

221.b The acceptance of a well as a source of water DR N/A

FSAR Sec. 9.5.1, p. 20 Fire protection water for the plant is taken from supply shall be dependent upon satisfactory

SD-149, Rev. 12, Sec. the fresh water supply impounded in the development of the well. The authority having 3.1 Auxiliary Reservoir, as described in Section jurisdiction may require an aquifer performance 221.a above, rather than from a well. The analysis. The history of the water table should requirements of this code Section are therefore be carefully investigated. The number of wells not applicable.

already in use in the area and the probable number that may be in use should be considered in relation to the total amount of water available.

HNP-M/BMRK-0007 Page 19 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 222 Pump Submergence 222.a Proper submergence of the pump must be DR Y

1364-1675, Rev. 1 The main fire pumps are properly submerged as provided for reliability of operation of the fire

1364-1676, Rev. 1 discussed in Section 222.b, which applies to pump unit.

CAR-2165-G-209, SHNPP fire pumps.

Rev. 13

OP-149, 17, Sec 3.3 222.b Wet Pit Installations. The minimum DR Y

1364-1675, Rev. 1 For both SHNPP main fire pumps, the top of the submergence should be such that the second

1364-1676, Rev. 1 pump column assembly (also the elevation of impeller from the bottom of the pump bowl

CAR-2165-G-209, the concrete slab on which the aboveground assembly will be below the lowest standing Rev. 13 portion or the pump assemblies rest) is 262-0 water level in the open body of water supplying

OP-149, 17, Sec 3.3 above sea level. The top of the pump bowl the pit. The minimum submergence shall be assemblies is 14-6 3/16 inches lower, at 247-5 increased by one foot for each 1000 feet of 13/16 elevation. Since the Auxiliary Reservoir elevation above seal level. water level is required to be at least 248-0 above sea level, the entire pump bowl assemblies (including all impellers) will always be submerged. This exceeds the requirements of this code section.

Since the elevation of the pump assemblies is less than 1000 feet above sea level, no increase is applied to the minimum required submergence.

222.c Well Installations. Submergence of the second DR N/A

FSAR Sec. 9.5.1, p. 20 Fire protection water for the plant is taken from impeller from the bottom of the pump bowl

SD-149, Rev. 12, Sec. the fresh water supply impounded in the assembly should be 10 feet below the pumping 3.1 Auxiliary Reservoir, as described in Section water level at 150 per cent of rated capacity. 221.a above, rather than from a well. The requirements of this code Section are therefore not applicable.

223 Well Construction 223.a It shall be the ground water supply contractor's DR N/A

FSAR Sec. 9.5.1, p. 20 Fire protection water for the plant is taken from HNP-M/BMRK-0007 Page 20 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) responsibility to make one or more test holes, if

SD-149, Rev. 12, Sec. the fresh water supply impounded in the necessary, in search of water-bearing formation, 3.1 Auxiliary Reservoir, as described in Section develop a well to meet the required water 221.a above, rather than from a well. The production necessary for a specific pump, to requirements of this code Section are therefore perform all work and install all equipment in a not applicable.

thorough and workmanlike manner.

332.b Each well completed must be of ample diameter DR N/A

FSAR Sec. 9.5.1, p. 20 Fire protection water for the plant is taken from and depth and sufficiently straight to receive the

SD-149, Rev. 12, Sec. the fresh water supply impounded in the pump. The turbine-type pump is designed to 3.1 Auxiliary Reservoir, as described in Section operate in a vertical position with all parts in 221.a above, rather than from a well. The correct alignment; it cannot operate in a crooked requirements of this code Section are therefore well unless the turbine unit hangs freely without not applicable.

being cramped.

224 Unconsolidated Formations 224.a All casings shall be steel of such diameter and DR N/A

FSAR Sec. 9.5.1, p. 20 Fire protection water for the plant is taken from installed to such depths as the formation may

SD-149, Rev. 12, Sec. the fresh water supply impounded in the justify and in the contractor's opinion best meet 3.1 Auxiliary Reservoir, as described in Section the conditions. Both inner and outer casing shall 221.a above, rather than from a well. The conform to the thickness and weight in Table requirements of this code Section are therefore 224. (See Table 224). not applicable.

224.b Outer casing shall extend down to DR N/A

FSAR Sec. 9.5.1, p. 20 Fire protection water for the plant is taken from approximately the top of the water-bearing

SD-149, Rev. 12, Sec. the fresh water supply impounded in the formation. The inner casing of lesser diameter 3.1 Auxiliary Reservoir, as described in Section and well screen shall extend into the water- 221.a above, rather than from a well. The bearing formation as the water-bearing stratum requirements of this code Section are therefore encountered may justify and, in the contractor's not applicable.

opinion, best meet the conditions.

224.c It should be emphasized that the well screen is a DR N/A

FSAR Sec. 9.5.1, p. 20 Fire protection water for the plant is taken from vital part of the well construction and careful

SD-149, Rev. 12, Sec. the fresh water supply impounded in the attention should be given to its selection. It shall 3.1 Auxiliary Reservoir, as described in Section be the same nominal diameter as the inner 221.a above, rather than from a well. The HNP-M/BMRK-0007 Page 21 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) casing and of the proper length to provide for requirements of this code Section are therefore the quantity of water to be developed. The not applicable.

screen shall be made of stainless steel material (304) except that Monel metal shall be used where it is anticipated that the chloride content of the well water will exceed 1000 parts per million. The screen shall have adequate strength to resist the external forces that will be supplied after it is installed and to minimize the likelihood of damage during the installation.

224.d The bottom of the well should be sealed DR N/A

FSAR Sec. 9.5.1, p. 20 Fire protection water for the plant is taken from properly with a cement plug or a plate of the

SD-149, Rev. 12, Sec. the fresh water supply impounded in the same material as the screen. The sides of the 3.1 Auxiliary Reservoir, as described in Section outer casing should be sealed by the introduction 221.a above, rather than from a well. The of neat cement placed under pressure from the requirements of this code Section are therefore bottom to the top. not applicable.

224.e The immediate area surrounding the well screen DR N/A

FSAR Sec. 9.5.1, p. 20 Fire protection water for the plant is taken from should be properly prepared with clean and

SD-149, Rev. 12, Sec. the fresh water supply impounded in the well-rounded gravel of such size and quantity as 3.1 Auxiliary Reservoir, as described in Section will create a gravel filter to insure a low velocity 221.a above, rather than from a well. The and friction loss of water leaving the water- requirements of this code Section are therefore bearing formation and entering the well. not applicable.

225 Consolidated Formations. Where wells take DR N/A

FSAR Sec. 9.5.1, p. 20 Fire protection water for the plant is taken from their supply from consolidated formations, such

SD-149, Rev. 12, Sec. the fresh water supply impounded in the as rock, the specifications should be decided 3.1 Auxiliary Reservoir, as described in Section upon by the authority having jurisdiction upon 221.a above, rather than from a well. The consultation with a recognized ground water requirements of this code Section are therefore consultant in the area. In instances where the not applicable.

drilling penetrates unconsolidated formations above the rock, surface casing shall be installed, seated in solid rock and cemented in place.

HNP-M/BMRK-0007 Page 22 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 226 Developing a Well. Developing a new well and DR N/A

FSAR Sec. 9.5.1, p. 20 Fire protection water for the plant is taken from cleaning it of sand (not to exceed five parts per

SD-149, Rev. 12, Sec. the fresh water supply impounded in the million) shall be the ground water supply 3.1 Auxiliary Reservoir, as described in Section contractor's responsibility and should be done 221.a above, rather than from a well. The with a test pump and not the new fire pump requirements of this code Section are therefore which could be ruined before it is placed in not applicable.

service. Freedom from sand shall be determined when the test pump is operating at 150 per cent of rated capacity of the fire pump for which the well is being prepared.

227 Test and Inspection of a Well 227.a A test to determine the water production of the DR N/A

FSAR Sec. 9.5.1, p. 20 Fire protection water for the plant is taken from well shall be made with an acceptable typed of

SD-149, Rev. 12, Sec. the fresh water supply impounded in the water measuring device such as an orifice, a 3.1 Auxiliary Reservoir, as described in Section venturi meter or a calibrated pitot tube, and shall 221.a above, rather than from a well. The be witnessed by a representative of the requirements of this code Section are therefore customer, contractor and authority having not applicable.

jurisdiction, as required. The test shall be continuous for a period of at least eight hours at 150 per cent of the rated capacity of the fire pump, with averaged hourly readings over the test period. The test should be evaluated in the light of the effect of other wells in the vicinity and any possible seasonal variation in the water table at the well site. Test data shall describe the static water level at 100 and 150 percent of the rated capacity of the fire pump for which the well is being prepared.

227.b The well work completed by the ground water DR N/A

FSAR Sec. 9.5.1, p. 20 Fire protection water for the plant is taken from supply contractor should be carefully examined

SD-149, Rev. 12, Sec. the fresh water supply impounded in the and it there is some doubt about straightness of 3.1 Auxiliary Reservoir, as described in Section well, gaging and plotting is recommended 221.a above, rather than from a well. The HNP-M/BMRK-0007 Page 23 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) before acceptance of the well. requirements of this code Section are therefore not applicable.

227.c Before the permanent pump is ordered, the water DR N/A

FSAR Sec. 9.5.1, p. 20 Fire protection water for the plant is taken from in the well should be analyzed for corrosiveness

SD-149, Rev. 12, Sec. the fresh water supply impounded in the including such items as pH, salts such as 3.1 Auxiliary Reservoir, as described in Section chlorides, harmful gases such as carbon dioxide 221.a above, rather than from a well. The (CO2) or hydrogen sulfide (H2S). If the water is requirements of this code Section are therefore corrosive, the pumps should be constructed of a not applicable.

suitable corrosion -resisting material such as bronze or red brass in accordance with chemical analysis and experience in the area.

230 Pump 231 Discharge Head. The discharge head should be DR JC

1364-1675, Rev. 1 The pump discharge head for both main fire of the aboveground type. In every case the

1364-1676, Rev. 1 pumps is of the underground type (it is installed discharge head shall be designed to support the

VM-EIZ, Rev. 5, pp. below the top of concrete slab elevation within driver, the pump column and the oil tube tension S5-45, S5-46 the ESWISS concrete foundation). This nut or packing container. The discharge head arrangement was tested and approved by FM for shall also act as a water passage to direct the the SHNPP installations, and is therefore water from the column into the discharge considered to meet the intent of this code fittings. section. Although the discharge head is below the concrete slab, the above ground portion of the assembly includes a pedestal which is designed to support the driver, the pump column and the packing container. The discharge head acts as a water passage to direct the water from the column into the discharge fittings.

232 Pump Column 232.a The column shall be furnished in sections not DR Y

VM-EIZ, Rev. 5, pp. Columns for the main fire pumps were furnished exceeding a nominal length of 10 feet, shall be S1-4, S1-5, S1-16 in standard ten-foot sections and are connected of minimum weight conforming to

FSAR Sec. 9.5.1, p. 21 by threaded sleeve type couplings, with column specifications in Table 232, and shall be pipes machined for straight thread, butt joint HNP-M/BMRK-0007 Page 24 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) connected by threaded sleeve type or flange type construction. Although no reviewed documents couplings. The ends of each section of threaded specified column weight, it can be reasonably pipe shall be faced parallel and machined with concluded to meet the requirements of this code threads to permit the ends to butt so as to form section based on the approval/listing of both accurate alignment of pump column. All pumps for fire service.

column flange faces shall be parallel and machined for rabbet fit to permit accurate alignment.

232.b Open line shaft water-lubricated columns shall DR N/A

CAR-SH-M-20, Rev. The main fire pumps feature open line shaft not be used where the distance from the pump 2, Sec. 7.2 water-lubricated columns. However, since the head to the static water level exceeds 50 feet.

VM-EIZ, Rev. 5, p. distance from the main pump heads to the S1-5 Auxiliary Reservoir minimum static water level

1364-1675, Rev. 1 is 12-0 (262-0 minus 248-0), the

1364-1676, Rev. 1 requirements of this code section are not

CAR-2165-G-209, applicable.

Rev. 13

OP-149, 17, Sec 3.3 232.c If the pump is to be of the enclosed line shaft oil DR N/A

CAR-SH-M-20, Rev. The main fire pumps feature water-lubricated lubricated type the shaft enclosing tube shall be 2, Sec. 7.2 columns. The requirements of this code section furnished in interchangeable sections not over are therefore not applicable.

10 feet in length, of extra strong pipe. An automatic sight feed oiler shall be provided on a suitable mounting bracket with connection to the shaft tube for oil lubricated pumps.

233 Bowl Assembly 233.a The pump bowl shall be of close-grained cast DR Y

VM-EIZ, Rev. 5, p. The pump bowl for both main pumps is of close-iron or bronze, and provided with bronze S1-16 grained cast iron. The bowl bearings are dual wearing rings or other suitable material in high lead bronze and rubber.

accordance with the chemical analysis of the water and experience in the area, as per Paragraph 224b.

HNP-M/BMRK-0007 Page 25 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 233.b Impellers shall be of bronze of the enclosed or DR Y

VM-EIZ, Rev. 5, pp. Both main fire pumps feature enclosed type semi-open type. S1-16, S6a-8 bronze impellers.

234 Suction Strainer 234.a A cast or heavy fabricated type of non-ferrous WD & DR Y

WD A bronze basket type strainer is attached at the cone or basket type strainer shall be attached to

VM-EIZ, Rev. 5, pp. suction inlet for each pump. Based on assembly the suction manifold of the pump. The suction S1-16, S6a-8 drawing dimensions, the suction strainer free strainer shall have a free area of at least four

1364-1675, Rev. 1 area is four times the area of the suction opening times the area of the suction connections and the

1364-1676, Rev. 1 for each pump. Field inspection verified that the openings shall be of such size to restrict the strainer openings are less than 1/2- inch in size.

passage of a 1/2 inch sphere.

234.b This suction strainer shall be required in DR Y

VM-EIZ, Rev. 5, pp. Suction strainers are provided for both main fire addition to intake screen, specified under S1-16, S6a-8 pumps.

Paragraph 143m.

1364-1675, Rev. 1

1364-1676, Rev. 1 235 Fittings 235.a The following fittings to be furnished by the DR Y

1364-1675, Rev. 1 All applicable fittings designated by this code pump manufacturer shall be required for

1364-1676, Rev. 1 section were provided by the pump vendor for attachment to the pump:

CAR-2165-G-209, attachment to the main fire pumps.

Discharge tee or elbow. Rev. 13 (For each referenced code Section, see the Hose valve head (separable type), Section 44.

corresponding section of this checklist for Hose valves, Section 44.

applicability and detailed SHNPP compliance Automatic air release valve and fittings, discussion).

Paragraph 235b.

Discharge gage conforming to Section 45.

Relief valve and discharge cone, when required by Section 43.

Water level testing device, Paragraph 235c.

235.b A 1 1/2-inch or larger automatic air release WD & DR Y

WD Both main fire pumps are provided with a 2-inch valve is required to vent air from the column and

CAR-2165-G-209, automatic air & vacuum release valve, located in discharge head upon starting the pump and also Rev. 13 the horizontal discharge line between the pump to serve to admit air to the column to dissipate

1364-2141, Rev. 3 and the discharge check valve HNP-M/BMRK-0007 Page 26 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) the vacuum when the pump is stopped. This

1364-2142, Rev. 3 valve shall be located at the highest point in the discharge line between the fire pump and the discharge check valve.

235.c Each pump installed in a well must be equipped DR N/A

FSAR Sec. 9.5.1, p. 20 SHNPP fire pumps are not installed in wells.

with a suitable water level detector. The air line

SD-149, Rev. 12, Sec. The requirements of this code Section are method (Section 236) is considered as a 3.1 therefore not applicable.

satisfactory method of determining depth of water level. This device should be permanently installed.

236 Air Line Method of Water Level Detection 236.a A satisfactory method of determining the water DR N/A

FSAR Sec. 9.5.1, p. 20 SHNPP fire pumps are not installed in wells.

level involves the use of an air line of small pipe

SD-149, Rev. 12, Sec. The requirements of this code Section are or tubing and of known vertical length, a 3.1 therefore not applicable.

pressure or depth gage, and an ordinary bicycle or automobile pump installed as shown by Fig.

236. The air line pipe should be of known length and extend beyond the lowest anticipated water level in the well in order to assure more reliable gage readings and should be properly installed.

As noted in Fig. 236 an air pressure gage is used to indicate the pressure in the air line.

236.b The air line pipe is lowered into the well, a tee is DR N/A

FSAR Sec. 9.5.1, p. 20 SHNPP fire pumps are not installed in wells.

placed in the line above the ground, and a

SD-149, Rev. 12, Sec. The requirements of this code Section are pressure gage is screwed into one connection 3.1 therefore not applicable.

and the other is fitted with an ordinary bicycle valve to which a bicycle pump is attached. All joints must be made carefully and must be air tight to obtain correct information. When air is forced into the line by means of the bicycle pump the gage pressure increases until all the water has been expelled. When this point is HNP-M/BMRK-0007 Page 27 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) reached the gage reading becomes constant. The maximum maintained air pressure recorded by the gage is equivalent to that necessary to support a column of water of the same height as that forced out of the air line. The length of this water column is equal to the amount of air line submerged.

236.c Deducting this pressure converted to feet (psi DR N/A

FSAR Sec. 9.5.1, p. 20 SHNPP fire pumps are not installed in wells.

pressure x 2.31 = feet) from the known length of

SD-149, Rev. 12, Sec. The requirements of this code Section are the air line will give the amount of 3.1 therefore not applicable.

submergence.

240 Installation 241 Pump House. The pump house should be of such WD & DR N/A

WD SHNPP fire pumps are not located in a pump character as will offer the minimum obstruction

CAR-2165-G-209, house. The requirements of this code section are to the convenient handling and hoisting of Rev. 13 therefore not applicable.

vertical pump parts. Otherwise the requirements Reference Sections 41 and 666 for discussion of of Section 41 and Section 666 should apply.

applicability and associated compliance.

242 Outdoor Setting. If in special cases the authority WD & DR JC

WD SHNPP fire pumps, which are suitable for having jurisdiction does not require a pump

CAR-SH-M-20, Rev. outdoor service, are not located in a pump room and the unit motor is installed outdoors the 2, Sec. 5.05, 5.06, 13.5 house. The installed fire pump configuration, as motor shall be screened, and adequately

VM-EIZ, Rev. 5, p. part of the fire protection water supply system, protected against tampering. The screen should S4-4 was approved by the NRC. Sheet metal be easily removable and provision made for

NUREG-1038, p. 9-51 screening, which provides ample ventilation and ample ventilation. A sheet metal on iron frame is

NAS Fire Protection can be easily removed, is provided around the better than wood. Audit H-FP-00-01 electric driven fire pump motor. Also, the diesel

AR 25060 driven fire pump engine, drive shaft, and right angle drive are similarly protected by metal screening or metal enclosures. However, access to the HNP fire pump motor is not limited due to the open gate at the ESWISS. For justification HNP-M/BMRK-0007 Page 28 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) of the acceptability of this condition, see Attachment 6.

243 Foundation 243.a The pump foundation for vertical type pumps DR Y

CAR-2165-G-209, Both main fire pumps have as their foundation should be substantially built to carry the weight Rev. 13 the concrete structure which is also the of the entire pump full of water and the driver. It foundation for the ESWISS building. As such, should be rigid enough to withstand and prevent the pump foundation far exceeds the any vibration. Area of the base of foundation requirements of this code section in terms of should extend at least 3 inches beyond the pump adequate size, strength and rigidity.

head base plate on all sides and be of sufficient area strength so that the load per square foot on concrete does not exceed the ordinary foundation standards, or two I-beams of sufficient length and weight may be used on either side of well.

243.b Certified prints can be obtained from the pump DR N/A

CAR-2165-G-209, As described in section 243.a above, the pump manufacturer giving the necessary dimensions. Rev. 13 foundation size far exceeds that required by the code. The recommendation of this code section is therefore not applicable.

243.c Top of the foundation shall be carefully leveled DR Y

CAR-2165-G-209, Both main fire pumps have as their foundation to permit the pump to hang free in the well. Rev. 13 the concrete structure which is also the foundation for the ESWISS building. It can therefore be reasonably assumed that the top of the pump foundations was properly leveled per the requirements of this code section.

243.d Where pump is mounted on I-beam over a pit DR N/A

CAR-2165-G-209, Both main fire pumps are mounted on concrete.

the right angle gear housing and driver should Rev. 13 The requirements of this code section are always be installed parallel to beams, never at therefore not applicable.

right angle.

244 Method of Erecting HNP-M/BMRK-0007 Page 29 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 244.a Several methods of installing a vertical pump DR JC

VM-EIZ, Rev. 5, The referenced vendor manual sections contain may be followed, depending upon the location Sections 1 and 5 an installation, operation and maintenance of the well and facilities available. Since most of manual which includes detailed instructions for the pump unit is underground, extreme care installation of the provided fire pumps.

must be used in assembling and installing it and Although actual supervision of the installation thoroughly checking the work as it progresses. by the seller was not specified, the reviewed The installation should be made under documentation provides reasonable assurance supervision of a representative of the pump that an adequate level of guidance was provided manufacturer. by the pump supplier. Also, this code section does not specify a strict requirement, rather, it provides guidance and recommendations.

Additionally, the pumps have been in service and functioning properly for over 25 years.

