ML110890871
| ML110890871 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/28/2011 |
| From: | Jeremy Dean State of NY, Office of the Attorney General |
| To: | Borchardt R NRC/EDO, Office of Nuclear Reactor Regulation |
| References | |
| G20110221, OEDO-2011-0226, 2.206, EDATS: SECY-2011-0226 | |
| Download: ML110890871 (59) | |
Text
EDO Principal Correspondence Control FROM:
DUE: 04/28/11 EDO CONTROL: G20110221 DOC DT: 03/28/11 FINAL REPLY:
Janice A.
Dean Office of the New York State Attorney General TO:
Borchardt, EDO FOR SIGNATURE OF
- Leeds, NRR
- GRN CRC NO:
DESC:
2.206 - Entergy Nuclear Operations, Inc., Fire Safety Regulations at Indian Point Units 1, 2 and 3
(EDATS: OEDO-2011-0226)
DATE: 03/29/11 ROUTING:
Borchardt Weber Virgilio Ash Muessle OGC/GC
- Dean, RI
- Burns, OGC
NRR CONTACT:
Leeds SPECIAL INSTRUCTIONS OR REMARKS:
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EDATS Number: OEDO-2011-0226 Source: OEDO Genera Infrmaio Assigned To: NRR OEDO Due Date: 4/28/2011 Other Assignees:
SECY Due Date: NONE
Subject:
2.206 - Entergy Nuclear Operations, Inc., Fire Safety Regulations at Indian Point Units I, 2 and 3
==
Description:==
CC Routing: Regionl; OGC; Tanya.rnensah@nrc.gov; catherine.scott@nrc.gov ADAMS Accession Numbers -
Incoming: NONE Response/Package: NONE Other I
'nfo ion Cross Reference Number: G20110221 Staff Initiated: NO Related Task:
Recurring Item: NO File Routing: EDATS Agency Lesson Learned: NO OEDO Monthly Report Item: NO Proes Inomtn Action Type: 2.206 Review Priority: Medium Sensitivity: None Signature Level: NRR Urgency: NO Approval Level: No Approval Required OEDO Concurrence: NO OCM Concurrence: NO OCA Concurrence: NO Special Instructions:
Originator Name: Janice A. Dean Date of Incoming: 3/28/2011 Originating Organization: Office of the New York State Document Received by OEDO Date: 3/29/2011 Attorney General Addressee: R. W. Borchardt, EDO Date Response Requested by Originator: 4/28/2011 Incoming Task Received: 2.206 Page 1 of I
Jaegers, Cathy From:
Sent:
To:
Cc:
Subject:
Attachments:
Janice Dean [Janice. Dean@ag.ny.gov]
Monday, March 28, 2011 12:26 PM Borchardt, Bill John Sipos New York State Attorney General Petition Pursuant to 10 C.F.R. 2.206 2011 03 28 OAG 2-206 petition re fire safety signed.pdf
Dear Executive Director of Operations Borchardt,
Attached please find an electronic version of the New York Attorney General's Petition Pursuant to 10 C.F.R. 2.206 regarding fire safety at Indian Point which was sent to you via overnight mail today.
Respectfully submitted, Janice A. Dean Assistant Attorney General Janice A. Dean Assistant Attorney General Office of the NYS Attorney General 120 Broadway, 26th Floor New York, New York 10271 (212) 416-8459 voice (212) 416-6007 fax janice.deane@ag.ny.gov 1
EDO -- G20110221
UNITED STATES NUCLEAR REGULATORY COMMISSION X---------------------------x In re:
Dkt Nos. 50-247; 50-286 Petition for Enforcement Filed by the Attorney General of the State of New York DPR-26; DPR-64 for Enforcement Action Against Entergy Nuclear Operations, Inc.
(Indian Point Unit, Indian Point Unit 2 Indian Point Unit 3).
X---------------------------x March 28, 2011 PETITION PURSUANT TO 10 C.F.R. § 2.206 REQUESTING THAT NRC TAKE ENFORCEMENT ACTION AGAINST ENTERGY NUCLEAR OPERATIONS, INC., AND ITS AFFILIATES FOR VIOLATIONS OF NRC'S 1980 FIRE SAFETY REGULATIONS AT INDIAN POINT UNIT 1, INDIAN POINT UNIT 2, AND INDIAN POINT UNIT 3 AND TO COMPEL ACTUAL COMPLIANCE WITH SUCH REGULATIONS Office of the Attorney General for the State of New York The Capitol State Street Albany, New York 12224
Note about Citations and References Contained in this Document All citations and references mentioned in this document are hereby incorporated by reference. Should NRC Staff have difficulty obtaining any such citations and references, they are requested to contact the Office of the Attorney General for the State of New York for assistance.
TABLE OF CONTENTS PRELIMINARY STATEMENT..................................................................................
1 INTEREST OF PETITIONER..................................................................................
1 INDIAN POINT'S UNIQUE LOCATION.................................................................
2 AUTHORITY FOR PETITION................................................................................
5 REGULATORY FRAMEWORK................................................................................
5 History of NRC's Fire Safety Standards........................................................ 6 Fire Safety Regulations for U.S. Nuclear Reactors....................................... 7 Systemic Weaknesses Exist in NRC Enforcement of its Fire Protection Regulations..........................................................................
10 Heightened Fire-safety Concerns Post-9/11................................................
14 Earthquakes Can Produce Fires...................................................................
16 INDIAN POINT VIOLATES NRC FIRE SAFETY REGULATIONS..................... 16 The Part 50, Appendix R Fire Protection Regulations Apply to the Indian Point Facilities............................................................
16 Violation of Applicable Federal Fire Safety Regulations............................. 17 C O N C L U SIO N..............................................................................................................
22 i
PRELIMINARY STATEMENT In 1980, the Nuclear Regulatory Commission ("NRC") promulgated specific and prescriptive fire safety regulations for United States nuclear power reactors. 10 C.F.R. § 50.48(b), Appendix R,Section III. Today, thirty years after the regulations became effective, the Indian Point reactors still do not comply with those fire safety regulations. This petition, filed pursuant to 10 C.F.R. § 2.206, requests that NRC actually enforce these important fire safety regulations and require the Indian Point nuclear reactors and related facilities to comply with the plain text of NRC's fire safety regulations.
INTEREST OF PETITIONER The Attorney General is the chief legal officer for the State of New York and its citizens. As such, the Attorney General has an interest in protecting the State's citizens, to the extent possible, from the health and safety risks posed by the nuclear reactors at Indian Point. The Indian Point site, which was selected before NRC adopted detailed siting regulations, has the highest surrounding population of any operating reactor site in the United States. Each day, more than seventeen million people live, work, or travel within fifty miles of Indian Point.
Like most U.S. reactors, the Indian Point facilities contain miles of electrical cables that control and power mechanical safety systems -
including valves, pumps, motors, and gauges -
designed to ensure the prompt shut down of the reactors. A fire at Indian Point that damaged those cables could disable the critical safety systems served by the cables and ultimately lead to a major radiation release that would have a disastrous impact on the lives, health, and property of the people of New York. Indeed, NRC Commissioners have long been concerned about the risks of fire at a nuclear reactor. During a 2008 briefing, NRC staff informed the Commissioners that "[a]pproximately one-half of the core damage risk at operating reactors results from accident sequences that initiate with fire events." NRC, Briefing on Fire Protection Issues, at 58-59 (July 17, 2008), ML082030647 (Statement of Jack Grobe, NRC Associate Director, Office of Nuclear Reactor Regulation for Safety Systems and Engineering).'
INDIAN POINT'S UNIQUE LOCATION The Indian Point reactors are located 24 miles north of New York City. As noted above, more than 17 million people live within 50 miles of Indian Point, a population that is projected to grow to 20 million by 2035. According to the Atomic Energy Commission ("AEC"), the NRC, and the Federal Emergency Management Agency ("FEMA"), more people live within 10 and 50 miles of the Indian Point reactors than at any other operating power reactor in the nation. Indeed, no other operating reactor site in the country comes close to Indian Point in terms of surrounding population.2 Moreover, the communities within the 50-mile radius around Indian Point also contain some of the most densely-developed and expensive real estate in the country, critical natural resources, centers of national and I
The nine digit "ML" accession numbers refer to documents in NRC's "Electronic Reading Room" that may be located via the agency's search engine known as Agencywide Documents Access and Management System (ADAMS) at www.nrc.gov/reading-rm/adams/web-based.html.
2 See, e.g., AEC, Population'Distribution Around Nuclear Power Plant Sites, Figure 2: Typical Site Population Distribution (5-50 Miles) (April 17, 1973); FEMA, Nuclear Facilities & Population Density Within 10 Miles (June 2005).
international commerce, transportation arteries and hubs, and historic sites. Thus, a severe accident at Indian Point has the potential to affect more people than an accident at any other reactor in the country.
The Indian Point facilities are approximately 35 miles from Times Square, and approximately 38 miles from Wall Street. The U.S. Census Bureau estimated that New York City had a population of 8,214,426 in 2006. The facilities are approximately 3 miles southwest of Peekskill, with a population of 22,441; 5 miles northeast of Haverstraw, with a population of 33,811, 16 miles southeast of Newburgh, with a population of 31,400, and 17 miles northwest of White Plains, with a population of 52,802. Indian Point is also 23 miles northwest of Greenwich, Connecticut, 37 miles west of Bridgeport, Connecticut, and 37-39 miles north northeast of Jersey City and Newark, New Jersey. Portions of four New York counties - Westchester, Rockland, Orange, and Putnam - fall within the inner 10-mile Emergency Planning Zone. Additional population centers in New York, such as New York City's five boroughs and Nassau County, lie within the 50-mile Emergency Planning Zone, as do significant population centers in Connecticut and New Jersey. See Declaration of Dr. Bruce Egan, August 28, 2009, ¶ 31 (ML092610916).
