RS-20-153, Amendment 29 to Fire Protection Report, Chapter 3, Guidelines of BTP Cmeb 9.5-1

Amendment 29 to Fire Protection Report, Chapter 3, Guidelines of BTP Cmeb 9.5-1

ML21008A427
Person / Time
Site:	Byron
Issue date:	12/17/2020
From:	Exelon Generation Co LLC
To:	Office of Nuclear Reactor Regulation, Office of Nuclear Material Safety and Safeguards
Shared Package
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References
RS-20-153
Download: ML21008A427 (170)

Text

BYRON AMENDMENT 13 DECEMBER 1990 3.0 GUIDELINES OF BTP CMEB 9.5-1 3.1 FIRE PROTECTION PROGRAM REQUIREMENTS IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

a. Fire Protection Program A fire protection program Comply. Refer to Section II.A of should be established at each Appendix A5.7.

nuclear power plant. The pro-gram should establish the fire protection policy for the pro-tection of structures, sys-tems, and components important to safety at each plant and the procedures, equipment, and per-sonnel required to implement the program at the plant site.

(1) The fire protection program Comply. Refer to Section II.A of should be under the direction Appendix A5.7.

of an individual who has been delegated authority commen-surate with the respon-sibilities of the position and who has available staff personnel knowledgeable in both fire protection and nuclear safety.

(2) The fire protection program Comply. Refer to Section II.A of should extend the concept of Appendix A5.7.

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 that do occur; 3.1-1

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE to provide protection for structures, systems, and components important to safety so that a fire that is not promptly extin-guished by the fire suppression activities will not prevent the safe shutdown of the plant.

(3) Responsibility for the overall Administrative procedures identify fire protection program should the individual delegated the be assigned to a person who has authority for establishing the Fire management control over all Protection program. He has nuclear organizations involved in fire plant safety expertise available as protection activities. Formu- part of the operating department.

lation and assurance of program implementation may be delegated to a staff composed of person-nel 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 direct-ing the fire protection program for the nuclear power plant.

The staff should be responsible for:

(a) Fire protection program Using the prefire plans for safety-requirements, including related areas, hazards are defined, consideration of potential structures and system identified.

hazards associated with The Fire Marshall (as administrator) postulated fires, with maintains the plans.

knowledge of building lay-out and systems design.

(b) Post-fire shutdown The Shift Manager is responsible for capability. operating safely and can order shutdown if he deems it necessary for safety.

3.1-2

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (c) Design, maintenance, Maintenance and surveillance are surveillance, and quality handled by the station Operating, assurance of all fire pro- Maintenance and Engineering tection features (e.g., programs and procedures.

detection systems, sup-pression systems, bar- Offsite QA is a separate riers, dampers, doors, organization. Onsite QA penetration seals, and organization provides review of fire brigade equipment). maintenance, and purchase activities in accordance with the corporate QA Manual.

(d) Fire prevention activities The Fire Marshall and Training (administrative controls Department direct training.

and training).

(e) Fire brigade organization The Fire Marshall administers the and training. station fire protection program (see 3.1. a(2))

(f) Prefire planning. Prefire plans are written for safety-related areas and are con-trolled by the Fire Marshall.

Preplans were reviewed by a Fire Protection Engineer.

Comply.

1. Responsibility for the Fire Protection Program

a. Initial Design and Construction Phase The fire protection system design for the EGC plants was developed by the project consulting engineer using members of his staff who were experienced in nuclear plant design.

Exelon Generation Company is a member of Nuclear Electric Insurance Limited (NEIL) and therefore guidelines for fire protection design were provided in the NEIL Property Loss Prevention Standards for Nuclear Generating Stations.

The building design was done by the consulting engineer. All design 3.1-3

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE drawings which were pertinent to fire protection were submitted to a fire protection consultant as required by NEIL for their review and comment. The fire protection consultant was employed by NEIL and was therefore independent of EGC.

The comments on design information made by the fire protection consultant were submitted to EGC for their action.

Exelon Generation Company reviewed the project consultants' design drawings and the fire protection consultants' comments. Judgments were made on a cost-benefit basis as to whether or not the fire protection features were to be incorporated into the plant.

Consideration was given to the fol-lowing plant features when eval-uation of fire protection was made:

a. plant and personnel safety,

b. credibility of a fire or fire hazard,

c. loss of generation because of fire loss, and

d. protection of surrounding or adjacent equipment resulting from a fire.

3.1-4

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE A Project Engineer who reported to the Project Engineering Manager coordinated fire protection design features at B/B.

Likewise, a review of design and design changes was performed by a Fire Protection Engineer in the Nuclear Services Department and by Independent Fire Protection Engineers working under contract to EGC. Resumes for the reviewers are in Appendix A5.1.

Surveillance tests were performed by the Project Construction Department and by the Station. The Fire Protection Engineers were involved in pre-operational and surveillance acceptance tests.

3.1-4a

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

b. Operating Phase Exelon Generation Company has a Fire Marshall and Fire Protection System Engineer at each nuclear plant. In addition, there are Fire Protection Engineers in the Corporate and/or site design engineering departments.

1. Properties and Equipment - The Fire Protection Engineers furnish information on underwriting standards, fire insurance rating standards and other information.

When necessary, they arrange for procuring advice from outside fire prevention agencies or other outside sources. When necessary, they arrange and set up meetings to discuss and resolve any questions on current standards or fire protection equipment.

2. Fire Inspections - Site personnel, QA (Nuclear Oversight),

and NEIL performs fire protection inspections of plant facilities.

3. Fire Fighting Equipment - The Station Fire Marshall sees that adequate fire fighting equipment is provided and that such equipment is maintained in good operating condition.

4. Tests - The station conducts tests of fire fighting equipment and automatic fire protection 3.1-5

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE systems to ensure that each is in good condition and operating satisfactorily. During normal or routine inspections, one or more of the following tests may be made:

a. alarm tests,

b. drain tests,

c. churning of fire pumps,

d. inspecting of control valves,

e. physical testing of fire pumps and yard hydrants,

f. checking or testing water deluge systems,

g. checking of automatic sprinkler systems, and

h. testing of standpipes and hoses.

5. Contacts - The Station Fire Marshall maintains company contacts with local fire departments. The Station Fire Marshall and the Fire Protection Engineers maintain con-tact with fire prevention organizations, insurance companies, and others on matters relating to fire fighting.

6. Reporting Fires - Fire reports are issued by the station. The Fire Marshall reports fires as necessary to the insurance company.

3.1-6

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

7. Training of Personnel - The Station Training Department, Corporate Training Department, and Fire Marshall are responsible for personnel training. This is done to ensure that individuals trained become familiar with the operation and use of fire fighting equipment.

8. Rules and Standards - The Fire Protection Engineers assist and ad-vise departments concerned with established rules and standards re-lative to fire prevention and pro-tection as may be necessary.

9. Recommendations - On all recommendations initiated by insurance agencies, fire prevention organizations, and other outside activities or company departments, the Fire Protection Engineers investigate, evaluate, discuss, and review such recommendations, where necessary, before making final re-commendations as to specific action to be taken.

10. Design Change - All design changes are reviewed for impact upon the Fire Protection Program per administrative procedures.

It is our opinion that the intent of the Branch Technical Position is met by the above outlined organizational structure in design, construction and operation of the EGC nuclear plants.

(4) The organizational respon- Administrative procedures define the sibilities and lines of com- organizational responsibilities and munication pertaining to fire lines of communication for the Fire protection should be defined Protection Program.

between the various positions through the use of organi-zational charts and functional descriptions of each position's responsibilities. The follow-ing positions/organizations should be designated:

3.1-7

BYRON AMENDMENT 27 DECEMBER 2016 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (a) The upper level offsite Administrative procedures identify management position which the offsite-delegated individual has management respon- responsible for the nuclear plant sibility for the form- fire protection program.

ulation, implementation, and assessment of the Assessment of the program is made by effectiveness of the EGC Fire Protection Engineers.

nuclear plant fire protection program.

(b) The offsite management Nuclear Oversight and EGC Fire position(s) directly Protection Engineers have these responsible for formu- responsibilities.

lating, implementing, and periodically assessing the effectiveness of the fire protection program for the licensee's nuclear power plant including fire drills and training con-ducted by the fire brigade and plant personnel. The results of these assess-ments should be reported to the upper level manage-ment position responsible for fire protection with recommendations for im-provements or corrective actions as deemed neces-sary.

(c) The onsite management Administrative procedures identify position responsible for the onsite-delegated individual the overall administration responsible for the overall of the plant operations administration of the plant and emergency plans which operations and emergency plans.

include the fire pro-tection and prevention program and which provide a single point of control and contact for all con-tingencies.

3.1-8

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (d) The onsite position(s) which:

i. Implements periodic Administrative Procedures require inspections to: the Fire Marshall to conduct minimize the amount periodic plant tours, identify of combustibles in unacceptable conditions, and safety-related areas; initiate corrective actions.

determine the effec-tiveness of house- The Fire Marshall is responsible for keeping practices; implementation and administration of assure the avail- the fire protection program.

ability and accept-able condition of all Administrative Procedures state that fire protection Radiation Protection department will systems/equipment, control and maintain emergency emergency breathing breathing apparatus.

apparatus, emergency lighting, communi- Administrative Procedures state that cation equipment, Electrical Maintenance will maintain fire stops, pene- emergency lighting and tration seals, and communications.

fire retardant coatings; and assures Fire barriers, seals, doors, and the prompt and effec- dampers will be inspected per tive corrective Station procedures and surveillance.

actions are taken to correct conditions Administrative Procedures state that adverse to fire pro- the Fire Marshall will investigate tection and preclude fires, evaluate prevention recom-their recurrence. mendations and make recommendation when needed.

ii. Is responsible for Fire brigade training is a re-the fire fighting sponsibility of both the Fire training for op- Marshall and the training depart-erating plant per- ment. Operating personnel are sonnel and the trained periodically through the plant's fire bri- Training Department on fire fight-gade; design and ing.

selection of equip-ment; periodic in- The Operating Manager ensures all spection and testing operating surveillance are done in of fire protection accordance to required guides.

systems and equip-ment in accordance The Maintenance, Engineering and with established Operating Managers are responsible procedures, and eva- for station procedures performed by luate test results their department.

and determine the acceptability of the systems under test.

3.1-9

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Fire Marshall will review the sur-veillances he deems necessary.

Evaluation of tests and sur-veillances is specified in test, surveillance and administrative procedures.

Fire Marshall is responsible for the purchase of fire brigade equipment.

iii. Assists in the critique of Critique of all fire drills is a all fire drills to deter- responsibility of the Fire Marshall.

mine how well the training objectives have been met.

iv. Reviews and evaluates The Fire Marshall will have these proposed work activities responsibilities.

to identify potential transient fire loads.

v. Implements a program for Contractor's training through NGET indoctrination of all fulfills this requirement. They are plant contractor personnel informed of emergency procedures in appropriate adminis- relative to fire protection.

trative procedures which implement the fire pro-tection program, and the emergency procedures rel-ative to fire protection.

vi. Implements a program for The Administrative procedures pro-instruction of personnel vide instructions for personnel on on the proper handling of the proper handling of oil spills.

accidental events such as These procedures reference corporate leaks or spills of flam- general instruction on spill pre-mable materials that are vention and counter measures.

related to fire pro-tection.

3.1-10

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (e) The onsite position responsible The Fire Protection Program for fire protection quality as- identifies that Fire Protection assurance. This position Activities are treated as augmented should be responsible for quality per the QA program.

assuring the effective Site/Off-Site QA (Nuclear Oversight) implementation of the fire Department personnel conduct audits protection program by planned and surveillances to ensure proper inspections, scheduled audits, implementation and administration of and verification that the the Fire Protection Program.

results of these inspections of audits are promptly reported to cognizant management personnel.

(f) The positions which are part of the plant fire brigade:

i. The plant fire brigade Administrative procedures define the positions should be re- Fire Chief and Brigade responsi-sponsible for fighting bilities and the requirements for fires. The authority and authority and duties.

responsibility of each fire brigade position relative to fire pro-tection should be clearly defined.

ii. The responsibilities of each fire brigade position should correspond with the actions required by the fire fighting procedures.

iii. The responsibilities of Training will be scheduled through the fire brigade members the Fire Marshall and Operating under normal plant con- Department. Administrative Proce-ditions should not con- dures specify personnel (non-flict with their respon- brigade) required for operation.

sibilities during a fire emergency.

3.1-11

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE iv. The minimum number of Byron complies with BTP CMEB 9.5-1 trained fire brigade paragraph 3.3.b and Appendix R members available onsite III.H. which requires a 5 member for each operating shift brigade.

should be consistent with the activities required to combat the most signi-ficant fire. The size of the fire brigade should be based upon the functions required to fight fires with adequate allowance for injuries.

v. The recommendations for See Table 3-1 for discussion of organization, training, conformance with NFPA 27.

and equipment of "Private Fire Brigades" as specified in NFPA No. 27-1975, including the applicable NFPA publi-cations listed in the appendix to NFPA No. 27, are considered appropriate criteria for organizing, training, and operating a plant fire brigade.

(5) Personnel Qualifications. Comply.

(a) The position responsible The position responsible for the for formulation and imple- fire protection program has the use mentation of the fire of a Fire Protection Consultant.

protection program should These Consultants meet SFPE member have within his organ- grade requirements. Exelon ization or as a consultant Generation Company also employs Fire a fire protection engineer Protection Engineers who meet the who is a graduate of an qualifications for member grade in engineering curriculum of SFPE. (The Fire Protection accepted standing and Engineer's duties are identified in shall have completed not the Fire Protection Program less than 6 years of en- administrative procedures.)

gineering attainment in-dicative of growth in en-gineering competency and achievement, 3 years of which shall have been in responsible charge of fire protection engineering work. These requirements are the eligibility 3.1-12

BYRON AMENDMENT 25 DECEMBER 2012 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE requirements as a Member in the Society of Fire Protection Engineers.

(b) The fire brigade members' The fire brigade members have an qualifications should annual physical which shows them include satisfactory capable of unrestricted activity.

completion of a physical examination for performing strenuous activity, and of the fire brigade training described in Position C.3.d.

(c) The personnel responsible The personnel responsible for for the maintenance and maintenance and testing of the fire testing of the fire protection systems receive training protection systems should scheduled by the training be qualified by training department.

and experience for such work.

(d) The personnel responsible The initial training of the fire for the training of the brigade was administered by State of fire brigade should be Illinois licensed instructors.

qualified by training and experience for such work.

(6) The following NFPA publications The administrative procedures needed should be used for guidance to for maintaining the performance of develop the fire protection the fire protection system and program: personnel were established with the guidance of the NFPA standard No. 4 - "Organization for available at the time. The Fire Services" organization of fire protection services and the review of their No. 4A - "Organization of a performance is one of the functions Fire Department" of the station administration.

No. 6 - "Industrial Fire Loss See Table 3-1 for discussion of Prevention" conformance with the listed NFPA publications.

No. 7 - "Management Control of Fire Emergencies" No. 8 - "Management Re-sponsibilities for Effects of Fire on Operations" 3.1-13

BYRON AMENDMENT 23 DECEMBER 2008 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE No. 27 - "Private Fire Brigades" (7) On sites where there is an Comply.

operating reactor and construction or modification of Position Description procedures other units is underway, the define this as a duty of the station superintendent of the operating manager.

plant should have the lead responsibility for site fire protection.

b. Fire Hazards Analysis The fire hazards analysis Comply.

should demonstrate that the plant will maintain the ability The overall fire protection program to perform safe shutdown is based on evaluation of fire functions and minimize hazards so a safe shutdown can be radioactive releases to the accomplished. The fire protection environment in the event of a program began with the protection of fire. specific hazards in mind, to minimize, or prevent the loss of The fire hazards analysis property. The main emphasis is now should be performed by placed on safe plant shutdown, but qualified fire protection and the protection of ALL hazards will reactor systems engineers to satisfy both reasons. Not ALL (1) consider potential in situ hazards are protected or separated and transient fire hazards; (2) as indicated in other sections of determine the consequences of the report, but the basis for the fire in any location in the fire protection program basically plant on the ability to safely complies.

shut down the reactor or on the ability to minimize and control Fire hazards were considered in the release of radioactivity to plant design for Byron/Braidwood the environment; and (3) Units 1 and 2. The cable separation specify measures for fire criteria for the plant is described prevention, fire detection, in Appendix 5.2 of this report. The fire suppression, and fire fire protection system is discussed containment and alternative in Appendix 5.4.

shutdown capability as required for each fire area containing Deviations from the compliance structures, systems, and criteria of 10 CFR 50 Appendix R are components important to safety listed and justified in Appendix that are in conformance with A5.7..

NRC guidelines and regulations.

"Worst case" fires need not be postulated to be simultaneous with nonfire-related failures in safety systems, plant 3.1-14

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE accidents, or the most severe natural phenomena.

On multiple-reactor sites, Comply.

unrelated fires in two or more units need not be postulated to A fire involving more than one occur simultaneously. Fires reactor unit was not postulated involving facilities shared except for facilities shared between between units and fires due to units.

man-made site-related events that have a reasonable probability of occurring and affecting more than one reactor unit (such as an aircraft crash) should be considered.

Because fire may affect safe The criteria used to demonstrate shutdown systems and because safe shutdown capability are the loss of function of systems consistent with these requirements.

used to mitigate the consequences of design basis accidents under postfire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents. Three levels of fire damage limits are established according to the safety function of the structure, system, or component:

3.1-15

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Safety Function Fire Damage Limits Hot Shutdown One train of equipment necessary to achieve hot shutdown from either the control room or emergency control station(s) must be maintained free of fire damage by a single fire, including an exposure fire.

Cold Shutdown Both trains of equipment necessary to achieve cold shutdown may be damaged by a single fire, including an exposure fire, but damage must be limited so that at least one train can be repaired or made operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> using onsite capability.

Design basis Both trains of equip-accidents ment necessary for mitigation of consequences following design basis accidents may be damaged by a single exposure fire.

The most stringent fire damage limit should apply for those systems that fall into more than one category.

Redundant systems used to mitigate the consequences of other design basis accidents but not necessary for safe shutdown may be lost to a single exposure fire. However, protection shall be provided so that 3.1-16

BYRON AMENDMENT 21 DECEMBER 2004 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE a fire within only one such system will not damage the redundant system.

The fire hazards analysis should Sections 2.3 and 2.4 basically separately identify hazards and provide for each fire zone in the provide appropriate protection in plant the relevant information from locations where safety-related this list applicable to each zone.

losses can occur as a result of:

(1) Concentrations of combustible contents, including transient fire loads due to combustibles expected to be used in normal operations such as refueling, maintenance, and modifications; (2) Continuity of combustible contents, furnishings, building materials or combinations thereof in configurations conducive to fire spread; (3) Exposure fire, heat, smoke, or water exposure, including those that may necessitate evacuation from areas that are required to be attended for safe shutdown; (4) Fire in control rooms or other locations having critical safety-related functions; (5) Lack of adequate access or smoke removal facilities that impede fire extinguishment in safety-related areas; (6) Lack of explosion-prevention measures; (7) Loss of electric power or control circuits; (8) Inadvertent operation of fire Inadvertent operation of fire suppression systems. suppression systems has no adverse impact on safe shutdown capability as described in EC 341981.

3.1-17

BYRON AMENDMENT 24 DECEMBER 2010 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE The fire hazards analysis should verify that the NRC fire protection program guidelines have been met.

The analysis should list applicable elements of the program, with explanatory statements as needed to identify location, type of system, and design criteria. The analysis should identify and justify any deviations from the regulatory guidelines. Justification for deviations from the regulatory guidelines should show that an equivalent level of protection will be achieved. Deletion of a protective feature without compensating alternative protection measures will not be acceptable, unless it is clearly demonstrated that the protective measure is not needed because of the design and arrangement of the particular plant.

c. Fire Suppression System Design Comply.

Basis Backup fire suppression equipment is (1) Total reliance should not be provided in the form of manual hose placed on a single fire stations and portable fire suppression system. extinguishers at or near where Appropriate backup fire automatic fire suppression systems suppression capability should are installed as well as at other be provided. locations throughout the plant.

At the River Screen House, backup portable fire extinguishers are provided.

(2) A single active failure or a The primary supply of fire crack in a moderate-energy line protection water at each station is (pipe) in the fire suppression described in Appendix 5.4.

system should not impair both the primary and backup fire Cracks in the fire protection piping suppression capability. For will not impair primary suppression example, neither the failure of system performance or availability a fire pump, its power supply of the backup hose stations. Non-or controls, nor a crack in a safety-related portions of the fire moderate-energy line in the protection system can be isolated fire suppression system, should from the safety-related portions by result in loss of function of manual isolation valves. Loss of a both sprinkler and hose main fire pump is considered in the standpipe systems in an area design of the system. The SX system protected by such primary and is also available as a backup for backup systems. the hose stations.

3.1-18

BYRON AMENDMENT 29 DECEMBER 2020 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (3) As a minimum, the fire Comply.

suppression system should be capable of delivering water to See Section A5.4.1. Cross-ties to manual hose stations located the essential service water system within hose reach of areas are provided to ensure seismically containing equipment required qualified water supply to the for safe plant shutdown Seismic Category I portions of the following the safe shutdown fire suppression (standpipe systems) earthquake (SSE). In areas of located in safety-related areas.

high seismic activity, the staff will consider on a case-by-case basis the need to design the fire detection and suppression systems to be functional following the SSE.

(4) The fire protection systems Comply.

should retain their original design capability for (a) Seismic design is considered in the whole FP natural phenomena of less system; however, only the Category I portions are severity and greater frequency designated seismic. The majority of the Fire than the most severe natural Protection system previously classified as Safety phenomena (approximately once Category I, Quality Group C has been reclassified as in 10 years) such as tornadoes, Safety Category II, Quality Group D (Ref. EC hurricanes, floods, ice storms, 626662); and remains classified as Seismic Category or small-intensity earthquakes I. Floods have no effect. A single tornado missile that are characteristic of the can do no more damage than as described in 3.1c2.

geographic region, and (b) potential man-made site-related events such as oil barge collisions or aircraft crashes that have a reasonable probability of occurring at a specific plant site. The effects of lightning strikes should be included in the overall plant fire protection program.

(5) The consequences of inadvertent Comply.

operation of or a crack in a moderate energy line in the fire suppression system should meet the guidelines specified for moderate-energy systems outside containment in SRP Section 3.6.1.

3.1-19

BYRON AMENDMENT 23 DECEMBER 2008 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

d. Alternate or Dedicated Shutdown Alternative or dedicated shut- Comply (Refer to Section 2.4 "Safe down capability should be Shutdown Analysis")

provided where the protection of systems whose functions are Exemptions from 10 CFR 50 Appendix R required for safe shutdown is Sections III.G and III.L are listed not provided by established in Appendix A5.7.

fire suppression methods or by Position C.5.6.

e. Implementation of Fire Protection Programs (1) The fire protection program Comply.

(plans, personnel, and equipment) for buildings Fire Brigade, hose reels and fire storing new reactor fuel and extinguishers were functional prior for adjacent fire areas that to receiving fuel. Training records could affect the fuel storage and surveillance were being area should be fully conducted for receipt of fuel. Pre-operational before fuel is fire plans were in place for the received at the site. Such fuel handling building and the adjacent areas include those adjacent fire areas. The fire whose flames, hot gases, and brigade members were trained prior fire-generated toxic and to receiving fuel on site.

corrosive products may jeopardize safety and surveillance of the stored fuel.

