Text

Response to Request for Additional Information License Amendment to Transition to NFPA 805
	ML13353A417
Person / Time
Site:	Ginna
Issue date:	12/17/2013
From:	Joseph Pacher; Constellation Energy Nuclear Group, EDF Group
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML13353A417 (117)
	v • d • e

Joseph Pacher Office: 585-771-5200 Site Vice President Fax: 585-771-3943 Email: Joseph.Pacher@cengllc.com CENGOS a joint venture of Constellation eDF Energy, 10 December 17, 2013 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

SUBJECT:

R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 Docket No. 50-244 Response to Request for Additional Information RE: License Amendment to transition to NFPA 805

REFERENCES:

(a) Letter from Mr. Joseph E. Pacher (Ginna LLC) to Document Control Desk (NRC) dated March 28, 2013,

Subject:

License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Perfornmance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (ML13093A064)

By Reference (a), R.E. Ginna Nuclear Plant, LLC (REG) submitted a request for the adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants.

On October 9, 2013, the NRC requested additional information regarding this submittal. Attached please find the first set of three responses to the staffs questions and revised documentation. There are no regulatory commitments identified in this letter.

Should you have any questions regarding this submittal, please contact Thomas Harding at 585-771-5219.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December 17, 2013.

S' lcerely, JP/KC Attachument: (1) 60-Day Responses to Request for Additional Information for NFPA 805 R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road, Ontario, New York 14519-9364

Document Control Desk December 17, 2013 Page 2 cc: NRC Regional Administrator, Region I NRC Project Manager, Ginna NRC Resident Inspector, Ginna A.L. Peterson, NYSERDA

Attachment (1) 60-Day Responses to Request for Additional Information for NFPA 805

60-Day Responses to Request for Additional Information for NFPA 805 FM RAI 02 American Society of Mechanical Engineers/American Nuclear Society (ASME/ANS) Standard RA-S-2008, "Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessments for Nuclear Power Plant Applications.", Part 4, requires damage thresholds be established to support the FPRA. Thermal impact(s) must be considered in determining the potential for thermal damage of SSCs. Appropriate temperature and critical heat flux criteria must be used in the analysis.

1. Describe how the installed cabling in the power block was characterized, specifically with regard to the critical damage threshold temperatures and critical heat flux for thermoset and thermoplastic cables as described in NUREG/CR-6850.

2. During the audit, it was discussed that four cables, which run through one of the battery rooms (BRIA) are credited with thermoset damage thresholds for the purposes of fire modeling and PRA calculations. Provide justification for treating these cables differently than the rest of the cables at the plant.

Response

1. All targets are assumed to be of thermoplastic material for damage criteria (i.e., 205 C and 6 kW.m 2, NUREG/CR-6850 Table H-i) with one exception, which is discussed later in the response to this RAI. The assumption of thermoplastic damage criteria is documented in G1-FSS-FOO1, section B.1.

2. The exception to thermoplastic damage criteria applies to cables in 5 conduits in Battery Room A These 5 conduits were verified to be of Thermoset insulation material (Ginna Key 2

Input 83, EWR-1444, and PCR-98-015) and the damage criteria of 330 C and 11 kW/m described in NUREG/CR-6850 Table H-1 was assigned to them. The treatment of the 5 conduits in Battery Room A is documented in G1-FSS-FOO1, Appendix B.

FM RAI 02 1

Page 1 of 114

60-Day Responses to Request for Additional Information for NFPA 805 FM RAI 05 Section 4.5.1.2, "Fire PRA" of the Transition Report states that fire modeling was performed as part of the Fire PRA development (NFPA 805, Section 4.2.4.2). This requires that qualified fire modeling and PRA personnel work together. Furthermore, Section 4.7.3, "Compliance with Quality Requirements in Section 2.7.3 of NFPA 805," of the Transition Report states that "Cognizant personnel who use and apply engineering analysis and numerical methods in support of compliance with 10 CFR 50.48(c) are competent and experienced as required by Section 2.7.3.4 of NFPA 805."

Regarding qualifications of users of engineering analyses and numerical models (i.e., fire modeling techniques):

1. What are the licensee's requirements to qualify personnel for performing fire modeling calculations in the NFPA 805 transition?

2. What is the process for ensuring that the fire modeling personnel meet those qualifications, not only before the transition but also during and following the transition?

3. When fire modeling is performed in support of FPRA, how is proper communication between the fire modeling and Fire PRA personnel ensured?

Response

1. Fire modeling calculations will be performed by a Fire Protection Engineer who meets the qualification requirements of Section 2.7.3.4 of NFPA 805. The qualification process will follow the guidance of ACAD 98-004 and CENG procedure CNG-TR-1.01-1000, "Conduct of Training." All those performing Fire Modeling for the Fire PRA require qualification to Fire PRA (ESP-FIQ-FPRA) and are documented per CNG-TR-1.01-1014. This qualification includes basic fire modeling techniques as part of the qualification as well as Fire PRA techniques. The CENG PRA Engineering Supervisor reviews experience and education for all Fire Modeling work. Those performing detailed fire modeling analysis using tools such as CFAST (Consolidated Model of Fire and Transport) or FDS (Fire Dynamics Simulator) will be required to have the relevant education and experience in fire modeling to perform the analysis.

2. In the case of the initial fire modeling, the vendor provided the credentials of the fire modelers, which were reviewed and approved by CENG supervision per procedure CNG-TR-1.01-1000. During and following transition, the existing engineering staff will continue to be knowledgeable in fire modeling techniques, including interpreting and maintaining the fire modeling database. If new fire modeling personnel are needed in the future, their credentials will also be reviewed and approved by CENG supervision. Also, per CNG-TR-1.01-1014, Section 4.6.0 requires that Engineering Supervisors have responsibility for "Verifying qualifications prior to assigning personnel to perform job performance requirement independently". This requires verifying the qualifications in the training server to verify the qualification is current.

FM RAI 05 1

Page 2 of 114

60-Day Responses to Request for Additional Information for NFPA 805

3. Throughout the Fire PRA process, the Fire Protection Engineers (FPE) who conducted the fire modeling and the PRA engineers maintained frequent communications. During the development phase of the Fire PRA, the fire modeling personnel populated the fire modeling database (FMDB), in which all the relevant fire modeling inputs are maintained. The scenario frequencies, which are produced by the FMDB, are electronically sent to the PRA engineers, who perform the quantification. Both the FPEs and the PRA engineers participated in the cutset review meetings during the development of the Fire PRA. The fire modeling database will be maintained under the responsibility of the FPE and the PRA engineers.

FM RAI 05 2

Page 3 of 114

60-Day Responses to Request for Additional Information for NFPA 805 FPE RAI 01 The compliance statement for License Amendment Request (LAR) (Agency wide Documents Access and Management System (ADAMS) Accession Number ML13093A065), Attachment A, Table B-i, Section 3.3.6 is "complies with use of evaluation". National Fire Protection Association Standard 805, "Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants" (NFPA 805), Section 3.3.6, requires metal roof coverings be Class A as determined by tests described in NFPA Standard 256, "Standard Methods of Fire Tests of Roof Coverings". The compliance basis states that "all metal roofs were specified to be FM class I.. The basis further describes the difference between the scope of testing for a Class A rating versus the scope of testing for a Factory Mutual (FM) Class 1 rating as detailed in FM Approval Standard 4470, "Approval Standard for Single-Ply, Polymer-Modified Bitumen Sheet, Built-Up Roof (BUR) and Liquid Applied Roof Assemblies for use in Class 1 and Noncombustible Roof Deck Construction." Section 4 of FM 4470 indicates that Class A, B, and C materials may achieve an FM Class I rating provided the conditions of acceptance for spread of flame, intermittent flame and burning brand are met. Provide a justification demonstrating how the requirements of Class A are met using the alternate classification.