In addition, the Indian Point reactors are approximately 5 miles from the New Croton Reservoir in Westchester County, which provides drinking water to New York City. An important regional gas pipe line, that was constructed before the Consolidated Edison Company ("ConEd") and AEC selected the site to locate nuclear reactors, travels under portions of the Indian Point site.
The Indian Point location was selected as the site of one of the first commercial power reactors in the nation in March 1955 - before the Atomic Energy Commission or the Nuclear Regulatory Commission developed any regulations concerning the siting of such reactors, before passage of the National Environmental Policy Act ("NEPA"), before the White House Council on Environmental Quality ("CEQ") promulgated any regulations implementing NEPA, before the 1989 ruling by the Unites States Court of Appeals for the Third Circuit that told NRC to promulgate regulations to require the examination of the impacts of severe accidents at nuclear reactors, and before NRC promulgated regulations requiring the examination of ways to mitigate the impacts caused by severe accidents in licensing proceedings. 3 Under NRC's current siting regulations, which were not in place when AEC approved the Indian Point site in 1956, it is highly unlikely that the Indian Point reactors could be located today in this densely populated area. See 10 C.F.R. § 100.21(h).
Limerick Ecology Action, Inc. v. NRC, 869 F.2d 719 (3d Cir. 1989).
AUTHORITY FOR PETITION 10 C.F.R. § 2.206(a) states, in relevant part:
Any person may file a request to institute a proceeding pursuant to
§ 2.202 to modify, suspend, or revoke a license, or for such other action as may be proper.
In turn, 10 C.F.R. § 2.202 states:
Orders.
(a) The Commission may institute a proceeding to modify, suspend, or revoke a license or to take such other action as may be proper by serving on the licensee or other person subject to the jurisdiction of the Commission an order that will:
(1) Allege the violations with which the licensee or other person subjectto the Commission's jurisdiction is charged, or the potentially hazardous conditions or other facts deemed to be sufficient ground for the proposed action, and specify the action proposed; (2) Provide that the licensee or other person must file a written answer to the order under oath or affirmation within twenty (20) days of its date, or such other time as may be specified in the order; (3) Inform the licensee or any other person adversely affected by the order of his or her right, within twenty (20) days of the date of the order, or such other time as may be specified in the order, to demand a hearing on all or part of the order, except in a case where the licensee or other person has consented in writing to the order; REGULATORY FRAMEWORK Entergy Nuclear Operations, Inc. ("ENO"), is the holder of Operating Licenses Nos. DPR-26 and DPR-64, which authorize the operation of the Indian Point Unit 2 nuclear power reactor and Indian Point Unit 3 nuclear power reactor located in Westchester County, New York. 4 ENO also owns Indian Point Unit 1, one of the nation's first reactors that stopped generating power in 1974 because it could not comply with federal safety regulations, but which, according to its owner, See generally NUREG-1350, Volume 20, 2008 - 2009 Information Digest, at 103 (Aug 2008).
still plays an important role in the operation of Indian Point Unit 2 and Unit 3.
Those licenses provide, among other things, that each facility is subject to all rules, regulations, and orders of the NRC now or hereafter in effect.
History of NRC's Fire Safety Standards In 1975, a major fire broke out at the Browns Ferry nuclear power station in Alabama. The fire, which was caused by a single candle a worker was using to test leaks in a pressurization system, burned for seven hours and caused extensive damage to many safety systems, including 600 safety-related cables and the emergency core cooling system needed for the quick and safe shutdown of the reactor. NRC, A Short History of Nuclear Regulation, 1946 - 1999, ch. 3, p. 43 (2000);5 see also Fire Protection Program for Nuclear Power Plants Operating Prior to January 1, 1979, 45 Fed. Reg. 36,082 (May 29, 1980). A subsequent NRC review concluded that improvements in fire prevention and control were essential and made a number of recommendations. See NRC Special Review Group, Recommendations Related to Browns Ferry Fire, NUREG-0050 (Feb. 1976),
One recommendation identified the need to ensure the separate protection of redundant electrical cables that both control and power critical systems necessary to achieve and maintain safe shutdown of a nuclear reactor. See NRC Office of the Inspector Gen. Special Inquiry, NRC's Oversight of Hemyc Fire Barriers, at 2 (Jan. 22, 2008), ML080250003.
This document, which is also known as NUREG/BR-0 175 is available at http://www.nrc.gov/about-nrc/short-history.html.
NRC subsequently promulgated fire-safety regulations. See generally 10 C.F.R. pt. 50, App. R; 45 Fed. Reg. 76,602, 76,608 (Nov. 19, 1980). The new regulations provided that, when redundant trains of cables and equipment for shutting down a reactor were located in the same area less than twenty feet apart (rather than, for example, in two rooms separated by a concrete barrier), the operator was required to install fire protection with at least three hours of fire resistance or, in areas with fire detection and automatic suppression (e.g., sprinkler systems), one hour of fire resistance. 10 C.F.R. pt. 50, App. R, III-(G)(2)(a),(c).
Fire Safety Regulations for U.S. Nuclear Reactors Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 48
(§ 50.48), requires that nuclear power plants that were licensed before January 1, 1979, satisfy the requirements of 10 C.F.R. Part 50, Appendix R, "FIRE PROTECTION PROGRAM FOR NUCLEAR POWER FACILITIES OPERATING PRIOR TO JANUARY 1, 1979,"
Section III, "SPECIFIC REQUIREMENTS," Subsection G, "Fire protection of safe shutdown capability." Indian Point Unit 1, Indian Point 2, and Indian Point Unit 3 were licensed to operate prior to January 1, 1979. As such, the licensee's Fire Protection Program ("FPP") must provide the established level of protection as intended by Section III.G of 10 C.F.R. Part 50, Appendix R.
In accordance with 10 C.F.R. § 50.48(b), nuclear power plants licensed before January 1, 1979 are required to meet Section III.G, of 10 C.F.R. Part 50, Appendix R.
Underscoring the critical importance of the fire safety regulations, the NRC Commissioners included the following language in the text of the regulation:
When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boiloff.
10 C.F.R. Part 50, Appendix R, Section I.Section III.G.2 requires one of the following means to ensure that a redundant train of safe shutdown cables and equipment is free of fire damage, where they are located in the same fire area outside of primary containment:
- a.
Separation of cables and equipment by a fire barrier having a 3-hour rating (Appendix R, section III, G, 2, a);
- b.
Separation of cables and equipment by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards and with fire detectors and an automatic fire suppression system installed in the fire area (Appendix R, section III, G, 2, b); or
- c.
Enclosure of cables and equipment of one redundant train in a fire barrier having a 1-hour rating and with fire detectors and an automatic fire suppression system installed in the fire area (Appendix R, section III, G, 2, c).
10 C.F.R. Part 50, Appendix R, Paragraph III.G.3 imposes the following requirements:
Alternative of [sic] dedicated shutdown capability and its associated circuits,' independent of cables, systems or components in the area, room, zone under consideration should be provided:
- a.
Where the protection of systems whose function is required for hot shutdown does not satisfy the requirement of paragraph G.2 of this section; or
- b.
Where redundant trains of systems required for hot shutdown located in the same fire area may be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems.
In addition, fire detection and a fixed fire suppression system shall be installed in the area, room, or zone under consideration.
1Alternative shutdown capability is provided by rerouting, relocating, or modifying existing systems; dedicated shutdown capability is provided by installing new structures and systems for the function of post-fire shutdown.
Appendix R, III, G.3.
Consequently, unless alternative or dedicated shutdown capability is provided or an exemption from paragraph III.G.2 is granted, circuits which could cause maloperation or prevent operation of redundant trains for post-fire safe shutdown and are located in the same fire area must be protected in accordance with paragraph III.G.2.
Additionally, section III, F mandates the installation of fire detection systems in areas that could be affected by a fire.
Automatic fire detection. Automatic fire detection systems shall be installed in all areas of the plant that contain or present an exposure fire hazard to safe shutdown or safety related systems or components.
These fire detection systems shall be capable of operating with or without offsite power.
Appendix R, III, F.
Systemic Weaknesses Exist in NRC Enforcement of its Fire Protection Regulations Recent reports by NRC's own Office of the Inspector General ("OIG") and the Government Accountability Office ("GAO") found significant deficiencies in the NRC's exercise of its responsibilities with respect to fire protection issues.
In a January 2008 Special Report, the NRC Inspector General documented NRC's repeated reluctance to address deficiencies in critical "fire barrier" products that are used to ensure electrical cables can withstand fire damage for one hour as required by NRC's fire safety regulations. NRC Office of the Inspector General, Special Inquiry, NRC's Oversight of Hemyc Fire Barriers, (Jan. 18, 2008)
ML080250003. 6 Specifically, in the late 1980s and early 1990s, after concerns arose about a fire barrier product, known as Thermo-Lag, used in nuclear reactors, NRC and the United States conducted additional testing and determined that the product did not meet its represented durability. In August 1992, an NRC OIG investigation determined that NRC had accepted manufacturer fire qualification test results for Thermo-Lag that were reported to have met required standards, but later were found to have been falsified. Id., at 4. On February 27, 1993, a NRC staff report addressed concerns pertaining to Thermo-Lag performance and testing issues and recommended that Staff reassess NRC reviews done for other fire barrier materials. Id.
On March 3, 1993, the U.S. House of Representatives Subcommittee on Oversight and Investigations conducted an oversight hearing concerning deficiencies in Thermo-Lag fire barriers during which then NRC Chairman Ivan 6
The January 2008 NRC OIG Report is available at http://www.nrc.gov/reading-rm/cdoc-cnll~ct~inn*li n.*n-*en120O&1*-O-46ndf_
Selin admitted that NRC Staff had been slow in responding to questions about Thermo-Lag and promised that Staff would expeditiously review other fire barrier products. Id.
