L-84-346, Forwards Rev 3 to Fire Hazard Analysis.Rev Includes New Exemptions & Changes to Existing Exemptions.Formal Disposition of Exemption Requested by Jan 1985,in Advance of NRC Audit Scheduled for Feb 1985

Forwards Rev 3 to Fire Hazard Analysis.Rev Includes New Exemptions & Changes to Existing Exemptions.Formal Disposition of Exemption Requested by Jan 1985,in Advance of NRC Audit Scheduled for Feb 1985

ML17215A662
Person / Time
Site:	Saint Lucie
Issue date:	11/28/1984
From:	Williams J FLORIDA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
L-84-346, NUDOCS 8412030336
Download: ML17215A662 (98)

Text

.REGULATORY FORMATION DISTRIBUTION S EM (RIDS)

ACCESSION NBR;8012030336 DOC ~ DATE; 8'/11/28 NOTARIZED:

NO FACIL:50-335 St ~ Lucie Planti Unit l~ Flor ida Power 8 Light Co ~

AUTH~ NAME AUTHOR AFFILIATION WILLIAMS'

~ W ~

Florida Power 8 Light Co, REC IP ~ NAME RECIPIENT AFFILIATION EISENHUT',D,G, Division of Licensing DOCKET' 05000335

SUBJECT:

Forwards Rev

3. to fire hazard analysis,Rev..includes new exemptiops 8, changes to existing exemptions. Formal.

disposition of exemption requested by Jan 1985~in advance of NRC audit scheduled for Feb 1985

'ISTRIBUTION CODEa A006D COPIES RECEIVED:LTR ENCL SIZE!

TITLEI OR Submittal: Fire Protection NOTES; OL+ 02/01/76 05000335 RECIPIENT ID CODE/NAME NRR ORB3 BC 01 COPIES LTTR ENCL 3

3 RECIPIENT ID CODE/NAME COPIES LTTR ENCL INTERNAL: ACRS 11 ELD/HDS2 IE/WHITNEYgL NRR WAMBACH NRR/DL D IR RGN2 3

3 1

0 1

1 1

0 1

1 1

ADM/LFMB 1

0 IE FILE 06 1

1 NRR FIORAVANT07 2'EB 09 2

2 REG FILE 04 1

EXTERNAL: LPDR NSIC 03 05 1

1 1

NRC PDR NTIS'2 1

1 1

1 TOTAL NUMBER OF COPIES REQUIRED:

LTTR 22 ENCL 19

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OX 14000, JUNO BEACH, FL 33408 Qllgz Office of Nuclear Reactor Regulation Attention:

Mr. Darrell G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 FLORIDAPOWER & LIGHTCOMPANY I'lovember 28, l984 L-84-346

Dear Mr. Eisenhut:

Re:

St. Lucie Unit 1 Docket No. 50-335 Fire Protection Attached is Revision 3 to the Fire Hazard Analysis for St. Lucie Unit 1.

The entire revised section of the Fire Hazard Analysis is included for ease of revision.

This revision to the Fire Hazard Analysis includes new exemptions as well as changes to the existing exemptions.

Alladditions and changes are identified by revision bars in the margins.

The Nuclear Regulatory Commission audit is presently scheduled for February, 1985.

Resolution of these exemptions will be an integral part of the audit.

Florida Power 4 Light requests that the Nuclear Regulatory Commission provide formal disposition of these exemption requests by the first week in January, 1985.

Your coorperation in this effort would be greatly appreciated.

Should you have any questions regarding this submittal, please advise.

Very truly yours, J.W. Williams, Jr.

Group Vice President Nuclear Energy Department JWW/SJR/dlr Attachment cc:

J.P. O'Reilly, Region II Harold F. Reis, Esquire 841203033b 841128 PDR ADOCK 05000335 PDR PEOPLE... SERVING PEOPLE

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FIRE.AREA "A" This fire area includes fire zones 77 (Train "A" Electric Penetration Area),

59 (Battery Room "A")

60 ("A" Switchgear Room),

and 44A ("A" Cable Penetration Area Extension) as shown on the attached drawings.

Essential equipment within this fire area is shown in the attached essential equipment list.

The following exemptions to Appendix R to 10CFR50 are requested:

Exemption Al An exemption is requested penetration No.

11 in the 19.00 ft, because no fire from Section III-G.2.a of Appendix R for wall

east, 3-hour fire barrier at fire zone'7, elevation damper is provided in the ventilation duct.

Evaluation Al Ionization type smoke detection system is provided as shown on drawings 8770-G-413.

2)

The duct penetration through the east barrier of fire zone 77 is being provided with a fire stop of approved 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rating.

Fire damage to the duct located in Fire Area "J" is precluded because the heavy gage'uct (which is 14 gage as compared to the 22 gage of a 3-hour rated fire damper),

and heavy duty support, metal heat transmission and dissipation characteristics and metal closure angles applies to the duct on both sides of the barrier would serve to render the 'ductwork impervious to expansion deformation or heat-failure for periods of expected fire duration.

While localized high off-gas temperatures can be expected in the immediate vicinity of a fire, air mixture dilution temperature at the duct, which is 18 ft above the floor, is not expected to reach high temperatures.

As the ventilation duct remains intact it is considered an extension of the Fire Barrier and thus the overall fire resistant integrity continues undiminished')

There is no more than 5 ft of duct in Fire Area "J" between penetration Nos ~

11 and 19.

In this. area the duct is'continuous with no registers and has a fire damper in penetration No. 19.

5)'ire Area Fire Area personnel transient "J" has negligible "J" is a Radiation access is limited, combustibles being combustible loading.

Controlled Area and therefore thus reducing the probability of introduced.

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0 Conclusion Al Based on our evaluation, the existing fire barrier provides adequate separation.

The installation of a fire damper in the ventilation duct at penetration No.

11 would not augment or materially enhance the safety of. the plant, since it would not aid in preventing fire migration between Fire Areas "A" and "J" ~

Therefore, we conclude, this is an acceptable exemption to Appendix R to 10CFR50, Section IIIW.2.a.

Exem tion A2 An exemption is requested from Section IIIW.2.a of Appendix R for exterior penetrations because no fire dampers or penetration seals are provided.

Evaluation A2 R3 1)

Fire Zone 59 has negligible combustible loading.,

2)

Ionization type smoke detection system is provided as shown on drawings 8770-G-413.

3)

Fire Area "A" as well as the outdoor area above the fire barrier is lightly trafficked, thus reducing the probability of transient combustibles being, introduced.

R3 4)

Roof-top fires are not a significant hazard based on the lack of combustible storage and heat dissipation from fires in transient combustibles.

5)

A steel missile shield enclosure for each roof-top ventilator provides additional fire protection.

6)

Exterior walls do not separate redundant trains of systems necessary to achieve and maintain hot shutdown.

R3 Conclusion A2

'ased on our evaluation, the existing barrier provides adequate separation.

The installation of fire dampers or penetration seals in exterior walls of Fire Area "A" would not augment or materially enhance the safety of the plant.

Therefore we conclude that this is an acceptable exemption from Appendix R to 10CFR50, Section III-G.2.a.

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Exem tion A3 An exemption is requested from Section III'-2.a of Appendix R because fire retardant coatings are not provided for the structural steel supporting the steel conduits which are wrapped to provide separation in accordance with Appendix R.

Evaluation A3 1)

Ionization type smoke detection system is provided as shown on drawing 8770-G-413.

2)

Portable fire extinguishers and a fire standpipe system with hose stations are available for use in the Area.

3)

Safety-related areas of the Reactor Auxiliary Building are provided with an early warning smoke detection system which provides both local indication and control room alarms')

Essential cable tray and conduits are designed to remain intact following a Safe Shutdown Earthquake (SSE).

There'fore, support capability is substantially greater than that required for dead weight only, such that in a nonearthquake condition, stresses developed within the supports will typically be less than one-fourth of allowable values.

This "overdesign" provides the support assembly with a significant inherent fire resistance.

R3 5)

Contact of the supports with a substantial heat sink such as 6

inches or more of concrete in a wall, ceiling or floor serves to significantly reduce temperatures in the steel supports at the points where loading is most critical.

Should a fire occur, temperatures developed within the steel members will not be uniformly distributed.

This has been recognized by the American Iron and Steel Institute (AISI) and verified in'ests performed by Ohio State University.

As stated in the AISI Fire Protection through Modern Buildin Codes:

(Fifth Edition 1981) "Substantial temperature differences, as great as

600F, (333c) have been recorded during standard fire tests between the upper and lower flanges of a beam.

This difference is accounted for by the direct contact of the upper flange of the beam with a concrete floor above."

Based on the above, deleterious fire effects are not considered probable for the in-situ support 'structures.

Conclusion A3 Based on our Evaluation, the provision of fire retardant coatings on the.

structural steel supports for the wrapped conduits would not augment or materially enhance the safety of the plant.

Therefore we conclude that this is an acceptable exemption from Appendix R to 10CFR50, Section III-G-2.a.

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Exem tion A4 A exemption is requested from Section IIIW.2.a of Appendix R for electrical penetrations to the containment from the RAB fire zone 77 (Train "A" Electrical Penetration Area) because no penetration fire seals are provided.

All of the penetrations are sealed air tight, however they do not constitute a

'ypical fire rated assembly.

l Evaluation A4 l.