244.b The following simple method is the most DR JC

VM-EIZ, Rev. 5, The referenced vendor manual sections contain common. Sections 1 and 5 an installation, operation and maintenance

1. Construct a tripod or portable derrick manual which includes detailed instructions for and use two sets of installing clamps installation of the provided fire pumps.

over open well or pump house. After Although the method described in this code the derrick is in place the alignment section was not specified, the information should be checked carefully with the contained in the vendor manual provides well or suction pit to avoid any trouble reasonable assurance that the installations were when setting the pump. performed in accordance with the

2. Attach set of clamps to the suction manufacturers specifications. Also, this code pipe on which strainer has already been section does not specify a strict requirement, placed and lower into the well until rather, it provides guidance and clamps rest on block beside well casing recommendations. Additionally, the pumps have or on pump foundation. been in service and functioning properly for

3. Attach clamps to pump stage assembly over 25 years.

and bring over well and install pump stages to suction pipe, etc., until each piece has been installed in accordance with manufacturer's instructions.

HNP-M/BMRK-0007 Page 30 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 245 Setting Impellers. The setting of the impellers DR JC

VM-EIZ, Rev. 5, The referenced vendor manual sections contain should only be undertaken by a representative of Sections 1 and 5 an installation, operation and maintenance the pump manufacturer. Improper setting will manual which includes detailed instructions for develop excessive friction loss by rubbing of installation of the provided fire pumps, impellers on pump seals with resultant increase including impeller adjustment. Although actual in power demand. If adjusted too high there will supervision of the installation by the seller was be a loss in capacity; full capacity is vital for fire not specified, the information contained in the pump service. The top shaft nut should be vendor manual provides reasonable assurance locked or pinned after proper setting. that the installations were performed in accordance with the manufacturers specifications. Also, this code section does not specify a strict requirement, rather, it provides guidance and recommendations. Additionally, the pumps have been in service and functioning properly for over 25 years.

250 Driver 251 Method of Drive 251.a The pump may be driven by a vertical hollow DR Y

VM-IJX, Rev. 16, p. One of the two SHNPP main vertical turbine fire shaft electric motor or right angle gear drive or S2-7 pumps is driven by a vertical hollow shaft dual drive with internal combustion engine or

1364-1742, Rev. 1 electric motor having a minimum bearing life of steam turbine. The driver provided must be so

VM-UJL, Rev. 0 121/2 years at 7675 lbs. downthrust. The other constructed that the total thrust of the pump,

CAR-SH-M-20, Rev. fire pump is driven by a right angle gear drive which includes the weight of the shaft, 2, Sec.12A.10, 12B.11, with internal combustion (diesel) engine, having impellers, and the hydraulic thrust, can be 13.5 a minimum bearing life well over five years.

carried on a thrust bearing of ample capacity so Additionally, the referenced specification that it will have an average life rating of five- required that the engines shall be specifically year continuous operation. All drivers must be approved by UL or FM for fire pump service, so constructed that axial adjustment of impellers providing reasonable assurance that the can be made to permit proper installation and requirements of this code section are fulfilled.

operation of the equipment.

251.b Motors shall be direct connected, of the vertical, DR Y

VM-IJX, Rev. 16, p. The electric driven fire pump motor is direct hollow shaft type, drip proof, normal starting connected, of the vertical, hollow shaft type, HNP-M/BMRK-0007 Page 31 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) torque, low starting current, squirrel cage S2-7 shielded (drip-proof), normal starting torque, induction type. The motor shall be equipped

1364-1742, Rev. 1 squirrel cage induction type, equipped with a with an antireverse ratchet. non-reverse coupling.

251.c Gear drives must be acceptable to the authority DR Y

VM-UJL, Rev. 0 The right angle gear drive is of the hollow shaft having jurisdiction. Gear drives shall be of the

NUREG-1038, p. 9-51 type and is equipped with non-reverse dowel hollow shaft type, permitting adjustment of the pins. The gear drive, as part of the fire pump impellers for proper installation and operation of assembly and fire water supply system, was the equipment. The gear drive shall be equipped approved by the NRC.

with an antireverse ratchet.

251.d Where internal combustion engines under DR N/A

FSAR Sec. 9.5.1, p. 22 The SHNPP diesel driven main fire pump is manual control are used, it shall be the pump designed for automatic starting. The manufacturer's responsibility to furnish a requirements of this code section are therefore coupling of suitable design which will prevent not applicable.

undue strain on either the engine or pump by reverse operation. Automatic starters are equipped with an antidieseling device which serves to prevent reverse operation from self ignition during compression.

251.e If dual drive is used, all equipment shall be of DR N/A

CAR-2165-G-209, Dual drive is not used for SHNPP fire pumps.

approved type and shall include approved free- Rev. 13 The requirements of this code section are wheeling clutches (see Paragraph 623.b) therefore not applicable.

252 Controls. The controls for the motor, steam DR N/A

FSAR Sec. 9.5.1, p. 22 Compliance assessment for motor and diesel turbine or internal combustion engine shall engine controllers is documented in the comply with the sections of this standard which applicable sections of this checklist. Steam cover these controls. turbine engines are not used for fire pumps at SHNPP.

260 Tests 261 Field Acceptance and Subsequent Tests 261.a When the installation is completed, with wells DR JC

P.O. NY-435007 The referenced purchase order included an and pumping equipment all in place, and

FPP-013, Rev. 33, Sec. option for the sellers supervising and/or start-up necessary adjustments and connections made, an 8.1.3 field service engineer if requested by the HNP-M/BMRK-0007 Page 32 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) operating test shall be made in the presence of

FPT-3001, Rev. 9 purchaser. This may have occurred, although no the customer, pump manufacturer and

FPT-3004, Rev. 11 reviewed documents confirmed whether this representative of the authority having

FPT-3010, Rev. 9 option was requested or whether the jurisdiction. Requirements regarding field

MPT-M0036, Rev. 8 requirements of this code section were acceptance test in Article 910 should be

CM-M0032, Rev. 5 specifically fulfilled.

followed insofar as they apply, excepting that However, the fire pumps and associated for well installations the test shall include a equipment have been in continuous service since continuous run long enough to satisfy the their initial installation and are subject to authority having jurisdiction that the permanent ongoing testing and maintenance as delineated pump performs as required, but in no event shall by the referenced procedures. Initial installation the test be for less than one hour.

acceptance tests are therefore essentially meaningless.

261.b A yearly inspection and test at 150 per cent rated DR Y

FPP-013, Rev. 33, Sec. The referenced procedures combine to capacity to determine water level and condition 8.1.3 implement the required testing at yearly of pump should be made.

FPT-3004, Rev. 11 intervals for the two main fire pumps (diesel driven and motor driven).

270 Operation and Maintenance.

271 Operation 271.a In starting the unit for the first time after N/A This code section provides recommended installation it is advisable to check over all checkpoints for initial starting of newly installed electrical connections to the motor and also the pumps. No verification is required.

discharge piping from the pump. Then momentarily operate the motor to see that the pump shaft rotates in a counter-clockwise direction when viewed from above.

271.b With these precautions taken the pump may be N/A This code section provides recommended started and allowed to run. Observe the procedures initial starting of newly installed operation for vibration while running and also pumps. No verification is required.

any heating of the motor.

HNP-M/BMRK-0007 Page 33 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 272 Vibration 272.a Pumping units are checked at the factory for N/A This code section provides information on the smoothness of running and performance and possible causes of vibration in pumping units.

should operate satisfactorily on the job. If No verification is required.

excessive vibration is present several conditions may cause the trouble - a bent pump or column shaft, impellers not properly set within the pump bowls, pump not hanging freely in the well, or strain transmitted through the discharge piping.

272.b If vibration develops later the unit should not be DR Y

FPP-013, Rev. 33, Sec. The referenced FPP and FPT procedures continued in operation. The pump manufacturer 8.1.3 implement monthly verification of main fire should be requested to service the installation

FPT-3001, Rev. 9 pump operability, which includes running the and to place it in proper running condition.

FPT-3010, Rev. 9 motor driven fire pump for at least 15 minutes

CM-M0032, Rev. 5 and the diesel engine driven fire pump for at

VM-EIZ, Rev. 5 least 30 minutes. The pumps are shutdown if any unusual noises or vibration are observed during these tests and the Control Room is notified. The procedures require documentation of any corrective actions to be taken. The referenced CM procedure provides instructions for corrective maintenance disassembly and repair of Johnston Vertical Turbine Pumps, and also references the corresponding Vendor Manual.

273 Excessive Motor Temperature. This condition is N/A This code section provides information on the generally caused either by a maintained low possible causes of excessive motor temperature.

voltage of the electric service, or when the No verification is required.

impellers are not properly set within the pump bowls.

274 Repair 274.a Manufacturer's instructions must be carefully DR Y

CM-M0032, Rev. 5 The referenced CM procedure provides HNP-M/BMRK-0007 Page 34 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) followed in making repairs, taking apart and

VM-EIZ, Rev. 5 instructions for corrective maintenance reassembling the pumps. This work should only disassembly and repair of Johnston Vertical be undertaken by someone familiar with their Turbine Pumps, and also references the design. corresponding Vendor Manual. These documents constitute the manufacturers instructions for proper repair of the fire pumps.

Fire pump repairs are performed by mechanics and craftsman trained to the procedures as required by the SHNPP Quality Assurance Program.

274.b In ordering spare or replacement parts use the DR Y

CM-M0032, Rev. 5 The referenced procedure includes a list of pump serial number stamped on the name plate

VM-EIZ, Rev. 5 replacement parts which corresponds to those fastened to the pump head. specified in the referenced Vendor Manual.

Each of the items has been assigned a CP&L Part Number.

Part II Drive and Driver Controllers for Pump Chapter Electric Drive 400 410 General 411 Electrical Equipment - Electrical equipment N/A This section of the code requires electrical shall comply with the National Electrical Code equipment to comply with the National (NFPA No. 70), except as modified or provided Electrical Code, NFPA-70, except as modified herein. by NFPA 20. Verification of compliance with NFPA 70 is outside the scope of this assessment.

NOTE: See Par. 2421 of the NFPA Standard for Installation of Sprinkler Systems (NFPA No. 13) regarding supervision of centrifugal fire pumps constituting the sole sprinkler supply.

420 Power Station 421 Single Power Station - When current is taken DR N/A

FSAR Sec. 9.5.1, p. 22 Power for the pumps is provided from the from a single power station, the station should

SD-149, Rev. 12, Sec. SHNPP plant electrical distribution system. The HNP-M/BMRK-0007 Page 35 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) be of noncombustible construction, so located or 3.2 power supply for the main pump electric motor protected as to be free from chances of serious

CAR-2166-B-041, Sh. is from the 480V power center 1-4A101 damage by exposure from fire, and the design 79, Rev. 6 (compartment 5A), which is fed from a 6.9kV and arrangement of apparatus within it such that

CAR-2166-B-041, Sh. switchgear that has an alternate feed through a there will be but little chance of interruption of 253S01, Rev. 9 bus tie with another 6.9kV switchgear. The service.

DBD-202, Rev. 6, jockey pump power is supplied from 480V Section 2.1 MCC-1-4A1012 (compartment 1BR). The requirements of this code section are not applicable.

422 From a Sub-Station - Where current is taken DR Y

FSAR Sec. 9.5.1, p. 22 Power for the pumps is provided from the through a sub-station this sub-station should also

SD-149, Rev. 12, Sec. SHNPP plant electrical distribution system. The meet the requirement of Section 421 and in 3.2 power supply for the main pump electric motor addition the number and arrangement of cables

CAR-2166-B-041, Sh. is from the 480V power center 1-4A101 between the station and the sub-station should 79, Rev. 6 (compartment 5A), which is fed from a 6.9kV be such as to practically guarantee continuous

CAR-2166-B-041, Sh. switchgear that has an alternate feed through a power at the sub-station. 253S01, Rev. 9 bus tie with another 6.9kV switchgear. The

DBD-202, Rev. 6, jockey pump power is supplied from 480V Section 2.1 MCC-1-4A1012 (compartment 1BR).

423 Other Sources 423.a Where service cannot be obtained from a power DR Y

FSAR Sec. 9.5.1, p. 22 Power for the pumps is provided from the station or sub-station meeting these

SD-149, Rev. 12, Sec. SHNPP plant electrical distribution system. The requirements, it should be obtained from two or 3.2 power supply for the main pump electric motor more stations or sub-stations so located and

CAR-2166-B-041, Sh. is from the 480V power center 1-4A101 equipped that an accident or fire at one will not 79, Rev. 6 (compartment 5A), which is fed from a 6.9kV cause an interruption of the service supplied by

CAR-2166-B-041, Sh. switchgear that has an alternate feed through a the others. 253S01, Rev. 9 bus tie with another 6.9kV switchgear. The

CAR-2166-G-037S01, jockey pump power is supplied from 480V Rev. 11 MCC-1-4A1012 (compartment 1BR).

DBD-202, Rev. 6, Section 2.1 423.b A private generating plant located on the DR N/A

FSAR Sec. 9.5.1, p. 22 Power for the pumps is provided from the HNP-M/BMRK-0007 Page 36 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) premises served by the fire pump, if in a

SD-149, Rev. 12, Sec. SHNPP plant electrical distribution system, separate power house or cut off from main 3.2 rather than from a private generating plant. The buildings, will be considered as a power station,

CAR-2166-B-041, Sh. power supply for the main pump electric motor and may be used as one source of current 79, Rev. 6 is from the 480V power center 1-4A101 supply.

CAR-2166-B-041, Sh. (compartment 5A), which is fed from a 6.9kV 253S01, Rev. 9 switchgear that has an alternate feed through a

CAR-2166-G-037S01, bus tie with another 6.9kV switchgear. The Rev. 11 jockey pump power is supplied from 480V

DBD-202, Rev. 6, MCC-1-4A1012 (compartment 1BR). The Section 2.1 requirements of this code section are not applicable.

430 Power Supply Lines (See Fig. 430, Appendix C, for illustrative Diagrams.)

431 Types of Lines 431.a The lines between the power plants and the DR JC

CAR-2166-B-041, Sh. The cables between the pump and power supply pump room should be of such number, so 79, Rev. 6 are installed underground. The multiple power arranged and so located that there will be small

CAR-2166-B-041, Sh. sources available through the plant electrical chance of an interruption of service to the motor, 253S01, Rev. 9 distribution system provide sufficient assurance due to accident to the lines.

DBD-202, Rev. 6, to preclude the chance of an interruption of Section 2.1.1.f, service to the motor due to accidents to the lines.

2.1.3.2.7 431.b All wiring in the pump room shall be in WD & DR Y

WD The pumps are installed outdoors. However, all approved rigid metal conduit, electrical metallic

CAR-2166-B-041, Sh. wiring is enclosed in conduit. The cables from tubing or liquid-tight flexible metal conduit, or 79, Rev. 6 the power supply to the pump are installed for 600 volts or less may be approved mineral

CAR-2166-B-041, Sh. underground.

insulated metal-sheathed cable (type MI). 253S01, Rev. 9

DBD-202, Rev. 6, NOTE: Where the monetary values involved Section 2.1.1.f, are large and the crippling of this pump service 2.1.3.2.7 would seriously affect the protection of the HNP-M/BMRK-0007 Page 37 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) property, at least two separate lines from the power plant or plants to the pump installation should be provided. The lines should be run by separate routes or in such a manner that a failure of both at the same time will by only a remote possibility.

Where current is taken from an underground Edison 3-wire system it will be considered that two independent lines have been provided if connections are brought into the pump room from two street mains or feeders not terminating directly in the same junction box.

A complete underground circuit from generating station to pump is strongly recommended and should be obtained when practicable. When such construction is not available, an overhead circuit may be allowed, but that part of the circuit adjacent to the plant or exposing plants should be run with special reference to damage in case of fire. Where the pump room is a part of, or in close proximity to, the plant which the pump is designed to protect, the wires for some distance from the pump room should be underground.

432 Capacity of Lines 432.a Each line between the power plant and pump DR Y

CAR-2166-B-041, Sh. The power cables from 480V General Services room shall be of such size that its carrying 79, Rev. 6 Bus 1-4A101 to the electric motor driven pump capacity, as given by the National Electrical

CAR-2166-B-041, Sh. are sized such that their carrying capacity will Code (NFPA NO. 70), will not be exceeded. 253S01, Rev. 9 not be exceeded.

HNP-M/BMRK-0007 Page 38 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A)

CAR-2166-G-037S01, Rev. 11

DBD-202, Rev. 6, Sec.

2.1.3.2.7 432.b The voltage at the motors should not drop more DR Y

DBD-202, Rev. 6, Sec. The power available from the plant electrical than 5 percent below the voltage rating of the 2.1.3.2.4 distribution system is such that there will be motors when the pumps are being driven at rated voltage drop of no greater than 2% at the motors output, pressure, and speed, and the lines under the described conditions.

between motors and power stations are carrying their peak loads.

432.c Where squirrel-cage motors are used, the DR Y

DBD-202, Rev. 6, Sec. The voltage available from the generation capacity of the generating station, the 2.1.3.2.3 stations and from the distribution system is connecting lines and the transformers should be sufficient to permit the motors to start with a ample and such as not to cause the voltage to voltage no less than 90 percent of the normal drop sufficiently to prevent the motor starting voltage.

(not more than 10 percent below normal voltage).

432.d When 208-220 (or 208-220/440) volt motors are DR N/A

CAR-2166-B-041, Sh. Pump motors are designed for 460V service and used on 208-volt nominal lines, the 5 percent 79, Rev. 6 are supplied from 480V power sources. The voltage drop allowed in 432b shall be figured

CAR-2166-B-041, Sh. requirements of this code section are therefore from the 220-volt rating. 253S01, Rev. 9 not applicable.

DBD-202, Rev. 6 433 Power Supply Protective Devices (Fuses or Circuit Breakers) 433.a Such devices when installed in the power supply DR JC

CAR-2166-B-041, Sh. Circuit breakers installed in the power supply circuits at utility plants, sub-stations, or plant 79, Rev. 6 circuits are rated for 1600 amps / 50000 amps load distribution centers ahead of the fire pump

CAR-2166-B-041, Sh. interrupting current or more. Although evidence feeder circuits shall hold indefinitely stalled 253S01, Rev. 9 of precise compliance with this code section rotor current conditions of the fire pump

CAR-2166-G-037S01, could not be found in the reviewed documents, motor(s) under maximum plant load. Rev. 11 credit is taken for the adequacy of the plant

DBD-202, Rev. 6, Sec. electrical distribution system, and on that basis HNP-M/BMRK-0007 Page 39 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 2.1.3.2.7 it is concluded that the requirements of this code section are satisfied.

433.b Such devices (fuses not recommended) when DR JC

CAR-2166-B-041, Sh. Circuit breakers installed in the fire pump feeder installed in the fire pump feeder circuit shall 79, Rev. 6 circuits are rated for 1600 amps / 50000 amps hold indefinitely stalled rotor current of the fire

CAR-2166-B-041, Sh. interrupting current or more. Although evidence pump motor(s) and other necessary associated 253S01, Rev. 9 of precise compliance with this code section fire pump installation electrical accessories.

CAR-2166-G-037S01, could not be found in the reviewed documents, Rev. 11 credit is taken for the adequacy of the plant NOTE: Each ungrounded conductor shall be

DBD-202, Rev. 6, Sec. electrical distribution system, and on that basis protected. See also 514b. 2.1.3.2.7 it is concluded that the requirements of this code section are satisfied.

440 Transformers 441 Installation - Transformers shall be installed in NA Verification of transformer installation per the accordance with the requirements of the requirements of NFPA 70 is outside the scope of National Electric Code (NFPA No. 70). If in the this assessment.

transformer room, there should be access from the outside of the building.

442 Isolation - Transformers supplying current to DR JC

CAR-2166-B-041, Sh. Station Service Transformer 1-4A101 supplies the lights and motors in the building served by 79, Rev. 6 current to the fire pump and other equipment the fire pump may also supply the pump motor,

CAR-2166-B-041, Sh. located at the ESWISS. Although evidence of provided all load except the pump motor load 253S01, Rev. 9 precise compliance with this code section could can be quickly cut off when necessary.

CAR-2166-G-037S01, not be found in the reviewed documents, credit Switches for doing this must be in the pump Rev. 11 is taken for the adequacy of the plant electrical room unless transformer room is near pump

DBD-202, Rev. 6, Sec. distribution system, and on that basis it is room, in which case they may be in transformer 2.1.3.2.7 concluded that the requirements of this code room. section are satisfied.

443 Location - Room containing transformers WD & DR N/A

CAR-2166-B-041, Sh. Station Service Transformer 1-4A101 supplies installed solely to supply current to the pump 79, Rev. 6 current to the fire pump and other equipment motor must be dry and heated in cold weather,

CAR-2166-B-041, Sh. located at the ESWISS. The requirements of or else the transformers must be normally left 253S01, Rev. 9 this code section are therefore not applicable.

connected to the supply lines.

CAR-2166-G-037S01, HNP-M/BMRK-0007 Page 40 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A)

Rev. 11 450 Motors 451 Types-600 Volts or Less - Electric motors are DR Y

VM-IJX, Rev. 16, Sec. The main fire pump motor is 300 horsepower, 3 an accepted dependable source of power for 2A, 2B Phase, 60 Cycle, 460V, 1800 RPM, of the operation of centrifugal fire pumps. All fire

CAR-SH-M-20, Rev. direct-current, squirrel-cage induction pump motors shall be rated for continuous duty 2, Sec. 12A weatherproof type. The motor is designed for and shall not be used at voltages in excess of

1364-1676, Rev. 1 starting under full voltage and is also designed 110 percent of rated voltage. It is the pump

1364-1719, Rev. 1 for starting under normal torque and at low manufacturers responsibility to provide a motor

1364-1741, Rev. 1 starting current. The locked-rotor current is of ample size as specified in Section 453. Only

1364-1742, Rev. 1 2200 amps, which is per the code Table for this motors wound for 208 volts shall be used for motor. The pump controller is configured for

CAR-2166-B-401, Sh.