As part of its response to the Thermo-Lag problem, NRC developed a Fire Protection Task Action Plan ("FP-TAP") that included a recommendation to assess other fire barrier materials, such as Hemyc, which is used at Indian Point. NRC OIG, NRC's Oversight of Hernyc Fire Barriers, at 4-5. In accordance with the FP-TAP, NRC selected the National Institute of Standards and Technology ("NIST") to conduct tests to evaluate the fire endurance characteristics of fire barriers.
According to the NRC Inspector General, a March 31, 1994 NIST test report (FR 3994) contained the results of a test performed by NIST on Hemyc on September 17, 1993, and noted that NRC staff were present to observe this test. As noted above, the 1993 NIST report concluded that the Hemyc test sample failed to meet a 1-hour duration period - despite the fact that it claimed to provide 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of protection from fire. Id. at 4-5. Far from taking expeditious action as it promised Congress, NRC Staff took no meaningful action on Hemyc for thirteen years -until it issued an Information Notice in 2005 after subsequent tests. Id. at 5-10 and Figure 3 (time line). This lack of follow-through and commitment by NRC Staff resulted in a deficient and degraded fire protection plan at Indian Point for approximately 20 years.
NRC Staff has not taken any meaningful enforcement action concerning Indian Point's use of the deficient Hemyc product. Instead on, on September 28, 2007, a NRC manager granted Indian Point Unit 3 an exemption from the Part 50, Appendix R, III G 2 c one-hour minimum requirement, so that the facility could continue to use Hemyc that provided only 24 and 30 minutes of protection from fire damage. 72 Fed. Reg. 56798-56801 (Oct 4. 2007).
A June 2008 GAO Report further documents NRC's lax approach to fire safety. See GAO Report to Congressional Requesters, NUCLEAR SAFETY, NRC Oversight of Fire Protection at U.S. Commercial Nuclear Reactor Units Could Be Strengthened, GAO-08-747 (June 30, 2008).7 NRC has not resolved several long-standing issues that affect the nuclear industry's compliance with existing NRC fire regulations, and NRC lacks a comprehensive database on the status of compliance.
These long-standing issues include (1) nuclear units' reliance on manual actions by unit workers to ensure fire safety (for example, a unit worker manually turns a valve to operate a water pump) rather than "passive" measures, such as fire barriers and automatic fire detection and suppression; (2) workers' use of "interim compensatory measures" (primarily fire watches) to ensure fire safety for extended periods of time, rather than making repairs; (3) uncertainty regarding the effectiveness of fire wraps used to protect electrical cables necessary for the safe shutdown of a nuclear unit; and (4) mitigating the impacts of short circuits that can cause simultaneous, or near-simultaneous, malfunctions of safety-related equipment (called "multiple spurious actuations") and hence complicate the safe shutdown of nuclear units. Compounding these issues is that NRC has no centralized database on the use of exemptions from regulations, manual actions, or compensatory measures used for long periods of time that would facilitate the study of compliance trends or help NRC's field inspectors in examining unit compliance.
GAO-08-747, preface.
7 The June 2008 GAO Report is available at http://www.gao.gov/products/GAO-08-747.
The GAO Report also found:
Nuclear units must plan for short circuits that could cause safety-related equipment to start or malfunction spuriously (instances called spurious actuations). To date, units typically account only for spurious actuations that occur one at a time or in isolation. In 2001, industry tests demonstrated that spurious actuations could occur simultaneously or in rapid succession and that units' current fire protection plans do not account for this possibility.
GAO-08-747, at 6.
In June 2008, NRC reiterated that "[t]he results of [plant examinations] and actual fire events indicate that fire can be a significant contributor to nuclear power plant risk, depending on design and operational conditions." NRC, Information Sheet: Fire-Induced Electrical Cable Failure Testing (June 6, 2008), ML081610109.
A subsequent briefing to the Commissioners confirmed that "[a]pproximately one-half of the core damage risk at operating reactors results from accident sequences that initiate with fire events." NRC, Briefing on Fire Protection Issues, at 58-59, ML082030647 (Statement of Jack Grobe).
The GAO Report found that between January 1995 through December 2007, nuclear unit operators reported 125 fires at 54 sites to NRC. GAO-08-747 at 4. Of these 125 fires, operators categorized 13 as "alerts"8 Id. at 11-12. As reflected in the following table, of the 9 "alert" fires for which a cause was identified, 6 were caused by electrical fires:
8 An "Alert" describes a situation that involves an actual or potential substantial degradation of the level of safety of the plant, with any resulting radiological releases expected to be limited to small fractions based on guidance from the U.S. Environmental Protection Agency. GAO-08-747 at
- 12.
Table 1: Characteristics of Fires Rising to "Alert" Status at U.S. Commercial Nuclear Units, 1995-2007 Year Unit State Location within unit Cause 2007 Arkansas Nuclear One, Unit 2 Arkansas Auxiliary building Electrical 2007 Columbia Generating Station Washington Equipment room Electrical 2007 Callaway Nuclear Plant Missouri Control building Electrical 2006 Arkansas Nuclear One, Unit 2 Arkansas Breaker compartment Electrical 2006 Perry Nuclear Power Plant Ohio Ventilation fan Bearing 2003 Palisades Power Plant Michigan Cable spreading room Electrical 2002 D.C. Cook Nuclear Plant Michigan Switchyard Electrical 2001 Cooper Nuclear Station Nebraska Startup translormer Unreported 2001 Fermi Unit 2 Michigan Emergency diesel generator Bearing 2000 Farley Unit 2 Alabama Service water pump motor Unreported 1998 Fermi Unit 2 Michigan Emergency diesel generator Unreported 1997 Limerick Generating Station Unit 2 Pennsylvania Emergency diesel generator exhaust Unreported 1996 Clinton Power Station Illinois Pump turbine insulation Oil-Soaked Insulation S0utc: GAO gnsly* 01 NRC WeI.
GAO-08-747, at 12, Table 1.
Heightened Fire-safety Concerns Post-9/11 Fire safety at nuclear power plants has taken on greater importance since September 11, 2001, when terrorists hijacked four jet airliners and crashed three of them into their intended targets, causing explosions and large, long-lasting fires.
Those explosions and fires destroyed a portion of the Pentagon in northern Virginia and caused the collapse of the World Trade Center towers in New York City. See Nat'l Inst. of Standards & Tech., Final Report on the Collapse of the World Trade Center Towers, 175-76 (2005) (concluding that long-lasting fires were a significant factor in the collapse of the Twin Towers). Minutes before hitting the World Trade Center, two of the hijacked planes flew near or over the Indian Point reactors, located on the Hudson River twenty-four miles north of New York City. See Nat'l Comm'n on Terrorist Attacks Upon the U.S., The 9/11 Commission Report (2004),
at 32 (map of flight paths of AA1l & UA175). The 9/11 Commission's report found that Khalid Sheikh Mohammad, the mastermind of the 9/11 attacks, originally planned to hijack additional aircraft to crash into targets on both coasts, including nuclear power plants. Id. at 154. As late as July 2001, the terrorists were considering attacking a specific nuclear facility in New York, which one of the pilots "had seen during familiarization flights near New York." Id. at 245. This facility was most likely Indian Point. Even if a terrorist attack were not successful in destroying one of the reactors, it could trigger a fire that could then lead to a major release of radioactivity.
Following 9/11, NRC amended all reactor licenses, including the operating licenses for Indian point Unit 2 and Indian Point Unit 3, "to address the generalized high-level threat environment in a consistent manner throughout the nuclear reactor community." See generally 67 Fed. Reg. 9,792 (Mar. 4, 2002). The amended licenses required the identification of mitigative measures to reduce the consequences of explosions or fire at nuclear plants, "including those that an aircraft impact might create." See Letter from J. Boska, NRC, to M. Balduzzi, Entergy Nuclear Operations (July 11, 2007), ML071920023; see, e.g., NRC, IP Nuclear Generating Unit 3 Operating License, Amendment No. 203, at 8 (July 11, 2007), ML052720273. However, the license amendments did not specifically compel the Indian Point facilities to address their shortcomings with the 10 C.F.R. § 50.48, Appendix R,Section III fire safety regulations.
Earthquakes Can Produce Fires A report by Sandia National Laboratories acknowledged that an earthquake involving a nuclear power reactor facility could result in fires. Fire Risk Scoping Study: Investigation of Nuclear Power Plant Fire Risk, Including Previously Unaddressed Issues, NURE/CR-5088, SAND88-0177 (1989).
There are a number of potential interactions that one can envision that could cause an interaction between earthquakes and fire. For example, earthquakes could cause fire initiators by pulling cables loose due to vibration or shifting of [electrical] cabinets....
Gases can be released from the hydrogen system, and there is always no shortage of sparks that could ignite flammable gases.
NUREG/CR-5088, at 60.
INDIAN POINT VIOLATES NRC FIRE SAFETY REGULATIONS NRC should compel Indian Point to comply with the specific requirements set forth in NRC's long-standing fire protection regulations contained in 10 C.F.R. Part 50, Appendix R, Section III, F and G.
The Part 50, Appendix R Fire Protection Regulations Apply to the Indian Point Facilities Indian Point Unit 1, Unit 2 and Unit 3 are required to comply with the fire safety requirements set forth in 10 C.F.R. § 50.48, Appendix R Section III because those three power reactors were licensed before 1979. According to AEC and NRC documents, ConEd received the following construction permits and operation licenses on the following dates:
CONSTRUCTION PERMIT ISSUED OPERATING LICENSE ISSUED IP Unit 1 May 4, 1956 March 26, 1962 IP Unit 2 October 14, 1966 September 28, 1973 IP Unit 3 August 13, 1969 December 12, 1975 Source: Federal Register and NRC Information Digest. 9 In addition, the requirements imposed by the fire safety regulations set forth in 10 C.F.R. § 50.48, Appendix R were automatically incorporated into operating licenses for commercial nuclear power reactors through 42 U.S.C. § 2237 (which provides "The terms and conditions of all licenses shall be subject to amendment, revision, or modification, by reason of amendments of this chapter or by reason of rules and regulations issued in accordance with the terms of this chapter") as well as 10 C.F.R. § 50.54(h) (which provides "The license shall be subject to the provisions of the [Atomic Energy] Act now or hereafter in effect and to all rules, regulations, and orders of the Commission.").
