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Control Rod Misalignment Analysis.
	ML17331B196
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Site:	Cook
Issue date:	09/30/1993
From:	; AMERICAN ELECTRIC POWER SERVICE CORP.
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9 ATTACHMENT 4 TO AEP'NRC'1182 CONTROL ROD MISALIGNMENT ANALYSIS

,'DR 9401270040 940117

'PDR, ADGCK 05000315'

DONALD Ce COOK NUCLEAR PLANT CONTROL ROD MISALIGNMENT ANALYSIS SEPTEMBER 1993 AMERICAN ELECTRIC POWER SERVICE CORPORATION COLUMBUS, OHIO

TABLE OF CONTENTS Introduction and Definition of Terms ........................1

1. 1 Introduction 1.2 Definition of Terms

2. ARPI Technical S ecification ................................3 2.1 Problem Description 3 2.2 Problem Solution 3 3~ Rod Misali nment Concerns .................................. 5 3.1 Reactivity Control 5 3.2 Control Rod Misoperation 5 3.3 Rod E)ection 7 3.4 Power Operation with Misaligned Rod 8 4~ Power Distribution Anal ses .................................9 4.1 Analysis Methods 10 4.2 Misalignment Calculations 11 4.3 Load Follow Transients 14 4.4 Unit 1 Applicability 15

5. Technical S ecification Chan es and Im lementation .........16 5.1 Technical Specification Changes 16 5.2 Technical Specification Implementation 18

6. ~Summa'...................................................20 7

8. References .................................................65

INTRODUCTION AND DEFINITION OF TERMS 1.1 Introduction Donald C. Cook Nuclear Plant constructed and operated by l'he the American Electric Power Company is located along the eastern shore of Lake Michigan in Bridgman, Berrien County, 4

Michigan. The reactor is a closed<<cycleg pressurized, light water moderated and cooled system, and uses slightly en-riched uranium oxide fuel. The Unit 1 reactor is designed to produce 3250 MW~~ and Unit 2 is designed to produced 3411 MW~. This report describes the result of the analyses performed to modify the rod position indication system technical specifications.

1.2 Definition of Terms The following list of symbols, terms and abbreviations will be used consistently throughout this reports BOL Beginning of Life MOL Middle of Life EOL End of Life MWD/MTU Megawatt days per metric tonne of uranium metal (represents burnup of fuel)

RCCA Rod Cluster Control Assemblies (type of control rods used)=

ARPI Analog Rod Position Indication (type of system used to determine the axial position of individual control rods)

T/S Technical Specification RTP Rated Thermal Power PDIL Power Dependent Insertion Limit (represents insertion limits for control banks)

APL Allowable Power Level (Monthly surveillance determines this power level. This power lev-el assures that limits on heat flux hot chan-nel factors are protected.)

ARO All Rods Out Qpo Change in reactivity (dp = ln k,/Q where k, and Q are eigenvalues obtained from two calculations) pcm Percent mille (a reactivity change of 1 pcm equals a reactivity change of 10~)

step A unit of control rod travel equal to 0.625 inch ppm Parts per million by weight (specifies chemi-cal shim boron concentration)

Heat flux hot channel factor (maximum rod power at any axial level divided by average rod power at that axial level)

Enthalpy rise hot channel factor (maximum rod power divided by average rod power) k(Z) F< normalized to the maximum value allowed at any core height HFP Hot Full Power HZP Hot Zero Power CAOC Constant Axial Offset Control (power distribution control procedure)

2. ARPZ TECHNICAL SPECIFICATION 2.1 Problem Descri tion The current Technical Specifications (T/Ss) allow an individual Rod Cluster Control Assembly (RCCA) to be misaligned from the bank demand position if the misalignment is less than 12 steps. As stated in the NRC letter dated October 28, 1979 (Reference 1 letter from A. Schwencer, NRC to J. Dolan, AEP), Westinghouse performed safety analyses for control rod misalignment up to 24 steps at the time of the development of the Standard Technical Specifications. The letter also noted that the Analog Rod Position Indication (ARPI) system is designed to an accuracy of 12 steps. Thus, in order to guarantee a rod misalignment of less than 24 steps, the indicated ARPI readings must be no larger than 12 steps. Experience with the ARPI system has shown that the indicated misalignment could be greater than 12 steps. It should be noted that there was no evidence of actual misalignment in the majority of cases. Procedures are in place to deal with actual rod misalignment when it occurs.

In order to reduce the action items imposed due to the current T/S limits, it is necessary to change the T/S to allow 18 step misalignment. Therefore, analyses must be performed for 30 step (18 step indicated + 12 step uncertainty) misalignment.

2.2 Problem Solution The T/Ss allow reactor operation with the control rods at Power Dependent Insertion Limit (PDIL). The T/Ss also pro-vide limits for peaking factors F< and Fm,. As the power level is lowered, the limits for F< and Fz, increase accord-ing to:

a. F~U '/P

b. F>,~ [1 + 0.2(1-P) ) or F<<~ [1 + 0.3(l-P) )

where P is the fraction of Rated Thermal Power.

These increases in the limit for F< and F>, can be used for accommodating increased RCCA misalignment at a lower power level. That is, at 85% RTP, the limit for peaking factor, F<< increases by 15%. Analyses must show that the increase in peaking factor due to a 30-step misalignment (18 step indicated + 12 step uncertainty) is lower than 15%. If it is, then a T/S requirement of 18 steps is possible up to a power level of 85% RTP.

At 100% RTP, the current level of misalignment of 24 steps (12 step indicated + 12 step uncertainty) is maintained. If the measured F< and F>, at 100% RTP are smaller than the corresponding limits at 100% RTP, then these margins can be used for accommodating larger than 12-step (indicated) misalignments. This can be determined on a monthly basis in con)unction with incore flux mapping.

The advantage of this procedure is that the initial condi-tions for transients are unaffected.

ROD MISALIGNMENT CONCERNS 3.1 Reactivit Control It is necessary at all times to maintain enough reactivity out of the core to safely cover the power defect with a suitable margin allowed for accidents. In order to maintain this required shutdown margin, a rod bank Power Dependent Insertion Limit (PDIL) is set. The amount of reactivity associated with this insertion limit is called the rod in-sertion allowance. RCCAs which are misaligned inward from their bank demand position will add to the rod insertion allowance. The reactivity of a misaligned group (mis'aligned by 30 steps) was calculated to be less than 120 pcm (Table 3.1-1). This is substantially less than the excess shutdown margin generally available. Tables 3.1-2 and 3.1-3 show excess shutdown margin for past cycles in both units. The I

Unit 1 PDIL will be changed to match the Unit 2 PDIL at the beginning of cycle 14. Figures 3.1-1 and 3.1-2 show the Unit 1 and Unit 2 PDILs respectively. By making the PDIL similar for both units, the Unit 2 analyses detailed in this report can also be applied for Unit 1.

3.2 Control Rod Miso eration The worst case control rod misoperation accident has been previously analyzed (Reference 2, 3) and found that applica-ble acceptance criteria are met.

A misoperation of control rods is detected by<

a0 change in power level as seen by the nuclear instrumen-tation system

b. asymmetric power distributions as seen by the nuclear instrumentation system or core exit thermocouples c~ rod bottom light d~ rod deviation alarm Reactor protection for control rod and control bank drop event is provided by the power range neutron flux high nega-tive rate trip. This protection is augmented by the follow-ing alarms: low level and low-low level rod insertion limit.

A dropped RCCA bank results in a reactivity insertion great>>

er than 500 pcm which will be detected by the power range neutron flux negative rate trip circuitry.

For a dropped RCCA event in automatic rod control mode, the rod control system detects a drop in power level and initi-ates bank withdrawal. Power overshoot may occur due to this after which the control system will insert the bank to re-store nominal power. Power overshoot is not impacted since the existing analysis assumed RCCA drop from ARO position.

The impact due to power distribution is minimal since the additional misalignment of six steps is allowed only if there is sufficient margin in F< and Fz, at full power.

Power distribution calculations were performed and are detailed in Section 4.

Zn the case of statically misaligned RCCA, an analysis was performed by the vendor to show that the DNBR does not fall

i

<~ e y If t

below the limit value. The most severe misalignment with respect to DNBR at significant power levels arise from cases in which one RCCA is fully inserted, or where control bank D is fully inserted with one RCCA fully withdrawn. Multiple independent alarms, including a bank insertion limit alarm, alert the operator well before the postulated conditions are approached. The analysis was performed with control bank D deeply inserted as the criteria on DNBR and peaking factor will allow. To be conservative, the PDIL for Unit 1 will be moved up by seven steps to accommodate the possible six-step II misalignment [See Figure 3.1-2. Allowed insertion of 182 steps at HFP was changed to 189 steps at HFP.]

A control rod which is misaligned from its bank at PDZL can slightly increase the available ejected rod worth. Calcula-tions were performed at HZP and HFP conditions. An HZP mis-alignment is not a concern since the calculation is per-formed for rod ejection from a fully inserted position. At full power conditionsg an increase in worth of less than 30 pcm ( 119 pcm : 4 = 29.75 pcm ) in rod worth was calculated.

Since adequate margin exists between the calculated pellet energy deposition and the acceptance criteria, the misalignment presents no concern in this area. A re-analysis of the EOL HZP rod ejection event was performed to account for effects of operation down to 50% power for extended periods of time (Reference 10). Specifically, the re-analysis addressed increases in the ejected rod worth and hot channel factor. The results showed average fuel pellet enthalpy and fuel center temperature to be below limits.

3. 4 Power 0 eration with a Misal i ned Rod The NSSS vendor has performed safety analyses for control rod misalignments up to 24 steps from the bank demand position to show that the misalignment will not cause power distributions worse than the limits. Operation with an RCCA significantly misaligned from its bank demand position would normally be detected and promptly realigned.

In the unlikely event that operation with a control rod mis-alignment of greater than 24 steps would occur, the impact on power distribution would be of concern. The increase in peaking factors due to single RCCA misalignment may be small but misalignment of one group of RCCAs may contribute to increases in peaking factors. Power distributions with control rod misalignment of 30 steps were therefore evaluated in detail, and the results are presented in Section 4 of this report.

4. POWER DISTRIBUTION ANALYSES Neutronic analyses were performed to evaluate the impact of RCCA misalignment on steady state power distributions and normal oper-ational transients such as load-follow operations. Calculations were done for both inward and outward misalignments from the de-mand counter position.

Current technical specifications require that the reactor operation be restricted to a +5% axial offset band about a target axial offset (CAOC operation). This restriction controls the axial power distribution and minimizes transient xenon effects on the axial power distribution. The reactor is operated below an Allowable Power Level (APL) which assures that the power distributions arising from operation under this strategy will meet the limit on heat flux hot channel factor.

The technical specification on quadrant power tilt ratio assures that the radial power distribution does not deviate substantially from the measured steady state power distribution between flux maps.

Therefore limits on axial offset and adrant ower tilt ratio are vital to maintainin satisfactor ower distribution and as-sure that most of the RCCA misali nments are detected and cor-rected in a timel manner.

4. 1 Anal sis Method The principal tool used in these calculations is the Westinghouse ANC code (Reference 6) exercised in a three-dimensional mode. Full core and quarter core models were used for the analyses. In this model, each fuel assembly is described by four nodes in the XY plane and 26 axial nodes.

The macroscopic cross-sections for ANC were generated by PHOENIX-P (Reference 7). The calculations were performed by Westinghouse using approved methodology.

ANC also has the capability of calculating discrete pin power and pin burnup from the nodal information. The F<~

and F~+ thus obtained is shown in Tables 4.2-1 through 4.2-

14. It should be noted that as far as this analysis is concerned, we are interested in changes in F< rather than absolute values of F<.

The Unit 2, Cycle 9 ANC model was used for the RPI analysis since Unit 2 core has axial blankets and therefore more conservative calculation from a peaking factor standpoint.

Also, the F< and Fz< T/S limits are slightly more restrictive for the remaining ANF fuel in unit 2.

In order to show that the calculational tools used in the analysis are reasonable, the Unit 2, Cycle 9 ANC model was depleted and results of the power distribution and boron letdown calculations were compared to the measured values.

This is shown in Appendix A.

The loading pattern and control rod locations for Unit 2, Cycle 9 are shown in Figures 4.1-1 and 4.1-2. The loading pattern and control rod locations for Unit 1, Cycle 13 are

shown in Figures 4.1-3 and 4.1-4.

4.2 Misali nment Calculations The first step was to determine a power level at which the peaking factor increase due to RCCA misalignment of 30 steps (18 step indicated + 12 step uncertainty) could be accommo-dated. Therefore, misalignment calculations from PDIL were performed. The question of multiple RCCA misalignment was addressed by analyzing misalignments of groups of RCCAs in the control bank (Groups 1 and 2 in Control Bank D). Group misalignment was considered since it is more realistic to assume that the RCCAs in one group would mis-step rather than different RCCAs from different groups would mis-step.