208-volt services when the voltage may be less across-the-line starting of the motor.

2581, Rev. 9 than that determined in accordance with 432d.

CAR-2166-B-401, Sh. The jockey pump motor is 7.5 horsepower, 3 Direct- or alternating-current motors may be 2582, Rev. 7 Phase, 60 Cycle, 460V, 3600 RPM, of the used in accordance with the following direct-current, squirrel-cage induction requirements:

weatherproof type. The motor is designed for starting under full voltage and is also designed

a. Direct-current motors shall be either of the for starting under normal torque and at low stabilized shunt type, or cumulative starting current. The locked-rotor current is 63.5 compound-wound type. The speed of the amps, which is per the code table for this motor.

motor at no load hot shall not exceed the The pump controller is configured for across-speed at full load hot by more than 10 the-line starting of the motor.

percent.

b. Alternating-current motors may be of the squirrel-cage induction type with across-the-line type starting equipment unless their starting characteristics would be objectionable to the company furnishing the power, in which case primary resistance primary reactor or auto-transformer type starting may be employed, or a wound rotor type of motor with appropriate starting HNP-M/BMRK-0007 Page 41 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) equipment may be substituted.

c. Squirrel-cage induction motors should have normal starting and breakdown torque. The locked-rotor current of three-phase, constant-speed, induction motors, measured with rated voltage and frequency impressed with rotor locked shall not exceed the following values:

(See Code for values and Notes that follow.)

452 Types-In Excess of 600 Volts - All fire pump DR N/A

VM-IJX, Rev. 16, Sec. Motors for the main motor driven fire pump and motors shall be rated for continuous duty and 2A, 2B the jockey pump are of the 460V type. The shall not be used at voltages in excess of 110

CAR-SH-M-20, Rev. requirements of this code section are therefore percent of rated voltage. Voltages above 600 2, Sec. 12A not applicable.

are not recommended for fire pump service, but

1364-1676, Rev. 1 where it is impracticable to use low voltage,

1364-1719, Rev. 1 higher voltages may be accepted by the

1364-1741, Rev. 1 authority having jurisdiction, for motor ratings

1364-1742, Rev. 1 of approximately 75 horsepower and larger at 2,300 volts and for motor ratings of approximately 100 horsepower and larger at 4,000 volts.

453 Current Limits 453.a All motors shall be of such capacity that at rated DR Y

VM-IJX, Rev. 16, Sec. The main motor driven fire pump and jockey voltage (and on a.c. motors at rated frequency) 2A, 2B pump motors are of adequate capacity such that their full load ampere rating will not be

CAR-SH-M-20, Rev. at rated voltage and frequency the full load exceeded (except as allowed by the service 2, Sec. 12A ampere rating of the motors will not be factor stamped on the name plate) under any

1364-1676, Rev. 1 exceeded.

conditions of pump load.

1364-1719, Rev. 1

1364-1741, Rev. 1

1364-1742, Rev. 1 453.b Motors used at altitudes above 3300 feet shall be WD & DR N/A

WD Motors for the main motor driven fire pump and HNP-M/BMRK-0007 Page 42 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) operated or derated according to NEMA

CAR-2165-G-209, the jockey pump are installed at approximately Standard MG1-14.14 (1963). Rev. 13 262-0 elevation. The requirements of this code section are therefore not applicable.

454 Marking 454.a Marking of motor terminals shall be in DR Y

CAR-SH-E-12, Rev. 6, The referenced specification required accordance with the current NEMA Standard p. 4 compliance with NEMA Standard MG1.

MG1-Part 2.

454.b A name plate shall be provided showing the WD & DR Y

WD A name plate is attached to each of the two following information:

1364-1741, Rev. 1 motors.

1364-1742, Rev. 1 Direct-Current Motors DR N/A

VM-IJX, Rev. 16, Sec. Alternating current type motors are installed for Manufacturers type and frame designation. 2A, 2B the main motor driven fire pump and the jockey Rated horsepower output.

CAR-SH-M-20, Rev. pump. The requirements of this code section are Time rating. 2, Sec. 12A not applicable.

Voltage.

1364-1676, Rev. 1 Temperature rise or class of insulation.

1364-1719, Rev. 1 Ambient temperature.

1364-1741, Rev. 1 RPM at full load.

1364-1742, Rev. 1 Full load amperes.

Shunt or compound wound.

Alternating-Current Motors WD & DR Y

WD The motor name plates contain the information Squirrel-cage Motors

1364-1741, Rev. 1 required by this code section.

Manufacturers type and frame designation.

1364-1742, Rev. 1 Rated horsepower output.

Time rating.

RPM at full load.

Frequency.

Number of phases.

Voltage.

Full load amperes.

Code letter.

HNP-M/BMRK-0007 Page 43 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A)

Service factor, if other than 1.0.

Temperature rise or class of insulation and ambient temperature.

Wound Rotor Induction Motor N/A Wound rotor induction motors are not used for In addition to information required in the main motor driven fire pump or jockey previous paragraph, also show secondary pump. This portion of the code section is amperes at full load and secondary voltage. therefore not applicable.

455 Water Protection 455.a Open motors which are subject to possible WD & DR N/A

WD Motors for the main fire pump and jockey pump splash of water from hose connections close to

1364-1741, Rev. 1 are drip-proof (shielded) with NEMA WP-I the pump, shall be protected against such

1364-1742, Rev. 1 (weather-protected) enclosures. The splashing by some means such as a

VM-IJX, Rev. 16, p. requirements of this code section are therefore noncombustible, moisture-resisting partition, S2d-27 not applicable.

furnished by the pump manufacturer, installed between the pump and the motor.

455.b Drip-proof motors shall be arranged as described WD & DR Y

WD Motors for the main fire pump and jockey pump above unless the hose valves are located outside

1364-1741, Rev. 1 are drip-proof (shielded) with NEMA WP-I the pump room.

1364-1742, Rev. 1 (weather-protected) enclosures. However, the

VM-IJX, Rev. 16, p. hose connections are located within a metal S2d-27 enclosure and are oriented such that hose discharge would be directly into the Auxiliary Reservoir and not directed toward the pump motors. The motors are therefore considered adequately protected against splashing, satisfying the intent of this code section.

455.c Splash-proof motors shall be acceptable without WD & DR N/A

WD Motors for the main fire pump and jockey pump splash partition as described above, providing

1364-1741, Rev. 1 are drip-proof (shielded) with NEMA WP-I the ventilating inlet and discharge are located so

1364-1742, Rev. 1 (weather-protected) enclosures. The as to prevent impact of dripping or splashing

VM-IJX, Rev. 16, p. requirements of this code section are therefore water on windings or other energized S2d-27 not applicable.

mechanisms.

HNP-M/BMRK-0007 Page 44 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 455.d Motors of totally enclosed, fan-cooled type shall WD & DR N/A

WD Motors for the main fire pump and jockey pump be acceptable without splash partition. They

1364-1741, Rev. 1 are drip-proof (shielded) with NEMA WP-I shall be sealed at the joints and have conduit

1364-1742, Rev. 1 (weather-protected) enclosures. The fittings arranged to prevent the entrance of

VM-IJX, Rev. 16, p. requirements of this code section are therefore water. S2d-27 not applicable.

NOTE: See item 19 in Appendix A-Glossary for a description of the various types of electric motors.

455.e Current-carrying parts of electric motors shall be WD & DR Y

WD Both pump motors are installed such that the at least 12 inches above the floor.

1364-1741, Rev. 1 entire motor enclosure is at least 12 inches

1364-1742, Rev. 1 above the concrete deck at the ESWISS.

456 Other Features 456.a Motors shall be equipped with anti-friction ball DR Y

VM-IJX, Rev. 16, p. Pump motors feature grease-lubricated ball or roller-type bearings mounted so as to be S2c-16, 20 bearings (jockey pump) and oil-lubricated effectively sealed against dirt and moisture.

1364-1741, Rev. 1 angular contact ball bearings (main pump).

1364-1742, Rev. 1 456.b Instructions as to lubrication and care of motor DR Y

VM-IJX, Rev. 16, p. The referenced vendor manual provides bearings shall accompany each motor. S2c-16, 20 instructions on the lubrication and care of the motors.

456.c The terminal box shall be of a type which can be WD & DR Y

WD The terminal box for the jockey pump motor arranged for attaching conduit at sides, top or

VM-IJX, Rev. 16, p. allows for conduit connection per this code bottom. A totally-enclosed fan-cooled motor S2d-27 section. The terminal box for the main fire shall be provided with a watertight conduit box.

1364-1741, Rev. 1 pump motor, although it is not specified as such,

1364-1742, Rev. 1 appears to allow for installation in any orientation.

456.d Where unusual moisture or abrasive dust WD N/A

WD The fire pump motors are not located in an area conditions are anticipated, motors shall be of subject to unusual abrasive dust conditions. The special type or specially insulated to withstand requirements of this code section are therefore such conditions. Under such conditions high not applicable. However, the motors are of the voltage motors shall be totally enclosed. vertical, squirrel-cage, and weatherproof type HNP-M/BMRK-0007 Page 45 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) that provides for protection from moisture.

457 Conformance - Motors furnished for centrifugal DR Y

P.O. NY-435007 The referenced purchase order required the fire pump use shall be guaranteed to conform seller to provide motors that were in with these specifications. conformance with latest issue of NPFA 20.

Chapter Electric Drive Controllers 500 510 Requirements for all Controllers 511 General 511.a The following specifications cover controlling N/A This code section provides general information equipment of the nonautomatic and automatic on the scope of Section 511. No verification is types for electric motors driving centrifugal fire required.

pumps. Chapter 400 dealing with the electric motor drive also applies insofar as it is appropriate.

511.b Automatic-type controllers are recommended for DR Y

P.O. NY-435007 A UL listed / FM approved Automatic controller use only where the fire pump takes its water

SD/C-C-1007, Rev. 0 is provided for the electric motor driven main under positive pressure and their use is not

SD/C-C-1010, Rev. 0 pump (GTE/Sylvania C10630). An approved recommended where a suction lift is involved. controller (GTE/Sylvania 10661 TM-1) is provided for the jockey pump. These pumps take suction under a positive head.

511.c All controllers shall be specifically approved for DR Y

P.O. NY-435007 Automatic controllers are provided for the fire pump service.

SD/C-C-1007, Rev. 0 electric motor driven main pump (GTE/Sylvania

SD/C-C-1010, Rev. 0 C10630) and jockey pump (GTE/Sylvania 10661 TM-1). The motor driven main fire pump controller is UL listed / FM approved for fire pump service. Although the jockey pump controller is not approved for fire pump service, this is acceptable since the jockey pump is a pressure maintenance pump rather than a fire pump (ref. Section 31.e).

HNP-M/BMRK-0007 Page 46 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 511.d The control panel shall be completely DR JC

P.O. NY-435007 The reviewed documents did not specify precise assembled, wired, and tested by the

CAR-SH-M-20, Rev. 2 adherence to the requirements of this section.

manufacturer before shipment from the factory.

SD/C-C-1007, Rev. 0 However, the specified equipment was provided

SD/C-C-1010, Rev. 0 by the seller, accepted by CP&L, installed, and

VM-EIZ has been functioning continuously as a part of the SHNPP fire protection water supply system since that time. It can be reasonably concluded that the intent of this code section has been fulfilled.

511.e Voltages above 600 v are not recommended for DR N/A

1364-1741, Rev. 1 Motors for the electric motor driven fire pump fire pump service, but where it is impracticable

1364-1742, Rev. 1 and the jockey pump are of the 460V type. The to use a low voltage, higher voltages may be

VM-EIZ requirements of this code section are therefore accepted by the authority having jurisdiction. not applicable.

High voltage controllers shall be rated at not more than 5000 v. (See Article 520).

511.f Controllers conforming to this Standard shall be WD Y

WD The controller for the main motor driven fire marked Fire Pump Controller and shall show pump is marked as required by this code section.

plainly the name of the manufacturer, the The jockey pump controller is labeled as a identifying designation and the complete Jockey Fire Pump Controller.

electrical rating.

512 Location 512.a The controller shall be located as close to as is WD Y

WD Controllers for the main motor driven fire pump practical and within sight of the motor. and jockey pump are each located in sight of, and within a 15-foot distance from, the associated motor.

512.b The controller shall be so located or protected WD & DR Y

WD Controllers for the main motor driven fire pump that it will not be injured by water escaping from

P.O. NY-435007 and jockey pump are protected by NEMA III the pump or connections. Current carrying parts

SD/C-C-1007, Rev. 0 weather resistant enclosures. The entire jockey of the controller shall be not less that 12 inches

SD/C-C-1010, Rev. 0 pump controller enclosure and all current-above the floor level.

VM-EIZ carrying parts of the motor driven fire pump controller are at least 12 inches above the HNP-M/BMRK-0007 Page 47 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A)

ESWISS concrete floor deck.

512.c A clearance of not less that 31/2 feet shall be WD & DR N/A

WD The controller enclosures, which are mounted provided at the rear of enclosures designed to be

SD/C-C-1007, Rev. 0 against the outside wall of the ESWISS, are not inspected and serviced from the rear.

SD/C-C-1010, Rev. 0 designed for rear access. The requirements of

VM-EIZ this code section are therefore not applicable.

513 General Construction 513.a Equipment - All equipment shall be suitable for DR Y

P.O. NY-435007 Equipment is suitable for use in a moderately use in locations subject to a moderate degree of

SD/C-C-1007, Rev. 0 damp location and is installed in NEMA III) moisture such as a damp basement.

SD/C-C-1010, Rev. 0 weather resistant enclosures.

513.b Mounting - All equipment shall be mounted in a WD Y

WD Equipment is mounted in NEMA III weather substantial manner on a single, noncombustible resistant steel enclosures which rest on a supporting structure. concrete slab and are secured to a concrete building wall.

513.c Enclosure - The structure or panel shall be WD & DR Y

WD Controllers for the main motor driven fire pump securely mounted in an enclosure(s) which will

P.O. NY-435007 and jockey pump are protected by NEMA III protect the equipment against mechanical injury

SD/C-C-1007, Rev. 0 weather resistant enclosures. The panels and falling drops of water striking the enclosure

SD/C-C-1010, Rev. 0 adequately protect the enclosed equipment from from the downward vertical.

VM-EIZ mechanical injury and falling drops of water.

513.d Connections and Wiring 513.d.1 All bus bars and connections shall be readily WD & DR Y

WD All connections are accessible for maintenance accessible for maintenance work after

SD/C-C-1007, Rev. 0 without disconnecting the external circuit installation of the controller without

SD/C-C-1010, Rev. 0 connectors.

disconnecting the external circuit conductors.

VM-EIZ 513.d.2 Test connections. Provision shall be made to WD & DR Y

WD The main motor driven fire pump controller allow the use of test meters by one of the

CAR-2166-B-401, Sh. features specific test connections which satisfy methods outlined in the following paragraphs (a) 2582, Rev. 7 paragraphs a) and b) as described in this code or (b).

SD/C-C-1007, Rev. 0 section. The jockey pump controller provides a) Terminal shall be so located and arranged

SD/C-C-1010, Rev. 0 capability for testing per paragraph a), although that a clamp-or such type meter can be the test points are not clearly identified as such.

safely and conveniently used, or HNP-M/BMRK-0007 Page 48 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) b) There shall be provided, as part of the controller, a readily accessible test link or equivalent means for connecting a current measuring instrument in one of the motor circuit conductors without the necessity for disconnecting any conductor which runs outside the equipment enclosures. The test link shall be connected between the isolating switch and the circuit breaker.

513.d.3 Bus bars and other wiring elements of the DR JC

CAR-2166-B-401, Sh. No reviewed documents verified compliance controller shall be designed on a continuous 2582, Rev. 7 with this section. However, the motor driven basis, except that conductors which are in a

P.O. NY-435007 pump controller (GTE/Sylvania C10630) is UL circuit only during the motor starting period may

SD/C-C-1007, Rev. 0 listed / FM approved for fire service, providing be designed accordingly.

SD/C-C-1010, Rev. 0 reasonable assurance of compliance with these requirements.

513.e Protection of Auxiliary Circuits. Circuits which DR JC

CAR-2166-B-401, Sh. No reviewed documents verified compliance are depended upon for proper operation of the 2582, Rev. 7 with this section. However, the motor driven controller shall not have over-current protective

P.O. NY-435007 pump controller (GTE/Sylvania C10630) is UL devices connected in them.

SD/C-C-1007, Rev. 0 listed / FM approved for fire service, providing

SD/C-C-1010, Rev. 0 reasonable assurance of compliance with these requirements.

513.f External Operation. All switching equipment WD & DR Y

WD Controllers for the main motor driven fire pump for manual use in connecting or disconnecting,

SD/C-C-1007, Rev. 0 and jockey pump are each equipped with or starting or stopping the motor shall be

SD/C-C-1010, Rev. 0 externally operable stopping / disconnection externally operable as defined in the National switches for manual use.

Electrical Code (NFPA No. 70). The isolation See section 514 for compliance with individual switch shall meet the requirements of Section subsections, as applicable.

514.

513.g Wiring Diagrams and Instructions. WD &DR JC

WD The inside of the control panels could not be

1) A wiring diagram shall be provided and

CAR-2166-B-401, Sh. accessed for verification of compliance with this permanently attached to the inside of the 2581, Rev. 7 code section. However, the referenced HNP-M/BMRK-0007 Page 49 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) enclosure.

CAR-2166-B-401, Sh. documents, which are wiring diagrams for the

2) All the field wiring terminals shall be 2582, Rev. 7 main motor driven fire pump and jockey pump plainly marked to correspond with the

P.O. NY-435007 controllers, are maintained by the SHNPP wiring diagram furnished.

SD/C-C-1007, Rev. 0 document control system and are readily

SD/C-C-1010, Rev. 0 retrievable. Therefore, although diagrams were not verified as permanently attached to the inside of each enclosure, the intent of this code requirement is fulfilled. Additionally, since the motor driven pump controller is UL listed / FM approved for fire service, there is reasonable assurance that field wiring terminals are marked to correspond to the applicable wiring diagrams.

513.h Marking. Each motor control device and each WD & DR JC

WD The inside of the control panel could not be switch and circuit breaker shall be marked to

P.O. NY-435007 accessed for verification of compliance with this plainly indicate the name of the manufacturer, code section. However, the motor driven pump his designated identifying number and the controller (GTE/Sylvania C10630) is UL listed /

electrical rating in volts, horsepower, amperes, FM approved for fire service, providing frequency, phases, etc., as to be visible after reasonable assurance of compliance with these installation. requirements.

513.i Instructions. Complete instructions covering the WD & DR Y

WD Start and stop instructions are provided on the operation of the controller shall be provided and

FPP-001, Rev. 26 front of the main motor driven fire pump conspicuously mounted on the controller. Pump controller, and a pre-start checklist is also operators should be familiar with these mounted to the junction box on the front of the instructions and should observe in detail all of motor itself. Operations personnel responsible their provisions. for inspection, testing & maintenance, and operation of the pumps are trained in the operation of this equipment as required by the SHNPP fire protection program.

514 Components 514.a Isolating Switch. Except as noted in Paragraph DR Y

CAR-2166-B-401, Sh. The non-automatic isolation switch is located on 531.b for limited service controllers, a manually 2581, Rev. 9 the front of the control panel, is externally operated isolating switch shall be provided operable, and is of the two-hand interlock type.

HNP-M/BMRK-0007 Page 50 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) within the enclosure, connected on the supply

SD/C-C-1010, Rev. 0 It is connected on the supply side of the circuit side of the circuit breaker with one pole for each breaker and has one pole for each of the 3 branch circuit connector. branch circuit connectors.

514.a.1 The switch shall be externally operable (see WD & DR Y

WD The non-automatic isolation switch is located on 513f) and the operating handle shall be provided

SD/C-C-1010, Rev. 0 the front of the control panel, is externally with a spring latch which will not interfere with operable, and is of the two-hand interlock type, the closing of the switch, but shall be so in which the switch and the release latch arranged that it requires the use of the other (button) cannot be operated with one hand.

hand to hold the latch released in order to permit the opening of the isolating switch.

514.a.2 The ampere rating of the switch shall be at least DR JC

CAR-2166-B-401, Sh. The reviewed documents did not provide the 115 per cent of the nameplate current rating of 2581, Rev. 9 ampere rating of the isolation switch. However, the motor.

P.O. NY-435007 the motor driven pump controller

SD/C-C-1010, Rev. 0 (GTE/Sylvania C10630) is UL listed / FM approved for fire service, providing reasonable assurance of compliance with this requirement.

514.a.3 The following warning shall appear on or WD Y

WD The required warning is located on the immediately adjacent to the isolating switch: instruction label mounted on the front of the WARNING - DO NOT OPEN OR CLOSE cabinet.

THIS SWITCH WHILE THE CIRCUIT BREAKER (DISCONNETING MEANS) IS IN CLOSED POSITION.