Violation of Applicable Federal Fire Safety Regulations NRC's Appendix R fire safety regulations require that nuclear units protect at least one redundant system--or "train"-of equipment and electrical cables required for a unit's safe shutdown through the use of fire protection measures, such as 1-hour or 3-hour fire barriers, 20 feet of separation between redundant 9 See 21 Fed. Reg. 3,085 (May 9, 1956); 31 Fed. Reg. 13,616-17 (Oct. 21, 1966); 34 Fed. Reg. 13,437 (Aug. 20, 1969); NUREG-1350, Volume 20, 2008 - 2009 Information Digest, at 103, 113 (Aug. 2008).
systems, and automatic fire detection and suppression systems. Instead of complying with the plain text of the Appendix R regulations, certain nuclear reactor operators informally resorted to manual work arounds for the strict safety requirements set forth in the regulations referred to as "operator manual actions".
Operator manual actions (or "OMAs") refer to discrete physical tasks that a worker performs - - sometimes at a location outside of the main control room -- on a specific piece of safety equipment, (for example, a unit worker manually turns a valve to operate a water pump) rather than "passive" measures, such as fire barriers and automatic fire detection and suppression. However, during emergencies at nuclear plants, trained staff may not have access to key locations or, as in the case in the ongoing emergency in Japan at the Fukushima reactors, may be forced to evacuate the facility. OMAs depend, by definition, on the presence of skilled staff to control the spread of fire. In contrast, the regulations promulgated to ensure "fire protection of safe shutdown capability" require passive, self-actuating systems that are part of the plant's physical infrastructure, and do not rely on human intervention. The regulations do not authorize operator manual actions as a means of protecting a redundant system from fire.
As of today, safety related cable at numerous locations within Indian Point do not comply with the text of NRC's fire safety regulations, 10 C.F.R. § 50.48, Appendix R. Indeed, ENO acknowledges that it would need to resort to unapproved operator manual actions to shut down Indian Point Unit 2 and Unit 3 if safety related electrical cables were damaged. March 6, 2009, ENO Communications NL-09-031 (IP2 Table 1), NL-09-032 (IP3 Table 1). NRC Staffs position is that crediting of operator manual actions was not explicitly or implicitly permitted by the regulation, and that any crediting of such manual actions for compliance with III.G.2, without prior review and approval by the Staff in the form of an exemption, is unacceptable and noncompliant with the Appendix R fire safety regulations.
Simply put, Indian Point Unit 2 and Unit 3 violate the NRC fire safety regulations.
The explicit requirements of 10 C.F.R. Part 50, Appendix R, Section III.G.2 mandate that the redundant cable trains must be separated and protected using one of the options given by Section III.G.2.
Based upon ENO's own statements, it appears that approximately 140 different fire zones in Indian Point Unit 2 would resort to operator manual actions to bring about a shutdown should safety related cables become damaged by a fire.
The story is similar at Unit 3, as it appears that that approximately 135 different fire zones in Indian Point Unit 3 would resort to operator manual actions to bring about a shutdown should safety related cables become damaged by a fire. Stated differently, it appears that up to 275 separate fire zones at both Indian Point Unit 2 and Unit 3 do not comply with the minimum requirements established in the 10 C.F.R. § 50.48, Appendix R,Section III.G.2. These fire zones that would need employees to take manual actions are identified in tables from ENO submissions to NRC and are attached to this petition. ENO Communications NL-09-031 (Table 1),
NL-09-032 (Table 1).
It is also noteworthy that many of the operator manual actions that ENO would resort to involve more than one discrete task by the employee to engage and/or operate a specific safety system. Thus, in several instances, multiple discrete employee tasks that are needed to bring about safe shutdown may be grouped together into what ENO may label or count as a single operator manual action.
Moreover, ENO's submissions make clear that several Indian Point fire zones lack fire detection and/or fixed fire suppression systems. See, e.g., ENO communication NL-09-031, IP2 Table 1, p. 23 of 34; ENO communication NL 032, IP3 Table 1, p. 18 of 42.
Although ENO has asked NRC Staff to exempt numerous locations within the Indian Point facilities from the binding fire safety regulations, NRC should not approve that exemption request. Such a raft of exemptions would be inconsistent with NRC's commitment that exemptions not swallow a regulation. In the administrative proceedings for the Shoreham reactor, the NRC Commissioners held that the exemption authority in 10 C.F.R. § 50.12 is "extraordinary" and "available.
- . only in the presence of exceptional circumstances." Long Island Lighting Co.
(Shoreham Nuclear Power Station, Unit 1), CLI-84-8, 19 NRC 1154, 1156 n.3 (May 16, 1984); see also United States Department of Energy (Clinch River Breeder Reactor Plant), CLI-83-1, 17 NRC 1, 4-6 (Jan. 5, 1983) (and cases cited therein). In late 1985, when NRC promulgated the present version of the § 50.12, it made clear that exemptions should not be widespread. 50 Fed. Reg. 50,764, 50,765 (Dec. 12, 1985) ("the Commission will exercise its discretion to limit exemptions in any particular area if the 'exceptions' to the rule threaten to erode the rule itself.").
ENO's pending exemption request ignores this NRC precedent.
ENO's 2009 request for wholesale exemptions from the Appendix R fire safety requirements demonstrate that it has not seriously explored how it could come into actual compliance with the federal regulations contained in 10 C.F.R. § 50.48, Appendix R,Section III.G.2. ENO has not informed the State (or apparently NRC) about any efforts to come into compliance or any credible analysis about the steps to come into such compliance.
CONCLUSION For the above reasons, the Attorney General requests NRC to immediately issue an order:
(1) identifying the violations of C.F.R. § 50.48, Appendix R, Paragraph III, F and G that exist as of the date of this petition at Indian Point Unit 1, Indian Point Unit 2, and Indian Point Unit 3; (2) compelling ENO and its affiliates to comply on or before September 20, 2011 with the requirements contained in 10 C.F.R. § 50.48, Appendix R, Paragraph III, F and G for all the fire zones in Indian Point Unit 2 and Indian Point Unit 3 and any Indian Point Unit 1 fire zone or system, structure, or component relied on by Indian Point Unit 2 or Indian Point Unit 3; (3) convene an evidentiary hearing before the Commissioners to adjudicate the violations by ENO and its affiliates of C.F.R. § 50.48, Appendix R, Paragraph III, F and G at Indian Point Unit 1, Indian Point Unit 2, and Indian Point Unit 3.
Respectfully submitted, Eric T. Schneiderman Attorney General State of New York ATTACHMENT INDIAN POINT UNIT 2 LIST OF FIRE ZONES THAT RELY ON OPERATOR MANUAL ACTIONS TABLE 1 FROM ENO COMMUNICATION NL-09-031
NL-09-031 Docket No. 50-247 Page 14 of 34 Table 1 IP2 Fire Hazards Analysis Summary
/+For Appendix R, Paragraph III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Equiv.
Category Fire Detection Fixed Fire Suppression Manual Fire Adjacent Manual Area Zone Fire Suppression Suppression Severity Type Coverage Type Coverage (see Note 1)
Equipment Fire (min)
(see Note 1)
Zone C
23 25 Low Ionization Area Wide None N/A CO2 Hydrant 900 F
5A
.108 Moderate None N/A None N/A None C02 7A Hose Station F
6 38 Low Ionization Area Wide None N/A None C02 7A Hose Station F
7 38 Low Ionization Area Wide None N/A None CO 2 7A Hose Station F
7A 58 Low-Ionization Area Wide None N/A C02 Wheeled Dry Chem Hose Stations F
8 38 Low Ionization Area Wide None N/A None C02 7A Wheeled Dry Chem Hose Station F
BA 31 Low None N/A None -
N/A None C02 7A I
_Hose Station F
9A 31 Low None N/A None N/A None C02 7A Hose Station F
10A 7
Low.
None N/A None N/A None C02 7A Hose Station F
11A 86 Moderate None N/A None N/A None C02 7A Hose Station F
20A 4
Low None N/A None N/A None C02 27A Hose Station F
21A 6
LOw None N/A None N/A None C02 27A Hose Station F
22A 9
Low None N/A None N/A None C02 27A Hose Station F
23A 8
Low None N/A None N/A None C02 27A I
_Hose Station
NL-09-031 Docket No. 50-247 Page 15 of 34 Table 1 IP2 Fire Hazards Analysis Summary
/+For Appendix R, Paragraph III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Equiv.
Category Fire Detection Fixed Fire Suppression Manual Fire Adjacent Manual Area Zone Fire Suppression Suppression Severity Type Coverage Type Coverage (see Note 1)
Equipment Fire (min)
(see Note 1)
Zone F
24A 45 Low None N/A None N/A None C02 27A Hose Station F
25A 22 Low None N/A None N/A None C02 27A Hose Station F
26A 3
Low None N/A None N/A None C02 27A Hose Station F
27A 91 Moderate Ionization Area Wide None N/A C02 Hose Stations F
28A 6
Low None N/A None N/A None C02 27A Hose Station F
33A 107 Moderate None N/A None N/A None C02 27A Hose Station F
59A 353 High Thermistor Charcoal Filters Deluge PAB and C02 Water Containment Ionization Outside Spray Ventilation Charcoal Filter Charcoal Enclosure Filters H
70A 25 Low Ionization RCPs 23&24 None N/A None" C02 76A Hose Station 77A H
71A 33 Low Ionization RCPs 21&22 None N/A None C02 76A Hose Station 72A H
72A 24 Low None N/A None N/A C02 Hose Station H
75A 79 Moderate Ionization N/A None N/A None C02 72A Hose Station H
76A 101 Moderate None N/A None N/A C02 Hose Station 77A H
77A 116 Moderate None N/A None N/A C02 I
I_
I Hose Station H
78A 10 Low None N/A None N/A None C02 76A I
I I
I I
I Hose Station 72A
NL-09-031 Docket No. 50-247 Page 16 of 34 Table 1 1P2 Fire Hazards Analysis Summary
/+For Appendix R, Paragraph III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Equiv.