(2) The fire protection program for Comply.

an entire reactor unit should be fully operational prior to initial fuel loading in that reactor unit.

(3) On reactor sites where there is Comply.

an operating reactor and construction or modification of The continuing evaluation of fire other units is under way, the hazards is accomplished by periodic fire protection program should inspections as specified in provide for continuing administrative procedures.

evaluation of fire hazards.

Additional fire barriers, fire Administrative control to protect protection capability, and the operating unit from construction administrative controls should fire hazards is accomplished by be provided as necessary to adhering to administrative protect the operating unit from procedures.

construction fire hazards.

3.1-20

BYRON AMENDMENT 13 DECEMBER 1990 3.2 ADMINISTRATIVE CONTROLS IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Administrative controls should be Administrative controls which will used to maintain the performance of be in effect will comply with the the fire protection system and requirements of this section.

personnel. These controls should establish procedures to:

a. Prohibit bulk storage of Comply. Refer to Section III.K.2 of combustible materials inside or Appendix A5.7.

adjacent to safety-related buildings or systems during operation or maintenance periods. Regulatory Guide 1.39 provides guidance on housekeeping, including the disposal of combustible materials.

b. Govern the handling and Comply. Refer to Section III.K.1 of limitation of the use of Appendix A5.7.

ordinary combustible materials, combustible and flammable gases and liquids, high efficiency particulate air and charcoal filters, dry ion exchange resins, or other combustible supplies in safety-related areas.

c. Govern the handling of and Comply. Refer Section III.K.3 of limit transient fire loads such Appendix A5.7.

as combustible and flammable liquids, wood and plastic products, or other combustible materials in buildings containing safety-related systems or equipment during all phases of operating, and especially during maintenance, modification, or refueling operations.

3.2-1

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

d. Designate the onsite staff Comply. Refer to Section III.K.4 of member responsible for the Appendix A5.7.

inplant fire protection review of proposed work activities to identify potential transient fire hazards and specify required additional fire protection in the work activity procedure.

e. Govern the use of ignition Comply. Refer to Section III.K.5 of sources by use of a flame Appendix A5.7.

permit system to control welding, flame cutting, brazing, or soldering 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the plant is operating or for the duration of a particular job during plant shutdown.

f. Control the removal from the Comply. Refer to Section III.K.6 of area of all waste, debris, Appendix A5.7.

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.

g. Govern leak testing; similar Comply. Leak testing is done with procedures such as airflow noncombustible materials.

determination should use one of the commercially available techniques. Open flames or combustion-generated smoke should not be permitted.

h. Maintain the periodic Comply. Refer to Section III.K.7 of housekeeping inspections to Appendix A5.7.

ensure continued compliance with these administrative controls.

3.2-2

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

i. Control the use of specific Comply with exceptions. Refer to combustibles in safety-related Section III.K.8 of Appendix A5.7 for areas. All wood used in details.

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 materials such as wood or paper excelsior, or polyethylene sheeting should be placed in metal containers with tight-fitting self-closing metal covers.

j. Disarming of fire detection or Comply. Disarming of fire detection fire suppression systems should or fire suppression systems is be controlled by a permit controlled by administrative system. Fire watches should be procedure. A fire watch or other established in areas where compensatory measures are systems are so disarmed. established as required by the governing administrative procedure.

3.2-3

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

k. Successful fire protection Comply. The scope of the job requires testing and maintenance classification for maintenance of the fire protection equipment personnel identifies job and the emergency lighting and responsibilities in the area of fire communication. A test plan that protection.

lists the individuals and their responsibilities in connection Disarming of fire detection or fire with routine tests and suppression systems for maintenance inspections of the fire detection is controlled by administrative and protection systems should be procedure. A fire watch or other developed. The test plan should compensatory measures are contain the types, frequency, and established as required by the detailed procedures for testing. governing administrative procedure.

Procedures should also contain The surveillance program (Test instructions on maintaining fire Plan) contains the types, frequency, protection during those periods and detailed procedures for testing.

when the fire protection system is impaired or during periods of plant maintenance, e.g., fire watches or temporary hose connections to water systems.

l. Control actions to be taken by Comply. Refer to Section III.K.9 of an individual discovering a Appendix A5.7.

fire, for example, notification of control room, attempt to extinguish fire, and actuation of local fire suppression systems.

m. Control actions to be taken by Comply. Refer to Section III.K.10 the control room operator to of Appendix A5.7.

determine the need for brigade assistance upon report of a fire or receipt of alarm on control room 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.

3.2-4

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

n. Control actions to be taken by Comply. Refer to Section III.K.11 the fire brigade after of Appendix A5.7.

notification by the control room operator of a 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.

o. Define the strategies for Pre-fire plans have been developed fighting fires in all safety- for Byron which generally meet these related areas and areas guidelines. Refer to Appendix A5.7, presenting a hazard to safety- Section K.12 for a detailed related equipment. These discussion of these plans and their strategies should designate: conformance to these requirements.

(1) Fire hazards in each area 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, 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 3.2-5

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE 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 overpres-surization 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 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 3.2-6

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE control room, and co-ordination 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.

3.2-7

BYRON AMENDMENT 20 DECEMBER 2002 3.3 FIRE BRIGADE IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

a. The need for good organization, The guidelines of Regulatory Guide training, and equipping of fire 1.101 are followed where applicable.

brigades at nuclear power plant Insurance industry standards in sites requires that effective existence at that time and NFPA 27-measures be implemented to "Private Fire Brigades" - were ensure proper discharge of consulted in writing the procedures.

these functions. The guidance in Regulatory Guide 1.101, Station administrative procedures "Emergency Planning for Nuclear governing the fire protection Power Plants," should be program outlines the organization, followed as applicable. training and the equipping of the fire brigades.

3.3-1

BYRON AMENDMENT 23 DECEMBER 2008 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

b. A site fire brigade trained and Comply, except as noted. Refer to equipped for fire fighting Section III.H of Appendix A5.7 for should be established to ensure details.

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.

3.3-1a

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

c. The minimum equipment provided Comply. Refer to Section III.H of for the brigade should consist Appendix A5.7 for details.

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 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.

3.3-2

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

d. The fire brigade training The fire brigade training program program shall ensure that the meets the requirements presented in capability to fight potential Items 1 through 9 herein. Refer to fires is established and Section III.I of Appendix A5.7 for a maintained. The program shall discussion of conformance with the consist of an initial classroom requirements of Items 1 through 8 instruction program followed by below.

periodic classroom instruction, fire fighting practice, and fire drills.

(1) The initial classroom instruction should include:

(a) Indoctrination of the plant fire fighting plan with specific identification of each individual's responsibilities.

(b) Identification of the type and location of fire hazards and associated types of fires that could occur in plant.

(c) The toxic and corrosive characteristics of expected products of combustion.

(d) Identification of the location of fire fighting equipment for each fire area and familiarization with the layout of the plant, including access and egress routes to each area.

3.3-3

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (e) The proper use of available fire fighting equipment and the corrective method of fighting each type of fire.

The types of fires covered should include fires in energized electrical equipment, fires in cables and cable trays, hydrogen fires, fires involving flammable and combustible liquids of hazardous process chemicals, fires resulting from construction or modification (welding), and record file fires.

(f) The proper use of communication, lighting, venti-lation, and emergency breathing equipment.

(g) The proper method for fighting fires inside buildings and confined spaces.

(h) The direction and coordination of the fire fighting activities (fire brigade leaders only).

(i) Detailed review of fire fighting strategies and procedures.

(j) Review of the latest plant modifications and corresponding 3.3-4

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE changes in fire fighting plans.

(k) Training of the plant Comply with Items k and l. The fire brigade should local fire department is included be coordinated with periodically in the station fire the local fire de- drills, which require them coming partment so that re- into the plant boundary. The local sponsibilities and fire department has been trained in duties are delineated operational precaution and the need in advance. This for radioactive protection of coordination should personnel in fighting fires in a be part of the nuclear power plant. It is clearly training course and understood by the local fire should be included in department that they are a reserve the training of the force only and that they will be local fire department under the direction of the station staff. Fire Marshall or Chief at the station.

(l) Local fire de-partments should be provided training in operational precautions when fighting fires on nuclear power plant sites and should be made aware of the need for radiological protection of personnel and the special hazards associated with a nuclear power plant site.

Note: Items (i) and (j) may be deleted from the training of no more than two of the nonoperations personnel who may be assigned to the fire brigade.

(2) The instruction should be Comply. Refer to Section III.I.1.b provided by qualified of Appendix A5.7.

individuals who are knowledgeable, experienced, and 3.3-5

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE suitably trained in fighting the types of fires that could occur in the plant and in using the types of equipment available in the nuclear power plant.

(3) Instruction should be provided to all fire brigade members and fire brigade leaders.

(4) Regular planned meetings should Comply. Refer to Section III.I.1.d be held at least every 3 months of Appendix A5.7.

for all brigade members to review changes in the fire protection program and other subjects as necessary.

(5) Periodic refresher training Comply. Refer to Section III.I.1.e sessions shall be held to of Appendix A5.7.

repeat the classroom in-struction program for all brigade members over a 2-year period. These sessions may be concurrent with the regular planned meetings.

(6) Practice (a) Practice sessions should Comply. Refer to Section III.I.2 of be held for each shift Appendix A5.7.

fire brigade on the proper method of fighting the various types of fires that could occur in a nuclear power plant.

These sessions shall provide brigade members with experience in actual fire extinguishment and the use of emergency breathing apparatus under strenuous conditions encountered in fire fighting.

(b) These practice sessions should be provided at least once per year for each fire brigade member.

3.3-6

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (7) Drills (a) Fire brigade drills should Items 7a through 7f under (7) drills be performed in the plant are accomplished by administrative so that the fire brigade procedure that includes drill and can practice as a team. drill assessments. Refer to Section III.I.3 of Appendix A5.7 for details.

(b) Drills should be performed at regular intervals not to exceed 3 months for each shift fire brigade.

Each fire brigade member should participate in each drill, but must parti-cipate in at least two drills per year.

A sufficient number of these drills, but not less than one for each shift fire brigade per year, should be unannounced to determine the fire fighting readiness of the plant fire brigade, brigade leader, and fire protection systems and equipment. Persons planning and authorizing an unannounced drill should ensure that the responding shift fire brigade members are not aware that a drill is being planned until it is begun. Unannounced drills should not be scheduled closer than 4 weeks.

At least one drill per year should be performed on a "back shift" for each shift fire brigade.

3.3-7

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (c) The drills should be pre-planned to establish the training objectives of the drill and should be critiqued to determine how well the training objectives have been met.

Unannounced drills should be planned and critiqued by members of the man-agement 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.

Unsatisfactory drill performance should be followed by a repeat drill within 30 days.

(d) These drills should provide for local fire department participation periodically (at least annually).

(e) At 3-year intervals, a randomly selected unannounced drill should be critiqued by qualified individuals independent of the licensee's staff. A copy of the written report from such individuals should be available for NRC review.

(f) Drills should as a minimum include the following:

i. Assessment of fire alarm effectiveness, time required to notify and assemble 3.3-8

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE fire brigade, and selection, placement, and use of equipment and fire fighting strategies.

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.

iii. The simulated use of fire fighting equipment required to cope with the situation and type of fire selected for the drill. The area and type of fire chosen for the drill should differ from those used in the previous drills so that brigade members are trained in fighting fires in various plant areas.

The situation selected should simulate the size 3.3-9

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE And arrangement of a fire that could reasonably occur in the area selected, allowing for fire development due to the time required to respond, to obtain equipment, and organize for the fire, assuming loss of automatic suppression capability.

iv. Assessment of brigade leader's direction of the fire fighting effort as to thoroughness, accuracy, and effectiveness.

(8) Records Individual records of training Comply. Refer to Section III.I.4 of provided to each fire brigade Appendix A5.7.

member, including drill critiques, should be maintained for at least 3 years to ensure that each member receives training in all parts of the training program. These records of training should be available for NRC review.

Retraining or broadened training for fire fighting within buildings should be scheduled for all those brigade members whose performance records show deficiencies.

(9) Guidance Documents NFPA 27, "Private Fire Comply. Fire training by Brigade," should be followed in responsible instructors is done organization, training, and periodically. See Table 3-1 for fire drills. This standard delineation of conformance with NFPA also is applicable for the 27. NFPA 197 has been renumbered inspection and maintenance of NFPA 1410, deals with public fire departments, and is not applicable at the station level.

3.3-10

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE fire fighting equipment. Among the The local fire department has been standards referenced in this checked for fire hose thread document, NFPA 197, "Training compatibility and a letter is on Standard on Initial Fire Attacks," file to document compatibility. The should be utilized as applicable. letter is on file in central files NFPA booklets and pamphlets listed at Byron Station.

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.

3.3-11

BYRON AMENDMENT 20 DECEMBER 2002 3.4 QUALITY ASSURANCE PROGRAM IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE The quality assurance (QA) programs The fire protection systems at Byron of applicants and contractors should Station Units 1 and 2 are addressed ensure that the guidelines for in two different manners under the design, procurement, installation, Quality Assurance Program.

and testing and the administrative controls for the fire protection 1. Fire protection systems classed systems for safety-related areas are as safety-related are covered satisfied. The QA program should be by the entire Quality Assurance under the management control of the Program which includes the QA organization. This control criteria set forth in Appendix consists of (1) formulating a fire B of 10 CFR 50.

protection QA program that incorporates suitable requirements 2. Fire protection systems that and is acceptable to the management are classed as non-safety-responsible for fire protection or related and that are awarded verifying that the program after September 1, 1978 are incorporates suitable requirements procured and installed in and is acceptable to the management accordance with the Branch responsible for fire protection, and Technical Position 9.5-1.

(2) verifying the effectiveness of Vendors awarded with supplying the QA program for fire protection or installing a fire protection through review, surveillance, and system after September 1, 1978 audits. Performance of other QA must have an approved QA program functions for meeting the Program as required by the fire protection program requirements Quality Assurance Program and may be performed by personnel be on the Approved Bidder's outside of the QA organization. The List.

QA program for fire protection should be part of the overall plant However, exceptions may be made QA program. It should satisfy the for selected non-safety-related specific criteria listed below. systems to allow installation without an approved QA program.

Each installation of this type requires a separate analysis that 3.4-1

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE includes, as a minimum, a regulatory change evaluation; a definable augmented quality class break point, such as an isolation valve; and a hydraulic evaluation for added sprinklers or fire hose stations, as applicable. The applicable fire and building codes (such as NFPA codes) will be followed and a fire protection engineer will review the change.

Scheduled fire protection inspections are conducted under the direction of QA (Nuclear Oversight) and with direct participation by a qualified fire protection engineer consultant. New designs or revisions to plant fire protection systems are reviewed as outlined in the response to Section 3.1.

The Quality Assurance Program applies to procurement, design, installation, modifications and maintenance activities involving fire protection systems. As such, each specific criteria listed as "a" through "j" of Section NRC Position are covered by the Quality Assurance 3.4-1a

BYRON AMENDMENT 19 DECEMBER 2000 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Program and by Department and Station Procedures. Further implementation relating to specific criteria, where deemed appropriate follow:

a. Design and Procurement Document Control Measures should be established to ensure that the guidelines of the regulatory position of this guide are included in design and procurement documents and that deviations therefrom are controlled.

b. Instructions, Procedures, b. Department and station and Drawings procedures are established to cover specific instructions Inspections, test, such as for inspections, test, administrative controls, administrative controls, fire fire drills, and training drills and training that govern that govern the fire the fire protection program.

protection program should be prescribed by documented instructions, procedures, or drawings and should be accomplished in accordance with these documents.

c. Control of Purchased c. Carbon dioxide (CO2) is Material, Equipment, and controlled as a non-safety-Services related item per Material Engineering Group Evaluation Measures should be M-94-0585-00.

established to ensure that purchased material, equipment, and services conform to the procure-ment documents.

3.4-2

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

d. Inspection d. Independent inspections are performed by Quality Assurance A program for independent (Nuclear Oversight), utilizing inspection of activities fire protection consultants, as affecting fire protection required.

should be established and executed by or for the At Byron, periodic inspections organization performing are performed on fire-rated the activity to verify penetration seals. Inspection conformance with docu- of the interface between mented installation exterior electrical conduit drawings and test proce- surfaces and the fire barrier dures for accomplishing are performed as part of the the activities. periodic fire barrier inspection. This conduit/barrier interface consists of an approved material specified by typical details on design drawings, which restores the barrier after the conduit has been installed in accordance with the QA Program. At the request of the Byron NRC Resident Inspector in May 2000, one sample conduit penetration in a masonry block wall in the Unit 2 4KV Switchgear Room was examined to verify its installation conforms to the design detail. It was confirmed that the conduit/barrier interface was installed during initial installation as specified in the design drawing. See also Section C.4.i for a discussion of Records associated with the installation of conduit/barrier interfaces.

3.4-3

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

e. Test and Test Control e. Tests of fire protection equipment and systems are A test program should be included in regularly scheduled established and imple- station operating surveillance mented to ensure that procedures. These procedures testing is performed and and test results are reviewed verified by inspection and and evaluated by appropriate audit to demonstrate station personnel. QA (Nuclear conformance with design Oversight) also audits this and system readiness area.

requirements. The tests should be performed in accordance with written test procedures; test results should be properly evaluated and acted on.

f. Inspection, Test, and Operating Status Measures should be established to provide for the identification of items that have satis-factorily passed required tests and inspections.

g. Nonconforming Items Measures should be established to control items that do not conform to specified requirements to prevent inadvertent use or installation.

3.4-3a

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

h. Corrective Action h. Tests of fire protection equipment and systems are Measures should be included in regularly scheduled established to ensure that operating surveillance conditions adverse to fire procedures. Nonconforming protection, such as fail- equipment is identified as a ures, malfunctions, de- result of their test and ficiencies, deviations, corrective action taken to defective components, un- rectify any deficiencies as controlled combustible provided by the QA Program.

material and nonconform-ances, are promptly identified, reported, and corrected.

i. Records i. Documentation involving the fire protection program is Records should be prepared retained in a central file or and maintained to furnish QA vault as provided by the QA evidence that the criteria Program.

enumerated above are being met for activities affect- Records of fire-rated barriers ing the fire protection and fire-rated penetration program. seals are maintained in accordance with the QA Program.

Individual installation records for each internal conduit non-combustible seal, cable tray fire stop, mechanical penetration seal, and other fire-rated seals are maintained in accordance with the QA Program. The sealing interface between exterior electrical conduit surfaces and a fire barrier is not considered an individual fire seal. Installation records of this interface are a part of the fire barrier QA records.

3.4-4

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

j. Audits j. Scheduled audits and surveillances of the fire Audits should be conducted protection activities in our and documented to verify plants are performed in compliance with the fire accordance with the QA Program protection program, by the Nuclear Oversight including design and Department.

procurement documents, instructions, procedures and drawings, and inspection and test activities.

3.4-4a

BYRON AMENDMENT 19 DECEMBER 2000 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE SITE QUALITY ASSURANCE The fire protection program is covered by the Quality Assurance Program. Fire Protection activities are subject to audit under the applicable portions of the approved QA program to ensure proper implementation and compliance with commitments, which is described in the QA topical report (QATR) CE-1-A.

FIRE PROTECTION AUDIT CRITERIA Quality Assurance can use, but is not limited to, the following documents as audit reference material.

1. Station Fire Protection Report

2. Station responses to the Branch Technical Position 9.5-1.

3. Station SER and Supplements

4. Technical Specifications

5. Station Fire Protection Procedures

6. QATR

7. NFPA Codes

8. Applicable sections of 10 CFR 50 App. R

9. 29 CFR 1910.155 to 165 3.4-5

BYRON AMENDMENT 23 DECEMBER 2008 3.5 GENERAL PLANT GUIDELINES IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

a. Building Design (1) Fire barriers with a minimum The fire area concept, as it relates fire resistance rating of 3 to reactor safety, was not a hours should be provided to: requirement in the initial design of Byron Station Units 1 and 2. As (a) Separate safety-related implied in the Branch Technical systems from any potential Position and as stated in Section fires in non-safety- 4.3.4.4 of NUREG-0050, "Recommend-related areas that could ation Related to Browns Ferry Fire,"

affect their ability to the fire area concept is impractical perform their safety to implement to any great extent to function; plants already under construction.

The original plant design did (b) Separate redundant incorporate a fire hazard separation divisions or trains of in accordance with insurance safety-related systems industry standards for nuclear power from each other so that plants. In areas where redundant both are not subject to safety-related systems could not be damage from a single fire; separated from each other by a barrier, an analysis was conducted (c) Separate individual units to determine if both ESF divisions on a multiple-unit site could be adversely affected by a unless the requirements of single postulated credible fire.

General Design Criterion 5 These areas are identified in are met with respect to Section 2.3. Deviations from the fires. Appendix R separation criteria are identified and justified in Appendix A5.7.

(2) Appropriate fire barriers The general separation criteria used should be provided within a for Byron Units 1 and 2 is described single safety division to in Appendix 5.2 of this report. In separate components that general, safety-related systems are present a fire hazard to other isolated from unacceptable fire safety-related components or hazards as discussed in Section 2.3.

high concentrations of safety-related cables within that division.

3.5-1

BYRON AMENDMENT 19 DECEMBER 2000 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (3) Openings through fire barriers Electrical penetration seals have for pipe, conduit, and cable been installed at all barrier trays which separate fire areas penetrations; their construction should be sealed or closed to characteristics are described in provide a fire resistance Appendix 5.2. Mechanical rating at least equal to that penetration seals have been required of the barrier itself. installed in all penetrations of Openings inside conduit larger rated fire barriers.

than 4 inches in diameter should be sealed at the fire All openings inside conduits that barrier penetration. Openings penetrate fire barriers that inside conduit 4 inches or less separate fire areas are sealed in in diameter should be sealed at accordance with Appendix A5.2.2 of the fire barrier unless the this report.

conduit extends at least 5 feet on each side of the fire barrier and is sealed either at both ends or at the fire barrier with noncombustible material to prevent the passage of smoke and hot gases. Fire barrier penetrations that must maintain environmental isolation or pressure differentials should be qualified by test to maintain the barrier integrity under such conditions.

Penetration designs should For both the electrical and utilize only noncombustible mechanical penetrations, all materials and should be materials used in the construction qualified by tests. The of the fire stops have a flame penetration qualification tests spread of 25 or less. Penetration should use the time-temperature tests were conducted in accordance exposure curve specified by with IEEE 634-78 using the time ASTM E-119, "Fire Test of temperature curve of ASTM E-119.

Building Construction and Materials." The acceptance criteria for the test should require that:

3.5-2

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (a) The fire barrier All rated fire barrier penetration penetration has withstood seals have 3-hour ratings.

the fire endurance test without passage of flame or ignition of cables on the unexposed side for a period of time equivalent to the fire resistance rating required of the barrier.

(b) The temperature levels The acceptance criteria is an recorded for the unexposed average of 250!F above ambient.

side are analyzed and This is considered to be equivalent demonstrate that the to the stated requirement.

maximum temperature does not exceed 325!F.

(c) The fire barrier Fire testing is normally done per penetration remains intact IEEE-634.

and does not allow projection of water beyond the unexposed surface during the hose stream test. The stream shall be delivered through a 1-1/2-inch nozzle set at a discharge angle of 30%

with a nozzle pressure of 75 psi and a minimum discharge of 75 gpm with the tip of the nozzle a maximum of 5 ft from the exposed face; or the stream shall be delivered through a 1-1/2-inch nozzle set at a discharge 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, 3.5-3

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE located 20 feet from the exposed face.