Response

The following is a description of the changes to LAR Attachment A, Table B-i, Section 3.3.6:

Change compliance statement associated with the B-1 table section 3.3.6 to:

"Complies via Previous Approval" and "Complies with use of Evaluation" Delete compliance basis in its entirety and replace with:

Compliance basis statement associated with "Complies via Previous Approval" to:

For the Fire Protection Evaluation documented via, letter From L.D. White, RG&E, To A.

Schwencer, NRC "Fire Protection Evaluation (Gilbert Associates Report No. 1936) dated 02/24/1977 Accession # 4006003751 [RG010540] [Sec. 5.0, Guideline D.1.e, pg. 5-23] the response to BTP APCSB 9.5-1, Appendix A, Guideline D.1.e stated, "All metal roofs were specified to be FM Class I except the Screen House. The FHA describes the roof construction for this area and outlines fire protection requirements."

Compliance basis statement associated with complies with use of Evaluation to:

"As part of the NFPA 805 transition process, Design Analysis DA-ME-08-013 was issued to document the acceptability of the Screen House roof assembly. Based on the low combustible loading inside the Screen House and the passive and active fire suppression features to mitigate a fire, the lack of a Class A roof was evaluated in the design analysis as being acceptable. As stated in the analysis, "There are robust fire mitigating design features within the Screen House which include: curbing around the diesel fire pump and oil storage tank, a drainage system within the curbed area, an automatic deluge sprinkler system S17 and smoke detectors installed over the cable trays in the SH basement, an automatic wet-pipe suppression system S18 and detection system Z26 installed above the fire pumps and service water pumps in the SH Operating floor, inside and outside hose reel coverage, and a large overhead door located in the south wall and roof exhaust fans to be used for potential smoke removal." The credited bases for acceptance are valid and meet applicable quality requirements."

FPE RAI 01 1

Page 4 of 114

60-Day Responses to Request for Additional Information for NFPA 805 "For new construction, A-202 [3.3.13] is the administrative control to utilize Class A roof coverings as determined by tests described in NFPA 256-2003."

FPE RAI 01 2

Page 5 of 114

60-Day Responses to Request for Additional Information for NFPA 805 Constellation Energy Nuclear Group Attachment A - NEI 04-02 Table B-1 Transition of Fundament Fire Protection Program & Design Elements NFPA 805 Requirements/Guidance Compliance Compliance Basis References Chapter 3 Statement Reference 3.3.6 Metal roof deck construction shall be designed and For the Fire Protection Evaluation documented via, RG010540, RG&E Fire Roofs installed so the roofing system will not sustain a use-ef letter From L.D. White, RG&E, To A. Schwencer, Protection Evaluation, self-propagating fire on the underside of the deck NRC "Fire Protection Evaluation (Gilbert 2/24/77 when the deck is heated by a fire inside the

)Accession Associates Report No. 1936) dated 02/24/1977 DA-ME-08-013,rev. 0, building. Roof coverings shall be Class A as determined by tests described in NFPA 256, Standard Methods of Fire Tests of Roof Coverings. ( Complies via Previous Approval

4006003751 (RG010540] [Sec. 5.0, Guideline DAle, pg. 5-23], the response to BTP APCSB 9.5-1, Appendix A, Guideline D.1.e stated, "All metal roofs were specified to be FM Class I Evaluation of Screen House Roof Assembly A-202,rev. 03100, The Fire Protection Program except the Screen House. The FHA describes the and Ginna Station Staff roof construction for this area and outlines fire Responsibilities for Fire protection requirements.' A Class. A rating rolatcs Protection to 1 oxternar fire ponornmanco roqui-rs that w ers a roof dock acccmbly is ,R-,-- -1aG ansubje6t4e te aRcorice of toctcInton fire,eoxtoFRral fire.-wind Uplift im..pat roSiratanco, foo9t traffic, cForroion FrozictaRG9, r*tAn., and suceopt~bility te heat damage as doscr.ibod in FM 4479 Approval Standward- for Clacs 1 Roof CoVors. A root assembly must pass all those tests in erdor o ga!9 a Clace 1 d6signation, FMV Clao 1.inncludoes FIa.447*n*.d FIVI440 Approval Standard for CGlse

1. n'cuatod Stool Docks Roofs. A Class 1 Complies with arefoAmbly cn b- ,ube ! foraClass A, B or- C 4tuo use of roof Annomblv foi~nc it inmo C AAocR.'AtI'.'l.

Evaluation As part of the NFPA 805 transition process, Design Analysis DA-ME-08-013 was issued to document the acceptability of the Screen House roof assembly. Based on the low combustible loading inside the Screen House and 'the passive and active fire suppression features to mitigate a fire, the lack of a Class A roof was evaluatihe-design analysis as beinq acceptable, As stated in reare roaus fir,**mitigating design features within the Screen House which include: curbing around the diesel fire pump and oil storage tank, a drainage system within the curbed area, an automatic deluge sprinkler system S17 and smoke detectors installed over the cable trays in the SH basement, an automatic wet-pipe suppression system S18 and detection system Z26

ý1_ J Ginna LAR Rev 0 Page A-19 Page 6 of 114

60-Day Responses to Request for Additional Information for NFPA 805 Constellation Energy Nuclear Group Attachment A - NEI 04-02 Table B-1 Transition of Fundament Fire Protection Program & Design Elements Compliance Basis References I

installed above the fire pumps and service water 3.3.6 pumps in the SH Operating floor, inside and Roofs outside hose reel coverage, and a large overhead (Continued) door located in the south wall and roof exhaust to be used for ote.Lamoke remoal**

The rfor acceptance are valid and meet applicable quality requirements.

For new construction, A-202 [3.3.13] is the administrative control to utilize Class A roof coverings as determined by tests described in NFPA 256 - 2003.

I _________ _____________________________ _________________

U _____________________________

Page A-20 Ginna LAR Rev Ginna LAR Rev 0 0 Page A-20 Page 7 of 114

60-Day Responses to Request for Additional Information for NFPA 805 FPE RAI 02 The compliance basis for LAR Attachment A, Table B-i, Section 3.3.7 states that flammable gas storage in fire areas TB-1 and TB-2 is such that the total content is less than 400 standard cubic feet (scf). The basis further states that NFPA Standard 55, 2010 edition, "Compressed Gases and Cryogenic Fluids Code," Section 10.1.1, indicates that the chapter "does not apply to individual systems using containers having a total hydrogen content of less than 400 scf, if each system is separated by a distance not less than 5ft." Describe the configuration of flammable gas storage in these fire areas and the administrative controls used to ensure the volume of flammable gas is maintained below 400 scf.

Response

The following description will be added to LAR Attachment A, Table B-I, Section 3.3.7:

The gas bottle racks are anchored to the concrete pedestal in the air ejector area located in the Turbine Building Mezzanine, and are also located greater than 5' away from the rack located in the Turbine Building Basement near the elevator. The racks are not located in the vicinity of any safety related equipment. The racks are located in a non-seismic building with no seismic category 1 or SR equipment; therefore, the rack is not required to meet seismic criteria. Signs are also provided to ensure total hydrogen content less than 400 scf.