514.b Circuit Breaker (Disconnecting Means). Except DR Y

SD/C-C-1010, Rev. 0 The main motor driven fire pump controller is as noted in Section 532 for limited service equipped with the required type circuit breaker controllers, the motor branch circuit breaker which is connected to the load side of the shall be protected by a suitable magnetic trip- isolating device.

type circuit breaker, connected directly to the load side of the isolating switch and conforming with the following requirements:

514.b.1 No other over-current protective devices shall be DR Y

CAR-2166-B-401, Sh. No over-current protective devices other than in the motor circuit on the load side of the circuit 2581, Rev. 9 the circuit breaker are installed in the motor HNP-M/BMRK-0007 Page 51 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) breaker. circuit on the load side of the breaker.

Note: See Article 433 for rating and setting of over-current devices in the circuit on the line side of the circuit breaker. See NFPA 70 for the number of over-current units required for circuit protection devices.

514.b.2 It shall have one pole for each ungrounded DR Y

SD/C-C-1007, Rev. 0 The circuit breaker is a 3-pole type, which is as branch circuit conductor.

SD/C-C-1010, Rev. 0 required for the 3-conductor branch circuit.

514.b.3 It shall be externally operable. (See 513f) WD & DR Y

WD The circuit breaker is externally operable using

SD/C-C-1007, Rev. 0 the handle mounted on the left-front of the

SD/C-C-1010, Rev. 0 cabinet.

514.b.4 It shall trip free of the handle. DR Y

SD/C-C-1007, Rev. 0 The breaker will trip free of the handle.

SD/C-C-1010, Rev. 0 514.b.5 Its rating shall not be less than 115% of the rated DR Y

E1-001.19, Rev. 0 The breaker rating is 800 amps, which is greater full load current of the motor.

CPL-2166-S-0301, Sh. than 115% of the full load current of the motor 31, Rev. 3 (345 amps).

514.b.6 It shall permit normal starting of the motor DR Y

E1-001.19, Rev. 0 The circuit breaker, which has a time delay without tripping.

SD/C-C-1010, Rev. 0 over-current feature, will allow normal starting of the motor without tripping.

514.b.7 It shall provide stalled rotor and instantaneous DR Y

E1-001.19, Rev. 0 The referenced calculation documents that the short circuit protection.

SD/C-C-1010, Rev. 0 circuit breaker is in compliance with item a)

(a) For a squirrel cage induction motor, it shall requirements, which are appropriate for a be of the time delay type and have a time squirrel cage induction motor as used to drive delay of not over 20 seconds at locked rotor the motor driven fire pump.

current (this is 600% of rated full load motor current for squirrel cage induction motors),

and shall be calibrated up to and set at 300%

of the motor full load current.

(b) For a direct-current motor and wound rotor alternating-current motor, it shall be of the HNP-M/BMRK-0007 Page 52 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) instantaneous type calibrated and set at 400% of the motor full load current.

514.b.8 Its interrupting rating shall be adequate for the DR Y

CAR-2166-B-041, Sh. The circuit breaker is rated for 50,000 amperes circuit in which it is used, and in no case be less 79, Rev. 6 interrupting current.

than 14,000 amps (symmetrical). Were the

E1-001.19, Rev. 0 available short circuit current of the power

SD/C-C-1010, Rev. 0 supply exceeds the interrupting capacity of the breaker, the breaker shall be protected with current limiting fuses coordinated with the breaker, The current limiting fuses shall be mounted in the control panel and connected between the isolating switch and the circuit breaker.

514.b.9 The required interrupting ratings should be DR Y

CAR-2166-B-041, Sh. The circuit breaker is rated for 50,000 amperes obtained by the purchaser based upon the 79, Rev. 6 interrupting current, which is greater than any of maximum possible short-circuit current at the

E1-001.19, Rev. 0 the values specified in Table 514. The pump room. The values, which are

SD/C-C-1010, Rev. 0 referenced calculation is an analysis performed approximate, show in Table 514 may be used as to determine the proper settings for the over-a guide. current protection circuit breaker. It is reasonable to assume that is adequate for the circuit in which it is used, including consideration of the maximum possible short-circuit current at the controller.

514.b.10 A nameplate with the legend CIRCUIT WD Y

WD The controller for the main motor driven fire BREAKER - DISCONNECTING MEANS in pump features a nameplate meeting the letters not less than 3/8 inch high shall be requirements of this code section.

located on the outside of the enclosure adjacent to the means for tripping the circuit breaker.

514.c MOTOR STARTER - The motor starter shall be DR Y

P.O. NY-435007 The motor starter is of the across-the-line type, of the magnetic type with a contact in each

CAR-2166-B-401, Sh. which features a contact in each conductor.

conductor. 2581, Rev. 9 HNP-M/BMRK-0007 Page 53 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 514.c.1 For electrical operation of reduced voltage DR JC

P.O. NY-435007 The reviewed documents did not provide the starters, timed automatic acceleration of the

CAR-2166-B-401, Sh. required starter data. However, the motor driven motor shall be provided and the period of motor 2581, Rev. 9 pump controller (GTE/Sylvania C10630) is UL acceleration shall not exceed 10 seconds. listed / FM approved for fire service, providing reasonable assurance of that the included motor starter is in compliance with this requirement.

514.c.2 Starting resistors shall be designed to permit one DR JC

P.O. NY-435007 The reviewed documents did not provide the 5-second starting operation in each 80 seconds

CAR-2166-B-401, Sh. required starter data. However, the motor driven for a period of not less than 1-hour. 2581, Rev. 9 pump controller (GTE/Sylvania C10630) is UL listed / FM approved for fire service, providing reasonable assurance of that the included motor starter is in compliance with this requirement.

514.c.3 The operating coil for the main contactor shall DR JC

P.O. NY-435007 The reviewed documents did not provide the be supplied directly from the main power

CAR-2166-B-401, Sh. required starter data. However, the motor driven voltage and not through a transformer for 2581, Rev. 9 pump controller (GTE/Sylvania C10630) is UL controllers of 600 volts or less. listed / FM approved for fire service, providing reasonable assurance of that the included motor starter is in compliance with this requirement.

514.d ALARMS AND SIGNAL DEVICES (ON DR Y

CAR-2166-B-401, Sh. A 6w, 120V lamp with resistor and amber lens is CONTROLLER) - A 6w or 7w candelabra base 2581, Rev. 9 connected per the requirements of this code 115-125 v. pilot lamp shall be connected to a

SD/C-C-1010, Rev. 0 section to indicate power available. This lamp pair of power supply conductors directly on the is accessible for replacement.

line side of the motor starter (load side of the circuit breaker) to indicate that the circuit breaker and test link are closed and that power is available at the controller for starting. The lamp shall be accessible for replacement.

Note: It is recommended that the lamp operating voltage be less than the rated voltage of the lamp to insure long operating life. When necessary, suitable resistors or potential transformers should be used to reduce the HNP-M/BMRK-0007 Page 54 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) voltage for operating the lamp.

514.e ALARM AND SIGNAL DEVICES DR Y

CAR-2166-B-401, Sh. Since there is no pump room, remote indication (REMOTE). Where the pump room is not 2581, Rev. 9 is provided in the Control Room at annunciator constantly attended, the controller shall be

SD/C-C-1010, Rev. 0 cabinet 2, ALB-30. Power source is 125V or equipped with contacts to operate circuits, not less.

exceeding 125 volts, for audible or visual alarms at a point constant attendance indicating the following:

514.e.1 Controller has operated into a pump running DR Y

CAR-2166-B-401, Sh. Remote panel has an annunciator that indicates condition. 2581, Rev. 9 Fire Pump B Operating.

SD/C-C-1010, Rev. 0 514.e.2 Loss of line power on line side of motor starter DR Y

CAR-2166-B-401, Sh. Power availability is indicated in the control in any phase. This may be accomplished 2581, Rev. 9 room per the requirements of this code section.

through use of drop out type relays controlling

SD/C-C-1010, Rev. 0 an alarm circuit energized by a reliable source of power supply. The relay contacts should close on failure of voltage. Unless the power to this alarm circuit is electrically supervised, the controller shall be arranged to start upon failure of this alarm circuit power.

515 Starting and Control 515.a The following definitions are from the National N/A General information. No verification required.

Electrical Code (1971) 515.a.1 Nonautomatic: Nonautomatic means that the N/A Definition. No verification is required.

implied action requires personal intervention for its control.

As applied to an electric controller, nonautomatic control does not necessarily imply a manual controller, but only that personal intervention is necessary.

515.a.2 Automatic: Automatic means self-acting, N/A Definition. No verification is required.

HNP-M/BMRK-0007 Page 55 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) operating by its own mechanism when actuated by some impersonal influence, as for example, a change in current strength, pressure, temperature, or mechanical configuration.

515.b NFPA No. 20 contemplates that:

515.b.1 Non-automatic controller shall be actuated by DR N/A

P.O. NY-435007 The fire pump controller is designed for electrical manual and mechanical manual means.

SD-149, Sec. 4.2.1 automatic starting of the motor driven fire pump on pressure drop. The requirements of this code section are therefore not applicable.

515.b.2 Automatic controller shall be operable as a DR Y

P.O. NY-435007 The fire pump controller is designed for nonautomatic controller and also by other non-

SD-149, Sec. 4.2.1 automatic starting of the motor driven fire pump personal means such as: low water pressure, on pressure drop. The controller can also be tripping of deluge and dry pipe valves, etc. manually operated.

515.c Nonautomatic 515.c.1 Manual Electric Control at Controller: There DR Y

SD/C-C-1010, Rev. 0 The control panel at the motor driven fire pump shall be a manually operated switch on the is equipped with a pushbutton switch and also an control panel so arranged that when the pumping emergency latch lever for manual actuation of unit is started manually, its operation cannot be the pump. The manual fire pump start sequence affected by the pressure switch, and so that the will cause the fire pump to start and run until unit will remain in operation until manually shut manually shut down.

down, except that an auto-transformer reduced-voltage type of starter need not have electrical control means for starting the motor.

515.c.2 Manual Electric Control at Remote Station - DR N/A

SD-149, Sec. 4.2.1 No reviewed documents indicated that the motor Additional control stations for causing

SD/C-C-1010, Rev. 0 driven fire pump can be manually started from a nonautomatic continuous operation of the remote location. The requirements of this code pumping unit independent of the pressure section are therefore not applicable.

actuated control switch may be provided at locations remote from the controller, but such stations shall not be operable to stop the unit.

515.c.3 Manual Mechanical Control at Controller: DR Y

OP-149, Rev. 17, p. 9 A Motor Driven Fire Pump Emergency Latch HNP-M/BMRK-0007 Page 56 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A)

(a) The controller shall be equipped with a

SD/C-C-1010, Rev. 0 Lever, located at the lower right side of the handle or lever which operates to close the controller cabinet, will manually start the pump motor-circuit switching mechanism if it is pulled down and latched. The handle mechanically for nonautomatic continuous moves in one direction only and will return to its running operation of the motors original off position if not latched.

independent of any electric control circuits or magnets (or equivalent devices) and independent of the pressure-activated control switch. Means shall be incorporated for mechanically latching or holding of the handle or lever for manual operation in the actuated position. The mechanical latching shall not be automatic, but at the option of the operator.

(b) The handle or lever shall be arranged to move in one direction only from off to final position with the exception of the auto-transformer reduced-voltage type starter.

(c) The motor starter shall return automatically to the off position in case the operator releases the starter handle in any but the full running position.

515.d Automatic 515.d.1 Water Pressure Control: An acceptable type DR Y

SD/C-C-1010, Rev. 0 A Mercoid pressure switch which is responsive pressure switch having independent high and

SD-149, Sec. 4.2.1 to water pressure in the fire protection water low calibrated adjustments, and which is

FPT-3001, Rev. 9 supply system is provided in the control circuit.

responsive to water pressure in the fire system This switch is set to start the motor driven fire shall be provided in the control circuit. pump when system water pressure falls below Note: Test Device - Suitable provision shall be 100 psig.

made for relieving pressure to the pressure HNP-M/BMRK-0007 Page 57 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) switch to test the operation of the controller and The referenced procedure operates the motor the pump. driven pump monthly, using the pressure switch and the controller to test automatic starting of the unit.

515.d.2 Fire Protection Equipment Control: When the DR N/A

P.O. NY-435007 The fire pump controller is designed for pump supplies special water control equipment

SD-149, Sec. 4.2.1 automatic starting of the motor driven fire pump (deluge, dry pipe valves, etc.) and it is desired to on pressure drop, rather than on the operation of start the pump before the pressure control(s) fire protection equipment. The requirements of would do so, the AHJ may require the controller this code section are therefore not applicable.

to be equipped to start the pump upon operation of the fire protection equipment. The controller shall be equipped with a relay of the drop-out type to start the pump when the fire protection equipment operates. The relay shall be actuated from a normally closed contact on the fire protection equipment.

Note: Deluge System Operation: see code for more details.

515.d.3 Sequence Starting: Controllers for multiple DR Y

SD-149, Sec. 4.2.1 Two main fire pumps are provided and are pump units shall incorporate a sequential timing

AR 25060 designed to sequentially start as follows:

device to prevent any one pump starting

EC 50147

The electric motor driven pump starts simultaneously with any other pump. If the water requirements are such that more than one automatically when pressure in the fire pump operates, the units shall start in intervals protection water system drops to 100 psig.

of five to ten seconds. Failure of a leading

The diesel engine driven pump pump to start shall not prevent subsequent automatically starts when pressure in the pumps from starting. system drops to 83 psig.

Each pump has a separate controller, and there is a sequential timing device to prevent both pumps from running simultaneously. An 8 HNP-M/BMRK-0007 Page 58 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) second time delay in the starting sequence for the DDFP prevents simultaneous starting of the fire pumps.

515.d.4 For sprinkler systems and standpipe systems DR Y

SD-149, Sec. 4.2.1 The motor driven fire pump controller is where an automatically controlled pump designed for automatic starting upon pressure constitutes the sole supply or where required by drop to 100 psig and for manual shutdown at the the AHJ, the controller shall be wired for pump controller.

automatic start and manual shutdown.

515.e METHODS OF STOPPING: Shutdown may be accomplished by either one or both of the following:

515.e.1 Manual - the control panel shall have means for DR Y

SD/C-C-1010, Rev. 0 The pump controller features a pushbutton electrical operation for stopping the motor which switch for manual shutdown.

in case of automatic controllers will return the controller to full automatic position.

515.e.2 Automatic - after starting causes have returned DR N/A

SD/C-C-1010, Rev. 0 Motor driven fire pump is arranged for manual to normal and the pumping unit has operated for shutdown. The automatic shutdown feature is the time fixed by the running period timer. not provided. This code section is not Note: Whenever the controller is arranged for applicable, since Section 515.e requires only one automatic shutdown, a running period timer set of the shutdown methods to be provided.

for one minute for each ten horsepower of motor rating, but not to exceed 7 minutes, shall be installed.

Chapter Internal Combustion Engine Drive 600 620 Engines 621 Approval. - Engines shall be specifically DR Y

Cummins Diesel The main diesel driven fire pump engine is UL approved for fire pump service. Engine NT-380-IF listed and FM approved for fire service.

Data Sheets

CAR-SH-M-20, Rev.

2, Sec. 13.4 HNP-M/BMRK-0007 Page 59 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 622 Ratings 622.a The engine shall have a bare engine brake DR JC

CAR-SH-M-20, Rev. The diesel engine is rated at 303 horsepower at horsepower rating at least 20% greater than the 2, Sec. 6, 12B 1900 rpm, which is approximately 14% greater maximum brake horsepower required to drive

AR 25060 than the 265 required fire pump brake the fire pump at rated revolutions per minute of horsepower for design conditions of 2500 gpm the pump unit. at 125 psi, and rated rpm of 1760.

Note: The 20 per cent excess power takes Note: Reference Section 622.d for increased account of the fact that new production engines horsepower requirements due to the use are permitted to run as low as 5 per cent under of a right angle gear drive.

the official bare engine horsepower curve and that up to 5 per cent may be needed for For justification of the acceptability of this operation of accessories, allowing at least 10 condition, see Attachment 6.

percent reserve power for reliability of performance and for normal depreciation of the engine with age and use.

622.b A deduction of 5% for spark ignition engines DR N/A

CAR-2165-G-209, The diesel engine is installed at approximately and 3 percent for diesel engines for each 1000 ft Rev. 13 262-0 above sea level. As such, the rise in altitude above sea level shall be made to requirements of this code section are not the engine horsepower rating as corrected to sea applicable.

level conditions.

622.c A deduction of 1 percent for every 10°F above DR N/A

Cummins Diesel The average outside temperature at SHNPP is 60°F shall be made to the engine horsepower Engine NT-380-IF 79°F (summer) and 41.3°F (winter), from which rating as corrected to sea level conditions. Data Sheets it can be estimated that the average daily

CAR-SH-M-62, Rev. temperature is approximately 60°F. It is 3, Sec. 2.01 therefore reasonable to conclude that no horsepower rating deduction per the requirements of this section is applicable.

622.d When the authority having jurisdiction permits DR JC

CAR-SH-M-20, Rev. A Randolph 300 HP capacity right angle gear the use of gear drives between the pump and its 2, Sec. 13.2 drive is used between the pump and the diesel driver, (see 623a) the horsepower requirement of

NUREG-1038, p. 9-51 engine, as approved by the NRC for HNP as part the pump should be increased to allow for power

1364-1675, Rev. 1 of the fire protection water supply system. The losses. horsepower requirement of the pump should, HNP-M/BMRK-0007 Page 60 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A)

AR 25060 therefore, be increased to allow for power losses. The right angle gear drive has a gear ratio of 11:10, which translates to 1956 driver rpm required to achieve the rated pump rpm of 1760.

Note: Since the bare engine brake horsepower rating of the diesel engine does not comply with the 20% code requirement stated in Section 622.a, the increased horsepower requirement due to the right angle gear drive must be factored into any evaluation of the acceptability of the installed diesel engine.

For justification for the acceptability of this condition, see Attachment 6.

622.e Engines listed for fire pump service by a DR Y

Cummins Diesel The diesel engine was manufactured by nationally recognized testing laboratory may be Engine NT-380-IF Cummins Engine Co., Inc. and is UL listed and accepted for horsepower ratings established by Data Sheets FM approved for fire service applications.

the laboratories.

623 Connection To Pump 623.a Except where otherwise permitted by the AHJ WD & DR Y

WD The diesel driven fire pump is a vertical shaft the engine shall be directly connected to a

VM-UJL, Rev. 0 turbine. The diesel engine is properly connected horizontal shaft pump by means of a flexible

1364-1691, Rev. 1 to the right angle gear drive.

coupling of suitable design. Vertical shaft pumps shall have the engine connected to the right angle drive with suitable universal joints.

623.b Dual drive units are not recommended. The use DR N/A

CAR-2165-G-209, Dual drive units are not installed at SHNPP.

of separate pumps provides greater flexibility Rev. 13 The requirements of this code section are and reliability. Where dual drive is used, the therefore not applicable.

coupling should be of an automatic type acceptable to the AHJ and the engine drive shall HNP-M/BMRK-0007 Page 61 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) be equipped with an approved free-wheeling clutch. If the other drive is an electric motor, it too shall be equipped with an approved free-wheeling clutch.

624 Instrumentation And Control 624.a GOVERNOR: - An adjustable governor shall be DR JC

Cummins Diesel The diesel engine is provided with a mechanical provided for the engine to regulate the speed Engine NT-380-IF flyball, mechanical variable speed type governor within a range of 10% between shutoff and Data Sheets to regulate engine speed. Although no reviewed maximum load conditions of the pump. It shall documents indicated the governor settings, the be set to maintain rated pump speed at referenced data sheets stated that the engine maximum pump load. would be furnished with safety engine switches in compliance with NFPA Bulletin 20.

624.b EMERGENCY GOVERNOR: - An emergency DR Y

PIC-I305, Rev. 3, p. 5 The diesel engine is equipped with a Syncrostart governor shall be provided for a diesel engine.

CAR-2166-B-401, Sh. Model CO-2M 210314 Over-Speed switch It should be arranged to shut down the engine at 2583, Rev. 6 which is set to shut down the engine at 2200 a speed approximately 20% above rated engine

Cummins Diesel rpm, approximately 15% above the rated engine speed. The emergency governor shall be Engine NT-380-IF speed of 1900 rpm. The device is arranged for arranged for manual reset. The position of the Data Sheets manual reset, and is supervised such that emergency shutdown device shall be supervised shutdown is annunciated at the controller panel so that the automatic engine controller will as well as at ALB-30.

continue to show an overspeed trouble signal until the device is reset to normal operating position.

624.c TACHOMETER - A tachometer shall be WD & DR Y

WD The diesel engine features an hour meter type provided to indicate rpm of the engine. It shall

1364-1693, Rev. 1 tachometer which indicates engine rpm as well be the totalizing type or an hour meter shall be as total engine operation time.

provided to record total time of engine operation.

624.d OIL PRESSURE GAGE - An oil pressure gage WD & DR Y

WD The diesel engine features an oil pressure gage shall be provided to indicate engine lubricating

1364-1693, Rev. 1 which indicates engine lubricating oil pressure.

oil pressure.

HNP-M/BMRK-0007 Page 62 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 624.e TEMPERATURE GAGE - A temperature gage WD & DR Y

WD The diesel engine features a temperature gage shall be provided to indicate engine cooling

1364-1693, Rev. 1 which indicates engine cooling water water temperature. temperature.

624.f CONTROL PANEL - All instruments of control WD & DR Y

WD The circuit breaker, water temperature gage, such as gages, switches, indicators and coils

1364-1693, Rev. 1 ammeter, lube oil pressure gage, tachometer-should be placed on a suitable board secured to hour meter, 24 vdc junction box, and vernier the unit at a suitable point. throttle are located on an instrument panel that is attached to the engine.