Ionization type smoke detection is provided as shown on drawings 8770M-413.

2.

Portable fire extinguishers and a fire standpipe system with hose stations are available for use in this area.

3.

Electrical penetration nozzles and sleeves are sealed in the RAB side with' 1/2 inch thick by 20 inch diameter ASTM Grade A-36 plates over the sleeve opening (sleeve is Schedule 80 ASME SA 106 Gr.B and is housed in a 36 inch thick concrete shell) and fillet weld to embedded plate.

Weld is the same as used on penetration header plates'-36 plates are designed as Seismic Category I This seal has been air tested at

.25" W.G.

The 1 1/2 inch thick by 20 inch diameter ASTM Grade A-36 plate continuously welded over the sleeve opening forming this air tight seal, is equal to or better than a three hour fire rated assembly.

See FSAR Section

3. 8.

4.

Between the 36 inch thick concrete shell and the 3 5/8 inch thick reinforced steel containment, there is an annulus of 48 inches which the penetration passes through.

The cables are covered with a

12 inch diameter sleeve as they pass through the annulus'he annulus has negligible combustible loading.

5.

At the Reactor Containment Building side, electrical penetrations pass through a schedule 80 sleeve which is continuously welded to the 3 5/8 inch'hick reinforced steel containment (reinforced 3 5/8 inches for penetration purposes) on both sides.

The electrical penetrations are terminated approximately 8 inches beyond the steel containment.

A schedule 80 ASME SA 234 pipe cap is continuously welded as per ASME III, Class MC, to the penetration

sleeve, sealed and air tested at approximately 44 psid.

The schedule 80 sleeve continuously welded to both sides of the' 5/8 inch steel containment forming this air tight seal constitutes more than a

three hour fire rated assembly.

R3 Conclusion A4 Based on our evaluation the existing air tight electrical penetrations through the 36 inch concrete shell, the 48 inch annulus and the 3 5/8 inch thick reinforced steel containment plus the smoke detection and manual suppression systems in the area provides adequate protection of a fire migration.

The installation of penetration seals would not augment or materially enhance, the safety of the plant.

Therefore we conclude, this is an acceptable exemption to Appendix R to 10CFR50, Section III-G.2.a.

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FIRE AREA "B" This fire area is fire zone 57 (cable spread room) as shown on the attached drawings.

Essential equipment within this fire area is shown in the attached essential

'equipment list.

The following exemptions from Appendix R to 10CFR50 are'requested:

An exemption is requested from Section III-G.2a of Appendix R because a 3-hour, rated fire door is not provided at the.entry on the exterior, of this fire

area, on elevation No. 43.00 feet, and no fire damper or penetration fire seals are provided.

R3 Evaluation Bl 1)

Outdoor exposure fires are not postulated in the plant yard based on the lack combustible storage adjacent to buildings'here concentrations of combustible materials (such as oil in the Turbine Generator Building) exist, fire'etection and automatic unsuppression systems are provided and the flow of combustible liquids's confined as outlined in the Fire Hazard Analysis Report.

2)

The doorway and exhaust. is over 20 ft above grade which permits heat dissipation.

3)

Ionization type smoke detection system is provided (as shown on Drawings 8770M-,413) and an automatic Halon 1301 suppression system is provided in this fire area.-

R3 4)

A postulated fire involving in-situ or transient combustibles in Fire Area "B" 'would not affect the nonessential Turbine-Generator Building because of the large physical separation and the heat dissipation effects of the atmosphere.

1 5)

The hot shutdown panel, which provides alternate shutdown capability for a fire in this area, is located in fire zone 56 of Fire Area "C"~

These fire areas will be totally separated by a'-hour rated fire barrier.

6).Exterior walls.do not separate redundant trains of systems necessary to achieve and maintain,hot shutdown.

R3 Conclusion Bl A fire in Fire Area "B" will not impair the availability of the hot shutdown panel (B-Train) and therefore, establishes an alternative shutdown capability which meets the criteria of Appendix R, Section III-L.

The installation of a fire door and damper and penetration fire seals in the exterior of Fire Area "B" would not augment or materially enhance the safety of the plant.'herefore, we conclude that this is an acceptable exemption from Appendix,R 'to

10CFR50, Section III-G.2.a.

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Exem tion B2 An exemption is requested from Section III-G.2a of Appendix R because fire retardant coatings are not provided for the structural steel supporting the steel conduits which are wrapped t'o provide separation in accordance with Appendix R.

Evaluation B2 2)

Ionization type smoke detection is provided (as shown on Drawings 8770-G-413) and an Automatic Halon 1301 Suppression system is provided in this fire area.

Portable fire extinguishers and a fire standpipe system with hose stations are available for use in the Area.

R3 3)

See Evaluation A3, Items 3 thru 5.

Conclusion B2 See Conclusion A3.

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FIRE AREA "C" This fire area includes fire zones 55W (Cable Loft), 78 (Train B Electrical Penetration Area), 43*, 44*, 54*

(RAB Personnel Areas),

56 (Train B Switchgear Room),

57B (Train B Electrical Equipment Cubicle) and 58 (Train B Battery Room),

as shown on the attached drawings'ssential equipment within this fire area is shown in the attached essential equipment list.

The following exemptions to Appendix 'R to 10CFR50 are requested:

R.

Exem tion Cl An exemption is requested from Section III'.2.a of, Appendix R for exterior wall and roof penetrations because no fire dampers or penetration fire seals or doors, are provided.

Evaluation Cl 1)

Ionization type smoke detection system is provided as shown on drawings 8770-G-413.

2)

Outdoor exposure fires are not postulated in the plant yard based on the lack of combustible storage adjacent to buildings and on the height o'f penetration above grade which allows for heat dissipation.

R3 3)

A postulated fire involving in-situ or transient combustibles in Fire Area "C" does not require 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated dampers or.

penetrat'ion fire seals or doors due to the non-essential nature of the Turbine Generator Building and large physical separation, the yard area and the additional dissipation of heat to the atmosphere.

4)

Exterior walls do not separate redundant trains of systems necessary to achieve and maintain hot shutdown.

R3 Conclusion Cl Based on our evaluation, the existing fire barrier provides adequate separation.

The installation of fire dampers, penetration fire seals and doors at exterior penetrations would not augment or materially enhance the safety of the plant since they would not aid in the preventing fire migration through the fire barrier.

Therefore, we conclude, this is an acceptable exemption to Appendix R to 10CFR50, Section III-G.2.a.

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Exem tion C2 An exemption is.requested from Section III-G.2.a of Appendix R for the hatch at Column RAJ/RA5 because a steel hatch cover of 1/4 inch minimum thickness is being provided at elevation 19.5 feet.

Evaluation C2 1)

The hatch cover is located in the fire barrier between Fire Areas "C" and "0", both of which have ionization smoke detection as shown on drawings 8770-G-413.

R3 2)

A 1/4 inch minimum thickness steel hatch cover is pr'ovided.

3)

Fire damage to the hatch cover is precluded because the metal

.thickness, heat transmission and dissipation characteristics serve to render the cover impervious to deformation, or heat failure for periods of expected fire duration.

While localized high off-gas temperatures can be expected in the immediate vicinity of a fire, air mixture dilution and the cooling effect of manually applied hose stations will mitigate the effects and duration of a fire.

4)

Sidewall type sprinklers are being provided below the 19.50 ft elevation near the hatch perimeter to provide coverage of the hatch cover underside and floor area below.

The sprinkler system will

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not be in strict accordance with NFPA 13, but will be a wet system supplied from existing fire protection piping in the Reactor

'uxiliary Building.

The sprinklers will inhibit the spread of fire from the area under the. hatch, cool any rising hot off-gases, and provide cooling for the steel hatch cover.

Conclusion C2 Based on our evaluation, the provision of a 1/4 in. minimum thickness steel hatch cover and sidewall type sprinklers provides adeq'uate separation of fire area.

The use of materials of greater fire resistance for the hatch cover would not augment 'or'aterially enhance the safety of the plant since it would not aid in preventing fire migration between Fire Areas "0" and "C".

Therefore, we conclude, this is an acceptable exemption to Appendix R to

10CFR50, Section III-G.2.a.

Exem tion C3 An exemption is requested, from Section III-G.2.a of Appendix R for the entries to the holdup tanks on elevation 19.50 ft (zone

41) because no fire doors are provided.

Evaluation C3 1)

Ionization type smoke detection system is provided as shown on drawings 8770-G-413.

2)

Fire zone 41 contains negligible combustible load.

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The entries to fire zone 41 are inside labyrinth entry corridors with wire mesh access doors.

4)

The holdup tanks would tend. to rapidly dissipate heat generated by a fire in Fire Area "C" through the tank walls into the contained water.

5)

There is no continuity of combustibles in fire zone 41, which will mitigate the propagation of fire from Fire Area "C" to adjacent Fire Area "E".

Conclusion C3 Based on our eval'uation the existing fire barrier provides adequate separation.

The installation of fire doors at the entries to holdup tank room would not augment or materially enhance the safety of the plant since they would not aid in preventing fire migratio'n through the entries'herefore, we

conclude, this is an acceptable exemption to Appendix R to 10CFR50, Section III-G.2.a.

Exem tion C4 An exemption is requested from Section III-G.2a of Appendix R because fire retardant coatings are not provided for the structural steel supporting the steel conduits which are wrapped to provide separation in accordance with Appendix R.