However, some single RCCA misalignment calculations were also performed. Especially, misalignment of RCCA H-8 was investigated since it is in the middle of the core and will be difficult to detect through monitoring excore detector quadrant tilt.

First, the change in peaking factors due to operation at lower power levels without RCCA misalignments was investigated. As seen in Table 4.2-1, peaking factors F<

and Fz< do not change substantially with power change as long as the reactor operation is on CAOC. Misalignment calculations were then performed at 85% RTP. The misalignment effect of a single RCCA H-8 and the misalignment effect of group 1 and 2 were investigated.

From Table 4.2-2, it can be seen that the maximum increase in F< is 4.7% and maximum increase in F~, is 2.1%. Similar calculations at MOL gave a maximum increase of 6.6't in F<

and 0.7% in F>, (Table 4.2-3). EOL calculations yielded an increase of 7.4% in F< and 0.9% in F>, (Table 4.2-4).

As noted in previous section, the equations governing the limits (ANF fuel) for F< and F~ are as follows:

~e 2. 1 x P(z)

P F~( = 1.49[1 + 0.2(1-P))

Therefore, the limits at 85% RTP will be:

F Lac$ 5% RlP ~ 2 47 IJmh $ $ % RTP F

It is evident that the limit for F< increased by 17.6% and the limit for F~increased by 2.6% at 85% RTP. Therefore, a

+18 steps misalignment is acceptable up to a power level of 85'%TPe Other sensitivity runs were also made for similar RCCA mis-alignments from different D-bank positions other than PDIL.

Results of misalignment calculations from D-bank position of 215 steps is shown in Table 4.2-5. Table 4.2-6 shows the results of calculations at 50% RTP with control bank at PDIL (i.e., D at 94.5 steps and C at 222.5 steps). The maximum increase in F< in these calculations was found to be 7.3%

and maximum increase in F>, was found to be 2.7%.

Full core analysis for investigating single RCCA misalign-ment was performed. RCCAs H-12 and D-12 were misaligned 30 steps from ARO and PDIL and increases in F< and Fz,.noted.

12

S From Tables 4.2-7, it can be seen that F< increased by 1.7%

and Fz, increased by 0.9%. This is accommodated by the increases in limits at 85% RTP. It should also be noted that the impact of RCCA H-8 misalignment on peaking factor is small. Therefore, it can be concluded that a 18-step misalignment up to 85% RTP can be tolerated.

The next step was to perform sensitivity calculations to determine the additional misalignment (above 12 steps indi-cated) allowed at power levels between 85% RTP and 100% RTP.

For this, misalignment calculations were performed for 24 steps (12 step indicated + 12 step uncertainty), 27 steps (15 step indicated + 12 step uncertainty), and 30 steps (18 step indicated + 12 step uncertainty). These calculations at 100% RTP were performed for the following RCCAs in con>>

trol bank D: H-8, RCCAs in Group 1 and RCCAs in Group 2.

Results from these calculations are shown in Tables 4.2<<8 through 4.2-10.

Sensitivity runs were made for a similar misalignment case from a D-bank position of 215 steps rather than from PDIL.

Results are shown in Tables 4.2-11 and 4.2-12. Review of these results shows that the change in F< is 2.2% and Fz, is 0.4%. These changes are similar to the change in peaking factors due to misalignment from PDIL. The effect of a single RCCA misalignment (D-12,K-14,H-12 and K-8) on peaking factors is shown in Table 4.2-13; as seen before, the impact is small.

The increase in F< due to an additional misalignment of three steps over the existing 12 step (indicated) misalign-13

ment was found to be 0.9%. The increase due to an addition-al misalignment of six steps was found to be 1.6%.

Additional load-follow calculations indicate an increase of 3.4%. Since the analysis was performed for a typical cycleg the F< margin necessary is increased to 6% for conservatism.

This means that if a margin of 6% in F< exists, then an additional misalignment of six steps (i.e., total of 18 steps indicated) is allowed at 100% RTP.

As far as peaking factor Fz, is concerned, a 0.5% increase over the 12-step misalignment case is noted. Load-follow calculations indicate that a 0.8% margin is required. This was the increase calculated for the 18-step case over the 12 step case.

Zn conclusion, it can be mentioned that if the requirements given in T/s 3.1.3.1 are satisfied, T/S limits on F< and F~, will not be violated even with an 18-step (indicated) misalignment. Since the T S limitln conditions for o era-tions are not violated the initial conditions assumed in accident anal ses are not violated.

4.3 Load-Follow Transient with RCCA Misali nment Effect of load-follow maneuver and misalignment on peaking factors was investigated. Axial power distribution which could be obtained during a load-follow operation was obtained by skewing the EOL xenon distribution to the bottom. This is a conservative assumption since typical load-follow under CAOC rules will not give a skewed xenon distribution as this. An option in the ANC code was used to get the skewed xenon distribution.

14

The results of the analysis is shown in Tables 4.3-1 through 4.3-3. The effect of single RCCA H-8 misalignment is small as before. The change in F< due to group misalignment was found to be 3.4%.

4.4 Unit 1 A licabilit

'he analyses in previous sections were performed for Unit 2 (3411 MWt) which consists of 17 x 17 fuel assemblies. The Unit 1 core (3250 MWt) consists of 15 x 15 fuel assemblies.

Both units have 12 feet cores consisting of 193 assemblies.

The difference in the fuel type is not considered to be sig-nificant for this type of analysis. Moreover, the Unit 1 PDZL has been moved up to match the revised Unit 2 insertion limit shown in Figure 3.1-1. Since the T/Ss allow a 12-step misalignment for both units currently, regardless of the fuel type or power level, and since the PDIL will be the same for both units, the analyses performed for Unit 2 is applicable for Unit 1.

A sensitivity study using the PHOENXX/ANC model for Unit 1, Cycle 13 shows that the response due to rod misalignment is almost the same as that in Unit'. As shown in Table 4.4-1, BOL calculations for Unit 1 yielded a change of 6.2% and 1.1% for F< and Fz<< respectively. Although the change in F<

is slightly higher in Unit 1 compared to Unit 2, such differences are expected and are accounted for in the F<

margin necessary to achieve 18 step misalignment at full power.

TECHNICAL SPECIFICATION CHANGES AND IMPLEMENTATION 5.1 Technical S ecification Chan es From the analyses detailed in Section 4.0, it can be seen that the increase in peaking factor F< due to an RCCA misalignment of 30 steps (18 step indicated + 12 step uncertainty) is less than 8% and the increase in F>, is less than 3%. These increases in peaking factors can be accommodated at a power level of 85% RTP. Therefore, the revised T/Ss allow RCCA misalignments of +18 steps (indicated) up to a power level of 85% RTP. [The current T/Ss allow rod misalignment of +12 steps (indicated) up to 100% RTP.)

Analysis detailed in Section 4 also shows that a 3.4% margin in F< is necessary to accommodate a misalignment of 30 steps (18 steps indicated + 12 step uncertainty) at full power.

That is, F< increases by 3.4% for an 18-step (indicated) misalignment compared to a 12-step (indicated) misalignment.

For conservatism, this is increased to require a margin of 6% in Fg, The current T/S basis references a 4% F>, margin for uncertainties arising from abnormal perturbations in radial power shape. This analysis shows that a 0.8% margin in F~,

is required to take into account an 18-step (indicated) misalignment. Therefore, the conservative requirement of 4%

margin is retained and is adhered to in a strict manner by specifying this requirement in T/S figure 3.1-4 (Appendix B) ~

It should be noted that the margin in F< is that available beyond the expected transient F< and is computed in the fol-lowing way:

F< (measured-steady state) F M F< (penalized) = FqM X 1.03 X 1.05 F< (transient) Fgw X 1 ~ 03 X 1+05 X V(Z)

F< (limit) Fq" X k(Z)

F x k(Z) margin Fz x1.03 x1.05x V(Z)

Compared with the definition of APL in T/S 3.2.6, the margin defined above is essentially the APL. Note that the margin calculated is with respect to the limit at 100% RTP.

In a similar manner the margin in F~, (defined as R) is calculated in the following way:

F>, (measured-steady state) = F~iN F~) (limit) Umh100%RTP F hll Limfc100%RTP FhH margin R N F~H Therefore, if the APL given in the monthly incore flux map is 106% and if the value of R (margin in Fz,) is 1.04, then an additional six-step misalignment is allowed above 85%

RTP. If the APL is lower, then a lower amount of misalignment is allowed. This is graphically shown in T/S 17

Figure 3.1-4.

Since a new rod insertion limit was used in the analysis/

the unit 1 PDZL will be changed to reflect the limit used in the analysis at the begining of cycle 14.

The updated T/S pages for both units are given in Appendix B.

18

p 8 e g

5.2 Technical S ecification Im lementation As seen in Section 5.1, the updated T/Ss allow a rod mis-alignment of +18 steps for power levels less than or equal to 85% RTP. Above 85% RTP, the level of misalignment allowed is based on the peaking factors obtained from the monthly incore flux map taken. For this, the plant procedure, "Surveillance of core power distribution limit/"

(**1EHP 4030 STP.330 and **2EHP 4030 STP.330) will be revised to provide the allowed rod misalignment on a monthly basis. The incore flux map gives the values for APL and F>,

and from T/S Figure 3.1-4, the additional rod misalignment is obtained.

For example, if an incore flux map taken at 98% RTP gives the following:

F hHolclMRd 1.40 APL 103%

Therefore,

~mimi t1000 hH Heaaurod

~he 1.49 1.40 4$ 1. 064 19-

Since the value of R obtained is greater than 1.04, from T/S Figure 3.1-4, for an APL of 103%, a misalignment of 15 steps is obtained for power levels greater than 85% RTP. Zn order to assist the reactor operator ln determining the allowed rod misalignment, a plot as shown below may be provided.

ALLONfED ROD MISALIGNMENT ARM (STEPS) 26 20 16-6-

0 0 20 40 60 80 100 RATED THERMAL POWER (%)

6,

SUMMARY

RCCA misalignments up to 30 steps (18 steps indicated + 12 steps uncertainty) were evaluated for impact on peaking factors and reactivity worths. A review of the results of the transient analyses showed that adequate conservatism exists in the analyses to absorb the penalties associated with increased rod mis-alignment. As a conservative measure, the power dependent inser-tion limit (PDIL) will be moved slightly upwards.

Power distributions were evaluated under steady state and load-follow conditions with rod misalignment of 30 steps (18 steps indicated + 12 steps uncertainty) showed that the increase in peaking factors could be accommodated at or below 85% RTP.

Calculations also showed that above 85% RTP, a misalignment of 30 steps (18 steps indicated + 12 steps uncertainty) could be accommodated if the APL is at least 106% and the margin in Fz, is at least 4%.

It should be noted that typical plant operation is with control rods essentially withdrawn from the core and under constant axial offset control. Also, the quadrant tilt is monitored. This, coupled with the fact that actual control rod misali nments are rare shows that this anal sis is conservative. An actual con-trol rod misali nment would be rom tl reali ned u on verifica-tion of its osition.

Based on this, the technical specification changes given in this report do not increase the probability of an accident or decrease safety margins previously established.