624.g FACTORY WIRING - AUTOMATIC DR Y

P.O. NY-435007 The referenced Purchase Order required that all CONTROLLER - All connecting wires for the switches shall be prewired to an enclosed, automatic controller shall be harnessed or labeled terminal strip mounted on the engine, flexibly enclosed, mounted on the engine and and that terminals shall be labeled to correspond connected in an engine junction box to terminals to those of the Auto Control panel.

numbered to correspond with numbered terminals in the automatic controller, for ready wiring in the field between the two sets of terminals.

624.h MAIN BATTERY CONTACTORS - Main WD Y

WD Diesel Engine main battery contactors are battery contactors shall be manually operable in manually operable.

case of control circuit failure.

625 Starting Methods 625.a Compression ignition diesel engines should WD & DR Y

WD The diesel engine is started by a 24 vdc electric preferably be equipped with an electric starting

CAR-2166-B-401, Sh. starting motor taking current from four 12V device taking current from a storage battery, but 2583, Rev. 6 batteries.

may be started by other reliable means.

625.b If air starting of diesel engines is used with air WD & DR N/A

WD The diesel engine is started by a 24 vdc electric pressure in excess of 100 pounds gage pressure,

CAR-2166-B-401, Sh. starting motor taking current from four 12V the air tanks shall be so located or guarded as 2583, Rev. 6 batteries, rather than by air pressure. The not to be subject to mechanical injury. For air requirements of this code section are therefore starting there shall be at least two containers not applicable.

each sufficient for six consecutive starts without HNP-M/BMRK-0007 Page 63 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) recharging. There shall be a separate air compressor, suitably powered, or means of obtaining air from some other system shall be installed, independent of any compressor driven by the engine operating the fire pump.

Automatic maintenance of air pressure is preferable, but in all cases suitable supervisory service shall be maintained to indicate high and low pressure conditions.

625.c If a gasoline starting engine is used to crank the WD & DR N/A

WD The diesel engine is started by a 24 vdc electric diesel engine, or gasoline is used in connection

CAR-2166-B-401, Sh. starting motor taking current from four 12V with electric ignition, the handling and storage 2583, Rev. 6 batteries, rather than by a gasoline starting of gasoline shall be as required for gasoline engine. The requirements of this code section engine driving of centrifugal fire pumps. are therefore not applicable.

Note: Electric current for ignition may be taken from the storage battery or from a high tension magneto.

625.d Gasoline engines shall be equipped with an WD & DR N/A

WD The diesel engine is started by a 24 vdc electric electric starting device taking current from the

CAR-2166-B-401, Sh. starting motor taking current from four 12V storage battery. 2583, Rev. 6 batteries, rather than by a gasoline starting engine. The requirements of this code section are therefore not applicable.

626 Storage Battery 626.a The battery shall have sufficient capacity, at WD & DR JC

WD Four 12V batteries, maintained at a temperature 40°F, to maintain the engine manufacturers

Cummins Diesel of between 60°F and 80°F by heater pads, are recommended cranking speed during the Engine NT-380-IF provided for starting the diesel engine.

following 6 minute cycle (15 seconds crank and Data Sheets Although no reviewed documents identified 15 second rest in 12 consecutive cycles). The

FPT-3010, Rev. 9 recommended cranking speed or documented fire pump manufacturer shall provide a

MPT-E0019, Rev. 4 compliance based on the specified 6 minute certification that the battery which was furnished cycle, the supplied batteries are considered complies with this requirement. acceptable since their engine starting capability HNP-M/BMRK-0007 Page 64 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) is verified monthly by the referenced FPT procedure and the batteries are inspected and tested weekly by the referenced MPT procedure.

626.b Lead Acid - Batteries shall be furnished in a dry DR Y

P.O. NY-435007 The referenced purchase order indicated that the charge condition with electrolyte liquid in

MPT-E0020, Rev. 3 seller furnished Lead Acid batteries in a dry separate container. Electrolyte should be added charged condition, and that electrolyte was at the time the unit is put into service. The provided. Reviewed documents did not describe battery shall then be given a conditioning charge initial conditioning of batteries, however, the to bring the electrolyte up to its designated referenced MPT procedure verifies diesel fire specific gravity. pump engine battery specific gravity (i.e.,

electrolyte level) on a quarterly basis, ensuring compliance with the intent of this code section.

626.c Nickel Cadmium - A nickel cadmium alkaline DR N/A

P.O. NY-435007 Lead acid batteries are used to start the diesel type battery may be used where desired in place engine rather than Nickel Cadmium. The of the lead acid battery described above. requirements of this code section are therefore not applicable.

626.d Recharging - Two ways of recharging storage DR Y

CAR-2166-B-401, Sh. Two ways of recharging storage batteries are batteries shall be provided. One shall be the 2583, Rev. 6 provided. The batteries are maintained generator furnished with the engine. The other automatically charged by the battery charger shall be an automatically controlled charger installed as part of the engine control panel, and taking power from an alternating power source. they can also be charged by the engine (Other charging methods must be specified if a alternator.

reliable alternating power source is not available) 626.e Chargers 626.e.1 All chargers shall be specifically approved for WD & DR Y

WD The battery charger was supplied as part of the fire pump service.

P.O. NY-435007 fire pump controller (Lexington Standard Model

CAR-2166-B-401, Sh. LX-1000), which is UL listed and FM approved 2583, Rev. 6 for fire service.

626.e.2 The rectifier shall be of the semiconductor type. DR JC

P.O. NY-435007 Reviewed documents did not indicate whether

CAR-2166-B-401, Sh. the rectifier is of the semiconductor type.

HNP-M/BMRK-0007 Page 65 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 2583, Rev. 6 However, the battery charger was supplied as part of the UL listed / FM approved fire pump controller, providing reasonable assurance that the requirement of this code section was fulfilled.

626.e.3 The charger for a lead acid battery shall be of a DR Y

P.O. NY-435007 Reviewed documents did not indicate whether type which automatically reduces the charging

CAR-2166-B-401, Sh. the battery charger automatically reduces the rate to less than 500 milliamperes when the 2583, Rev. 6 charging rate per this code section. However, battery reaches a full charge condition. the battery charger was supplied as part of the UL listed / FM approved fire pump controller, providing reasonable assurance that the requirements of this code section were fulfilled.

626.e.4 The control equipment incorporated in an off- DR Y

P.O. NY-435007 Reviewed documents did not indicate whether on type of charger for a lead acid battery shall

CAR-2166-B-401, Sh. the battery charger control equipment functions start the rectifier hourly and automatically shut 2583, Rev. 6 per this code section. However, the battery off when the battery has been fully charged. charger was supplied as part of the UL listed /

FM approved fire pump controller, providing reasonable assurance that the requirements of this code section were fulfilled.

626.e.5 The battery charger shall be capable of DR Y

P.O. NY-435007 Reviewed documents did not indicate whether delivering energy into a fully discharged battery

CAR-2166-B-401, Sh. the battery charger can fully charge batteries in such a manner that it will not damage the 2583, Rev. 6 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per this code section. However, battery and will restore to the battery 100% of the battery charger was supplied as part of the the battery's ampere hour rating within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . UL listed / FM approved fire pump controller, providing reasonable assurance that the requirements of this code section were fulfilled.

626.e.6 An ammeter of an accuracy of 5% of the normal DR Y

P.O. NY-435007 Reviewed documents did not indicate whether charging rate shall be furnished to indicate the

CAR-2166-B-401, Sh. an ammeter of the type required was provided.

operation of the charger. 2583, Rev. 6 However, the battery charger was supplied as part of the UL listed / FM approved fire pump controller, providing reasonable assurance that the requirements of this code section were HNP-M/BMRK-0007 Page 66 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) fulfilled.

626.e.7 The charger shall be so designed that it will not DR Y

P.O. NY-435007 Reviewed documents did not indicate whether be damaged or blow fuses during the cranking

CAR-2166-B-401, Sh. charger was designed per this code section.

cycle of the engine when operated by an 2583, Rev. 6 However, the battery charger was supplied as automatic or manual controller. part of the UL listed / FM approved fire pump controller, providing reasonable assurance that the requirements of this code section were fulfilled.

626.e.8 A single charger that automatically alternates DR Y

P.O. NY-435007 The installed unit is used to charge all four 12V from one battery to another on an hourly cycle

CAR-2166-B-401, Sh. batteries. Reviewed documents did not indicate may be used on two battery installations. 2583, Rev. 6 whether the charger alternates among batteries per this code section. However, the battery charger was supplied as part of the UL listed /

FM approved fire pump controller, providing reasonable assurance that the requirements of this code section were fulfilled.

626.e.9 A manual charge switch with indicator light WD & DR Y

WD The battery charger provided with the diesel shall be provided or in lieu thereof, the charge

P.O. NY-435007 driven fire pump is of the automatic type.

shall automatically charge at the maximum rate

CAR-2166-B-401, Sh.

when required by the state of charge of the 2583, Rev. 6 battery.

626.f Location: - Storage batteries shall be WD Y

WD Batteries are located on the ESWISS concrete substantially supported, secured against slab adjacent to, and at essentially the same displacement, and located where they will not be elevation as, the engine controller and the diesel subject to excessive temperature, vibration, engine. The batteries are contained in mechanical injury, or flooding with water, and weatherproof steel enclosures which are easily are readily accessible for servicing. Location at accessible but are not subject to excessive the side of and level with the engine is temperature, mechanical injury or flooding.

recommended to minimize battery to starter lead length.

627 Cooling HNP-M/BMRK-0007 Page 67 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 627.a The engine cooling system shall be of the closed WD & DR Y

WD The engine cooling system is of the closed circuit type including a circulating pump drive

VM-MJD, Rev. 6, p. circuit type including a heat exchanger and an by the engine, a heat exchanger and a reliable S1-28 engine jacket temperature thermostat (120-engine jacket temperature regulating device

Cummins Diesel 140°F). Water is circulated by fire pump (Fail Safe type of thermostat). An opening Engine NT-380-IF pressure. An opening is provided in the heat shall be provided in this circuit for filling the Data Sheets exchanger to add liquid and check the coolant system, checking coolant level, and adding level.

make-up water when required.

627.b The cooling water supply for the heat exchanger WD & DR Y

WD The cooling supply for the heat exchanger is shall be from the discharge of the fire pump

VM-MJD, Rev. 6, p. taken from the discharge side of the fire pump, taken off prior to the pump discharge valve. S1-28 is of threaded, galvanized schedule 40 piping, Threaded rigid piping shall be used. The pipe

Cummins Diesel and contains the valves, regulator and connection shall include a manual shutoff valve, Engine NT-380-IF accessories required by this code section.

a strainer, a pressure regulating valve, an Data Sheets automatic electric solenoid valve (when required) and a second manual shut-off valve.

Provision should be made for a pressure gage to be installed in the cooling water supply system on the engine side of the last control valve.

627.c A by-pass line with a manual valve shall be WD & DR Y

WD A by-pass line is provided per the requirements installed around the manual shut-off valve,

VM-MJD, Rev. 6, p. of this code section.

strainer, pressure regulating valve, automatic S1-28 solenoid valve (when required) and second

Cummins Diesel manual shut-off valve. Engine NT-380-IF Data Sheets 627.d An outlet shall be provided for the waste water WD &DR Y

WD The waste pipe outlet line from the heat line from the heat exchanger and the line shall

1364-1693, Rev. 1 exchanger is of 11/2 diameter, larger than the 1 be at least one size larger than the inlet line. The

VM-MJD, Rev. 6, p. diameter inlet piping. Waste discharge is into an outlet line shall be short, with the discharge into S1-28 open cone, with no valves installed in the waste a visible open waste cone, and no valves shall be line.

used in this line.

HNP-M/BMRK-0007 Page 68 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 627.e A water jacketed (cooled) exhaust manifold WD & DR Y

WD The diesel engine features a water cooled shall be used since no fan is available to

Cummins Diesel exhaust manifold.

dissipate heat and to avoid hazard to operators or Engine NT-380-IF flammable material adjacent to the engine. This Data Sheets exhaust manifold should be cooled by raw water discharging from the heat exchanger.

628 Carburetion 628.a If a down-draft carburetor is used, suitable DR N/A

1364-1693, Rev. 1 The diesel engine is fuel-injected and does not provision shall be made in addition to the

VM-MJD, Rev. 6, p. feature a carburetor. The requirements of this carburetor float valve to prevent delivery of S3-66 code section are therefore not applicable.

liquid gasoline to the engine cylinders.

Note: This is usually accomplished by a drain from the intake manifold. This should be piped to a safe location.

628.b The carburetor drip cup drain should be piped at DR N/A

1364-1693, Rev. 1 The diesel engine is fuel-injected and does not its lower end to a safe location.

VM-MJD, Rev. 6, p. feature a carburetor. The requirements of this S3-66 code section are therefore not applicable.

629 Anti-Dieseling Devices 629.a Anti-dieseling devices. A reliable and effective DR N/A

1364-1693, Rev. 1 The diesel engine runs on No. 2 diesel fuel anti-dieseling device shall be provided on

Cummins Diesel rather than gasoline. The requirements of this automatically controlled spark-ignited gasoline Engine NT-380-IF code section are therefore not applicable.

engines with a displacement of 350 cubic inches Data Sheets and larger to insure positive shutdown without dieseling. Control for the device shall be provided by the automatic engine controller or supplemental accessories to the controlled engines.

629.b Less than 350 cubic inch displacement engines DR N/A

1364-1693, Rev. 1 The diesel engine runs on No. 2 diesel fuel shall also be equipped with this device unless

Cummins Diesel rather than gasoline. The requirements of this approval tests show that it is unnecessary. Engine NT-380-IF code section are therefore not applicable.

Data Sheets HNP-M/BMRK-0007 Page 69 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 630 Location 631 Construction 631.a While it may not always be possible to locate a WD Y

WD The diesel engine driven fire pump is located fire pump driven by an internal combustion outside of and directly adjacent to the South wall engine in a separate pump house it is in every of the ESWISS. The building is of solid case highly important that the pump room be concrete construction and has no openings of wholly cut off by noncombustible construction any kind on the South wall. The Auxiliary of a heavy character. Reservoir is directly to the East of the engine, and the areas directly to the North and West consist of open ground with no equipment or building. The engine itself is fully protected by a sheet steel enclosure. Additionally, the diesel engine is separated from the motor driven fire pump and the jockey pump by the ESWISS building and a distance of approximately 104 feet.

631.b Floors should be pitched for adequate drainage WD Y

WD The concrete slab in the vicinity of the of escaping water or fuel away from critical equipment is pitched to promote drainage, which equipment such as pump, driver, controller, fuel is further enhanced by the presence of grating tank, etc. and the Auxiliary Reservoir within 10 to 15 feet of the equipment.

Note: A curb is provided around the Diesel Fuel Oil tank to contain spilled fuel and prevent it from spreading in case of a fire.

631.c Where fire pumps constitute the entire water WD N/A

WD Gasoline engine driven fire pumps are not used supply or where they constitute the major water as SHNPP. The requirements of this code supply, gasoline engine driven fire pumps section are therefore not applicable.

located in the same room with fire pumps driven by other methods should, because of their possible fire hazard, have a heat resistant barrier HNP-M/BMRK-0007 Page 70 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) wall to isolate the gasoline engine from other pumping units.

632 Ventilation 632.a Means for thorough ventilation shall be WD Y

WD Ample ventilation is available for the diesel provided, adequate for engine air supply and for engine, which is located outside and has remove of hazardous vapors. louvered panels built into the sheet steel cabinet in which it is enclosed..

632.b Gasoline engine driven fire pump units should WD N/A

WD Gasoline engine driven fire pumps are not used not be installed in depressed pump rooms. as SHNPP.

Installation shall be such that escaping gasoline vapors cannot accumulate in e pump room or vicinity.

640 Fuel Supply Arrangement 641 Review Of Plan: - Before any system is DR Y

NUREG-1038, p. 9-51 The fuel supply arrangement for the diesel installed the AHJ should be consulted as to the

FSAR Sec. 9.5.1, p. 20 engine, as part of the fire protection water system proposed to the end that the suitability of supply system, was approved by the NRC.

the system for conditions be determined.

642 Guards: - A guard or protecting pipe shall be WD Y

WD Exposed fuel lines from the Diesel Fuel Oil tank provided for all exposed fuel lines. and near the Diesel engine are protected by steel instrument tube raceways.

643 Diesel 643.a Capacity Diesel Fuel Supply:- The capacity of DR Y

FSAR, Sec. 9.5.1, p. The diesel engine fuel supply, as part of the fire the main diesel fuel supply tank shall be 22 protection water supply system, was approved determined by conditions and subject to special

Cummins Diesel by the NRC. Fuel tank capacity is 550 gallons, consideration in each case by the AHJ; Engine NT-380-IF which will provide sufficient fuel to operate the minimum storage capacity shall be sufficient to Data Sheets diesel engine for more than 34 hours3.935185e-4 days 0.00944 hours 5.621693e-5 weeks 1.2937e-5 months at the operate the engine for at least eight hours, and

FPP-013, Rev. 33, Sec. estimated fuel consumption rate of 15.75 gallons greater capacity should be provided in places 8.1.3 per hour (295 hp @ 1900 rpm). The minimum where prompt replenishment of supply is

NUREG-1038, p. 9-51 allowable fuel level of 130 gallons will operate unlikely. There shall be a separate fuel line and the diesel engine for more than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . There fuel tank for each engine. Where multiple is only one diesel engine and one fuel tank.

HNP-M/BMRK-0007 Page 71 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) engine drive pumps are used , the fuel lines shall be interconnected and valved so that all engines may continue to operate even though one or more fuel tanks may be out of service.

643.b Location Diesel Fuel Supply: - The tank shall be WD & DR Y

WD The diesel engine fuel supply location, as part of located in accordance with municipal

FSAR, Sec. 9.5.1, p. the fire protection water supply system, was ordinances, and requirements of the AHJ. 22 approved by the NRC. The tank is UL listed, Means shall be provided for determining the

Cummins Diesel and is equipped with suitable filling and vent amount of fuel in the storage tank. The tank Engine NT-380-IF connections. The tank features a gage which should have suitable filling and vent Data Sheets measures inches of water, and an adjacent sign connections.

1364-1697, Rev. 3 provides conversion to gallons of fuel.

NUREG-1038, p. 9-51 643.c Diesel Fuel Piping: - NFPA 31 may be used as a WD & DR Y

WD. A flexible connection is used to connect the fuel guide. A suitable flexible connection of

1364-1697, Rev. 3 line to the engine fuel piping system. No shutoff approved metallic type shall be provided in the

CAR-2165-G-209, valves are installed in the return line to the fuel fuel line where it connects to the engine fuel Rev. 13 tank.

piping. No shutoff valve shall be installed in the fuel return line to the tank.

644 Natural Gas DR N/A

FSAR Sec. 9.5.1, p. 22 No. 2 Diesel fuel oil is used for the diesel engine. The requirements of this code section are therefore not applicable.

645 Gasoline DR N/A

FSAR Sec. 9.5.1, p. 22 No. 2 Diesel fuel oil is used for the diesel engine. The requirements of this code section are therefore not applicable.

646 Gasoline Piping DR N/A

FSAR Sec. 9.5.1, p. 22 No. 2 Diesel fuel oil is used for the diesel engine. The requirements of this code section are therefore not applicable.

650 Exhaust Piping 651 Exhaust Piping - Exhaust from the engine shall WD & DR Y

WD The diesel engine, since it is installed outdoors, be piped to a safe point outside the pump room

1364-1693, Rev. 1 exhausts directly to the outside air. The exhaust and arranged to exclude water. A seamless or

Cummins Diesel pipe is short (less than 3 feet) and is attached to HNP-M/BMRK-0007 Page 72 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) welded corrugated (not interlocked) flexible Engine NT-380-IF a horizontally mounted silencer (muffler) with a connection shall be made between the engine Data Sheets seamless bellows-type flexible connector. The exhaust outlet and the exhaust pipe. The exhaust outlet of the silencer is provided with a exhaust pipe shall be as short as possible and not rain cap. The exhaust assembly is insulated over 15 feet unless the size of exhaust pipe is from combustible material by the sheet steel of increased at least one pipe size, and shall be the diesel engine enclosure and heat resistant properly insulated from combustible material. aluminum paint applied to the silencer. The use Muffler, receiving vessel or other attachments of a silencer (muffler) is acceptable due to its which may accumulate unburned gases are not outdoor location.

recommended, but if used shall not be located in the pump room. Exhaust gases should not be discharged where they will affect persons or endanger buildings, flues or stacks. A free and independent exhaust is essential to the reliability of the equipment.

660 Maintenance 661 General - Internal combustion engines DR Y

VM-MJD, Rev. 6 The referenced procedures implement necessarily embody moving parts of such design

FPP-013, Rev.33, Sec. comprehensive inspection and preventive and in such number that the engines cannot give 8.1.3 maintenance activities which are performed on reliable service unless given intelligent care.

MPT-M0036, Rev. 8 the diesel engine every 18 months. The The manufacturers instruction book covering referenced Vendor Manual (VM) contains the care and operation should be preserved and maintenance information on the diesel engine.

pump operators should be familiar with its Personnel assigned to operate, inspect, test and contents and should observe in detail all of its maintain the pump are provided with training.

provisions.

662 Weekly Run: The engine shall be started at least DR JC

FPP-013, Rev.33, Sec. The diesel engine driven fire pump is started and once a week and run for at least thirty minutes to 8.1.3 operated each month for a minimum of 30 bring it up to normal running temperature and to

FPT-3010, Rev. 9, minutes.

make sure that it is running smoothly at rated Sec. 1, 6 The referenced procedures require the pump to speed.