Evaluation C4 1)

Ionization type smoke detection system is provided as shown on drawings 8770-G-413.

2)

Portable fire extinguishers and a fire standpipe system with hose stations are available for us'e in the Fire Area.

3)

See Evaluation A3, Items 3 thru 5.

Conclusion C4 See Conclusion A3 ~

EXEMPTION C5 R3 An exemption is requested from Section III-G.2.a of Appendix R for electrical penetrations to the containment from the RAB fire zone 78 (Train "B" Electrical Penetration Area) because no penetratio'n fire seals are provided.

All of the penetrations are sealed air tight, however they do not constitute a

typical fire rated assembly.

EVALUATION C5 See Evaluation A4 CONCLUSION C5 See'onclusion A4 024F/03F

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FIRE AREA "D" This Fire Area was deleted and has been incorporated in Fire Area "C".

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FIRE AREA "E" This fire area includes fire zones 46 (Containment Purge),

47 (AB Switchgear-Room),

49 (RAB Volume Control Tank),

48 (RAB Letdown Heat Exchanger),

61 (RAB HVAC Equipment Room),

41 (RAB Holdup Tank),

55E (Corridor east of column line RAH),

50 (Demineralizers),

51 (Drumming Station),

52 (Boric Acid Concentrators),

62 (Resin Addition Tank) and 80 (Steam Generator Blowdown Tank) as shown on the attached drawings.

Essential equipment within this fire area is shown on the attached list.

The following exemptions from Appendix,R to 10CFR50 are requested:

An exemption is requested from Section III-G.2.a of Appendix R for the hatch at Column RAC/RA4 because a steel hatch cover of 1/4 inch minimum thickness is being provided at elevation 19.50 feet.

Evaluation El The hatch cover separates Fire Areas "E" and "0", both of which have ionization smoke detection as shown on drawings 8770-G-413.

R3 2)

A 1/4 inch minimum thickness steel hatchcover is provided.

3)

Fire damage to the hatch cover is precluded because the metal thickness, heat transmission and dissipation characteristics serve to render the cover impervious to deformation or heat failure for periods of expected fire duration.

While localized high off-gas temperatures can be expected in the immediate vicinity of a fire, air mixture dilution and the cooling effect of manually applied hose streams will mitigate the effects and duration of a fire.

4)

A sidewall type sprinkler is being provided below the 19.50 ft elevation near the hatch perimeter to provide coverage of the hatch cover underside and floor area below.

The sprinkler will not be in strict accordance with NFPA 13, but will be a wet system supplied from existing fire protection piping in the Reactor Auxiliary Building.

The sprinkler will inhibit the spread of fire to the area under the hatch, cool any rising hot off-gases, and provide cooling for the steel hatch cover.

Conclusion El Based on our evaluation, the provision of a 1/4 in. minimum thickness steel hatch cover and sidewall type sprinkler provides adequate separation of 'fire areas.

The use of materials of greater fire resistance for the hatch cover would not augment or materially enhance the safety of the plant since it would not aid in the preventing fire migration between Fire Areas "E" and "0".

Therefore, we conclude, this is an acceptable exemption to Appendix R to

10CFR50, Section III-G.2.a.

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Exem tion E2 An exemption is requested from Section III-G.2.a of Appendix R because no-fire doors or dampers or penetration fire seals are provided at exterior wall penetrations.

Evaluation E2 1)

Outdoor exposure fires are not postulated in the plant yard based on the lack of combustible storage adjacent to buildings.

Where concentrations of combustible material (such as oil in the Turbine Generator Building) exist, fire detection and automatic suppression systems are provided and the flow of combustible liquids is confined as outlined in the Fire Hazard Analysis Report.

2)

A postulated fire involving in-situ or transient combustibles in Fire Area "E" would not affect the non-essential yard area because of the heat dissipation effects of the atmosphere.

3)

Exterior Walls do not separate redundant trains of systems necessary to achieve and maintain hot shutdown.

R3 Conclusion E2 Based on our evaluation, the existing fire barrier provides adequate separation.

The installation of the fire doors, dampers and fire seals in exterior wall penetrations would not augment or materially enhance the safety of the plant.

Therefore, we conclude that this is an acceptable exemption from Appendix R to

10CFR50, Section III-G.2.a.

Exem tion.E3 An exemption is requested from Section III-G.2.a of appendix R for the entries to the holdup tanks (zone

41) because no fire doors are provided.

Evaluation E3 See Evaluation'C3 Conclusion E3 See Conclusion C3 Exemption E4 An exemption is requested from Section III-G.2a of Appendix R because fire retardant coatings are not provided for the structural steel supporting the steel conduits which are wrapped to provide separation in accordance with Appendix R.

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Evaluation E4 2)

Ionization type smoke detection system is provided as shown on drawings 8770-G-413.

Portable fire extinguishers and a fire standpipe system with hose stations are available for use in the Area.

3)

See Evaluation A3, Items 3 thru 5.

Conclusion E4 See Conclusion A3.

EXEMPTION E5 An exemption is'equested from Section III-G.2.a of Appendix R for mechanical penetrations to the containment from the RAB fi're zones 46 (Containment Purge),

61 (RAB HVAC Equipment Room) because no penetration fire seals are provided.

All of the penetrations are sealed air tight, however they do not constitute.

a typical fire r'ated assembly.

EVALUATION E5 2 ~

Portable fire extinguishers and a fire standpipe system with hose stations, are available for use in this area.

Ionization type smoke detection system is provided as shown on Drawings 8770-G-413.

3.

All mechanical penetrations are sealed air tight and penetrate a

36 inch thick concrete shell from the RAB into the containment.. This seal has been air tested at -.25" wg.

Between the 36 inch concrete shell and the steel containment, there is an annulus of 48 inches which the penerations passes through.

The annulus has negligible combustible loading.

At the Reactor Containment Building side, there is a

3 5/8 inch thick reinforced steel containment (reinforced 3 5/8 inches for penetration purposes). The penetrations pass through this steel containment, sealed air tight and tested at approximately 44 psid.

R3 4 ~

Six general types of. piping penetration assemblies are provided.

The penetration assemblies consists of a containment vessel penetration

nozzle, a process

pipe, a Shield Building penetration sleeve and a shield building bellows seal.

In the case of cold penetrations the containment vessel penetration nozzle is an

'ntegral part of the process pipe.

In the case of hot and semi-hot penetrations, a multiple flued head is provided as an integral part of the process pipe.

A guard pipe, which encloses the process pipe and directs any.fluid released back into the containment, is welded to the flued head.

For hot penetrations an expansion joint metal bellows is welded to the flued head and the containment vessel penetration nozzle to accomodate thermal movements.

The containment vessel penetration nozzles are designed to meet the requirements for Class MC vessels under ASME Code,Section III.

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At the terminal of a piping penetration assembly near the Shield Building a low pressure leakage barrier is provided in the form of a Shield Building bellows seal.

The bellows provides' flexible membrane type closure between the Shield Building penetration

sleeve, which is embedded in the Shield Building, and the process pipe.,

The Shield Building bellows is designed to withstand a design differential pressure of five psig and provide an adequate leak-tight seal consistent with overall allowable Shield Building leakage.

For additional mechanical penetration description and details see FSAR in Section 3.8.

6.

All of the penetrations are sealed air tight by continuous welding with a minimum of two passes.

The air tight penetration seals constitute more than

a. three hour fire rated assembly.

R3 CONCLUSION E5 Based on our, evaluation, the existing air tight mechanical penetrations through the 36 inch concrete shell, the 48 inch annulus and the 3 5/8 inch thick reinforced steel containment, plus the smoke detection and manual suppression systems in the area provides adequate protection of a fire migration.

The installation of penetration seals would not augment or materially enhance the safety of the plant.

Therefore, we conclude, this is an acceptable exemption to Appendix R to 10CFR50, Section III-G.2.a. 024F/03F

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Exemption F6 An exemption is requested from Section III-G.2.a of Appendix R because the 48 inch HVAC containment purge make-up (piping and valves),

the 2-inch HVAC hydrogen purge make-up (piping and valves) to the containment from RAB fire zone 46 (Containment Purge),

the 48 inch HVAC containment purge exhaust (piping and valves) and the two 2-inch HVAC hydrogen purge exhaust (piping and valves) to the" containment, from RAB fire zone 61 (RAB HVAC Equipment Room) are not provided with fire dampers.

Note that these HVAC systems utilize piping and valves instead of the usual ducts a'nd dampers.

Evaluation E6 1)

Portable fire extinguishers and a fire standpipe system with hose stations are available for use in this area.

2)

Ionization. type smoke detectors is provided as shown on drawings 8770-G-413.

)

3)

This area contains negligible combustible loading.

4)

Fire damage to the pipes located in this area is precluded because the 48-inch standard wall pipes and the 2 inch schedule 40 pipes have a wall thickness'of approximately

.375-inch and.187-inch respectively (as compared to the.0312-inch thickness of a 3-hour rated fire damper).

Fire damage to the pipes is precluded because the pipe thickness,-heat transmission and dissipation characteristics serve to render the pipe impervious to deformation or heat failure for periods of expected fire durations.

While localized, high off-gas temperatures can be expected in the immed'iate vicinity of a fire, air mixture dilution at the pipes is not expected to reach high temperatures.