21

TABLE 3.1-1 ROD WORTH CALCULATION Bank/Group Rod worth (pcm) Delta pcm Control Bank D 9189 248.3 Control Bank D 8189, 367.7 119.4 Grou 2 8 159 Control Bank D 9189, 349.6 101.3 Group 1 9 159 22

~ '

TABLE 3.1-2 UNIT 1 SHUTDOWN MARGIN Cycle Parameter 10 12 13 Net Rod Worth 6620 6399 6170 5913 5807 5837 5764 5870 5479 5743 5733 5736 5768

[(ARI-1)*0.9]

HFP Requirement 3380 3500 3500 2970 2956 2968 2970 3390 2904 2274 2293 2319 2461 Required Shutdown 1600 1750 1750 1750 1750 1750 1750 1600 1600 1600 1600 1600 1600 Margin Excess Shutdown 1640 1149 920 1193 1101 1119 1044 880 975 1869 1840 1817 1707 Margin Note: All reactivity values in pcm 23

TABLE 3. 1-3 UNIT 2 SHUTDOWN MARGIN C cle Parameter Net Rod Worth 5660 5130 5210 5484 5471 5409 5908 5626 4779

[ (ARI-1) *0.9)

HFP Requirement 3280 3230 3360 3150 3150 3150 2740 3129 2324 Required Shutdown 1600 1600 1600 1600 1600 1600 2000 1600 1600 Margin Excess Shutdown 780 300 250 734 721 659 1168 897 855 Margin Note: All reactivity values in pcm 24

TABLE 4 UNIT 2

'-1 CYCLE 9 EOL D IN TO HOLD TARGET AO Description 100% RTP, ARO l. 696 1.423 75% RTP, D in for l. 644 1.409 tar et AO 50% RTP, D in for 1 603 1.444 target AO 25% RTP, D in for 1.654 1.483 target AO 25

~ '

TABLE 4.2-2 UNIT 2 CYCLE 9 BOL 85% RTP 30 STEPS FROM PDIL 18 + 12 Rod Position ARO 1.832 1.475 D 8 PDIL (160.7 2.039 1.465 D 8 PDIL, H-8 8190.7 2.027 1.493 D 8 PDIL, H-8 8130.7 2.044 1.449 D 9 PDIL, GP2 9190.7 1.954 1.490 D 9 PDIL, GP2 9130.7 2.134 1.456 D 8 PDIL, GP1 8190.7 1.970 1.440 D 8 PDIL, GP1 9130.7 2.117 1.496 Delta F 4.7%

Delta Fz, 2.1%

Notes 1) Control Bank D Locations Group 1 : D4, D12, M12, M4 Group 2 : H4, D8, H12, M8, HS

2) Delta F< 6 Delta F~, is the percent difference between highest value and value for the case with D-bank at PDIL 26-

~ ~

'I

TABLE 4.2-3 UNIT 2 CYCLE 9 MOL 85% RTP 30 STEPS FROM PDIL 18 + 12 Rod Position ARO 1. 740 1 ~ 474 D 8 PDZL 160. 7 2.182 1.474 D 8 PDZL, H-8 9190.7 2.158 1.473 D 9 PDZL, H-8 9130. 7 2.206 1.475 D 9 PDZL, GP2 9190.7 2.026 1.470 D 9 PDIL, GP2 9130.7 2.326 1.483 D 9 PDZL, GP1 9190.7 2.050 1.484 D 9 PDZL, GP1 9130.7 2.306 1.475 Delta F 6. 6't Delta F~, 0.7%

27

I

~

TABLE 4.2-4 UNIT 2 CYCLE 9 EOL 85% RTP 30 STEPS FROM PDIL 18 + 12 Rod Position ARO 1.697 1.409 D 8 PDZL 160.7 2.225 1.412 D 9 PDZL, H-8 9190.7 2.191 1.424 D 9 PDZLi H-8 9130.7 2.253 1.417 D 8 PDZL, GP2 8190.7 2.036 1.415 D 9 PDZL, GP2 8130.7 2.389 1.419 D 8 PDIL, GP1 8190.7 2.061 1.410 D 9 PDZL, GP1 9130.7 2 '68 1.415 Delta F 7.4%

Delta F>, 0.9%

28-

TABLE 4.2-5 UNIT 2 CYCLE 9 EOL 85% RTP 30 STEPS FROM 215 STEPS 18 + 12 Rod Posh.tion ARO l. 697 1.409 D 8 215 STEPS 1.640 1.404 D 8 215, H-8 9231 1.664 1.414 D 9 215, H-8 9185 1.607 1.396 D 8 215, GP2 9231 1.688 1.413 D 8 215, GP2 9185 1.759 1.403 D 9 215, GP1 9231 1.654 1.400 D 8 215, GPl 8185 l. 727 1.442 Delta F 7 ~ 3't Delta F>, 2 ~ 7't 29-

TABLE 4.2-6 UNIT 2 CYCLE 9 BOL 50% RTP 30 STEPS FROM PDIL 18 + 12 Rod Position D 8 50% PDIL (94.5) 2. 597 1.489 C 9 50% PDIL 222.5 DGC 9 50'tP PDIL D 2. 615 1.511 GP2 9 64 '

DGC 9 50'tP PDIL 2.479 1.476 D GP2 8 124.5 D&C 9 50'tP PDIL 2.702 1.495 C GP2 8 192.5 Delta F 4.0%

Delta F~ 1.5%

30

4 1 TABLE 4i2-7 UNIT 2 CYCLE 9 EOL 85% RTP 30 STEPS FROM PDIL 18 + 12 Rod Position ARO 1.697 1.409 D 8 PDIL 160 ' 2.225 1.412 D 8 PDIL,D-12 9130.7 2.262 1.425 D 8 PDIL,K-14 9195.0 2.245 1.418 D 9 PDIL, H-12 8130 7 2.257 1.423 D 8 PDIL,K-8 8195 0 ~ 2.239 1.416 Delta F 1 7%

Delta F~, 0.9%

31

I TABLE 4.2-8 UNIT 2 CYCLE 9 EOL 100% RTP 24 STEPS FROM PDIL 12 + 12 Rod Position ARO 1. 696 1.423 D 8 PDIL 189.0 2 '69 1.396 D 9 PDZL, H-8 9213 2.040 1.448 D 9 PDIL, H-8 9165 2.099 1 ~ 391 D 8 PDZL, GP2 8213 1.906 1.442 D 8 PDZL, GP2 9165 2 220 1.392 D 8 PDZL, GPl 9213 1.934 1.385 D 8 PDZL, GPl 9165 2.198 1.421 Delta F 7 ~ 3't Delta F~, 3 ~ 7't 32

TABLE 4.2-9 UNIT 2 CYCLE 9 EOL 100'%TP 27 STEPS PROM PDIL 15 + 12 Rod Posi.tion ARO 1.696 1.423 D 8 PDIL 189 2.069 1.396 D 9 PDIL, H-8 9216 2.035 1.453 D 9 PDIL, H-8 9162 2.103 1.392 D 9 PDIL, GP2 9216 1.891 1.447 D 8 PDIL, GP2 8162 2.238 1.393 D 9 PDIL, GP1 9216 1.921 1.387 D 8 PDIL, GP1 9162 2.216 1.424 Delta F 8.2%

Delta F~ 4. 1%

33

TABLE 4.2-10 UNIT 2 CYCLE 9 EOL 100% RTP 30 STEPS FROM PDIL 18 + 12 Rod Position F &

ARO 1.696 1.423 D 8 PDIL 189 2.069 1.396 D 8 PDIL, H-8 9219 2.033 1.455 D 9 PDIL, H-8 8159 2 '06 1 ~ 392 D 9 PDILi GP2 9219 1.884 1.449 D 8 PDIL, GP2 8159 2.254 1.354 D 9 PDIL, GP1 9219 1.917 1.388 D 9 PDIL, GP1 8159 2.230 1.426 Delta F 8 ~ 9't Delta Fz, 4.2%

0 t

I ll

TABLE 4.2-11 UNIT 2 CYCLE 9 EOL 100'%TP 24 STEPS FROM 215 STEPS 12 + 12 Rod Position ARO 1.696 1.423 D 8 215 STEPS 1.737 1.419 D 8 215, H-8 9231 1.732 1 ~ 428 D 9 215, H-8 9191 1.769 1.381 D 8 215, GP2 8231 1.713 1.427 D 9 215, GP2 9191 1.907 1.386 D 8 215, GP1 9231 1 720 1.416 D 8 215, GP1 9191 1.876 1.446 Delta F 9.8%

Delta F~, 1.9%

35

0 EI

TABLE 4.2-12 UNIT 2 CYCLE 9 EOL 100% RTP 30 STEPS FROM 215 STEPS 18 + 12 Rod Position ARO 1. 696 1.423 D 8 215 STEPS 1 '37 1.419 D 9 215, H-8 9231 1.732 1.428 D 8 215, H-8 9185 1 '77 1.382 D 9 215, GP2 9231 1.713 1.427 D 9 215, GP2 9185 1 '45 1.389 D 8 215, GP1 9231 1. 720 1.416 D 9 215, GP1 8185 1.911 1.452 Delta F 12 '%

Delta F~ 2 3%

36

TABLE 4.2-13 UNIT 2 CYCLE 9 EOL 100% RTP 30 STEPS FROM PDIL 18 + 12 Rod Position ARO 1.696 1.423 D 8 PDIL 189. 0 2.069 1.396 D 8 PDIL,D-12 9159.0 2.109 1.405 D 8 PDIL,K-14 8195.0 2.091 1.401 D 8 PDIL,H-12 9159.0 2.107 1.400 D 8 PDIL,K-8 9195.0 2.088 1.394 Delta F 1.9%

Delta F~, 0.7%

37

TABLE 4.3-1 UNIT 2 CYCLE 9 EOL 100% RTP 24 STEPS FROM PDIL 12 + 12 LOAD-FOLLOW MODE Rod Position

2. 108 1.409 D 8 PDIL 189 1. 685 1.400 D 8 PDIL, H-8 9213 1.743 1.442 D 8 PDIL, H-8 9165 1.649 1.406 D 8 PDIL, GP2 9213 1.904 1.434 D 9 PDIL, GP2 9165 1.637 1.408 D 9 PDIZ, GPl 9213 1.812 1.396 D 8 PDIL, GP1 9165 1. 673 1.404 Delta F 13.0%

Delta F~< 3.0%

38

TABLE 4.3-2 UNIT 2 CYCLE 9 EOL 100% RTP 30 STEPS FROM PDIL 18 + 12 LOAD-FOLLOW MODE Rod Posit'.on 2.108 1 409 D 8 PDIL 189 1.685 1.400 D 9 PDIL, H-8 9219 1.764 1.453 D 9 PDIL, H-8 8159 1.648 1.407 D 9 PDIL, GP2 9219 1.962 1.445 D 8 PDIL, GP2 9159 1.676 1.410 D 8 PDIL, GP1 8219 1.844 1.400 D 8 PDIL, GPl 8159 1.673 1.408 Delta F 16.4%

Delta Fz, 3.8%

39

TABLE 4.3-3 UNIT 2 CYCLE 9 EOL 100% RTP 30 STEPS FROM 215 STEPS 18 + 12 LOAD-FOLLOW MODE Rod Position ARO 2.108 1.409 D 8 215 STEPS 2.044 1 ~ 403 D 8 215, H-8 8185 1.984 1.391 D 8 215, H-8 9231 2.073 1.415 D 9 215, GP2 8185 1.819 1.402 D 8 215, GP2 8231 2.099 1.413 D 6 215, GP1 9185 1.936 1.447 D 8 215, GPl 9231 2.055 1.398 Delta F 2.7%

Delta F~< 3.1%

- 40

TABLE 4.4-1 UNIT 1 CYCLE 13 BOL 85% RTP 30 STEPS FROM PDIL 18+12 STEPS Rod Position ARO 1.556 1.381 D 8 PDIL (160.7) 1.781 1.426 D 8 PDIL, H-8 9190. 7 1.756 1.430 D 9 PDIL, H-8 8130.7 1.804 1.422 D 9 PDIL, GP2 8190.7 1.671 1.419 D 8 PDIL, GP2 9130.7 1.892 1.438 D 8 PDIL, GP1 8190.7 1. 697 1.415 D 8 PDIL, GP1 9130.7 1.868 1.442 D 8 PDIL, B10 9190o7 1.759 1.441 D 8 PDIL, B10 9130i7 1.802 1.440 Delta F 6.2%

Delta F~ 1.1%

Note: Control Bank D Locations:

Group 1 : F2, B10, K14, P6 Group 2: B6, F14, P10, K2, H8 41

ROD GROUP INSERTION LIMITS vs. POWER UNIT 2 STEPS (0.545,231) 200 (1.0,189) 4 BANK C 150

,128) 100 4 BANK D 50 (0 )

0 0'.2 0.4 0.6 0.8 FRACTlON OF RATED THERMAL POWER Figure 3.1-1 Figure 4.l-2 CONTROL AND SHOTDOMN ROD LOCATIONS '

P N N L K J H G F E 0 C B A 180' SA SC Sa D D SC SD 7

8 C D 9O~

D 270 9

SA D D D SA SEI SD SA B Oo BANK NUMBER OF ROD CLUSTERS SA SB S 8S 454 A

B C

0 I

FIGURE 4.1-1 COOK NUCLEAR PLAN 1 UNIT 2 CYCLE 9 CORE LOADINGPATIZRN R P N M L K J H G FI E D C 8 A I I I I I I 108 9 9 108 118 118 118 118 118 118 118 118 118 9 9

118 118 9

118 10A 118 10A 11A 10A 1.1A 108 108 10A 11A 108 11A 9

10A 108 .11A 108 11 A 108 108 10A 11A

'18 10A 108 118 11A'0A 11A 9

1,18 10A 118 9 108 118 108 10A 11A 10A 10A 10A 11A 10A 108 118 9 .