FPE RAI 02 1

Page 8 of 114

60-Day Responses to Request for Additional Information for NFPA 805 Constellation Energy Nuclear Group Attachment A - NEI 04-02 Table B-1 Transition of Fundament Fire Protection Program & Design Elements NFPA 805 Requirements/Guidance Compliance Compliance Basis References Chapter 3 Statement Reference 3.3.7 Bulk Flammable Gas Storage. Bulk compressed or Complies with Provisions are in place via A-202 [Sec. 3.7] and " DA-ME-2002-005,rev. 0, Bulk Flammable cryogenic flammable gas storage shall not be use of FPS-16 [Attach. 3] that prohibit bulk storage of Primary and Secondary Gas Storage permitted inside structures housing systems, Evaluation compressed or cryogenic flammable gas within Hydrogen Storage equipment, or components important to nuclear structures housing systems, equipment, or Buildings NFPA 50A Code safety. components important to safety. With the exception Review.

of the Primary and Secondary Hydrogen Storage " A-202,rev. 03100, The Buildings, FPS-16 requires that bulk compressed Fire Protection Program or cryogenic flammable gas be stored outdoors, a and Ginna Station Staff minimum of 50 feet away from buildings, Responsibilities for Fire structures, and equipment. Protection FPS-16,rev. 01700, Bulk The Primary and Secondary Hydrogen Storage Storage of Combustible Buildings, which are designated storage areas, are Materials and Transient separated from adjacent plant structures by 3-hour Fire Loads rated fire barriers such that a fire or explosion will not adversely impact systems, equipment, or components important to nuclear safety.

Assessment of the Hydrogen Storage Buildings with the applicable requirements of NFPA 50A has been documented via DA-ME-2002-005. The credited bases for acceptance are valid and meet applicable quality requirements.

The gas bottle racks are anchored to the concrete pedestal in the air ejector area located in the K

Turbine Building Mezzanine, and are also located greater than 5' away from the rack located in the Turbine Building Basement near the elevator. The racks are not located in the vicinity of any safety related equipment. The racks are located in a non-seismic building with no seismic category 1 or SR equipment; therefore, the rack is not required to meet seismic criteria. Signs are also provided to ensure total hydrogen content less than 400 scf.

I. .1_____________ +/- ________________________________________ a Ginna LAR Rev 0 Page A-18 Page 9 of 114

60-Day Responses to Request for Additional Information for NFPA 805 FPE RAI 03 The compliance statement for LAR Attachment A, Table B-i, Section 3.4.1(c) is "complies".

NFPA 805, Section 3.4.1(c) specifically requires the fire brigade leader and two brigade members to have sufficient training and knowledge of nuclear safety systems to understand the effects of fire and fire suppressants on nuclear safety performance criteria. The compliance basis for this element states that that the Brigade Captain and Backup Brigade Captain are Auxiliary Operators, but does not specify the details of the training and knowledge of these members.

Describe how the requirements of NFPA 805 Section 3.4.1(c) are met with regard to training and knowledge of the brigade leader and at least two of the brigade members.

An approach acceptable to the staff for meeting this training and knowledge requirement is provided in Regulatory Guide (RG) 1.189, "Fire Protection for Nuclear Power Plants," Rev. 2, Section 1.6.4.1, Qualifications:

"The brigade leader and at least two brigade members should have sufficient training in or knowledge of plant systems to understand the effects of fire and fire suppressants on safe-shutdown capability. The brigade leader should be competent to assess the potential safety consequences of a fire and advise control room personnel. Such competence by the brigade leader may be evidenced by possession of an operator's license or equivalent knowledge of plant systems."

Response

The following is a description of the changes to LAR Attachment A, Table B-i, Section 3.4.1 (c):

Change compliance statement to: "Complies via Previous Approval".

Change compliance basis to:

Ginna's fire protection program is consistent with existing commitments and utilizes a compliance category of "Complies by previous NRC Approval" in accordance with NFPA 805 Section 3.1. The fire brigade training is acceptable per letter From D.L. Ziemann, NRC To L.D.

White, RG&E, "Fire Protection SER with Summary of MODs, Evaluation of Plant Features &

Specific Plant Areas" dated 02/14/1979, Accession # 7903140202 [RG001680] Sections 3.1.31 and 6.2, along with Ginna Station Fire Protection Program Report Table A-1 Appendix A Section B.5.b [EPM-FPPR].

FPE RAI 03 1

Page 10 of 114

60-Day Responses to Request for Additional Information for NFPA 805 Constellation Energy Nuclear Group Attachment A - NEI 04-02 Table B-1 Transition of Fundament Fire Protection Program & Design Elements NFPA 805 Requirements/Guidance Compliance Compliance Basis References Chapter 3 Statement Reference 3.4.1(c) During every shift, the brigade leader and at least A '2A') Mcý, 32A 151 a~.- the. Fi~ F2Et~l

EPM-FPPR ANL,rev. 8.0, Brigade Members two brigade members shall have sufficient training Fire Protection Program Training and knowledge of nuclear safety systems to KCo~mplies 7.1]!rcFquiFrcs that the Fire Brigade Captain an~d Report (FPPR) understand the effects of fire and fire suppressants on nuclear safety performance criteria. Exception to (c): Sufficient training and knowledge shall be

( via Previous Approval Backup Fire Brigade Captain On; oach Shift b9 trained plant Auxiliary OperatoFrs, have fire brigad mcmbor: qualification training, and- additionalFife

A 202,rev. 03100, The-Fire Protection Program and GiOnn Statil ta#

permitted to be provided by an operations advisor , Captain

-igad training. Additionally, one (1) Respensibilitfiec f(ar Fire dedicated to industrial fire brigade support. additional FiPre Brigade m. mbr On each 6hift ic required to be a trained plant Auxilia;.y Operator RG0016 K Safety R , '

and have fire brigade nmhembe qu alification tainig Ginna's fire protection program is consistent with "

Evaluation Report Docket No. 50-244, 2/14/1979. )

existing commitments and utilizes a compliance category of "Complies by previous NRC Approval" in accordance with NFPA 805 Section 3.1. The fire brigade training is acceptable per NRC FP SER, 2/14/79, sections 3.1.31 and 6.2 [RG001680],

along with the Fire Protection Program Report Table A-i, Appendix A section B.5.b [EPM-FPPRJ.

+/-_________________________________________________ I ________________ L_________________________________________________

Ginna LAR Rev 0 Page A-28 Page 11 of 114

60-Day Responses to Request for Additional Information for NFPA 805 FPE RAI 04 The compliance basis for LAR Attachment A, Table B-i, Section 3.11.5 states that Hemyc wrap is installed in Battery Room lB. LAR Attachment S, Table S-2, Item 7 is an implementation item to evaluate the existing configuration of the wrap to determine if it is adequate to protect certain cables for 45 minutes and to modify the wrap to ensure 45 minutes is achieved. NFPA 805 Section 3.11.5 states that "electrical raceway fire barrier systems (ERFBS) required by chapter 4 shall be capable of resisting the fire effects of hazards in the area", and "ERFBS shall be tested in accordance with and shall meet the acceptance criteria of NRC Generic Letter 86-10, Supplement 1." Provide additional detail regarding the capability of this ERFBS to meet the requirements of NFPA 805 Section 3.11.5. Include in the response a discussion of how the ERFBS duration is based on fire testing of similar material and application.

Response

An analysis has been performed to address the commitment of LAR Attachment S, Table S-2, Item 7. The analysis (Ref. 0028-0018-000-001) compares the Ginna Hemyc wrap configuration in Battery Room B to the following test configurations and is representative of the wrap configuration in the field (air drops, terminations, support / interference protection, collars, etc.):

Omega Point Laboratories, Inc., Project Number 14790-123264, Date: April 18, 2005, Titled:

HEMYC (1-Hour) Electrical Raceway Fire Barrier Systems Performance Testing: Cable Tray, Cable Air Drop and Junction Box Raceways.