R3 5)

The 48-inch HVAC Containment Purge make-up pipe and the 48-inch HVAC containment purge exhaust pipe are provided with three remote manually operated butterfly valves in each pipe.

The 2-inch HVAC hydrogen purge make-up pipe and the two 2-inch HVAC hydrogen purge exh'aust pipes are provided with two manual hand-operated gate valves in each p'ipe.

These valves are located as follows:

The 48-inch HVAC containment purge make-up pipe has one valve in the Containment Purge

Room, one valve in the 'the 48-inch annulus and one valve inside containment.

The 48-inch HVAC containment purge exhaust pipe has one valve in the. RAB HVAC Equipment

Room, one valve in the 48-inch annulus and one valve inside containment.

The one 2-inch HVAC hydrogen purge make-up pipe has two valves in the Containment Purge Room and the two 2-inch HVAC hydrogen purge'xhaust

pipes, each have two valves in the RAB HVAC Equipment Room. 024F/03F

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Two of the three 48 inch valves in'he HVAC containment purge make-up pipe are operated from the "A" train and the other (annulus) valve from the "B" train.

Two of the three 48 inch valves in the HVAC containment purge exhaust pipe are operated from the "B" train and the other (annulus) from the "A" train.

Cable routing is such that a single fire in the containment, or a fire in either, the Containment Purge Room or in the RAB HVAC Equipment Room can not cause spurious opening of all three valves.

In addition, these valves fail closed.

7) All of the aforementioned 2-inch valves are locked closed and are local manual operated.

R3 Conclusion E6 Based on our evaluation, the existing fire barrier provides adequate separation.

The installation of rated fire dampers in the 48 inch and 2 inch piping would not augment or materially enhance the safety of the plant, since it would not further aid in preventing fire migration between Fire Areas "E" and "K".

Therefore we conclude this is an acceptable exemption to Appendix R

to 10CFR50 Section III-G.2.a. 024 F/03F

(I 1'

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FIRE AREA "F" This'ire area is fire zones 70 (Control Room),

71 (H&V Room),

73 (Technical Support Center) and 82 (Component Cooling Mater Surge Tank Room) as shown on the attached drawings.

Essential equipment within this fire area is shown in the attached list.

The following exemptions to Appendix R to 10CFR50 are requested:

Exem tion Fl An exemption is requested from Section III-G.2.a of Appendix R for exterior wall penetrations because no fire dampers or penetration seals are provided.

Evaluation Fl 1)

Outdoor exposure fires are not postulated in the plant yard based on the lack of combustible storage adjacent to buildings.

Where concentrations of combustible material (such as oil in the Turbine Generator Building) exist, fire detection and automatic suppression systems are provided and the flow of combustible liquids is confined as outlined in the Fire Hazard Analysis Reports 2)

The penetrations are over 50 ft above grade which permits heat dissipation.

3)

Ionization type smoke detection system is provided as shown on drawings 8770-G-413.

R3 4)

A postulated fire involving in-situ or transient combustibles in Fire Area,"F" would not affect the non-essential Turbine Generator Building because of the large physical separation and the heat dissipation effects of the atmosphere.

5)

Exterior Walls do not separate redundant trains of systems necessary to achieve and maintain hot shutdown.

R3 Conclusion Fl

'Based on our evaluation, the existing barrier provides adequate, separation.

The installation of fire dampers or penetration seals in exterior walls of Fire Area "F" would not augment or materially enhance the safety of the plant.

Therefore we conclude that this is an acceptable exemption from Appendix R to 10CFR50, Section III-G.2.a.

Exem tion F2 An exemption is requested from Section III-G.3 of Appendix R because no fixed fire suppression system is provided. 024 F/03F

C

Evaluation F2 1)

The Hot Shutdown Panel, which provides alternate shutdown capability for a fire in this area, is located in fire zone 56 of Fire Area "C".

These fire areas are totally separated by a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire barrier.

2)

Ionization type smoke detection is provided as shown on drawings 8770-G-413.

3)

Deleted 4)

The Fire Area is continuously manned with senior operations personnel.

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5)

Portable fire extinguishers are available for use in the area; Conclusion F2 Based on our evaluation, the existing fire protection is adequate

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The installation of a fixed fire suppression,.>stem would not augment or materially enhance the safety of the plant.

Therefore we conclude that this is an acceptable exemption from Appendix R to 10CFR50, 'Section III-G.3. 024F/03F

I

FIRE AREA "G-G" This fire area is the yard area including Fire Zones 10 (Gas Storage Building),

11 (Misc. Oil Storage Buildings) 12 (Water Plant),

42 (Chemistry Personnel Building), 79 (Raw Water Storage Tanks) and 81 (Area between RAB and RCB) as shown on the attached drawings'his fire area contains no essential equipment or cables and Appendix R Section III-G does not apply. 024F/03F

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Fire Area "H-H" This fire area is Fire Zone 6 (Diesel Generator Building lA) as shown on the attached drawings'ssential equipment within this fire area is shown in the attached essential equipment list.

The following exemption to Appendix R to 10CFR50 is requested:

Exemption H-H 1

An exemption is requested from Section III-G.2.a of Appendix R for labyrinth

entries, and penetrations in the exterior fire barrier walls because no fire rated doors, penetration seals or fire dampers are provided.

Elevation H-H 1 1)

The fire area is lightly trafficked, thus minimizing the probability of introducing transient combustibles')

Thermal type fire detection system is provided as shown on drawings 8770-G-413 and a pre-action sprinkler system is provided in this area.

R3 4

3)

Outdoor exposure fires are not postulated in the plant yard based on the lack of combustible storage adjacent to buildings.

4)

Fire Area "H-H" is separated from Fire Area "I-I" by a full height 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated (18 inch) interior fire barrier.

5)

Possible oil flow a rupture of any of the oil containing vessel in this fire area will be confined and/or safely directed away from important plant structures by floor drains.

Although highly unlikely, any oil escape would be =through the lowe'st level of egress-where it would be directed away from the premises by the site drainage arrangements.

6)

All exterior penetrations are missile protected.

7)

Exterior Walls do not separate redundant trains of systems necessary to achieve and maintain hot shutdown.

R3 Concusion H-H 1 Based on our evaluation, the exterior fire barrier wall, and 24 inch thick reinforced concrete exterior walls with labyrinth entries provide adequate separation.

The provision of fire rated,

doors, penetration seals and dampers would not augment or materially enhance the safety of the plant since it would not aid in the preventing of fire migration between Fire Areas "H-H" and "I-I" therefore, we conclude, this is an acceptable exemption to Appendix R to

10CFR50, Section III-G.2.a. 024F/03F

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Fire Area "I-I This fire area is Fire Zone 7 (Diesel Generator Building 1B) as shown on the attached drawings.

Essential equipment within this fire area is shown in the attached essential equipment list.

The following exemptions to Appendix R to 10CFR50 are requested:

Exemptions I-I 1 An exemption is requested from Section III-G.2.a of Appendix R for labyrinth

entries, and penetrations in the exterior fire barrier walls because n'o fire rated doors, penetration seals or fire dampers are provided.

Evaluation I-I 1 1)

The fire area is lightly trafficked, thus minimizing the probability of introducing transient combustibles.

2)

Thermal type fire detection system is provided as shown, on drawings 8770-G-413 and a preaction sprinkler system is provided in this area.

R3 3)

Outdoor exposure fires are not postulated in the plant yard based on the lack of combustible storage adjacent to buildings.

4)

Fire Area "I-I"is separated from Fire Area "H-H'y a full,height; 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated (18 inch) interior fire barrier.

5)

Possible oil flow from a rupture of any of the oil containing vessels in this fire area will be confined and/or safely directed away from important plant structures by floor drains.

Although highly unlikely, any oil escape would be through the lowest level of egress where it would be directed away from the premises by the site drainage arrangements.

6)

All exterior penetrations are missile protected.

7)

The diesel building air intake is over 60'rom its redundant counterpart.

8)

Exterior Walls do not separate redundant trains of systems necessary to achieve and maintain hot shutdown.

R3 Concusion I-I 1 Based on our evaluation, the exterior fire barrier wall, and 24 inch thick reinforced concrete exterior walls with labyrinth entries provide adequate separation.

The provision of fire rated,

doors, penetration seals and dampers would not,augment or materially enhance the safety of the plant since it would not aid in the preventing of fire migration between Fire Areas "H-H" and "I-I" therefore, we conclude, this is an acceptable exemption to Appendix R to 10CFR50, III-G.2.a. 024F/03F

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FIRE AREA "J" This fire area includes fire zones 33 (Piping Penetration Room),

45 (RAB Pipe Tunnel) and 62B (RAB ECCS Ventilation Equipment) as shown on the attached drawings.

Essential equipment within this fire area is shown in the attached essential equipment list.

The following exemptions from Appendix R to 10CFR50 are requested:

An exemption "is requested from Section III-G.2.a of Appendix R for penetration No.

11 on elevation 19.50 ft because no fire damper is provided in the ventilation duct.

Evaluation Jl This exemption is evaluated as Exemption No. Al in Fire Area "A".

Conclusion Jl See Conclusion Al*of Fire Area "A".

Exemption J2 An exemption is-requested from Section -III-G.2.a of Appendix R for penetration No.

13 on elevation 42.00 ft because no fire damper or penetration fire seal is provided in the ventilation duct.