'08 118 108 '11A'0B 10A 108 118 10B 10A 108 11A 108 118 9 900 118 9 10A 11A 10A 118 10C 1.18 104 11A 10A 9 118 9 118 108 11A 10B 10A 108 118 108 10A 11A 108 118 9 318 108 30A 1-1A 10A 10A 10A 11A. 10A 108 118 108 10

'08 11/ 'IOA 11A 108 11A 108 1.1A 108 11A MB 11A 10A. 118 9 11 118 9

118 9

10A 118 118 11A 10A 118 1OA 108 118 11A 108 118 10A 9

118 11A 108 118 10A 108 118 1'IA 10A 118 10A 118 118 118 9

9 118 9 12 13 9 9 9 108 15 00 LEGEND R R : REGION IDENTIFIER

~

I I 44

ROD GROUP INSERTION LIMITS vs. POWER UNIT 3 STEPS (0.545,231) 200 (1.o,1sg)

~4 BA 150 (o,12s) 100 rr r %BAN K D 50 (o,o) 0 0 0.2 0.4 0.6 0.8 FRACTION OF RATED THERMAL POWER Figure 3.1-2

FIGURE 4.1-3 D. C. COOK UNIT 1 CYCLE 13 CORE LOADINGPATTERN R P N'l L K J H G F E D C 8 A 138 14A 148 14A 148 14A 138 138 15A 158 158 15A 158 15A 158 158 15 A 138 138 14A 158 148 148 14A 14A 14A 148 148 158 14A 138 15A 158 14A 15A 138 15A 148 15 A 138 15 A 14A 158 15A 138 158 148 15A 14A 15A 14A 148 14A 15A 14 A 15A 148 158 138 5 14A 158 148 138 15A 13A 15A 14A 15 A 13A 15A 138 148 158 14A . 6 148 15A 14 A 15A 14A 15A 13A 158 13A 15A 14A 15A 14A 15A 148 7 90o 14A 158 14A 148 148 14A 158 138 158 14A 148 148 14A 158 14A 8 148 15A 14A 15A 14A 15A 13A 158 13A 15A 14A 15A 14A 15A 148 9 14A 158 148 138 15A 13A 15A 14A 15A 13A 15A 138 148 158 14A 10 138 158 148 15A 14A 15A 14A 148 14A 15A 14 A 15A 148 158 138 15A 158 14A 15A 138 15A 148 15A 138 15A 14A 158 15A 12 138 14A 158 148 148 14A "14A 14A 148 148 158 14A 138 138 15A 158 158 15A 158 15A 158 158 15 A 138 14A 148 14A 148 14A 138 p0 LEGEND R : REGION IDENTIFIER "- 46-'

Fi.gure 4.1-4 Control Rod'attern for Oonald C. Cook 1 R P N M L K J H G F E 0, C B A 180 Absorber Material

'g SA SA SB 7

8 90 Sg sA 27O'2 10 SO SA 13

14. sc 15 Oo BANK SYMBOL NUMBER OF ROO CLUSTERS SA 8 ~

SB 8 SC S~ 4 A 8 4

C 8

9

7. "

APPENDICES Appendix A: Unit; 2, Cycle 9 ANC Model Appendix B: Technical Specification Pages

- 48

APPENDIX A UNIT 2 CYCLE 9 ANC MODEL Results of the Unit 2, Cycle 9 core design using Westinghouse code system PHOENIX-P/ANC and methodology are compared to measured data.

The results from the Zero Power Physics Testing are given in Tables A-l, A-2, and A-3. HFP critical boron obtained from ANC was compared to the measured critical boron and is shown in Figure A-l. It should be noted that the small deviation from the design data is due to the boron-10 depletion phenomena. The BOL and MOL radial assembly power distributions are given in Figure A-2 and A-3. Review of these data indicate that the ANC model is adequate for power distribution analyses.

- 49

TABLE A-1 HZP MODERATOR TEMPERATURE COEFFIC1ENT Temperature MTC -MTC 547 F 0.14 pcm/'F TABLE A-2 HZP ROD WORTH MEASUREMENT Bank % Error CBD 0.19 CBC -3.02 CBB -7.06 CBA -4.79 SBD -6.03 SBC -4.92 SBB -1.62 SBA. -10.14 TOTAL -3.86 TABLE A-3 HZP BORON ENDPOINT MEASUREMENT Bank C BMean CS Deolya ARO 6.9 ppm CBD In 8.7 ppm Unit 2 Cycle 9 Boron Letdown Curve 1300 1200 1100 1000 900

0

~ A 800 700 600 500 0

400 0 300 0 200 100 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Critical Boron Burnup (GWD/MTU)

Design Curve Measured Data

FIGURE A-2 D.C. COOK UNIT 2 CYCLE 9 BOC HFP POWER DISTRIBUTION H

0.813 0.806 0 '07

+

1.394 1.254 1.382 1.219 0.012 0.035

l. 111 1.219 1.014 10 1. 120 1.168 1.032

-0.009 0.051 -0.018

+ +

1.335 1.194 1.243 1. 148 1 322 1.198 '1.233 1. 159 0.013 -0.004 0.010 -0.011 D

+ + -+

1.125 1.305 1. 132 1.253 1.003 12 1.081 1.293 1.084 1.249 1.004 0.044 0.012 0.048 0.004 -0.001

+ + + --+

0.974 1. 133 1. 184 1.023 1.072 0.500 13 0.980 1. 139 1. 178 1.031 1.102 0.517

-0.006 -0.006 0.006 -0.008 -0.030 -0.017

+ + + -+ +

1.210 1. 189 l. 191 1. 147 0.920 0.256 14 1.207 1. 190 1.197 1.147 0.924 0. 267 0.003 -0.001 -0.006 0.000 -0.004 -0.011

+ + +

0. 412 0.411 0.488 0. 326 15 0. 426 0. 419 0.507 0.336

-0.014 -0.008 -0.019 -0.010

+

STANDARD DEVIATION = 0.020 POWER LEVEL 100 CYCLE BURNUP 489 MWD/MT 1.101 MAP 209-10 1.098 ANC 0.003 DIFFERENCE 1 52

FIGURE A-3 D.C. COOK UNIT 2 CYCLE 9 MOC 90%RTP POWER DISTRIBUTION H

0.771 0 776

-0.005 1.336 1.038 1.325 1.055 0.011 -0.017

+

0.968 1.022 0.946 10 0.973 1.018 0.947

-0.005 0.004 -0.001

+ +

1. 330 1.096 1.373 1.157 1.319 1.105 1.353 1.165 0.011 -0.009 0.020 -0.008 D

+ + + +

1 017 1.359 1. 069 1.362 1.027 12 1.031 1.339 1.079 1.372 1.035

-0.014 0. 020 -0.010 -0.010 -0.008

+ + + +

0.905 1 '76 1.122 1 '10 1.253 0.576 13 0.925 1.075 1.116 1.013 1.242 0.583

>>0.020 0.001 0.006 -0.003 0.011 -0.007

+ -+

1. 252 1. 267 1.270 1.167 0.928 0.292 14 1. 236 1. 260 1.266 1.177 0.926 0.303 0.016 0.007 0.004 -0.010 0.002 -0.011

+ + + +

0.449 0.454 0 '45 0.355 15 0. 464. 0.463 0.556 0.366

-0.015 -0.009 -0.011 -0.011

+ + +

STANDARD DEVIATION = 0.011 POWER LEVEL 90 4 CYCLE BURNUP 9247 MWD/MT 1. 101 MAP-209-28 1.098 ANC 0.003 DIFFERENCE

- 53

APPRNDIX B TECHNICMI SPECIFICATION PAGES 54

REACTIVITY CONTROL SYSTEMS 3 4 1 3 MOVABLE CONTROL ASSEMBLIES GROUP HEIGHT LIMITING CONDITION FOR OPERATION 3.1.3.1 All full length (shutdown and control) rods shall be OPERABLE with all individual indicated rod positions within the allowed rod misalignment of their group step counter demand position as follows:

o for THERMAL POWER less than or equal to 85X of RATED THERMAL POWER, the allowed rod misalignment is J18 steps, and o for THERMAL POWER greater than 85X of RATED THERMAL POWER, the allowed rod misalignment is J12 steps or as determined from Figure 3.1-4. Figure 3.1-4 permits for an allowed rod misalignment from

~13 steps (for APL equal to 101X) to +18 steps (for APL greater or equal to 106X) provided the value of R (defined in Figure 3.1-4) is greater than or equal to 1.04.

APPLICABILITY: MODES 1* and 2*

ACTION'.

With one or more full length rods inoperable due to being immovable as a result of excessive friction or mechanical interference or known to be untrippable, determine that the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. With more than one full length rod inoperable or misaligned from the group step counter demand position by more than the allowed rod misalignment, be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c. With one full length rod inoperable due to causes other than addressed by ACTION a, above, or misaligned from its group step counter demand position by more than the allowed rod misalignment, POWER OPERATION may continue provided that within one hour either:

1. The affected rod is restored to OPERABLE status within the above alignment requirements, or

2. The affected rod is declared inoperable and the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied. POWER OPERATION may then continue provided that:

a) A reevaluation of each accident analysis of Table 3.1-1 is performed within 5 days; this reevaluation shall confirm that the previously analyzed results of these accidents remain valid for the duration of operation under these conditions, and

See Special Test Exceptions 3.10.2 and 3.10.4 COOK NUCLEAR PLANT - UNIT 1 3/4 1-18 AMENDMENT NO. 45, Q8, 420

REACTIVITY CONTROL SYSTEMS LIMITING CONDITION FOR OPERATION Continued b) The SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is determined at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and c) A power distribution map is obtained from the movable incore detectors and F~(Z) and F~ are verified to be within their limits within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and d) Either the THERMAL POWER level is reduced to less than or equal to 75X of RATED THERMAL POWER within one hour and within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months the high neutron flux trip setpoint is reduced to less than or equal to 85X of RATED THERMAL POWER, or e) The remainder of the rods in the group with the inoperable rod are aligned to within the allowed rod misalignment of the inoperable rod within one hour while maintaining the rod sequence and insertion limits as specified in the COLR; the THERMAL POWER level shall be restricted pursuant to Specification 3.1.3.5 during subsequent operation.

SURVEILLANCE RE UIREMENTS 4.1.3.1.1 The position of each full length rod shall be determined to be within the group demand limit by verifying the individual rod positions at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months except during time intervals when the Rod Position Deviation Monitor is inoperable, then verify the group positions at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

4.1.3.1.2 Each full length rod not fully inserted in the core shall be determined to be OPERABLE by movement of at least 8 steps in any one direction at least once per 31 days.

4.1.3.1.3 The allowed rod misalignment for THERMAL POWER greater than 85X of RATED THERMAL POWER shall be determined in conjunction with the measurement of APL as defined in Specification 4.2.6.2.

COOK NUCLEAR PLANT - UNIT 1 3/4 1-19 AMENDMENT NO. 420, P

ALLOWED ROD MISALIGNMENT ABOVE 85% RTP FIGURE 3.1-4 STEPS 20 19 17 16 15 App l icable when R > 1.04 L'I%LIT o id'%TP W ere R =

FN 13 100 101 102 103 104 105 106 107 108 APL COOK NUCLEAR PLANT - UNIT 1 3/4 1-19b Amendment No.

REACTIVITY CONTROL SYSTEMS POSITION INDICATOR CHANNELS LIMITING CONDITION FOR OPERATION 3.1.3.2 All shutdown and control rod position indicator channels and the demand position indication system shall be OPERABLE and capable of determining the rod positions within the allowed rod misalignment specified in Specification 3.1.3.1.

APPLICABILITY: MODES 1 and 2.

ACTION'.

With a maximum of one rod position indicator channel per group inoperable either:

1. Determine the position of the non-indicating rod(s) indirectly by the movable incore detectors at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and immediately after any motion of the non-indicating rod which exceeds 24 steps in one direction since the last determination of the rod's position, or

2. Reduce THERMAL POWER to less than 50X of RATED THERMAL POWER within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

b. With a maximum of one demand position indicator per bank inoperable either:

1. Verify that all rod position indicators for the affected bank are OPERABLE and that the most withdrawn rod and the least withdrawn rod of the bank are within a maximum of the allowed rod misalignment of each other, at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , or

2. Reduce THERMAL POWER to less than 50X of RATED THERMAL POWER within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

SURVEILLANCE RE UIREMENTS 4.1.3.2 Each rod position indicator channel shall be determined to be OPERABLE by verifying the demand position indication system and the rod position indicator channels agree within the allowed rod misalignment at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months except during time intervals when the Rod Position Deviation Monitor is inoperable, then compare the demand position indication system and the rod position indicator channels at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

COOK NUCLEAR PLANT - UNIT 1 3/4 1-20 AMENDMENT NO. ~

POWER DISTRIBUTION LIMITS BASES 3 4.2 2 and 3 4 2 3 HEAT FLUX HOT CHANNEL FACTOR AND NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR The limits on heat flux hot channel factor, and nuclear enthalpy rise hot channel factors ensure that 1) the design limits on peak local power density and minimum DNBR are not exceeded and 2) in the event of a LOCA the peak fuel clad temperature will not exceed the 2200'F ECCS acceptance criteria limit.