AR 25060 be operated monthly for 30 minutes. This frequency meets the requirements of Nuclear HNP-M/BMRK-0007 Page 73 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A)

Electric Insurance Limited (NEIL) and of FPP-013, Section 8.1.3. However, this does not meet the requirement of this code section.

For a discussion of the acceptability of this condition, see Attachment 6.

663 Fuel Tank:- The fuel storage tank shall be kept DR Y

FPP-013, Rev. 33, Sec. The diesel fuel oil tank minimum operable fuel well supplied. This tank should always be filled 8.1.3 level is 130 gallons, and a level of less than 225 through strainer funnel designed to withhold any

OP-149, Rev. 17, p. 6 gallons will trigger a low fuel level alarm.

water or other foreign matter that may be Requirements for service tanks and gasoline present. Any service tank shall also be kept full.

storage tanks are not applicable to SHNPP.

Note: Gasoline deteriorates with age. It is therefore desirable that gasoline storage tanks be drained and refilled with fresh supply at least once each year. The occasional use of an upper lubricant is desirable for smooth operation of the engine and preventing sticking valves 664 Engine Upkeep:- The engine should be kept DR Y

FPT-3010, Rev. 9, The engine oil level is checked monthly prior to clean, dry and well lubricated, and the proper oil Sec. 7.1 the operability test. Oil is changed at least once level should be maintained in the crankcase. Oil

MPT-M0036, Rev. 8 every 18 months per the referenced MPT should be changed in accordance with engine

FPP-013, Rev. 33, Sec procedure, which was prepared in conjunction manufacturers recommendations, but at least 8.1.3 with the engine manufacturers annually. recommendations for the class of service. This interval meets the frequency requirements of FPP-013, Sec. 8.1.3.

665 Storage Batteries 665.a Storage batteries should be kept charged at all DR Y

FPP-013, Rev. 33, Sec The referenced procedures require that he times and tested frequently with a hydrometer to 8.1.3 batteries are inspected monthly to verify that the ascertain the condition of the cells and the

MPT-E0019, Rev. 4 electrolyte level of each battery is above the amount of charge in the battery. plates and the overall voltage is greater than or equal to 24 volts.

HNP-M/BMRK-0007 Page 74 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 665.b Distilled water only should be used in storage DR Y

MPT-E0019, Rev. 4 Distilled or demineralized water is used to raise battery cells and the plates should be kept the water level to the required level.

submerged at all times.

665.c An automatic battery charger is not a substitute DR Y

MPT-E0020, Rev. 3 Quarterly, the electrolyte temperature and for proper maintenance of the battery and

MPT-E0021, Rev. 4 specific gravity are checked for adequacy.

charger. Periodic inspection of the battery and Every 18-months, the batteries, cell plates, the charger shall be made. This inspection battery boxes, jumpers and connecting cables should determine that the charger is operating are inspected for any indication of damage or correctly, the water level in the battery is abnormal deterioration.

correct, and the battery shall be checked by means of a hydrometer to show it is maintaining its proper charge.

666 Temperature 666.a Pump room temperatures must be maintained WD & DR JC

WD No pump room is provided at SHNPP. The above 40°F.

NUREG-1038, p. 9-51 engine driven fire pump diesel engine is installed outdoors at the location of the ESWISS. This arrangement, as part of the fire protection water supply system, was approved by the NRC.

666.b Diesel engines, at temperatures below 70°F, may DR Y

P.O. NY-435007 The diesel engine is provided, by the require some form of starting aid as

Cummins Diesel manufacturer, with an electric jacket water recommended by the engine manufacturer. Engine NT-380-IF heater and lube oil heater, with thermostat Data Sheets control (on at 120°F - off at 140°F) as a starting aid.

666.c Automatically started engines should be DR Y

P.O. NY-435007 The diesel engine, installed outdoors and installed in enclosed pump rooms where a

Cummins Diesel equipped with the starting aid described in minimum of temperature of 60°F for gasoline Engine NT-380-IF section 666.b, has been approved, as part of the engines and 70°F for diesel engines is Data Sheets fire protection water supply, by the NRC. Also, maintained.

NUREG-1038, p. 9-51 this code section delineates a recommendation rather than a mandatory requirement.

666.d Since fire pump engines must carry full load as WD & DR Y

WD The diesel engine is provided, by the HNP-M/BMRK-0007 Page 75 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) soon as started, automatic heaters should be

P.O. NY-435007 manufacturer, with an electric jacket water employed to maintain jacket water temperatures

Cummins Diesel heater with thermostat control (on at 120°F - off of liquid cooled engines at (a minimum of 120F) Engine NT-380-IF at 140°F) as a starting aid.

or near operating temperature. This may be Data Sheets accomplished through the circulation of hot water through the jacket or through heating of engine water by electric elements inserted into the block. The benefits to be gained are (1) quick starting, (2) reduction in engine wear, (3) reduced drain on batteries, (4) reduced oil dilution, (5) reduction in carbon deposits, and (6) with gasoline fueled engines it becomes possible to adjust the automatic choke so that the engine is far more likely to start every time.

667 Parts: - Spare parts of such portions of the DR Y

MPT-M0036, Rev. 8 The referenced procedure identifies commonly machine as may be expected to give trouble used spare parts and corresponding assigned should be kept on hand. CP&L part numbers. These parts are maintained on site or can be requisitioned for receipt in a timely manner.

Chapter Engine Drive Controllers 700 710 Requirements for All Controllers 711 General 711.a The following specifications cover controlling N/A General design information. No verification is equipment of the combined non-automatic and required.

automatic types for internal combustion engines driving centrifugal fire pumps. Chapter 600 dealing with the internal combustion engine drive also applies where appropriate.

711.b Automatic type controllers are recommended for N/A General design information. No verification is use only where the fire pump takes its water required.

HNP-M/BMRK-0007 Page 76 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) under positive pressure and their use is not recommended where a suction lift is involved.

711.c All controllers shall be specifically approved for DR Y

P.O. NY-435007 The diesel driven fire pump is provided with an fire pump service. automatic fire pump controller (Lexington Standard Model LX-1000), which is UL listed and FM approved for fire service.

711.d The control panel shall be completely DR Y

P.O. NY-435007 The reviewed documents did not specify precise assembled, wired and tested by the manufacturer adherence to the requirements of this section.

before shipment from the factory. However, the specified equipment was provided by the seller, accepted by CP&L, installed, and has been functioning continuously as a part of the SHNPP fire protection water supply system since that time. It can be reasonably concluded that the intent of this code section has been fulfilled.

711.e Controllers conforming to this Standard shall be WD Y

WD The diesel driven fire pump controller bears a marked Fire Pump Controller and shall show label marked Automatic Fire Pump Controller plainly the name of the manufacturer, the and containing the information required by this identifying designation and the complete code section.

electrical rating.

711.f The services of a representative of the DR JC

P.O. NY-435007 The referenced purchase order included an manufacturer may be required for installation option for the sellers supervising and/or start-up and adjustment of the equipment. It shall be the field service engineer if requested by the responsibility of the installing contractor to purchaser. This may have occurred, although no make the necessary arrangements for this reviewed documents confirmed whether this service. option was requested or whether the requirements of this code section were specifically fulfilled.

However, the fire pumps, controllers, and associated equipment have been in continuous service since their initial installation and are HNP-M/BMRK-0007 Page 77 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) subject to ongoing testing and maintenance as delineated by SHNPP procedures. Verification of initial installation and adjustment is therefore essentially meaningless.

712 Location 712.a The controller shall be located as close to as is WD Y

WD The engine driven fire pump controller is practical and within sight of the engine. located approximately 10 feet from, and within sight of, the diesel engine.

712.b The controller shall be so located or protected WD Y

WD The engine driven fire pump controller (fully that it will not be injured by water escaping from enclosed in a metal cabinet) is located the pump or connections. approximately 6 feet from the pump and further from pump connections, all of which are located below the slab upon which the controller rests.

As such, the controller is not subject to injury from escaping water.

712.c A clearance of not less than 2-1/2 feet shall be WD N/A

WD The controller enclosure, which is mounted provided at the rear of enclosures designed to be flush to the ESWISS South wall, is not designed inspected and serviced from the rear. for inspection and service from the rear. The requirements of this code section are therefore not applicable.

713 General Construction 713.a Equipment. All equipment shall be suitable for WD & DR Y

WD The controller is contained in a NEMA III floor use in locations subject to a moderate degree of

P.O. NY-435007 mounted, dust and moisture resistant enclosure.

moisture such as a damp basement. Reliability

1364-1812, Rev. 2 of operation shall not be adversely affected by

1364-1814, Rev. 1 normal dust accumulations.

Note: In areas affected by excessive moisture, heat may be useful in reducing the dampness.

713.b Mounting. All equipment except engine WD & DR Y

WD The controller, and all equipment that is not mounted shall be mounted in a substantial

P.O. NY-435007 engine mounted, is contained in a NEMA III manner on a single, noncombustible supporting

1364-1812, Rev. 2 floor mounted, dust and moisture resistant HNP-M/BMRK-0007 Page 78 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) structure. enclosure. The enclosure rests on the ESWISS concrete slab.

713.c Enclosure. The structure or panel shall be WD & DR Y

WD The panel is contained in a NEMA III floor securely mounted in an enclosure(s) which will

P.O. NY-435007 mounted, dust and moisture resistant enclosure.

protect the equipment against mechanical injury

1364-1812, Rev. 2 The enclosure provides adequate protection and falling drops of water striking the enclosure against mechanical injury and falling water.

from the downward vertical.

713.d Locks: All switches required to keep the WD & DR JC

WD The controller panel is provided with a cabinet controller in the automatic position shall be

1364-1812, Rev. 2 lock. A break glass panel covers switches within locked cabinets having break glass

AR 25060 required to keep the controller in the panels.

NAS Fire Protection automatic position. However, the cabinet is Audit H-FP-00-01 not kept locked.

For a discussion of the acceptability of this condition, see Attachment 6.

713.e Wiring Diagrams 713.e.1 A wiring diagram shall be provided and DR JC

1364-1812, Rev. 2 The referenced documents, which are wiring, permanently attached to the inside of the

1364-1813, Rev. 3 schematic, and other electrical diagrams for the enclosure showing exact wiring for this

1364-1814, Rev. 1 diesel driven fire pump controller, are controller including a legend of identifying

1364-1815, Rev. 1 maintained by the SHNPP document control numbers of individual components.

1364-1816, Rev. 4 system and are readily retrievable. Therefore, although diagrams were not verified as permanently attached to the inside of each enclosure, the intent of this code section is fulfilled. Field wiring terminals are marked to correspond to the applicable wiring diagrams.

713.e.2 All wiring terminals shall be plainly marked to DR Y

1364-1812, Rev. 2 Field wiring terminals are marked to correspond correspond with the wiring diagram furnished.

1364-1813, Rev. 3 to the referenced wiring diagrams.

1364-1814, Rev. 1

1364-1815, Rev. 1

1364-1816, Rev. 4 713.f Connections and Wiring:

HNP-M/BMRK-0007 Page 79 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) 713.f.1 Wiring elements of the controller shall be DR JC

P.O. NY-435007 The reviewed documents did not confirm designed on a continuous duty basis, except that compliance with the requirements of this code conductors which are in a circuit only during the section. However, the diesel driven fire pump engine starting period may be designed controller and all associated equipment are UL accordingly. listed / FM approved for fire pump service, thus providing reasonable assurance that the requirements of this code section are fulfilled.

713.f.2 Field Wiring. All wiring leading from the panel WD & DR JC

P.O. NY-435007 The reviewed documents did not confirm to the engine and batteries shall have adequate compliance with the requirements of this code carrying capacity and shall be protected against section. However, the diesel driven fire pump mechanical injury. Controller manufacturers controller and all associated equipment are UL specifications regarding distance and wire size listed / FM approved for fire pump service, thus shall be followed. providing reasonable assurance that the requirements of this code section are fulfilled.

713.g Marking. Each operating component of the DR JC

P.O. NY-435007 The reviewed documents did not confirm controller shall be marked to plainly indicate an compliance with the requirements of this code identifying number referenced to the wiring section. However, the diesel driven fire pump diagram. The markings shall be located so as to controller and all associated equipment are UL be visible after installation. listed / FM approved for fire pump service, thus providing reasonable assurance that the requirements of this code section are fulfilled.

713.h Instructions. Complete instructions covering the WD & DR JC

WD Operating instructions are not provided on the operation of the controller shall be provided and

OP-149, Rev. 17, pp. controller, however, OP-149 provides conspicuously mounted on the controller. Pump 10, 132 instructions for operation of the pump.

operators should be familiar with these

FPP-001, Rev. 20 Personnel assigned to operate the pumps have instructions and should observe in detail all of been provided with training as required by the their provisions. SHNPP fire protection program.

714 Components 714.a Alarm and Signal Devices (On Controller) 714.a.1 A pilot lamp(s) shall be provided in the line side WD & DR Y

WD A pilot lamp are provided to indicate the of the starting equipment circuit to indicate that

1364-1813, Rev. 3 controller is in the automatic position with HNP-M/BMRK-0007 Page 80 Rev. 1 Attachment 3

Shearon Harris Nuclear Power Plant Code Compliance Verification Checklist Code of Record: NFPA 20 - 1972 Areas Reviewed: Centrifugal Fire Pumps Comply Code Verification Verification Requirements (Y, N, JC Reference Summary of Results Section Method or N/A) the controller is in the automatic position with

1364-1815, Rev. 1 power available for starting the engine. The power available for starting. The lamp shall be lamp is accessible for replacement.

accessible for replacement. (See also Note in code re: lamp operating voltage) 714.a.2 A pilot lamp shall be provided in each battery WD & DR Y

WD Pilot lamps are provided for each battery bank to supply to indicate that batteries are connected to

1364-1813, Rev. 3 indicate power available.

the controller and are at least partially charged

1364-1815, Rev. 1 when the controller is set in the automatic position.

714.a.3 Pilot lamps and a common bell shall be provided WD & DR Y

WD Pilot lamps and a common bell are provided to to indicate trouble caused by:

1364-1813, Rev. 3 indicate:

a) Low oil pressure in the lubrication

1364-1815, Rev. 1 system. The controller shall provide

1364-1816, Rev. 4 a) Low Lube Oil Pressure means for testing the position of the

CAR-2166-B-401, Sh. b) High Cooling Water Temperature pressure switch contacts without 2583, Rev. 6 c) Engine Failed to Start causing trouble alarms. d) Engine Over-speed b) High engine jacket water temperature.

c) Failure of engine to start automatically.

d) Shutdown from over-speed (diesel only).

714.b Alarm and Signal Devices (Remote). Where the DR Y

CAR-2166-B-401, Sh. Since there is no pump room, the pump pump room is not constantly attended, the 2583, Rev. 6 controller is equipped to operate circuits, controller shall be equipped with contacts (open

1364-1813, Rev. 3 powered by 115V 60 Hz AC, for audible and or closed) to operate circuits powered by a

1364-1815, Rev. 1 visual alarms in the Control Room (which is source other than engine starting batteries, not

1364-1816, Rev. 4 constantly attended) at annunciator cabinet 2, exceeding 125 volts, for audible or visual alarms ALB-30, and visual alarms at the MFDIC in the at a point of constant attendance indicating the Communications Room. Visual alarm following: annunciation in the Control Room consists of a single lamp indicator for a common off station signal. Visual alarm indication at the MFDIC is provided for pump running, pump controller switch turned to MANUAL or OFF, and trouble HNP-M/BMRK-0007 Page 81 Rev. 1 Attachment 3

Oconee NFPA-805 Project Chapter 3 Initiative November 08, 2006 1

Discussion Outline Present Scope Overview of Project Task Discuss Project Deliverables Depict process to document compliance Present Duke Chapter 3 task 1.1 & 1.2 process Discuss future state Fire Protection Program bases document Explain interpretation of interim documentation.

Conclusion 2

Scope of Project Use NFPA-805 Chapter 3 as a roadmap to help define the ONS fire protection classical fire protection program properties.

Chapter 3 is a combination/enhancement of the qualities that are required to create an effective program as derived through a merger of the GDC-3, 10CFR50.48(a), NUREG 0800, and applicable sections of Appendix R (excluding the subsections pertaining to Safe Shutdown Equipment SSEL).

Clearly define the safe today fire protection features in a database as licensed in the current license bases as defined by SERs and letters to the NRC since ONS has a pre-79 license and an shutdown protection methodology.

Evaluate FP features that were evaluated for equivalency with requirements through the past process of 86-10 in a documented control process versus memos to file or left in CAPs.

Create a draft document to be used in the interim to maintain configuration control.

3

Project Deliverables Complete a NEI-04-02 Table B-1 that confirms compliance with each NFPA-805 Chapter 3 line item.

Deliver a report that includes supporting details and references that document compliance with each line item in Table B-1.

Perform a walk down of each FIRE ZONE in the plant to create a current FHA with additional items of interest.

Create a list of potential ignition sources per NUREG-6850 defined bin list descriptions. Any future fire modeling will still require target to source spatial walk downs 4

Determination of Compliance CAZ: Compartment/Area/zone This process was developed to aid our decision process on how to manage those elements required by NFPA-805 that may not obviously meet the intent of the requirement.

5

Project Tasks 1.1 & 1.2 Task 1.1 - populate Table B-1 with available and applicable approved licensing information (presented by Nexus)

Task 1.2 - physically walk down and verify all classical fire protection features and 6850 ignition sources in each fire zone. Relate any fire protection program elements in that zone to prior licensing commitments. (presented by Nexus) 6

Fire Protection Program Document Development Place the information from Task 1.1 and 1.2 in an interim site draft deliverable document to ensure future plant changes take this new information into consideration.

Expect to modify/enhance this interim document as the NFPA 805 Chapter-4 effort evolves and clarifies the needs for classical fire protection elements/features based on the reconstituted safe shutdown and 6850 analysis outputs.

Move forward to analyze and validate any fire protection elements deviation or degradation equivalency.

7

Summary Publish an interim site guidance document for to ensure information is maintained current while the Chapter 4 analysis is finalized Ensure that a maintainable site fire protection licensing roadmap is produced.

Ensure future success in audit traceability of compliance.

Ensure that future configuration control of the data can be achieved Use the deliverable document to support the information required for the license submittal/

transition report.

8

Oconee Nuclear Station NFPA 805 Chapter 3 Transition NEI 04-02 Table B-1 By: Corey Kinsman Nexus Technical Services Corporation 1

Topic Outline 9 NEI 04-02 Requirements 9 Information Gathering (Procedure & Results) 9 Table B-1 Limitations 9 Table B-1 Enhancements 9 Lessons Learned 2

NEI 04-02 Table B-1 Requirements

Columns to include:

- NFPA 805 Chapter 3 requirements

- Mapped to current licensing (similar BTP sections)

- Compliance Statement

- Current Licensing Basis Documents 3

Information Gathering

Procedure

- Searched Fire Protection historical files and electronic database (NEDL)

- Used information from applicable documents to populate compliance statements

Findings

- Electronic searches are limited

No global search & requires correct sub-section

- Out-of-date documents, requiring alternate references

BTP comparisons, commitment matrices, etc.

4

Table B-1 Limitations

Large amounts of supporting information are not conducive to table format

Lengths of information for a single section sometimes stretched over multiple pages

Difficult to navigate and to read 5

Sample Original Table B-1 (Draft) 6

Table B-1 Enhancements

Table completed with high-level summaries

- NFPA 805 section heading

- Method of Compliance

Comply, Not Applicable, Comply with Previous Approval, Does Not Comply, etc.

- Brief Compliance Statement

- Mapped to existing licensing 7

Sample Table B-1 (Draft) 8

Table B-1 Enhancements (cont.)

Table linked to a back-up report that provides the in-depth details and references included in the original Table B-1 format 9

Sample Table B-1 Report (Draft) 10

Table B-1 Enhancements (cont.)

Designed with simplification, usefulness, and maintenance in mind

- Simplification: All references in one location (NEDL),

One-line summaries for quick answers, Reading logic

- Usefulness: Format allows for the Transition Report integration into a new DBD/Licensing document

- Maintenance: Updating information, Navigation to specific sections, No electronic links to references/

Docs in doc. control system 11

Lessons Learned

Keep documents in one place - Doc. Control with better indices

Dont create new configuration management headaches - integrate with existing systems 12

NFPA 805 Chapter 3 Transition Fire Hazards Analysis Verification Oconee Nuclear Station By: Robert A. Jackson, PE Senior Engineer Nexus Technical Services Corporation 1

Chapter 3 Goal

Generate a fire protection feature basis document suitable for transition of NFPA 805 fire-area specific requirements 2

Chapter 3 Interfaces Index B-1 Zone Ig. Source Report Supression Hose Ext. Detection Emerg. Lt.

ELL/NEDL Fire Plans (Maps) 3

Background

Due to potential incomplete documentation of fire protection features, revalidation was required

Oconee may be an outlier in the industry 4

Methodology

Project Instruction

- Standard approach for team implementation

- Documentation of assumptions

- Definitions of data to be gathered

- Checklist for field data

Inaccessible zones

- Done from table-top look using general arrangement and electrical layout drawings and output from the EDB (electrical equipment and motors) 5

Methodology

Drawing Mark-up

- Include location fire protection features and configuration corrections

Review

- Senior FPE review of fire zones to check data gathered (FP features and ignition sources)

- Major hazards protected

- FP feature discrepancies 6

Bin Definitions Bin # Item Criteria Notes 1 Batteries (Battery Room) Interconnected batteries = 1 set 2 Reactor Coolant Pump (Containment) 4 Main Control Board (Control Room) U1/U2 Control Room = 3 control boards each for unit (Switchyard mimic board counts as bin 15); U3 Control Room

= 2 control boards and 1 Switchyard mimic board 8 Diesel Generators All subsystems included as 1 count.