(4) Penetration openings for Ventilation system penetrations in ventilation systems should be rated barriers are protected by fire protected by fire dampers dampers having a rating equivalent having a rating equivalent to to that of the barrier.

that required of the barrier (see NFPA-90A, "Air For details, see the Fire Protection Conditioning and Ventilating Report Subsection 2.1.4.1b and c.

Systems"). Flexible air duct coupling in ventilation and See Table 3-1 for delineation of filter systems should be conformance with NFPA-90A.

noncombustible.

(5) Door openings in fire barriers Access doors in fire barriers are should be protected with Label A or B fire doors or are of equivalently rated doors, Label A or B construction (see frames, and hardware that have Section 2.1, page 2.1-8 for a been tested and approved by a detailed discussion of doors nationally recognized labora- provided for rated fire barriers).

tory. Such doors should be self-closing or provided with See Table 3-1 for delineation of closing mechanisms and should conformance with NFPA 80:

be inspected semiannually to verify that automatic hold-open, release, and closing mechanisms and latches are operable. (See NFPA 80, "Fire Doors and Windows.")

One of the following measures All fire doors have automatic should be provided to ensure closers. Options a, b, and d are they will protect the opening used on various doors in the plant.

as required in case of fire: Cable spreading room interior doors alarm in the control room. The other supervised doors are monitored by security.

3.5-4

BYRON AMENDMENT 23 DECEMBER 2008 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (a) Fire doors should be kept closed and electrically supervised at a contin-uously manned location; (b) Fire doors should be Locked fire doors are inspected locked closed and every 31 days, based upon historical inspected weekly to verify analysis of plant specific records that the doors are in the (document identification number closed position; DG99-000873).

(c) Fire doors should be provided with automatic hold-open and release mechanisms and inspected daily to verify that doorways are free of obstructions; or (d) Fire doors should be kept Unlocked fire doors are inspected closed and inspected daily every 7 days, based upon historical to verify that they are in analysis of plant specific records the closed position. (document identification number DG99-000873).

The fire brigade leader should The brigade chief can obtain a key have ready access to keys for to access all areas.

any locked fire doors.

Access protected by automatic The diesel generator day tank rooms, total flooding gas suppression the auxiliary feedwater diesel systems should have driven pump and day tank rooms, and electrically supervised self- the essential service water makeup closing fire doors or should pump diesel oil storage tank rooms satisfy option (a) above. are not electrically supervised, although they are protected by automatic total flooding gas suppression systems. The diesel generator rooms are also protected by automatic total flooding gas suppression systems; however, the doors from the diesel generator rooms to their respective ventilation shaft areas are not electrically supervised.The fire doors to these rooms are surveilled to ensure they are in their proper positions.

3.5-5

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (6) Personnel access routes and The stairwells at Byron which serve escape routes should be as escape routes for station provided for each fire area. personnel and access routes for Stairwells outside primary fire-fighting personnel, as per the containment serving as escape requirements of building codes, are routes, access routes for enclosed by 2-hour fire rated firefighting, or access routes masonry walls with self-closing fire to areas containing equipment doors, and are clearly marked.

necessary for safe shutdown should be enclosed in masonry or concrete towers with a minimum fire rating of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and self-closing Class B fire doors.

3.5-5a

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (7) Fire exit routes should be Comply, see item 6 above.

clearly marked.

(8) Each cable spreading room The Byron design complies, except should contain only one for instances where cables from both redundant safety division. safety divisions are routed in the Cable spreading rooms should same cable spreading room. Fire not be shared between reactors. Protection Report Section 2.4.2 Cable spreading rooms should be describes the measures taken in separated from each other and these areas to assure safe shutdown.

from other areas of the plant by barriers having a minimum fire resistance of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

(9) Interior wall and structural Minor amounts of combustibles are components, thermal insulation used as architectural finish materials, radiation shielding materials. These existing materials materials, and soundproofing do not significantly contribute to should be noncombustible. the fire loading in the plant, and do not expose safety-related systems to undue risks.

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.

3.5-6

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (10) Metal deck roof construction Not applicable. Metal deck roof should be noncombustible and construction is not used at Byron listed as "acceptable for fire" Station.

in the UL Building Materials Directory, or listed as Class I in the Factory Mutual System Approval Guide.

(11) Suspended ceiling and their Comply.

supports should be of non-combustible construction.

Concealed spaces should be devoid of combustibles except as noted in Position C.6.b.

(12) Transformers installed inside Comply. See Table 3-1 for fire areas containing safety- discussion of compliance with NFPA related systems should be of 70.

the dry type or insulated and cooled with noncombustible liquid. Transformers filled with combustible fluid that are located indoors should be enclosed in a transformer vault (see Section 450 (c) of NFPA 70, "National Electrical Code").

(13) Outdoor oil-filled transformer Does not fully comply. The Unit 1 should have oil spill (2) Unit Auxiliary Transformer 141 confinement features or (241) is within approximately 30 drainage away from the feet of the turbine building. The buildings. Such transformers turbine building wall has a 2-hour should be located at least 50 fire rating in this area. It also feet distant from the building, has a door with a 1-1/2-hour or or by ensuring that such Class B fire rating. The turbine building walls within 50 feet building and equipment located of oil-filled transformers are inside it are non-safety-related.

without openings and have a All outdoor transformers are fire resistance rating of at separated from the safety-related least 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. auxiliary building by approximately 48 feet. The auxiliary building wall in this area has a 3-hour fire rating.

3.5-7

BYRON AMENDMENT 25 DECEMBER 2012 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (14) Floor drains sized to remove Comply. See Table 3-1 for expected firefighting waterflow discussion of compliance with NFPA without flooding safety-related Codes such as NFPA 13, 15. 16, etc.,

equipment should be provided in which takes the place of the those areas where fixed water previous guidance in NFPA 92M. NFPA fire suppression systems are 92M-1972 is no longer an NFPA Code.

installed. Floor drains should also be provided in other areas where hand hose lines may be used if such firefighting water could cause unacceptable damage to safety-related equipment in the area (see NFPA-92, "Water-proofing and Draining of Floors"). Where gas sup-pression systems are installed, the drains should be provided with adequate seals or the gas suppression system should be sized to compensate for the loss of the suppression agent through the drains. Drains in areas containing combustible liquids should have provisions for preventing the backflow of combustible liquids to safety-related areas through the interconnected drain systems.

Water drainage from areas that may contain radioactivity should be collected, sampled, and analyzed before discharge to the environment.

b. Safe Shutdown Capability (1) Fire protection features should Refer to Appendix A5.7, Section be provided for structures, III.G for a discussion of fire systems, and components protection provided for safe important to safe shutdown. shutdown capability and detailed These features should be discussion of conformance to the capable of limiting fire damage criteria listed in paragraphs b(1),

so that: b(2), and b(3).

(a) One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency 3.5-8

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE control station(s) is free of fire damage; and (b) Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station(s) can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

2. To meet the guidelines of Position C5.b.1, one of the following means of ensuring that one of the redundant trains is free of fire damage should be provided:

(a) Separation of cables and equipment and associated circuits of redundant trains by a fire barrier having a 3-hour rating.

Structural steel forming a part of or supporting such fire barriers should be protected to provide fire resistance equivalent to that required of the barrier; (b) Separation of cables and equipment and associated circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustible or fire hazards. In addition, fire detectors and an automatic fire suppression system should be installed in the fire area; or (c) Enclosure of cable and equipment and associated circuits of one redundant train in a fire barrier having a 1-hour rating.

In addition, fire de-tectors and an automatic 3.5-9

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE fire suppression system should be installed in the fire area.

(3) If the guidelines of Positions C5.b.1 and C5-b.2 cannot be met, then alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room, or zone under consideration should be provided.

c. Alternative or Dedicated Shutdown Capability (1) Alternative or dedicated shutdown capability provided for a specific fire area should be able to achieve and maintain subcritical reactivity conditions in the reactor, maintain reactor coolant inventory, achieve and maintain hot standby* conditions for a PWR (hot shutdown* for a BWR) and achieve cold shutdown*

conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and maintain cold shutdown conditions thereafter. During the postfire shutdown, the reactor coolant system process variables shall be maintained within those predicted for a loss of normal ac power, and the fission product boundary integrity shall not be affected; i.e., there shall be no fuel clad damage, rupture, or any primary coolant boundary, or rupture of the containment boundary.

• As defined in the Technical Requirements Manual 3.5-10

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (2) The performance goals for the Comply, with following shutdown functions should be: clarification. For some fire zones, it is necessary to take credit for (a) The reactivity control Making certain repairs in order to function should be capable achieve cold shutdown within 72 of achieving and hours. Refer to Section 2.4 for maintaining cold shutdown details for individual fire zones.

reactivity conditions.

(b) The reactor coolant makeup function should be capable of maintaining the reactor coolant level above the top of the core for BWRs and be within the level indication in the pressurizer for PWRs.

(c) The reactor heat removal function should be capable of achieving and maintaining decay heat removal.

(d) The process monitoring function should be capable of providing direct readings of the process variables necessary to perform and control the above functions.

(e) The supporting functions should be capable of providing the process cooling, lubrication, etc., necessary to permit the operation of the equipment used for safe shutdown functions.

(3) The shutdown capability for Comply.

specific fire areas may be unique for each such area, or it may be one unique combination of systems for all such areas. In either case, the alternative shutdown capability shall be independent of the specific fire area(s) 3.5-11

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE and shall accommodate postfire conditions where offsite power is available and where offsite power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Procedures shall be in effect to implement this capability.Comply.

(4) If the capability to achieve Comply.

and maintain cold shutdown will not be available because of fire damage, the equipment and systems comprising the means to achieve and maintain the hot standby or hot shutdown condition shall be capable of maintaining such conditions until cold shutdown can be achieved. If such equipment and systems will not be capable of being powered by both onsite and offsite electric power systems because of fire damage, an independent onsite power system shall be provided. The number of operating shift personnel, exclusive of fire brigade members, required to operate such equipment and systems shall be onsite at all times.

(5) Equipment and systems Comply. Repair procedures have been comprising the means to achieve prepared to cover any repairs and maintain cold shutdown required. All materials and conditions should not be equipment needed to make these damaged by fire; or the fire repairs will be maintained onsite.

damage to such equipment and systems should be limited so that the systems can be made operable and cold shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Materials for such repairs shall be readily available onsite and procedures shall be in effect to implement such repairs. If such equipment and systems used prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the fire will not be capable of being powered by 3.5-12

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE both onsite and offsite electric power systems because of fire damage, an independent onsite power system should be provided. Equipment and systems used after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be powered by offsite power only.

(6) Shutdown systems installed to Comply.

ensure postfire shutdown capability need not be designed to meet seismic Category I criteria, single failure criteria, or other design basis accident criteria, except where required for other reasons, e.g., because of interface with or impact on existing safety systems, or because of adverse valve actions due to fire damage.

(7) The safe shutdown equipment and Comply. There are no associated systems for each fire area circuits as defined in IEEE 384-1974 should be known to be isolated at B/B. Associated circuits as from associated circuits in the defined in the NRC's April 6, 1982 fire area so that hot shorts, clarification letter to Generic open circuits, or shorts to Letter 81-12 are addressed in ground in the associated Subsection 2.4.1.6.

circuits will not prevent operation of the safe shutdown equipment. The separation and barriers between trays and conduits containing associated circuits of one safe shutdown division and trays and conduits containing associated circuits or safe shutdown cables from the redundant division, or the isolation of these associated circuits from the safe shutdown equipment, should be such that a postulated fire involving associated circuits will not prevent safe shutdown.

3.5-13

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

d. Control of Combustibles (1) Safety-related systems should Comply.

be isolated or separated from combustible materials. When this is not possible because of the nature of the safety system or the combustible material, special protection should be provided to prevent a fire from defeating the safety system function. Such protection may involve a combination of automatic fire suppression, and construction capable of withstanding and containing a fire that consumes all combustibles present. Examples of such combustible materials that may not be separable from the remainder of its system are:

(a) Emergency diesel generator The emergency diesel generator fuel fuel oil day tanks. oil day tanks are provided with automatic fire suppression.

(b) Turbine-generator oil and The turbine generator oil and hydraulic control fluid hydraulic control fluid system are systems. contained in the Turbine Building and thus separated from all safety-related areas.

(c) Reactor coolant pump lube Fire Protection of the reactor oil system. coolant pump lube oil system is described in A5.7 Section III 0 and 3.7.a(1) (e).

(2) Bulk gas storage (either See Table 3-1 for delineation of compressed or cryogenic), conformance with NFPA 50A.

should not be permitted inside structures housing safety-related equipment. Storage of flammable gas such as hydrogen should be located outdoors or in separate detached buildings so that a fire or explosion will not adversely affect any safety-related systems or 3.5-14

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE equipment. Refer to NFPA 50A, Gaseous Hydrogen Systems.")

Care should be taken to locate high pressure gas storage containers with the long axis parallel to building walls.

This will minimize the possibility of wall penetration in the event of a container failure. Use of compressed gases (especially flammable and fuel gases) inside buildings should be controlled. (Refer to NFPA 6, "Industrial Fire Loss Prevention.")

(3) The use of plastic materials Comply.

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 See Table 3-1 for delineation of should, as a minimum, comply conformance with NFPA 30.

with the requirements of NFPA 30, "Flammable and Combustible Liquids Code."

3.5-15

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (5) Hydrogen lines in safety- Comply.

related areas should be either designed to seismic Class I A 1-inch diameter hydrogen pipe is requirements, or sleeved such routed from the station hydrogen that the water pipe is directly system through the Auxiliary vented to the outside, or Building to the Volume Control Tank.

should be equipped with excess This line provides a blanket of flow valves so that in case of hydrogen above the reactor coolant a line break, the hydrogen in the Volume Control Tank to aid in concentration in the affected oxygen control.

areas will not exceed 2%.

Within the auxiliary building, the hydrogen piping is Category II, except for the sections of pipe between the Volume Control Tank and the control valve which are Category I. However, the Category II portions are seismically supported throughout this building. An excess flow check valve is also provided at the bulk storage facility. The pipe routing takes this pipe through the general areas on elevation 364'-0",

383'-0", and 401'-0", and through the Unit 1 piping penetration area on elevation 364'-0". These areas are all large open areas. Because of the large size of these areas, any hydrogen flow from a line break would be stopped by the excess flow check valve well before the concentration would reach 2%.

Although these areas contain safe shutdown equipment, the hydrogen piping is separated from exposed safe shutdown equipment within these areas by the maximum distance practicable. Because of this separation and the seismic support of the piping, the hydrogen piping does not present a significant fire hazard to the safe shutdown equipment.

The Volume Control Tank Room is enclosed by shield walls. The valves used for operation of the Volume Control System are located in an adjacent valve aisle. Therefore, a fire in the Volume Control Tank 3.5-16

BYRON AMENDMENT 28 DECEMBER 2018 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Room would not disable system operation. A short loop of the hydrogen piping containing the hydrogen control valves also extends into this valve aisle. The hydrogen pipe between the control valve and the Volume Control Tank is Category I piping. The remainder of the hydrogen pipe is Category II, but additional margin is incorporated into the design of the pipe and supports to protect against failure under seismic loads.

The Unit 2 piping is a continuation of the Unit 1 system.

e. Electrical Cable Construction, Cable Trays, and Cable Penetrations (1) Only metal should be used for Comply.

cable trays. Only metallic tubing should be used for conduit. Thin-wall metallic tubing should not be used.

Flexible metallic tubing should only be used in short lengths to connect components to equipment. Other raceways should be made of noncombustible material.

(2) Redundant safety-related cable Separation of redundant safety-systems outside the cable related cable systems by 3-hour spreading room should be rated barriers is not employed separated from each other and outside of the cable spreading from potential fire exposure rooms. The cable separation hazards in nonsafety-related criteria used at Byron are described areas by fire barriers with a in Appendix 5.2. Continuous line-minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. type heat detectors are not used, as These cable trays should be they are unnecessary. The general provided with continuous line- areas containing safety-related type heat detectors and should cable trays have ionization (or be accessible for manual photoelectric) and thermal type fire firefighting. Cables should be detectors, which are effective in designed to allow wetting down detecting fires involving cable with fire suppression water materials.

without electrical faulting.

Manual hose stations and Automatic water-type area suppression is not employed on the 3.5-17

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE portable hand extinguishers cable tray system at Byron. Cables should be provided. are not considered to be the primary fire hazard in any areas of the Safety-related cable trays of a plant except the cable spreading single division that are rooms, and therefore they do not separated from redundant have specific fire suppression divisions by a fire barrier systems provided, except for the with a minimum rating of 3 cable spreading rooms. However, hours and are normally cable trays are protected by the accessible for manual detection and/or manual suppression firefighting should be equipment provided for areas where protected from the effects of a they are located.

potential exposure fire by providing automatic water Refer to Section 2.3 for detailed suppression in the area where discussion of each fire zone.

such a fire could occur.

Automatic area protection, where provided, should consider cable tray arrangements and possible transient combustibles to ensure adequate water coverage for areas that could present an exposure hazard to the cable system. Manual hose standpipe systems may be relied upon to provide the primary fire suppression (in lieu of automatic water suppression systems) for safety-related cable trays of a single division that are separated from redundant safety divisions by a fire barrier with a mini-mum rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and are normally accessible for manual firefighting if all of the following conditions are met:

(a) The number of equivalent*

standard 24-inch-wide cable trays (both safety-related and nonsafety-related) in a given fire area is six or less;

• Trays exceeding 24 inches should be counted as two trays; trays exceeding 48 inches should be counted as three trays, regardless of tray fill.

3.5-18

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (b) The cabling does not provide instrumentation, control or power to systems required to achieve and maintain hot shutdown; and (c) Smoke detectors are provided in the area of these cable routings, and continuous line-type heat detectors are provided in the cable trays.

Safety-related cable trays that are not accessible for manual firefighting should be protected by a zoned automatic water system with open-head deluge or open directional spray nozzles arranged so that adequate water coverage is provided for each cable tray.

Such cable trays should also be protected from the effects of a potential exposure fire by providing automatic water suppression in the area where such a fire could occur.

In other areas where it may not be possible because of other overriding design features necessary for reasons of nuclear safety to separate redundant safety-related cable systems by 3-hour-rated fire barriers, cable trays should be protected by an automatic water system with open-head deluge or open directional spray nozzles arranged so that adequate water coverage is provided for each cable tray. Such cable trays should also be protected from the effects of a potential exposure fire by providing automatic water suppression in the area where such a fire could occur. The capability to 3.5-19

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE achieve and maintain safe shutdown considering the effects of a fire involving fixed and potential transient combustibles should be evaluated with and without actuation of the automatic suppression system and should be justified on a suitably defined basis.

(3) Electric cable construction Cables installed in cable trays, should, as a minimum, pass the with the exception of certain flame test in the current IEEE specialty instrumentation cables, Std. 383. (This does not imply pass the IEEE 383-1974 flame test.

that cables passing this test Cables that do not pass the flame will not require fire test will be identified and any protection.) corrective action which is deemed necessary will be implemented.

(4) Cable raceways should be used Comply.

only for cables.

(5) Miscellaneous storage and Comply.

piping for flammable or combustible liquids or gases Propane storage is in a separate should not create a potential building. Welding gases and oxygen exposure hazard to safety- are stored outdoors. Individual related systems. bottles of flammable gasses used for calibration are located in the auxiliary building.

f. Ventilation (1) The products of combustion and Since all fire barrier ventilation the means by which they will be openings have fire dampers which removed from each fire area close if a fire causes room should be established during temperature to exceed a setpoint, the initial stages of plant automatic exhaust of combustion design. Consideration should products is not possible. However, be given to the installation of the means and methods to remove automatic suppression systems smoke from all safety-related plant as a means of limiting smoke areas have been established and are and end heat generation. Smoke set forth in Station procedures.

and corrosive gases should generally be discharged directly outside to an area that will not affect safety-related plant areas. The normal plant ventilation system 3.5-20

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE may be used for this purpose if capable and available. To facilitate manual firefighting, separate smoke and heat vents should be provided in specific areas such as cable spreading rooms, diesel fuel oil storage areas, switchgear rooms, and other areas where the potential exists for heavy smoke conditions (see NFPA 204 for additional guidance on smoke control).

(2) Release of smoke and gases All smoke and gases which contain containing radioactive possible radioactive material is materials to the environment monitored prior to release to the should be monitored in environment.

accordance with emergency plans as described in the guidelines For details, see FSAR Subsections of Regulatory Guide 1.101, 3.1.2.6.1, 3.1.2.6.2, 6.4.1, "Emergency Planning for Nuclear 6.4.4.1, 6.5.1, 6.5.1.1, 9.4.1.2.b, Power Plants." Any ventilation 9.4.1.3e, 9.4.1.3h, 9.4.9.1.1.6-2, system designed to exhaust 9.4.9.1.2.c, and 9.4.9.1.2e potentially radioactive smoke or gases should be evaluated to ensure that inadvertent operation or single failures will not violate the radiologically controlled areas of the plant design. This requirement includes containment functions for protecting the public and maintaining habitability for operations personnel.

(3) Special protection for Power supply and controls for ventilation power and control mechanical ventilation equipment are cables may be required. The not necessarily routed outside of power supply and controls for fire zones served by the system.

mechanical ventilation systems Most ventilation equipment is should be run outside the fire located within the fire hazard area, area served by the system where thereby requiring electrical cable practical. to be routed accordingly. However, such cabling is in conduit. To relocate the vent equipment outside the fire hazard area would be impractical. For details, see FSAR 3.5-21

BYRON AMENDMENT 25 DECEMBER 2012 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Subsections 4.4.4, 9.4.1.1.g, and 9.4.1.3a.

(4) Engineered safety feature Comply. For details, see FSAR filters should be protected in Subsection 6.5.1.2.1.d-5 and Fire accordance with the guidelines Protection Report Subsection of Regulatory Guide 1.52. Any 2.3.3.14.

filter that includes combustible materials and is a potential exposure fire hazard that may affect safety-related components should be protected as determined by the fire hazards analysis.

(5) The fresh air supply intakes to Comply. For details, see FSAR areas containing safety-related Subsection 9.4.1.1.1e and Figure equipment or systems should be 6.4-1.

located remote from the exhaust air outlets and smoke vents of other fire areas to minimize the possibility of contam-inating the intake air with the products of combustion.

(6) Stairwells should be designed Comply, see part 6 of Subsection to minimize smoke infiltration 3.5a.

during a fire.

(7) Where total flooding gas See Table 3-1 for delineation of extinguishing systems are used, conformance to NFPA 12 and NFPA 12A.

area intake and exhaust ventilation dampers should be For details, see Fire Protection controlled in accordance with Report Subsections 2.3.3.6, 2.3.3.7, NFPA 12, "Carbon Dioxide 2.3.3.8, 2.3.3.9, 2.3.3.10 and 11, Systems," and NFPA 12A, "Halon 2.3.3.14, 2.3.3.16, 2.3.3.18, and 1301 Systems, to maintain the 2.3.3.20.

necessary gas concentration.

g. Lighting and Communication Lighting and two-way voice communication are vital to safe shutdown and emergency response in the event of fire. Suitable fixed and portable emergency lighting and communication devices should be provided as follows:

3.5-22

BYRON AMENDMENT 29 DECEMBER 2020 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (1) Fixed self-contained lighting Comply. Fixed self-contained consisting of fluorescent or lighting will be provided in all sealed-beam units with areas where manual operation is individual 8-hour minimum assumed in the safe shutdown battery power supplies should analysis in Section 2.4.

be provided in areas that must be manned for safe shutdown and See FPR Section A.5.7.III.5.

for access and egress routes to and from all fire areas. Safe shutdown areas include those required to be manned if the control room must be evacuated.