Each of these is measurable, but will normally only be determined periodically, as specified in Specifications 4.2.2.1, 4.2.2.2, 4.2.3, 4.2.6.1 and 4.2.6.2. This periodic surveillance is sufficient to ensure that the hot channel factor limits are maintained provided:

a. Control rods in a single group 'move together with no individual rod insertion differing by more than + 18 steps from the group demand position (allowed rod misalignment: ) for power levels less than or equal to 85X of RATED THERMAL POWER. For power levels greater than 85X of RATED THERMAL POWER, the allowed rod misalignment is from J12 to ~18 steps, which is dependent on the Allowable Power Level and the ratio of F~ limit at 100X of RATED THERMAL POWER to maximum measured F~ as indicated in Figure 3.1-4.

b. Control rod groups are sequenced with overlapping groups as described in Specification 3.1.3.5.

c ~ The control rod insertion limits of Specifications 3.1.3.4 and 3.1.3.5 are maintained.

d. The axial power distribution, expressed in terms of AXIAL FLUX DIFFERENCE, is maintained within the limits.

The relaxation in F~ as a function of THERMAL POWER allows changes in the radial power shape for all permissible rod insertion limits. F~ will be maintained within its limits as specified in the COLR, provided conditions (a) through (d) above are maintained.

When an F< measurement is taken, both experimental error and manufacturing tolerance must be allowed for. 5X is the appropriate allowance for a full core map taken with the incore detector flux mapping system, and 3X is the appropriate allowance for manufacturing tolerance.

When F~~ is measured, experimental error must be allowed for, and 4X is the appropriate allowance for a full core map taken with the incore detection system. This 4X measurement uncertainty has been included in the design DNBR limit value. The specified limit for F~ also contains an additional 4X allowance for uncertainties. The total allowance is based on the following considerations:

COOK NUCLEAR PLANT - UNIT 1 B 3/4 2-4 AMENDMENT NO. M, IRAN,

REACTIVITY CONTROL SYSTEMS 3 4 1 3 MOVABLE CONTROL ASSEMBLIES GROUP HEIGHT LIMITING CONDITION FOR OPERATION 3.1.3.1 All full length (shutdown and control) rods shall be OPERABLE with all individual indicated rod positions within the allowed rod misalignment of their group step counter demand position as follows:

o for THERMAL POWER less than or equal to 85K of RATED THERMAL POWER, the allowed rod misalignment is +18 steps, and o for THERMAL POWER greater than 85X of RATED THERMAL POWER, the allowed rod misalignment is ~12 steps or as determined from Figure 3.1-4. Figure 3.1-4 permits for an allowed rod misalignment from J13 steps (for APL equal to 101X) to J18 steps (for APL greater or equal to 106X) provided the value of R (defined in Figure 3.1-4) is greater than or equal to 1 04.~

APPLICABILITY: MODES 1* and 2*

~CTION:

a. With one or more full length rods inoperable due to being immovable as a result of excessive friction or mechanical interference or known to be untrippable, determine that the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. With more than one full length rod inoperable or misaligned from the group step counter demand position by more than the allowed rod misalignment, be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c. With one full length rod inoperable due to causes other than addressed by ACTION a, above, or misaligned from its group step counter demand position by more than the allowed rod misalignment, POWER OPERATION may continue provided that within one hour either:

1. The affected rod is restored to OPERABLE status within the above alignment requirements, or

2. The affected rod is declared inoperable and the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied. POWER OPERATION may then continue provided that:

a) A reevaluation of each accident analysis of Table 3.1-1 is performed within 5 days; this reevaluation shall confirm that the previously analyzed results of these accidents remain valid for the duration of operation under these.

conditions, and

See Special Test, Exceptions 3.10.2 and 3.10.3 COOK NUCLEAR PLANT - UNIT 2 3/4 1-18 AMENDMENT NO. 40,

REACTIVITY CONTROL SYSTEMS LIMITING CONDITION FOR OPERATION Continued b) The SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is determined at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and c) A power distribution map is obtained from the movable incore detectors and F<(Z) and F~ are verified to be within their limits within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and d) Either the THERMAL POWER level is reduced to less than or equal to 75X of RATED THERMAL POWER within one hour and within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months the high neutron flux trip setpoint is reduced to less than or equal to 85X of RATED THERMAL POWER, or e) The remainder of the rods in the group with the inoperable rod are aligned to within the allowed rod misalignment of the inoperable rod within one hour while maintaining the rod sequence and insertion limits as specified in the COLR; the THERMAL POWER level shall be restricted pursuant to Specification 3.1.3.6 during subsequent operation.

SURVEILLANCE RE UIREMENTS 4.1.3.1.1 The position of each full length rod shall be determined to be within the group demand limit by verifying the individual rod positions at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months except during time intervals when the Rod Position Deviation Monitor is inoperable, then verify the group positions at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

4.1.3.1.2 Each full length rod not fully inserted in the core shall be determined to be OPERABLE by movement of at least 8 steps in any one direction at least once per 31 days.

4.1.3.1.3 The allowed rod misalignment for THERMAL POWER greater than 85X of RATED THERMAL POWER shall be determined in conjunction with the measurement of APL as defined in Specification 4.2.6.2.

COOK NUCLEAR PLANT - UNIT 2 3/4 1-19 AMENDMENT NO. 40,

ALLOWED ROD MISALIGNMENTABOVE 85% RTP FIGURE 3.1-4 STEPS 20 19 16 15 AVVlicable when R > 1.04 14 W ere R =

13 100 101 102 103 104 105 106 107 108 APL COOK NUCLEAR PLANT " UNIT 2 3/4 1-208 Amendment No.

REACTIVITY CONTROL SYSTEMS POSITION INDICATOR CHANNELS LIMITING CONDITION FOR OPERATION 3.1.3.2 All shutdown and control rod position indicator channels and the demand position indication system shall be OPERABLE and capable of determining the rod positions within the allowed rod misalignment specified in Specification 3.1.3.1.

APPLICABILITY: MODES 1 and 2.

ACTION'.

With a maximum of one rod position indicator channel per group inoperable either:

1. Determine the position of the non-indicating rod(s) indirectly by the movable incore detectors at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and immediately after any motion of the non-indicating rod which exceeds 24 steps in one direction since the last determination of the rod's position, or

2. Reduce THERMAL POWER to less than 50K of RATED THERMAL POWER within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

b. With a maximum of one demand position indicator per bank inoperable either: I

1. Verify that all rod position indicators for the affected bank are OPERABLE and that the most withdrawn rod and the least withdrawn rod of the bank are within a maximum of the allowed rod misalignment of each other, at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , or

2. Reduce THERMAL POWER to less than 50X of RATED THERMAL POWER within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

SURVEILLANCE RE UIREMENTS 4.1.3.2 Each rod position indicator channel shall be determined to be OPERABLE by verifying the demand position indication system and the rod position indicator channels agree within the allowed rod misalignment at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months except during time intervals when the Rod Position Deviation Monitor is inoperable, then compare the demand position indication system and the rod position indicator channels at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

COOK NUCLEAR PLANT -'UNIT 2 3/4 1-21 AMENDMENT NO. 40

POWER DISTRIBUTION LIMITS BASES 3 4 2 2 and 3 4 2.3 HEAT FLUX HOT CHANNEL FACTOR AND NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR The limits on heat flux hot channel factor, and nuclear enthalpy rise hot channel factor ensure that 1) the design limits on peak local power density and minimum DNBR are not exceeded and 2) in the event of a LOCA the peak fuel clad temperature will not exceed the 2200 F ECCS acceptance criteria limit.

Each of these is measurable but will normally only be determined periodically as specified in Specifications 4.2.2.1, 4.2.2.2, 4.2.3, 4.2.6.1 and 4.2.6.2. This periodic surveillance is sufficient to ensure that the limits are maintained provided:

a. Control rods in a single group move together with no individual rod insertion differing by more than ~18 steps from the group demand position (allowed rod misalignment) for power levels less than or equal to 85X of RATED THERMAL POWER. For power levels greater than 85X of RATED THERMAL POWER, the allowed rod misalignment is from J12 to ~18 steps, which is dependent on the Allowable Power Level and the ratio of F~ limit at 100X of RATED THERMAL POWER to maximum measuered F~ as indicated in Figure 3.1-4.

b. Control rod groups are sequenced with overlapping groups as described in Specification 3.1.3.6.

co The control rod insertion limits of Specifications 3.1.3.5 and 3.1.3.6 are maintained.

d. The axial power distribution, expressed in terms of AXIAL FLUX DIFFERENCE, is maintained within the limits.

F~ will be maintained within its limits as specified in the COLR provided conditions a. through d. above are maintained. The relaxation of F~ as a function of THERMAL POWER allows changes in the radial power shape for all permissible rod insertion limits. The form of this relaxation for DNBR limits is discussed in Section 2.1.1 of this basis.

When an F< measurement is taken, both experimental error and manufacturing tolerance must be allowed for. 5X is the appropriate allowance on F< for a full, core map taken with the incore detector flux mapping system and 3X if -the appropriate allowance for manufacturing tolerance.

COOK NUCLEAR PLANT, - UNIT 2 B 3/4 2-4 AMENDMENT NO. 8R,

8' REFERENCES

1. U.S. Nuclear Regulatory Commission Letter, A. Schwencer (NRC) to J. Dolan (AEP), October 19, 1979.

2. "Reduced Temperature and Pressure Operation for Donald C.

Cook Nuclear Plant, Unit 1 Licensing Report," WCAP-11902/

October 1988.

3. "Vantage5 Reload Transition Safety Report for Donald C. Cook Nuclear Plant Unit 2 ", Revision 2, September 1990.

4~ "Power Distribution Control and Load Following Procedures,"

WCAP-8385, September 1974.

5. "Exxon Nuclear Power Distribution Control for Pressurized Water Reactors Phase 2," XN-NF-77-57, January 1978.

6. "ANC A Westinghouse Advanced Nodal Computer Code", WCAP-10965-P-A, December 1985.

7. "Qualification of the PHOENIX-P / ANC Nuclear Design System for Pressurized Water Reactor Cores"g WCAP 11596@ December 1987.

8. "D. C. Cook Nuclear Plant Unit 2 Technical Specifications Appendix A to License No. DPR-74."

9. "D. C. Cook Nuclear Plant Unit 1 Technical Specifications Appendix A to License No. DPR-58."

10. "Donald C. Cook Nuclear, Plant Unit 2 Cycle 9, Reload Safety Evaluation",Revision 1, October 1993 66

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ATTACHMENT 1 TO AEP:NRC 0692CV Response to Request for Additional Information Regarding Generic Letter 92-08, "Thermo-Lag 330-1 Fire Barry.ers," pursuant to 10 CFR 50.54 (f) Donald C. Cook Nuclear Plant, Units 1 and 2

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sf Attachment 1 to AEP:NRC:0692CV Page 1 The numbered responses provided below correspond to the associated numbered reporting requirement in the generic letter.

Thermo-Lag Fire Barrier Configurations and Amounts B. Required Information

1. Describe the Thermo-Lag 330-1 barriers installed in the plant to a0 meet 10 CFR 50.48 or Appendix R to 10 CFR Part 50,

b. support an exemption from Appendix R, C~ achieve physical independence of electrical systems,

d. meet a condition of the plant operating license,

e. satisfy licensing commitments.

2 ~ For the total population of Thermo-Lag fire barriers described under Item I.B.1, submit an approximation of:

a0 For cable tray barriers: the total linear feet and square feet of 1-hour barriers and the total linear feet and square feet of 3-hour barriers.

b. For conduit barriers: the total linear feet of 1-hour barriers and the total linear feet of 3-hour barriers.

C~ For all other fire barriers: the total square feet of 1-hour barriers and the total square feet of 3-hour barriers.

'd ~ For all other barriers and radiant energy heat shields: the total linear or square feet of 1-hour barriers and the total linear or square feet of 3-hour barriers, as appropriate for the barrier configuration or type."

to AEP:NRCs0692CV Page 2

RESPONSE

Thermo-Lag fire barriers are installed in order to comply with 10 CFR 50 Appendix R, Section III.G.2.a and c. Several of these 1-hour fire barriers are installed to enclose intervening combustibles.

Thermo-Lag panels are also used in the construction of a radiant energy barrier between 10kVA isolimiter trains (non Appendix R equipment located outside containment). A small amount of Thermo-Lag material is used on the structural support of Appendix R instrumentation located inside containment.

Neither of these applications is intended as a rated fire barrier.

Thermo-Lag installations at Cook Nuclear Plant are typically installed using a combination of preformed panels, conduit preshapes, and trowel applications. Thermo-Lag materials are used to wrap conduit, cable tray, pull boxes, and junction boxes. Thermo-Lag panels are used in the construction of one free standing wall and to protect the hot shutdown panels in each control room.

Cook Nuclear Plant uses only 12-inch-wide cable trays which are six inches deep. In some locations, up to four trays are installed side by side and enclosed together within one boxed enclosure.

Conduits are wrapped with conduit preshapes in most cases. In some areas, several conduits are enclosed in a common boxed enclosure using preformed panels. Thermo-Lag panel joints and conduit preshape joints are prebuttered and covered with an additional layer of trowel grade material. Raceway interferences such as supports and non-Appendix R trays and conduits are wrapped 18 inches from the point of contact with the raceway.