Evaluation J2 1)

Fire Area "J" contains negligible combustible loading.

2)

Outdoor exposure fires are not postulated in the plant yard based on the lack of combustible storage adjacent to buildings.

Where concentrations of combustible material (such as oil in the Turbine Generator Building),exist, fire 'detection and automatic suppression systems are provided and the flow of combustible liquids is confined as outlined in the Fire Hazard Analysis Report.

3) 4)

The duct penetration is located over 35 feet above grade which permits heat dissipation.

Exterior Walls do not separate redundant trains of systems necessary to achieve and maintain hot shutdown.

R3 Conclusion J2 Based on our evaluation, the existing fire barrier provides adequate separation.

The installation of a fire damper in the ventilation duct and a

penetration fire seal at penetration No.

13 would not augment or materially enhance the safety of the plant.

Therefore, we conclude, that this is an acceptable exemption from Appendix R to 10CFR50, Section III-G.2.a. 024F/03F

4 4

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Exem tion J3 An exemption is requested from Section III-G.2.a of Appendix R for penetration No.

5 on elevation -0.5 ft because no penetration fire seal or fire damper is provided in the ventilation duct.

Evaluation J3 This exemption is evaluated as Exemption No. L2 in Fire Area "L".

Conclusion J3 See Conclusion L2 of Fire Area "L".

Exemption J4 An exemption is requested from Section III-G.2. a of Appendix R for watertight doors RA-7 and S,because the fire rating of the custom manufactured doors is not Underwriters, Laboratory listed.

Evaluation J4 2 ~

3 ~

Conc lus ion The water tight doors separate Fire Areas which have low in-situ combustibles and 'as radiation areas, have limited personnel

access, which reduces the probability of introducing transient combustibles.

The 'doors are solid steel, minimum of 1/4 inch thickness.

Fire damage to the doors is precluded because the metal thickness, heat transmission and dissipation characteristi'cs serve to render the doors impervious to deformation or,heat failure for periods of expected fire duration.

While localized high off-gas temperatures can be expected in the immediate vicinity of a fire, air mixture dilution and-the cooling effect of manually applied hose streams will mitigate the effects and duration of a fire.

J4 Based on our evaluation, the provisions of 1/4 inch thick steel doors provides adequate separat'ion of fire areas.

The use of, materials of greater fire resistance for the watertight doors would not augment or materially enhance the safety of the'lant'since it would not aid in preventing fire migration between fire areas.

Therefore, we conclude, this is an acceptable exemption to Appendix R to 10CFR50, Section III-G.2.a. 024F/03F

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EXEMPTION J5 An exemption is requested from 'Section III-G-2.a of Appendix R for mechanical penetrations to the containment from the RAB fire zones 33 (Piping Penetration Room),

and 45 (RAB Pipe Tunnel) because no penetration fire seals are provided.

All of the penetrations are sealed air tight, however they do not constitute a typical fire rated assembly.

EVALUATION J5 1..

Fire area "J" contains negligible combustible loading.

2.

Portable fire extinguishers and a fire standpipe system with hose stations are available for use in this fire area.

R3 3.

See Evaluation E5 (Items 3 through 6).

CONCLUSION J5 Based on our evaluation, the'existing air tight mechanical penetrations through the 36 inch concrete shell, the 48 inch annulus and the 3 5/8 inch thick reinforced steel containment plus the negligible combustible loading and the manual fire suppression system in the area provides adequate protection of a fire migration.

The installation of penetration seals would not augment or materially enhance the safety of the plant.

Therefore, we conclude this is an acceptable exemption to Appendix R to 10CFR50, Section III-G.2.a. 024F/03F

I l

I

FIRE AREA "K" This fire area is the Reactor Containment Building previously designated as Fire Area 26.

Essential equipment within this fire area is shown in the attached essential equipment list.

1 The following exemptions to appendix R to 10CFR50 are requested:

Exemption Kl An exemption is requested from Section III-G.2.d of Appendix R because the containment cables and associated non-safety circuits of redundant trains are

, not in all cases separated by 20 ft with no intervening combustibles.

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Evaluation Kl 1)

A Reactor Cooling Pump Oil Collection System is provided to collect pressurized and unpressurized leaks from each of the Reactor Coolant Pump Lube Oil Systems.

This installation confines the major portion of combustible inventory to a separate oil collection tank in accordance with Appendix R, Section III-0.

The remaining combustible loading in the fire area is low.

2)

Pire detection is provided as shown on drawings 8770"G"413.

3)

Redundant safety-related equipment is protected from exposure to localized combustible sources by spatial separation and/or the use

-of existing barriers/partitions (i.e. concrete walls, floors and ceilings) having greater than three hours fire resistive rating.

Separation is provided to maintain independence of electrical circuits and equipment so that the protective function required during any design basis event can be accomplished.

'Ihe degree and method of separation varies with the potential hazards in a particular area.

This is acc'omplished by use of spatial separation,

barriers, and radiant energy shields where required.

4)

Electrical cables are concentrated at the Penetration Areas at Elev 23.00 ft between Column Lines 6 and 8.

The cables trays are immediately separated and routed to the several items of equipment.

A radiant energy shield is provided between safety-related A and B

cables trays in the cable penetration area to provide separation.

5)

Non IEEE-383 1974 cables in Fire Area "K" were coated with Flamemastic fire protective coating system.

New cables meet the IEEE-383 1974 criteria.

R3 6)

Fire Area "K" is a high radiation area and personnel access is limited, thus minimizing the probability of introducing transient combustibles. 024F/03F

I A

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7)

The large free volume (2.5 million cubic feet) of Fire Area "K" allows for dissipation of hot off-gas temperatures and reduces the effect of stratified hot gases at essential components.

8)

Instrument cable trays are covered.

Conclusio'n Kl Based on our evaluation, the existing features in Fire Area "K" provide adequate separation for a-fire in transient or in-situ combustibles

~

Additional modification would not augment or materially enhance the safety of the plant since it would not aid in the prevention of fire damage to redundant components essential for safe shutdown.

Therefore, we conclude, this is an acceptable exemption to Appendix R to 10CFR50, Section III-G.2.de Exem tion K2 An exemption is requested from Section III-0 of Appendix R because the Oil Collection System is not capable of collecting lube oil from all four of the reactor coolant-pump lube oil systems.

Evaluation K2 Per design specifications, components inside containment have a

maximum allowable surface temperature during normal operation of 150 F, thus reducing the probability of 'starting a fire.

Oil used:

Flash Point 450'F Fire Point 480'F Ignition Point 530'F 2)

The RCP oil collection system is required to be Seismic Category II per R.G. 1.29, paragraph C.2.

3)

A design basis accident and a fire are not postulated to occur simultaneously.

4)

Under normal operating conditions, it would be impractical to assume that all RCP oil systems would fail at once.

Therefore, a

tank to contain all RCP oil is not necessary.

5)

Each RCP oil system has an alarm which will sound in the control room if approximately 15 gallons of oil is lost from the oil system.

This 'alarm requires operator action.

6)

Deleted 7)

The RCP oil collection tank is capable of holding 225 gallons which-exceeds the total capacity of one pump (190 gal.) plus reasonable leakage from the remaining pumps. 024F/03F

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Conclusion K2 Based on our evaluation, the existing RCP oil collection system provides adequate capability for collecting lube oil from all potential piessurized and unpressurized leakage sites in the reactor coolant pump lube oil systems.

Additional modifications would not augment or materially enhance the safety of the plant since it would not aid in the prevention of fire damage to redundant components essential for safe shutdown.

Therefore, we conclude, this is an acceptable exemption to Appendix R to 10 CFR 50, Section III.O.

Exemption K3 A exemption is requested from Section III-G.2.a of Appendix R for electrical penetrations to the RAB Fire Zones 77 (Train "A" Electrical Penetration Area) and 78 (Train "B" Electrical Penetration Area) from the containment because no penetration fire seals are provided.

All of the penetrations are sealed air tight, however they do not constitute a typical fire rated assembly.

Evaluation K3 Ionization type smoke detection is provided as shown on drawings 8770-G-413.

2 ~

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Portable fire extinguishers are available for use in this area.

At the Reactor Containment Building side, electrical penetrations pass through a schedule 80 sleeve which is continuously welded to the 3 5/8 inch thick reinforced steel containment (reinforced 3 5/8 inches for penetration purposes) on both sides.

The electrical penetrations are terminated approximately 8 inches beyond the steel containment.

A schedule 80 ASME SA 234 pipe cap is continuously welded as per ASME III, Class MC, to the penetration

sleeve, sealed and air tested at approximately 44 psid.

The schedule 80 sleeve continuously welded to both sides of the 3 5/8 inch steel containment forming this air tight seal constitutes more than a

three hour fire rated assembly.

See FSAR Section 3.8.

R3 4 ~

Between the 36 inch thick concrete shell and the 3 5/8 inch thick reinforced steel containment, there is an annulus of 48 inches which the penetration passes through.

The cables are covered with a

12 inch diameter sleeve as they pass through the annulus'he annulus has negligible combustible loading.

5 ~

Electrical penetration nozzles and sleeves are sealed in the RAB side with 1 1/2 inch thick by 20 inch diameter ASTM Grade A-36 plates over the sleeve opening (sleeve is Schedule 80 ASME SA 106 Gr.B and is housed in a 36 inch thick concrete shell) and fillet weld to embedded plate.