Intertek Testing Services NA, Inc., Report Number 3106846, Revision Date: February 5, 2007, Titled: HEMYC 1-Hour Electrical Raceway Fire Barrier System (ERFBS), Fire Resistance Performance Furnace temperatures used in the testing follow the ASTM E-1 19 time-temperature curve. The specific combustible loading in BRIB is not an input in the analysis (Ref. 0028-0018-000-001).

The results of the evaluation (Ref. 0028-0018-000-001) indicate that the Hemyc wrap configuration will be able to provide 25 minutes of protection after the damage temperature (205 0C) of the thermoplastic cables is reached. This is provided that the Unistrut supports inside the steel cable chase are stuffed with ceramic fiber material to ensure a path for combustion products does not exist. 205 °C is the damage temperature of the thermoplastic cables according to NUREG/CR-6850 and as referenced in the Fire PRA Notebook G1-FSS-F001.

The installation of the needed ceramic fiber will be tracked via ESR-12-0142.

The fire PRA model will credit an additional 25 minutes of protection beyond the point where cables L0318 and C0687 in the back of Battery Room 1B would normally be damaged. This will be reflected in the overall results and the delta risk calculations which will be part of our Attachment W update. The Attachment W update will be transmitted as part of our to RAI PRA 44 response. The Hemyc protection is not being credited to deterministically resolve any FPE RAI 04 1

Page 12 of 114

60-Day Responses to Request for Additional Information for NFPA 805 VFDRs. The combustible loading in BR1B will be kept as low as reasonably achievable, such that the 1-hour structural steel fire proofing would not be compromised, as discussed in the B-1 Table section 3.11.2.

FPE RAI 04 2

Page 13 of 114

60-Day Responses to Request for Additional Information for NFPA 805 Constellation Energy Nuclear Group Attachment A - NEI 04-02 Table B-1 Transition of Fundament Fire Protection Program & Design Elements NFPA 805 Requirements/Guidance Compliance Compliance Basis References Chapter 3 Statement Reference 3.11.5 ERFBS "ELECTRICAL RACEWAY FIRE BARRIER SYSTEMS (ERFBS). ERFBS required by Chapter Complies Ginna is not crediting the existing HEMYC wrap configurations within the plant as a fire rated

" A-52.12,rev. 06801, Nonfunctional Equipment 4 shall be capable of resisting the fire effects of the barrier, with the exception of fire area BR1 B Important to Safety hazards in the area. ERFBS shall be tested in (Battery Room 1 B) as described below: " A-202,rev. 03100, The accordance with and shall meet the acceptance Fire Protection Program criteria of NRC Generic Letter 86-10, Supplement Engineering Service Request, ESR-12-0142, as and Ginna Station Staff 1, "Fire Endurance Test Acceptance Criteria for listed in Attachment S-2, item 7, of the LAR, will Responsibilities for Fire Fire Barrier Systems Used to Separate Safe determine if the existing configuration of the Hemyc Protection Shutdown Trains Within the Same Fire Area." The wrap (HWCB03) in the Battery Room 1B is " ESR-12-0142, NFPA 805 ERFBS needs to adequately address the design adequate to protect L0318, C0687, and a portion CDF Reduction Mod-014 requirements and limitations of supports and of E0053., for at least 4,5 minutcs. If the aRnalyic HWC£3 iuae*-t4-intervening items and their impact on the fire chowcV this- ;.6not pG6cciblo, a mo`1dificatiOn Will 139 barrier system rating. The fire barrier system's pei~emid Flald to the HamBYc to encuro 45 pratect L031 8, 00687, ability to maintain the required nuclear safety and Part of E0053-in,-th4e circuits free of fire damage for a specific thermal Batteiry Roam B for 45 exposure, barrier design, raceway size and type, cable size, fill, and type shall be demonstrated.

Exception No. 1: When the temperatures inside the

( An analysis has been performed to address the commitment of LAR Attachment S, Table S-2, Item

7. The analysis (Ref. 0028-0018-000-001)

FR;;Ut6 gi~enBatteFy Room B hac a major fire fire barrier system exceed the maximum compares the Ginna Hemyc wrap configuration in ( rbcuh that 15 minu-to is temperature allowed by the acceptance criteria of Battery Room B to the following test configurations defe~dbe Generic Letter 86-10, "Fire Endurance Acceptance and is representative of the wrap configuration in ,. c QW 2_ it( In 7 Test Criteria for Fire Barrier Systems Used to the field (air drops, terminations, support /

0028-0018-000-001, Separate Redundant Safe Shutdown Training Within the Same Fire Area," Supplement 1, P~AA interference protection, collars, etc.): Qualification of HEMYC Fire Barrier Wrap in functionality of the cable at these elevated Omega Point Laboratories, Inc., Project Number Battery Room B of Ginna temperatures shall be demonstrated. Qualification 14790-123264, Date: April 18, 2005, Titled: LNuclear Station, Revision demonstration of these cables shall be performed HEMYC (1-Hour) Electrical Raceway Fire Barrier 02.

in accordance with the electrical testing Systems Performance Testing: Cable Tray, Cable requirements of Generic Letter 86-1 0, Supplement Air Drop and Junction Box Raceways 1, Attachment 1, "Attachment Methods for Demonstrating Functionality of Cables Protected Intertek Testing Services NA, Inc., Report Number by Raceway Fire Barrier Systems During and After 3106846, Revision Date: February 5, 2007, Titled:

Fire Endurance Test Exposure." Exception No. 2: HEMYC 1-Hour Electrical Raceway Fire Barrier ERFBS systems employed prior to the issuance of System (ERFBS), Fire Resistance Performance Generic Letter 86-10, Supplement I, are acceptable providing that the system successfully met the Furnace temperatures used in the testing follow the limiting endpoint temperature requirements as ASTM E-1 19 time-temperature curve. The specific specified by the AHJ at the time of acceptance." combustible loading in BRIB is not an input in the II analysis (Ref. 0028-0018-000-001).

The results of the evaluation (Ref. 0028-0018-000- V Page A-84 Ginna LAR Rev Ginna LAR Rev 0 0 Page A-84 Page 14 of 114

60-Day Responses to Request for Additional Information for NFPA 805 Constellation Energy Nuclear Group Attachment A - NEI 04-02 Table B-1 Transition of Fundament Fire Protection Program & Design Elements NFPA 805 Requirements/Guidance Compliance Basis References Chapter 3 Reference 001) indicate that the Hemyc wrap configuration \

3.11.5 will be able to provide 25 minutes of protection 1/4 ERFBS after the damage temperature (205 °C) of the (Continued) thermoplastic cables is reached. This is provided that the Unistrut supports inside the steel cable chase are stuffed with ceramic fiber material to ensure a path for combustion products does not exist. 205 0C is the damage temperature of the thermoplastic cables according to NUREG/CR-6850 and as referenced in the Fire PRA Notebook G1 -FSS-FOO1. The credited bases for acceptance are valid and meet applicable quality requirements.

The installation of the needed ceramic fiber will be tracked via ESR-12-0142.

Ginna LAR Rev 0 Page A-85 Page 15 of 114

60-Day Responses to Request for Additional Information for NFPA 805 FPE RAI 05 LAR Attachment L, Approval Request 1, is for approval of the use of two portable gas fire heaters in the Screen House to keep the traveling screens from freezing during cold weather.

The basis for the request states that the closest equipment credited for the Nuclear Safety Capability Assessment (NSCA) in the Screen House, the motor fire pump and service water pumps, are at a minimum 40 feet from the location of the portable gas heaters, which places them outside the zone of influence (ZOI) of the heaters. Describe the administrative controls that ensure the portable heaters are located at a minimum of 40 feet from the NSCA equipment, each time they are installed. In addition, describe how the administrative controls of combustibles account for the heaters when installed, including any changes to bulk storage or transient fire load locations.