(2) Suitable sealed-beam battery- Comply. Portable lights are powered portable hand lights provided for emergency use by the should be provided for fire brigade and other operations emergency use by the fire personnel.

brigade and other operations personnel required to achieve safe plant shutdown.

(3) Fixed emergency communications Comply. A plant pager system is installed at independent of the normal plant locations shown on prints 6/20E-0-3789 and communication system should be 3789A. Power is supplied from MCC 131X2 installed at preselected (1AP25E) and 231X2 (2AP25E).

stations.

(4) A portable radio communications Comply. Four repeaters are provided system should be provided for at the Byron station. The repeaters use by the fire brigade and are located in the Operations Task other operations personnel Read Room (OTRR) on elevation 451 required to achieve safe plant in the Turbine Building along with shutdown. This system should column row L. The repeaters connect not interfere with the with the station Distributed Antenna communications capabilities of System (DAS) above the OTRR on the plant security force. Elevation 468 in the Turbine Fixed repeaters installed to Building along column row L. A permit use of portable radio single credible fire at either communication units should be location could disable all protected from exposure fire repeaters. However, the remaining damage. Preoperational and base stations and hand-held radios periodic testing should would remain operable for the fire demonstrate that the brigade, other operations personnel, frequencies used for portable and security to mitigate the radio communication will not consequences of such a fire and to affect the actuation of achieve safe plant shutdown.

protective relays. Testing has demonstrated that coverage of the plant by the 3.5-23

BYRON AMENDMENT 18 DECEMBER 1998 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE remaining radio system components in the event of such a fire is adequate.

Separate radio talk groups for normal radio system operation and and independent frequency for abnormal operations are available for use by the fire brigade and other operations personnel required to achieve safe plant shutdown.

Security has its own talk group for normal operation and its own frequency for abnormal operations.

Preoperational testing has demonstrated that the frequencies used for portable radio communications do not affect the actuation of protective relays nor the transmitters that input to a relay that actuate a reactor trip for an engineered safety feature.

In the latter case, the areas surrounding the transmitters have been labeled with appropriate warning messages. Further, portable radio transmissions are not allowed in the auxiliary electric equipment room and other designated areas.

These actions have been taken in lieu of periodic testing.

3.5-24

BYRON AMENDMENT 20 DECEMBER 2002 3.6 FIRE DETECTION AND SUPPRESSION IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

a. Fire Detection Protection (1) Detection systems should be Comply with exceptions. See Table provided for all areas that 2.2-3.

contain or present a fire exposure to safety-related equipment.

(2) Fire detection systems should Comply, see Appendix 5.4.

comply with the requirements of Class A systems as defined in See Table 3-1 for delineation of NFPA 72D, "Standard for the conformance to NFPA 72D.

Installation, Maintenance, and Use of Proprietary Protective Signaling Systems," and Class 1 circuits as defined in NFPA 70, "National Electrical Code."

(3) Fire detectors should be Comply. Line type heat detectors selected and installed in are not used, in general, at B/B accordance with NFPA 72E, except in most charcoal filters and "Automatic Fire Detectors." all outdoor transformers.

Preoperational and periodic testing of pulsed line-type See Table 3-1 for delineation of heat detectors should conformance to NFPA 72E.

demonstrate that the frequencies used will not affect the actuation of protective relays in other plant systems.

(4) Fire detection systems should The fire detection system will give give audible and visual alarm audible and visual alarm and and annunciation in the control annunciation in the control room.

room. Where zoned detection Local alarms are provided for areas systems are used in a given with fixed suppression systems.

fire area, local means should be provided to identify which detector zone has actuated.

Local audible alarms should sound in the fire area.

(5) Fire alarms should be Comply.

distinctive and unique so they will not be confused with any other plant system alarms.

3.6-1

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (6) Primary and secondary power The fire detection system is powered supplies should be provided for from an ESF bus.

the fire detection system and for electrically operated See Table 3-1 for delineation of control valves for automatic conformance to NFPA 72D.

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 <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of loss of offsite power.

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

b. Fire Protection Water Supply Systems (1) An underground yard fire main See Table 3-1 for delineation of loop should be installed to conformance to NFPA 24.

furnish anticipated water requirements. NFPA 24, "Standard for Outside Protection" gives necessary guidance for such installation.

It references other design codes and standards developed by such 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.

3.6-2

BYRON AMENDMENT 19 DECEMBER 2000 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (2) Approved visually indicating Comply.

sectional control valves such as post-indicator valves should be provided to isolate portions of the main for maintenance or repair without shutting off the supply to primary and backup fire suppression systems serving areas that contain or expose safety-related equipment.

(3) Valves should be installed to Comply.

permit isolation of outside hydrants from the fire main for maintenance or repair without interrupting the water supply to automatic or manual fire suppression systems in any area containing or presenting a fire hazard to safety-related or safe shutdown equipment.

(4) The fire main system piping Comply, except for connections to should be separate from service service water system, demineralized or sanitary water system water system, the service air piping, except as described in compressor, and temporary cross-tie Position C.5.c.(4). capabilities to the centrifugal charging pump oil coolers.

(5) A common yard fire main loop Comply. Byron has only one loop in may serve multiunit nuclear the auxiliary building which serves power plant sites if cross- both units.

connected between units.

Sectional control valves should permit maintaining independence of the individual loop around each unit. For such installations, common water supplies may also be utilized.

For multiple-reactor sites with widely separated plants (approaching 1 mile or more),

separate yard fire main loops should be used.

3.6-3

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (6) If pumps are required to meet Comply.

system pressure or flow requirements, a sufficient number 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 <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

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.

3.6-4

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE The fire pump installation See Table 3-1 for delineation of should conform to NFPA 20, conformance with NFPA 20.

"Standard for the Installation of Centrifugal Fire Pumps."

(7) Outside manual hose See Table 3-1 for delineation of installation should be conformance with NFPA 24.

sufficient to provide an effective hose stream to any onsite location where fixed or transient combustibles could jeopardize safety-related equipment. Hydrants should be installed approximately every 250 feet on the yard main system. A hose house equipped with hose and combination nozzle and other auxiliary equipment recommended in NFPA 24, "Outside Protection,"

should be provided as needed, but at least every 1,000 ft.

Alternatively, mobile means of providing hose and associated equipment, such as hose carts or trucks, may be used. When provided, such mobile equipment should be equivalent to the equipment supplied by three hose houses.

(8) Threads compatible with those Comply.

used by local fire departments should be provided on all hydrants, hose couplings, and standpipe risers.

(9) Two separate, reliable Not applicable.

freshwater supplies should be provided. Saltwater or brackish water should not be used unless all freshwater supplies have been exhausted.

If tanks are used, two 100%

(minimum of 300,000 gallons each) system capacity tanks should be installed. They should be so interconnected that pumps can take suction 3.6-5

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE from either or both. However, a failure in one tank or its piping should not cause both tanks to drain. Water supply capacity should be capable of refilling either tank in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or less.

(10) Common tanks are permitted for Not applicable.

fire and sanitary or service water storage. When this is done, however, minimum fire water storage requirements should be dedicated by passive means, for example, use of a vertical standpipe for other water services. Administrative controls, including locks for tank outlet valves, are unacceptable as the only means to ensure minimum water volume.

(11) The fire water supply should be Comply.

calculated on the basis of the largest expected flow rate for The original calculations on the a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, but not fire protection system were based on less than 300,000 gallons. a line break that creates the This flow rate should be based greatest friction loss in the system (conservatively) on 500 gpm for per NEIL requirements. This has the manual hose streams plus the same effect as delivering water over largest design demand of any the longest route even though the sprinkler or deluge system as longest route was not considered in determined in accordance with the calculation. It would take four NFPA 13 or NFPA 15. The fire line breaks to restrict the flow to water supply should be capable only the longest route.

of delivering this design demand over the longest route See Table 3-1 for delineation of of the water supply system. conformance to NFPA 13 and NFPA 15.

(12) Freshwater lakes or ponds of Comply. At Byron, the natural draft sufficient size may qualify as cooling tower basin serves as the sole source of water for fire sole source of water for fire protection but require separate protection. As described in a redundant suctions in one or January 6, 1983 letter from T. R.

more intake structures. These Tramm to H. R. Denton responding to supplies should be separated so a CMEB request, the required volume that a failure of one supply of fire protection water will always will not result in a failure of be available from this source.

the other supply.

3.6-6

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (13) When a common water supply is Comply. This is not applicable to permitted for fire protection Byron since different sources of and the ultimate heat sink, the water are utilized for the ultimate following conditions should heat sink and fire protection.

also be satisfied:

(a) The additional fire protection water requirements are designed into the total storage capacity, and (b) Failure of the fire protection system should not degrade the function of the ultimate heat sink.

(14) Other water systems that may be Service Water and Essential Service used as one of the two fire Water tie-ins are manual; however, water supplies should be these are not designed to be permanently connected to the redundant to the fire water pumps.

fire main system and should be capable of automatic alignment to the fire main system.

Pumps, controls, and power supplies in these systems should satisfy the requirements for the main fire pumps. The use of other water systems for fire protection should not be incompatible with their functions required for safe plant shutdown. Failure of the other system should not degrade the fire main system.

c. Water Sprinkler and Hose Standpipe (1) Sprinkler systems and manual See paragraph 3.1c(2).

hose station standpipes should have connections to the plant underground water main so that a single active failure or a crack in a moderate-energy line cannot impair both the primary and backup fire suppression systems. Alternatively, headers fed from each end are permitted inside buildings to 3.6-7

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE supply both sprinkler and standpipe systems, provided steel piping and fittings meeting the requirements of ANSI B31.1, "Power Piping," are used for the headers up to and including the first valve supplying the sprinkler systems where such headers are part of the seismically analyzed hose standpipe system. When provided, such headers are considered an extension of the yard main system. Each sprinkler and standpipe system should be equipped with OS&Y (outside 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.

(2) Control and sectionalizing Electrical supervision is generally valves in the fire water provided for valves controlling systems should be electrically individual, fixed extinguishing supervised or administratively systems. These valves alarm in the controlled. The electrical control room. Although interior and supervision signal should exterior sectional control valves indicate in the control room. are not electrically supervised, All valves in the fire their positions are administratively protection system should be controlled by station operating periodically checked to verify procedures.

position (see NFPA 26, "Supervision of Valves"). See Table 3-1 for delineation of conformance to NFPA 26.

(3) Fixed water extinguishing systems should conform to See Table 3-1 for delineation of requirements of appropriate conformance to NFPA 13 and NFPA 15.

standards such as NFPA 13, "Standards for the Installation of Sprinkler Systems," and NFPA 15, "Standard for Water Spray Fixed Systems."

3.6-8

BYRON AMENDMENT 29 DECEMBER 2020 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (4) Interior manual hose Hose stations are generally located installation should be able to outside of unoccupied areas.

reach any location that Shutoff valves are provided for all contains, or could present a standpipes or sections of interior fire exposure hazard to, piping. Generally, these standpipe safety-related equipment with hose stations are located throughout at least one effective hose the plant at approximately 100-foot stream. To accomplish this, intervals on each floor.

standpipes with hose connections equipped with a Most of the hoses and associated hose reels have maximum of 100 feet of 1-1/2- been removed per EC 626870 as the fire brigade inch woven-jacket, lined for utilizes high-rise hose packs transported to the hose and suitable nozzles scene.

should be at least 4 inches in diameter for multiple hose The standpipes used have a varying diameter of connections and 2-1/2 inches in 2-1/2 inches to 4 inches. Portions of the Fire diameter for single hose Protection System that service safety-related connections. These systems equipment or run through areas where safety-should follow the requirements related equipment is housed use Seismic Category of NFPA 14, "Standpipe and Hose I piping. The majority of the Fire Protection Systems," for sizing, spacing, System previously classified as Safety Category I, and pipe support requirements. Quality Group C has been reclassified as Safety Category II, Quality Group D (Ref. EC 626662);

Hose stations should be located and remains classified as Seismic Category I.

as dictated by the fire hazard analysis to facilitate access and use for firefighting operations. Alternative hose Hose stations at the River Screen stations should be provided for House have been abandoned. These an area if the fire hazard stations are not needed as a means could block access to a single of backup fire suppression.

hose station serving that area. (Reference EC #351113).

Provisions should be made to See Table 3-1 for delineation of supply water at least to conformance to NFPA 14.

standpipes and hose connections for manual firefighting 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 3.6-9

BYRON AMENDMENT 29 DECEMBER 2020 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE 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 (ap-proximately 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.

(5) The proper type of hose nozzle to be supplied to each area should be based on the fire The proper type of hose nozzle is brought to scene hazard analysis. The usual and utilized by the fire brigade based on the type of combination spray/straight- fire and surrounding environment. Straight stream stream nozzle should not be nozzles are supplied to areas of new fuel storage.

used in areas where the straight stream can cause unacceptable mechanical damage.

Fixed fog nozzles should be provided at locations where high-voltage shock hazards exist. All hose nozzles should have shutoff capability.

(Guidance on safe distances for water application to live electrical equipment may be found in the "NFPA Fire Protection Handbook.")

3.6-10

BYRON AMENDMENT 19 DECEMBER 2000 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (6) Fire hose should be Comply by satisfying the hydrostatically tested in recommendations of NFPA 1962.

accordance with the recommendations of NFPA 1962, "Fire Hose - Care, Use, Maintenance." Hose stored in outside hose houses should be tested annually. Interior standpipe hose should be tested every 3 years.

(7) Certain fires, such as those See Table 3-1 for delineation of involving flammable liquids, conformance with NFPA 11 and NFPA respond well to foam sup- 16. NFPA 11A and 11B are not pression. Consideration should applicable.

be given to use of mechanical low-expansion foam systems, high-expansion foam gener-ators, or aqueous film-forming foam (AFFF) systems, including the AFFF deluge system. These systems should comply with the requirements of NFPA 11, NFPA 11A, NFPA 11B, and NFPA 16, as applicable.

d. Halon Suppression Systems Halon fire extinguishing Comply, except as noted below.

systems should comply with the requirements on NFPA 12A and See Table 3-1 for delineation of NFPA 12B, "Halogenated Fire conformance with NFPA 12A.

Extinguishing Agent Systems -

Halon 1301 and Halon 1211." Interlock and alarms are tested Only UL-listed or FM-approved initially by technical staff. The agents should be used. halon is bought listed with a Provisions for locally Certification of Conformance.

disarming automatic Halon systems should be key locked The control panels will be locked and under strict administrative with the keys controlled by control. Automatic Halon operating.

extinguishing systems should not be disarmed unless controls The disarming of the system will as described in Position C.2.c. alarm in the control room.

are provided.

3.6-11

BYRON AMENDMENT 21 DECEMBER 2004 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE In addition to the guidelines Testing of halon cylinders will be of NFPA 12A and 12B, preventive performed semiannually, as allowed maintenance and testing of the by NFPA 12A Section 1-11.1.6.

systems, including check-weighing of the Halon Pre-discharge alarms are provided cylinders, should be done at locally, except for the Halon system least quarterly. protecting the QA Records Vault.

Pre-discharge timers delay the discharge to allow personnel time to leave the area. The Halon systems for the Upper Cable Spreading Rooms also alarm in the control room.

Particular consideration should Concentration testing is done by the also be given to: vendor. They verify hold time and ventilation openings are controlled (1) Minimum required Halon by fire dampers held by electro-concentration, thermal links.

distribution, soak time, and ventilation control; There are only ventilation ducts and cables in the area. Neither is (2) Toxicity of Halon; likely to experience serious corrosive damage. The rooms will be (3) Toxicity and corrosive vented per the prefire plans.

characteristics of the thermal decomposition The halon test results obtained from products of Halon; and the Byron site testing indicate concentrations in the upper cable (4) Location and selection of spreading room over 6%. These rooms the activating detectors. are not normally occupied.

3.6-12

BYRON AMENDMENT 21 DECEMBER 2004

e. Carbon Dioxide Suppression Systems Carbon dioxide extinguishing Comply.

systems should comply with the requirements of NFPA 12, Byron has an evacuation time with "Carbon Dioxide Extinguishing alarm on CO2 systems. Local Systems." Where automatic disarming will be electrically carbon dioxide systems are supervised and controlled by used, they should be equipped Operating. Disarming the system with a predischarge alarm will alarm in the control room.

system and a discharge delay to Normally open valves will be permit personnel egress. verified every 92 days for position.

Provisions for locally disarming automatic carbon See Table 3-1 for delineation of dioxide systems should be key conformance with NFPA 12.

locked and under strict administrative control.

Automatic carbon dioxide extinguishing systems should not be disarmed unless controls as described in Position C.2.c.

are provided.

3.6-12a

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Particular consideration should also be given to:

(1) Minimum required CO2 Concentration and hold times are concentration, verified by a vendor test during the distribution, soak time, construction phase. Ventilation is and ventilation control; controlled by fire dampers with electrothermal links.

(2) Anoxia and toxicity of CO2; In addition to a pre-discharge alarm for personnel protection, an (3) Possibility of secondary odorizer has been added to the CO2 thermal shock (cooling) systems, which adds a wintergreen damage; odor to the CO2.

(4) Conflicting requirements for venting during CO2 injection to prevent overpressurization versus sealing to prevent loss of agent; and (5) Location and selection of the activating detectors.

f. Portable Extinguishers Fire extinguishers should be See Table 3-1 for delineation of provided in areas that contain, conformance with NFPA 10.

or could present a fire exposure hazard to, safety-related equipment in accordance with guidelines of NFPA 10, "Portable Fire Extinguishers, Installation, Maintenance and Use." Dry chemical extinguishers should be installed with due consideration given to possible adverse effects on safety-related equipment installed in the area.

3.6-13

BYRON AMENDMENT 2

DECEMBER 20

3.7 GUIDELINES FOR SPECIFIC PLANT AREAS IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

a. Primary and Secondary Containment (1) Normal Operation - Fire Byron complies except as identified protection requirements for the below.

primary and secondary containment areas should be provided for hazards identified by the fire hazards analysis.

Examples of such hazards Fixed automatic suppression is not include lubricating oil or provided. Hose stations and hydraulic fluid system for the portable extinguishers are available primary coolant pumps, cable throughout the containment.

tray arrangements and cable Ionization (or photoelectric) penetrations, and charcoal detectors provide local coverage filters. Because of the over cable penetrations. Heat general inaccessibility of detectors are provided over the primary containment during reactor coolant pumps. The charcoal normal plant operation, filter units within containment are protection should be provided provided with manual deluge systems.

by automatic fixed systems. Temperature switches provide The effects of postulated fires detection alarms to the control room within the primary containment for the charcoal units.

should be evaluated to ensure that the integrity of the Note: The charcoal is removed and primary coolant system and the deluge piping isolated containment is not jeopardized assuming no action is taken to fight the fire.

(a) Operation of the fire Comply. Manual hose stations are protection systems should relied upon for primary suppression not compromise the integ- inside the containment. Safety-rity of the containment or related equipment inside the other safety-related containment is qualified for a post-systems. Fire protection LOCA environment, including water activities in the contain- spray. Firefighting activities are ment areas should function thus not expected to adversely in conjunction with total affect safe shutdown components or containment requirements the containment integrity.

such as ventilation and control of contaminated liquid and gaseous release.

3.7-1

BYRON AMENDMENT 2

DECEMBER 20

IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE (b) Inside noninerted Division 11 and 12 cable come in containment one of the close proximity. Descriptions of fire protection means such occurrences and justification stated in Positions are provided in Appendix A5.7.

C.5.b.1 and C.5.b.2 or the following fire protection means should be provided:

separation of cables and equipment and associated nonsafety circuits of redundant trains by a noncombustible radiant energy shield having a minimum fire rating of one-half hour.

(c) In primary containment, Fire detection systems are provided fire detection systems over reactor coolant pumps, should be provided for electrical penetrations, and in the each fire hazard. The charcoal absorber banks. A general type of detection used and area fire detection system is not the location of the employed in the containment at detectors should be the Byron.

most suitable for the particular type of fire Note: The Charcoal is removed and hazard identified by the deluge pipe isolated, but the fire fire hazard analysis. detection system remains functional A general area fire detection capability should be provided in the primary containment as backup for the above described hazard detection. To accomplish this, suitable smoke or heat detectors compatible with the radiation environment should be installed.

(d) Standpipe and hose Comply. Standpipes and hose stations should be inside stations are provided inside the PWR containments and BWR containment. The normal fire containments that are not protection system water supply is inerted. Standpipe and used. The containment penetrations hose stations inside comply with the stated requirements.

containment may be connected to a high quality water supply of 3.7-2

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE sufficient quantity and pressure other than the fire main loop if plant-specific features prevent extending the fire main supply inside containment.

For BWR drywells, standpipe and hose stations should be placed outside the drywell with adequate lengths of hose, no longer than 100 feet, to reach any location inside the drywell with an effective hose stream.

The containment pene-tration of the standpipe system should meet the isolation requirements of General Design Criterion 56 and should be seismic Category I and Quality Group B.

(e) The reactor coolant pumps Comply. Refer to Section III.0 of should be equipped with an Appendix A5.7.

oil collection system if the containment is not inerted during normal operation. The oil collection system should be so designed, engineered, and installed that failure will not lead to fire during normal or design basis accident conditions and that there is reasonable assurance that the system will withstand the safe shutdown earthquake.

Such collection systems should be capable of collecting lube oil from all potential pressurized and unpressurized leakage sites in the reactor coolant pump lube oil 3.7-3

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE systems. Leakage should be collected and drained to a vented closed container that can hold the entire lube oil system inventory. A flame arrester is required in the vent if the flash point 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 accommodate the largest potential oil leak.

(f) For secondary containment Byron does not have a secondary areas, cable fire hazards containment area.

that could affect safety should be protected as described in Position C.5.e(2). The type of detection system for other fire hazards identified by the fire hazards analysis should be the most suitable for the particular type of fire hazard.

(2) Refueling and Maintenance - Comply.

Refueling and maintenance operations in containment may Administrative procedures ensure introduce additional hazards adequate fire protection for such as contamination control transient fire loads.

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

3.7-4

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Possible fires would not necessarily be in the vicinity of fixed detection and suppression systems.

Management procedures and controls necessary to ensure adequate fire protection for transient fire loads are discussed in Position C.1.

Adequate self-contained Two self-contained breathing units breathing apparatus should be are provided at each entrance to the provided near the containment containment and at selected entrances for firefighting and locations in the containment. These damage control personnel. air packs will provide the necessary These units should be air for firefighting and damage independent of any breathing control personnel. These units are apparatus or air supply systems independent from the station's provided for general plant supplied air system.

activities and should be clearly marked as emergency equipment.

b. Control Room Complex The control room complex The walls, floor, and roof are 3 (including galleys, office hour fire barriers as shown in Fire spaces, etc.) should be Protection Report Figures 2.3-7 and protected against disabling 2.3-8 Sheets 1 and 3.

fire damage and should be separated from other areas of Neither automatic fixed suppression the plant by floors, walls, and systems nor smoke dampers are roof having minimum fire provided for peripheral rooms (i.e.,

resistance ratings of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. offices) in the control room Peripheral rooms in the control complex.

room complex should have automatic water suppression and For details see FSAR Subsections should be separated from the 6.4.2.3, 6.4.2.4, and Fire control room by noncombustible Protection Report Subsection construction with a fire 2.3.2.1.

resistance rating of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

Ventilation system openings Control room fire dampers are held between the control room and by thermal links not hooked to the peripheral rooms should have detectors.

automatic smoke dampers that close on operation of the fire Portable fire extinguishers in the detection or suppression control room will carry either a 3A-system. If a halon flooding 80 B:C or a 10 B:C rating. A hose system is used for fire station will be available near the suppression, these dampers entrance to the control room.