Weld is the same as used on penetration header plates.

A-36 plates are designed as Seismic Category I.

This seal has been air tested at -.25" W.G.

The 1 1/2 inch thick by 20 inch diameter ASTM Grade A-36 plate continuously welded over the sleeve opening forming this air tight seal, is equal to or better than a three hour fire rated assembly. 024F/03F

I 11

CONCLUSION K3 Based on'ur evaluation the existing air tight electrical penetrations through the 3 3/8, inch thick reinforced= steel containment, the 48 inch annulus and the

'36 inch concrete shell plus the smoke detection and thp manual suppression system in the area provides adequate protection of a fire migration.

The installation of penetration seals would not augment or materially enhance the safety of the plant.

Therefore we conclude, this is an acceptable exemption to Appendix R to

10CFR50, Section III-G-2.a.

EXEMPTION K4 An exemption is requested from Section III-G.2.a of Appendix R for mechanical penetrations to the RAB fire zones 33 (Piping Penetration Room),

45 (RAB Pipe Tunnel),

46 (Containment Purge),

and 61 (RAB HVAC Equipment Room) from the containment because no penetration fire seals are provided.

All of the penetrations are sealed air tight,'however they do not constitute a typical fire rated assembly.

EVALUATION K4 Portable fire extinguishers are available for use in this area.

2 ~

Ionization type smoke detection system is provided as shown on Drawings 8770-G-413.

3 ~

All mechanical penetrations are sealed air.tight.

At the Reactor Containment Building side, there is a

3 5/8 inch thick reinforced steel containment (reinforced 3 5/8 inches for penetration purposes).

The penetrations pass through this steel containment, sealed air tight and tested at approximately 44 psid.

Between the steel containment and the 36 inch concrete shell, there is an annulus of 48 inches which the penetrations pass through.

The annulus has negligible combustible loading.

The penetrations pass from the 48 inch annulus thru a 36 inch concrete shell into the RAB.

This penetration seal has been air tested at

.25"wg.

R3 4,

Six general types of piping penetration assemblies are provided.

The penetration assemblies consists of a containment vessel penetration

nozzle, a process

pipe, a Shield Building penetration sleeve and a shield building bellows seals In the case of cold penetrations the containment vessel penetration nozzle is an integral part of the process pipe.

In the case of hot and semi-hot penetrations, a multiple flued head is provided as an integral part of the process pipe.

A guard pipe, which encloses the process pipe and directs any fluid 'released back into the containment, is welded to the flued head.

For hot penetrations an expansion joint metal bellows is welded to the flued head,and the containment vessel penetration nozzle to accomodate thermal movements.

The containment vessel penetration nozzles are designed to meet the requirements for Class, MC vessels under ASME Code,Section III. 024F/03F

cl I"

5.

At the terminal of a piping penetration assembly near the Shield Building a low pressure leakage barrier is provided in the form of a Shield Building bellows seal.

The bellows provides a flexible membrane type closure between the Shield Building penetration sleeve,,which is embedded in the Shield Building, and the process pipe.

The Shield Building bellows is designed to withstand a design differential pressure of five psi and provide an adequate leak-tight seal consistent with overall allowable Shield Building leakage.

For additional mechanical penetration description and details see FSAR in Section 3.8.

6.

All of the penetrations are sealed air tight by continuous welding with a minimum of two passes.

The air tight penetration seals constitute more than a three hour fire rated assembly.

R3 Conclusion K4

-Based on our evaluation, the existing air tight mechanical penetrations through the 3 5/8 inch thick reinforced steel containment, the 48 inch. annulus and the 36 inch concrete shell, plus the smoke detection and the manual suppression system in the area provides adequate protection of a fire migration.

The installation of penetration seals would not augment or materially enhance the safety of the plant.

Therefore, we conclude, this is an acceptable. exemption to Appendix R to 10CFR50, Section III-G.2.a. 024F/03F

J f

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Exem tion K5 A exemption is requested from Section III-G.2.a of Appendix R because the 48-inch HVAC containment purge make-up (piping and valves),

the 2-inch HVAC hydrogen purge make-up (piping and valves) to RAB fire zone 46 (Containment Purge) from the containment, the 48-inch HVAC containment purge exhaust (piping and valves) and the two 2 inch HVAC hydrogen purge exhaust (piping and valves to RAB fire zone 61 (RAB HVAC Equipment Room) from the containment are not provided with fire dampers.

Note that these HVAC systems utilize piping and valves instead of the usual ducts and dampers.

Exemption K5 1.

Portable fire extinguishers are provided for use in this area.

2.

Ionization type smoke detection system is provided as shown on Drawings 8770-G-413.

3)

This area contains negligible combustible loading.

4)

Fire damage to the pipes located in this area is precluded because the 48-inch standard wall pipes and the 2 inch schedule 40 pipes have a wall thickness of approximately

.375-inch and.187-inch respectively (as compared to the.0312-inch thickness of a 3-hour

'ated fire damper)

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Fire damage to the pipes is piecluded because the pipe thickness, heat transmission and dissipation characteristics serve to render the pipe impervious to deformation or heat failure for periods of expected fire durations.

While localized high off-gas temperatures can be expected in the immediate vicinity of a fire, air mixture dilution at the pipes is not expected to reach'igh temperatures.

5)

The 48-inch HVAC Containment Purge make-up pipe and the 48-inch HVAC containment purge exhaust pipe are provided with three remote manually operated butterfly valves in each pipe.

The 2-inch HVAC hydrogen purge make-up pipe and the two 2-inch HVAC hydrogen purge exhaus't pipes are provided with two manual hand-operated gate valves in each pipe.

R3 These valves are located as follows:

The 48-inch HVAC containment purge make-up pipe has one valve in inside containment, one valve in the the 48-inch annulus and one valve in the Containment Purge Room.

The 48-inch HVAC containment purge exhaust pipe has one valve inside containment, one valve in the 48-inch annulus and one valve in the RAB HVAC Equipment Room.

The one 2-inch HVAC hydrogen purge make-up pipe has two valves in the Containment Purge Room and the two 2-inch HVAC hydrogen purge exhaust

pipes, each have two valves in the RAB HVAC Equipment Room. 024F/03F

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6)

Two of the three 48 inch valves in the HVAC containment purge make-up pipe are operated'from the "A" train and the other (annulus) valve from the "B" train.

Two of the three 48 inch valves in the HVAC containment purge exhaust pipe are operated from the "B" train and the other (annulus) from the "A" train.

Cable routing is such that a single fire in the'ontainment, or a fire in either the Containment Purge Room or in the RAB HVAC Equipment Room cannot cause spurious opening of all three valves..

In addition, these valves fail closed.

7)

All of the'aforementioned 2-inch valves are locked closed and are local manual operated.

R3 Conclusion K5 Based on our evaluation, the existing fire barrier provides adequate separation.

The installation of rated fire dampers in the 48 inch and 2 inch piping would not augment or materially enhance the safety of the plant, since it would not" further aid in preventing the fire migration between Fire Area "K" and "E".

Therefore we conclude this is an acceptable exemption to Appendix R to 10CFR50 Section III-G.2.a. 024F/03F

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FIRE AREA "L" This fire area is fire zones 31 and 32 (Shutdown Heat Exchanger Room) as shown on the attached drawings.

Essential equipment within this area is shown in the attached essential equipment list.

The following exemptions from Appendix R to 10CFR50 are requested:

Exemption Ll An exemption is requested from Section III-G.2.a of Appendix R because a full height 3 hr rated fire barrier is not provided between the redundant shutdown heat exchangers.

Evaluation Ll 2)

The shutdown heat exchangers are 16 ft apart edge to edge and are separated by a 7 ft high 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated partition.

This fire area contains a negligible in-situ combustible load and as a radiation area has limited personnel

access, which reduces the probability of introducing transient combustibles')

Smoke detectors are being provided in the exhaust ducts for Ventilation Fans HVE 10A and 10B that serve this area.

4)

A fire on either side of the fire partition, involving either in"situ and/or transient combustibles could not directly impinge upon or radiate heat to the essential equipment on the opposite side.

While localized high off-gas temperatures can be expected in the vicinity of a fire, air mixture dilution temperatures which would stratify in the upper level of this area would not reach a

point capable of jeopardizing the operation of the redundant heat exchanger-5)

Cables routed in this area are in steel'onduit.

Redundant essential cable necessary for safe shutdown extending above the fire rated partition are provided with a minimum one hour rated protection.

R3 Conclusion Ll Based on our evaluation the existing 7 ft high 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated partition provides adequate separation of the redundant heat exchangers

~

"Providing a full height 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier in lieu of the existing partition would not augment or materially enhance the safety of the plant since a single fire would not cause damage to the redundant heat exchangers.

Therefore, we conclude that this is an acceptable exemption from Appendix R to 10CFR50.

Section III-G.2.a ~ 024F/03F

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Exem tion L2 I

An exemption is requested from Section III-G.2.a of Appendix R for "penetration 5,through the fire barrier between Fire Areas "L" and "J" because no penetration fire,seal or fire damper is provided in the ventilation duct.