Category Fire Detection Fixed Fire Suppression Manual Fire Adjacent Manual Area Zone Fire Suppression Suppression Severity Type Coverage Type Coverage (see Note 1)
Equipment Fire
.(min)
(see Note 1)
Zone H
80A 19 Low None N/A None N/A CO2 Hose Station 72A H
81A 16 Low None N/A None N/A CO2 Hose Station 72A H
82A 18 Low None N/A None N/A CO2 Hose Station 77A H
83A 19 Low None N/A None N/A CO2 Hose Station 77A H
84A 20 Low None N/A None N/A CO2 Hose Station 72A H
85A 60 Low None N/A None N/A CO2 Hose Station 72A H
86A 1 -
Low None N/A None N/A None CO2 87A Hose Station H
'87A 23 Low None N/A None N/A CO2 Hose Stations J
16 3,051 High Thermal Clean and Dirty Automatic Clean and None CO2 47A Oil Storage Foam Dirty Oil Hose Stations (foam Tanks Spray Storage Tanks and water)
J 17 1,143 High Thermal Turbine Lube Automatic Turbine Lube None CO2 47A Oil Reservoir Foam Oil Reservoir Hose Stations (foam Spray and water)
J 18 363 High Thermal Turbine Lube Automatic Turbine Lube None CO2 47A Oil Conditioner Foam Oil Conditioner Hose Stations (foam Spray and water)
J 19 18 Low None N/A None N/A None CO2 44A Hose Stations (foam 46A and water)
J
- 20.
572 High Thermal Boiler Feed Automatic Boiler Feed None C02 44A Pump Oil Foam Pump Oil Hose Stations (foam 46A Console and Spray Console and and water)
J 21 22 Low Thermal Hydrogen Seal Automatic Hydrogen Seal None CO 2 44A Oil Unit Foam Oil Unit Foam Hose Station 43A Spray
a, NL-09-031 Docket No. 50-247 Page 17 of 34 Table 1 IP2 Fire Hazards Analysis Summary
/+For Appendix R, Paragraph III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Equiv.
Category Fire Detection Fixed Fire Suppression Manual Fire Adjacent Manual Area Zone Fire Suppression Suppression Severity Type Coverage Type Coverage (see Note 1)
Equipment Fire (min)
(see Note 1)
Zone J
25 48 Low None N/A None
- N/A None CO 2 270 1
Hose Station 2041 J
39A 132 Moderate None N/A Automatic Computer CO2 Wet Pipe Office Hose Station Sprinkler J
40A 81 Moderate None N/A None N/A CO2 Dry Chemical Hose Station J
41A 46 Low None N/A None N/A CO2 Wheeled Dry Chem Hose Station J
42A 2
Low None N/A None N/A CO2 Dry Chemical Hose Station J
43A 61 Low None N/A None N/A CO2 Wheeled Dry Chem Hose Stations (foam
& water)
J 44A 30 Low None N/A None N/A CO2 Hose Station J
45A 15 Low None N/A Automatic Boiler Feed CO2 Foam Pump Oil Hose Station (foam Spray Console
& water)
J 46A 42 Low None N/A None N/A Hose Station CO 2 47A J
47A 10 Low None N/A None N/A CO2 Foam Hose Stations J
48A 11 Low None N/A None N/A CO2 Hose Stations (water
& foam)
I
NL-09-031 Docket No. 50-247 Page 18 of 34 Table 1 IP2 Fire Hazards Analysis Summary
/+For Appendix R, Paragraph II.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Equiv.
Category Fire Detection Fixed Fire Suppression Manual Fire Adjacent Manual Area Zone Fire Suppression Suppression Severity Type Coverage Type Coverage (see Note 1)
Equipment Fire (min)
(see Note 1)
Zone J
49A 2
Low None N/A None N/A None C02 39A I
_Hose Station J
50A 44 Low None N/A None N/A C02 Hose Stations J
.51A 1
Low None.
N/A.
None N/A CO2 Hose Station 50A J
52A 149 Moderate None N/A None N/A C02 Wheeled Dry Chem Hose Station J
53A 75 Low None N/A None N/A CO2 Hose Station 52A J
64A
<1 Low None N/A None N/A None Hydrants 900 J
115 74 Low Ionization CCR Panels, None N/A C02 Hose Stations 141 Exhaust Ducts Pressurized Water 201 J
130 1
Low None N/A None N/A None C02 141 Hose Station 540 J
140 3
Low Ionization Return Air
. None N/A C02 Hose Stations 141 Ducts 201 J
141 1
Low None N/A None N/A Hose Stations J
150 2
Low None N/A None N/A Pressurized Water Hose Station 141 J
160 15 Low Ionization Cabinets /
None N/A C02 Hose Station 141 Ceiling J
170 24 Low Ionization Cabinets /
None N/A C02 Hose Stations 141 Ceiling.
201 J
171 39 Low Ionization N/A None N/A None C02 170 Hose Stations 141 201 J
180 5
Low None N/A None N/A C02 Hose Stations 141 Dry Chemical 201 J
200 52 Low None N/A None N/A C02 Hose Station 201 Pressurized Water
NL-09-031 Docket No. 50-247 Page 19 of 34 Table 1 1P2 Fire Hazards Analysis Summary
/+For Appendix R, Paragraph III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Equiv.
Category Fire Detection Fixed Fire Suppression Manual Fire Adjacent Manual Area Zone Fire Suppression Suppression Severity Type Coverage Type Coverage (see Note 1)
Equipment Fire (min)
(see Note 1)
Zone J
201
<1 Low None N/A None N/A Hose Stations J
210 53 Low None N/A None N/A C02 Hose Station 201 Pressurized Water J
220 102 Moderate None N/A None N/A C02 Hose Station 201 Pressurized Water J
230 56 Low None N/A None N/A CO2 Hose Station 201
_Pressurized Water J
240 87 Moderate None N/A Automatic Throughout C02 Hose Station 201 Wet Pipe Office Areas Pressurized Water 244 Sprinkler Dry Chemical J
241 20 Low Thermistor Charcoal Filter Manual Charcoal Filter C02 Hose Station 244 Enclosure Closed Enclosure Dry Chemical Head Water Spray J
242 11 Low None N/A None N/A Pressurized Water Hose Station 201 J
243 1
Low None N/A None N/A Dry Chemical Hose Station J
244 1
Low None N/A None N/A Hose Stations
NL-09-031 Docket No. 50-247 Page 20 of 34 Table 1 IP2 Fire Hazards Analysis Summary
/+For Appendix R, Paragraph III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Equiv.
Category Fire Detection Fixed Fire Suppression Manual Fire Adjacent Manual Area Zone Fire Suppression Suppression Severity Type Coverage Type Coverage (see Note 1)
Equipment Fire (min)
(see Note 1)
Zone J
250 66 Low Ionization Office Areas Automatic Computer CO2 Hose Stations 201 Preaction Room, Repair Pressurized Water 243 Sprinkler and Parts 244 Rooms #1 &
- 2, and Tape Library Automatic TSC Office Wet Pipe Area, NRC Sprinkler Office Area, Central Files Work Area J
251 14 Low None N/A Automatic Radwaste CO 2 Hose Stations 201 Wet Pipe Office Area Pressurized Water 243 Sprinkler Dry Chemical 244 J
252 112 Moderate None N/A Automatic Area Wide Dry Chemical Hose Station 243 Wet Pipe Sprinkler J
253 1,420 High None N/A Automatic Area Wide Dry Chemical Hose Station 243 Wet Pipe Sprinkler J
254 59 Low None N/A None N/A Dry Chemical Hose Station 243 J
260
<1 Low None N/A None N/A None CO2 160 Hose Station 141 243 J
270 10 Low None N/A None N/A CO2 Hose Stations 201 Dry Chemical 243 244 J
271 17 Low None N/A None N/A None Dry Chemical 270 I
I I
Hose Station 201
NL-09-031 Docket No. 50-247 Page 21 of 34 Table 1 1P2 Fire Hazards Analysis Summary
/+For Appendix R, Paragraph III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Equiv.
Category Fire Detection Fixed Fire Suppression Manual Fire Adjacent Manual Area Zone Fire Suppression Suppression Severity Type Coverage Type Coverage (see Note 1)
Equipment Fire (min)
(see Note 1)
Zone J
272 47 Low Ionization /
UPS room Automatic UPS room CO2 Hose Station 243 Thermal Preaction Sprinkler J
273 47 Low None N/A None N/A CO2 Hose Stations 201 244 J
274 42 Low None N/A None N/A CO2 Hose Station 244.-
Dry Chemical J
275 91 Moderate None N/A None N/A Dry Chemical Hose Station 243 J
280 523 High None N/A Automatic Former Oil CO2 Hose Stations 201 Wet Pipe
.Storage Room Dry Chemical 243 Sprinkler and Tool Pressurized Water 244 Room J
350 15 Low None N/A Automatic Work Control Pressurized Water Wet Pipe Center and Hose Station Sprinkler One Stop Shop J
360 21 Low None N/A Automatic I&C M&TE CO2 Wet-Pipe Office Dry Chemical Sprinkler Hose Station J
361 28 Low None N/A None N/A CO2 Hose Stations 244 Dry Chemical 453 J
362 3
Low None N/A None N/A None Dry Chemical 360
-. _Hose Station 453 J
370 10 Low None N/A Automatic Unit 1 Turbine CO 2 Wet Pipe Building El. 15' Dry Chemical Sprinkler Pressurized Water Hose Station I
J
.371 9
Low None N/A None N/A CO 2 Hose Station 244
NL-09-031 Docket No. 50-247 Page 22 of 34 Table 1 IP2 Fire Hazards Analysis Summary
/+For Appendix R, Paragraph III.G.2 Fire Areas In Which OMAs Are Credited Fire Fire Equiv.