3.7-5

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE should be strong enough to support the pressure rise accompanying halon discharge and seal tightly against infiltration of halon into the control room. Carbon dioxide flooding systems are not acceptable for these areas.

Manual firefighting capability The approximate locations of should be provided for both: extinguishers and hoses are shown on Fire Protection Report Figures 2.3-8 Sheets 1 and 3.

(1) Fire originating within a cabinet, console, or connecting cables; and (2) Exposure fires involving combustibles in the general room area.

Portable Class A and Class C fire extinguishers should be located in the control room. A hose station should be installed immediately outside the control room.

Nozzles that are compatible Comply.

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

Smoke detectors should be Do not comply fully. Smoke provided in the control room, detectors are installed in the vents cabinets, and consoles. If of the cabinets. Detectors are redundant safe shutdown installed at the ceiling.

equipment is located in the Additional protection is not same control room cabinet or provided. Fire Hazards panel console, additional fire provides an additional location for protection measures should be indication where separation was not provided. Alarm and local met. Ceiling detectors alarm on 3.7-6

BYRON AMENDMENT 28 DECEMBER 2018 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE indication should be provided 1PM09J, and the duct detectors in the control room. alarm on OPM02J and the SER.

Additionally, fire protection features are not provided for panels containing redundant safe shutdown equipment; however, this equipment is addressed in Section 2.4.

Breathing apparatus for control Comply.

room operators should be readily available. S.C.B.A. is provided for the control room emergency personnel. Seven units plus two extra units for single failure criteria will be provided.

For details see FSAR Subsection 6.4.1.f.

The outside air intake(s) for Comply in terms of providing the control room ventilation ionization (or photoelectric) system should be provided with detectors at outside air intakes, as smoke detection capability to well as isolating the intakes on alarm in the control room to ionization detection with provision enable manual isolation of the to use alternate intakes for makeup control room ventilation system air. In addition, all the air is and thus prevent smoke from passed through recirculation entering the control room. charcoal filters.

The detectors alarm at OPM02J and the SER. The manual damper controls are on OPM02J.

For details see FSAR Subsections 9.4.1.2b and 9.4.1.1.1e, and 6.4.1h.

Venting of smoke produced by Comply.

fire in the control room by means of the normal ventilation The manual controls for air intake system is acceptable; however, are on OPM02J.

provision should be made to permit isolation of the For details see FSAR Subsection recirculating portion of the 9.4.1.3d and Fire Protection Report normal ventilation system. Subsection 2.3.2.1.

Manually operated venting of the control room should be available to the operators.

3.7-7

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE All cables that enter the Comply.

control room should terminate in the control room. That is, All cables that enter the control no cabling should be routed room terminate in the control room.

through the control room from one area to another. Cables in The ESF Division 11 cables enter underfloor and ceiling spaces from the ceiling and ESF Division 12 should meet the separation cables enter from the floor. Cable criteria necessary for fire separation is defined in IEEE protection. Standard 384-1974 and NRC Regulatory Guide 1.75.

Air-handling functions should Comply, except as explained below.

be ducted separately from cable runs in such spaces; i.e., if Ceiling and floor are not used as a cables are routed in underfloor plenum. Ducts are not used for or ceiling spaces, these spaces cable runs.

should not be used as air plenums for ventilation of the There are no electrical cable trays control room. Fully enclosed located under floor and ceiling electrical raceways located in spaces. This is currently also true such underfloor and ceiling for the raised floor in the Byron spaces, if over 1 square foot computer room, which is part of the in cross-sectional area, should control room complex. There are have automatic fire suppression some conduits above the dropped inside. Area automatic fire ceiling.

suppression should be provided for underfloor and ceiling Upper cable spreading room has spaces if used for cable runs automatic halon and lower cable unless all cable is run in 4- spreading room has automatic CO2.

inch or smaller steel conduit Upper cable spreading room has a or the cables are in fully manual CO2 system as a backup.

enclosed raceways internally protected by automatic fire suppression.

There should be no carpeting in Carpeting in the main control room the control room. has a Class 1 rating.

c. Cable Spreading Room The primary fire suppression in Comply, except as explained below:

the cable spreading room should be an automatic water system The Byron design includes several such as closed-head sprinklers, cable spreading rooms at elevation open-head deluge system, or 439'-0" and 463'-4-1/2". The rooms open directional water spray are designed such that redundant system. Deluge and open spray safe shutdown cabling is routed systems should have provisions through separate rooms (except as for manual operation at a noted in Section 2.4.2) and isolated by 3-hour fire barriers. The upper cable spreading rooms are protected 3.7-8

BYRON AMENDMENT 28 DECEMBER 2018 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE remote station; however, there by an automatic Halon 1301 system should be provisions to with a manual CO2 backup system.

preclude inadvertent operation. Manual hose stations and portable Location of sprinkler heads or extinguishers provide additional spray nozzles should consider backup. The lower cable spreading cable tray arrangements and areas are protected by an automatic possible transient combustibles CO2 System. Backup is provided by to ensure adequate water manual hose stations and portable coverage for areas that could extinguishers. The Halon and CO2 present exposure hazards to the systems as installed at Byron meet cable system. Cables should be the requirements of the governing designed to allow wetting down NFPA codes 12 and 12A.

with water supplied by the fire suppression system without electrical faulting.

Open-head deluge and open Cable spreading rooms 3.3B-1 and directional spray system should 3.3B-2 have only one access door.

be zoned. The BTP position is that an automatic water suppression system The use of foam is acceptable. should be installed in the cable spreading rooms. The Byron system Cable spreading rooms should provides adequate fire protection in have: the cable spreading rooms without an automatic water system. Hose (1) At least two remote and stations are available for use in separate entrances for the cable spreading rooms if access by fire brigade required.

personnel; (2) An aisle separation An automatic water suppression between tray stacks at system was not installed in the least 3 feet wide and 8 cable rooms because of concerns feet high; about the probability and effects of inadvertent actuations. The thermal (3) Hose stations and portable elements in the Fenwall rate extinguishers installed compensated heat detectors are very immediately outside the similar to the thermal elements in room; the automatic water suppression systems. Since a cable fire would (4) Area smoke detection; and generate large quantities of smoke in a very early stage of a fire, the (5) Continuous line-type heat ionization (or photoelectric) detectors for cable trays detectors would be very effective in inside the cable spreading detecting small cable fires and room. annunciating in the Control Room.

If the fire was of such magnitude Drains to remove firefighting that the thermal detectors sensed water should be provided. When the fire, the actuation of the fire gas systems are installed, suppression system would then be initiated. The 3.7-9

BYRON AMENDMENT 28 DECEMBER 2018 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE drains should have adequate detector circuits are designed that seals or the gas extinguishing if either of the redundant detection systems should be sized to zones failed, the remaining compensate for losses through detection zone could then solely the drains. initiate the automatic suppression system. For this application the A separate cable spreading room cross-zoning of rate compensated should be provided for each heat detectors with ionization (or redundant division. Cable photoelectric) detectors would not spreading rooms should not be reduce the responsiveness of a fire shared between reactors. Each detection system compared to a cable spreading room should be closed head sprinkler system. A separated from the others and deluge system which indiscriminately from other areas of the plant sprays a large area will result in a by barriers with a minimum fire significant effort to restore the rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. If this is cable spreading room to normal not possible, a dedicated conditions and could potentially system should be provided. cause other problems if water leaks into adjacent areas such as the The ventilation system to each control room which is below the cable spreading room should be upper cable spreading room, or the designed to isolate the area ESF switchgear room which is below upon actuation of any gas the lower cable spreading room.

extinguishing system in the Inadvertent actuation of a Halon or area. Separate manually CO2 system would have no adverse actuated smoke venting that is effects.

operable from outside the room should be provided for the The probability of a fire in a cable cable spreading room. spreading room is quite low. The main combustible material is cable insulation. The cables are covered with EPR or EPDM insulation with hypalon jackets. The cables have passed IEEE 383-1974 flame tests.

In the event of a fire in a cable spreading room, spread of the fire would be prevented by 3-hour fire barriers. Disabling of one full cable spreading room would not prevent safe shutdown of the plant due to the redundancy and separation criteria used in design. The fire barrier construction ensures a long residence time in the event of a Halon or CO2 discharge.

In the unlikely event that water is required to quench hot areas after a fire, manual application of water using the nearby hose stations will 3.7-10

BYRON AMENDMENT 20 DECEMBER 2002 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE provide localized control without the effects to the general area which could result from actuation of a deluge system. As shown in the Byron Fire Protection Report, hose stations are located in each compartment of the upper and lower cable spreading areas. Hose stations are located adjacent to each doorway so that application of water is available.

In summary, the Byron cable spreading area fire protection system design ensures that fire will not compromise plant safety. Use of automatic halon or CO2 systems instead of water deluge reduces the probability of a plant shutdown or equipment damage in the event of a spurious actuation. Additionally, the area is well supplied with manual hose stations and portable hand extinguishers.

d. Plant Computer Rooms Computer rooms for computers The process computer at Byron is performing safety-related non-safety-related and is part of functions that are not part of the control room complex. Automatic the control room complex should fixed suppression is not provided.

be separated from other areas Fire protection features which are of the plant by barriers having provided are described in Subsection a minimum fire resistance 2.3.4 of this report.

rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and should be protected by automatic detection and fixed automatic suppression. Computers that are part of the control room complex but not in the control room should be separated and protected as described in Position C.7.b. Computer cabinets located in the control room should be protected as other control room equipment and cable runs therein. Non-safety-related computers outside the control room complex should be separated 3.7-11

BYRON AMENDMENT 26 DECEMBER 2014 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE from safety-related areas by fire barriers with a minimum rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and should be protected as needed to prevent fire and smoke damage to safety-related equipment.

e. Switchgear Rooms Switchgear rooms containing Comply, except as noted below:

safety-related equipment should be separated from the remainder Alarms do not annunciate locally.

of the plant by barriers with a minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Doors in the L-line on El. 426-0 Redundant switchgear safety that separate the Switchgear Rooms divisions should be separated and adjacent turbine building fire from each other by barriers zones are non-labeled fire doors.

with a 3-hour fire rating. The subject doors are addressed in Automatic fire detectors should Generic Letter 86-10 Evaluation EC-alarm and annunciate in the EVAL 392628; this evaluation control room and alarm locally. determined that the doors are Cables entering the switchgear adequate for the fire hazards to room that do not terminate or which they are exposed and justifies perform a function there should the use of each non-labeled fire be kept at a minimum to door. Refer to EC 391812 and EC-EVAL minimize the combustible 392627.

loading. These rooms should not be used for any other purpose. Fire hose stations and portable fire extinguishers should be readily available outside the area.

Equipment should be located to See Table 3-1 for discussion of facilitate access for manual conformance with NFPA 92M.

firefighting. Drains should be provided to prevent water accumulation from damaging safety-related equipment (see NFPA 92M, "Waterproofing and Draining of Floors"). Remote manually actuated ventilation should be provided for venting smoke when manual fire suppression effort is needed (see Position C.5.f).

3.7-12

BYRON AMENDMENT 22 DECEMBER 2006 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

f. Remote Safety-Related Panels Redundant safety-related panels Comply, except as noted below:

remote from the control room complex should be separated The remote shutdown panels can be from each other by barriers electrically isolated from control having a minimum fire rating of room equipment by transfer switches 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Panels providing located on the panels. For control remote shutdown capability room evacuation or damage, this should be separated from the isolates the remote shutdown panels control room complex by from the control room, but also barriers having a minimum fire renders the control room panels rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Panels inoperable. The remote shutdown providing remote shutdown panels are not separated from each capability should be other by 3-hour rated barriers. The electrically isolated from the automatic detectors provided for the control room complex so that a remote shutdown control room do not fire in either area will not alarm locally.

affect shutdown capability from the other area. The general Alternate shutdown is provided for a area housing remote safety- fire in the remote shutdown control related panels should be room by operating equipment from the provided with automatic fire switchgear rooms and locally. This detectors that alarm locally is covered by Byron abnormal and alarm and annunciate in the operating procedures.

control room. Combustible materials should be controlled and limited to those required for operation. Portable extinguishers and manual hose stations should be readily available in the general area.

g. Safety-Related Battery Rooms Safety-related battery rooms Comply, with exception noted below:

should be protected against fires and explosions. Battery The safety-related batteries are rooms should be separated from located in the same room with their each other and other areas of associated battery charger, the plant by barriers having a inverter, and dc switchgear and minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> distribution panels. The battery inclusive of all penetrations itself is located in a separate area and openings. DC switchgear of the room with its own ventilation and inverters should not be system, separated from the assoc-located in these battery rooms. iated electrical panels by a 3-hour Automatic fire detection should rated fire barrier. Each battery be provided to alarm and and electrical equipment room is annunciate in the control room separated from its redundant 3.7-13

BYRON AMENDMENT 26 DECEMBER 2012 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE and alarm locally. Ventilation counterpart and other fire zones by systems in the battery rooms 3-hour rated fire barriers.

should be capable of maintaining the hydrogen Detectors do not alarm locally.

concentration well below 2 vol-

%. Loss of ventilation should be alarmed in the control room.

Standpipe and hose and portable extinguishers should be readily available outside the room.

h. Turbine Building The turbine building should be The Applicant complies with this separated from adjacent position with two exceptions. The structures containing safety- complete collapse of the turbine related equipment by a fire building structure is not a design barrier with a minimum rating basis event for the Byron plant.

of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The fire barriers This building, although not a should be designed so as to Category I structure, is designed maintain structural integrity for the SSE and other Category I even in the event of a complete loads. Fire protection features are collapse of the turbine adequate to prevent a fire of structure. Openings and sufficient severity to threaten the penetrations in the fire integrity of the structure from barrier should be minimized and developing. Additionally, four fire should not be located where the doors in the L-line wall that turbine oil system or generator separate the turbine building on El.

hydrogen cooling system 401-0 and adjacent DG Rooms and creates a direct fire exposure four fire doors in the L-line wall hazard to the barrier. that separate the turbine building Considering the severity of the on El. 426-0 and adjacent fire hazards, defense in depth Switchgear Rooms are non-labeled may dictate additional fire doors. The subject doors are protection to ensure barrier addressed in Generic Letter 86-10 integrity. Evaluation EC-EVAL 392627; this evaluation determined that the doors are adequate for the fire hazards to which they are exposed and justifies the use of each non-labeled fire door. Refer to EC 391812 and EC-EVAL 392627.

Additionally, two fire doors that separate the turbine building and adjacent Fire Zone 11.5-0 are non-labeled fire doors. The subject doors are addressed in Generic Letter 86-10 Evaluation EC-EVAL393650; this evaluation determined that the doors are adequate for the fire hazards to which they are exposed and justifies the use of each non-labeled fire door.

3.7-14

BYRON AMENDMENT 26 DECEMBER 2012 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

i. Diesel Generator Areas Diesel generators should be Comply, except as noted below:

separated from each other and from other areas of the plant UV detectors do not alarm locally.

by fire barriers having a Thermal detectors do not alarm minimum fire resistance rating locally prior to CO2 discharge.

of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

Doors in the L-line on El. 401-0 that separate the dg Rooms and adjacent turbine building fire zones are non-labeled fire doors. The subject doors are addressed in Generic Letter 86-10 Evaluation EC-EVAL 392627; this evaluation determined that the doors are adequate for the fire hazards to which they are exposed and justifies the use of each non-labeled fire door. Refer to EC 391812 and EC-EVAL 292627.

Some diesel oil piping associated with one ESF train is routed through redundant train's room.

Calculations have been performed to demonstrate that even if this DO piping is unprotected, a fire in this zone does not affect the operability of the redundant diesel generator. Therefore, a fire in this zone would not affect the ability to shut down the plant safely (reference Calculations MAD 90-0079 and 3C8-0890-001). However, fire wrap was added as a conservative measure on most DO lines associated with the ESF train credited for safe shutdown.

3.7-14a

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE Automatic fire suppression should be installed to combat any diesel generator or lubricating oil fires; such systems should be designed for operation when the diesel is running without affecting the diesel. Automatic fire detection should be provided to alarm and annunciate in the control room and alarm locally.

Hose stations and portable extinguishers should be readily available outside the area.

Drainage for firefighting water and means for local manual venting of smoke should be provided.

Day tanks with total capacity up to 1100 gallons are permitted in the diesel generator area under the following conditions:

(1) The day tank is located in a separate enclosure with a minimum fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, including doors or penetrations. These enclosures should be capable of containing the entire contents of the day tanks and should be protected by an automatic fire suppression system, or (2) The day tank is located inside the diesel generator room in a diked enclosure that has sufficient capacity to hold 110% of the contents of the day tank or is drained to a safe location.

3.7-15

BYRON AMENDMENT 24 DECEMBER 2010 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

j. Diesel Fuel Oil Storage Areas Comply, except as noted below:

Diesel fuel oil tanks with a Diesel fuel oil tanks are located capacity greater than 1,100 within the auxiliary building. See gallons should not be located Table 3-1 for delineation of inside buildings containing conformance with NFPA 30.

safety-related equipment. If above-ground tanks are used, The outdoor above-ground diesel fuel they should be located at least oil storage tanks (located more than 50 feet from any building 50 feet away from any building containing safety-related containing safety-related equipment) equipment or, if located within are not protected by an automatic 50 feet, they should be housed fire suppression system. Potential in a separate building with fuel oil spills are confined within construction having a minimum a berm. Manual suppression fire resistance rating of 3 capability from nearby hydrants will hours. Potential oil spills prevent the fire from spreading from should be confined or directed the berm.

away from buildings containing safety-related equipment.

Totally buried tanks are acceptable outside or under buildings (see NFPA 30, "Flammable and Combustible Liquids Code," for additional guidance).

Above-ground tanks should be protected by an automatic fire suppression system.

k.Safety-Related Pumps Comply, except as noted below:

l.

Pump houses and rooms housing Most safety-related pumps are redundant safety-related pump located in the auxiliary building.

trains should be separated from Most pumps are located in individual each other and from other areas rooms separated from other plant of the plant by fire barriers areas by walls of substantial having at least 3-hour ratings. construction, but which generally do These rooms should be protected not carry fire ratings. Automatic by automatic fire detection and fire detection is provided for all suppression unless a fire pumps, but automatic suppression is hazards analysis can in general not provided. Refer to demonstrate that a fire will the applicable portions of Sections not endanger other safety- 2.3 and 2.4 of this Fire Protection related equipment required for Report for a description of safe plant shutdown. Fire individual pumps and the fire detection should alarm and hazards and safe shutdown analyses.

annunciate in the control room and alarm locally. Hose Automatic suppression is provided for the essential service water makeup pumps. Portable extinguishers are available as backup 3.7-16

BYRON AMENDMENT 29 DECEMBER 2020 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE stations and portable Deviations from the 10 CFR 50 extinguishers should be readily Appendix R criteria are listed in accessible. Appendix A5.7.

Ionization detectors are provided which annunciate and alarm in the control room.

Detectors do not alarm locally.

Floor drains should be provided to prevent water accumulation from damaging safety-related equipment (see Position C.5.a.(14)).

Provisions should be made for manual control of the ventilation system to facilitate smoke removal if required for manual firefighting operation (see Position C.5.f).

l. New Fuel Area Hand portable extinguishers Comply, except as noted below:

should be located within this area. Also, hose stations Ionization (or photoelectric) detectors are should be located outside but provided which annunciate and alarm in the within hose reach of this area. control room.

Automatic fire detection should alarm and annunciate in the control room and alarm locally. Detectors do not alarm locally.

Combustibles should be limited to a minimum in the new fuel area. The storage area should be provided with a drainage system to preclude accumulation of water. The storage configuration of new fuel should always be so maintained as to preclude criticality for any water density that might occur during fire water application.

3.7-17

BYRON AMENDMENT 29 DECEMBER 2020 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE

m. Spent Fuel Pool Area Protection for the spent fuel Comply, except as noted below:

pool area should be provided by local hose stations and Ionization (or photoelectric) detectors are portable extinguishers. provided which annunciate and alarm in the Automatic fire detection should control room.

be provided to alarm and annunciate in the control room and to alarm locally. Detectors do not alarm locally.

n. Radwaste and Decontamination Areas Fire barriers, automatic fire Comply, except as noted below:

suppression and detection, and ventilation controls should be Radwaste areas within the auxiliary provided. building are separated from other auxiliary building areas by non-fire-rated walls. The radwaste areas within the service building are provided with 3-hour rated barriers between the adjacent turbine building and between other service building areas. Most radwaste areas are not provided with automatic fire suppression systems. Automatic suppression with only partial coverage is provided for radwaste areas within the service building.

Refer to Subsection 2.3.14 for detailed description of the various radwaste areas of the plant.

Decontamination areas at Byron are not treated as separate fire areas, and hence do not have fire barriers or automatic suppression systems.

Four such areas are identified on plant drawings. A decontamination skid is shown on the ground floor of the service building. It is part of fire zone 14.6-0. A decontamination station is shown in the radwaste tunnel on Elevation 383 feet 0 inch near column-row 26/N. It is part of fire zone 14.1-0. In the fuel handling building, a decontamination area is shown on Elevation 401 feet 0 inch near column-row 17/Z. It is a pit for washing down spent fuel 3.7-18

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE casks and has neither rated fire barriers nor automatic suppression.

It is part of fire zone 12.1-0 (refer to Subsection 2.3.12).

Finally, a decontamination/change area and a decontamination pad are shown on Elevation 426 feet 0 inch in the general area of the auxiliary building between column-rows 15-21/U-V. These rooms are separated from the rest of the auxiliary building by non-fire-rated walls, and they do not have automatic suppression. Refer to Subsection 2.3.11 for a detailed description of these areas.

o. Safety-Related Water Tanks Storage tanks that supply water Comply.

for safe shutdown should be protected from the effects of an exposure fire. Combustible materials should not be stored next to outdoor tanks.

p. Records Storage Areas Records storage areas should be Comply. The record storage areas so located and protected that a are located such that there is no fire in these areas does not exposure to safety-related systems.

expose safety-related systems The main record storage facility is or equipment (see Regulatory located in the service building.

Guide 1.88, "Collection, For compliance with Regulatory Guide Storage, and Maintenance of 1.88, see B/B-FSAR Page A1.88-1.

Nuclear Power Quality Assurance Records").

q. Cooling Towers Comply.

Cooling towers should be of noncombustible construction or so located and protected that a fire will not adversely affect any safety-related systems or equipment. Cooling towers should be of noncombustible construction when the basins 3.7-19

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE are used for the ultimate heat sink or for the fire protection water supply.

r. Miscellaneous Areas Miscellaneous areas such as Comply.

shops, warehouses, auxiliary boiler rooms, fuel oil tanks, and flammable and combustible liquid storage tanks should be so located and protected that a fire or effects of a fire, including smoke, will not adversely affect any safety-related systems or equipment.