9 Air Compressors Includes control panel; compressors with motors less than 5-hp excluded; Note all portable compressors 10 Battery Chargers Typically find these with DC buses 13 Dryers Clothes dryers 14 Electric Motors Greater than 5-hp; not associated with other bins; Do not count motor operated valves 15 Electrical Cabinets UPS (Power supplies), SWGR, MCC, Load Centers, DC Dist Cab, relay cab, control & switch panel that are not part of other bins. Free standing electrical cabinets (SWGR/MCC/Load Centers) counted by vertical segments.

Terminal boxes (labeled TB) or unlabeled electrical cabinets with any dimension greater than 6. (Most TBs are low voltage, typically they are labeled as High Voltage if they have voltage greater than 440 VAC. If labeled as high voltage, they should be counted).

Count wall mounted panels not excluded by the rules below.

Exclusions:

- Well sealed, secured doors, less than 440V and less than 4 switches or lights

- Welding receptacles (i.e. 600VAC cabinet w/connector)

- Cabinet less than 1x1x1 unless labeled as High voltage (labeled with the words High Voltage or indication of voltage at least 440 VAC)

- Abandoned and de-energized panels 7

Bin Definitions (cont.)

Bin # Item Criteria Notes 16 High-Energy Arcing Faults -Regular bus duct (not iso phase bus duct)

-Load Centers and Switchgear (in addition to Bin 15)

If greater than 440 VAC but less than 1000 VAC, count entire load center or switchgear as one HEAF

If greater than 1000VAC, count each vertical segment of the load center or switchgear as a HEAF 17 Hydrogen Tanks Multi-tank trailers = 1 19 Misc. Hydrogen Fires Other that storage, generator cooling and battery rooms 21 Pumps & Large Hydraulic Valves Pumps above 5-hp; include large hydraulic valves if any 23 Transformers Include those not integral part of larger component; Include low-voltage regulators;

- Include all those over rating 45 kVA 26 Ventilation Subsystems Count air handling units (AHUs), and chillers 27 Yard Transformer (catastrophic) Include isolation phase bus duct 28 Yard Transformer (non-catastrophic) Include anything that was in Bin 27 except for isolation phase bus ducts 29 Yard Transformer (other) Assume 1 count of Bin 29 for each component that was previously assigned to both Bins 27 and 28.

30 Boiler (TB) Ancillary items included except electrical cabinets if installed separate 32 Main Feedwater Pumps (TB) Include ancillary items 33 T/G Exciter (TB) 34 T/G Hydrogen Entire unit = 1 (include piping, valves, heat exchangers, oil separators, etc.)

35 T/G Oil Entire unit = 1 (include storage tanks, pumps, heat exchangers, valves, control devices etc.)

8

Data Gathering Checklist

- Field Walkdown 9

Data Gathering Checklist

- Ignition Source 10

Field Walkdown Results

Data Recorded

- Ignition Sources

- Suppression

- Detection

- Manual Fire Protection (Fire Extinguishers/Hose Stations

- Storage Areas

- Other: floor drainage, concerns

Observed discrepancies

- Drawings to field equipment

- Fire protection feature/hazard protection 11

Database

Data

- Field Walkdown

- Table top - Emergency Lights, fire barriers, adjacent zones, zone information (fire area, building, elevation, etc)

- Input into spreadsheet for simplicity

Imported into database for control, query and report functions

Reports

- Fire Protection Feature (Zone basis)

- Ignition Sources

- Multiple other report options limited by the amount data entered 12

Database Output - FP Features 13

Database Output - FP Features 14

Database Output - Ignition Source 15

Conceptual Document Content Conceptual Document Outline Ch. 1 -

Introduction Ch. 2 NFPA 805 Ch. 3A - Table B-1 Fire Code Compliance Ch. 3B - T.B-1 Report Att. A - Index Att. B - Zone-by-zone Classical FP Att. C - Zone-by-zone Ignition Sources Att. D -

Suppression Matrix Att. E - FE/HS Matrix 16

Lessons Learned/Good Practices

Define scope/definitions at beginning

Schedule around outage

Define a date-stamp for data collection

Routine team meetings

Prompt review of fire zones 17

Where Do We Go From Here?

Equivalency Evaluations (86-10s)

Support Iterations between Chapter 3 and 4

PRA/Fire Scenario Support - Evaluate target and spatial separation of fire hazards 18

NFPA 805 Pilot Observations Meeting Fire PRA Ignition Source Counting November 8, 2006 Dave Miskiewicz Kiang Zee Page 1

FAQs O 06-0016 Electrical Cabinets (Bin 15)

O 06-0017 HEAF Counting (Bin 16)

O 06-00XX MCB Counting (Bin 4)

O 06-00XX Misc Counting Items (valves, transformers, etc.

Page 2

Bin 15 O When does size matter?

O Define outlier criteria O Provide a basis for outliers O Examples Page 3

Bin 16 O Energy O Only count switchgear and load centers (MCCs not counted)

O Count Bus Duct as 1 HEAF (more discussion needed)

O Count load centers as 1 HEAF Page 4

Bin 4 O Use NUREG/CR-6850 App. L Page 5

FAQ Number 06-0016, Revision 0a (DRAFT - pre-NEI NFPA-805 task Force)

Plant: Harris Nuclear Plant (HNP) FAQ # 06-0016 Submittal Date: 11-6-06 Licensee

Contact:

David Miskiewicz Tele/email 919-546-7588 NRC

Contact:

Tele/email Distribution: Check all that apply (NEI Internal Use)

FPWG RIRWG NSSS OG NFPA 805 TF

Subject:

Clarification/enhancement of Ignition Source counting guidance for Electrical Cabinets in NUREG/CR-6850, supporting NFPA-805 Fire PRA application.

Interpretation of guidance? Yes Proposed new guidance not in NEI 04-02? Yes Details:

NEI 04-02 Guidance needing interpretation (include section, paragraph number, and line number):

New attachment on interpretation issues Circumstances requiring guidance interpretation or new guidance:

The guidance provided in NUREG/CR-6850 for Task 6, Fire Ignition Frequency (Section 6.5.6, Bin 15), states:

Bin 15 - Electrical Cabinets (Plant-Wide Components): Electrical cabinets represent such items as switchgears, motor control centers, DC distribution panels, relay cabinets, control and switch panels (excluding panels that are part of machinery), fire protection panels, etc. Electrical cabinets in a nuclear power plant vary significantly in size, configuration, and voltage. Size variation range from small-wall mounted units to large walk-through vertical control cabinets, which can be 20 to 30 long. The configuration can vary based on number of components that contribute to ignition, such as relays and circuit cards, and combustible loading, which also affects the fire frequency. Voltages in electrical cabinets vary from low voltage (120 V) panels to 6.9 kV switchgears. Even though it is expected that these features affect the likelihood of fire ignition, from a simple analysis of the event data involving the electrical cabinets, it was determined that the variation by cabinet type did not warrant separate frequency evaluation. Therefore, one fire frequency was estimated for the electrical cabinets.

This guidance infers that cabinet size is not a factor for ignition source counting. However, additional guidance states that electrical cabinets should be counted by their vertical segments .... During the presentation of Pilot Project results it was determined that differences related to the definition of segments could result in notable inconsistency between individual users of NUREG/CR-6850.

1

FAQ Number 06-0016, Revision 0a The discussion of this issue found that this issue affects only general electrical cabinets and panels. In the case of switchgears, load centers, unit substations, and motor control centers the term segment was uniformly interpreted to be equal to the individual vertical sections that define these types of components. As applied to general electrical cabinets and panels, the term segments could be interpreted to mean different metrics.

A segment could be defined as an enclosed element that is generally independent of size or volume (also referred to as a vertical section).

A segment could be defined as an individual section of an enclosure regardless of whether it was fully enclosed.

A segment could be defined based on a standard or reference sample panel size.

Depending on the metric being used, the counting of electrical cabinets would result in varying results and consequently, different fire ignition frequency values. While NUREG/CR-6850 allows the establishment of plant specific criteria for counting of electrical cabinets, additional guidance is required to achieve a consistent basis for determining the ignition frequencies.

Detail contentious points if licensee and NRC have not reached agreement This topic has impact on the NFPA-805 pilots, non-pilots and other users of NUREG/CR-6850.

Potentially relevant existing FAQ numbers:

This guidance is specific to the characterization of electrical cabinets for Bin 15 ignition frequency determination. The characterization of switchgear and load center segments for the purposes of high energy arcing faults is addressed by FAQ 06-0017.

Response Section A generalized counting criterion for general electrical cabinets and panels is proposed. This proposed criterion would involve two elements.

For switchgears, load centers, unit substations, and motor control centers the counting for the purposes of NUREG/CR-6850, Task 6, Bin 15 would be based on vertical section. This counting is illustrated in the following examples.

2

FAQ Number 06-0016, Revision 0a Medium Voltage Switchgear 9 Breakers and Sections Count = 9 for Bin 15 Load Center or Unit Substation 16 Breakers in 4 Sections Count = 4 for Bin 15 Motor Control Center 41 Breakers/Starters in 9 Sections Count = 9 for Bin 15 For general electrical cabinets and panels, it is proposed that the counting be based on a physically enclosed element. A physically enclosed element means that that the cabinet or panel is fully enclosed by 6 solid elements with the provision that a non-combustible floor or ceiling may represent the bottom or top. The term solid element is not intended to mean that the element is substantially continuous. Consequently, breeches or unsealed penetrations could still be treated as solid. The term solid is intended to prevent a panel that is divided by an element that is substantially open from being treated as two separate panels.

This proposed counting for electrical cabinets and panels is to be applied for a wide range of panel sizes. However, recognizing that the ignition frequency is more a function of the cabinet contents than the cabinet size, a basis is needed to address outlier conditions. It is proposed that each user be required to establish criteria for identifying the outliers and the basis for counting them. As an example, they can be counted by establishing a nominal standard or reference cabinet size. The count could also be based on evaluating the cabinet internals relative to a defined standard or reference configuration.

For example, a particular user may define a cabinet with any horizontal dimension more than 8 feet as an outlier, and a standard cabinet as being nominally 4 feet in length x 3 feet deep. (cabinet height is not generally an issue based on the use of vertical sections). Using this example, the following cabinet and panel examples would be counted as follows:

3

FAQ Number 06-0016, Revision 0a 6 ft Cabinet is not an outlier -

Count = 1 Cabinet is same as standard Count = 1 Internal dividers are not solid Count = 1 Internal dividers are solid Count = 6 Three independent cabinets Count = 3 12 feet, 3 ft deep Panel is an outlier, using a 4 standard cabinet -

Count = 3 9 ft long , 6 ft deep Cabinet is an outlier, evaluation of contents shows low cable loading typical of the standard cabinet -

Count = 1.

9 ft long , 6 ft deep Cabinet is an outlier, no evaluation of contents, based on reference cabinet Count = 3 - due to both variation from the standard length and width.

4

FAQ Number 06-0016, Revision 0a The intent is that a basis for the counting of outliers is required. A volumetric comparison is not required. Also, to prevent any appearance that this treatment is intended to be based on physical measurements, the proposed approach allows only integer counting. The assignment of fractional values would not be allowed. In addition, the proposed methodology retains the option for screening small cabinets resulting in a count of zero for them (as discussed in NUREG/CR-6850). As applied in this case, the user would be allowed to screen cabinets or panels based on defined criteria and exclude them from the Deleted: on a defined criteria overall population count.

Basis:

The existing guidance in NUREG/CR-6850 is based on industry data which has only been provided with fidelity adequate to support plant level ignition frequencies for electrical cabinets. Although the guidance does address the broad applicability of the data, it leaves room for variability that can create issues with PRA quality. It is important that the ignition frequency results be of sufficient quality to support not only NFPA-805 transition but also the more broad scope of regulatory inspection and enforcement issues.

The guidance proposed will provide more consistency when determining plant specific electrical cabinet ignition frequencies while working within the bounds of the exiting data provided by the NUREG. This should facilitate the review and acceptability of the results.

5

FAQ Number 06-0017, Revision 0a Formatted: Left: 82.8 pt, Right:

66.95 pt, Top: 69.85 pt, Footer (DRAFT - pre-NEI NFPA-805 task Force) distance from edge: 21.6 pt Deleted: FAQ Plant: Oconee FAQ # 06-0017 Deleted: Harris Nuclear Plant (HNP)

Submittal Date: 11-6-06 Licensee

Contact:

Kiang Zee Tele/email Deleted: David Miskiewicz NRC

Contact:

Tele/email Deleted: 919-546-7588 Distribution: Check all that apply (NEI Internal Use)

Formatted: Centered 1

Formatted: Left: 72 pt, Right: 54 pt, Top: 36 pt, Bottom: 36 pt, Header distance from edge: 21.6 pt, FPWG RIRWG NSSS OG NFPA 805 TF Footer distance from edge: 21.6 pt

Subject:

Clarification/enhancement of Ignition Source counting guidance for High Energy Arcing Faults (HEAF) in NUREG/CR-6850, supporting NFPA-805 Fire PRA application.

Interpretation of guidance? Yes Proposed new guidance not in NEI 04-02? Yes Details:

NEI 04-02 Guidance needing interpretation (include section, paragraph number, and line number):

New attachment on interpretation issues Circumstances requiring guidance interpretation or new guidance:

The guidance provided in NUREG/CR-6850 for Task 6, Fire Ignition Frequency (Section 6.5.6, Bin 16), states:

Bin 16 - High-Energy Arcing Faults (Plant-Wide Components): High-energy arcing faults are associated with switchgear and load centers. Switchyard transformers and isolation phase buses are not part of this bin. For this bin, similar to electrical cabinets, the vertical segments of the switchgear and load centers should be counted.

Additionally, to cover potential explosive failure of oil filled transformers (those transformers that are associated with 4.16 or 6.9kV switchgear and lower voltage load centers) may be included in vertical segment counts of the switchgear.

Pilot discussions and benchmarking of NUREG/CR-6850 for Task 6, Fire Ignition Frequency, has shown inconsistency in the treatment of High Energy Arcing Faults (Bin 16). Strict interpretation of the guidance is that the HEAF count should mimic the electrical cabinet counts for switchgear and load centers. The application of such a counting method is expected to result in reported High Energy Arcing Fault (HEAF) frequency values for an individual plant being inconsistent with industry experience. The industry experience and consequently the HEAF frequency is based on 3 events occurring on medium voltage switchgears and 1/2 event occurring on a 480 VAC Load Center. Because of the relative numbers of switchgears and load centers at an individual plant, it is expected that the resultant frequency may be inappropriately skewed.

There is a concern that the occurrence of a HEAF frequency distribution that departs significantly from the 3 to 1/2 ratio would cause results to be challenged. There is also a question of counting Bus Ducts. There is a need to resolve this issue to prevent future rework and to Deleted: o reduce burden associated with uncertainty treatment.

Detail contentious points if licensee and NRC have not reached agreement This topic has impact on the NFPA-805 pilots, non-pilots and other users of NUREG/CR-6850.

Potentially relevant existing FAQ numbers:

This guidance is specific to the characterization of electrical cabinets for Bin 16 HEAF determination. The characterization and counting of electrical cabinets for Bin 15 determination is addressed by FAQ 06-0016.

Response Section It is proposed that the existing guidance in NUREG/CR-6850 that recommends counting based on segments be modified. Since industry experience shows that the medium voltage switchgears

FAQ Number 06-0017, Revision 0a are most likely to experience this event, it is proposed that each load center or unit substation be counted as a single unit regardless of the number of vertical sections or segments. This treatment would ensure that the majority of the HEAF frequency is allocated to the medium voltage switchgears.

Medium Voltage Switchgear 9 Breakers and Sections Count = 9 for Bin 16 Load Center or Unit Substation 16 Breakers in 4 Sections Count = 1 for Bin 16 Bus ducts are recommended to be counted as an equivalent to an individual section, regardless of length. Since the termination point of the bus duct is the likely location for the HEAF, and each individual bus duct is terminated at both ends, the likelihood of a shorter bus duct having a HEAF is not significantly different than a longer bus duct. When a grouping of bus ducts route between a two electrical sources or cabinets, each individual bus duct is counted. Comment [K1]: Kiang - bus ducts have many bolted connections. The number of connections is a function of length. The argument that HEAF are most likely to occur at the terminal ends would be interpreted to mean at each bolted connection. Therefore, length might become an issue.

Also, it is unclear how the bus ducts are to be counted. If a single bus duct passes through 6 compartments, is it counted as 1/6 per room or 1 in each room.

I would propose that bus ducts be ignored. The only instance that I know of if the Waterford event and that occurred near the switchgear. The HEAF for the switchgear should bound the consequences.

Formatted: Centered 3

Basis:

The existing guidance in NUREG/CR-6850 is based on industry data which has only been provided with fidelity adequate to support plant level ignition frequencies for HEAFs. Although the guidance does address the data, it leaves room for variability that can create issues with PRA quality. It is important that the ignition frequency results be of sufficient quality to support not only NFPA-805 transition but also the more broad scope of regulatory inspection and enforcement issues.

The guidance proposed will provide more consistency when determining plant specific electrical cabinet ignition frequencies while working within the bounds of the exiting data provided by the NUREG. This should facilitate the review and acceptability of the results.

FAQ Number 06-0018x, Revision 0a Formatted: Left: 82.8 pt, Right:

66.95 pt, Top: 69.85 pt, Footer (DRAFT - pre-NEI NFPA-805 task Force) distance from edge: 21.6 pt Deleted: FAQ Plant: Harris Nuclear Plant (HNP) FAQ # 06-0018? Deleted: 0017 Submittal Date: 11-6-06 Licensee

Contact:

David Miskiewicz Tele/email 919-546-7588 NRC

Contact:

Tele/email Distribution: Check all that apply (NEI Internal Use)

Formatted: Centered 1

Formatted: Left: 72 pt, Right: 54 pt, Top: 36 pt, Bottom: 36 pt, Header distance from edge: 21.6 pt, FPWG RIRWG NSSS OG NFPA 805 TF Footer distance from edge: 21.6 pt

Subject:

Clarification/enhancement of Ignition Source counting guidance for Main Control Board Deleted: High Energy Arcing Faults (HEAF)

(MCB) in NUREG/CR-6850, supporting NFPA-805 Fire PRA application.

Deleted: The guidance provided in Interpretation of guidance? Yes NUREG/CR-6850 for Task 6, Fire Ignition Frequency (Section 6.5.6, Bin 16), states:¶ Proposed new guidance not in NEI 04-02? Yes ¶ Bin 16 - High-Energy Arcing Faults (Plant-Wide Components): High-energy Details: arcing faults are associated with switchgear and load centers. Switchyard NEI 04-02 Guidance needing interpretation (include section, paragraph number, and line transformers and isolation phase buses number): are not part of this bin. For this bin, similar to electrical cabinets, the vertical New attachment on interpretation issues segments of the switchgear and load centers should be counted. Additionally, to cover potential explosive failure of oil Circumstances requiring guidance interpretation or new guidance: filled transformers (those transformers that are associated with 4.16 or 6.9kV switchgear and lower voltage load NUREG/CR-6850, Section 6.5.6 centers) may be included in vertical segment counts of the switchgear.¶

¶ The guidance provided in NUREG/CR-6850 for Task 6, Fire Ignition Frequency, is subject to Deleted: Pilot discussions and application inconsistency in the treatment of Main Control Board (Bin 4). The guidance for Task benchmarking of NUREG/CR-6850 for 6 does not provide any specific definition or characterization of what constitutes a Main Control Task 6, Fire Ignition Frequency, has shown inconsistency in the treatment of Board (MCB) other than a reference to it being the central element of the room. A discussion High Energy Arcing Faults (Bin 16).

amongst the Pilot Plants that included consideration of other plants in their respective fleets Strict interpretation of the guidance is that the HEAF count should mimic the found wide variability in the configuration of the main control room. There was a concern that electrical cabinet counts for switchgear inconsistent treatment of this bin would unnecessarily challenge the completion and review of and load centers. The application of such a counting method is expected to the Fire PRA. This challenge would be manifested by a notable change in the fire frequency result in reported High Energy Arcing assigned to an individual panel depending on whether it was counted as Bin 4 or Bin 15. Fault (HEAF) frequency values for an individual plant being inconsistent with industry experience. The industry Further review of NUREG/CR-6850 found that a definition of MCB is provided in Appendix L. experience and consequently the HEAF frequency is based on 3 events occurring However, this Appendix develops a fire modeling treatment of fire behavior within a panel on medium voltage switchgears and 1/2 enclosure. There was a concern that absent documented agreement, there could be a future event occurring on a 480 VAC Load Center. Because of the relative numbers challenge to the use of the definition in Appendix L for the purposes of Task 6, Bin 4 counting. of switchgears and load centers at an individual plant, it is expected that the resultant frequency may be Detail contentious points if licensee and NRC have not reached agreement ... [1]

This topic has impact on the NFPA-805 pilots, non-pilots and other users of NUREG/CR-6850. Deleted: electrical cabinets Deleted: 16 Potentially relevant existing FAQ numbers: Deleted: HEAF This guidance is specific to the characterization of Main Control Board for Bin 4 determination. Comment [K1]: Kiang - bus ducts The characterization and counting of electrical cabinets for Bin 15 determination is addressed by have many bolted connections. The number of connections is a function of FAQ 06-0016. length. The argument that HEAF are most likely to occur at the terminal ends

... [2]

Response Section Deleted: It is proposed that the existing guidance in NUREG/CR-6850 that recommends counting based on segments It is proposed that the definition of Main Control Board provided in NUREG/CR-6850, be modified. Since industry experience shows that the medium voltage ... [3]

Appendix L be accepted as also being applicable for Task 6, Bin 4 counting.