Category Fire Detection Fixed Fire Suppression Manual Fire Adjacent Manual Area Zone Fire Suppression Suppression Severity Type Coverage Type Coverage (see Note 1)
Equipment Fire (min)
(see Note 1)
Zone J
372 81 Moderate None N/A Automatic Area Wide CO 2 Wet Pipe (including Dry Chemical Sprinkler within pallet Pressurized Water storage racks)
Hose Station J
380 4
Low None N/A Automatic North Portion CO 2 Wet Pipe of the fire zone Dry Chemical Sprinkler (partial)
Hose Stations J
381 18 Low None N/A Automatic Area Wide None C02 380 Wet Pipe Hose Station Sprinkler I J
450 27 Low None N/A None N/A CO2 Hose Station 452 I_
Pressurized Water J
451 6
Low None N/A None N/A CO2 Hose Station 452 J
452 1
Low None N/A None N/A Hose Stations J
453 1
Low None N/A None N/A Hose Stations J
460 68 Low None N/A None N/A C02 Hose Stations 452 Dry Chemical 453 Pressurized Water J
470 7
Low None N/A None N/A CO 2 Hose Stations 452 Dry Chemical 453 Pressurized Water J
480 39 Low Ionization Telephone Automatic Kitchen Area CO2 Hose Stations 452 Equipment Wet Pipe Dry Chemical 453 Room and Sprinkler Pressurized Water Cafeteria Dry Kitchen Hood Chemical Exting.
System J
500
<1 Low None N/A None N/A C02 Hose Station 452
NL-09-031 Docket No. 50-247
.Attachment 2 Page 23 of 34 Table 1 IP2 Fire Hazards Analysis Summary
/+For Appendix R, Paragraph III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Equiv.
Category Fire Detection Fixed Fire Suppression Manual Fire Adjacent Manual Area Zone Fire Suppression Suppression Severity Type Coverage Type Coverage (see Note 1)
Equipment Fire (min)
(see Note 1)
Zone J
510 4
Low None N/A None N/A CO2 Hose Station 452 J
520 19 Low None N/A None N/A CO2 Hose Station 452 Pressurized Water J
530 2
Low None N/A None N/A Hose Stations J
540 34 Low None N/A None N/A CO 2 Hose Station 452 Dry Chemical Pressurized Water J
550
<1 Low Ionization Area Wide None N/A CO2 Hose Station 452 J
560 3
Low None.
N/A None N/A CO2 Hose Station 452 Pressurized Water J
600 1,902 High None N/A None N/A None Hydrants 900 J
610 8
Low Thermal Hydrogen Automatic Maintenance CO2 Hydrants 900 Storage Bank Wet Pipe Library Dry Chemical Sprinkler Pressurized Water Deluge Hydrogen Water Storage Bank Spray J
700 62 Low None N/A None N/A CO2 Hose Stations Stairwells Hose Station 8 & 9 J
710 337 High None N/A Automatic Oil & Mixed None CO2 Stairwell 9 Wet Pipe Waste Storage Hose Station Sprinkler Room J
720 2
Low None N/A None N/A.
C02 Hose Stations Stairwells 1_
8&9 J
730 51 Low None N/A None N/A CO2 Hose Station J
740
<1 Low None N/A None N/A None CO2 Stairwells
'___Hose Stations 8 & 9
NL-09-031 Docket No. 50-247 Page 24 of 34 Table 1 1P2 Fire Hazards Analysis Summary
/+For Appendix R, Paragraph III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Equiv.
Category Fire Detection Fixed Fire Suppression Manual Fire Adjacent Manual Area Zone Fire Suppression Suppression Severity Type Coverage Type Coverage (see Note 1)
Equipment Fire (min)
(see Note 1)
Zone J
750 15 Low Ionization CCR and None N/A CO2 corridor outside Hose Station Fire Zone 710 Wheeled Dry Chem J
760
<1 Low None N/A None N/A None C02 Stairwells Hose Stations 8 & 9 J
770 1
Low None N/A None N/A None C02 Stairwells Hose Stations 8 & 9 J
780 10 Low None N/A None N/A C02 Dry Chemical
- J 790 25 Low None N/A None N/A CO 2 Dry Chemical Hose Station J
800
<1 Low Flame Interim Onsite None N/A None Hose Stations Stairwell 1 Storage Facility
& FHB J
910
<1 Low Thermistor Utility Tunnel None N/A CO2 Hose Stations K
60A
- 1.
Low None N/A None N/A C02 Hydrants 900 K
61A 1
Low None N/A None N/A None C02 65A I
Hydrant 900 K
62A 1
Low None N/A None N/A None C02 23 Hydrant 900 K
65A 5
Low None N/A None N/A CO2 Hydrants 900 Hose Station 52A P
1 2
Low Ionization Area Wide None N/A None C02 8
Hose Station 7A YD 55
<1 Low None N/A None N/A C02 YD 55A Note 2 Thermistor 21 Main Deluge 21 Main None Hydrants 900 Transformer Water Transformer Spray
NL-09-031 Docket No. 50-247.
Page 25 of 34 Table 1 IP2 Fire Hazards Analysis Summary
/+For Appendix R, Paragraph III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Equiv.
Category Fire Detection Fixed Fire Suppression Manual Fire Adjacent Manual Area Zone Fire Suppression Suppression Severity Type Coverage Type Coverage (see Note 1)
Equipment Fire (min)
(see Note 1)
Zone YD 56A Note 2 Thermistor 22 Main Deluge 22 Main None Hydrants 900 Transformer Water Transformer Spray YD 57A Note 2 Thermistor Unit Auxiliary Deluge Unit Auxiliary None Hydrants 900 Transformer Water Transformer Spray YD 58A Note 2 Thermistor Station Auxiliary Deluge Station None Hydrants 900 Transformer Water Auxiliary Spray Transformer YD 900 Note 2 Thermistor Carbon Filter Deluge Spare Hydrants pre-staged 11/"
141 on CCR Water Transformer Hose Houses jumper fire hose and Ventilation Spray CCR charcoal filter Room roof deluge inlet stop valve FP-1 105 at the hose station on elevation 72'-0" YD 920 Note 2 None N/A Wet Pipe Area Wide CO2 Hydrants 900 I
I Sprinkler I___
I_
Dry Chemical Hose Houses NOTES 1.
In this column, CO2, Dry Chemical, Wheeled Dry Chem[ical], Pressurized Water, and Halon are types of Extinguishers - there is at least one in the zone when listed for a zone. Extinguishers in Area H are stored outside Containment during normal operation. Hose stations are water unless otherwise noted.
- 2. Combustible loading is not computed for the outdoor (YD) areas given the absence of compartmentalization and the recognition that heat and products of combustion from a fire in any of these zones will be dissipated to the outdoor environment, with the principal challenge to adjacent SSCs resulting from radiant heat flux from the postulated fire scenario.
ATTACHMENT INDIAN POINT UNIT 3 LIST OF FIRE ZONES THAT RELY ON OPERATOR MANUAL ACTIONS TABLE 1 FROM ENO COMMUNICATION NL-09-032
NL-09-032 Docket No. 50-286 Page 16 of 42 Table 1 IP3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv.
Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min)
Type Coverage Type Coverage (see Note 1)
(see Note 1)
AFW-6 23 Low 19.0 Ionization Area Wide Automatic Area Wide CO2 Wet Pipe Dry Chemical Sprinklers ETN-4 7A Low 59.0 Thermal/
Cable Trays/
Automatic Cable Trays CO2 Ionization Area Wide Preaction Only Dry Chemical Water Spray ETN-4 60A Low 68.0 Thermal/
Cable Trays/
Automatic Cable Trays CO2 Ionization Area Wide Preaction Only Dry Chemical Water Spray ETN-4 73 Low 11.0 None N/A None N/A CO 2 ETN-4 73A Moderate 96.0 Thermal/
Cable Trays/
Automatic Cable Trays CO 2 Ionization Area Wide Preaction Only Dry Chemical Water Spray ETN-4 74A Low 28.0 Thermal/
Cable Trays/
Automatic Cable Trays CO2 Ionization Area Wide Preaction Only Dry Chemical Water Spray_
PAB-2 1
Low 8.0 Ionization Area Wide None N/A CO2 PAB-2 1A Low 9.0 Ionization Area Wide None N/A None CO 2 1
PAB-2 2
Low 35.0 Ionization Area Wide None N/A Hose Station CO 2
PAB-2 2A Low 15.0 Ionization Area Wide None N/A Dry Chemical PAB-2 3
Low 69.0 Ultraviolet Area Wide None N/A None CO2 12A I
Hose Station 14A PAB-2 3A Low
<1.0 None N/A None N/A None CO2 2
1_
Hose Station PAB-2 4
Low 74.0 Ultraviolet Area Wide None N/A None CO2 12A Hose Station 14A
NL-09-032 Docket No. 50-286 Page 17 of 42 Table 1 IP3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv.
Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min)
Type Coverage Type Coverage (see Note 1)
(see Note 1)
PAB-2 4A Moderate 87.0 None N/A None N/A Hose Station Dry Chemical PAB-2 5
Moderate 85.0 Ionization Area Wide None N/A None Hose Stations 17A C02 A
PAB-2 5A Low 6.0 None N/A None N/A None None PAB-2 6
Moderate 84.0 Ionization Area Wide None N/A None Hose Stations 17A CO2 PAB-2 6A Moderate 75.0 None N/A None N/A None Hose Station 4A Dry Chemical PAB-2 7
Moderate 77.0 Ionization Area Wide None N/A None Hose Stations 17A C0 2 PAB-2 8
Low 19.0 Ionization Area Wide None N/A CO2 PAB-2 8A Low 16.0 None N/A None N/A None Dry Chemical 12A C02 14A Hose Station PAB-2 9
Low 10.0 None N/A None N/A None Hose Station 4A Dry Chemical PAB-2 9A Low 60.0 Ionization Area Wide None N/A None C02 12A Hose Station 14A PAB-2 10A Low 23.0 None N/A None N/A None C02 12A Hose Station 14A PAB-2 11A High 166.0 None N/A None N/A None C02 12A I
I Hose Station 14A PAB-2 12A Low 42.0 Ionization 15'-0" Corr.
None N/A C02 PAB-2 13A Low 37.0 None N/A None N/A None C02 12A I
I I
I Hose Station 14A
NL-09-032 Docket No. 50-286 Page 18 of 42 Table 1 1P3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv.
Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min)
Type Coverage Type Coverage (see Note 1)
(see Note 1)
PAB-2 14A Low 48.0 Ionization Area Wide Manual Separates Hose Station Water Spray PAB-2 (door)
Curtain and Trans.
Yard PAB-2 15A Moderate 95.0 None N/A None N/A None CO2 12A Hose Station 14A PAB-2 16A High
> 3 Hours None N/A None N/A None CO2 12A Hose Station 14A PAB-2 17A Low 38.0 Ionization Area Wide None N/A Hose Stations CO2 Dry Chemical_
Ionization Under Floor, MCC Area Ultraviolet MCC Area PAB-2 18A Low 66.0 None N/A None N/A None Hose Stations 17A CO2 Dry Chemical PAB-2 19A Low 26.0 None N/A None N/A None Hose Stations 17A CO2 Dry Chemical PAB-2 20A Moderate 92.0 None N/A None N/A None Hose Stations 17A C0 2 Dry Chemical PAB-2 21A Moderate 125.0 Ionization &
Area Wide None N/A None Hose Stations 17A Ultraviolet CO2 I_
I I
I Dry Chemical PAB-2 22A Low 29.0 None N/A None N/A CO2 I
I_
__I Dry Chemical
NL-09-032 Docket No. 50-286 Page 19 of 42 Table 1 1P3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv.
Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min)
Type Coverage Type Coverage (see Note 1)
(see Note 1)
PAB-2 23A High 152.0 None N/A None N/A None C02 22A Dry Chemical 22A C02 24A PAB-2 24A Low 30.0 None N/A None N/A CO2 PAB-2 25A Moderate 91.0 None N/A None N/A None Hose Stations 27A SC002 PAB-2 26A High 152.0 None N/A None N/A None Hose Stations 27A
_C02 PAB-2 27A Low 15.0 None N/A None N/A Hose Stations C02 PAB-2 28A Moderate 115.0 None N/A None N/A None Hose Stations 27A C02 PAB-2 29A Moderate 127.0 None N/A None N/A None Hose Stations 27A C02 PAB-2 30A Moderate 108.0 None N/A None N/A None Hose Stations 27A C02 PAB-2 31A Low 63.0 None N/A None N/A None Hose Stations 27A CO_
PAB-2 32A Low 64.0 None N/A None N/A None Hose Stations 27A C02 PAB-2 58A Low 16.0 Ionization PAB 41' None N/A None Dry Chemical 2A Corridor Hose Stations 59A CO 59A PAB-2 59A Low 5.0 Ionization Area Wide None N/A Hose Stations C02 PAB-2 61A Low
< 1.0 None N/A None N/A None None PAB-2 62A Low 15.0 None N/A None N/A Dry Chemical None
NL-09-032 Docket No. 50-286 Page 20 of 42 Table 1 1P3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv.
Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min)
Type Coverage Type Coverage (see Note 1)
(see Note 1)
PAB-2 63A Low 38.0 None N/A None N/A None Hose Stations 17A CO2 PAB-2 68A Low 42.0 None N/A None N/A None None PAB-2 69A Moderate 110.0 Ionization Area Wide None N/A None C02 12A Hose Station 14A PAB-2 79 Low 25.0 None N/A None N/A None Dry Chemical 8A PAB-2 79A Low 58.0 None N/A None N/A None C02 59A Hose Station PAB-2 88A Moderate 112.0 Ionization 72'-0" El. -
Manual Containment Hose Stations Filter Area Deluge Purge Exh.
C02 Water Spray Charcoal Filter Dry Chemical
-- Manual PAB Exhaust Deluge Charcoal Filter Water Spray Manual Cont. Pressure Deluge Relief Charcoal Water Spray Filter PAB-2 89A Low 41.0 None N/A None N/A C02 PAB-2 107 Low 14.0 Ionization/
el. 44'-6" Area None N/A Hose Stations Thermal Wide Ion. / el.
C02 54' & 73' Area Dry Chemical Wide Thermal Pressurized Water PAB-2 127 Low 50.0 Ionization Area Wide None N/A C02 Pressurized Water PAB-2 128 Low 22.0 Thermal Area Wide Automatic Area Wide C02 Pre-Action Dry Chemical Sprinklers PAB-2 622 Low 43.0 None N/A None N/A None Dry Chemical 74A
NL-09-032 Docket No. 50-286 Page 21 of 42 Table 1 1P3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv.
Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min)
Type Coverage Type Coverage (see Note 1)
(see Note 1)
TBL-5 16 High
>3 hours Thermal Area Wide Automatic Lube Oil None Hose Stations -
42A I
I Foam Spray Storage Tank water & foam TBL-5 17 High
>3 hours Thermal Area Wide Automatic Lube Oil None Hose Stations -
42A Foam Spray Reservoir, water & foam Htrs, Separator TBL-5 18 High
>3 hours None N/A Automatic Area Wide None Hose Stations -
42A Wet Pipe water & foam Sprinklers TBL-5 19 Low 24.0 None N/A Automatic Area Wide None Hose Station 37A, 38A Wet Pipe CO2 39A, 41A Sprinklers Dry Chemical TBL-5 20 High
>3 hours Thermal Area Wide Automatic Area Wide Foam Hose Stations Foam Spray (Boiler Feed Pump Oil Console & Oil Accumulators)
TBL-5 21 Low 30.0 Thermal Area Wide Automatic Area Wide (H2 None Hose Stations -
37A Foam Spray Seal Oil Unit) water Hose Station -
foam CO2 Dry Chemical
NL-09-032 Docket No. 50-286 Page 22 of 42 Table 1 1P3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv.
Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (mn)
Type Coverage Type Coverage (see Note 1)
(see Note 1)
TBL-5 37A Low 53.0 Ionization/
MCC 34, Automatic Area Wide Hose Stations -....
Thermal 6.9KV Wet Pipe overhead Water Switchgear Sprinklers (except Swgr Hose Station - Foam
/Battery &
Area), including C02 Charger Rm Battery &
Dry Chemical Charger Rms Automatic Separates Water Spray TBL-5 & Trans.
Exposure Yard Protection TBL-5 38A Low 15.0 Ionization MCC 32 Automatic Area Wide Hose Station Wet Pipe overhead CO2 Sprinklers I Dry Chemical
NL-09-032 Docket No. 50-286 Page 23 of 42 Table 1 IP3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv.
Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min)
Type Coverage Type Coverage (see Note 1)
(see Note 1).
TBL-5 39A Low 37.0 Ionization MCC 33 Automatic Area Wide None Hose Stations -
40A Wet Pipe overhead Water Sprinklers Hose Station -
Foam C02 Wheeled Class D Thermal BFP Oil Automatic Boiler Feed Console &
Foam Spray Pump Oil BFP Drive Console Turb. HP Bgs.
Manual Turbine Water Spray Building Boiler Feed Pumps Automatic Local App.,
C02 Drive Turb. HP Bgs, Boiler Feed Pumps TBL-5 40A Low 7.0 None N/A Automatic Area Wide Hose Stations -....
Wet Pipe overhead water & foam Sprinklers C02 Wheeled Class D Dry Chemical TBL-5 41A Low 9.0 None N/A Automatic Area Wide Hose Station Wet Pipe overhead C02 Sprinklers Dry Chemical TBL-5 42A Low 24.0 Ionization MCC 35 Automatic Area Wide Hose Stations -
Wet Pipe overhead water & foam I Sprinklers
NL-09-032 Docket No. 50-286 Page 24 of 42 Table 1 IP3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv.
Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Coverage Type Coverage Suppression Equipment Fire Zone (min)
Type (see Note 1)
(see Note 1)
TBL-5 43A Low 33.0 None N/A Automatic Area Wide Hose Stations Wet Pipe overhead CO2 Sprinklers Halon Pressurized Water Automatic Separates Water Spray TBL-5 and Exposure Trans. Yard Protection TBL-5 44A Low 13.0 None N/A None N/A None Hose Stations 43A CO2 Halon Pressurized Water TBL-5 45A Low 3.0 None N/A None N/A None TBL-5 46A Low 9.0 None N/A Automatic Area Wide Hose Stations Wet Pipe overhead CO 2 Sprinklers Dry Chemical TBL-5 47A Low 21.0 None N/A Automatic Area Wide Hose Station Wet Pipe overhead C02 Sprinklers Dry Chemical Thermal R4D4 Automatic R4D4 Separator Foam Spray Separator TBL-5 48A Low
< 1.0 None N/A None N/A None Hose Station 47A C02 Dry Chemical
NL-09-032 Docket No. 50-286 Page 25 of 42 Table 1 1P3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv.