3.7-20

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE 3.8 SPECIAL PROTECTION GUIDELINES

a. Storage of Acetylene-Oxygen Fuel Gases Gas cylinder storage location Comply.

should not be in areas that contain or expose safety- Administrative procedures cover the related equipment or the fire permit needed to use acetylene-protection systems that serve oxygen fuel gases.

those safety-related areas. A permit system should be required to use this equipment in safety-related areas of the plant (also see Position C.2).

b. Storage Areas for Ion Exchange Resins Unused ion exchange resins Comply.

should not be stored in areas that contain or expose safety-related equipment.

c. Hazardous Chemicals Hazardous chemicals should not Hazardous chemicals such as caustic be stored in areas that contain soda, sulfuric acid, etc., are kept or expose safety-related in proper containers in accordance equipment. with fire protection recom-mendations. Ventilation and flood protection are provided. Storage areas have curbs, good drainage, and sump capability.

d. Materials Containing Radioactivity Materials that collect and Comply.

contain radioactivity such as spent ion exchange resins, charcoal filters, and HEPA filters should be stored in closed metal tank or containers that are located in areas free from ignition sources or combustibles. These materials should be protected from exposure to fires in adjacent areas as well. Consideration 3.8-1

BYRON AMENDMENT 13 DECEMBER 1990 IMPLEMENTATION OR JUSTIFICATION FOR SECTION NRC POSITION NONCOMPLIANCE 3.8 SPECIAL PROTECTION GUIDELINES should be given to requirements for removal of decay heat from entrained radioactive materials.

3.8-2

BYRON-1 AMENDMENT 28 DECEMBER 2018 NATIONAL FIRE PROTECTION ASSOCIATION FIRE CODE REVIEW BYRON NUCLEAR STATION UNIT NO. 1 AND COMMON AREAS WITH UNIT NO. 2 DEVIATION REPORT 3.9-1

BYRON-1 AMENDMENT 28 DECEMBER 2018 INTRODUCTION A National Fire Protection Association (NFPA) fire code review was conducted at the Byron Station. A fire code review was performed for Byron Units 1 and 2. This review included the applicable referenced NFPA fire codes contained within the branch technical position CMEB 9.5-1 entitled, "Fire Protection Program Requirements." The code review consisted of a review and an evaluation of the fire protection design, installation, original acceptance testing, and periodic surveillance and maintenance as recommended by the respective NFPA standards. In addition, the Byron Station has been reviewed against the most current edition of the National Fire Protection Association codes as contained in the 1983 and 1984 publication of the fire codes.

Commonwealth Edison recognizes that the National Fire Protection Association codes are consensus documents which by committee attempt to reflect the state-of-the-art in fire protection and loss prevention practices, and provide the guidance and criteria intended to be applicable to all industry. As fire protection engineering, and the application of fire protection engineering, is not an exact science, good engineering judgment must be relied on in utilizing and applying the NFPA standards and criteria contained within the individual sections of the standards.

Within the fire protection industry, the NFPA fire codes and the application of the guidance provided is subjective at best and regularly subject to change. Therefore, Commonwealth Edison maintains that using the NFPA codes and criteria provided as guidance, applying good engineering judgment, provides the high level of reliability and availability of fire protection program which NFPA is attempting to achieve through providing such guidance. Furthermore, it was determined that the review of the Byron Station against the most current edition of the fire codes was prudent as the codes generally attempt to reflect the state-of-the-art in fire protection and loss prevention practices. A sample review of the deviations identified in the review of the 1983/1984 fire codes was performed against the earlier editions of the codes that were in place during the original design of the Byron Station. It was determined that the earlier codes had no significant impact on the deviations identified.

A list of the National Fire Protection Association fire codes reviewed for this submittal follows. The date of the current edition of each code used for this review and the date of the edition for each code which applied during the original design at the Byron Station are listed. The NFPA code deviation table is an attempt to address the major deviation noted from the wording of the respective NFPA codes. They are listed in certain instances by fire zone, where applicable.

A majority of the deviations identified address items not in compliance with the wording of the standard; however, they are not considered applicable or necessary and so are designated as being acceptable. This exemplifies that the application of such standards is again subjective and requires engineering judgment. Minor deviations identified during the performance of the review were corrected at the time. In Table 3-1 a disposition of the deviation has been provided for areas containing equipment related to 3.9-2

BYRON-1 AMENDMENT 28 DECEMBER 2018 the safe shutdown of the plant. Deviations which were deemed to affect safe shutdown equipment of the plant have also been dispositioned. The review also included common fire protection areas such as standpipes and hose, fire pumps, underground fire mains and hydrants, and the private fire brigade.

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

A 25% extension of the frequency interval specified for the surveillance/predefine activity is permitted to facilitate scheduling of the activity and to provide consideration for unit operating conditions that may not be suitable for conducting the surveillance maintenance activities). This 25% extension does not significantly degrade the reliability that results from performing the surveillance/predefine activity at its specified frequency. This is based on the recognition that the most probable result of any particular surveillance/predefine activity being performed is the verification of conformance with the requirements for the surveillance/predefine activity.

The 25% surveillance/predefine activity frequency interval extension is not intended to be used repeatedly merely as an operational convenience to extend surveillance/predefine activity frequency intervals.

In conclusion, as originally stated, the NFPA fire codes should be utilized as guidance and cannot be applied effectively without utilizing the necessary engineering judgment.

NFPA Standard No. 4, "Organization for Fire Services," and NFPA Standard No. 4A, "Organization of a Fire Department," deal primarily with municipal or governmental organizations. These NFPA standards do not directly apply or should not be applied in the strict sense to the Byron fire protection program. NFPA Standard No. 6, "Organization of Industrial Fire Loss Prevention," and NFPA Standard No. 7, "Management Control of Fire Emergencies," and NFPA Standard No. 8, "Management Responsibilities for Effects of Fire on Operations" contain information which can serve as a useful tool in the development of a fire protection program. Based on a review of the Byron Station procedures addressing this area, the guidance provided in these documents has been adequately addressed, where applicable, and in some instances exceeds the scope of the standards. The guidance provided in the above referenced standards, which are no longer published, has been used in the development and implementation of the fire protection program at the Byron Station. Therefore, deviation reports have not been provided for these standards.

3.9-3

BYRON-1 AMENDMENT 28 DECEMBER 2018 In dealing with NFPA 70, "National Electrical Code," Commonwealth Edison adequately addresses the national electric code in their design and installation. As referenced in the BTP Section 450-C, the electric code refers to oil-filled transformers installed inside the buildings. No deviation report was developed for the code.

All internal transformers at the Byron Station are of the dry type. NFPA Standard No.

92M, "Water-Proofing and Draining of Floors," is no longer in existence in the current fire codes. The purpose of the standard, as originally issued, is adequately addressed in the applicable sections of the NFPA codes reviewed. Therefore, no deviation report was developed for this code.

3.9-4

BYRON-1 AMENDMENT 29 DECEMBER 2020 DATE OF ISSUE FOR CODE NFPA CODE TITLE 1977 NO. 1984 CODES CODES 4 Organization for Fire Services 1971 No Listing 4A Organization of a Fire Department 1971 No Listing 6 Organization of Industrial Fire Loss Prevention 1974 No Listing 7 Management Control of Fire Emergencies 1974 No Listing 8 Management Responsibilities for Effects 1974 No Listing of Fire on Operations 10 Portable Fire Extinguisher, Installation 1975 1981 Maintenance and Use 11 Foam Extinguishing Systems 1976 1983 11A High Foam Extinguishing Systems (Does not apply) 1976 1983 11B Synthetic Foam Extinguishing Systems (Does not apply) 1974 No Listing 12 CO2 Systems

• 1980 12A Halon 1301 Systems 1973 1980 12B Halon 1211 Systems (Does not apply) 1973 1980 13 Standards for the Installation of Sprinkler Systems 1976 1983 14 Standpipe and Hose Systems 1976 1983 15 Standards for Water Spray Fixed Systems 1973 1982 16 Foam - Water Sprinkler Systems and Foam - Water Spray 1974 1980 Systems 20 Standard for the Installation of 1976 1983 Centrifugal Fire Pumps 24 Standard for Outside Protection ** 1984 26 Supervision of Valves 1975 1983 27 Private Fire Brigades 1975 No Listing 30 Flammable and Combustible Liquids Code 1976 1981 37 Stationary Combustion Engines and Gas Turbine 1975 1979 50A Gaseous Hydrogen Systems 1973 1984 70 National Electrical Code 1977 1984 72D Standard for the Installation, Maintenance, and Use of 1975 1979 Proprietary Protective Signaling Systems 72E Automatic Fire Detectors 1974 1982 80 Fire Doors and Windows 1975 1983 90A Air Conditioning and Ventilation Systems 1976 1981 92M Waterproofing and Draining of Floors (Does not apply) 1972 No Listing 204 Smoke and Heat Venting 84 code = 204 M 1968 1982

• NFPA Standard and No. 12 - 1977 (NFPA Fire Codes - 1978 Edition)

• • NFPA Standard and No. 24 - 1981 (NFPA Fire Codes - 1982 Edition) 3.9-5

BYRON-1 AMENDMENT 19 DECEMBER 2000 TABLE 3-1 NFPA CODE DEVIATION REPORT NFPA 10, 1981 Edition - Portable Extinguishers FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 1.1-1(S)* 10-1981-1-6.12 1 Verify that dry chemical Leave extinguishers as is. Ambient temperatures will not extinguishers installed in the exceed 122°F maximum containment building will not be according to the Technical exposed to ambient Specifications. Since normal temperatures exceeding 120ºF. ambient temperatures will be Otherwise, they must be less than 120°F, the temperature designed for the expected exposure to dry chemical temperature. extinguishers is minimal.

A11(S&NS) 10-1981-4-4.1.1 2 Verify that all stored pressure - addresses loaded type water extinguishers will annually be extinguishers. Byron does not discharged and disassembled. use this type of extinguisher but uses stored pressure type of water extinguishers. The inspection procedures for these extinguishers have been reviewed by M&MPC and found acceptable

• Note: An S following the fire zone number indicates that equipment required for safe shutdown of the plant is present.

NS indicates that no safe shutdown equipment is present.

3.9-6

BYRON-1 AMENDMENT 24 DECEMBER 2010 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 10, 1981 Edition - Portable Extinguishers FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 1-1, 2 (S)* 10-1981-4-3.1 - Extinguishers shall be inspected Extinguishers are inspected Performance based historical monthly. quarterly, except for fire reviews of previously performed extinguishers located inside the monthly inspections have containment building during at- demonstrated few inspection power conditions. failures, sufficient to justify extending the inspections to a quarterly basis. This evaluation was conducted in accordance with the approved administrative procedure for Performance Based Evaluation for Fire Protection.

During at-power conditions, access to the containment building is controlled administratively to prevent unauthorized entry. There is very small risk that fire extinguishers located within the containment will be tampered with or removed during at-power conditions. An inspection of fire extinguishers is performed at the beginning of each plant refueling outage.

3.9-7

BYRON-1 AMENDMENT 24 DECEMBER 2010 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 10, 1981 Edition - Portable Extinguishers FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 1-1, 2 (S)* 10-1981-4-4.1 - Extinguishers shall be subjected Comply, except for extinguishers During at-power conditions, to maintenance not more than 1 located inside the containment access to the containment year apart. building during at-power building is controlled conditions. administratively to prevent unauthorized entry. There is very small risk that fire extinguishers located within containment will be tampered with during at-power conditions.

Maintenance or replacement of fire extinguishers inside the containment building is performed at the beginning of each plant refueling outage.

1-1, 2 (S)* 10-1981-4-4.3 - Extinguishers shall have a tag or Comply, except for fire Fire extinguishers located inside label securely attached. extinguishers located inside the the containment building will not containment building. have an attached inspection /

maintenance tag. Tags capable of being routinely signed and dated are not compatible with the plant requirement to prohibit potential debris that may clog the containment recirculation sump.

The extinguisher inspection and maintenance data sheets from plant procedures provide retrievable records of the required inspections and maintenance and satisfy the intent of the code for the fire extinguishers located within the containment building.

3.9-8

BYRON-1 AMENDMENT 20 DECEMBER 2002 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 11, 1983 Edition - Foam Systems 18.20-0(NS) (Previous NFPA 11 review recommendations are deleted because the foam system previously protecting the outdoor fuel oil storage tank has been abandoned and is no longer used.)

3.9-9

BYRON-1 AMENDMENT 29 DECEMBER 2020 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 12, 1980 Edition - Carbon Dioxide FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION All CO2 12-1980-1-10.3.2 1 Provide the hydrostatic test pressure - UL listing of test pressure satisfies Systems (S&NS used on the valves controlling the NFPA 12..

low pressure CO2 systems.

LCSR 12-1980-1-11.2 2 Verify that all carbon dioxide - System demonstration procedure Pneumatic timer systems will be thoroughly inspected was reviewed; will be 18 month testing and tested at least annually. surveillance. This frequency is considered to be satisfactory.

8.3-1 12-1980-1-9.6.1 5 Verify that the CO2 storage tanks - Both the 2 ton and 10 ton tanks were 18.11-0 (10 ton and 2 ton) were tested and certified and stamped in accordance marked in accordance with with ASME VIII.

specifications of ASME for unfired pressure vessels.

9.1-1, 9.2-1, 12-1980-1-8.3.8 7 Fuel supply should be automatically - Diesel engine is required for safe 9.3 1, 9.4-1, shut off to the diesel generators and shutdown and fuel will not be 11.4 A 1(S diesel driven auxiliary feedwater interlocked to shut off. The room is pump in case of fire in those areas. protected by automatic CO2 in the event of a fire.

3.9-10

BYRON-1 AMENDMENT 29 DECEMBER 2020 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 12, 1980 Edition - Carbon Dioxide 3.3 A-1 NFPA 12 - - - System is administratively 3.3 A-2 paragraph 2-4.1. operated to perform an additional 3.3 B-1 manual actuation after 10 3.3 B-2 minutes, to provide a hold time 3.3 C-1 equal to 20 minutes (M&MPCS 3.3 C-2 letter dated Oct. 3, 1984).

3.3 D-1 3.3 D-2 All carbon 12-1980-1-11.2 - Verify that all carbon dioxide Justification for deviation is All carbon dioxide systems with dioxide systems will be thoroughly documented in Performance the exception of the fire zone systems with inspected and tested at least Based Evaluation 389723 18.11-0, 18.11-1, and 18.11-2 the exception annually. will be inspected and tested of LCSR every 3 years.

pneumatic timer testing 3.9-11

BYRON-1 AMENDMENT 29 DECEMBER 2020 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 12A, 1980 Edition - Halon 1301 Fire Extinguishing Systems FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 13.0(NS) NFPA 12A-1980 1- 6 The completed system shall be To assure that the Freon The system was tested using 2 7.4 tested to meet the approval of substitute test gas provided a test cylinders containing 82 the authority having jurisdiction. meaningful test, list the weight(s) pounds of Halon 122 each.

of the Freon for the 1/28/81 test.

13.0(NS) NFPA 12A-1980 8 Plans and specifications shall The Viking 1/28/81 test report In a letter from Viking dated include all pertinent items refers to 1-100 lb reserve halon 12/11/84, Attachment A states necessary for the proper design. cylinder; however, there is no that this system does not have a reserve backup for this system connected reserve.

All Halon NFPA 12 A - 1980 At least annually, all systems Justification for this deviation is Halon system are inspected and Systems 1-11.1.1 shall be thoroughly inspected documented in Performance tested every 3 years.

and tested for proper operation Based Evaluation 389723 and by competent personnel. 623789 3.9-12

BYRON-1 AMENDMENT 26 DECEMBER 2014 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 13 - Sprinkler Systems FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION All zones 13-1983 2-9.2.2 1 Gauges on system risers shall Gauges on riser are 300 psi. Gauges with pressure of 300 psi sprinklered have a maximum limit not less are considered more than All System than twice the normal working adequate on the systems in the pressure. plant.

Stairwell 13-1983 1-8.1.1 2 Only approved devices should be "N" stamped and approved (UL) Present valve arrangement does sprinklers in 3 installed on sprinkler systems may not be available. The valve not compromise system integrity.

fire (S) zones (shutoff valve). fits the descrip¬tion in NFPA 13 U.L. listed valves will not be Aux. Bldg. P- other than it closes much faster installed in lieu of "N" stamp 18 than the required 5 seconds. valves.

8.3-2(NS) 13-1989 4-4.18 3.1 Baffles shall be installed Spacing criteria is not met on Sidewall sprinklers are shielded 8.5-2(NS) whenever sprinklers are less certain hatchway sprinklers. Ref. by structural steel from the than 6 ft. apart to prevent the Drawings M-603, Sht17, 24, 25, upright sprinkler discharge.

sprinkler opening first from 26, 27, 28, 29, 38, 39,40,41, 42, wetting adjoining sprinklers. 43, 44, 45, 46, 47, 48 8.6-0 13-1983 3-8.4 - For sprinklers installed in Pendant style sprinklers for Unit Resolved to the fact that the pendant position below ceiling, 2 startup bldg. are locking return system is adequately flushed, return bend shall be used when bends. main drain tests are performed the water supply is from a raw quarterly (further flushing the water source. When water system piping) and the water supply is potable, return bends supply is strained through a are not required. screen prior to its introduction into the system.

All zones(S) 13-1983 3-13.1.3 8 Sprinkler system fittings should - The design of the pipe and sprinklered be examined to determine if they fittings has been verified to be are of the heavy pattern type due adequate for the maximum to pressure on systems operating pressure of the exceeding 175 psi. system.

Note: Some areas could not be visually inspected due to obstructions and measurements could not be obtained.

These areas were reviewed against as-built drawings indicating piping dimensions and no deviations were observed in the sprinkler systems.

3.9-13

BYRON-1 AMENDMENT 29 DECEMBER 2020 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 13 - Sprinkler Systems FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 10.2-1, 10.1-1, 13-1983 4.3-1 8 Deflectors of sprinklers shall be - Suppression systems will 10.2-2, 10.1-2 located 1 in. to 10 in. (25mm to function as intended even though 243mm) below combustible multiple sprinklers exceed the ceilings or 1 in. to 12 in. (25mm maximum allowable distance of to 305mm) below 12 inches from the ceiling. As noncombustible ceilings. The the systems are manually operating elements of sprinklers actuated and consist of open shall be located below the sprinklers without thermal ceiling. elements, they do not rely on the collection of heat at the ceiling to activate the sprinklers. The presence of combustibles in the form of gaskets above the sprinklers will not contribute to fire sustainability or growth as the combustibles do not represent a significant fire hazard and are mainly contained within the ductwork. Reference EC/EVAL 381603 for details.

3.9-14

BYRON-1 AMENDMENT 29 DECEMBER 2020 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 13 - Sprinkler Systems FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 18.10A-1, N/A The deluge systems piping for The deluge systems piping for 18.10B-1, Main Power Transformers 1E, Main Power transformers are 18.10A-2, 1W, 2E, and 2W are designed in redesigned (Reference EC #

18.10B-2 accordance with applicable 397983 and 397984). It is sections of NFPA 13-2013 acceptable to design the new systems to the latest available code year (2013) 18.10C-1 N/A The deluge systems piping for The deluge system piping for 18.10D-1 Unit Auxiliary Transformers UATs 141-1 and 141-2 are (UATs) 141-1 and 141-2 are redesigned (Reference EC #

designed in accordance with 626215). It is acceptable to applicable sections of NFPA 13- design the new systems to the 2019. latest available code year (2019).

Note: Some areas could not be visually inspected due to obstructions and measurements could not be obtained.

These areas were reviewed against as-built drawings indicating piping dimensions and no deviations were observed in the sprinkler systems.

3.9-15

BYRON-1 AMENDMENT 19 DECEMBER 2000 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 13A, 1981 Edition - Inspection, Testing, and Maintenance of Sprinkler System FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION All Sprinklered 13A-1981-3-5.1.1 1 A stock of 24 sprinklers should - Actions are in place to maintain a Zones (S&NS) be maintained at all times spare stock of at least 24 including all temperature types sprinkler heads.

that are utilized in the plant.

All Exterior 13A-1981-2-7.3.1 4 Quarterly each post indicator - Quarterly the station verifies that Zones (S&NS) valve should be given a "spring" the lock is on and annually opens or torsion test. and closes the valve. This is considered adequate All Exterior 13A-1981-2-1.21 - NFPA 13A specifies a monthly Yard hydrants are inspected Zones inspection to verify that hydrants annually to NFPA 25 inspection, are not obstructed and that they test, and maintenance are accessible, visible, and with requirements.

caps in place.

3.9-16

BYRON-1 AMENDMENT 29 DECEMBER 2020 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 14, 1983 Edition - Standpipe and Hose FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION All 14-1983-4-43.3 1 Each hose reel or hose rack - Fire hose will be utilized by throughout the station should be trained fire brigade personnel provided with a label affixed to only. Other than red color-coded include "Fire Hose for Use by piping, no further instructions will Occupants" and operating be provided.

instructions.

All 14-1983-4-2.1 3 Verification should be made to Could not find listing on Existing valves do not assure that all existing angle Anderson Greenwood Co. or compromise system integrity.

valves on the standpipe systems Conval Valves. Other valves ASME Section III valves are are U.L. listed or F.M. approved. have no Mfg. NA. or Model No. required and will remain in place, as these valves are considered of equal quality to a listed valve.

Note: The majority of the Fire Protection System previously classified as Safety Category I, quality Group C has been reclassified as Safety Category II, Quality Group D (Ref. EC 626662); and remains classified as Seismic Category I. The use of ASME Section III valves to justify the use of non-listed valves remains valid; however, with reclassification of the piping, future valve replacements may require the use of listed valves if the replacements are performed with non-ASME section III valves.

3.9-17

BYRON-1 AMENDMENT 29 DECEMBER 2020 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 14, 1983 Edition - Standpipe and Hose FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION All 14-1983-7-5.1.3 5 Verification should be made to - The design of the pipe and assure that fittings used on the fittings has been verified to be standpipe systems are "extra- adequate for the maximum heavy" where pressures exceed operating pressure of the 175 psi. system.

All 14-1983-4-7.1 8 The flowing pressures at hose - Fire brigade members are being outlets exceed 100 psi each. trained for working pressures in Outlet shall be provided with an excess of 150 psi. Brigade approved device to reduce to training is being documented.

reduce the pressure with required flow at the outlet to 100 psi.

3.9-18

BYRON-1 AMENDMENT 29 DECEMBER 2020 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 14, 1983 Edition - Standpipe and Hose FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION All 14-1983-7-7.1 10 An approved 3-1/2" dial spray The purposes of these gauges is The normal operating pressures pressure gauge should be to assure that minimum pressure of the fire protection system have provided at the top of each requirements at the hose stations been reviewed and calculations standpipe. Gauges shall be are met. indicate adequate pressure will located in a suitable place where be maintained. Therefore the water will not freeze. Each gauges are not considered gauge will be controlled by a necessary.

valve having arrangements for draining.

All 14-1983-4.1.1, 4-3.1 11 Elevation No. 412 in containment - Elevation 412' is adequately and 4-4.1 No. 1 is adequately covered by covered by hose stations from hose connections from other adjacent levels in containment.

levels. Elevation No. 412 does not have any hose connection in containment.

All 14-1983-4-4.3.4 12 All nozzles for Class II service - The proper type of hose nozzle is hose throughout the plant should brought to scene and utilized by be listed for use on Class A, B, the fire brigade based on the and C fires. type of fire and surrounding environment. Straight stream nozzles are supplied to areas of new fuel storage.

12.1-0 14-1983-4-4.3.4 15 Replace the straight-steam - Solid stream nozzles will remain nozzles on hose reels 170, 171, in fuel handling areas.

and 173 with U.L. listed nozzles rated for Class A, B, and C fires.