Descriptions of each Thermo-Lag 330-1 barrier installed in Cook Nuclear Plant and its intended purpose are provided in Attachment 2.

to AEP:NRC:0692CV Page 3

2. The data provided below is an estimation of the total linear feet and square feet of Thermo-Lag fire barrier materials installed at Cook Nuclear Plant Units 1 and 2. The approximate square feet of cable tray and other fire barriers is based upon the outside barrier dimensions and includes only that portion of a fire barrier that could be exposed to a fire. For example, for a vertical cable tray mounted against a wall, the side of the tray adjacent to the wall is not included in the approximation of square feet for the associated fire barrier.

Cable tray barriers:

one hour barriers are 370 linear feet one hour barriers are 1850 square feet three hour barriers are 0 linear feet three hour barriers are 0 square feet

b. Conduit barriers:

one hour barriers are 930 linear feet three hour barriers are 100 linear feet C~ Other fire barriers:

one hour barriers are 120 square feet three hour barriers are 800 square feet d~ Other barriers and radiant energy shieldss (One non-Appendix R radiant energy shield located outside of containment) total square footage is 75

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to AEP:NRC:0692CV Page 4 "II. Important Barrier Parameters B. Re ired Information State whether or not you have obtained and verified each of the aforementioned parameters for each Thermo-Lag barrier installed in the plant. If not, discuss the parameters you have not obtained or verified. Retain detailed information on site for NRC audit where the aforementioned parameters are known.

2 ~ For any parameter that is not known or has not been verified, describe how you will evaluate the in-plant barrier for acceptability.

3 ~ To evaluate NUMARC's application guidance, an understanding of the types and extent of the unknown parameters is needed. Describe the type and extent of the unknown parameters at your plant in this context."

RESPONSE

The list of 24 parameters of importance for utilities'se provided in the request for additional information is an excerpt from a July 1993 NUMARC letter. Since that time, Phase I testing has been completed and other parameters of importance identified. NUMARC provided a list of 27 parameters of importance in a January 14, 1994, letter to utilities.

Planned NUMARC Phase 2 testing could identify further parameters of importance, or demonstrate that some of these preliminary parameters are not significant. When the final content of the NUMARC Application Guide is finalized and accepted by the NRC, we will determine if additional parameter identification efforts are necessary.

We have conducted walkdowns of each installation to obtain or confirm observablc/

physical data and developed as-built sketches where formal drawings did not exist. These sketches and drawings, together with installation procedures and specifications, address a majority of the 24 barrier parameters listed in part II.A. for each installation.

to AEP:NRC:0692CV Page 5 The following parameters have either not been obtained or have not been verified for some installationss Parameter I8 Air drops Some parameters internal to the fire barrier system have not been verified in all cases. For example, air drop designs are established by our design standards. However, it has not yet been verified that cable tray to conduit junctions were installed to these standards.

Parameter I9 Baseline fire barrier panel thickness Panel thickness has not been verified for every installation. A check of material in stock and a limited check of some installed panels found thickness to be 0.625 inches.

Parameter f18 Butt joints or scored and grooved joints The installation procedure allowed for the use of butt joints or scored joints for cable tray enclosures. However, discussions with the supervisor in charge of the Thermo-Lag installations revealed that virtually all boxed enclosures using Thermo-Lag panels were installed using prebuttered butt joints due to limited working spaces.

Walkdowns have confirmed this installation technique where the joint was visible.

2 ~ Parameters of importance that are not presently known or verified will be evaluated using one or more of the following options:

assume limiting conditions, e.g.,

pre-buttered butt joints versus score and fold joints,

b. reviews of contractor work practices and procedures through documentation or testimony,

I ly to AEPsNRC:0692CV Page 6 c~ review of receipt inspection and installation documentation,

d. destructive examination of barriers on a sample basis to obtain information on construction techniques or material thickness, or

e. visual observations where appropriate.

Your letter also provides an eight item listing of parameters of importance concerning cable protected by fire barriers. It is not clear that consideration of these parameters would be necessary for most barriers; therefore, significant efforts to obtain the listed parameters, or describe how barriers will be evaluated in absence of these parameters, may be un)ustified. To the extent that fire test results are satisfactory on the basis of temperature, as provided for in the draft test and acceptance criteria, we believe researching, at this time, for the NRC listing of cable performance parameters to be evaluated should be limited to the percentage cable fill in cable trays (subset of item 4 of the NRC 8 item listing), which relates to enclosed thermal mass and barrier performance.

Consideration of the remaining listed cable parameters (items 1, 2, 3, 5, 6, 7 and 8) will be deferred until the scope of cable functionality verification becomes clear.

We believe this interpretation of the reporting requirements of your letter is consistent with the guidance provided by the NRC via our telephone conversation with NRR Staff on January 12, 1994, on this topic.

If fire tests demonstrate temperature criteria exceedances, one optional approach to resolution, as provided in the NRC draft test and acceptance criteria, would be to evaluate cable functionality at the elevated temperatures. In this case, determination of cable performance at elevated temperature (item 8) would be necessary, using cable performance test data or information for specific installed cable types (items 1, 2, 3g and 7 of the NRC listing). However, NRC has yet to finalize requirements for cable

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I' to AEP:NRC:0692CV Page 7 functionality evaluation, nor are test results yet available that would clearly indicate the scope of such evaluations. The degree and conservatism of cable functionality evaluation requirements implied by the NRC listing of cable parameters, and discussed in proposed Supplement 1 to Generic 'etter 86-10, significantly exceed the original requirements of Generic Letter 86-10.

Ztems 4, 5, and 6 of the NRC listing address issues relative to potential cable/barrier contact for cable trays. This is an unresolved industry issue at this time, and barrier inspection in this regard would be difficult or impossible. Barrier contact would be most likely to occur in situations of large cable fills. However, the large cable fills also provide significant thermal mass that could improve barrier system performance and mitigate the effect of cables in contact with the barrier. NUMARC has agreed to provide additional thermocouples, below the cable tray rungs in the Phase 2 cable tray tests to provide information to address NRC concerns relative to potential contact of cables with the cold side of the fire barriers. Further, note that a small piece of Sealtemp cloth (NRC item 6) was used only in NUMARC test Number 1-4 (24" steel cable tray with air drop,,three hour test), and did not impact performance'r useability of the test.

Potential cable/barrier contact is not expected for Cook Nuclear Plant cable trays due to the type of tray used. These trays have a continuous expanded metal bottom which would prevent any cable sagging. No significant sagging of the 'top portion of the fire barrier is likely since trays are only twelve inches wide.

3. See response to 1 and 2 above.

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~ I Attachment 1 to AEP:NRC:0692CV Page 8 "III. Thermo-La Fire Barriers Outside the Sco e of the NUMARC Procrram B. Required Information Describe the, barriers discussed under Item I.B.1 that you have determined will not be bounded by the NUMARC test program.

2 ~ Describe the plant-specific corrective action program or plan you expect to use to evaluate the fire barrier configurations particular to the plant. This description should include a discussion of the evaluations and tests being considered to resolve the fire barrier issues identified in GL 92-08 and to demonstrate the adequacy of existing in-plant barriers.

3. If a plant-specific fire endurance test program is anticipated, describe the following:

a~ Anticipated test specimens.

b. Test methodology and acceptance criteria including cable functionality."

RESPONSE

Several Thermo-Lag configurations exist at Cook Nuclear Plant which are different from those currently included in the scope of the NUMARC test program. Some additional barriers may fall outside of the expanded NUMARC test program depending upon the configurations tested and the final content of the Application Guideline. Configurations currently believed to be outside the NUMARC program can be divided into cable raceway barriers and non cable raceway barriers. The following provides a description of each of these barriers.

Cable Racewa Barriers ae In some cases, two or more 12 inch wide cable trays were installed side by side at Cook Nuclear Plant rather than using a 24 inch or 36 inch wide tray, as used in the NUMARC testing configurations. In several cases, four 12 inch wide trays to AEP!NRC:0692CV Page 9 were installed in this manner and protected with a 48 inch wide boxed enclosure constructed of Thermo-Lag, panels.

b. Several irregularly shaped boxed

'enclosures were installed at Cook Nuclear Plant as fire barriers for cable tray junctions. For these configurations, a metal pan was fabricated in the field to accommodate the )unction of several cable trays.

These pans were fabricated in various sizes such as 5 feet by 2 feet and 3.5 feet by 3.5 feet. The Thermo-Lag enclosures protecting these pans were constructed using techniques similar to those used for cable trays with the exception that bolts were used to connect the bottom Thermo-Lag panels to the pans to provide support for the panels.

C ~ Thermo-Lag panels were used to construct three-hour fire barriers around several pilasters in the diesel generator rooms (Fire Zones 15 and 19). The pilasters are of concrete construction and are physically a part of the diesel generator room walls. Each pilaster contains several conduits which have been embedded below approximately two inches of concrete. Two layers of approximately one half inch thick Thermo-Lag panels were attached to the outside of each pilaster.

~ Non Cable Racewa Barriers d0 A wall constructed to separate (i.e.,

provide a fire barrier between) the component cooling water (CCW) pumps consists of two 1/2 inch thick Thermo-lag panels separated by a 1/4 inch thick expanded metal stiffener.

The wall is approximately 36 feet long and 78 inches high. The Thermo-Lag panels were overlapped to provide protection for the bolts attaching the panels to the metal studs.

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0 to AEP:NRC:0692CV Page 10

e. The hot shutdown (HSD) panels were originally i.nstalled to comply with the requirements of 10 CFR 50, Appendix A General Desi.gn Cri.terion 19, and are used to provide shutdown capability from outside the control room for design basis considerations other than Appendix R fires. The Unit 1 HSD panel is in the Unit 2 control room and the Unit 2 HSD panel is in the Unit 1 control room.

The HSD panels are steel enclosures approximately 12 feet 6 inches wide, 5 feet deep and 8 feet high. A 3-hour fire barrier was constructed around the HSD panels to ensure that fires external to the panels do not damage internal wiring and fires internal to the panel do not spread outside. The walls were constructed of concrete block and steel columns with a Thermo-Lag trowel grade coating on the steel members. The roof was constructed in a manner similar to the CCW pump room wall in that two approximately 1/2 i.nch thick Thermo-Lag panels, separated and stiffened by expanded metal, were mounted on steel beams anchored to the top of the block wall. Access to each panel is via a steel roll-up fire door across the front of the panel.

A supplemental response, which identifies cable raceway barriers outside the NUMARC program scope, will be provided to the NRC.

This response will take into consideration the results of NUMARC's expanded generic test program if undertaken.

NUMARC is also initiating actions to facilitate shared testing of installations that cannot be practically considered under the generic program scope but may be common to several facilities. Zt is expected that a matrix of shared tests could be developed and provided to the industry. NUMARC is scheduled to provide additional information to utilities in this regard by April 1, 1994. Therefore, a supplemental response will also be provided for non cable raceway barriers which will take into consideration the potential for future plant specific or shared testing.

to AEP:NRC:0692CV Page 11 The supplemental response to Item ZZI.B.1 will be provided to the NRC within 60 days following receipt of the NUMARC Application Guideline.

263. The plant-specific plan to be used for evaluation of the above configurations has not been established at this time. This plan will be largely dependent on whether or not the scope of the NUMARC test program will be expanded to cover some or all of the above configurations. NUMARC has stated that additional information will be provided to utilities in this regard by April 1, 1994, and the Application Guideline will be final by mid-April 1994. Our response to Items ZZI.B.2 and ZII.B.3 will be provided to the NRC within 60 days following receipt of the Application Guideline. This will allow time to assess the final generic program scope, and the potential for shared testing, both of which could reduce or eliminate the need for plant specific corrective actions, particularly fire testing.

"IV. Am acit Deratin B. Recpxired Information For the barriers described under Item I.B.1, describe those that you have determined will fall within the scope of the NUMARC program for ampacity derating, those that will not be bounded by the NUMARC program, and those for which ampacity derating does not apply.

2. For the barriers you have determined fall within the scope of the NUMARC program, describe what additional testing or evaluation you will need to perform to derive valid ampacity derating factors.

3. For the barrier configurations that you have determined will not be bounded by the NUMARC test program, describe your plan for evaluating whether or not the ampacity derating tests relied upon for the ampacity derating factors used for those electrical components protected by Thermo-Lag 330-1 (for protecting the safe-shutdown capability from fire or to achieve physical independence of to AEP:NRC:0692CV Page 12 electrical systems) are correct and applicable to the plant design. Describe all corrective actions needed and submit the schedule for completing such actions.

4. In the event that the NUMARC fire barrier

'ests indicate the need to upgrade existing in-plant barriers or to replace existing Thermo-Lag barriers with another fire barrier system, describe the alternative actions you will take (and the schedule for performing those actions) to confirm that the ampacity derating factors were derived by valid tests and are applicable to the modified plant design."

RESPONSE

In the early 1980's, we expanded our ampacity derating program to consider Thermo-Lag installations at Cook Nuclear Plant. This program was applied to all wrapped cable raceways containing power cables.