Evaluation L2 1)

Fire Area "L" and "J" have negligible in-situ combustibles and as radiation areas have limited personnel

access, which reduces the probability of introducing transient combustibles')

Ionization type smoke detection system is provided as shown on drawings 8770-G-413.,

3)

Fire damage to the duct is precluded because the heavy gage duct material (14 gage as compared to 22 gage for 3-hour rated fire dampers) and metal heat transmission and dissipation characteristics would serve to render the duct impervious to expansion deformation or heat failure for periods of expected fire duration.

4)

Smoke detectors are being provided in the exhaust ducts for ventilation fans HVE 10A and 10B that serve this area.

R3 Conclusion L2 Based on our evaluation the existing fire barrier provides adequate separation.

The installation of a fire damper.in the ventilation duct at penetration 5 or penetration fire seal would not augment or materially increase the safety of the plant since they would not'rovide mater'ial protection for the heat excha'ngers.

Therefore, we conclude that this is an acceptable exemption from Appendix R to 10CFR50, Section III-G.2.a.

Exem tion L3 An exemption is requested from Section III-G.2.a of Appendix R for.watertight door RA-7 and 61 because of fire rating of the custom manufactured door is not Underwriters Laboratory listed.

Evaluation L3 See Evaluation J4(RA-7) and Evaluation.M2(RA-61).

Conclusion L3 See Conclusion J4(RA-7) and Conclusion M2(RA-61) ~ 024F/03F

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FIRE AREA "M" This fire area is fire zones 34 and 35 (RAB ECCS Room) as shown on the attached drawings.

Essential equipment within this fire area is, shown in the attached essential equipment list.

The following exemptions to Appendix R to 10CFR50 are requested:

Exem tion Ml An exemption is requested from Section III-G.2.a of Appendix R because a full height 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire barrier is not provided between the redundant shutdown cooling pumps.

Evaluation Ml 1)

Ionization type smoke detection system is provided as shown on drawings 8770-G-413.

/RS 2)

'The Fire area has a very low combustible loading.

3)

Fire Area "M" is a radiation area and therefore personnel access is limited which reduces the probability of introducing transient combustibles.

4)

The redundant LPSI Pumps are physically over 20 ft apart, edge to edge.

5)

Redundant equipment and cable essential for safe shutdown in this fire area are separated by a 20 ft high, 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated partition from Column RAI to RAG (reducing to 9.5. ft high from Column RAG to RAE).

6)

A postulated fire on either side of the 20 ft high 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated partition involving transient or in-situ combustibles would not directly impinge upon or radiate heat to the essential equipment on the opposite side.

While localized high off~as temperatures can be expected in the immediate vicinity of a fire, air mixture dilution temperatures would not reach a level detrimental to the normal operation of the LPSI Pumps.

I 7)

Cables routed in this area are in steel conduits.

Redundant essential cables extending above the fire rated partition are provided with a minimum one hour rated protection.

R3 Conclusion Ml Based on our evaluation, the existing 20 ft high 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated partition provides adequate separation of redundant trains.

The extension of the partition to full height, would not augment or materially enhance the safety of the plant since it would not aid in the containment of a fire to one= train of equipment required for the shutdown.

Therefore, we conclude, this is an acceptable exemption to Appendix R to 10CFR50, Section III-G.2.a. 024F/03F

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Exem tion M2 An exemption is requested from Section III-G.2.a of Appendix R.for watertight doors RA-4, 5, 6 and 61 because the fire rating of the custom manufactured doors is not Underwriters Laboratory listed.

Evaluation M2 1)

The watertight doors separate Fire Areas M and 0 and M and L (Door 61).

Pire Area M and L, as radiation areas, have limited personnel

access, which reduces the probability of introducing transient combustibles'ire Areas L,

M and 0 have a smoke detection system for early warning of a fire condition as shown on drawings 8770-G-413.

R3 2)

The door is solid steel, minimum of 1/4 inch thickness

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Fire damage to the door is precluded because the metal thickness, heat transmission and dissipation characteristics serve to render the door impervious to deformation or heat failure for periods of expected fire duration.

While localized high off-gas temperatures can be-expected in the immediate vicinity of a fire, air mixture dilution and the cooling effect of manually applied hose streams will migitate 'the effects and duration of a fire.

Conclusion M2 Based on our evaluation, the provisions of 1/4 inch thick steel doors provides adequate separation of fire areas'he use of materials of greater fire resistance for the wate'rtight doors would not augment or materially enhance the safety of the plant since it would not aid in preventing fire migration between fire areas.

Therefore, we conclude, this is an acceptable

'exemption to Appendix R to

10CFR50, Section III-G,2.a. 024 F/03F

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FIRE AREA "N" This fire area is fire zones 38 (Charging Pump 1C),

75 (Charging Pump 1B),

76 (Charging Pump 1A) and 36A (Charging Pump Access Hallway) as shown on the attached drawings. Essential equipment in this area is shown in the attached essential equipment list.

The following exemptions from Appendix R to 10CFR50 are requested:

Exem tion Nl Exemption is requested from Section III-G.2.a of Appendix R since the redundant 'charging pumps and related equipment are not separated by a full height 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire barrier.

Evaluation Nl Ionization type smoke detection system is provided as shown on drawings 8770-G-413

')

The charging pumps are approximately 10 ft apart separated by a 7

ft high 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated partition, with labyrinth entries from the common access corridor.

3)

The access corridor contains charging pump push button stations, separated by more than 20 ft with negligible intervening combustibles.

The pushbutton station for Charging Pump 1B is being relocated from the common access corridor to in'side the Charging Pump 1B cubicle.

R3 5)

Conduits carrying cables for charging Pump 1A in Fire Zone 38 will be provided with minimum one hour rated protection.

6)

This fire area contains a very low combustible loading and as a

radiation'area has limited personnel

access, thus reducing the probability of introducing transient 'combustibles.

7)

A fire on either side of the fire partitions involving in-situ and/or transient combustibles would not directly impinge upon or-radiate heat to the essential equipment on the opposite side.

While 'localized high off-gas temperatures can be expected in the vicinity of a fire, air mixture dilution temperatures which would stratify'in the uppe'r level of this area would not reach a point capable of jeopardizing the operation of the redundant charging pumps')

Cables routed in this area are in steel conduits.

Redundant essential cables extending above the fi:re rated partition are provided with a minimum one hour rated protection.

-R3 024F/03F

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Conclusion Nl Based on our evaluation, the 7 ft 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated partitions and one hour conduit protection provide adequate separation of the redundant charging pumps d their related equipment.

The extension of the walls to full height would an i

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d not augment or materially enhance the safety of the plant sxnce xt woul not prove rovide additional protection for redundant charging pumps.

Therefore, we conclude that this is an acceptable exemption fr'om Appendix R to 10 CFR50, Section III&.2.a.

R3 Exemption N2 - Deleted; incorporated in Exemption Nl.

Exem tion N3 An exemption is requested from Section III-G.2.a of Appendix R for watertight door RA-8 because the fire rating of the custom manufactured door is not Underwriters Laboratory listed.

Evaluation N3 - See Evaluation J4.

Conclusion N3 See Evaluation J4.

Exem tion N4 An exemption is requested from Section III-G.2a of Appendix R because fire retardant coatings are not provided for the structural steel supporting the steel conduits which are wrapped to provide separation in accordance with Appendix R.

Evaluation N4 1)

Ionization type smoke detection system is provided as shown on drawings 8770-G-413.

2)

Portable fire extinguishers and a fire standpipe system with hose stations are available for use in the Fire Area.

R3 3)

See Evaluation A3, Items 3 thru 5 ~

Conclusion N4 See Conclusion A3. 024F/03F

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FIRE AREA "0" This fire area includes fire zones 27 (Aerated Waste Storage Tank Area),

29 (Chemical= Drain Tank Area),

36 (Main Hallway -0.5 Elevation),

37 (Boric Acid Condensate Room),

39 (Gas Decay Tank Area),

40 (Boric Acid Make-up Tank Room) and 74 (Spent Resin Tank Room) as shown on the attached drawings.

Essential equipment within this fire area is shown in the'ttached essential equipment list+

The following exemptions to Appendix R to 10CFR50 are requested:

Exem tion 02 An exemption is requested from Section III-G.2.a of Appendix R for the hatch at Column RAC/RA4 because a steel hatch cover of 1/4 inch minimum thickness is being provided at elevation 19.50 feet.

Evaluation 02 - See Evaluation El Conclusion 02 See Conclusion El Exem tion 03 An exemption is requested from Sec'tion III-G.2.a o'f Appendix R for the hatch at Column RAJ/RA5 because a steel hatch cover of 1/4 inch minimum thickness is being provided at elevation 19.50 feet.

Evaluation 03 -'ee Evaluation C2 Conclusion 03 See Conclusion C2 Exem tion 04 An exemption is requested from Section III-G.2.a of Appendix R for watertight doors RA-4, 5 and 6 because the fire rating of the 'custom manufactured doors is not Underwriters Laboratory listed.

Evaluation 04 See Evaluation M-2 Conclusion 04 - See Conclusion M-2 024F/03F

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Exem tion 05 An exemption is requested from Section III-G.2a of Appendix R because fire retardant coatings are not provided for the structural steel supporting the steel conduits which are wrapped to provide separation in accordance with Appendix R.

Evaluation 05 1)

Ionization type smoke detection system is provided over essential cable trays in this fire. area as shown on drawings 8770-G-413.

2)

Portable fire extinguishers and a fire standpipe system with hose stations are available for use in the area.