Response

The following is a description of the changes to LAR Attachment L, Approval Request 1 from the requirements of NFPA 805 Section 3.3.1.3.4:

Add this paragraph to the Basis for Request:

"The administrative controls that install the portable heaters are M- 115 (Installation and Removal of Screen House Gas Space Heaters)and T-35P (Screen House Supplemental Heat, Placingin Service, and Removal from Service). The gas line for the gas fired heaters is hard piped and therefore, the location is fixed, and maintainedat a distance which is at a minimum of 40 feet."

The administrative controls of combustibles is controlled by the use of FPS-16 (Bulk Storage of Combustible Materials and Transient Fire Loads), EP-3P-0132 (Combustible loading worksheet), and A-905 (Open Flame, Welding, and Grinding Permit) as described in the Combustible Loading discussion.

Add the following to the Combustible Loading discussion:

"There is no impact to the combustible loading analysis (ref. DA-ME-98-004) when the portable gas heaters are in service due to the hard piping of the gas supply. Transient combustibles are tracked administrativelythrough FPS-16, Attachment 2 (Transient Combustible Permit). The Fire Marshal or designee reviews the permit for the proposed usage and/or storage of transients,in regards to location, and includes potential restrictionsto be followed as necessary.

The Temporary Combustible Permit is periodically reviewed to ensure restrictionsare being followed and documented as part of the plant inspection program performed per A-54.7, Fire Protection Tour. Additionally, during the initial installationof the portable heaters, via procedure M- 115, there is a step to notify the Fire Marshal prior to performing the procedure. This will ensure the potentialfor a transientalready in place in the Screen House to be evaluated for relocationif it is in the proximity of the two portable gas fired heaters."

FPE RAI 05 1

Page 16 of 114

60-Day Responses to Request for Additional Information for NFPA 805 FPE RAI 06 LAR Attachment L, Approval Request 2, is for approval of wiring above suspended ceilings that may not comply with the requirements of NFPA 805, Section 3.3.5.1. The basis for the request indicates that there are multiple areas where suspended ceilings are located, however only the Control Room (CR) was discussed in detail. Provide a description of the other fire areas that contain wiring above suspended ceilings, including proximity to fire areas containing nuclear safety capability systems and equipment. Also, include a discussion on the type, use, and amount of wiring, proximity to combustibles, presence of ignition sources, as well as any fire detection or suppression features that may be installed.

Response

The Turbine Building Operating Level Conference Room and the MUX Room are incorrectly listed as rooms with wiring above suspended ceilings. These rooms are closed, self contained units (in essence "boxes") within larger rooms and won't be considered in this evaluation. LAR Attachment A, Section 3.3.5.1 will be revised to delete discussion of these rooms from the Compliance Basis. The TSC (Technical Support Center) and adjoining hallway, along with the Service Building Basement office areas are discussed in greater detail as shown below in the revised Approval Request 2:

Approval Request 2 NFPA 805, Section 3.3.5.1 states:

"Wiring above suspended ceiling shall be kept to a minimum. Where installed, electrical wiring shall be listed for plenum use, routed in armored cable, routed in metallic conduit, or routed in cable trays with solid metal top and bottom covers."

NRC approval is requested for a Performance-Based (PB) method to demonstrate an equivalent level of fire protection for the requirement of NFPA 805, section 3.3.5.1 regarding wiring above suspended ceilings.

Basis for Request Ginna has wiring above suspended ceilings that may not comply with the requirements of this code section. Suspended ceilings were identified in the following areas:

" Control Room

TSC (Technical Support Center) and adjoining hallway

Service Building Basement office areas These areas are not risk significant with the exception of the Control Room. A walk down of the areas revealed that the majority of the wiring is communication systems or lighting systems related.

Control Room The FIN (Fix it Now) team determined there are no active power cables above the suspended ceiling of the Control Room. One cable was abandoned in place with no power to it. Overall the FPE RAI 06 1

Page 17 of 114

60-Day Responses to Request for Additional Information for NFPA 805 cabling in the Control Room has a very low possibility of a fire due to limited combustible loading, discontinuity of combustibles, and the inherent features of the electrical circuit design.

The Control Room HVAC system design and operation supports the rapid identification of combustion products if a fire were to occur in the MCR suspended ceiling. The normal Control Room HVAC system is located in the basement floor of the three-story Control Building and is connected to the Control Room Envelope (CRE) by supply and return ducts that are located in the stairwell. The normal HVAC system supports the NORMAL and PURGE modes of operation. The system includes a supply and return air fan and in the NORMAL mode provides fresh outside air and exhaust, coarse filtration, and heating or cooling via electric heating or chilled water cooling coils. The NORMAL system includes a separate fan for lavatory exhaust, which is isolated in the EMERGENCY mode of operation. In the PURGE mode of operation the NORMAL system has the same functions described above while also providing the maximum amount of fresh air and exhaust air to purge airborne contaminants from the CRE.

The normal HVAC system's outside air intake duct is equipped with redundant trains of radiation, chlorine, and ammonia monitors. Any one of these six monitors reaching their setpoint will actuate the EMERGENCY mode of operation, employing the Control Room Emergency Air Treatment System (CREATS), along with providing an alarm in the Control Room. The normal HVAC system is also equipped with a smoke detector that monitors return air in the duct between the CRE and the return air fan, and provides an alarm in the Control Room. CREATS simply isolates and recirculates air within the CRE boundary in a closed-loop system. The existing fire detection system or the Control Room operators who are continuously present in the area would quickly identify the presence of smoke while the air is being recirculated.

The observed video/communication/data cables above this suspended ceiling are approximated to be less than 5% of the total space. Video/communication/data cables are low voltage. These low voltage cables are not generally susceptible to shorts which would result in a fire. The Control Room does contain NSCA components/equipment. Portable fire extinguishers are available in this zone. Hose reels are available for use on the Turbine Building Operating floor, if required. Smoke and heat detectors provide area detection for the Control Room, although they are not located above the suspended ceiling.

Technical Support Center (TSC) and adioining hallway A walk down determined that the quantity of wiring which may not be plenum rated or routed in a metallic conduit, above these ceilings is minor. Approximating, less than 1% of the space above the suspended ceilings in the TSC and adjoining hallways is occupied by electrical wiring that may not be listed for plenum use, routed in armored cable, or routed in metallic conduit.

The majority of this wiring is low voltage communications wiring or lighting systems related.

There are no intervening combustibles in the space above the suspended ceilings since the vast majority of equipment is metal, and all other wiring is routed in conduits.

The TSC hallway is located between the TSC and the Turbine Building Mezzanine and other rooms including the TSC diesel generator room, TSC inverter room, and TSC battery room. 3 hr fire door F7 (TSC south hallway door) is located between the TSC south hallway and the Turbine Building Mezzanine. 3 hr fire door F8 is located between the TSC south hallway to the TSC battery room, 3 hr fire door F9 is located between the TSC south hallway to the TSC inverter room, 3 hr fire door F10 is located between the TSC south hallway to the TSC diesel generator room, 3 hr fire door Fl 1 is located between the TSC south hallway to exterior, 3 hr FPE RAI 06 2

Page 18 of 114

60-Day Responses to Request for Additional Information for NFPA 805 rated fire door F12 between the TSC south hallway to the TSC office area, and a 3 hr rated fire door F14 (TSC north hallway door) between the TSC north hallway. [References EPM-FPPR, 33013-2617,1 and 21488-0119,3]. There also are 3 hr rated walls between the TSC north and south hallway and the Turbine Building Mezzanine, along with a 3 hr rated fire wall between the Safety Assessment System (SAS)/Power Plant Computer System (PPCS) computer room and the Turbine Building Mezzanine [EPM-FPPR and penetration database].