Fire Detection Fixed Fire Suppression Manual Adjacerit Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min)
Type Coverage Type Coverage (see Note 1)
(see Note 1)
TBL-5 49A Low 7.0 Ionization/
Office/Exciter Automatic Total Flooding, Hose Stations Thermal Enclosure, C02 Exciter CO2 incl. Bgs 10 &
Enclosure and Dry Chemical 11 Bearings 10 & Wheeled Dry Chem 11 Halon Foam Pressurized Water TBL-5 50A Low
< 1.0 Thermal Governor Automatic Governor Hose Stations Housing & Oil Preaction Housing & Oil CO2 Lines & TG Spray Lines & TG Dry Chemical Bearings 1-9 Bearings 1-9 Manual C02 Local App., TG Bgs 1,2,3 & MS Valves in Governor Enclosure Manual C02 Local App., TG Bas 4,5,6 & 7 Manual C02 Local App., TG Bearings 8 & 9 TBL-5 51A Low 6.0 None N/A None N/A Hose Stations CO 2
Thermal TB pipe Automatic TB pipe bridge bridge to AFW Water Spray to AFW Pump Pump Bldg Curtain Bldg TBL-5 52A Low 10.0 None N/A None N/A Dry Chemical
NL-09-032 Docket No. 50-286 Page 26 of 42 Table 1 IP3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv.
Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity T
Suppression Equipment Fire Zone (min)
Type Coverage Type Coverage (see Note 1)
(see Note 1)
TBL-5 53A Low 7.0 None N/A None N/A None Dry Chemical 52A Hose Station 54A TBL-5 54A Low 14.0 None N/A None N/A Hose Station TBL-5 57A Low 37.0 Thermal TB pipe Automatic TB pipe bridge Dry Chemical bridge to AFW Water Spray to AFW Pump Pump Bldg Bldg TBL-5 58 Low 67.0 None N/A None N/A None Hose House &
YARD-7 Hydrant TBL-5 59 Low 65.0 Ionization Area Wide Automatic Area Wide None Hose Station 38A Wet Pipe CO2
__Sprinklers Dry Chemical TBL-5 109 Low 32.0 Thermal Area Wide Automatic Area Wide CO 2 Wet Pipe Dry Chemical Sprinklers TBL-5 110 Low 12.0 Ionization Area Wide None N/A Hose Station CO 2 DryChemical TBL-5 111 Low 2.0 Thermal Area Wide Automatic Area Wide Dry Chemical Wet Pipe Sprinklers TBL-5 112 Low 2.0 Ionization Area Wide None N/A Hose Station CO 2
TBL-5 113 Low
< 1.0 Ionization Area Wide None N/A CO2 Dry Chemical TBL-5 114 Low 2.0 Ionization Area Wide None N/A Hose Station CO 2
YARD-7 22 Low 27.0 Photoelectric Area Wide None N/A Dry Chemical
NL-09-032 Docket No. 50-286 Page 27 of 42 Table 1 1P3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv.
Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min)
Type Coverage Type Coverage (see Note 1)
(see Note 1)
YARD-7 55A Low 2.0 Photoelectric Area Wide None N/A Hose Stations CO 2
YARD-7 56A Low 2.0 None N/A None N/A Adjacent Yard Hose House &
YARD-7 Hydrant Hydrant YARD-7 64A High
> 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> Thermal Area Wide Automatic Main Adjacent Yard Hose House &
YARD-7 Deluge Transformer 31 Hydrant Hydrant Water Spray XFMR Automatic Separates detectors Water Spray TBL-5 and actuate water Exposure Trans. Yard curtains Protection Automatic Separates Water Spray XFMR 31 and Curtain Unit Aux.
XFMR YARD-7 65A High
> 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> Thermal Area Wide Automatic Main Adjacent Yard Hose House &
YARD-7 Deluge Transformer 32 Hydrant Hydrant Water Spray Manual Separates Water Spray PAB-2 (door)
Curtain and Trans.
Yard
NL-09-032 Docket No. 50-286 Page 28-of 42 Table 1 iP3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv.
Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min)
Type Coverage Type Coverage (see Note 1)
(see Note 1)
YARD-7 66A High
> 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> Thermal Area Wide Automatic Unit Auxiliary Adjacent Yard Hose House &
YARD-7 Deluge Transformer Hydrant Hydrant Water Spray XFMR Automatic Separates detectors Water Spray TBL-5 and actuate water Exposure Trans. Yard curtains Protection Automatic Separates Water Spray XFMR 31 and Curtain Unit Aux.
XFMR YARD-7 67A High
> 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> Thermal Area Wide Automatic Station Adjacent Yard Hose House &
YARD-7 Deluge Auxiliary Hydrant Hydrant Water Spray Transformer Manual Separates Water Spray PAB-2 (door)
Curtain and Trans.
Yard YARD-7 90A Low 9.0 None N/A None N/A Hose Station C02 YARD-7 91A Low 9.0 None N/A None N/A Hose Station C02 YARD-7 92A Low
< 1.0 None N/A None N/A None Dry Chemical 96A YARD-7 93A Low
< 1.0 None N/A None N/A None Dry Chemical 96A YARD-7 94A Low
< 1.0 None N/A None N/A None C02 98A YARD-7 95A Low
< 1.0 None N/A None N/A None C02 98A YARD-7 96A Low 63.0 None N/A None N/A Dry Chemical YARD-7 97A Low 6.0 None N/A None N/A None CO2 98A
NL-09-032 Docket No. 50-286 Page 29 of 42 Table 1 1P3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv.
Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (mrin)
Type Coverage Type Coverage (see Note 1)
(see Note 1)
YARD-7 98A Low 6.0 None N/A None N/A C02 YARD-7 105A Low N/A None N/A None N/A None None YARD-7 106A Low N/A None N/A None N/A None None YARD-7 108 Low 9.0 None N/A None N/A None Hydrant &
YARD-7 Hose House YARD-7 115 Low 12.0 ThermaV Local Automatic Area Wide Hose Stations Photoelectric coverage only Wet Pipe C02 Sprinklers Pressurized Water Dry Chemical YARD-7 116 Low 24.0 Photoelectric Local Automatic Area Wide Hose Station coverage only Wet Pipe C02 Sprinklers Dry Chemical Pressurized Water YARD-7 117 Low 47.0 Photoelectric Local Automatic Total Flooding, Hose Stations coverage only Halon TSC Computer CO 2 Room Dry Chemical Pressurized Water Halon Manual TSC/OSC Water Spray Charcoal Filter YARD-7 118 Low 47.0 Photoelectric, Local None N/A Hose Stations Thermal and coverage only CO 2 Ionization inc. underfloor Pressurized Water computer area Dry Chemical
NL-09-032 Docket No. 50-286 Page 30 of 42 Table 1 1P3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv.
Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min)
Type Coverage Type Coverage (see Note 1)
(see Note 1)
YARD-7 119 Low 47.0 Thermal/
Local None N/A Hose Stations Photoelectric coverage only C02 Dry Chemical
-Pressurized Water YARD-7 120 Low 47.0 Photoelectric, Local Automatic Total Flooding, Hose Stations Thermal/
coverage only/
Halon Documents Dry Chemical Thermal Documents Vault Pressurized Water Vault Halon YARD-7 121 Low 47.0 Thermal/
Local Manual Filter Units AS-Hose Stations Photoelectric coverage only Water Spray FU-1,2,3 C02 Dry Chemical Pressurized Water Halon YARD-7 122 Low 47.0
- Thermal, Local None N/A Hose Station Photoelectric coverage only C02 Dry Chemical Pressurized Water Halon YARD-7 123 Low 47.0 Ionization Area Wide None N/A Hose Station C02 Dry Chemical Pressurized Water Halon YARD-7 125 Low 7.0 Ionization Area Wide Automatic Area Wide Hose Stations Wet Pipe C02 Sprinklers Dry Chemical Pressurized Water Halon
NL-09-032 Docket No. 50-286 Page 31 of 42 Table 1 IP3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv.
Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min)
Type Coverage Type Coverage (see Note 1)
(see Note 1)
YARD-7 126 Low 3.0 Ionization Area Wide Automatic Area Wide Hose Stations Wet Pipe CO2 Sprinklers Pressurized Water I
_Foam YARD-7 129 Low 30.0 Ionization/
Area Wide/
Automatic Area Wide Hose Stations Thermal Men's &
Wet Pipe C02 Women's Sprinklers Dry Chemical Rooms Pressurized Water YARD-7 130 Low 47.0 Ionization/
Area Wide/
Automatic Area Wide Hose Stations Thermal Men's Room Wet Pipe C02 I
I
& lunch room Sprinklers Pressurized Water YARD-7 131 High 177.0 Ionization &
Area Wide Automatic Total Flooding C02 Thermal Halon Dry Chemical YARD-7 131A High
>3 hours None N/A None N/A None Hose House &
YARD-7 Hydrant YARD-7 132 Low 38.0 Ionization/
Elec. Pump Automatic Area Wide, C02 Infrared Room/ Diesel Wet Pipe except Elec.
Dry Chemical Pump Room Sprinklers Fire Pump Rm YARD-7 133 Low
< 1.0 Ionization Area Wide &
None N/A C02 in Ctrl Panels Dry Chemical YARD-7 136 Low 0.0 None N/A None N/A None None YARD-7 222 Low N/A None N/A None N/A None Hose House &
YARD-7 Hydrant YARD-7 552 Low N/A None N/A None N/A None None YARD-7 553 Low N/A None N/A None N/A None None YARD-7 554 Low N/A None N/A None N/A None Hose House &
YARD-7 I
_Hydrant
4 NL-09-032 Docket No. 50-286 Page 32 of 42 NOTE
- 1. In this column, C0 2, Dry Chemical, Wheeled Dry Chem[ical], Wheeled Class D, Pressurized Water, Foam, and Halon are types of Extinguishers - there is at least one in the zone when listed for a zone. Extinguishers in Area CNT-1 are stored outside Containment during normal operation. Hose stations are water unless otherwise noted.