A computer model was developed based on American Institute of Electrical Engineers (AIEE) transaction paper 57-660, by Neher, McGrath, and Buller to calculate the temperature rise in the conductor, heat generation per foot'of raceway, and ampacity.

The model considers that all cables in the raceway were energized with the maximum steady state current.

A test program was developed to validate the computer model. A series of test runs simulating representative as-built tray and conduit, configurations were conducted at our Canton Test Lab. The results of the tests validated the analytical computer model. The testing was conducted under rigid laboratory controls, with test procedures, and with engineering supervision and review, however, it was not under the auspices of a 10 CFR 50 Appendix B quality assurance program.

to AEP:NRC:0692CV Page 13 The calculations using this computer model confirmed that the cable raceway design at Cook Nuclear Plant included suf ficient margin to accommodate the temperature rise resulting from wrapping raceways with Thermo-Lag. We do not believe that any additional testing or evaluation is necessary to derive valid ampacity derating factors for these cable raceways installed at Cook Nuclear Plant.

We will review the NUMARC program for ampacity derating when it is made available. In the event that fire barrier tests indicate the need to upgrade existing in-plant barriers or to replace existing Thermo-Lag barriers with another fire barrier system, we will make a determination as to whether to use NUMARC's ampacity derating program or our own program. We will inform the NRC of the ampacity program to be used for fire barrier upgrades or replacements within 90 days following receipt of the NUMARC Ampacity Test Report.

~ Ig Alternatives B. Required Information Describe the specific alternatives available to you for achieving compliance with NRC fire protection requirements in plant areas that contain Thermo-Lag fire barriers. Examples of possible alternatives to Thermo-Lag based upgrades include the following.

Upgrade existing in-plant barriers using other materials.

2 ~ Replace Thermo-Lag barriers with other fire barrier materials or systems.

3~ Reroute cables or relocate other protected components.

4, Qualify 3-hour barriers as 1-hour barriers and install detection and suppression systems to satisfy NRC fire protection equipment."

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to AEP:NRC:0692CV Page 14

RESPONSE

The selection of specific alternatives available for achieving compliance with NRC fire protection requirements in plant areas that contain Thermo-Lag fire barriers will depend on a number of factors.

Three currently undefined factors must be considered in determining whether upgrades using additional Thermo-Lag materials are practical, and what alternatives would be most appropriate in case Thermo-Lag upgrades cannot be developed.

Test and acceptance criteria have not been finalized and issued by NRC.

Proposed draft criteria contain new conservatism in fire test methods and acceptance criteria that could affect the scope and complexity of upgrades to installed barriers. The content of the final criteria, and the resulting impact on utility-specific action plans, is uncertain.

2. Complete Phase 2 tests results will not be known until the mid-March time frame.

Results of baseline (as installed) and upgraded test configurations from Phase 2 must be considered to determine appropriate utility action plans to address specific configurations.

Moreover, further generic testing may be undertaken following Phase 2, as noted previously.

3. The NUMARC Application Guideline, to be finalized by mid-April, will include a matrix of important performance parameters and bounding conditions.

Discussion with NRC will be necessary to reach agreement on the selection of comparison parameters and bounding conditions. The results of these NRC interactions will define the final content and would directly impact the generic applicability of a given test to an installed configuration.

to AEP:NRC:0692CV Page 15 Your letter provides only a partial listing of resolution alternatives. Three additional alternatives are provided below. Other resolution alternatives may be possible. Further,"it should be noted that implementation of alternative solutions may be considered even if upgrades have been successfully tested. Potential alternatives include the following.

1~ Re-evaluation of engineering analyses used for determination of Appendix R safe shutdown pathways, equipment, and actions, could provide a basis for reduction in the scope of protected circuits and their associated fire barriers.

2 ~ Exemption requests could be submitted based upon the use of fire modeling in con)unction with baseline (non-upgraded) test results to demonstrate adequate protection for the installed hazard. In conjunction with the above, probabilistic safety analysis (PSA) could be used as an exemption basis, by demonstrating insignificant core damage frequency impacts, assuming barrier inoperability.

3. Re-evaluation of licensing commitments that may exceed the requirements of pertinent regulations may be undertaken.

During our review of this issue, we noted that several conduits and cable trays which were wrapped with Thermo-Lag materials no longer require protection from fire. This conclusion was made possible by a combination of design changes and the removal of several components from the list of safe shutdown equipment. The need to retain existing fire barrier installations will continue to be evaluated as a part of our ongoing effort to revalidate our current safe shutdown analysis.

to AEP:NRC:0692CV Page 16 "VI. Schedules B. Required Information Submit an integrated schedule that addresses the overall corrective action schedule for the plant.

At a minimum, the schedule should address the following aspects for the plant:

implementation and completion of corrective actions and fire barrier upgrades for fire barrier configurations within the scope of the NUMARC program, 2 ~ implementation and completion of plant-specific analyses, testing, or alternative actions for fire barriers outside the scope of the NUMARC program."

RESPONSE

Because of the uncertainties noted in the above discussion of NRC Items III and V above, submittal of an integrated schedule that addresses the overall corrective action program for the plant is not possible at this time. While the scope of the NUMARC test program for Phase 1 and 2 is known, what will ultimately be "bounded" is a function of the outcome of the tests, and the final content of the Applications Guide. In addition, NUMARC is considering an expansion of the planned test program scope. Considerable information concerning the results of currently planned NUMARC tests, expansion of the NUMARC test program, and the content of the Applications Guide will become available in April.

This information will directly impact the overall corrective action schedule for Cook Nuclear Plant.

We will provide the required schedule information to the NRC within 60 days following receipt of the Application Guideline.

"VII. Sources and Correctness of Information Describe the sources of the information provided in response to this request for information (for example, from plant drawings, quality assurance documentation, walkdowns or inspections) and how the accuracy and validity of the information was verified."

to AEP:NRC:0692CV Page 17

RESPONSE

Numerous different sources were employed to provide the response to this request for information. A ma)ority of the information concerning fire barrier descriptions and parameters was contained in Thermo-Lag installation piocedures and specifications and verified through field walkdowns. Other sources of information that were consulted include quality assurance documentation contained in design change packages under which the Thermo-Lag fire barriers were installed, design drawings of specific fire barriers, and discussions with contractor personnel responsible for Thermo-Lag installation. Our ampacity testing was conducted under rigid laboratory controlsg with test procedures, and with engineering supervision and review; however, it was not under the auspices of a 10 CFR 50 Appendix B quality assurance program.

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ATTACHMENT 2 TO AEP:NRC:0692CV Response to Request for Additional Information Regarding Generic Letter 92-08, "Thermo-Lag 330-1 Fire Barriers," pursuant to 10 CFR 50.54 (f) - Donald C. Cook Nuclear Plant, Units 1 and 2 Descriptions of Thermo-Lag 330-1 Barriers Installed in Cook Nuclear Plant

AEP:NRC:0692CV Attachment Page l of 4

~

Barrier

~

No.~ Fire Rating Enclosed raceway Conduit{C)/Tray{T) Size {inches)

Barrier length (ft) 23 Area (sq.ft)

Description -c" Pi

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Purpose

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Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Barrier No. Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches) co -(

Barrier length (ft) /0 Area (sq.ft) A'8 Description AZMI c'c= Z) /7 5EZ Wd

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below

AEP:NRC:0692CV Attachment Page ? of f2

~3 Barrier

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No. ~ Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft)

Description PRC7-AB / W r w2O Purpose Physical independence of Appendix R safe shutdown systems

~ Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Barrier No. Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches)

B-/ t'z~z~ zQ 2

~Y Barrier length (ft) Area (sq.ft)

Description Ru

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Mo oj= aWCfg 7 C'c. BUD Zo Purpose Physical independence of Appendix R safe shutdown systems

~ Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

AEP:NRC:0692CV Attachment Page of 4

~

Barrier No. Fire RaCing /aR Enclosed raceway Conduit(C)/Tray(T) Size (inches) ox P -Z t~Zw ZM R" g Barrier length (ft) Area (sq. ft)

Description W/MBT D~r/ oP ~c'ff Sec'Q Cc, cKcM CCC SLY

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Purpose

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Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Barrier No. Fire Rating / R Enclosed raceway Conduit(C)/Tray(T) Size (inches)

Put.c Bo 7 -Z R P82 Bb & - SCZQ 4.z C.

Barrier length (ft) Area (sq.ft)

Description EnJcc co sczds Pz-Z P8-9 F O

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Purpose

~ Physical indep'endence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

AEP:NRC:0692CV Attachment 4 2 Page W of 38 Barrier No. Fire Rating / A'8 Enclosed raceway Conduit(C)/Tray(T) Size (inches)

Area (sq.ft)

Description PwC I=A821CA. I ED Sw~r IzM3D = Cc~

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Purpose Physical independence of Appendix R safe shutdown systems

~ Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Barrier No. Fire Rating f- lg+

Enclosed raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) p3 Area (sq.ft)

Description =FR- (cA ML=zo C' u'I gac

~

Purpose

~ Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates baaed upon field walkdowns

AEP:NRC:0692CV Page ~

Attachment 4 ~

of ~~

Barrier

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No.

~ Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches) 7 Z-/

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Barrier No. 28 Fire Rating Enclosed raceway Conduit (C) /Tray(T) Size (inches)

Barrier length /Z Area (sq. ft)

C'onrc (ft)'escription

~

Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below 4

Note: Dimensions provided are estimates based upon field walkdowns

AEP: NRC: 069 2CV Attachment 0 P-Page 4 of D8 Barrier No. Fire Rating I-//8 Enclosed raceway Conduit(C)/Tray(T) Size (inches)

MC<

Barrier length (ft) Area (sq.ft)

Description Cuu 7/ cW Purpose X'hysical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Barrier No. Fire Rating /-4 R Enclosed raceway Conduit(C)/Tray(T) Size (inches) 8 PS R. C.

Barrier length (ft) JD Area (sq.ft)

Description C nJ /7 BR~A A H~~

Purpose X Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates baaed upon field walkdowns

AEP:NRC:0692CV Page ~

Attachment 0 R of ~B Barrier

~

No.~ Fire Rating /-Wi8 Enclosed raceway Conduit{C)/Tray(T) Size (inches) 8-r v+ a-~

Barrier length {ft) Area (sq.ft)

Description ~4 M rO A/ i ~~WA j~w~

~

Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Barrier No. Pire Rating Enclosed raceway Conduit{C)/Tray{T) Size (inches) ae - c'9 IZ 7 rZ

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

~.

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AEP:NRC-0692CV Attachment Page P of 4

~2 Barrier No. Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches)

Geo z B-Z, Barrier length (ft) 7 Ccovn ) .Area (eg.ft) 8'> 3 )

Description ~ST. 9 4EZ /0 I

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Barrier No. Fire Rating (

Enclosed raceway Conduit(C)/Tray(T) Size (inches) 8'do~ Z-> C Barrier length (ft) Area (sq.ft) hf~

Description

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

AEP:NRC:0692CV Attach<gent Page "f of 4

~

Barrier

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No. ~ Fire Rating raceway Conduit(C)/Tray(T) Size (inches)

SA'nclosed socoG-z Eood 5-Z C SZ &ad I -2 C

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V~ Ie Purpose Y Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Barrier No. 5B Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches) 8 G- C Barrier length (ft) /'6 Area (sq.ft)

Description Cev e GZ) o C'cmic~~

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

J J

AEP:NRC:0692CV Attachment 4 Page ~O of ~8 Barrier

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No. ~ Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches)

O'- GP Azea (sq.ft)

Description ~i ~z uI<> +<>~ > +~ u<> +> > <44<<~

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below rrier No. Fire Rating Enclos raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft)

Description Purpose Physical independence of Appendix R safe tdown systems Enclosure of intervening combustibles for Ap dix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

AEP:NRC:0692CV f

Attachment Page ~( of ~ 2 Barrier

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No.~ d4 Fire Rating / &'R Enclosed raceway Conduit(C)/Tray(T) Size (inches)

/2 Barrier length (ft) Area (sg.ft) sO 4 Description rh'Z- d2 s A. ]2 // VER'r Ical 7eav >zggA vgs AJCVALLc=.D 4 i kz- c o4- PP i2 7 RA Y5 UC48 CLW5Q Pc=

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below rrier No. Fire Rating Enclo d raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sg.ft)

Description Purpose Physical independence of Appendix R saf hutdown systems Enclosure of intervening combustibles for endix R Discussed in Appendix R exemption request Other reason, described below Note:, Dimensions provided are estimates based upon field walkdowns

'l J

AEP:NRC-0692CV Attachment 4 ~

Page ~2 of AR Barrier No.

~ 7A' Fire Rating / 0R Enclosed raceway Conduit (C) /Tray(T) Size (inches)

Barrier length (ft) //. 3 Area (sq.ft) A'rf Description Causa'zv ~~HA

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Barrier No. Fire Rating / NN Enclosed raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft) WA Description

~

Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed'n Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

J I 9 I

AEP:NRC:0692CV Page ~

Attachment of 0 2.