Deleted: The existing guidance in NUREG/CR-6850 is based on industry Basis: data which has only been provided with fidelity adequate to support plant level ignition frequencies for HEAFs. ... [4]

The guidance proposed will provide more consistency when determining plant specific control Formatted: Normal, Indent: Left:

room ignition frequencies while working within the bounds of the exiting data provided by the 18 pt NUREG. This should facilitate the review and acceptability of the results. Deleted: electrical cabinet

Page 2: [1] Deleted dnm 11/7/2006 1:23:00 PM Pilot discussions and benchmarking of NUREG/CR-6850 for Task 6, Fire Ignition Frequency, has shown inconsistency in the treatment of High Energy Arcing Faults (Bin 16). Strict interpretation of the guidance is that the HEAF count should mimic the electrical cabinet counts for switchgear and load centers. The application of such a counting method is expected to result in reported High Energy Arcing Fault (HEAF) frequency values for an individual plant being inconsistent with industry experience. The industry experience and consequently the HEAF frequency is based on 3 events occurring on medium voltage switchgears and 1/2 event occurring on a 480 VAC Load Center. Because of the relative numbers of switchgears and load centers at an individual plant, it is expected that the resultant frequency may be inappropriately skewed. There is a concern that the occurrence of a HEAF frequency distribution that departs significantly from the 3 to 1/2 ratio would cause results to be challenged. There is also a question of counting Bus Ducts. There is a need to resolve this issue to prevent future rework and to reduce burden associated with uncertainty treatment.

Page 2: [2] Comment [K1] KLZ 11/4/2006 4:03:00 AM Kiang - bus ducts have many bolted connections. The number of connections is a function of length. The argument that HEAF are most likely to occur at the terminal ends would be interpreted to mean at each bolted connection. Therefore, length might become an issue.

Also, it is unclear how the bus ducts are to be counted. If a single bus duct passes through 6 compartments, is it counted as 1/6 per room or 1 in each room.

I would propose that bus ducts be ignored. The only instance that I know of if the Waterford event and that occurred near the switchgear. The HEAF for the switchgear should bound the consequences.

Page 2: [3] Deleted dnm 11/7/2006 1:25:00 PM It is proposed that the existing guidance in NUREG/CR-6850 that recommends counting based on segments be modified. Since industry experience shows that the medium voltage switchgears are most likely to experience this event, it is proposed that each load center or unit substation be counted as a single unit regardless of the number of vertical sections or segments. This treatment would ensure that the majority of the HEAF frequency is allocated to the medium voltage switchgears.

Medium Voltage Switchgear 9 Breakers and Sections Count = 9 for Bin 16 Load Center or Unit Substation 16 Breakers in 4 Sections

Count = 1 for Bin 16 Bus ducts are recommended to be counted as an equivalent to an individual section, regardless of length. Since the termination point of the bus duct is the likely location for the HEAF, and each individual bus duct is terminated at both ends, the likelihood of a shorter bus duct having a HEAF is not significantly different than a longer bus duct.

When a grouping of bus ducts route between a two electrical sources or cabinets, each individual bus duct is counted.

Page Break Page 2: [4] Deleted dnm 11/7/2006 1:26:00 PM The existing guidance in NUREG/CR-6850 is based on industry data which has only been provided with fidelity adequate to support plant level ignition frequencies for HEAFs. Although the guidance does address the data, it leaves room for variability that can create issues with PRA quality. It is important that the ignition frequency results be of sufficient quality to support not only NFPA-805 transition but also the more broad scope of regulatory inspection and enforcement issues.

NFPA 805 Transition Harris Nuclear Plant (HNP)

Nuclear Safety Performance Criteria Transition HNP Pilot Meeting Nov. 6-9, 2006 Raleigh, NC Keith Began Bob Rhodes 11/08/06 1

Introduction z Nuclear Safety Performance Criteria transition review consists of:

Review of safe shutdown methodology for basic attributes (NFPA 805, Chapters 1 and 2)

Fire area by fire area review (NFPA 805, Chapter 4

[Focus of Presentation]

2

NEI 04-02 Guidance z Section 4.3.2 provides guidance z Appendix B.2 provides clarification Section B.2.1 - Methodology Review Section B.2.2 - Fire Area by Fire Area Transition z Sample Tables B-2 and B-3 3

NEI 04-02 Guidance (contd)

NEI 04-02 Figure 4-3 4

NEI 04-02 Guidance (contd)

Note: Example only - Not HNP data 5

HNP Background z Post-1979 Plant (NUREG-0800) z Issues Related to Hemyc and MT Fire Barriers z Safe Shutdown Re-Analysis (2003-2006) z Nuclear Safety Performance Criteria Transition:

Started October 2006 Drafted Project Instruction Piloted Process for 2 Fire Areas 6

Methodology Transition Assemble Documentation Select NFPA 805 / NEI 00-01 Section Perform Comparison of SSD Method vs. NEI 00-01 Yes Yes No No NEI 00-01 Guidance Could misalignment have In Strict Alignment with No Meets Intent of NEI 00-01 Has NRC approval been Applicable? adverse consequences? NEI 00-01 Guidance? Guidance? obtained for method?

No No Yes Yes Yes Document and Document Address Open Item 7

Fire Area Review 8

Fire Area Review - Assemble Documentation z Industry Documentation:

NEI 04-02, Revision 1 Outstanding Frequently Asked Questions (FAQs) related to the Fire Area-by-Fire Area Transition Guidance on Resolution of Industry Issues (e.g.,

operator manual actions, Hemyc/MT, circuit failures) 9

Fire Area Review - Assemble Documentation FAQ ID Topic 06-0004 Clarify NFPA 805 Chapter 4 and 3 relationship for 'required' FP systems/features 06-0006 High-low pressure interface definition and NEI 00-01/NFPA 805 discrepancies 06-0008 Alternate method for Engineering Evaluations 06-0011 Clarify III.G.3 Compliance Transition 06-0012 Clarify Manual Action Transition in Appendix B 10

Fire Area Review - Assemble Documentation z Plant specific calculations/analyses for:

Fire area assessment and supporting analyses Operator manual action feasibility assessments Engineering evaluations (e.g., GL 86-10 evaluations)

Assessment of spurious component actuations Licensing basis/regulatory documents Exemptions, Exemption requests (or Deviations, Deviation Requests) and supporting correspondence Safety evaluation reports Inspection reports Response to generic letters, etc.

11

Fire Area Review - Performance Goals z Document accomplishment of NFPA 805 performance goals for the selected fire area.

z Document the Method of Accomplishment in summary level form.

z Document comments/additional information.

z Provide specific reference/basis documents z Capture existing non-compliances related to post-fire safe shutdown Perform or review existing operator manual action information Issues already in CAP as part of SSD Re-Analysis Multiple Spurious Operations/GL 2006-XX issues 12

Fire Area Review - Performance Goals 13

Fire Area Review - Performance Goals 14

Fire Area Review - Performance Goals (Operator Manual Actions) z Key Industry issue is determining which Operator Manual Actions (Recovery Actions) are Allowed/Approved z This is a key part of defining scope of the transition change evaluation z NEI 04-02 App. B, Section B.2.2 z FAQ 06-0012 provides proposed clarification based on recent industry activity z Process was piloted for selected fire areas z Binned Actions based upon FAQ 06-0012 guidance 15

Fire Area Review - Performance Goals (Operator Manual Actions)

For each Operator Manual Action for a Given Fire Area No Action is a Normally No Action Credited for App. No Action is taken inside of Action taken to Achieve & No Manually Operated R Section III.G.3 the Main Control Room? Maintain Cold Shutdown?

Switch/Valve (NUREG-0800 C.5.c)?

Bin A Bin B Bin C Bin D Yes Yes Yes Yes Yes Yes Yes No Action Related to No No Prior NRC Approval Action is Related to fire Credited Train, but does Obtained? affected train?

not disable Function?

Bin G Bin F Bin E No Action is Feasible?

Yes Operator Action Not Allowed /

Operator Manual Action is Not Approved (Candidate for RI-ACCEPTABLE PB Change Evaluation)

Bin H 16

Fire Area Review - Performance Goals (Basis Docs) 17

Fire Area Review - Performance Goals (Open Items) 18

Fire Area Review - FA Licensing Basis z Licensing Basis Documents (exemptions/deviations/SERs) reviewed to ensure bases remain valid z Approving documents (e.g., SER) as well as submittals were reviewed z Interfaces between NFPA 805 Chapters 4 and 3 (e.g., barriers, detection, and suppression systems) 19

Fire Area Review - FA Licensing Basis 20

Fire Area Review - FA Licensing Basis (Basis Document Details) 21

ire Area Review - Engineering Evaluations z Engineering Evaluations to be reviewed to ensure bases remain valid z Interfaces between NFPA 805 Chapters 4 and 3 (e.g., barriers, detection, and suppression systems) z FAQ 06-0008 provides guidance on adequacy determination z Not yet tested during HNP Pilot Process 22

Fire Area Review - Engineering Evaluations (Reference FAQ 06-0008) 23

NEI 04-02 Fig. 4-3 Alignment 24

Alternative Shutdown Considerations (FAQ 06-0011) z Safe today safe tomorrow z Consistent with NFPA 805 Figure 2-2 Deterministic Approach z ASD fire areas addressed in Fire PRA z Perform change evaluations for any noncompliances (e.g., failure to meet III.G.3/NUREG-0800 C.5.c)

Consistent with NEI 04-02 table 4-3 Specifically discussed in NEI 04-02 Appendix B.2.

z Operator manual actions for ASD fire areas must be feasible.

z Feasible operator manual actions for ASD fire areas are acceptable & do not require change evaluations (based on previous approval) 25

Overall Observations and Insights z Reviews are not intended to be reconstitution/revalidation efforts (safe today, safe tomorrow) z Prep work for reviews is key:

Readily available licensing documentation Correlation of licensing correspondence to fire areas Correlation of engineering evaluations to fire areas z Efficient reviews require plant-specific knowledge z Effective summary level documentation facilitates efficient documentation of performance goals z Recent revalidation efforts provide good starting point for open item/change evaluation scope 26

Overall Observations and Insights (contd) z Relationship between NFPA 805 Chapters 4 and 3 important to process e.g., Document fire barriers as part of Table B-1 or B-3?

z NUREG-0800 plant has more classical FP information in SER than an App. R plant (barrier deviations) z Deviations contain the type of info found in App. R plants GL 86-10 evaluations.

z Categorization of allowed/approved operator manual actions prior to transition efforts will expedite nuclear safety transition.

27

Potential Challenges z Integration of multiple spurious operation compliance issues depending upon GL 2006-XX scope/content.

z Decisions on transitioning deviations / exemptions with large amounts of detail:

What level of confirmation.

28

Duke Power NFPA 805 Ch 4 Transition Oconee (ONS)

November 08, 2006 1

Discussion Topics Nuclear Safety Goals, Objectives and Performance Criteria Deterministic Approach Methodology Fire-Area-by-Fire-Area Performance-Based Approach Issues 2

NFPA-805 Section 1.3.1, Nuclear Safety Goal The nuclear safety goal is to provide reasonable assurance that a fire during any operational mode and plant configuration will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition.

3

NFPA-805 Section 1.4.1, Nuclear Safety Objectives In the event of a fire during any operational mode and plant configuration, the plant shall be as follows:

Reactivity Control. Capable of rapidly achieving and maintaining subcritical conditions Fuel Cooling. Capable of achieving and maintaining decay heat removal and inventory control functions Fission Product Boundary. Capable of preventing fuel clad damage so that the primary containment boundary is not challenged.

4

NFPA-805, Section 1.5.1, Nuclear Safety Performance Criteria Fire Protection features shall be capable of providing reasonable assurance that, in the event of a fire, the plant is not placed in an unrecoverable condition.

To demonstrate this, the following performance criteria shall be met.

(a) Reactivity Control. Reactivity control shall be capable of inserting negative reactivity to achieve and maintain subcritical conditions. Negative reactivity inserting shall occur rapidly enough such that fuel design limits are not exceeded.

(b) Inventory and Pressure Control. With fuel in the reactor vessel, head on and tensioned, inventory and pressure control shall be capable of controlling coolant level such that subcooling is maintained for a PWR and shall be capable of maintaining or rapidly restoring reactor water level above top of active fuel for a BWR such that fuel clad damage as a result of a fire is prevented.

(c) Decay Heat Removal Decay heat removal shall be capable of removing sufficient heat from the reactor core or spent fuel such that fuel is maintained in a safe stable condition.

(d) Vital Auxiliaries Vital auxiliaries shall be capable of providing the necessary auxiliary support equipment and systems to assure that the systems required under (a), (b), (c) and (e) are capable of performing their required nuclear safety function.

(e) Process Monitoring Process monitoring shall be capable of providing the necessary indication to assure the criteria addressed in (a) through (d) have been achieved and are being maintained.

5

NSPA Documentation Analysis Documentation broken up into two main themes Methodology (NFPA-805 Chapters 1 and 2)

Fire Area by Fire Area (NFPA-805 Chapter 4)

NEI 04-02 recommends documenting this in two different tables:

Methodology Review Worksheet - Table B-2 Fire Area Assessment Worksheet - Table B-3 6

Methodology Review Duke presented information on Table B-2 in previous Pilot Observation Meetings Use of Table B-2 in its original intended layout was judged to be too confusing and hard to read We propose an alternate approach that presents information in a more concise manner yet still references detailed backup information 7

Alternate Table B-2 Format 8

Fire Area Assessment On a Fire-Area by Fire-Area basis, must select using either the Deterministic or the Performance-Based Approach.

Deterministic Approach has been deemed to satisfy the performance criteria Performance-Based Approach Use of Fire Modeling Use of Risk Evaluation Required when using Recovery Actions 9

Fire Area Assessment Deterministic Performance-Based Existing Fire Area Approach Compliance Strategy Approach Does not meet Meets NFPA 805 Meets Deterministic Meets Deterministic deterministic Ch. 4 Deterministic Criteria with approved Criteria with GL 86-10 requirements Criteria exemption / deviation evaluation yes Allowed to evaluate under Document Document CLB?

yes GL 86-10 "quality" no acceptable? Perform and document analysis Perform RI-PB Document Analysis no Upgrade GL 86-10 evaluation or Perform change consider other evaluation options 10

Approach Selection Process Selection of Deterministic vs. Performance-Based will likely have to be performed on a functional basis (or even on a component basis)

Some fire areas have multiple compliance strategies, affecting two or more functions (reactivity control, pressure control, inventory control, etc.)

One function may credit separation, another operator manual actions 11

Approach Selection Process Process will have to be performed for each different function/compliance strategy (must decide if it meets Deterministic Requirements or if Performance-Based approach will be needed) 12

NFPA-805 Ch 4 Methodology Use of both Deterministic and Performance-Based approaches are documented in a similar fashion on a fire area basis Fire Areas that fully meet deterministic requirements are documented in the fire area assessment worksheet Fire Areas that do not meet one or more attributes of the deterministic requirements will reference one or more Change Evaluations 13

Fire Area Assessment Worksheet, Table B-3 14

NSPA Information Organization NSPA information is being documented in a relational database Database structure designed for multiple uses NFPA-805 Transition Transition Report Post-Transition Design Basis Document 15

NSPA Information Organization - continued Database documents several major topics in one convenient location Fire Area by Fire Area compliance Nonpower Operational considerations Radiological Release Life Safety Code Plant Damage/Business Interruption 16

NSPA Database Report Table Format 17

NSPA Database Report Table Format - Example 18

NSPA Database

- continued Database links to a text document that provides additional detail when needed Text document used to provide a detailed description of fire area attributes for use in Design Basis Document post-transition 19

Oconee Observations Establishing uses and final resting place of fire area transition information led to use of database to help manage information Database has extensive flexibility to allow different report formats to present the same information for different purposes (Table B-3 information can be used for Transition Report as well as post-transition DBD) 20

Oconee Observations Plant utilizes III.G.3 Alternate Shutdown for vast majority of plant areas Final resolution of FAQ 06-011 may have significant impact on level of effort for Oconee transition If Alternate shutdown areas are not transitioned deterministically, significant number of Performance-Based, Risk-Informed evaluations will be needed Using Performance-Based, Risk-Informed approach begins to look the same as Change Evaluation, which should not be required if you are in compliance with III.G.3 21

NFPA 805 TRANSITION FSSPMD DATA FSSPMD DATA CIRCUIT SSEL ANALYSIS SSEL CAFTA LOGIC TEXT FILE CES PIs CIRCUIT ANALYSIS PRA EQUIPMENT NON-POWER CAFTA LOGIC TEXT FILE FSSPMD SOFTWARE FSSPMD SOFTWARE CRTN CAFTA SOFTWARE CAFTA SOFTWARE NSCA DOCUMENTATION SSA DOCUMENTATION NUCLEAR SAFETY CAPABILITY ASSESSMENT CALC SAFE SHUTDOWN ANALYSIS CALC NSCA Function Summary FIRE SAFETY ANALYSIS EGR-NGGC-0005 NFPA 805 Transition Process Non-Power Evaluation SSA System Summary Detailed Change Evals NFPA 805 Transition Tasks EGR-NGGC-0017 NEW & REVISED Fire Area Summary Fire Area Summary SSA Implementing EC PLANT FA Compliance FA Compliance NFPA 805 Transition Tasks DOCUMENTATION Non-Power Evaluation PSA Summary NFPA Implementing EC Non-Power Evaluation Coordination Detailed Change Evals MHIF Calculation CES PROJECT INSTRUCTIONS Coordination MHIF Calculation Manual Action T-H Calculations Feasibility Manual Action Calculation T-H Calculations Feasibility Calculation SSA Shutdown SSA Drawings FIRE PRA Procedures SSA Shutdown SSA Drawings Procedures FHA INFORMATION FHA DOCUMENTATION FP Features Ignition Sources Code Compliance FP Features Evaluations FHA Code Compliance (Including BTUs)

Evaluations Engineering FP Drawings Equivalency Engineering Evaluations EGR-NGGC-0102 Equivalency FP Drawings Evaluations (GL 86-10s)

Fire Fighting DBD Procedures Fire Fighting DBD Procedures

NRC Perspective of Pilot Plant Transition Paul W. Lain, P.E.

NFPA 805 Program Manager NRC/NRR/DRA/AFPB November 9, 2006

Purpose Provide feedback on whats on track or off track 2

NRC Interactions w/ Pilots

08/05 - Pilot Kick-Off Mtg @ RII

11/05 - Observation Visit @ Duke HQ

03/06 - Public Workshop @ NRC HQ

03/06 - Observation Visit @ Progress HQ

07/06 - FAQ Kick-Off Mtg @ NRC HQ

07/06 - Pubic Workshop @ AEP

08/06 - FAQ Public Conference Call

08/06 - NEI FPIF / 805 Information Exchange

09/06 - FAQ Public Mtg @ Winston & Strawn

10/06 - Observation Visit @ Oconee

10/06 - FAQ Public Conference Call

11/06 - Observation Visit @ Harris/PE HQ

11/06 - FAQ Public Mtg @ NEI 3

Programmatic Issues

Process: Information Dissemination

- Parking Lot Issues

- NRC Trip Reports w/ Lessons Learned

- Industry Information Meetings

- NEI Task Force

- FAQ Process

- Working Level Reviews 4

Programmatic Issues

Process: Timing

- RG 1.205 Approval Endorsing NEI 04-02

- Enforcement Discretion Extension

- NRC Trip Reports w/ Lessons Learned

- FAQ Process

- NEI Peer Review Guide

- ANS Standard 5

Future Programmatic Issues

Visits

- Periodicity

- Observation vs Working Level

Duke LAR Date

Topical Reports vs FAQ Approval

- Multiple Spurious Methodology

- Additions to NUREG/CR-6850 Methodology

- Alternatives to 50.48(c) Methodology 6

NEI NFPA 805 Task Force

Mission

Communication

Solutions

Going Forward

Mission

Successfully implement Regulatory Guide 1.205 based on the industry guidance document, NEI 04-02

Provide support to plants transitioning to 10 CFR 50.48 (c)

Work under the auspices of the Fire Protection Working Group and coordinate with the Risk-Informed Regulation Working Group

Communication

Representation from Risk Applications Task Force & Fire Protection Working Group

Monthly meetings w/Task Force and NRC

Sharing of information

- Pilot updates

- Transition issues

- FAQs

Web Board

Solutions

FAQs

- Issues captured from transitioning plants

- Solutions developed and vetted through Industry group (s)

- Approval by joint effort from Industry/NRC

NEI 04-02

- Approved FAQs incorporated to document

- Periodic & future revisions endorsed by NRC

Going Forward

Status and lessons learned from pilots will be communicated

Overall coordination is essential:

pilots must be given the highest priority to baseline the transition and LAR process

- Expectation: Expedited review

- Goal: 0 RAIs

Need to resolve the 3 year enforcement discretion question

Going Forward The NEI NFPA 805 Task Force is the pathway for resolution of technical issues and communication hub for successful transition to 10 CFR 50.48 (c).

Questions?

ML063310386

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