There were no ignition sources observed during the walk downs and the proximity of the wiring to areas containing NSCA equipment is not an issue since there are 3 hr rated walls and penetrations between these areas. There is also detection located in the hallways, and rooms within the TSC along with S30 automatic sprinkler system which provides suppression coverage for the TSC Diesel Generator Room and Operational Support Center. S27 is an automatic halon suppression system which provides suppression for the SAS/PPCS computer room and subfloor. Portable fire extinguishers are available in this zone and in adjacent fire areas/zones along with hose stations.

Service Building Basement office areas A walk down of the electric shop and mechanical maintenance administrative areas (fire zone SB-1) was conducted due their proximity to the Primary Water Treatment room (fire zone SB-1WT) which contains NSCA equipment including the condensate storage (CST) tanks and CST local level indicator. There was only (1) de-energized power cables observed above the electric shop ceiling. The quantity of electrical wiring that may not be listed for plenum use, routed in armored cable, or routed in metallic conduit above the suspended ceilings above the electric shop and maintenance administrative areas was observed to be minor (less than 1% of space) and classified as video/communication/data cables. There are no NCSA components located in fire zone SB-I. There are no ignition sources above these ceilings. Although there is a non-rated wall between the Primary Water Treatment room and the Service Building Basement, S19 is an automatic sprinkler system that provides suppression protection in fire zone SB-1 and SB-1WT. Portable fire extinguishers are available in this zone, and there are hose stations available in adjacent fire areas/zones as well as yard hydrant connections.

The basis for the approval request of this difference from NFPA 805, Chapter 3 requirements is:

There are no ignition sources above these ceilings

" The wiring above ceilings in offices, conference rooms, laboratories, lobbies, etc. do not pose a hazard:

" Low voltage is not susceptible to shorts causing a fire

" There is a lack of continuity of combustibles

" There is no equipment important to nuclear safety in the vicinity of these cables

" Modification Design Process requires new installations to use plenum-rated equivalent or armored cable (Note: FAQ 06-0022 identified acceptable electrical cable flame propagation tests). Plenum-rated cable is tested to NFPA-262.

Power, control or instrumentation cables installed are either IEEE-383 qualified (or equivalent) or provided with a flame retardant coating.

Acceptance Criteria Evaluation Nuclear Safety and Radiological Release Performance Criteria:

FPE RAI 06 3

Page 19 of 114

60-Day Responses to Request for Additional Information for NFPA 805 The location of wiring above suspended ceilings does not affect nuclear safety since: (1) the space enclosing these cables are non-combustible, (2) the location of wiring above the suspended ceilings has a minimum amount of nearby ignition sources considering the adjacent power, control, or instrument cables, and (3) the video/communication/data cables are low energy and therefore pose a low fire ignition hazard due to hot shorts. Therefore, there is no impact on the nuclear safety performance criteria.

The wiring above the suspended ceilings has no impact on the radiological release performance criteria. The radiological review was performed based on the potential location of radiological concerns and is not dependent on the type of cables or locations of suspended ceilings.

Safety Margin and Defense-in-Depth:

The amount of non-rated and non-enclosed wiring above the ceilings in the Power Block is minor and does not present a significant fire hazard. Therefore, the safety margin inherent in the analysis for the fire event has been preserved.

The three echelons of defense-in-depth are 1) prevent fires from occurring (hot work and other administrative control), 2) rapidly detect, control and extinguish fires that occur thereby limiting damage (fire detection systems, automatic fire suppression systems, manual fire suppression and pre-fire plans to aid the fire brigade), and 3) provide an adequate level of fire protection for systems and structures, so that a fire will not prevent essential safety functions from being performed (fire barriers, fire rated cable, success path remains free of fire damage, recovery actions). The prior introduction of non-listed video/communications/data cables routed above suspended ceilings does not directly result in compromising automatic fire suppression systems, manual fire suppression functions, or post-fire safe shutdown capability.

The inherent safety margin remains unchanged. The introduction of non-listed video /

communications / data cables routed above suspended ceilings does not impact fire protection defense-in-depth. The video/communication/data cables routed above suspended ceilings does not directly result in compromising automatic fire suppression or detection functions, manual fire suppression function, or post-fire safe shutdown capability.

==

Conclusion:==

NRC approval is requested for the acceptance of a Performance-Based (PB) method to demonstrate an equivalent level of fire protection for the requirement of NFPA 805, Section 3.3.5.1 regarding the currently installed non-plenum listed cables routed above suspended ceilings.

Ginna determined that the performance-based approach/NFPA 805 alternative satisfies the following criteria:

(A) Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release; (B) Maintains safety margins; and (C) Maintains fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability.

FPE RAI 06 4

Page 20 of 114

60-Day Responses to Request for Additional Information for NFPA 805 Constellation Energy Nuclear Group Attachment A - NEI 04-02 Table B-1 Transition of Fundament Fire Protection Program & Design Elements NFPA 805 Requirements/Guidance Compliance Compliance Basis References Chapter 3 Statement Reference 3.3.5.1 Wiring above suspended ceiling shall be kept to a Submit for Ginna has wiring above suspended ceilings that CNG-FES-007 rev.

Suspended minimum. Where installed, electrical wiring shall be NRC Approval may not comply with the requirements of this code 00015, Preparation of Wiring listed for plenum use, routed in armored cable, section. Suspended ceilings were identified in the Design Inputs and Change routed in metallic conduit, or routed in cable trays following areas: Impact Screen with solid metal top and bottom covers.

Turbino BuRpildring Oporating L9VOI Conference Rnnm

MUX Room (romputor room)

TSC (Technical Support Center) and adjoining hallway

Service Building Basement office areas

Control Room See Attachment L of the Transition report for further details on the request for NRC approval for existing wiring above suspended ceilings.

The wiring above suspended ceilings for future installations is controlled administratively within CNG-FES-007 [Attach. 3].

I I Page A-IS Ginna LAR Rev Ginna LAR Rev 0 0 Page A-15 Page 21 of 114

60-Day Responses to Request for Additional Information for NFPA 805 FPE RAI 07 LAR Attachment L, Approval Request 3, is for approval of the use of wiring that may not comply with the requirements of NFPA 805, Section 3.3.5.3. The Approval Request states that the performance based (PB) method is specifically associated with the installation of video/communication/data cables. However, the basis for the request includes a discussion of power cables used for modifications such as the spent fuel pool bridge crane which was modified using cables others than those meeting the Institute of Electrical and Electronics Engineers (IEEE) Standard 383, "IEEE Standard for Qualifying Class 1E Electric Cables and Field Splices for Nuclear Power Generating Stations." It is unclear whether this request is for all types of cable or only video/communication/data cables. Clarify the scope of the request. In addition, provide further justification for the acceptability of using cable that does not comply with NFPA 805, Section 3.3.5.3. Include a qualitative or quantitative risk evaluation, as well as a more detailed discussion of how safety margin (SM) and defense-in-depth (DID) are maintained using this PB approach.

Response

Change compliance statement in the B-1 table section 3.3.5.3 from "Submit for NRC Approval" to "Complies via Previous Approval" and "Submit for NRC Approval".

The "Complies via Previous Approval" is applicable to all non video/communication/data cables, and the "Submit for NRC Approval" is applicable to the video/communication/data cables.