These hose stations are located in fuel handling areas.

3.9-19

BYRON-1 AMENDMENT 29 DECEMBER 2020 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 14, 1983 Edition - Standpipe and Hose FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 18.11-0,1,2 14-1983-3-2 - Hose stations should be provided Hose stations in the River Hose stations are not required as for the River Screen House such Screen House have been a backup suppression system to that all portions of the building abandoned. protect safety related equipment.

are within 30ft of a nozzle when (Reference EC #351113).

attached to not more than 100 ft of a hose.

- 14-1983-4-2.1 27 Provide a U.L. listed valve at the - Non-listed valve does not affect standpipe outlet of hose station operability of hose station.

270 for attachment of hose.

- 14-1983-4-4.3.2 28 Verification should be made on Check hose rack at station Nos. Fire hose is used by trained fire all hose racks to assure they are 179, 180, 256, 263, 264, 184, brigade personnel only.

suitable for the hose installed. 265, and 178. U.L. listed Nonlisted hose reels do not Each rack should be U.L. listed replacement hose reels are no affect the firefighting for lined or unlined hose. longer available. They will be performance of the hose station.

replaced with similar nonlisted Most of the hoses and hose reels, as needed. associated hose reels have been removed per EC 626870 as the fire brigade utilizes high-rise hose packs transported to the scene.

- 14-1983-2-1.3.1 40 Verification should be made on - M&MPC has determined existing and 2-1.3.2 all standpipe under 50 ft in height design is acceptable.

to be a minimum of 2 inches in size and all in excess of 50 ft shall be at least 2-1/2 in. in size 3.9-20

BYRON-1 AMENDMENT 25 DECEMBER 2012 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 14, 1983 Edition - Standpipe and Hose FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION

- 14-1983-2-1.3 and 41 Verification should be made to - The normal operation pressures 5-4.1 assure that all Class II standpipe of the fire protection system have systems are sized for a minimum been reviewed and calculations flow of 100 gpm for 30 minutes. indicate that adequate pressure Where one or more standpipes are required, all common supply piping and flow will be maintained.

should be hydrostatically sized for a minimum flow of 100 gpm. The supply shall be sufficient to maintain a residual pressure of 65 psi at the topmost outlet of each standpipe.

3.9-21

BYRON-1 AMENDMENT 24 DECEMBER 2010 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 15, 1983 Edition - Water Spray Systems FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 18.10E-1(NS) 15-1983-2-1.1 1 A cock handle should be - An operator carries a valve installed on the alarm test handle during testing and connection for the water spray attaches it to the stem. This system protecting the system guards against malicious auxiliary transformer 142-1. operation.

8.3-1, 18.10A- 15-1983-2-5.1 2 The Viking model D-5 deluge A static pressure slightly above Static pressure slightly above the 1, 18.10B-1, valves for the water spray the working pressure would working pressure would not be 18.10C-1, systems protecting the probably not be harmful to the harmful to the equipment.

18.10D 1, transformers, lube oil storage equipment. Higher pressure 18.10E 1(NS) tank, and turbine bearings are rated valves and fittings should listed for maximum working not be needed if the static stays pressures of 175 psi. The static not more than 5 to 10 psi above pressure on the systems was the rated working pressure of approximately 180 psi. Higher 175 psi.

pressure fittings should be used on these systems.

18.10A-1, 15-1983-2-1.2 3 The equipment used to - The detection equipment only 18.10B 1, automatically actuate the supply on alarm function and do 18.10C 1, transformer water spray systems not actuate the water spray.

18.10D 1, should be listed by Underwriters' Thus the unlisted equipment is 18.10E 1(NS) Laboratories for the purpose. considered acceptable.

The heat detection equipment is not listed in the 1983 Fire Protection Equipment directory.

3.9-22

BYRON-1 AMENDMENT 24 DECEMBER 2010 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 15, 1983 Edition - Water Spray Systems FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 18.10A-1 15-1983-2-1.1 5 A cock handle should be - An operator carries a valve (NS) installed on the alarm test handle during testing and connection for the main attaches it to the stem. This transformer 1E. guards against malicious operation.

18-10B-1 15-1983-2-1.1 6 A cock handle should be - An operator carries a valve (NS) installed on the alarm test handle during testing and connection for the main attaches it to the stem. This transformer 1W. guards against malicious operation.

18.10C-1 15-1983-2-1.1 7 A cock handle should be - An operator carries a valve (NS) installed on the alarm test handle during testing and connection for the water spray attaches it to the stem. This system protecting the unit guards against malicious auxiliary transformer 141-1. operation.

18.10D-1 15-1983-2-1.1 8 A cock handle should be - An operator carries a valve (NS) installed on the alarm test handle during testing and connection for the water spray attaches it to the stem. This system protecting the unit guards against malicious auxiliary transformer 141-2. operation.

11.7-0 (S) 15-1983-4-7.1.1 9 The main control valves The individual valves are Valve has been locked open and supplying water to all the supervised but not the main is surveilled on a monthly basis.

individual manual water spray valve.

systems protecting the charcoal filters for the auxiliary building should be supervised.

3.9-23

BYRON-1 AMENDMENT 24 DECEMBER 2010 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 15, 1983 Edition - Water Spray Systems FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 11.7-0(S) 15-1983-4-3 10 The thermostat sensing line There are approximately 6 The lines were extended per on the charcoal filter water sections each with 9 levels Design Change FP-196 and spray systems should extend of filter trays. installed per Modification M6 farther than two filter sections 86-0039.

to cover the hazard.

18.10A-1, 15-1983-4-3 11 The transformer water spray The only automatic operation Station does not intend 18.10B-1, systems should operate is on failure of the redesign. Actuation of deluge 18.10C-1, automatically upon actuation transformer. valve trips transformer.

18.10D-1, of the heat detection system 18.10E-1(NS) for proper hazard protection.

All(NS) 15-1983-8-6 14 Provide water spray system - Test procedure requires work test data to verify that, under request to be initiated if test conditions, heat detectors response times are in excess operate within 40 seconds of maximum allowable time when exposed to standard specified in 1-3-85 M&M letter.

heat test source.

All 15-1983-6-2.5 15 Verify that water spray system - Procedures require testing to control valves and automatic be conducted every 18 months.

detection equipment is tested This is considered adequate.

at least annually.

All 15-1983-6-2.6 16 Verify that manual tripping - Procedures require testing to devices and valves for water be conducted every 18 months.

spray systems are operated This is considered adequate.

at least annually.

3.9-24

BYRON-1 AMENDMENT 29 DECEMBER 2020 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 15, 1983 Edition - Water Spray Systems FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION All 15-1983-6-2.8 17 Verify that all spray nozzles - Procedures established for 18-are visually inspected and month surveillance. This is cleaned, if necessary, at least considered adequate.

annually.

All 15-1983-6-1.3 20 Provide the frequency of - Procedure for 18 months regularly scheduled plant surveillance has been written.

inspections at which water This is considered adequate.

spray equipment is to be visually checked.

All 15-1983-4-6.2 21 Verify that provisions are - Drains are purposely closed.

made for effective drainage of Operators would manually water from the filter area open drains upon system during the operation of the operation.

systems.

18.10A-1, N/A The deluge systems piping for The deluge systems piping for 18.10B-1, Main Power transformers 1E, Main Power Transformers are 18.10A-2, 1W, 2E and 2W are designed redesigned (Reference EC 18.10B-2 in accordance with applicable #397983 and 397984). It is sections of NFPA 15-2012. acceptable to design the new systems to the latest available code year (2012).

18.10C-1, N/A The deluge systems piping for The deluge systems piping for 18.10D-1 the Unit Auxiliary UATs 141-1 and 141-2 are Transformers (UATs) 141-1 redesigned (References EC #

and 141-2 are designed in 626215). It is acceptable to accordance with applicable design the new systems to the sections of NFPA 15-2017 latest available code year (2017).

3.9-25

BYRON-1 AMENDMENT DECEMBER 20 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 16, 1980 Edition - Foam Water Systems FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 10.1-1 16-1980-2-1 1 All component parts including The A-20 activator is Listing of these valves is not 10.2-1(S) the foam water sprinkler pneumatic but is hydrau- considered necessary since system shall be listed. lically supplied. Valves were this system will be manually noted not to be listed. The actuated. A review of the non-Alison control panel is not listed panels by S&L and listed. M&MPC considers the non-listed panels that were supplied equally reliable to the Alison panels that are listed.

Preoperational tests verified that the panels function as designed.

10.1-1 16-1980-4-3.3 2 All fittings shall be listed for - The design of the pipe and 10.2-1(S) pressures greater than 175 fittings has been verified to be psig. adequate for the maximum operating pressure of the system.

10.1-1 16-1980-5-2 4 Verification should be given System pressure relief set Hydrostatic testing at 225 psi is 10.2-1(S) that hydrostatic testing has at 180 psi. considered adequate.

been conducted at 50 psig over the fire pump's churn.

10.1-1 16-1980-7-1.1 5 The foam water sprinkler Procedures are for servicing The procedure has been 10.2-1(S) system shall be serviced by every 18 months. reviewed and approved qualified personnel (including a review by semiannually. M&MPC).

3.9-26

BYRON-1 AMENDMENT 24 DECEMBER 2010 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 20, 1984 Edition - Fire Pumps FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 18.12-0 20-1983-2-7.1 1 The electrical motor-driven Protected by distance and The electric fire pump is fire pump shall be protected redundancy. detached a minimum of 34 feet against possible interruption from a possible oil fire of service. exposure from the circulating water pumps. The electric pump is also backed up by a redundant diesel engine-driven fire pump that is located and protected in a 3-hour fire-rated room.

18.12-0 20-1983-7-1.1.1 6 The electric motor-driven fire The controller is not listed. Justification has been provided pump controller shall be listed to the NRC in a December 14, for electric motor- driven 1983 letter from T. R. Tramm to service. H. R. Denton.

18.12-0 20-1983-7-1.1.3 7 The electric motor-driven fire - Manufacturer's label not pump controller shall be required. Refer to justification marked to show noted above.

manufacturer's name and complete electrical rating.

18.13-0 20-1983-8-2.7.2 10 The automatic electric - Existing design justified, "UL" solenoid valve located in the does not label solenoid valve in exchanger supply line for the the required range.

OB fire pump diesel engine should be specifically listed for fire protection service.

3.9-27

BYRON-1 AMENDMENT 24 DECEMBER 2010 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 20, 1984 Edition - Fire Pumps FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 18.13-0 20-1983-8-6.1 - - NFPA 20 specifies a weekly The diesel engine fire pump is run of engines for not less started from ambient conditions than 30 minutes. and operated for greater than or equal to 30 minutes every 31 days.

18.12-0 & 20-1983-11-4.5 - - NFPA 20 specifies the units The motor- and diesel-driven 18.13-0 are to be operated weekly. fire pumps are operated every 31 days.

3.9-28

BYRON-1 AMENDMENT 20 DECEMBER 2002 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT Note NFPA 24, 1981 Edition - Fire Mains and Hydrants FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION Outside Ring 24-1981-3-3.2 1 The following post-indicator Not practical to relocate. Isolation capabilities are Header valve (PIVs) are located considered adequate.

closer than 40 ft to the buildings: 0FP 560, 0FP 559, 0FP 561, 0FP 577 Outside Ring 24-1981-4-2.2 3 The following hydrants are Not practical to relocate. Loss of any single hydrant Header located closer than 40 ft to does not affect building buildings they are protecting: coverage.

0FP 10S, 0FP 12S, 0FP 13S, 0FP 23S Outside Ring 24-1981-5-1.3 4 The existing practice is to - The hose houses have been Header secure one 2-1/2-inch hose to removed. A dedicated fire the hydrant, but with the response truck or cart is now remaining part of the hose maintained with hoses and located in the hose house. equipment equivalent to three The hose should be hose houses.

disconnected and completely stored in the hose house.

Outside Ring 24-1981-8-6.2.9 10 Documentation should be Welded underground piping Restraints not needed on Header provided that substantiates except connections to welded piping; thrust blocking the decision to omit thrust hydrants. provided at hydrant blocking on underground connections.

piping at tees, elbows, etc.

3.9-29

BYRON-1 AMENDMENT 20 DECEMBER 2002 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT Note NFPA 24, 1981 Edition - Fire Mains and Hydrants FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION Outside Ring 24-1981-8-4 12 Check valves should be These connections are Service water systems are third Header installed in connections normally closed and order backup water supply and between the fire protection automatic check valves are procedures have been written water system and service not needed. to monitor potential leakage of water system. butterfly valves installed.

Outside Ring 24-1981-8-4 13 The butterfly isolation valves These valves are on service Valves are ASME Section III.

Header on the connections between water system and listing is Leakage monitoring procedure fire protection water system not necessary. addresses leakage concerns.

and service water system No further action is required.

should be UL listed.

3.9-30

BYRON-1 AMENDMENT 20 DECEMBER 2002 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 26, 1983 Edition - Valve Supervision FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION

- 26-1983-3-1 - - NFPA 26 specifies that Locked open valves are locked open valves should inspected every 92 days to be inspected monthly. verify the valve is in the correct position.

3.9-31

BYRON-1 AMENDMENT 20 DECEMBER 2002 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 27, 1981 Edition - Private Fire Brigades FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION

- NFPA 27-1981 - NFPA specifies training Training sessions are Training sessions conducted 4.3 sessions should be held at conducted quarterly. quarterly result in a total of 12 least monthly for one hour or hours of training per year for more per shift. each brigade member. This level of training is considered as satisfying NFPA.

3.9-32

BYRON-1 AMENDMENT 24 DECEMBER 2010 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 30, 1981 Edition - Flammable Liquids Code FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 8.2-1 Diesel 30-1981 2-4.2 2 A 6.68" diameter emergency The subject tank is not The existing tank design will lube oil drain 30-1981 2-2.5 breather vent should be safety-related and is not not be changed.

tank 369(NS) provided for the tank. required for safe shutdown and a fire in this area will not affect safe shutdown of either unit. Area-wide automatic water suppression is provided for the area where this tank is located.

The tank is provided with an existing vent.

8.7B-0 37-1979 5-5.3 4 The liquid transfer - Heat activated valves were Station 30-1981 2-4.4.3 connections beneath the installed per Modification M6 Auxiliary liquid level of the tank should 84-0256.

Diesel F.O. be provided with either (a) a Storage normally closed remotely Tank(NS) activated valve 95 or, (b) an automatic closing heat activated valve, or (c) another approved device to provide for quick cut-off of flow in the event of fire in the vicinity of the tank.

3.9-33

BYRON-1 AMENDMENT 24 DECEMBER 2010 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 30, 1981 Edition - Flammable Liquids Code FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 8.7B-0 37-1979 5.6-1 5 Tests should be performed on The subject tank is not The existing tank design will Station 30-1981 2-4.2 the 4" breather vent (BV) to safety-related, is not not change.

Auxiliary 30-1981 2-2.5 determine whether the long required for safe shutdown, Diesel F.O. length of pipe will create and a fire in the area will not Storage backpressures that can cause affect safe shutdown of Tank(NS) the internal pressures in the either unit. An automatic F.O. storage tank to exceed suppression system is 2.5 psi when 78,900 CFH provided. Existing vents are needs to be vented. provided.

18.20-0 30-1981 2-4.2 6 Supplement the existing 6" The subject tank is not The existing tank design will (125,000 gal. breather vent (BV) and the 4" safety-related, is not not change.

F.O. Storage overflow line with an 8.8" required for safe shutdown, Tank)(NS) diameter emergency breather and a fire in the area will not vent (EBV). affect safe shutdown of either unit. Existing vents are provided.

3.9-34

BYRON-1 AMENDMENT 20 DECEMBER 2002 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 37, 1979 Edition - Stationary Combustion Engines FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 9.3-1 37-1979 1 The tank should be equipped - The fuel oil circulates to 9.4-1 5-4.1 with (1) a high level alarm, storage tanks to maintain full EMD's Day 5-4.2 and (2) a high level shutoff. capacity. Fuel does not Tanks(S) overflow into room.

9.3-1 37-1979 2 The liquid transfer -

9.4-1 5-5.3 connections beneath the Shutoff will not be permitted for EMD's Day 30-1981 liquid level of the tank should this equipment since it is Tanks(S) 2-4.4.3 be provided with either (a) A safety-related.

normally closed remotely activated valve, (b) an automatic closing heat activated valve, or (c) another approved device to provide for quick cut-off of flow in the event of fire in the vicinity of the tank.

10.1-1 37-1979 3 The liquid transfer - Shutoff will not be permitted for 10.2-1 5-5.3 connections beneath the this equipment since it is (25,000- 30-1981 liquid level of the tank should safety-related.

gallon diesel 2-4.4.3 be provided with either (a) a F.O. storage normally closed remotely tanks)(S) activated valve or (b) an automatic losing heat activated valve or (c) another approved device to provide for quick cut-off of flow in the event of fire in the vicinity of the tank.

3.9-35

BYRON-1 AMENDMENT 24 DECEMBER 2010 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 37, 1979 Edition - Stationary Combustion Engines FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 8.7B-0(NS) 37-1979 5 The tank should be equipped The tank is already equipped A high-level automatic shutoff 5-4.1 with (1) an overflow line piped with an overflow line but the has been added.

5-4.2 back to the supply tank line terminates on the floor of (125,000-gallon F.O. storage the room. The high level tanks), (2) a high level alarm, device should be interlocked and (3) a high level automatic to shut off the pump in the shutoff. event of high tank levels.

10.1-1 37-1979 6 The 4" overflow line should The overflow line is presently A high-level alarm was installed 10.2-1 5-5.3 (1) be increased to one pipe sized the same as the fill on the tank.

(25,000- 30-1981 size greater than the 4" inlet line. The overflow line Gallon 2-4.4.8 line, and (2) be liquid tight and terminates at floor level F.O. Storage discharging back to the above a funnel piped to a Tank)(S) outside source of liquid or to sump below the room. The an approved location. overflow arrangement of the tanks was reviewed and a high-level alarm on the tank is considered necessary.

10.1-1 37-1979 7 Supplement the 3" breather - M&M has accepted S&L 10.2-1 5-6.1 vent (BV) with an emergency calculation justifying present (25,000- 30-1981 breather vent (EBV) of at design.

Gallon 2-4.2 least 9.14" diameter piped to F.O. Storage 30-1981 the outside.

Tanks)(S) 2-2.5 11.4A-1 37-1979 8 The overflow line (10 59A The return line and the fill M&M has accepted S&L (Auxiliary 5-4.2 1/2) to the 1B in the diesel oil line are the same size calculation justifying present Feedwater storage room should be (1-1/2") design.

Diesel F.O. increased in size to 2".

Storage Tank)(S) 3.9-36

BYRON-1 AMENDMENT 24 DECEMBER 2010 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 37, 1979 Edition - Stationary Combustion Engines FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 11.4A-1 37-1979 9 The tank should be equipped - Tank is manually filled. Any (Auxiliary 5-4.1 with (1) high-level alarm, and overflow is piped back to Feedwater 5-4.2 (2) high-level shutoff. 25,000-gal. storage tanks. This Diesel F.O. is considered adequate.

Storage Tank)(S) 11.4A-1 37-1979 10 The liquid transfer connection - Shutoff is not permitted on (Auxiliary 5-5.3 beneath the liquid level of the safety-related equipment.

Feedwater 30-1981 tank should be provided with Diesel F.O. 2-4.4.3 (a) A normally closed Storage remotely activated valve, (b)

Tanks)(S) an automatic closing heat activated valve, or (c) another approved device to provide for quick cut-off of flow in the event of fire in the vicinity of the tank.

11.4A-1 37-1979 11 Tests should be performed on - M&M has accepted S&L Auxiliary 5.6-1 the 2" vent pipe to determine calculation justifying present Feedwater 30-1981 whether the long length of design.

Diesel F.O. 2-4.2 pipe will create back-Storage pressures that can cause the Tank(S) internal pressures in the tank to exceed 2.5 psi when 73,700 cfh needs to be vented.

3.9-37

BYRON-1 AMENDMENT 24 DECEMBER 2010 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 37, 1979 Edition - Stationary Combustion Engines FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 18.12-0 37-1979 12 The liquid transfer - Shutoff is not provided on (Diesel fire 5-5.3 connections beneath the safety-related equipment.

pump F.O. 30-1981 liquid level of the tank should Storage 2-4.4.3 be provided with (a) a Tank) normally closed remotely activated valve, (b) an automatic closing heat activated valve, or (c) another approved device to provide for quick cut-off of flow in the event of fire in the vicinity.

3.9-38

BYRON-1 AMENDMENT 24 DECEMBER 2010 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 50A, 1984 Edition - Gaseous Hydrogen Systems FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 18.18-0 and 50A-1984 2-6.1 4 All piping, tubing, and fittings - The hydrogen system and all interior shall be tested and proven components have been zones in gas-tight at maximum designed and fabricated to which the operating pressure. meet all requirements of NFPA piping Bulletin 50A, Gaseous crosses (NS Hydrogen Systems, with the areas) following exception. Brazed joints are fabricated with experienced operators who have followed industry proven procedures, however, the performance and procedure qualifications per ASME Section IX have not been documented.

- 50A-1984 2-4.1 5 All valves, gauges, and other - The hydrogen system and accessories shall be proven components have been suitable for hydrogen designed and fabricated to services. meet all requirements of NFPA Bulletin 50A, Gaseous Hydrogen Systems, with the following exception. Brazed joints are fabricated with experienced operators who have followed industry proven procedures, however, the performance and procedure qualifications per ASME Section IX have not been documented 3.9-39

BYRON-1 AMENDMENT 24 DECEMBER 2010 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 72D, 1979 Edition - Proprietary Protective Signaling Systems FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION

- 72D-75-1232(b)/ 1 Test gate valve supervising - Switches are periodically tested 1234 switches semiannually and annually. Drain tests are 72D-79-2-4.3 perform drain test. conducted. The annual testing period is considered adequate.

The procedure has been written and approved.

- 72D-75-1254 3 Upon receipt of trouble - The authority having 72D-79-4-7.3 signals, the control room jurisdiction is not notified when operator shall notify the detection equipment is out of authority having jurisdiction service for an extended period.

where interruption of normal Rather, the limiting conditions service will exist for more than for operation are specified in four hours and provide written the Technical Requirements notice to the authority having Manual, Section 3.10.a.

jurisdiction when equipment Additional fire protection has been out of service for measures are specified for eight hours. such cases. This is considered to be adequate.

- 72D-75-2022 4 All devices, combinations of Alison panels in the control MCR and local panels are 72D-79-2-2.2 devices and equipment room and local panels custom designed for Byron.

constructed shall be 0FP01J, 0FP04J, and Based upon reviews by approved/listed for the 0FP05J are not UL listed or M&MPC, S&L and Byron Site purposes intended. (This FM approved. Engineering and pre-pertains to the Alison Control operational tests, the original Panels). and modified panels are considered to be equivalent to approved/listed panels (Reference M&MPC letters dated Sept 5 & 22, 1986).

3.9-40

BYRON-1 AMENDMENT 20 DECEMBER 2002 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 72D, 1979 Edition - Proprietary Protective Signaling Systems FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION

- 72D-79-3-5.12 6 Automatic fire detectors which - Upon receipt of a trouble alarm, have integral trouble contacts an operator is dispatched to the shall be wired on the initiating area and a fire watch may be device circuit so that a trouble initiated until trouble is cleared.

condition on one detector will This is considered to be not impair the alarm operation acceptable.

from other initiating devices.