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Barrier No. Fire Rating Enclosed raceway, Conduit(C)/Tray(T) Size (inches) 3 C7-r o Area (sq.ft)

'I Description col o 7aZ i,LS

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below rrier No. Fire Rating Enclo raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq. ft)

Description Purpose Physical independence of Appendix R safe hutdown systems Enclosure of intervening combustibles for A endix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

AEP:NRC:0692CV Page ~ of Attachment 4 ~

ZR Barrier~

No. ~ 8'A Fire Rating f'b8 Enclosed raceway Conduit(C)/Tray(T) Size (inches)

Barrier length {ft) rG Area {sq.ft)

Description 5 c'ca Ho sz- PAdez s

~

Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Barrier No. Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches)

'7 GH -/

) ~<5 Area (sq. ft)

Description ~~ i s E<3eDc If oA3 iZ I c 5 7etP. cu /7 cMS

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

AEP:NRC:0692CV Attachment Page / of 0

~+

Barrier

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No. ~ P~ Fire Rating D raceway Conduit(C)/Tray(T) Size (inches) 4R'nclosed Barrier length (ft) Area (sq.ft)

Description

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request, Other reason, described below Barrier No. Fire Rating Dff'N Enclosed raceway Conduit(C)/Tray(T) Size (inches) 8~o 2'-I Q~o( C' ooZ R-(.

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Description u n iv-s m Co c =VL, s P LISP n %coo v' MNm P A3 =zN

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

I I 1 I

AEP:NRC:0692CV Attachment page /& of ~

4 P-Barrier No. Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft)

Description AR MTc.ZO <ice + C,C SM Purpose Physical independence of Appendix R safe shutdown systems

~ Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request.

Other reason, described below rier No. Fire Rating Enclos raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft)

Description Purpose physical independence of Appendix R safe hutdown systems Enclosure of intervening combustibles for endix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

AEP:NRC:0692CV Attachment 4 P-Page ~l of Z~

Barrier No. '0 4 Fire Rating Enclosed raceway Conduit.(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft) P. g 844ll '(ZDAURL5)

Description EnJ Cz 05 CzASIS r 5 Hv"C'owe'RcWZ'LY

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below rrier No. Fire Rating Enclo raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft)

Description Purpose Physical independence of Appendix R safe utdown systems Enclosure of intervening combustibles for A endix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdovns

Attachment Page of f~

AEP:NRC:0692CV

~

No. //A Fire Rating / H'R BS'arrier Enclosed raceway Conduit(C)/Tray(T) Size (inches)

Ps o R-(

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Description dc H'cMIPpe a&uj7-8 Mrs// APE WHgPhM .

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)C Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request, Other reason, described below Barrier No. Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches) 7P-Barrier length (ft) P Area (sq.ft)

Description Coarct 2 7" MW A%Pc ZO ~r v g ~~$ /ggP~,

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

AEP:NRC:0692CV

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Attachment 2 Page Barrier No. // M Fire Rating / AC Enclosed raceway Conduit(C)/Tray(T) Size (inches)

&5 5 G-2 /

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Description Fc hlDCC /7 R/7 P'P' /'/ h b

Purpose X Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below rrier No. Fire Rating Enclo raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft)

Description Purpose Physical independence of Appendix R safe s tdown systems Enclosure of intervening combustibles for App dix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

AEP:NRC:0692CV Attachment.

Page 2> of ~

4 P-Barrier No. Fire Rating Enclosed raceway Conduit(C) /Tray(T) Size (inches)

QBZ- C VO Barrier length (ft) Area (sq. ft)

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Description /A WI ZoM r 4c o>ca=.2o &JC<o> ~I~a=

~Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles fox Appendix R Discussed in Appendix R exemption request Other reason, described below rier No. Fire Rating Enclos raceway Conduit(C)/Tray(T) Size (inches)

.Barrier length (ft) Area (sq.ft)

Description Purpose Physical independence of Appendix R safe utdown systems Enclosure of intervening combustibles for Ap ndix R Discussed in Appendix R exemption request Other reason, described below .

Note: Dimensions provided are estimates based upon field walkdowns

AEP:NRC:0692CV Attachment 0 2 Page ~Z of ~B Barrier

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No.~ ~ 3 4 Fire Rating 1 H 0 Enclosed raceway Conduit(C)/Tray(T) Size (inches)

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Description AS/

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43'urpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Ba ier No. Fire Rating Enclose aceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft)

Description Purpose Physical independence of Appendix R safe utdown systems Enclosure of intervening combustibles for A endix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

)

AEP:NRC:0692CV Attachment 4 2 Page 8 2 of ~~

Barrier No. I9 A Fire Rating I Enclosed raceway Conduit{C)/Tzay(T) Size {inches)

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Description Co4bg r7 Pdcs/A PE5 o'sc=D

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Barrier No. Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches) 8 7 PC R" 2.

Barrier length (ft) a O Area (sg.ft)

Description C'ou n i r 7z~w dw Pm Purpose X Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

AEP:NRC:0692CV Attachment 0 2 Page P9 of ~

Barrier

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No.

~ I IC Fire Rating / A'C.

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Description Co& Zou't r fMFE 5'SM

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussedin Appendix R exemption request Other reason, described below Barrier No. 1 g ~l8 Enclosed raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft)

Description

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field Malkdowns

1 I

AEP:NRC:0692CV

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Attachment 4 2 Page 2'f of Barrier

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No.~

4w Enclosed raceway Conduit(C)/Tray(T) Size (inches)

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Description sr t F44' Z

/ < 2 I <<a I e HO EACH oSuRE Purpose Phy'sical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendixxemption request-Other reason, described below Barrier No. I Fire Rating / HH Enclosed raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft)

Description

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon

~

field walkdowns

I I I J

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AEP:NRC:0692CV Attachment Page 85 of 4

~

2 Barrier

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No. ~ /5 A Fire Rating I-HR Enclosed raceway Conduit(C)/Tray(T) Size (inches)

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Description MD 7<8 Y5 cr44cYTM 7D A I A C'c MW N Io AKC'tnC S edit. st= Io A3 VCR adcc Re 5 V'A Purpose Y Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption recpxest Other reason, described below Barrier No.

Enclosed raceway ig~a Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft) /P Description COSa 8 5 73'~ P L~

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of. intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

4

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i AEP:NRC:0692CV Attachment 4 2 Page 2b of B~

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.~ ~kA Fire Rating l ~4 Enclosed raceway Conduit(C)/Tray(T) Size (inches) rt'2- P IZ Barrier length (ft) Area (sq.ft)

Description Ei ~r L= rn/

Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Barrier No. Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) A3 Description a HI zen~ c r <A;S crSc- a s'rD 0 C. L- Lr5 r~ C Purpose

~ Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

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AEP:NRC:0692CV Attachment Page ~2. of ~

0 2.

Barrier No. l 7 ~ Fire Rating l lk~

Enclosed raceway Conduit(C)/Tray(T) Size (inches) 280 'tR -Z Barrier length (ft) Area (sq. ft)

Description Conc u I I PREsHhl'BQ

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below rrier No. Fire Rating Enclo d raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft)

Description Purpose physical independence of Appendix R safe utdown systems Enclosure of intervening combustibles for A endix R Discussed in'Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

I ~

AEP:NRC:0692CV Attachment Page 28 of ~

4 2 Barrier

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No.~ /~ 4 Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches)

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Description Cow& Q I c /M P ew us~

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Barrier No. Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches) 7BRQ. B 9/EP 4-2 Barrier length (ft) A'4 Area (sq. ft)

Description 0 a. SeZv IoU P CoW /7 wh/C'CQ Sc o ~o cLO54 RR s

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

AEP:NRC:0692CV Attachment 0 Page 29 of ~P-Barrier

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No.~ Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches) uL Barrier length (ft) Afh Area (sq. ft)

Description Z4 <<~ En/Ccosud~ usr<5 ~sr Purpose X Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Barrier No. /8 ~ Fire Rating / //W Enclosed raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft)

Description 4+2- Cs 8- Pu&S Sr2)~ g SrbE mls& Q o~-APNEA 7AWY EPrl C 5 Co4 ke - LdAZL i BAN AA S

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

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AEP:NRC-0692CV Attachment 4 2 Page ~O of ~

Barrier~

No.

~ Fire Rating /

C'onduit(C)/Tray(T)

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below arrier No. Fire Rating Enclo d raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) ~o Area (sq.ft)

Description Purpose Physical independence of Appendix R sa shutdown systems Enclosure of intervening combustibles for endix R Discussed in Appendix R exemption request Other reason, described below Note: ~ Dimensions provided are estimates based upon field walkdowns

I

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AEP:NRC:0692CV Page ~ ~

Attachment of 0 2 Barrier

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No.~ Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches) 2Hz-C C3 Barrier length (ft)

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Barrier No. Fire Rating l l+(c Enclosed raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) 3 & Area (sq.ft) (0 Description fled z OX ~

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates baaed upon field walkdowns

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AEP:NRC-0692CV Attachment. 4 2.

Page S8 of ~

Barrier

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No.

~ 20 Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches) z

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Barrier length (ft) Area (sq.ft) 2.

Description

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note:~ Dimensions provided are estimates based upon field walkdowns

1 r zl,

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AEP: NRC: 0692CV f2 Attachment Page 33 of ~

Barrier

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No. ~ 2.0 C. Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches)

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Description / A'ZC OU*Y ~

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendi.x R exemption request Other reason, described below Barrier No. Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft) l2.0 Description S~@J ~

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~Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed "in Appendix R exemption recpxest Other reason, described below Dimensions provided are estimates based upon I'ote:

field walkdowns

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AEP: NRC: 0692CV .

Page B~ of ~

Attachment 4 2, Barrier

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No.

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Description P M SOPPO P TE.D oaE+ ou LL, f P -C e

'BoA= b EA3CLo 7 SZ PA L=.LS.

Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below rrier No. Fire Rating Encl d raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft)

Description Purpose Physical independence of Appendix R fe shutdown systems Enclosure of intervening combustibles 2 r Appendix R Discussed in Appendix R exemption reques Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

5 4~

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AEP: NRC - 0692CV Attachment 4 2.

Page BS of ~.

Barrier

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No.~ 2.o Q Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches)

- C.5 2 -I Barrier length (ft) 'rea (sq.ft) 0 Description a d:MQ.

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Barrier No. mod Fire Rating Enclosed raceway Conduit(C) /Tray(T) Size (inches)

Barrier length (ft) 2 Area (sq.ft)

Description M ue 'TP O. u R;L ok)

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

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AEP: NRC: 0692CV Attachment 4 2 Page ~0 of &~

Barrier

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No.

~ 2.1 Fire" Rating HP Enclosed raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft)

Description S'~C. iO2JS.

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Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Barrier No. Fire Rating (8R, Enclosed raceway Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft)

Description 2.

S'7~9~

~

Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates based upon field walkdowns

AEP: NRC - 0692CV Attachment Page ~B f 2 of 98 Barrier No. W2. Cl Fire Rating Enclosed raceway Conduit(C)/Tray(T) Size (inches)

N'A'rea /Z Barrier length (ft)

Description Z/vC AX'-c uk'u

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(sq.ft)

A LL

/AX'- p/ Eggy

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purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below

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Barrier No. 2.2. B Fire Rating Enclosed raceway Conduit(C)/Tray{T) Size {inches)

S-C ~2./Z Barrier length (ft) A'A Area (sq.ft) /

Description h)D A~ WC/A Z /'A cW d HWgW MO ON 4 AZZ cÃCZ Su

~

Purpose Physical independence of Appendix R safe shutdown systems Enclosure of intervening combustibles for Appendix R Discussed in Appendix R exemption request Other reason, described below Note: Dimensions provided are estimates baaed upon field walkdowns

~ A I

AEP:NRC: 0692CV 98'f ~

Attachment 4 2-Page Bazzier No. Fire Rating AA Enclosed raceway Conduit(C)/Tray(T) Size (inches)

X 2. ~A Barrier length (ft) Area (sq. ft) 35'75'Ã6'</7 Description HA'~4~ ~Ra~R w+7Ara+W ZS r~ S /nf QA v SAr&d&4&</5'.

Purpose

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E'f'C Physical independence of Appendix R safe shutdown systems Enclosuze of intervening combustibles foz Appendix R Discussed in Appendix R exemption request, Other reason, described below C

~$ 'oX Za/&c7-ro nr Barrier N Fire Rating Enclosed zacew Conduit(C)/Tray(T) Size (inches)

Barrier length (ft) Area (sq.ft)

Description Purpose Physical independence of Appendix R safe shu own'x systems Enclosuze of intervening combustibles for Appen R Discussed in Appendix R exemption request Other reason, described below Note:

E Dimensions provided are estimates based upon

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field walkdowns

ML17331B196

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