Procedure EP-3-P-0504, "Electrical/I&C Analyses Impact Form and Load Growth Control Program", and corporate procedure CNG-FES-007, "Preparation of Design Inputs and Change Impact Screen," ensures that all new power, control or instrument cable installed will be constructed to meet or exceed the requirements of:

IEEE 383-1974 or IEEE 1202-1991 or CSA (Canadian Standards Association) 22.2 No. 0.3 or NFPA 262 or UL 44, UL 83, UL 1581, UL 1666, or UL 1685 The compliance basis statement for "Complies via Previous Approval" is as follows:

The UFSAR [Sec. 9.5.1.2.4.8] states, "The cable insulation used at Ginna includes Kerite, oil-based rubber,neoprene, and polyvinyl chloride (PVC). The cables have, as a minimum, passed the ASTM and UL horizontal and vertical flame tests. Power cables and PVC control cables have passed the Consolidated Edison Bonfire Test. The majority of electrical cables were purchased and installed prior to issuance of IEEE 383; however, the potential combustion products for the materials used at the station have been evaluated from generic test reports and do not exhibit an unusual or significantly hazardous nature. All cables used for modifications meet IEEE 383 criteriaunless specifically excepted. "A specific determinationis made whenever it is impracticable to meet IEEE 383 criteria for cables used in modifications. RGO03006 [Encl.

1, Item 3.2.4, pg. 2] states, "SER Section 3.2.4 indicates that the licensee is investigating the fire characteristics,including fire resistance, of the cable insulation used in the plant. By letter dated April 30, 1979, the licensee provided a list of cable insulation types and quantities used in the plant. The assumptions on Page I-1 of the licensee's study performed in response to SER FPE RAI 07 1

Page 22 of 114

60-Day Responses to Request for Additional Information for NFPA 805 Section 3.2. 1 obviate the need for a separate staff analysis of the fire characteristicsof electrical cable insulation. We conclude that this item is acceptable."

Electric cable construction is acceptable per NRC SER Supplement No. 2 Fire Protection Accession # 8102270116, dated 02/06/1981, Section 3.2.4, [RG003006] and EPM-FPPR Appendix A section D.3.f.

The compliance basis statement for "Submit for NRC Approval" is as follows:

The approval request is for the video/communication/data cables that do not comply with the requirement of NFPA 805, section 3.3.5.3.

See Attachment L of the Transition report for further details on the request for NRC approval for the video/communication/data cables that do not comply with this requirement.

Procedure EP-3-P-0504, "Electrical/I&C Analyses Impact Form and Load Growth Control Program", and corporate procedure CNG-FES-007, "Preparation of Design Inputs and Change Impact Screen," ensures that all new power, control or instrument cable installed will be constructed to meet or exceed the requirements of:

IEEE 383-1974 or IEEE 1202-1991 or CSA (Canadian Standards Association) 22.2 No. 0.3 or NFPA 262 or UL 44, UL 83, UL 1581, UL 1666, or UL 1685 The following is a complete revision of Attachment L, Approval Request 3 from the requirements of NFPA 805 Section 3.3.5.3:

NFPA 805, Section 3.3.5.3 NFPA 805, Section 3.3.5.3 states:

"Electriccable construction shall comply with a flame propagationtest as acceptable to the AHJ. "

NRC approval is requested for the acceptance of a Risk-Informed Performance-Based (PB) method to demonstrate an equivalent level of fire protection for the requirement of NFPA 805, Section 3.3.5.3 regarding an acceptable flame propagation test for electric cable construction.

The scope of this request includes video/communication/data cables. NRC approval of a Risk-Informed PB method is needed to justify the use cable that may not comply with the requirements of this code section, which are not necessarily tested in accordance with the flame propagation test requirements of IEEE-383, or any other qualification standard outlined in FAQ 06-0022 as endorsed by the NRC.

Basis for Request The video/communication/data cables are not necessarily tested in accordance with the flame propagation tests outlined in the FAQ 06-0022 as endorsed by the NRC. These low voltage FPE RAI 07 2

Page 23 of 114

60-Day Responses to Request for Additional Information for NFPA 805 cables are not generally susceptible to shorts which would result in a fire, therefore self-ignited fires are not a concern. An exposure fire could potentially ignite the cables, although the same fire would result in damage to other cables in the vicinity.

With the exception of the telephone communications room located in fire area BOP/ zones TB-2 (Turbine Building Mezzanine), and TSC-1M (Administrative Computer Room), along with the Control Room (fire area CC/ zone CR), the remaining areas contain a limited quantity of this wiring which is sufficiently dispersed, is considered an insignificant fire hazard, and is not capable of causing fire damage to components necessary for safe shutdown.

The telephone communications room in fire area BOP/ zone TB-2 is protected by an automatic sprinkler system S38. Portable fire extinguisher, and hose stations are also available in this fire area. A fire in this room would be readily extinguished by the automatic actuation of sprinkler system S38.

TSC-1M is protected by smoke detectors S34D1 and S34D2, portable fire extinguishers, and hose stations in adjacent areas. A potential fire in this area would be detected and consequently extinguished.

BOP/CR is protected by a constantly manned area, Z19 smoke and heat detectors, portable fire extinguishers, and hose reels available in adjacent areas. A potential fire in this area would be readily detected due to the constantly manned area, and consequently extinguished.

The combustible loading in these areas is tracked within DA-ME-98-004 and transient combustibles are tracked administratively through FPS-16.

Acceptance Criteria Evaluation Nuclear Safety and Radiological Release Performance Criteria:

Video/communication/data cables are low-voltage cable not susceptible to shorts that would result in a fire. Therefore, there is no impact on the nuclear safety performance criteria.

The flame propagation testing of electrical cable construction has no impact on the radiological release performance criteria. The radiological review was performed based on the potential location of radiological concerns and is not dependent on the flame propagation tests of cables.

The limited use of video/communication/data cabling has been shown to be acceptable and does not create or pose an un-acceptable fire hazard. Therefore, the radiological release performance criteria are also satisfied based on the determination of limiting radioactive release.

Safety Margin and Defense-in-Depth The introduction of non-listed video/communication/data does not impact fire protection defense-in-depth. The video/communication/data cables do not directly result in compromising automatic fire suppression or detection functions, manual fire suppression functions, or post-fire safe shutdown capability.

Exposed video/communication/data cables, installed at Ginna, with cable construction that does not comply with a flame propagation test acceptable to the AHJ is not capable of causing fire damage to components necessary for safe shutdown due to the nature of the low voltage of FPE RAI 07 3

Page 24 of 114

60-Day Responses to Request for Additional Information for NFPA 805 these cables not being susceptible to hot shorts or being a significant fire hazard in areas other than the communications room, administrative computer room, and Control Room. The suppression system, smoke detectors, portable fire extinguishers, and hose reels is considered adequate to prevent fire propagation in these areas. The Control Room is also constantly manned. Therefore, the safety margin and defense-in-depth is maintained.

The three echelons of defense-in-depth are 1) prevent fires from starting (administrative procedures for combustible/hot work controls) via FPS-16, 2) rapidly detect, control and extinguish fires that do occur thereby limiting damage (fire detection systems, automatic/manual fire suppression, fire brigade/pre-fire plans), and 3) provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers, success path remains free of fire damage, recovery actions).

Exposed video/communication/data cables, installed at Ginna, with cable construction that does not comply with a flame propagation test acceptable to the AHJ does not affect echelon 1 of the defense-in-depth concept because cable construction is not involved with administrative procedures to prevent fire from occurring, and administrative procedures control and track combustibles at Ginna via FPS-16. In areas containing these cables which cannot be categorized as insignificant adequate detection, manual hose stream, and fire extinguishers are provided to ensure the fire is rapidly detected and controlled/extinguished by the fire brigade.