- 72D-79-3-6.2.2 7 Automatic sprinkler system - Upon receipt of a trouble alarm, signals shall indicate an operator is dispatched to the distinctively the particular area and a fire watch may be function (valve position, initiated until trouble is cleared.

grounds, opens, etc.). This is considered to be acceptable.

- 72D-75-2223 8 When central station primary Bus 132 (ESF Bus) is the Bus 142 is a safety-related 72D-79-2-6.2.3 power is provided from a primary power supply to the ESF power source. It is commercial light and power proprietary alarm systems. normally fed from the system source and engine-driven Bus 134 is the secondary auxiliary transformer, but is generator, storage batteries power supply. An also has a diesel generator having the capacity to operate impairment in Bus 142 could backup in case of a loss-of-the system under maximum impair all sources of power offsite power. In addition, a load for four hours shall be to Bus 132. manual crosstie to Unit 2 Bus provided. 242 is provided. This supply is as reliable as was intended by the NFPA code, and is 3.9-41

BYRON-1 AMENDMENT 20 DECEMBER 2002 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 72D, 1979 Edition - Proprietary Protective Signaling Systems FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION

- 72D-75-2224 9 A separate power supply, Trouble signals are fed from Due to the high reliability of the 72D-79-2-6.24 independent of the main the primary source. primary power supply, as power supply, shall be mentioned above, this is provided for the operation of considered to be acceptable.

trouble signals (may use the secondary power supply).

- 72D-75-2461 11 Provide distinctive trouble and Signals used for Unit 1 and The Unit 1 and Unit 2 fire alarm alarm signals in the control No. 2 are distinctive from panels are located not adjacent room for Units No. 1 and No. other plant signals but not to one another in the control

2. from the Unit No. 1 and Unit room. It will be obvious to an No. 1 control panels. operator responding to a fire alarm which unit is affected.

The existing design is considered to be acceptable.

3.9-42

BYRON-1 AMENDMENT 29 DECEMBER 2020 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 72E, 1982 Edition - Fire Detectors FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION All zones 72E-1982-8.3.3 - Test smoke detectors Previous deviation tested Smoke detectors are tested except 1.2-1, semiannually. smoke detectors every 18 every 3 years.

1.2-2, 8.1-0, months as documented in PSD 8.3-1, 14.6-0, FP transmittal 92-113.

18.11-0, Justification for this deviation is 18.12-0, documented in Performance 18.35-0, Based Evaluation 389723 18.36-0, 18.38-0 and QA vault All zones 72E-1982-8.3.2.2 - Test a restorable heat Previous deviation tested heat Restorable heat detectors are except U1 detector on each circuit detectors every 18 months as tested every 3 years.

and U2 semiannually. After 5 years documented in PSD FP containment. all must be tested. transmittal 92-113.

Justification for the deviation is documented in Performance Based Evaluation 389723.

9.1-1, 9.2-1, 72E-1982-8.3.4 All flame detectors, fire-gas Justification for this deviation is Ultraviolet (UV) detectors are 9.1-2, 9.2-2, detectors and other fire documented in Performance tested every 3 years.

12.1-0 detectors shall be tested at Based Evaluation 389723.

least semiannually as prescribed by the manufacturer and more often if found to be necessary for the application.

3.9-43

BYRON-1 AMENDMENT 29 DECEMBER 2020 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 72E, 1982 Edition - Fire Detectors FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 18.10A-1, N/A The thermistor wire The thermistor wire detection 18.10B-1, detection for Main Power for Main Power Transformers is 18.10A-2, Transformers 1E, 1W, 2E, redesigned. (Reference EC #

18.10B-2 and 2W is designed in 397983 and 397984). It is accordance with applicable acceptable to design the new sections of NFPA 72-2013 detection to the latest available code year (2013) 18.10C-1 N/A The thermistor wire for the The thermistor wire detection 18.10D-1 Unit Auxiliary Transformers for UATs 141-1 and 141-2 is (UATs) 141-1 and 141-2 is redesigned (Reference EC #

designed in accordance 616215). It is acceptable to with applicable sections of design the new detection to the NFPA 72-2019 latest available code year (2019).

3.9-44

BYRON-1 AMENDMENT 13 DECEMBER 1990 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 80, 1981 Edition - Fire Doors FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 288 80-1981 1 Only labeled or listed doors It should be verified that all The justification for the use of 291 1-6.1 shall be used. doors in fire rated barriers non label doors in certain have UL labels affixed, instances is contained on page indicating appropriate fire 2.1-8 of the FPR.

ratings.

SD 175-319 80-1981 2 Only labeled or listed doors The justification for the use of 373-383 1-6.1 shall be used. non label doors in certain 348-374 instances is contained on page 392-351 2.1-8 of the FPR.

357-381-382 411-432 415-440 420-460 427-463 538-551 552-669 3.9-45

BYRON-1 AMENDMENT 21 DECEMBER 2004 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 80, 1981 Edition - Fire Doors FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION SD 171-180 80-1981 3 Weather stripping or - Gaskets or weather- stripping 181-212 2-1.2 gasketing of any kind on fire for air tightness does not 292-295 doors (or frames) shall be appreciably affect the fire 298-299 furnished only in accordance resistance rating of the door.

300-336 with the manufacturer's No further action is required.

302-340 published listings. Exception:

319-348 Where acceptable to authority 329-349 having jurisdiction, gasketing 350-374 of noncombustible or limited 351-381 combustible material may be 370-382 applied to the frame providing 373-383 closing and latching of the 398 door is not inhibited.

400-411 412-413 420-425 427-428 430-431 432-440 441-461 462-477 489 500-501 523-538 545-548 551-552 648-649 682-693 695-701 3.9-46

BYRON-1 AMENDMENT 25 DECEMBER 2012 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 80, 1981 Edition - Fire Doors FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION SD 180 80-1981 4 Only labeled door frame shall - The justification for the use of SD 181 2-5.1 be used. non label doors in certain 167-317 instances is contained on page 318-336 2.1-8 of the FPR.

398 442-553 669-720 See also Doors listed in Paragraph 1-6.1 Various, as 80-1981 5 The clearance between the The clearance between the The clearances may be applicable 2-5.4 door and the frame and door and the frame and increased as stated and between meeting edges of between meeting edges of justified in EC-EVAL#339805.

doors swinging in pairs shall doors swinging in pairs may Clearances that satisfy the not exceed 1/8 inch. exceed 1/8 inch. criteria specified in the EC-EVAL represent an acceptable minor deviation from NFPA 80 and may be considered operable without additional evaluation or corrective action.

Various, as 80-1981 6 The clearance between the The clearance between the The clearances may be applicable 2-5.4 bottom of the door and a bottom of the door and a increased as stated and raised noncombustible sill raised noncombustible sill justified in EC-EVAL#339805.

shall not exceed 3/8 inch. may exceed 3/8 inch. Clearances that satisfy the Where there is no sill, the Where there is no sill, the criteria specified in the EC-maximum clearance between maximum clearance EVAL represent an acceptable the bottom of the door and between the bottom of the minor deviation from NFPA 80 floor shall not exceed 3/4 door and floor may exceed and may be considered inch. 3/4 inch. operable without additional evaluation or corrective action.

3.9-47

BYRON-1 AMENDMENT 25 DECEMBER 2012 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 80, 1981 Edition - Fire Doors FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION SD 169-170 80-1981 8 Holder/release devices shall - Security hardware is necessary SD 171-175 2-8.5 be permitted when acceptable for controlled areas. Refer to SD 180-181 2-8.8 to the authority having page 2.1-9 of the FPR.

234 jurisdiction. The devices shall 319-348 be installed in accordance 351-373 with the manufacturer's 381-383 instructions and only in 398-400 conformance with the 411-415 individual manufacturer's 420-427 published listings.

477-489 538-551 552-648 649-701 729-730 Various, as 80-1983 - Coordinating Device: When - For a double leaf fire door, applicable 2-8.4.1 there is an astragal or which is controlled by plant 3-7 projecting latch bolt that security card reader system, a prevent the inactive door of a door Coordinating Device is not pair of doors from closing and required.

latching before the active door closes and latches, a Justification is contained in coordinating device shall be ECs 347761 and 362746.

used. A coordinating device shall not be required where each door closes and latches independent of the other door.

3.9-48

BYRON-1 AMENDMENT 26 DECEMBER 2014 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 80, 1981 Edition - Fire Doors FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 9.1-1, 9.1-2, 80-1983 - The DG rollup doors and - Where fusible links are used, 9.2-1, 9.2-2 6-6.2 normally closed. For this one fusible link shall be located case, the rollup doors are near the top of the opening and already in their fire-related additional links shall be located safe shutdown position at or near the ceiling on each (i.e., closed) and initiation of a side of the wall.

close signal via a fusible link is not required. When a DG rollup door is opened, the appropriate LCOAR for fire barriers, 0BOL 10.g, is entered and a fire watch is posted for the zone.

5.1-1, 80-1981 - Only labeled or listed doors Several doors at El. 401-0 The subject doors are addressed 5.1-2, 1-6.1 shall be used. and El. 426-0 in the L-line wall in Generic Letter 86-10 5.2-1, are reinforced with steel plates Evaluation EC-EVAL 392627; 5.2-2, for HELB pressure loading in this evaluation determined that 9.1-1, conjunction with seismic the modified doors are adequate 9.1-2, loading under HELB design for the fire hazards to which they 9.2-1, basis analysis. The doors are are exposed and justifies the use 9.2-2 not labeled. of each non-labeled door. Refer to EC 391812 and EV-EVAL 392627.

5.1-1, 80-1981 - Only labeled or listed doors The frames for several doors at The subject door frames are 5.1-2, 2-5.1 shall be used. El. 401-0 and El. 426-0 in addressed in Generic Letter 86-5.2-1, the L-line wall are reinforced for 10 Evaluation EC-EVAL 392627; 5.2-2, HELB pressure loading in this evaluation determined that 9.1-1, conjunction with seismic the modified doors are adequate 9.1-2, loading under HELB design for the fire hazards to which they 9.2-1, basis analysis. The door are exposed and justifies the use 9.2-2 frames are not labeled. of each non-labeled door. Refer to EC 391812 and EV-EVAL 392627.

3.9-49

BYRON-1 AMENDMENT 26 DECEMBER 2014 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 80, 1981 Edition - Fire Doors FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 5.1-1, 80-1981 - Hinges shall be as required in The hinges for several doors The number and attachment of 5.1-2, 2-8.1.1, Table 2-8A. Doors up to 60 in. at El. 401-0 and El. 426-0 the subject door hinges is 5.2-1, 80-1981 in height shall be provided with in the L-line wall are replaced addressed in Generic Letter 86-5.2-2, Table 2-8A, two hinges and an additional to support reinforcing steel 10 Evaluation EC-EVAL 392627; 9.1-1, 80-1981 hinge for each additional 30 in. plates for HELB pressure this evaluation determined that 9.1-2, 2-8.1.3 of door height or fraction loading in conjunction with the modified doors are adequate 9.2-1, thereof. Hinges shall be seismic loading under HELB for the fire hazards to which they 9.2-2 secured to frames with steel design basis analysis. The are exposed and justifies the use screws. Types of screws will number of hinges is reduced of each non-labeled door and vary depending on material from three to two; the new hinge configuration. Refer to EC used for the manufacture of hinges are not attached to the 391812 and EC-EVAL 392627.

labeled door frames. Refer to door frame.

labeled door frame manufacturers instructions and published listings for specific screw requirements.

8.3-2, 11.5-0 80-1981 - Only labeled or Two doors at El. 401-0 in the -

1-6.1 listed doors shall L-line wall are reinforced with be used. steel plates for HELB pressure loading in conjunction with seismic loading under HELB design basis analysis. One door also has horizontal stiffeners. The doors are not labeled.

3.9-50

BYRON-1 AMENDMENT 27 DECEMBER 2016 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 80, 1981 Edition - Fire Doors FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 8.3-2, 11.5-0 80-1981 Only labeled door The frames for two doors at -

2-5.1 frame shall be El. 401-0 in the L-line wall used. are reinforced for HELB pressure loading in conjunction with seismic loading under HELB design basis analysis. The door frames are not labeled.

8.3-2, 11.5-0 80-1981 Hinges shall be secured to The hinges for the two doors ATTACHMENT OF THE 2-8.1.3 frames with steel screws. at El. 401-0 in the L-line wall SUBJECT DOOR HINGES IS Types of screws will vary are replaced to support steel ADDRESSED IN Generic Letter depending on material plates added to reinforce the 86-10 Evaluation EC-EVAL used for the manufacture of doors for HELB pressure 393650; this evaluation labeled door frames. Refer loading in conjunction with determined that the modified to labeled door frame seismic loading under HELB doors are adequate for the fire manufacturers instructions design basis analysis. The hazards to which they are and published listings for replacement hinges are not exposed and justifies the use of specific screw attached to the door frame; each non-labeled door and hinge requirements. they are welded to a short configuration.

hollow steel section, which is Refer to EC 393481 and EC welded to a plate that is EVAL 393650.

attached to the concrete wall and/or structural steel.

Attachments to the wall are made with 3/4 concrete expansion anchors. The other hinge leaf is attached to the door with through-bolts.

3.9-51

BYRON-1 AMENDMENT 27 DECEMBER 2016 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 80, 1981 Edition - Fire Doors FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 5.1-1, 5.1-2, 80-1983, 4-1.2 Center parting doors shall have The astragal for fire doors These fire doors were evaluated 5.2-1, 5.2-2 an astragal securely attached in 0DSD351, 348, 377, and 380 in GL 86-10 Evaluation EC place so as to project a minimum was removed and replaced per 392627. While this specific of 3/4 in. station drawings as a result of deviation was not addressed, the HELB modifications. New conclusion of EC 392627 installation criteria allows a 3 remains valid. A 3 inch gap inch gap between the floor and between the floor and the the astragal. astragal is bound by EC 392627.

3.9-52

BYRON-1 AMENDMENT 24 DECEMBER 2010 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 90A, 1981 Edition - Air Conditioning and Ventilation FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 18.1-1 (ESF 90A-1981-2-4.1.1 1 Air filters shall be approved These filter enclosures Temporary condition.

Div. elev. 426') such as Class 1 and Class 2 contain Class 2 filters with Pegboard was removed when 18.2-1 (ESF that will not burn or emit combustible pegboard systems were required to be Div. excessive smoke. panels in the frame. operable.

11 elev. 426')

18.1-1 (Lower Combustible pegboard cable sprd. rm. should be removed.

elev. 439')

11.7-1 (Cont.

purge supply elev. 467')

11.7-0 (Cont.

purge exhaust elev. 451')

18.2-1 (Non-ESF supply unit elev. 451')

18.4-1 (Control Rm. HVAC elev. 451')(S) 11.3F-1 and 90A-1981-3-3.1 2 Duct openings through fire (f) Common 3-hr fire wall Neither area comprises a 3-hr 11.3G-1(S) walls shall be protected by an between safety inj. pump fire-rated room. Safe shutdown automatic closing 3-hr-rated and charging pump/cooler does not require 3-hr rated fire damper. is violated by common separation. Not necessary to duct system outside the install damper in duct.

room that does not have fire dampers.

3.9-53

BYRON-1 AMENDMENT 24 DECEMBER 2010 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 90A, 1981 Edition - Air Conditioning and Ventilation FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 11.7-0 (Cont. 90A-1981-4-3(b) 4 Duct smoke detectors shall be (b) Couldn't locate detector S&L review with M&M resulted purge installed in the return air if any. Containment in cancel-lation of change.

exhaust duct stream prior to exhausting purge system may be Existing design is acceptable.

elev. 475')(S) from the building or being connected to Aux. Bldg.

diluted by outside air. exhaust shaft.

5.6-1(S) 90A-1981-4-3(a) 5 Duct smoke detectors shall be (b) 32" x 18" supply duct Adequate area smoke installed in the main supply from Div. 12 Elec. detection has been provided.

duct downstream of filters. Equipment Room (zone This is adequate in lieu of duct 5.4-1) to Div. 11 Elec. detector.

Equipment Room (zone 5.6-1)

All Zones 90A-1981-2-1.4.2 7 Service openings shall be Pertains to all dampers and Location of fire protection identified with letters to detectors for entire plant. equipment including dampers indicate location of fire has been identified.

protection devices.

3.9-54

BYRON-1 AMENDMENT 24 DECEMBER 2010 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 90A, 1981 Edition - Air Conditioning and Ventilation FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 8.3-1 (Supply 90A-1981-4-5.1 (9) 9 Detectors shall be installed in The pyrotronics model CA-4 New detectors have been duct for heater & accordance with NFPA 72E. is listed for air velocities of furnished for the VT and VA drain pump 72E-1982-9-1.1.4 500-3100 FPM. In reference Systems.

area, elev. to the S&L HVAC drawings 401') (NS) 8.3-1 (Boiler and actual detector location, Room exhaust the following areas exceed (72,000 3100 FPM; should verify cfm elev. 418') actual airflows.

(NS) 8.5-1 (Air return

@ col. F1 (14,000 cfm) elev.

426')(NS) 5.2-1 (ESF Div. 11 supply)

(S) 8.3-1 (Supply for cond. pump area, elev.

401')(NS) 18.3-1 (Steam pipe tunnel and safety valve vent, system Area 2 col. 27 elev. 416')(S) 11.6A-0 (Lab fume exhaust duct elev.

426')(S) 3.9-55

BYRON-1 AMENDMENT 26 DECEMBER 2014 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 90A, 1981 Edition - Air Conditioning and Ventilation FIRE ZONES NFPA REFERENCE NUMBER RECOMMENDATION COMMENTS RESOLUTION 8.6-0 (Control 10 Detectors shall be installed in (e) Detectors adjacent to Per conversation with S&L, Room office accordance with NFPA 72E. fans. Sampling tubes detectors do not need to be supply fans should be a minimum of moved.

A&B elev. two duct widths from 468') sources of turbulence.

Generic to all 90A-1981-4-3 11 Detectors in the main supply - All systems are compliant with duct smoke (a)&(b) and return air ducts shall the exception of the VA, VC, detectors(S) automatically stop the fan(s). and VP systems, which were evaluated and deemed acceptable as is due to nuclear safety functions.

Generic to all 90A-1981-4-4 12 Smoke dampers shall be Describe where and what Smoke dampers are not HVAC installed in systems over HVAC systems are utilized required per letter from systems(S) 15,000 cfm. for smoke control. M&MPC dated 12/3/85.

Generic to all 90A-1981-4-5.1 13 Detectors shall be installed in Provide documentation for Functional system testing detectors accordance with NFPA 72E. testing sensitivity, interlocks, procedures are adequate.

Initial and periodic tests shall alarms, smoke test, in Agreement reached with NRC.

be conducted. accordance mfgs instructions.

18.13-0, 90A-1981-3-3.1 When the penetration of a fire - Per ECs 395618 and 397405, 18.14A-1, wall by the duct system non-fire rated dampers and 18.14A-2, cannot be avoided, the louvers located within the 18.14B-1, opening shall be protected by 3-hour fire walls of these zones 18.14B-2 an approved automatic- are of adequate protection and closing fire damper or fire will maintain the required 3-door assembly having a fire hour fire barrier.

protection rating not less than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and shall be installed within the wall.

3.9-56

BYRON-1 AMENDMENT 26 DECEMBER 2014 TABLE 3-1 (Contd)

NFPA CODE DEVIATION REPORT NFPA 10, 1981 Edition - Portable Extinguishers FIRE ZONES NFPA REFERENCE NUMBER DEVIATION COMMENTS RESOLUTION 3.1-1 NFPA 90A para 3 Some fusible links have a - The fusible link temperature 3.2A-1 3.7.1.5, Fusible links temperature rating greater than rating is significantly below 5.1-1 shall have a 50 F above the normally typical fire temperatures and 5.2-1 temperature rating encountered maximum room below ignition temperature of the approximately 50°F temperature due to ab normal material on either side of the above the maximum accident conditions associated wall. A Certificate of temperature that with a HELB. Conformance was provided by normally is SR Products for non-UL listed encountered when ETLs stating that the ETLs are the system is in designed and manufactured with operation or shut the same parts and standards as down, but not less their UL listed devices. Refer to than 160°F. EC 388895, 388896, or 392208.

3.9-57

BYRON-2 AMENDMENT 28 DECEMBER 2018 INTRODUCTION Table 3.2 is a listing of NFPA deviations identified for safety-related areas on Byron Unit

2. This list indicates deviations which were not identified on the Unit 1 NFPA deviation list.

3.9-58

BYRON-2 AMENDMENT 13 DECEMBER 1990 TABLE 3-2 (Contd)

NFPA CODE DEVIATION REPORT FIRE ZONES NFPA REFERENCE RECOMMENDATION RESOLUTION All water spray 15 - 1985 A suitable flushing connection should be System main drain tests are performed which will flush systems 2-13 incorporated into the water spray systems to piping up to system piping. The system can be facilitate routine flushing. pneumatically cleaned if determined necessary. No further action required.

All automatic water 15 - 1985 A gauge connection should be provided at or Hydraulic analysis verified the adequacy of the water spray systems 4-9.25 near the nozzle calculated as having the least supply to meet the greatest hydraulic demand. A pressure under normal flow conditions. review of the individual water spray systems calculation against the design and water supply confirm the calculation with respect to the system design. A gauge on this system is not considered necessary. No further action required.

3.3A-2 12A - 1985 Only listed or approved equipment and devices The Halon check valves are not specifically listed 3.3B-2 2-7.4 shall be used in the system. Halon check independently; however, provided as a component of 3.3C-2 valves Model No. 1-061-733, Serial No. M- this halon system design which was reviewed and 3.3D-2 2964. found to have been designed, installed and tested in accordance with the recommendation of NFPA. The preoperational test of these systems will verify operability of these valves. These valves are considered to be adequate. No further action required.

All automatic water 15 - 1985 The solenoid switch manufactured by The testing procedures confirm component operability.

spray systems 2-1.2 Automatic Switch Company and installed on This is considered acceptable.

the automatic water spray systems should be U.L. listed.

11.7-0, 11.7-1, 11.7 1985 Individual strainers should be provided at each Strainers are provided upstream of the fire pumps.

2, 18.4-2, 4-11.3 nozzle where water passageways are smaller Also, flushing procedures will eliminate any debris.

3.3A-2, 3.3A-1 than 1/8 inch.

3.9-59

BYRON-2 AMENDMENT 26 DECEMBER 2014 TABLE 3-2 (Contd)

NFPA CODE DEVIATION REPORT FIRE ZONES NFPA REFERENCE RECOMMENDATION RESOLUTION

- NFPA 13, para. 3-8.4, Return Return bends are not provided for pendent The sprinkler systems have been adequately flushed; bends shall be used when sprinklers. main drain tests are performed quarterly (which will pendent sprinklers are further serve to flush the lead-in piping) and the plant supplied from a raw water fire protection water is strained through a screen prior source. to its introduction into the system.

- NFPA 90A, para. 3-3.7.1.5, Some fusible links have a temperature rating The fusible link temperature rating is significantly Fusible links shall have a greater than 50°F above the normally below typical fire temperatures and below ignition temperature rating encountered maximum room temperature due temperature of the materials on either side of the wall.

approximately 50°F above to abnormal accident conditions associated A certificate of Conformance was provided by SR the maximum temperature with a HELB. Products for non-UL listed ETLs slating that the ETLs that normally is encountered are designed and manufactured with the same parts when the system is in and standards as their UL listed devices. Refer to EC operation or shut down, but 388442, 388443, or 392209.

not less than 160°F.

3.9-60