R3 3)

See Evaluation A3, Items 3 thru 5.

Conclusion 05 See Conclusion A3. 024F/03F

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FIRE AREA "P-P" This fire area is Fire Zones 64 through 69 (Fuel Handling Building) as shown on the attached drawings.

This fire area contains no essential equipment or cables and Appendix R Section III-G does not apply. =

024F/03F

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FIRE AREA "-

This fire area is Fire Zones 13 through 25 {Turbine Building) as shown on the attached drawings'his fire area contains no essential equipment or cables and Appendix R Section III-G does not apply.

024F/03F

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FIRE AREA "R-R" This fire -area is Fire Zone 3 (Intake Cooling Water Pump Area) as shown on the attached drawings.

Essential equipment within this fire area is shown in the attached Essential Equipment List.

The following exemption from Appendix R to 10CFR50 is requested:

Exem tion R-R 1

An exemption from Section III-G.2.b of Appendix R is requested because no automatic suppression system is provided.

Evaluation R-R 1

2)

This fire area is lightly trafficked, thus minimizing the probability of introducing transient combustibles.

The fire area has low combustible load and no continuity of combustibles.

"3)

The pumps are over 13 ft apart centerline to centerline'able and conduit is embedded in concrete and exposed only for a"short length at each pump.

4)

A postulated fire involving in-situ and)or transient combustibles will be prevented from spreading at the pump level by the floor openings and curbs separating each pump.

5)

The pump room is designed for natural ventilation which precludes the buildup of heat.

e)

Fire Ar'ea R-R is provided with fire detectors at each pump as shown on drawings 8770-G-413'3 Conclusion R-Rl Based on our evaluation, the existing arrangement provides adequate protection for the redundant Intake Cooling Water Pumps.

The installation of an automatic suppression system would not augment or materially enhance the safety of the plant since the area design prevents the migration of a fire.

Therefore, we conclude that this is an acceptable exemption from Appendix R to

10CFR50, Section III-G.2.b. 024F/03F

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FIRE AREA "S-S" This fire area is Fire Zone 1 (Steam Trestle Area) as shown on the attached drawings'ssential equipment within this fire area is shown in the attached essential equipment list.

The following exemption to Appendix R to 10CFR50 is requested:

An exemption is requested from Section III-G.2.a of Appendix R because a

3 h'our fire barrier is not provided between Auxiliary Feed Water Pumps A and B

and its redundant counterpaits Auxiliary Feed Water Pump C.

Evaluation S-Sl 1)

Portable fire,extinguisher are available for use in this area.

2).

The fire area is lightly trafficked thus minimizing the probability of introducing transient combustibles.

3)

The fire area has a negligible combustble loading with no continuity of combustibles.

I R3-4)

Auxiliary Feed Water Pump C and its associated valves and, cables has adequate separation from its redundant counterparts, Auxiliary Feed Water Pumps A.and B and their associated

.valves and.cables.

R3 5)

Pump C is located within a concrete dike wall and steel missile

. shield.

Pumps A and B are located within a separate but similar enclosures.

6)

Auxiliary Feed Water Pumps A 6 B are located within a concrete dike

wall, 8 inches thick, 2'-6" high and a one inch thick missile shield approximately 9'-0" high.

This missile shield extends from the 19.50'levation to the underside of the 5/16 inch thick steel platform at Elevation 41.08' R3 7)

Auxiliary Feed Water Pump.C is located within a separate and similar enclosure.

8)

This is an open-air structure, dissipation to atmosphere from transient combustibles.

allowing.for verical heat a fire involving in-situ and/or 9)

Fire detectors are being provided in the fire area, consistin'g of two detectors at the Pump C trestle and two detectors at the Pumps A and B trestle as shown on drawings 8770-G-413.

R3 Conclusion S-S1 Based on our evaluation, the existing 1 inch missile shields and the 8 inch concrete dike, is equal to or better than a

3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire barrier.

The installation of a three hour fire barrier would not'augment or materially enhance the safety of the plant.

Therefore, we conclude, this is an acceptable deviation to Appendix R to 10CFR50 Section III-G.2.a.

R3'43-024F/03F

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FIRE AREA "T=T" This fire area is Fire Zone 4 (Diesel Oil Storage Tanks) as shown on the attached drawings.

Essential equipment within this fire area is shown in the attached essential equipment list.

The following exemption to Appendix R to 10CFR50 is requested:

'J Exem tion T-Tl An exemption is requested from Section III-G.2.b of Appendix R for fire detection and an automatic fire suppression system because detectors and automatic fire suppression are not provided.,

Evaluation T-Tl 1)

The area is lightly trafficked, thus minimizing the probability of introducing combus tibles.

2)

Adequate special separation from other plant equipment required for safe shutdown is provided.

3)

Outdoor exposure fires are not postulated in the plant yard igniting the diesel oil based on the lack of combustible storage adjacent to the tanks.

4)

Redundant tanks are 21 feet apart, shell to shell.

5')

Redundant tanks are in separate 5.5 ft high concrete dikes.

6)

Tank spacing and diking arrangement exceed the requirements of the National Fire Code (NFPA 30, 1973).

7)

NFPA 30, 1973 of the National Fire Codes does not require detection or automatic suppression for the diesel oil tanks as presently arranged.

R3 l R3 8)

An intertie is available to utilize the St Lucie Unit 2 Diesel Oil Storage Tanks.

Conclusion T-Tl Based on our evaluation the existing tank spacing and dikes provide adequate separation.

The installation of fire detection and automatic suppression would not augment or materially enhance the safety of the plant since it would not improve the existing adequate separation provided.

Therefore, we conclude, this is an acceptable exemption to Appendix R to 10CFR50, Section III-G.2.b. 024F/03F

FIRE AREA "U-U" This fire area is Fire Zone 5 (Component Cooling Area) as shown on the attached drawings.

Essential equipment within this area is shown in the attached essential equipment list.

The following exemption from Appendix R to 10CFR50 is requested:

Exemption U-Ul An exemption is requested from Section III-G.2.b of.Appendix R for automatic fire suppression system and partial area coverage for fire detection because an automatic fire suppresion system is not provided and only one fire detector per pump will be provided.

Evaluation U-Ul This area is lightly trafficked thus the probability of introducing transient combustibles is minimized.

2)

The Fire Area has a very low combustible load with no continuity of combustibles.

3)

Each Component Cooling Water Pump and Heat Exchanger is mounted on an 11.5 foot high concrete pedestal surrounded by open metal grate at elevation 23.5 feet.

Pump and Heat Exchanger 1A are 11 feet from Pump 1C and 30 feet from Pump and Heat Exchanger 1B.

Pump and Heat Exchanger 1B is also 11 feet from Pump" 1C (distances measured from nearest edge to nearest edge).

Power-cables to pumps are located in buried conduit, with a short exposed section at each pump and motorized isolation valve.

Failure of the motorized valves in any combination of positions will not affect system capability, therefore, cable to the valves is not addressed further.

4)

The, metal grate will prevent a pool fire at the pump level, and the existing separation is considered adequate for the pumps and c'able (each capable of supplying 100 percent of the cold shutdown requirements) from an exposure fire 11,5 feet below.

5)

Fire detectors are being provided in the fire area, consisting of one detector at each Component Cooling Water Pump as shown on drawings 8770"G-413.

)

R3 6)

This is on open-air structure, allowing for vertical heat dissipation to atmosphere from a fire involving in-situ and/or transient combustibles.

R3 Conclusion U-Ul Based on our evaluation, installation of proposed fire detection in addition to the existing arrangement provides adequate protection for the redundant Component Cooling Water Pumps.

The installation of an automatic fire suppression system and additional detectors would not augment or materially enhance the safety of the plant since no single fire would effect redundant equipment.

Therefore, we conclude that this is an acceptable exemption to Appendix R to 10CFR50, Section III-G.2.b. 024F/03F

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FIRE AREA "V-V" This fire area is Fire Zone 8 (Refueling Water Tank) as shown on the attached drawings.

Essential equipment within this fire area is shown in the'ttached essential equipment list.

The tank contains in excess of 400,000 from an exposure fire would be rapidly the contained water.

Thus the tank is fire.

gallons of water.

The heat generated dissipated through the tank wall into no subject to damage from the exposure This fire area meets the criteria of Appendix R to 10CRF50, Section III-G.1. 024F/03F

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FIRE AREA "W-W" This'ire area is Fire Zone 9 (Primary Water Tank) as shown on the attached drawings.

This fire area contains no essential equipment or cables and Appendix R Section III-G does not apply. 024F/03F

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FIRE AREA "X-X" This Fire Area is fire zone 2 (Condensate Storage Tank Area) as shown on the attached drawings.

Essential equipment is shown in the attached essential equipment list.

The Condensate Storage Tank contains over 300,000 gallons of water.

The heat generated from any exposure fire external to the tank would be rapidly dissipated through the tank wall into the contained water.

Thus the tank is not susceptible to damage from external exposure fires.

This fire area meets the criteria of Appendix R to 10CFR50, Section III-G.l~ 024F/03F

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FIRE AREA "Y-Y" This fire area is Fire Zones 72 and 63 (RAB Roof and RAB Blowdown Heat Exchanger) as shown on the attached drawings.

This fire area contains no essential equipment or cables and Appendix R Section III-G does not apply. 024F/03F