Therefore, echelon 2 of the defense-in-depth concept is maintained. The telephone communications room is a room within fire zone TB-2 (Turbine Building Mezzanine). Since it is protected by an automatic sprinkler system, there is an adequate level of protection to prevent the spread of fire to systems and structures. The administrative computer room in fire zone TSC-1M, is protected by smoke detectors and hose reels, along with 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months concrete block wall to adjacent fire zone TSC-1N (Technical Support Center) and TB-2 (Turbine Building Mezzanine). The Control Room is protected by smoke and heat detectors, an automatic deluge spray system which provides a water curtain on the wall between the Control room and the Turbine Building Operating Floor, along with 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated walls to the exterior YARD area.

Therefore, echelon 3 of the defense-in-depth concept is maintained.

Conclusion NRC approval is requested for the use of video/communication/data cables that are not tested to the flame propagation tests as endorsed by the NRC.

The engineering evaluation performed determined that the performance-based approach utilized to evaluate this difference from the requirements of NFPA 805, Chapter 3:

(A) Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release; (B) Maintains safety margins; and (C) Maintains fire protection defense-in-depth fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).

FPE RAI 07 4

Page 25 of 114

60-Day Responses to Request for Additional Information for NFPA 805 Constellation Energy Nuclear Group Attachment A - NEI 04-02 Table B-1 Transition of Fundament Fire Protection Program & Design Elements NFPA 805 Requirements/Guidance Compliance Compliance Basis References Chapter 3 Statement Reference 3.3.5.3 Electric cable construction shall comply with a The UFSAR [Sec. 9.5.1.2.4.8] states, "The cable " RG003006, Safety Electrical Cable flame propagation test as acceptable to the AHJ. lNRG AP*p*,l insulation used at Ginna includes Kerite, oil-based Evaluation Report Construction rubber, neoprene, and polyvinyl chloride (PVC). Supplement 2, 2/6/81 Complies via The cables have, as a minimum, passed the ASTM " CNG-FES-007 rev.

Previous and UL horizontal and vertical flame tests. Power 00015, Preparation of Approval cables and PVC control cables have passed the Design Inputs and Change Consolidated Edison Bonfire Test. The majority of Impact Screen electrical cables were purchased and installed prior " EP-3-P-0504,rev. 01500, to issuance of IEEE 383; however, the potential Electrical I and C Analyses combustion products for the materials used at the Impact Form station have been evaluated from generic test

EPM-FPPR rev 8.0, ANL,rev.8.0, reports and do not exhibit an unusual or significantly hazardous nature. All cables used for Fire Protection Program modifications meet IEEE 383 criteria unless Report (FPPR) specifically excepted." A specific determination is made whenever it is impracticable to meet IEEE 383 criteria for cables used in modifications.

RG003006 [End. 1, Item 3.2.4, pg. 2] states, "SER Section 3.2.4 indicates that the licensee is investigating the fire characteristics, including fire resistance, of the cable insulation used in the plant.

By letter dated April 30, 1979, the licensee provided a list of cable insulation types and quantities used in the plant. The assumptions on Page I-1 of the licensee's study performed in response to SER Section 3.2.1 obviate the need for a separate staff analysis of the fire characteristics of electrical cable insulation. We conclude that this item is acceptable."

Electric cable construction is acceptable per NRC SER Supplement No. 2 Fire Protection Accession

8102270116, dated 02/06/1981, Section 3.2.4

[RG003006] and EPM-FPPR Appendix A section D.3.f.

Minor quantitioc of existing vido4,o.....* .. c At.Ond..t;;cuabl'e ;and other coade tyP8s May not moot the requiremenRt of this code 66ctiR. TherforoF, NRC approVal Of oxistin9 cablec; tha4t do not mee~t thA requirement of NIFPA I ____________________________________________ .j ______________ I Ginna LAR Rev 0 Page A-17 Page 26 of 114

60-Day Responses to Request for Additional Information for NFPA 805 Constellation Energy Nuclear Group Attachment A - NEI 04-02 Table B-1 Transition of Fundament Fire Protection Program & Design Elements NFPA 805 Requirements/Guidance Compliance Basis References Chapter 3 Reference 3.3.5.3 805, Section 3.3.5.3 and approval of a Electrical Cable poFformanr.e baeod (121)methed to clommsnt~rato Construction the equiValency of future Gable typcc that may net (continued) Meet thic requirement i6 requested. See Attachmcnt: L to thc TraneitiOn Report.

EP 3 P 0504 [SoG. 5.2] and GNG FES 00:7 [Attach.

3] include accoptablo cable flame9 propagation tects, ac ic6ted in FAQ 06 0022, for Mutur med:Aiiat!GRc.

NoEtei The 8XcoPtiGn to thic cection is not ondorccd by 1OCF=R5O.48 (c)(2)i(v' and has boon remoVed-.

,The approval request is for the video/communication/data cables that do not K- 4d dJ comply with the requirement of NFPA 805, section 3.3.5.3.

See Attachment L of the Transition report for further details on the request for NRC approval for the video/communication/data cables that do not

(

comply with this requirement.

Procedure EP-3-P-0504, "Electrical/l&C Analyses Impact Form and Load Growth Control Program",

and corporate procedure CNG-FES-007, "Preparation of Design Inputs and Change Impact Screen," ensures that all new power, control or instrument cable installed will be constructed to

( meet or exceed the requirements of:

IEEE 383-1974 or

( IEEE 1202-1991 or CSA (Canadian Standards Association) 22.2 No.

0.3 or NFPA 262 or UL44, UL 83, UL 1581, UL 1666, or UL 1685 4- ______________________________________ j. ____________ L ____________________________________________________________

Page A-lB Ginna LAR Ginna Rev 00 LAR Rev Page A-18 Page 27 of 114

60-Day Responses to Request for Additional Information for NFPA 805 FPE RAI 08 LAR Attachment L, Approval Request 4, is for approval of the reactor coolant pump (RCP) oil mist that results from pump/motor operation. Provide the following additional information:

a. Further characterization of the misting in terms of location of deposition, and the fire hazard associated with these deposition locations, including proximity to equipment necessary to meet nuclear safety performance criteria. Include the basis for acceptability.

b. What actions, if any, are taken to clean oil mist deposits from equipment surfaces (e.g., during maintenance outages).

Response

a. RCP oil misting has a potential to uniformly deposit on surfaces in the pump bay located within Reactor Coolant System Loop A and Loop B. Oil has only been observed to accumulate on the equipment located within the pump bay when there was a malfunction of a component. However, a light sheen of oil is typically observed on equipment located within the pump bay due to misting, as well as on the walls of the RCP cubicle.

Regarding the proximity to equipment necessary to meet nuclear safety performance criteria, RCP 'A' is associated with fire area/zone RC/T-LOOPA and RCP 'B' with fire area/zone RC/T-LOOPB [Ref. drawing 33013-2928,5]. The RCPs are located in the basement of the Reactor Containment Building and extend vertically upwards as shown on drawing 33013-2131. The NSCA components located in fire zones RC-1, T-LOOPA, and T-LOOPB were evaluated for the potential of oil misting as shown in the following tables:

NSCA equipment associated with Fire Area/Zone - RC/RC-1 EIN Description Location Room Comments 123 Excess Letdown Flow 235', RC Basement TI-SE Not subject to oil misting. Concrete wall Control Valve Regenerative HX separates RCP from component. Ref.

Area 33013-2131.

200A Letdown Orifice 235', RC Basement Ti-SE Not subject to oil misting. Concrete wall Regenerative HX separates RCP from component. Ref.